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510(k) Data Aggregation
(132 days)
The standard and oblique Rampart One devices are integrated intervertebral body fusion devices indicated for intervertebral body fusion at one level or two contiguous levels in the lumbar spine from L2 to S1 in patients with degenerative disc disease (DDD) with up to Grade I spondylolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. These patients should be skeletally mature and have had six months non-operative treatment.
The standard and oblique Rampart One devices are designed for use with autograft and/or allograft comprised of cancellous and/or corticocancellous bone graft and are intended for use with supplemental fixations systems cleared by FDA for use in the lumbar spine.
Rampart One implants are intervertebral body fusion devices for use with bone graft in the intervertebral disc space to stabilize spinal segments as an adjunct to fusion. These devices are manufactured from PEEK-OPTIMA HA Enhanced (spacer), titanium alloy (face plate), and tantalum (radiopaque markers) materials. Rampart One devices incorporate integrated fixation in the form of titanium allov screws. Rampart One devices are provided in standard and oblique configurations. The standard device accommodates four screws and the oblique device accommodates two screws. In each device the screws are inserted through the anteriorly-located face plate into the adjacent vertebral bodies. Rampart One devices are provided in various heights and lordotic angles and contain a hollow core to receive autograft and/or allograft comprised of cancellous and/or corticocancellous bone graft. Placement is achieved with an insertion instrument that allows for manipulation of the implant in the intervertebral disc space.
The provided text is a 510(k) premarket notification for a medical device called the "Rampart One Lumbar Interbody Fusion Device." This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than proving clinical efficacy or diagnostic performance. Therefore, the information typically requested in your prompt (such as a table of acceptance criteria, sample sizes for test/training sets for AI, expert qualifications, adjudication methods, MRMC studies, or standalone algorithm performance) is not part of this document.
The document primarily addresses the device's design, materials, indications for use, and non-clinical mechanical testing to show that it is as safe and effective as existing predicate devices.
Here's a breakdown of the available information in relation to your request, with an emphasis on what is not present because it's not a required component of a 510(k) for this type of device:
1. A table of acceptance criteria and the reported device performance:
- Acceptance Criteria for Substantial Equivalence: The primary acceptance criterion for a 510(k) is the demonstration of "substantial equivalence" to a predicate device. This is achieved by showing that the new device has the same intended use and technological characteristics as the predicate, or that any differences do not raise new questions of safety or effectiveness.
- Reported Device Performance (Non-Clinical): Mechanical testing was conducted. The document states:
- ASTM F2077: Static and Dynamic Compression, Static and Dynamic Compression Shear tests were performed.
- ASTM F2267: Subsidence test was performed.
- ASTM F543-13: Axial Pullout test was performed.
- Anti-Screw Backout Expulsion: A test was performed.
- Bacterial endotoxin testing (BET): Conducted in accordance with ANSI/AAMI ST-72:2011.
- Specific performance metrics (e.g., precise load limits, displacement values, or pass/fail thresholds) are NOT detailed in this summary. The FDA review process would have evaluated the raw data and compared it against established standards or predicate device performance, but these specific numbers are not public in this summary document. The "Conclusion" states: "Spineology has demonstrated that the Rampart One Lumbar Interbody Fusion Device is substantially equivalent to the predicate devices."
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):
- Not Applicable in the traditional sense for this type of device: For a mechanical device like an interbody fusion device, "test set" typically refers to the samples of the device itself (e.g., a certain number of devices tested for mechanical properties). The document does not specify the number of devices tested for each mechanical test.
- Data Provenance: The tests were conducted according to ASTM and ANSI/AAMI standards, likely in a laboratory setting. Country of origin for data is not specified, but the submitter is Spineology Inc. in Saint Paul, Minnesota, USA. The testing is prospective in the sense that the manufacturer specifically conducted these tests for this submission.
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: This is not a diagnostic device or an AI/ML algorithm that requires expert ground truth labeling. Mechanical properties are measured objectively by instrumentation in a laboratory, not by expert opinion.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable: No expert adjudication is involved in evaluating the primary performance of this mechanical device.
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 mechanical implantable device, not a diagnostic imaging or AI-assisted device. No human reader studies (with or without AI assistance) are relevant or mentioned.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Not applicable: This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- Mechanical Standards: The "ground truth" for the mechanical testing is adherence to established industry standards (ASTM, ANSI/AAMI) for biocompatibility, sterility, and mechanical strength, often compared against performance data from predicate devices. Clinical "outcomes data" is generally part of a PMA (Premarket Approval) process, not a 510(k), unless specific new safety/effectiveness questions arise.
