(193 days)
No reference devices were used in this submission.
No
The summary describes a mechanical spinal fixation system and does not mention any software, algorithms, or AI/ML capabilities.
No
The device is described as an implantation system for spinal segments, which is used to provide immobilization and restore integrity to the spinal column as an adjunct to fusion or for a limited time period. While it treats conditions, it does so through physical support and stabilization, not by active therapeutic action like drug delivery or energy emission.
No
Explanation: The device description clearly states that the PASS OCT Spinal System consists of implants such as rods, hooks, and screws used for immobilization and fusion of spinal segments. There is no indication that this system is used for diagnosing medical conditions.
No
The device description explicitly lists various hardware components made of titanium alloy, PEEK, and cobalt-chromium molybdenum alloy, such as rods, hooks, screws, and plates. It also describes mechanical testing of these components.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use clearly describes a surgical implant system designed to provide mechanical support and stabilization to the spine. This is a therapeutic device, not a diagnostic one.
- Device Description: The description details physical components like rods, hooks, screws, and plates made of various alloys. These are physical implants, not reagents, instruments, or software used to examine specimens from the human body.
- Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting markers, or providing diagnostic information about a patient's condition based on in vitro testing.
In summary, the PASS OCT Spinal System is a surgical implant used for spinal stabilization, which falls under the category of medical devices, but not In Vitro Diagnostic devices.
N/A
Intended Use / Indications for Use
The PASS OCT Spinal System is intended to provide immobilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The PASS OCT Spinal System is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.
In order to achieve additional levels of fixation, the PASS OCT Spinal System may be connected to the PASS LP Spinal System rods with the dual diameter rods. Refer to the PASS LP Spinal System package insert for a list of the PASS LP Spinal System indications of use.
Product codes (comma separated list FDA assigned to the subject device)
NKG, KWP
Device Description
The PASS OCT Spinal System is a posterior system, which consists of a variety of shapes and sizes of rods, hooks, polyaxial screws, occipital plates, occipital bone screws, and connection components, which can be rigidly locked to the rod in a variety of configurations. See package insert of the system for labeling limitations.
The implants are manufactured in titanium alloy Ti-6AI-4V ELI conforming to ISO 5832-3 specifications and ASTM F136 specifications, in PEEK OPTIMA LT1 conforming to ASTM F2026 specifications and in cobalt-chromium molybdenum alloy Co-Cr28Mo6 that conforms to ISO 5832-12 and ASTM F1537 specifications, and also CP Titanium according to ASTM F67 and ISO 5832-2 specifications.
Function: The PASS OCT spinal system was developed as an implant:
- To provide immobilization and stabilization of posterior spinal segments
- to auqment the development of a solid spinal fusion
- to provide stability to ease fusion
- to be mechanically resistant to allow the fusion of the operated level
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
craniocervical junction, cervical spine (C1 to C7), thoracic spine from 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 components of the PASS OCT spinal were mechanically evaluated in dynamic compression tests following the ASTM F2706-08.
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.
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.
No reference devices were used in this submission.
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
§ 888.3075 Posterior cervical screw system.
(a)
Identification. Posterior cervical screw systems are comprised of multiple, interconnecting components, made from a variety of materials that allow an implant system to be built from the occiput to the upper thoracic spine to fit the patient's anatomical and physiological requirements, as determined by preoperative cross-sectional imaging. Such a spinal assembly consists of a combination of bone anchors via screws (i.e., occipital screws, cervical lateral mass screws, cervical pedicle screws, C2 pars screws, C2 translaminar screws, C2 transarticular screws), longitudinal members (e.g., plates, rods, including dual diameter rods, plate/rod combinations), transverse or cross connectors, interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors), and closure mechanisms (e.g., set screws, nuts). Posterior cervical screw systems are rigidly fixed devices that do not contain dynamic features, including but not limited to: non-uniform longitudinal elements or features that allow more motion or flexibility compared to rigid systems.Posterior cervical screw systems are intended to provide immobilization and stabilization of spinal segments in patients as an adjunct to fusion for acute and chronic instabilities of the cervical spine and/or craniocervical junction and/or cervicothoracic junction such as: (1) Traumatic spinal fractures and/or traumatic dislocations; (2) deformities; (3) instabilities; (4) failed previous fusions (
e.g., pseudarthrosis); (5) tumors; (6) inflammatory disorders; (7) spinal degeneration, including neck and/or arm pain of discogenic origin as confirmed by imaging studies (radiographs, CT, MRI); (8) degeneration of the facets with instability; and (9) reconstruction following decompression to treat radiculopathy and/or myelopathy. These systems are also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.(b)
Classification. Class II (special controls). The special controls for posterior cervical screw systems are:(1) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use.
(2) Nonclinical performance testing must demonstrate the mechanical function and durability of the implant.
(3) Device components must be demonstrated to be biocompatible.
