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Surgify Halo is a sterile surgical burr indicated for shaping and removal of hard tissue and bone in Neurosurgical, Spinal, ENT, and General Surgical procedures.

The Surgify Halo is a sterile-packaged, single-use rotary cutting device (a burr) made from high-grade metallic materials, designed to cut bone and other hard tissues selectively while minimizing chattering. The device is similar to conventional surgical cutting burrs but includes a ring mechanism in the burr head to reduce chattering. Like traditional burrs, the device is designed to be compatible with commonly marketed, high-speed, surgical drill systems. The Surgify Halo comprises: Shank, Locking Features, Burr Head, and Safety Mechanism (a self-centering ring and spring mechanism installed in the burr head). The moving ring, larger than the burr head, can adopt two positions: First Position (Hard Tissue Mode) where the ring protrudes, preventing cutting edges from engaging, and Second Position (Soft Tissue Mode) where the ring extends beyond the cutting edge, shielding it to minimize accidental soft tissues and an exposed position for cutting hard surfaces like bone.

The Surgify Halo is a sterile surgical burr used for shaping and removing hard tissue and bone in neurosurgical, spinal, ENT, and general surgical procedures. The company performed performance testing and design validation/summative evaluation to demonstrate substantial equivalence to its predicate device (K250380).

Here's a breakdown of the acceptance criteria and study details:

1. Table of Acceptance Criteria and Reported Device Performance

Note: The provided text states that "All tests fulfilled Design input requirements" and "All tests fulfilled Design input and user requirements." It does not explicitly state numerical acceptance criteria for each parameter (e.g., "chatter rate

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Surgify Halo is a sterile surgical burr indciated for shaping and removal of hard tissue and bone in Neurosurgical, Spinal, ENT, and general surgical procedures

The Surgify Halo is a sterile-packaged, single-use rotary cutting device (a burr) made from high-grade metallic materials, designed to cut bone and other hard tissues selectively while minimizing chattering. The device is similar to conventional surgical cutting burrs but includes a ring mechanism in the burr head to reduce chattering. Like traditional burrs, the device is designed to be compatible with commonly marketed, high-speed, surgical drill systems.

The Surgify Halo comprises:

• Shank: Transfers rotary motion from the drill motor to the burr head.
• Locking Features: Located at the distal end of the shank, these features securely attach the burr to the high-speed surgical drill.
• Burr Head: Shaped with two cutting edges for cutting of bone and hard tissue.
• Safety Mechanism: A self-centering ring and spring mechanism installed in the burr head. The moving ring, larger than the burr head, can adopt two positions:
  • First Position: (Hard Tissue Mode) The ring protrudes, preventing the cutting edges from engaging with the work material.
  • Second Position: (Soft Tissue Mode) The ring extends beyond the cutting edge, shielding it to minimize accidental soft tissues and an exposed position for cutting hard surfaces like bone.

The provided text is a 510(k) summary for a medical device (Surgify Halo) and does not contain information about an AI/ML component or a study proving its performance against acceptance criteria in the context of AI/ML. The device is a surgical burr, which is a physical cutting tool, not a software or AI-driven diagnostic or therapeutic device.

Therefore, I cannot extract the requested information regarding acceptance criteria, study details for AI/ML performance, sample sizes, expert involvement, or ground truth establishment related to AI/ML.

The "Performance Data" section describes functional testing for a physical device (durability, chattering, compatibility with drill systems) and sterilization/passivation validation, along with a table of "Design Verification Tests" and their result that "All tests fulfilled Design input requirements". This kind of performance data is standard for mechanical surgical tools and is not related to the performance of an AI/ML algorithm.

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The iBur™ Hubs and Cutting Accessories are intended to be used with the Stryker Consolidated Operating Room Equipment (CORE®) Console and electric and pneumatic motors. When used with these motors, the iBur™ Hubs and Cutting Accessories are intended to cut bone in the following manner: drilling, reaming, decorticating, shaping, dissecting, shaving, and smoothing for the following medical applications: Neuro; Spine; Ear, Nose, and Throat (ENT)/Otorhinolaryngology; and Endoscopic applications.

