The TriFix Spinal System is indicated for degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies). Levels of fixation are for the thoracic, lumbar, and sacral spine.

The Tri-Fix Spinal System is a pedicle screw system 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 neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudoarthrosis).

The posterior Tri-Fix Spinal System is also indicated for pedicle screw fixation for severe spondylolithesis (grades 3 and 4) at L5-S1, in skeletally mature patients, when autogenous bone graft is used, when affixed to the posterior lumbosacral spine, and intended to be removed after solid fusion is attained. Levels of fixation are from L3-S1.

The posterior Tri-Fix System, when not used with pedicle screws is indicated for hook, wire, and/or sacral screw fixation from T1 to the ilium sacrum. The non-pedicle screw indications are spondylolithesis, degenerative disc disease, (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), deformities (scoliosis, lordosis and kyphosis), tumor, fracture, and previous failed fusion surgery.

Device Description

The TrFix Washerless Plate system is intended to be used for posterior lumbar fusion procedures. The system is manufactured from titanium which complies with ASTM F136. The components, which are included as part of the system, include screws, rods, plates, and accessory connection components.

AI/ML Overview

The provided text describes a 510(k) summary for the Tri-Fix Washerless Plate system. This is a medical device, and the submission focuses on demonstrating substantial equivalence to a previously cleared device, not on clinical performance metrics like sensitivity, specificity, or reader studies. Therefore, many of the requested categories (such as experts, adjudication, effect size, standalone performance, ground truth types, and training set details) are not applicable to this type of submission.

Here's an analysis based on the information provided:

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

Acceptance Criteria	Reported Device Performance
Equivalence to previously cleared components	Biomechanical testing according to ASTM F1717 demonstrated that the new component (nut) is substantially equivalent to previously cleared components of the TriFix system.
	Both static and fatigue compression tests were completed.

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

The study was a biomechanical test, not a clinical study involving human patients. The "sample size" refers to the number of constructs tested.

Test Set Sample Size: Not explicitly stated in terms of a specific number of constructs, but implied as sufficient to conduct "both static and fatigue compression tests."
Data Provenance: Not applicable in the sense of country of origin for patient data, as this was a biomechanical engineering test. It was a non-clinical, in-vitro study.

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

Not applicable. This was a biomechanical engineering test, not a clinical study requiring expert ground truth for diagnostic accuracy. The "ground truth" was the physical performance of the device under stress, measured against engineering standards.

4. Adjudication method for the test set

Not applicable. This was a biomechanical test with objective physical measurements, not a test requiring human adjudication of results.

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 device is a surgical implant, not an AI-powered diagnostic tool. No MRMC study was conducted.

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

Not applicable. This device is a physical surgical implant, not an algorithm.

7. The type of ground truth used

The ground truth for this non-clinical study was the biomechanical performance of the device components when tested against established industry standards (ASTM F1717) for static and fatigue compression.

8. The sample size for the training set

Not applicable. As a biomechanical engineering study to demonstrate substantial equivalence, there is no "training set" in the context of machine learning or AI.

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

Not applicable. There was no training set for this biomechanical engineering study.

Summary

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013403
page 1 of 3

Section 7 - 510(k) Summary of Safety and Effectiveness

7.1Statement	This summary of 510(k) safety and effectiveness information is being submittedin accordance with the requirements of SMDA 1990 and CFR 807.92
--------------------------------	---------------------------------------------------------------------------------------------------------------------------------------------------

7.2	Endius, Inc.
Submitter	23 West Bacon Street
	Plainville, MA 02762

7.3	Susan Finneran
Company	Director RA
Contact	508-643-0983 Ext. 114

7.4		Proprietary Name:
Device		Tri-Fix Spinal Fixation System
Name		Common Name:
		Pedicle Screw System , Non-pedicle spinal fixation system
		Classification Name:
		Spinal Pedicle Screw (MNI), Spinal Interlaminal fixation orthosis (KWP),
		Spondylolithesis Spinal Fixation Device System (MNH)

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Image /page/1/Picture/0 description: The image shows handwritten text on a white background. The text at the top reads "K01340 3", with the numbers and letters slightly uneven. Below this, the phrase "page 2 of 3" is written in a similar handwriting style, indicating this is page 2 of a 3-page document.

The TrFix Washerless Plate system is intended to be used for posterior lumbar 7.6 fusion procedures. The system is manufactured from titanium which complies Device with ASTM F136. The components, which are included as part of the system, Description include screws, rods, plates, and accessory connection components.

7.7

Device Indications and Intended Use

The posterior Tri-Fix System, when not used with pedicle screws is indicated for hook, wire, and /or sacral screw fixation from T1 to the ilium sacrum. The nonnook, ware, andications are spondylolithesis, degenerative disc disease, (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), deformities (scoliosis, lordosis and kyphosis), tumor, fracture, and previous failed fusion surgery.

7.8 Substantial Equivalence

The Washerless Plate with the new nut design is substantially equivalent to the Washerless Plate that was originally cleared via K010903.

