(117 days)
Not Found
No
The device description and performance studies focus on mechanical components and their structural integrity, with no mention of software, algorithms, or data processing that would indicate AI/ML.
Yes
The device is intended for "posterior non-cervical pedicle fixation" and "anterolateral fixation" as an "adjunct to fusion" for various spinal conditions, clearly indicating a therapeutic purpose to stabilize and fuse parts of the spine.
No
This device, the M.U.S.T. Pedicle Screw System and Extension, is described as an adjunct to fusion for various spinal conditions, focusing on stabilization and fusion of the spine. Its components are surgical implants and instruments, not tools for diagnosing medical conditions.
No
The device description clearly states that the M.U.S.T. Extension consists of physical components like hooks, which are hardware. The entire submission focuses on the mechanical and geometrical properties of these physical implants and their performance in biomechanical tests, not software functionality.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use/Indications for Use: The intended use clearly describes a surgical implant system for spinal fixation and fusion. This is a therapeutic device used in vivo (within the body) during surgery.
- Device Description: The description details components like screws, rods, and hooks, which are all physical implants used in surgical procedures.
- Lack of IVD Characteristics: There is no mention of the device being used to examine specimens (like blood, urine, or tissue) in vitro (outside the body) to provide information for diagnosis, monitoring, or screening.
Therefore, the M.U.S.T. Pedicle Screw System and its Extension are classified as surgical implants, not In Vitro Diagnostics.
N/A
Intended Use / Indications for Use
The M.U.S.T. Pedicle Screw System is intended for posterior non-cervical pedicle fixation (T1-S2/ilium) and nonpedicle fixation, or anterolateral fixation (T8-L5). These devices are indicated as an adjunct to fusion for all of 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; pseudoarthrosis and failed previous fusion in skeletally mature patients.
Product codes (comma separated list FDA assigned to the subject device)
NKB, MNH, MNI, KWO, KWP
Device Description
The M.U.S.T. Extension is intended to be used as part of the M.U.S.T. pedicle screw system (K121115, K132878) for the stabilization and the fusion of the lumbar and thoracic spine. The M.U.S.T. pedicle screw system includes cannulated or non cannulated poly-axial pedicle screws (K12115, K132878), cannulated or non cannulated mono-axial pedicle screws (K132878), set screws (K121115), straight and pre-bent rods (K12115), and cross connectors (K132878). The M.U.S.T. Extension consists of the following components, which are all provided in both sterile and unsterile packaging: Wide blade hook, Pedicle hook, Pedicle hook screw, Angled hook, Offset hook, Narrow blade hook. All components are made of Ti6Al4V ELI (ISO 5832-3/ASTM F 136).
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
posterior non-cervical pedicle fixation (T1-S2/ilium) and nonpedicle fixation, or anterolateral fixation (T8-L5)
Indicated Patient Age Range
skeletally mature patients
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 modification to the device system to include the addition of the M.U.S.T. Extension was evaluated by risk analysis to identify any new risks associated with the change. Based on the risk analysis, design verification was conducted to written protocols with pre-defined acceptance criteria. The protocols and pre-defined acceptance criteria were based on the standards, FDA quidance, and comparison to the predicate device system.
The following geometrical comparisons were performed in order to substantiate the applicability of the tests already performed on the predicate devices and to demonstrate that the M.U.S.T. Extension is not worst case compared to the predicate devices:
- Implant/Rod/Set Screw interface (Hooks)
- Implant/Bone interface (Hooks)
There were not any additional tests performed on the hooks as the interface to the rod. the tulip and thread geometry, the set screw and the final tightening torque are exactly the same as for the M.U.S.T. monoaxial screws (K132878). Therefore, the biomechanical implant performance regarding yield strength, fatigue strength and construct stiffness can be considered at least equal to the predicate devices.
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.
K121115, K132878, K083393, K042962, K091445, K052151, K041119, K072022, K022949, K100952, K024096
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
§ 888.3070 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.
0
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 18, 2014
Medacta International SA % Mr. Adam Gross Medacta USA 1556 West Carroll Avenue Chicago, Illinois 60607
Re: K141044
Trade/Device Name: M.U.S.T. Extension Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNH, MNI, KWO, KWP Dated: July 17, 2014 Received: July 18, 2014
Dear Mr. Gross:
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
1
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/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 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 DAJean -S for
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known) K141044
Device Name M.U.S.T. Extension
Indications for Use (Describe)
The M.U.S.T. Pedicle Screw System is intended for posterior non-cervical pedicle fixation (T1-S2/ilium) and nonpedicle fixation, or anterolateral fixation (T8-L5). These devices are indicated as an adjunct to fusion for all of 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; pseudoarthrosis and failed previous fusion in skeletally mature patients.
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)
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Image /page/3/Picture/0 description: The image contains the logo for Medacta International. The logo features two blue triangles pointing upwards, followed by the word "Medacta" in blue. Below the word is a yellow line, and below that is the word "International" in blue, followed by a red and white Swiss flag.
