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510(k) Data Aggregation
(114 days)
The PASS LP Spinal System is a pedicle screw fixation system intended for immobilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, tracture or dislocation), deformity or curvature (e.g., scoliosis, and/or lordosis), tumor, spinal stenosis, pseudarthrosis, or failed previous fusion.
Except for rod plates, when used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS LP Spinal System implants are indicated as an adjunct to treat adolescent idiopathic scolosis. Additionally, the system is intended to treat pediatic patients diagnosed with the following conditions: spondylolistis and fracture caused by tumor and/or trauma. The PASS LP Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.
The PASS LP Spinal System is designed to contribute to correction and surgical stabilization of the thoracic, lumbar and sacral spine.
The system consists of pedicle screws, hooks, sacral plates, iliac screws, connectors, clamps, rods, nuts, rod plates and crosslink components. It can be used for single or multiple level fixations. Components are manufactured from titanium allov (Ti-6Al-4V ELI) that conforms to ISO 5832-3 ASTM F136 and cobaltchromium molybdenum alloy Co-Cr28Mo6 that conforms to ISO 5832-12 and ASTM F1537.
A subset of PASS LP Spinal System components may be used for posterior pedicle screw fixation in pediatrics cases. These constructs may be comprised of a variety of shapes and sizes of rods, hooks, sacral plates, iliac screws, clamps, nuts and crosslink components. The PASS LP components can be rigidly locked into a variety of configurations, with each construct being tailored made for the individual case.
The purpose of this submission is to extend the PASS LP Spinal System, with the addition of new components:
- । 'Top loading Pedicle hooks'
- -'Top loading Transverse Process hooks'
The provided text describes a 510(k) premarket notification for the "PASS LP Spinal System," a medical device. This document is a regulatory submission to the FDA, and as such, it focuses on demonstrating substantial equivalence to a predicate device rather than presenting a performance study with defined acceptance criteria in the manner one might expect for a novel AI/software device.
Therefore, the input document does not contain the requested information regarding acceptance criteria and a study proving a device meets those criteria for software or AI performance.
The document is about a spinal implant system and discusses:
- Its intended use.
- Comparison of its technological characteristics (design, materials) to predicate devices.
- Biocompatibility testing (which followed standards like ISO 10993) and mechanical testing (using Finite Element Analysis based on ASTM F1798 standards to compare with predicate devices).
- Explicitly states "No clinical studies were performed" and "No animal studies were performed."
Given the nature of the document, the following points based on your request cannot be extracted:
- A table of acceptance criteria and the reported device performance: Not applicable for this type of medical device submission where "performance" is primarily structural integrity and biocompatibility, demonstrated through testing against relevant standards rather than a clinical performance metric.
- Sample size used for the test set and the data provenance: Not applicable. The "tests" here are biomechanical and biocompatibility tests, not a clinical test set for AI/software performance.
- Number of experts used to establish the ground truth for the test set and the qualifications: Not applicable. No ground truth in the context of data labeling is mentioned.
- Adjudication method: Not applicable.
- Multi reader multi case (MRMC) comparative effectiveness study: Explicitly stated "No clinical studies were performed."
- Standalone (i.e. algorithm only without human-in-the-loop performance) study: This device is a physical implant, not an algorithm.
- The type of ground truth used: Not applicable.
- The sample size for the training set: Not applicable.
- How the ground truth for the training set was established: Not applicable.
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(149 days)
The APEX-DL Spine System with APEX Spine System Components is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudoarthrosis).
The APEX-DL Spine System with APEX Spine System Components is also indicated for pedicle screw fixation 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, with the device fixed or attached to the lumbar and sacral spine (levels of pedicle screw fixation are L3 to S1), and for whom the device is intended to be removed after solid fusion is attained.
The APEX-DL Spine System with APEX Spine System Components is also a sacraliliac screw fixation system of the non-cervical spine indicated for degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (fracture and/or dislocation), spinal stenosis, deformities (scoliosis, lordosis and/or kyphosis), tumor, and previous failed fusion (pseudo-arthrosis).
