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510(k) Data Aggregation

    K Number
    K193396
    Manufacturer
    Date Cleared
    2020-02-05

    (61 days)

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

    The PERLA® TL posterior osteosynthesis system is intended to provide immobilization and stabilization 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: degenerative disc disease; spondylolisthesis; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis). When used for posterior non-cervical pedicle screw fixation in pediatric patients, the PERLA® TL posterior osteosynthesis system is indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. The PERLA® TL posterior osteosynthesis system is intended to be used with autograft and/or allograft.
    Pediatric pedicle screw fixation is limited to a posterior approach.

    Device Description

    The PERLA® TL posterior osteosynthesis system consists of a range of screws, rods set screws, hooks, rod connectors and cross-connectors. These connecting components can be rigidly locked to the rod in a variety of configurations to be adapted for the individual case. The Perla®TL system is manufactured from medical grade titanium alloy and medical grade cobalt chromium conforming respectively to standards ASTM F136 and ASTM F1537.
    The PERLA® TL posterior osteosynthesis implants are delivered either non sterile or sterile (gamma sterilization) and supplied with dedicated surgical instruments (reusable - provided non-sterile except for the drill supplied as sterile or not sterile). Bacterial endotoxin testing as specified in USP standard is used for pyrogenicity testing to achieve the Endotoxin limit of 20 EU / device.

    AI/ML Overview

    This document pertains to the PERLA® TL posterior osteosynthesis system, a medical device, not an AI/ML device. Therefore, the questions related to AI/ML specific aspects such as sample sizes for test/training sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, and ground truth establishment for training sets are not applicable.

    However, based on the provided text, I can extract information regarding the device's acceptance criteria and the study conducted to prove it meets these criteria, focusing on the mechanical aspects relevant to this type of medical device.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Bench Testing per ASTM Standards)Reported Device Performance (PERLA® TL System)
    Static Axial Gripping per ASTM F1798: Must meet or exceed the performance of the predicate device.Results demonstrate comparable mechanical properties to the predicate device (ROMEO® 2 Posterior Osteosynthesis System).
    Static Axial Torque Gripping per ASTM F1798: Must meet or exceed the performance of the predicate device.Results demonstrate comparable mechanical properties to the predicate device (ROMEO® 2 Posterior Osteosynthesis System).
    Static Compression Bending per ASTM F1717: Must meet or exceed the performance of the predicate device.Results demonstrate comparable mechanical properties to the predicate device (ROMEO® 2 Posterior Osteosynthesis System).
    Static Torsion per ASTM F1717: Must meet or exceed the performance of the predicate device.Results demonstrate comparable mechanical properties to the predicate device (ROMEO® 2 Posterior Osteosynthesis System).
    Dynamic Compression Bending per ASTM F1717: Must meet or exceed the performance of the predicate device.Results demonstrate comparable mechanical properties to the predicate device (ROMEO® 2 Posterior Osteosynthesis System).
    Bacterial Endotoxin Limit: Not explicitly stated as "acceptance criteria" but mentioned for pyrogenicity testing. The device must achieve an Endotoxin limit of 20 EU/device as specified in USP standard.Bacterial endotoxin testing as specified in USP standard is used for pyrogenicity testing to achieve the Endotoxin limit of 20 EU / device.

    2. Sample size used for the test set and the data provenance
    The document does not specify the exact sample sizes used for each of the mechanical tests (Static Axial Gripping, Static Axial Torque Gripping, Static Compression Bending, Static Torsion, and Dynamic Compression Bending). These are typically bench tests conducted on a sufficient number of device samples to ensure statistical validity and demonstrate equivalence to the predicate device.
    Data provenance: The tests were conducted according to ASTM standards, which are internationally recognized. The data is from non-clinical testing performed by Spineart to support the 510(k) submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
    Not applicable as this is not an AI/ML diagnostic device requiring expert interpretation for ground truth. The "ground truth" here is the objective measurement of mechanical properties against established ASTM standards and comparison to a legally marketed predicate device.

    4. Adjudication method for the test set
    Not applicable. Mechanical testing governed by ASTM standards uses objective measurements and predefined pass/fail criteria, often through comparison to a predicate device, rather than expert adjudication.

    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, as this is not an AI/ML device.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
    Not applicable, as this is not an AI/ML device.

    7. The type of ground truth used
    For the mechanical tests, the ground truth is established by the specified ASTM standards (e.g., F1798, F1717) themselves, which define methodologies for measuring specific mechanical properties. The performance of the predicate device (ROMEO® 2 Posterior Osteosynthesis System) also serves as a benchmark for demonstrating substantial equivalence. For bacterial endotoxin, the USP standard defines the acceptable limit. A "cadaver lab trial" was also conducted, which provides real-world functional insights, but its "ground truth" would be observational and qualitative regarding surgical handling and fit rather than a strict quantitative measure against a "ground truth" in the diagnostic sense.

    8. The sample size for the training set
    Not applicable, as this is not an AI/ML device. There is no concept of a "training set" in the context of mechanical performance testing for this type of implant.

    9. How the ground truth for the training set was established
    Not applicable, as this is not an AI/ML device.

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