Specific applications include Craniectomy, Laminotomy/Laminectomy, Minimally Invasive Surgery (MIS) Spine, Expanded Endonasal Approach (EEA)/ Anterior Skull Base/ Endoscopic/ Transnasal/ Transphenoidal, and Orthopedic Spine.

These devices are also usable in the preparation for the placement of screws, metal, wires, pins, and other fixation devices.

iBur™ Cutting Accessories are prescription medical devices that are designed to provide an interface between a cutting accessory and a high speed motor. When used with a motor and a cutting accessory, the iBur™ Hubs are intended to cut, drill, ream, decorticate, shape, dissect, shave and smooth bone in a variety of surgical procedures including the following specialty areas: Neuro, Spine, ENT, Endoscopic. Cutting accessories are single use, sterile devices which have a mount or notch machined at their proximal end and a head with a sharp cutting edge at their distal end. The iBur™ Cutting Accessories are designed to fit the corresponding iBur™ Hubs. The cutting accessories when used with a high speed drill and iBur™ Hubs are intended to cut, drill, ream, decorticate, shape, dissect, shave and smooth bone in a variety of surgical procedures.

This document is a 510(k) premarket notification for a medical device, the Stryker iBur™ Hubs and Cutting Accessories. It outlines the modifications to an existing device, compares it to a legally marketed predicate device (K210377), and provides performance data to demonstrate substantial equivalence.

Here's a breakdown of the requested information based on the provided text:

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

The document does not provide a specific table of acceptance criteria with corresponding numerical performance metrics for the iBur™ device. Instead, it makes a general statement about meeting acceptance criteria and demonstrating sufficiency for intended use.

However, it does indicate the types of performance tests conducted and their qualitative outcomes:

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

The document does not explicitly state the sample size used for the test set or the data provenance. It mentions "performance testing was conducted on the proposed devices" but does not specify the number of devices or units tested.

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)

This information is not applicable to this document. The device is a surgical cutting accessory, not an AI/diagnostic device that requires expert-established ground truth from a test set. The validation focuses on the device's physical performance characteristics.

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

This information is not applicable. Adjudication methods are typically used for establishing ground truth in diagnostic studies, which is not the nature of this submission.

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 information is not applicable. The device is a surgical tool, not an AI system.

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

This information is not applicable. The device is a surgical cutting accessory, not an AI algorithm.

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

This information is not explicitly stated in terms of "ground truth" as it would be for an AI or diagnostic device. For this type of device (surgical cutting accessory), the "ground truth" for performance is established through engineering and material science testing, ensuring the device meets predefined technical specifications for cutting efficacy, safety (e.g., temperature), and structural integrity. This is indicated by the mention of "all acceptance criteria were met for the performance testing."

8. The sample size for the training set

This information is not applicable. The device is a physical product, not an AI model that requires a training set.

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

This information is not applicable. The device is a physical product, not an AI model.

In summary, the provided document is a 510(k) premarket notification for a modified medical device. It focuses on demonstrating that the device's modifications do not alter its fundamental scientific technology or intended use and that its performance remains substantially equivalent to a predicate device through non-clinical performance testing. The questions regarding AI, expert ground truth, and training data are not relevant to this type of device submission.

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Surgify Halo is a sterile surgical burr indicated for shaping and bone in neurosurgical, spinal, ENT, and general surgical procedures.

The Surgify Halo is a rotary cutting device made of high-grade metallic materials. It cuts bone and other hard tissues selectively while reducing chattering. The device is similar to conventional surgical cutting burrs with the addition of a ring mechanism installed in the burr head to reduce chattering. Similar to conventional burrs, the device is designed for use with compatible high-speed surgical drill systems. The Surgify Halo comprises: A shank, which transfers rotary movement of the drill motor to the head. Locking features at the distal end of the shank which allow the burr shank to be locked to a high-speed surgical drill. A head that is shaped to have two cutting edges to cut bone and hard tissue. A safety mechanism consisting of a ring and spring installed in the burr head. The mechanism is self-centering and comprises a spring and a moving ring that is bigger than the burr head. The moving ring can have two different positions: In the first position, the ring protrudes to a level higher than cutting edges and prevents the cutting edges from cutting into the work material. In the second position, the ring retracts into the groove to a level lower than the cutting edges to allow the burr to cut the work material

The provided text describes the Surgify Halo, a sterile surgical burr, and its performance evaluation to demonstrate substantial equivalence to a predicate device (Adeor HiCut Highspeed Instrument).

