K Number
K211449
Device Name
Triton™ Sacroiliac Joint Fixation System
Manufacturer
Date Cleared
2021-08-31

(113 days)

Product Code
Regulation Number
888.3040
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Triton™ Sacroiliac Joint Fixation system is intended for fixation of sacroiliac joint distruptions, and intended for sacroiliac joint fusion for conditions including; -sacroiliac joint disruptions, -degenerative sacroiliitis -to augment immobilization and stabilization of the sacroiliac joint in skeletally mature patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion and -Acute, non-acute, and non-traumatic fractures involving the sacroiliac joint
Device Description
The Triton™ Sacroiliac Joint Fixation System is a multiple component system consisting of non-sterile instruments and sterile, cannulated Ø8mm, Ø12mm and Ø14mm Screws offered in multiple lengths. The Triton SI Screws are manufactured from medical-grade titanium alloy (Ti-6Al-4V ELI) per ASTM F3001, Class C. The implants feature 3 fluted channels for bone collection and a tapered proximal tip. The Ø12mm and Ø14mm Screws feature multiple open and porous-filled windows for packing and disbursement of autograft and allograft materials.
More Information

Not Found

No
The device description and performance studies focus on mechanical properties and surgical fixation, with no mention of AI or ML.

Yes
The device is described as a "Sacroiliac Joint Fixation system" and is intended for "fixation of sacroiliac joint disruptions" and "sacroiliac joint fusion," which are therapeutic interventions.

No
The device is described as a "Sacroiliac Joint Fixation system" intended for fixation and fusion of the sacroiliac joint, indicating a therapeutic or surgical purpose rather than a diagnostic one.

No

The device description explicitly states it is a "multiple component system consisting of non-sterile instruments and sterile, cannulated Ø8mm, Ø12mm and Ø14mm Screws" made from titanium alloy. 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 fixation system for the sacroiliac joint. This involves physically implanting a device to stabilize or fuse the joint.
  • Device Description: The description details screws made of titanium alloy, designed for surgical implantation and bone collection/grafting. This is consistent with a surgical implant, not a diagnostic test performed on biological samples.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting specific markers, or providing diagnostic information about a patient's condition based on in vitro analysis.

IVD devices are used to examine specimens from the human body to provide information for diagnosis, monitoring, or screening. This device is a therapeutic device used for surgical intervention.

N/A

Intended Use / Indications for Use

The Triton™ Sacroiliac Joint Fixation system is intended for fixation of sacroiliac joint distruptions, and intended for sacroiliac joint fusion for conditions including;
-sacroiliac joint disruptions,
-degenerative sacroilititis
-to augment immobilization and stabilization of the sacroiliac joint in skeletally mature patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion and
-Acute, non-acute, and non-traumatic fractures involving the sacroiliac joint.

Product codes

OUR

Device Description

The Triton™ Sacroiliac Joint Fixation System is a multiple component system consisting of non-sterile instruments and sterile, cannulated Ø8mm, Ø12mm and Ø14mm Screws offered in multiple lengths. The Triton SI Screws are manufactured from medical-grade titanium alloy (Ti-6Al-4V ELI) per ASTM F3001, Class C. The implants feature 3 fluted channels for bone collection and a tapered proximal tip. The Ø12mm and Ø14mm Screws feature multiple open and porous-filled windows for packing and disbursement of autograft and allograft materials.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

sacroiliac joint, sacropelvic

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)

Non-clinical Testing:
Static Pull Out per ASTM F543
Static Torsion per ASTM F543
Static Cantilever per ASTM F2193
Dynamic Cantilever per ASTM F2193

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

Not Found

Predicate Device(s)

K203138, K021932, K151818, K171686

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

August 31, 2021

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left, there is a seal with an abstract design and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA" arranged around it. To the right, there is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG" in blue, and "ADMINISTRATION" in a smaller font size below it.

