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510(k) Data Aggregation

    K Number
    K110284
    Manufacturer
    Date Cleared
    2011-06-08

    (127 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Novel III Spinal System is a pedicle screw system indicated for the treatment of severe Spondylolisthesis (Grade 3 and 4) of the L5-S 1 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.

    In addition, the Novel Spinal 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 neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis).

    Device Description

    The Novel ///TM Spinal Fixation and Adjustable Bridge System is a top-loading posterior spinal fixation system which consists of pedicle screws, rods, set screws, and a transverse (cross) linking mechanism. The Novel /// ™ Spinal Fixation and Adjustable Bridge System implant components are fabricated from titanium allov (Ti-6Al-4V ELI) that conforms to ASTM F 136. Various sizes of these implants are available.

    Specialized instruments made from surgical instrument grade stainless steel are available for the application and removal of the Novel ////™ Spinal Fixation and Adjustable Bridge System implants.

    AI/ML Overview

    This 510(k) summary does not contain information related to an AI/ML device. The submission is for a medical device (spinal fixation system) and its modified sterilization trays, not a software algorithm that performs diagnostic or prognostic functions.

    Therefore, many of the requested items (e.g., acceptance criteria for AI performance, sample size for test/training sets, expert ground truth, MRMC studies) are not applicable to this document.

    Here's an analysis based on the information provided in the 510(k) summary, focusing on the device modification mentioned:


    Acceptance Criteria and Study for Novel III™ Spinal Fixation and Adjustable Bridge System (Modified Sterilization Trays)

    This 510(k) submission primarily concerns a "Special 510(k): Device Modification" related to redesigning custom sterilization trays for the Novel III™ Spinal Fixation and Adjustable Bridge System. The core spinal fixation device itself has already been cleared (predicates K081153 and K103147).

    1. Acceptance Criteria and Reported Device Performance

    The acceptance criteria and reported device performance are focused on the sterilization process for the redesigned trays, not on the clinical performance of the spinal system or an AI/ML algorithm.

    Acceptance Criteria CategorySpecific CriterionReported Performance / Outcome
    Sterilization ValidationAchieve a Sterility Assurance Level (SAL) equal to at least 1 x 10⁻⁶Validation satisfactorily performed on the redesigned sterilization trays.
    Mechanical Testing (of the implant)Conformance to ASTM F 1717-04 (Static Compression, Tension, Torsion Bending)Performed on the subject/predicate device. (Note: Not for the new trays themselves, as trays are not worst-case and don't require this specific testing)
    Material Conformance (of the implant)Titanium alloy (Ti-6Al-4V ELI) conforms to ASTM F 136Stated that implant components conform to ASTM F 136.
    Substantial EquivalenceDevice is substantially equivalent to predicate devicesDetermined by FDA (letter) and stated in submission.

    2. Sample Size and Data Provenance

    • Test Set Sample Size:
      • For the sterilization validation, the sample size is not explicitly stated in the summary, but it would typically involve a statistically relevant number of sterilization cycles and biological indicator tests. The summary just states it was "satisfactorily performed."
      • For mechanical testing of the implant, the sample size is not specified but would follow ASTM F 1717-04 guidelines.
    • Data Provenance: The data provenance for the tests performed (sterilization validation, mechanical testing) is not specified beyond being generated by Medyssey Co. Ltd. There is no mention of country of origin or whether it was retrospective or prospective, as these terms are relevant for clinical studies, not typically for device performance testing like sterilization or mechanical strength.

    3. Number of Experts and Qualifications for Ground Truth Establishment

    This item is not applicable as the submission does not involve an AI/ML algorithm or a diagnostic/prognostic device that requires expert ground truth establishment from clinical images or data. The ground truth for sterilization is a defined SAL, established through validated laboratory procedures.

    4. Adjudication Method for the Test Set

    This item is not applicable. The type of testing performed (sterilization validation, mechanical testing) does not involve human readers or adjudication processes.

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

    This item is not applicable. No MRMC study was performed as this is not an AI/ML device, nor is it a diagnostic imaging device where human reader performance would be the primary endpoint. The submission explicitly states: "Clinical tests: No clinical tests conducted on either the subject system nor the predicate system."

    6. Standalone Performance (Algorithm Only)

    This item is not applicable as there is no algorithm or software component for standalone performance evaluation in this 510(k) submission.