Here's an analysis of the acceptance criteria and the study details:

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

The document does not explicitly present a table of formal acceptance criteria with specific numerical thresholds. Instead, it states that "All tests fulfilled Design input requirements" and that the "performance of the Surgify Halo burr was comparable to that of the conventional diamond and fluted burrs." This implies that the acceptance criteria were defined by the product's design input requirements and the performance of established devices.

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The Hubly Electric Drill is a single-use, sterile, disposable device intended for use on adult patients during neurosurgical procedures for drilling of cranial bone.

The Hubly Electric Drill is a battery powered cranial drill. It is single-use disposable and provided ethylene oxide sterilized. The drill is designed to create optimal burr holes, in the emergency room, at the bedside, or in the operating room. The system is designed to streamline bedside intracranial access and facilitate the treatment of emergent conditions in adult patients.

The device is a battery-powered hand drill which can be used one-handed using either hand. The drill is trigger-activated after removal of the battery pull tab. The drill has a single speed and turns off when the trigger is released. The drill bit has depth indicators at 5 and 10mm depth, which the physician may use to visually gauge depth of penetration while drilling.

The drill also has an auto-stop feature which detects when the bit breaks through the inner table of the skull and immediately stops the drill. The device has an LED indicator which indicates to the user (green) when they are applying enough force and (red) when the drill stops.

The drill features mechanical plunge prevention with a tapered stainless steel drill may be reactivated any number of times using the trigger if the physician desires.

The provided text describes performance testing for the Hubly Electric Drill. However, it does not contain specific numerical acceptance criteria or numerical reported device performance in a table format, nor does it detail a study proving the device meets specific acceptance criteria in the way requested.

Instead, the document outlines various tests conducted to demonstrate the device's substantial equivalence to a predicate device and its safety and effectiveness.

Here's an attempt to extract and synthesize the information based on the request, noting where information is not explicitly provided in the text:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not provide a table with explicit numerical acceptance criteria and corresponding reported device performance values. It generally states that the device "meets all design specifications and requirements" for bench tests and "all in vivo requirements were met" for the animal study.

2. Sample Size Used for the Test Set and Data Provenance

• Test Set Sample Size: The document does not specify a numerical sample size for any of the performance tests (bench testing, animal study).
• Data Provenance:
  • Bench Testing: Conducted by Hubly Inc. (implied, as they are the applicant).
  • Animal Study: Conducted in a GLP (Good Laboratory Practice) compliant setting using a sheep model. The location/country is not specified.
  • Retrospective/Prospective: The tests described (bench, animal) are prospective studies conducted to support the 510(k) submission.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts

• This information is not provided in the document. The studies described are performance tests and an animal study, not studies relying on expert review for ground truth establishment.

4. Adjudication Method for the Test Set

• This information is not applicable/provided. The described tests are instrumental/procedural performance tests and an animal study, not studies involving human reader interpretation requiring adjudication.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

• No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The document explicitly states: "Clinical testing was not performed on human subjects." The studies focused on bench performance and an animal model.

6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

• The Hubly Electric Drill is a physical medical device (a drill), not an AI algorithm. Therefore, a standalone algorithm performance study is not applicable. The "software verification testing" was conducted on firmware responsible for the automatic stopping feature, but this is an embedded system, not a standalone AI application. The software implements "additional safety features" and has a "Moderate" level of concern.

7. Type of Ground Truth Used

• Bench Testing: Ground truth was implicitly based on engineering design specifications and requirements (e.g., battery life, depth of penetration, trigger performance).
• Animal Study: Ground truth was based on observational outcomes in the sheep model, specifically demonstrating that "Users (Test Device Evaluators) could safely use the Hubly Electric Drill for intracranial access without damaging the dura or brain tissue."

8. Sample Size for the Training Set

• This information is not applicable/provided. The device is a physical drill with embedded firmware, not a machine learning model that requires a training set in the conventional sense. The "software" mentioned is firmware, which is typically developed through traditional software engineering processes, not trained on data.

