(64 days)
The S4 Spinal System is intended for anterior/anterolateral and posterior, non-cervical pedicle and non-pedicle fixation. Fixation is limited to skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is indicated for treatment of the following acute and chronic instabilities or deformities:
1 ) degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies)
2) spondylolisthesis,
3) trauma (i.e., fracture or dislocation),
4) spinal stenosis,
5) deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
6) tumor,
7) pseudoarthrosis, and
8) failed previous fusion.
The S4 Spinal System consists of polyaxial screws and monoaxial screws of varying diameters and lengths, various hook styles, rods of varying lengths, fixed and adjustable cross-connectors, and various styles of rod connectors. All implant components are top loading and top tightening. The S4 Spinal System is manufactured from Titanium and Titanium alloy in accordance with ISO 5832/3 and ISO 5832/2.
The provided document describes the Aesculap® Implant Systems (AIS) S4 Spinal System Modification Lateral Offset Connectors and its premarket notification (K130291). The study proving the device meets acceptance criteria is a non-clinical performance study comparing the modified device to predicate devices.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (What was measured) | Reported Device Performance |
|---|---|
| Static Axial Compression Bending (per ASTM F1717-12) | "meet or exceed the performance of the predicate devices" |
| Dynamic Axial Compression Bending (per ASTM F1717-12) | "meet or exceed the performance of the predicate devices" |
| Static Torsion (per ASTM F1717-12) | "meet or exceed the performance of the predicate devices" |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: Not explicitly stated. The document mentions "non-clinical testing" was performed, which typically suggests a laboratory-based test with a specific number of samples for each test type, but the exact count is not provided.
- Data Provenance: Not applicable in the context of clinical data. This refers to laboratory-based mechanical performance testing.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Not applicable. This was a non-clinical, mechanical performance study, not a study requiring expert clinical assessment for ground truth. The "ground truth" here is the physical performance data itself, measured according to industry standards.
4. Adjudication Method for the Test Set
- Not applicable. This was a non-clinical, mechanical performance study. Adjudication methods are typically associated with clinical studies involving interpretation of data or images by multiple experts.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
- No. This document describes a non-clinical mechanical performance study, not a clinical MRMC study.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
- Not applicable. This device is a physical spinal implant component, not an algorithm or AI system.
7. The Type of Ground Truth Used
- Mechanical performance data a per ASTM standards: The ground truth for this study was the quantifiable mechanical performance (e.g., strength, stiffness, fatigue resistance) measured according to the specified ASTM F1717-12 standards.
8. The Sample Size for the Training Set
- Not applicable. This was a mechanical performance study, not a machine learning or AI study that would typically involve a "training set."
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As above, this was a mechanical performance study, not an AI study.
Summary of the Study:
The study conducted was a non-clinical performance study on the S4 Lateral Offset Rod Connectors. It involved standardized mechanical tests (Static Axial Compression Bending, Dynamic Axial Compression Bending, and Static Torsion) as recommended by FDA Guidance for Spinal System 510(k)s and according to ASTM F1717-12. The acceptance criterion was that the modified device "meet or exceed the performance of the predicate devices" in these tests. The results demonstrated that the device successfully met this criterion, leading to a determination of substantial equivalence.
