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510(k) Data Aggregation
(91 days)
The Pathfinder® CR System is an accessory to the Pathfinder Endoscope Overtube, intended to be used with an endoscope to facilitate evacuation of retained blood, free-floating blood clots, and fluid from the stomach in adult patients (22 years of age or older).
It is for use only by medically licensed and trained gastroenterologists located in hospitals, clinics and doctors' offices.
The Pathfinder® CR System is a disposable endoscopy fluid management system for the 14mm ID Pathfinder®Endoscope Overtube. It is designed to evacuate retained blood, free-floating blood clots, and fluid from the stomach in adult patients (22 years of age or older). It also provides access for endoscopic device passage and exchange. The suction adapter is attached to the Overtube and connected to a foot pedal to control suction on/off functionality. The foot pedal is connected to a suction source with vacuum regulator that provides a range between 200 to 375 mmHg (26.7 to 50.0 kPa). It is for use only by medically licensed and trained gastroenterologists located in hospitals, clinics, and doctor offices. The Pathfinder® CR System consists of the following main components: Suction Adapter (CR, Adapter), Foot Pedal (Suction Controller), Suction Tubing (Tubing).
The provided FDA 510(k) summary for the Neptune Medical Pathfinder® CR System primarily focuses on demonstrating substantial equivalence to predicate devices through technical characteristics, biocompatibility, and non-clinical functional and performance testing. It explicitly states that "No clinical testing was applicable to this submission" and "No animal testing was applicable to this submission." Therefore, the document does not contain information about a study with acceptance criteria of the type requested, which would typically involve human-in-the-loop performance or standalone algorithm performance.
However, based on the provided text, I can infer the "acceptance criteria" are related to successful functional and performance testing and biocompatibility, rather than a clinical performance study with metrics like sensitivity, specificity, or AUC.
Here's a breakdown of the available information:
Acceptance Criteria and Reported Device Performance
The document describes several non-clinical functional and performance tests. While specific quantitative acceptance criteria are not explicitly listed in a table format with corresponding reported performance values, the overall conclusion states that the device "successfully demonstrated that the device correctly performs as designed, has been validated for its intended use, and raises no new questions regarding either safety or effectiveness."
To provide a table as requested, I'll interpret the successful completion of each test as meeting an implicit acceptance criterion.
| Acceptance Criterion (Implicit) | Reported Device Performance and Evidence |
|---|---|
| Biocompatibility: | |
| Meets ISO 10993 requirements for patient-contacting materials (Suction Adapter) | Testing demonstrated that the material used in the Suction Adapter meets the requirements of the applicable ISO 10993 standard. Tests included Cytotoxicity, Sensitization, Irritation Reactivity, Acute Systemic Toxicity, and Material Mediated Pyrogenicity. |
| Functional and Performance Testing: | It's important to note that specific PASS/FAIL criteria or numerical results for these tests are not provided in this summary. The summary states that these activities "successfully demonstrated that the device correctly performs as designed." |
| Dimensional Measurements | Successfully demonstrated (implied by overall conclusion). |
| Adapter Scope Installation | Successfully demonstrated (implied by overall conclusion). |
| Endoscope Trackability | Successfully demonstrated (implied by overall conclusion). |
| Device Trackability | Successfully demonstrated (implied by overall conclusion). |
| System Flow Rate | Successfully demonstrated (implied by overall conclusion). Includes specifications for maximum suction pressure of (-)0.5 Bar / (375mmHg). |
| Adapter Tubing Installation and Removal | Successfully demonstrated (implied by overall conclusion). |
| Adapter Tensile Integrity | Successfully demonstrated (implied by overall conclusion). |
| Adapter Cantilever Integrity | Successfully demonstrated (implied by overall conclusion). |
| Adapter Scope and Cantilever Seal | Successfully demonstrated (implied by overall conclusion). |
| Adapter Torque | Successfully demonstrated (implied by overall conclusion). |
| Foot Pedal Cyclic and Actuation Force | Successfully demonstrated (implied by overall conclusion). |
| Foot Pedal Tubing Installation and Removal | Successfully demonstrated (implied by overall conclusion). |
| Simulated Use | Successfully demonstrated (implied by overall conclusion). |
| Sterility & Shelf Life: | |
| Sterilization effective for Suction Adapter | Ethylene Oxide (EO) used as the method of Sterilization. Neptune Medical is responsible for its sterilization. |
| Shelf life validation | Proposed shelf life of 6 months from the date of manufacture. (Implies satisfactory validation was performed, though details aren't provided). |
| Substantial Equivalence: | |
| As safe, as effective, and performs as well as predicates | "Differences in design and technology do not raise any unanswered questions of safety or effectiveness and the intended use remains unchanged." Concluded to be substantially equivalent to Pathfinder Endoscope Overtube (K211301) and Pure-Vu EVS System (K232922) based on bench testing and biocompatibility. |
Regarding the specific questions about evaluation studies:
2. Sample size used for the test set and the data provenance:
- Not applicable / Information not provided. This document details non-clinical (bench) testing, not a clinical study involving a test set of patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. No expert review of a "test set" to establish ground truth is described, as there was no clinical study.