9. How the Ground Truth for the Training Set Was Established

• This information is not applicable/provided for the reasons stated in point 8.

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The Lorenz Twist Drills are intended to be used for drilling holes in bone during neurosurgical procedures.

Biomet Microfixation Twist Drills are drill bits which can either be attached to a manual instrument handle or attached to a powered handpiece/drill motor and used to drill holes in bone in neurosurgical procedures. The 2.1 x 255mm Drill, 22mm Stop is manufactured from medical grade stainless steel per ASTM F899. The subject drill bit is intended for single use only and is provided non-sterilized by the end-user prior to use. The subject submission seeks to add the compatibility of the 2.1 x 255mm Drill, 22mm Stop drill with neurosurgical stereotactic instrument systems.

The provided text describes the submission of a medical device (2.1 x 255mm Drill, 22mm Stop) for FDA clearance. It details the performance testing conducted, but it does not represent a study involving AI, human readers, or ground truth establishment in the context of medical image analysis or similar diagnostic applications. Instead, it refers to the physical characteristics and usability of a surgical drill.

Therefore, many of the requested categories (e.g., sample size for test set/training set, number of experts, adjudication method, MRMC study, standalone performance, type of ground truth) are not applicable to this type of device and the information provided.

However, I can extract the relevant information regarding the device's acceptance criteria and the study performed for its clearance.

Acceptance Criteria and Device Performance

Study Details (as applicable to a physical surgical instrument)

1. Sample size used for the test set and the data provenance: Not applicable. For the tolerance analysis, dimensional measurements of the drill were compared against the specified dimensions of neurosurgical stereotactic placement devices. For usability, a group of users (not specified in number) would have participated in the summative usability evaluation.

   • Provenance: Not specified, but likely conducted by the manufacturer or a contracted lab.
   • Retrospective/Prospective: The usability evaluation would have been prospective, while the tolerance analysis is a form of design verification.

2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable in the context of establishing "ground truth" as it relates to diagnostic accuracy. For usability testing, healthcare professionals (e.g., neurosurgeons, surgical technicians) would have been involved, but their number and specific qualifications are not detailed.

3. Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable for this type of device. Usability testing typically involves observing user interactions and collecting feedback against predetermined criteria.

4. 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 study concerns the physical characteristics and usability of a surgical drill, not AI software or diagnostic image interpretation.

5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable. This device is a manual surgical tool and does not involve an algorithm.

6. The type of ground truth used (expert concensus, pathology, outcomes data, etc): Not applicable. "Ground truth" in a diagnostic sense is not relevant here. The ground for the tolerance analysis was the dimensional specifications for compatibility, and for usability, it was the safe and effective operation of the device by users according to predefined usability criteria.

7. The sample size for the training set: Not applicable. No training set as this is not a machine learning model.

8. How the ground truth for the training set was established: Not applicable. No training set.

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The Lorenz Twist Drills are intended to be used for drilling holes in bone during neurosurgical procedures.

Biomet Microfixation Twist drills are drill bits which can either be attached to a manual instrument handle or attached to a powered handpiece/drill motor and used to drill holes in bone.

The subject submission seeks to add the 2.1 x 255mm Drill, 22mm Stop to the Lorenz Twist Drills family to be used in neurosurgical procedures.

2.1 x 255mm Drill, 22mm Stop manufactured from medical grade stainless steel per ASTM F899. The subject drill bit is intended for single use only and is provided non-sterile, to be sterilized by the end-user prior to use.

This document is a 510(k) summary for a medical device (a drill for neurosurgical procedures), not a study report for an AI/ML powered medical device. Therefore, it does not contain the information requested in your prompt regarding acceptance criteria, study details, expert involvement, or ground truth establishment for an AI/ML system.

The document focuses on demonstrating substantial equivalence of a new physical drill (2.1 x 255mm Drill, 22mm Stop) to an existing predicate device (Walter Lorenz Surgical, Inc; Lorenz Twist Drills - K062842). This is done through:

• Comparison of Indications for Use, Technological Characteristics, and Material: The document explicitly states that the subject and predicate devices are similar in these aspects.
• Performance Testing: Mechanical tests (Static Cantilever Bend Testing, Static Torsion Testing, and Lifecycle testing) were performed on the subject drill. The conclusion states that "the results have shown them to be substantially equivalent to the predicate device."

