The Synthes USS are non-cervical spinal fixation devices intended for posterior pedicle screw fixation (T1-S2/ilium), posterior hook fixation (T1-L5), or anterolateral fixation (T8-L5). Pedicle screw fixation is limited to skeletally mature patients with the exception of the Small Stature USS, which includes small stature and pediatric patients. These devices are indicated as an adjunct to fusion for all of the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis, Scheuermann's Disease), tumor, stenosis, and failed previous fusion (pseudoarthrosis).

When treating patients with Degenerative Disc Disease (DDD), transverse bars are not cleared for use as part of the posterior pedicle screw construct.

When used with the 3.5/6.0 mm parallel connectors, the Synthes USS 6.0 mm rod systems can be linked to the CerviFix 3.5 mm Systems. In addition, when used with 3.5/5.0 mm parallel connectors, the Synthes Small Stature USS can be linked to the CerviFix 3.5 mm Systems. When used with the 5.0/6.0 mm parallel connectors, the Synthes Small Stature USS can be linked to the Synthes USS 6.0 mm rod systems.

When used with the 3.5/6.0 mm and 4.0/6.0 mm tapered rods, the Synthes USS 6.0 mm rod systems can be linked to the CerviFix 3.5 mm and 4.0 mm Systems, respectively. When used with the 3.5/5.5 mm and 4.0/5.5 mm tapered rods, Matrix can be linked to the CerviFix 3.5 mm and 4.0 mm Systems, respectively. When used with the 5.5/6.0 mm tapered rods, the Synthes USS 6.0 mm rod systems can be lined to the Matrix System.

In addition, Synthes USS 6.0 mm rod systems can be interchanged with all USS 6.0 mm rods and transconnectors.

Synthes USS

6.0 mm Rod Systems: USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, USS Fracture, Click'X, Click'X Monoaxial, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, ClampFix
5.5 mm Rod System: Matrix
5.0 mm Rod System: USS Small Stature

CerviFix

3.5 mm Rod Systems: CerviFix, Axon, Synapse
4.0 mm Rod System: Synapse

Device Description

The Synthes Matrix System is an addition to Synthes' existing posterior thoracolumbar spine systems. The Matrix System consists of a family of non-cervical spinal fixation devices intended for posterior pedicle screw fixation (T1-S2), posterior hook fixation (T1-L5) or anterolateral fixation (T8-L5). The implants include pedicle bone screws, polyaxial pedicle screws, monoaxial pedicle screws, polyaxial heads, reduction screws, reduction heads, locking caps, transconnectors, transverse bars, rods and hooks. The implants are primarily manufactured from titanium (ASTM F67 - 06), titanium alloy (ASTM F1295 - 05), cobalt-chromium-molybdenum alloy (ASTM F1537 - 08) or nitinol (ASTM F2063 - 05), similar to the predicates.

The subject of this submission is the addition of transverse bars and tapered rods.

AI/ML Overview

The document describes the Synthes Matrix System, a spinal fixation device. The study provided focuses on non-clinical performance testing rather than clinical trials with human subjects or AI performance.

Here's an analysis of the provided text in relation to your request:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria (from ASTM F1717–09 standards)	Reported Device Performance (Synthes Matrix System)
Static compression bend testing	Performs as well as or better than predicate devices
Static torsion testing	Performs as well as or better than predicate devices
Dynamic compression bend testing	Performs as well as or better than predicate devices

2. Sample size used for the test set and the data provenance

Sample Size: Not specified. The document states "Synthes conducted the following non-clinical testing..." but does not detail the number of units tested for each type of test.
Data Provenance: The testing was non-clinical, conducted by Synthes. It does not involve human subjects, so concepts like country of origin or retrospective/prospective don't apply in the medical imaging sense.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This question is not applicable to the provided document. The study is a non-clinical, mechanical performance test, not a study evaluating human judgment or diagnostic accuracy. The "ground truth" here is compliance with ASTM standards, not expert consensus on medical images or patient outcomes.

4. Adjudication method for the test set

Not applicable. As noted above, this is a mechanical performance test, not a study involving human readers or adjudicators of medical data.

