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510(k) Data Aggregation

    K Number
    K233593
    Date Cleared
    2024-02-06

    (90 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The MAGEC Spinal Bracing and Distraction System is indicated for skeletally immature patients with severe progressive spinal deformities (e.g., Cobb angle of 30 degrees or more; thoracic spine height less than 22 cm) secondary to early-onset scoliosis associated with or at risk of Thoracic Insufficiency Syndrome(TIS). TIS is defined as the inability of the thorax to support normal respiration or lung growth.

    Device Description

    The subject MAGEC Spinal Bracing and Distraction System has an identical design and principle of operation to the predicate design iterations cleared in the predicate Magec System (K201543, K161751, K140613). The subject system includes sterile single use MAGEC rods manufactured from Ti-6Al-4V, conforming to ASTM F136, along with various accessories including a sterile Rod Template and Manual Distractor, a non-sterile Wand Magnet Locator, and is compatible with a hand held External Remote Controller (ERC) 1 or 2. The MAGEC rod can be surgically implanted using appropriate NuVasive Reline 4.5-5.0 (Reline Small Stature or RSS) or Armada fixation components (i.e., pedicle screws, hooks and/or connectors). The titanium MAGEC rod includes an actuator portion that holds a small internal magnet. The magnet in the actuator can be turned non- invasively by use of the ERC, which is electrically powered. The hand-held non-invasive ERC is placed over the patient's spine and then manually activated, which causes the implanted magnet to rotate and either distract or retract the rod. Periodic distraction of the rod is performed to lengthen the spine and to provide adequate bracing during growth to minimize the progression of scoliosis. Once the physician determines that the implant has achieved its intended use and is no longer required, the implant is explanted.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the MAGEC Spinal Bracing and Distraction System, focusing on expanding its indications for use. It primarily demonstrates substantial equivalence to predicate devices rather than proving performance against specific acceptance criteria in the typical sense of a diagnostic or AI device.

    However, based on the information provided, we can infer "acceptance criteria" from the measured clinical outcomes that are presented to support the expanded indication. The device's performance is demonstrated through a retrospective registry study comparing clinical and radiographic data.

    Here's a breakdown of the requested information:

    1. A table of acceptance criteria and the reported device performance

    The document doesn't explicitly state "acceptance criteria" with numerical thresholds as one might find for a new, novel device. Instead, the study aims to show that the performance of the MAGEC System in older skeletally immature patients (subject group) is comparable to its established performance in younger patients (predicate group). Therefore, the "acceptance criteria" are implicitly that the clinical outcomes in the subject group should not be worse than those in the predicate group, supporting substantial equivalence.

    Acceptance Criteria (Inferred from comparison)Reported Device Performance (Subject Group 2: Age ≥10 years)Reported Device Performance (Predicate Group 1: Age <10 years)
    Major curve Cobb angle, Δ, mean (not worse)25.0%26.5%
    Thoracic height (T1-T12), Δ, mean (not worse)15.5%15.1%
    Spinal height (T1-S1), Δ mean (not worse)15.3%15.3%
    Device-related adverse events (not worse)8.1%35.3%

    2. Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)

    • Sample Size (Test Set):
      • Group 1 (Predicate: Age <10 years): N=1,080 patients
      • Group 2 (Subject: Age ≥10 years): N=172 patients
      • Group B (Subject/Literature: Age ≥10 years): N=57 patients
    • Data Provenance: Retrospective registry study. The country of origin is not specified in the provided text.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    The document does not mention the use of experts to establish ground truth for the test set in the context of image interpretation or diagnostic accuracy. This is a spinal bracing and distraction system, and the "ground truth" for its effectiveness is based on clinical and radiographic measurements taken during the treatment process within the registry.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

    Not applicable. The study is a retrospective registry study tracking clinical and radiographic outcomes, not an adjudication process for diagnostic accuracy.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This is a medical device for spinal treatment, not an AI-assisted diagnostic device that would involve human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is a physical medical device (spinal bracing and distraction system), not an algorithm or AI system.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The "ground truth" for the device's effectiveness is based on clinical and radiographic outcomes data (e.g., changes in Cobb angle, thoracic height, spinal height, and incidence of device-related adverse events) collected from patients treated with the MAGEC System.

    8. The sample size for the training set

    Not applicable. This is a study of a physical medical device, not a machine learning model, so there is no training set in the AI sense.

