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510(k) Data Aggregation
(77 days)
The Spineology Threshold™ Pedicular Fixation System is intended for posterior, non-cervical fixation as an adjunct to fusion in skeletally mature patients for the following indications: degenerative disc disease (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, kyphosis and/or lordosis); tumor; pseudoarthrosis; and/or failed previous fusion.
The Spineology Threshold Pedicular Fixation System consists of cannulated screws (titanium allov), curved and straight rods (titanium alloy), and adjustable Connector (titanium alloy), and fixed Connex Rod Connector (titanium alloy) devices to allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Threshold cannulated screws are available with or without a hydroxyapatite coating. The system is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine. The cannulated screws can be placed in the pedicles in a variety of trajectories ranging from the standard anatomic transpedicular path projected medially toward the ventral vertebral body, to a caudocephalad path sagittally and a laterally directed path in the transverse plane.
Spineology Connex Cross Connector devices are transversely-placed implants that are intended to connect the rod on one side of the spinal construct to the rod on the other side. These devices are manufactured from titanium alloy and are adjustable to allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. ConneX Cross Connector devices are intended to be used with Spineology's Fortress™, Threshold V2™, and Palisade™ Pedicular Fixation Systems which are intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine.
Spineology Connex Rod Connector devices are implants that are intended to connect two rods in a spinal construct. These devices are manufactured from titanium alloy and the components allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. ConneX Rod Connector devices are intended to be used with Spineology's Fortress™, Threshold™, Threshold™ V2, and Palisade™ Pedicular Fixation Systems which are intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine.
This document is a 510(k) premarket notification for a medical device, the Spineology Threshold™ Pedicular Fixation System. It focuses on demonstrating that new components (ConneX™ Cross Connector, ConneX™ Rod Connector, and 5.5 titanium Straight Rod devices) are substantially equivalent to previously cleared predicate devices. Therefore, the information provided primarily concerns non-clinical testing to support this substantial equivalence, rather than a clinical study evaluating the device's diagnostic performance for a specific condition.
Based on the provided text, here's a breakdown regarding acceptance criteria, study details, and related information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state numerical "acceptance criteria" in terms of specific performance metrics (like accuracy, sensitivity, specificity) for a diagnostic device, nor does it report "device performance" in similar terms. Instead, the "acceptance criteria" are implied by the performance standards outlined in ASTM F1717, ASTM F1798, and ASTM F2193 for mechanical testing, and ANSI/AAMI ST-72:2011 for bacterial endotoxin testing. The "reported device performance" is a statement that the devices were tested in accordance with these standards.
| Acceptance Criteria (Implied Standard) | Reported Device Performance (Compliance Statement) |
|---|---|
| Mechanical performance as defined by ASTM F1717 (Static Cantilever Bending) | Testing conducted in accordance with FDA Guidance: Spinal System 510(k)s (2004) and ASTM F1717-15. |
| Mechanical performance as defined by ASTM F1798 (Static Compression Bending) | Testing conducted in accordance with FDA Guidance: Spinal System 510(k)s (2004) and ASTM F1798. |
| Mechanical performance as defined by ASTM F2193 (Flexural Grip, Dynamic Compression Bending) | Testing conducted in accordance with FDA Guidance: Spinal System 510(k)s (2004) and ASTM F2193. (Specific tests mentioned: Flexural Grip, Dynamic Compression Bending). |
| Bacterial endotoxin limits as defined by ANSI/AAMI ST-72:2011 | Bacterial endotoxin testing (BET) was conducted in accordance with ANSI/AAMI ST-72:2011. |
Note: The document states that these tests were performed and implies successful completion to demonstrate substantial equivalence, but it does not provide the raw data or specific quantitative results of these tests, which would typically be included in a full submission rather than this summary letter.
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: The document does not specify a "sample size" in terms of individual patients or cases for diagnostic accuracy. Instead, it refers to "representative worst case" devices for mechanical testing. The number of devices tested for each mechanical or bacterial endotoxin test is not disclosed.
- Data Provenance: The data is from non-clinical (laboratory) testing, not from human subjects. Therefore, there is no country of origin or retrospective/prospective distinction for patient data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This section is not applicable as the document describes non-clinical mechanical and biological (endotoxin) testing of manufacturing components, not a clinical study requiring expert assessment for ground truth.
