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510(k) Data Aggregation

    K Number
    K201568
    Manufacturer
    Date Cleared
    2020-11-12

    (154 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Calvary Spine Pedicle Screw System is intended to provide immobilization and stabilization 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 thoracic, lumbar, and sacral spine (T1 to S1/ilium); degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.

    When used for posterior, non-cervical (T1 to S1/ilum), pedicte screw fixation in pediatric patients, the Calvary Spine Pedicle Screw System implants are indicated as an adjunct to fusion to treat progressive spinal deformities (i.e., scoliosis, kyphosis, or lordosis) including idiosis, neuromuscular scoliosis, and congenital scoliosis. Additionally, the Calvary Spine Pedicle Screw System is intended to treat pediatric patients diagnosed with spondylolisthesis/spondylolysis, fracture caused by tumor and/or trauma, pseudarthrosis, and/or failed previous fusion.

    This system is intended to be used with autograft. Pediatric pedicle screw fixation is limited to a posterior approach.

    Device Description

    Calvary Spine Pedicle Screw System includes screws and connecting components in a wide variety of sizes and shapes, which can be locked in various configurations, each assembly being tailor-made. Calvary pedicular screws must be used with Ø 5.5mm straight and curved rods.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study for the Calvary Spine Pedicle Screw System:

    Based on the provided FDA 510(k) summary (K201568), there is no information about acceptance criteria or a study proving the device meets specific performance criteria in terms of an AI/algorithm-based medical device.

    The document describes a traditional medical device, specifically a pedicle screw system, which is a hardware implant used in spinal fusion surgery. The "acceptance criteria" discussed in this document refer to the regulatory requirements for establishing substantial equivalence to previously cleared predicate devices, primarily based on design, materials, and mechanical performance through non-clinical testing.

    Therefore, I cannot populate most of the requested fields because they are specifically tailored for studies validating AI/algorithm performance.

    However, I can extract the relevant information regarding the type of study and the basis for substantial equivalence:


    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a traditional medical device and not an AI/algorithm, there are no specific performance metrics like sensitivity, specificity, or AUC to list as acceptance criteria for automated diagnosis or analysis. The "acceptance criteria" for this device are broadly the demonstration of substantial equivalence to predicate devices based on:

    Acceptance Criteria (Broad Interpretation for Traditional Device)Reported Device Performance (Summary)
    Intended Use EquivalenceEquivalent to predicate devices.
    Material EquivalenceUses same materials (Ti-6Al-4V ELI, CP Titanium, CoCrMo).
    Design EquivalenceEquivalent in shape, sizes, material, manufacturing process.
    Strength EquivalenceGreater or equivalent strength values compared to predicate devices.

    2. Sample Size Used for the Test Set and Data Provenance

    • Not applicable (N/A) for an AI/algorithm test set.
    • The "test set" in this context refers to the samples used in non-clinical mechanical testing, which are typically manufactured units of the device. No information on the specific number of units tested for each mechanical test is provided, but it would involve standard engineering sample sizes for material and mechanical property evaluations.
    • Data Provenance: The data provenance for mechanical testing would be from internal laboratory testing of the manufactured devices. No country of origin for data in the AI sense is relevant here, nor is retrospective or prospective human data.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    • N/A for an AI/algorithm test set.
    • Ground truth for mechanical properties is established through standard engineering and materials testing protocols (e.g., ASTM standards), not by human experts adjudicating images or clinical data.

    4. Adjudication Method for the Test Set

    • N/A for an AI/algorithm test set.
    • Mechanical test results are objective measurements against defined standards, not subject to human adjudication methods like 2+1 or 3+1.

    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

    • No. An MRMC study was not done.
    • This device is not an AI/algorithm, therefore, there is no human-in-the-loop performance improvement with AI assistance to measure.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    • No. A standalone algorithm performance study was not done.
    • This device is not an AI/algorithm.

    7. The Type of Ground Truth Used

    • Mechanical and Material Standards: The "ground truth" for this medical device's performance is compliance with established material specifications (e.g., ASTM F136, F67, F1582) and mechanical testing standards for spinal implants, demonstrating equivalent or superior strength to predicate devices.

    8. The Sample Size for the Training Set

    • N/A for an AI/algorithm training set.
    • This device does not involve a training set as it's not an AI/algorithm.

