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510(k) Data Aggregation

    K Number
    K182837
    Date Cleared
    2019-01-22

    (105 days)

    Product Code
    Regulation Number
    888.3075
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K171369, K070573, K142838, K042508, K110353, K111076

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

    The M.U.S.T. MINI Posterior Cervical Screw System is intended to provide immobilization of spinal segments as an adjunct to fusion, in skeletally mature patient, for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fraumatic dislocations; instability or deformity; failed previous (e.g., pseudarthrosis); tumors involving the cervical spine; degenerative disease, including intractable radior myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability.

    The M.U.S.T. MINI Posterior Cervical Screw System is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

    In order to achieve additional levels of fixation, the M.U.S.T. MINI Posterior Cervical Screw System may be connected to the M.U.S.T. System rods with the M.U.S.T. MINI rod connectors. Transition rods with differing diameters may also be used to connect the M.U.S.T. MINI Posterior Cervical Screw System to the M.U.S.T. System. Refer to the M.U.S.T. System package insert for a list of the M.U.S.T. Indications of Use.

    When used with the Occipital Plate, the M.U.S.T MINI Posterior Cervical Screw System is also intended to provide immobilization and stabilization for the occipito-cervico-thoracic junction (occiput - T3) in treatment of the instabilities mentioned above, including occipitocervical dislocation.

    Device Description

    The subject M.U.S.T. MINI Extension implants are line extension to the previously cleared Medacta M.U.S.T. MINI Posterior Cervical Screws System (K171369).

    The new subject Posterior Occipital-Cervical Screw System is a multi-component device, manufactured from Titanium-based and CoCr materials, consisting of occipital screws and straight and pre-bent rods that longitudinally connect the occiput with the posterior cervical spine. The system is intended to stabilize and fuse the spine in degenerative disc disease, spinal fusion, cervical fractures and in surgically repaired spinal pseudoarthrosis. In addition, it is used in deformity correction e.g. scoliosis to correct and stabilize the spine.

    The M.U.S.T. MINI Extension implants have been designed with the same or similar shape, dimensions and materials as the previously cleared Medacta M.U.S.T. MINI Posterior Cervical Screws System (K171369), Synthes Synapse OCT System (K070573 and K142838), DePuy Mountaineer OCT Spinal System (K042508 and K110353) and Alphatec Solanas Avalon Posterior Fixation System (K111076).

    The M.U.S.T. MINI Extension implants are manufactured with the same materials of the Medacta predicate device M.U.S.T. MINI Posterior Cervical Screws System (K171369): Ti-6Al-4V ELI (ISO 5832-3 Implants for surgery -- Metallic materials -- Part 3: Wrought titanium 6-aluminium 4-vanadium allov + ASTM F136 Standard Specification for Wrought Titanium-4Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401)) and CoCtMo (ISO 5832-12 Implants for surgery -- Metallic materials -- Part 12: Wrought cobalt-chromium-molybdenum alloy + ASTM F1537 Standard Specification for Wrought Cobalt-28Chromium-6Molybdenum Alloys for Surgical Implants (UNS R31537, UNS R31538, and UNS R31539)).

    Additionally, the new 4x and 6x package for the already cleared (K171369) M.U.S.T. MINI set screw implant have been introduced.

    AI/ML Overview

    This document describes the M.U.S.T. MINI Extension, a spinal fixation system, and its substantial equivalence to predicate devices, rather than a diagnostic AI device. Therefore, the requested information about acceptance criteria, study details, expert involvement, and AI-specific performance metrics is not applicable in the context of this 510(k) submission.

    The provided text does not contain information about an AI device or a study assessing its performance against acceptance criteria using a test set, ground truth, or human readers.

    Instead, the document focuses on demonstrating that the M.U.S.T. MINI Extension is substantially equivalent to existing, legally marketed spinal fixation devices through a comparison of:

    • Intended use: The conditions for which the device is designed to be used.
    • Design and technological characteristics: Materials, dimensions, and overall structure.
    • Performance evaluations: Mechanical tests to ensure the device meets safety and efficacy standards for spinal implants.

    Here's a breakdown of the relevant information provided in the document:

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

    The document mentions that "Testing was conducted according to written protocols with acceptance criteria that were based on standards." However, it does not provide a specific table of acceptance criteria and reported numerical performance results for the new device compared to those criteria. It lists the types of mechanical tests performed, which inherently have acceptance criteria defined by the cited ASTM standards, but the specific Pass/Fail outcomes or quantitative measurements are not detailed in this summary.

