(128 days)
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
This 510(k) is intended to introduce an extension to the existing Radius™ Spinal System. The proposed line extension includes additional staples, and connectors.
This document describes a Special 510(k) Premarket Notification for a line extension to the Radius™ Spinal System, not a software device or an AI model. Therefore, the typical acceptance criteria and study designs associated with AI/ML-driven medical devices (like those related to performance metrics, expert reviews, ground truth, and training/test sets) are not applicable here.
The provided text pertains to a Class III and Class II spinal fixation system, which is a physical implant. The "study" mentioned refers to engineering analysis and testing to demonstrate compliance with FDA guidance for spinal systems, focusing on material, design, and indications for use.
Here's an breakdown of the relevant information provided, structured to show why the requested AI/ML specific details cannot be fulfilled:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Type | Acceptance Criteria Standard | Reported Device Performance | Comments (Why AI/ML criteria are not applicable) |
|---|---|---|---|
| Substantial Equivalence (Core for this submission) | Compliance with FDA's Guidance for Spinal System 510(k)'s May 3, 2004, regarding material, design, and indications for use as compared to predicate devices. | "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." | This is about physical device attributes and intended use, not AI-driven performance metrics like sensitivity, specificity, AUC, etc. |
| Mechanical/Physical Testing | Not explicitly detailed in the summary, but implied by "Engineering analysis and testing." This would typically involve fatigue testing, static testing, torsional rigidity, etc., as per relevant ASTM or ISO standards for spinal implants. | "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." | Specific performance values (e.g., N.m for torsion, cycles for fatigue) are not included in this summary. These are physical characteristics, not AI performance metrics. |
| Material Compatibility | Biocompatibility standards (e.g., ISO 10993). | Not explicitly stated, but implied by "material" aspect of substantial equivalence. The device is a "Spinal Fixation Appliance" likely made of metals (e.g., Titanium as per the linked Xia® Titanium Spinal System). | This pertains to the materials used in the physical device, not an AI model. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not applicable. This is a physical device, and testing involves physical specimens and engineering analyses, not a "test set" of data in the AI/ML sense.
- Data Provenance: Not applicable.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
- Number of Experts: Not applicable. "Ground truth" in this context refers to established engineering principles, regulatory standards, and comparison to legally marketed predicate devices, not expert consensus on medical images or patient data.
- Qualifications of Experts: The experts involved would be engineers, materials scientists, and regulatory affairs professionals specializing in medical device design and spinal implants.
4. Adjudication Method
- Adjudication Method: Not applicable. This concept is relevant for reconciling discrepancies in human annotations or diagnostic interpretations for AI model training or evaluation. For a physical device, compliance is assessed against predefined engineering specifications and regulatory guidance.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
- MRMC Study: No. This type of study is specifically designed to assess the impact of an AI algorithm on human reader performance, typically in diagnostic imaging. It is not relevant for a physical spinal implant.
- Effect Size of AI assistance: Not applicable.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable. There is no algorithm or software being evaluated for standalone performance.
7. The Type of Ground Truth Used
- Type of Ground Truth: For this type of device, the "ground truth" for demonstrating substantial equivalence is:
- Regulatory Standards: Compliance with FDA's Guidance for Spinal System 510(k)'s (May 3, 2004).
- Engineering Principles: Adherence to established mechanical, material, and design specifications.
- Predicate Device Characteristics: Direct comparison of the new components to the material, design, and indications for use of the predicate devices (Stryker Spine Radius™ Spinal System, Stryker Spine Xia® Spinal System, Medtronic Sofamor Danek CD Horizon® Legacy™ System).
8. The Sample Size for the Training Set
- Sample Size: Not applicable. This is a physical device, not an AI model requiring a training data set.
9. How the Ground Truth for the Training Set was Established
- Ground Truth Establishment: Not applicable.
In summary: The provided document describes a regulatory submission for a physical medical device (a line extension to a spinal fixation system). The "acceptance criteria" and "study" refer to engineering analyses and testing to ensure the new components are substantially equivalent to existing predicate devices and comply with FDA regulations for spinal implants. The concepts of AI/ML performance, ground truth, and data sets (training/test) are not relevant to this submission.
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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 |
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| Line Extension to the Radius™ Spinal System | Special 510(k) Premarket Notification |
|---|---|
| Predicate Devices | Stryker 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 Modification | This 510(k) is intended to introduce an extension to theexisting Radius™ Spinal System. The proposed lineextension includes additional staples, and connectors. |
| Intended Use | The Radius™ Spinal System is intended for use in thenoncervical spine. When used as an anterior/anterolateraland posterior, noncervical pedicle and non-pedicle fixationsystem, the Radius™ Spinal System is intended to provideadditional support during fusion using autograft or allograftin skeletally mature patients in the treatment of thefollowing acute and chronic instabilities or deformities:Degenerative disc disease (DDD) (defined as backpain of discogenic origin with degeneration of thedisc confirmed by history and radiographic studies); Spondylolisthesis; Trauma (i.e., fracture or dislocation); Spinal stenosis; Curvatures (i.e., scoliosis, kyphosis, and/orlordosis); 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 mmRadius™ rod-to-rod connector |
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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.
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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.
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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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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
§ 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.