K Number
K110522
Device Name
VERTEX RECONSTRUCTION SYSTEM, VERTEX SELECT RECONSTRUCTION SYSTEM
Date Cleared
2011-04-01

(37 days)

Product Code
Regulation Number
888.3050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
When intended to promote fusion of the occipitocervical spine, cervical spine, and the thoracic spine, (Occiput-T3), the VERTEX Reconstruction System is indicated for the following: DDD (neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, spinal stenosis, fracture, dislocation, failed previous fusion and/or tumors. When intended as an adjunct to fusion of the occipitocervical spine, cervical spine, and the thoracic spine, (Occiput-T3), the VERTEX® Reconstruction System is indicated for skeletally mature patients using allograft and/or autograft for the following: DDD (neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, spinal stenosis, fracture, dislocation, failed previous fusion and/or tumors. Occipitocervical Components: Plate Rod/Plates/Rods/Occipital Screws/Hooks The occipitocervical plate rods, plates, rods, occipital screws, and hooks are intended to provide stabilization to promote fusion following reduction of fracture/dislocation or trauma in the occipitocervical junction and the cervical spine. When used to treat these occipitocervical and cervical conditions, these screws are limited to occipital fixation only. The screws are not intended to be placed in the cervical spine. Occipitocervical constructs require bilateral fixation to C2 and below. Note: Segmental fixation is recommended for these constructs. Hooks and Rods The hooks and rods are also intended to provide stabilization to promote fusion following reduction of fracture/dislocation or trauma in the cervical/upper thoracic (C1-T3) spine. Multi-axial Screws/Connectors The use of multi-axial screws are limited to placement in T1-T3. The screws are not intended to be placed in the cervical spine. Titanium ATLAS® Cable System to be used with the VERTEX® Reconstruction System allows for cable attachment to the posterior cervical or thoracic spine. In order to achieve additional levels of fixation, the VERTEX® Reconstruction System may be connected to the CD HORIZON® Spinal System rods with the VERTEX® rod connectors. Refer to the CD HORIZON® Spinal System package insert for a list of the CD HORIZON® Spinal System indications of use.
Device Description
The VERTEX SELECT Reconstruction System is a posterior system, which consists of a variety of shapes and sizes of plates, rods, hooks, screws, multi-axial screws, and connecting components, which can be rigidly locked to the rod in a variety of configurations, with each construct being tailor-made for the individual case. Titanium ATLAS® cable may be used with this system at the surgeon's discretion. See the package inserts of both of those systems for labeling limitations. The VERTEX Reconstruction System is fabricated from medical grade titanium, medical grade titanium alloy, and medical grade cobalt chromium. Medical grade titanium, medical grade titanium alloy, and/or medical grade cobalt chromium may be used together. Never use titanium, titanium alloy, and/or cobalt chromium with stainless steel in the same construct. The VERTEX Reconstruction System includes a retaining ring for the multi-axial screw made of Shape Memory Alloy (Nitinol - NiTi). Shape Memory Alloy is compatible with titanium, titanium alloy, and cobalt chromium implants only. Some components contain elastomeric stakes made of silicone adhesive commonly used in implantable medical devices. Do not use with stainless steel. To achieve best results, do not use any of the VERTEX Reconstruction System implant components with components from any other system or manufacturer unless specifically labeled to do so in this or another MEDTRONIC document. As with all orthopaedic and neurosurgical implants, none of the VERTEX Reconstruction System components should ever be reused under any circumstances.
More Information

Not Found

No
The 510(k) summary describes a mechanical spinal fixation system composed of plates, rods, hooks, screws, and connectors. There is no mention of any software, algorithms, or data processing capabilities that would suggest the use of AI or ML. The device's function is purely structural support for spinal fusion.

Yes

The device is intended to promote fusion and provide stabilization for various spinal conditions, indicating a therapeutic purpose.

No

The VERTEX Reconstruction System is described as a posterior system composed of various components (plates, rods, hooks, screws, etc.) intended to provide stabilization to promote fusion in the spine. It is a surgical implant used for treatment, not for diagnosing conditions.

No

The device description explicitly lists physical components such as plates, rods, hooks, screws, and cables, which are hardware implants.

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health.
  • Device Description and Intended Use: The VERTEX Reconstruction System is described as a posterior system consisting of implants (plates, rods, hooks, screws, etc.) intended for surgical implantation to stabilize the spine and promote fusion. Its intended use is for treating various spinal conditions like DDD, spondylolisthesis, fracture, etc.
  • Lack of IVD Characteristics: The text does not mention any analysis of biological specimens, diagnostic testing, or providing information about a patient's health based on such analysis.

