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510(k) Data Aggregation

    K Number
    K212358
    Manufacturer
    Date Cleared
    2022-01-10

    (165 days)

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

    K141599, K173102, K202812, K142079

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

    The Romero Cervical Cage consists of an interbody device indicated for use in anterior cervical interbody fusion procedures in skeletally mature patients with cervical disc disease at one or two contiguous levels from the C2 to the T1 disc. Cervical disc disease is defined as intractable radiculopathy and/or myelopathy with herniated disc and/or osteophyte formation on posterior vertebral endplates producing symptomatic nerve root and/or spinal cord compression confirmed by radiographic studies. The Romero Cervical Cage includes cages with and without screw holes. For cages with internal screw holes, the provided screws must be used for internal fixation. The Romero Cervical Cage requires additional supplemental fixation cleared for the cervical spine. The Romero Cervical Cage is designed for use with autograft bone and/or allogenic bone graft composed of cancellous and/or corticocancellous bone graft, to facilitate fusion and is to be implanted via an open, anterior approach. This cervical device is to be used in patients who have had six weeks of nonoperative treatment. Patients with previous non-fusion spinal surgery at involved level may be treated with the device.

    Device Description

    The Romero Cervical Cage is an anterior cervical interbody device consisting of a PEEK HA or PEEK OPTIMA interbody cage with tantalum radiographic markers and two Titanium (Ti-6Al-4V ELI) fixation screws for cages with screw holes. The PEEK material used conforms to ASTM F2026, the Titanium screws conforms to ASTM F136 and the Tantalum radiographic markers conforms to ASTM F560. The interbody cage is provided in 6° lordosis, anatomic (domed), and lordotic (tapered) profiles in footprints ranging from (WxD) 14x12 to 20x16 (by increments of 2 mm in either direction) and sizes ranging from 5.5 mm (H04) to 14.5 mm (H13) (excluding H04 and H05 in the (WxD) 14x12 to 14x16 footprint for the self-anchored cages). The two radiographic markers are present on the posterior wall to confirm position and orientation relative to the AP plane. The bone screws are provided as self-drilling and self-tapping options in 3.5 mm and 4.0 mm diameters and 8-20 mm lengths and feature an anti-backout / tri-lobe screw head design. Both cages and screws are available in separate, single-use sterile packaging.

    AI/ML Overview

    The provided text is an FDA 510(k) summary for the Romero Cervical Cage, an intervertebral body fusion device. It does not describe a study involving an AI/Machine Learning (AI/ML) device, nor does it contain information about "device performance," "acceptance criteria," "sample sizes for test or training sets," "expert ground truth," "adjudication methods," or "MRMC studies."

    The document focuses on demonstrating substantial equivalence of a physical medical device (a cervical cage) to predicate devices through mechanical performance testing. The "Performance Testing" section states: "Mechanical testing was performed to demonstrate substantial equivalence using static compression, static compression shear, static torsion, dynamic compression, dynamic compression shear, and dynamic torsion testing per ASTM F2077-18. Subsidence testing per ASTM F2267-04, expulsion and axial push out testing. The result showed that the worst-case constructs were substantially equivalent to legally marketed devices. No clinical or animal studies were performed."

    Therefore, I cannot fulfill your request for information related to AI/ML device acceptance criteria and study details based on the provided text. The device in question is a physical implant, not an AI/ML algorithm.

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    K Number
    K212715
    Manufacturer
    Date Cleared
    2021-12-20

    (116 days)

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

    K173102

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

    The Vy Spine™ ClariVy™ Cervical IBF System is indicated for intervertebral body fusion of the spine in skeletally mature patients. The device systems are designed for use with autogenous bone graft to facilitate fusion. One device may be used per intervertebral space. The implants are intended to be used supplemental spinal fixation cleared for the implanted level.

    The Vy Spine™ ClariVy™ Cervical IBF System is intended for use at one level in the cervical spine, from C3 to T1, for treatment of cervical degenerate disc disease (DDD is defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies). The Vy Spine™ ClariVy™ Cervical IBF System is to be used in patients who have six weeks of non-operative treatment.

    Device Description

    The Vy Spine™ ClariVy™ Cervical IBF System is comprised of implants components. The implant component, the Vy Spine™ ClariVy™ Cervical IBF device, is a spacer, which inserts between vertebral bodies in the anterior column of the cervical spine. The spacer may be made of PEEK Optima LT1 or PEEK Optima LT1-HA with Tantalum markers. The Vy Spine™ ClariVy™ Cervical IBF System may also include Titanium alloy bone screws to secure the device to the vertebral body.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the Vy Spine™ ClariVy™ Cervical IBF System:

    Based on the provided text, the device does not involve artificial intelligence or algorithms, and therefore, the typical acceptance criteria and study design elements requested (such as sample size for test/training sets, experts for ground truth, MRMC studies, standalone performance) are not applicable.

