AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The RIALTO™ SI Fusion System is intended for sacroiliac joint fusion for conditions including sacroiliac joint disruptions and degenerative sacroiliitis.

IPC™ System is indicated for the incision/cutting, removal, drilling and sawing of soft and hard tissue and bone, and biomaterials in Neurosurgical (Cranial, Craniofacial), Orthopedic, Arthroscopic, Spinal, Sternotomy, and General surgical procedures. The IPC™ POWEREASE™ System is indicated for drilling, tapping and driving screws and working end attachments during spinal surgery, including open and minimally invasive procedures. It is also used in placement or cutting of screws, posts and rods.

Medtronic Navigated Reusable Instruments are intended to be used during the preparation and placement of Medtronic screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Navigated Reusable Instruments are specifically designed for use with the StealthStation™ System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy. Medtronic Navigated Reusable Instruments are also compatible with the IPC™ POWEREASE™ System.

Device Description

The subject RIALTO™ SI Fusion System consists of cannulated devices available in various lengths, used to provide stabilization when fusion of the sacroiliac joint is desired. Autograft and/or allograft may be placed in conjunction with the RIALTO™ SI Fusion System. The RIALTO™ implant are made using Titanium Alloy and are 40mm-60mm in length with a diameter of 12mm. This device may be implanted via a minimally invasive approach using fluoroscopy or navigated instruments compatible with Medtronic StealthStation® and IPC® POWEREASE®.

The subject Medtronic Reusable Taps, Drivers and Drills are spine preparation instruments made of high grade stainless steel and are designed specifically for subject RIALTO™ SI Fusion System. The subject Taps, Drivers and Drills are compatible with Medtronic's IPC® POWEREASE® System may be connected to the IPC® POWEREASE® handpiece. The subject Taps, Drivers and Drills can be used manually using existing Medtronic Class I Exempt quick connect handles in place of the IPC® POWEREASE® handpiece.

The subject Medtronic Navigated Reusable Taps, Drivers and Drills are spine preparation instruments made of high grade stainless steel. These instruments were specifically designed for use with subject RIALTO™ SI Fusion System in procedures where the use of stereotactic surgery may be appropriate. The subject Taps, Drivers and Drills are also compatible with Medtronic's IPC® POWEREASE™ System when connected to the POWEREASE™ handpiece or may be used manually with existing Medtronic Class I Exempt quick connect handles in place of the IPC® POWEREASE® handpiece or the NavLock™ tracker.

AI/ML Overview

The provided text describes the RIALTO™ SI Fusion System, Medtronic Reusable Instruments for Use with the IPC™ Powerease™ System, and Medtronic Navigated Manual Reusable Instruments for use with the StealthStation™ and IPC™ Powerease™ Systems. Within the summary of the 510(k) submission, the "Performance Data" section details the testing conducted.

Here's an analysis based on the provided text:

1. A table of acceptance criteria and the reported device performance

Test TypeAcceptance Criteria (General)Reported Device Performance
Mechanical TestingMet pre-determined acceptance criteriaMet the pre-determined acceptance criteria for all tests.
Push-Out TestingNot explicitly stated, implied to be based on predicate performance.Passed
Torque-to-Fail TestingNot explicitly stated, implied to be based on predicate performance.Passed
Four Point Bend TestingNot explicitly stated, implied to be based on predicate performance.Passed
Shear TestingNot explicitly stated, implied to be based on predicate performance.Passed
Navigation accuracy (Navigated Instruments)Not explicitly stated, implied to be based on predicate performance.Passed
BiocompatibilitySafe and effective use in similar commercially available medical devices.Not required, based on material history (titanium alloy, stainless steel).
Non-Pyrogenicity Endotoxin Testing20 endotoxin units (EU)/device pyrogen limit specification.Confirmed that the subject implants meet the 20 EU/device testing limit.

2. Sample sizes used for the test set and the data provenance

The document does not explicitly state the sample sizes used for any of the mechanical tests (Push-Out, Torque-to-Fail, Four Point Bend, Shear, Navigation Accuracy). It also does not specify the number of implants used for the Non-Pyrogenicity Endotoxin Testing beyond "worst case subject RIALTO™ SI Fusion implants."

