K002824 · Aesculap, Inc. · KWQ · May 8, 2001 · Orthopedic
Device Facts
Record ID
K002824
Device Name
MACS MODULAR ANTERIOR CONSTRUCT SYSTEM
Applicant
Aesculap, Inc.
Product Code
KWQ · Orthopedic
Decision Date
May 8, 2001
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3060
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
This anterolateral/anterior system consists of several vertebral screws, locking nuts, and rods. The system of attachment is screw fixation to the anterolateral vertebral bodies of the lumbar and thoracic spine (T1-L5). This system is intended for use during the development of a solid spinal fusion. When used as an anterolateral/anterior spine plate and rod system, the macs™ modular anterior construct system is indicated for patients with: Degenerative disk disease defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies; Spondylolisthesis; Spondylolysis; Fracture; Spinal stenosis; Deformities (i.e., scoliosis, kyphosis, lordosis, whether neuromuscular or related to deficient posterior elements); Tumors (neoplastic disease); Pseudarthrosis; Failed previous fusion surgery.
Device Story
The macs™ modular anterior construct system is an implantable spinal fixation device used to stabilize the thoraco-lumbar spine (T1-L5). The system consists of titanium alloy plates, rods, nuts, and cancellous bone screws. It is implanted by experienced spinal surgeons via open, endoscopic, or mini-surgical approaches. The device is attached to the anterolateral vertebral bodies to provide structural support and apply force to correct spinal deformities or stabilize segments during the development of a solid spinal fusion. The system is supplied non-sterile and must be steam-sterilized on-site before use. It is intended for prescription use only. The device provides mechanical stabilization to treat conditions such as degenerative disc disease, fractures, and tumors, potentially reducing pain and correcting spinal alignment by maintaining vertebral position during the fusion process.
Clinical Evidence
Bench testing only. Biomechanical studies were conducted, including compression-bending, torsion, and fatigue endurance testing. Results indicated that the stiffness and fatigue performance of the macs™ plate and rod constructs are comparable to other systems on the market and within required specifications.
Technological Characteristics
Construct materials: Titanium alloy (ASTM F-136-96). Components: Plates, rods, nuts, and cancellous bone screws. Dimensions: Profile <10mm. Energy source: None (mechanical fixation). Sterilization: Steam sterilization on-site. Connectivity: None. Software: None.
Indications for Use
Indicated for patients with degenerative disc disease, spondylolisthesis, spondylolysis, fracture, spinal stenosis, spinal deformities (scoliosis, kyphosis, lordosis), tumors, pseudarthrosis, or failed previous fusion surgery requiring anterolateral/anterior spinal fixation (T1-L5) to facilitate solid spinal fusion.
Regulatory Classification
Identification
A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.
Predicate Devices
BodyForm® - Thoraco-Lumbar Fixation System (K983622)
{0}------------------------------------------------
# MAY = 82001
| Summary of Safety and Effectiveness Information | AESCULAP® INC. |
|-------------------------------------------------|------------------|
| Premarket Notification, Section 510(k) | DECEMBER 5, 2000 |
Safe Medical Devices Act of 1990, 21 CFR 807.92 Regulatory Authority:
| Device Name: | |
|-------------------------|----------------------------------------------|
| Trade Name: | macsTL modular anterior construct system |
| Common Name(s): | Anterior thoraco-lumbar spine plates |
| Classification Name(s): | Spinal intervertebral body fixation orthosis |
Establishment Name & Registration Number:
| Name: | Aesculap® Inc. |
|---------|----------------|
| Number: | 2916714 |
### Classification(s):
#### \$ 888.3060 Spinal intervertebral body fixation orthosis.
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eyetype screw. The device is used to apply force to a series of vertebrae to correct sway back, scoliosis (lateral curvature of the spine), or other conditions.
Classification. Class II.
| Device Class: | Class II for all requested indications |
|-----------------------|----------------------------------------------|
| Classification Panel: | Orthopaedic and Rehabilitation Devices Panel |
| Product Code(s): | KWQ |
Applicant Name & Address:
Aesculap® Inc. 1000 Gateway Blvd. South San Francisco, CA 94080-7028 650.876.7000 voice - 650.876.0266 fax
### Company Contact:
Wilson Constantine, M.D. Aesculap® Inc. 1000 Gateway Blvd. South San Francisco, CA 94080-7028 650.876.7000 voice - 650.876.0266 fax
### Submission Correspondent:
Mr. David W. Schlerf Buckman Company, Inc. 200 Gregory Lane, Suite C -100 Pleasant Hill, CA 94523-3389 925.356.2640 - 925.356.2654 - fax
{1}------------------------------------------------
### Performance Standards (Section 514 compliance):
Performance Standards (Section 314 compliance).