Therefore, the VERTEX Reconstruction System is a surgical implant device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

When intended to promote fusion of the occipitocervical spine, cervical spine, and the thoracic spine, (Occiput-T3), the VERTEX Reconstruction System is indicated for the following: DDD (neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, spinal stenosis, fracture, dislocation, failed previous fusion and/or tumors.

When intended as an adjunct to fusion of the occipitocervical spine, cervical spine, and the thoracic spine, (Occiput-T3), the VERTEX® Reconstruction System is indicated for skeletally mature patients using allograft and/or autograft for the following:
DDD (neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, spinal stenosis, fracture, dislocation, failed previous fusion and/or tumors.

Occipitocervical Components: Plate Rod/Plates/Rods/Occipital Screws/Hooks
The occipitocervical plate rods, plates, rods, occipital screws, and hooks are intended to provide stabilization to promote fusion following reduction of fracture/dislocation or trauma in the occipitocervical junction and the cervical spine. When used to treat these occipitocervical and cervical conditions, these screws are limited to occipital fixation only. The screws are not intended to be placed in the cervical spine.
Occipitocervical constructs require bilateral fixation to C2 and below.
Note: Segmental fixation is recommended for these constructs.
Hooks and Rods
The hooks and rods are also intended to provide stabilization to promote fusion following reduction of fracture/dislocation or trauma in the cervical/upper thoracic (C1-T3) spine.
Multi-axial Screws/Connectors
The use of multi-axial screws are limited to placement in T1-T3. The screws are not intended to be placed in the cervical spine.
Titanium ATLAS® Cable System to be used with the VERTEX® Reconstruction System allows for cable attachment to the posterior cervical or thoracic spine.
In order to achieve additional levels of fixation, the VERTEX® Reconstruction System may be connected to the CD HORIZON® Spinal System rods with the VERTEX® rod connectors. Refer to the CD HORIZON® Spinal System package insert for a list of the CD HORIZON® Spinal System indications of use.

Product codes

KWP

Device Description

The VERTEX SELECT Reconstruction System is a posterior system, which consists of a variety of shapes and sizes of plates, rods, hooks, screws, multi-axial screws, and connecting components, which can be rigidly locked to the rod in a variety of configurations, with each construct being tailor-made for the individual case. Titanium ATLAS® cable may be used with this system at the surgeon's discretion. See the package inserts of both of those systems for labeling limitations.
The VERTEX Reconstruction System is fabricated from medical grade titanium, medical grade titanium alloy, and medical grade cobalt chromium. Medical grade titanium, medical grade titanium alloy, and/or medical grade cobalt chromium may be used together. Never use titanium, titanium alloy, and/or cobalt chromium with stainless steel in the same construct. The VERTEX Reconstruction System includes a retaining ring for the multi-axial screw made of Shape Memory Alloy (Nitinol - NiTi). Shape Memory Alloy is compatible with titanium, titanium alloy, and cobalt chromium implants only. Some components contain elastomeric stakes made of silicone adhesive commonly used in implantable medical devices. Do not use with stainless steel.
To achieve best results, do not use any of the VERTEX Reconstruction System implant components with components from any other system or manufacturer unless specifically labeled to do so in this or another MEDTRONIC document.
As with all orthopaedic and neurosurgical implants, none of the VERTEX Reconstruction System components should ever be reused under any circumstances.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

occipitocervical spine, cervical spine, and the thoracic spine, (Occiput-T3), Occipitocervical junction, C1-T3, posterior cervical or thoracic spine

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)

Not Applicable; the system did not change. The surgical techniques were only updated to provide more detail. The overall implant process did not change.

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.

K003780, K062447, K070742, K082728, K083071, K090714, K091365

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

§ 888.3050 Spinal interlaminal fixation orthosis.

(a)
Identification. A spinal interlaminal fixation orthosis is a device intended to be implanted made of an alloy, such as stainless steel, that consists of various hooks and a posteriorly placed compression or distraction rod. The device is implanted, usually across three adjacent vertebrae, to straighten and immobilize the spine to allow bone grafts to unite and fuse the vertebrae together. The device is used primarily in the treatment of scoliosis (a lateral curvature of the spine), but it also may be used in the treatment of fracture or dislocation of the spine, grades 3 and 4 of spondylolisthesis (a dislocation of the spinal column), and lower back syndrome.(b)
Classification. Class II.