    Examples of tests performed (implying acceptance criteria based on standards):

    • Static Compression Bending Test (ASTM F2706-08 (Reapproved 2014))
    • Static Torsion Test (ASTM F2706-08 (Reapproved 2014))
    • Dynamic Axial Compression Test (ASTM F2706-08 (Reapproved 2014))
    • Dynamic Torsion Test (ASTM F2706-08 (Reapproved 2014))
    • Axial Gripping Test (ASTM F1798-13)
    • Plate Torque to Failure Test
    • Screw Torque to Failure Test
    • Pyrogenicity (Bacterial Endotoxin Test (LAL test) according to European Pharmacopoeia §2.6.14/USP chapter , and pyrogen test according to USP chapter )

    2. Sample size used for the test set and the data provenance:

    • Sample size: Not explicitly stated for each mechanical test. Mechanical tests typically use a specific number of samples of the device components.
    • Data provenance: Not applicable in the context of a clinical patient dataset. The "data" here refers to the results of mechanical testing on the device itself (implants, rods, screws). These tests are performed in a lab setting, not on patient data.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • This is not applicable as there is no "ground truth" related to expert assessment of AI output. The "truth" for this device's performance is determined by adherence to engineering standards and mechanical properties.
    • There was a "Design Validation Workshop" mentioned, which implies expert review during the design process, but not for establishing ground truth in a diagnostic context.

    4. Adjudication method for the test set:

    • Not applicable, as there are no expert adjudications in the context of mechanical testing of a spinal implant.

    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, an MRMC study was not done. This type of study is relevant for diagnostic imaging AI, where human readers evaluate cases with and without AI assistance. This document is for a physical surgical implant.

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

    • Not applicable. This device is a physical implant, not a standalone algorithm.

    7. The type of ground truth used:

    • For the mechanical tests, the "ground truth" is defined by the objective physical and mechanical properties required by the cited ASTM standards. It's not expert consensus, pathology, or outcomes data in the typical sense of AI/diagnostic studies, but rather engineering specifications.

    8. The sample size for the training set:

    • Not applicable. This is not an AI device that requires a training set.

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

    • Not applicable, as there is no training set for this device.

    In summary: The provided document is a 510(k) summary for a physical medical device (spinal implant) and demonstrates its substantial equivalence primarily through comparisons with predicate devices and mechanical performance testing against established engineering standards. It does not involve AI, diagnostic performance, patient data, or expert interpretations in the way the requested questions imply.

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

    The BRIDALVEIL Occipital Cervical Thoracic System is intended to provide immobilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (Cl to C7) and the thoracic spine from TI-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions ( e.g., pseudarthrosis ); tumors involving the cervical spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The BRIDALVEIL Occipital Cervical Thoracic System is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

    In order to achieve additional levels of fixation, the BRIDALVEIL Occipital Thoracic System may be connected to the OLYMPIC Posterior Spinal Fixation System rods and connectors. Transition rods with differing diameters may also be used to connect the BRIDALVEIL Occipital Cervical Thoracic System to the OLYMPIC Posterior Spinal Fixation System. Refer to the OLYMPIC Posterior Spinal Fixation System package insert for instructions for use and indications for use.

    Device Description

    The BRIDALVEIL Occipital Cervical Thoracic System is a spinal fixation system intended to stabilize the uppermost portion of the spine during the fusion process. The system contains a wide variety of implants and instruments which allows for the transition across multiple spinal segments: Occipital Plate with Screws, Cervical Polyaxial Screws, Laminar Hooks, Cross Connectors, Rod Connectors, and Rods manufactured from Ti6Al4V ELI (ASTM F136) and cobalt chrome alloy (ASTM F1537).

    AI/ML Overview

    The provided text describes the regulatory clearance for the BRIDALVEIL Occipital Cervical Thoracic System, a spinal fixation system. It does not detail acceptance criteria and a study that proves the device meets those criteria in the context of an AI/ML device.

    This document is a 510(k) premarket notification for a traditional medical device (spinal fixation system), not an AI/ML device. Therefore, the details requested in the prompt, such as reported device performance, sample size for test sets, expert qualifications for ground truth, adjudication methods, MRMC studies, standalone performance, training set details, and ground truth establishment for the training set, are not applicable in the context of this submission.

