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510(k) Data Aggregation

    K Number
    K222281
    Date Cleared
    2022-10-26

    (89 days)

    Product Code
    Regulation Number
    882.4725
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Intracept Intraosseous Nerve Ablation System is intended to be used in conjunction with radiofrequency (RF) generators for the ablation of basivertebral nerves of the L3 through S1 vertebrae for the relief of chronic low back pain of at least six months duration that has not responded to at least six months of conservative care, and is also accompanied by features consistent with Type 1 or Type 2 Modic changes on an MRI such as inflammation, edema, vertebral endplate changes, disruption and fissuring of the endplate, vascularized fibrous tissues within the adjacent marrow, hypointensive signals (Type 1 Modic change), and changes to the vertebral body marrow including replacement of normal bone marrow by fat, and hyperintensive signals (Type 2 Modic change).

    Device Description

    The Intracept Intraosseous Nerve Ablation System (Intracept System) is comprised of sterile, singleuse components: The Intracept Access Instruments include cannulas and stylets that provide access to the intended site of radiofrequency (RF) ablation. The Intracept RF Probe conducts RF energy to the target location. To obtain the energy needed for tissue ablation, the Intracept RF Probe is used with the Relievant Radiofrequency Generator (RFG). The Relievant RFG is a universal AC powered, microcontroller controlled, bipolar RF generator intended to deliver RF energy to a targeted site. During RF energy delivery, power is continuously monitored and controlled, based on temperature and impedance measurements at the treatment site, to ensure proper operation. Currently, the Relievant RF Generator (reference device (K171143)) is the only compatible RF generator for use with the Intracept System. The Intracept System uses RF energy to ablate the basivertebral nerve for relief of chronic low back pain and involves a two-step process. First, utilizing the Access Instruments, based on a minimally invasive, transpedicular or extrapedicular approach, a cannula and stylets are placed into the vertebral body to create a path or channel to the terminus of the basivertebral foramen. The RF Probe is then placed into this channel and controlled RF energy is delivered to ablate the basivertebral nerve. This nerve has been identified as a proprioceptive sensory nerve with enervation of the vertebral endplates.

    AI/ML Overview

    The Relievant Medsystems, Inc. Intracept Intraosseous Nerve Ablation System (K222281) did not undergo a clinical study as substantial equivalence was determined based on non-clinical performance testing. The device is a modification of a previously cleared device (K213836). Modifications were made to the Access Instruments component of the system to improve usability and performance, but the RF Probe remained unchanged.

    Here's a summary of the non-clinical testing:

    1. Table of Acceptance Criteria and Reported Device Performance:

    TestAcceptance CriteriaReported Device Performance
    Biocompatibility TestingCompliance to applicable ISO 10993 standards for tissue/bone/dentin contact <24 hours. Materials used in construction are equivalent to the Predicate Device.All tests passed.
    CytotoxicityISO 10993-5 (MEM Elusion)PASS
    SensitizationISO 10993-10 (Guinea Pig Maximization Sensitization)PASS
    Acute Systemic ToxicityISO 10993-11 (Acute Systemic Injection Test in Mice)PASS
    Intracutaneous ReactivityISO 10993-10 (Intracutaneous Reactivity Irritation Test in Rabbits)PASS
    Dimensional and Functional TestingDevices are equivalent in size, materials, and construction to the Predicate Device.All tests passed.
    CorrosionISO 10555-1, Annex A: No visible signs of corrosion.PASS
    TransitASTM D4169 - Standard Practice for Performance Testing of Shipping Containers and Systems (DC 13, assurance level II)PASS
    Gross LeaksASTM F2096 - Standard Test Method for Detecting Gross Leaks in Packaging by Internal Pressurization (Bubble Test)PASS
    Seal StrengthASTM F88/F88M - Standard Test Method for Seal Strength of Flexible Barrier Materials (Seal peel ≥1.0 lbs/in)PASS
    MechanicalMet all performance testing per Product Specifications.PASS
    SterilizationANSI/AAMI/ISO 11137-1 and 11137-2: Sterility assurance of 10-6.PASS
    Interface and Primary Operating Function TestingDevices have equivalent performance to the Predicate Device.All tests passed.
    Simulated UseFollowing exposure to 6 full deployments, devices remained functional without damage and met interface requirements.PASS
    UsabilityIEC 62366-1: Application of Usability Engineering to Medical Devices. Usability testing simulated in sawbones.PASS

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

    • Sample Size: Not explicitly stated for each bench test, but the usability testing involved "15 users."
    • Data Provenance: Not applicable as these were non-clinical bench tests. The provenance is internal laboratory testing.

    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, as this was non-clinical bench testing. The evaluation was against established standards and product specifications.

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

    Not applicable, as this was non-clinical bench testing. Results were objectively measured against predefined criteria in relevant standards.

    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

    No MRMC study was done, as this was a non-clinical submission for device modification, not an AI/software device requiring comparative effectiveness studies with human readers.

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

    Not applicable, as this is a physical medical device (nerve ablation system), not an AI algorithm.

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

    Not applicable. For non-clinical bench testing, the "ground truth" is defined by the technical specifications and international standards (e.g., ISO, ASTM, AAMI, IEC) to which the device must conform.

    8. The sample size for the training set

    Not applicable, as this was not an AI/ML device requiring a training set.

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

    Not applicable, as this was not an AI/ML device requiring a training set.

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