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510(k) Data Aggregation

    K Number
    K132757
    Manufacturer
    Date Cleared
    2013-11-20

    (77 days)

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

    K070229, K072914, K080611, K080792, K121630

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

    The EVEREST Spinal System may be used in conjunction with the RANGE® (MESA® and DENALI®) Spinal Systems, all of which are cleared for the following indications:

    Non-cervical, pedicle screw fixation devices for posterior stabilization as an adjunct to fusion for the following indications: Trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures (i.e. scoliosis, kyphosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion. It is also indicated for the treatment of severe spondylolisthesis ( grades 3 and 4 ) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine ( L3 to sacrum) with removal of the implants after the attainment of a solid fusion.

    Non-cervical, non-pedicle spinal fixation devices intended for posterior or anterolateral thoracolumbar screw stabilization as an adjunct to fusion for the following indications: degenerative disc disease (DDD ) (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies ); spondylolisthesis; trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures ( i.e. scoliosis, kyphosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion.

    Device Description

    The Everest Spinal System is a top-loading, multiple component, posterior (thoraciclumbar) spinal fixation system which consists of pedicle screws, rods, locking set screws, and hooks.

    AI/ML Overview

    The provided text describes a 510(k) summary for the Everest Spinal System, which is a medical device. As such, the concept of "acceptance criteria" and "device performance" as it pertains to medical image analysis, AI algorithms, or diagnostic tools with quantifiable metrics like sensitivity, specificity, or AUC, is not directly applicable in this context.

    Instead, for a spinal fixation system like the Everest Spinal System, "acceptance criteria" are typically met through demonstrating substantial equivalence to predicate devices based on design, materials, function, and mechanical performance. The "study" that proves the device meets these criteria is typically a mechanical testing study.

    Here's an analysis based on the provided text, reinterpreting the request for a device like this:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Demonstration of Substantial Equivalence)Reported Device Performance
    Mechanical Performance: Performed equally to or better than predicate devices in specified tests.The subject device performed equally to or better than predicate systems in static compression bending, static torsion, and dynamic compression in accordance with ASTM F1717.
    Design Features & Sizing: Substantially the same as predicate systems.The design features and sizing of the components were compared and found to be substantially the same as predicate systems.
    Materials: Manufactured from specified materials (Titanium Alloy and Cobalt Chrome) per ASTM and ISO standards.Devices are manufactured from Titanium Alloy and Cobalt Chrome per ASTM and ISO standards. (Implied, as this is a device description and characteristic shared with predicates).
    Intended Use: Consistent with predicate devices.The intended use aligns with the cleared indications of the Everest Spinal System predicate (K103440, K120656) and Range Spinal System (K070229, K072914, K080611, K080792, K121630).
    No Significant Differences: No adverse effect on use compared to marketed systems.There are no significant differences between the Everest Spinal System and other systems currently being marketed which would adversely affect the use of the product.

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

    • Sample Size for Test Set: Not applicable in the traditional sense for this type of mechanical device. The "test set" would be the collection of components and configurations of the Everest Spinal System that underwent mechanical testing. The specific number of devices or test repetitions for each mechanical test (static compression bending, static torsion, dynamic compression) is not provided in this summary.
    • Data Provenance: The mechanical tests were performed by K2M, Inc. to compare against predicate device performance. This is typically internal testing conducted according to recognized industry standards (ASTM F1717). This is a prospective evaluation of the new device components. The "country of origin of the data" would be the United States, where K2M is located.

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

    • Not applicable. For mechanical testing of a spinal fixation system, "ground truth" is established by adherence to recognized international mechanical testing standards (e.g., ASTM F1717) and the physical measurements obtained during the tests. It does not involve human expert interpretation in the way radiological images would.

    4. Adjudication Method for the Test Set

    • Not applicable. This concept relates to reconciling discrepancies in human expert interpretations (e.g., in diagnostic studies). Mechanical testing results are determined objectively by instrumentation and adherence to test protocols, not through human adjudication.

    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 study type is relevant for diagnostic devices (especially those involving AI or human interpretation of images/data). The Everest Spinal System is a physical implant, not a diagnostic tool or an AI-assisted system.

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

    • Not applicable. This device does not involve an algorithm or AI. Its performance is purely mechanical.

    7. The Type of Ground Truth Used

    • Objective Mechanical Measurements and Standard Compliance: The "ground truth" is defined by the objective physical measurements (e.g., load, displacement, cycles to failure) obtained during mechanical testing on the device components, compared against the established performance characteristics of predicate devices and the requirements of the ASTM F1717 standard.

