K Number
K131321
Date Cleared
2013-06-05

(28 days)

Product Code
Regulation Number
888.3070
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The CD HORIZON® Spinal System with or without SEXTANT® instrumentation is intended for posterior, non-cervical fixation as an adjunct to fusion for the following indications; degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis and/or lordosis); tumor; pseudarthrosis; and/or failed previous fusion.

Except for hooks, when used as an anterolateral thoracic/lumbar system. the CD HORIZON® Spinal System may also be used for the same indications as an adjunct to fusion.

With the exception of degenerative disc disease, the CD HORIZON® LEGACY™ 3.5mm rods and the CD HORIZON® Spinal System PEEK rods and associated components may be used for the aforementioned indications in skeletally mature patients as an adjunct to fusion. The 3.5mm rods may be used for the specific pediatric indications noted below.

When used for posterior non-cervical pedicle screw fixation in pediatric patients, the CD HORIZON® Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally, the CD HORIZON® Spinal System is intended to treat pediatric patients diagnosed with the following conditions: spondylolisthesis/spondylolysis and fracture caused by tumor and/or trauma. These devices are to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

The CD HORIZON® SPIRE™ Plate is a posterior, single level, non-pedicle supplemental fixation device intended for use in the non-cervical spine (F1-S1) as an adjunct to fusion in skeletally mature patients," It is intended for plate fixation/attachment to spinous processes for the purpose of achieving supplemental fixation in the following conditions: degenerative disc disease (as previously defined); spondylolisthesis; trauma; and/or tumor.

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

Device Description

The CD HORIZON® Spinal System consists of a variety of shapes and sizes of rods, hooks, screws, CROSSLINK® Plates, staples and connecting components, as well as implant components from other Medtronic spinal systems, which can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.

A subset of CD HORIZON® Spinal System components may be used for posterior pedicle screw fixation in pediatric cases. These constructs may be comprised of a variety of shapes and sizes of rods (ranging in diameter from 3.5mm to 6.35mm), hooks, screws, CROSSLINK® Plates, and connecting components. Similarly to the CD HORIZON® implants used in adult cases, these components can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.

The system also includes various instruments used to assist in the implantation of the system via minimally invasive approaches.

The purpose of this submission is to modify Medtronic's CD HORIZON® Spinal System to add additional lined rods to the system, specifically, 5.5mm and 6.0mm lined rods in cobalt chrome, and a 6.35mm lined rod in titanium alloy.

AI/ML Overview

Here's an analysis of the provided text regarding the acceptance criteria and study for the CD HORIZON® Spinal System, structured according to your request:

It's important to preface this by stating that this document is a 510(k) summary for a spinal implant system, not a medical device that generates data (like an AI algorithm or diagnostic tool). Therefore, many of the requested points, particularly those related to machine learning studies (e.g., test sets, ground truth establishment, expert consensus, MRMC studies), are not applicable to this type of submission. This document focuses on the mechanical and material properties of the device and its substantial equivalence to previously cleared devices.


Acceptance Criteria and Device Performance Study for CD HORIZON® Spinal System (K131321)

This 510(k) pertains to a modification of an existing spinal system, specifically the addition of new sizes of lined rods. The "acceptance criteria" here are primarily based on the demonstration that these new components do not introduce new risks and maintain the fundamental scientific technology and performance characteristics of the predicate devices.

1. A table of acceptance criteria and the reported device performance

Acceptance Criteria CategorySpecific Criteria (Implied)Reported Device Performance
Safety - Absence of New RisksNo new risks are introduced by the additional lined rods."Verification and validation activities demonstrated that no new risks have been introduced..."
Performance - Worst Case ScenarioThe addition of lined rods does not create a new worst-case scenario for the overall system."...and that the addition of the subject lined rods does not create a new worst case for the overall CD HORIZON® Spinal System."
Material EquivalenceNew rods are manufactured from same biocompatible materials as predicate.New rods manufactured from "same cobalt chromium alloy per ASTM F1537 and titanium alloy per ASTM F136 as the predicate rods."
Dimensional & Design EquivalencNew rods have similar fundamental scientific technology, dimensions (diameter, length) to predicate.New rods have "the same fundamental scientific technology," are "5.5mm, 6.0mm and 6.35mm in diameter, and are 500-700mm in length." The lining is a "visual aid."
Substantial EquivalenceThe modified device is substantially equivalent to legally marketed predicate devices."Medtronic believes the subject CD HORIZON® Spinal System, including the subject lined rods, to be substantially equivalent to legally marketed predicate devices..." (FDA concurs with this finding in the closing statement).

