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510(k) Data Aggregation
(117 days)
TALON SPINAL SYSTEM
The Spine 360 Talon Spinal 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 thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudoarthrosis).
The Talon Spinal Fixation System was cleared for use via K071824, and is comprised of polyaxial screws, locking plugs, spinal rods and rod to rod connectors. The Talon System can be used for single or multiple level fixations. All components are manufactured from titanium alloy (Ti-6AI-4V ELI) that conforms to ASTM F136. Spine 360 proposes to add new smaller diameter (4.5mm) screws in various lengths, cannulated screws in various diameters and lengths, pedicle screw spacers as well as the minimally invasive surgical technique for use with the Spine 360 Talon Spinal System. The new components are based upon the same fundamental scientific technology and do not alter the indications for use as compared to the existing system.
This excerpt focuses on the Spine 360 Talon Spinal System, a medical device, and the documentation provided does not include the detailed information about acceptance criteria and a study design that you are requesting for a typical AI/software-as-a-medical-device (SaMD) submission.
The provided document is a 510(k) Summary for a Premarket Notification (K102995) for a Spinal Fixation System. This is a physical medical device (implants for spinal fusion) and the regulatory submission heavily relies on non-clinical (mechanical) testing and demonstration of substantial equivalence to predicate devices, rather than clinical performance studies with acceptance criteria based on human or AI-assisted performance metrics.
Therefore, I cannot directly extract the following information from the provided text:
- A table of acceptance criteria and the reported device performance: The acceptance criteria for this device are related to mechanical properties (e.g., strength, stiffness, fatigue) and functional equivalence to predicate devices, not diagnostic performance metrics like sensitivity, specificity, or AUC.
- Sample size used for the test set and the data provenance: Not applicable in the context of this device's testing. Mechanical tests involve test specimens, not patient data.
- Number of experts used to establish the ground truth for the test set and the qualifications: Not applicable. Ground truth for mechanical testing would be direct measurements from the tests themselves.
- Adjudication method: Not applicable.
- If a multi reader multi case (MRMC) comparative effectiveness study was done: Not applicable, as this is not a diagnostic device involving human readers.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable, as this is a physical implant.
- The type of ground truth used: For this device, the "ground truth" for non-clinical testing refers to the physical properties measured during mechanical tests against established ASTM standards and against predicate device performance.
- The sample size for the training set: Not applicable, as this is not an AI/ML device requiring a training set.
- How the ground truth for the training set was established: Not applicable.
What is present in the document is:
1. Acceptance Criteria (implied through non-clinical test summary and substantial equivalence justification):
The acceptance criteria for this type of device are primarily based on:
- Meeting or exceeding the performance standards of recognized ASTM standards (e.g., ASTM F1717-09 for Static Compression Bending, Dynamic Compression Bending).
- Demonstrating equivalence or better performance (in terms of compression bending performance, stiffness, and dynamic compression bending fatigue strength) compared to the predicate devices.
- Providing stability greater than tolerated thresholds in range of motion and stiffness limits of the human lumbar spine, and adequately stabilizing a fusion site.
2. Reported Device Performance (Summary):
The document states:
- "The Spine 360 Spinal Fixation System proposed additional 4.5 screws, cannulated screws and spacers demonstrated equivalence or better in compression bending performance and stiffness to the predicate device listed."
- "The dynamic compression bending fatigue strength for the Spine 360 Spinal Fixation System had already demonstrated a greater endurance strength than predicates referenced."
- "The Spine 360 Spinal Fixation System including the smaller 4.5 screws, cannulated screws and spacers will provide stability greater than the tolerated thresholds in range of motion and stiffness limits of the human lumbar spine and will adequately stabilize a fusion site."
In summary, the provided document describes a medical device undergoing a 510(k) clearance process based on substantial equivalence and mechanical testing, not a software or AI device requiring the type of clinical validation study details you've requested.
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