Therefore, I cannot provide the requested information about acceptance criteria for an AI/ML device, details of a study involving human readers, or ground truth establishment based on this document.

The document describes a traditional medical device submission, not an AI/ML one.

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Biomet Microfixation Twist Drills are intended for drilling holes in large and small bone during orthopedic, spinal, neurosurgical, medial sternotomy, and oral and maxillofacial procedures.

Biomet Microfixation manufactures and distributes a variety of single use twist drills to aid in the implantation of Biomet Microfixation implants. Biomet Microfixation Twist Drills are intended for drilling holes in large and small bone during orthopedic, spinal, neurosurgical, medial sternotomy, and oral and maxillofacial procedures. The drills are manufactured from Stainless Steel. Some drills contain flutes along the majority of the drill length, while others contain a "stop" feature which prevents further drilling past a designated length. Additionally, some drills contain an "adjustable stop" feature which allows to surgeon to set the stop length intraoperatively. Twist Drills are distributed non-sterile and are intended for single-patient use. Cleaning should only be performed on new or uncompromised drills. The drills should be steam sterilized by the health-care facility prior to use.

This FDA 510(k) summary is for a medical device (Twist Drills), not an AI/ML algorithm. Therefore, many of the requested categories related to algorithm performance, training data, and expert review are not applicable.

Here's an analysis of the provided document based on the available information:

This document describes the FDA's decision to clear the Biomet Microfixation Twist Drills (K213208) as substantially equivalent to a predicate device (Twist Drills K062842).

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

The document states that "Design verification and validation testing were performed on the subject devices" and "The results from all design verification and validation tests confirmed that the subject devices met the predetermined acceptance criteria." However, the specific, quantitative acceptance criteria themselves are not provided in this summary document. The performance is reported as meeting these unspecified criteria.

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

This document discusses performance testing for a physical medical device, not a data-driven AI/ML algorithm. Therefore, terms like "test set" and "data provenance" in the context of data analysis are not directly applicable. The document refers to "design verification and validation testing," which would involve physical samples of the drill. The sample size for these physical tests is not specified in this summary.

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)

This is not applicable as the document describes a physical medical device, not an AI/ML diagnostic or prognostic tool that requires expert-established ground truth.

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

This is not applicable for a physical medical device without a diagnostic component.

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 as the document describes a physical medical device, not an AI-assisted diagnostic tool.

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

This is not applicable as the document describes a physical medical device.

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

For a physical medical device like a drill, "ground truth" generally refers to objective physical and mechanical properties. The validation would typically involve comparing the device's performance against predefined engineering specifications and safety standards, rather than expert consensus on diagnostic images or pathology. The document generally refers to "predetermined acceptance criteria" and "design verification and validation tests."

8. The sample size for the training set

This is not applicable as the document describes a physical medical device, not an AI/ML algorithm that requires a training set.

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

This is not applicable as the document describes a physical medical device.

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The Midas Rex MR8 Depth Stop attachment and tools are indicated for the incision, cutting, removing, and drilling of soft and hard tissue during cranial surgical procedures with the intent to create a hole through the cranium to allow surgeons access to desired surgical locations and/or to facilitate insertion, placement of other surgical devices during such procedures.

The Midas Rex MR8 Depth Stop attachment and tools are intended to create a cranial access hole of a known diameter and depth.

This document (K213454) is a 510(k) premarket notification for a medical device and, as such, does not contain the detailed information necessary to answer all aspects of your request regarding acceptance criteria and a study that proves the device meets those criteria.

Specifically, this submission focuses on demonstrating substantial equivalence to a predicate device, rather than providing a comprehensive study protocol and results for a new device's performance against specific acceptance criteria. The document states that "The changes from the predicate, do not raise any new issues of safety and effectiveness" and that "The following testing was conducted to demonstrate that the modifications to the subject devices are as safe and effective as the predicate." This implies that the focus was on validating that the changes did not degrade performance, and the existing predicate device's performance serves as the benchmark.