    Instead, the document focuses on demonstrating substantial equivalence to existing predicate devices based on:

    • Intended Use: Providing immobilization and stabilization of spinal segments as an adjunct to fusion for various conditions (traumatic fractures/dislocations, instability, tumors, degenerative disease, etc.) in the craniocervical junction, cervical spine (C1-C7), and thoracic spine (T1-T3). It also mentions restoring spinal column integrity for a limited time in advanced stage tumor patients.
    • Design: The system includes occipital plates with screws, cervical polyaxial screws, laminar hooks, cross connectors, rod connectors, and rods.
    • Materials: Ti6Al4V ELI (ASTM F136), cobalt chrome alloy (ASTM F1537), Elgiloy CoCrNi alloy (ASTM F1058), and Nitinol #1 (ASTM E2063).
    • Mechanical Safety and Performance: Evaluated through non-clinical bench testing.

    Here's the information extracted from the document, framed in the context of a traditional medical device submission, rather than an AI/ML one:


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

    For this traditional medical device (BRIDALVEIL Occipital Cervical Thoracic System), "acceptance criteria" revolve around demonstrating substantial equivalence to predicate devices through conformity to recognized standards for mechanical performance and material properties. "Reported device performance" is derived from the results of these non-clinical tests meeting the requirements of those standards.

    Acceptance Criterion (Demonstrating Substantial Equivalence)Reported Device Performance (Summary from Non-Clinical Tests)
    Mechanical Performance:The BRIDALVEIL Occipital Cervical Thoracic System demonstrated mechanical performance equivalent to the predicate devices across various tests.
    Static Compression Bending (ASTM F1717)Results indicated equivalence to predicate devices.
    Dynamic Compression Bending (ASTM F1717)Results indicated equivalence to predicate devices.
    Static Torsion (ASTM F1717)Results indicated equivalence to predicate devices.
    Static Compression Bending (ASTM F2706)Results indicated equivalence to predicate devices.
    Dynamic Compression Bending (ASTM F2706)Results indicated equivalence to predicate devices.
    Static Torsion (ASTM F2706)Results indicated equivalence to predicate devices.
    Dynamic Torsion (ASTM F2706)Results indicated equivalence to predicate devices.
    Static Axial Grip (ASTM F1798)Results indicated equivalence to predicate devices.
    Static Torsional Grip (ASTM F1798)Results indicated equivalence to predicate devices.
    Static Transverse Moment (ASTM F1798)Results indicated equivalence to predicate devices.
    Material Biocompatibility:Materials used (Ti6Al4V ELI, CoCrMo alloy, Elgiloy CoCrNi alloy, Nitinol #1) are commonly accepted in spinal implants and are equivalent to those used in predicate devices, implying established biocompatibility. (No specific biocompatibility tests are listed, but material equivalence is claimed.)
    Sterility:(Not explicitly detailed in the summary, but implicit for an implantable device that it would meet relevant sterility standards.)

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

    • Sample Size for Test Set: Not applicable in the context of human data. The "test set" here refers to physical specimens of the device components tested in a laboratory setting. No human patients or retrospective/prospective data were used for performance evaluation.
    • Data Provenance: The data provenance is from non-clinical bench testing conducted in a laboratory. The specific country of origin of the lab is not stated in the provided text.

    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" in this context refers to the defined parameters and performance standards derived from the ASTM standards for mechanical testing. These standards are established by expert committees in engineering and materials science, but individual experts are not "adjudicating" a test set as they would for clinical images or diagnoses.

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

    • Not applicable. There's no human adjudication process described for the mechanical test results; rather, the results are compared against predefined criteria within the ASTM standards.

    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 not an AI/ML device, and no MRMC studies or human reader performance evaluations were conducted.

    6. 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 "standalone performance" is the mechanical testing of the device itself against engineering standards.

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

    • For this device, the "ground truth" (or reference for evaluation) is established through recognized industry standards for mechanical testing of spinal implants (e.g., ASTM F1717, ASTM F2706, ASTM F1798). The device's performance is compared against the requirements and typical performance of predicate devices as measured under these standardized conditions.

    8. The sample size for the training set

    • Not applicable. This is not an AI/ML device that requires a training set.