2. Sample size used for the test set and the data provenance

  • Not applicable. This submission is for mechanical components, not an algorithm or diagnostic device tested on clinical data. The "test set" here refers to components undergoing non-clinical (e.g., mechanical, materials) testing, not a patient dataset.
  • The document implies that testing was conducted on manufactured components, but does not specify the sample size of tested rods, nor does it refer to "countries of origin of data" or "retrospective/prospective" studies in a clinical data sense. The provenance of the testing data would be internal Medtronic labs.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

  • Not applicable. "Ground truth" in the context of expert consensus on diagnostic images or clinical outcomes is not relevant here. The "ground truth" for this device would be established engineering standards, material specifications (e.g., ASTM standards), and established biomechanical performance metrics for spinal implants. Expertise would come from engineers, materials scientists, and quality assurance personnel involved in device design and testing, not clinical experts establishing a ground truth from patient data.

4. Adjudication method for the test set

  • Not applicable. Adjudication methods like "2+1" or "3+1" are used for resolving discrepancies in expert interpretations of clinical data or image annotations. This is not performed for mechanical device testing. Compliance with engineering standards and specifications would be internally verified and validated.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, how much human readers improve with AI vs without AI assistance.

  • Not applicable. This is a hardware implant, not an AI-powered diagnostic or assistive tool. Therefore, MRMC studies are completely irrelevant to this submission.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done.

  • Not applicable. This is a hardware implant. There is no algorithm or standalone performance to evaluate.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

  • For this type of device, the "ground truth" relies on engineering specifications, material science standards (e.g., ASTM F1537 for cobalt chromium, ASTM F136 for titanium alloy), and biomechanical testing standards. The goal is to demonstrate that the new components meet these established engineering criteria and perform comparably to predicate devices in terms of mechanical integrity, fatigue strength, and biocompatibility.

8. The sample size for the training set

  • Not applicable. There is no "training set" as this is not a machine learning model.

9. How the ground truth for the training set was established

  • Not applicable. As there is no training set, there is no ground truth to establish for it in this context.

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K131321 :: page 1 of 4

CD HORIZON® Spinal System 510(k) Summary May 7, 2013

JUN 0 5 2013 -

Medtronic Sofamor Danek USA, Inc. I. Company: 1800 Pyramid Place Memphis, TN 38132 (901) 396-3133

Lauren Kamer II. Contact: Senior Regulatory Affairs Specialist ,

III. Proprietary Trade Name: CD HORIZON® Spinal System

IV. Common Name:Spinal Fixation Appliance, Spinal Fixation Orthosis
V. Classification Name:Spinal Interlaminal Fixation Orthosis,Spinal Intervertebral Body Fixation Orthosis,
and Pedicle Screw Spinal System(21 CFR 888.3050, 888.3060 and 888.3070)
Classification:Class III (Pre-amendment)
Product Codes:NKB, KWP, KWQ, MNH, MNI, and OSH

VI. Product Description

The CD HORIZON® Spinal System consists of a variety of shapes and sizes of rods, hooks, screws, CROSSLINK® Plates, staples and connecting components, as well as implant components from other Medtronic spinal systems, which can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.

A subset of CD HORIZON® Spinal System components may be used for posterior pedicle screw fixation in pediatric cases. These constructs may be comprised of a variety of shapes and sizes of rods (ranging in diameter from 3.5mm to 6.35mm), hooks, screws,

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CROSSLINK® Plates, and connecting components. Similarly to the CD HORIZON® implants used in adult cases, these components can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.

The system also includes various instruments used to assist in the implantation of the system via minimally invasive approaches.

The purpose of this submission is to modify Medtronic's CD HORIZON® Spinal System to add additional lined rods to the system, specifically, 5.5mm and 6.0mm lined rods in cobalt chrome, and a 6.35mm lined rod in titanium alloy.

VII. Indications for Use

The CD HORIZON® Spinal System with or without SEXTANT® instrumentation is intended for posterior, non-cervical fixation as an adjunct to fusion for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis and/or lordosis); tumor; pseudarthrosis; and/or failed previous fusion.

Except for hooks, when used as an anterolateral thoracic/lumbar system, the CD HORIZON® Spinal System may also be used for the same indications as an adjunct to fusion. :

With the exception of degenerative disc disease, the CD HORIZON® LEGACY™ 3.5mm rods and the CD HORIZON® Spinal System PEEK rods and associated components may be used for the aforementioned indications in skeletally mature patients as an adjunct to fusion. The 3.5mm rods may be used for the specific pediatric indications noted below.