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K130291 - Page 1 of 2
Traditional 510(k) Premarket Notification
S4 Spinal System Modification Lateral Offset Connectors
510(k) SUMMARY (as required by 21 CFR 807.92)
Aesculap® Implant Systems (AIS) S4 Spinal System January 31, 2013
| COMPANY: | Aesculap®Implant Systems (AIS), LLC.3773 Corporate ParkwayCenter Valley, PA 18034Establishment Registration Number: 3005673311 |
|---|---|
| CONTACT: | Lisa M. Boyle, Sr Regulatory Affairs Specialist610-984-9274 (phone)610-791-6882 (fax)lisa.boyle@aesculap.com |
| TRADE NAME:COMMON NAME: | S4 Spinal SystemPedicle Screw System |
| REGULATION NUMBER: | 888.3070 - Orthosis, Spinal Pedicle Fixation ForDegenerative Disc Disease888.3070 -Orthosis, Spinal Pedicle Fixation888.3070 - Orthosis, Spondyloisthesis Spinal Fixation888.3050 -Appliance, Fixation, Spinal Fixation |
| PRODUCT CODE:REVIEW PANEL: | NKB, MNI, MNH, and KWP.Orthopedics |
INDICATIONS FOR USE
The S4 Spinal System is intended for anterior/anterolateral and posterior, non-cervical pedicle and non-pedicle fixation. Fixation is limited to skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is indicated for treatment of the following acute and chronic instabilities or deformities:
1 ) degenerative disc disease (defined as discogenic back pain with
degeneration of the disc confirmed by history and radiographic studies) 2) 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.
DEVICE DESCRIPTION
The S4 Spinal System consists of polyaxial screws and monoaxial screws of varying diameters and lengths, various hook styles, rods of varying lengths, fixed and adjustable cross-connectors, and various styles of rod connectors. All implant components are top
APR 1 1 2013
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Traditional 510(k) Premarket Notification
S4 Spinal System Modification Lateral Offset Connectors
Page 2 of 2
loading and top tightening. The S4 Spinal System is manufactured from Titanium and Titanium alloy in accordance with ISO 5832/3 and ISO 5832/2.
TECHNOLIGICAL CHARACTERISTICS(compared to Predicate(s))
The components of the Aesculap® Implant Systems S4 Spinal System are offered in similar shapes and sizes, and have the same indications 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 Lateral Offset Rod Connectors are substantially equivalent to other predicate devices. The following testing was performed:
- Static Axial Compression Bending per ASTM 1717-12 .
- Dynamic Axial Compression Bending per ASTM F1717-12 •
- Static Torsion per ASTM 1717-12 .
The results of these studies showed that the subject Aesculap S4 Lateral Offset Rod Connectors meet or exceed the performance of the predicate devices, and the device is therefore found to be substantially equivalent.
SUBSTANTIAL EQUIVALENCE
Aesculap® Implant Systems, Inc. believes that the S4 Spinal System is substantially equivalent to rod connectors from the S4 Spinal System (K123352/K112551/K062085) and the Depuy Spine Expedium Systems (K033901, K063156, K073126, K073364, and K081898).
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle with three stripes forming its body and wings. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 11, 2013
Aesculap® Implant Systems, LLC % Ms. Lisa M. Boyle Senior Regulatory Affairs Specialist 3773 Corporate Parkway Center Valley, Pennsylvania 18034
Re: K130291
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, MNI, MNH, KWP Dated: February 18, 2013 Received: February 19, 2013
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 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 - Ms. Lisa Boyle
の 2017年 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00 - 10:00
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.
Image /page/3/Picture/6 description: The image shows the text "Erin F.D. Keith". The text is in a bold, sans-serif font. The letters "F.D." are stylized with a geometric pattern. The text is black and the background is white.
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Traditional 510(k) Premarket Notification
S4 Spinal System Modification Lateral Offset Connectors
K130291 - Page 1 of 1
INDICATIONS FOR USE STATEMENT
510(k) Number: K130291
Device Name: S4 Spinal System
Indications for Use:
The S4 Spinal System is intended for anterior/anterolateral and posterior, non-cervical pedicle and non-pedicle fixation. Fixation is limited to skeletally mature patients and is intended to be used as an adjunct to fusion using autograft or allograft. The device is indicated for treatment of the following acute and chronic instabilities or deformities:
1 ) 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.
Prescription Use _ X _ _ X _ _ _ _ _ and/or _
(Part 21 CFR 801 Subpart D)
(21 CFR 801 Subpart C)
Over-the-Counter Use
(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: K130291
§ 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.