    8. The Sample Size for the Training Set

    • Not applicable. There is no "training set" in the context of a mechanical medical device like this, as it does not involve machine learning or AI.

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

    • Not applicable. As there is no training set, this question is irrelevant for the Everest Spinal System.

    In summary: The "study" proving the device met acceptance criteria was a mechanical testing study comparing the new components of the Everest Spinal System against predicate devices according to ASTM F1717 standards. The success criterion was that the new components performed "equally to or better than" the predicate devices in static compression bending, static torsion, and dynamic compression, and that their design and materials were substantially equivalent.

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    K Number
    K112920
    Manufacturer
    Date Cleared
    2011-12-21

    (79 days)

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

    K052398, K080611, K081381, K070229, K062174

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

    The Range Spinal System is comprised of the DENALI, DENALI DEFORMITY, and MESA Spinal Systems and the ARI Anterior Vertebral Body Staples, all of which are cleared for the following indications:

    Non-cervical, pedicle screw fixation devices for posterior stabilization as an adjunct to fusion for the following indications: trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures (i.e. scoliosis, kyphosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion. It is also indicated for the treatment of severe spondylolisthesis ( grades 3 and 4 ) of the LS-S 1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine ( L3 to sacrum) with removal of the implants after the attainment of a solid fusion.

    Non-cervical, non-pedicle spinal fixation devices intended for posterior or anterolateral thoracolumbar screw stabilization as an adjunct to fusion for the following indications: degenerative disc disease (DDD ) (defined as back pain of discogenic origin with degencration of the disc confirmed by history and radiographic studies ); spondylolisthesis; trauma ( i.e. fracture or dislocation ); spinal stenosis; curvatures ( i.e. scoliosis, kyphosis; and/or lordosis); tumor; pseudoarthrosis; and failed previous fision.

    Device Description

    The Range Spinal System is a top-loading, multiple component, posterior (thoracic-lumbar) spinal fixation system which consists of pedicle screws, rods, locking set screws, and hooks.

    Materials: The devices are manufactured from Titanium Alloy and Cobalt Chrome per ASTM and ISO standards.

    Function: The system functions as an adjunct to fusion to provide immobilization and stabilization of the posterior thoracic and lumbar spine.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the Range Spinal System: Mesa Modifications. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving safety and effectiveness through clinical trials. Therefore, the information typically requested regarding acceptance criteria, study data, sample sizes, expert involvement, and ground truth establishment for AI/diagnostic devices will not be present in this document.

    Here's an analysis based on the available information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance CriteriaReported Device Performance
    Mechanical Performance:
    Substantial equivalence to predicate Range Spinal System components regarding static compression, static torsion, and dynamic compression as per ASTM F1717.The modified implants were tested in static compression, static torsion, and dynamic compression in accordance with ASTM F1717. The modified implants were determined to be substantially equivalent to the predicate devices.
    Design Features and Sizing:
    Substantially the same as predicate devices.The design features and sizing of the components were compared to predicate devices and the Range Spinal System was found to be substantially the same as these systems.

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

    • Test Set Sample Size: Not applicable. The submission relies on mechanical testing of components, not human test subjects or clinical data in the context of diagnostic performance. The sample size for the mechanical tests (e.g., number of screws or rods tested) is not specified in this summary.
    • Data Provenance: Not applicable in the context of clinical data. The data provenance is from laboratory mechanical testing.

    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):

    • Not applicable. Ground truth as typically understood for diagnostic or AI devices (e.g., expert consensus on medical images) is not relevant for this type of mechanical device submission and testing. The "ground truth" here is compliance with ASTM standards and comparison to a predicate device's mechanical properties.

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

    • Not applicable. This is not a clinical study involving human readers or interpretation of results that would require an adjudication method.

    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 spinal fixation system, not an AI or diagnostic device designed to assist human readers.

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

    • Not applicable. This refers to an AI/algorithm's performance, which is not relevant to this device.

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

    • The "ground truth" in this context is the established performance characteristics and mechanical properties of the legally marketed predicate devices, and the compliance with established ASTM standards (like F1717) for mechanical testing.

    8. The sample size for the training set:

    • Not applicable. This submission does not involve machine learning or AI models with training sets.

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

    • Not applicable. There is no training set mentioned in this submission.
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