· Sacroiliac joint dysfunction that is a direct result of sacroiliac joint disruption and degenerative sacroiliitis. This includes conditions whose symptoms began during pregnancy or in the peripartum period and have persisted postpartum for more than 6 months.

· To augment immobilization and stabilization of the sacroiliac joint in patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion.

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

· Degenerative disc disease (DDD) as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies

· Spondylolisthesis
· Trauma (i.e., fracture or dislocation)
· Spinal stenosis
· Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
Spinal tumor
Pseudarthrosis
· Failed previous fusion

When connected to compatible pedicle screws with 5.5- or 6.0-mm posterior rods made from either titanium alloy or cobalt chrome alloys, the iFuse Bedrock Granite Implant System is intended to provide immobilization and stabilization of spinal segments in skeletally immature patients as an adjunct to thoracolumbar fusion for the treatment of progressive spinal deformities (i.e., scoliosis, or lordosis) including idiopathic scoliosis, neuromuscular scoliosis, and congenital scoliosis, as well as the following conditions: spondylolysis, fracture caused by tumor and/or trauma, pseudarthrosis, and/or failed previous fusion. These devices are to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

Please refer to the additional information section in the Instructions for Use on compatible pedicle screw system rods.

The iFuse Bedrock Granite Navigation instruments are intended to be used with the iFuse Bedrock Granite Implant System to assist the surgeon in precisely locating anatomical structures in iFuse Bedrock Granite Implant System procedures, in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as the pelvis or vertebra, can be identified relative to the acquired image (CT, MR, 2D fluoroscopic image or 3D fluoroscopic image reconstruction) and/or an image data based model of the anatomy. iFuse Bedrock Granite Navigation instruments are intended to be used with the Medtronic StealthStation System.

Device Description

The iFuse Bedrock Granite® Implant System consists of various lengths and diameters, and associated instruments sets. Instrument sets are provided for both open and minimally invasive approaches. The titanium (Ti-6A1-4V ELI) implant consists of a porous fusion sleeve with threaded length attached to a solid post that has connection and implant features of a typical pedicle fixation screw. It is intended to provide sacroiliac joint fusion in the sacral alar iliac (SAI) trajectory (when used with commercially available sacroiliac joint fusion promoting devices), and foundational stabilization when connected to pedicle screw fixation systems in both the SAI and the iliac trajectories. Additionally, iFuse Bedrock Granite can be placed into the S1 pedicle. The device is designed for connection to commercially available pedicle screw systems via Ø5.5 mm or Ø6.0 mm titanium alloy or cobalt chrome alloy spinal fixation rods.

AI/ML Overview

This FDA 510(k) summary document for the iFuse Bedrock Granite® Implant System does not contain the detailed information required to describe the acceptance criteria and the study that proves the device meets those criteria in the format requested.

Specifically, the document primarily focuses on demonstrating substantial equivalence to a predicate device based on mechanical benchtop testing rather than clinical performance or AI/software-related performance metrics.

Here's a breakdown of what can be extracted and what is missing:

The device is a medical implant system and instruments, not an AI or software-only device. Therefore, questions related to AI performance, such as sample sizes for test/training sets, ground truth establishment for AI, expert numbers for ground truth, adjudication methods, and MRMC studies, are not applicable in this context.

Information that can be extracted:

1. Table of Acceptance Criteria and Reported Device Performance:

The document mentions several performance tests according to ASTM standards. It states: "The test results demonstrate that the device is substantially equivalent to the predicate device." However, the specific acceptance criteria (e.g., minimum load, maximum deformation) and the numerical results (reported device performance) for each test are not provided in this summary. It only lists the types of tests performed.