    9. How the Ground Truth for the Training Set Was Established

    • N/A for an AI/algorithm training set.
    • Not applicable as there is no training set.

    Summary of what was done (based on the provided text):

    The Calvary Spine Pedicle Screw System underwent non-clinical testing to demonstrate that it is substantially equivalent to legally marketed predicate devices. This equivalence was established based on:

    • Similar materials (Ti-6Al-4V ELI, CP Titanium, CoCrMo).
    • Similar intended use.
    • Similar design (shape, sizes, manufacturing process).
    • Comparable or superior strength values, presumably measured through mechanical testing (though specific tests and methodology are not detailed in this summary).

    The document explicitly states: "No clinical studies were performed." This is common for 510(k) clearances where substantial equivalence can be demonstrated through non-clinical data.

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    K Number
    K201659
    Manufacturer
    Date Cleared
    2020-10-05

    (109 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The KHEIRON Spinal Fixation 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 thoracic, lumbar, and sacral spine: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis), spinal stenosis, spinal tumor, pseudarthrosis and failed previous fusion.

    When used for posterior, non-cervical, pedicle screw fixation in pediatric patients, the KHEIRON System implants are indicated as an adjunct to fusion to treat progressive spinal deformities (i.e., scoliosis, kyphosis) including idiopathic scoliosis, neuromuscular scoliosis, and congenital scoliosis. Additionally, the KHEIRON Spinal Fixation System is intended to treat pediatic patients diagnosed with spondylolysis, fracture caused by tumor and/or trauma, pseudarthrosis, and/or failed previous fusion.

    This system is intended to be used with autograft. Pediatric pedicle screw fixation is limited to a posterior approach.

    Device Description

    The KHEIRON® Spinal Fixation System may be used for a variety of conditions that affect the thoracic and lumbar spine. In cases in which the posterior elements are fractured, the pedicle screw offers an excellent means of stabilizing a specific spinal segment. KHEIRON Spinal Fixation System includes screws and connecting components in a wide variety of sizes and shapes, which can be locked in various configurations, each assembly being tailor-made. KHEIRON pedicular screws must be used with Ø 5.5mm and Ø 6mm rods.

    AI/ML Overview

    The KHEIRON® Spinal Fixation System is a medical device and the provided document is a 510(k) summary for its premarket notification to the FDA. This summary focuses on demonstrating substantial equivalence to predicate devices rather than proving the device meets specific performance criteria through a standalone study of its capabilities in a clinical setting.

    Therefore, the requested information regarding acceptance criteria, study details, sample sizes, ground truth establishment, expert qualifications, and MRMC studies is not directly available in the provided text. The document states "No clinical studies were performed."

    However, the document does provide information on non-clinical testing to demonstrate the physical performance and safety of the device:

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

    Since no specific numerical acceptance criteria (e.g., minimum strength values) are given, and only a comparative statement is made regarding performance against predicates, a direct table of acceptance criteria and the reported device performance as typically expected for an AI/diagnostic device is not applicable here.

    Instead, the non-clinical test summary states:

    Acceptance Criteria CategoryReported Device Performance
    Strength (Mechanical)"The KHEIRON Spinal Fixation System has greater or equivalent strength values compared to other devices cleared for use in the thoracolumbosacral spine."

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

    • Test Set Sample Size: Not specified as clinical studies were not performed. For non-clinical tests (mechanical tests), the sample sizes for the devices tested were not provided.
    • Data Provenance: Not applicable as no clinical data was used. Mechanical testing is typically done in a laboratory setting. No country of origin for the mechanical test data is mentioned.

    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, as no clinical studies requiring expert consensus for ground truth were performed.

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

    • Not applicable, as no clinical studies requiring ground truth adjudication were performed.

    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:

    • No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. The document explicitly states, "No clinical studies were performed." This device is a mechanical spinal fixation system, not an AI or diagnostic tool that would typically involve human "readers."

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

    • Not applicable. This device is a mechanical implant, not an algorithm.

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

    • For the non-clinical mechanical tests, the "ground truth" would be the engineering standards (e.g., ASTM F1717 and ASTM F1798) and the performance characteristics of the predicate devices. The device's strength was directly measured against these established benchmarks.

    8. The sample size for the training set:

    • Not applicable, as this is a mechanical spinal fixation system and not an AI/machine learning device that requires a training set.