(4) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments.
(5) Labeling must include the following:
(i) A clear description of the technological features of the device including identification of device materials and the principles of device operation;
(ii) Intended use and indications for use including levels of fixation;
(iii) Device specific warnings, precautions, and contraindications that include the following statements:
(A) “Precaution: Preoperative planning prior to implantation of posterior cervical screw systems should include review of cross-sectional imaging studies (
e.g., CT and/or MRI) to evaluate the patient's cervical anatomy including the transverse foramen, neurologic structures, and the course of the vertebral arteries. If any findings would compromise the placement of these screws, other surgical methods should be considered. In addition, use of intraoperative imaging should be considered to guide and/or verify device placement, as necessary.”(B) “Precaution: Use of posterior cervical pedicle screw fixation at the C3 through C6 spinal levels requires careful consideration and planning beyond that required for lateral mass screws placed at these spinal levels, given the proximity of the vertebral arteries and neurologic structures in relation to the cervical pedicles at these levels.”
(iv) Identification of magnetic resonance (MR) compatibility status;
(v) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user, and;
(vi) Detailed instructions of each surgical step, including device removal.
0
Image /page/0/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 three faces in profile, stacked one behind the other, representing people. The faces are rendered in a simple, abstract style.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
October 16, 2015
Medicrea International S.A. Mr. Jean-Denys Marechal Regulatory Affairs Manager 14 Porte du Grand Lyon 01700 Neyron FRANCE
Re: K150918
Trade/Device Name: PASS OCT Spinal System Regulatory Class: Unclassified Product Code: NKG, KWP Dated: October 2, 2015 Received: October 7, 2015
Dear Mr. Marechal:
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
Page 2 - Mr. Jean-Denys Marechal
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.
Mark N. Melkerson -S
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) K150918
Device Name PASS OCT Spinal System
Indications for Use (Describe)
The PASS OCT Spinal System is intended to provide immobilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The PASS OCT Spinal System is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.
In order to achieve additional levels of fixation, the PASS OCT Spinal System may be connected to the PASS LP Spinal System rods with the dual diameter rods. Refer to the PASS LP Spinal System package insert for a list of the PASS LP Spinal System indications of use.
| Type of Use (Select one or both, as applicable) |
|---|
| ☑ Prescription Use (Part 21 CFR 801 Subpart D) |
| □ Over-The-Counter Use (21 CFR 801 Subpart C) |
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3
510(k) SUMMARY
MEDICREA INTERNATIONAL's PASS OCT Spinal System
In accordance with 21 CFR 807.92 of the Code of Federal Requlations the following 510(k) summary is submitted to add additional rods to PASS OCT Spinal System and also to get expansion of indications to include posterior cervical screw use.
Date Prepared: 02 October 2015
1. Submitter:
Contact Person:
MEDICREA INTERNATIONAL S.A. 14 Porte du Grand Lyon NEYRON 01700 FR
Jean- Denys MARECHAL MEDICREA INTERNATIONAL 14 Porte du Grand Lyon NEYRON 01700 FR Phone Number: 00 33 4 72 81 87 87
2. Trade name: PASS OCT Spinal System
Regulatory Identification/Classification:
Orthosis, Cervical pedicle screw spinal fixation Product code: NKG Unclassified, Pre-Amendment
Spinal Interlaminal Fixation Orthosis Regulation Number: 21 CFR 888.3050 Product Code: KWP Class II
3. Predicate or legally marketed devices which are substantially equivalent:
Primary predicate:
- Vertex Reconstruction System, (MEDTRONIC SOFAMOR DANEK USA; K143471) . Additional predicates:
- Virage OCT Spinal Fixation System; (ZIMMER SPINE, K133556) ●
- . PASS OCT Spinal System, (MEDICREA INTERNATIONAL, K121979)
No reference devices were used in this submission.
4
4. Description of the device:
The PASS OCT Spinal System is a posterior system, which consists of a variety of shapes and sizes of rods, hooks, polyaxial screws, occipital plates, occipital bone screws, and connection components, which can be rigidly locked to the rod in a variety of configurations. See package insert of the system for labeling limitations.
The implants are manufactured in titanium alloy Ti-6AI-4V ELI conforming to ISO 5832-3 specifications and ASTM F136 specifications, in PEEK OPTIMA LT1 conforming to ASTM F2026 specifications and in cobalt-chromium molybdenum alloy Co-Cr28Mo6 that conforms to ISO 5832-12 and ASTM F1537 specifications, and also CP Titanium according to ASTM F67 and ISO 5832-2 specifications.
Never use stainless steel and titanium implant components in the same construct.
To achieve best results, do not use any of the PASS OCT Spinal System implant components with components from any other systems or manufacturer unless specifically labeled to do so in this or another MEDICREA® INTERNATIONAL document.
