EXPEDIUM SYSTEM, VIPER SYSTEM

K110216 · Depuy Spine, Inc. · NKB · Apr 1, 2011 · Orthopedic

Device Facts

• Record ID: K110216
• Device Name: EXPEDIUM SYSTEM, VIPER SYSTEM
• Applicant: Depuy Spine, Inc.
• Product Code: NKB · Orthopedic
• Decision Date: Apr 1, 2011
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The EXPEDIUM and VIPER Systems are intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine. The EXPEDIUM and VIPER Systems are intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor; pseudarthrosis; and failed previous fusion in skeletally mature patients. When used in a percutaneous approach with MIS Instrumentation, the VIPER Systems are intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion in skeletally mature patients.

Device Story

EXPEDIUM and VIPER Systems are spinal fixation implants consisting of cortical fix polyaxial screws of various geometries and sizes. Used by surgeons in clinical settings to provide immobilization and stabilization of spinal segments as an adjunct to fusion. Implants are placed in the thoracic, lumbar, and sacral spine to treat instabilities or deformities. The system supports both open and percutaneous (MIS) surgical approaches. By stabilizing the affected spinal segments, the device facilitates fusion, potentially reducing pain and correcting spinal alignment in patients with degenerative or traumatic conditions.

Clinical Evidence

No clinical tests were performed. Substantial equivalence is supported by non-clinical bench testing, including static and dynamic cantilever beam testing and static axial slip testing in accordance with ASTM F1798-97.

Technological Characteristics

Materials: ASTM F138 stainless steel and ASTM F136 titanium alloy. Design: Polyaxial screw fixation system. Mechanical testing performed per ASTM F1798-97. Sterilization: Not specified.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization/stabilization as an adjunct to fusion for thoracic, lumbar, and sacral spine conditions including degenerative disc disease, spondylolisthesis, trauma (fracture/dislocation), spinal stenosis, spinal curvatures (scoliosis, kyphosis, lordosis), tumor, pseudarthrosis, and failed previous fusion.

Regulatory Classification

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.

Special Controls

*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.

Predicate Devices

• EXPEDIUM® System (K033901, K051024, K062174, K063156, K063741, K080313, K081898)
• VIPER® System (K033901, K090648, K101993)

Submission Summary (Full Text)

