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510(k) Data Aggregation

    K Number
    K193365
    Date Cleared
    2020-01-27

    (54 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    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/ilum) and 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 purpose of this submission is to add the M.U.S.T. MC Cross Connectors to the M.U.S.T. Pedicle Screw System (K132878, K171170, K121115, K153664, K141988) for the stabilization and fusion of the non-cervical spine. The M.U.S.T. Pedicle System includes a wide range of implants: Rods, Polyaxial and Mono-axial Pedicle Screws, Hooks, Connectors of various design and size, that are used in combination to compose a spinal construct.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the M.U.S.T. Pedicle Screw System, which is a medical device for spinal fixation. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than performing novel clinical studies to prove performance against specific acceptance criteria.

    Therefore, the requested information regarding acceptance criteria, device performance, study details (sample size, data provenance, expert validation, ground truth, MRMC studies, standalone performance, training set) typically associated with a de novo or PMA submission for a new device's efficacy and safety is not applicable to this 510(k) summary.

    Here's how the provided information aligns with the request, highlighting what is and isn't available from this document:

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

    • Not Applicable in this Context. For a 510(k), the "acceptance criteria" for the device's performance are primarily established by the performance of the predicate devices. The study performed is to demonstrate that the new device (M.U.S.T. MC Cross Connectors) performs equivalently to the predicate devices and meets relevant industry standards rather than achieving specific performance metrics against a disease outcome.

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

    • Not Applicable for clinical data.
    • Mechanical Testing:
      • Sample Size: The document states that "worst-case implants" were tested, but it does not specify the exact number of samples used for each test (Static compression/bending, Dynamic compression bending).
      • Data Provenance: The provenance of the data is from internal testing conducted by Medacta International SA. The country of origin for the testing facility is not explicitly stated, but Medacta International SA is based in Switzerland. The studies are prospective in the sense of being planned tests on newly manufactured components.

    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)

    • Not Applicable. This is a mechanical device, not a diagnostic or AI-driven system that requires expert interpretation for ground truth establishment. The "ground truth" for mechanical testing is derived from engineering principles and validated test standards.

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

    • Not Applicable. Adjudication methods like 2+1 or 3+1 are used in clinical trials or studies involving expert review of images or clinical outcomes. For mechanical performance testing, the results are typically quantitative and objective, based on physical measurements and material properties.

    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. An MRMC study is relevant for diagnostic devices, particularly those involving image interpretation by human readers, often comparing human performance with and without AI assistance. This device is a surgical implant, not a diagnostic tool, and involves no human "readers" in the context of interpretation.

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

    • Not Applicable. This question is also relevant for AI/software as a medical device (SaMD). The M.U.S.T. Pedicle Screw System is a physical implant, not an algorithm.

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

    • Mechanical Testing Standards. For the non-clinical performance tests, the "ground truth" is implied by the adherence to and successful completion of established industry standards for spinal implant testing, specifically ASTM F1717 (Static compression/bending and Dynamic compression bending) and European Pharmacopoeia §2.6.14 / USP chapter <85> and <151> for pyrogenicity. The acceptance criteria are embedded within these standards.

    8. The sample size for the training set

    • Not Applicable. The concept of a "training set" doesn't apply to the mechanical testing of a physical medical device like this, which doesn't involve machine learning algorithms.

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

    • Not Applicable. As there is no training set for an algorithm, this question is not relevant.

    Summary of Relevant Information from the Document for a 510(k):

    The document explicitly states:

    • "No clinical studies were conducted." This reinforces that the focus is on non-clinical, mechanical performance and comparison to predicate devices.
    • Performance Tests: The device underwent "Non-Clinical Studies" including:
      • Static compression / bending per ASTM F1717
      • Dynamic compression bending per ASTM F1717
      • Cadaver studies (though no specifics are given beyond "Cadaver studies O")
      • Pyrogenicity testing (Bacterial Endotoxin Test per European Pharmacopoeia §2.6.14/USP chapter <85> and pyrogen test per USP chapter <151>).
    • Acceptance Criteria for Non-Clinical Tests: "Testing was conducted according to written protocols with acceptance criteria that were based on standards." The implicit acceptance criteria are that the device meets or exceeds the performance of legally marketed predicate devices, as defined by the standards (e.g., ASTM F1717) and the specific testing protocols.

    In essence, for a 510(k) for a physical implant, the "study that proves the device meets the acceptance criteria" is primarily the non-clinical performance testing demonstrating that the device is substantially equivalent to existing, legally marketed predicate devices, by meeting relevant recognized standards. This is a comparison of technological characteristics and performance, not a clinical efficacy study with human subjects.

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