EBI SPINELINK SYSTEM by EBI, L.P.

The EBI SpineLink™ System is a spinal fixation device screw fixation and a nonpedicle hook and sacral/iliac screw fixation system of the noncervical spine.

When used as a pedicle screw fixation system, in the non-servical spine of skeletally mature patients, the System is intended to provide immobilization of stinal segments, as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine: Degenerative spondylolisthesis with objective of neurologic impairment, fracture, dislocations, scoliosis, kyphosis, spinal tumor, and failed previous fusion (psuedarthrosis).

In addition, when used as a pedice system in skeletally mature patients, it is intended for patients: (a) having severe spondylolistheis (Grades 3 and 4) of the fifth lymbar - first sacral (LS-S1) vertebral joint; (b) who are receiving fusions using autogenous bone graft only; (c) who are having the desice fixed or attached to the lumbar and sacral spine (L3 and below); and (d) who are having the device removed after the development of a solid fusion mass.

When used as a posterior hook and saxral/ibac screw fixation system, the levels of attachment are the lumbar and thoracic spine, and screw fixation limited to the sacrum and illum. The System is intended for the treatment of degenerative disc disease (defined as back pain with degeneration of the disc confirmed by history and radiographic studies). Psuedarthrosis; scollosis; spondylouisthesis, fracture; previous failed fusion; or tumor resection.

W hen used as an anterior fixation system, the levels of attachment are the anterolateral bodies of the lumbar and thoracic spine. The System is intended for the treatment of degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies). Psuedarthrosis; stenosis; scoliosisthesis, fracture; previous failed fusion; or tumor resection.

Device Description

The EBI SpineLink™ System is a spinal fixation device that uses interconnecting links and/or rods. This submission is for the addition of rods and couplers (pinchblocks) to supplement the existing system.

AI/ML Overview

The provided text is a 510(k) Summary of Safety & Effectiveness for a spinal fixation device, the EBI SpineLink™ System. This document focuses on demonstrating substantial equivalence to predicate devices and does not describe a clinical study in the typical sense with acceptance criteria, sample sizes, ground truth establishment, or expert involvement to evaluate device performance against specific metrics like sensitivity or specificity.

Instead, the "study" mentioned is mechanical testing to demonstrate performance of the device's new components.

Here's an breakdown of the information that can be extracted or inferred from the provided text, and what cannot:

1. Table of acceptance criteria and reported device performance:

Acceptance Criteria	Reported Device Performance
Applicability to standards and functional requirements	"Mechanical testing of the new components demonstrated that the device complies with applicable standards and meets all of its functional requirements."

2. Sample sized used for the test set and the data provenance:

Sample Size for Test Set: Not specified. This typically refers to the number of patient cases or images in an AI/diagnostic study, which is not applicable here as it's mechanical testing of a physical device.
Data Provenance: Not applicable. The "data" comes from mechanical testing performed on device components.

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

Number of Experts: Not applicable. Ground truth for mechanical testing is established by engineering specifications and testing protocols, not medical experts.
Qualifications of Experts: Not applicable.

4. Adjudication method for the test set:

Adjudication method: Not applicable. This concept pertains to resolving discrepancies in expert interpretations in diagnostic studies, which is not relevant to mechanical testing.

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:

MRMC Study: No. This is a mechanical device, not an AI or diagnostic imaging device.

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

Standalone Study: No. This is not applicable to a spinal fixation device.

7. The type of ground truth used:

Type of Ground Truth: Engineering specifications and established mechanical testing standards. The "ground truth" for a mechanical device relates to its ability to withstand specified forces, resist corrosion, etc., as defined by relevant ASTM standards or internal design requirements.

8. The sample size for the training set:

Sample Size for Training Set: Not applicable. There is no "training set" in the context of mechanical testing of a physical device.

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

Ground Truth Establishment for Training Set: Not applicable.

Summary of what the document does communicate:

The document focuses on establishing substantial equivalence to previously cleared devices based on:

Intended Use: The EBI SpineLink™ System's intended use has not changed from previously cleared versions.
Materials: Components are manufactured from Ti-6A1-4V ELI per ASTM F136.
Function: Mechanical testing was performed on new components (rods and couplers/pinchblocks) to ensure they comply with applicable standards and meet functional requirements. This is the "study" referred to in the context of device performance. The specific standards or detailed results of this mechanical testing are not provided in this summary but would have been part of the full 510(k) submission.

Summary

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NOV 2 3 1999

510(k) Summary of Safety & Effectiveness

This 510(k) Summary of Safety and Effectiveness for the EBI SpineLink™ System is provided as required per Section 513(1)(3) of the Food, Drug and Cosmetic Act.