0

APR - 1 20i1

510(k) SUMMARY

A summary of 510(k) safety and effectiveness information in accordance with the requirements of 21 CFR 807.92.

Submitter Information
NameMedtronic Sofamor Danek USA, Inc.
Address2600 Pyramid Place Memphis, TN 38132
Phone number901-344-1463
Fax number901-346-9738
Establishment
Registration
Number1030489
Name of contact
personNicholas Tabrizi
Date preparedMarch 17, 2011
Name of device
Trade or
proprietary nameVERTEX® Reconstruction System
Common or usual
nameVERTEX SELECT® Reconstruction System
Classification
nameSpinal Interlaminal Fixation Orthosis
Classification panelClass II
Regulation21 CFR 888.3050
Product Code(s)KWP
Legally marketed
device(s) to which
equivalence is claimed510(k) Number Title Date Cleared K003780 Vertex Reconstruction System 9/28/01 K062447 Traverse OCT Spinal Fixation System 10/15/07 K070742 Modification to Vertex Reconstruction System 9/14/07 K082728 Vertex Reconstruction System, Vertex Select Reconstruction System 1/16/09 K083071 Vertex Reconstruction System 11/14/08 K090714 Vertex Reconstruction System, Vertex Select Reconstruction System 4/17/09 K091365 Vertex Reconstruction System, Vertex Select Reconstruction System 8/6/09
Reason for 510(k)
submissionThe purpose of this 510(k) is to consolidate several cleared surgical techniques
into two concise documents.
Device descriptionThe VERTEX SELECT Reconstruction System is a posterior system, which
consists of a variety of shapes and sizes of plates, rods, hooks, screws, multi-
axial screws, and connecting components, which can be rigidly locked to the
rod in a variety of configurations, with each construct being tailor-made for the
individual case. Titanium ATLAS® cable may be used with this system at the

1

| surgeon's discretion. See the package inserts of both of those systems for

labeling limitations.
The VERTEX Reconstruction System is fabricated from medical grade titanium,
medical grade titanium alloy, and medical grade cobalt chromium. Medical
grade titanium, medical grade titanium alloy, and/or medical grade cobalt
chromium may be used together. Never use titanium, titanium alloy, and/or
cobalt chromium with stainless steel in the same construct. The VERTEX
Reconstruction System includes a retaining ring for the multi-axial screw made
of Shape Memory Alloy (Nitinol - NiTi). Shape Memory Alloy is compatible with
titanium, titanium alloy, and cobalt chromium implants only. Some components
contain elastomeric stakes made of silicone adhesive commonly used in
implantable medical devices. Do not use with stainless steel.
To achieve best results, do not use any of the VERTEX Reconstruction System
implant components with components from any other system or manufacturer
unless specifically labeled to do so in this or another MEDTRONIC document.
As with all orthopaedic and neurosurgical implants, none of the VERTEX
Reconstruction System components should ever be reused under any
circumstances.
Intended use of the
deviceWhen intended to promote fusion of the occipitocervical spine, cervical spine,
and the thoracic spine, (Occiput-T3), the VERTEX Reconstruction System is
indicated for the following: DDD (neck pain of discogenic origin with
degeneration of the disc confirmed by history and radiographic studies),
spondylolisthesis, spinal stenosis, fracture, dislocation, failed previous fusion
and/or tumors.
Indications for useWhen intended as an adjunct to fusion of the occipitocervical spine, cervical
spine, and the thoracic spine, (Occiput-T3), the VERTEX® Reconstruction
System is indicated for skeletally mature patients using allograft and/or
autograft for the following:
DDD (neck pain of discogenic origin with degeneration of the disc confirmed by
history and radiographic studies), spondylolisthesis, spinal stenosis, fracture,
dislocation, failed previous fusion and/or tumors.
Occipitocervical Components: Plate Rod/Plates/Rods/Occipital
Screws/Hooks
The occipitocervical plate rods, plates, rods, occipital screws, and hooks are
intended to provide stabilization to promote fusion following reduction of
fracture/dislocation or trauma in the occipitocervical junction and the cervical
spine. When used to treat these occipitocervical and cervical conditions, these
screws are limited to occipital fixation only. The screws are not intended to be
placed in the cervical spine.
Occipitocervical constructs require bilateral fixation to C2 and below.
Note: Segmental fixation is recommended for these constructs.
Hooks and Rods
The hooks and rods are also intended to provide stabilization to promote fusion
following reduction of fracture/dislocation or trauma in the cervical/upper
thoracic (C1-T3) spine.
Multi-axial Screws/Connectors
The use of multi-axial screws are limited to placement in T1-T3. The screws
are not intended to be placed in the cervical spine.
Titanium ATLAS® Cable System to be used with the VERTEX® Reconstruction
System allows for cable attachment to the posterior cervical or thoracic spine.