When used in a percutaneous posterior approach with AIM MIS instrumentation, the APEX-DL Spine System with APEX Spine System Components is intended for non-cervical pedicle fixation for the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, curvatures (i.e., scoliosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion in skeletally mature patients . Levels of fixation are for the thoracic, lumbar and sacral spine.
When used for posterior non-cervical pediatic patients, the APEX-DL Spine System implants with APEX Spine System Components are indicated as an adjunct to treat adolescent idiopathic scoliosis. The APEX DL Spine System is intended to be used with autograft. Pediatric pedicle screw fixation is limited to a posterior approach.
The APEX-DL Spine System includes Monoaxial, Uniplanar, and Polyaxial Double Lead Thread Screws in the cannulated and non-cannulated versions and in regular and reduction (extended tab) versions. APEX-DL Spine System is a low profile thoracolumbar implant for use with wide range of patient statures. The APEX-DL Spine System Polyaxial screws feature a friction head, which is designed to provide precise reduction mechanism as a result of easier rod capturing. The APEX-DL Spine System also includes Lordosed Percutaneous Rods. The APEX-DL Spine System is compatible with the APEX Spine System 5.5mm and 6.0mm rods, hooks, side-by-side connectors, iliac connectors, cross connectors, and washers.
The APEX-DL Spine System is a spinal implant for immobilization and stabilization of spinal segments. The document indicates that no clinical studies were performed. The acceptance criteria and testing are based on non-clinical (mechanical) tests.
1. Table of Acceptance Criteria and Reported Device Performance
Test Type | Acceptance Criteria | Reported Device Performance |
---|---|---|
ASTM F1717 (Vertebrectomy Model) | ||
Static Compression Bending | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
Static Torsion | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
Dynamic Compression Bending | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
ASTM F1798 (Interconnection Mechanisms) | ||
Static Axial Gripping Capacity | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
Axial Torque Gripping Capacity | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
Static Flexion-Extension | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
Dynamic Flexion-Extension | Not explicitly stated (comparison to predicates) | Results were "equal or higher than the predicate systems" |
Note: The acceptance criteria are implicitly defined as demonstrating mechanical properties that are "equal or higher" than the identified predicate devices, based on the testing standards.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not explicitly stated in the provided document. For each of the ASTM tests listed, a specific number of samples (implants/constructs) would have been used, but this detail is not provided.
- Data Provenance: The data is from non-clinical (mechanical) testing conducted presumably by SpineCraft, LLC or a contracted testing facility. It is not patient or human data; therefore, country of origin or retrospective/prospective does not apply in the typical sense.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. This is a non-clinical, mechanical testing study, not a study requiring expert clinical assessment or ground truth establishment in a medical imaging or diagnostic context. The "ground truth" here is the objective measurement of mechanical properties according to established ASTM standards.
4. Adjudication Method for the Test Set
Not applicable. This is a non-clinical, mechanical testing study. Adjudication methods like 2+1 or 3+1 are used for expert consensus in clinical or imaging studies.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. An MRMC study is a clinical study involving multiple human readers interpreting medical cases. The provided document explicitly states, "No clinical studies were performed."
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This device is a physical spinal implant, not an algorithm or AI system.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance is based on objective mechanical measurements according to recognized industry standards (ASTM F1717 and ASTM F1798). The performance is then compared to "predicate systems" as a benchmark for substantial equivalence.
8. The Sample Size for the Training Set
Not applicable. This is a physical medical device undergoing mechanical testing, not a machine learning model that requires a training set.
9. How the Ground Truth for the Training Set Was Established
Not applicable. As described in point 8, there is no "training set" for this type of device evaluation.
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(90 days)
The ASTRA System is intended to provide immobilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; spinal tumor; and failed previous fusion (pseudo-arthrosis).
The ASTRA Spine System is also indicated for pedicle screw fixation 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, with the device fixed or attached to the lumbar and sacral spine (levels of pedicle screw fixation are L3 to S1), and for whom the device is intended to be removed after solid fusion is attained.
The ASTRA System is also a sacral/iliac screw fixation system of the non-cervical spine indicated for degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radies), spondylolisthesis, trauma (fracture and/or dislocation), spinal stenosis, deformities (scoliosis, lordosis and/or kyphosis), tumor, and previous failed fusion (pseudo-arthrosis).
