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510(k) Data Aggregation

    K Number
    K222355
    Date Cleared
    2023-03-08

    (216 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K022074

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The PathKeeper System is a stereotaxic image guidance system intended for the spationing and orientation of surgical instruments used by orthopedic surgeons and neurosurgeons during posterior approach spinal fusion surgeries when pre-operative CT imagery is available. The System, with PathKeeper spine surgery planning and navigation software and 3D optical camera, is intended as an aid for precisely locating anatomical structures in posterior approach open spine fusion surgery during pedicle screw placement in the thoraco-lumbo-sacral region.

    The device is indicated for posterior approach open spine fusion surgery during pedicle screw placement in the thoracolumbo-sacral region where reference to a rigid anatomical structure can be identified.

    Device Description

    The PathKeeper System is an Orthopedic Surgical Navigation System. The system provides registration between preoperative computed tomography (CT) data and intraoperative Optical Topographic Image (OTI) data acquired using a proprietary OTI 3D camera. The system provides surgical guidance data by displaying the location of optically tracked Surgical Accessories relative to the patient anatomy, based on the calculated registration. Position and orientation data of PathKeeper's Tracked Surgical Accessories are linked to the preoperative scan data using the workstation.

    The PathKeeper System is designed for open spine surgery where reference to a rigid structure - Dynamic Reference Frame (DRF) - spine reference DRF - can be identified relative to the pre-operative image data of the anatomy. In open spine surgery the posterior elements of the operated vertebrae are exposed, either unilaterally or bilaterally. PathKeeper System's 3D image-processing capabilities provide co-registration of the topography of exposed bone structures obtained by the proprietary OTI 3D camera, to the pre-operative CT scan of the patient.

    The PathKeeper System is a portable console.

    The components of the PathKeeper System are, in arbitrary order:

    • . Workstation Cart with Articulated Arm ALSO referred to as Cart with Head (articulated arm and Camera) - A high-resolution proprietary Camera with OTI capabilities mounted to an articulated rigid metallic holding arm, computer (with PathKeeper software installed), monitor, keyboard, mouse, and DVD drive on a medicalgrade cart. The cart with its parts described above, is provided nonsterile with cleaning instructions in the User Manual. There is no patient contact.
    • . PathKeeper Software for pre-operative planning and intra-operative registration and navigation. The PathKeeper Software shall be installed on the workstation computer and displayed on the workstation monitor and will perform the bulk of the required computation for the system to operate. There is no patient contact.
    • . Surgical Accessories Kit including the following components:
      • · 6 Navigation Dynamic Reference Frames (DRFs) which are to be attached to common surgical tools (i.e., Awl, Pedicle probe, and Screwdriver). Note: Tools are not provided with the system and are not subject to this submission
      • Tool setun/calibration plate DRF
      • · Spine reference DRF
    • · Sterilization case (all DRFs above reside in this case)
      These tools are reusable, steam-sterilized accessories serving as spatial markers.
    • . Spheres - Single-use sterile standard navigation Retro-Reflective Spheres. Note: these are acquired off-the-shelf items and not provided with the system or the subject of this submission.
    • . Patient reference attachment mechanism - off-the-shelf attachment mechanism (Walton Cartilage Clamp, 8", Curved, Catalog # 270-170, manufactured by Integra LifeSciences) via which the Spine reference DRF (patient reference) is connected to the bony anatomy of the spine. Note: this is an acquired off-the-shelf item and not provided with the system or the subject of this submission.
    • . Sterile cover for handle - off-the-shelf single-use sterile cover (Universal Surgical Light Handle Cover, Catalog # LB82, manufactured by Steris Corporation) same as for OR lighting handles. Note: this is an off-the-shelf item and not provided with the system or the subject of this submission.
    AI/ML Overview

    Here's an analysis of the acceptance criteria and study information for the PathKeeper System, based on the provided FDA 510(k) summary:

    Acceptance Criteria and Device Performance for PathKeeper System (K222355)

    The provided document describes the non-clinical performance data used to demonstrate the safety and effectiveness of the PathKeeper System.

    1. Table of Acceptance Criteria and Reported Device Performance

    The summary doesn't explicitly list numerical "acceptance criteria" alongside "reported device performance." Instead, it states that "All accuracy specification were met" following various tests. The key performance metric highlighted is accuracy, assessed against ASTM F2554-18 and Target Registration Error.