2

In order to achieve additional levels of fixation, the VERTEX® Reconstruction System may be connected to the CD HORIZON® Spinal System rods with the VERTEX® rod connectors. Refer to the CD HORIZON® Spinal System package insert for a list of the CD HORIZON® Spinal System indications of use.
Summary of the technological characteristics of the device compared to the predicate device
CharacteristicNew DevicePredicate [Device Name]
[510(k) number]
Surgical TechniqueVERTEX SELECT®
Reconstruction System Surgical
TechniqueVertex Reconstruction System, K003780
Modification to the Vertex Reconstruction
System, K0070742
Vertex Reconstruction System, Vertex
Select Reconstruction System, K082728
Vertex Reconstruction System, K083071
Vertex Reconstruction System, Vertex
Select Reconstruction System, K090714
Vertex Reconstruction System, Vertex
Select Reconstruction System, K091365
Traverse™ OCT Spinal Fixation System,
K062447
Surgical TechniqueVERTEX SELECT®
Reconstruction System Posted
Screw Module Surgical
TechniqueModification to the Vertex Reconstruction
System, K0070742
Vertex Reconstruction System, K083071
PERFORMANCE DATA
SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL
EQUIVALENCE*
Performance Test Summary-New Device
CharacteristicStandard/Test/FDA GuidanceResults Summary
N/AN/AN/A
Comparative Performance Information Summary
CharacteristicRequirementNew DevicePredicate Device
N/AN/AN/AN/A
SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL
EQUIVALENCE AND/OR OF CLINICAL INFORMATION
Not Applicable
CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA
Not Applicable; the system did not change. The surgical techniques were only updated to

3

provide more detail. The overall implant process did not change.

.

4

Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract symbol resembling an eagle or bird with three stylized lines forming the body and wings.

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

Medtronic Sofamor Danek USA. Inc. % Mr. Nicholas Tabrizi Senior Regulatory Affairs Specialist 1800 Pyramid Place Memphis, Tennessee 38132

APR - 1 2011

Re: K110522

Trade/Device Name: VERTEX® Reconstruction System Regulation Number: 21 CFR 888.3050 Regulation Name: Spinal interlaminal fixation orthosis Regulatory Class: Class II Product Code: KWP Dated: March 21, 2011 Received: March 22, 2011

Dear Mr. Tabrizi:

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 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

5

Page 2 - Mr. Nicholas Tabrizi

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.

ff you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersQffices/CDRH/CDRHQffices/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 yours,

Aling B. nh

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

Enclosure

6

510(k) Number (if known): K110522

Device Name: VERTEX® Reconstruction System

Indications for Use:

When intended as an adjunct to fusion of the occipitocervical spine, and the thoracic spine, (Occiput-T3), the VERTEX® Reconstruction System is indicated for skeletally mature patients using allograft and/or autograft for the following:

DDD (neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, spinal stenosis, fracture, dislocation, failed previous fusion and/or tumors.

Occipitocervical Components: Plate Rod/Plates/Rods/Occipital Screws/Hooks

The occipitocervical plates, rods, occipital screws, and hooks are intended to provide stabilization to promote fusion following reduction of fracture/dislocation or trauma in the occipitocervical junction and the cervical spine. When used to treat these occipitocervical and cervical conditions, these screws are limited to occipital fixation only. The screws are not intended to be placed in the cervical spine.

Occipitocervical constructs require bilateral fixation to C2 and below. Note: Segmental fixation is recommended for these constructs.

Hooks and Rods

The hooks and rods are also intended to provide stabilization to promote fusion following reduction of fracture/dislocation or trauma in the cervical/upper thoracic (C1-T3) spine.

Multi-axial Screws/Connectors

The use of multi-axial screws are limited to placement in T1-T3. The screws are not intended to be placed in the cervical spine.

Titanium ATLAS® Cable System to be used with the VERTEX® Reconstruction System allows for cable attachment to the posterior cervical or thoracic spine.

In order to achieve additional levels of fixation, the VERTEX® Reconstruction System may be connected to the CD HORIZON® Spinal System rods with the VERTEX® rod connectors. Refer to the CD HORIZON® Spinal System package insert for a list of the CD HORIZON® Spinal System indications of use.

Prescription Use × (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)

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

K110522 510(k) Number_

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