K Number
K133288
Device Name
CASPIAN OCT SPINAL SYSTEM
Manufacturer
Date Cleared
2014-07-01

(249 days)

Product Code
Regulation Number
888.3050
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The CASPIAN OCT / MESA Mini / DENALI Mini Spinal System is intended to provide stabilization as an adjunct to fusion of the cervical spine and occipito-cervico-thoracic junction (occiput-T3) when used with autograft or allograft and is indicated for the following: - DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies) - . Spondylolisthesis - . Spinal stenosis - Fracture/dislocation - . Revision of previous cervical spine surgery - . Tumors - Atlantoaxial fracture with instability - t Occipitocervical dislocation The occipital bone screws are limited to occipital fixation only. The rod and hook components are intended for use in the cervical/upper thoracic (C1-T3) spine. The pedicle screws are limited to placement in T1-T3 in treating thoracic conditions only. The pedicle screws are not intended to be placed in or treat conditions involving the cervical spine. The CASPIAN OCT / MESA Mini / DENALI Mini System can also be linked to the Range Spinal System using the 3.5mm/5.5mm rod connectors or transitional rods.
Device Description
The Caspian OCT Spinal System is a top-loading, multiple component, posterior (occipital-cervicalthoracic) spinal fixation system. The purpose of this submission is to add the Occipital Anchor to the system. Materials: The subject devices are manufactured from Ti6A14V Eli per ASTM and ISO standards. Function: The system functions as an adjunct to fusion to provide immobilization of the posterior cervical and thoracic spine.
More Information

Not Found

No
The document describes a mechanical spinal fixation system and does not mention any software, algorithms, or AI/ML capabilities.

Yes
The device is described as "intended to provide stabilization as an adjunct to fusion" for various spinal conditions, indicating it is used to treat or alleviate a medical condition, which is the definition of a therapeutic device.

No

The device is a spinal fixation system designed to provide stabilization as an adjunct to fusion, not to diagnose medical conditions.

No

The device description explicitly states it is a "multiple component, posterior (occipital-cervicalthoracic) spinal fixation system" and is manufactured from Ti6A14V Eli, indicating it is a hardware-based implantable device.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that the device is a spinal system intended to provide stabilization as an adjunct to fusion of the cervical spine and occipito-cervico-thoracic junction. This is a surgical implant used in vivo (within the body) to treat structural issues.
  • Device Description: The description details a mechanical fixation system made of titanium, designed to immobilize the spine. This is consistent with a surgical implant, not a diagnostic test performed in vitro (outside the body).
  • Lack of Diagnostic Elements: There is no mention of analyzing biological samples (blood, urine, tissue, etc.) or providing diagnostic information about a patient's condition. The device's function is purely mechanical support.
  • Performance Studies: The performance studies described are mechanical and biomechanical testing, which are relevant to the structural integrity and function of a surgical implant, not the accuracy of a diagnostic test.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device does not fit that description.

N/A

Intended Use / Indications for Use

The CASPIAN OCT / MESA Mini / DENALI Mini Spinal System is intended to provide stabilization as an adjunct to fusion of the cervical spine and occipito-cervico-thoracic junction (occiput-T3) when used with autograft or allograft and is indicated for the following:

  • DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies)
  • . Spondylolisthesis
  • . Spinal stenosis
  • Fracture/dislocation
  • . Revision of previous cervical spine surgery
  • . Tumors
  • Atlantoaxial fracture with instability
  • t Occipitocervical dislocation

The occipital bone screws are limited to occipital fixation only.

The rod and hook components are intended for use in the cervical/upper thoracic (C1-T3) spine. The pedicle screws are limited to placement in T1-T3 in treating thoracic conditions only. The pedicle screws are not intended to be placed in or treat conditions involving the cervical spine.

The CASPIAN OCT / MESA Mini / DENALI Mini System can also be linked to the Range Spinal System using the 3.5mm/5.5mm rod connectors or transitional rods.

Product codes (comma separated list FDA assigned to the subject device)

KWP

Device Description

The Caspian OCT Spinal System is a top-loading, multiple component, posterior (occipital-cervicalthoracic) spinal fixation system. The purpose of this submission is to add the Occipital Anchor to the system.

Materials: The subject devices are manufactured from Ti6A14V Eli per ASTM and ISO standards.

Function: The system functions as an adjunct to fusion to provide immobilization of the posterior cervical and thoracic spine.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cervical spine and occipito-cervico-thoracic junction (occiput-T3), occipital, C1-T3, T1-T3

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The subject components were mechanically tested and performed equally to or better than the original Caspian OCT Spinal constructs in static compression, static torsion and dynamic compression in accordance with ASTM F2706. The constructs were also compared in biomechanical (cadaver) testing and the devices were found to perform substantially the same.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K101084, K052402

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

0

510(k) Summary for the Caspian OCT Spinal System

This 510(k) summary for the Caspian OCT Spinal System is provided as required per Section 513(i)(3) of the Food, Drug and Cosmetic Act.

