(163 days)
No
The summary describes a mechanical spinal fixation system and its components. There is no mention of software, algorithms, image processing, or any terms related to AI/ML. The performance studies are mechanical tests, not algorithmic performance evaluations.
Yes
The device is intended to provide immobilization of spinal segments as an adjunct to fusion in the treatment of various acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine, which clearly indicates a therapeutic purpose.
No
The NIDO™ Pedicle Screw System is a surgical implant designed for spinal fixation, providing immobilization of spinal segments. It is not used for diagnosing medical conditions.
No
The device description explicitly states it is a "modular head, multiple component posterior spinal fixation system" consisting of physical components like pedicle screw tulips, rod connectors, and screws manufactured from Titanium alloy. This indicates it is a hardware-based medical device.
Based on the provided information, the NIDO™ Pedicle Screw System is not an IVD (In Vitro Diagnostic) device.
Here's why:
- IVD Definition: In Vitro Diagnostic devices are used to examine specimens (like blood, urine, or tissue) taken from the human body to provide information for diagnosis, monitoring, or screening.
- NIDO™ Pedicle Screw System Function: The NIDO™ Pedicle Screw System is a surgical implant used to stabilize the spine. It is physically implanted into the patient's body.
- Intended Use: The intended use clearly states it's for "immobilization of spinal segments in skeletally mature patients as an adjunct to fusion." This is a therapeutic and structural function, not a diagnostic one based on analyzing bodily specimens.
- Device Description: The description details the materials and components of a surgical implant, not equipment for analyzing biological samples.
Therefore, the NIDO™ Pedicle Screw System falls under the category of a surgical implant or medical device used for structural support and stabilization, not an In Vitro Diagnostic device.
N/A
Intended Use / Indications for Use
The NIDO™ Pedicle Screw System is intended to provide immobilization 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 thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.
The NIDO™ Pedicle Screw System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; deformities or curvatures (i.e. scoliosis, and/or lordosis), tumor; pseudoarthrosis; and failed previous fusion.
The NIDO™ Pedicle Screw System Cannulated/Fenestrated Screws are intended to be used with saline and radiopaque dye.
Product codes (comma separated list FDA assigned to the subject device)
NKB
Device Description
The NIDO™ Pedicle Screw System is a modular head, multiple component posterior spinal fixation system which consists of subject modular pedicle screw tulips, and rod connectors manufactured from Titanium alloy Ti-6Al-4V per ASTM F136.
The subject pedicle screws are available in solid and cannulated/fenestrated configurations in various sizes to match patient anatomy. The fenestrated/cannulated screws are cannulated for use over a guidewire; they are fenestrated to allow the surgeon to apply a radiopaque dye or saline solution. The fenestrated/cannulated screws are not intended to allow for the use of bone cement. Screw tulips are available in standard, extended tab and closed styles, with a universal locking cap to lock the construct. Rod connectors are provided in domino, lateral and tulip styles.
The subject components are intended for use with previously cleared rods and crosslinks connectors from the primary predicate Cosmolock Pedicle Screw System.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
thoracic, lumbar, and sacral spine / L5-S1 vertebra (L3 to sacrum)
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)
No clinical studies were necessary to demonstrate substantial equivalence.
Non-Clinical Test Summary:
- Static and Dynamic Compression Bending (per ASTM F1717)
- Static Torsion (per ASTM F1717)
- Static Axial Tension (Tulip Shank Disassociation) (per ASTM F1798)
- Static Axial Gripping (per ASTM F1798)
- Static Torsional Gripping (per ASTM F1798)
- Static Flexion-Extension (per ASTM F1798)
- Axial Screw Pullout (per ASTM F543)
The results of this testing indicate that the NIDO™ Pedicle Screw System is substantially equivalent to predicate devices.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.
Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.
Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).
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.
0
September 15, 2023
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Kalitec Medical % Justin Eggleton Vice President, Spine Regulatory Affairs MCRA 803 7th Street NW Washington, District of Columbia 20001
Re: K230974
Trade/Device Name: NIDO™ Pedicle Screw System Regulation Number: 21 CFR 888.3070 Regulation Name: Thoracolumbosacral pedicle screw system Regulatory Class: Class II Product Code: NKB Dated: September 6, 2023 Received: September 6, 2023
Dear Justin Eggleton:
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
1
801); medical device reporting of medical device-related adverse events) (21 CFR 803) for 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 (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 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/cdrh-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,
Image /page/1/Picture/6 description: The image contains the text "Colin O'neill -S" in a simple, sans-serif font. The text is arranged vertically, with "Colin" on the top line and "O'neill -S" on the bottom line. In the background, there is a faded logo of the FDA.
