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510(k) Data Aggregation

    Why did this record match?
    Device Name :

    FaSet Fixation System, UNITY Sacroiliac Joint Fixation System, Huvex Interspinous Fixation System, and

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

    The FaSet Fixation System is intended to stabilize the spine as an aid to fusion through bilateral immobilization of facet joints. The Facet Screw System is indicated for posterior surgical treatment with or without bone graft at single or multiple levels from C2 to S1 (inclusive). For transfacet fixation, the screws are inserted posteriorly through the superior side of the facet, across the facet joint, and into the pedicle. For translaminar facet fixation, the screws are inserted posteriorly through the lateral aspect of the spinous process, through the lamina, through the superior side of the facet, across the facet joint, and into the pedicle. The FaSet Fixation System is indicated for treatment for any or all of the following:

    • Spondylolisthesis
    • Pseudoarthrosis or failed previous fusions which are symptomatic, or which may cause secondary instability or deformity
    • Spondylolysis
    • Degenerative Disk Disease (DDD) as defined by back pain of discogenic origin with degeneration of disk confirmed by history and radiographic studies and/or degenerative disease of the facets with instability
    • Trauma including spinal fractures and/or dislocations.

    The UNITY Sacroiliac Joint Fixation System is indicated for sacroiliac joint fusion for:

    • Sacroiliac joint dysfunction including degenerative sacroiliitis and sacroiliac joint disruptions
    • Augmenting immobilization and stabilization of the sacroiliac joint in skeletally mature patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion

    The UNITY Sacroiliac Joint Fixation System is also indicated for fracture fixation of acute, non-acute, and non-traumatic fractures involving the sacroiliac joint.

    The Huvex Interspinous Fixation System is a posterior, non-pedicle supplemental fixation device intended for use in the lumbar spine (T1-S1) as an adjunct to fusion in skeletally mature patients. It is intended for plate fixation/attachment to the spinous processes for the purpose of achieving supplemental fusion in the following conditions: 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), tumor, and/or lumbar spinal stenosis. The Huvex Interspinous Fixation System is intended for use, in conjunction with autogenous bone graft, and not intended for stand-alone use.

    The AEON-C™ Stand Alone System is a stand-alone anterior cervical intervertebral fusion device indicated for use in skeletally mature patients with degenerative disc disease (DDD) with accompanying radicular symptoms at one or two contiguous levels from C2-T1. DDD is defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies. The AEON-C™ Stand Alone System should be packed with autograft and/or allograft comprised of cancellous, cortical and/or corticocancellous bone graft and implanted with an anterior approach. Patients should receive at least six (6) weeks of non-operative treatment prior to treatment with a cervical intervertebral fusion device. If the device is being used without the provided screws, supplemental fixation must be used.

    Device Description

    The FaSet Fixation System consist of permanent implant devices manufactured from titanium or titanium alloy (Ti-6Al-4V ELI) as specified in ASTM F67, and F136. Various sizes and lengths of these implants are available to accommodate patient anatomy. The device is intended to provide mechanical support and stability to the implanted level until biologic fusion is achieved.

    The UNITY Sacroiliac Joint Fixation System consists of screws designed to enhance sacroiliac joint fusion. The UNITY Sacroiliac Joint Fixation System is offered in various diameters, lengths, and three screw types in cannulated form to accommodate patient anatomy and is manufactured from titanium alloy (Ti-6Al-4V ELI) as specified in ASTM F136 and cobalt chrome alloy as specified in ASTM F1537. The three design types of the subject device are:

      1. Standard Thread Screw (with and without slots)
      1. Lag Screw (with and without slots) and
      1. Washer Screw (with slots)

    The Huvex Interspinous Fixation System consists of a left plate, a right plate, pin, bolt, inner cap, center bar, and set screw. Each of these components is provided in several sizes to allow for the construction of five different HUVEX Interspinous Fusion implant sizes. The left plate is provided assembled with the poly axial bar. The bar has a bone graft window to allow fusion between spinous process. Poly axial bar is also designed to fit the anatomical characteristics of the spinous process. The right plate is designed to be combined with left plate fixed to spinous process. Right plate contains a set screw to lock the right plate to the poly axial bar. The Huvex Interspinous Fixation System components are supplied non-sterile, are single use and are fabricated from titanium alloy (Ti-6AI-4V ELI) that conforms to ASTM F136.

    In addition to the implants a set of reusable surgical instruments are provided. Both implant and instruments have trays that are used for handling and storage.