    9. How the ground truth for the training set was established

    Not applicable, as there is no training set for an AI model. For the clinical study, the "ground truth" (i.e., the collected patient data and outcomes) was established through existing medical records and measurements from the retrospective registry study.

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    K Number
    K141278
    Date Cleared
    2015-03-24

    (312 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Ellipse MAGEC® Spinal Bracing and Distraction System is intended for skeletally immature patients less than 10 years of age with severe progressive spinal deformities (e.g., Cobb angle of 30 degrees or more; thoracic spine height less than 22 cm) associated with or at risk of Thoracic Insufficiency Syndrome (TIS). TIS is defined as the inability of the thorax to support normal respiration or lung growth.

    Device Description

    The Ellipse Technologies, Inc. MAGEC Spinal Bracing and Distraction System is comprised of a sterile single use spinal rod that can be surgically implanted using appropriate Stryker® Xia® fixation components (i.e. Pedicle screws, hooks and/or connectors). The system includes a non-sterile hand held External Remote Controller (ERC) that is used at various times after implant to non-invasively lengthen or shorten the implanted spinal rod. The implanted spinal rod is used to brace the spine during growth to minimize the progression of scoliosis. The titanium rod includes an actuator portion that holds a small internal magnet in the actuator can be turned non-invasively by use of the ERC. Rotation of the magnet causes the MAGEC rod to be lengthened or shortened.

    The hand held non-invasive ERC is electrically powered. The ERC is placed over the patient's spine and then manually activated, which causes the implanted magnet to rotate and either lengthen or shorten the rod. Periodic lengthening of the rod is performed to distract the spine and to provide adequate bracing during growth to minimize the progression of scoliosis. Once the physician determines that the implant has achieved its intended use and is no longer required, the implant is explanted. Additional accessories for the MAGEC System include the MAGEC Manual Distractor and the MAGEC Wand Magnet Locator. The MAGEC Manual Distractor is a sterilizable, single use device, which is used in the operating room to test the device prior to implantation. The MAGEC Wand Magnet Locator is a non-sterile device which is used during the distraction procedure to locate the magnet within the MAGEC rod. The ERC is placed over this location on the child's back during a distraction procedure.

    AI/ML Overview

    The provided document is a 510(k) summary for the Ellipse MAGEC® Spinal Bracing and Distraction System, focusing on the inclusion of a second-generation External Remote Controller (ERC 2). The submission aims to demonstrate substantial equivalence to a previously cleared MAGEC System (K140178).

    Here's an analysis of the acceptance criteria and the study proving the device meets them, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not explicitly state numerical acceptance criteria (e.g., specific thresholds for accuracy, sensitivity, or precision). Instead, it relies on demonstrating that the ERC 2 performs equivalently to its predicate device through design functionality, safety, and compatibility testing. The "reported device performance" is essentially the successful completion of these tests, showing the ERC 2 meets the standards set for medical devices of its type and performs as intended.

    Test/Document DescriptionApplicable Test Standard / Performance Demonstrated
    Risk Management ReportEN ISO 14971: Non-clinical performance data indicates "no new risks identified with the ERC 2."
    Electrical SafetyIEC 60601-1 (3rd edition): Testing performed to demonstrate electrical safety. The results of testing demonstrate that the ERC 2 meets the intended use and performance specifications.
    Electromagnetic Compatibility and InterferenceIEC 60601-1-2: Testing performed to demonstrate electromagnetic compatibility. The results of testing demonstrate that the ERC 2 meets the intended use and performance specifications.
    Design Verification TestingN/A (in-house developed test methodologies): Testing performed to demonstrate "suitability of the device for its intended use" and that it "meets the intended use and performance specifications." The ERC 2 was designed to improve ergonomic handling and user interfaces while maintaining the same methods and principles of operation as the first generation ERC.
    Software ValidationFDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices: Validation performed to ensure software functionality and safety. The results of testing demonstrate that the ERC 2 meets the intended use and performance specifications.

    2. Sample Size Used for the Test Set and Data Provenance:

    The document mentions "in vitro evaluations" and "non-clinical testing" for the ERC 2. It does not specify a "test set" in the context of patient data or clinical trials with a defined sample size. The testing described is primarily engineering and performance verification of the device components.

    For the clinical performance data, the document states: "The retrospective clinical study performed on the MAGEC System and previously submitted is also applicable to the ERC 2 and this submission."