ChoiceSpine, LLC Kim Finch Director of Regulatory Affairs 400 Erin Drive Knoxville, Tennessee 37919

Re: K211449

Trade/Device Name: Triton™ Sacroiliac Joint Fixation System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: OUR Dated: July 29, 2021 Received: July 30, 2021

Dear Kim Finch:

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/cdrl/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

1

devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrl-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

for

Colin O'Neill, M.B.E. Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K211449

Device Name

Triton™ Sacroiliac Joint Fixation system

Indications for Use (Describe)

The Triton™ Sacroiliac Joint Fixation system is intended for fixation of sacroiliac joint distruptions, and intended for sacroiliac joint fusion for conditions including;

-sacroiliac joint disruptions,

-degenerative sacroilititis

-to augment immobilization and stabilization of the sacroiliac joint in skeletally mature patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion and

-Acute, non-acute, and non-traumatic fractures involving the sacroiliac joint

Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

Date:July 7, 2021
Sponsor:ChoiceSpine, LLC
400 Erin Drive
Knoxville, TN 37919
Phone:865-246-3333
Fax:865-246-3334
Contact Person:Kim Finch, Director of Regulatory Affairs
Proposed Proprietary
Trade Name:Triton™ Sacroiliac Joint Fixation System
Product Class:Class II
Classification Name:Triton™ Sacroiliac Joint Fixation System
• 21 CFR 888.3040- Smooth or Threaded Metallic Bone Fixation Fastener
Device Product Code:Triton™ Sacroiliac Joint Fixation System
• OUR
Purpose of Submission:The purpose of this submission is to gain clearance for the new Triton™ Sacroiliac Joint Fixation System.
Device Description:The Triton™ Sacroiliac Joint Fixation System is a multiple component system
consisting of non-sterile instruments and sterile, cannulated Ø8mm, Ø12mm
and Ø14mm Screws offered in multiple lengths. The Triton SI Screws are
manufactured from medical-grade titanium alloy (Ti-6Al-4V ELI) per ASTM
F3001, Class C. The implants feature 3 fluted channels for bone collection and
a tapered proximal tip. The Ø12mm and Ø14mm Screws feature multiple
open and porous-filled windows for packing and disbursement of autograft
and allograft materials.
Indications for Use:The Triton™ Sacroiliac Joint Fixation System is intended for fixation of
sacroiliac joint disruptions, and intended for sacroiliac joint fusion for
conditions including;
• sacroiliac joint disruptions
• degenerative sacroiliitis
• to augment immobilization and stabilization of the sacroiliac joint in
skeletally mature patients undergoing sacropelvic fixation as part of a
lumbar or thoracolumbar fusion and
• Acute, non-acute, and non-traumatic fractures involving the sacroiliac
joint.
Materials:The Triton™ Sacroiliac Joint Fixation System implants are composed of a
titanium alloy (Ti-6Al- 4V ELI per ASTM F3001, Class C). The system
instrumentation is made from medical grade stainless steels, aluminum, and
Predicate Devices:Primary Predicate:
Orthofix Firebird SI Fusion System (K203138)
Additional Predicates:
Synthes Ø6.5mm Cannulated Screw (K021932)
Zyga Technology, Inc. SImmetry® Sacroiliac Joint Fusion System (K151818)
ChoiceSpine Hawkeye VBR System (K171686)
Non-clinical Testing:Static Pull Out per ASTM F543
Static Torsion per ASTM F543
Static Cantilever per ASTM F2193
Dynamic Cantilever per ASTM F2193
Conclusion/Technological Characteristics:The only difference between the Triton™ Sacroiliac Joint Fixation System and
the predicate devices are device geometry. The differences in geometry are
not significant and would not adversely affect the use of the product. The
Triton™ System is substantially equivalent in material, size offerings,
classification, anatomical location, manufacturing and sterilization methods,
surgical approach, principle of operation, indications for use, and mechanical
testing plan. The system components were assessed in accordance with ISO

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plastics.

10993-1 and found substantially equivalent to the predicate devices.