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510(k) Data Aggregation

    K Number
    K050117
    Date Cleared
    2005-02-17

    (30 days)

    Product Code
    Regulation Number
    888.3060
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    MODIFICATION TO PYRAMID ANTERIOR PLATE FIXATION SYSTEM

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

    The MEDTRONIC SOFAMOR DANEK PYRAMID® ANTERIOR PLATE Fixation System is indicated for use as an anteriorly placed supplemental fixation device for the lumbosacral level below the bifurcation of the vascular structures.

    When properly used, this system will help provide temporary stabilization until a solid spinal fusion develops. Specific indications include: 1) Degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); 2) Pseudoarthrosis; 3) Spondylolysis; 4) Spondylolisthesis; 5)Fracture; 6) Neoplastic disease; 7) Unsuccessful previous fusion surgery; 8) Lordotic deformities of the spine; 9) Idiopathic thoracolumbar or lumbar scoliosis; 10) Deformity (i.e., scoliosis, lordosis, and/or kyphosis) associated with deficient posterior elements such as that resulting from laminectomy, spina bifida, or myelomenigocele; and/or 11) Neuromuscular deformity (i.e., scoliosis, lordosis, and / or kyphosis) associated with pelvic obliquity.

    Device Description

    The PYRAMID® ANTERIOR PLATE Fixation System consists of a variety of plates and screws, as well as ancillary products and instrument sets. The PYRAMID® ANTERIOR PLATE Fixation System implant components can be locked into a variety of configurations, with each construct being tailor-made for the individual case. The implant components are made of titanium alloy (Ti-6A1-4V) described by ASTM Standard F136 or ISO 5832-3. Stainless steel and titanium implant components must not be used together in a construct.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the PYRAMID® ANTERIOR PLATE Fixation System, specifically to include modified screws.

    Based on the provided text, there is no study described that demonstrates the device meets specific acceptance criteria in terms of performance metrics like accuracy, sensitivity, or specificity for an AI/ML powered device.

    This document is a regulatory submission for a medical device (a spinal fixation system), not a study report for an AI/ML algorithm. The "acceptance criteria" and "device performance" in this context refer to manufacturing, material specifications, and substantial equivalence to a previously cleared predicate device, rather than the performance of an AI model.

    Therefore, many of the requested categories for AI/ML device studies (like sample sizes for test/training sets, expert ground truth, MRMC studies, standalone performance, etc.) are not applicable to this document.

    However, I can extract information relevant to the regulatory approval process and the broader context of device "performance" in a non-AI sense.

    Here's the breakdown based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied by 510(k) Process)Reported Device Performance (Implied by 510(k) Clearance)
    Substantial Equivalence: Device (including modified screws) is as safe and effective as a legally marketed predicate device.The FDA reviewed the 510(k) and determined the device is substantially equivalent to legally marketed predicate devices.
    Material Compatibility/Safety: Components made of suitable biocompatible materials.Implied by the use of titanium alloy (Ti-6A1-4V) described by ASTM Standard F136 or ISO 5832-3.
    Intended Use Compatibility: Device's design and materials support its specified indications for use.The system is indicated for use as an anteriorly placed supplemental fixation device for the lumbosacral level and helps provide temporary stabilization until solid spinal fusion develops.
    Manufacturing Quality: Adherence to General Controls provisions (e.g., GMP requirements, labeling).FDA states the device is subject to general controls provisions of the Act, including requirements for annual registration, listing, good manufacturing practice, and labeling.

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

    • Not Applicable. This document is not about a study involving a test set for an AI/ML algorithm. The 510(k) process relies on demonstrating substantial equivalence to a predicate device, which typically involves engineering testing, material testing, and potentially clinical literature review, rather than a "test set" in the AI sense.

    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. No explicit "ground truth" establishment for a test set is described in the context of an AI/ML device. The "experts" involved would be regulatory reviewers at the FDA (Celia M. Witten, Ph.D., M.D., Director, Division of General, Restorative and Neurological Devices Office of Device Evaluation) assessing the submission.

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

    • Not Applicable. No test set or adjudication method for AI/ML performance 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. An MRMC study is not mentioned as this relates to an AI/ML device.

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

    • Not Applicable. This is not an AI/ML device.

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

    • Not Applicable in the AI/ML sense. The "ground truth" for this regulatory submission is the established safety and effectiveness of the predicate device (K013665), to which the current device is deemed substantially equivalent.

    8. The sample size for the training set

    • Not Applicable. No training set is involved for an AI/ML algorithm.

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

    • Not Applicable. No training set is involved for an AI/ML algorithm.