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

    • Not applicable, as this is a mechanical spinal fixation system and not an AI/machine learning device.

    Summary of Non-Clinical Testing:

    The KHEIRON® Spinal Fixation System underwent the following non-clinical mechanical tests:

    • Static and dynamic compression bending (according to ASTM F1717)
    • Static torsion (according to ASTM F1717)
    • Torsional and axial gripping capacity (according to ASTM F1798)

    The results of these evaluations indicated that the KHEIRON Spinal Fixation System is "substantially equivalent to legally marketed predicate devices" and specifically noted that its "strength values" were "greater or equivalent" compared to other cleared devices for thoracolumbosacral spine use.

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    K Number
    K192121
    Date Cleared
    2019-10-29

    (84 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    Reference Devices :

    K940631 / K950099, K950697, K954696

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

    The Black Diamond Pedicle Screw System, with or without MIS instrumentation, 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 thoracic, lumbar, and sacral spine: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, deformities or curvatures (i.e. scoliosis, kyphosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.

    When used for posterior, non-cervical, pedicle screw fixation in pediatric patients, the Black Diamond Pedicle Screw System implants are indicated as an adjunct to treat progressive spinal deformities (i.e., scoliosis, kyphosis, or lordosis) including idiopathic scoliosis, neuromuscular scoliosis, and congenital scoliosis. Additionally, the Black Diamond Pedicle Screw System is intent patients diagnosed with: spondylolisthesis/spondylolysis, fracture caused by tumor and/or trauma, pseudarthrosis, and/or failed previous fusion. This system is intended to be used with autograft and/or allograft. Pediatic pedicle screw fixation is limited to a posterior approach.

    Device Description

    The Black Diamond Pedicle Screw System is a top loading, multiple component, posterior spinal fixation system which consists of pedicle screws, rods, and cross links. All the components are available in a variety of sizes to match more closely the patient's anatomy

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device called the "Black Diamond Pedicle Screw System." This document focuses on demonstrating substantial equivalence to previously marketed predicate devices, primarily through non-clinical mechanical testing, rather than a clinical study involving human patients or complex AI algorithms. Therefore, much of the information requested about acceptance criteria for AI/ML performance, sample sizes for test sets, expert adjudication, MRMC studies, and ground truth establishment is not applicable to this specific submission.

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The "acceptance criteria" presented in this submission are not expressed as specific performance metrics and thresholds (e.g., accuracy > X%, AUC > Y%) typical for AI/ML devices. Instead, the acceptance is based on demonstrating substantial equivalence to predicate devices through various comparisons, primarily mechanical testing.

    Acceptance Criteria (Implied by Substantial Equivalence Claim)Reported Device Performance (Summary)
    Similar intended use"similar intended uses"
    Same materials"fabricated from the same material as the predicate devices"
    Similar design features/functions"share similar basic design features and functions"
    Dimensionally similar"dimensionally similar to cited predicate devices"
    Sterilization method (non-sterile)"supplied non-sterile and cited predicate devices are non-sterile"
    Non-inferior mechanical performance"Showed as good or better performance to the cited predicate devices under the same test conditions."

    2. Sample Size Used for the Test Set and Data Provenance:

    • Test Set Sample Size: Not applicable in the context of human data or image data for AI/ML. The "test set" here refers to the Black Diamond Pedicle Screw System components themselves undergoing non-clinical mechanical testing. The specific number of physical components tested is not detailed, but standard mechanical testing involves multiple samples to ensure statistical validity.
    • Data Provenance: Not applicable in the context of human data. The "data" comes from mechanical testing of the device components.

    3. Number of Experts Used to Establish Ground Truth and Qualifications:

    Not applicable. Ground truth for mechanical testing is established by engineering standards and measurements, not human expert interpretation.

    4. Adjudication Method:

    Not applicable.

    5. MRMC Comparative Effectiveness Study:

    Not applicable. No clinical studies involving human readers or AI assistance were performed.

    6. Standalone Performance Study:

    Not applicable. This is a physical medical device, not an AI algorithm. The performance evaluation is based on mechanical testing of the device itself.

    7. Type of Ground Truth Used:

    Ground truth for this submission is based on engineering standards and direct physical measurements derived from non-clinical mechanical testing (e.g., static and dynamic compression per ASTM F1717, static torsion per ASTM F1717).