    7. Type of Ground Truth Used

    • For Sterilization Validation: The ground truth is the Sterility Assurance Level (SAL), which is a quantitative measure (1 x 10⁻⁶), established through specific, validated laboratory methods involving biological indicators and physical parameters of the sterilization cycle.
    • For Mechanical Testing: The ground truth is the performance specifications defined by the ASTM F 1717-04 standard.
    • For Substantial Equivalence: The ground truth is the characteristics and performance of the predicate devices and the regulatory standard for equivalence.

    8. Sample Size for the Training Set

    This item is not applicable. There is no "training set" as this is not an AI/ML device.

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

    This item is not applicable as there is no training set.

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    K Number
    K103147
    Manufacturer
    Date Cleared
    2010-12-16

    (52 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Novel III Spinal System is a pedicle screw system indicated for the treatment of severe Spondylolisthesis (Grade 3 and 4) of the L5-S 1 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. In addition, the Novel Spinal 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 neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis).

    Device Description

    The Novel ///™ Spinal Fixation and Adjustable Bridge System is a top-loading posterior spinal fixation system which consists of pedicle screws, rods, set screws, and a transverse (cross) linking mechanism. The Novel III TM Spinal Fixation and Adjustable Bridge System implant components are fabricated from titanium alloy (Ti-6AI-4V ELI) that conforms to ASTM F 136. Various sizes of these implants are available. Specialized instruments made from surgical instrument grade stainless steel are available for the application and removal of the Novel ///™ Spinal Fixation and Adjustable Bridge System implants.

    AI/ML Overview

    The provided text is a 510(k) summary for the Novel III™ Spinal Fixation and Adjustable Bridge System, which is a medical device. This type of document focuses on establishing substantial equivalence to a predicate device, primarily through mechanical testing and comparison of design and intended use.

    Therefore, the document does not contain the information requested in points 1-9, as those details are typically associated with clinical trials or studies assessing diagnostic performance, which are not relevant for this type of device submission.

    Here's a breakdown of why the information is not present:

    • Acceptance Criteria and Device Performance (1): Not applicable for this type of device. The acceptance criteria here would be meeting the mechanical testing standards (ASTM F 1717-04 for the predicate, and implied substantial equivalence for the modified device). No specific reported "performance" in the sense of diagnostic accuracy or a clinical outcome study is provided or required for a device modification of this nature.
    • Sample Size, Data Provenance (2): No clinical test set involving patients is described. The "test set" refers to the components tested in mechanical validation.
    • Number of Experts, Qualifications (3): No expert ground truth establishment for a test set is described.
    • Adjudication Method (4): Not applicable as there's no interpretation of clinical data by experts.
    • MRMC Comparative Effectiveness Study (5): This is a mechanical device, not an AI or diagnostic tool where human readers would improve with AI assistance.
    • Standalone Performance (6): "Algorithm only without human-in-the-loop performance" is not relevant for a spinal fixation system.
    • Type of Ground Truth (7): Not applicable. The "ground truth" for this device is its mechanical integrity and ability to perform its intended structural support function, verified by engineering and material standards, not by clinical pathology or outcomes in a study for this submission.
    • Sample Size for Training Set (8): No training set as this is not an AI/ML device requiring training data.
    • Ground Truth for Training Set (9): Not applicable, as there's no training set.

    Summary of what is present and relevant to the 510(k) in relation to 'testing':

    The submission indicates that the predicate device (Novel™ Spinal System) underwent mechanical testing, including:

    • Static Compression Bending
    • Static Tension Bending
    • Static Torsional
    • Dynamic Compression Fatigue Testing

    All these tests were performed per ASTM F 1717-04.

    The subject device (Novel III™ Spinal Fixation and Adjustable Bridge System) "contains dimensionally modified components (not worst case) and therefore not subject to ASTM F 1717-04 additional testing." This implies that because the modifications were not considered "worst case" in terms of mechanical stress, the new device was deemed substantially equivalent to the predicate without needing to repeat all the same mechanical tests. The acceptance criteria for the subject device are therefore implicitly:

    1. Substantial Equivalence: The modified components do not negatively impact the mechanical performance already established for the predicate device.
    2. Compliance with ASTM F 1717-04 (by proxy via predicate): The predicate device met these standards, and the modifications to the subject device are not considered to compromise that compliance.

    In essence, the "study" proving the device meets acceptance criteria is the mechanical testing of the predicate device against ASTM F 1717-04, and the subsequent engineering analysis that concluded the modifications in the Novel III™ system did not require new, full-scale mechanical testing due to their non-worst-case nature.

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