K Number
K103070
Device Name
GPS TM, G SURGICAL ANTERIOR CERVICAL PLATE SYSTEM +
Date Cleared
2011-01-12

(86 days)

Product Code
Regulation Number
888.3060
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The GPS™, G Surgical Anterior Cervical Plate System is intended for use in anterior cervical decompression and fusion (ACDF) surgery at levels C2-C7. The system is indicated for temporary stabilization of the anterior spine during the development of cervical fusions in skeletally mature patients with the following indications: - Degenerative Disc Disease (as defined by neck pain of the discogenic origin with . degeneration of disc confirmed by patient history and radiographic studies) - Trauma (including fractures) . - Tumors . - Deformities or curvatures (including kyphosis, lordosis, or scoliosis) . - Pseudarthrosis . - . Failed previous fusion - . Spondylolisthesis - . Spinal Stenosis
Device Description
The GPS™ G Surgical Anterior Cervical Plate System consists of a variety of shapes and sizes of bone plates, bone screws, locking screws, and associated instruments. Fixation is provided by bone screws, of various lengths, inserted into the vertebral body of the cervical spine using an anterior approach. The GPS™ G Surgical Anterior Cervical Plate System implant components are made from titanium alloy described by ASTM F136 and supplied non sterile. Specialized instruments made from surgical instrument grade stainless steel are available for the application and removal of the GPS ™, G Surgical Pedicle System implants.
More Information

Not Found

No
The device description and performance studies focus on the mechanical properties and materials of a surgical plate system, with no mention of AI or ML.

Yes.
The device is intended for temporary stabilization of the anterior spine during the development of cervical fusions, and is indicated for conditions such as degenerative disc disease, trauma, and tumors, which are therapeutic applications.

No
Explanation: The GPS™ G Surgical Anterior Cervical Plate System is described as an implantable device used for temporary stabilization of the anterior spine during cervical fusions. Its indications for use are related to various spinal conditions that would be diagnosed through other means (e.g., radiographic studies). The device itself is not used to diagnose these conditions.

No

The device description explicitly states that the system consists of bone plates, bone screws, locking screws, and associated instruments made from titanium alloy and stainless steel, which are physical hardware components.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body (like blood, urine, or tissue) to provide information about a person's health.
  • Device Description: The GPS™ G Surgical Anterior Cervical Plate System is described as a system of bone plates, bone screws, and instruments intended for surgical implantation to stabilize the spine.
  • Intended Use: The intended use is for temporary stabilization of the anterior spine during cervical fusion surgery. This is a surgical procedure performed directly on the patient's body, not a test performed on a sample outside the body.

The description clearly indicates a surgically implanted device used for structural support, which falls outside the scope of In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The GPS™, G Surgical Anterior Cervical Plate System is intended for use in anterior cervical decompression and fusion (ACDF) surgery at levels C2-C7. The system is indicated for temporary stabilization of the anterior spine during the development of cervical fusions in skeletally mature patients with the following indications:

  • Degenerative Disc Disease (as defined by neck pain of the discogenic origin with . degeneration of disc confirmed by patient history and radiographic studies)
  • Trauma (including fractures) .
  • Tumors .
  • Deformities or curvatures (including kyphosis, lordosis, or scoliosis) .
  • Pseudarthrosis .
  • . Failed previous fusion
  • . Spondylolisthesis
  • . Spinal Stenosis

Warning: The device is not intended for screw attachments or fixation to the posterior elements (pedicles) of the cervical, thoracic or lumbar spine.

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

KWQ

Device Description

The GPS™ G Surgical Anterior Cervical Plate System consists of a variety of shapes and sizes of bone plates, bone screws, locking screws, and associated instruments. Fixation is provided by bone screws, of various lengths, inserted into the vertebral body of the cervical spine using an anterior approach. The GPS™ G Surgical Anterior Cervical Plate System implant components are made from titanium alloy described by ASTM F136 and supplied non sterile. Specialized instruments made from surgical instrument grade stainless steel are available for the application and removal of the GPS ™, G Surgical Pedicle System implants.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cervical spine (C2-C7)

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)

Performance testing was performed on the GPS™ G Surgical Anterior Cervical Plate System included static compression, dynamic compression and static torsion in accordance with ASTM F1717. The test results demonstrate the GPS™ G Surgical Anterior Cervical Plate System is safe and effective and adequate for the intended use. No clinical testing was performed.

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.

K030866, K000536, K021461

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

§ 888.3060 Spinal intervertebral body fixation orthosis.

(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.