    8. Sample Size for the Training Set:

    Not applicable. This device is not an AI/ML model and does not have a "training set" in that context.

    9. How the Ground Truth for the Training Set Was Established:

    Not applicable.

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    K Number
    K150294
    Date Cleared
    2015-06-05

    (119 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DPZ Pedicular Fixation 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 thoracic, lumbar and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, deformities or curvatures (i.e., scoliosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.

    The DPZ Pedicular Fixation System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e., fracture or dislocation); spinal stenosis, deformities or curvatures (i.e., scoliosis, and/or lordosis), tumor, pseudarthrosis and failed previous fusion.

    Device Description

    The DPZ Pedicular Fixation System is a top loading, multiple component, posterior spinal fixation system which consists of pedicle screws, rods and cross links. All of the components are available in a variety of sizes to more closely match the patient's anatomy.

    AI/ML Overview

    The provided text describes the DPZ Pedicular Fixation System, its intended use, and the non-clinical tests conducted to demonstrate its equivalence to predicate devices. However, it explicitly states: "No clinical studies were performed."

    Therefore, I cannot provide information on acceptance criteria based on human performance or studies involving human readers/experts, as no such clinical data is presented in this document.

    Here's the information that can be extracted from the provided text regarding the device's acceptance criteria and the study that proves it meets them:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Test Standard)Reported Device Performance (Result Summary)
    Static compression per ASTM F1717"The results of these evaluations indicate that the DPZ Pedicular Fixation System is equivalent to predicate devices."
    Dynamic compression per ASTM F1717"The results of these evaluations indicate that the DPZ Pedicular Fixation System is equivalent to predicate devices."
    Static torsion per ASTM F1717"The results of these evaluations indicate that the DPZ Pedicular Fixation System is equivalent to predicate devices."

    2. Sample size used for the test set and the data provenance:

    • Sample Size: Not specified for the non-clinical tests. The document only mentions "The following analyses were conducted."
    • Data Provenance: Not explicitly stated, but it refers to "non-clinical tests" which typically involve laboratory or bench testing of the device hardware.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. The "ground truth" for non-clinical mechanical testing is based on the specifications within the ASTM F1717 standard and the measured performance of the device compared to predicate devices. Human experts are not involved in establishing this ground truth for a mechanical test.

    4. Adjudication method for the test set:

    • Not applicable, as this refers to human reader review and consensus, which was not performed.

    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:

    • No MRMC study was done, as "No clinical studies were performed."

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

    • Not applicable. This is a medical device (pedicle fixation system), not an algorithm or AI. The standalone performance refers to the device's mechanical integrity under specified ASTM standards.

    7. The type of ground truth used:

    • The ground truth for the non-clinical tests was based on the performance requirements and methodologies outlined in the ASTM F1717 standard for spinal implant constructs. The device's performance was then compared to that of predicate devices to establish substantial equivalence.

    8. The sample size for the training set:

    • Not applicable. This is a non-AI/algorithm medical device. "Training set" refers to data used to train an AI model.

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

    • Not applicable for the same reason as above.
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    K Number
    K143683
    Manufacturer
    Date Cleared
    2015-05-22

    (149 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    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.

    Device Description

    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.

    AI/ML Overview

    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 TypeAcceptance CriteriaReported Device Performance
    ASTM F1717 (Vertebrectomy Model)
    Static Compression BendingNot explicitly stated (comparison to predicates)Results were "equal or higher than the predicate systems"
    Static TorsionNot explicitly stated (comparison to predicates)Results were "equal or higher than the predicate systems"
    Dynamic Compression BendingNot explicitly stated (comparison to predicates)Results were "equal or higher than the predicate systems"
    ASTM F1798 (Interconnection Mechanisms)
    Static Axial Gripping CapacityNot explicitly stated (comparison to predicates)Results were "equal or higher than the predicate systems"
    Axial Torque Gripping CapacityNot explicitly stated (comparison to predicates)Results were "equal or higher than the predicate systems"
    Static Flexion-ExtensionNot explicitly stated (comparison to predicates)Results were "equal or higher than the predicate systems"
    Dynamic Flexion-ExtensionNot 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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    K Number
    K150417
    Manufacturer
    Date Cleared
    2015-05-19

    (90 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    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.