510(k) Summary
Applicant/Sponsor: Medacta International SA Strada Regina 6874 Castel San Pietro (CH) Switzerland Phone (+41) 91 696 60 60 Fax (+41) 91 696 60 66
- Contact Person: Adam Gross Director of Regulatory, Quality and Compliance Medacta USA 1556 W Carroll Ave Chicago, IL 60607 Phone: (805) 910-6511 Fax: (805) 437-7553 Email: AGross@medacta.us.com
Date Prepared: July 16, 2014
DEVICE INFORMATION
Trade/Proprietary Name: M.U.S.T. Extension Common Name: Pedicle screw spinal system Classification Name: orthosis, Spinal pedicle fixation, for degenerative disc disease 21 CFR 888.3070, 21 CFR 888.3060, 21 CFR 888.3050 Class III Device Product Codes: MNI, MNH, NKB, KWQ, KWP
Predicate Device(s):
| 510(k) | Product | 510(k) Holder | Clearance Date |
|---|---|---|---|
| K121115 | M.U.S.T Pedicle Screw System | Medacta International | 7/18/2012 |
| K132878 | M.U.S.T Extension | Medacta International | 12/18/2013 |
| K083393 | XIA3 | Stryker | 4/23/2009 |
| K042962, | CD Horizon | Medtronic | 12/14/2004, |
| K091445 | 9/27/2010 | ||
| K052151 | Pangea | Synthes | 12/7/2005 |
| K041119 | Expedium | Depuy | 7/19/2004 |
| K072022 | Valeo Pedicle Screw System | Amedica | 11/19/2007 |
| K022949 | USS | Synthes Spine | 3/24/2003 |
| K100952 | Matrix | Synthes Spine | 8/6/2010 |
| K024096 | Optima | U&I | 3/12/2003 |
4
Product Description
The M.U.S.T. Extension is intended to be used as part of the M.U.S.T. pedicle screw system (K121115, K132878) for the stabilization and the fusion of the lumbar and thoracic spine. The M.U.S.T. pedicle screw system includes cannulated or non cannulated poly-axial pedicle screws (K12115, K132878), cannulated or non cannulated mono-axial pedicle screws (K132878), set screws (K121115), straight and pre-bent rods (K12115), and cross connectors (K132878). The M.U.S.T. Extension consists of the following components, which are all provided in both sterile and unsterile packaging
| Component | Sizes | Material |
|---|---|---|
| Wide blade hook | Small, Medium, Large | Ti6Al4V ELI (ISO |
| 5832-3/ASTM F 136) | ||
| Pedicle hook | Xsmall, Small, Medium, Large | Ti6Al4V ELI (ISO |
| 5832-3/ASTM F 136) | ||
| Pedicle hook | ||
| screw | Diameter 3.5mm; Length 15 & 20mm | Ti6Al4V ELI (ISO |
| 5832-3/ASTM F 136) | ||
| Angled hook | Right and Left | Ti6Al4V ELI (ISO |
| 5832-3/ASTM F 136) | ||
| Offset hook | Right and Left | Ti6Al4V ELI (ISO |
| 5832-3/ASTM F 136) | ||
| Narrow blade | ||
| hook | Small, Medium, Large | Ti6Al4V ELI (ISO |
| 5832-3/ASTM F 136) |
Indications for Use
The M.U.S.T. Pedicle Screw System is intended for posterior non-cervical pedicle fixation (T1-S2/ilium) and nonpedicle fixation, or anterolateral fixation (T8-L5). These devices are indicated as an adjunct to fusion for all of 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, and/or lordosis): tumor: pseudoarthrosis and failed previous fusion in skeletally mature patients.
5
Comparison to Predicate Devices
The indications for use, design features and materials of the M.U.S.T. Extension are substantially equivalent to those of the predicate devices. The substantial equivalence of the M.U.S.T. Extension implants is supported by the performance testing, materials information, and data analysis provided within this Premarket Notification.
Performance Testing
The modification to the device system to include the addition of the M.U.S.T. Extension was evaluated by risk analysis to identify any new risks associated with the change. Based on the risk analysis, design verification was conducted to written protocols with pre-defined acceptance criteria. The protocols and pre-defined acceptance criteria were based on the standards, FDA quidance, and comparison to the predicate device system.
The following geometrical comparisons were performed in order to substantiate the applicability of the tests already performed on the predicate devices and to demonstrate that the M.U.S.T. Extension is not worst case compared to the predicate devices:
- Implant/Rod/Set Screw interface (Hooks)
- Implant/Bone interface (Hooks) o
There were not any additional tests performed on the hooks as the interface to the rod. the tulip and thread geometry, the set screw and the final tightening torque are exactly the same as for the M.U.S.T. monoaxial screws (K132878). Therefore, the biomechanical implant performance regarding yield strength, fatigue strength and construct stiffness can be considered at least equal to the predicate devices.
Conclusion:
Based on the above information, the M.U.S.T. Extension can be considered as substantially equivalent to its predicate devices.