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

No. This is a non-clinical performance study of a spinal fixation device, not a study involving AI or human readers of medical images.

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

No. This is a non-clinical performance study of a spinal fixation device, not an algorithm.

7. The type of ground truth used

The "ground truth" implicitly used for this non-clinical testing is the mechanical performance requirements specified in ASTM F1717–09 standards for static compression bend, static torsion, and dynamic compression bend testing. The device's performance was compared against these established industry standards and against predicate devices.

8. The sample size for the training set

Not applicable. This is a non-clinical performance study of a physical device, not an AI algorithm that requires a training set.

9. How the ground truth for the training set was established

Not applicable for the same reason as point 8.

Summary

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K10a34 Page 1 of 2

SYNTHES®
Spine

4 510(k) Summary

JUL -1 2010

510(k) Summary
Name of Firm:	Synthes Spine
	1302 Wrights Lane East
	West Chester, PA 19380
510(k) Contact:	Amnon Talmor
	Spine Regulatory Affairs Specialist
	Telephone: 610-719-5446
	Facsimile: 610-719-5102
	Email: talmora@synthes.com
Date Prepared:	March 3, 2010
Trade Name:	Synthes Matrix System
Classification:	21 CFR 888.3050-Spinal interlaminar fixation orthosis
	21 CFR 888.3060-Spinal intervertebral body fixation orthosis
	21 CFR 888.3070-Pedicle screw spinal system
	Class III
	Orthopaedic and Rehabilitation Devices Panel
	Product Code: NKB, MNH, MNI, KWQ, KWP
Predicate Devices:	Synthes Univeral Sacral System, K963045
	Synthes Matrix System, K092929
	Synthes Pangea System, K052151
	Synthes Click'X Monoaxial, K031175
	Synthes Dual Opening USS, K023675
	Synthes USS, K022949
	Synthes USS Iliosacral and USS Polyaxial, K082572
	Synthes CerviFix, K001864
	Synthes Synapse System, K070573
Device	The Synthes Matrix System is an addition to Synthes' existing posterior
Description:	thoracolumbar spine systems. The Matrix System consists of a family of non-
	cervical spinal fixation devices intended for posterior pedicle screw fixation
	(T1-S2), posterior hook fixation (T1-L5) or anterolateral fixation (T8-L5). The
	implants include pedicle bone screws, polyaxial pedicle screws, monoaxial
	pedicle screws, polyaxial heads, reduction screws, reduction heads, locking
	caps, transconnectors, transverse bars, rods and hooks. The implants are
	primarily manufactured from titanium (ASTM F67 - 06), titanium alloy
	(ASTM F1295 - 05), cobalt-chromium-molybdenum alloy (ASTM F1537
	- 08) or nitinol (ASTM F2063 - 05), similar to the predicates.

	The subject of this submission is the addition of transverse bars and
	tapered rods.