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# k110216

APR - 1 20i1

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### 510(K) SUMMARY

| Submitter: | DePuy Spine, Inc.<br>325 Paramount Drive<br>Raynham, MA 02767 |
|------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Eugene Bang<br>Regulatory Affairs Associate<br>Voice: [phone]<br>Fax: [phone]<br>Email: [e-mail] |
| Date Prepared: | January 24, 2011 |
| Trade Name: | EXPEDIUM® and VIPER® Systems |
| Device Class: | Class III |
| Product Code(s): | NKB, KWQ, KWP, MNH, MNI |
| Common Name: | Appliance, Fixation, Spinal Interlaminal;<br>Appliance, Fixation, Spinal Intervertebral Body;<br>Orthosis, Spondyloisthesis Spinal Fixation;<br>Orthosis, Spinal Pedicle Fixation;<br>Orthosis, Spinal Pedicle Fixation, For Degenerative Disc Disease |
| Classification Name: | Spinal interlaminar fixation orthosis<br>per 21 CFR §888.3050 |
| | Spinal intervertebral body fixation orthosis<br>per 21 CFR §888.3060 |
| | Pedicle screw spinal fixation<br>per 21 CFR §888.3070 |
| Predicate Devices: | EXPEDIUM® System - K033901, K051024, K062174, K063156, K063741,<br>K080313, K081898<br>VIPER® System - K033901, K090648, K101993 |
| Device Description: | The proposed cortical fix polyaxial screws for EXPEDIUM and VIPER System<br>are available in various geometries and sizes. |
| Intended Use: | The EXPEDIUM and VIPER Systems are intended to provide immobilization<br>and stabilization of spinal segments in skeletally mature patients as an adjunct to<br>fusion in the treatment of acute and chronic instabilities or deformities of the<br>thoracic, lumbar and sacral spine.<br>The EXPEDIUM and VIPER Systems are intended for noncervical pedicle<br>fixation and nonpedicle fixation for the following indications: degenerative disc<br>disease (defined as back pain of discogenic origin with degeneration of the disc<br>confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e.,<br>fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis,<br>and/or lordosis); tumor; pseudarthrosis; and failed previous fusion in skeletally<br>mature patients.<br>When used in a percutaneous approach with MIS Instrumentation, the VIPER<br>Systems are intended for noncervical pedicle fixation and nonpedicle fixation for<br>the following indications: degenerative disc disease (defined as back pain of<br>discogenic origin with degeneration of the disc confirmed by history and<br>radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation);<br>spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); tumor;<br>pseudoarthrosis; and failed previous fusion in skeletally mature patients. |
| Materials: | Manufactured from ASTM F138 implant grade stainless steel and ASTM F136<br>implant grade titanium alloy. |
| Comparison to<br>Predicate Device: | The substantial equivalence of the subject device to the predicates indentified<br>above is based upon the equivalence of intended use, design (fundamental<br>scientific technology), materials, manufacturing methods, performance, sterility,<br>biocompatibility, safety and packaging design. |
| Non-clinical Test | |
| Summary: | The following mechanical tests were conducted: |
| | Static cantilever beam testing in accordance with ASTM F 1798-97 Standard<br>Guide for Evaluating the Static and Fatigue Properties of Interconnection<br>Mechanisms and Subassemblies Used in Spinal Arthrodesis Implants. The<br>acceptance criteria was/were met. Static axial slip testing in accordance with ASTM F 1798-97 Standard Guide<br>for Evaluating the Static and Fatigue Properties of Interconnection<br>Mechanisms and Subassemblies Used in Spinal Arthrodesis Implants. The<br>acceptance criteria was/were met. Dynamic cantilever beam testing in accordance with ASTM F 1798-97<br>Standard Guide for Evaluating the Static and Fatigue Properties of<br>Interconnection Mechanisms and Subassemblies Used in Spinal Arthrodesis<br>Implants. The acceptance criteria was/were met. |
| Clinical Test | |
| Summary: | No clinical tests were performed. |
| Conclusion: | Based on the predicate comparison and testing, the subject additions to the<br>EXPEDIUM and VIPER Systems are substantially equivalent to the predicate<br>devices. |

DePuy Spine, Inc., a Johnson & Johnson Company

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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is a stylized eagle emblem with three parallel lines forming the body and wings.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

APR - 1 2011

DePuy Spine, Inc. % Mr. Eugene Bang Regulatory Affairs Associate 325 Paramount Drive Raynham, Massachusetts 02767

Re: K110216

Trade/Device Name: EXPEDIUM® and VIPER® Systems Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNH, MNI, KWP, KWQ Dated: January 24, 2011 Received: October 12, 2010

Dear Mr. Bang:

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. 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

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Page 2 - Mr. Eugene Bang

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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours.

Azi B. De tu
for

Mark N. Melkerson Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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### INDICATIONS FOR USE STATEMENT

510(k) Number (if known): KI | 0216

Device Name: EXPEDIUM® and VIPER® Systems

#### Indications For Use:

The EXPEDIUM and VIPER Systems are intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of acute and chronic instabilities or deformities of the thoracic, lumbar and sacral spine.

The EXPEDIUM and VIPER Systems are intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, kyphosis, and/or lordosis); turnor; pseudarthrosis; and failed previous fusion in skeletally mature patients.

When used in a percutaneous approach with MIS Instrumentation, the VIPER Systems are intended for noncervical pedicle fixation and nonpedicle fixation for the following indications: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies); spondylolisthesis; trauma (i.e., fracture or dislocation); spinal stenosis; curvatures (i.e., scoliosis, and/or lordosis); tumor; pseudoarthrosis; and failed previous fusion in skeletally mature patients.

Prescription Use

AND/OR

Over-The-Counter Use

(Part 21 CFR 801 Subpart D)

(21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sire Division of Smarcal, Orthopedic, and Restorative Devices

K110216 510(k) Number_

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