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510(k) Data Aggregation
(51 days)
The MAGEC® System is intended for skeletally immature patients less than 10 years of age with severe progressive spinal deformities (e.g., Cobb andle of 30 dearees or more: thoracic spine height less than 22 cm) associated with or at risk of Thoracic Insufficiency Syndrome (TIS). TIS is defined as the inability of the thorax to support normal respiration or lung growth.
The MAGEC® System is comprised of a sterile single use spinal rod that can be surgically implanted using appropriate NuVasive® Reline®, Reline 4.5-5.0 (Reline Small Stature) or Armada® fixation components (i.e. pedicle screws, hooks and/or connectors). The implanted MAGEC Rod is used to brace the spine during growth to minimize the progression of scoliosis. The system includes a non-sterile hand held External Remote Controller (ERC) 1 or 2 that is used periodically after implantation to non-invasively distract the implanted spinal rod. The titanium MAGEC Rod includes an actuator portion that holds a small internal magnet. The magnet in the actuator can be turned non-invasively by use of the ERC, which is electrically powered. The hand held non-invasive ERC is placed over the patient's spine and then manually activated, which causes the implanted magnet to rotate and either distract or retract the rod. Once the physician determines that the implant has achieved its intended use and is no longer required, the implant is explanted. Additional accessories for the MAGEC® System include the MAGEC Manual Distractor, MAGEC Rod Template, and the MAGEC Wand Magnet Locator. The MAGEC Manual Distractor is a sterile, single use device, which is used in the operating room to test the MAGEC Rod prior to implantation. The MAGEC Rod Template is a sterile, single-use accessory used for intraoperative planning of the surgical procedure. The MAGEC Wand Magnet Locator is a non-sterile device which is used during the distraction procedure to locate the magnet within the MAGEC Rod previously implanted in a patient.
The purpose of this premarket notification is to implement assembly process changes and a design change to the MAGEC Rod cleared in K171791 to address the Field Safety Notice and Product Recall issued on February 13, 2020 for the MAGEC X device (FDA Recall Number Z-1898-2020 and Recall Event ID 85495).
The provided text is a 510(k) summary for the NuVasive MAGEC® System, which is a spinal rod system designed for skeletally immature patients with severe progressive spinal deformities. The submission aims to demonstrate substantial equivalence to previously cleared MAGEC systems.
Here's an analysis of the acceptance criteria and study information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state quantitative "acceptance criteria" for device performance in terms of specific thresholds for outcomes (e.g., minimum distraction force, maximum bending, etc.) that the device needed to meet. Instead, it refers to performance testing against established ASTM standards and internal verification for distraction/retraction. The general "acceptance criteria" can be inferred as demonstrating substantial equivalence to the predicate devices through successful completion of the listed nonclinical tests.
Test Description | Applicable Standard | Reported Device Performance |
---|---|---|
Static Compression Bending | ASTM F1717: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model | Demonstrated substantial equivalence to predicate devices |
Dynamic Compression Bending | ASTM F1717: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model | Demonstrated substantial equivalence to predicate devices |
Static Torsion | ASTM F1717: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model | Demonstrated substantial equivalence to predicate devices |
Distraction and Retraction Verification | N/A | Demonstrated substantial equivalence to predicate devices (verified function) |
Torsional Strength | ASTM F1798: Standard Guide For Evaluating The Static And Fatigue Properties Of Interconnection Mechanisms And Subassemblies Used In Spinal Arthrodesis Implants | Demonstrated substantial equivalence to predicate devices |
2. Sample Size Used for the Test Set and Data Provenance
The document only mentions "nonclinical testing" and lists standards for mechanical testing. It does not provide details on the sample size for these tests (e.g., number of rods tested for bending, torsion, etc.). The data provenance is also not specified beyond being "nonclinical testing." It does not involve human data, so terms like "country of origin" or "retrospective/prospective" are not applicable in this context.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
This information is not applicable. The testing described is nonclinical mechanical testing, not clinical studies requiring expert review or ground truth establishment in a diagnostic context.
4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set
This information is not applicable as the testing is nonclinical mechanical testing and does not involve human assessment or adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
No, an MRMC comparative effectiveness study was not done. The submission focuses on nonclinical testing for substantial equivalence of a medical device (spinal rod system), not on diagnostic performance or human reader improvement with AI assistance.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
This question is not applicable. The MAGEC System is a physical medical device (spinal rod and external controller), not an algorithm or AI system. Its performance is related to mechanical properties and functional reliability, not algorithmic accuracy.
7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)
The "ground truth" for the nonclinical tests is established by the specifications and acceptance limits defined within the referenced ASTM standards (e.g., specific forces, deflections, cycles, or distraction distances). The device is expected to meet or exceed the performance of the predicate and comply with these mechanical standards.
8. The Sample Size for the Training Set
This information is not applicable. The MAGEC System is a physical device, not an AI/ML model that requires a training set.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable, as there is no training set for a physical medical device.
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(108 days)
The EVEREST Spinal System may be used in conjunction with the RANGE® (MESA® and DENALI®) Spinal Systems, all of which are cleared for the following indications: Posterior non-cervical fixation as an adjunct to fusion for the following indications: degenerative disc disease (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; pseudarthrosis; and/or failed previous fusion. Except for hooks, when used as an anterolateral thoracic/lumbar system the EVEREST Spinal System may also be used for the same indications as an adjunct to fusion. When used for posterior non-cervical pedicle screw fixation in pediatric patients the EVEREST Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. These devices are to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.
