K Number
K153042
Device Name
TRYPTIK2C-plate Anterior Cervical Plate System
Manufacturer
Date Cleared
2016-03-28

(161 days)

Product Code
Regulation Number
888.3060
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
TRYPTIK2C-Plate® Anterior Cervical Plate System is intended to be used for temporary stabilization of the cervical spine (C2-C7) during the development of solid spinal fusion in patients with instability caused by the following degenerative disc disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), trauma (including fractures), tumor, spondylolisthesis, spinal stenosis, deformity (i.e., scoliosis, kyphosis, lordosis), pseudarthrosis, and failed previous fusions
Device Description
The TRYPTIK2C-Plate Anterior Cervical Plate System consists of a range of anterior cervical plates and polyaxial (variable angle) bone screws. The plate attaches to the anterior portion of the vertebral body of the cervical spine (C2-C7) and functions as an adjunct to fusion to provide immobilization and stabilization of cervical segments of the spine.
More Information

No
The summary describes a mechanical implant for spinal stabilization and does not mention any software, algorithms, or data processing that would indicate the use of AI/ML.

Yes
This device is intended to provide temporary stabilization and immobilization of the cervical spine during spinal fusion, which directly addresses medical conditions like degenerative disc disease, trauma, and tumors.

No

This device is an anterior cervical plate system intended for temporary stabilization and immobilization of the cervical spine during fusion, not for diagnosing medical conditions.

No

The device description clearly states it consists of physical components: anterior cervical plates and polyaxial bone screws.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that the device is for the "temporary stabilization of the cervical spine (C2-C7) during the development of solid spinal fusion". This describes a surgical implant used within the body.
  • Device Description: The description details a system of "anterior cervical plates and polyaxial (variable angle) bone screws" that attach to the "anterior portion of the vertebral body". This is a physical implant.
  • Lack of IVD Characteristics: IVD devices are used to examine specimens (like blood, urine, or tissue) outside the body to provide information about a person's health. This device does not perform any such function.

The information provided describes a surgical implant used to stabilize the spine, which is a completely different category of medical device than an IVD.

N/A

Intended Use / Indications for Use

TRYPTIK2C-Plate® Anterior Cervical Plate System is intended to be used for temporary stabilization of the cervical spine (C2-C7) during the development of solid spinal fusion in patients with instability caused by the following degenerative disc disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), trauma (including fractures), tumor, spondylolisthesis, spinal stenosis, deformity (i.e., scoliosis, kyphosis, lordosis), pseudarthrosis, and failed previous fusions

Product codes

KWO, KWQ

Device Description

The TRYPTIK2C-Plate Anterior Cervical Plate System consists of a range of anterior cervical plates and polyaxial (variable angle) bone screws. The plate attaches to the anterior portion of the vertebral body of the cervical spine (C2-C7) and functions as an adjunct to fusion to provide immobilization and stabilization of cervical segments of the spine.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Cervical spine (C2-C7)

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

The following non-clinical tests were conducted according to ASTM F1717-15: Static Compression Bending, Static Tension Bending, Static Torsion and Dynamic Compression Bending. Results demonstrate comparable mechanical properties to the predicate devices. Additionally, static push-out testing has been conducted according to an in-house protocol.

Key Metrics

Not Found

Predicate Device(s)

K072650, K792352, K926453, K043082, K052292

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3060 Spinal intervertebral body fixation orthosis.

(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.

0

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

March 28, 2016

SPINEART Mr. Franck Pennesi Director of Industry & Quality International Center Cointrin 20 route de pré-bois, CP1813 Geneva, 1215 SWITZERLAND

Re: K153042

Trade/Device Name: TRYPTIK2C-plate® Anterior Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: KWO Dated: March 3, 2016 Received: March 7, 2016

Dear Mr. Pennesi:

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 Parts 801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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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" (21CFR 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

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| DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration | Form Approved: OMB No. 0910-0120
Expiration Date: January 31, 2017
See PRA Statement below. |

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Indications for Use

510(k) Number (if known)K153042
Device NameTRYPTIK2C-Plate® Anterior Cervical Plate System
Indications for Use (Describe)TRYPTIK2C-Plate® Anterior Cervical Plate System is intended to be used for temporary stabilization of the cervical spine (C2-C7) during the development of solid spinal fusion in patients with instability caused by the following degenerative disc disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), trauma (including fractures), tumor, spondylolisthesis, spinal stenosis, deformity (i.e., scoliosis, kyphosis, lordosis), pseudarthrosis, and failed previous fusions
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)Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)
Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