    Device Description

    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

    AI/ML Overview

    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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    K Number
    K140678
    Date Cleared
    2014-06-19

    (93 days)

    Product Code
    Regulation Number
    888.3070
    Reference & Predicate Devices
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The CosmoLock Pedicle Screw 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 thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.

    The CosmoLock Pedicle Screw System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; deformities or curvatures (i.e. scoliosis, and/or lordosis), tumor; pseudoarthrosis; and failed previous fusion.

    Device Description

    The CosmoLock Pedicle Screw System is a top loading, multiple component, posterior spinal fixation system which consists of pedicle screws, rods and cross links. All of the components are available in a variety of sizes to match more closely the patient's anatomy.

    Materials:

    Ti-6Al-4V per ASTM F136 CoCr per ASTM F1537

    AI/ML Overview

    This document is a 510(k) Summary for the CosmoLock Pedicle Screw System. It describes the device and its intended use and claims substantial equivalence to predicate devices. However, it does not contain the detailed information needed to answer many of your questions, as it explicitly states that no clinical studies were performed.

    Here's an analysis based on the provided text:

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

    Acceptance Criteria (Test)Reported Device Performance
    Static compression per ASTM F1717Equivalent to predicate devices (implied: met criteria)
    Dynamic compression per ASTM F1717Equivalent to predicate devices (implied: met criteria)
    Static torsion per ASTM F1717Equivalent to predicate devices (implied: met criteria)

    2. Sample sized 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 in the document. The studies mentioned are non-clinical (mechanical tests), and details about sample sizes for these tests are not specified.

    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 applicable/provided. No clinical studies were performed, and therefore no ground truth established by experts is relevant to the data presented.

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

    This information is not applicable/provided. No clinical studies were performed.

    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

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This document states, "No clinical studies were performed."

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

    This information is not applicable. The device is a mechanical pedicle screw system, not an AI or algorithm-based device. No standalone performance study in this context was performed.

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

    The ground truth for the non-clinical tests would be the established mechanical testing standards (ASTM F1717) and the performance of the predicate devices. There is no biological or expert-defined "ground truth" in the typical medical imaging/diagnosis sense, as this is a mechanical implant.

    8. The sample size for the training set

    This information is not applicable/provided. No clinical studies were performed, and there is no mention of an algorithm or AI requiring a training set.

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

    This information is not applicable/provided. No training set or associated ground truth was established, as no clinical studies or AI development are described. The focus is on demonstrating mechanical equivalence to predicate devices.

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    K Number
    K071377
    Device Name
    POLARIS BE RODS
    Manufacturer
    Date Cleared
    2007-08-06

    (81 days)

    Product Code
    Regulation Number
    888.3050
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K940631, K950099

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

    The SYNERGY Spinal System implants are intended to be used as a temporary construct that assists normal healing and are not intended to replace normal body structures. They are intended to stabilize the spinal operative site during fusion procedures and should be removed after fusion.

    The implants are attached to the spine posteriorly by means of hooks and/or screws joined with rods and anteriorly by means of vertebral screws joined with rods.

    As a pedicle screw system the SYNERGY Spinal System is intended only for patients: (a) having severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral joint; (b) who are receiving fusions using autogenous bone graft only; (c) who are having the screws fixed or attached to the lumbar and sacral spine; and (d) who are having the device removed after the development of a solid fusion mass. The levels of screw fixation are L3 to S1/Ilium.

    In addition, the pedicle screw system may also be used to provide immobilization and stabilization 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 spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis).

    As a posterior, non-pedicle, screw and hook system, and an anterolateral, intervertebral body screw system, the specific indications for the SYNERGY Spinal System are:

    1. Degenerative Disc Disease (as defined by chronic back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
    2. Idiopathic scoliosis.
    3. Kyphotic deformities of the spine.
    4. Paralytic scoliosis and/or pelvic obliquity.
    5. Lordotic deformities of the spine.
    6. Neuromuscular scoliosis associated with pelvic obliquity.
    7. Vertebral fracture or dislocation.
    8. Tumors.
    9. Spondylolisthesis.
    10. Stenosis.
    11. Pseudarthrosis.
    12. Unsuccessful previous attempts at spinal fusion.

    For posterior, non-pedicle, screw use, the SYNERGY screws and lateral connectors are intended for sacral/iliac attachment only, and the SYNERGY hooks and transverse connectors are intended for posterior thoracic and/or lumbar use only. As a whole, the levels of use are T1 to the Sacrum/Ilium.

