(25 days)
Custom Spine Issys Pedicle Screw System is used for the following human spine pathologies:
- Deformity
- Trauma & Tumor
When used as pedicle screw fixation system of the non cervical posterior spine (T1-S1) in skeletally mature patients, these systems are indicated for one or more of the following: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis).
In addition these systems are indicated for pedicle screw fixation in skeletally mature patients with severe spondylolisthesis (grade 3 and 4) at the L5-S1 joint having fusion with autogenous bone graft, having the device fixed or attached to the lumbar and sacral spine (with pedicle placement at L3 and below) with removal of the implants after the development of a solid fusion mass
The Custom Spine Issys Pedicle Screw System is comprised of various types and sizes of implantable components that are assembled to create a rigid spinal construct to provide stabilization and promote spinal fusion. It is used as an as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine. The system consists of bone screws, a polyaxial screw head, saddle pin, spinal rods, and blocker screws and is designed to facilitate optimal screw and rod placement. Instruments made and is doble grade stainless steel are also provided which provide for the application and removal of the implant.
The provided document describes a 510(k) premarket notification for the Custom Spine Issys Pedicle Screw System, which demonstrates substantial equivalence to predicate devices rather than undergoing a de novo clinical study with specific acceptance criteria as would be typical for novel devices. Therefore, the information provided does not contain the level of detail requested for a comprehensive study.
However, based on the available information, I can extract and infer the closest equivalent details.
1. Table of Acceptance Criteria and Reported Device Performance
For a 510(k) submission seeking substantial equivalence, the "acceptance criteria" are implied by demonstrating that the new device performs as well as or similarly to the predicate devices. The performance data presented is typically bench testing.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Mechanical performance equivalent to predicate devices (Moss-Miami Spinal System, Universal Spinal System, Optima Spinal System) as per ASTM F1717 | Bench testing in accordance with ASTM F1717 was conducted to demonstrate substantial equivalency to the Moss Miami Spinal System, Universal Spinal System, and Optima Spinal System. The FDA found the device substantially equivalent. |
| Substantial equivalency in design, materials, construction, and intended use as predicate devices. | The Issys Pedicle Screw is the same in intended use and technological characteristics as the predicate devices, raising no new safety and efficacy concerns. |
2. Sample Size Used for the Test Set and Data Provenance
The document refers to "bench testing in accordance with ASTM F1717."
- Sample Size: Not explicitly stated. ASTM F1717 specifies various test methods for spinal implant constructs, and the sample size would typically be determined by the specific sub-tests performed. Without the full test report, the exact number of tested constructs is unknown, but standard practice usually involves a minimum of 3-5 samples per test condition for mechanical testing.
- Data Provenance: The testing was conducted by Custom Spine, likely in a laboratory setting, as "bench testing." This is not human data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This section is not applicable as the study described is a bench test for mechanical equivalence, not a clinical study involving expert interpretation of patient data to establish ground truth.
4. Adjudication Method for the Test Set
This section is not applicable for the same reasons as above. No human adjudication of patient data was required for this type of submission.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. The submission focuses on substantial equivalence through bench testing to established predicate devices, not on comparing human reader performance with or without AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm performance study was not done. This device is a mechanical pedicle screw system, not an AI/software device.
7. The Type of Ground Truth Used
The "ground truth" for demonstrating substantial equivalence was the established performance specifications and characteristics of the predicate devices as defined by the ASTM F1717 standard and by comparing the design, materials, construction, and intended use. The physical and mechanical properties of the Issys Pedicle Screw System were expected to meet or exceed those of the predicate devices.
8. The Sample Size for the Training Set
This section is not applicable. This is a hardware medical device, and there is no "training set" in the context of machine learning or AI.
9. How the Ground Truth for the Training Set Was Established
This section is not applicable as there is no training set for this device.
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December 29, 2004
JAN 1 4 2005
Custom Spine 601 Jefferson Road Suite 208 Parsippany, NJ 07054
510(k) Summary of Safety and Effectiveness Custom Spine Issys Pedicle Screw System December 29, 2004
- Sponsor Name 】. Custom Spine 601 Jefferson Road, Suite 208 Parsippany, NJ 07054 (877) 770-SPINE (7746)
-
- Device Name Proprietary Name: Issys Pedicle Screw
Common Name: Pedicle Screw System
| Classification Name and Reference: | 21CFR 888.3070Pedicle Screw Spinal System21 CFR 888.3050Spinal interlaminal fixation orthosis |
|---|---|
| Device Product Code: | MNI: Orthosis, Spinal, Pedicle FixationMNH: Orthosis, spondylolisthesis spinal fixationKWP: Appliance, fixation, spinal interlaminal |
3. Device Description
The Custom Spine Issys Pedicle Screw System is comprised of various types and sizes of implantable components that are assembled to create a rigid spinal construct to provide stabilization and promote spinal fusion. It is used as an as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine. The system consists of bone screws, a polyaxial screw head, saddle pin, spinal rods, and blocker screws
Page 1 of 2
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and is designed to facilitate optimal screw and rod placement. Instruments made and is doble grade stainless steel are also provided which provide for the application and removal of the implant.