    In summary, this document is a regulatory clearance for a physical medical device (spinal fixation system) based on substantial equivalence, not a performance study of an AI/ML powered device.

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    K Number
    K021226
    Date Cleared
    2002-05-13

    (25 days)

    Product Code
    Regulation Number
    888.3060
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    MODIFICATION TO PYRAMID ANTERIOR PLATE FIXATION SYSTEM

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

    The Medtronic Sofamor Danek PYRAMID™ ANTERIOR PLATE Fixation System is indicated for use as an anteriorly placed supplemental fixation device for the lumbosacral level below the bifurcation of the vascular structures.

    When properly used, this system will help provide temporary stabilization until a solid spinal fusion develops. Specific indications include: 1) Degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); 2) Pseudoarthrosis; 3) Spondylolysis; 4) Spondylolisthesis; 5)Fracture; 6) Neoplastic disease; 7) Unsuccessful previous fusion surgery; 8) Lordotic deformities of the spine; 9) Idiopathic thoracolumbar or lumbar scoliosis; 10) Deformity (i.e., scoliosis, lordosis, and/or kyphosis) associated with deficient posterior elements such as that resulting from laminectomy, spina bifida, or myelomenigocele; and/or 11) Neuromuscular deformity (i.e., scoliosis, lordosis, and / or kyphosis) associated with pelvic obliquity.

    Device Description

    The PYRAMID™ ANTERIOR PLATE Fixation System is a supplemental fixation construct consisting of a variety of shapes and sizes of plates, and screws, as well as ancillary products and instrument sets. The PYRAMID™ ANTERIOR PLATE Fixation System implant components can be locked into a variety of configurations, with each construct being tailor-made for the individual case. The implant components are made of titanium alloy (Ti-6A1-4V) described by ASTM Standard F136 or ISO 5832-3. Stainless steel and titanium implant components must not be used together in a construct.

    AI/ML Overview

    The provided text describes a 510(k) submission for the Medtronic Sofamor Danek PYRAMID™ ANTERIOR PLATE Fixation System. This document focuses on demonstrating substantial equivalence to a predicate device through mechanical testing, not a study involving human readers or AI. Therefore, most of the requested information regarding acceptance criteria for AI/human reader performance is not applicable.

    Here's an analysis of the provided information:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Substantial Equivalence to Predicate DeviceDetermined to be substantially equivalent to K013665 (PYRAMID™ ANTERIOR PLATE Fixation System).
    Mechanical Functionality & Safety TestsMechanical testing was performed.
    Compliance with Regulatory StandardsImplants made of titanium alloy (Ti-6A1-4V) described by ASTM Standard F136 or ISO 5832-3.

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

    • Not Applicable. This submission is for a medical device (spinal fixation system) and its substantial equivalence is demonstrated through mechanical testing, not a clinical study with a test set of human subjects or data.

    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. Ground truth in the context of expert consensus is not relevant for this type of mechanical device submission. The "ground truth" here would be the performance of the predicate device against which the new device is compared.

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

    • Not Applicable. This is not a study requiring adjudication of expert opinions.

    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 not an AI-assisted diagnostic or interpretive device.

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

    • No. This is a physical medical implant, not an algorithm.

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

    • The "ground truth" or benchmark here is the performance of the predicate device (K013665, PYRAMID™ ANTERIOR PLATE Fixation System) as established by its clearance and subsequent safety and effectiveness. The new device's mechanical performance is compared to this established predicate.

    8. The sample size for the training set

    • Not Applicable. There is no "training set" in the context of mechanical testing for substantial equivalence.

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

    • Not Applicable. There is no "training set" or corresponding ground truth establishment in this context.
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    K Number
    K013665
    Date Cleared
    2002-01-29

    (84 days)

    Product Code
    Regulation Number
    888.3060
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    PYRAMID ANTERIOR PLATE FIXATION SYSTEM

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

    The Medtronic Sofamor Danek PYRAMID™ ANTERIOR PLATE Fixation System is indicated for use as an anteriorly placed supplemental fixation device for the lumbosacral level below the bifurcation of the vascular structures.

    When properly used, this system will help provide temporary stabilization until a solid spinal fusion develops. Specific indications include: 1) Degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); 2) Pseudoarthrosis; 3) Spondylolysis; 4) Spondylolisthesis; 5)Fracture; 6) Neoplastic disease; 7) Unsuccessful previous fusion surgery; 8) Lordotic deformities of the spine; 9) Idiopathic thoracolumbar or lumbar scoliosis; 10) Deformity (i.e., scoliosis, lordosis, and/or kyphosis) associated with deficient posterior elements such as that resulting from laminectomy, spina bifida, or myelomenigocele; and/or 11) Neuromuscular deformity (i.e., scoliosis, and / or kyphosis) associated with pelvic obliquity.

