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510(k) Data Aggregation
(92 days)
K003351, pre-1976
The Posterior Cable Screw System is intended to reduce pars defect and to stabilize the spinal operative site during fusion procedures as an adjunct to a rigid posterior fixation system cleared/approved for trauma and spondylolisthesis. The system is indicated for the following:
· Defect of the pars interarticularis
· Spondylolisthesis
The Posterior Cable Screw System is indicated for pedicle screw attachment for these indications between T1 and the sacrum. Cables may be used for interspinous wiring. The grommet may be used with the cable. The system is not intended to be used in conjunction with a stainless steel implant.
The Posterior Cable Screw System consists of screws, cables, and grommets utilized for the correction of pars defects. A construct consists of two cable screws with locking set screws and a cable connecting the two screws. The screws are inserted into the pedicles and the cable is passed around the spinous process between the two screws. The grommet surrounds the cable at the location of the spinous process. The cable is tensioned and the set screws are tightened and fully locked per the surgical technique. The implants are manufactured from medical grade titanium alloy per ASTM F136 and cobalt chromium alloy per ASTM F90. The implants are provided sterile. The Posterior Cable Screw System utilizes Class I manual instruments to facilitate implantation of the device components.
This document is a 510(k) premarket notification from the FDA regarding the "Frontier Medical Devices Posterior Cable Screw System." It does not contain information about acceptance criteria or a study that proves the device meets specific performance criteria in the way typically seen for AI/software-as-a-medical-device (SaMD) clearances.
Instead, this document focuses on demonstrating substantial equivalence to predicate devices for a physical medical implant. Therefore, most of the requested information (sample sizes, expert adjudication, MRMC studies, standalone performance for an algorithm, ground truth methods for AI, training set sizes) is not applicable or present in this given text.
However, I can extract the relevant information from the provided text regarding the device's performance in the context of substantial equivalence.
Here's an analysis based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance:
Since this is a physical medical device seeking substantial equivalence, "acceptance criteria" and "reported device performance" are evaluated in the context of mechanical and material properties similar to predicate devices, rather than diagnostic accuracy or algorithmic performance.
Criterion Type | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Functional/Mechanical Performance | Perform in a manner substantially equivalent to predicate systems under dynamic testing conditions (implies meeting or exceeding the mechanical strength and durability standards of the predicate). | "Dynamic tests were provided to support that the Posterior Cable Screw System performs in a manner substantially equivalent to that of predicate systems. No new issues of safety or effectiveness were raised." "Any differences [in technological characteristics compared to predicates] were not considered significant based on mechanical bench testing." |
Material Composition | Utilize medical-grade materials commonly used in similar devices, comparable to predicate devices. | "The implants are manufactured from medical grade titanium alloy per ASTM F136 and cobalt chromium alloy per ASTM F90." (This aligns with industry standards for spinal implants and is implicitly compared to predicate materials). |
Safety and Effectiveness | Not raise any new types of safety or efficacy issues compared to legally marketed predicate devices. | "No new issues of safety or effectiveness were raised" by the dynamic tests. "The minor differences in technological characteristics that do exist do not raise any new types of safety or efficacy issues." "There are no significant differences between the subject system and the predicates which would adversely affect the use of the product." |
Intended Use | Align with the intended use of predicate devices for specific spinal conditions and anatomical locations. | The "Indications for Use" section explicitly states: "The Posterior Cable Screw System is intended to reduce pars defect and to stabilize the spinal operative site during fusion procedures as an adjunct to a rigid posterior fixation system cleared/approved for trauma and spondylolisthesis. The system is indicated for the following: · Defect of the pars interarticularis · Spondylolisthesis" (This is directly comparable to the predicate's use). |
Note: The FDA's 510(k) clearance process for devices like this typically relies on demonstrating that the new device is as safe and effective as a legally marketed predicate device, rather than establishing completely new performance metrics. The "acceptance criteria" are therefore framed in terms of equivalence.
The following questions are not applicable to this document as it pertains to a physical medical device (spinal implant system) and not an AI/software device. The document describes pre-clinical performance data (dynamic tests) for mechanical properties, not an algorithm's diagnostic performance.
- Sample size used for the test set and the data provenance: Not applicable. The "test set" here refers to mechanical bench testing, not a dataset of patient cases.
- 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 engineering specifications and test results, not expert consensus on medical images/data.
- Adjudication method: Not applicable.
- If a multi-reader multi-case (MRMC) comparative effectiveness study was done: Not applicable.
- If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable.
- The type of ground truth used: For this device, the "ground truth" for proving substantial equivalence lies in established engineering standards (ASTM F136, ASTM F90) for materials and mechanical testing methodologies accepted by the FDA for spinal implants.
- The sample size for the training set: Not applicable. There is no "training set" for physical device manufacturing in this context.
- How the ground truth for the training set was established: Not applicable.
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(81 days)
The SCI BacFix® Ti Spinal Fixation System consists of a combination of components which include rods, hooks, locking wedges, screws, transverse connectors, cable-screws, cables and spinous process grommets which are indicated to provide temporary stability of the thoracic, thoracolumbar, or lumbar spine (T1 to S1).