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

    • Not applicable. This is not an AI/ML device.
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    K Number
    K153386
    Manufacturer
    Date Cleared
    2016-01-25

    (63 days)

    Product Code
    Regulation Number
    888.3075
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K003780, K023675, K991089, K110353

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

    The PERLA® posterior cervico-thoracic fixation system is intended to provide immobilization of spinal segments as an adjunct to following acute and chronic instabilities of the cervical spine (C 1 to C7) and the thoracic spine from TI-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radios, and degenerative disease of the facets with instability.

    The PERLA® posterior cervico-thoracic fixation system is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

    In order to achieve additional levels of fixation, the PERLA® posterior cervico-thoracic fixation system may be connected to the ROMEO® Posterior Osteosynthesis System with rod connectors. Transition rods may also be used to connect the PERLA® posterior cervico-thoracic fixation system to the ROMEO® Posterior Osteosynthesis System. Refer to the ROMEO® Posterior Osteosynthesis System package insert for a list of the ROMEO® Posterior Osteosynthesis System indications of use.

    Device Description

    The Spineart Perla® system is a posterior cervico-thoracic fixation system intended to provide stabilization to promote fusion of the cervical spine and the upper thoracic spine. Perla® system consists of a variety of shapes and sizes of rods, hooks, multi-axial screws, set screws, rod connectors and transverse connectors. These connecting components can be rigidly locked to the rod in a variety of configurations to be adapted for the individual case. The Perla® system can also be linked to the cleared Spineart Romeo®2 spinal system (K151695) using the specific Perla® Axial and Parallel Rod to Rod connectors 3.5/5.4mm or the Perla® Transition Rods 3.5/5.4mm which are part of this submission.

    AI/ML Overview

    The provided document is a 510(k) summary for the PERLA® Posterior Cervico-Thoracic Fixation System. It details the device's indications for use, technological characteristics, and performance data to demonstrate substantial equivalence to predicate devices. However, the document does not contain information about the acceptance criteria or a study proving the device meets specific acceptance criteria in the context of an AI/ML device.

    The information provided describes a traditional medical device (implantable fixation system for spinal segments) and its FDA clearance process. It does not involve AI or algorithms, and therefore, the requested information about AI/ML device performance, sample sizes for test/training sets, ground truth establishment, expert adjudication, or MRMC studies is not applicable or present in this document.

    Therefore, the table below will be filled with "Not Applicable" or "Information Not Provided" as the document pertains to a physical medical device and not an AI/ML system.


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (for AI/ML device)Reported Device Performance (from document, if applicable to AI/ML)
    Not Applicable (no AI/ML device)Not Applicable (no AI/ML device)

    2. Sample size used for the test set and the data provenance

    • Test Set Sample Size: Information Not Provided (Not applicable to a physical spinal fixation system)
    • Data Provenance: Information Not Provided (Not applicable to a physical spinal fixation system)

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • Number of Experts: Information Not Provided (Not applicable to a physical spinal fixation system)
    • Qualifications of Experts: Information Not Provided (Not applicable to a physical spinal fixation system)

    4. Adjudication method for the test set

    • Adjudication Method: Information Not Provided (Not applicable to a physical 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

    • MRMC Study Conducted?: No (Not applicable; this is a physical spinal fixation system, not an AI/ML system for image interpretation or diagnosis by human readers.)
    • Effect Size: Not Applicable

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

    • Standalone Study Conducted?: No (Not applicable; this is a physical spinal fixation system, not an AI/ML algorithm.)

    7. The type of ground truth used

    • Type of Ground Truth: Information Not Provided (Not applicable to a physical spinal fixation system. For this device, "ground truth" would refer to manufacturing specifications, material properties, and mechanical testing results, which are detailed in the document but not in the context of diagnostic "ground truth" for AI.)

    8. The sample size for the training set

    • Training Set Sample Size: Information Not Provided (Not applicable to a physical spinal fixation system)

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

    • Ground Truth Establishment: Information Not Provided (Not applicable to a physical spinal fixation system)

    Summary of Device Performance (from the document, relevant to a physical device):

    The document states that "Published literature and bench testing per ASTM F1717 demonstrate that the PERLA® posterior cervico-thoracic fixation system is substantially equivalent to the predicate devices."

