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510(k) Data Aggregation

    K Number
    K132765
    Manufacturer
    Date Cleared
    2014-07-14

    (313 days)

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

    K032037, K123246, K090252, K133052

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

    The Innovasis PFX™ Posterior Spinous Fixation System is a posterior, non-pedicle supplemental fixation device intended for use in the posterior non-cervical spine (T1-S1) of skeletally mature patients. It is intended for plate fixation/attachment to the spinous process for the purpose of achieving supplemental fusion. The PFX Posterior Spinous Fixation System is intended for use at one level, with bone graft material. The PFX Posterior Spinous Fixation System is indicated for use as an aid in immobilization and stabilization of spinal segments as an adjunct to fusion for treatment of the following conditions:

    • · Degenerative disc disease: Back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies.
    • · Trauma: fracture or dislocation
    • · Spondvlolisthesis
    • Tumor
    Device Description

    The Innovasis® PFX™ Posterior Spinous Fixation System consists of plates, struts and screws that are used to build a construct to provide supplemental stabilization of spinal segments to support fusion. The components are available in a range of sizes to fit the anatomical needs of a variety of patients. PFX™ implants are composed of titanium alloy (per ASTM F136).

    AI/ML Overview

    The provided document describes the Innovasis PFX™ Posterior Spinous Fixation System, a medical device, and its testing for substantial equivalence to predicate devices. The study conducted is a non-clinical performance study focused on mechanical testing rather than a clinical study involving human subjects or AI performance.

    Therefore, many of the requested criteria related to clinical studies, AI performance, and human expert review are not applicable to the information provided.

    Here's a breakdown of the requested information based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Applicable Standards)Reported Device Performance (Tests Conducted)
    ASTM F1798-97(Reapproved 2008) Standard Guide for Evaluating the Static and Fatigue Properties of Interconnection Mechanisms and Subassemblies Used in Spinal Arthrodesis ImplantsTests Performed: Axial Pushoff, Lock Post Dissociation, Torque to Failure
    Results: "Testing demonstrates substantial equivalence to the predicates." and "The PFX Posterior Spinous Fixation device when tested using recognized standardized testing performed comparably to the predicates in all modes of loading and also exceeded the in vivo force tolerances of the human spine."
    ASTM F1717-12 Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model (This standard is generally for devices replacing a vertebral body. Its application here implies testing the construct's ability to provide stability akin to what would be needed after a vertebrectomy, even though this device is for spinous process fixation.)Tests Performed: Static Compression Bending, Static Torsion, Dynamic Compression Bending
    Results: "Testing demonstrates substantial equivalence to the predicates." and "The PFX Posterior Spinous Fixation device when tested using recognized standardized testing performed comparably to the predicates in all modes of loading and also exceeded the in vivo force tolerances of the human spine."
    Overall Substantial Equivalence to Predicate Devices (CD HORIZON® SPIRE™ Z Spinal System, Aspen™ Spinous Process Fixation System, Affix Spinous Process Plate System)Comparability:
    • "The PFX Posterior Spinous Fixation device when tested using recognized standardized testing performed comparably to the predicates in all modes of loading and also exceeded the in vivo force tolerances of the human spine."
    • "The materials utilized (titanium alloy) are substantially equivalent to the predicates."
    • "The mode of operation (clamping mechanism utilizing wings and spikes, center post and set screw) is substantially equivalent to the predicates."
    • "The indications for use are substantially equivalent." |

    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 explicitly stated as a number of physical devices. The "tests" section implies multiple tests were conducted (e.g., Axial Pushoff, Static Compression Bending, etc.), each likely on a sample of devices. However, the exact sample size for each specific test (e.g., how many devices for axial pushoff) is not detailed.
    • Data Provenance: The tests are non-clinical (mechanical testing). There is no "data provenance" in terms of patient data or country of origin for such data. The tests were performed to ASTM standards, which are internationally recognized.

    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 was a non-clinical mechanical performance study, not a study evaluating diagnostic accuracy or clinical outcomes that would require expert-established ground truth.

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

    • Not Applicable. As a mechanical performance study, there was no need for adjudication by human experts. The "ground truth" was derived from the physical testing measurements against engineering 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 document describes a medical device's physical performance, not an AI or imaging diagnostic tool. Therefore, MRMC studies and AI assistance are irrelevant to this submission.

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

    • Not Applicable. This is not an AI algorithm. It is a physical spinal fixation device.

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

    • The "ground truth" for this non-clinical study was the performance parameters defined by recognized industry standards (ASTM F1798 and ASTM F1717) and comparative performance to predicate devices. The device was deemed to have met the acceptance criteria if its mechanical performance was comparable to, and ideally exceeded, that of the predicate devices under standardized test conditions.

    8. The sample size for the training set

    • Not Applicable. This is a physical device, not a machine learning model; therefore, there is no "training set."

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

    • Not Applicable. There is no training set for this type of device submission.
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