Acceptance Criteria	Reported Device Performance (Not explicitly stated, only "substantially equivalent")
Static and Dynamic Cantilever Testing per ASTM F2193	Met substantial equivalence to predicate
Post-Fatigue Sleeve Dissociation Testing	Met substantial equivalence to predicate
Static Torsion Testing per ASTM 543	Met substantial equivalence to predicate
Static Axial Pull out Testing per ASTM 543	Met substantial equivalence to predicate
Characterizing the Porous Surface Bedrock Granite Test (Static Shear, Shear Fatigue, Static Tensile, Abrasion Properties)	Met substantial equivalence to predicate
Construct Testing per ASTM F1717 (Static and Dynamic Compression Bending, Static Torsion)	Met substantial equivalence to predicate

Information that is missing or not applicable based on the document:

2. Sample size used for the test set and the data provenance: Not applicable. The tests mentioned are benchtop mechanical tests, not clinical studies with patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for mechanical bench testing is typically defined by engineering specifications and material properties, not expert clinical consensus from images.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set: Not applicable.
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: Not applicable. This is a mechanical implant, not an AI diagnostic or assistive device. The navigation instruments are mentioned, but no performance data is provided for them, let alone an MRMC study comparing human performance with and without AI assistance for these instruments.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: Not applicable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): For the mechanical tests, the "ground truth" would be the engineering specifications and performance characteristics of the predicate device against which the subject device's performance is compared for substantial equivalence. No clinical ground truth types are mentioned.
8. The sample size for the training set: Not applicable. This is not an AI/ML device that requires a training set.
9. How the ground truth for the training set was established: Not applicable.

In summary, this FDA 510(k) pertains to a physical medical device (implant system) and its mechanical performance, rather than an AI-driven software device. Therefore, many of the requested details related to AI performance metrics, clinical studies, and expert-established ground truths are not present or relevant in this document. The "study" proving acceptance criteria is a series of mechanical benchtop tests demonstrating substantial equivalence to a predicate device.

Summary

{0}------------------------------------------------

January 26, 2024

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Si-Bone, Inc. Jayasri Prabakaran Associate Director, Regulatory Affairs 471 El Camino Real, Suite 101 Santa Clara, California 95050

Re: K233508

Trade/Device Name: iFuse Bedrock Granite® Implant System Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth Or Threaded Metallic Bone Fixation Fastener Regulatory Class: Class II Product Code: OUR, NKB, OLO Dated: October 31, 2023 Received: October 31, 2023

Dear Jayasri Prabakaran:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

{1}------------------------------------------------

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 mediation-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,

Eileen
Digitally signed
by Eileen Cadel -
S
Cadel -S Date: 2024.01.26
15:14:24 -05'00'
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

{2}------------------------------------------------

Indications for Use

510(k) Number (if known) K233508

Device Name

iFuse Bedrock Granite® Implant System

Indications for Use (Describe)

The iFuse Bedrock Granite Implant System is intended for sacroiliac joint fusion in skeletally mature patients for the following conditions:

· Sacroiliac joint dysfunction that is a direct result of sacroiliac joint disruption and degenerative sacroilitis. This includes conditions whose symptoms began during pregnancy or in the period and have persisted postpartum for more than 6 months.

· To augment immobilization and stabilization of the sacroillac joint in patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion.

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

· Degenerative disc disease (DDD) as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies

Spondylolisthesis
· Trauma (i.e., fracture or dislocation)
· Spinal stenosis
· Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
· Spinal tumor
Pseudarthrosis
· Failed previous fusion

Please refer to the additional information section in the Instructions for Use on compatible pedicle screw system 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)

{3}------------------------------------------------

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."

{4}------------------------------------------------

510(k) SUMMARY

iFuse Bedrock Granite® Implant System

I. 510(k) SUBMITTER

SI-BONE, Inc.