    • Sample Size: Not specified in the provided text.
    • Data Provenance: Retrospective, as explicitly stated. The country of origin is not mentioned.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications:

    This information is not applicable and not provided. The non-clinical testing for the ERC 2 focuses on engineering specifications and safety standards, not on diagnostic accuracy requiring expert interpretation of results. The previous retrospective clinical study supporting the MAGEC system (not the ERC 2 specifically) would have involved clinical assessments, but details on ground truth establishment and expert involvement are not in this document.

    4. Adjudication Method for the Test Set:

    Not applicable and not provided, as the testing described for the ERC 2 doesn't pertain to diagnostic accuracy where adjudication of expert opinions would be relevant.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:

    No, an MRMC comparative effectiveness study is not mentioned in the context of this 510(k) submission. This submission focuses on the safety and performance of a device component (ERC 2) and its substantial equivalence to a predicate, not on the comparative effectiveness of human readers with or without AI assistance.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    This is not applicable to the device described. The MAGEC system is a physical implant and an external controller (ERC 2), not a standalone algorithm. The ERC 2 is a human-operated device used to interact with the implanted rod.

    7. The Type of Ground Truth Used:

    For the non-clinical testing of the ERC 2 (electrical, EMC, design verification, software validation), the "ground truth" is defined by the relevant engineering standards (EN ISO 14971, IEC 60601-1, IEC 60601-1-2) and FDA guidance for software. The device's performance against these established benchmarks serves as the "truth." For the retrospective clinical study mentioned, the type of ground truth used is not specified in this document, but would typically involve clinical outcomes or expert diagnoses.

    8. The Sample Size for the Training Set:

    This information is not applicable and not provided. The ERC 2 is a hardware device with embedded software, not a machine learning model that requires a "training set" in the conventional sense of AI development.

    9. How the Ground Truth for the Training Set was Established:

    Not applicable, as there is no "training set" in the context of an AI/ML model for this device.

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    K Number
    K140613
    Date Cleared
    2014-09-18

    (192 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Ellipse MAGEC Spinal Bracing and Distraction System is intended for skeletally immature patients less than 10 years of age with severe progressive spinal deformities (e.g., Cobb angle of 30 degrees or more; thoracic spine height less than 22 cm) associated with or at risk of Thoracic Insufficiency Syndrome (TIS). TIS is defined as the inability of the thorax to support normal respiration or lung growth.

    Device Description

    The MAGEC Spinal Bracing and Distraction System is comprised of a sterile single use spinal rod that can be surgically implanted using appropriate Stryker® Xia9 fixation components (i.e. Pedicle screws, hooks and/or connectors). The system includes a non-sterile hand held External Remote Controller (ERC) that is used at various times after implant to non-invasively lengthen or shorten the implanted spinal rod. The implanted spinal rod is used to brace the spine during growth to minimize the progression of scoliosis. The titanium rod includes an actuator portion that holds a small internal magnet. The magnet in the actuator can be turned non-invasively by use of the ERC. Rotation of the magnet causes the MAGEC Rod to be lengthened or shorten.

    The hand held non-invasive ERC is electrically powered. The ERC is placed over the patient's spine and then manually activated, which causes the implanted magnet to rotate and either lengthen or shorten the rod. Periodic lengthening of the rod is performed to distract the spine and to provide adequate bracing during growth to minimize the progression of scoliosis. Once the physician determines that the implant has achieved its intended use and is no longer required, the implant is explanted. Additional accessories for the MAGEC System include the MAGEC Manual Distractor and the MAGEC Wand Magnet Locator. The MAGEC Manual Distractor is a sterilizable, single use device, which is used in the operating room to test the device prior to implantation. The MAGEC Wand Magnet Locator is a non-sterile device which is used during the distraction procedure to locate the magnet within the MAGEC Rod. The ERC is placed over this location on the child's back.

    AI/ML Overview

    The provided documentation does not contain detailed acceptance criteria or a comprehensive study that proves a device meets specific acceptance criteria in the typical format of a clinical or performance study for a diagnostic or AI-powered device.

    Instead, the document is a 510(k) summary for the MAGEC® Spinal Bracing and Distraction System, which is a medical device for treating severe spinal deformities in skeletally immature patients. The purpose of this 510(k) submission is to demonstrate substantial equivalence to a previously cleared predicate device, not to establish performance against new, specific acceptance criteria for a novel device.

