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510(k) Data Aggregation

    K Number
    K984522
    Date Cleared
    1999-01-06

    (16 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    MODIFICATION OF TSRH SPINAL SYSTEM

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

    When used as a pedicle screw fixation system of the non-cervical posterior spine in skeletally mature patients, the TSRH® Spinal System is indicated for one or more of the following: (1) degenerative spondylolisthesis with objective evidence of neurologic impairment, (2) fracture, (3) dislocation, (4) scoliosis, (5) kyphosis, (6) spinal tumor, and/or (7) failed previous fusion (pseudarthrosis).

    In addition, when used as a pedicle screw fixation system, the TSRH® Spinal System is indicated for skeletally mature patients: (a) having severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral ioint: (b) who are receiving fusions using autogenous bone graft only; (c) who are having the device fixed or attached to the lumbar and sacral spine (L3 and below); and (4) who are having the device removed after the development of a solid fusion mass.

    When used as a posterior, non-cervical, non-pedicle screw fixation system, the TSRH® Spinal System is intended for the following indications: (1) degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), (2) spinal stenosis, (3) spondylolisthesis, (4) spinal deformities (i.e., scoliosis, and/or lordosis), (5) fracture, (6) pseudarthrosis, (7) tumor resection, and/or (8) failed previous fusion.

    When used as an anterolateral thoracic/lumbar system, the TSRH® Spinal System is intended for the following indications: (1) degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), (2) spinal stenosis, (3) spondylolisthesis, (4) spinal deformities (i.e., scoliosis, kyphosis, and/or lordosis), (5) fracture, (6) pseudarthrosis, (7) tumor resection, and/or (8) failed previous fusion.

    Device Description

    The purpose of this 510(k) submission is to add the 3D Connector and associated screws to the TSRH® Spinal System.

    The TSRH® Spinal System consists of a variety of shapes and sizes of rods, hooks, screws, cross connectors, and connecting components. In addition, GDLH® rods, DYNA-LOK® bolts, CD HORIZON™ Low Profile MULTI-SPAN™ CROSSLINK® Plates, GDLH® rod/bolt connectors, GDLH® Variable Angle T-Bolts, and GDLH® and CD HORIZON™ set screws and locking screws may be used with the TSRH® Spinal System.

    The TSRH® Spinal System implant components can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case. The hooks are intended for posterior use only and the staples are for anterior use only. The TSRH-3D™ connectors and TSRH-3D™ screws are intended for posterior use only. All CROSSLINK® Plates are for posterior use and the CROSSLINK Axial and Offset Plates may be used anteriorly as well.

    The TSRH Spinal System components are fabricated from either stainless steel conforming to ASTM F-138 or ISO 5832-1 or ISO 5832-9, or titanium alloy conforming to ASTM F-136 or ISO 5832-3. The TSRH Spinal System may sold sterile or non-sterile.

    AI/ML Overview

    This 510(k) summary (K984522) describes the addition of 3D Connectors and associated screws to the existing TSRH® Spinal System. The submission primarily focuses on establishing "substantial equivalence" to predicate devices rather than providing detailed acceptance criteria and performance study results in the manner common for AI/ML device submissions.

    Therefore, much of the requested information regarding acceptance criteria, specific performance metrics, sample sizes for test/training sets, expert qualifications, and adjudication methods is not available in this document. This is typical for a 510(k) submission for a physical medical device from this era, where the focus is on demonstrating that the new components are essentially the same as previously cleared components and do not raise new questions of safety or effectiveness.

    Here's an attempt to answer the questions based on the provided text, while highlighting what is missing due to the nature of the document:

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

    Acceptance Criteria (Inferred from Substantial Equivalence)Reported Device Performance (as stated in the document)
    Identical Intended Use: To provide spinal fixation."The subject device is identical to the predicate device in intended use..."
    Identical Indications For Use: (As listed in Section IV)"The subject device is identical to the predicate device in... indications for use..."
    Identical Levels of Attachment: (Not explicitly detailed, but implied by spinal system components)"The subject device is identical to the predicate device in... levels of attachment..."
    Identical Labeling: (Not explicitly detailed, but implied by regulatory compliance)"The subject device is identical to the predicate device in... labeling..."
    Identical Material: Stainless steel (ASTM F-138 or ISO 5832-1/5832-9) or Titanium alloy (ASTM F-136 or ISO 5832-3)."The TSRH Spinal System components are fabricated from either stainless steel conforming to ASTM F-138 or ISO 5832-1 or ISO 5832-9, or titanium alloy conforming to ASTM F-136 or ISO 5832-3."
    Identical Sterilization Method: Sterile or non-sterile options."The TSRH Spinal System may sold sterile or non-sterile."
    Identical Method of Use: Implied to be similar to predicate devices for spinal fixation."The subject device is identical to the predicate device in... method of use..."
    Identical Fundamental Scientific Technology: Implied to be mechanical spinal fixation."The subject device is identical to the predicate device in... fundamental scientific technology."
    Substantial Equivalence to Predicate Devices: TSRH® Top Tightening T-Bolts and TSRH® Variable Angle Screws.Concluded that "The TSRH®-3D Connector and associated screws are substantially equivalent to the TSRH® Top Tightening T-Bolts and TSRH® Variable Angle Screws."

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

    Not available/Applicable. This document does not describe a performance study with a test set of data points in the way an AI/ML device would. Instead, substantial equivalence is claimed based on similarities in design, materials, and intended use to existing predicate devices.

    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)

    Not available/Applicable. No expert-derived ground truth for a test set is described.

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

    Not available/Applicable. No test set or adjudication method is described.

    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 available/Applicable. This is not an AI-assisted device, and no MRMC study is mentioned.

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

    Not available/Applicable. This is not an algorithm-only device.

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

    Not available/Applicable. The concept of "ground truth" for a performance study is not relevant here as the submission focuses on substantial equivalence of physical components. The "truth" in this context is that the new components are comparable in design, material, and function to previously cleared devices.

    8. The sample size for the training set

    Not available/Applicable. No training set for an algorithm is discussed.

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

    Not available/Applicable. No training set or ground truth establishment for it is discussed.

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