K Number
K080026
Date Cleared
2008-01-28

(24 days)

Product Code
Regulation Number
888.3070
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Quantum - MIS Cannulated System is 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 instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and /or lordosis), spinal tumor, and failed previous fusion (pseudoarthrosis). In addition, this device is a pedicle screw system indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3-S1) with removal of the implants after the attainment of a solid fusion.

Device Description

The Quantum - MIS Cannulated System implants are substantially equivalent to the components of a previously cleared Pioneer spinal system, with similar materials, performance, and indications for use demonstrated.

AI/ML Overview

The provided text describes a 510(k) summary for a medical device called the "Quantum - MIS Cannulated System." This document primarily focuses on demonstrating substantial equivalence to previously cleared predicate devices rather than providing detailed acceptance criteria and a study to prove meeting those criteria in the way a clinical or standalone performance study for an AI/ML device would.

Therefore, many of the requested items (e.g., sample size for test sets, number of experts, adjudication methods, MRMC studies, standalone performance, training set details) are not applicable or not provided in this type of submission.

Here's a breakdown of the available information based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance

The submission does not explicitly state quantitative acceptance criteria with corresponding reported performance values in the format of a table as would be expected for a clinical or AI performance study. Instead, it relies on demonstrating equivalence through adherence to recognized standards and similar characteristics to predicate devices.

Acceptance Criteria CategoryAcceptance Criteria (Implicit)Reported Device Performance
Mechanical PerformanceConformance with ASTM Standard Specifications for biocompatible alloys and mechanical integrity."Testing per recognized ASTM standards was presented." (Specific results not detailed in this summary.)
BiocompatibilityUse of biocompatible alloys."Biocompatible alloys in conformance with ASTM Standard Specifications."
Indications for UseThe device should be suitable for the specified indications (e.g., immobilization and stabilization of spinal segments, treatment of severe spondylolisthesis) in skeletally mature patients as an adjunct to fusion. This is an alignment with the predicate device's use.The device's "Intended Use" statement aligns with its predicate devices.
Material EquivalenceMaterials should be similar to predicate devices."The Quantum - MIS Cannulated System implants are substantially equivalent to the components of a previously cleared Pioneer spinal system, with similar materials..."
Performance EquivalencePerformance should be similar to predicate devices."...similar...performance...demonstrated."

2. Sample Size Used for the Test Set and Data Provenance

Not applicable. This is a 510(k) submission for a physical medical device (pedicle screw system), not an AI/ML device or diagnostic test that would typically have a "test set" in the sense of patient data. The "testing" referred to is likely mechanical and material testing, not a clinical trial or performance study on patient data.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

Not applicable. Ground truth as typically defined for AI/ML or diagnostic studies (e.g., expert consensus on images, pathology results) is not relevant for this type of device submission.

4. Adjudication Method for the Test Set

Not applicable.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and effect size.

Not applicable. This is not an AI-assisted diagnostic device where MRMC studies would be conducted.

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

Not applicable. This is not an algorithm-based device.

7. The Type of Ground Truth Used

The "ground truth" for this device, in the context of its regulatory submission, is primarily established by:

  • Adherence to recognized ASTM standards for material properties and mechanical performance.
  • Demonstrated equivalence to predicate devices that have already been legally marketed and proven safe and effective.
  • Biocompatibility testing of materials.

8. The Sample Size for the Training Set

Not applicable. There is no concept of a "training set" for physical medical devices in this context.

9. How the Ground Truth for the Training Set was Established

Not applicable.

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1

510(k) Summary

JAN 2 8 2008

Sponsor:JAN 28 2008Pioneer Surgical Technology375 River Park CircleMarquette, MI 49855Contact: Jonathan M. Gilbert(906) 226-4812
Device Name:Quantum - MIS Cannulated System
ClassificationThe classification of the subject system is Class II, as per the Code ofFederal Regulations, Title 21, Section 888.3070: Pedicle Screw SpinalSystem. The product codes are MNH, and MNI. The Panel code is 87.
PredicateDevice:K041167 - Quantum Spinal SystemK070551 - Quantum Spinal SystemK072187 - LowTop Spinal Rod System
IntendedUse:The Quantum - MIS Cannulated System is intended to provideimmobilization and stabilization of spinal segments in skeletally maturepatients as an adjunct to fusion in the treatment of the following acuteinstabilities or deformities of the thoracic, lumbar, and sacral spine:degenerative spondylolisthesis with objective evidence of neurologicalimpairment, trauma (i.e., fracture or dislocation), deformities orcurvatures (i.e., scoliosis, kyphosis, and /or lordosis), spinal tumor, andfailed previous fusion (pseudoarthrosis).In addition, this device is a pedicle screw system indicated for thetreatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1vertebra in skeletally mature patients receiving fusion by autogenousbone graft having implants attached to the lumbar and sacral spine(L3-S1) with removal of the implants after the attainment of a solidfusion.
Material:Biocompatible alloys in conformance with ASTM StandardSpecifications.
PerformanceData:Testing per recognized ASTM standards was presented.
Basis ofSubstantialEquivalence:The Quantum - MIS Cannulated System implants are substantiallyequivalent to the components of a previously cleared Pioneer spinalsystem, with similar materials, performance, and indications for usedemonstrated

pg 1 of 1

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/1/Picture/12 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular fashion around the symbol. The caduceus is black, and the text is also black.

Public Health Service

JAN 28 2008

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Pioneer Surgical Technology % Mr. Jonathan M. Gilbert 375 River Park Circle Marquette, MI 49855

Re: K080026

Trade/Device Name: Quantum-MIS Cannulated System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: II Product Code: MNI, MNH Dated: January 3, 2008 Received: January 8, 2008

Dear Mr. Gilbert:

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 - Mr. Jonathan M. Gilbert

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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at (240) 276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at (240) 276-3464. 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 Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Mark N Millican

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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2.0 Indications for Use Statement

Indications for Use

K080026 510(k) Number (if known):

Device Name: Quantum - MIS Cannulated System The Quantum - MIS Cannulated System is intended to provide Indications: immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute instabilities or deformities of the thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and /or lordosis), spinal tumor, and failed previous fusion (pseudoarthrosis). In addition, this device is a pedicle screw system indicated

for the treatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3-S1) with removal of the implants after the attainment of a solid fusion.

Prescription Use √ OR Over-the-Counter Use __
(Per 21 CFR 801.109)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

__, and I'm not going to apologize for it.

(Division Sign-C Division of Ceneral, Restorative, and Neurological Is

510(k) Number K080026

g l of l

§ 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.