    While specific numerical targets for acceptance criteria are not detailed in this summary, the conclusions of the verification and validation activities serve as implicit statements of meeting acceptance criteria.

    Acceptance Criteria (Implicit)Reported Device Performance (Summary of Conclusion)
    System Verification: Design requirement specifications are fulfilled.Verification successful if all design requirements have been fulfilled. (Conclusion: Met)
    System Validation: Indications for Use and Customer Requirements are met under simulated use case situations.Validation successful if all user needs met. (Conclusion: Met)
    Usability: Device is safe and effective with respect to user errors.Validation successful if device is safe and effective with respect to user errors. (Conclusion: Met)
    Safety regarding risk analysis: Risk control requirements are effective and mitigate associated risks to an acceptable level.Risk Control requirements are effective and mitigate the associated risks to an acceptable level. (Conclusion: Met)
    Product Safety standards: Compliance with recognized standards (e.g., ANSI AAMI 60601-1, IEC 60601-1-2, ISO 10993-1).Compliance with recognized standards have been verified. (Conclusion: Met)
    Non-Clinical Accuracy: Meet accuracy specifications set by ASTM F2554-18 and Target Error Registration.All accuracy specification were met after testing on phantom models, non-clinical human cadaver performance, and performance registration testing. (Conclusion: Met)

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

    The primary test sets mentioned for accuracy assessment are:

    • Phantom Models: Used for testing against ASTM F2554-18 and Target Error Registration. No specific sample size for phantom models is provided.
    • Human Cadaveric Workflow Study: Performed for usability testing. No specific sample size for cadavers is provided.
    • Non-Clinical Human Cadaver Performance Testing: Used for accuracy assessment. No specific sample size for cadavers is provided.

    The data provenance is non-clinical, involving phantom models and human cadavers. This indicates that the data is not from live patients, and therefore, there is no country of origin of patient data or distinction between retrospective or prospective in the clinical sense.

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

    The document mentions "Surgeon Performed Human Cadaveric Workflow Study - from usability testing" and "Non-Clinical Human Cadaver Performance Testing." However, it does not specify the number of experts used to establish ground truth or their qualifications. It implicitly refers to "surgeons" in the context of usability and performance testing on cadavers, suggesting their involvement in these evaluations.

    4. Adjudication Method for the Test Set

    The document does not describe any adjudication method (e.g., 2+1, 3+1, none) for establishing ground truth on the test sets. The accuracy assessments are stated to be based on comparisons to "ground truth position (on phantom)" but the process for determining this ground truth is not detailed beyond adhering to ASTM F2554-18.

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

    No MRMC comparative effectiveness study was done or reported in this 510(k) summary. The study focuses on the standalone performance of the device in non-clinical settings. There is no mention of human readers improving with AI assistance because the PathKeeper System is a navigation system, not an AI-assisted diagnostic tool that interprets images for human readers.

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

    Yes, a standalone performance study was done. The non-clinical performance data, particularly the accuracy tests on phantom models and cadavers (against ASTM F2554-18 and Target Error Registration), evaluate the device's ability to precisely locate anatomical structures and guide surgical instruments without an explicit "human-in-the-loop" evaluative step for its accuracy claims. The system itself provides the navigational data and the accuracy assessment verifies this data against a known truth.

    7. Type of Ground Truth Used

    The ground truth used for accuracy assessment was primarily established through physical measurements and known positions on phantom models, validated against a standard (ASTM F2554-18), and "ground truth position (on phantom)". For cadaveric studies, the ground truth would typically involve physical measurements or verified anatomical landmarks to assess the accuracy of the system's tracking and navigation. There is no mention of pathology or outcomes data as ground truth, as these are typically associated with clinical studies or diagnostic devices.

    8. Sample Size for the Training Set

    The document does not provide information on the sample size used for the training set of the PathKeeper System's software or algorithms. Device training sets are typically internal developmental data and are not usually disclosed in 510(k) summaries unless specifically relevant to novel AI/ML aspects requiring specific FDA review.

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

    Similarly, the document does not specify how the ground truth for the training set was established. This information is generally part of the internal development process and not typically included in a 510(k) summary unless explicitly requested or critical for demonstrating substantial equivalence for an AI/ML device.

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    K Number
    K191012
    Date Cleared
    2019-08-07

    (113 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K022074, K182928, K142344

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Navigated Pedicle Access Kit is intended to be used in image guided surgery with the 7D Surgical System. The Navigated Pedicle Access Kit is intended for use in posterior spinal surgery to assist in the acurate placement of pedicle screws. The device is sterile and designed for single use.