    Device Description

    The PYRAMID™ ANTERIOR PLATE Fixation System is a supplemental fixation construct consisting of a variety of shapes and sizes of plates, and screws, as well as ancillary products and instrument sets. The PYRAMID™ ANTERIOR PLATE Fixation System implant components can be locked into a variety of configurations, with each construct being tailor-made for the individual case. The implant components are made of titanium alloy (Ti-6A 1- 4V) described by ASTM Standard F136 or ISO 5832-3. Stainless steel and titanium implant components must not be used together in a construct.

    AI/ML Overview

    This document is a 510(k) summary for a medical device called the Medtronic Sofamor Danek PYRAMID™ ANTERIOR PLATE Fixation System. It describes the device, its intended use, and its substantial equivalence to previously cleared predicate devices.

    Here's an analysis of the provided information, specifically addressing the acceptance criteria and study aspects you've requested.

    It's important to note that this document is a 510(k) summary, which is a premarket notification for devices demonstrating substantial equivalence to a predicate device. It typically does not contain detailed clinical trial data or performance metrics in the same way a PMA (Premarket Approval) application would for novel, high-risk devices. The "study" here refers to mechanical testing for equivalence, not a clinical study on human subjects.


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

    Acceptance Criteria (Implied)Reported Device Performance
    Substantial equivalence to predicate devices (K922543, K010632) for intended use and safety/functionality."Mechanical testing was performed on the PYRAMID™ ANTERIOR PLATE Fixation System, which determined it to be substantially equivalent to the ZPLATE-ATL™ Anterior Fixation System and the BUTTERFLY™ PLATE Fixation System."
    Meeting relevant ASTM/ISO standards for materials."The implant components are made of titanium alloy (Ti-6Al-4V) described by ASTM Standard F136 or ISO 5832-3."

    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 in terms of number of physical components tested, but implies sufficient samples were used for mechanical testing to establish equivalence. This is not a clinical "test set" in the traditional sense of patient data.
    • Data Provenance: The origin of the mechanical testing data (e.g., specific lab, country) is not specified. Given Medtronic's location in Memphis, TN, it's likely U.S.-based or from a reputable international testing facility. This would be considered "prospective" testing as it was conducted specifically for this submission.

    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)

    This section is not applicable to this type of submission. Ground truth established by medical experts (e.g., radiologists) is relevant for diagnostic devices or AI algorithms interpreting medical images. For a spinal fixation system, "ground truth" for mechanical performance is established by engineering standards and comparative testing to predicate devices, typically assessed by engineers and regulatory bodies.

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

    This is not applicable. Adjudication methods like 2+1 (two readers agree, third resolves discrepancy) are used for clinical studies involving human interpretation (e.g., image reading). Mechanical testing relies on objective measurements against defined criteria.

    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 is not applicable. This device is a passive implantable medical device, not an AI-powered diagnostic or assistive tool for human readers. Therefore, an MRMC study related to AI assistance would not be performed for this product.

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

    This is not applicable. This device does not involve an algorithm.

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

    For the mechanical testing performed, the "ground truth" would be the established performance characteristics and safety profiles of the predicate devices based on their own clearances and recognized engineering standards (e.g., ASTM/ISO). The new device's performance is compared to these benchmarks to demonstrate substantial equivalence.

    8. The sample size for the training set

    This is not applicable. This device is a physical implant, not a machine learning algorithm requiring a training set.

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

    This is not applicable as it applies to machine learning algorithms.


    Summary of the "Study" mentioned:

    The study referred to in this 510(k) summary is mechanical testing.

    • Objective: To demonstrate that the PYRAMID™ ANTERIOR PLATE Fixation System is "substantially equivalent" in terms of functionality and safety to the predicate devices (ZPLATE-ATL™ Anterior Fixation System and BUTTERFLY™ PLATE Fixation System).
    • Methodology: Mechanical tests were performed. While specifics of the tests (e.g., fatigue testing, static testing, torsional testing) are not detailed in this summary, they would typically involve applying forces and stresses to the device and comparing its performance (e.g., strength, durability, screw pull-out resistance, plate bending strength) against those of the predicate devices.
    • Proof of Meeting Acceptance Criteria: The statement "Mechanical testing was performed... which determined it to be substantially equivalent..." serves as the proof that the device meets the (implied) acceptance criteria of performance comparable to the cleared predicate devices. This equivalence demonstrates that it is as safe and effective as the devices already on the market.
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