Range (Mesa and Denali) and ARI are cleared for the following indications: Posterior non-cervical fixation as an adjunct to fusion for the following indications: degenerative disc disease (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; pseudarthrosis; and/or failed previous fusion. Except for hooks, when used as an anterolateral thoracic/lumbar system the Range Spinal System may also be used for the same indications as an adjunct to fusion. Except for the ARI staples, the Range Spinal System is indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis when used for posterior noncervical fixation in pediatric patients. The Range Spinal System for pediatric use is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.
The Caspian OCT/MESA Mini/DENALI Mini Spinal System is intended to provide immobilization and stabilization of spinal seqments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine (T1-T3): traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudoarthrosis); 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 Caspian OCT/MESA Mini/DENALI Mini Spinal 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 Caspian OCT/MESA Mini/DENALI Mini Spinal System may be connected to Range/MESA/DENALI Spinal System and Everest Spinal System components via the rod to rod connectors or transition rods.
The YUKON OCT Spinal System is intended to provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1to C7) and the thoracic spine (T1-T3): traumatic spinal fractures and/or traumatic dislocations: instability or deformity: failed previous fusions (e.q., pseudoarthrosis); 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 YUKON OCT Spinal 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 YUKON OCT Spinal System may be connected to Everest Spinal System components via the rod to rod connectors or transition rods.
The previously cleared K2M EVEREST, RANGE (MESA and DENALI), CASPIAN OCT (MESA Mini and DENALI mini) and YUKON OCT Spinal Systems are top-loading, multiple component posterior spinal fixation implants consisting of pedicle screws, hooks, rods and connectors, intended to provide support during spinal fusion procedures. The primary purpose of this submission is to establish an MR Conditional labeling claim for these implants. In addition, CASPIAN components that were previously provided non-sterile are now being optionally offered as sterile packaged devices.
Here's an analysis of the provided text regarding the acceptance criteria and study for the EVEREST, RANGE, CASPIAN OCT, and YUKON OCT Spinal Systems:
Based on the provided FDA 510(k) summary, the primary purpose of this submission is not to introduce a new device with novel performance criteria, but rather to:
- Establish an MR Conditional labeling claim for existing, previously cleared spinal systems.
- Optionally offer previously non-sterile CASPIAN components as sterile packaged devices.
Therefore, the "acceptance criteria" and "device performance" in this context refer to demonstrating the safety and compatibility of the devices in an MRI environment, and that their core technological characteristics remain equivalent to their predicates.
It is important to note that this document is a 510(k) summary for modifications to existing devices (primarily MR compatibility and sterilization options), not for the initial clearance of the spinal systems themselves. The original studies for the biomechanical and clinical performance of the spinal systems would have been part of their initial 510(k) submissions. This document focuses on the new testing related to the modifications.
Acceptance Criteria and Reported Device Performance
Acceptance Criteria (for MR Conditional Labeling and Sterilization) | Reported Device Performance |
---|---|
MR Conditional Labeling: Devices must meet relevant ASTM standards for MRI safety. | MR Compatibility testing per ASTM F2503 was performed. The test results demonstrate that the listed spinal systems' performance is substantially equivalent to the predicate devices. |
Sterilization: Sterile packaged devices must meet appropriate sterilization standards. | CASPIAN components previously provided non-sterile are now being optionally offered as sterile packaged devices. (Implies that sterilization validation was performed, though specific standards or results are not detailed in this summary.) |
Technological Characteristics: No changes to the fundamental scientific technology or performance of the spinal systems. | The systems possess the same technological characteristics as their predicate devices; no changes have been made to any of the devices. The fundamental scientific technology is the same as previously cleared devices. |
Intended Use: The intended use of the systems remains the same as their predicate devices. | The systems possess the same intended use as the predicate devices. |
Study Details (Relevant to this 510(k) submission)
The primary study mentioned in this document is related to MR Compatibility testing.
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Sample size used for the test set and the data provenance:
- The document does not specify a "sample size" in terms of number of patients or cases for this particular testing. MR compatibility testing (per ASTM F2503) typically involves testing the physical devices themselves (e.g., assessing heating, artifact generation, and displacement forces), not patient data.
- Data provenance: Not applicable in the context of device testing for MR compatibility. The tests would be conducted in a controlled laboratory environment.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable as this is a device performance test, not an AI or diagnostic expert review study. MR compatibility testing is conducted by engineers and technicians following established ASTM protocols.
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Adjudication method for the test set:
- Not applicable for device performance testing. Results are typically determined by measurements against predefined ASTM standards.
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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. This document pertains to spinal implants (physical medical devices), not AI software or diagnostic imaging analysis. Therefore, no MRMC study, AI integration, or human reader improvement assessment was performed or is relevant to this submission.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- No. This is not an algorithm or software device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable as this concerns the physical properties of the device for MR compatibility. The "ground truth" would be the measured physical interactions (e.g., temperature rise, deflection) of the implant components in an MRI electromagnetic field compared to acceptable limits defined by ASTM F2503.
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The sample size for the training set:
- Not applicable. There is no software or AI model involved that would require a training set.
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How the ground truth for the training set was established:
- Not applicable. There is no software or AI model involved.
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