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510(k) Data Aggregation

    K Number
    K181829
    Manufacturer
    Date Cleared
    2018-11-14

    (128 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K172419, K170512

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

    The Velofix™ TLIF Cage is 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 non-operative treatment. The Velofix™ TLIF Cage is to be used with supplemental internal spinal fixation. Additionally, the Velofix™ TLIF Cage is to be used with autogenous bone graft material.

    Device Description

    The Velofix™ TLIF Cage consists of implants available in various heights, width, length and angle with an open architecture to accept packing of auto bone graft material. The Velofix™ TLIF Cage may be implanted a single device via a transforaminal approach and adopted to the anterior anatomy of the vertebral endplates.

    The Velofix™ TLIF Cage device has two types: the one is consisted of cage body (PEEK), articulating component (Ti Alloy) and radiographic markers (Tantalum); the other is consisted of cage body and articulating component made of Ti Alloy. The articulating component is for attachment to the inserter instrument to allow the cage to pivot to the final positioning.

    The Velofix™ TLIF Cage implant is manufactured from either

    1. Polyetheretherketone (PEEK) with a titanium alloy for articulating component (Ti6Al4V ELI), and tantalum radiographic markers for spinal applications, or

    2. Titanium alloy (Ti6Al4V ELI) for cage body and articulating component for spinal applications.

    The Velofix™ TLIF Cage is implanted by using the instruments manufactured from stainless steel materials that conform to ASTM F899.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called the Velofix™ TLIF Cage, specifically an update to introduce a titanium alloy version. The document focuses on establishing substantial equivalence to previously cleared predicate devices rather than proving the device meets specific acceptance criteria through a clinical study.

    Therefore, many of the requested information points (such as acceptance criteria, reported device performance, sample sizes for test/training sets, experts, adjudication methods, MRMC studies, standalone performance, ground truth types) are not applicable or cannot be extracted from this type of regulatory submission. This document is a summary demonstrating equivalency, not a detailed study report.

    Here's an attempt to answer the questions based only on the provided text, noting where information is not available:

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

    This information is not provided in the document. The submission focuses on demonstrating substantial equivalence to predicate devices, not on setting and meeting specific quantitative acceptance criteria for performance in a clinical setting. It states that mechanical strength evaluation was conducted for comparison, but no specific criteria or reported performance values are given.

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

    This information is not provided. The document explicitly states: "Any mechanical test in non clinical setting (bench testing) was not conducted on the Velofix™ TLIF Cage." It refers to a "mechanical strength evaluation" but does not detail a test set, sample size, or data provenance. This is a regulatory filing for a device, not a human clinical trial.

    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 information is not provided. "Ground truth" in the context of device performance, especially for a spinal implant, would typically come from clinical outcomes, pathology, or expert assessment in a clinical trial. This document does not describe such a study.

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

    This information is not provided. Since no clinical or bench test set with expert assessment is detailed, no adjudication method is mentioned.

    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 information is not provided. An MRMC study is relevant for AI or imaging interpretation devices. The Velofix™ TLIF Cage is an intervertebral body fusion device (an implant), not an AI or imaging device, so an MRMC study would not be applicable to its intended use.

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

    This information is not provided. This question is relevant for AI algorithms. The Velofix™ TLIF Cage is a physical implant, so the concept of "standalone algorithm performance" does not apply.

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

    This information is not provided. As a physical implant aiming for substantial equivalence, the "ground truth" for its performance would typically relate to fusion rates, complication rates, and pain reduction, assessed through clinical outcomes. However, this submission does not detail such studies or outcomes data as it relies on equivalency to existing devices.

    8. The sample size for the training set

    This information is not provided. This question is relevant for machine learning models. The Velofix™ TLIF Cage is a physical medical device, not an AI model, so there is no "training set."

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

    This information is not provided. This question is relevant for machine learning models. As it's a physical device, this concept does not apply.


    Summary of what the document does state about "studies" and "performance":

    The document states:

    • "Any mechanical test in non clinical setting (bench testing) was not conducted on the Velofix™ TLIF Cage." (This refers to the proposed device, which is the titanium alloy version).
    • "However, the mechanical strength evaluation was conducted to compare data of proposed device of the Velofix™ TLIF Cage (K172419) and to verify there are no new safety and effectiveness issues were not raised by the proposed device." (K172419 is the primary predicate device, which was made of PEEK. This suggests a comparison of the new titanium version to the previously cleared PEEK version, not a de novo study against explicit criteria.)
    • The conclusion is that the device is "substantially equivalent to predicate devices with respect to indications for use and technological characteristics," implying that the performance is considered similar, therefore acceptable.
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