    The submission is for an intervertebral body fusion (IBF) device, which is a physical implant. The "Non-Clinical Testing" section describes mechanical testing to assess the device's physical properties, not its diagnostic or predictive performance.

    Therefore, many of the specific questions cannot be answered from the provided document as they pertain to AI/software device evaluation, not a physical implant.


    Acceptance Criteria and Reported Device Performance

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

    Since this is a physical medical device (intervertebral body fusion system), the "acceptance criteria" are related to mechanical performance, material properties, and biocompatibility, rather than diagnostic accuracy metrics like sensitivity or specificity. The text describes the testing performed but does not explicitly state numerical acceptance criteria in a table. It implies that meeting the standards outlined in the ASTM protocols demonstrates acceptable performance.

    Acceptance Criteria CategoryReported Device Performance / Assessment Method
    Mechanical Performance- Tested per ASTM F-2077 (Standard Test Methods for Intervertebral Body Fusion Devices)
    - Tested per ASTM F-2267 (Standard Test Method for Measuring Load Displacement of Spinal Implants Under Static and Dynamic Compression and Transverse Load)
    - Tested per ASTM Draft F-04.25.02.02 standards (specifications not fully detailed in the document, but implies relevant mechanical tests for spinal implants)
    - Mechanical tests included: static axial compression, dynamic axial compression, static axial torsion, dynamic axial torsion, static compressive shear, dynamic compressive shear, expulsion, and subsidence.
    Material Composition- The subject device has the "same material" (PEEK Optima LT1 or PEEK Optima LT1-HA with Tantalum markers) as the predicate devices, which is presumed to be acceptable.
    Biocompatibility- The subject device has the "same... biocompatibility" as the predicate devices, implying it meets established biocompatibility standards.
    Design and Sizes- The subject device has the "same... design, sizes" as the predicate devices, indicating substantial equivalence in these aspects.
    Intended Use- The subject device has the "same... indication of use" as the predicate devices, affirming its suitability for the specified clinical application (intervertebral body fusion of the cervical spine for DDD).
    Function- The subject device was shown to have equivalent technological characteristics to its predicate devices through comparison in areas including design, intended use, material composition, and function. (This implies functional equivalence based on mechanical and material properties compared to a legally marketed predicate).
    Substantial Equivalence- The device is considered substantially equivalent to the predicate device (Reliance Cervical IBF K173102) in terms of material, intended use, levels of attachment, size range, and use with supplemental fixation, based on the non-clinical testing and comparison of technological characteristics. This is the primary "acceptance criterion" for 510(k) clearance, rather than a quantifiable performance metric for a diagnostic AI device.

    Unavailable Information (Due to Device Type)

    The following information is not applicable or available in the provided document because the Vy Spine™ ClariVy™ Cervical IBF System is a physical implant, not an AI/software device. The questions are structured for AI/diagnostic product evaluations, which is not what this FDA clearance describes.

    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. This pertains to clinical data for diagnostic/AI devices. For this physical implant, the "test set" would be physical samples of the device undergoing mechanical testing. The document refers to "various ASTM Standards" and testing "at a third party facility," but does not detail the number of physical units tested or their "provenance."

    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. Ground truth, in this context, usually refers to clinically confirmed diagnoses or outcomes for evaluating AI/diagnostic performance. For a mechanical device, performance is evaluated against engineering standards and material properties, not expert-adjudicated clinical "ground truth."

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

    • Not Applicable. Adjudication methods are used to establish a consensus ground truth for diagnostic studies, typically with human readers. This concept does not apply to the mechanical testing of a physical implant.

    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. MRMC studies are for evaluating the performance of diagnostic systems (often AI) with and without human interaction, which is irrelevant for an intervertebral body fusion implant.

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

    • Not Applicable. This device does not contain any algorithms or software. The document explicitly states: "This device does not contain software or electrical equipment."

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

    • Not Applicable. For mechanical testing, the "ground truth" is defined by the physical behaviors and measurements against established engineering standards (e.g., how much load a device can withstand before deformation or failure), not clinical diagnostic truths.

    8. The sample size for the training set

    • Not Applicable. There is no "training set" as this is not an AI/software device that learns from data.

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

    • Not Applicable. As there is no training set, there is no ground truth establishment for it.

    Summary regarding the device:

    The Vy Spine™ ClariVy™ Cervical IBF System is a Class II physical medical device intended for intervertebral body fusion. Its clearance (K212715) relies on demonstrating substantial equivalence to a previously cleared predicate device (Reliance Cervical IBF K173102) through:

    • Comparison of technological characteristics (material, design, size, intended use).
    • Non-clinical mechanical testing performed according to ASTM standards to ensure its safety and effectiveness are comparable to the predicate.

    The document very clearly states: "This device does not contain software or electrical equipment." This is why the questions related to AI/software performance evaluation are not relevant.

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