Therefore, many of the questions asked cannot be directly answered from the provided text.

Here's an attempt to extract what is available and explain what is missing:

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

The document does not provide a table of acceptance criteria and reported device performance in the way you've requested. Instead, it describes a comparison to a predicate device to demonstrate substantial equivalence. The "performance" is primarily implied by the claim that the technological characteristics are similar and that conducted testing (Product Life Verification, Summative Validation, Biocompatibility Testing) supports the functionality, integrity, and safety and effectiveness for its intended use, making it "as safe and effective as the predicate."

The closest thing to "acceptance criteria" discussed are the aspects compared to the predicate, as shown in the table on pages 5-6. However, these are comparative features, not quantified performance criteria with acceptance thresholds.

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

The document mentions "Product Life Verification," "Summative Validation," and "Biocompatibility Testing." However, it does not specify sample sizes for any of these tests, nor does it provide information on the data provenance (e.g., country of origin, retrospective or prospective). Given the nature of a 510(k) for a mechanical device modification, these would likely be engineering and bench testing, not clinical studies in the typical sense.

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

This information is not provided in the document. The testing described (Product Life, Summative Validation, Biocompatibility) are typically engineering validation tests, not clinical studies requiring expert ground truth in the context of diagnostic AI.

4. Adjudication method for the test set

This information is not provided. As above, the described testing types do not typically involve adjudication methods for "ground truth" derived from expert consensus.

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 or mentioned. This device is a surgical drill accessory, not an AI software/diagnostic device.

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

Not applicable. This device is a mechanical surgical tool component, not an algorithm.

7. The type of ground truth used

The concept of "ground truth" in the way it's typically applied to AI or diagnostic studies (expert consensus, pathology, outcomes data) is not relevant or discussed for this type of mechanical device submission. The "ground truth" for this device would be established by engineering specifications, material properties, and mechanical performance tests.

8. The sample size for the training set

Not applicable. This is a mechanical device, not an AI/machine learning product that requires a training set.

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

Not applicable. As above, this is a mechanical device.

Summary of Findings from the Document:

The K213454 submission demonstrates substantial equivalence primarily by:

• Comparing the subject device's features and intended use to a legally marketed predicate device (K191597).
• Highlighting that the differences are minor (e.g., extended depth setting, minor tool head geometry, new user task, compatibility with MR8 system) and do not raise new safety or effectiveness concerns.
• Stating that risk management (ISO 14971:2019) was conducted and found no new risks.
• Reporting that specific engineering tests were conducted: "Product Life Verification," "Summative Validation," and "Biocompatibility Testing," which "demonstrate that the functionality, integrity, and safety and effectiveness of the subject devices are sufficient for their intended use."

The document's purpose is to show that the modified device is "as safe and effective" as the already cleared predicate, rather than to establish new, distinct performance criteria and demonstrate achievement of those from scratch.

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The P300 Attachment is intended to be used with electric and pneumatic surgical instruments and cutting accessories for cutting, drilling, removal, and shaping of bone in the procedures of: Neuro, Spine, Orthopedic, and General Surgery.

NSK Sterile Cutting Accessory(ies) is for single use only. This device is intended for use, in conjunction with P300 Attachment, in cutting, drilling, removal, and shaping of bone in the procedures of: Neuro, Spine, Orthopedic, ENT, Maxillofacial, and General Surgery.

The P300 Attachment is a powered bone cutting and drilling instruments designed to be used with the Primado2 Total Surgical System (K132264), which provides mechanical power to the attachment. The P300 Attachment is comprised of two families: Standard Attachment 300 and Slim Attachment 300. The Standard Attachment 300 and Slim Attachment 300 consist of angled and straight types of attachments with varying lengths. The Standard Attachment 300 is an attachment to the Primado2 Total Surgical System that can be in either a straight or angled configuration and comes in 5 different tube lengths, ranging from 12 mm to 79 mm. Accessories compatible with the Standard Attachment 300 include 52 NSK Sterile Cutting Accessories, a STD Attachment Beak, and 4 Irrigation Nozzles. The Slim Attachment 300 consists of 2 parts, a Slim Attachment Hub that comes in 2 configurations (straight or angled) and a Slim Tube that comes in 8 configurations and varies in tube lengths from 110 mm to 240 mm, and can be straight, curved, or angled. Accessories compatible with the Slim Attachment 300 include 49 NSK Sterile Cutting Accessories, a Slim Tube Beak and a Slim Tube Hood, and 2 Irrigation Nozzles. The Standard Attachment 300 and Slim Attachment 300 share the same Cleaning Tools for automated cleaning, manual cleaning, and purging. For both the Standard Attachment 300 and the Slim Attachment 300, the length of the bur can be adjusted in six levels. Both the Standard and Slim attachments include a non-slip surface etching on the grip. The attachments consist of stainless steel, polytetrafluoroethylene, Copper-Beryllium Alloy, fluorocarbon rubber, and PEEK.