    The following non-clinical tests were conducted:

    • Static Compression Bending, Static Torsion, and Dynamic Compression Bending according to ASTM F1717.
    • Static flexion-extension testing, Static axial gripping, and Static torsion gripping according to ASTM F1798.
    • Axial pullout strength and Torque to failure according to ASTM F543.

    The conclusion is that "Design comparisons and non-clinical performance testing demonstrate that the PERLA® posterior cervico-thoracic fixation system is substantially equivalent to its predicate devices in terms of intended use, material, design, mechanical properties and function."

    These tests and their results are used to establish substantial equivalence for a traditional spinal implant, not to evaluate the performance of an AI/ML algorithm against predefined acceptance criteria for diagnostic accuracy or similar metrics.

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    K Number
    K121808
    Manufacturer
    Date Cleared
    2012-07-20

    (30 days)

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

    K081107, K092640, K103232, K110353

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

    The Caspian OCT/miniMesa/miniDenali Spinal System is intended to provide stabilization as an adjunct to fusion of the cervical spine and occipito-cervico-thoracic junction (occiput-T3) when used with autograft or allograft and is indicated for the following: DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies), spondylolisthesis, spinal stenosis, fracture/dislocation, revision of previous cervical spine surgery, tumors, atlantoaxial fracture with instability, occipitocervical dislocation.

    The occipital bone screws are limited to occipital fixation only.

    The rod and hook components are intended for use in the cervical/upper thoracic (C1-T3) spine. The pedicle screws are limited to placement in T1-T3 in treating thoracic conditions only. The pedicle screws are not intended to be placed in or treat conditions involving the cervical spine.

    The Caspian Spinal System can also be linked to the Range Spinal System using rod connectors or transitional rods.

    Device Description

    The Caspian Spinal System is a top-loading, multiple component, posterior (cervical-thoracic) spinal fixation system which consists of pedicle screws, rods, locking set screws, hooks, and rod connectors. Rod connectors and transitional rods are being added to the system.

    Materials: The devices are manufactured from Ti6A14V Eli and Cobalt Chrome per ASTM and ISO standards.

    Function: The system functions as an adjunct to fusion to provide immobilization of spinal segments of the cervical and thoracic (TI-T3) spine.

    AI/ML Overview

    The provided text is a 510(k) summary for the Caspian Spinal System, which is a medical device for spinal fixation. It describes the device, its intended use, and its comparison to predicate devices for substantial equivalence.

    However, a critical review of the document reveals that it does not contain any information regarding clinical studies, acceptance criteria, or performance metrics in the way that would typically be described for a diagnostic AI/ML device.

    The relevant sections of the document describe:

    • Device Description: A top-loading, multiple component, posterior (cervical-thoracic) spinal fixation system made from Ti6A14V Eli and Cobalt Chrome.
    • Intended Use: Provides stabilization as an adjunct to fusion of the cervical spine and occipito-cervico-thoracic junction (occiput-T3) for various conditions.
    • Comparison to Predicate Devices: Mechanical testing (static and dynamic compression bending and static torsion) was performed in accordance with ASTM F1717. The additional components were determined not to represent worst-case for the system for mechanical testing compared to existing components. The design features, sizing, materials, and intended uses were found to be substantially the same as predicate devices (K2M Caspian Spinal System and DePuy Mountaineer).

    Therefore, I cannot provide the requested information for acceptance criteria and study details because the provided document does not contain this type of data.

    This document is a 510(k) summary for a spinal implant (a mechanical device), not a diagnostic AI/ML device. For spinal implants, the "acceptance criteria" and "study" typically refer to mechanical testing (e.g., fatigue, static strength, bending stiffness) and biocompatibility testing, rather than clinical performance metrics like sensitivity, specificity, or reader studies associated with diagnostic algorithms.

    The document states:
    "Mechanical testing of the subject components included static and dynamic compression bending and static torsion testing in accordance with ASTM F1717. When compared to the existing components of the K2M Caspian OCT Spinal System, the additional components were determined not to represent worst case for the system for mechanical testing."

    This indicates that mechanical tests were done, and the results were deemed equivalent to the predicate device, implying they met the predicate's performance. However, specific numerical acceptance criteria or performance results (e.g., "device withstood X N of force") are not provided in this summary.

