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510(k) Data Aggregation

    K Number
    K153386
    Manufacturer
    Date Cleared
    2016-01-25

    (63 days)

    Product Code
    Regulation Number
    888.3075
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K003780, K023675, K991089, K110353

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

    The PERLA® posterior cervico-thoracic fixation system is intended to provide immobilization of spinal segments as an adjunct to following acute and chronic instabilities of the cervical spine (C 1 to C7) and the thoracic spine from TI-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 radios, and degenerative disease of the facets with instability.

    The PERLA® posterior cervico-thoracic fixation 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, the PERLA® posterior cervico-thoracic fixation system may be connected to the ROMEO® Posterior Osteosynthesis System with rod connectors. Transition rods may also be used to connect the PERLA® posterior cervico-thoracic fixation system to the ROMEO® Posterior Osteosynthesis System. Refer to the ROMEO® Posterior Osteosynthesis System package insert for a list of the ROMEO® Posterior Osteosynthesis System indications of use.

    Device Description

    The Spineart Perla® system is a posterior cervico-thoracic fixation system intended to provide stabilization to promote fusion of the cervical spine and the upper thoracic spine. Perla® system consists of a variety of shapes and sizes of rods, hooks, multi-axial screws, set screws, rod connectors and transverse connectors. These connecting components can be rigidly locked to the rod in a variety of configurations to be adapted for the individual case. The Perla® system can also be linked to the cleared Spineart Romeo®2 spinal system (K151695) using the specific Perla® Axial and Parallel Rod to Rod connectors 3.5/5.4mm or the Perla® Transition Rods 3.5/5.4mm which are part of this submission.

    AI/ML Overview

    The provided document is a 510(k) summary for the PERLA® Posterior Cervico-Thoracic Fixation System. It details the device's indications for use, technological characteristics, and performance data to demonstrate substantial equivalence to predicate devices. However, the document does not contain information about the acceptance criteria or a study proving the device meets specific acceptance criteria in the context of an AI/ML device.

    The information provided describes a traditional medical device (implantable fixation system for spinal segments) and its FDA clearance process. It does not involve AI or algorithms, and therefore, the requested information about AI/ML device performance, sample sizes for test/training sets, ground truth establishment, expert adjudication, or MRMC studies is not applicable or present in this document.

    Therefore, the table below will be filled with "Not Applicable" or "Information Not Provided" as the document pertains to a physical medical device and not an AI/ML system.


    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (for AI/ML device)Reported Device Performance (from document, if applicable to AI/ML)
    Not Applicable (no AI/ML device)Not Applicable (no AI/ML device)

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

    • Test Set Sample Size: Information Not Provided (Not applicable to a physical spinal fixation system)
    • Data Provenance: Information Not Provided (Not applicable to a physical spinal fixation system)

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

    • Number of Experts: Information Not Provided (Not applicable to a physical spinal fixation system)
    • Qualifications of Experts: Information Not Provided (Not applicable to a physical spinal fixation system)

    4. Adjudication method for the test set

    • Adjudication Method: Information Not Provided (Not applicable to a physical spinal fixation system)

    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

    • MRMC Study Conducted?: No (Not applicable; this is a physical spinal fixation system, not an AI/ML system for image interpretation or diagnosis by human readers.)
    • Effect Size: Not Applicable

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

    • Standalone Study Conducted?: No (Not applicable; this is a physical spinal fixation system, not an AI/ML algorithm.)

    7. The type of ground truth used

    • Type of Ground Truth: Information Not Provided (Not applicable to a physical spinal fixation system. For this device, "ground truth" would refer to manufacturing specifications, material properties, and mechanical testing results, which are detailed in the document but not in the context of diagnostic "ground truth" for AI.)

    8. The sample size for the training set

    • Training Set Sample Size: Information Not Provided (Not applicable to a physical spinal fixation system)

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

    • Ground Truth Establishment: Information Not Provided (Not applicable to a physical spinal fixation system)

    Summary of Device Performance (from the document, relevant to a physical device):

    The document states that "Published literature and bench testing per ASTM F1717 demonstrate that the PERLA® posterior cervico-thoracic fixation system is substantially equivalent to the predicate devices."

    The following non-clinical tests were conducted:

    • Static Compression Bending, Static Torsion, and Dynamic Compression Bending according to ASTM F1717.
    • Static flexion-extension testing, Static axial gripping, and Static torsion gripping according to ASTM F1798.
    • Axial pullout strength and Torque to failure according to ASTM F543.

    The conclusion is that "Design comparisons and non-clinical performance testing demonstrate that the PERLA® posterior cervico-thoracic fixation system is substantially equivalent to its predicate devices in terms of intended use, material, design, mechanical properties and function."

    These tests and their results are used to establish substantial equivalence for a traditional spinal implant, not to evaluate the performance of an AI/ML algorithm against predefined acceptance criteria for diagnostic accuracy or similar metrics.

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