(81 days)
The S4 Spinal System is intended for anterior/anterolateral and posterior, non-cervical fixation in skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is intended to be used as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities:
- 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),
- spinal stenosis,
- deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
- tumor,
- pseudoarthrosis, and
- failed previous fusion.
The S4 Spinal System consists of polyaxial screws and monoaxial screws of varying in The SF Opinar Oystom "Oneice" or styles, rods of varying lengths, and fixed and various styles of rod connectors. All implant components are top loading and top tightening. The Styles of Four connectors: Annoufactured from Titanium alloy in accordance with 150 5832/3 and ISO 5832/2.
Acceptance Criteria and Device Performance Study for the S4 Spinal System
This document outlines the acceptance criteria and the study conducted to demonstrate the performance of the Aesculap® Implant Systems S4 Spinal System, specifically focusing on the line extension to add a new parallel rod connector.
1. Table of Acceptance Criteria and Reported Device Performance
| Test Type | Acceptance Criteria | Reported Device Performance |
|---|---|---|
| Static Axial Compression Bending | Performance at least equivalent to legally marketed predicate devices (implicitly, per ASTM F1717-11a) | The S4 Parallel Rod Connector demonstrated performance that met or exceeded the performance of the predicate devices. |
| Dynamic Axial Compression Bending | Performance at least equivalent to legally marketed predicate devices (implicitly, per ASTM F1717-11a) | The S4 Parallel Rod Connector demonstrated performance that met or exceeded the performance of the predicate devices. |
| Static Torsion | Performance at least equivalent to legally marketed predicate devices (implicitly, per ASTM F1717-11a) | The S4 Parallel Rod Connector demonstrated performance that met or exceeded the performance of the predicate devices. |
Note: The FDA guidance for spinal system 510(k) submissions recommends non-clinical testing to demonstrate substantial equivalence. The acceptance criteria for these tests are implicitly defined as demonstrating performance that is at least equivalent to the identified predicate devices.
2. Sample Size and Data Provenance
- Test Set Sample Size: Not explicitly stated in the provided documents. The studies likely involve a sufficient number of test samples to be statistically significant for mechanical tests as per ASTM standards, but the exact count is not given.
- Data Provenance: The studies were non-clinical mechanical tests conducted in a laboratory setting. The country of origin for the data is not specified but would typically be where these tests were performed (e.g., within Aesculap's facilities or a designated testing laboratory). This is retrospective data in the sense that it's generated for pre-market notification to compare a new device against existing standards and predicates.
3. Number of Experts and Qualifications for Ground Truth
- Not Applicable. For non-clinical mechanical performance testing of medical devices like spinal systems, "ground truth" is established through physical measurements and adherence to recognized industry standards (e.g., ASTM F1717-11a), rather than expert consensus on diagnostic images or clinical outcomes. The "experts" involved would be engineers and technicians proficient in conducting and interpreting these specific biomechanical tests.
4. Adjudication Method
- Not Applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or studies involving human interpretation of data (e.g., medical images). For mechanical testing, the results are quantitative and objective, measured directly from the physical testing.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No. An MRMC study is not relevant for this type of non-clinical mechanical performance testing. MRMC studies are used to assess the impact of a diagnostic or assistive AI device on human reader performance, which doesn't apply to the S4 Spinal System's mechanical properties.
6. Standalone Performance Study
- Yes. The described performance data focuses on the "subject Aesculap S4 Parallel Rod Connector" itself, indicating a standalone evaluation of its mechanical properties. The tests (Static Axial Compression Bending, Dynamic Axial Compression Bending, Static Torsion) evaluate the device's inherent mechanical performance against established ASTM standards and in comparison to predicate devices, without human interaction as part of the performance metric.
7. Type of Ground Truth Used
- Standardized Mechanical Test Results and Predicate Device Performance Data: The ground truth for these tests is based on the quantitative results obtained from applying recognized ASTM standards (ASTM F1717-11a) to the device and comparing these results to the known performance of legally marketed predicate devices. The "truth" is whether the new connector's performance metrics meet or exceed those of the established predicate devices under the specified test conditions.
8. Sample Size for the Training Set
- Not Applicable. This is a non-clinical mechanical performance study, not an AI or algorithm-based study that requires a training set.
9. How the Ground Truth for the Training Set Was Established
- Not Applicable. As no training set was used, this question is not applicable.
{0}------------------------------------------------
K112551 Page 1 of 2
510(k) SUMMARY (as required by 21 CFR 807.92) B.