When used in a percutaneous, posterior approach with AVANT Spine MIS instrumentation, the ASTRA Spine System is intended for non-cervical pedicle fixation for the following indications: degenerative disc disease (defined as discogenic back pain 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), tumor, pseudo-arthrosis, and failed previous fusion in skeletally mature patients . Levels of fixation are for the thoracic, lumbar and sacral spine.
The ASTRA Spine System is a top loading, multiple component, posterior spinal fixation system which consists of rods, cannulated and non-cannulated monoaxial, uniplanar and polyaxial screws, hooks, iliac connectors, rod connectors, and cross connectors. Most of the components are available in a variety of sizes to more closely match the patient's anatomy.
Materials:
Titanium alloy
CoCr alloy
Here's an analysis of the provided text regarding the ASTRA Spine System, focusing on acceptance criteria and study details.
Important Note: The provided document is a 510(k) summary for a medical device (Spine System), not an AI/ML device. Therefore, many of the requested fields related to AI/ML specific studies (like sample sizes for test/training sets, data provenance, expert ground truth, MRMC studies, standalone performance) are not applicable to this type of medical device submission. This document focuses on demonstrating substantial equivalence to predicate devices through non-clinical (mechanical) testing.
1. Table of Acceptance Criteria and Reported Device Performance
For this medical device, the "acceptance criteria" are implicitly defined by performance equivalence to predicate devices in standardized mechanical tests. The "reported device performance" is a statement of comparative equivalence.
Acceptance Criteria (Implicit) | Reported Device Performance (Summary) |
---|---|
Static Compression Bending: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Static Torsion: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Dynamic Compression Bending: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Axial Gripping: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Torsional Gripping: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Static Flexion-Extension: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Dynamic Flexion-Extension: Must perform at least equivalent to predicate systems. | "The results of this testing were compared to predicate systems, with the results being equal to or higher than the predicate systems." |
Overall Substantial Equivalence: Must be substantially equivalent in intended use, design, material, performance, and function. | "The ASTRA Spine System is substantially equivalent to the predicate devices in terms of indications for use, design, material, performance and function." |
2. Sample Size Used for the Test Set and the Data Provenance
This is a physical device, and the "test set" refers to the tested device components.
- Sample Size: Not explicitly stated in terms of number of components tested for each test, but standard engineering practices for medical device testing would involve a sufficient number (e.g., n=5 or n=10 per test) to ensure statistical significance, though the exact numbers are not provided in this summary.
- Data Provenance: The tests are non-clinical, meaning they were conducted in a laboratory setting. There is no patient data provenance (e.g., country of origin, retrospective/prospective) since no human data was used for these mechanical tests.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- Not Applicable. For mechanical testing of a physical device, ground truth is established by standardized testing protocols (e.g., ASTM standards) and measured physical properties, not by expert consensus on clinical data. Engineers and lab technicians perform and analyze the tests according to these standards.
4. Adjudication Method for the Test Set
- Not Applicable. There is no adjudication in the sense of reconciling human expert opinions for clinical images or data. The results of mechanical tests are objective measurements against defined criteria.
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 physical spinal implant, not an AI/ML diagnostic or assistive device. No MRMC studies were performed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Not Applicable. This is a physical spinal implant; there is no algorithm or standalone performance.
7. The Type of Ground Truth Used
- Mechanical Test Standards and Predicate Device Performance: The "ground truth" for the non-clinical tests is based on the established performance characteristics and safety profiles of legally marketed predicate devices, as defined by FDA regulations for substantial equivalence, and adherence to relevant ASTM standards (ASTM F1717 and ASTM F1798).
8. The Sample Size for the Training Set
- Not Applicable. This is a physical device; there is no AI/ML model or "training set" in the context of machine learning. The device design and materials are based on engineering principles and knowledge of predicate devices.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. As there is no training set for an AI/ML model, this question is not relevant. The "ground truth" for developing the physical device is based on established biomechanical and medical understanding of spinal fixation and the performance of existing, cleared devices.
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