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(01346) 1/3/3

7.10 Summary of Non-Clinical Tests

Biomechanical testing according to ASTM F1717 was completed on Washerless Plate constructs with the new nut to demonstrate equivalence to previously cleared components of the TriFix system. Corpectomy constructs were fabricated using Washerless plates (previously cleared) with the new nut (the subject of this 510k) and tested according to ASTM F1717.

Both static and fatigue compression tests were completed and the results demonstrated that the new component (nut) is substantially equivalent to previously cleared components of the TriFix system.

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Image /page/3/Picture/1 description: The image is a black and white logo for the Department of Health and Human Services - USA. The logo features a stylized image of an eagle or bird with three curved lines representing its wings or body. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird image. The text is in all capital letters and is evenly spaced around the circle.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV 1 4 2001

Ms. Susan Finneran Director Regulatory Affairs/ Clinical Sciences Endius, Inc. 23 West Bacon Street Plainville, Massachusetts 02762

Re: K013403

Trade Name: Tri-Fix Washerless Plate System Regulatory Class: Class III Regulatory Number: 21 CFR 888.3070, 21 CFR 888.3050 Regulation Name: Pedicle Screw Spinal System, Spinal Interlaminal Fixation Orthosis Product Code: MNI, MNH, KWP Dated: October 12, 2001 Received: October 13, 2001

Dear Ms. Finneran:

We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.

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Page 2 - Ms. Susan Finneran

This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed nouticate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, (301) 591-1059. Tradition f Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or at (301) 443-6597, or at its Internet address "http://www.fda.gov/cdrh/dsmamain.html".

Sincerely yours,
Mark N Wilkerson

elia M. Witten, Ph.D., M.D. Director Division of General Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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NOV 1 4 2001 510(k) Number (if known): ↑(ひとくろくら

K013403

Device Name: Tri-Fix Washerless Plate System (Stainless Steel and Titanium)

Indications for Use:

The TriFix Spinal System is indicated for degenerative disc disease (defined as discogenic back The Trit in Spinal Bj Scent to adisc confirmed by history and radiographic studies). Levels of fixation are for the thoracic, lumbar, and sacral spine.

The Tri-Fix Spinal System is a pedicle screw system intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the submitsmon 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 (pseudoarthrosis).

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurence of CDRH, Office of Device Evaluation (ODE)

(Posted July 1, 1998)

Optional Format 3-10-98)

for Mark n Millerson

(Division Sign-Off)
Division of General, Restorative
and Neurological Devices

510(k) Number K013403

004

Regulation Number and Section

§ 888.3070 Thoracolumbosacral pedicle screw system.

(a)
Identification. (1) Rigid pedicle screw systems are comprised of multiple components, made from a variety of materials that allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Such a spinal implant assembly consists of a combination of screws, longitudinal members (e.g., plates, rods including dual diameter rods, plate/rod combinations), transverse or cross connectors, and interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors).(2) Semi-rigid systems are defined as systems that contain one or more of the following features (including but not limited to): Non-uniform longitudinal elements, or features that allow more motion or flexibility compared to rigid systems.
(b)
Classification. (1) Class II (special controls), when 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: 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 (pseudarthrosis). These pedicle screw spinal systems must comply with the following special controls:(i) Compliance with material standards;
(ii) Compliance with mechanical testing standards;
(iii) Compliance with biocompatibility standards; and
(iv) Labeling that contains these two statements in addition to other appropriate labeling information:
“Warning: The safety and effectiveness of pedicle screw spinal systems have been established only for spinal conditions with significant mechanical instability or deformity requiring fusion with instrumentation. These conditions are significant mechanical instability or deformity of the thoracic, lumbar, and sacral spine secondary to 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 (pseudarthrosis). The safety and effectiveness of these devices for any other conditions are unknown.”
“Precaution: The implantation of pedicle screw spinal systems should be performed only by experienced spinal surgeons with specific training in the use of this pedicle screw spinal system because this is a technically demanding procedure presenting a risk of serious injury to the patient.”
(2) Class II (special controls), when a rigid pedicle screw system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion in the treatment of degenerative disc disease and spondylolisthesis other than either severe spondylolisthesis (grades 3 and 4) at L5-S1 or degenerative spondylolisthesis with objective evidence of neurologic impairment. These pedicle screw systems must comply with the following special controls:
(i) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use.
(ii) Non-clinical performance testing must demonstrate the mechanical function and durability of the implant.
(iii) Device components must be demonstrated to be biocompatible.
(iv) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments.
(v) Labeling must include the following:
(A) A clear description of the technological features of the device including identification of device materials and the principles of device operation;
(B) Intended use and indications for use, including levels of fixation;
(C) Identification of magnetic resonance (MR) compatibility status;
(D) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user; and
(E) Detailed instructions of each surgical step, including device removal.
(3) Class II (special controls), when a semi-rigid system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion for any indication. In addition to complying with the special controls in paragraphs (b)(2)(i) through (v) of this section, these pedicle screw systems must comply with the following special controls:
(i) Demonstration that clinical performance characteristics of the device support the intended use of the product, including assessment of fusion compared to a clinically acceptable fusion rate.
(ii) Semi-rigid systems marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with the special controls in paragraphs (b)(2)(i) through (v) and paragraph (b)(3)(i) of this section.