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TRADITIONAL 510k TRYPTIK2c-Plate ANTERIOR CERVICAL PLATE SYSTEM

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510(k) SUMMARY

SPINEART
Submitted byInternational Center Cointrin
20 route de pré-bois
CP1813
1215 GENEVA 15
SWITZERLAND
ContactsFranck PENNESI Director of Industry & Quality
Phone : +41 22 570 1246 Fax : +41 22 799 40 26
Mail : fpennesi@spineart.com
Regulatory contact : Dr Isabelle DRUBAIX (Idée Consulting)
Mail : idrubaix@nordnet.fr
Date PreparedMarch 3rd 2016
Common NameAnterior Cervical Plate System
Trade NameTRYPTIK2C-Plate Anterior Cervical Plate System
Classification NameSpinal intervertebral body fixation orthosis
ClassII
Product CodeKWQ Appliance, Fixation, Spinal Intervertebral Body
CFR section888.3060 Spinal intervertebral body fixation orthosis
Device panelORTHOPEDIC
Primary predicate: IST Anterior Cervical Plate System manufactured by Innovative
Legally marketed
predicate devicesSpinal Technologies Inc (K072650)
Other predicates: Synthes Cervical Vertabrae Plates manufactured by Depuy
Synthes (K792352); Synthes Anterior Cervical Vertebrae Plate manufactured by
Synthes USA (K926453); Tosca Anterior Cervical Plate System manufactured by
Signus Medizintechnik GMBH (K043082);Spider Cervical Plating (SCP) System
manufactured by X-SPINE SYSTEMS, INC. (K052292)
Indications for useTRYPTIK2C-Plate Anterior Cervical Plate System is intended to be used for
temporary stabilization of the cervical spine (C2-C7) during the development of
solid spinal fusion in patients with instability caused by the following
degenerative disc disease (as defined by neck pain of discogenic origin with
degeneration of the disc confirmed by patient history and radiographic studies),
trauma (including fractures), tumor, spondylolisthesis, spinal stenosis, deformity
(i.e., scoliosis, kyphosis, lordosis), pseudarthrosis, and failed previous fusions

4

Description of the deviceThe TRYPTIK2C-Plate Anterior Cervical Plate System consists of a range of anterior cervical plates and polyaxial (variable angle) bone screws. The plate attaches to the anterior portion of the vertebral body of the cervical spine (C2-C7) and functions as an adjunct to fusion to provide immobilization and stabilization of cervical segments of the spine.
Technological
CharacteristicsThe TRYPTIK2C-Plate Anterior Cervical Plate System consists of 1-level, 2-level, 3-level and 4-level plates with cancellous and cortical variable-angle bone screws. The Plate configurations are ranging in total lengths from 20mm (1-level) to 92mm (4-level). The plate is 2.4mm thick and 16.5mm wide and incorporates integrated expansive rings for anti-back out of the bone screws that functions as a one-step locking mechanism. The Screw range comes in two diameters, Ø 4.0 and Ø 4.5, and length is ranging from 12mm to 18mm with 2mm increment.
The TRYPTIK2C-Plate Anterior Cervical Plates and screws are all made of Titanium alloy Ti6Al4V ELI conforming to ISO 5832.3 and ASTM F136. The TRYPTIK2C-Plate Anterior Cervical Plates and screws are delivered sterile (gamma sterilization). The TRYPTIK2C-Plate Anterior Cervical Plate System is supplied with all the surgical instruments required for its installation.
Discussion of TestingThe following non-clinical tests were conducted according to ASTM F1717-15: Static Compression Bending, Static Tension Bending, Static Torsion and Dynamic Compression Bending. Results demonstrate comparable mechanical properties to the predicate devices. Additionally, static push-out testing has been conducted according to an in-house protocol.
Comparison to Predicate
DevicesThe indications for use, design features and materials of the TRYPTIK2C-Plate Anterior Cervical Plates and screws are substantially equivalent to those of the predicate devices. The substantial equivalence of the TRYPTIK2C-Plate Anterior Cervical Plates and screws is supported by the performance testing, materials information, and data analysis provided within this Premarket Notification
ConclusionBased on the above information, the TRYPTIK2C-Plate Anterior Cervical Plates and screws can be considered as substantially equivalent to its predicate devices in terms of intended use, material, design, mechanical properties and function.