MATERIALS: Titanium Alloy (Ti-6Al-4V) according to the ASTM F136-11 & ISO 5832-30; CP Titanium according to the ASTM F67 and ISO 5832-2; PEEK OPTIMA LT1® according to the ASTM F2026-10 and cobalt-chromium molybdenum alloy Co-Cr28Mo6 according to ISO5832-12 and ASTM F1537.
Function: The PASS OCT spinal system was developed as an implant:
- · To provide immobilization and stabilization of posterior spinal segments
- · to auqment the development of a solid spinal fusion
- to provide stability to ease fusion
- to be mechanically resistant to allow the fusion of the operated level
5. Indication for Use
The PASS OCT Spinal System is intended to provide immobilization of spinal seqments as an adjunct to fusion for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The PASS OCT Spinal System is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.
In order to achieve additional levels of fixation, the PASS OCT Spinal System may be connected to the PASS LP Spinal System rods with the dual diameter rods. Refer to the PASS LP Spinal System package insert for a list of the PASS LP Spinal System indications of use.
6. Substantial equivalence claimed to predicate devices
The PASS OCT Spinal system components are technologically similar to the already cleared PASS OCT Spinal System Components, Vertex Reconstruction System Components and Synapse
5
Occipital Cervical Thoracic Components in terms of intended use, materials used, mechanical safety and performances
- PASS OCT Spinal System, (MEDICREA INTERNATIONAL, K121979) .
- . Vertex Reconstruction System, (MEDTRONIC SOFAMOR DANEK USA; K143471)
- Virage OCT Spinal Fixation System; (ZIMMER SPINE, K133556) .
The table below compares the features and characteristics of PASS OCT components to their predicate devices.
| Device | MEDICREA
INTERNATIONAL
PASS OCT
Spinal System
NEW
COMPONENT | MEDTRONIC
SOFAMOR DANEK
Vertex
Reconstruction
System | ZIMMER
SPINE
Virage OCT Spinal
Fixation System | MEDICREA
INTERNATIONAL
PASS OCT Spinal
System |
|--------------------|-----------------------------------------------------------------------------|------------------------------------------------------------------|-------------------------------------------------------------|-----------------------------------------------------------------------|
| 510(k)
number | Unknown | K143471 | K133556 | K121979 |
| Intended
use | | | | |
| Occipital | Yes | Yes | Yes | Yes |
| Cervical | Yes | Yes | Yes | Yes |
| Thoracic | Yes | Yes | Yes | Yes |
| Components | | | | |
| Anchorage
means | - Polyaxial
screws
- Polyaxial
hooks - Occipital bone
screws | - Multi-axial
screws - Hooks
- Occipital bone
screws | - Polyaxial Screws - Hooks
- Occipital bone
screws | - Polyaxial screws - Polyaxial hooks
- Occipital bone
screws |
| Rods
diameter | Ø3.5 mm | Ø3.5mm and
Ø3.2mm | Ø3.5mm | Ø3.5 mm |
| Straight rods | Yes | Yes | Yes | Yes |
| Pre-bent
rods | Yes | Yes | Yes | No |
| Materials | | | | |
6
| Device | MEDICREA
INTERNATIONAL
PASS OCT
Spinal System
NEW
COMPONENT | MEDTRONIC
SOFAMOR DANEK
Vertex
Reconstruction
System | ZIMMER
SPINE
Virage OCT Spinal
Fixation System | MEDICREA
INTERNATIONAL
PASS OCT Spinal
System |
|--------|-------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------|--------------------------------------------------------------------------|
| | Titanium Alloy
(Ti-6Al-4V)
according
to
ASTM F136 &
ISO 5832-3 | Titanium Alloy (Ti-
6Al-4V) according
to ASTM F136 &
ISO 5832-3 | Ti-6Al-4V (ASTM
F136)
Or Co-Cr 28Mo6
alloy 1 (following
the ASTMF1537) | Titanium Alloy (Ti-
6Al-4V) according
to ASTM F136 &
ISO 5832-3 |
| | -Grade Titanium
according
to
ASTM F67-13 &
ISO 5832-2
PEEK OPTIMA
LT1 conforming
to ASTM F2026 | - Grade Titanium
according
to
ASTM F67 & ISO
5832-2
- Shape Memory
Alloy (Nitinol-NiTi)
according to
ASTM F2063 | | PEEK OPTIMA
LT1 conforming to
ASTM F2026 |
| | Co-Cr 28Mo6
alloy 1 (following
the ASTMF1537) | | | |
7. Non-clinical Test Summary:
The components of the PASS OCT spinal were mechanically evaluated in dynamic compression tests following the ASTM F2706-08.
8. Clinical Test Summary
Published literature was used to demonstrate substantial equivalence.
9. Conclusions Non clinical and Clinical
The PASS OCT Spinal System are substantially equivalent to legally marketed predicate device.