    The Bullet End Rods are intended for use with the Jackson Intrasacral Fixation Technique.

    The Adjustable Length Rod is intended for in situ adjustment after placement of the hooks or screws during spinal fusion surgery.

    For anterior use, the recommended levels of attachment are: T10 to L3 for the double rod constructs and T5 to L5 for the single rod constructs. The 4.75 mm diameter rod system can be used in single and double rod constructs while the 6.35 mm diameter rod system is to only be used in single rod constructs. In all cases, instrumentation must be at least 1 cm from any major vessel.

    Device Description

    The Polaris™ BE Rods are manufactured from CP titanium or stainless steel in a diameter of 6.35mm. Two styles of rods are available, double bullet-ended and single bullet-ended where the opposite end is blunt like standard rods. This tip design facilitates the use of an intrasacral surgical technique (Jackson Intrasacral Fixation Technique). Lengths vary from 6 to 60cm.

    AI/ML Overview

    This submission is for Polaris™ BE Rods, which are spinal rods made from CP titanium or stainless steel, designed for use in spinal fusion procedures. The submission states that "No clinical testing is necessary for a determination of substantial equivalence." Therefore, there is no study that proves the device meets acceptance criteria.

    The following information is what can be extracted from the provided text based on your request, even though the core request regarding acceptance criteria and a proving study is not met by the document.

    1. Table of Acceptance Criteria and Reported Device Performance

    Not applicable. The submission explicitly states "No clinical testing is necessary for a determination of substantial equivalence." The device is deemed substantially equivalent based on similarities in materials, design, sizing, and indications to predicate devices. There are no explicitly defined acceptance criteria or performance metrics reported from a study within this document.

    2. Sample Size Used for the Test Set and Data Provenance

    Not applicable. No dedicated test set was used for a study proving acceptance criteria. A paper containing retrospective outcome data for intrasacral rod fixation is mentioned as provided, but details about the sample size, country of origin, or how it relates to proving acceptance criteria for this specific device are not given. This paper is presented as supplementary information rather than a primary study demonstrating performance against acceptance criteria for the Polaris™ BE Rods.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts

    Not applicable. No ground truth establishment by experts for a test set is described, as no such study was conducted for this device's substantial equivalence determination.

    4. Adjudication Method for the Test Set

    Not applicable. No adjudication method is mentioned as no test set was used for a study proving acceptance criteria for this device.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs Without AI Assistance

    Not applicable. This device is a physical spinal rod, not an AI-assisted diagnostic or therapeutic tool. Therefore, an MRMC comparative effectiveness study with or without AI assistance is irrelevant and not mentioned.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

    Not applicable. This device is a physical spinal rod, not an algorithm.

    7. The Type of Ground Truth Used

    Not applicable. No ground truth type is specified, as no study requiring ground truth establishment was conducted for this device. The basis for approval is substantial equivalence to predicate devices, focusing on materials, design, sizing, and indications.

    8. The Sample Size for the Training Set

    Not applicable. There is no training set mentioned, as this device does not involve machine learning or AI.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. As there is no training set, there is no mention of how ground truth for it was established.

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    K Number
    K982914
    Manufacturer
    Date Cleared
    1998-10-02

    (44 days)

    Product Code
    Regulation Number
    888.3070
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    When used as a pedicle screw fixation system, Aesculap's Spine System® Evolution is intended to provide immobilization and stabilization 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 spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis).

    It is also intended for the treatment of severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra in skelatally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine with removal of the implants after the attainment of a solid fusion. Levels of pedicle screw fixation for this indication are from L3-S1.

    When used as a non-pedicle screw system, Aesculap's Spine System® Evolution is indicated for use in patients with degenerative disc disease (defined as back pain of discongenic origin with degeneration of the disc confirmed by history and radiographic studies), kyphosis, spondylolisthesis, neurological scoliosis, spine tumors and fractures. It is intended for posterior fixation from levels T1 through S1.

    Device Description

    Spine System® Evolution is a multiple component system comprised of a variety of single use devices that allow the surgeon to build a spinal implant construct in order to stabilize the thoracic and lumbar vertebrae and promote spinal fusion. The additional components presented in this submission are pedicle, laminar, thoracic and counter hooks. The spinal implants are manufactured from titanium alloy (Ti6Al4V) in accordance to ISO 5832/III. The specialized instrumentation used to implant and explant the Spine System® Evolution implants are made from surgical grade stainless steel in accordance to ISO 7153/1.

