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510(k) Data Aggregation

    K Number
    K092128
    Manufacturer
    Date Cleared
    2009-09-14

    (61 days)

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

    MODIFICATION TO: PSS SYSTEM

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

    The PSS System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudoarthrosis).

    The PSS System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4 of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; curvatures (i.e. scoliosis; and/or lordosis); spinal tumor; pseudoarthrosis; and failed previous fusion,

    Device Description

    The PSS System is a top-loading, multiple component, posterior spinal fixation system which consists of pedicle screws, rods, cross links, locking cap screws and hooks. All of the components are available in a variety of sizes to match more closely the patient's anatomy. All components are made from medical grade stainless steel, titanium alloy described by such standards as ASTM F-138, ASTM F136 or ISO5832-3. The products are supplied clean and "NON-STERILE".

    AI/ML Overview

    This document is a 510(k) premarket notification for the "PSS System," a pedicle screw spinal system. A 510(k) submission generally focuses on demonstrating substantial equivalence to a predicate device, rather than providing extensive clinical study data with detailed acceptance criteria and performance metrics typically seen in studies for novel high-risk devices or AI/ML-driven diagnostics.

    Therefore, the requested information regarding acceptance criteria, study details, expert involvement, and ground truth for an AI/ML device is not applicable to this 510(k) submission. This submission primarily relies on comparing the new device's design, materials, and intended use to existing legally marketed predicate devices.

    Here's why and what information is available:

    • Type of Device: The PSS System is a pedicle screw spinal system, a mechanical implant.
    • Regulatory Pathway: This is a 510(k) submission, which aims to demonstrate "substantial equivalence" to a predicate device. This pathway typically relies on engineering and performance testing (e.g., mechanical strength, fatigue), material characterization, and comparison of design features and intended use with already cleared devices. It does not usually involve clinical trials to establish sensitivity, specificity, or reader performance improvements.
    • Focus of Submission: The conclusion explicitly states: "Based on the results, the overall designs of the PSS System which consists of pedicle screws, rods, cross links, locking cap screws and hooks are substantially equivalent to the predicate devices."

    Therefore, the specific questions related to AI/ML device study design, acceptance criteria, sample sizes, expert ground truth, and MRMC studies cannot be answered from the provided text because these elements are not part of a typical 510(k) for a mechanical spinal implant.

    If this were an AI/ML device, the detailed information requested would be crucial. However, for this specific document, that information is not relevant or present.

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    K Number
    K090033
    Manufacturer
    Date Cleared
    2009-05-06

    (120 days)

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

    MODIFICATION TO: PSS SYSTEM

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

    The PSS System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudoarthrosis).

    The PSS System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4 of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; curvatures (i.e. scoliosis; and/or lordosis); spinal tumor: pseudoarthrosis; and failed previous fusion.

    Device Description

    The PSS System is a top-loading, multiple component, posterior spinal fixation system which consists of pedicle screws, rods, cross links, locking cap screws. All of the components are available in a variety of sizes to match more closely the patient's anatomy. All components are made from medical grade titanium or titanium alloy described by such standards as ASTM F136 or ISO5832-3. The products are supplied clean and "NON-STERILE".

    AI/ML Overview

    This document describes a spinal fixation system (PSS System) and its regulatory clearance, but it does not contain the type of study that would typically involve acceptance criteria, performance metrics, ground truth, or expert review in the context of AI/device performance.

    The provided text pertains to a 510(k) premarket notification for a medical device (a pedicle screw spinal system). This regulatory pathway focuses on demonstrating substantial equivalence to a legally marketed predicate device, primarily through mechanical testing and material specifications, not clinical or diagnostic performance evaluated against expert ground truth.

    Therefore, many of the requested elements for the study (acceptance criteria table, sample sizes for test/training sets, expert qualifications, adjudication methods, MRMC studies, standalone performance, ground truth types) are not applicable or not present in this type of regulatory submission.

    Here's an analysis based on the information available:

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

    • Not Applicable in this context. The focus of this 510(k) is mechanical equivalence. The "performance" is primarily mechanical strength and durability.
    • The study cited is "Testing in accordance with ASTM F1717 'Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model'".
    • Acceptance Criteria (Implied): The PSS System must perform "substantially equivalent" to the predicate device (Spinal USA PSS System K071438) when tested according to ASTM F1717. This standard would define specific mechanical tests (e.g., static and dynamic compression, bending, torsion) and their corresponding pass/fail criteria or performance metrics (e.g., maximum load, stiffness, fatigue life).
    • Reported Device Performance: The document states: "Testing in accordance with ASTM F1717 'Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model' of the PSS System demonstrates that the device is substantially equivalent to the Spinal USA PSS System (K071438)." Specific numerical performance data from the ASTM F1717 test are not provided in this summary.

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

    • Not Applicable (direct interpretation of "test set" for performance evaluation). For mechanical testing, the "sample size" would refer to the number of physical device constructs tested. This information is not provided in the summary but would be detailed in the full test report.
    • Data Provenance: The testing was conducted internally by Spinal USA, presumably in a laboratory setting (Country of Origin: USA, as the submitter information is in Mississippi). This is a prospective test in the sense that the new device was built and specifically tested against the standard.

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

    • Not Applicable. The "ground truth" for mechanical testing is defined by the physical properties and performance measured under controlled laboratory conditions according to the ASTM standard, not by expert human interpretation.

    4. Adjudication method for the test set

    • Not Applicable. Mechanical test results are objective measurements (e.g., force, displacement, cycles to failure), not subject to human adjudication for discrepancies.

    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 mechanical device, not an AI-powered diagnostic or assistive tool.

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

    • Not Applicable. This is a mechanical device, not an algorithm.

    7. The type of ground truth used

    • Mechanical Integrity/Performance according to ASTM F1717 Standard. The "ground truth" is the objective physical behavior of the device under specified loads, measured against the requirements of the standard and compared to the predicate device's performance.

    8. The sample size for the training set

    • Not Applicable. This is a mechanical device, not an AI algorithm requiring a training set.

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

    • Not Applicable.

    In summary: The provided document is a regulatory submission for a physical medical device. The "study" mentioned is a mechanical performance study designed to establish substantial equivalence to a predicate device, as required for 510(k) clearance by the FDA. It does not involve the types of clinical performance evaluations, expert ground truth, or AI-specific metrics that your questions are geared towards.

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