When used for posterior non-cervical pedicle screw fixation in pediatric patients, the CD HORIZON® Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally, the CD HORIZON® Spinal System is intended to treat pediatric patients diagnosed with the following conditions: : spondylolisthesis/spondylolysis and fracture caused by tumor and/or trauma. These devices are to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

{2}------------------------------------------------

  • The CD HORIZON® SPIRE™ Plate is a posterior, single level, non-pedicle supplemental fixation device intended for use in the non-cervical spine (TI-S!) as an adjunct to fusion in skeletally mature patients. It is intended for plate fixation/attachment to spinous processes for the purpose of achieving supplemental fixation in the following conditions: degenerative disc disease (as previously defined); spondylolisthesis; trauma; and/or tumor.
    In order to achieve additional levels of fixation, the CD HORIZON® Spinal System rods may be connected to the VERTEX® Reconstruction System with the VERTEX® rod connector. Refer to the VERTEX® Reconstruction System Package Insert for a list of the VERTEX® indications of use.

VIII. Summary of Technological Characteristics

The subject CD HORIZON® Spinal System, including the additional lined rods, has the same fundamental scientific technology as the predicate CD HORIZON® Spinal System. Like the predicate CD HORIZON® Spinal System rods, the subject rods are 5.5mm, 6.0mm and 6.35mm in diameter, and are 500-700mm in length. The subject rods are manufactured from the same cobalt chromium alloy per ASTM F1537 and titanium alloy per ASTM F136 as the predicate rods. The subject rods are lined to provide a visual aid to the surgeon when contouring the rod in a certain plane

IX. Identification of the Legally Marketed Predicate Devices Used to Claim Substantial Equivalence

The design features, materials, labeling, and indications for use of the subject devices are substantially equivalent to devices previously cleared as part of CD HORIZON® Spinal System (K113174, SE Nov 21, 2011; K121680, SE Jul 5, 2012; K043488, SE Mar 21, 2005; K040962; SE May 14, 2004; K042025, SE Aug 25, 2004).

X. Brief Discussion of the Non-Clinical Tests Submitted

A risk analysis of the device modifications was completed in accordance with Medtronic design control procedures. Verification and validation activities demonstrated that no new risks have been introduced to CD HORIZON® Spinal System by the addition of the subject lined rods, and that the addition of the subject lined rods does not create a new worst case for the overall CD HORIZON® Spinal System. The previously submitted testing for CD HORIZON® LEGACY™ 4.5 devices still applies.

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XI. Conclusions Drawn from the Non-Clinical Tests

Verification and validation activities demonstrated that no new risks have been introduced to CD HORIZON® Spinal System by the addition of the subject lined rods, and that the addition of the subject lined rods does not create a new worst case for the overall CD HORIZON® Spinal System. Therefore, Medtronic believes the subject CD HORIZON® Spinal System, including the subject lined rods, to be substantially equivalent to legally marketed predicate devices, including the predicate CD HORIZON® Spinal System.

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Image /page/4/Picture/1 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" arranged around the perimeter. Inside the circle is a stylized image of an eagle with its wings spread, facing to the right.

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

June 5, 2013

Medtronic Sofamor Danek USA, Incorporated % Ms. Lauren Kamer Senior Regulatory Affairs Specialist 1800 Pyramid Place Memphis, Tennessee 38132

'Re: K131321

Trade/Device Name: CD HORIZON® Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, OSH, MNH, MNI, KWP, KWQ Dated: May 7, 2013 Received: May 8, 2013

Dear Ms. Kamer:

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. Lauren Kamer

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 contact 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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/ReportalProblem/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.

Erin Keith

For

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

Enclosure

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510(k) Number (if known): K131321

Device Name: CD HORIZON® Spinal System

Indications for Use:

The CD HORIZON® Spinal System with or without SEXTANT® instrumentation is intended for posterior, non-cervical fixation as an adjunct to fusion for the following indications; degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis and/or lordosis); tumor; pseudarthrosis; and/or failed previous fusion.

Except for hooks, when used as an anterolateral thoracic/lumbar system. the CD HORIZON® Spinal System may also be used for the same indications as an adjunct to fusion.

With the exception of degenerative disc disease, the CD HORIZON® LEGACY™ 3.5mm rods and the CD HORIZON® Spinal System PEEK rods and associated components may be used for the aforementioned indications in skeletally mature patients as an adjunct to fusion. The 3.5mm rods may be used for the specific pediatric indications noted below.

When used for posterior non-cervical pedicle screw fixation in pediatric patients, the CD HORIZON® Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally, the CD HORIZON® Spinal System is intended to treat pediatric patients diagnosed with the following conditions: spondylolisthesis/spondylolysis and fracture caused by tumor and/or trauma. These devices are to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

The CD HORIZON® SPIRE™ Plate is a posterior, single level, non-pedicle supplemental fixation device intended for use in the non-cervical spine (F1-S1) as an adjunct to fusion in skeletally mature patients," It is intended for plate fixation/attachment to spinous processes for the purpose of achieving supplemental fixation in the following conditions: degenerative disc disease (as previously defined); spondylolisthesis; trauma; and/or tumor.

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

Prescription Use X (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 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

Page 1 of 1

(Division Sign-Off) Division of Orthopedic Devices 510(k) Number: K131321

§ 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.