MOUNTAINEER OCT SPINAL SYSTEM

K110353 · Depuy Spine, Inc. · KWP · Apr 7, 2011 · Orthopedic

Device Facts

• Record ID: K110353
• Device Name: MOUNTAINEER OCT SPINAL SYSTEM
• Applicant: Depuy Spine, Inc.
• Product Code: KWP · Orthopedic
• Decision Date: Apr 7, 2011
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 888.3050
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

When intended to promote fusion of the cervical spine and occipito-cervico-thoracic junction (occiput - T3), the MOUNTAINEER Occipito-Cervical-Thoracic (OCT) Spinal System is intended for: - DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies) - spondylolisthesis - spinal stenosis - fracture/dislocation - atlanto/axial fracture with instability - occipitocervical dislocation - revision of previous cervical spine surgery - tumors The occipital bone screws are limited to occipital fixation only. The use of the monoaxial and polyaxial screws is limited to placement in the upper thoracic spine (T1-T3) in treating thoracic conditions only. They are not intended to be placed in the cervical spine. The Songer Cable System, to be used with the MOUNTAINEER OCT Spinal System, allows for wire/cable attachment to the posterior cervical spine. The MOUNTAINEER OCT Spinal System can also be linked to the ISOLA®, TiMX®, MONARCH®, EXPEDIUM®, VIPER® and MOSS® MIAMI Systems using the dual wedding band and axial connectors, and via dual diameter rods.

Device Story

The MOUNTAINEER OCT Spinal System is a posterior spinal fixation system consisting of plates, nuts, bone screws, rods, connectors, and cables. It is used by surgeons in clinical settings to promote fusion of the cervical spine and occipito-cervico-thoracic junction. The system provides mechanical stabilization of the spine to facilitate bone fusion, potentially reducing pain and restoring stability in patients with degenerative, traumatic, or neoplastic conditions. The subject device introduces Cobalt Chromium (Co-Cr) rods as an alternative to existing Titanium (Ti-6Al-4V) rods. The system is designed to be compatible with various other DePuy spinal systems via specific connectors.

Clinical Evidence

Bench testing only. Static and dynamic compression-bending testing and static torsion testing were performed per ASTM F 1717 to characterize the mechanical performance of the Cobalt Chromium rods.

Technological Characteristics

Spinal interlaminar fixation orthosis. Components: plates, nuts, bone screws, rods, connectors, cables. Materials: ASTM F-1537 Cobalt Chromium (subject), Ti-6Al-4V (predicate). Mechanical fixation via screws, rods, and cables. Compatible with multiple existing spinal systems via connectors.

Indications for Use

Indicated for patients requiring cervical spine and occipito-cervico-thoracic (occiput-T3) fusion due to DDD, spondylolisthesis, spinal stenosis, fracture/dislocation, atlanto/axial fracture with instability, occipitocervical dislocation, revision surgery, or tumors. Occipital screws limited to occipital fixation; monoaxial/polyaxial screws limited to T1-T3 thoracic conditions.

Regulatory Classification

Identification

A spinal interlaminal fixation orthosis is a device intended to be implanted made of an alloy, such as stainless steel, that consists of various hooks and a posteriorly placed compression or distraction rod. The device is implanted, usually across three adjacent vertebrae, to straighten and immobilize the spine to allow bone grafts to unite and fuse the vertebrae together. The device is used primarily in the treatment of scoliosis (a lateral curvature of the spine), but it also may be used in the treatment of fracture or dislocation of the spine, grades 3 and 4 of spondylolisthesis (a dislocation of the spinal column), and lower back syndrome.

Predicate Devices

• DePuy MOUNTAINEER OCT Spinal System (K042508)
• DePuy MOUNTAINEER OCT Spinal System (K080828)

Reference Devices

• ISOLA®
• TiMX®
• MONARCH®
• EXPEDIUM®
• VIPER®
• MOSS® MIAMI

Submission Summary (Full Text)

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# 510(K) SUMMARY

| A. | Submitter Information | |
|----|-------------------------|---------------------------------------------------------------|
| | | DePuy Spine, Inc. |
| | | 325 Paramount Drive |
| | | Raynham, MA 02767 |
| | Contact Person: | Luke Bulino |
| | | Senior Regulatory Affairs Associate |
| | Voice: | [phone] |
| | Fax: | [phone] |
| | E-Mail: | [e-mail] |
| B. | Date Prepared | 2/04/11 |
| C. | Device Name | |
| | Trade/Proprietary Name: | MOUNTAINEER OCT Spinal System |
| | Common/Usual Name: | Spinal System |
| | Classification Name: | Spinal interlaminar fixation orthosis<br>per 21 CFR §888.3050 |

### D. Predicate Device Name

Trade names: DePuy MOUNTAINEER OCT Spinal System (K042508, K080828)

### E. Device Description

The MOUNTAINEER OCT Spinal System consists of plates, nuts, bone screws, rods, transverse rod connectors, lateral offset connectors, head-to-head connectors, cable connectors, dual wedding band and axial connectors, set screws, minipolyaxial screws, monoaxial screws, hooks and SONGER® Cables.

