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510(k) Data Aggregation
(20 days)
ANAX™ 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 (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); 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. ANAX™ 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, ANAX™ OCT Spinal System may be connected to Perfix™ Spinal System and ANAX™ 5.5 Spinal System rods with the rod connectors. Transition rods with differing diameters may also be used to connect ANAX™ OCT Spinal System to Perfix™ Spinal System and ANAX™ 5.5 Spinal System.
The ANAX™ OCT Spinal System is for fixation the cervicocranium (Occiput/C2), the true subaxial region (C3/C6), and the cervicothoracic junction (C7 to T2) by one system. The ANAX™ OCT Spinal System consists of polyaxial screws, polyaxial shank screws, hooks, rods, set screws, transverse (cross) links and occipital plate. Connectors are also provided for surgical convenience. The ANAX™ OCT Spinal System allows surgeons to build a spinal implant construct to stabilize and promote spinal fusion. The single-use ANAX™ OCT Spinal System components are supplied as non-sterile and are fabricated from medical grade titanium alloy (ASTM F136) and medical grade cobalt-chromium-molybdenum alloy (ASTM F1537). All polyaxial screws have self-tapping functions in the ANAX™ OCT Spinal System.
Specialized instruments made from surgical instrument grade stainless steel are available for the application and removal of the ANAX™ OCT Spinal System implants.
The provided FDA 510(k) Clearance Letter for the ANAX™ OCT Spinal System does not describe acceptance criteria or a study that proves the device meets specific acceptance criteria based on performance metrics such as sensitivity, specificity, or accuracy.
Instead, this document focuses on demonstrating substantial equivalence to predicate devices. This is a common pathway for medical device clearance, where the new device is shown to be as safe and effective as a legally marketed device that does not require Pre-Market Approval (PMA).
Here's an analysis based on the information provided, highlighting why certain questions cannot be answered from this document:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Not explicitly stated as such, but inferred from testing) | Reported Device Performance |
---|---|
Mechanical Integrity: Demonstrated through comprehensive mechanical testing (e.g., ASTM F1717, F1798) to ensure safety and effectiveness. | Comparable/Superior Material Performance: Cobalt-chromium-molybdenum (CoCr) rods exhibit higher tensile and yield strength compared to titanium (Ti) rods. All failure modes occurred at the screw-housing interface, not the rod itself. |
Safety and Effectiveness: No new questions of safety or effectiveness introduced by the modification (addition of CoCr rods). | Comparative material analysis and existing mechanical test data confirm equivalent or superior performance, indicating no new safety or effectiveness concerns. |
Design, Functions, Intended Use Equivalence: To predicate devices. | The modified device maintains identical indications for use, equivalent overall construct design, dimensions, and components (with rod material being the only modification). |
Explanation: The "acceptance criteria" here are implicitly related to demonstrating that the new CoCr rods perform at least as well as, or better than, the existing titanium rods in terms of mechanical properties and do not alter the overall system's safety or intended function. The FDA's acceptance of the 510(k) implies that these criteria were met.
Regarding the specific study details for AI/software-based devices, the following cannot be answered from this document because the ANAX™ OCT Spinal System is a physical implantable medical device, not an AI or software device.
2. Sample size used for the test set and the data provenance: Not applicable. The "test set" here refers to physical components tested.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for physical components is typically derived from engineering specifications and material science, not expert consensus in the diagnostic sense.
4. Adjudication method for the test set: Not applicable.
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.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): For a physical device, "ground truth" relates to material properties (e.g., tensile strength, yield strength), dimensional accuracy, and mechanical performance under simulated physiological loads, established by engineering standards (e.g., ASTM F136, F1537, F1717, F1798).
8. The sample size for the training set: Not applicable. This is not an AI/ML device.
9. How the ground truth for the training set was established: Not applicable.
Summary of Relevant Information from the Document:
- Device Type: Physical implantable spinal fixation system (ANAX™ OCT Spinal System).
- Modification: Addition of cobalt-chromium-molybdenum (CoCr) rods.
- Mechanism of Proof: Substantial equivalence to predicate devices.
- Key Evidence for Substantial Equivalence:
- Indications for Use: Identical to predicate devices.
- Design & Components: Equivalent overall construct, dimensions, and components, with the only change being rod material.
- Material Properties: CoCr rods demonstrate higher tensile and yield strength than the previously cleared titanium (Ti) rods.
- Manufacturing: CoCr rods are manufactured and processed using the same methods and surface treatments as the Ti rods.
- Performance Testing: Comprehensive mechanical testing (e.g., ASTM F1717, F1798) was conducted, including a worst-case configuration.
- Failure Analysis: All observed failure modes occurred at the screw-housing interface, not within the rod itself, suggesting the rods are sufficiently strong.
- Conclusion of Study: The mechanical integrity of the CoCr rods was confirmed, and the comparative material analysis showed comparable or superior performance, leading to the conclusion that the addition of CoCr rods does not raise new questions of safety or effectiveness.
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