Aesculap® Implant Systems S4 Spinal System August 31, 2011
| COMPANY: | Aesculap®Implant Systems, Inc.3773 Corporate ParkwayCenter Valley, PA 18034Establishment Registration Number: 3005673311 |
|---|---|
| CONTACT: | Lisa M. Boyle610-984-9274 (phone)610-791-6882 (fax) |
| TRADE NAME: | S4 |
| COMMON NAME: | S4 Spinal System |
888.3070 - Orthosis, Spinal Pedicle Fixation For REGULATION NUMBER: Degenerative Disc Disease 888.3070 - Orthosis, Spinal Pedicle Fixation 888.3070 - Orthosis, Spondyloisthesis Spinal Fixation 888.3050 - Appliance, Fixation, Spinal Fixation
NKB, MNI, MNH, and KWP PRODUCT CODE: REVIEW PANEL: Orthopedics
PURPOSE FOR PREMARKET NOTIFICATION
The S4 Spinal System described in this submission represents a line extension to the system. The purpose of the line extension is to add a new parallel rod connector.
SUBSTANTIAL EQUIVALENCE
SOBOTANTIAlle Systems, Inc. believes that the S4 Spinal System is substantially Aescular Implant Oyotents, Inter Be(K100623/K071945/K062085/K032219), and the Aesculap Spine System Evolution (K001080).
DEVICE DESCRIPTION
The S4 Spinal System consists of polyaxial screws and monoaxial screws of varying in The SF Opinar Oystom "Oneice" or styles, rods of varying lengths, and fixed and various styles of rod connectors. All implant components are top loading and top tightening. The Styles of Four connectors: Annoufactured from Titanium alloy in accordance with 150 5832/3 and ISO 5832/2.
INDICATIONS FOR USE
The S4 Spinal System is intended for anterior/anterolateral and posterior, non-cervical The Spinal Oyatin's limited to skeletally mature is limited to skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is intended to be used as an adjaring acute and chronic instabilities or deformities:
3
ﺃﻣ
{1}------------------------------------------------
K112551 Page 2 of 2
1 ) degenerative disc disease (defined as discogenic back pain with
1 ) Gogeneration of the disc confirmed by history and radiographic studies)
-
spondvlolisthesis.
-
trauma (i.e., fracture or dislocation),
-
spinal stenosis,
-
- Spinal Storioloj
-
deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
-
tumor,
-
pseudoarthrosis, and
-
failed previous fusion.
TECHNOLIGICAL CHARACTERISTICS(compared to Predicate(s))
The components of the Aesculap® Implant Systems S4 Spinal System are offered in similar shapes and sizes as the predicate devices. All the components are manufactured from Titanium and Titanium Alloy, which is the same material as the predicate devices.
PERFORMANCE DATA
As recommended by the FDA Guidance for Spinal System 510(k)'s, non-clinical testing was performed to demonstrate that the S4 Parallel Rod Connector is substantially equivalent to other predicate devices. The following testing was performed:
- Static Axial Compression Bending per ASTM 1717-11a .
- Dynamic Axial Compression Bending per ASTM F1717-11a .
- Static Torsion per ASTM 1717-11a .
The results of these studies showed that the subject Aesculap S4 Parallel Rod The redults of areaseds the performance of the predicate devices, and the device is therefore found to be substantially equivalent.
{2}------------------------------------------------
Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo features a stylized eagle with its wings spread, symbolizing protection and care. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are 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
NOV 2 1 2011
Aesculap Implant Systems, Inc. % Ms. Lisa M. Boyle 3773 Corporate Parkway Center Valley, Pennsylvania 18034
Re: K112551
Trade/Device Name: S4 Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNH, MNI, KWP Dated: November 17, 2011 Received: November 18, 2011
Dear Ms. Boyle:
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
{3}------------------------------------------------
Page 2 - Ms. Lisa M. Boyle
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 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/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Mark N. Melkerson
Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{4}------------------------------------------------
Page 1 of 1
INDICATIONS FOR USE STATEMENT A.
510(k) Number:__K1125551
Device Name: S4 Spinal System
Indications for Use:
The S4 Spinal System is intended for anterior/anterolateral and posterior, non-cervical is The S4 Spillar System is intended for aniention in limited to skeletally mature petients and is intended to be used as an adjunct to fusion using autograft or allograft. The device: is Intended to be used as an adjunct to factorial instabilities or deformities:
indicated for treatment of the following acute and chronic instabilities or deformities:
1 ) degenerative disc disease (defined as discogenic back pain with 1 ) degenerative disc also alsoulos (confirmed by history and radiographic studies)
-
spondylolisthesis,
-
trauma (i.e., fracture or dislocation),
-
spinal stenosis,
-
spirial stenosis,
-
deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
-
tumor,
-
pseudoarthrosis, and
-
failed previous fusion.
Prescription Use______________________________________________________________________________________________________________________________________________________________ (21 CFR 801 Subpart C) (Part 21 CFR 801 Subpart D)
(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_ | KII 2551 |
|---|---|
| ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
2
§ 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.