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510(k) Data Aggregation

    K Number
    K141835
    Manufacturer
    Date Cleared
    2014-09-10

    (65 days)

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

    ROMEO POSTERIOR OSTEOSYNTHESIS SYSTEM PREBENT CROSS-CONNECTORS; PREBENT RODS

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

    ROMEO® posterior osteosynthesis system is intended to provide immobilization 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: severe spondylolisthesis (grades 3 and 4) of the L5-S V vertebra: degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis).

    When used as a posterior, non-cervical, non-pedicle screw fixation system, ROMEO posterior osteosynthesis system is intended for the following indications: degenerative disc disease (DDD) (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion

    Device Description

    The Romeo® posterior fixation system comprises polyaxial screws, monoaxial screws, spondylolisthesis screws, setscrew, straight and pre-bent Titanium or CoCr rods, and cross connectors. The Romeo® Polyaxial Screws come in various lengths (from 25 to 90 mm) and diameters (4.0, 4.5, 5.0, 5.5, 6.0, 7.0 and 8.0 mm) to accommodate different patient anatomies. The modification to Romeo® posterior osteosynthesis system consists of the addition of a prebent cross connectors and prebent CoCr rods.

    AI/ML Overview

    This document is a 510(k) premarket notification for the ROMEO® Posterior Osteosynthesis System, seeking to demonstrate substantial equivalence to previously cleared predicate devices. It does not contain information about the acceptance criteria or a study proving the device meets specific performance metrics in the way a clinical study for an AI/ML device would.

    Instead, this document focuses on mechanical and material equivalence for a traditional medical device (spinal system components). Therefore, I cannot fulfill your request for:

    • A table of acceptance criteria and the reported device performance: This document doesn't define pass/fail criteria for a study in terms of accuracy, sensitivity, specificity, etc., as it's not a diagnostic or AI/ML device. The "performance" described relates to the physical characteristics and intended use of the spinal components.
    • Sample size and data provenance for a test set: No test set in the context of an AI/ML or diagnostic study is described.
    • Number of experts and qualifications for ground truth: Not applicable, as there's no diagnostic ground truth being established.
    • Adjudication method: Not applicable.
    • MRMC comparative effectiveness study: Not applicable.
    • Standalone (algorithm only) performance: Not applicable, as this is a physical medical device.
    • Type of ground truth used: Not applicable.
    • Sample size for the training set: Not applicable.
    • How ground truth for the training set was established: Not applicable.

    What the document does convey regarding "acceptance criteria" and "study" is related to engineering principles and regulatory compliance for a spinal implant system:

    • Acceptance Criteria (Implicitly): The "acceptance criteria" for this device are implicitly tied to demonstrating substantial equivalence to predicate devices. This involves showing that the new components (prebent cross connectors and prebent CoCr rods) have equivalent intended use, material, design, mechanical properties, and function to existing cleared devices. The "special controls established for Pedicle screw spinal system" and the "Spinal System 510(k)s - Guidance for Industry and FDA Staff Document" (May 3, 2004) serve as the regulatory framework and implicitly contain design and performance expectations.
    • "Study" (Demonstration of Equivalence): The "study" isn't a traditional clinical trial or performance study with human subjects, but rather a technical assessment and comparison. The document states:
      • "No additional testing has been performed for the added prebent cross connectors and prebent CoCr rods." This is a crucial statement and indicates that the manufacturer is relying on the established equivalence of the materials and design to existing cleared components.
      • "Verification Activity and Validation Activity demonstrate that the added prebent cross connectors and prebent CoCr rods are substantially equivalent to previously cleared devices." This suggests that internal engineering verification and validation activities (e.g., material testing, mechanical load testing, fatigue testing, dimensional analysis) were conducted to ensure the new components meet the same functional and safety profiles as the predicate components, even if no new testing was deemed necessary beyond that for existing components.

    In summary, this document is a regulatory filing for a physical medical device (spinal implant components), not for an AI/ML diagnostic or prognostic tool. Therefore, the questions related to clinical performance metrics, ground truth, and reader studies are not applicable to the information provided.

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