Submitter: EBI, L.P. 1. 100 Interpace Parkway Parsippany, NJ 07054
Contact Person: Jon Caparotta Telephone: (973) 299-9022

Date prepared: August 27, 1999

2. Proprietary Name:	EBI SpineLink™ System
Common Name:	Spinal Fixation Device
Classification Names:	Spondylolisthesis Spinal Fixation Device SystemSpinal Intervertebral Body Fixation OrthosisSpinal Interlaminal Fixation Orthosis

Predicate or legally marketed devices that are substantially equivalent: 3.
- " EBI SpineLinkTM System
- EBI Webb-Morley Spine System
1. Description of the device: The EBI SpineLink™ System is a spinal fixation device that uses interconnecting links and/or rods. This submission is for the addition of rods and couplers (pinchblocks) to supplement the existing system.
1. Intended Use: The EBI SpineLink™ System has not changed the Indications for Use or fundamental scientific technology of the previously cleared EBI SpineLink™ System (K964797, K971970, K984027, K982908, and K990999). The EBI SpineLink™ System is a spinal fixation device for pedicle screw fixation and a nonpedicle hook and sacral/iliac screw fixation system of the noncervical spine.

When used as a pedicle screw fixation system, in the non-cervical spine of skeletally mature patients, the System is intended to provide immobilization of spinal segments, as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine: Degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocations, scoliosis, kyphosis, spinal tumor, and failed previous fusion (psuedarthrosis).

In addition, when used as a pedicle screw fixation system in skeletally mature patients, it is intended for patients: (a) having severe spondylolisthesis (Grades 3 and 4) of the fifth lumbar - first sacral (L5-S1) vertebral joint; (b) who are receiving fusions using autogenous bone graft only; (c) who are having the device fixed or attached to the lumbar and sacral spine (L3 and below); and (d) who are having the device removed after the development of a solid fusion mass.

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When used as a posterior hook and sacral/iliac screw fixation system, the levels of attachment are the lumbar and thoracic spine, and screw fixation limited to the sacrum and illum. The System is intended for the treatment of degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies). Psuedarthrosis; stenosis; scoliosis; spondylolisthesis, fracture; previous failed fusion; or tumor resection.

When used as an anterior fixation system, the levels of attachment are the anterolateral vertebral bodies of the lumbar and thoracic spine. The System is intended for the treatment of degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies). Psuedarthrosis; stenosis; scollosis; spondylolisthesis, fracture; previous failed fusion; or tumor resection.

Materials: The components of the system are manufactured from Ti-6A1-4V ELI per ASTM 6. F136. The components will be available with and without TiN coating.
Comparison of the technological characteristics of the device to predicate devices: 7. There are no significant differences between the EBI SpineLink™ System and other currently marketed spinal systems. It is substantially equivalent* to the predicate devices in regards to intended use, materials and function. Mechanical testing of the new components demonstrated that the device complicable standards and meets all of its functional requirements.

Any statement made in conjunction with this submission of substantial equivalence to any other product is intended only to relate to whether the product can be lawfully market approval or reclassification and is not intended to be interpreted as an admission or any other infringement litigation. (Establishment Registation and Premarket Notification Procedures, Final Regulation, Preamble, August 23, 1977, FR 42520 (Docket No. 76N-0355.))

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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV 2 3 1999

Mr. Jon Caparotta Manager, Regulatory Affairs Electro-Biology, Inc. 100 Interpace Parkway 07054-1079 Parsippany, New Jersey

Re: K992920 EBI SpineLink™ System Regulatory Class: II Product Codes: MNI, MNH, KWP, and KWQ Dated: August 27, 1999 August 30, 1999 Received:

Dear Mr. Caparotta:

We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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, Druq, and Cosmetic Act (Act). You may, therefore, market the device, subject to the general controls provisions The general controls provisions of the Act of the Act. include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. ಗಿ substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP requlation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or requlations.

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Page 2 - Mr. Jon Caparotta

This letter will allow you to begin marketing your device as described in your 510 (k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling requlation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to
premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".

Sincerely yours,

Neil R.P. Ogden
James E. Dillard III

Acting Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radioloqical Health

Enclosure

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Statement of Indications for Use:

The EBI SpineLink™ System is a spinal fixation device screw fixation and a nonpedicle hook and sacral/iliac screw fixation system of the noncervical spine.

Ro for

(Division Sign-Off)
Division of General Restorative Devices
510(k) Number K992920

Prescription Use
(Per 21 CFR 801.109)

Regulation Number and Section

§ 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.