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510(k) Data Aggregation

    K Number
    K092420
    Date Cleared
    2009-11-19

    (105 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The KRD1™ Pedicle Screw 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 instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (Pseudoarthrosis).

    In addition, the KRD1™ Pedicle Screw System is indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft.

    Device Description

    The KRD1™ Pedicle Screw System consists of longitudinal rods, polyaxial screws, transverse connectors, and instrumentation to facilitate installation of this system.

    The KRD11M Pedicle Screw is offered in multiple screw diameters, with multiple lengths to accommodate individual patient needs. KRD1™ Pedicle Screw assemblies consist of the screw, a tulip, and a washer that secures the tulip to the screw and also serves as the saddle for the longitudinal rod. The tulip and screw designs allow the screw to have a polyaxial rotation relative to the tulip. A locking cap is placed on top of the pedicle screw assembly to secure the position of the implant and to retain the longitudinal rod.

    The KRD1™ Pedicle Screw assembly serves as the central fixation device to which various rods and cross connectors are secured to provide desired fixation.

    Longitudinal rods are provided in two configurations, straight and lordotic, have a fixed diameter (5.5mm), and vary by length.

    Cross connector assemblies are provided in multiple configurations, varying by length. Cross connectors are used to provide additional fixation support.

    The KRD1™ Pedicle Screw System components are fabricated from medical grade titanium alloy conforming to ASTM F-136 specifications.

    AI/ML Overview

    This document describes the KRD1™ Pedicle Screw System, a spinal fixation device, and its acceptance criteria for regulatory approval.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriteriaReported Device Performance
    Substantial equivalence to predicate devices in:Shown to be substantially equivalent to predicate devices in:
    - Indications for use- Indications for use
    - Function- Function
    - Operating principles- Operating principles
    - Materials- Materials
    Performance (mechanical testing)Performance (mechanical testing) was conducted and demonstrated substantial equivalence to predicate devices.
    Clinical dataNot required for this device type and demonstrated substantial equivalence.

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

    The document does not explicitly mention a "test set" in the context of clinical or performance data that would typically have a sample size for evaluation. Instead, the device's performance was established through mechanical testing and comparison to predicate devices, rather than through clinical trials with patient-specific test sets. Therefore, details regarding sample size for a "test set" and data provenance (country of origin, retrospective/prospective) are not applicable in the conventional sense for this type of device submission. The "data" provenance would refer to the mechanical testing results themselves.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications

    As clinical data or a patient-based "test set" requiring expert ground truth were not required or performed, this information is not applicable. The ground truth for device performance was established through engineering and biomechanical principles in mechanical testing.

    4. Adjudication Method for the Test Set

    Since no patient-based "test set" was utilized, an adjudication method for such a set is not applicable.

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

    A Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not performed as this device relies on mechanical testing and comparison to predicates for substantial equivalence, not on human reader performance with or without AI assistance. Therefore, there is no effect size reported for human readers with AI vs. without AI assistance.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    This device is a physical pedicle screw system, not an algorithm or AI-driven software. Therefore, a standalone (algorithm only) performance study is not applicable.

    7. Type of Ground Truth Used

    The ground truth used for establishing the device's performance and safety was primarily based on mechanical testing results and comparison of these results, as well as design and material specifications, against established performance characteristics of legally marketed predicate spinal fixation devices. This implies that the 'ground truth' is adherence to engineering standards and established safety and efficacy profiles of similar devices.

    8. Sample Size for the Training Set

    As this is a physical medical device and not an AI/ML algorithm requiring a training set, the concept of a "training set" and its sample size is not applicable.

    9. How Ground Truth for the Training Set Was Established

    Since there is no "training set" for this physical device, the method for establishing its ground truth is not applicable.

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