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510(k) Data Aggregation

    K Number
    K142939
    Date Cleared
    2015-01-13

    (96 days)

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

    The Revolution™ Spinal Fixation System is intended for pedicle screw fixation of the noncervical posterior spine in order to provide immobilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: (1) degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), (2) spondylolisthesis, (3) trauma (i.e., fracture or dislocation), (4) spinal stenosis, (5) deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis), (6) tumor, (7) pseudoarthrosis, (8) failed previous fusion.

    Device Description

    The Intelligent Implant Systems' Revolution™ Spinal Fixation System consists of monoaxial bone screws of various lengths and diameters and a series of connector assemblies for connecting the bone screws. The Revolution™ Bone Screws have a standard thread for interfacing bone and a partially threaded post designed to engage the Revolution™ Connectors. Screws are available in 4.5mm major diameter and lengths from 25mm to 50mm and 5.5mm, 6.5mm, and 7.5mm major diameters and lengths from 25mm to 55mm. All screw diameter sizes except for the 4.5mm are cannulated for use with a 1.4 mm k-wire. To allow the surgeon to determine the height of the connector relative to the bone, screws with extended non-threaded collars are provided. These extended collars effectively provide built in spacers that prevent the bone screw from being driven too deep and control the overall height of the completed assembly. The Revolution™ Connectors are provided in various lengths and are used to connect the pedicle screws and create a rigid structure. To allow for variation in screw placement, each end of the connector allows for angular compensation. One end allows for full polyaxial angulation, similar to a typical polyaxial screw. The other end has a pivoting-slide that allows for angulation in only one plane along the long axis of the Connector while also sliding within an opening in the Connector. As the distance between two screws is always variable, the slide allows the Connector to compensate for this difference, minimizing inventory and eliminating the need to cut spinal rods. In addition, the Connectors have a threaded locking nut built into each end and each nut fits over the top of a bone screw post. These locking nuts are turned clockwise to tighten. A calibrated torque wrench provides the correct setting for locking the nuts on the bone screw post with sufficient force. The system can be unlocked, if necessary, by turning the locking nuts counterclockwise. All implant components of the Revolution™ Spinal Fixation System are manufactured from Ti-6Al-4V ELI alloy, conforming to ASTM F136.

    AI/ML Overview

    This FDA 510(k) summary describes a spinal fixation system, not a device with AI components. Therefore, the questions related to AI performance, ground truth, experts, and training/test sets are not applicable.

    The document focuses on the Revolution™ Spinal Fixation System, a mechanical implant. For such a device, acceptance criteria and testing revolve around its physical properties, material compatibility, and structural integrity under simulated physiological conditions.

    Here's an analysis of the provided information, addressing the applicable questions and indicating when a question is not relevant to this type of device:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document states that the testing was conducted "according to methods defined in ASTM F 1798-13, 'Standard Test Method for Evaluating the Static and Fatigue Properties of Interconnection Mechanisms and Subassemblies Used in Spinal Arthrodesis Implants', and ASTM F 1717-14, 'Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model'."

    Since specific numerical acceptance criteria (e.g., minimum strength in Newtons) are not explicitly stated in this summary, the table below will reflect the type of tests performed and the general conclusion given in the document. The implicit acceptance criterion is that the device meets the requirements of these ASTM standards and performs comparably to predicate devices.

    Acceptance Criterion (Implicit based on ASTM standards)Reported Device Performance
    ASTM F1798-13 Tests:(Implied to meet standard, comparable to predicate)
    Static Flexion-Extension StrengthComparable to published values on plate and rod systems
    Axial Gripping StrengthComparable to published values on plate and rod systems
    Static A-P Pullout StrengthComparable to published values on plate and rod systems
    ASTM F1717-14 Tests:(Implied to meet standard, comparable to predicate)
    Static Compression BendingComparable to published values on plate and rod systems
    Static Torsional BendingComparable to published values on plate and rod systems
    Dynamic Compression BendingComparable to published values on plate and rod systems
    Material Compatibility:Complies with ASTM F-136.
    Material: Ti-6Al-4V ELI

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

    The document does not specify a "sample size used for the test set" in terms of patient data, as this is a mechanical device. Instead, it refers to mechanical testing. The sample size for mechanical testing (i.e., the number of devices or components tested) is not explicitly stated in this summary. The data provenance is mechanical testing conducted in a laboratory setting to validate the device's physical properties.

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

    Not applicable. This device is not an AI/diagnostic system. Ground truth in this context refers to the physical properties measured against established engineering standards (ASTM).

    4. Adjudication Method for the Test Set

    Not applicable. Adjudication methods are typically for clinical studies or AI algorithm outputs where multiple human reviewers assess data. Here, the "truth" is determined by standardized mechanical testing procedures.

    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 or diagnostic device that would involve human readers.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    Not applicable. This device does not involve an algorithm.

    7. The Type of Ground Truth Used

    For this mechanical device, the "ground truth" is defined by established engineering and material standards, specifically:

    • ASTM F 1798-13: "Standard Test Method for Evaluating the Static and Fatigue Properties of Interconnection Mechanisms and Subassemblies Used in Spinal Arthrodesis Implants"
    • ASTM F 1717-14: "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model"
    • ASTM F-136: Standard for the Ti-6Al-4V ELI material.

    The device's performance is compared against the requirements and typical performance values for devices conforming to these standards.

    8. The Sample Size for the Training Set

    Not applicable. This is a physical device, not an AI model that requires a training set.

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

    Not applicable. This device does not have a "training set" in the context of AI.

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