The data provenance is from Medtronic Sofamor Danek USA, Inc. and is for the purpose of a 510(k) premarket notification, which typically involves laboratory testing rather than patient data. Therefore, it is not retrospective or prospective in terms of human clinical data. The materials used (Titanium alloy and stainless steel) have a "long clinical history of safe and effective use," implying a historical, general provenance but not a specific study for this device.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

This information is not applicable to the types of studies described. The performance data consists of mechanical and biocompatibility testing, which do not involve expert assessment for ground truth.

4. Adjudication method (e.g., 2+1, 3+1, none) for the test set

This information is not applicable to the types of studies described, as no expert review or adjudication process for a test set is mentioned.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

There is no mention of an MRMC comparative effectiveness study or any study involving human readers or AI assistance. The device is a physical medical implant system, not a diagnostic or AI-driven system.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

This information is not applicable as the device is a physical implant system, not an algorithm or AI system.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

For the mechanical testing, the "ground truth" is established by engineering standards and specifications (ASTM F543-13, ASTM F2193-02 (2007)) and comparison to the performance of predicate devices. For biocompatibility, the "ground truth" is based on the established clinical history of materials. For non-pyrogenicity, the "ground truth" is a regulatory standard (20 EU/device pyrogen limit, ANSI/AAMI ST72, USP <161>).

8. The sample size for the training set

This information is not applicable as there is no mention of a "training set" for an algorithm or AI.

9. How the ground truth for the training set was established

This information is not applicable as there is no mention of a "training set" for an algorithm or AI.

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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 border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol resembling an eagle or a stylized human profile, composed of three interconnected lines or shapes.

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

August 12, 2016

Medtronic Sofamor Danek Mr. Ankit Shah Senior Regulatory Affairs Specialist 1800 Pyramid Place Memphis, Tennessee 38132

Re: K161210

Trade/Device Name: RIALTO™ SI Fusion System, MEDTRONIC RESUSABLE INSTRUMENTS FOR USE WITH IPC™ POWEREASE™ SYSTEM, MEDTRONIC NAVIGATED MANUAK REUSABLE INSTRUMENTS FOR USE WITH THE STEALTHSTATION" AND IPC™ POWEREASE "SYSTEMS Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: OUR, OLO, HWE Dated: July 29, 2016

Received: August 1, 2016

Dear Mr. Shah:

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

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(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 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,

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
Indications for UseForm Approved: OMB No. 0910-0120
Expiration Date: January 31, 2017
See PRA Statement below.
510(k) Number (if known)K161210
Device NameRIALTOTM SI Fusion System
Indications for Use (Describe)The RIALTOTM SI Fusion System is intended for sacroiliac joint fusion for conditions including sacroiliac joint disruptions and degenerative sacroiliitis.
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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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 FDA 3881 (8/14)

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DEPARTMENT OF HEALTH AND HUMAN SERVICESFood and Drug AdministrationIndications for UseForm Approved: OMB No. 0910-0120Expiration Date: January 31, 2017See PRA Statement below.
510(k) Number (if known)K161210
Device NameMEDTRONIC REUSABLE INSTRUMENTS FOR USE WITH THE IPCTM POWEREASEM SYSTEM
Indications for Use (Describe)IPCT™ System is indicated for the incision/cutting, removal, drilling and sawing of soft and hard tissue and bone, and biomaterials in Neurosurgical (Cranial, Craniofacial), Orthopedic, Arthroscopic, Spinal, Sternotomy, and General surgical procedures. The IPCTM POWEREASET™ System is indicated for drilling, tapping and driving screws and working end attachments during spinal surgery, including open and minimally invasive procedures. It is also used in placement or cutting of screws, posts and rods.
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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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 FDA 3881 (8/14) Page 1 of 1 PSC Publishing Services (301) 443-6740 EF

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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
Indications for Use
Form Approved: OMB No.0910-0120
Expiration Date:January 31, 2017
See PRA Statement below.
510(k) Number (if known)K161210
Device NameMEDTRONIC NAVIGATED MANUAL REUSABLE INSTRUMENTS FOR USE WITH THE STEALTHSTATION TM AND IPC TM POWEREASETM SYSTEMS
Indications for Use (Describe)Medtronic Navigated Reusable Instruments are intended to be used during the preparation and placement of Medtronic screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Navigated Reusable Instruments are specifically designed for use with the StealthStation™ System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy. Medtronic Navigated Reusable Instruments are also compatible with the IPCTM POWEREASET™ System.
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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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 FDA 3881 (8/14)Page 1 of 1
-----------------------------------

