(29 days)
The EXPEDIUM Spine System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine.
The EXPEDIUM Spine System is intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (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 in skeletally mature patients.
The subject EXPEDIUM Spine System components consist of implants that are available in various geometries and sizes.
The provided document describes a Special 510(k) Submission for additions to the EXPEDIUM Spine System, which is a medical device for spinal stabilization. The submission is primarily focused on demonstrating the substantial equivalence of the modified device to existing predicate devices.
Here's an analysis of the acceptance criteria and study information contained in the document, based on your requested points:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Mechanical Performance | The device's mechanical performance was characterized by testing according to recognized ASTM standards. |
| Biocompatibility | Implied through the use of implant grade materials (ASTM F 138 and ASTM F 2229 stainless steel, ASTM F 136 titanium alloy), which are known to be biocompatible for medical implants. |
| Substantial Equivalence to Predicate Devices | The FDA determined the device to be substantially equivalent to legally marketed predicate devices, indicating it meets existing safety and effectiveness standards. |
Study that Proves the Device Meets Acceptance Criteria:
The document states: "Performance data per ASTM F 1717 and ASTM 1798 were submitted to characterize the subject EXPEDIUM Spine System components addressed in this notification."
- ASTM F 1717: Standard Test Methods for Spinal Implant Constructs in a Corpectomy Model. This standard evaluates the static and fatigue properties of spinal implant constructs used in corpectomy procedures.
- ASTM F 1798: Standard Guide for Evaluating the Fatigue Properties of Spinal Implants – refers to the evaluation of fatigue properties specifically (though the provided excerpt only mentions "ASTM 1798" without "F" and full title, this is the most likely relevant standard).
These tests evaluate the mechanical strength, durability, and stability of the spinal implant components under simulated physiological loading conditions. Successful completion of these tests with results comparable to, or better than, predicate devices demonstrates that the device meets the necessary mechanical performance acceptance criteria. The use of implant-grade materials (ASTM F 138, ASTM F 2229, ASTM F 136) inherently addresses biocompatibility criteria as these materials are well-established for implant use.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document does not specify the number of implants or constructs tested for the performance data (ASTM F 1717 and ASTM F 1798). Test standards typically provide guidance on sample sizes, but the exact numbers used are not detailed here.
- Data Provenance: The studies are laboratory-based mechanical tests performed on the device components. The data provenance is internal to DePuy Spine, Inc. (the manufacturer) and is not clinical data from patients (retrospective or prospective).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of information is not applicable to this submission. The "ground truth" for mechanical performance tests is defined by the objective physical and material properties measured against established engineering standards (ASTM F 1717, ASTM F 1798), not by expert human interpretation or consensus.
4. Adjudication Method for the Test Set
This is not applicable. Mechanical tests rely on instrumental measurements and defined pass/fail criteria from engineered standards, not on 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
This is not applicable. This submission is for a physical medical implant (spinal fixation system), not an AI-powered diagnostic or assistive device where MRMC studies would be relevant.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was Done
This is not applicable. This is not an algorithmic device.
7. The Type of Ground Truth Used (Expert Consensus, Pathology, Outcomes Data, etc.)
The ground truth for this device is based on engineering standards and physical measurements. Specifically:
- Compliance with ASTM F 1717 (Standard Test Methods for Spinal Implant Constructs in a Corpectomy Model) to evaluate static and fatigue properties.
- Compliance with ASTM F 1798 (Standard Guide for Evaluating the Fatigue Properties of Spinal Implants).
- Use of implant-grade materials (ASTM F 138, ASTM F 2229, ASTM F 136) with documented acceptance criteria for their physical and chemical properties and biocompatibility.
8. The Sample Size for the Training Set
This is not applicable. There is no "training set" in the context of mechanical testing for a spinal implant. The testing is for verification and validation against specified performance requirements.
9. How the Ground Truth for the Training Set was Established
This is not applicable for the reasons stated above.
{0}------------------------------------------------
Special 510(k) Submission - Additions to EXPEDIUM Spine System
5. 510(K) SUMMARY
| Submitter: | DePuy Spine, Inc. |
|---|---|
| 325 Paramount Drive | |
| Raynham, MA 02767 |
SEP 2 5 2009
Contact Person: Frank Jurczak Regulatory Affairs Associate (508) 828-3288 Voice: Fax: (508) 828-3797 E-Mail: fjurczak@its.jnj.com
Date Prepared: August 26, 2009
Device Class: Class III
Classification Name: Spinal interlaminar fixation orthosis per 21 CFR §888.3050
Spinal intervertebral body fixation orthosis per 21 CFR §888.3060
Pedicle screw spinal fixation per 21 CFR §888.3070
Classification Panel: Orthopedics
FDA Panel Number: 87
Product Code(s): NKB, KWQ, KWP, MNH, MNI
EXPEDIUM Spine System Proprietary Name:
Predicate Devices: EXPEDIUM Spine System (K033901, K041119, K051024, K062174) MOSS MIAMI Spine System (K983583) CD HORIZON (Addition of BioDur 108 Screws) (K034056) MONARCH Spine System (K023438)
Device Description: The subject EXPEDIUM Spine System components consist of implants that are available in various geometries and sizes.
Intended Use: The EXPEDIUM Spine System is intended to provide immobilization and stabilization of spinal segments in
{1}------------------------------------------------
skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine.
The EXPEDIUM Spine System is intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (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 in skeletally mature patients.
Materials:
Manufactured from ASTM F 138 and ASTM F 2229 implant grade stainless steel, ASTM F 136 implant grade titanium alloy.
Performance data per ASTM F 1717 and ASTM 1798 were Performance Data: submitted to characterize the subject EXPEDIUM Spine System components addressed in this notification.
DePuy Spine, Inc., a Johnson & Johnson Company
年092424
{2}------------------------------------------------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-G609 Silver Spring, MD 20993-0002
DePuy Spine, Inc % Frank Jurczak 325 Paramount Drive Raynham, Massachusetts 02767
SEP 2 5 2009
Re: K092626
Trade/Device Name: Modification to Expedium Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle Screw Spinal System Regulatory Class: Class III Product Code: NKB, MNH, MNI, KWO, KWP Dated: August 26, 2009 Received: August 27, 2009
Dear Mr. Jurczak:
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 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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.
{3}------------------------------------------------
Page 2 - Mr. Frank Jurczak
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutfDA/CentersOffices/CDRH/CDRHOffices/ucm1158001,'phrfaor the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. 302mm rase note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR, Paul 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its tolloffree mbber (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Mark N. Melk rson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{4}------------------------------------------------
INDICATIONS FOR USE STATEMENT 4.
510(k) Number (if known): Ko92626
Device Name: EXPEDIUM Spine System
Indications For Use:
The EXPEDIUM® Spine System is intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine.
The EXPEDIUM Spine System is intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (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; pseudarthrosis; and failed previous fusion in skeletally mature patients.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (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)
Karen S. Bney
(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number K092624
DePuy Spine, Inc., a Johnson & Johnson Company
Page 4-1
§ 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.