The PressON Spinal Fixation System is a posterior, non-cervical pedicle screw system intended to provide immobilization and stabilization of spinal segments that can accept a device construct up to 80mm in length 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 including degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis).

In addition, this device is a pedicle screw system indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to S1) with removal of the implants after the attainment of a solid fusion.

Device Description

The PressON Spinal Fixation System is composed of pedicle screws and rods. These components can be assembled and implanted using associated instruments via a posterior approach into the pedicles of the noncervical vertebral bodies. Components are made from Ti-6Al-4V ELI (ASTM F-136).

AI/ML Overview

Here's a breakdown of the acceptance criteria and study information based on the provided document:

The document describes the PressON Spinal Fixation System, a Class II pedicle screw spinal system (21 CFR 888.3070 (b) (1)). It highlights its substantial equivalence to predicate devices in terms of materials, design, indications for use, and operational principles.

Acceptance Criteria and Device Performance:

The acceptance criteria for the PressON Spinal Fixation System are based on its substantial equivalence to legally marketed predicate devices through performance testing. The reported device performance indicates that the system meets these criteria.

Acceptance Criteria	Reported Device Performance
Static Flexion-Extension Loading (per ASTM F1798-97(2008))	Indicates substantial equivalence to predicate devices.
Static Anterior Posterior Loading (per ASTM F1798-97(2008))	Indicates substantial equivalence to predicate devices.
Static Compression Bending (per F1717-13)	Indicates substantial equivalence to predicate devices.
Static Torsion (per F1717-13)	Indicates substantial equivalence to predicate devices.
Dynamic Compression Bending (per F1717-13)	Indicates substantial equivalence to predicate devices.

Study Details:

Sample Size for the Test Set and Data Provenance:
- The document does not specify a sample size for a "test set" in the context of clinical data for AI or diagnostic purposes. The studies mentioned are mechanical and material performance tests (static and dynamic loading) conducted on the device itself.
- The data provenance is from mechanical testing labs (implied, not explicitly stated as country of origin, but generally conducted in a controlled lab environment). These are prospective mechanical tests conducted on the device components.
Number of Experts and Qualifications for Ground Truth of Test Set:
- This information is not applicable (N/A) as the study is a mechanical performance verification and not a clinical study requiring expert assessment for diagnostic ground truth.
Adjudication Method for the Test Set:
- This information is not applicable (N/A) for mechanical performance testing.
Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No, an MRMC comparative effectiveness study was not done. This type of study is for comparing human readers with and without AI assistance in diagnostic tasks, which is not relevant for this device.
Standalone (Algorithm Only) Performance Study:
- No, a standalone algorithm performance study was not done. This device is a physical medical implant (spinal fixation system), not a software algorithm or AI-based diagnostic tool.
Type of Ground Truth Used:
- The "ground truth" for the mechanical performance studies is the established performance standards and criteria defined by the ASTM F1798-97(2008) and F1717-13 standards, and the comparative performance of the predicate devices. The device's ability to withstand these defined forces and loads, and perform comparably, establishes its "truth" of efficacy in this context.
Sample Size for the Training Set:
- This information is not applicable (N/A). There is no training set mentioned in the context of AI or machine learning for this physical product.
How Ground Truth for the Training Set Was Established:
- This information is not applicable (N/A) for the same reason as above.

Summary

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FEB 2 5 2014

Submitter:	Nexus Spine LLC
Contact Person:	Mr. Chris Harmston, Director of Quality and Regulatory Affairs2825 East Cottonwood Parkway Suite 330Salt Lake City, UT 84121Telephone: (801) 742-8342Fax: (801) 702-8585
Date Prepared:	February 24, 2014
Trade Name:	PressON Spinal Fixation System
Classification, Nameand Number:	Class IIPedicle Screw Spinal System21 CFR 888.3070 (b) (1)
Product Code:	MNI and MNH
Predicate Device(s):	The subject device is substantially equivalent to the following devices:
	OvalTwist Pedicle Screw SystemSignus Medizintechnik GMBH510(k) number K061577
	DePuy AcroMed MOSS Miami Spinal SystemDePuy Acromed Inc.510(k) number K983583
	TSRH Spinal SystemMedtronic Sofamor Danek USA510(k) number K081080
	EBI SpineLink SystemEBI, L.P.510(k) number K992920
	NuVasive SpheRx DBR II SystemNuVasive, Inc510(k) number K083028
Device Description:	The PressON Spinal Fixation System is composed of pedicle screws androds. These components can be assembled and implanted using associatedinstruments via a posterior approach into the pedicles of the noncervical
	vertebral bodies. Components are made from Ti-6Al-4V ELI (ASTM F-136).
Intended Use:	The PressON Spinal Fixation System is a posterior, non-cervical pediclescrew system intended to provide immobilization and stabilization of spinalsegments that can accept a device construct up to 80mm in length inskeletally mature patients as an adjunct to fusion in the treatment of thefollowing acute and chronic instabilities or deformities of the thoracic,lumbar, and sacral spine including degenerative spondylolisthesis withobjective evidence of neurological impairment, fracture, dislocation,scoliosis, kyphosis, spinal tumor, and failed previous fusion(pseudarthrosis).
	In addition, this device is a pedicle screw system indicated for the treatmentof severe spondylolisthesis (Grade 3 and 4) of the L5-S1 vertebra inskeletally mature patients receiving fusion by autogenous bone graft havingimplants attached to the lumbar and sacral spine (L3 to S1) with removal ofthe implants after the attainment of a solid fusion.
Statement ofTechnologicalComparison:	The PressON Spinal Fixation System is substantially equivalent tothe above listed predicate devices in terms of materials, design,indications for use and operational principles.
Performance Data:	Verification activities including static flexion-extension loading and staticanterior posterior loading tests per ASTM F1798-97(2008), and staticcompression bending, static torsion and dynamic compression bending testsper F1717-13 indicate PressON Spinal Fixation System is substantiallyequivalent to predicate devices.
Conclusion:	Documentation provided demonstrates the PressON Spinal Fixation Systemis substantially equivalent to predicate devices.

510(k) Summary

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Comments of Children

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus, a symbol often associated with medicine and healthcare. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus.

Public Health Service

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

February 25, 2014

Nexus Spine, LLC Mr. Chris Harmston Director of Quality and Regulatory Affairs 2825 East Cottonwood Parkway, Suite 330 Salt Lake City, Utah 84121

Re: K133287

Trade/Device Name: PressON Spinal Fixation System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class II Product Code: MNH, MNI Dated: January 27, 2014 Received: January 28, 2014

Dear Mr. Harmston:

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. Chris Harmston

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 tollfree 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/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,

Vincent J. Devlin -S

for

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

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: December 31, 2013 See PRA Statement on last page.

510(k) Number (if known)

K133287

Device Name PressON Spinal Fixation System

Indications for Use (Describe)

The PressON Spinal Fixation System is a posteried pedicte serew system intended to provide immobilization and stabilization of spinal segments that canstruct up to 80mm in length in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities of the thoracic, lumbar, and sacral spine including degeneralive spondylolises with objective evidencent, fracture, discoving scoliosis, kyphosis, spinal tumor, and failed previous fusion (pscudarthrosis).

In addition, this device is a pedicle sorev system indicated for the treatment of severe spondy holist the 1.5-S i vertebra in skeletally mature patients receiving for anongenous bone graft having implants attached to the lumbar and sacral spine (1.3 to SI) with removal of the implants after the attainment of a solid fusion.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signalure)

FORM FDAY88884 (9/13)

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Regulation Number and Section

§ 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.