4. Adjudication method for the test set:
- Not applicable. No clinical test set or adjudication method is described.
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. The document explicitly states, "No clinical testing was applicable to this submission." This device is a mechanical system, not an AI-assisted diagnostic tool, so an MRMC study related to AI assistance would not be relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a mechanical system, not an algorithm. The testing described is functional performance testing of the device itself.
7. The type of ground truth used:
- Bench Test Specifications / Engineering Requirements. For the functional tests, the "ground truth" would be the engineering specifications and design requirements against which the device's performance was measured. For biocompatibility, it's compliance with ISO 10993 standards.
8. The sample size for the training set:
- Not applicable. This pertains to algorithm development. This device is a mechanical system.
9. How the ground truth for the training set was established:
- Not applicable. This pertains to algorithm development. This device is a mechanical system.
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(127 days)
The Pathfinder Endoscope Overtube with Balloon is intended to be used with an endoscope to facilitate intubation, change of endoscopes, and treatment in the gastrointestinal (GI) tract in adult patients (22 years of age and older).
The Pathfinder Endoscope Overtube with Balloon device consists of a hollow tube with a balloon at the distal end for use over a flexible gastrointestinal endoscope. The purpose of the balloon is to contact the lumen walls to provide stabilization to the distal end of the overtube within the GI tract. The endoscope is inserted through the proximal end of the device and comes out the distal end. The free space between the overtube and the endoscope is lubricated with water through the irrigation line by connecting to the irrigation/water Luer (female Luer lock fitting) and injecting water. The vacuum line is connected to free space within the device and is completely contained. A source of vacuum must be connected to the barb fitting per the diagram below for the overtube to transition between the flexible and rigid conditions. The balloon line is connected to an extrusion within the device that creates an air pathway from handle to the balloon. An inflation device must be connected to the Luer (male Luer lock fitting) to inflate and/or deflate the balloon. The handle rotator has two positions. The first position connects the device to atmosphere (vent) to stay in the flexible condition. The second position connects the device to a source of vacuum to transition to the rigid condition. When transitioned to the rigid condition, the device maintains its shape at the time of rigidization, allowing the endoscope to advance or withdraw relative to the overtube with minimal disturbance to surrounding anatomy. Balloon inflation and deflation are actuated and controlled by an existing balloon controller unit within the endoscopy suite. The device must be connected to the balloon controller to transition into the inflated and deflated condition.
The provided text does not contain information about a study that proves a device meets acceptance criteria related to AI/algorithm performance.
The document is a 510(k) Premarket Notification from the FDA to Neptune Medical, Inc. for their "Pathfinder Endoscope Overtube with Balloon Device." It describes the device, its intended use, comparison to predicate devices, and summaries of functional and performance bench testing, and biocompatibility testing. It explicitly states:
- "No clinical testing was applicable to this submission."
- The entire submission focuses on a physical medical device, not an AI or algorithm.
Therefore, I cannot fulfill your request to describe the acceptance criteria and study for an AI-powered device's performance, as the provided text pertains to a traditional medical device not involving AI.
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(29 days)
The Pathfinder Endoscope Overtube is intended to be used with an endoscope to facilitate intubation, change of endoscopes, and treatment in the gastrointestinal (GI) tract in adult patients (22 years of age and older).
The Pathfinder Endoscope Overtube (Pathfinder) device consists of a flexible overtube that may be connected to vacuum for rigidization. It is used with an endoscope for procedures in the gastrointestinal tract. The handle includes a vacuum line which is connected to free space within the device that is completely contained, forming the vacuumable volume. The handle rotator has two positions: the first connects the vacuumable volume within the device to atmosphere (vent) to stay in the flexible position, and the second position connects the vacuumable volume to a source of vacuum to transition to the rigid condition. When transitioned to the rigid condition, the device maintains its shape at the time of rigidization, allowing the endoscope to advance or withdraw relative to the overtube with minimal disturbance to the surrounding anatomy. When transitioned to the flexible condition, the device is able to move relative to the patient anatomy and endoscope for navigation through the GI tract. The device is provided sterile (EO). After use, the device is discarded and disposed of in accordance with local regulations.
The provided document describes a Special 510(k) submission for modifications to the Pathfinder Endoscope Overtube, specifically the addition of new sizes and a change in material durometer for the vacuum and irrigation line. This is NOT a typical AI/ML medical device submission, and therefore, many of the requested fields related to AI/ML performance, ground truth, and expert evaluation are not applicable.