    The AEON-C™ Stand Alone System includes PEEK interbodies and titanium interbodies, which utilize a titanium alloy locking mechanism that is either integrated in an anterior fixation plate or within the interbody. Both PEEK interbodies and titanium interbodies, with or without fixation plates, are to be anchored to patient anatomy via two (2) titanium alloy bone screws. The implant design includes multiple footprints, heights and lordosis options and the screw design includes multiple diameters and lengths, to fit a variety of patient anatomies. The interbodies can be used without the provided screws when supplemental fixation is used.

    AI/ML Overview

    The provided document is a 510(k) summary for several medical devices: FaSet Fixation System, UNITY Sacroiliac Joint Fixation System, Huvex Interspinous Fixation System, and AEON-C™ Stand Alone System.

    This document describes that the subject devices are substantially equivalent to their predicate devices, which means they are considered as safe and effective as a legally marketed device that does not require premarket approval.

    Here's an analysis based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    This document does not contain specific quantitative acceptance criteria or reported device performance metrics in the way one would typically see for a novel diagnostic or AI-driven decision support system. Instead, the devices are cleared based on substantial equivalence to predicate devices.

    The "Performance Data" section states:

    • "The K&J Consulting - FaSet Fixation System, Huvex Interspinous Fixation System, and AEON-C™ Stand Alone System devices are identical to predicate devices and therefore, no performance testing is required."
    • "New components being added to the UNITY Sacroiliac Joint Fixation System, but the new components do not introduce a new mechanical worst-case, so no new testing is required."

    Therefore, there is no table presenting acceptance criteria and reported device performance because the regulatory clearance is based on the devices being identical or having similar technological characteristics and not introducing new safety/effectiveness concerns compared to previously cleared devices.

    2. Sample Size Used for the Test Set and Data Provenance

    Since no new performance testing was required due to substantial equivalence, there is no test set sample size or data provenance mentioned in this document for the subject devices.

    3. Number of Experts Used to Establish Ground Truth and Their Qualifications

    Given that performance testing was not required for these devices (as they are identical or technologically similar to predicates), there is no mention of experts or ground truth establishment in this context.

    4. Adjudication Method

    No adjudication method is mentioned as there was no performance testing involving human review of a test set.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No MRMC study was conducted or reported for these devices. The devices are hardware implants, not AI-driven systems where such studies are typically performed.

    6. Standalone (Algorithm Only) Performance Study

    Not applicable. These are physical implantable devices, not algorithms.

    7. Type of Ground Truth Used

    No ground truth data was used for the substantial equivalence determination beyond the specifications and established safety/effectiveness profiles of the predicate devices.

    8. Sample Size for the Training Set

    Not applicable. These are physical implantable devices, not AI/ML algorithms that require a training set.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable.

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    K Number
    K222448
    Date Cleared
    2022-10-13

    (59 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    UNITY Sacroiliac Joint Fixation System

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

    The UNITY Sacroiliac Joint Fixation System is indicated for use in skeletally mature patients for sacroiliac joint fusion for conditions including sacroiliac joint disruptions and degenerative sacroiliitis.

    Device Description

    The UNITY Sacroiliac Joint Fixation System consists of screws designed to enhance sacroiliac joint fusion. The UNITY Sacroiliac Joint Fixation System is offered in various diameters, lengths, and three screw types in cannulated form to accommodate patient anatomy. The three design types of the subject device are: 1. Standard Thread Screw (with and without slots) 2. Lag Screw (with and without slots) and 3. Washer Screw (with slots)

    AI/ML Overview

    This appears to be an FDA 510(k) clearance letter and a 510(k) summary for the UNITY Sacroiliac Joint Fixation System. This type of documentation permits a device to be legally marketed, but it typically does not contain detailed information about the acceptance criteria and study results in the way you've requested for proving a device meets acceptance criteria, especially regarding AI or diagnostic performance studies.

    The document states: "The UNITY Sacroiliac Joint Fixation does not create a new worst case for device performance; additional testing is not needed." This is a key statement indicating that the device is cleared based on substantial equivalence to an existing predicate device, not on new clinical performance data demonstrating its effectiveness in a traditional clinical trial or AI performance study.

    Therefore, I cannot provide the requested information from this document. The questions you've asked (sample sizes for test/training sets, expert consensus, MRMC studies, standalone performance, etc.) are common for AI/diagnostic device clearances, but this particular device is a fixation system (essentially, screws for the sacroiliac joint), which falls under a different regulatory pathway.