The MOUNTAINEER OCT System Titanium Rods (Ti-6AL-4V) are offered in both Straight and Dual Diameter designs. The Straight Rod diameter is 3.5mm and has lengths

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ranging from 25mm-100mm in increments of 5mm and lengths ranging from 100mm-400mm in increments of 20mm. The Dual Diameter Rods consists of 3.5 - 4.5mm, 3.5 -4.75mm. 3.5 - 5.5mm. and 3.5 - 6.35mm diameters with Rod lengths of 420mm and 600mm.

The proposed MOUNTAINEER Cobalt Chromium (Co-Cr) Rods also consist of both Straight and Dual Diameter designs. The Straight Rod diameter is 3.5mm and available in lengths ranging from 25mm to 100mm (increments of 5mm) and 120, 200, 340 and 400mm. The Dual Diameter MOUNTAINEER Co-Cr Rods consist of 3.5 – 4.5mm, 3.5 – 4.75mm, 3.5 – 5.5mm and 3.5 – 6.35mm and available in lengths of 420 and 600mm.

Other than the modifications to the material from Ti-6Al-4V to Co-Cr, no other modifications have been made. The proposed Cobalt Chromium rods are not being made to address a known recall or adverse events. These proposed components have been developed as additions to the existing MOUNTAINEER OCT Spinal System.

#### F. Intended Use

When intended to promote fusion of the cervical spine and occipito-cervico-thoracic iunction (occiput - T3), the MOUNTAINEER Occipito-Cervical-Thoracic (OCT) Spinal Svstem is intended for:

- . DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by patient history and radiographic studies)
- spondylolisthesis .
- . spinal stenosis
- fracture/dislocation .
- atlanto/axial fracture with instability ●
- . occipitocervical dislocation
- revision of previous cervical spine surgery .
- . tumors

The occipital bone screws are limited to occipital fixation only.

The use of the monoaxial and polyaxial screws is limited to placement in the upper thoracic spine (T1-T3) in treating thoracic conditions only. They are not intended to be placed in the cervical spine.

The Songer Cable System, to be used with the MOUNTAINEER OCT Spinal System, allows for wire/cable attachment to the posterior cervical spine.

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The MOUNTAINEER OCT Spinal System can also be linked to the ISOLA®, TiMX®, MONARCH®, EXPEDIUM®, VIPER® and MOSS® MIAMI Systems using the dual wedding band and axial connectors, and via dual diameter rods.

### F. Summary of Similarities and Differences in Technological Characteristics, Performance and Intended Use

The proposed devices are identical to the predicate device with the exception of the material being changed from Titanium to Cobalt Chromium. The design, indications for use, and technology remain identical to the predicate system.

#### G. Materials

Manufactured from ASTM F-1537 Cobalt Chromium.

#### H. Performance Data

Performance data per ASTM F 1717 were submitted to characterize the subject MOUNTAINEER OCT Spinal System rods addressed in this notification. This testing was compromised of static and fatigue testing on the proposed device. Specifically, static and dynamic compressionbending testing as well as static torsion testing was performed.

### l. Conclusion

- Both the Performance Testing and Substantial Equivalence Justification demonstrate that the device is as safe, as effective, and performs as well as the predicate device

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# DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS) of the United States. The seal features the department's name encircling a symbol. The symbol is a stylized depiction of an eagle with its wings spread, representing the department's mission to protect the health of all Americans and provide essential human services.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002

DePuy Spine, Inc. % Mr. Christopher Rogers 325 Paramount Drive Raynham, Massachusetts 02767

Re: K110353

Trade/Device Name: Mountaineer OCT Spinal System Regulation Number: 21 CFR 888.3050 Regulation Name: Spinal interlaminal fixation orthosis Regulatory Class: Class II Product Code: K WP Dated: March 11, 2011 Received: March 14, 2011

APR - 7 2011

Dear Mr. Rogers:

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. Ilsting 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 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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Page 2 - Mr. Christopher Rogers

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.

Kry B. R. h
fr.

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): Unknown

MOUNTAINEER OCT Spinal System Device Name:

## Indications For Use:

When intended to promote fusion of the cervical spine and occipito-cervico-thoracic junction (occiput - T3), the MOUNTAINEER Occipito-Cervical-Thoracic (OCT) Spinal System is intended for:

- DDD (neck pain of discogenic origin with degeneration of the disc as confirmed by . patient history and radiographic studies)
- . spondylolisthesis
- . spinal stenosis
- . fracture/dislocation
- . atlanto/axial fracture with instability
- occipitocervical dislocation .
- revision of previous cervical spine surgery .
- � tumors

The occipital bone screws are limited to occipital fixation only.

The use of the monoaxial and polyaxial screws is limited to placement in the upper thoracic spine (T1-T3) in treating thoracic conditions only. They are not intended to be placed in the cervical spine.

The Songer Cable System, to be used with the MOUNTAINEER OCT Spinal System, allows for wire/cable attachment to the posterior cervical spine.

The MOUNTAINEER OCT Spinal System can also be linked to the ISOLA®, TiMX®, MONARCH®, EXPEDIUM®, VIPER® and MOSS® MIAMI Systems using the dual wedding band and axial connectors, and via dual diameter rods.

Prescription Use _____________________________________________________________________________________________________________________________________________________________

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)

AND/OR

Concurrence of CDRH, Offig of Device Evaluation (ODE)

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

KI10353 510(k) Number_