4. Adjudication Method for the Test Set
This section is not applicable as the document describes non-clinical mechanical and biological (endotoxin) testing.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done
No, a Multi Reader Multi Case (MRMC) comparative effectiveness study was not reported in this document. This type of study is typically conducted for diagnostic or AI-assisted devices to evaluate human performance with and without AI. This submission is for surgical implants, and the testing focuses on the mechanical and biological safety of the components.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm performance study was not reported. This device is not an algorithm or AI system, but rather physical implant components.
7. The Type of Ground Truth Used
For the mechanical testing, the "ground truth" (or reference standard) is the published performance specifications and methodologies within the cited ASTM standards. For bacterial endotoxin testing, the ground truth is the validated limits and methodologies within ANSI/AAMI ST-72:2011.
8. The Sample Size for the Training Set
This section is not applicable. This document describes the clearance of physical medical device components (implants), not an AI/ML algorithm that would have a training set.
9. How the Ground Truth for the Training Set Was Established
This section is not applicable as there is no training set for an AI/ML algorithm.
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(25 days)
The Threshold™ Pedicular Fixation System is intended for posterior, non-cervical fixation as an adjunct to fusion in skeletally mature patients for the following indications: degenerative disc disease (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, kyphosis and/or lordosis); turnor; pseudoarthrosis; and/ or failed previous fusion.
Spineology's Threshold Pedicular Fixation System consists of cannulated and solid titanium alloy screws and rods to allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Threshold cannulated and solid screws are available with or without a hydroxyapatite coating. The system is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine. The cannulated and solid screws can be placed in the pedicles in a variety of trajectories ranging from standard anatomic transpedicular path projected medially toward the ventral vertebral body, to a caudocephalad path sagittally and a laterally directed path in the transverse plane.
This document describes acceptance criteria and studies for the Threshold™ Pedicular Fixation System, specifically for the addition of uncoated and hydroxyapatite (HA) coated Threshold solid pedicle screws.
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria Category | Specific Test/Requirement | Acceptance Criteria | Reported Device Performance |
|---|---|---|---|
| Mechanical Performance | Static Fatigue Properties (ASTM F1798-97) | Must meet or exceed properties of predicate devices | Demonstrated substantial equivalence to predicate devices (specific values not provided in this document, but implied by claiming "sufficient" demonstration). |
| Metallic Bone Screws (ASTM F543-13) | Must meet or exceed properties of predicate devices | Demonstrated substantial equivalence to predicate devices. | |
| Spinal Implant Constructs (ASTM F1717-13) | Must meet or exceed properties of predicate devices | Demonstrated substantial equivalence to predicate devices. | |
| Biocompatibility | Bacterial Endotoxin Testing (BET) / Limulus amoebocyte lysate (LAL) test (ANSI/AAMI/ST72) | < 20 EU/Device | Performed (specific results of testing not provided but implied to be acceptable as no issues were noted). |
| Material Equivalence | Base Materials | Same as predicate devices | Confirmed to be the same base materials. |
| Coating Equivalence | Hydroxyapatite (HA) Coating | Same as predicate devices | Confirmed to be the same HA coating. |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not explicitly stated as traditional "test sets" for a performance study were not used for this submission. The submission relies on non-clinical testing (mechanical testing, finite element analysis) and comparison to predicate devices, rather than a clinical study with human subjects.
- Data Provenance: The mechanical testing was performed in accordance with ASTM standards, implying laboratory-based testing. The finite element analysis (FEA) is a computational method. This is retrospective in the sense that it relies on existing data and models or newly generated data in a lab setting, rather than prospective human clinical trials for this particular submission.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- Not applicable. The submission does not involve a clinical study with human patients and an associated ground truth established by experts for diagnostic or treatment outcomes. The evaluation is based on engineering and material science principles.
4. Adjudication Method for the Test Set:
- Not applicable, as a clinical test set requiring expert adjudication was not part of this submission. The evaluation was based on meeting engineering standards and comparison to predicate devices.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This submission pertains to a pedicle fixation system, a physical implant, and not an AI-powered diagnostic or treatment assistance device.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
- No, a standalone performance study in the context of an algorithm's performance was not done. This is a physical medical device.
7. Type of Ground Truth Used:
- The "ground truth" for this device's evaluation is primarily established by engineering standards and material specifications. For mechanical testing, this means the defined limits and methodologies of the ASTM standards (F1798-97, F543-13, F1717-13) and for biocompatibility, the limits of ANSI/AAMI/ST72. Substantial equivalence to predicate devices serves as a comparative benchmark.
8. Sample Size for the Training Set:
- Not applicable. This submission does not involve a machine learning algorithm requiring a "training set."
9. How the Ground Truth for the Training Set Was Established:
- Not applicable. There is no training set for this device.
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