Mazor X System / Mazor X Stealth Edition
K251316Mazor Robotics Ltd. · cleared 2025-09-11 · product code OLO · Neurology
Premarket evidence — what FDA accepted
source quote (p.6)
“The Mazor X system combines robotic trajectory guidance with navigated surgical instruments (either guided or free hand navigation) to enable the surgeon to precisely position surgical instruments and/or implants according to predefined planning. With the imaging capabilities of the system, the user can also visualize the implants on the patients CT. Same as the predicate device the modified Mazor X consists of a workstation with dedicated software, the surgical system, navigation camera, accessories, instruments and disposable kits. The modified Mazor X, the subject of this 510(k) application, introduces software and hardware modifications to the Mazor X System cleared in 510(k) K230064. The software incorporates the 2D Automatic Measurements feature which automatically detects key spinopelvic landmarks and produces spinopelvic measurements on AP and LAT X-rays images. The feature utilizes two locked AI algorithms: the Endplate detection algorithm and the Femoral head detection algorithm.”
source quote (p.11)
“2D Automatic Measurements: incorporates a locked machine learning based algorithm that automatically detects anatomical landmarks, used for calculating anatomical measurements, for the automatic pre-op planning capability. The software incorporates the 2D Automatic Measurements feature which automatically detects key spinopelvic landmarks and produces spinopelvic measurements on AP and LAT X-rays images. The feature utilizes two locked AI algorithms: the Endplate detection algorithm and the Femoral head detection algorithm. The software incorporates the Plan Assist feature, which automatically suggests initial pedicle screw positions during spinal surgery planning using locked AI algorithm”
source quote (p.11)
“2D Automatic Measurements: incorporates a locked machine learning based algorithm that automatically detects anatomical landmarks, used for calculating anatomical measurements, for the automatic pre-op planning capability. Plan Assist feature, a locked machine learning based algorithm, enhances the initial screw placement by considering user preferences and clinical constrains, thus providing clinically acceptable initial screw placement.”
source quote (p.14)
“Mazor X system is developed in accordance with the Cybersecurity design controls to ensure Mazor X Cybersecurity and maintain safety and effectiveness, similarly to the currently cleared device.”
Validation studies (2)
Retrospective clinical
n=399 images
endpoints: Single measurement absolute agreement intraclass correlation coefficient (ICC) was used to assess agreement the AI measurement results and the reference standard. The acceptance criterion of the ICC of least 0.75 with a 95% confidence level was achieved for all spinopelvic measurements.
Retrospective clinical
n=25 images
endpoints: The True Positive Rate (TPR) exceeded 80% with 95% confidence, meeting the acceptance criteria.
Reported performance (6 observations)
source quote (p.13)
“Mazor X System mean accuracy <1.5mm”
source quote (p.13)
“Navigation Accuracy mean positional error <2mm and mean trajectory error of 2°.”
source quote (p.13)
“Navigation Accuracy mean positional error <2mm and mean trajectory error of 2°.”
source quote (p.13)
“Mazor X will also provide Facet Decortication depth accuracy within 1.5mm.”
source quote (p.18)
“Single measurement absolute agreement intraclass correlation coefficient (ICC) was used to assess agreement the AI measurement results and the reference standard. The acceptance criterion of the ICC of least 0.75 with a 95% confidence level was achieved for all spinopelvic measurements.”
source quote (p.19)
“The True Positive Rate (TPR) exceeded 80% with 95% confidence, meeting the acceptance criteria.”
Each value carries its own analysis unit and task — never compare or pool across devices. Source: 510(k) summary PDF.
Predicate network
Postmarket — what happened after clearance
- recall_reason_pattern
Software/algorithm-related recall in product code OLO (, initiated 2025-12-10): "Software errors that can result in incorrect surgical instrument positioning during spinal surgery." Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:98199
- recall_reason_pattern
Software/algorithm-related recall in product code OLO (Tornier S.A.S. 161 Rue Lavoisier Montbonnot-Saint-Martin France, initiated 2025-03-05): "Stryker identified an elevated complaint rate related to difficulties using the Blueprint Mixed Reality Guidance Instrumentation system is multifactorial, but in each instance proh" Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:96437
- recall_reason_pattern
Software/algorithm-related recall in product code OLO (Medtronic Navigation, Inc., initiated 2024-08-22): "Due to two software anomalies that can occur within a spine procedure. Two issues are: 1. Navigation Orientation - when lateral orientation radiographic images are taken, informat" Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:95283
- recall_reason_pattern
Software/algorithm-related recall in product code OLO (, initiated 2024-07-17): "Software anomalies which can result in two separate issues: A lagging screen display during a navigated procedure; or the potential for a mismatch between the navigated screw and t" Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:95189
Recall and MAUDE counts are product-code-level (reports aren't reliably attributable to one device); a recall is shown as device-attributed only when the recall record itself lists this clearance number. Signals are descriptive observables with sources — never a judgment that the device is unsafe or drifting. Snapshot 2026-07-08.