Here's the breakdown of the information that can be extracted from the provided text, and where it indicates non-applicability for AI/ML specific criteria:
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a device modification submission for physical characteristics (sizes, material), the "acceptance criteria" are related to the functional and performance testing of the physical properties of the device, rather than a quantifiable performance metric like sensitivity or specificity for an AI algorithm. The document states that the "line extension was the subject of extensive testing under applicable design control requirements."
| Acceptance Criteria Category | Reported Device Performance / Evaluation | Notes |
|---|---|---|
| Lubricity | Tested | Demonstrated through bench testing. Specific quantitative results are not provided in the summary. |
| Insufflation | Tested | Demonstrated through bench testing. Specific quantitative results are not provided in the summary. |
| Insertion/Removal | Tested | Demonstrated through bench testing. Specific quantitative results are not provided in the summary. |
| Navigation | Tested | Demonstrated through bench testing. Specific quantitative results are not provided in the summary. |
| Rigidization/De-Rigidization | Tested | Demonstrated through bench testing. Specific quantitative results are not provided in the summary. |
| Dimensional Measurements | Confirmed to specification | Nine new sizes, from 65 to 145 cm long and 11 to 16 mm inner diameter, were designed and tested. |
| Endoscope Compatibility | Tested | Demonstrated through bench testing. Specific quantitative results are not provided in the summary. |
| Device Safety & Effectiveness | Shown to be safe; no unanswered questions of safety or effectiveness. | Conclusion statement after all testing. |
2. Sample size used for the test set and the data provenance
The document mentions "extensive testing" but does not provide specific sample sizes for each type of functional and performance testing (e.g., how many devices were tested for lubricity, how many cycles for rigidization).
- Sample Size (Test Set): Not specified in the provided summary.
- Data Provenance: The testing appears to be bench testing (laboratory-based) as stated in section 1.10: "the modified Pathfinder Endoscope Overtube has been shown to be safe through bench testing." This is not retrospective or prospective clinical data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This question is not applicable as this submission is for a physical medical device (endoscope overtube) and not an AI/ML device that requires human interpretation for ground truth.
4. Adjudication method for the test set
This question is not applicable for the same reason as point 3.
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
This question is not applicable as this is not an AI-assisted device requiring human interpretation of results. No MRMC study was conducted.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This question is not applicable as this is not an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
This question is not applicable as there is no "ground truth" in the context of an AI algorithm's performance. The "truth" for this device modification is adherence to design specifications and successful functional performance as measured by engineering tests.
8. The sample size for the training set
This question is not applicable as this is not an AI/ML device, and therefore, there is no "training set."
9. How the ground truth for the training set was established
This question is not applicable as there is no "training set" and no "ground truth" in the AI/ML context.
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(57 days)
The Pathfinder Endoscope Cap is intended to be used in combination with compatible endoscopes to maintain the field of view during endoscopic procedures such as mucosal resection.
The Pathfinder Endoscope Cap is single-use distal attachment for endoscopes. It is an aid to endoscopic visualization and treatment in the gastrointestinal (GI) tract. The Pathfinder Endoscope Cap consists of a single piece of Pebax® in a symmetrical, tapering shape for placement on the distal tip of an endoscope. It is a short, transparent tube with an attaching portion used to connect the cap to an applicable endoscope, a distal portion that tapers into a narrower diameter opening, and a side hole for drainage to prevent fluids lodging on the surface of the endoscope. The device is intended to be used in combination with compatible endoscopes to maintain the field of view during endoscopic procedures such as mucosal resection in the GI tract.
The Pathfinder Endoscope Cap has the following physical and performance characteristics:
- Sterilized by ethylene oxide
- For single use
- Tapering distal tip
- Soft stop (tactile indicator of correct depth position)
- Compatible with endoscopes with 11.7 mm outer diameter distal ends, such as the Olympus PCF-H180A and PCF-H190
- Compatible with the Pathfinder Endoscope Overtube, which is intended for use with the same size endoscopes.
The provided text describes the 510(k) premarket notification for the "Pathfinder Endoscope Cap" and its substantial equivalence comparison to a predicate device. However, it does not include the detailed information requested regarding acceptance criteria and a study proving the device meets those criteria, specifically concerning performance metrics like sensitivity, specificity, or reader improvement with AI.
The document focuses on the Pathfinder Endoscope Cap's physical characteristics, materials, and a comparison with a predicate device based on general technological and performance criteria. It also mentions mechanical testing and biocompatibility testing.
Here's a breakdown of what is and is not in the provided text, structured as requested:
1. Table of acceptance criteria and the reported device performance:
This information is not provided in the text. The document states that the device underwent "mechanical testing" and "biocompatibility evaluation," but it does not list specific acceptance criteria (e.g., minimum tensile strength, maximum tracking force) or the quantitative results from these tests. It only lists the types of tests performed.
