K Number
K182345
Device Name
Spineology Navigation Instruments
Manufacturer
Date Cleared
2018-09-21

(24 days)

Product Code
Regulation Number
882.4560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic 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, long bone, or vertebra, can be identified relative to a CT- or MR-based model, fluoroscopic images, or digitalized landmarks of the anatomy.
Device Description
Spineology Navigation Instruments are non-sterile, reusable instruments; including awls, bone taps, drills, and screwdrivers that are operated manually. These instruments are manufactured from stainless steel in accordance with ASTM F899 and are intended to be used within the context and limitations of the indications for use for Spineology's FDA-cleared Fortress™, Threshold™, Threshold™ V2, and Palisade™ Pedicular Fixation Systems and the Medtronic Synergy Experience StealthStation® System S7 (v2.1.0).
More Information

Not Found

No
The summary describes manual surgical instruments used in conjunction with a navigation system, but there is no mention of AI or ML being incorporated into the instruments themselves or the navigation system's core functionality as described.

No.
The device is a set of navigation instruments (awls, bone taps, drills, screwdrivers) used during spinal surgery to assist in precisely locating anatomical structures for pedicle screw placement, rather than directly treating a medical condition.

No.
The device description indicates that the Spineology Navigation Instruments are surgical tools (awls, bone taps, drills, screwdrivers) used during spinal surgery to assist in the placement of pedicle screws by precisely locating anatomical structures. This is an intraoperative guidance or assistive device, not a diagnostic device that identifies a disease or condition. Its purpose is to guide surgical actions, not to diagnose.

No

The device description explicitly states that the Spineology Navigation Instruments are non-sterile, reusable instruments made from stainless steel, including awls, bone taps, drills, and screwdrivers. These are physical hardware components, not software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information for diagnosis, monitoring, or screening.
  • Device Function: The Spineology Navigation Instruments are surgical instruments (awls, bone taps, drills, screwdrivers) used during spinal surgery to assist the surgeon in precisely locating anatomical structures. They are used in conjunction with a navigation system that utilizes imaging data (CT, MR, fluoroscopy) of the patient's anatomy.
  • Intended Use: The intended use is to aid in the placement of pedicle screws during spinal surgery, not to analyze biological specimens for diagnostic purposes.

The device is a surgical navigation tool, not a diagnostic test performed on samples outside the body.

N/A

Intended Use / Indications for Use

Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic 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, long bone, or vertebra, can be identified relative to a CT- or MR-based model, fluoroscopic images, or digitalized landmarks of the anatomy.

Product codes

OLO

Device Description

Spineology Navigation Instruments are non-sterile, reusable instruments; including awls, bone taps, drills, and screwdrivers that are operated manually. These instruments are manufactured from stainless steel in accordance with ASTM F899 and are intended to be used within the context and limitations of the indications for use for Spineology's FDA-cleared Fortress™, Threshold™, Threshold™ V2, and Palisade™ Pedicular Fixation Systems and the Medtronic Synergy Experience StealthStation® System S7 (v2.1.0).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CT- or MR-based model, fluoroscopic images

Anatomical Site

Spinal segments in skeletally mature patients (thoracic, lumbar, and sacral spine), skull, long bone, or vertebra.

Indicated Patient Age Range

skeletally mature patients

Intended User / Care Setting

Surgeon, not explicitly stated

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)

Spineology performed design verification activities to demonstrate that the design outputs of the subject Spineology Navigation Instruments met the design input requirements. Testing of the Adapter included, but was not limited to, assessment of instrument mating and confirmation that performance of Spineology Navigation Instruments is unaffected by use of the Adapter.
Spineology conducted a risk assessment to confirm that the subject Adapter for Spineology Navigation Instruments does not introduce new issues of safety or effectiveness.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K180796, K172518

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.4560 Stereotaxic instrument.

(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square, the words "U.S. FOOD & DRUG" are written in blue, with the word "ADMINISTRATION" written in a smaller font size below.