    AI/ML Overview

    The provided document is a 510(k) summary for the Aesculap Spine System® Evolution Additional Components, submitted in 1998. It primarily focuses on demonstrating substantial equivalence to pre-existing spinal fixation systems rather than proving device performance against specific acceptance criteria through a clinical study or even extensive standalone performance testing as would be expected for an AI/ML device.

    Therefore, many of the requested elements for an AI/ML device's acceptance criteria and study proving performance are not applicable or not present in this type of regulatory submission for a medical device from that era.

    Here's an attempt to answer based on the provided document, highlighting what is (and isn't) present:


    Acceptance Criteria and Study to Prove Device Performance (Aesculap Spine System® Evolution Additional Components)

    This submission demonstrates substantial equivalence of the Aesculap Spine System® Evolution Additional Components to previously marketed spinal implant systems. The "performance data" presented is primarily mechanical testing, typical for hardware medical devices, rather than a study proving performance against acceptance criteria as might be expected for an AI/ML device.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Established through Predicate Device Equivalence)Reported Device Performance (from mechanical testing)
    Material Composition: Titanium alloy (Ti6Al4V) in accordance with ISO 5832/III.The implants "are manufactured from titanium alloy (Ti6Al4V) in accordance to ISO 5832/III."
    Mechanical Performance: Performance equivalent to predicate devices when subjected to spinal implant construct testing.Subjected to mechanical testing according to ASTM Standard F 1717-96 (Static and Fatigue Test Methods for Spinal Implant Constructs in a Corpectomy Model). (Specific numerical results are not provided in this summary, but the implication is that it met the expected performance for such tests).
    Intended Use: Immobilization and stabilization of spinal segments as an adjunct to fusion for specific conditions (degenerative spondylolisthesis, fracture, scoliosis, etc.). Also, for severe spondylolisthesis (grades 3 and 4) of L5-S1 and as a non-pedicle screw system for degenerative disc disease, kyphosis, etc.The device is intended for these uses. The substantial equivalence argument implies it performs adequately for these indications, similar to predicate devices.
    Design and Function: Substantially equivalent in design and function to predicate devices.Aesculap believes the components are "substantially equivalent in design, material composition, function and intended use" to listed predicate devices.

    Note: For a traditional hardware device like this, "acceptance criteria" are often met by demonstrating adherence to recognized standards (like ISO for materials, or ASTM for mechanical testing) and by showing substantial equivalence to devices already legally on the market that have demonstrated safe and effective performance. Specific quantitative performance metrics for clinical outcomes against predefined thresholds are not typically part of a 510(k) summary for such devices.

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not applicable in the context of an AI/ML device's test set. For mechanical testing, the "sample size" would refer to the number of components or constructs tested in a lab setting. This information (specific number of samples tested for ASTM F 1717-96) is not provided in the summary.
    • Data Provenance: Not applicable in the context of clinical data provenance for an AI/ML device. The "performance data" refers to in vitro mechanical testing.

    3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts

    Not applicable. This device is a physical spinal implant system, not a diagnostic AI/ML device requiring expert-established ground truth for a test set.

    4. Adjudication Method for the Test Set

    Not applicable. No expert adjudication process is described for this type of mechanical device.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. An MRMC study is relevant for AI/ML diagnostic tools that impact human reader performance. This is a spinal implant, so such a study was not performed or described.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    Not applicable. This device is a physical implant, not an algorithm. The "standalone performance" is related to its mechanical integrity, which was assessed via in vitro ASTM F 1717-96 testing. The results of this testing are not detailed in the summary, simply that it was performed.

    7. Type of Ground Truth Used

    Not applicable in the context of typical AI/ML ground truth.
    For this device, "ground truth" would be established by:

    • Adherence to material standards (ISO 5832/III).
    • Results of mechanical testing (ASTM F 1717-96) demonstrating structural integrity and fatigue life, often compared against specified limits or predicate device performance.
    • The established safety and effectiveness track record of the predicate devices to which it claims substantial equivalence.

    8. Sample Size for the Training Set

    Not applicable. This is a physical device, not an AI/ML algorithm requiring a training set.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. As above, no training set for an AI/ML algorithm.

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