K Number
K070631
Device Name
DEVICE MODIFICATION TO RADIUS SPINAL SYSTEM
Manufacturer
Date Cleared
2007-07-13

(128 days)

Product Code
Regulation Number
888.3070
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Radius™ Spinal System is intended for use in the noncervical spine. When used as an anterior/anterolateral and posterior, noncervical pedicle and non-pedicle fixation system, the Radius™ Spinal System is intended to provide additional support during fusion using autograft or allograft in skeletally mature patients in the treatment of the following acute and chronic instabilities or deformities: Degenerative disc disease (DDD) (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); Spondylolisthesis; Trauma (i.e., fracture or dislocation); Spinal stenosis; Curvatures (i.e., scoliosis, kyphosis, and/or lordosis); Tumor; Pseudoarthrosis; and Failed previous fusion. The Radius™ Spinal System can also be linked to the Xia® Titanium Spinal System via the Ø5.5 mm to Ø6.0 mm Radius™ rod-to-rod connector
Device Description
This 510(k) is intended to introduce an extension to the existing Radius™ Spinal System. The proposed line extension includes additional staples, and connectors.
More Information

Not Found

No
The summary describes a spinal fixation system and its components, with no mention of AI or ML capabilities.

Yes

The device is intended to provide additional support during spinal fusion for various acute and chronic instabilities or deformities, which is a therapeutic intervention.

No.
The Radius™ Spinal System is a fixation system intended to provide support during spinal fusion procedures, not to diagnose medical conditions.

No

The device description explicitly states the proposed line extension includes additional staples and connectors, which are hardware components.

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant for stabilizing the spine during fusion procedures. This is a therapeutic device, not a diagnostic one.
  • Device Description: The device is described as a spinal system including staples and connectors, which are physical implants used in surgery.
  • No mention of in vitro testing: There is no indication that this device is used to examine specimens (like blood, tissue, or urine) outside of the body to provide diagnostic information.

IVD devices are used to diagnose diseases or other conditions, including a determination of the state of health, in order to cure, mitigate, treat, or prevent disease or its sequelae. This device's purpose is to provide structural support and aid in spinal fusion, which is a treatment.

N/A

Intended Use / Indications for Use

The Radius™ Spinal System is intended for use in the noncervical spine. When used as an anterior/anterolateral and posterior, noncervical pedicle and non-pedicle fixation system, the Radius™ Spinal System is intended to provide additional support during fusion using autograft or allograft in skeletally mature patients in the treatment of the following acute and chronic instabilities or deformities: Degenerative disc disease (DDD) (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); Spondylolisthesis; Trauma (i.e., fracture or dislocation); Spinal stenosis; Curvatures (i.e., scoliosis, kyphosis, and/or lordosis); Tumor; Pseudoarthrosis; and Failed previous fusion. The Radius™ Spinal System can also be linked to the Xia® Titanium Spinal System via the Ø5.5 mm to Ø6.0 mm Radius™ rod-to-rod connector

Product codes (comma separated list FDA assigned to the subject device)

NKB, KWP, KWQ, MNH, MNI

Device Description

This 510(k) is intended to introduce an extension to the existing Radius™ Spinal System. The proposed line extension includes additional staples, and connectors.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

noncervical spine

Indicated Patient Age Range

skeletally mature patients

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Engineering analysis and testing to demonstrate compliance with FDA's Guidance for Spinal System 510(k)'s May 3, 2004 was completed for the Stryker Spine Radius™ Spinal System, including the subject components.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K062270, K043473, K012870, K031893, K052181, K060631, K020709

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

0

K070631

3

Line Extension to the Radius™ Spinal System

Special 510(k) Premarket Notification

7/13/07

510(k) Summary Line Extension to the Radius Spinal System

Proprietary Name:Radius™ Spinal System
Common Name:Spinal Fixation Appliances
Proposed Regulatory Class:Class III and Class II
Orthosis, Spinal Pedicle Fixation, For Degenerative
Disc Disease
21 CFR 888.3070
Spinal intervertebral body fixation orthosis
21 CFR 888.3060
Spinal interlaminal fixation orthosis
21 CFR 888.3050
Device Product Code:NKB, KWP, KWQ, MNH, MNI
For Information contact:Simona Voic
Regulatory Affairs Project Manager
2 Pearl Court
Allendale, NJ 07401
Telephone: (201) 760-8145
Fax: (201) 760-8345
Email: Simona.Voic@stryker.com
Date Summary Prepared:July 10, 2007