471 El Camino Real, Suite 101, Santa Clara, CA 95050 Phone: 408-207-0700 Fax: 408-557-8312

Contact Person:	Jayasri Prabakaran, Associate Director, Regulatory Affairs
FDA Establishment Registration No.:	3007700286
Date Prepared:	January 18, 2024

II. DEVICE

Trade Name of Device	iFuse Bedrock Granite® Implant System
Classification Name	Sacroiliac Joint Fixation
Classification	II
Regulation Number	21 CFR 888.3040; Smooth or threaded metallic bone fastener21 CFR 888.3070, Thoracolumbosacral pedicle screw system21 CFR 882.4560, Stereotaxic instrument
Product Code	OUR, NKB, OLO

III. PREDICATE DEVICES

Primary Predicate:

Predicate Device	Manufacturer	510(k)#	Clearance Date
iFuse Bedrock Granite ImplantSystem	SI-BONE, Inc.	K222774	December 22, 2022

Additional Predicates:

Predicate Device	Manufacturer	510(k)#	Clearance Date
CD Horizon Spinal System	Medtronic SofamorDanek	K223494	January 23, 2023
SpineCraft, LLC	SpineCraft, LLC	K223273	December 22, 2022

{5}------------------------------------------------

IV. DEVICE DESCRIPTION

V. INDICATIONS FOR USE

The iFuse Bedrock Granite Implant System is intended for sacroiliac joint fusion in skeletally mature patients for the following conditions:

· To augment immobilization and stabilization of the sacroiliac joint in patients undergoing sacropelvic fixation as part of a lumbar or thoracolumbar fusion.

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

· Degenerative disc disease (DDD) as defined by back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies

· Spondylolisthesis
· Trauma (i.e., fracture or dislocation)
· Spinal stenosis
· Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
Spinal tumor
Pseudarthrosis
· Failed previous fusion

Please refer to the additional information section in the Instructions for Use on compatible pedicle screw system rods.

The iFuse Bedrock Granite Navigation instruments are intended to be used with the iFuse Bedrock Granite Implant System to assist the surgeon in precisely locating anatomical structures in iFuse

{6}------------------------------------------------

Bedrock Granite Implant System procedures, in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as the pelvis or vertebra, can be identified relative to the acquired image (CT, MR, 2D fluoroscopic image or 3D fluoroscopic image reconstruction) and/or an image data based model of the anatomy. iFuse Bedrock Granite Navigation instruments are intended to be used with the Medtronic StealthStation System.

SUMMARY OF SUBSTANTIAL EQUIVALENCE VI.

The subject device is substantially equivalent to its predicate in terms of intended use and indications for use, technological characteristics, materials, manufacturing methods, and principles of operation. The differences in the indication for use statement from the previously cleared legally marketed predicate are not critical to the intended therapeutic, diagnostic, or surgical use of the device. Therefore, based on the intended use, indications for use, technological characteristics, and principles of operation, iFuse Bedrock Granite Implant System is substantially equivalent to its predicate device.

VII. PERFORMANCE DATA

SI-BONE performed the following performance tests:

· Static and Dynamic Cantilever Testing per ASTM F2193
· Post-Fatigue Sleeve Dissociation Testing
· Static Torsion Testing per ASTM 543
· Static Axial Pull out Testing per ASTM 543
· Characterizing the Porous Surface Bedrock Granite Test (Static Shear, Shear Fatigue, Static Tensile, Abrasion Properties)
· Construct Testing per ASTM F1717 (Static and Dynamic Compression Bending, Static Torsion)

The test results demonstrate that the device is substantially equivalent to the predicate device.

VIII. CONCLUSION

The modified iFuse Bedrock Granite implant (reduced diameter and length) is substantially equivalent to its predicate in terms of intended use and indications for use, technological characteristics, materials, manufacturing methods, and principles of operation. Testing has shown substantially equivalent benchtop performance. The differences in the indication for use statement from previous cleared legally marketed predicates are not critical to the intended therapeutic, prosthetic, or surgical use of the device. Test results demonstrate that the device is substantially equivalent to the legally marketed device and does not raise different questions of safety and effectiveness than the predicate device.

Regulation Number and Section

§ 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.