    Device Description

    The IZI Pedicle Access Kit consists of one pedicle access needle with cannula. The handle contains 4 retro-reflective Navigation Markers (Spherz K022074). The device is sterile and designed for single use. The patient-contacting components are the stainless-steel cannulas and needle. The product is used to gain access to the pedicle in image guided surgeries using the 7D Surgical System. The retro-reflective Navigation Markers (Spherz) that are attached to the handle allows the camera system of 7D Surgical System (K180352) to accurately locate where the tip of the needle is in space.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the IZI Navigated Pedicle Access Kit, based on the provided FDA 510(k) summary:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't explicitly state "acceptance criteria" in a numerical or categorical format like typical sensitivity/specificity thresholds. Instead, it describes performance based on accuracy testing and conformance to standards. The reported device performance is demonstrated by its compliance with these tests and standards, showing that it performs as safely and effectively as the predicate device.

    Test/StandardAcceptance Criteria (Implied)Reported Device Performance
    Non-Clinical Performance Surgical Simulations on Phantom ModelsThe device accurately navigates and assists in pedicle screw placement in a simulated surgical environment with the 7D Surgical System, demonstrating equivalent performance to the predicate.Performed to verify absolute accuracy, repeatability of accuracy, and navigation accuracy with the 7D Surgical System.
    ASTM F2554-10 Standard Practice for Measurement of Positional Accuracy of Computer Assisted Surgical SystemsCompliance with the standard for measuring positional accuracy of computer-assisted surgical systems.Accuracy testing performed according to this standard to verify absolute accuracy and repeatability of the device and navigation accuracy.
    Target Registration Error (TRE) EvaluationTRE should demonstrate acceptable clinical accuracy of the system on phantom models in a clinical simulated environment.Used to evaluate the clinical accuracy of the system on phantom models in a clinical simulated environment.
    Biocompatibility ProfileSame biocompatibility profile as the reference device K1423244.The IZI Pedicle Access Kit has the same biocompatibility profile as the reference device K1423244.

    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 the "phantom models" used in the non-clinical performance surgical simulations. It mentions "phantom models" generally.
    • Data Provenance: The data is based on "Non-Clinical Performance Surgical Simulations Conducted on Phantom Models." This indicates it's retrospective simulation data from a controlled lab environment, not from human patients. The country of origin for the data is not specified, but the applicant (IZI Medical Products LLC) is based in Maryland, USA, and the predicate device manufacturer (7D Surgical Inc.) is in Ontario, Canada, suggesting a North American context for the testing.

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

    The document does not provide details on the number or qualifications of experts involved in establishing the ground truth for the non-clinical simulations. The "ground truth" for TRE is described as "measured physically or otherwise," implying objective physical measurements rather than expert consensus on images.

    4. Adjudication Method for the Test Set:

    No adjudication method is described, as the evaluation appears to be based on objective physical measurements (e.g., TRE) in a simulated environment, not subjective assessment by multiple individuals.

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

    No, an MRMC comparative effectiveness study was not conducted. This document describes a device (a physical surgical instrument) and its navigation accuracy when used with a surgical system, not an AI diagnostic algorithm that assists human readers in interpreting medical images. Therefore, the concept of "human readers improve with AI vs without AI assistance" is not applicable here.

    6. Standalone Performance:

    Yes, a standalone performance assessment (algorithm only, without human-in-the-loop performance) was effectively done. The performance metrics (absolute accuracy, repeatability, navigation accuracy, and TRE) are for the device (IZI Navigated Pedicle Access Kit) and its interaction with the 7D Surgical System in a simulated environment. There isn't a "human-in-the-loop" component being evaluated in these specific non-clinical tests.

    7. Type of Ground Truth Used:

    The ground truth used was objective physical measurements in a phantom model. For TRE, it's defined as "the error discrepancy between the position reported by the image guided surgery system and the ground truth position measured physically or otherwise." This implies a gold standard established by precise physical measurement to compare against the system's reported position.

    8. Sample Size for the Training Set:

    The document does not mention a "training set" or "training data." This submission is for a physical surgical device, not a machine learning or AI algorithm in the context of data training. The "device performance tests" are verification and validation activities, which are akin to testing, not training.

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

    As there is no mention of a training set for an AI/ML algorithm, this question is not applicable to the information provided.

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