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
2
Indications for Use
510(k) Number (if known) K230974
Device Name NIDO™ Pedicle Screw System
Indications for Use (Describe)
The NIDO™ Pedicle Screw System is intended to provide immobilization 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 thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.
The NIDO™ Pedicle Screw System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; deformities or curvatures (i.e. scoliosis, and/or lordosis), tumor; pseudoarthrosis; and failed previous fusion.
The NIDO™ Pedicle Screw System Cannulated/Fenestrated Screws are intended to be used with saline and radiopaque dye.
| 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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3
510(k) Summary
| Trade Name: | NIDO™ Pedicle Screw System |
|---|---|
| Submitter: | Kalitec Direct, LLC dba Kalitec Medical |
| 618 E. South Street, Suite 500 | |
| Orlando, FL 32801 | |
| Contact: | Keith Cannan |
| Senior Vice President, Quality and Regulatory Affairs | |
| 618 E. South Street, Suite 500 | |
| Orlando, FL 32801 | |
| 407-545-2063 | |
| Prepared By: | Justin Eggleton |
| Vice President, Spine Regulatory Affairs | |
| MCRA, LLC | |
| 803 7th Street NW | |
| Washington, DC 20001 | |
| 202-522-5804 | |
| jeggleton@mcra.com | |
| Date Prepared: | July 31, 2023 |
| Device | |
| Classification: | 21 CFR §888.3070, Thoracolumbosacral pedicle screw system |
| Common Name: | Pedicle screw spinal system |
| Class: | II |
| Product Code: | NKB |
Primary Predicate Device:
| Manufacturer | Device Name | 510(k) Number |
|---|---|---|
| Kalitec Direct LLC dba Kalitec | ||
| Medical | Cosmolock Pedicle Screw System | K172808/ K140678 |
Reference Device:
| Manufacturer | Device Name | 510(k) Number |
|---|---|---|
| Orthofix, Inc. | JANUS® Fenestrated Screws | K180179 |
4
Indications for Use:
The NIDO™ Pedicle Screw System is 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 thoracic, lumbar, and sacral spine: degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, deformities or curvatures (i.e. scoliosis, and/or lordosis), spinal tumor, pseudarthrosis and failed previous fusion.
The NIDO™ Pedicle Screw System is also intended for non-cervical pedicle screw fixation for the following indications: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra in skeletally mature patients receiving fusion by autogenous bone graft having implants attached to the lumbar and sacral spine (L3 to sacrum) with removal of the implants after the attainment of a solid fusion. It is also intended for the following indications: trauma (i.e. fracture or dislocation); spinal stenosis; deformities or curvatures (i.e. scoliosis, and/or lordosis), tumor; pseudoarthrosis; and failed previous fusion.
The NIDO™ Pedicle Screw System Cannulated/Fenestrated Screws are intended to be used with saline and radiopaque dye.
Device Description:
The NIDO™ Pedicle Screw System is a modular head, multiple component posterior spinal fixation system which consists of subject modular pedicle screw tulips, and rod connectors manufactured from Titanium alloy Ti-6Al-4V per ASTM F136.
The subject pedicle screws are available in solid and cannulated/fenestrated configurations in various sizes to match patient anatomy. The fenestrated/cannulated screws are cannulated for use over a guidewire; they are fenestrated to allow the surgeon to apply a radiopaque dye or saline solution. The fenestrated/cannulated screws are not intended to allow for the use of bone cement. Screw tulips are available in standard, extended tab and closed styles, with a universal locking cap to lock the construct. Rod connectors are provided in domino, lateral and tulip styles.
The subject components are intended for use with previously cleared rods and crosslinks connectors from the primary predicate Cosmolock Pedicle Screw System.
Summary of the Technological Characteristics Compared To Predicate:
The NIDO™ Pedicle Screw System is equivalent in material, design, and manufacturing process to the listed predicate devices.
Non-Clinical Test Summary:
- . Static and Dynamic Compression Bending (per ASTM F1717)
- Static Torsion (per ASTM F1717)
- . Static Axial Tension (Tulip Shank Disassociation) (per ASTM F1798)
- Static Axial Gripping (per ASTM F1798) ●
5
- Static Torsional Gripping (per ASTM F1798) •
- Static Flexion-Extension (per ASTM F1798)
- . Axial Screw Pullout (per ASTM F543)
The results of this testing indicate that the NIDO™ Pedicle Screw System is substantially equivalent to predicate devices.
Clinical Test Summary:
No clinical studies were necessary to demonstrate substantial equivalence.
Substantial Equivalence Conclusion:
The NIDO™ Pedicle Screw System is substantially equivalent to the predicate devices listed above. This conclusion is based upon the device's similarities in principles of operation, technology, materials and indications for use.