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510(k) Data Aggregation
(43 days)
The Life Spine Anterior Cervical Plate System is intended for anterior interbody screw fixation of the cervical spine. This system is indicated for use in temporary stabilization of the anterior spine from C2 to T1 during the development of a cervical spinal fusion in patients with (1) degenerative disc disease, DDD (as defined by neck pain of discogenic origin with degeneration of disc confirmed by patient history and radiographic studies), (2) spondylolisthesis, (3) trauma (including fractures or dislocations), (4) spinal cord stenosis, (5) deformity or curvatures (i.e. kyphosis, lordosis and/or scoliosis), (6) tumors, (7) pseudarthrosis, (8) failed previous fusions.
Nota Bene: This device system is intended for anterior cervical interverterbral body fusions only.
WARNING: This device is not approved for screw attachment to the posterior elements (pedicles) of the cervical, thoracic, or lumbar spine.
The Life Spine Anterior Cervical Plate consists of various sizes of anterior cervical bone plates and screws. Components are available in a variety of sizes to fit patient anatomy. All components are manufactured from implant grade titanium alloy 6A1-4V ELI per ASTM F-136. The Life Spine Anterior Cervical Plate components will be supplied clean and "NON-STERILE'.
The provided 510(k) summary for the Life Spine Anterior Cervical Plate System does not include acceptance criteria or a study demonstrating the device meets performance criteria in the way typically expected for an AI/CADe device. This document is for a physical medical implant (a spinal fixation system), and as such, the performance evaluation focuses on biomechanical properties and material compatibility rather than diagnostic accuracy metrics.
Therefore, many of the requested categories for AI/CADe device studies are not applicable to this 510(k) submission. Below, I've filled in the relevant information based on the provided text, and noted when information is not applicable or not present.
Acceptance Criteria and Device Performance for Life Spine Anterior Cervical Plate System
| Information Category | Acceptance Criteria (Specified in Document) | Reported Device Performance (Specified in Document) |
|---|---|---|
| Primary Performance Metric | Not explicitly stated as acceptance criteria, but substantial equivalence in biomechanical testing is the goal. | Biomechanical testing in accordance with ASTM F1717 was conducted. Substantial equivalence to predicate devices (Life Spine NEO™ Cervical Plating System K040844, Life Spine KINETIC® Anterior Cervical Plate K062643) in indications for use, design, function, and materials used was demonstrated. |
| Material Compatibility | Use of implant grade titanium alloy 6A1-4V ELI per ASTM F-136. | Components are manufactured from implant grade titanium alloy 6A1-4V ELI per ASTM F-136. |
| Sterility | Supplied clean and "NON-STERILE". | Supplied clean and "NON-STERILE". |
| Indications for Use (Equivalence) | Equivalent indications for use to predicate devices. | The device's intended use mirrors that of the predicate devices. |
| Design and Function (Equivalence) | Equivalent design and function to predicate devices. | Substantial equivalence in design and function was demonstrated. |
Study Details:
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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. Biomechanical testing (ASTM F1717) uses physical test specimens of the device, not a "test set" of patient data as would be used for AI/CADe. The number of physical units tested is not specified.
- Data Provenance: Not applicable. The testing is laboratory-based biomechanical testing of the device itself.
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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. Ground truth, in the context of AI/CADe devices, refers to an agreed-upon clinical diagnosis or finding. For a physical implant, "ground truth" relates to material properties and mechanical performance measured against standards, not expert medical consensus on a dataset.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. This refers to adjudication of clinical findings by experts, which is not relevant for biomechanical testing of a physical implant.
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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 not an AI/CADe device.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an AI/CADe device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Ground Truth: For this type of device, the "ground truth" for performance is defined by established engineering standards and material specifications. Specifically, ASTM F1717 provides the methods and criteria for testing spinal implant constructs, and ASTM F136 specifies the standard for the titanium alloy material. The device's performance is compared against the expected behavior for devices meeting these standards and the performance of the chosen predicate devices.
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The sample size for the training set:
- Not applicable. This is not an AI/CADe device.
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How the ground truth for the training set was established:
- Not applicable. This is not an AI/CADe device.
Summary of the Device Evaluation:
The Life Spine Anterior Cervical Plate System's acceptance criteria and proof of performance are based on demonstrating substantial equivalence to legally marketed predicate devices. This is achieved through:
- Material Specification: Using an implant grade titanium alloy (Ti 6A1-4V-ELI) that conforms to ASTM F-136, a recognized standard for surgical implant materials.
- Biomechanical Testing: Conducting biomechanical tests in accordance with ASTM F1717, a standard specifically for spinal implant constructs. These tests evaluate the mechanical properties and stability of the device. The results from these tests would have been compared to the performance of the predicate devices to show that the new device performs at least as safely and effectively.
- Comparison of Indications for Use, Design, and Function: The submission explicitly states that the device was shown to be substantially equivalent to predicate devices in these aspects. This means clinical indications, physical design, and how the device is intended to perform its function were determined to be similar enough that no new safety or effectiveness concerns are raised.