1

K070631

page 2 of 3

Line Extension to the Radius™ Spinal SystemSpecial 510(k) Premarket Notification
Predicate DevicesStryker Spine Radius™ Spinal System, K062270 Stryker Spine Xia® Spinal System, K043473,
K012870, K031893, K052181, K060631. Medtronic Sofamor Danek CD Horizon® Legacy™
System, K020709.
Description of Device ModificationThis 510(k) is intended to introduce an extension to the
existing Radius™ Spinal System. The proposed line
extension includes additional staples, and connectors.
Intended UseThe Radius™ Spinal System is intended for use in the
noncervical spine. When used as an anterior/anterolateral
and posterior, noncervical pedicle and non-pedicle fixation
system, the Radius™ Spinal System is intended to provide
additional support during fusion using autograft or allograft
in skeletally mature patients in the treatment of the
following acute and chronic instabilities or deformities:
Degenerative disc disease (DDD) (defined as back
pain of discogenic origin with degeneration of the
disc confirmed by history and radiographic studies); Spondylolisthesis; Trauma (i.e., fracture or dislocation); Spinal stenosis; Curvatures (i.e., scoliosis, kyphosis, and/or
lordosis); Tumor; Pseudoarthrosis; and Failed previous fusion. The Radius™ Spinal System can also be linked to the Xia®
Titanium Spinal System via the Ø5.5 mm to Ø6.0 mm
Radius™ rod-to-rod connector

2

Image /page/2/Picture/0 description: The image shows a sequence of handwritten alphanumeric characters. The sequence reads 'K070631'. The characters are written in a simple, slightly irregular style, typical of handwriting.

Line Extension to the Radius™ Spinal System

Special 510(k) Premarket Notification

Summary of the Technological Characteristics

Documentation is provided which demonstrates the new components of the Stryker Spine Radius™ Spinal System to be substantially equivalent to the predicate devices in terms of material, design, and indications for use. Engineering analysis and testing to demonstrate compliance with FDA's Guidance for Spinal System 510(k)'s May 3, 2004 was completed for the Stryker Spine Radius™ Spinal System, including the subject components.

3

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image is a seal for the Department of Health & Human Services - USA. The seal is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is an abstract image of what appears to be an eagle.

Public Health Service

JUL 1 9 2007

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Stryker Spine % Ms. Simona Voic Regulatory Affairs Project Manager 2 Pearl Court Allendale, NJ 07401

Re: K070631

Trade/Device Name: Radius™ Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNH, MNI, KWP, KWQ Dated: June 14, 2007 Received: June 15, 2007

Dear Ms. Voic:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate 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) that do not require approval of a premarket approval application (PMA). 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 (PMA), 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 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 FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

4

Page 2 - Ms. Simona Voic

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 reference to premarket 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 Consumer Assistance at toll-free number (800) 638-2041 or (240) 276-3150 or the Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Mark A. Milkerson

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Page 1 of 1

Line Extension to the Radius™ Spinal System

Special 510(k) Premarket Notification

Indications for Use

510(k) Number (if known): K070631

Device Name: Line Extension to the RadiusTM Spinal System

Indications for Use:

The Radius™ Spinal System is intended for use in the noncervical spine. When used as an anterior/anterolateral and posterior, noncervical pedicle and non-pedicle fixation system, the Radius™ Spinal System is intended to provide additional support during fusion using autograft in skeletally mature patients in the treatment of the following acute and chronic instabilities or deformities:

  • Degenerative disc disease (DDD) (defined as back pain of discogenic origin with degeneration of �
    the disc confirmed by history and radiographic studies);

  • Spondylolisthesis;

  • Trauma (i.e., fracture or dislocation);

  • Spinal stenosis;

  • Curvatures (i.e., scoliosis, kyphosis, and/or lordosis); .

  • Tumor; �

  • Pseudoarthrosis; and .

  • Failed previous fusion.

The Radius™ Spinal System can also be linked to the Xia® Titanium Spinal System via the ØS. Ø6.0 mm Radius™ rod-to-rod connector

Prescription Use (Part 21 CFR 801 Subpart D) · AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Mark A. Milliken

Division Sign-C Division of General, Restorative, and Neurological Devices

510(k) Number