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510(k) Data Aggregation

    K Number
    K100409
    Date Cleared
    2010-06-23

    (127 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    POLARIS SPINAL SYSTEM, POLARIS/SYNERGY STRUCTUE ANTERIOR FIXATION SYSTEM

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

    The Polaris Spinal System is a non-cervical spinal fixation device intended for immobilization and stabilization as an adjunct to fusion as a pedicle screw fixation system, a posterior hook and sacral/iliac screw fixation system, or as an anterolateral fixation system. Pedicle screw fixation is limited to skeletally mature patients and for use with autograft. The device is indicated for all the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma, (i.e., fracture or dislocation), deformity or curvature (i.e., scoliosis, kyphosis, and lordosis), tumor, stenosis, pseudarthrosis, and failed previous fusion.

    The Ballista instruments are intended to be used with the 5.5 Polaris implants. The Ballista instruments when used with the Ballista cannulated screws and percutaneous rods, are indicated to provide the surgeon with a percutaneous approach for posterior spinal surgery for the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma, (i.e., fracture or dislocation), deformity or curvature (i.e., scoliosis, and lordosis), tumor, stenosis, pseudarthrosis, and failed previous fusion that warrant the use of a non-cervical spinal fixation device intended for use as a pedicle screw fixation system or sacral/iliac screw fixation system. Pedicle screw fixation is limited to skeletally mature patients and for use with autograft.

    The Accu Vision Instruments, when used with the Polaris Spinal System implants are indicated to provide the surgeon with a minimally invasive approach for posterior spinal surgery for the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma, (i.e., fracture or dislocation), deformity or curvature (i.e., scoliosis, kyphosis, and lordosis), turnor. stenosis, pseudarthrosis, and failed previous fusion that warrant the use of a non-cervical spinal fixation device intended for use as a pedicle screw fixation system or sacral/iliac screw fixation system. Pedicle screw fixation is limited to skeletally mature patients and for use with autograft.

    The dominos in the Polaris Spinal System can be used to connect the Polaris Spinal System to the Altius Spinal System, The Array Spinal System, the Biomet Omega21 Spinal System, or the Synergy Spinal System to achieve additional levels of fixation. Please refer to the individual system's Package Insert for a list of the indications for use for each system.

    Device Description

    This submission is a line extension to the Polaris Spinal System to add new titanium dominoes and washers to the system.

    AI/ML Overview

    The provided document is a 510(k) summary for the Polaris Spinal System, which is a medical device, and not an AI/ML device. Therefore, the common acceptance criteria for AI/ML devices such as accuracy, sensitivity, specificity, AUC, etc., and the associated study designs (MRMC, standalone, human-in-the-loop) are not applicable.

    Instead, this document describes a line extension to an existing spinal fixation system, focusing on its substantial equivalence to predicate devices based on mechanical performance testing.

    Here's an analysis based on the information provided regarding the device's performance:

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

    Acceptance Criteria (Mechanical)Reported Device Performance (Mechanical)
    Static Transverse Rotation (per ASTM 1798-97)Met all mechanical test requirements based on worst-case construct testing.
    Static Axial Slip (per ASTM 1798-97)Met all mechanical test requirements based on worst-case construct testing.
    Dynamic Axial Compression Bending-Fatigue (per ASTM 1717-04)Met all mechanical test requirements based on worst-case construct testing.

    2. Sample size used for the test set and the data provenance

    The document does not specify the exact sample size for the mechanical tests (e.g., number of constructs or replicates tested).
    The data provenance is not explicitly stated as country of origin, but it refers to "Mechanical testing was conducted in accordance with FDA's Guidance for Industry and FDA Staff - Spinal System 510(k)s dated May 3, 2004." This suggests in-house or contracted laboratory testing following US regulatory guidelines. The testing is prospective in the sense that the tests were performed specifically for this submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This is not applicable as the "ground truth" for a mechanical test is defined by the physical limits and standards set within the ASTM specifications, not by human expert assessment. The "experts" would be the engineers and technicians conducting the tests and interpreting the results against the ASTM standards.

    4. Adjudication method for the test set

    Not applicable for mechanical testing. The results are quantitative and compared against pre-defined ASTM standards.

    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 device is a physical spinal fixation system, not an AI diagnostic or assistive tool.

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

    Not applicable for a physical medical device.

    7. The type of ground truth used

    The "ground truth" for the performance evaluation is based on established industry standards and guidance documents for mechanical testing of spinal systems:

    • FDA's Guidance for Industry and FDA Staff - Spinal System 510(k)s dated May 3, 2004
    • ASTM 1798-97 (reapproved 2003) for Static Transverse Rotation and Static Axial Slip
    • ASTM 1717-04 for Dynamic Axial Compression Bending-Fatigue

    8. The sample size for the training set

    Not applicable. The concept of a "training set" is relevant for AI/ML models, not for mechanical testing of a medical device.

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

    Not applicable for mechanical testing.


    In summary, the study described in the K100409 document is a mechanical performance study designed to demonstrate substantial equivalence of the new components (titanium dominoes and washers) of the Polaris Spinal System to existing predicate devices. The acceptance criteria are defined by industry-standard ASTM tests and FDA guidance for spinal systems. The device "meets the acceptance criteria" by satisfying the requirements of these mechanical tests, which are intended to ensure the device's safety and effectiveness for its intended use as a spinal fixation system.

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