When intended for pedicle screw fixation, implants are 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 or sacral spine: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis). Levels of pedicle screw attachment for these indications range to T1 to the sacrum.
As a pedicle screw system, the BacFix® Spinal Fixation System is also intended for patients having Grade 3 or Grade 4 spondylolisthesis at LS-S1, when utilizing autologous bone graft, when affixed to the posterior when deling and intended to be removed after solid fusion is established. Levels of pedicle screw fixation for this indication are from L3 to the sacrum.
When intended for non-pedicle, posterior screw fixation of the non-cervical spine, the indications are:
- Idiopathic scoliosis.
- Neuromuscular scoliosis/kyphoscoliosis with associated paralysis or spasticity.
- Scoliosis with deficient posterior elements such as that resulting from laminectomy or myelomeningocele.
- Spinal fractures (acute reduction or late deformity).
- Degenerative disc disease (back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
- Neoplastic disease.
- Spondylolisthesis.
- Spinal Stenosis.
- Failed previous fusion.
The cable-screws, cables and spinous process grommets are indicated for:
- Defect of pars lateralis.
- Spondylolisthesis.
Cables and spinous processes grommets may be used for interspinous wiring if additional stability is needed.
The Bach IT Spinal Fixation System is intended to or also with ASTM F136. The BacFix Spinal System is manufactured from thamall andy, which vehip.comectors and other ancillary components. The FTRaton System moudes secews, 1003, noored for market under K973687, and supplemented through II (calif Bach IX 11 Spillar Fixation System was cleared ink transverse connector), K003351 (addition of additional JTUK Submissions: Troughts (addition of end-to-end and side-by-side connectors).
The provided document describes the BacFix Spinal Fixation System and its substantial equivalence to a predicate device, the Isola Spinal System, rather than presenting a study to prove acceptance criteria for a novel device through clinical trials or performance metrics against specific targets. This 510(k) submission relies on nonclinical (biomechanical) testing to demonstrate equivalence.
Here's a breakdown based on the information provided:
1. Table of Acceptance Criteria and Reported Device Performance
Instead of traditional acceptance criteria with quantitative performance metrics, this submission uses the concept of "substantial equivalence" to a predicate device. The primary "acceptance criterion" is that the BacFix system's biomechanical properties fall within the established range of the predicate device.
Acceptance Criterion (via Substantial Equivalence to Isola Spinal System) | Reported Device Performance (BacFix Spinal Fixation System) |
---|---|
Indications for Use: Same as predicate device (Isola Spinal System). | Same as predicate, encompassing temporary stability of the thoracic, thoracolumbar, or lumbar spine (T1 to S1), pedicle screw fixation for various conditions (T1 to sacrum), Grade 3 or 4 spondylolisthesis at L5-S1, and non-pedicle posterior screw fixation for non-cervical spine. Special indications for cable-screws, cables, and spinous process grommets. |
Materials: Biocompatible, similar to predicate. | Titanium 6Al-4V. Predicate uses Stainless steel or titanium. (Deemed equivalent, as both are biocompatible and commonly used in spinal implants). |
Components: Similar screws, rods, hooks, transverse connectors. | Screws, rods, hooks, transverse connectors. Predicate has "Same." |
Product Labeling: Includes all necessary warnings. | Instructions for use and box labeling including all the necessary warning statements. Predicate has "Same." |
Packaging/Sterilization: Non-sterile, single use only. | Non-sterile, single use only. Predicate has "Same." |
Biomechanical Test Results: Stiffness range, per ASTM 1717-96, must be within the range of the Isola Spinal System. | Stiffness range, per ASTM 1717-96, within the range of the Isola Spinal System. |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not explicitly stated in terms of number of devices or constructs. The document mentions "Mechanical testing was conducted on the stiffest and most flexible data collected for BacFix data." This implies a limited set of configurations or specimens were tested to represent the range of the device. The data provenance is not specified, but it would have been generated in a controlled laboratory setting (nonclinical).
- Data Provenance: Nonclinical, laboratory-generated biomechanical test data designed to conform to ASTM F1717-96 (Standard Test Methods for Spinal Implant Constructs in a Corpectomy Model).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
Not applicable. This is a nonclinical bench test, not a study involving expert assessment of medical images or patient outcomes. The "ground truth" here is the physical performance of the device under mechanical load, measured against established engineering standards (ASTM F1717-96) and compared to a predicate device's known performance.
4. Adjudication Method for the Test Set
Not applicable. This is a nonclinical bench test. No adjudication by human observers is described.
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 is a 510(k) submission for a spinal fixation system, not an AI/imaging device. No MRMC study was performed or described.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This is a mechanical device, not an algorithm.
7. The Type of Ground Truth Used
The "ground truth" for this submission is the biomechanical performance data (stiffness range) of the BacFix system as measured according to ASTM F1717-96, and then compared to the known biomechanical performance data of the Isola Spinal System, also measured against the same standard. Essentially, direct physical measurement against a standardized test method.
8. The Sample Size for the Training Set
Not applicable. This is a mechanical device that does not use a "training set" in the context of machine learning.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no "training set" for this type of device submission.
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