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510(k) Data Aggregation

    K Number
    K171046
    Date Cleared
    2017-07-07

    (91 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K082309, K162715, K142488, K151322

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

    Cambria NanoMetalene is intended to be used as an adjunct to spinal fusion procedures at one or two contiguous levels (C3-C7) in skeletally mature patients with degenerative disc disease (defined as neck pain with degeneration of the disc confirmed by history and radiographic studies) of the cervical spine. Patients should have received at least six weeks of non-operative treatment with the device. Devices are intended to be implanted via an open, anterior approach and used with autograft bone graft and/or allogeneic bone graft composed of cancellous and /or corticocancellous bone and supplemental fixation, such as an anterior plating system.

    Cambria is intended to be used as an adjunct to spinal fusion procedures at one or two contiguous levels (C3-C7) in skeletally mature patients with degenerative disc disease (defined as neck pain with discogenic origin with degeneration of the disc confirmed by history and radiographic studies) of the cervical spine. Patients should have received at least six weeks of non-operative treatment prior to treatment with the device. Devices are intended to be implanted via an open, anterior approach and used with autograft bone graft and/or allogeneic bone graft composed of cancellous and /or corticocancellous bone and supplemental fixation, such as an anterior plating system.

    Device Description

    The Cambria System device is an intervertebral fusion device intended to act as a disc spacer and hold bone graft to promote fusion in the cervical spine. The cervical spacers are manufactured from PEEK (ASTM F2026), with tantalum (ASTM F560) radiographic markers, and are generally box-shaped with a central canal for receiving autograft bone graft material and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone. The system is implanted via an anterior approach.

    The Cambria System device is offered in a variety of heights and footprints to accommodate variations in patient anatomy. The cervical spacers are offered in all PEEK or with a surface coating of commercially pure titanium (ASTM F67) referred to as NanoMetalene (NM).

    The Cambria NanoMetalene cervical spacers are provided in gamma sterilized packaging; the Cambria PEEK implants are provided non-sterile for subsequent sterilization at the healthcare facility.

    The instruments included with the Cambria System facilitate the placement and adjustment of the interbody spacers, and removal if necessary. The instruments also include the trays and caddies for storage, protection, and organization prior to and during the steam sterilization process.

    AI/ML Overview

    The provided 510(k) summary for the SeaSpine Cambria System does not include acceptance criteria or a study demonstrating the device meets such criteria in the way typically found for AI/software-as-a-medical-device (SaMD) products. This document describes a medical device (an intervertebral fusion device) and its substantial equivalence to a predicate device, focusing on mechanical performance, materials, and sterility, rather than diagnostic accuracy or algorithmic performance.

    Therefore, many of the requested sections (e.g., sample size for test sets, number of experts, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable to the information provided in this regulatory submission for a physical implantable device.

    However, I can extract the relevant information regarding the non-clinical and clinical testing performed to support the device's substantial equivalence.


    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a physical medical device (intervertebral fusion device), the "acceptance criteria" and "device performance" are primarily related to its mechanical properties, material safety, and sterility, rather than diagnostic metrics like sensitivity or specificity. No explicit acceptance criteria values (e.g., "must withstand X force") are provided in this summary, but the types of tests performed imply compliance with relevant standards.

    Acceptance Criteria (Implied)Reported Device Performance
    Mechanical Performance:
    - Withstand axial compression (ASTM F2077)Engineering analysis verified that modifications did not create new worst cases. Conclusions from previously performed axial compression, compression shear, and torsion testing (ASTM F2077) remained valid.
    - Withstand compression shear (ASTM F2077)Engineering analysis verified that modifications did not create new worst cases. Conclusions from previously performed axial compression, compression shear, and torsion testing (ASTM F2077) remained valid.
    - Withstand torsion (ASTM F2077)Engineering analysis verified that modifications did not create new worst cases. Conclusions from previously performed axial compression, compression shear, and torsion testing (ASTM F2077) remained valid.
    - Resist subsidence (ASTM F2267)Engineering analysis verified that modifications did not create new worst cases. Conclusions from previously performed subsidence testing (ASTM F2267) remained valid.
    - Resist expulsion (lab protocol)Engineering analysis verified that modifications did not create new worst cases. Conclusions from previously performed expulsion testing (lab protocol) remained valid.
    Sterility:
    - Achieve Sterility Assurance Level (SAL) of 10⁻⁶For Cambria NanoMetalene System implants, packaging, shipping, and sterilization tests were performed to validate a SAL of 10⁻⁶ and ensure maintenance of a sterile barrier.
    - Meet bacterial endotoxin limits (ANSI/AAMI ST-72:2011)Bacterial Endotoxin Testing (BET) was conducted in accordance with ANSI/AAMI ST-72:2011.
    Clinical Equivalence (for expanded indications, 2 contiguous levels):An assessment of clinical literature data was completed to support the proposed indication for use of the Cambria System at 2 contiguous levels (C3-C7). The clinical data demonstrate that the Cambria System device performs comparably to the predicate device that is currently marketed for the same intended use. (Specific metrics or data from this assessment are not detailed in this summary.)

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

    • Test Set (Non-Clinical): Not explicitly stated, but mechanical testing typically uses a specific number of samples per test type as proscribed by the ASTM standards (e.g., ASTM F2077, F2267). The summary indicates "engineering analysis" and states that "conclusions from previously performed" tests remained valid, suggesting that a formal re-testing of a full set of samples might not have been performed if the modifications were deemed minor structurally.
    • Data Provenance (Clinical Literature): The summary mentions an "assessment of clinical literature data." This implies retrospective data collection from existing studies, but the specific country of origin or the nature of these studies is not detailed.

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

    This section is not applicable as the document describes a physical medical device, not an AI/SaMD product requiring expert-derived ground truth for diagnostic or interpretative tasks. The "ground truth" for mechanical testing is compliance with physical standards. For clinical equivalence, it relies on literature established via clinical trials for similar predicate devices.

    4. Adjudication Method for the Test Set

    This section is not applicable for the reasons stated above.

    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 section is not applicable as the device is not an AI product.

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

    This section is not applicable as the device is not an AI product.

    7. The Type of Ground Truth Used

    • Non-Clinical (Mechanical): Ground truth is based on established engineering and materials science principles, and adherence to recognized standards such as ASTM F2077, ASTM F2267, and ANSI/AAMI ST-72:2011.
    • Clinical: For supporting the expanded indications, the ground truth was derived from "clinical literature data," implying established clinical outcomes and efficacy data for similar devices from published studies or historical clinical trials.

    8. The Sample Size for the Training Set

    This section is not applicable as the device is not an AI product and therefore does not have a "training set" in the machine learning sense. Its design and manufacturing are based on established engineering principles and materials.

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

    This section is not applicable for the reasons stated above.

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