  1. Submitter : K2M, Inc. 751 Miller Drive SE. Suite FI Leesburg, VA 20175

Contact Person : Nancy Giezen K2M. Inc. Telephone: 703-777-3155

Date Prepared: 10/24/13

    1. Tradename:
      Common Name:

Classification Name:

Regulatory Class:

Device Product Code:

Caspian OCT Spinal System Spinal Fixation System Spinal Interlaminal Fixation Orthosis (21CFR 888.3050) KWP Class II

3. Predicate or legally marketed devices which are substantially equivalent :

  • K2M Caspian OCT Spinal System (K101084) .
  • Medtronic Vertex (K052402) t

4. Description of the device:

The Caspian OCT Spinal System is a top-loading, multiple component, posterior (occipital-cervicalthoracic) spinal fixation system. The purpose of this submission is to add the Occipital Anchor to the system.

Materials: The subject devices are manufactured from Ti6A14V Eli per ASTM and ISO standards.

Function: The system functions as an adjunct to fusion to provide immobilization of the posterior cervical and thoracic spine.

5. Intended Use:

The CASPIAN OCT / MESA Mini / DENALI Mini Spinal System is intended to provide stabilization as an adjunct to fusion of the cervical spine and occipito-cervico-thoracic junction (occiput-T3) when used with autograft or allograft and is indicated for the following:

  • 해 DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies)
  • . Spondylolisthesis
  • . Spinal stenosis
  • � Fracture/dislocation
  • . Revision of previous cervical spine surgery
  • . Tumors
  • � Atlantoaxial fracture with instability
  • t Occipitocervical dislocation

The occipital bone screws are limited to occipital fixation only.

K133288 Page 1 of 2

1

The rod and hook components are intended for use in the cervical/upper thoracic (C1-T3) spine. The pedicle screws are limited to placement in T1-T3 in treating thoracic conditions only. The pedicle screws are not intended to be placed in or treat conditions involving the cervical spine.

The CASPIAN OCT / MESA Mini / DENALI Mini System can also be linked to the Range Spinal System using the 3.5mm/5.5mm rod connectors or transitional rods.

  1. Comparison of the technological characteristics of the device to predicate and legally marketed devices : The subject components were mechanically tested and performed equally to or better than the original Caspian OCT Spinal constructs in static compression, static torsion and dynamic compression in accordance with ASTM F2706. The constructs were also compared in biomechanical (cadaver) testing and the devices were found to perform substantially the same.

There are no significant differences between the Caspian OCT Spinal System and other systems currently being marketed which would adversely affect the use of the product. It is substantially equivalent to these other devices in design, function, material and intended use.

2

Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which features a staff with a serpent entwined around it. The logo is surrounded 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

July 1, 2014

K2M, Incorporated Ms. Nancy Giezen Manager, Regulatory Affairs 751 Miller Drive SE, Suite Fl Leesburg, Virginia 20175

Re: K133288

Trade/Device Name: Caspian OCT Spinal System Regulation Number: 21 CFR 888.3050 Regulation Name: Spinal interlaminal fixation orthosis Regulatory Class: Class II Product Code: KWP Dated: May 30, 2014 Received: June 2, 2014

Dear Ms. Giezen:

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

3

Page 2 - Ms. Nancy Giezen

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 Industry and Consumer Education 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. 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 Industry and Consumer Education 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.

Sincercly yours.

Ronald P. Jean -S for

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

Enclosure

4

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K133288

Device Name Caspian OCT Spinal System

Indications for Use (Describe)

The CASPIAN OCT/MESA Mini Spinal System is intended to provide stabilization as an adjunct to fusion of the cervical spine and occipito-cervical-thoracic junction (occiput-T3) when used with autograft or allograft and is indicated for the following:

  • DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies):

  • -Spondylolisthesis;

  • -Spinal stenosis:

  • -Fracture/dislocation;

  • -Revision of previous cervical spine surgery;

  • -Tumors:

  • -Atlantoaxial fracture with instability;

  • -Occipitocervical dislocation

The occipital bone screws are limited to occipital fixation only.

The rod and hook components are intended for use in the cervical/upper thoracic (C1-T3) spine. The pedicle screws are limited to placement in T1-T3 in treating thoracic conditions only. The pedicle screws are not intended in or treat conditions involving the cervical spine.

The CASPIAN OCT/MESA Mini System can also be linked to the Range Spinal System using the 3.5mm/5.5mm rod connectors or transitional rods.

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

2 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) (Signature)

Division of Offhopedic Devices

5

This section applies only to requirements of the Paperwork Reduction Act of 1995.

1

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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