PSC Publishing Services (301) 443-6740 EF

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RIALTO™ SI Fusion System 510(k) SUMMARY July 2016

  • I. Medtronic Sofamor Danek USA, Inc. Submitter 1800 Pyramid Place Memphis, TN 38132 (901)396-3133
    Contact Ankit K. Shah Senior Regulatory Affairs Specialist

July 28, 2016 Date Prepared

  • Device II.
    • RIALTO™ SI Fusion System, Medtronic Reusable Name of Device Instruments for Use with the IPC™ Powerease™ System, and Medtronic Navigated Manual Reusable Instruments for use with the StealthStation™ and IPC™M Powerease™ Systems
    • Smooth or threaded metallic bone fixation fastener Common Name (Implant) Taps, Drivers and Drills (Instrument)
    • Classification Name Sacroiliac Joint Fixation - OUR (For Implant)

Stereotaxic Instrument - OLO (For Navigated Instruments)

Surgical Instrument Motors and Accessories/Attachments -HWE

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(For Instruments Compatible with the IPC®POWEREASE® System)
ClassificationClass II (Implant and Instruments)
Product CodesOUR (Implants)21 CFR 888.3040OLO (Navigated Instruments)21 CFR 882.4560
HWE (IPC® POWEREASE® Compatible Instruments)21 CFR 878.4820
PredicatesThere are 6 Predicates.
MSB Sacroiliac Joint Fusion DeviceK110472, S.E. 05/29/2012 (Primary Predicate)
iFuse Implant SystemK131405, S.E. 10/16/2013
IPC® POWEREASE® SystemK111520, S.E. 10/26/2011
Navigated CD Horizon Solera Screwdriver/TapsK140454, S.E. 05/22/2014
Navigated CD HORIZON® SOLERA™ Screwdrivers, CDHORIZON® SOLERA™ Taps, CD HORIZON®SOLERA™ Iliac Taps, CD HORIZON® LEGACY™ TapsK124004, S.E. 03/22/2013
Navigated Disc Prep Instruments and CAPSTONE TrialsK150231, S.E. 06/16/2015
The predicates have not been subject to a design relatedrecall.

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III.Product Description

RIALTO™ SI Fusion System

The subject RIALTOTM SI Fusion System consists of cannulated devices available in various lengths, used to provide stabilization when fusion of the sacroiliac joint is desired. Autograft and/or allograft may be placed in conjunction with the RIALTO™ SI Fusion System. The RIALTO™ implant are made using Titanium Alloy and are 40mm-60mm in length with a diameter of 12mm. This device may be implanted via a minimally invasive approach using fluoroscopy or navigated instruments compatible with Medtronic StealthStation® and IPC® POWEREASE®.

Medtronic Reusable Instruments Only Compatible with the IPC® POWEREASE® System

The subject Medtronic Reusable Taps, Drivers and Drills are spine preparation instruments made of high grade stainless steel and are designed specifically for subject RIALTO™ SI Fusion System. The subject Taps, Drivers and Drills are compatible with Medtronic's IPC® POWEREASE® System may be connected to the IPC® POWEREASE® handpiece. The subject Taps, Drivers and Drills can be used manually using existing Medtronic Class I Exempt quick connect handles in place of the IPC® POWEREASE® handpiece.

Medtronic Reusable Instruments Compatible with the STEALTHSTATION® System and IPC® POWEREASE® System

The subject Medtronic Navigated Reusable Taps, Drivers and Drills are spine preparation instruments made of high grade stainless steel. These instruments were specifically designed for use with subject RIALTO™ SI Fusion System in procedures where the use of stereotactic surgery may be appropriate. The subject Taps, Drivers and Drills are also compatible with Medtronic's IPC® POWEREASE™ System when connected to the POWEREASE™ handpiece or may be used manually with existing Medtronic Class I Exempt quick connect handles in place of the IPC® POWEREASE® handpiece or the NavLock™ tracker.

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IV. Indications for Use:

RIALTO™ SI Fusion System

The RIALTO™ SI Fusion System is intended for sacroiliac joint fusion for conditions including sacroiliac joint disruptions and degenerative sacroiliitis.

