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510(k) Data Aggregation

    K Number
    K153169
    Date Cleared
    2016-01-29

    (88 days)

    Product Code
    Regulation Number
    888.3075
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    PASS OCT Patient Specific Rods

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

    The PASS OCT spinal system is intended to provide immobilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The PASS OCT spinal system is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

    In order to achieve additional levels of fixation, the PASS OCT spinal system may be connected to the PASS LP spinal system with the dual diameter rods. Refer to the PASS LP spinal system package insert for a list of the PASS LP spinal system indications of use.

    Device Description

    The PASS OCT Spinal System is a posterior system, which consists of a variety of shapes and sizes of rods, hooks, polyaxial screws, occipital plates, occipital bone screws, and connection components, which can be rigidly locked to the rod in a variety of configurations. See package insert of the system for labeling limitations.

    The implants are manufactured in titanium alloy Ti-6AI-4V ELI conforming to ISO 5832-3 specifications and ASTM F136 specifications, in PEEK OPTIMA LT1 conforming to ASTM F2026 specifications and in cobalt-chromium molybdenum alloy Co-Cr28Mo6 that conforms to ISO 5832-12 and ASTM F1537 specifications, and also CP Titanium according to ASTM F67 and ISO 5832-2 specifications.

    The purpose of this submission is to add Patient Specific, UNiD OCT rods. The Patient Specific Rod is a rod bent before surgery by MEDICREA, following the design defined by the surgeon only specific to a unique patient.

    AI/ML Overview

    The provided document is a 510(k) summary for a medical device called "PASS OCT Patient Specific Rods." This document primarily focuses on establishing substantial equivalence to a predicate device rather than detailing studies to meet specific acceptance criteria in the manner one might find for a novel AI/software product. Therefore, much of the requested information regarding acceptance criteria, sample sizes for training/test sets, expert qualifications, and specific study designs (like MRMC or standalone performance) is not applicable or not present in this type of submission.

    However, I can extract the information that is present and indicate where the requested details are not provided.

    Here's a breakdown based on the provided text:

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

    Acceptance CriteriaReported Device Performance
    Mechanical Evaluation:
    • Static Compression
    • Dynamic Compression
    • Static Torsion
    • Dynamic Torsion | Met:
    • Mechanically evaluated following ASTM F2706-08.
    • Conducted on a justified worst case.
    • IMPLICITLY met, as the submission concludes substantial equivalence based on these tests. The document does not provide specific numerical outcomes (e.g., maximum load, cycles to failure) or pass/fail thresholds, but states these tests were performed and support the equivalence claim. |

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

    • Sample size for test set: The document states that "the mechanical test was conducted on a justified worst case." This implies that a limited number of samples (perhaps one or a few representing the worst case) were tested to demonstrate mechanical properties. It does not specify the exact number of samples.
    • Data provenance: Not specified in the document.

    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 applicable/Not provided. This submission is for a physical medical device (spinal rods) and relies on mechanical testing standards, not clinical assessments by experts for "ground truth" in the context of image analysis or diagnostic algorithms.

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

    • Not applicable/Not provided. This is not relevant for mechanical testing of spinal rods.

    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

    • No. This is a submission for a physical medical implant (spinal rods), not an AI or imaging diagnostic device.

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

    • Not applicable/Not provided. This is not relevant for a physical medical implant.

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

    • For the non-clinical (mechanical) tests, the "ground truth" is adherence to ASTM F2706-08 standards for static and dynamic compression and torsion. The device's performance is compared against the expected behavior as defined by these engineering standards.

    8. The sample size for the training set

    • Not applicable/Not provided. This is not an AI/software product that requires a training set.

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

    • Not applicable/Not provided. This is not an AI/software product that requires a training set or ground truth in that context. The "ground truth" for the device's design and manufacturing is based on established engineering principles, material science, and predicate device designs.

    Summary of Study (Non-Clinical Test Summary):

    • Study Type: Non-clinical mechanical evaluation.
    • Purpose: To demonstrate that the PASS OCT Patient Specific Rods are technologically similar and perform comparably to predicate devices in terms of mechanical safety.
    • Methods: Static and dynamic compression tests and static and dynamic torsion tests were performed. These tests followed the ASTM F2706-08 standard.
    • Test Cases: The tests were conducted on a "justified worst case" configuration of the device.
    • Conclusion: Based on these mechanical tests, the components were concluded to be substantially equivalent to legally marketed predicate devices, implying they met the performance expectations outlined in the standard for safety and effectiveness.
    • Clinical Data: The document explicitly states that "Published literature was used to demonstrate substantial equivalence," meaning no new clinical studies were conducted for this 510(k) submission.
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