    To directly answer your points based on the provided text:

    1. A table of acceptance criteria and the reported device performance: Not present. The device is cleared based on equivalence to a predicate, not performance against specific criteria.
    2. Sample sized used for the test set and the data provenance: Not applicable. No new test set data for performance was generated as per the document.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable.
    4. Adjudication method for the test set: Not applicable.
    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. This is not an AI device.
    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This is not an AI device.
    7. The type of ground truth used: Not applicable.
    8. The sample size for the training set: Not applicable.
    9. How the ground truth for the training set was established: Not applicable.
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    K Number
    K173201
    Manufacturer
    Date Cleared
    2018-04-26

    (206 days)

    Product Code
    Regulation Number
    888.3040
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    UNITY Sacroiliac Joint Fixation System

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

    The UNITY Sacroiliac Joint Fixation System is indicated for use in skeletally mature patients for sacroiliac joint fusion for conditions including sacroiliac joint disruptions and degenerative sacroiliitis.

    Device Description

    The UNITY Sacroiliac Joint Fixation System consists of screws designed to enhance sacroiliac joint fusion. The UNITY Sacroiliac Joint Fixation System is offered in various diameters, lengths, and three screw types in cannualated form to accommodate patient anatomy. The three design types of the subject device are:

    1. Standard Thread Screw (with and without slots)
    2. Lag Screw (with and without slots) and
    3. Washer Screw (with slots)
    AI/ML Overview

    The provided text is a 510(k) premarket notification for the UNITY Sacroiliac Joint Fixation System, a medical device. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than providing a detailed study proving the device meets specific acceptance criteria in the way a diagnostic AI might.

    Therefore, many of the requested fields regarding acceptance criteria and study details for an AI-based device are not directly applicable or available in this document. The document describes mechanical performance testing and biocompatibility.

    Here's an analysis based on the provided text:

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

    Acceptance Criteria CategorySpecific Criteria (Implicit via predicate comparison and standards)Reported Device Performance
    Material BiocompatibilityEquivalent to predicate (Rexious Spinal Fixation System K111362)Utilizes same manufacturing processes, materials, and sterilization as K111362.
    Mechanical PerformanceFunction as intended and provide expected stability (per ASTM F2193-14 & ASTM F543-17)"In all instances, the UNITY Sacroiliac Joint Fixation System functioned as intended and stability observed was as expected."
    Intended UseSame intended use as predicate devices."The UNITY Sacroiliac Joint Fixation System has the same intended uses..."
    Technological CharacteristicsSimilar technological characteristics and principles of operation as predicate devices."The subject and predicate devices are based on the following same technological elements..." "The minor technological differences between the UNITY Sacroiliac Joint Fixation System and its predicate devices raise no new issues of safety or effectiveness."

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

    The document does not specify the exact sample sizes used for the mechanical tests. It states that "Three motion and stress tests were performed" and lists four tests, implying a set of samples for each test type. The data provenance is implied to be from the manufacturer (Huvexel Co., Ltd. in South Korea) through their testing activities. The nature of these tests (mechanical stress and motion) is inherently prospective as new devices would be manufactured and tested.

    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 field is not applicable. The device is a physical implant, not a diagnostic AI system requiring expert interpretation for ground truth. The "ground truth" for the mechanical performance is defined by the standards and the physical properties observed during testing.

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

    This field is not applicable. Adjudication methods are typically used for establishing ground truth in clinical or image-based studies, not for mechanical device testing. The assessment of mechanical performance is based on adherence to engineering standards and observed physical behavior.

    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 field is not applicable. The UNITY Sacroiliac Joint Fixation System is a physical implant, not an AI-assisted diagnostic tool.

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

    This field is not applicable. The device is a physical implant, not an algorithm.

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

    For biocompatibility, the ground truth is established by referencing the prior FDA clearance of the Rexious Spinal Fixation System (K111362) which used similar materials, manufacturing processes, and sterilization. This is a form of historical data/pre-established safe use.

    For mechanical testing, the ground truth is established by engineering standards (ASTM F2193-14 and ASTM F543-17) which define acceptable ranges and behaviors for the specified tests. The "functioned as intended" and "stability observed as expected" implies meeting these standards.

    8. The sample size for the training set

    This field is not applicable. The device is a physical implant, not an AI model requiring a training set.

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

    This field is not applicable. The device is a physical implant, not an AI model.

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