2. Sample size used for the test set and the data provenance:
This information is not provided in the text. The document mentions "mechanical testing" and "biocompatibility evaluation" but gives no details about the sample sizes used for these tests or the origin of any data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not provided in the text. The device is a physical endoscope cap, not an AI or diagnostic tool that would typically involve expert ground truth for performance evaluation in the context of medical image analysis.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
This information is not provided in the text. Similar to point 3, this type of method is relevant for expert-based evaluation of diagnostic or AI performance, which is not described for this physical device.
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:
This information is not provided in the text. The device is a physical endoscope cap, not an AI system. Therefore, an MRMC study comparing human reader performance with and without AI assistance is not applicable and not mentioned.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
This information is not provided in the text. As noted, this is a physical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
This information is not provided in the text. Given the device is a physical cap, typical "ground truth" as applied to diagnostic or AI performance evaluation (e.g., pathology, expert consensus) would not be relevant. The "ground truth" for its performance would likely be engineering specifications and functional testing results (e.g., does it fit correctly, does it maintain integrity during use), but these specific details are not elaborated.
8. The sample size for the training set:
This information is not provided in the text. Since this is not an AI device, there is no "training set."
9. How the ground truth for the training set was established:
This information is not provided in the text. As above, this is not an AI device, so this concept is not applicable.
Summary of available information regarding the "study" for the Pathfinder Endoscope Cap:
The document describes the following types of testing that were performed:
- Mechanical Testing:
- Dimensional and visual testing
- Cap tracking force (through compatible overtube)
- Cap tensile strength with tape
- Biocompatibility Testing: Conducted in accordance with ISO 10993-1 and relevant standards.
- Cytotoxicity
- Sensitization
- Irritation
- Systemic Toxicity
The stated conclusion (Section 1.10) is: "The enclosed biocompatibility and performance testing results demonstrate that the subject device is safe and effective for its intended use and substantially equivalent to the predicate."
However, the specific quantitative results of these tests and the acceptance criteria that those results met are not detailed in the provided FDA letters and summary. This document primarily serves as a notification of a 510(k) clearance and outlines the general characteristics and comparison to a predicate device, rather than a detailed study report.
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(94 days)
The Pathfinder™ Endoscope Overtube is intended to be used with an endoscope to facilitate intubation, change of endoscopes, and treatment in the gastrointestinal (GI) tract in adult patients (22 years of age and older).
The Pathfinder™ Endoscope Overtube (Pathfinder™) device consists of a flexible overtube that may be connected to vacuum for rigidization via an attached stopcock and is used with an endoscope for procedures in the gastrointestinal tract. The stopcock is connected to the vacuum line which is connected to free space within the device and is completely contained, forming the vacuumable volume. The stopcock has two positions: the first position connects the vacuumable volume within the device to atmosphere (vent) to stay in the flexible condition, and the second position connects the device to a source of vacuum to the rigid condition. When transitioned to the rigid condition, the device maintains its shape at the time of rigidization, allowing the endoscope to advance or withdraw relative to the overtube with minimal disturbance to surrounding anatomy. When transitioned to the flexible condition, the device is able to move relative to the patient anatomy and endoscope for navigation through the GI tract. The device is provided sterile (EO). After use, the device is discarded and disposed of in accordance with local regulations.
This document is a 510(k) premarket notification for a medical device called the Pathfinder™ Endoscope Overtube. It does not describe a study involving an AI-based medical device, nor does it include information on acceptance criteria for such a device.
The document focuses on demonstrating substantial equivalence to a predicate device (KMS Medical EndoGuide) primarily through:
- Comparison of technological characteristics: This involves comparing the design, materials, intended use, and other features of the new device to the predicate.
- Non-clinical performance data: This typically includes biocompatibility testing (cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity) and mechanical testing (simulated use, lubricity, insufflation, insertion/removal, steering, navigation, rigidization/de-rigidization, endoscope compatibility).
Therefore, I cannot provide the information requested in your prompt regarding acceptance criteria for an AI-based device and the study proving it meets them. The document does not contain any of the following:
- Table of acceptance criteria and reported device performance for an AI device.
- Sample size used for an AI test set or data provenance.
- Number of experts or their qualifications for establishing ground truth for an AI test set.
- Adjudication method for an AI test set.
- MRMC comparative effectiveness study or human reader improvement with AI assistance.
- Standalone algorithm performance.
- Type of ground truth used for an AI algorithm.
- Sample size for an AI training set.
- How ground truth for an AI training set was established.
The provided text is solely for a traditional medical device (an endoscope overtube) and its regulatory clearance process, not for an AI/ML-based diagnostic or therapeutic device.
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(73 days)
When intended for pedicle screw fixation from T1-S1, the indications include 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 disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis), tumor and failed previous fusion.
As a pedicle screw system placed between L3 and S1, the indications include Grade 3 or Grade 4 spondylolisthesis, when utilizing autograft or allograft, when affixed to the posterior lumbosacral spine, and intended to be removed after the solid fusion is established.
