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510(k) Data Aggregation

    K Number
    K141044
    Date Cleared
    2014-08-18

    (117 days)

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

    The M.U.S.T. Pedicle Screw System is intended for posterior non-cervical pedicle fixation (T1-S2/ilium) and nonpedicle fixation, or anterolateral fixation (T8-L5). These devices are indicated as an adjunct to fusion for all of 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 failed previous fusion in skeletally mature patients.

    Device Description

    The M.U.S.T. Extension is intended to be used as part of the M.U.S.T. pedicle screw system (K121115, K132878) for the stabilization and the fusion of the lumbar and thoracic spine. The M.U.S.T. pedicle screw system includes cannulated or non cannulated poly-axial pedicle screws (K12115, K132878), cannulated or non cannulated mono-axial pedicle screws (K132878), set screws (K121115), straight and pre-bent rods (K12115), and cross connectors (K132878). The M.U.S.T. Extension consists of the following components, which are all provided in both sterile and unsterile packaging: Wide blade hook, Pedicle hook, Pedicle hook screw, Angled hook, Offset hook, Narrow blade hook.

    AI/ML Overview

    The provided text describes the M.U.S.T. Extension device as an adjunct to the M.U.S.T. Pedicle Screw System. The document is an FDA 510(k) premarket notification and primarily focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific acceptance criteria through a standalone study.

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document states that "design verification was conducted to written protocols with pre-defined acceptance criteria." However, it does not explicitly list these acceptance criteria or present the detailed results of the device's performance against them in a table format. Instead, it relies on geometrical comparisons and the assumption that the new components are not "worst case" compared to predicate devices for which testing was previously done.

    2. Sample Size for Test Set and Data Provenance:

    The document does not describe a separate "test set" in the context of an AI/algorithm. The focus is on physical device testing. The "geometrical comparisons" mentioned do not involve a sample size of patient data or data provenance. The assessment is based on the design of the device components.

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

    Not applicable. This document pertains to a medical device's physical and mechanical properties, not an AI algorithm requiring expert ground truth for a test set.

    4. Adjudication Method for the Test Set:

    Not applicable for the reasons stated above.

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

    No MRMC study was done, as this document is for a physical medical device (pedicle screw system components), not an AI-assisted diagnostic tool.

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study:

    No standalone algorithm study was done or is applicable to this device submission.

    7. Type of Ground Truth Used:

    The "ground truth" in this context refers to established engineering and biomechanical principles and standards used for evaluating the performance of implantable devices. The document implies compliance with these standards based on the geometric similarity to predicate devices. There is no biological or clinical "ground truth" derived from patient data described.

    8. Sample Size for the Training Set:

    Not applicable. There is no AI algorithm being trained or evaluated in this submission.

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

    Not applicable for the reasons stated above.

    Summary of Device Acceptance and Study Information from the Text:

    The document asserts that the M.U.S.T. Extension is substantially equivalent to its predicate devices based on:

    • Indications for Use: They are the same as the predicate devices.
    • Design Features: The M.U.S.T. Extension components (hooks, screws) have similar design features to existing components in the M.U.S.T. system (K121115, K132878) and other predicate devices.
    • Materials: All components are made from Ti6Al4V ELI (ISO 5832-3/ASTM F 136), which is a commonly accepted material for such implants and is consistent with predicate devices.
    • Performance Testing (Reaffirmation based on geometric comparison):
      • A risk analysis was conducted to identify new risks.
      • Design verification was performed with predefined acceptance criteria based on standards, FDA guidance, and comparison to predicate devices.
      • Geometrical comparisons were performed for the implant/rod/set screw interface (hooks) and implant/bone interface (hooks).
      • It was determined that "There were not any additional tests performed on the hooks as the interface to the rod, the tulip and thread geometry, the set screw and the final tightening torque are exactly the same as for the M.U.S.T. monoaxial screws (K132878)."
      • Conclusion: "Therefore, the biomechanical implant performance regarding yield strength, fatigue strength and construct stiffness can be considered at least equal to the predicate devices."

    The study described is not a clinical trial or an AI algorithm validation. It is a design verification and substantial equivalence demonstration based on engineering principles, material science, and comparison to previously cleared predicate devices, arguing that the new components perform at least as well as the already tested existing components. The acceptance criteria and "proving" of the device are implied through conformity with established standards for similar devices and the principle of substantial equivalence rather than explicit, novel performance benchmarks.

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