(177 days)
No
The device description and intended use focus solely on mechanical components for spinal stabilization. There is no mention of any software, algorithms, or data processing that would suggest the use of AI or ML. The performance studies described are mechanical and cadaveric, not related to algorithmic performance.
Yes
The device is intended to provide immobilization of spinal segments as an adjunct to fusion in the treatment of instabilities or deformities, which is a therapeutic function.
No
The device is a stabilization system for spinal segments used as an adjunct to fusion, which is a treatment, not a diagnostic procedure. Its components and indicated uses describe surgical implants for immobilization, not for identifying a disease or condition.
No
The device description explicitly states that the system consists of physical components like posted screws, couplers, and surgical instruments, manufactured from Ti-6AI-4V. This indicates a hardware-based medical device, not a software-only one.
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 used to stabilize the spine during fusion procedures. This is a therapeutic intervention performed directly on the patient's body.
- Device Description: The device consists of physical components (screws, couplers, instruments) made of titanium, designed for surgical implantation.
- Lack of IVD Characteristics: An IVD device is used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information about a physiological state, health, disease, or congenital abnormality. This device does not interact with or analyze such specimens.
- Performance Studies: The performance studies described are mechanical testing and a cadaveric validation study, which are typical for surgical implants, not IVDs.
In summary, the Syzygy Stabilization System is a surgical implant used for spinal stabilization, not a device used for in vitro diagnostic testing of patient specimens.
N/A
Intended Use / Indications for Use
The Syzygy Stabilization System is intended to provide immobilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and/or sacral spine, specifically as follows:
• When intended for pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients the Syzygy Stabilization System is indicated for one of the following: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies); fracture; dislocation; scoliosis; kyphosis; spinal tumor; and/or failed previous fusion (pseudarthrosis).
· In addition, when used as a pedicle screw fixation system, the Syzygy Stabilization System is indicated for skeletally mature patients having degenerative spondylolisthesis with objective evidence of neurologic impairment and/or severe spondylolisthesis (grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral joint; who are receiving fusions using autogenous bone graft only; who are having the device fixed or attached to the lumbar and sacral spine (L3 and below); and who are having the device removed after the development of a solid fusion mass.
Product codes
NKB, MNI, MNH
Device Description
The Syzygy Stabilization System consists of posted screws, couplers, and associated surgical instruments. The system is used in conjunction with the Amendia Savannah-T pedicle screw and rod system. The Syzygy posted screws are self-tapping with a cancellous thread design. They are available in cannulated and non-cannulated configurations, in a variety of diameters and lengths. The Syzygy posted screws are attached to the pedicles via couplers (medial and cranial) which accept and secure the longitudinal rods to build a rigid construct. The screws and couplers are manufactured from Ti-6AI-4V (ASTM F136) and are provided non-sterile for singleuse.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
thoracic, lumbar, and/or sacral spine; non-cervical posterior spine; fifth lumbar-first sacral (L5-S1) vertebral joint; lumbar and sacral spine (L3 and below)
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)
Mechanical testing for the Syzygy Stabilization System was performed on the worst case subject device in accordance with ASTM standards.
Test: Static Axial Compression Bending, Standard: ASTM F1717-14
Test: Static Axial Tension Bending, Standard: ASTM F1717-14
Test: Static Torsion, Standard: ASTM F1717-14
Test: Dynamic Axial Compression Bending, Standard: ASTM F1717-14
Test: Dynamic Axial Tension Bending, Standard: ASTM F1717-14
A cadaveric validation study was also performed.
For all test methods, the subject devices met the requirements as established by the test protocol and applicable ASTM standards. The results demonstrated that the Subject device is substantially equivalent to the Predicate.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
K072116, K132925, K052123, K102995
Reference Device(s)
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information
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.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 27, 2016
Amendia, Incorporated Ms. Kristen Allen Sr. Regulatory Affairs Specialist 1755 West Oak Parkway Marietta, Georgia 30062
Re: K153152
Trade/Device Name: Syzygy Stabilization System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNI, MNH Dated: March 24, 2016 Received: March 25, 2016
Dear Ms. Allen:
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 (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" (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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Indications for Use
510(k) Number (if known)
Device Name Syzygy Stabilization System
Indications for Use (Describe)
The Syzygy Stabilization System is intended to provide immobilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and/or sacral spine, specifically as follows:
• When intended for pedicle screw fixation of the non-cervical posterior spine in skeletally mature patients the Syzygy Stabilization System is indicated for one of the following: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies); fracture; dislocation; scoliosis; kyphosis; spinal tumor; and/or failed previous fusion (pseudarthrosis).