Medtronic Reusable Instruments For Use with the IPC® POWEREASE® System

IPC® System is indicated for the incision/cutting, removal, drilling and sawing of soft and hard tissue and bone, and biomaterials in Neurosurgical (Cranial, Craniofacial), Orthopedic, Arthroscopic, Spinal, Sternotomy, and General surgical procedures.

The IPC® POWEREASE® System is indicated for drilling, tapping and driving screws and working end attachments during spinal surgery, including open and minimally invasive procedures. It is also used in placement or cutting of screws, posts and rods.

Medtronic Navigated Reusable Instruments For Use with STEALTHSTATION® and IPC® POWEREASE™ Systems

Medtronic Navigated Reusable Instruments are intended to be used during the preparation and placement of Medtronic screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Navigated Reusable Instruments are specifically designed for use with the StealthStation® System, which is indicated for any medical condition in which stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra, can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy. Medtronic Navigated Reusable Instruments are also compatible with the IPC® POWEREASE™ System.

V. Comparison of Technological Characteristics

The primary predicate for the RIALTO™ SI Fusion System is the predicate SI-FIX Sacroiliac Joint Fusion System K110472, S.E. 05/29/2012 (Primary Predicate).

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The subject RIALTO™ SI Fusion System implants have the same or similar intended use, fundamental scientific technology, material, and indications as the following FDA cleared predicates K110472 (S.E. 05/29/2012) and K131405 (S.E. 10/16/2013).

The subject RIALTO™ SI Fusion System instruments have the same or similar intended use, fundamental scientific technology, material, and indications as the following FDA cleared predicates K111520 (S.E. 10/26/2011), K110472 (S.E. 05/29/2012), K140454 (S.E. 05/22/2014), K124004 (S.E. 03/22/2013) and K150231 ( S.E. 06/16/2015)

VI. Performance Data

The following performance data are provided in support of the substantial equivalence determination.

Biocompatibility

Identical to the primary predicate devices the implants in the subject RIALTO™ SI Fusion System are made using Titanium alloy.

The non-sterile instruments are manufactured using stainless steel and are identical to the materials used for the instruments cleared under predicate submissions.

The titanium alloy and stainless steel material used for the subject RIALTO™ SI Fusion System implants and instruments have a long clinical history of safe and effective use in similar commercially available medical devices. Therefore, no additional biocompatibility testing is required.

Mechanical Testing

In accordance with the Guidance for Industry and FDA Staff - Spinal System 510(k)'s, Medtronic has evaluated the subject devices to demonstrate substantial equivalence to the predicate devices.

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Design verification testing for the subjectimplants was completed in accordance with

  • ASTM F543-13 Standard Specification and Test Methods for Metallic Medical . Bone Screws
  • ASTM F2193-02 (2007) Standard Specifications and Test Methods for . Components Used in the Surgical Fixation of the Spinal Skeletal System

The tests completed were:

  • Push-Out -
  • Torque—to-Fail -
  • Four Point Bend -
  • Shear Testing -

The verification testing on the instruments included Navigation accuracy on the instruments compatible with StealthStation™ and IPC™ Powerease™.

The subject devices met the pre-determined acceptance criteria for all tests. Therefore, design verification testing determined that the subject screws and instruments are substantially equivalent to the predicate devices.

Design validation testing was performed that demonstrated that the subject instruments performed as intended and to validate the surgical approach.

Non-Pyrogenicity Endotoxin Testing

The bacterial endotoxin test, also known as Limulus Amebocyte Lysate (LAL) test, was performed utilizing worst case subject RIALTO™ SI Fusion implants to verify that the subject implants meet the 20 endotoxin units (EU)/device pyrogen limit specification. Testing was successfully performed and it was confirmed that the subject implants meet the 20 EU/device testing limit for general medical devices that are implanted as outlined in ANSI/AAMI ST72, Bacterial endotoxins - Test methods, routine monitoring, and

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alternatives to batch testing and USP <161>, Transfusion and Infusion Assemblies and Similar Medical Devices.

VII. Conclusions

Based on the test results and additional supporting information provided in this premarket notification, the subject devices demonstrated substantial equivalence to the legally marketed predicate devices.

§ 888.3040 Smooth or threaded metallic bone fixation fastener.

(a)
Identification. A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.(b)
Classification. Class II.