The existing, commercially available Zimmer Spine PathFinder NXT® Minimally Invasive Pedicle Screw System ("PathFinder NXT System") consists of various screws, rods and associated accessories and is intended to provide temporary stabilization following surgery to fuse the spine. The PathFinder NXT screws are polyaxial cannulated designs with a range of spinal rod lengths. The PathFinder NXT System allows the surgeon to place polyaxial pedicle screws either through an open or mini-open procedure. The percutaneous insertion rods are for minimally invasive procedures. The PathFinder NXT System is designed to aid in the surgical correction of several types of spinal conditions and intended only to provide stabilization during the development of a solid fusion with a bone graft. These implants are intended to be removed after the development of a solid fusion mass.
Additionally, the PathFinder NXT System includes instrumentation to facilitate the implantation of the PathFinder NXT implants.
The provided document describes the acceptance criteria and the study conducted for the Zimmer Spine PathFinder NXT® Minimally Invasive Pedicle Screw System to demonstrate its substantial equivalence to predicate devices, rather than an AI/ML device. Therefore, many of the requested fields, such as those pertaining to AI/ML specific studies (e.g., sample size for test set, data provenance, number of experts for ground truth, adjudication method, MRMC study, standalone performance, training set sample size, and ground truth for training set) are not applicable to this submission.
The acceptance criteria for this medical device are based on demonstrating substantial equivalence to legally marketed predicate devices in terms of design, materials, function, and intended use. The study focuses on performance testing to confirm this equivalence.
Here's a summary based on the provided text, with "N/A" for fields not relevant to this type of medical device submission:
1. Table of acceptance criteria and the reported device performance
| Acceptance Criteria (Demonstrates Substantial Equivalence via) | Reported Device Performance |
|---|---|
| Bench Testing (per ASTM F1717 & F1798 standards): | - Implants, polyaxial screws, and rods confirmed to have product performance suitable for intended use. |
| - Static compression bending | |
| - Static torsion testing | |
| - Dynamic compression bending | |
| - Static axial grip | |
| - Static torsion grip | |
| - Static flexion-extension bending | |
| Cadaver Lab Testing (Human Factors): | - Evaluated human factors regarding the combination of instrument design changes and labeling design changes, as well as interaction with implants. Confirmed substantial equivalence of these changes compared to predicate devices. |
| Biocompatibility Testing: | - Ensured the subject device materials are biocompatible after manufacturing, based on minor design changes made in comparison to predicate devices. |
| Sterilization, Dry Time, and Cleaning Testing: | - Ensured the subject device's steam sterilization, cleaning, and dry time requirements and instructions are substantially equivalent to the predicate devices. |
| Overall Substantial Equivalence: | - Zimmer Spine considers the subject device's product performance to be substantially equivalent to its predicate devices because there are no changes to the product performance specifications or device functional scientific technology compared to the predicate PathFinder NXT® Minimally Invasive Pedicle Screw System and Sequoia® Pedicle Screw System. |
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: Not explicitly stated for specific tests (e.g., number of screws, rods tested). The document mentions "components of the subject PathFinder NXT® Minimally Invasive Pedicle Screw System" were reviewed and tested.
- Data Provenance: Not specified, but generally, bench and cadaver lab testing for FDA submissions are conducted by manufacturers or contracted labs, likely within the United States or other regulated regions. The nature of the tests (bench, cadaver) is inherently prospective within a controlled lab environment.
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. This is a physical device and not an AI/ML system requiring expert-derived ground truth for image interpretation or diagnosis. The "ground truth" here is adherence to engineering standards and functional performance. However, cadaver lab testing would involve surgical experts for evaluation. The qualifications of these experts are not detailed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This is not an AI/ML system requiring adjudication of interpretations. Performance is measured against engineering standards and functional requirements.
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 not an AI/ML system.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is not an AI/ML system. The device itself is a "standalone" surgical implant system.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for this medical device's performance testing is based on:
- Engineering Standards: Adherence to established ASTM F1717 and F1798 standards for mechanical performance.
- Biocompatibility Standards: Ensuring materials meet medical-grade biocompatibility requirements.
- Functional Equivalence: Demonstrating that changes to the device (e.g., instrument design, labeling) do not negatively impact the intended function or safety when compared to predicate devices, including evaluation in cadaver labs for human factors.
8. The sample size for the training set
- Not applicable. This is not an AI/ML system that uses a training set.
9. How the ground truth for the training set was established
- Not applicable. This is not an AI/ML system.
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(42 days)
When intended for pedicle screw fixation from T1 -S1, the indications include 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 disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, and/or lordosis), tumor and failed previous fusion.
As pedicle screw system placed between L3 and S1, the indications include Grade 3 or Grade 4 spondylolisthesis, when utilizing autologous bone graft, when affixed to the posterior lumbosacral spine, and intended to be removed after the solid fusion is established.
