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510(k) Data Aggregation

    K Number
    K142576
    Device Name
    Spinal System
    Manufacturer
    Date Cleared
    2015-02-26

    (167 days)

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

    K984578

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

    When used as a pedicle screw fixation system, the Eisertech Spinal System 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 posterior thoracic, lumbar, and sacral spine:

    1. Degenerative disc disease (as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies)

    2. Degenerative spondylolisthesis with objective evidence of neurologic impairment

      1. Fracture
      1. Dislocation
      1. Scoliosis
      1. Kyphosis
      1. Spinal tumor and/or
      1. Failed previous fusion (pseudoarthrosis)

    The Eisertech Spinal System is also indicated for the treatment of severe spondylolisthesis (Grades 3 and 4) of the LS-S1 vertebral joint in skeletally mature patients receiving fusion by autogenous bone graft, having the device fixed or attached to the lumbar and sacral spine (L3 to sacrum), with removal of the implants after attainment of a solid fusion. When used as an anterolateral non-pedicle screw system in the thoracic and lumbar spine, the Eisertech Spinal System is also intended for the following indications:

    1. Degenerative disc disease (as defined by back pain of discogenc origin with degeneration of the disc confirmed by patient history and radiographic studies)
      1. Spinal stenosis
      1. Spondylolisthesis
      1. Spinal deformities
      1. Fracture
      1. Pseudoarthrosis
      1. Tumor resection and/or
      1. Failed previous fusion
    Device Description

    The Eisertech Spinal System consists of a variety of polyaxial screws, rods, hooks, locking nuts, and rod-to-rod connectors. Implant components can be rigidly locked into a variety of different configurations to suit the individual pathology and anatomical conditions of the patient. All components are made of titanium allow per ASTM F136.

    AI/ML Overview

    This document is a 510(k) premarket notification decision letter from the FDA for the "Spinal System" device by Eisertech, LLC. It outlines the regulatory classification, indications for use, and a summary of non-clinical tests conducted to establish substantial equivalence to a predicate device.

    Here's an analysis of the provided information regarding acceptance criteria and the study that proves the device meets them:

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

    The document does not explicitly present acceptance criteria in a tabular format as performance metrics for a diagnostic or AI device. Instead, it details mechanical testing performed on the Spinal System to demonstrate its safety and effectiveness relative to a legally marketed predicate device.

    Acceptance Criteria (Implied from Mechanical Testing Standards):

    Acceptance Criteria CategorySpecific Test / StandardAcceptance Outcome (Reported Device Performance)
    Static Strength - BendingASTM F1717 - Static Compression BendingDevice passed, demonstrating substantial equivalence to the predicate.
    Static Strength - TorsionASTM F1717 - Static TorsionDevice passed, demonstrating substantial equivalence to the predicate.
    Dynamic Strength - BendingASTM F1717 - Dynamic Compression BendingDevice passed, demonstrating substantial equivalence to the predicate.
    Interconnection Strength - Pull-off(Not a specific ASTM F1717 component, but a custom test for tulip/screw shank)Device passed, demonstrating substantial equivalence to the predicate.
    Interconnection Strength - Static Torsion(Custom test for tulip/screw shank)Device passed, demonstrating substantial equivalence to the predicate.
    Interconnection Strength - Dynamic Torsion(Custom test for tulip/screw shank)Device passed, demonstrating substantial equivalence to the predicate.

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

    The document refers to mechanical testing of a physical device, not a test set of data. Therefore, concepts like sample size for a test set of data, country of origin, or retrospective/prospective data provenance are not applicable in this context. Mechanical testing typically involves a number of physical samples (e.g., individual screws, rods, or assembled constructs) to ensure statistical validity of the results, but the exact number of samples used for each mechanical test is not specified in this summary.

    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 question is not applicable. The "ground truth" for a mechanical implant like the Spinal System is established by engineering standards and physical measurements, not by expert consensus on clinical images or data. The "experts" involved would be mechanical engineers and quality control personnel following established test protocols.

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

    This question is not applicable. Adjudication methods like 2+1 or 3+1 are used for establishing ground truth in clinical studies involving interpretation (e.g., image reading). For mechanical testing, the results are derived from objective measurements against defined pass/fail criteria, not subjective interpretations requiring adjudication.

    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 question is not applicable. An MRMC study is relevant for evaluating the impact of AI on human reader performance, typically in diagnostic imaging. The Spinal System is a physical implant, not an AI diagnostic tool, so such a study would not be performed for this device.

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

    This question is not applicable. "Standalone performance" refers to the performance of an algorithm without human intervention. The Spinal System is a physical medical device, not an algorithm, so this concept does not apply.

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

    The "ground truth" for the mechanical performance of the Spinal System is based on:

    • Established engineering standards: Specifically, ASTM F1717 for static and dynamic testing of spinal implant constructs.
    • Physical measurements and defined tolerances: The device components and assembled constructs must meet specific strength, stiffness, and fatigue resistance criteria as outlined in the relevant ASTM standards or internal design specifications.

    8. The sample size for the training set

    This question is not applicable. "Training set" refers to data used to train an AI model. The Spinal System is a physical medical device, and its performance is evaluated through mechanical testing, not by training an algorithm.

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

    This question is not applicable for the same reason as point 8.

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