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510(k) Data Aggregation

    K Number
    K133053
    Date Cleared
    2014-07-15

    (291 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    MILESTONE SPINAL SYSTEM

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Milestone™ Spinal System is indicated for interbody fusion with autogenous bone graft in patients with degenerative disc disease (DDD) at one or two levels from L2 to S1. These DDD patients may also have up to Grade I Spondylolisthesis or retrolisthesis at the involved level. These patients should be skeletally mature and have had six months of non-operative treatment. These implants may be implanted via an open or a minimally invasive posterior approach. Alternatively, these implants may also be implanted via transforaminal approach. These implants are to be used with autogenous bone graft.

    DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies.

    These devices are intended to be used with supplemental fixation instrumentation, which has been cleared by the FDA for use in the lumbar spine.

    Device Description

    The Milestone Spinal System consists of INVIBIO PEEK-OPTIMA LT1 lumbar cages of various lengths and heights, which can be inserted between two lumbosacral vertebral bodies to give support and correction during lumbar interbody fusion surgeries. They are designed with angular teeth to allow the implant to grip the superior and inferior end plates. The hollow geometry of the implants allows them to be packed with autogenous bone graft in lumbar interbody fusion procedures. The cages contain radiographic tantalum markers used for both intra and post-operative positioning and visualization. The cages are provided sterile. The Milestone Spinal System also includes various device specific instruments which are provided non-sterile.

    AI/ML Overview

    Here's an analysis of the provided 510(k) summary, specifically addressing the acceptance criteria and the study proving the device meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    CategoryAcceptance Criteria (Standard / Test)Reported Device Performance
    SterilizationISO 11137-2:2012, Sterilization of healthcare products-Radiation-Part 2: Establishing the sterilization doseComplies with ISO 11137-2:2012
    Endotoxin LimitUSP Bacterial Endotoxin LimitComplies with USP
    Seal StrengthASTM F88/F88M-09, Standard Test Method for Seal Strength of Flexible Barrier MaterialsComplies with ASTM F88/F88M-09
    Intervertebral Body Fusion Device PerformanceASTM F 2077-03 Test Methods For Intervertebral Body Fusion DevicesComplies with ASTM F 2077-03
    Material (Cage)INVIBIO PEEK-OPTIMA LTI (Implied acceptance by using this material, aligning with predicate PEEK)INVIBIO PEEK-OPTIMA LTI
    Material (Instrument)630 Stainless Steel (Implied acceptance by using this material, aligning with predicate)630 Stainless Steel
    Radiographic Marker MaterialTantalum (Implied acceptance by using this material, aligning with predicate)Tantalum
    Physical Dimensions (Height)8mm, 10mm, 12mm, 14mm (Must match predicate for substantial equivalence)8mm, 10mm, 12mm, 14mm
    Physical Dimensions (Length)22mm, 26mm, 32mm, 36mm (Must match predicate for substantial equivalence)22mm, 26mm, 32mm, 36mm
    Intended UseMust be substantially equivalent to predicate device's intended useSubstantially equivalent to predicate device's intended use
    Radiological MarkersPresence for intra and post-operative positioning and visualizationCages contain radiographic tantalum markers

    Study Proving Device Meets Acceptance Criteria:

    The study that proves the device meets the acceptance criteria is a non-clinical testing program. The summary explicitly states:

    "Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:" (followed by a list of standards).

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

    The document does not specify sample sizes for non-clinical tests (e.g., how many devices were tested for seal strength or ASTM F2077-03). Non-clinical tests typically refer to laboratory testing of physical and mechanical properties, not patient data. Therefore, the concept of "country of origin of the data" and "retrospective or prospective" is not applicable here as no patient data was used.

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

    This information is not applicable as there was no clinical study or patient data involved in establishing ground truth. The "ground truth" for the non-clinical tests was established by adherence to recognized international and national standards (e.g., ISO, USP, ASTM) and comparison to a legally marketed predicate device.

    4. Adjudication Method for the Test Set

    This information is not applicable as there was no clinical study or patient data requiring expert adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. The document explicitly states: "No clinical study is included in this submission."

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    This question is not applicable as the device is an intervertebral body fusion device (an implant), not a software algorithm or AI-based diagnostic tool.

    7. The Type of Ground Truth Used

    The "ground truth" for demonstrating the device meets the acceptance criteria (and is substantially equivalent) relies on physical and mechanical performance data obtained from non-clinical testing against recognized industry standards (e.g., ASTM F2077-03) and direct comparison of specifications (materials, dimensions, intended use) to an existing predicate device.

    8. The Sample Size for the Training Set

    This information is not applicable. The device is an orthopedic implant, not an AI or machine learning model that requires a "training set."

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable as there is no training set for this type of device.

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