The existing, commercially available Zimmer Spine PathFinder NXT® system consists of various screws, rods and associated accessories and is intended to provide temporary stabilization following surgery to fuse the spine. PathFinder NXT screws are polyaxial cannulated designs with a range of spinal rod lengths. PathFinder NXT allows the surgeon to place polyaxial pedicle screws either through an open or mini-open procedure. PathFinder NXT is designed to aid in the surgical correction of several types of spinal conditions and intended only to provide stabilization during the development of a solid fusion with a bone graft. These implants are intended to be removed after the development of a solid fusion mass. Additionally, the PathFinder NXT MIS System includes instrumentation to facilitate the implantation of the PathFinder NXT implants. The prior 510(k) for the PathFinder NXT MIS System included both Class I 510(k) exempt instrumentation and those instruments considered to the implant. PathFinder NXT was cleared via 510(k) #K100845 on 21 September 2010.
The Fixed Percutaneous Rod Holder accessory that is the subject of this premarket notification instrument is intended for use with the PathFinder NXT® Pedicle Screw System. This instrument is designed specifically for use with the rod implant component of the PathFinder NXT® Pedicle Screw System and, is considered an accessory to the implant. The Fixed Percutaneous Rod Holder holds and inserts a rod percutaneously through the extender sleeves which are positioned on the implanted screw head.
This 510(k) summary describes a modification to an existing medical device, the PathFinder NXT® Minimally Invasive Pedicle Screw System, specifically an accessory called the Fixed Percutaneous Rod Holder. The submission focuses on demonstrating substantial equivalence to the predicate device, not on proving de novo clinical effectiveness of the entire system.
Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criterion | Reported Device Performance | Comments |
|---|---|---|
| Reliability under anticipated clinical loads | "Design Verification Testing conducted, (1) reliability testing under anticipated clinical loads, ... demonstrated that the proposed device is substantially equivalent to the predicate device." | No specific quantitative metrics or thresholds for "reliability" are provided beyond the statement of substantial equivalence. |
| Fatigue strength under aggressive use simulations (beyond foreseeable misuse) | "...and (2) aggressive use simulations to test the fatigue strength when subjected to excessive loading beyond foreseeable misuse to determine survivability and extent of impact on intended use (function), demonstrated that the proposed device is substantially equivalent to the predicate device." | No specific quantitative metrics or thresholds for "fatigue strength" or "survivability" are provided beyond the statement of substantial equivalence. |
| Material composition | "are both manufactured from the same material (-17-4PH Stainless Steel)" and "the steel utilized for the proposed and unmodified instrument meet the ASTM A-564 'Standard Specification for Hot-Rolled and Cold-Finished Age-Hardening Stainless Steel Bars and Shapes'." | This is a direct comparison to the predicate and a conformity to a recognized standard. |
| Cleaning and Sterilization | "are cleaned and sterilized in the same way with the same parameters" | This is a direct comparison to the predicate. |
| General form and design | "similar designs" and "similar to the predicate version of the instrument in general form" | This is a qualitative comparison to the predicate. |
| Intended Use | "have the same intended use" | This is a direct comparison to the predicate. |
2. Sample Size Used for the Test Set and Data Provenance
This submission does not describe a clinical study with a "test set" in the traditional sense of patient data. The "tests" performed were engineering design verification tests on the device itself. Therefore, the concepts of "sample size for the test set" and "data provenance (e.g., country of origin of the data, retrospective or prospective)" are not applicable to this type of submission.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
There were no human experts used to establish ground truth for a test set of patient data, as this was a device modification and engineering verification testing. The "ground truth" for the performance was established by the physical testing against engineering specifications and comparison to the predicate device. Therefore, this information is not applicable.
4. Adjudication Method for the Test Set
As there was no clinical test set requiring human interpretation or labeling, an adjudication method is not applicable. The "adjudication" in this context would be the internal engineering and regulatory review process by Zimmer Spine, Inc. and ultimately the FDA.
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
This submission does not involve Artificial Intelligence (AI) or reader interpretation of images. It is for a physical medical device (pedicle screw system accessory). Therefore, an MRMC comparative effectiveness study is not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
This is a physical medical device, not an algorithm or AI system. Therefore, a standalone algorithm performance study is not applicable.
7. The Type of Ground Truth Used
For this device modification, the "ground truth" was established by:
- Engineering Specifications: The design verification tests measured physical properties and performance against defined engineering requirements and tolerances.
- Predicate Device Performance: The primary ground truth for substantial equivalence was the established performance and safety profile of the legally marketed predicate device (PathFinder NXT® Minimally Invasive Pedicle Screw System, #K100845). The modified accessory was deemed equivalent if it performed at least as well as the predicate under specified conditions and did not introduce new safety or effectiveness concerns.
- Industry Standards: Compliance with ASTM A-564 for material specification.
