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510(k) Data Aggregation

    K Number
    K141557
    Date Cleared
    2014-12-08

    (179 days)

    Product Code
    Regulation Number
    888.1100
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Herniatome Percutaneous Discectomy Device is intended for use in aspiration of disc material during percutaneous discectomies in the lumbar, thoracic, and cervical regions of the spine.

    Device Description

    The Herniatome Percutaneous Discectomy Kit is comprised of an Introducer needle and a Herniatome Percutaneous Discectomy Device. The Herniatome Percutaneous Discectomy Device is a single-use disposable discectomy device that is designed to remove intervertebral disc nucleus pulpous material under CT and fluoroscopic guidance. Radiopaque marker bands are located on the Introducer needle and the Herniatome Percutaneous Discectomy Device. The Herniatome Percutaneous Discectomy Device contains a battery source DC motor that causes the internal double pitch mechanism to act as a screw conveyor to retrieve and remove the excised debris through the outer cannula and into the transparent collection container.

    The Herniatome Percutaneous Discectomy Device is provided in two base models, a curved or straight distal end cannula with a lateral window and each model is provided with two different gage cannulas and two different cannula lengths for utilization in the specific region of the spine.

    AI/ML Overview

    This document describes a 510(k) premarket notification for the "Herniatome Percutaneous Discectomy Device". The purpose of this submission is to demonstrate substantial equivalence to a legally marketed predicate device. This is NOT a study about an AI/ML device, and therefore several of your requested categories (1, 2, 3, 4, 5, 6, 7, 8, 9) are not applicable as they relate to AI/ML device performance and testing.

    Here's the relevant information that can be extracted from the provided text regarding the device and its performance testing:

    Device Name: Herniatome Percutaneous Discectomy Device

    Predicate Device: Stryker Instruments, Dekompressor™ Percutaneous Discectomy Probe, K032473

    Intended Use: The Herniatome Percutaneous Discectomy Device is intended for use in aspiration of disc material during percutaneous discectomies in the lumbar, thoracic, and cervical regions of the spine.


    1. Table of acceptance criteria and the reported device performance

    The document does not provide a table of explicit numeric acceptance criteria for the performance tests, nor does it report specific numerical device performance metrics. Instead, it states that the device "successfully passed all of the following performance tests."

    Acceptance CriteriaReported Device Performance
    Biocompatibility: Device classified as an External Communicating Device in contact with Tissue/Bone/Dentin Communicating for a Limited Duration (<24 hours). Tests performed include Cytotoxicity, Maximum Sensitization (sodium chloride & sesame oil), Intracutaneous Reactivity, and Acute Systemic Toxicity, all assessed against ISO 10993-1, 10993-5, 10993-10, and 10993-11."produced by Gallini Medical Products was assessed against the International Standard ISO 10993-1… The battery of testing include the following tests… [all tests listed in Acceptance Criteria column]." (Implied success as no failure is reported, and a substantial equivalence claim is made.)
    Electrical Safety and Electromagnetic Compatibility: Compliance with IEC 60601-1 standards for safety and IEC 60601-1-2 for Electromagnetic Compatibility."Electrical Safety and Electromagnetic Compatibility that were performed on the Herniatome Percutaneous Discectomy Device in accordance with IEC 60601-1 standards for safety and the IEC 60601-1-2. Standard for Electromagnetic Compatibility." (Implied success as no failure is reported, and a substantial equivalence claim is made.)
    Performance Testing: (Specific criteria not detailed, but tests included: Accelerated Aging Shelf Life Package Testing, 3-year Real Time Aging Battery Life Testing, Electromagnetic Compatibility and Electrical Safety, Radiodetectability, Technical Characteristic Performance Volume Flow Rate Study)"The Herniatome Percutaneous Discectomy Device successfully passed all of the following performance tests."
    Shelf Life: Performance of the device meets standard requirements without significant difference to product performance requirements before aging, demonstrating stability and reliability within a three-year useful life, in accordance with ISO 11607."In accordance with ISO 11607 the real time three year aging of Herniatome Percutaneous Discectomy Device demonstrated that the performance of the device met the standard requirements without any significant difference to product performance requirements before aging. So the product is stable and reliable within the three-year useful life."
    Software Verification and Validation Testing: (Applicable if device contains software)"The Herniatome Discectomy Device does not contain any software." (No software present, thus no V&V testing required.)
    Animal Studies: (Applicable if device conducts performance testing on animals)"The Herniatome Percutaneous Discectomy Device did not conduct any performance testing on animals." (No animal studies conducted.)

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

    This information is not provided in the document. The document lists performance tests conducted but does not detail sample sizes, data provenance (e.g., country of origin), or whether the data was retrospective or prospective.


    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 is not applicable as it is a medical device submission, not specifically an AI/ML device performance study requiring expert ground truth for classification/detection tasks. The "ground truth" for this device would be its ability to physically perform its intended function, as demonstrated by engineering and biocompatibility tests.


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

    This is not applicable for this type of medical device submission. Adjudication methods are typically associated with human-in-the-loop studies or clinical trials involving subjective assessments, which are not detailed here.


    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

    21 CFR 888.1100 (Arthroscope) is not an AI/ML device. Therefore, a multi-reader multi-case comparative effectiveness study with AI assistance is not applicable and was not performed.


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

    This is not applicable. The Herniatome Percutaneous Discectomy Device is a mechanical surgical instrument, not an algorithm or AI/ML device.


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

    For this type of device, "ground truth" is established through engineering principles, material science, and adherence to performance standards and regulations.

    • Biocompatibility: Demonstrated through validated laboratory tests (Cytotoxicity, Sensitization, Intracutaneous Reactivity, Acute Systemic Toxicity) against ISO standards.
    • Electrical Safety & EMC: Demonstrated through testing against IEC standards.
    • Performance (e.g., Volume Flow Rate, Radiodetectability): Demonstrated through specific engineering tests, where the "ground truth" is the established functional specification or expected physical behavior under test conditions.
    • Shelf Life: Demonstrated through accelerated and real-time aging studies, ensuring the device maintains its performance and sterility over time, according to ISO 11607.

    There is no "expert consensus" or "pathology" in the sense of diagnostic interpretation for this mechanical device's ground truth.


    8. The sample size for the training set

    This is not applicable as the device is not an AI/ML system that requires a training set.


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

    This is not applicable as the device is not an AI/ML system that requires a training set or associated ground truth.

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