- Intended use:
ndow ace:
Custom Spine Issys Pedicle Screw System is used for the following human spine pathologies:
- . Deformity
- Trauma & Tumor ●
When used as pedicle screw fixation system of the non cervical posterior spine (T1-S1) in skeletally mature patients, these systems are indicated for one or more of the following: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis).
In addition these systems are indicated for pedicle screw fixation in skeletally mature patients with severe spondylolisthesis (grade 3 and 4) at the L5-S1 joint having fusion with autogenous bone graft, having the device fixed or attached to the lumbar and sacral spine (with pedicle placement at L3 and below) with removal of the implants after the development of a solid fusion mass
-
- Identification of Legally Marketed Device
Equivalency of the Custom Spine Pedicle Screw system is based on the predicate device Moss- Miami Spinal System, Universal Spinal System, XIA Spinal System, and Optima Spinal System.
- Identification of Legally Marketed Device
-
- Comparison of Technological Characteristics
The Issys Pedicle Screw is substantially equivalent in design, materials, construction and intended use as those of the predicates identified above. Since the Issys Pedicle Screw is the same in intended use and technological characteristics as the predicate devices, the Issys Pedicle Screw does not raise any new safety and efficacy concerns when compared to these similar legally marketed devices.
- Comparison of Technological Characteristics
-
- Performance Testing
Bench testing in accordance with ASTM F1717 was conducted to demonstrate substantial equivalency to the Moss Miami Spinal System, Universal Spinal System, and Optima Spinal System.
- Performance Testing
Page 2 of 2
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or a stylized human figure with outstretched arms.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JAN 1 4 2005
Custom Spine, Inc. C/o Ms. Debbie Iampietro QRC Associates PO Box 1070 Conway, New Hampshire 03818
Re: K043522
Ro-19322
Trade/Device Name: Custom Spine ISYSS Pedicle Screw System Regulation Number: 21 CFR 888.3050, 888.3070 Regulation Namber 21 Crice Coolinal fixation orthosis, Pedicle screw spinal system Regulatory Class: II Product Code: KWP, MNH, MNI Dated: December 17, 2004 Received: December 21, 2004
Dear Ms. Iampietro:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced we have leviewed your beculor 910(t) prehistantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, enciosure) to tegany marketed products as a concess that have been reclassified in the enability the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require accordance will the provisions of also Posts (PMA). You may, therefore, market the device, subject to approval of a promation upprovial approvial controls provisions of the Act include the general controls provisions of also reens and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be If your device is classified (see above) into i major regulations affecting your device can be found in the Subject to such additions, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FIEASE be advised mar 1271 o tobailed us a device complies with other requirements of the Act or any FDA has made a decemination max your cod by other Federal agencies. You must comply with all the Federal statutes and regulations administration and listing (21 CFR Part 807); labeling (21 ACF S requirements, merading, our novactice requirements as set forth in the quality systems (QS) CFK Fart 8017, good manufacturing practicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 - Ms.Iampietro
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate 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), please contact the Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by ate of Comment notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Jour vole Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
Mark A. Mulkern
Celia 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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Custom Spine Issys Pedicle Screw System December 29, 2004 ંવપુર 822
Indications for Use
510(k) Number (if known):_Unknown
Device Name: Custom Spine Issys Pedicle Screw System
Indications For Use:
Custom Spine Issys Pedicle Screw System is used for the following human spine pathologies:
- Deformity .
- Trauma & Tumor .
When used as pedicle screw fixation system of the non cervical posterior spine (TI-S1) in skeletally mature patients, these systems are indicated for one or more of the following: degenerative spondylolisthesis with objective evidence of of the following: degener, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudarthrosis).
In addition these systems are indicated for pedicle screw fixation in skeletally mature patients with severe spondylolisthesis (grade 3 and 4) at the L5-S1 joint having fusion with autogenous bone graft, having the device fixed or attached to the lumbar and sacral spine (with pedicle placement at L3 and below) with the rainowal of the implants after the development of a solid fusion mass
Prescription Use X
AND/OR
Over-The-Counter Use
(Part 21 CFR 801 Subpart D)
(21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of General, Restorative,
and Neurological Devices
510(k) Number K043522
§ 888.3050 Spinal interlaminal fixation orthosis.
(a)
Identification. A spinal interlaminal fixation orthosis is a device intended to be implanted made of an alloy, such as stainless steel, that consists of various hooks and a posteriorly placed compression or distraction rod. The device is implanted, usually across three adjacent vertebrae, to straighten and immobilize the spine to allow bone grafts to unite and fuse the vertebrae together. The device is used primarily in the treatment of scoliosis (a lateral curvature of the spine), but it also may be used in the treatment of fracture or dislocation of the spine, grades 3 and 4 of spondylolisthesis (a dislocation of the spinal column), and lower back syndrome.(b)
Classification. Class II.