8. The Sample Size for the Training Set
There was no "training set" in the context of machine learning or AI. The design and manufacturing process for a physical device doesn't involve a training set. If interpreted in a broader sense as development and testing, the "samples" would be the prototype devices and test articles subjected to the design verification tests. The exact number of units tested is not specified in the summary but would be detailed in the full design verification report.
9. How the Ground Truth for the Training Set Was Established
As there was no "training set" in the AI sense, this question is not applicable. If referring to the development process of the device itself, the design "ground truth" was established through engineering design processes, material selection based on established standards, and performance goals derived from clinical needs and the performance of the predicate device.
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(180 days)
When intended for pedicle screw fixation from TI-S1, the indications include 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 disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, and/or lordosis), tumor, and failed previous fusion.
As a pedicle screw system placed between L3 and S1, the indications include Grade 3 or Grade 4 spondylolisthesis, when utilizing autograft or allograft, when affixed to the posterior lumbosacral spine, and intended to be removed after solid fusion is established.
The purpose of this 510(k) submission is to modernize the existing PathFinder Pedicle Screw System. A set of percutaneous insertion rods and new instrumentation have been included for minimally invasive procedures.
The Zimmer Spine PathFinder II system consists of polyaxial cannulated screws and rods and is intended to provide temporary stabilization following surgery to fuse the spine. A range of spinal rod lengths included in this system allows the surgeon to place polyaxial pedicle screws through an open or mini-open procedure. This system is intended only to provide stabilization during the development of a solid fusion with autograft or allograft. These implants are intended to be removed after the development of a solid fusion mass.
The Zimmer Spine PathFinder® II Minimally Invasive Pedicle Screw System is indicated for pedicle screw fixation from T1-S1 for immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion for various spinal instabilities or deformities. Additionally, for placement between L3 and S1, it is indicated for Grade 3 or Grade 4 spondylolisthesis.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Static and dynamic axial compression bending performance in accordance with ASTM F1717 | Performed as intended, demonstrating substantial equivalence to the predicate device. |
| Static torsion performance in accordance with ASTM F1717 | Performed as intended, demonstrating substantial equivalence to the predicate device. |
| Substantial equivalence to predicate device (Sequoia Pedicle Screw System) regarding intended use, indications for use, and no new safety/effectiveness issues. | The proposed device was found to be as safe and effective and performs as well as or better than the predicate device. |
2. Sample Size and Data Provenance:
- Test Set Sample Size: Not explicitly stated in the provided text for the mechanical tests. The document mentions "the proposed PathFinder II system and predicate Sequoia Pedicle Screw system" as the subjects of the tests, implying full systems were tested, but the number of individual components or systems tested is not specified.
- Data Provenance: The mechanical tests were performed by Zimmer Spine, Inc. The location of these tests and the nationality of the data are not specified. The tests are non-clinical, meaning they were likely conducted in a laboratory setting. This is a retrospective evaluation as it's part of a 510(k) submission for a device based on pre-existing technology and a predicate.
3. Number of Experts and Qualifications for Ground Truth:
- Not applicable directly. This information is typically relevant for studies involving human interpretation (e.g., imaging devices, diagnostic algorithms). For this device, the "ground truth" for mechanical performance is established by standardized testing protocols (ASTM F1717) and engineering principles, rather than expert consensus on a data set. The FDA's review and determination of substantial equivalence act as the ultimate "expert" validation in this regulatory context.
4. Adjudication Method for the Test Set:
- Not applicable directly. Adjudication methods (like 2+1, 3+1) are used to resolve disagreements among human experts when establishing ground truth. In this case, the evaluation relies on objective mechanical test results compared against established standards. The FDA's review process itself can be seen as a form of adjudication in determining regulatory acceptance based on the submitted data.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, an MRMC comparative effectiveness study was not done. This type of study is typically performed to assess the impact of a device or AI on human reader performance, especially in diagnostic or screening contexts. The Zimmer Spine PathFinder® II is a spinal implant, and its performance is evaluated through mechanical testing, not through human reader interpretation of images or data.
6. Standalone (Algorithm Only) Performance Study:
- Yes, in a sense, a standalone performance was done for the mechanical aspects. The mechanical tests (static and dynamic axial compression bending, static torsion) were performed on the device itself, functioning independently of human interaction during the test. The "performance" here refers to the device's physical response to simulated forces as measured against a standard, not an algorithm's output.
7. Type of Ground Truth Used:
- Standardized Mechanical Test Results/Engineering Principles. The "ground truth" for this device's performance is derived from the objective measurements obtained during mechanical testing in accordance with ASTM F1717 and the comparison of these results to those of the predicate device. The performance is deemed acceptable if it meets or exceeds the predicate's performance under these standardized conditions.
