K Number
K103819
Device Name
PSL ANTERIOR CERVICAL PLATE SYSTEM
Date Cleared
2011-02-15

(47 days)

Product Code
Regulation Number
888.3060
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The PSL Anterior Cervical Plate System is intended for anterior screw fixation of the cervical spine (C2-C7). These implants have been designed to provide stabilization as an adjunct to cervical fusion. Indications for the use of this implant system are: degenerative disc disease defined as neck pain of discogenic origin with the degeneration of the disc confirmed by history and radiographic studies, spondylolisthesis, trauma, spinal stenosis, deformity, tumor, pseudarthrosis or failed previous fusion.
Device Description
The PSL Anterior Cervical Plate (ACP) System comprises plate and screw components in a variety of sizes and lengths. Three styles of plate, including fixed, variable and corpectomy, are available. Primary, self-drilling primary and rescue screws are offered.
More Information

Not Found

No
The summary describes a mechanical implant system for spinal fusion and does not mention any software, image processing, or AI/ML capabilities.

Yes
The device is described as providing "stabilization as an adjunct to cervical fusion" and is used to treat various conditions such as "degenerative disc disease, spondylolisthesis, trauma, spinal stenosis, deformity, tumor, pseudarthrosis or failed previous fusion," all of which indicate a therapeutic purpose.

No
The device, the PSL Anterior Cervical Plate System, is an implant used for stabilization as an adjunct to cervical fusion. It is a treatment device, not a diagnostic one.

No

The device description explicitly states it comprises "plate and screw components," which are physical hardware implants.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states "anterior screw fixation of the cervical spine (C2-C7)" and "stabilization as an adjunct to cervical fusion." This describes a surgical implant used in vivo (within the body) to provide structural support.
  • Device Description: The description details "plate and screw components" which are physical implants.
  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening. This device does not perform any such analysis of specimens.

This device is a surgical implant, specifically an orthopedic device for spinal fixation.

N/A

Intended Use / Indications for Use

The PSL Anterior Cervical Plate System is intended for anterior screw fixation of the cervical spine (C2-C7). These implants have been designed to provide stabilization as an adjunct to cervical fusion. Indications for the use of this implant system are: degenerative disc disease defined as neck pain of discogenic origin with the degeneration of the disc confirmed by history and radiographic studies, spondylolisthesis, trauma, spinal stenosis, deformity, tumor, pseudarthrosis or failed previous fusion.
WARNING: The PSL Anterior Cervical Plate System is not intended for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic or lumbar spine.

Product codes

KWQ

Device Description

The PSL Anterior Cervical Plate (ACP) System comprises plate and screw components in a variety of sizes and lengths. Three styles of plate, including fixed, variable and corpectomy, are available. Primary, self-drilling primary and rescue screws are offered.

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

Not Found

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

Static compression bending and torsion, and dynamic compression bending were performed according to ASTM F1717 on a worst-case, cervical plate construct. The mechanical test results demonstrated that the PSL ACP performs as well as the predicate device.

Key Metrics

Not Found

Predicate Device(s)

K032815, K073708

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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

8. 510(k) Summary

FEB 15 2011

Date:29 December 2010
Sponsor:Precision Surgery Limited
2700 W. 9th Ave, Suite 120
Oshkosh, WI 54904
Phone 920-223-0547
Fax 920-223-0551
Contact Person:Kamaljit S. Paul, MD
Proposed Trade
Name:PSL Anterior Cervical Plate System
Device ClassificationClass II
Classification Name:Spinal intervertebral body fixation orthosis
Regulation:888.3060
Device Product
Code:KWQ
Device Description:The PSL Anterior Cervical Plate (ACP) System comprises plate and
screw components in a variety of sizes and lengths. Three styles of
plate, including fixed, variable and corpectomy, are available.
Primary, self-drilling primary and rescue screws are offered.
Intended Use:The PSL Anterior Cervical Plate System is intended for anterior
screw fixation of the cervical spine (C2-C7). These implants have
been designed to provide stabilization as an adjunct to cervical
fusion. Indications for the use of this implant system are:
degenerative disc disease defined as neck pain of discogenic origin
with the degeneration of the disc confirmed by history and
radiographic studies, spondylolisthesis, trauma, spinal stenosis,
deformity, tumor, pseudarthrosis or failed previous fusion.
WARNING: The PSL Anterior Cervical Plate System is not intended
for screw attachment or fixation to the posterior elements (pedicles)
of the cervical, thoracic or lumbar spine.
Materials:The PSL ACP System components are manufactured from titanium
alloy (Ti-6Al-4V per ASTM F136). The screw-retaining central rail is
manufactured from nickel titanium alloy (NiTi per ASTM F2063).
Predicate Device:Fixed, Variable & Corpectomy Cervical Plate System
(K032815/K073708)

1

Technological The PSL ACP System is identical to the predicate Fixed, Variable & Corpectomy Cervical Plate System, only the system name has Characteristics: changed. Therefore, the system possesses the same technological characteristics as the predicate. These include: . intended use (as described above), design (plate-based fixation system having self-tapping screws in .

  • various sizes),
  • . material (titanium alloy) and
  • sizes (plate and screw sizes are the same as those offered by . the predicate system).

The fundamental scientific technology of the PSL ACP is the same as the previously cleared device.

Static compression bending and torsion, and dynamic compression bending were performed according to ASTM F1717 on a worst-case, cervical plate construct. The mechanical test results demonstrated that the PSL ACP performs as well as the predicate device.

The PSL Anterior Cervical Plate System is substantially equivalent to the devices referenced above and is therefore safe and effective for its intended use.

Performance Data:

Conclusion:

2

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS). The seal features a stylized eagle with its head turned to the right. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circle around the eagle. The seal is black and white.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-066-0609 Silver Spring, MD 20993-0002

Precision Surgery, Ltd. % BackRoads Consulting, Inc. Karen E. Warden, Ph.D. 8202 Sherman Road Chesterland, Ohio 44026

FEB 15 201

Re: K103819

Trade/Device Name: PSL Anterior Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: KWO Dated: December 29, 2010 Received: December 30, 2010

Dear Dr. Warden:

. ·

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 - Karen E. Warden, Ph.D.

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

Sincerely vours.

A. Sig. B. R2A
for

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

Enclosure

4

7. Indications for Use Statement

510(k) Number: K103819

Device Name: PSL Anterior Cervical Plate System

Indications for Use:

The PSL Anterior Cervical Plate System is intended for anterior screw fixation of the cervical spine (C2-C7). These implants have been designed to provide stablization as an adjunct to cervical fusion. Indications for the use of this implant system are: degenerative disc disease defined as neck pain of discogenic origin with the degeneration of the disc confirmed by history and radiographic studies, spondylolisthesis, trauma, spinal stenosis, deformity, tumor, pseudarthrosis or failed previous fusion.

WARNING: The PSL Anterior Cervical Plate System is not intended for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic or lumber spine.

Prescription Use X (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)

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

K103819 - -510(k) Number_