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510(k) Data Aggregation

    K Number
    K170266
    Manufacturer
    Date Cleared
    2017-04-14

    (77 days)

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

    The Spineology Palisade™ Pedicular Fixation System is intended for posterior, non-cervical fixation as an adjunct to fusion in skeletally mature patients for 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/ or failed previous fusion.

    Device Description

    The Spineology Palisade Pedicular Fixation System consists of screws (titanium allov), curved and straight rods (cobalt chrome), adjustable Connex Cross Connector (titanium alloy), and fixed ConneX Rod Connector (titanium alloy) devices to allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Palisade screws are available with or without a hydroxyapatite coating. The system is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine. The screws can be placed in the pedicles in a variety of trajectories ranging from the standard anatomic transpedicular path projected medially toward the ventral vertebral body, to a caudocephalad path sagittally and a laterally directed path in the transverse plane.

    AI/ML Overview

    The provided text is a 510(k) premarket notification for a medical device, the Spineology Palisade™ Pedicular Fixation System. This document focuses on demonstrating substantial equivalence to predicate devices through a comparison of intended use, indications, technology, materials, and non-clinical mechanical testing results.

    Crucially, this document does not contain information about clinical studies involving human patients, nor does it present acceptance criteria and performance data in the context of an "AI/algorithm" or "device performance" as might be expected for diagnostic or AI-driven medical devices. The device in question is a surgical implant (pedicle screw system), and its clearance is based on mechanical testing and comparison to existing, already-cleared predicate devices.

    Therefore, many of the requested categories for acceptance criteria and study details are not applicable to the content of this 510(k) submission. I will address the points as best as possible with the available information.


    Acceptance Criteria and Study for Spineology Palisade™ Pedicular Fixation System (Additions: ConneX™ Cross Connector, ConneX™ Rod Connector, and 4.75mm cobalt chrome Straight Rod)

    1. A table of acceptance criteria and the reported device performance

    Since this is a mechanical device, performance is evaluated through non-clinical mechanical testing, demonstrating that the device components can withstand relevant forces and stresses. The "acceptance criteria" are implied by successful completion of these tests, showing comparable or acceptable performance to predicate devices and industry standards. Specific numerical acceptance values and direct comparisons to predicate device values are not explicitly given in this summary document, but the statement of "substantial equivalence" implies successful achievement.

    TestAcceptance Criteria (Implied)Reported Device Performance
    ConneX™ Cross Connectors and ConneX™ Rod Connectors
    ASTM F1717 (Static Compression Bending)Performance comparable to predicate devices and acceptable per standard.Testing conducted; results support substantial equivalence.
    ASTM F1717 (Dynamic Compression Bending)Performance comparable to predicate devices and acceptable per standard.Testing conducted; results support substantial equivalence.
    ASTM F1798 (Flexural Grip)Performance comparable to predicate devices and acceptable per standard.Testing conducted; results support substantial equivalence.
    ASTM F2193 (Static Cantilever Bending)Performance comparable to predicate devices and acceptable per standard.Testing conducted; results support substantial equivalence.
    Bacterial Endotoxin Testing (BET) (ANSI/AAMI ST-72:2011)Meets endotoxin limits for medical devices.Testing conducted; results support substantial equivalence.
    Straight Rods
    ASTM F1717-15 (Static Compression Bending)Performance comparable to predicate devices and acceptable per standard.Testing conducted; results support substantial equivalence.
    Bacterial Endotoxin Testing (BET) (ANSI/AAMI ST-72:2011)Meets endotoxin limits for medical devices.Testing conducted; results support substantial equivalence.

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

    The document does not specify the exact number of units or "sample size" for each mechanical test. However, it states "representative worst case" devices were tested. Data provenance is implied to be from internal Spineology Inc. testing facilities ("non-clinical testing"). The data is entirely retrospective in the sense that it evaluates manufactured device components against predefined standards. As this is a mechanical device, country of origin related to human data is not applicable here.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This is not applicable. The "ground truth" for mechanical testing is established by engineering standards (ASTM) and FDA guidance for spinal systems. There are no human experts establishing a "ground truth" for diagnostic or clinical outcomes in this type of submission.

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

    This is not applicable. Adjudication methods are relevant for clinical studies where expert consensus is needed to determine outcomes, which is not the case for mechanical performance testing.

    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

    This is not applicable. This is a surgical implant, not a diagnostic imaging device or an AI-assisted system. No human reader studies were conducted or are relevant for this type of device clearance.

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

    This is not applicable. There is no algorithm/AI component in this medical device.

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

    For the mechanical testing, the "ground truth" is defined by adherence to recognized engineering standards (ASTM) and FDA guidance for spinal systems. The performance of the device components under various loading conditions is compared against these established benchmarks and implicitly against the performance of predicate devices.

    8. The sample size for the training set

    This is not applicable. There is no "training set" as this is not an AI/ML device.

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

    This is not applicable. There is no "training set" or "ground truth" for a training set as this is not an AI/ML device.

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