Reimbursement — how devices like this got paid
Not yet tracked — no payment pathway indexed for this clearance (the reimbursement corpus is a growing seed set).
Applicable FDA guidance — what the submission is measured against
FDA guidance documents and guiding principles applicable to 510(k) AI/ML devices in the Neurology panel. A curated reference index, not legal or regulatory advice — each item states its own status, and a draft is never binding.
- Final guidance2026-01Clinical Decision Support Software
Clinical decision support · SaMD (general)
New final guidance issued Jan 2026, superseding the Sept 2022 version; narrows the device-CDS scope. Applies to software that informs clinical management.
- Final guidance2026-01General Wellness: Policy for Low Risk Devices
SaMD (general) · Clinical decision support
Revised final (Jan 2026); now addresses noninvasive products estimating physiologic parameters (SpO2, BP, glucose). Reshapes the device / non-device line for AI wellness features.
- Final guidance2025-09Computer Software Assurance for Production and Quality Management System Software
SaMD (general) · Postmarket
Final (Sept 2025). Covers software used in production/QMS (incl. ML development-pipeline tooling), superseding Section 6 of the 2002 GPSV — not device software functions themselves.
- Final guidance2025-06Cybersecurity in Medical Devices: Quality Management System Considerations and Content of Premarket Submissions
Cybersecurity · Software premarket content
Reissued June 2025 (retitled 'Quality Management System', was Sept 2023 'Quality System'); adds coverage of FD&C Act §524B cyber devices.
- Final guidance2024-12Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence-Enabled Device Software Functions
Predetermined Change Control Plan · AI/ML lifecycle · Software premarket content
Final (Dec 2024). Supersedes the April 2023 AI/ML PCCP draft.
- Final guidance2023-10Electronic Submission Template for Medical Device 510(k) Submissions
Software premarket content
eSTAR has been mandatory for 510(k)s since Oct 2023 — operationally unavoidable, though not AI-specific.
- Final guidance2023-08Off-The-Shelf Software Use in Medical Devices
Software premarket content · SaMD (general)
Final (Aug 2023). Applies when a device incorporates off-the-shelf software components (common in ML stacks).
- Final guidance2023-06Content of Premarket Submissions for Device Software Functions
Software premarket content · SaMD (general)
Final (June 2023); replaced the May 2005 'Software Contained in Medical Devices' guidance. Documentation level drives the software content of the submission.
- Final guidance2022-09Policy for Device Software Functions and Mobile Medical Applications
SaMD (general) · Clinical decision support
Current version Sept 2022. Frames which software functions FDA regulates as devices.
- Final guidance2021-10De Novo Classification Process (Evaluation of Automatic Class III Designation)
De Novo pathway
Final (Oct 2021), issued with the De Novo final rule. Most relevant to first-of-a-kind devices without a predicate (DEN-numbered clearances).
- Final guidance2016-12Postmarket Management of Cybersecurity in Medical Devices
Cybersecurity · Postmarket
- Final guidance2002-01General Principles of Software Validation
SaMD (general) · Software premarket content
Still active except Section 6 (superseded Sept 2025 by the Computer Software Assurance final guidance).
- Draft guidance2025-01Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations
AI/ML lifecycle · Software premarket content · Transparency
Draft as of July 2026 (published Jan 2025); finalization is on CDRH's FY2026 agenda but not yet published. Treat as FDA's stated direction, not a binding expectation.
- Draft guidance2024-08Predetermined Change Control Plans for Medical Devices
Predetermined Change Control Plan · Postmarket
Draft (Aug 2024) extending PCCPs beyond AI to all devices under FD&C §515C; not final as of July 2026.
- Guiding principles2024-06Transparency for Machine Learning-Enabled Medical Devices: Guiding Principles
Transparency · AI/ML lifecycle
- Guiding principles2023-10Predetermined Change Control Plans for Machine Learning-Enabled Medical Devices: Guiding Principles
Predetermined Change Control Plan · AI/ML lifecycle
FDA/Health Canada/MHRA joint principles (Oct 2023); companion to the GMLP and Transparency principles.
- Guiding principles2021-10Good Machine Learning Practice for Medical Device Development: Guiding Principles
AI/ML lifecycle · SaMD (general)
FDA/Health Canada/MHRA joint principles (Oct 2021). Foundational, not a binding guidance; IMDRF issued a related GMLP document Jan 2025.
Applicability is derived from the device's FDA advisory panel and pathway — cross-cutting guidances apply to every AI/ML device; panel-specific ones are flagged. Titles, dates, and links verified against fda.gov as of July 2026.