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510(k) Data Aggregation

    K Number
    K090779
    Date Cleared
    2009-07-07

    (106 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K033090, K042673, K051286, K071890

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

    The Zodiac® Polyaxial Spinal Fixation System is intended for use as a posterior spinal fixation device to aid in the surgical correction of various spinal deformities and pathologies of the spine. It is intended to provide stabilization during the development of fusion utilizing a bone graft. Specific indications for the Zodiac® Polyaxial Spinal Fixation System are dependent in part on the configuration of the assembled device and the method of attachment to the spine.

    It is intended that this device, in any system configuration, be removed after development of solid fusion mass. Hook component indications are limited to T7-L5. Sacral-iliac screw indications are limited to the sacrum-iliac crest only.

    1. The Zodiac® Polyaxial Spinal Fixation System when used as a hook and sacral iliac screw fixation system (nonpedicle screw) is intended for:

    a. Patients having fractures of the thoracic and lumbar spine,

    b. Patients having deformity (i.e. idioscoliosis, neuromuscular scoliosis or kyphoscoliosis with associated paralysis or spasticity),

    c. Patients having spondylolisthesis (i.e. isthmic spondylolisthesis, degenerative spondylolisthesis, and acute pars fracture allowing spondylolisthesis).

    1. The Zodiac® Polyaxial Spinal Fixation System, when used a pedicle screw system in the thoraco-lumbo-sacral iliac region of the spine is intended for degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal turnor and failed previous fusion (pseudoarthrosis).

    2. In addition, the Zodiac® Polyaxial Spinal Fixation System, when used as a pedicle screw system is intended for:

    a. Patients receiving only autogenous bone graft

    b. Patient having the device fixed or attached to the lumbar and sacral iliac spine and having severe spondylolisthesis grade 3 or 4 at the fifth lumbar-first sacral (L5-S1) vertebral joint.

    1. The Zodiac® Polyaxial Spinal Fixation System, when used as a laminar hook and bone screw system is intended for:

    a. Patients having fractures of thoracic and lumbar spine.

    b. Patients having thoracolumbar deformity (i.e. idioscoliosis, neuromuscular scoliosis, kyphoscoliosis or kyphoscoliosis with associated paralysis or spasticity),

    c. Patients having spondylolisthesis (i.e. Isthmic spondylolisthesis, degenerative spondylolisthesis and acute pars fracture allowing spondylolisthesis).

    Device Description

    The Zodiac® Polyaxial Spinal Fixation System is intended for use as a posterior spinal fixation device to aid in the surgical correction of various spinal deformities and pathologies in the thoracolumbo-sacral iliac portion of the spine. It is intended to provide stabilization during the development of fusion utilizing a bone graft. Specific indications for the Zodiac® Polyaxial Spinal Fixation System are dependent in part on the configuration of the assembled device and the method of attachment to the spine.

    AI/ML Overview

    This document describes a 510(k) submission for the Zodiac® Polyaxial Spinal Fixation System, which is a medical device. As such, the "acceptance criteria" and "device performance" are not related to diagnostic accuracy or clinical outcomes as would be the case for AI/ML devices. Instead, they refer to the device's mechanical properties and its substantial equivalence to previously approved devices. The "study" refers to mechanical testing.

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


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

    Acceptance Criteria (Implied)Reported Device Performance
    Mechanical and dynamic performance per recognized consensus standards and FDA guidance for spinal systems."Mechanical and dynamic testing was performed which provides reasonable assurance of safety and effectiveness for its intended use."
    Satisfaction of requirements for posterior lumbar fixation."This testing clearly demonstrated that the performance characteristics satisfy the requirements of posterior lumbar fixation."
    Substantial equivalence to predicate Zodiac® Polyaxial Spinal Fixation System devices in terms of general design, intended use, and technological characteristics."The mechanical performance of the Zodiac® Polyaxial Spinal Fixation System additional components is substantially equivalent to the predicate Zodiac® Polyaxial Spinal Fixation System device. It is similar in terms of general design, intended use, and technological characteristics to the predicate devices."

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

    This information is not applicable as this is a mechanical device, not an AI/ML diagnostic or prognostic device that uses data for testing. The "test set" would refer to the physical samples of the device undergoing mechanical testing. The document states "Mechanical and dynamic testing was performed," implying laboratory testing of device components.

    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. For mechanical devices, "ground truth" is established by engineering specifications, material properties, and standardized testing protocols, not by expert consensus on clinical data.

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

    This information is not applicable. Adjudication methods are used for resolving discrepancies in expert interpretations of data, which is not relevant for mechanical testing of a spinal fixation system.

    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. This is a physical spinal fixation device, not an AI/ML diagnostic tool. Therefore, MRMC studies involving human readers and AI assistance are not relevant.

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

    This information is not applicable. This is a physical spinal fixation device, not an algorithm.

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

    For mechanical devices, the "ground truth" is typically derived from engineering specifications, material science principles, and established international and national consensus standards (e.g., ASTM, ISO standards for spinal implants) that define performance requirements for strength, fatigue life, and other mechanical properties. The document explicitly states, "Performance testing was performed per the recognized consensus standards and per the guidance document, Spinal System 510(k)s - Guidance for Industry and FDA Staff," indicating adherence to these established engineering "ground truths."

    8. The sample size for the training set

    This information is not applicable. This is a physical medical device. "Training set" refers to data used to train AI/ML models, which is not relevant here.

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

    This information is not applicable. As no training set is used for a mechanical device.


    Summary of the Study:

    The study described is a series of mechanical and dynamic performance tests conducted on the Zodiac® Polyaxial Spinal Fixation System and its additional components.

    • Objective: To provide reasonable assurance of the safety and effectiveness of the device for its intended use and to demonstrate substantial equivalence to predicate devices.
    • Methodology: Testing was performed according to "recognized consensus standards and per the guidance document, Spinal System 510(k)s - Guidance for Industry and FDA Staff." This involved evaluating both "static and fatigue performance characteristics."
    • Results: The testing "clearly demonstrated that the performance characteristics satisfy the requirements of posterior lumbar fixation." Furthermore, the "mechanical performance of the Zodiac® Polyaxial Spinal Fixation System additional components is substantially equivalent to the predicate Zodiac® Polyaxial Spinal Fixation System device."
    • Conclusion: The tests confirmed that the device's mechanical properties were comparable to previously approved predicate devices, supporting its substantial equivalence claim to the FDA.
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