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    K Number
    K113593
    Date Cleared
    2012-04-17

    (134 days)

    Product Code
    Regulation Number
    888.3050
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    When intended for stabilization as an adjunct to fusion of the cervical spine and occipito-cervicothoracic junction (occiput -T3), the Nextgen Altius OCT System is intended for use with allograft or autograft and indicated for: DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies); spondylolisthesis; deformities or curvatures (i.e., scoliosis, kyphosis and/or lordosis); pseudoarthrosis; trauma, (i.e., fracture or dislocation); atlanto/axial fracture with instability; occipitocervical dislocation; revision of previous cervical spine surgery; and tumors.

    The occipital bone screws are limited to occipital fixation only.

    The use of pedicle screws, is limited to placement in T1-T3 in treating thoracic conditions only. They are not intended to be placed in or treat conditions involving the cervical spine.

    The Nextgen Altius OCT System can also be linked to the Biomet Polaris Systems via transitional rods or using Altius Rod Connectors or Polaris Dominoes. Please refer to the individual system's package insert for a list of indications for use for each system.

    Device Description

    The Nextgen Altius OCT System is an occipito-cervico-thoracic spinal fixation system. This submission is a line extension to Altius OCT System to add CoCr rods and alternate styles of rods, and screws, as well as other system components to the system and to update the indications for use for the system as a whole.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and the study information based on the provided document:

    This 510(k) summary is for a spinal fixation system, which falls under the category of a medical device and not an AI/ML algorithm. Therefore, many of the requested points related to AI/ML studies (like MRMC, standalone algorithm performance, AI improvement over human readers, training set details) are not applicable to this document. The study described is a series of mechanical tests to demonstrate substantial equivalence to existing predicate devices.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (from FDA Guidance)Reported Device Performance
    Mechanical Test Requirements:
    Static compression bendingMet all mechanical test requirements based on worst-case construct testing
    Static torsion fatigueMet all mechanical test requirements based on worst-case construct testing
    Compression bending fatigueMet all mechanical test requirements based on worst-case construct testing
    Substantial Equivalence to Predicate Devices (design, indications, operational principle, safety, effectiveness)The subject components are substantially equivalent to predicate devices (Altius OCT System, Depuy Mountaineer OCT Spinal System, Vertex Max® & Select™ Reconstruction Systems); did not present any new issues of safety or effectiveness.
    Compliance with ASTM F2706Conducted in accordance with ASTM F2706
    Compliance with ASTM F1717Conducted in accordance with ASTM F1717
    Compliance with ASTM F1798Conducted in accordance with ASTM F1798

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

    • Sample Size for Test Set: This information is not explicitly stated in the summary. For mechanical tests, the "sample size" would refer to the number of constructs tested for each configuration.
    • Data Provenance: The data is generated from mechanical laboratory testing of the device components, not from patient data. Therefore, concepts like "country of origin" or "retrospective/prospective" studies are not applicable.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    • Not Applicable. As this is a mechanical testing study for a physical device, expert-established ground truth (in the clinical sense, e.g., for image interpretation) is not relevant. The "ground truth" here is adherence to established mechanical testing standards (ASTM standards) and the comparison of performance metrics against predicate devices.

    4. Adjudication Method for the Test Set

    • Not Applicable. Adjudication methods (like 2+1, 3+1) are used for resolving disagreements in expert clinical assessments or diagnostic interpretations. This study involves objective mechanical performance measurements, not subjective expert reviews.

    5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done

    • No. An MRMC study is relevant for evaluating the impact of an AI/ML system on human reader performance. This document describes mechanical testing of a spinal fixation device, which does not involve human readers for diagnostic interpretation.

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

    • No. This is not an AI/ML algorithm. It is a physical medical device.

    7. The Type of Ground Truth Used

    • The "ground truth" in this context is based on established mechanical testing standards (ASTM F2706, F1717, F1798) and performance characteristics of legally marketed predicate devices. The goal is to demonstrate that the new device's components meet these engineering and regulatory benchmarks, indicating that they are at least as safe and effective as existing devices.

    8. The Sample Size for the Training Set

    • Not Applicable. There is no "training set" in the context of mechanical testing for a spinal fixation system. This concept applies to the development of AI/ML algorithms.

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

    • Not Applicable. As there is no training set, there is no ground truth established for one.
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    K Number
    K120656
    Manufacturer
    Date Cleared
    2012-04-04

    (30 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Everest Spinal System if used in conjunction with the Range (Mesa and Denali) Spinal Systems are:

    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 (thoracic-lumba) spinal fixation system which consists of pedicle screws, rods, locking set screws, and hooks. The purpose of this submission is to increase the range of screw sizes and to add connectors to enable use with Range Spinal System conponents.