    The "acceptance criteria" presented here are inferred from the need to show substantial equivalence, primarily through mechanical testing and a comparison of clinical outcomes to those expected from growing rods.

    Here's an attempt to extract the requested information based on the provided text, recognizing that it may not perfectly fit the structure of a typical AI/diagnostic device performance study:


    Acceptance Criteria and Device Performance Study for MAGEC® Spinal Bracing and Distraction System (K140613)

    The device, the MAGEC® Spinal Bracing and Distraction System, is demonstrated to be substantially equivalent to a predicate device (MAGEC Spinal Bracing and Distraction System, K140178) by showing similar indications for use, principles of operation, technological characteristics, and comparable performance through non-clinical testing and a retrospective clinical study of the predicate device.

    1. A table of acceptance criteria and the reported device performance

    Since this is a substantial equivalence submission, the "acceptance criteria" are implied by the performance of the predicate device and the new device's ability to meet those standards.

    Acceptance Criteria (Implied by Substantial Equivalence to K140178)Reported Device Performance (MAGEC® Spinal Bracing and Distraction System, K140613) and/or Predicate (K140178)
    Mechanical Performance:
    - Withstand static loads (Modified ASTM F1717)- Demonstrated sufficient performance in Static Mechanical Testing (Modified ASTM F1717).
    - Withstand dynamic loads (Modified ASTM F1717)- Demonstrated sufficient performance in Dynamic Mechanical Testing (Modified ASTM F1717).
    - Design Verification and Validation- Successful design verification and validation.
    Functional Safety:
    - Biocompatibility (ISO 10993-1)- Demonstrated biocompatibility (tests performed on predicate, applicable to K140613).
    - Sterility (Gamma radiation sterilization, SAL 10^-1, ISO 11137-2 VDmax 35)- Sterilization process validated for predicate (applicable to K140613).
    - Shelf life- Shelf life testing performed on predicate (applicable to K140613).
    In Vivo Performance (Safety & Efficacy):
    - Safe operation in vivo- In vivo porcine study on predicate showed safety; no complications from distraction occurred.
    - Ability to perform per functional specifications (e.g., non-invasive distraction of spine)- In vivo porcine study on predicate showed efficient non-invasive distraction.
    Clinical Outcomes (Probable Benefit - based on retrospective study of predicate in humans):
    - Cobb angle correction in coronal plane- Clinical study on predicate showed spinal deformity correction and maintenance, similar to traditional growing rods.
    - Thoracic spine height increase- Clinical study on predicate showed continued growth and thoracic spine height increase.
    - Improvement in Space Available for Lung (SAL)- Clinical study on predicate showed improved thoracic cavity symmetry (SAL).
    - Reduction in number of subsequent surgical procedures (implied by non-invasive adjustment)- Non-invasive adjustment capability of MAGEC System (both predicate and K140613) reduces need for regular surgical lengthening.
    - Coronal and sagittal balance improvement (not explicitly stated as outcome, but generally expected for spinal deformity correction)- Not explicitly detailed as an outcome in the summary, but implied by overall spinal correction.
    - Weight gain (as an indicator of overall health/growth in children with TIS)- Considered as an endpoint in the clinical study of the predicate.

    2. Sample size used for the test set and the data provenance

    • Test Set (Clinical Data for Predicate): The document mentions a "retrospective clinical study for children" that evaluated the predicate MAGEC System. The exact sample size (N) is not specified in the provided text.
    • Data Provenance: The retrospective clinical study was conducted outside the United States.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. This was a clinical outcomes study, not a study requiring expert consensus for ground truth on an AI or diagnostic device. The outcomes (e.g., Cobb angle, TBH) are typically measured objectively based on medical imaging and patient records.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable. This was a clinical outcomes study, not a study requiring adjudication of expert interpretations.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This is not an AI-assisted diagnostic device, but a physical medical implant.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable. This is not an AI or algorithm-based device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    For the human clinical performance portion (retrospective study of the predicate): Outcomes data (e.g., Cobb angle correction, thoracic spine height increase, SAL improvement, reduction in subsequent surgeries, weight gain) based on clinical measurements and patient records.

    For the non-clinical testing: Physical measurements and engineering standards (e.g., ASTM F1717 for mechanical tests, ISO standards for biocompatibility and sterilization).

    8. The sample size for the training set

    Not applicable. This is not an AI or machine learning device that requires a training set.

    9. How the ground truth for the training set was established

    Not applicable. This is not an AI or machine learning device.

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