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510(k) Data Aggregation

    K Number
    K212831
    Date Cleared
    2021-10-29

    (52 days)

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

    MectaLIF Extension

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

    The MectaLIF implants in combination with supplemental fixation are indicated for use with autogenous bone graft in patients with degenerative disc disease (DDD) at one or two contiguous spinal levels from L2 - S1 whose condition requires the use of interbody fusion. Degenerative disc disease is defined as discogenic pain with degeneration of the disc confirmed by patient history and radiographic studies. These patients may have had a previous non-fusion spinal surgery at the involved spinal level(s). Patients must be skeletally mature. Patients should have received 6 months of non-operative treatment prior to treatment with the devices.

    Device Description

    The subject MectaLIF Extension implants are a line extension to the MectaLIF Oblique and Posterior PEEK implants (K110927, K131671 and K181970) and MectaLIF Oblique and Posterior TiPEEK implants (K133192 and K181970). MectaLIF implants are used to replace a degenerative disc in order to restore the height of the spinal column structure. The devices are not intended to be coupled with other implants but are intended to be used with supplemental fixation and autogenous bone graft. The subject MectaLIF Extension includes various sizes of MectaLIF Oblique and MectaLIF Posterior implants with different widths, lengths, heights, and lordosis angles. The implants are made of implant grade Polyetherketone and have markers made of Tantalum. The devices are available both uncoated or coated with commercially pure titanium coating.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the MectaLIF Extension device.

    It's important to note that the document is a 510(k) Premarket Notification from the FDA, which focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than proving de novo safety and effectiveness. Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are framed within this context of demonstrating equivalence through non-clinical performance data rather than a full-scale clinical trial.


    Acceptance Criteria and Device Performance for MectaLIF Extension (Based on 510(k) Summary)

    Based on the provided FDA 510(k) summary (K212831), the "acceptance criteria" for the MectaLIF Extension are implicitly tied to demonstrating performance comparable to its predicate devices, aligning with relevant ASTM and ISO standards for intervertebral body fusion devices. The study proving these criteria are met consists primarily of non-clinical (benchtop) performance testing. No clinical studies were conducted for this 510(k) submission.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria Category (Implicit)Specific Tests / Standards (Performance Data)Reported Device Performance (Summary from Document)
    Mechanical Performance- Static and dynamic axial compression test (ASTM F2077-18)
    • Static and dynamic shear compression test (ASTM F2077-18)
    • Axial compressive subsidence test (ASTM F2077-18)
    • Measuring Load Induced subsidence (ASTM F2267-04)
    • Expulsion Test rationale (Implied adherence to performance requirements) | Design validation and performance testing conducted to written protocols. Implied to meet or exceed relevant predicate device and standard requirements. |
      | Material Properties & Coating Performance | - TiPEEK coating validation (ASTM F1854-15 for stereological evaluation of porous coatings; ASTM F1147-05 for tension testing)
    • Wear analysis of TiPEEK coated devices (ISO 17853:2011; ASTM F1877-16) | Adherence to relevant ASTM and ISO standards for material and coating validation. Implied acceptable performance. |
      | Biocompatibility & Sterility | - Bacterial endotoxin test (LAL test) according to European Pharmacopoeia §2.6.14 (equivalent to USP chapter )
    • Pyrogen test according to USP chapter
    • Biocompatibility assessment (General statement, implying tests like cytotoxicity, sensitization, irritation performed per ISO 10993)
    • Sterility Validation | Tests were conducted. Devices are not labeled as non-pyrogenic. Implied to meet biocompatibility and sterility requirements. |
      | Shelf-Life & Packaging | - Shelf-life evaluation
    • Packaging validation | Evaluation/validation done. Implied acceptable. |
      | Design Integrity (New Sizes/Lordosis/Volume) | - Design Validation Report for MectaLIF Oblique 10mm width instrument/implant interface (specific to one of the new configurations, implies assessment of fit, function, and instrument compatibility for new sizes/lordosis) | Conducted as part of design validation to written protocols. Implied suitable. |

    Note: The document states that "Based on the risk analysis, design validation and performance testing were conducted to written protocols." and lists the specific tests. The detailed quantitative results (e.g., exact load values survived, specific wear rates) are not included in this public summary but would be part of the full 510(k) submission. The "reported device performance" in this context is the statement that these tests were conducted and support the claim of substantial equivalence.


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

    • Sample Size for Test Set: The document does not specify the exact sample sizes (number of devices tested) for each non-clinical performance test (e.g., how many cages underwent axial compression testing). These numbers are typically defined by the specific ASTM/ISO standards referenced.
    • Data Provenance: The tests are explicitly non-clinical (benchtop mechanical, material, and biological tests).
      • Country of Origin: The submitter is "Medacta International SA, Strada Regina 6874 Castel San Pietro (CH) Switzerland." The testing would presumably have been performed in a lab accredited to conduct these tests, likely in Switzerland or a country with recognized testing facilities.
      • Retrospective or Prospective: Not applicable as these are benchtop tests, not clinical data from patients.

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

    This concept is not applicable in this context. For a 510(k) submission primarily relying on non-clinical performance data, there is no "ground truth" derived from expert clinical opinion or patient outcomes in the same way there would be for an AI/CADe device submitting clinical study results. The "ground truth" for non-clinical tests is established by:

    • The measurement equipment and its calibration.
    • The test methods defined by recognized standards (e.g., ASTM, ISO), which dictate how a device's performance characteristic is measured.
    • The acceptance criteria set by the manufacturer (and implicitly accepted by the FDA for substantial equivalence) based on predicate device performance and standard requirements.

    4. Adjudication Method for the Test Set

    This concept is not applicable. Adjudication methods (e.g., 2+1, 3+1) are used in clinical studies, particularly for diagnostic accuracy or image review, to resolve discrepancies between readers or to establish a definitive diagnosis as ground truth. Since this submission relies on non-clinical benchtop testing, there are no human readers or clinical cases requiring adjudication.


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

    No, an MRMC comparative effectiveness study was not done. The document explicitly states: "Clinical Studies: No clinical studies were conducted." This type of study would be relevant for a device intended to aid in clinical diagnosis or treatment decisions by human readers, typically for AI/CADe.


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

    No, a standalone performance evaluation (as defined for AI algorithms) was not done. This device is an intervertebral body fusion implant, not software or an algorithm.


    7. The Type of Ground Truth Used

    The "ground truth" for determining acceptance for this device is based on:

    • Engineering Standards and Specifications: Adherence to defined physical and mechanical properties, material composition, and dimensions as tested against industry standards (ASTM F2077, F2267, F1854, F1147) and biocompatibility standards (ISO, USP, European Pharmacopoeia).
    • Predicate Device Equivalence: The primary "ground truth" for a 510(k) clearance is demonstrating that the new device is "substantially equivalent" to a legally marketed predicate device regarding safety and effectiveness. This means the performance characteristics of the new device are comparable to, or better than, the predicate devices based on the non-clinical tests.

    8. The Sample Size for the Training Set

    This concept is not applicable. "Training set" refers to data used to train machine learning models. This device is a physical medical implant, not an AI/ML algorithm.


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

    This concept is not applicable. As stated above, this is a physical medical device, not an AI/ML algorithm requiring a training set and associated ground truth establishment.

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