In essence, for this physical medical device, "acceptance criteria" are implied by the requirements for substantial equivalence, which primarily involve adherence to recognized material standards and performance comparable to existing, legally marketed devices as demonstrated through established biomechanical testing protocols.
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(29 days)
The NEO™ Anterior Cervical Plate System is intended for anterior interbody screw fixation of the cervical spine. This system is indicated for use in temporary stabilization of the anterior spine from C2 to T1 during the development of a cervical spinal fusions in patients with degenerative disc disease (as defined by neck pain of discogenic origin with degeneration of disc confirmed by patient history and radiographic studies); spondylolisthesis; trauma (including fractures or dislocations); spinal cord stenosis; deformity or curvatures (i.e. kyphosis, lordosis or scoliosis); tumors: pseudarthrosis; and / or failed previous fusions.
WARNING: This device is not approved for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic, or lumbar spine.
The NEO™ Anterior Cervical Plate consists of various sizes of anterior cervical bone plates, screws and screw locking tabs. Components are available in a variety of sizes to fit popient. anatomy. All components are manufactured from implant grade titanium alloy 6A1-4V EIJ per ASTM F-136. The NEO™ Anterior Cervical Plate components will be supplied clean and "NON-STERILE".
Here's an analysis of the provided text regarding the acceptance criteria and supporting study for the NEO™ Anterior Cervical Plate:
This document is a 510(k) Summary of Safety and Effectiveness for a medical device called the NEO™ Anterior Cervical Plate. In the context of 510(k) submissions, the “acceptance criteria” and "study that proves the device meets the acceptance criteria" are generally framed in terms of demonstrating substantial equivalence to a predicate device, rather than detailed performance metrics against specific, quantitative acceptance criteria common in software or diagnostic device evaluations.
Here's a breakdown based on the information provided:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Biomechanical Performance (Strength, Durability, Stability) | Biomechanical testing in accordance with ASTM F1717 was conducted to demonstrate substantial equivalence. |
| Material Compatibility/Safety | Manufactured from medical grade titanium alloy described by ASTM F136 (Ti 6AL-4V-ELI). |
| Indications for Use Equivalence | Shown to be substantially equivalent to previously cleared devices in indications for use. |
| Design Equivalence | Shown to be substantially equivalent to previously cleared devices in design. |
| Function Equivalence | Shown to be substantially equivalent to previously cleared devices in function. |
Note: For a 510(k) submission of this type of orthopedic implant, "acceptance criteria" are generally demonstrated through equivalence to a predicate device in terms of safety and effectiveness, which is supported by material testing and biomechanical testing aligning with recognized standards. Specific quantitative performance targets are less frequently disclosed in the summary documents, especially for devices establishing substantial equivalence to prior-generation predicate devices.
Study Information:
2. Sample Size Used for the Test Set and Data Provenance
- The document mentions "Biomechanical testing in accordance with ASTM F1717." ASTM F1717 is a standard for "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model." This standard typically outlines how tests should be performed and what parameters to measure (e.g., stiffness, displacement, fatigue life), but it does not specify a "sample size" in the clinical sense (e.g., number of patients).
- For biomechanical testing, the "sample size" would refer to the number of test specimens (e.g., number of device constructs tested). This specific number is not provided in the document.
- The data provenance is laboratory testing, not human or patient data. Therefore, the concepts of "country of origin of the data" and "retrospective or prospective" do not apply.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This question is not applicable to this type of device and study. The "ground truth" for biomechanical testing is typically established by the adherence to and results of a recognized international standard (ASTM F1717) and engineering principles, not through expert consensus on clinical cases. The "experts" would be the engineers and technicians conducting the tests and interpreting the results against the standard and predicate device data.
4. Adjudication Method for the Test Set
- Not applicable. Adjudication methods (like 2+1, 3+1) are used for clinical studies involving human readers or evaluators, not for direct biomechanical engineering tests.
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. This is a hardware orthopedic implant (anterior cervical plate). An MRMC study is relevant for diagnostic devices, particularly AI-powered ones. There is no AI component mentioned or implied.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- No. This is a hardware orthopedic implant. This question pertains to AI/software.
7. The Type of Ground Truth Used
- The "ground truth" for demonstrating substantial equivalence for this device is based on engineering standards and direct physical measurements derived from biomechanical testing, compared to the known performance of a predicate device. It is not based on expert consensus, pathology, or outcomes data in the clinical sense.
8. The Sample Size for the Training Set
- Not applicable. There is no "training set" as this is not an AI/machine learning device.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. There is no "training set."
In summary:
The provided document describes a 510(k) submission for a physical medical implant. The primary "study" mentioned is biomechanical testing in accordance with ASTM F1717. This testing serves to demonstrate that the device performs mechanically in a manner substantially equivalent to its predicate device(s), thereby establishing its safety and effectiveness for its intended use and material composition. The questions regarding AI, expert consensus, clinical sample sizes, and adjudication methods are not relevant to this type of regulatory submission or device.
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