VIPER SYSTEMS

K111571 · Johnson & Johnson · NKB · Jul 6, 2011 · Orthopedic

Device Facts

• Record ID: K111571
• Device Name: VIPER SYSTEMS
• Applicant: Johnson & Johnson
• Product Code: NKB · Orthopedic
• Decision Date: Jul 6, 2011
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic

Indications for Use

The 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 VIPER Systems metallic components are intended for noncervical pedicle fixation and nonpedicle fixation for fusion 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. When used in a posterior percutaneous approach with MIS instrumentation, the VIPER Systems metallic components are intended for noncervical pedicle fixation and nonpedicle fixation for fusion 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. The VIPER PEEK rods are only indicated for fusion procedures for spinal stenosis with instability (no greater than Grade I spondylolisthesis) from L1-S1 in skeletally mature patients.

Device Story

VIPER Systems are 5.5mm rod spinal fixation systems; components include monoaxial, polyaxial, uni-planar screws, and extended tab implants. Used by surgeons in OR for thoracic, lumbar, and sacral spinal stabilization. Metallic components (stainless steel/titanium) provide rigid fixation; PEEK rods provide alternative stabilization for specific L1-S1 indications. System supports both open and posterior percutaneous MIS approaches. Surgeons select appropriate screw geometry/size based on patient anatomy to achieve immobilization; device acts as internal splint to facilitate bone fusion. Benefits include stabilization of unstable spinal segments, correction of deformities, and relief of symptoms associated with degenerative conditions or trauma.

Clinical Evidence

Bench testing only. Performance data per ASTM F 1798 submitted, including static and dynamic cantilever beam testing and static axial slip testing to characterize the subject components.

Technological Characteristics

5.5mm rod system; materials: ASTM F 138/F 139 stainless steel and ASTM F 136 titanium alloy. Components: monoaxial, polyaxial, uni-planar screws, and extended tab implants. Mechanical fixation via pedicle/non-pedicle screws and rods. No software or electronic components.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization/stabilization as an adjunct to fusion for thoracic, lumbar, and sacral spine instabilities or deformities, including degenerative disc disease, spondylolisthesis, trauma, spinal stenosis, scoliosis, kyphosis, lordosis, tumor, pseudoarthrosis, and failed previous fusion. PEEK rods limited to L1-S1 fusion for spinal stenosis with instability (max Grade I spondylolisthesis).

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

• DePuy Spine EXPEDIUM®/VIPER® Spine System (K073562)
• DePuy Spine EXPEDIUM® Spine System (K070387)
• DePuy Spine EXPEDIUM® Spine System (K080313)
• DePuy Spine EXPEDIUM® Spine System (K102249)
• DePuy Spine MOSS MIAMI Spine System (K011182)

Submission Summary (Full Text)

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

KII)571

: JUL - 6 2011

# 510(K) SUMMARY

| A. Submitter Information | DePuy Spine, Inc. 325 Paramount Drive Raynham, MA 02767 |
|--------------------------|---------------------------------------------------------------------------------------------------------------|
| Contact Person: | Daphney Germain-Kolawole Regulatory Affairs Associate |
| Voice: | [phone] |
| Fax: | [phone] |
| E-Mail: | [e-mail] |
| B. Date Prepared | 6/3/2011 |
| C. Device Class | Class III |
| D. Device Name | |
| Trade/Proprietary Name: | VIPER Systems |
| Common/Usual Name: | Pedicle Screw Spinal System |
| Classification Name: | Spinal interlaminar fixation orthosis per 21 CFR §888.3050 Pedicle screw spinal fixation per 21 CFR §888.3070 |
| Classification Panel: | Orthopaedics |
| FDA Panel Number: | 87 |
| E. Product Code(s) | NKB, MNI, MNH, KWP |

DePuy Spine, Inc., a Johnson & Johnson Company

Ps 1 of 3

,

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

### Predicate Device Name ri

DePuy Spine EXPEDIUM®/VIPER® Spine System (K073562) Trade name: DePuy Spine EXPEDIUM® Spine System (K070387) DePuy Spine EXPEDIUM® Spine System (K080313) DePuy Spine EXPEDIUM® Spine System (K102249) DePuy Spine MOSS MIAMI Spine System (K011182)

#### G. Device Description

The VIPER Systems are 5.5mm rod systems offered in both titanium and stainless steel materials. The systems consist of monoaxial screws, polyaxial screws, uni-planar screws, and extended tab implants. They are available in various geometries and sizes to accommodate patient anatomy. The VIPER Systems 8mm to 12mm diameter favored angle polyaxial screws are not intended to be used with the VIPER PEEK rods.

#### H. Intended Use

The 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 VIPER Systems metallic components are intended for noncervical pedicle fixation and nonpedicle fixation for fusion 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.

When used in a posterior percutaneous approach with MIS instrumentation, the VIPER Systems metallic components are intended for noncervical pedicle fixation and nonpedicle fixation for fusion 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

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

KIII S7+I

lordosis); tumor, pseudarthrosis; and failed previous fusion in skeletally mature patients.

The VIPER PEEK rods are only indicated for fusion procedures for spinal stenosis with instability (no greater than Grade I spondylolisthesis) from L1-S1 in skeletally mature patients.

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

The proposed modifications to the DePuy Spine VIPER® Systems are identical to the predicate devices except for the addition of favored angle polyaxial screws in various sizes to the systems. The design, materials, and technology remain identical to the predicate systems.

#### J. Materials

Manufactured from ASTM F 138 implant grade stainless steel, ASTM F 139 implant grade stainless steel, and ASTM F 136 implant grade titanium alloy.

#### K. Performance Data

Performance data per ASTM F 1798 were submitted to characterize the subject VIPER Systems components addressed in this notification. Specifically, static and dynamic cantilever beam testing as well as static axial slip testing were 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.

Pg 3 of 3

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

Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo features a stylized eagle with three lines representing its wings and tail feathers. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular pattern around the eagle.

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

JUL -- 6 2011

DePuy Spine, Inc. % Ms. Daphney Germain-Kolawole Regulatory Affairs Associate 325 Paramount Drive Raynham, Massachusetts 02767

Re: K111571 Trade/Device Name: VIPER® Systems Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: III Product Code: NKB, MNH, MNI, KWP Dated: June 03, 2011 Received: June 06, 2011

Dear Ms. Germain-Kolawole:

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 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

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

Page 2 - Ms. Daphney Germain-Kolawole

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/AboutlFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.html 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/ReportalProblem/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/ResourcesforYou/Industry/default.htm.

Sincerely yours.

E. S. Keith

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

Enclosure

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

### INDICATIONS FOR USE STATEMENT

## KIII 5 71 510(k) Number (if known):

Device Name: VIPER® Systems

### Indications For Use:

The 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 VIPER Systems metallic components 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.

When used in a posterior percutaneous approach with MIS instrumentation, the VIPER Systems metallic components are intended for noncervical pedicle fixation and nonpedicle fixation for fusion 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.

The VIPER PEEK rods are only indicated for fusion procedures for spinal stenosis with instability (no greater than Grade I spondylolisthesis) from L1-S1 in skeletally mature patients.

| Prescription Use | X |
|------------------|---|
|------------------|---|

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

| 510(k) Number | K111571 |
|---------------|---------|
|---------------|---------|

DePuy Spine, Inc., a Johnson & Johnson Company
Page 18