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Spine CAMP

Medical Metrics, Inc. • Radiology • 10/18/2022

510(k)IEC 62304 Class B
FDA Summary PDF

Device Purpose

Spine CAMP™ is a fully-automated software designed to analyze X-ray images of the lumbar and cervical spine, providing quantitative metrics on spinal morphology, alignment, and motion to support clinical decision-making for adult patients. Its methodology relies on non-adaptive artificial intelligence models, trained using data from the predicate device KIMAX QMA®, to automate image processing tasks, with performance validated through statistical equivalence to this predicate.

Summary

Spine CAMP™ is a fully-automated image processing software device designed to assist medical professionals by analyzing X-ray images of the spine. Its core function is to calculate various spinal parameters, including distances, angles, linear and angular displacements, and combinations thereof, to characterize spinal morphology, alignment, and motion. The system processes sagittal plane radiographs of the lumbar and cervical spine, employing non-adaptive artificial intelligence models, trained on data derived from its predicate device (KIMAX QMA®), to automate vertebral body detection, landmark specification, and registration, which were previously manual operations. The output of Spine CAMP™ includes comprehensive reports, annotated images, and visualizations of intervertebral motion using an image registration method called "stabilization." These outputs are intended to support qualified healthcare practitioners in clinical decision-making for skeletally mature patients (18 years and older). Common clinical applications involve assessing spinal stability, alignment, degeneration, fusion status, motion preservation, and implant performance. The device's performance was validated through non-clinical bench testing, which involved comparing its outputs (vertebral landmark coordinates, image calibration, radiographic metrics) against those of the KIMAX QMA® using the same image datasets; these tests demonstrated strong correlation and statistical equivalence between the two systems.

AI Regulatory Concerns

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Keywords

Spine CAMP™Automated image processingX-ray analysisSpinal metricsLumbar spineCervical spineIntervertebral motionNon-adaptive AIRadiographic assessmentKIMAX QMA®

Device Metadata

Submission Number
K221632
Company
Medical Metrics, Inc.
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. How does the performance of Spine CAMP™'s non-adaptive AI models vary across different X-ray image qualities or patient anatomies not extensively represented in the training dataset derived from KIMAX QMA®?; What are the specific thresholds for statistical equivalence used in the comparison with KIMAX QMA®, and how do these translate to clinical significance for the various measured spinal parameters?; Given that the AI models are non-adaptive, what is the proposed process for updating or retraining these models if new imaging artifacts or spinal pathologies become prevalent, or if the predicate device's methodology evolves?; Can the "stabilization" feature for visualizing intervertebral motion provide quantitative data on the quality of image registration, and how sensitive is it to subtle but clinically relevant instability?; What are the typical processing times for analyzing lumbar versus cervical spine X-rays, and how does the system handle images with significant spinal deformities or surgical implants that might challenge automated detection algorithms?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class B (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score5/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan⚠ Not mentioned in summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(training data, algorithm, dataset, retraining)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials
- Not detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Postmarket cybersecurity monitoring plan not clearly documented in AI-generated device summary.

• Not detected in AI-generated device summary: SBOM, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Spine CAMP - Medical Metrics, Inc. | ESL FDA AI Device Intelligence