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510(k) Data Aggregation

    K Number
    K183550
    Date Cleared
    2019-04-08

    (109 days)

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

    The Vitality® Spinal Fixation System implants are non-cervical spinal fixation devices intended for posterior pedicle screw fixation (T1-S2/ilium), posterior hook fixation (T1-L5), or anterolateral fixation (T8-L5). Pedicle screw fixation is indicated for skeletally mature patients and for adolescent patients.

    These devices are indicated as an adjunct to fusion for all of the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic sites), spondylolisthesis, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis, Scheuermann's Disease), tumor, stenosis, pseudoarthrosis and/or failed previous fusion. When used as an adjunct to fusion, the Vitality® Spinal Fixation System is intended to be used with autograft and/or allograft.

    In addition the Vitality® Spinal Fixation System is intended for treatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft, having implants attached to the lumbosacral spine and or ilium with removal of the implant after attainment of a solid fusion. Levels of pedicle screw fixation for these patients are L3-sacrum/ilium.

    When used for posterior non-cervical pedicle screw fixation in pediatric patients, the Vitality® System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. The Vitality® System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

    Assembly of a spinal fixation construct using the Vitality® Spinal Fixation System may include additionally any Instinct® Java™ System hook, any APEX® System hook, or the Universal Clamp® (titanium). These direct-connect single point of fixation implants act in concert with the Vitality® System rods and implants to support its surgical indications for use.

    In order to achieve additional levels of fixation, the Vitality® Spinal Fixation System rods may be connected to the Instinct® Java™ System (Ø5.5mm rod) or the Virage® OCT Spinal Fixation System (Ø3.5mm rod) with the corresponding Vitality® rod connectors. Refer to the Instinct® Java™ System and Virage® OCT Spinal Fixation System package inserts for instructions for use.

    Device Description

    The Vitality® Spinal Fixation System is a thoracolumbar and sacroiliac fixation system designed to aid in the surgical correction of several types of spinal conditions. The system consists of a variety of spinal rods, pedicle screws, hooks, and connectors intended only to provide temporary stabilization during the development of a solid fusion of the spine with bone graft. The system can be rigidly locked into a variety of configurations, with each construct being customized to the patient's anatomy. All implants are single use only and should hot be reused under any circumstances. The implant system is intended to be removed after solid fusion has occurred.

    The system also includes instrumentation for insertion and removal and securing of the implants. All implants are made from medical grade titanium alloy; select rods are also available in medical grade cobalt chromium alloy. Implants made from medical grade titanium, medical grade titanium alloy, and medical grade cobalt chromium may be used together. Never use titanium, titanium alloy, and/or cobalt chromium with stainless steel in the same implant construct.

    The Vitality Spinal Fixation System is compatible with the Virage® OCT Spinal Fixation System Rods, Instinct® Java" Spinal Fixation System Rods and Hooks, and Universal Clamp® Spinal Fixation System.

    AI/ML Overview

    The provided document pertains to a 510(k) premarket notification for a medical device, specifically the Vitality® Spinal Fixation System. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving the device meets specific acceptance criteria through a clinical study as would be seen for a novel AI/software medical device.

    Therefore, many of the requested categories for acceptance criteria and study details are not directly applicable to this submission. The document explicitly states:

    • "To support substantial equivalence, mechanical testing of the modified screw implants of the subject Vitality® Spinal Fixation System were assessed and tested appropriately in accordance with ASTM standards. Performance testing included tests per ASTM F1717 (dynamic compression bending) and demonstrated the subject devices are safe and effective for use with pedicle screw fixation. In all instances, the modified device functioned as intended and demonstrated substantial equivalence to the predicate device(s)."
    • "The subject Vitality® Spinal Fixation System is substantially equivalent to the Vitality® Spinal Fixation System (K171907)."
    • "Based on this information, the subject device does not raise any new issues regarding the safety or efficacy when compared to its predicates."

    This means the "acceptance criteria" and "study" are primarily focused on mechanical performance testing against established ASTM standards and demonstrating substantial equivalence to a previously cleared device (Vitality® Spinal Fixation System, K171907). There is no mention of an AI algorithm, human readers, or clinical performance studies with ground truth in the context of this submission.

    Here's how to address the request based on the provided text:


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

    Acceptance Criteria CategorySpecific Criteria (ASTM Standard)Reported Device Performance Statement
    Mechanical PerformanceASTM F1717 (Dynamic Compression Bending)"demonstrated the subject devices are safe and effective for use with pedicle screw fixation. In all instances, the modified device functioned as intended"
    Substantial EquivalenceComparison to predicate (K171907) for:"substantially equivalent to the Vitality® Spinal Fixation System (K171907)"
    - Intended Use"remain the same as, or similar to, the primary predicate"
    - Indications for Use"remain the same as, or similar to, the primary predicate"
    - Design"remain the same as, or similar to, the primary predicate"
    - Manufacturing Methods"remain the same as, or similar to, the primary predicate"
    - Fundamental Technology"remain the same as, or similar to, the primary predicate"
    - Operational Principles"remain the same as, or similar to, the primary predicate"
    Safety and EfficacyNo new issues compared to predicates"does not raise any new issues regarding the safety or efficacy when compared to its predicates."

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

    The document mentions "mechanical testing of the modified screw implants."

    • Sample size: Not explicitly stated (e.g., number of screws, number of tests performed). It refers to "the modified screw implants" generally.
    • Data provenance: Lab-generated data from mechanical testing according to ASTM standards for medical devices (product testing). Not applicable to country of origin, retrospective/prospective in the clinical sense.

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

    Not applicable. Ground truth for mechanical testing is based on engineered specifications and standardized test results rather than expert consensus on clinical data.

    4. Adjudication method for the test set

    Not applicable. Mechanical testing results are objective measurements against a standard.

    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 device is a mechanical implant; no AI component or human reader studies are mentioned.

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

    Not applicable. This device is a mechanical implant; no AI algorithm is involved.

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

    For mechanical testing, the "ground truth" would be the pass/fail criteria defined by the ASTM F1717 standard (e.g., maximum force before failure, displacement at yield, fatigue life cycles) for the specific type of spinal fixation device.

    8. The sample size for the training set

    Not applicable. This is a mechanical device, not a machine learning algorithm that requires a training set.

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

    Not applicable. This is a mechanical device, not a machine learning algorithm.

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