September 21, 2018

Spineology Inc Karen Roche VP, Operations & Technologies 7800 Third Street N., Suite 600 St. Paul, Minnesota 55128

Re: K182345

Trade/Device Name: Spineology Navigation Instruments Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: August 27, 2018 Received: August 28, 2018

Dear Karen Roche:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 of medical device-related adverse events) (21 CFR 803) for

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

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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Form Approved: OMB No. 0910-0120

Expiration Date: 06/30/2020

See PRA Statement below.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K182345

Device Name Spineology Navigation Instruments

Indications for Use (Describe)

Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic StealthStation® System, which is indical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, long bone, or vertebra, can be identified relative to a CT- or MR-based model. fluoroscopic images, or digitalized landmarks of the anatomy.

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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Spineology ***

510(k) Summary

Date Prepared:September 18, 2018
Submitter:Spineology Inc.
7800 3rd Street North, Suite 600
Saint Paul, MN 55128
Establishment Registration Number:2135156
Contact Person:Karen Roche
Vice President, Operations & Technology
Phone: 651.256.8513
Fax: 651.256.8505
Email: kroche@spineology.com
Device Name and Classification
Trade Name:Spineology Navigation Instruments
Common Name:Orthopedic Stereotaxic instrument
Classification Name:Stereotaxic Instrument
Product Codes:OLO
Regulatory Class:Class II
Regulation Number:21 CFR 882.4560

Predicate Device

K180796, K172518 Spineology Navigation Instruments (Spineology Inc.)

Orthopedic

Purpose 1.

Panel:

The purpose of this Premarket Notification is to obtain FDA clearance for the addition of an Adapter to Spineology's FDA cleared Spineology Navigation Instrument set.

Device Description 2.

A. Spineology Navigation Instruments

Spineology Navigation Instruments are non-sterile, reusable instruments; including awls, bone taps, drills, and screwdrivers that are operated manually. These instruments are manufactured from stainless steel in accordance with ASTM F899 and are intended to be used within the context and limitations of the indications for use for Spineology's FDA-cleared Fortress™, Threshold™, Threshold™ V2, and Palisade™ Pedicular Fixation Systems and the Medtronic Synergy Experience StealthStation® System S7 (v2.1.0).

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B. Spineology Pedicular Fixation Systems

Spineology Fortress, Threshold V2, and Palisade Pedicular Fixation Systems consist of screws, curved and straight rods, and Connex Connector devices to allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. All screws are available with or without a hydroxyapatite coating. These systems are intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine. The screws can be placed in the pedicles in a variety of trajectories ranging from the standard anatomic transpedicular path projected medially toward the ventral vertebral body, to a caudocephalad path sagittally and a laterally directed path in the transverse plane.

3. Indications for Use

Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic 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, long bone, or vertebra, can be identified relative to a CT- or MR-based model, fluoroscopic images, or digitalized landmarks of the anatomy.

4. Technological Characteristics

When compared to the predicate device, Spineology Navigation Instruments have the same intended use and equivalent technological characteristics, including:

  • Primary Design Features, including but not limited to, critical dimensions, distal (functional) end features (i.e., implant/inserter interface), and proximal end mating features
  • . Materials of Construction
  • Fundamental Scientific Technology
  • Function/Performance
  • .
  • Use with Medtronic StealthStation System
  • Principle of Operation

5. Non-Clinical Testing

Spineology performed design verification activities to demonstrate that the design outputs of the subject Spineology Navigation Instruments met the design input requirements. Testing of the Adapter included, but was not limited to, assessment of instrument mating and confirmation that performance of Spineology Navigation Instruments is unaffected by use of the Adapter.

Spineology conducted a risk assessment to confirm that the subject Adapter for Spineology Navigation Instruments does not introduce new issues of safety or effectiveness.

6. Clinical Testing

Clinical testing was not performed or required to establish the substantial equivalence of Spineology Navigation Instruments to the predicate device.

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7. Conclusion

Spineology has demonstrated the substantial equivalence of the subject Spineology Navigation Instruments through the comparison of these devices to the legally marketed predicate device and confirmed that the intended use is the same and any differences in technological characteristics between the subject and predicate device do not raise new issues of safety and effectiveness.