Intended Use/	The Synthes USS are non-cervical spinal fixation devices intended for
Indications for	posterior pedicle screw fixation (T1-S2/ilium), posterior hook fixation (T1-
Use:	L5), or anterolateral fixation (T8-L5). Pedicle screw fixation is limited to
	skeletally mature patients with the exception of the Small Stature USS, which
	includes small stature and pediatric patients. These devices are indicated as an
	adjunct to fusion for all of the following indications: degenerative disc disease
	(defined as discogenic back pain with degeneration of the disc confirmed by
510(k) Summary
	history and radiographic studies), spondylolisthesis, trauma (i.e., fracture ordislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and/orlordosis, Scheuermann's Disease), tumor, stenosis, and failed previous fusion(pseudoarthrosis).
	When treating patients with Degenerative Disc Disease (DDD), transversebars are not cleared for use as part of the posterior pedicle screw construct.
	When used with the 3.5/6.0 mm parallel connectors, the Synthes USS 6.0 mmrod systems can be linked to the CerviFix 3.5 mm Systems. In addition, whenused with 3.5/5.0 mm parallel connectors, the Synthes Small Stature USS canbe linked to the CerviFix 3.5 mm Systems. When used with the 5.0/6.0 mmparallel connectors, the Synthes Small Stature USS can be linked to theSynthes USS 6.0 mm rod systems.
	When used with the 3.5/6.0 mm and 4.0/6.0 mm tapered rods, the SynthesUSS 6.0 mm rod systems can be linked to the CerviFix 3.5 mm and 4.0 mmSystems, respectively. When used with the 3.5/5.5 mm and 4.0/5.5 mmtapered rods, Matrix can be linked to the CerviFix 3.5 mm and 4.0 mmSystems, respectively. When used with the 5.5/6.0 mm tapered rods, theSynthes USS 6.0 mm rod systems can be linked to the Matrix System.
	In addition, Synthes USS 6.0 mm rod systems can be interchanged with allUSS 6.0 mm rods and transconnectors.
	Synthes USS6.0 mm Rod Systems: USS Side-Opening, USS Dual-Opening, USS VASvariable axis components, USS Fracture, Click'X, Click'X Monoaxial,Pangea, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, ClampFix 5.5 mm Rod System: Matrix 5.0 mm Rod System: USS Small Stature
	CerviFix3.5 mm Rod Systems: CerviFix, Axon, Synapse 4.0 mm Rod System: Synapse
Comparison of thetechnologicalcharacteristics ofthe device to thepredicate device:	The design features, material, and indications for use of the subject MatrixSystem is substantially equivalent to the predicate devices identified.Additionally, the safety and effectiveness of this system is adequatelysupported by documentation within this premarket notification.
Performance Data(Non-Clinicaland/or Clinical):	Synthes conducted the following non-clinical testing: static compressionbend, static torsion, and dynamic compression bend testing in accordancewith ASTM F1717–09. The conclusions drawn from testing demonstratethat the Matrix System is as safe and effective and performs as well as orbetter than the predicate devices identified. Clinical data was not needed forthis device.

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K100634 Page 2 of 2

@ SYNTHES® Spine

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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle or bird-like symbol with three curved lines representing its wings or body. The logo is surrounded by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular fashion. The text is in uppercase letters and is positioned around the upper half of the circular logo.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

JUL -1 2010

Synthes Spine % Mr. Amon Talmor Regulatory Affairs Specialist 1302 Wrights Lane East West Chester, Pennsylvania 19380

Re: K100634

Trade/Device Name: Synthes Matrix System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNI, MNH, KWP, KWQ Dated: June 25, 2010 Received: June 28, 2010

Dear Mr. Talmor:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you; however, that device labeling must be truthful and not misleading.

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

{3}------------------------------------------------

Page 2 - Mr. Amon Talmor

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 (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 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 toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely vours.

Barbara Hughum

Mark N. Melkerson Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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@ SYNTHES® Spine

4 Indications for Use Statement

510(k) Number: K100634 Device Name: Synthes Matrix System

The Synthes USS are non-cervical spinal fixation devices intended for posterior pedicle screw fixation (T1-S2/ilium), posterior hook fixation (T1-L5), or anterolateral fixation (T8-L5). Pedicle screw fixation is limited to skeletally mature patients with the exception of the Small Stature USS, which includes small stature and pediatric patients. These devices are indicated as an adjunct to fusion for all of the following indications: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis, Scheuermann's Disease), turnor, stenosis, and failed previous fusion (pseudoarthrosis).

When treating patients with Degenerative Disc Disease (DDD), transverse bars are not cleared for use as part of the posterior pedicle screw construct.

In addition, Synthes USS 6.0 mm rod systems can be interchanged with all USS 6.0 mm rods and transconnectors.

Synthes USS

6.0 mm Rod Systems: USS Side-Opening, USS Dual-Opening, USS VAS variable axis components, o USS Fracture, Click'X, Click'X Monoaxial, Pangea Monoaxial, USS Polyaxial, USS Iliosacral, ClampFix
5.5 mm Rod System: Matrix O
o 5.0 mm Rod System: USS Small Stature

CerviFix

3.5 mm Rod Systems: CerviFix, Axon, Synapse O
4.0 mm Rod System: Synapse O

Prescription Use × (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 IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off)
Division of Surgical, Orthopedic,
ad Restorative Devices

thes Matrix System K106680(k) Number

K160634

Synthes Matrix System K10@600(K) Number

Regulation Number and Section

§ 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.