0

K103070
page 1 of 2

510(k) Summary

(as required by 21 CFR 807.92)

Submitted By:

Donald Grafton G Surgical Co., Ltd. 4218 Skvwav Dr Naples, FL 34112 Ph 239 919 4895 Fax 239 455 8988

JAN 1 2 2011

4

Date:

Oct. 4, 2010

Sponsor:

G Surgical Co., Ltd. 152 Soi Ramkhamhaeng 138 Sapansung, Bangkok Thailand 10240

Trade Name: Common Name: Classification Name: Device Class:

Device/Product Code(s):

GPS ™, Anterior Cervical Plate System Anterior Cervical System Spinal Intervertebral Body Fixation Orthosis FDA proposed classification as Class II (888.3060) following Orthopedic and Rehabilitation Device Advisory Review, for the requested indications. Anterior Cervical Plates (KWQ) 21 CFR § 888.3060

Predicate Devices:K030866 Synthes CSLPApril 18, 2003
K000536 Synthes CSLPMay 15, 2000
K021461 Medtronic Atlantis Vision®July 22, 2002

Device Description: The GPS™ G Surgical Anterior Cervical Plate System consists of a variety of shapes and sizes of bone plates, bone screws, locking screws, and associated instruments. Fixation is provided by bone screws, of various lengths, inserted into the vertebral body of the cervical spine using an anterior approach. The GPS™ G Surgical Anterior Cervical Plate System implant components are made from titanium alloy described by ASTM F136 and supplied non sterile. Specialized instruments made from surgical instrument grade stainless steel are available for the application and removal of the GPS ™, G Surgical Pedicle System implants.

Indications for Use: The GPS™, G Surgical Anterior Cervical Plate System is intended for use in anterior cervical decompression and fusion (ACDF) surgery at levels C2-C7. The system is indicated for temporary stabilization of the anterior spine during the development of cervical fusions in skeletally mature patients with the following indications:

  • Degenerative Disc Disease (as defined by neck pain of the discogenic origin with . degeneration of disc confirmed by patient history and radiographic studies)
  • Trauma (including fractures) .
  • Tumors .

129


1

K103070
page 2 of 2

  • Deformities or curvatures (including kyphosis, lordosis, or scoliosis) .
  • Pseudarthrosis .
  • . Failed previous fusion
  • . Spondylolisthesis
  • . Spinal Stenosis

Warning: The device is not intended for screw attachments or fixation to the posterior elements (pedicles) of the cervical, thoracic or lumbar spine.

Performance Data: Performance testing was performed on the GPS™ G Surgical Anterior Cervical Plate System included static compression, dynamic compression and static torsion in accordance with ASTM F1717. The test results demonstrate the GPS™ G Surgical Anterior Cervical Plate System is safe and effective and adequate for the intended use. No clinical testing was performed.

Substantial Equivalence: The GPS™ G Surgical Anterior Cervical Plate System is equivalent to the predicate devices in design, function and indications of use. The results of non clinical testing demonstrate that the mechanical performance of the GPS™ G Surgical Anterior Cervical Plate System is equivalent to the predicate devices. Thus the GPS™ G Surgical Anterior Cervical Plate System is substantially equivalent to the predicate devices.

2

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized image of an eagle with its wings spread, and three horizontal lines below the eagle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the eagle.

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

G Surgical Co., Ltd. % Mr. Donald Grafton 152 Soi Ramkhamhaeng 138 Sapansung, Bangkok Thailand 10240

JAN 1 2 2011

Re: K103070

Trade/Device Name: GPS™, G Surgical Anterior Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: KWQ Dated: December 16, 2010 Received: December 17, 2010

Dear Mr. Grafton:

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. Donald Grafton

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.

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, "Mistranding 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/Resourcesfor-You/Industry/default.htm.

Sincerely yours,

A
B

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

Enclosure

4

K103070
page 1 of 1

INDICATIONS FOR USE

Device Name GPS™, G Surgical Anterior Cervical Plate System

JAN 1 2 2011

દ્વા

Indications for Use: The GPS™, G Surgical Anterior Cervical Plate System is intended for use in anterior cervical decompression and fusion (ACDF) surgery at levels C2-C7. The system is indicated for temporary stabilization of the anterior spine during the development of cervical fusions in skeletally mature patients with the following indications:

  • Degenerative Disc Disease (as defined by neck pain of the discogenic origin with . degeneration of disc confirmed by patient history and radiographic studies)
  • Trauma (including fractures) .
  • Tumors
  • Deformities or curvatures (including kyphosis, lordosis, or scoliosis) .
  • Pseudarthrosis �
  • � Failed previous fusion
  • Spondylolisthesis .
  • Spinal Stenosis .

Warning: This device is not approved for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic or lumbar spine.

x AND/OR Over the Counter Use Prescription Use (Part 21 CFR 801 Subpart D) (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)

(Division Sign-Off)

Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number_ K103070