8. Sample Size for the Training Set:
- Not applicable. This device is a physical medical implant, not an AI/machine learning algorithm that requires a "training set" of data. The "training" for such devices involves design, engineering, and manufacturing processes informed by established biomechanical principles and material science.
9. How Ground Truth for the Training Set Was Established:
- Not applicable. As explained above, there is no "training set" in the context of an AI algorithm for this physical device. The design and validation of the device rely on engineering specifications, material testing, and the performance of previous or predicate devices.
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(89 days)
PathFinder - Mini-Open Posterior Approach
When intended for pedicle screw fixation from L1-S1, the indications include 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 disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis), tumor, and failed previous fusion.
As a pedicle screw system placed between L3 and S1, the indications include Grade 3 or Grade 4 spondylolisthesis, when utilizing autologous bone graft, when affixed to the posterior lumbosacral spine, and intended to be removed after solid fusion is established.
After solid fusion occurs, these devices serve no functional purpose and should be removed. In most cases, removal is indicated because the implants are not intended to transfer or support forces developed during normal activities. Any decision to remove the device must be made by the physician and the patient, taking info consideration the patient's general medical condition and the potential risk to the patient of a second surgical procedure.
The Abbott Spine, Inc. PathFinder® system is a pedicle screw fixation system designed to allow for use of an open or mini open surgical technique. The approved Pathfinder® system consists of various screws and rods and is intended to provide temporary stabilization following surgery to fuse the spine.
The subject device is the result of modifications to the existing PathFinder® 6.5mm polyaxial pedicle screws resulted in the inclusion of a 4.5mm polyaxial pedicle screw to the Pathfinder System. The subject device shares the same intended use and fundamental scientific technology as the predicate device.
The Abbott Spine PathFinder® System is a spinal fixation system. The submission K071174 specifically concerns modifications to the existing PathFinder® 6.5mm polyaxial pedicle screws to include a 4.5mm polyaxial pedicle screw.
Acceptance Criteria and Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Substantial equivalence to predicate device | Laboratory and bench testing results demonstrate substantial equivalence to the predicate device. |
Study Details
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Acceptance Criteria and Reported Device Performance: See table above.
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Sample size used for the test set and the data provenance:
- Sample Size: Not applicable. The submission states "NONCLINICAL PERFORMANCE AND CONCLUSION: Laboratory and bench testing results demonstrate that the proposed device is substantially equivalent to the predicate device. CLINICAL PERFORMANCE AND CONCLUSIONS: Clinical data and conclusions were not needed for this device." The evaluation relied on nonclinical (laboratory and bench) testing.
- Data Provenance: Not applicable, as no clinical data was required or provided. The nonclinical testing would have been conducted in a laboratory setting.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable, as no clinical ground truth was established. The device's performance was evaluated through nonclinical laboratory and bench testing against the predicate device.
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Adjudication method for the test set: Not applicable, as no clinical ground truth requiring adjudication was established.
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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 device is a mechanical spinal fixation system, not an AI-assisted diagnostic or therapeutic device.
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If a standalone (i.e. algorithm only without human-in-the loop performance) was done: Not applicable. This device is a mechanical implant, not an algorithm.
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The type of ground truth used: Not applicable for clinical ground truth. For the nonclinical evaluation, the "ground truth" was the
performance characteristics and regulatory standards applied to the predicate device (PathFinder® System K030625). The new device's
performance in laboratory and bench tests was compared to these established characteristics to demonstrate substantial equivalence. -
The sample size for the training set: Not applicable, as no clinical trials or machine learning models were involved.
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How the ground truth for the training set was established: Not applicable, as no clinical trials or machine learning models were involved.
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(189 days)
Stereotaxic spatial positioning and orientation of an instrument holder or tool guide to be used by a surgeon manually to guide standard neurosurgical instruments.
A stereotaxic system with a computer-controlled mechanical arm for spatial positioning and orientation of an instrument holder or tool guide. Guidance is based on a pre-operative plan developed with three-dimensional imaging software, and utilises CCD camera registration based on fiducial markers. The system is intended for use by neurosurgeons to guide standard neurosurgical instruments.
The provided documents do not contain the details required to complete your request. Specifically, the 510(k) summary for the "PathFinder Image Guided Surgical Localiser" (K041477) focuses on its equivalence to a predicate device, its intended use, and compliance with safety and EMC standards. It does not include information about:
- Acceptance criteria and reported device performance: There is no table or description of specific performance metrics or thresholds the device must meet. The document states "no substantive change in performance" compared to the predicate, but doesn't quantify it.
- Study details:
- Sample size for test set.
- Data provenance.
- Number and qualifications of experts for ground truth.
- Adjudication method.
- MRMC comparative effectiveness study or its effect size.
- Standalone algorithm performance.
- Type of ground truth used.
- Sample size for training set.
- How ground truth for the training set was established.
The document primarily asserts equivalence based on technological characteristics and safe use, rather than presenting a performance study with detailed acceptance criteria and results.
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