Here's an analysis of the acceptance criteria and study information for the P300 Attachment and NSK Sterile Cutting Accessories, based on the provided FDA 510(k) summary:

This device is not an AI/ML device, but a surgical attachment. Therefore, most of the requested AI/ML specific criteria (sample size for test set, data provenance, number of experts, adjudication, MRMC study, standalone performance, training set size and ground truth establishment for training set) are not applicable.

Acceptance Criteria and Reported Device Performance

The device appears to be a traditional medical device (Powered Simple Cranial Drills, Burrs, Trephines, and Their Accessories), and the FDA 510(k) summary focuses on demonstrating substantial equivalence to a predicate device through non-clinical bench testing, rather than a clinical study with traditional acceptance criteria for diagnostic performance metrics (e.g., sensitivity, specificity, AUC).

The acceptance criteria are implied by the successful completion of specific non-clinical tests and demonstrations of compliance with relevant standards. The "performance" section describes the results of these tests, which effectively serve as the reported device performance meeting the implicit acceptance criteria of the standards and internal specifications.

Study Information

1. 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 applicable. The "test set" in this context refers to samples used for non-clinical bench testing (e.g., cell cultures, animal models for biocompatibility, physical device units for functional testing). Specific numbers for these types of samples are not provided in the summary. For example, for the "Acute Systemic Toxicity Test," it mentions "mice" but not the count. The biocompatibility testing selected "worst-case representative models" (Slim Attachment 300, specific bur/nozzle models) for evaluation.
   • Data Provenance: The manufacturing site for NAKANISHI INC. is listed as Kanuma, Tochigi 322-8666 Japan. The tests would likely have been conducted by or for the manufacturer. The FDA 510(k) summary does not specify the country of origin for the testing facilities, but it typically aligns with the manufacturer's region or accredited labs. All testing is prospective in nature, as it's conducted specifically for demonstrating the safety and effectiveness of the device being submitted.

2. 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 non-clinical submission for a surgical instrument. "Ground truth" in the context of expert consensus, as might be used for AI diagnostic devices, is not a concept applied here. The "truth" is established by adherence to recognized international and national standards (e.g., ISO, ASTM, ANSI/AAMI) for material safety, reprocessing, and sterilization, verified through laboratory testing.

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

   • Not applicable. Adjudication methods are typically relevant for clinical studies or studies involving human interpretation of data where consensus is needed to establish ground truth for a diagnostic outcome. This submission relies on objective physical, chemical, and biological testing results.

4. 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. This is a non-clinical submission for a mechanical surgical instrument. MRMC studies are used for evaluating the performance of AI/CADe diagnostic devices in conjunction with human readers.

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

   • No. This device does not have an algorithm or AI component.

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

   • For this device, the "ground truth" is defined by established scientific and engineering principles, as articulated in national and international standards (e.g., ISO 10993 for biocompatibility, ISO 17664/17665/ANSI/AAMI ST79 for reprocessing, ISO 11137-2 for sterilization). Compliance with these standards, demonstrated through specific laboratory tests (e.g., cytotoxicity assays, sensitization tests, pyrogenicity tests, material characterization), serves as the evidence that the device is safe and performs as intended.

7. The sample size for the training set:

   • Not applicable. This device does not use an AI/ML algorithm that requires a training set.

8. How the ground truth for the training set was established:

   • Not applicable, as there is no training set for an AI/ML algorithm.

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