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510(k) Data Aggregation

    K Number
    K120646
    Manufacturer
    Date Cleared
    2012-06-07

    (97 days)

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

    The CapSure® PS System is a non-cervical spinal fixation system intended for posterior pedicle screw fixation (T1-S2/ilium) in skeletally mature patients. The CapSure® PS System is indicated for degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudoarthrosis).

    The CapSure® PS System is also indicated for pedicle screw fixation in skeletally mature patients with severe spondylolisthesis (Grades 3 and 4) at the L5-S1 vertebral joint, having fusions with autogenous bone graft, with the device fixed or attached to the lumbar and sacral spine (levels of pedicle screw fixation are L3-S2/ilium), and for whom the device is intended to be removed after solid fusion is attained.

    Device Description

    The CapSure® PS System consists of a selection of non-sterile, single use, titanium allov polyaxial screw and connector components, and titanium alloy and cobalt chrome alloy rod components that are assembled to create a rigid spinal construct. The components of the CapSure® PS System are attached to the non-cervical spine in order to stabilize the spine during fusion of the vertebral bodies, and are intended to be removed after spinal fusion is achieved.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for a medical device called the "CapSure® PS System," which is a Pedicle Screw Spinal System. This type of submission is for demonstrating substantial equivalence to a predicate device, not for proving a new device's efficacy through a clinical study that would have acceptance criteria for performance metrics like sensitivity or specificity.

    Therefore, many of the requested elements for a study proving device performance (such as sample size for test sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, ground truth types, training set size, and training set ground truth establishment) are not applicable to this type of device submission.

    Instead, the acceptance criteria and proof of performance for this device are based on mechanical testing to demonstrate that the new components for the CapSure® PS System are substantially equivalent to the previously cleared predicate CapSure® PS System components and other predicate pedicle screw systems.

    Here's the information that is applicable based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Criteria/MethodReported Device Performance
    Mechanical PerformanceMechanical testing according to ASTM F1717, including:The subject CapSure® PS System demonstrated substantial equivalence to the predicate CapSure® PS System.
    - Static compression bendingPassing results (implicit by substantial equivalence claim)
    - Dynamic compression bendingPassing results (implicit by substantial equivalence claim)
    - Static torsionPassing results (implicit by substantial equivalence claim)
    Material EquivalenceMaterials: Titanium alloy, cobalt chrome alloyEquivalent to predicate devices (implicit by substantial equivalence claim)
    Intended Use & Indications for Use EquivalenceIntended use and indications for use are similar to predicate devices.The updated CapSure® PS System maintains substantial equivalence in intended use and indications for use to its predicate devices, with modifications for new component additions.

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

    • Not applicable for a clinical study. For mechanical testing, the "sample size" would refer to the number of components tested according to ASTM F1717. This specific number is not provided in the 510(k) summary, but it would adhere to the sample size requirements of the ASTM F1717 standard itself.
    • Data Provenance: The data comes from internal mechanical testing performed by Spine Wave, Inc.

    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):

    • Not applicable. Ground truth in the context of clinical interpretation by experts is not relevant here as this is a mechanical device, not a diagnostic or AI device. The "ground truth" for mechanical testing is adherence to the specified ASTM standard.

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

    • Not applicable. This concept relates to expert review of clinical cases. For mechanical testing, adherence to the ASTM standard is directly measurable.

    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 a mechanical spinal fixation system, not an AI-assisted diagnostic device.

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

    • Not applicable. This refers to AI algorithms, which is not relevant to this device.

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

    • For mechanical testing, the "ground truth" is adherence to established engineering standards and specifications (ASTM F1717) and demonstrating performance equivalent to the predicate devices.

    8. The sample size for the training set:

    • Not applicable. This refers to AI training data.

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

    • Not applicable. This refers to AI training data.
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