Food and Drug Administration mandated Performance standards for anterior spine plates are not in effect. rood and Drug Ammilistiation manance Performance Standards applicable to the mass AESCOLAF® INC. Intends to compy mathe present time, various performance standards such as ASTM, ISO, QSR/CGMP and in-house SOP standards are used. In addition, AESCULAR® INC. complies with the ISO, QSNCONI and in-nouse SOF standards are are are are are and 520 of the Food, Drug, and Cosmetic Act.
#### Special Controls:
Special Controls.
All Class II devices are subject to Special Controls. No FDA mandated special controls are in effect at the present time.
#### Labeling:
The macs" modular anterior construct system discussed in this premarket notification will be manufactured for AESCULAR® INC. and labeled as such. The system will be marketed exclusively to healthcare facilities and physicians.
Surgical Technique. The surgical approach of the macs™ modular anterior construct system is similar to other anterior thoraco-lumbar plate spinal systems.
Warning: Federal (United States) Law restricts this device to sale by or on the order of a physician only.
This device is not approved for screw attachment of fixation to the posterior elements Warning: (pedicles) of the cervical, thoracic or lumbar spine.
CAUTION: Mixing of dissimilar metals can accelerate the corrosion process. The components of this system must NOT be used with implants of other material in building a construct. Components of the macs ... modular anterior construct system should NOT be used with components from any other system or manufacturer.
"Precaution: The implantation of the macs" - modular anterior construct system should be performed only by experienced spinal surgeons with specific training in the use of such spinal devices because the technique is a technically demanding procedure presenting a risk of serious injury to the patient."
### Preamendments Device (legally marketed comparison device):
AESCULAP® Inc. believes that the macs" modular anterior construct system is substantially equivalent to the following spinal device system marketed by Theken Surgical.
BodyForm® - Thoraco-Lumbar Fixation System, K983622 - Theken Surgical, LLC.
### Centaur™ Spinal System - K994347 - Howmedica/Osteonics/Stryker
The BodyForm® - Thoraco-Lumbar Fixation System is cleared for marketing. BodyForm® is a spinal construct made up of one plate contoured to match the lateral profile of the thoraco-lumbar vertebral bodies, four Morse taper headed screws, and two locking set screws. The plates are sized and designed in such a way that they will accommodate particular bone graft heights. The BodyForm® is intended to be used for the surgical treatment of spinal instability or deformity. Equivalence can be seen in the design, material composition, surgical technique, testing methodologies and intended use.
The Centaur™ Spinal System is cleared for marketing. Used anteriorly, the Centaur™ System is a spinal construct manufactured from ASTM F-136-96 titanium alloy (Ti6Al4V). The system is comprised of primary and secondary bone screws, rods, lateral connectors, plates and accessories. The Centaur™ Spinal System is intended to treat deformities of curvature, fracture, tumor, spinal stenosis, spondylosisthesis, failed previous spine surgery and degenerative disk disease. Equivalence can be seen in the design, material composition, surgical technique, testing methodologies and intended use.
{2}------------------------------------------------
To facilitate comparison of the macs™ modular anterior construct system to the systems identified above, a 1 0 facilitate comparison table is located at the end of the document.
### Summary of Biomechanical Testing:
In the compression-bending test the results are satisfactory. In the torsion test the ultimate torque of the plate and rods is satisfactory. The fatigue endurance of the rod and plate constructs is satisfactory. I he fallgar endarance of the plate and the pairs of rods are satisfactory.
### Results and Conclusions:
The stiffness of the plate system is equivalent to that of the rod system.
The stimoss of the place is comparable and within the required specifications.
The fatigue performance is comparable and within the required specifications.
These results show that the performance of the macs " system is comparable to other systems on t market when the published data are reviewed.
## Summary Basis for Equivalence and Comparison Table:
Summary Dasts for Equirated on the macs 14 modular anterior construct system implant constructs Biomechanical studies conductor on the macs - nocaliar for use as a spinal fixation device system. Based on the available information concerning the referenced comparison devices, these devices are similar in that:
- The devices have the same intended use and indications for use. .
- The devices are made of the same implant alloy. .
- The devices have similar form, function, components, instruments, dimensions, geometry and features. .