· In addition, when used as a pedicle screw fixation system, the Syzygy Stabilization System is indicated for skeletally mature patients having degenerative spondylolisthesis with objective evidence of neurologic impairment and/or severe spondylolisthesis (grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral joint; who are receiving fusions using autogenous bone graft only; who are having the device fixed or attached to the lumbar and sacral spine (L3 and below); and who are having the device removed after the development of a solid fusion mass.
| Type of Use (Select one or both, as applicable) | ||||
|---|---|---|---|---|
| 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) | 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) | |
| 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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Image /page/3/Picture/0 description: The image shows the logo for AMENDIA. The logo consists of the word "AMENDIA" in blue, with a blue square around the letter "A". Below the word "AMENDIA" is the tagline "creating balanced solutions" in a smaller, lighter blue font. The logo is simple and modern, and the blue color gives it a sense of trust and reliability.
510(k) Summary
Syzyqy Stabilization System
| Submitter: | Amendia, Inc.
1755 W. Oak Parkway
Marietta, GA 30062 |
|--------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Kristen Allen
Sr. Regulatory Affairs Specialist
910-612-4153 (P), 877-420-1213 (F)
kallen@amendia.com (e-mail) |
| Date Prepared: | April 26, 2016 |
| Trade Name: | Syzygy Stabilization System |
| Common Name: | Orthosis, Spinal Pedicle Fixation, For Degenerative Disc Disease |
| Device Product Code
and Classification: | Regulation Number: 21 CFR 888.3070
NKB, Class III, Pedicle Screw Spinal System, For Degenerative
Disc Disease
MNI, Class II, Pedicle Screw Spinal System
MNH, Class II, Spondylolisthesis Spinal Fixation Device System |
| Primary Predicate: | Savannah Lumbar Percutaneous Stabilization System (K072116) |
| Additional Predicate: | Savannah-T Pedicle Screw System (K132925)
Pangea (K052123)
Talon Spinal System (K102995) |
Device Description:
The Syzygy Stabilization System consists of posted screws, couplers, and associated surgical instruments. The system is used in conjunction with the Amendia Savannah-T pedicle screw and rod system. The Syzygy posted screws are self-tapping with a cancellous thread design. They are available in cannulated and non-cannulated configurations, in a variety of diameters and lengths. The Syzygy posted screws are attached to the pedicles via couplers (medial and cranial) which accept and secure the longitudinal rods to build a rigid construct. The screws and couplers are manufactured from Ti-6AI-4V (ASTM F136) and are provided non-sterile for singleuse.
Indications and Intended use:
The Syzygy Stabilization System is intended to provide immobilization and stabilization of spinal segments as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and/or sacral spine, specifically as follows:
- When intended for pedicle screw fixation of the non-cervical posterior spine in skeletally . mature patients the Syzygy Stabilization System is indicated for one or more of the following: degenerative disc disease (defined as discogenic back pain with degeneration of
4
Image /page/4/Picture/0 description: The image shows the logo for Amendia. The logo is blue and features the word "AMENDIA" in a sans-serif font. The "A" is inside of a blue square. Below the word "AMENDIA" is the tagline "creating balanced solutions" in a smaller font.
the disc confirmed by history and radiographic studies); spondylolisthesis; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and/or failed previous fusion (pseudarthrosis).
- . In addition, when used as a pedicle screw fixation system, the Syzygy Stabilization System is indicated for skeletally mature patients having degenerative spondylolisthesis with objective evidence of neurologic impairment and/or severe spondylolisthesis (grades 3 and 4) of the fifth lumbar-first sacral (L5-S1) vertebral joint; who are receiving fusions using autogenous bone graft only: who are having the device fixed or attached to the lumbar and sacral spine (L3 and below); and who are having the device removed after the development of a solid fusion mass.
Summary of Technological Characteristics:
The subject device is substantially equivalent to the predicate device as well as other similar devices cleared by FDA for commercial distribution in the United States. The Subject Device is equivalent to the predicate in regards to technological characteristics including design (rod, screw and coupler configuration), intended use (as described above), material composition (Titanium Alloy), sizes (dimensions are comparable to those offered by the predicate systems) and fundamental scientific technology (same as previously cleared devices).
Summary of Performance Testing:
Mechanical testing for the Syzygy Stabilization System was performed on the worst case subject device in accordance with ASTM standards.
| Test | Standard |
|---|---|
| Static Axial Compression Bending | ASTM F1717-14 |
| Static Axial Tension Bending | ASTM F1717-14 |
| Static Torsion | ASTM F1717-14 |
| Dynamic Axial Compression Bending | ASTM F1717-14 |
| Dynamic Axial Tension Bending | ASTM F1717-14 |
A cadaveric validation study was also performed.
For all test methods, the subject devices met the requirements as established by the test protocol and applicable ASTM standards. The results demonstrated that the Subject device is substantially equivalent to the Predicate.
Conclusion:
Based on the comparison to predicate device, the Syzygy Stabilization System has been shown to be substantially equivalent to the legally marketed predicate device.