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: As above, no training set is involved.
Summary of what the document does provide:
- Device Name: Rampart One Lumbar Interbody Fusion Device
- Intended Use: Intervertebral body fusion at one or two contiguous levels in the lumbar spine (L2-S1) for patients with degenerative disc disease (DDD) with up to Grade I spondylolisthesis, who are skeletally mature and have had six months of non-operative treatment.
- Materials: PEEK-OPTIMA HA Enhanced (spacer), titanium alloy (face plate), tantalum (radiopaque markers).
- Mechanisms of Action: Integrated fixation with titanium alloy screws, hollow core for bone graft.
- Non-Clinical Testing Conducted: Mechanical tests (Static/Dynamic Compression/Shear, Subsidence, Axial Pullout, Anti-Screw Backout Expulsion) and Bacterial Endotoxin Testing, all performed according to recognized standards.
- Predicate Devices: Several predicate devices are listed, including other Spineology Rampart devices and devices from Cutting Edge Spine, Synthes Spine, and Biomet Spine. The new device is compared to these predicates to demonstrate substantial equivalence in intended use, indications for use, fundamental scientific technology, principle of operation, biological safety, base materials, and size offering.
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(115 days)
Rampart O and Rampart P are intervertebral body fusion device indicated for intervertebral body fusion at one level or two contiguous levels in the lumbar spine from L2 to S1 in patients with degenerative disc disease (DDD) with up to Grade I spondylolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. These patients should be skeletally mature and have had six months of nonoperative treatment.
These devices may be implanted singly or in pairs via an open or a minimally invasive posterior or transforaminal approach.
Rampart O and Rampart P are designed for use with autograft as an adjunct to fusion and is intended for use with supplemental fixation systems cleared by the FDA for use in the lumbar spine.
The Spineology Rampart O and P Devices are designed for use with autograft as an adjunct to fusion and is intended for use with supplemental fixation systems cleared for use in the lumbar spine. The device is available in a range of lengths and heights. The device and associated instruments are provided non-sterile.
This document is a 510(k) summary for the Spineology Rampart O and P Devices, which are intervertebral body fusion devices. The purpose of this 510(k) is to add devices as small as 20 mm in length and to add products that include features allowing for rotation of the devices after insertion on implants with tantalum markers.
Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets the criteria:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Substantial equivalence to predicate devices (materials, configuration, performance characteristics). | Demonstrated similar performance characteristics to the identified predicate devices in preclinical testing. |
Compliance with FDA's "Class II Special Controls Guidance Document: Intervertebral Body Fusion Device". | Tested in compliance with this guidance document. |
Mechanical performance (static compression and static compression shear) comparable to predicate devices. | Preclinical testing included static compression and static compression shear according to ASTM F2077. This testing demonstrated similar performance characteristics. |
Suitability for new sizes (as small as 20mm in length). | The 510(k) specifically adds devices as small as 20mm in length. Preclinical testing would have supported this. |
Functionality of new features (rotation after insertion with tantalum markers). | The 510(k) adds products with features allowing for rotation of devices after insertion on implants with tantalum markers. Preclinical testing would have supported this. |
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: The document does not specify a "test set" in the context of human data. The testing mentioned is preclinical. For preclinical mechanical testing, sample sizes would typically be several units per test condition to ensure statistical robustness, but the exact numbers are not provided in this summary.
- Data Provenance: The data is preclinical testing. The country of origin and whether it's retrospective or prospective are not applicable to the type of testing described (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)
This section is not applicable as the provided text describes preclinical mechanical testing of an intervertebral body fusion device, not an AI/software device that requires expert-established ground truth for a test set.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This section is not applicable for the same reason as point 3.
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. The device is an intervertebral body fusion device, which is a physical implant, not a software or AI tool requiring MRMC studies for human reader performance.
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 algorithm or AI.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For the preclinical testing, the "ground truth" would be established by engineering standards and physical measurements based on ASTM F2077. For instance, load cells and displacement sensors would provide objective data on static compression and shear forces, which are then compared against performance characteristics of predicate devices.
8. The sample size for the training set
This section is not applicable as the device is not an AI/machine learning model that requires a training set.
9. How the ground truth for the training set was established
This section is not applicable for the same reason as point 8.
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