The use of QSR based process controls, testing standards (ASTM F-1717 - 96 testing, materials standards (ASTM F-136, 92 and ISO 5832-3) and the similarities of the references comparison devices establish that (ASTM IFTS), 22 and 150 3052 3y and is substantially equivalent to available legally marketed anterior thoraco-lumbar spinal devices. It is believed that the anticipated clinical performance of the macs Tr modular anterior construct system is equivalent to the referenced systems.
| FEATURE | macsTL modular anterior construct system | Centaur<br>System | BodyForm | SE? |
|-------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------|---------------------------|----------|
| Indications<br>for Use: | degenerative disk disease defined as back pain of<br>discogenic origin with degeneration of the disc<br>confirmed by history and radiographic studies<br>spondylolisthesis<br>fracture<br>spinal stenosis<br>deformities (i.e., scoliosis, kyphosis, lordosis)<br>tumors<br>pseudarthrosis<br>Failed Previous Fusion Surgery | SAME | SAME | YES |
| Components: | Plate, rod, nuts & cancellous bone screws | SAME | SAME | YES |
| Sterility: | No. Steam sterilize on-site before use. | SAME | SAME | YES |
| Profile: | <10mm | EQUIVALENT | EQUIVALENT | YES |
| Materials: | Titanium alloy | SAME | SAME | YES |
| Attachment: | Anterior - Thoraco/lumbar spine | SAME | SAME | YES |
| Manufacturer: | Aesculap, Inc. | Howmedica | Theken<br>Surgical, LLC | YES |
| Surgical<br>Approach: | Open, endoscopic or mini-surgical | Open or mini-<br>surgical | Open or mini-<br>surgical | NO - YES |
| Product Code: | KWQ | SAME | SAME | YES |
| K - Number: | Pending | K994347 | K983622 | YES |
#### Summary Comparison Table:
{3}------------------------------------------------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle or bird design with three curved lines representing the wings or feathers. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the bird symbol.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAY - 8 2001
AESCULAP, Inc. Mr. David W. Schlerf c/o Buckman Company, Inc. 200 Gregory Lane, Suite C-100 Pleasant Hill, California 94523
Re: K002824
Trade Name: macs™ modular anterior construct system Regulation Number: 21 CFR 888.3060 Regulatory Class: Class II Product Code: KWQ Dated: December 5, 2000 Received: March 13, 2001
Dear Mr. Schlerf:
We have reviewed your Section 510(k) notification of intent to market the device referenced we nave and we have determined the device is substantially equivalent (for the indications for use above and we have as a losses marketed in interstate commerce prior to May 28, 1976, the stated in the eneroune) to were Device Amendments, or to devices that have been reclassified in encordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, controls provisions or actice, 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 ( Femanel I pp 1 car) in the Code of Federal Regulations, Title 21, Parts 800 to 895. A 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 mspootions, are regulation 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 regulations.
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.
{4}------------------------------------------------
# Page 2 - Mr. David W. Schlerf
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and If you desire specific advice for your devices), please contact the Office of Compliance at
additionally 809.10 for in vitro diagnostic devices), please contact the Office of additionally 809.10 for in Vito diagnostic no nove, promotion and advertising of your device, (301) 594-4659. Additionally, for questions of the presentents of the regulation please contact the Office of Compilance at (301) - 1 - 1057 - 1039 - 10.07.97). Other general
entitled, "Misbranding by reference to premarket not any of transport Small entitled, "Misbranding by relective to premarket mary be obtained from the Division of Small
information on your responsibilities under the Act (201) /43-6597, or at is information on your responsionines uncer (800) 638-2041 or at (301) 443-6597, or at its
Manufacturers Assistance at its toll-free 11 its be Manufacturers "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours,
аттилешопр
Celia M. Witten, Ph.D., M.D. Director Division of General Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
{5}------------------------------------------------
Page 1 of
510(k) Number : K002824
macs™ modular anterior construct system Device Name(s):
# Indications for Use:
# KWQ 888.3060 - Spinal Intervertebral Body Fixation Orthosis
This anterolateral/anterior system consists of several vertebral screws, locking Inis allectuateraliances system of attachment are screw fixation to the anterolateral vertebral bodies of the lumbar and thoracic spine (T1-L5). This amerolateral verteoral boures of unilization during the development of a solid spinal fusion.
When used as an anterolateral/anterior spine plate and rod system, the MaCs™ modular anterior construct system is indicated for patients with:
- Degenerative disk disease defined as back pain of discogenic origin with degeneration of the . disc confirmed by history and radiographic studies
- Spondylolisthesis .
- Spondylolysis ◆
- Fracture �
- . Spinal stenosis
- Spillar schools
Deformities (i.e., scoliosis, kyphosis, lordosis, whether neuromuscular or related to deficient . posterior elements)
- Tumors (neoplastic disease) .
- Pseudarthrosis .
- Failed previous fusion surgery
PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY Concurrence of CDRH, Office of Device Evaluation (ODE)
D. Mutaelllro Mc Cunn
(Division Sign-Off) Division of General, Restorative and Neurological Devices
510(k) Number KOOZES24
Prescription Use
(Per 21 CFR 801.109)
OR
Over-The-Counter Use _________________________________________________________________________________________________________________________________________________________ (Optional format 1-2-96)
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.