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510(k) Data Aggregation

    K Number
    K141397
    Date Cleared
    2014-06-26

    (29 days)

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

    SURE-LOK C EXTENDED TAB PEDICLE SCREW SYSTEM

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

    The Sure-Lok C Extended Tab PSS System is intended to provide 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 spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis).

    The Sure-Lok C Extended Tab Pedicle Screw System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4 of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; curvatures (i.e. scoliosis, kyphosis; and/or lordosis); spinal tumor; pseudarthrosis; and failed previous fusion.

    Device Description

    The Sure-Lok C Extended Tab PSS System is a top-loading, multiple component, posterior spinal fixation system which consists of cannulated and non-cannulated pedicle screws, straight and pre-curved rods, and locking cap screws. All components are available in a variety of sizes to match more closely the patient's anatomy. The Sure-Lok C Extended Tab PSS System is suitable for the following procedures: open, mini-open, percutaneous MIS approach, or a combination of any during the same procedure. All components are made from medical grade stainless steel, titanium or titanium alloy which comply with such standards as ASTM F-138, ASTM F-136, ISO5832-1 or ISO5832-3. All components are supplied clean and "NON STERILE."

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device (Sure-Lok C Extended Tab Pedicle Screw System), which focuses on demonstrating substantial equivalence to predicate devices rather than proving a device meets specific acceptance criteria through a clinical study. Therefore, most of the requested information regarding clinical study performance, sample sizes, expert ground truth, and comparative effectiveness is not applicable or not available in this document.

    Here's an analysis based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    This document does not present acceptance criteria in terms of performance metrics (e.g., sensitivity, specificity, accuracy) that would typically be found for an AI/algorithm-based device. Instead, it focuses on compliance with established engineering standards for mechanical and material properties.

    Acceptance Criteria (Standards Compliance)Reported Device Performance
    ASTM F-138 (Medical Grade Stainless Steel)Complies with standard
    ASTM F-136 (Medical Grade Titanium/Titanium Alloy for Long Arm Cannulated Screw)Complies with standard (specifically Ti-6AI-4V ELI)
    ISO5832-1 (Implants for surgery - Metallic materials - Part 1: Wrought stainless steel)Complies with standard
    ISO5832-3 (Implants for surgery - Metallic materials - Part 3: Wrought titanium 6-aluminium 4-vanadium alloy)Complies with standard
    ASTM F1717-12 (Spinal Implant Constructs in a Corpectomy Model)Complies with standard (for mechanical performance overall)

    The justification for meeting these criteria is a statement of compliance with these recognized standards, rather than presenting detailed test reports. The document states: "Consistent with FDA's guidance document entitled "Use of Standards in Substantial Equivalence Determinations" (...) Precision Spine is including this statement that the Sure-Lok C Extended Tab Pedicle Screw System complies with the following recognized standards instead of providing the test reports demonstrating compliance with these standards."

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

    Not applicable/Not available. No clinical test set or data provenance from patients is mentioned. The "study" here is demonstrating compliance with engineering standards.

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

    Not applicable/Not available. No expert review or ground truth establishment relevant to an AI/algorithm is described. The ground truth for this type of device is compliance with material and mechanical standards.

    4. Adjudication method for the test set

    Not applicable/Not available. There is no test set in the context of an algorithm's performance review.

    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/Not available. This device is a pedicle screw system, a physical implant, not an AI or imaging diagnostic tool. Therefore, an MRMC study is not relevant to its approval.

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

    Not applicable/Not available. This device is a physical pedicle screw system, not an algorithm.

    7. The type of ground truth used

    The "ground truth" for this device's approval is based on:

    • Compliance with recognized engineering and material standards: ASTM F-138, ASTM F-136, ISO5832-1, ISO5832-3, and ASTM F1717-12. This establishes the physical and mechanical properties.
    • Substantial Equivalence to predicate devices: The modifications (slightly increased length of extended tab screw, changed rod edges) are deemed not to raise new questions of safety or effectiveness because "The Sure-Lok C Extended Tab Pedicle Screw System has the same intended use and fundamental scientific technology as our previously cleared Pedicle Screw System devices."

    8. The sample size for the training set

    Not applicable/Not available. There is no "training set" in the context of a pedicle screw system as it is not an AI or learning algorithm.

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

    Not applicable/Not available. As there is no training set for an AI, this question is not relevant.

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