K Number
K123232
Manufacturer
Date Cleared
2013-02-07

(114 days)

Product Code
Regulation Number
888.3050
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Spineology Spinous Process Plate is a posterior, non-pedicle supplemental fixation device, intended for single level use in the non-cervical spine (T1 - S1). It is intended for single level plate fixation/attachment to spinous process for the purpose of achieving supplemental fusion in the following conditions:
• Degenerative disc disease - defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies.
• Trauma (i.e., fracture or dislocation)
• Spondylolisthesis
• Tumor
The Spineology Spinous Process Plate is not intended for stand-alone use.

Device Description

The Spineology Spinous Process Plate is a non-pedicle fixation device that clamps bilaterally to the spinous processes. The three-part titanium device is provided sterile and not intended for stand-alone use.

AI/ML Overview

Here's a breakdown of the acceptance criteria and study information for the Spineology Spinous Process Plate, based on the provided document:

Acceptance Criteria and Device Performance

Acceptance Criteria (Set by ASTM F1717 and internal testing)Reported Device Performance
Static Testing:Passed
- CompressionPassed
- TorsionPassed
Dynamic Testing:Passed
- CompressionPassed
- TorsionPassed
Static Dissociation TestingCompleted
Push-out from foam (plate grip strength) testingCompleted

Note: The document states that the testing was performed, and the overall conclusion is that the device is "substantially equivalent" in performance characteristics to the predicate products. It does not provide specific numerical thresholds or the exact numerical results for each test. Instead, it indicates successful completion and comparison to predicate devices, implying that the acceptance criteria tied to the performance of those predicate devices were met.

Study Information

  1. Sample size used for the test set and the data provenance:
    The document does not specify the sample size for any of the tests (static, dynamic, static dissociation, push-out). It also does not mention data provenance (e.g., country of origin, retrospective or prospective). The testing appears to be primarily mechanical/bench testing on the device itself.

  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
    Not applicable. This device underwent mechanical testing against established standards (ASTM F1717) and comparative testing against predicate devices. There is no mention of "ground truth" derived from human experts in the context of clinical or image-based assessment as this is a spinal implant.

  3. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
    Not applicable, as this was mechanical testing, not a clinical study involving human judgment that would require adjudication.

  4. 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:
    Not applicable. This document pertains to a spinal implant (mechanical device), not an imaging or AI-assisted diagnostic device. Therefore, an MRMC study or assessment of human reader improvement with AI assistance is irrelevant.

  5. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
    Not applicable. This is a physical medical device, not an algorithm or software. Its performance is assessed through mechanical and physical testing.

  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
    For the mechanical testing, the "ground truth" (or basis for comparison) was established engineering standards (ASTM F1717) and the performance of legally marketed predicate devices (CD HORIZON SPIRE™ and Lanx Aspen). The performance of the new device was compared to these established benchmarks to demonstrate substantial equivalence.

  7. The sample size for the training set:
    Not applicable. This is a physical medical device undergoing mechanical testing, not a machine learning model requiring a training set.

  8. How the ground truth for the training set was established:
    Not applicable, for the same reason as above.

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K123232
Page 1 of 1

FEB 7 2013

Appendix C510(k) Summary
Applicant:Spineology Inc.7800 3rd Street N., Suite 600Saint Paul, MN 55128651-256-8500
Contact Person:Bryan Becker
Date Prepared:October 15, 2012
Trade Name:Spineology Spinous Process Plate
Reason for This510(k):New device
ProductClassification andCode:Class II Medical Device, Product Code KWP, 21 CFR 888.3050, SpinalInterlaminal Fixation Orthosis
Predicate Device(s):CD HORIZON SPIRE™, Medtronic Sofamor Danek (K032037,K043053, and K102886) and Lanx Aspen, Lanx (K103091)
Device Description:The Spineology Spinous Process Plate is a non-pedicle fixation devicethat clamps bilaterally to the spinous processes. The three-part titaniumdevice is provided sterile and not intended for stand-alone use.
Intended Use:The Spineology Spinous Process Plate is a posterior, non-pediclesupplemental fixation device, intended for single level use in the non-cervical spine (T1 - S1). It is intended for single level platefixation/attachment to spinous process for the purpose of achievingsupplemental fusion in the following conditions:• Degenerative disc disease - defined as back pain of discogenicorigin with degeneration of the disc confirmed by history andradiographic studies.• Trauma (i.e., fracture or dislocation)• Spondylolisthesis• TumorThe Spineology Spinous Process Plate is not intended for stand-alone use.
Summary ofTechnologicalCharacteristics:The device is shown to be substantially equivalent to the intended use,materials, configuration, and performance characteristics of the predicateproducts.
Testing:Static (compression and torsion) and dynamic (compression and torsion)testing was performed per ASTM F1717. Static dissociation testing andpush-out from foam (plate grip strength) was also completed.
Conclusion:The information submitted in this premarket notification supports adetermination that the Spineology Spinous Process Plate is substantiallyequivalent in technological characteristics and intended use to thepredicate device.

.

ﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨﻨ ":"

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Image /page/1/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 forming its body and wings. The logo is encircled by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

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

Letter dated: February 7, 2013

Spineology Incorporated % Mr. Bryan Becker Regulatory Affairs Manager 7800 310 Street North, Suite 600 Saint Paul, Minnesota 55128

Re: K123232

Trade/Device Name: Spineology Spinous Process Plate Regulation Number: 21 CFR 888.3050 Regulation Name: Spinal interlaminal fixation orthosis Regulatory Class: Class II Product Code: KWP Dated: January 4, 2013 Received: January 8, 2013

Dear Mr. Becker:

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 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

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Page 2 - Mr. Bryan Becker

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/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Mark N. Melkerson

  • Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
    Enclosure

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Appendix D Indications for Use Form

510(k) Number(if known): K123232

· Device Name: The Spineology Spinous Process Plate

Indications for Use:

The Spineology Spinous Process Plate is a posterior, non-pedicle supplemental fixation device, intended for single level use in the non-cervical spine (T1 - S1). It is intended for single level plate fixation/attachment to spinous process for the purpose of achieving supplemental fusion in the following conditions:

  • · Degenerative disc disease defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies.
  • · Trauma (i.e., fracture or dislocation)
  • Spondylolisthesis
  • · Tumor

The Spineology Spinous Process Plate is not intended for stand-alone use.

Prescription Use Xবে বিশ্বকাপের প্রকল্পে করে বিশ্বকাপে বিশ্বকাপ বিশ্বকাপ থেকে বিশ্বকাপ করে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে পারে। এরপর পর পর পর পর করAND/OR
(Part 21 CFR 801 Subpart D)

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)

Ronald P. Jean -S

(Division Sign-Off) Division of Orthopedic Devices 510(k) Number: K123232

Page 1 of 1

§ 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.