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510(k) Data Aggregation

    K Number
    K091359
    Date Cleared
    2009-09-02

    (117 days)

    Product Code
    Regulation Number
    888.3050
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K080828,K033961,K080143,K032394,K070966

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

    The GSO PCT Spinal System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion. It is intended to be used as a temporary construct that assists normal healing and is not intended to replace normal body structures. The GSO PCT Spinal System should be removed after fusion.

    The GSO PCT Spinal System is intended to promote fusion of the cervical spine and cervico-thoracic junction (C1-T3), and is indicated for the following:

    1. Degenerative disc disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies)
    2. Spondylolisthesis
    3. Spinal stenosis
    4. Fracture or dislocation
    5. Revision of previous cervical or cervico-throracic spine surgery
    6. Tumors

    The use of multi-axial pedicle screws is limited to placement in the upper thoracic spine (T1-T3) for the purpose of anchoring the construct. The multi-axial pedicle screws are not intended to be placed in the cervical spine.

    Device Description

    The GSO PCT Spinal System consists of rods, screws, hooks, and connecting components that can be locked rigidly into various configurations to build a spinal construct specific to the needs of each individual patient. The implants are attached to the spine posteriorly by means of screws and/or hooks joined with rods. Cross connector components are used to attach two rods in parallel. The GSO PCT Spinal System can be installed with any suitable instrumentation.

    The GSO PCT Spinal System components are manufactured from CP Titanium conforming to ASTM F67 and Ti-6A1-4V Titanium alloy conforming to ASTM F136. Devices are available in various diameters, lengths and sizes.

    AI/ML Overview

    This appears to be a 510(k) premarket notification document for a spinal implant system, not an AI/ML medical device. Therefore, many of the requested categories related to AI/ML device performance and testing (e.g., sample size for test set, number of experts, adjudication method, MRMC study, standalone performance, training set details) are not applicable.

    However, I can extract information related to the acceptance criteria and the study performed to demonstrate "device meets acceptance criteria" in the context of a traditional medical device (spinal implant).

    Acceptance Criteria and Reported Device Performance for GSO PCT Spinal System

    1. Acceptance Criteria2. Reported Device Performance
    Sufficient strength for intended use (as demonstrated by mechanical testing according to ASTM F1717).Mechanical testing conducted according to ASTM F1717 demonstrates that the GSO PCT Spinal System has sufficient strength for its intended use.
    Similar indications, design, and materials to legally marketed predicate devices.The GSO PCT Spinal System has a similar indications and design and is manufactured from the same materials as the Mountaineer OCT Spinal System - Depuy Spine, Inc. (K080828), the Altius OCT System - Interpore Cross International (K033961), and the OASYS System - Stryker Spine (K080143, K032394).

    Study Details (Non-AI/ML Medical Device)

    • Sample sized used for the test set and the data provenance: Not applicable. For this type of device, mechanical testing is done on device samples, not patient data sets.
    • 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 standards and measurements, not expert clinician consensus.
    • Adjudication method for the test set: Not applicable.
    • 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/ML device.
    • If a standalone (i.e. algorithm only without human-in-the loop performance) was done: Not applicable. This is not an AI/ML device.
    • The type of ground truth used:
      • For mechanical strength: Engineering standards (ASTM F1717) and physical measurements.
      • For substantial equivalence: Comparison against legally marketed predicate devices based on indications, design, and materials.
    • The sample size for the training set: Not applicable. This is not an AI/ML device.
    • How the ground truth for the training set was established: Not applicable. This is not an AI/ML device.

    Summary of the Study:

    The primary study conducted for the GSO PCT Spinal System was non-clinical mechanical testing.

    • Study Type: Mechanical performance testing.
    • Methodology: The testing was conducted according to ASTM F1717. ASTM F1717, "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model," typically evaluates the static and fatigue strength of spinal implant constructs under various loading conditions (e.g., compression, torsion, bending) to ensure they can withstand the anticipated physiological stresses without failure.
    • Results: The mechanical testing demonstrated that the GSO PCT Spinal System possesses "sufficient strength for its intended use."

    Additionally, the submission relies on demonstrating substantial equivalence to existing legally marketed devices (Mountaineer OCT Spinal System, Altius OCT System, and OASYS System). This comparison serves as a form of "study" to support the safety and effectiveness by showing similarity in:

    • Indications for Use
    • Design
    • Materials of construction (CP Titanium conforming to ASTM F67 and Ti-6A1-4V Titanium alloy conforming to ASTM F136).

    Clinical Testing: The document explicitly states: "Clinical testing was not necessary to demonstrate the substantial equivalence of the GSO PCT Spinal System to the predicate devices." This is common for 510(k) submissions where substantial equivalence can be established through non-clinical data and direct comparison to predicates.

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