The General Spinal System is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients. It provides stabilization and immobilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities deformities: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, kyphosis, and/or lordosis), (3) spinal tumor, (4) failed previous fusion, (5) pseudarthrosis, (6) spinal stenosis. It is not intended for pedicle screw fixation above T8.

Device Description

The General Spinal System consists of Fixed-Angle Screws, Fix-Angle Reduction Screws, Hooks, Rods, Cross Link and Set Screws. It is made of Titanium Alloy (Ti6Al4VELI), which meets ASTM F136-02a, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Allov for Surgical Implant Applications. which are widely used for surgical implants with well known biocompatibility. The proposed devices are provided non-sterile. It is required to be sterilized via autoclave method to reach a SAL of 10 by the hospital prior to surgery. The recommended sterilization method was validated per ISO 17665-1: 2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices

AI/ML Overview

This document describes the General Spinal System, a pedicle screw spinal system. The primary method of demonstrating acceptance criteria for this device is through non-clinical testing, specifically mechanical performance testing, and comparison to a legally marketed predicate device to establish substantial equivalence.

1. Table of Acceptance Criteria and Reported Device Performance

Parameter	Acceptance Criteria (Standard)	Reported Device Performance (Test Results)
Mechanical Performance	ASTM F1717-04: Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model	Complies with the standard.
Static compression bending	As per ASTM F1717-04	Met specifications.
Dynamic compression bending	As per ASTM F1717-04	Met specifications.
Static torsion	As per ASTM F1717-04	Met specifications.
Material Biocompatibility	ASTM F136-02a: Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications	Made of Titanium Alloy (Ti6Al4VELI) meeting this standard, confirming well-known biocompatibility.
Sterilization Efficacy	ISO 17665-1:2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices	Recommended sterilization method was validated to reach a SAL (Sterility Assurance Level) of 10^-6.

2. Sample Size Used for the Test Set and Data Provenance

Sample Size for Test Set: The document does not specify exact sample sizes (e.g., number of constructs tested) for each mechanical test performed under ASTM F1717-04. It only states that "Non clinical tests were conducted to verify that the proposed device met all design specifications."
Data Provenance: The tests are non-clinical (laboratory tests) conducted by Tianjin Walkman Biomaterial Co., Ltd. in China. The data provenance is internal testing, not patient data.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications

This information is not applicable. The "ground truth" for non-clinical performance evaluations of medical devices like spinal systems is typically established by recognized national/international standards (e.g., ASTM, ISO), which define test methodologies, acceptance criteria, and performance limits. These standards are developed and maintained by committees of experts, but specific "experts" assigned to establish "ground truth" for a particular device's test set are not mentioned or required in this context.

4. Adjudication Method for the Test Set

This information is not applicable. The non-clinical tests involve objective measurements (e.g., load, displacement) against specified performance criteria, rather than subjective interpretation requiring adjudication among multiple parties.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

No, a multi-reader multi-case (MRMC) comparative effectiveness study was not performed. This type of study is relevant for diagnostic imaging devices where human interpretation of images is a key factor. This submission pertains to a surgical implant (pedicle screw spinal system), where performance is assessed through mechanical testing and material properties.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

This is not applicable. The device is a physical surgical implant, not a software algorithm.

7. The Type of Ground Truth Used

The "ground truth" for the device's performance in this context is defined by established engineering and material standards. Specifically:
- Mechanical Integrity: ASTM F1717-04 defines the "ground truth" for appropriate mechanical performance characteristics (static/dynamic bending, torsion) expected of spinal implant constructs.
- Material Biocompatibility: ASTM F136-02a defines the "ground truth" for the material properties and biocompatibility of the titanium alloy used.
- Sterilization: ISO 17665-1:2006 defines the "ground truth" for a validated sterilization process to achieve a specified Sterility Assurance Level.

8. The Sample Size for the Training Set

This information is not applicable. The device is a physical medical device, not an AI/ML algorithm that requires a training set. The design and manufacturing process are informed by general engineering principles and material science, not a data-driven "training" process in the AI sense.

9. How the Ground Truth for the Training Set Was Established

This information is not applicable as there is no "training set" for this device.

Summary

{0}------------------------------------------------

K140229 Page 1 of 4

APR 2 9 2014

Section 3 510(k) Summary

This 510(k) Summary of 510(k) information is being submitted in accordance with requirements of SMDA 1990 and Title 21, CFR Section 807.92.

The assigned 510(k) Number: K140229

Date of Submission: 01/27/2014
Sponsor Identification

Tianjin Walkman Biomaterial Co., Ltd No. 19 Technology Road, Tianyu Technology Development Zone, East of Jinghai, Tianjin, 301609. China

Establishment Registration Number: Not yet registered

Contact Person: Ms. Fengmei Ren Position: Management Representative Tel: +86-22-68660780 Fax: +86-22-68660776 Email: wm-rfm@126.com

Submission Correspondent 3.

Ms. Diana Hong& Mr. Lee Fu Mid-Link Consulting Co., Ltd P.O. Box 120-119 Shanghai. 200120. China Tel: +86-21-22815850 Fax: 240-238-7587 Email: info@mid-link.net

{1}------------------------------------------------

Proposed Device Identification 4.