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

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

    AI/ML Overview

    The provided 510(k) summary for the "Everest Spinal System" is for a physical medical device (spinal fixation system) and not for an AI/ML-driven device or software. Therefore, the questions regarding acceptance criteria, study design, ground truth, and reader studies that are typically applicable to AI/ML device performance evaluation do not directly apply in this context.

    This summary focuses on demonstrating substantial equivalence to existing predicate devices based on mechanical performance and material compatibility.

    Here's an analysis of the provided information, framed as closely as possible to your request, but highlighting the differences for a physical device:

    Acceptance Criteria and Device Performance (for a physical medical device)

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    Mechanical Performance- Static Compression Strength (referencing ASTM F1717)"The modified Everest Spinal System constructs performed equally to or better than the predicates in static compression..."
    Mechanical Performance- Static Torsion Strength (referencing ASTM F1717)"The modified Everest Spinal System constructs performed equally to or better than the predicates in... static torsion..."
    Mechanical Performance- Dynamic Compression Strength (referencing ASTM F1717)"The modified Everest Spinal System constructs performed equally to or better than the predicates in... dynamic compression in accordance with ASTM F1717."
    Design & Materials- Design features and sizing comparison to predicates"The design features and sizing of the components were also compared and the Everest Spinal System was found to be substantially the same as these systems."
    Design & Materials- Materials: Titanium Alloy and Chrome per ASTM and ISO standardsConfirmed to be manufactured from Titanium Alloy and Chrome per ASTM and ISO standards.
    Intended Use- Adjunct to fusion, posterior stabilization in thoracic-lumbar spine for specific indications (trauma, stenosis, curvatures, tumor, pseudoarthrosis, failed fusion, severe spondylolisthesis L5-S1)The device is intended for these uses, consistent with predicates.

    Summary of Device Evaluation and Study for Substantial Equivalence:

    The study presented is not an AI/ML algorithm validation study, but rather a comparative engineering and design study to demonstrate substantial equivalence of a physical medical device.

    1. Sample size used for the test set and the data provenance:

      • This is not applicable in the context of an AI/ML study. For a physical device, "test set" refers to physical prototypes or components of the Everest Spinal System. The document doesn't specify the exact number of components tested but implicitly suggests sufficient samples were used to conduct the required ASTM F1717 mechanical tests.
      • Data Provenance: The tests were conducted according to ASTM and ISO standards, implying a controlled laboratory environment. The "country of origin of the data" would be where these tests were performed, but this detail is not provided. It is a prospective generation of test data from manufactured components.
    2. 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 is not applicable. The "ground truth" for a mechanical device is established by objective, verifiable physical measurements and engineering standards (ASTM F1717, ISO standards). There are no human "experts" establishing a subjective ground truth in this type of study.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable. Mechanical tests are typically evaluated against predefined quantitative limits set by standards like ASTM F1717, not through human adjudication.
    4. 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 physical device, and no human "readers" or AI assistance are involved in its performance evaluation.
    5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      • Not applicable. This is a physical device, not an algorithm.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

      • For this physical device, the "ground truth" is defined by established engineering performance standards (ASTM F1717) and material specifications (ASTM and ISO standards for Titanium Alloy and Chrome). The performance of the device is directly compared to these objective standards and to the performance of existing legally marketed predicate devices under the same test conditions.
    7. The sample size for the training set:

      • Not applicable. There is no AI/ML model being trained.
    8. How the ground truth for the training set was established:

      • Not applicable. No AI/ML model training occurred.

    Conclusion for this Device:

    The K2M Everest Spinal System demonstrated substantial equivalence by:

    • Showing that its mechanical performance (static compression, static torsion, dynamic compression) was "equally to or better than" the predicate devices when tested according to ASTM F1717.
    • Confirming its design features and sizing were "substantially the same" as predicate systems.
    • Verifying its materials (Titanium Alloy and Chrome) met the relevant ASTM and ISO standards.
    • Confirming its intended use aligns with the predicate devices.

    This allows the FDA to conclude there are no significant differences that would adversely affect the product's use, thus granting 510(k) clearance based on substantial equivalence.

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