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510(k) Data Aggregation

    K Number
    K201240
    Date Cleared
    2020-08-05

    (89 days)

    Product Code
    Regulation Number
    888.3010
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Mariner Cap System

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

    The Mariner Cap System is intended to provide temporary stabilization as a bone anchor during the development of solid bony fusion and aid in the repair of bone fractures.

    The indications for use include the following applications:

      1. Spinal trauma surgery, used in sublaminar or facet wiring techniques;
      1. Spinal reconstructive surgery, incorporated into constructs for the purpose of correction of spinal deformities such as adolescent idiopathic scoliosis, adult scoliosis, kyphosis and spondylolisthesis;
      1. Spinal degenerative surgery, as an adjunct to spinal fusions.

    The Mariner Cap System shall be used in conjunction with the SeaSpine Mariner Pedicle Screw System whenever "wiring" may help secure the attachment of other implants.

    Device Description

    The Mariner Cap is composed of three components: the Mariner Cap SP Connector, the Mariner Cap SP Locking Base, and the Locking Insert. The cap is designed to mate with the Mariner Pedicle Screw System screws. The Mariner Cap is added to the proximal end of the Mariner Screw and provides for an alternate method to attach the JAZZ Band and JAZZ Passer Band to skeletal structures as compared to the current method using a JAZZ connector (K171881).

    AI/ML Overview

    The provided FDA 510(k) summary (K201240) describes the Mariner Cap System, a device intended for temporary stabilization as a bone anchor. However, this document does not contain the detailed information required to describe the acceptance criteria and a study that proves the device meets those criteria in the context of device performance as typically understood for AI/ML devices.

    The document is a regulatory submission for a medical device (a physical implant), not a software or AI/ML device. Therefore, the "acceptance criteria" and "study" mentioned primarily refer to non-clinical mechanical testing to demonstrate substantial equivalence to a predicate device, rather than performance metrics like sensitivity, specificity, or reader improvement, which are common for AI/ML studies.

    Here's a breakdown based on the information available and why certain aspects of your request cannot be fulfilled:

    1. Table of Acceptance Criteria and Reported Device Performance

    Based on the provided text, the "acceptance criteria" and "reported device performance" are related to mechanical testing for equivalence to a predicate device.

    Acceptance Criteria (Implied)Reported Device Performance
    Similar performance to predicate system in dynamic compression (ASTM 1717)Mariner Cap System demonstrated similar performance to the predicate system through dynamic compression testing.
    Similar performance to predicate system in static compressionMariner Cap System demonstrated similar performance to the predicate system through static compression testing.
    Equivalent technological characteristicsThe Mariner Cap System was shown to have equivalent technological characteristics to the cited predicate and reference device (components, description, intended use, operating principle, design, materials, sterility, manufacturing).

    Note: This is a very different type of "performance" than what would be reported for an AI/ML device. There are no accuracy, sensitivity, or specificity metrics.

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

    • Sample Size for Test Set: Not applicable in the context of mechanical testing. The testing would involve a certain number of manufactured devices for various mechanical tests, but this isn't a "test set" of patient data. The document does not specify the number of Mariner Cap Systems or components tested.
    • Data Provenance: Not applicable. The "data" refers to the results of mechanical tests performed on the physical device components, not patient data from a specific country or collected retrospectively/prospectively.

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

    • Number of Experts: Not applicable. Ground truth as typically understood for diagnostic AI/ML (e.g., radiologist reads) is not relevant for this type of mechanical device testing. The "ground truth" here would be the physical properties and mechanical behavior of the device under specific test conditions, as measured by standard engineering methods.
    • Qualifications of Experts: Not applicable. Engineering and quality assurance personnel would perform and analyze these tests, following recognized standards (like ASTM 1717).

    4. Adjudication Method

    • Adjudication Method: Not applicable. This concept is relevant for disagreements among human readers or algorithm outputs in diagnostic studies. For mechanical testing, results are quantitative and compared against established benchmarks or predicate device performance.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • MRMC Study: No. This type of study is specifically for evaluating the impact of an AI algorithm on human reader performance. The Mariner Cap System is a physical implant, not an AI/ML diagnostic tool.

    6. Standalone (Algorithm Only) Performance

    • Standalone Performance: No. The device is a physical implant, not an algorithm.

    7. Type of Ground Truth Used

    • Type of Ground Truth: For the mechanical testing, the "ground truth" would be the physical and mechanical properties of the device and its components, determined through standardized engineering tests (e.g., measuring forces, displacements, structural integrity, material properties) and compared against a predicate device.

    8. Sample Size for the Training Set

    • Sample Size for Training Set: Not applicable. There is no training set as the device is not an AI/ML algorithm.

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

    • Ground Truth for Training Set Established: Not applicable. As there is no training set for an AI/ML algorithm, this question is not relevant.

    In summary, the provided document describes a regulatory clearance for a physical medical implant (the Mariner Cap System) based on non-clinical mechanical testing demonstrating substantial equivalence to a predicate device. The questions posed in your request are largely tailored towards evaluating AI/ML-based medical devices, and thus many are not applicable to the context of this 510(k) submission.

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