Common Name: Pedicle Screw Spinal System Proposed Device Name: General Spinal System Classification Name: Pedicle screw spinal system Product Code: MNI, MNH Regulation Number: 21 CFR part 888.3070 Review Panel: Orthopedic

Intended Use Statement:

The General Spinal System is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients. It provides stabilization and immobilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities deformities: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, and/or lordosis), (3) spinal tumor, (4) failed previous fusion, (5) pseudarthrosis, (6) spinal stenosis. It is not intended for pedicle screw fixation above T8.

1. Predicate Device Identification
  510(k) Number: K082617 Product Name: Trauson General Spinal System (GSS) Manufacturer: Trauson (Jiangsu) Medical Instrument Co., Ltd.

Device Description 6.

The General Spinal System consists of Fixed-Angle Screws, Fix-Angle Reduction Screws, Hooks, Rods, Cross Link and Set Screws.

It is made of Titanium Alloy (Ti6Al4VELI), which meets ASTM F136-02a, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Allov for Surgical Implant Applications. which are widely used for surgical implants with well known biocompatibility.

The proposed devices are provided non-sterile. It is required to be sterilized via autoclave method to reach a SAL of 10 by the hospital prior to surgery. The recommended sterilization method was validated per ISO 17665-1: 2006 Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices

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

7. Non-Clinical Test Conclusion

Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed. device complies with the following standard:

ASTM F1717-04, Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model, including the following items:

Static compression bending test;
Dynamic compression bending test;
Static torsion test.
1. Substantially Equivalent (SE) Conclusion

The following table compares the DEVICE to the predicate device with respect to intended use, technological characteristics and principles of operation, etc.

Item	Proposed Device	Predicate Device
		K082617
Product Code	MNH	MNH
	MNI	MNI
RegulationNumber	21 CFR 888.3070	21 CFR 888.3070
Intended Use	The General Spinal System is intended forposterior pedicle screw fixation of thenon-cervical posterior spine in skeletallymature patients. It provides stabilization andimmobilization of spinal segments as anadjunct to fusion in the treatment of thefollowing acute and chronic instabilitiesdeformities: (1) trauma (i.e. fracture ordislocation), (2) curvatures (scoliosis, kyphosis,and/or lordosis), (3) spinal tumor, (4) failedprevious fusion, (5) pseudarthrosis, (6) spinalstenosis. It is not intended for pedicle screwfixation above T8.	Trauson General Spinal System (GSS) isintended for posterior pedicle screw fixation(GSS-VII can be applied for anterior oranterolateral fixation) of the non-cervicalposterior spine in skeletally mature patients. Itprovides stabilization and immobilization ofspinal segments as an adjunct to fusion in thetreatment of the following acute and chronicinstabilities deformities.When used as a posterior spinethoracic/lumbar system, Trauson General SpinalSystem (GSS) is indicated for one or more of thefollowing: (1) trauma (i.e. fracture or

Table 3-1 Comparison of Technology Characteristics

{3}------------------------------------------------

		dislocation), (2) curvatures (scoliosis, kyphosis,and/or lordosis), (3) spinal tumor, (4) failedprevious fusion, (5) pseudarthrosis, (6) spinalstenosis.
		Trauson General Spinal (GSS) is notintended for pedicle screw fixation about T8.
Assembly	Fixed-Angle Screws, Fix-Angle ReductionScrews, Cross Link, Rod and Set Screws	Fix-Angle Reduction_Screws, Cross Link, Rodand Set Screws
Material	Titanium alloy	Titanium alloy
How supplied	Non-Sterile	Non-Sterile
Single Use	Yes	Yes
Sterile	Subject to steam sterilized prior to use.	Subject to steam sterilized prior to use.
Performance	ASTM F 1717-04 Standard Test Methods forSpinal Implant Constructs in a VertebrectomyModel	ASTM F 1717-04 Standard Test Methods forSpinal Implant Constructs in a VertebrectomyModel

Differences in physical specification and performance between the proposed and predicate device have been discussed and address. The proposed device is determined to be Substantially Equivalent (SE) to the predicate device, in respect of safety and effectiveness.

{4}------------------------------------------------

Image /page/4/Picture/0 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three stripes forming its wing and body. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle.

Public Health Service

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

April 29, 2014 ·

Tianjin Walkman Biomaterial Company, Limited % Mid-Link Consulting Company, Limited Ms. Diana Hong P.O. Box 120-119 Shanghai, 200120, CHINA -

Re: K140229

Trade/Device Name: General Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class II Product Code: MNI, MNH Dated: January 27, 2014 Received: January 30, 2014

Dear Ms. Hong:

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 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.

{5}------------------------------------------------

Page 2 - Ms. Diana Hong

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/Safetv/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.

Sincerely 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

{6}------------------------------------------------

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K140229

Device Name

General Spinal System

Indications for Use (Describe)

The General Spinal System is intended for posterior pedicle screw fixation of the non-cervical posterior spine in skeletally mature paients. It provides stabilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities deformities: (1) trauma (i.e. fracture or dislocation), (2) curvatures (scoliosis, kyphosis, and/or lordosis), (3) spinal tumor, (4) failed previous fusion, (5) spinal stenosis. It is not intended for pedicle screw fixation above T8.

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)

James P. Bertram -S 2014.04.29 12:31:40 -04

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

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."

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

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.