Dymaxeon Spine System

K150184 · Back 2 Basics Direct, LLC · NKB · Jun 15, 2015 · Orthopedic

Device Facts

• Record ID: K150184
• Device Name: Dymaxeon Spine System
• Applicant: Back 2 Basics Direct, LLC
• Product Code: NKB · Orthopedic
• Decision Date: Jun 15, 2015
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Dymaxeon Spine System is intended to provide immobilization of spinal segments in skeletally mature patients as an adjunct to fusion of the following acute and chronic instabilities or deformities of thoracic, lumbar, and sacral/iliac spine (T1-S1/Ileum): degenerative disc disease (defined as discogenic back pain with degeneration of disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, soliosis, spinal tumor, and failed previous fusion (pseudarthrosis).

Device Story

Posterior pedicle screw system for temporary spinal stabilization during fusion; provides single or multiple level fixation. System components include polyaxial pedicle screws, rods, transverse connectors, and hooks (laminar, pedicular, offset). Surgeon implants hardware into thoracic, lumbar, or sacral/iliac spine to immobilize segments. Device manufactured from titanium alloy (Ti6Al4V ELI). Used in clinical settings by surgeons. Provides mechanical support to facilitate bone fusion; benefits patient by stabilizing spinal instabilities or deformities.

Clinical Evidence

Bench testing only. Mechanical testing performed per ASTM F1717, including static compression bending, static torsion, and dynamic compression bending, to validate the performance of the 5.5mm rod, cannulated screw, and transverse connector components.

Technological Characteristics

Materials: Titanium alloy (Ti6Al4V ELI per ASTM F136). Components: Polyaxial pedicle screws, rods (5.5mm and 6.0mm), transverse connectors (non-axial and multi-axial), and hooks (laminar, pedicular, offset). Fixation: Posterior pedicle screw system. Testing standards: ASTM F1717.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization as an adjunct to fusion for acute/chronic instabilities or deformities of the thoracic, lumbar, and sacral/iliac spine (T1-S1/Ileum), including degenerative disc disease, degenerative spondylolisthesis with neurological impairment, fracture, dislocation, scoliosis, spinal tumor, and pseudarthrosis.

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

• Dymaxeon Spine System (K121786)
• Corelink Tiger Spine System (K113058)
• Blackstone SFS Parallel Rod Connectors (K080407)
• Synthes Anterior CSLP System (K000536)
• Stryker Xia Spinal System (K071373)

Submission Summary (Full Text)

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of three human profiles facing to the right, stacked on top of each other.

June 15, 2015

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

Back 2 Basics Direct, LLC % Mr. Samuel Pollard Musculoskeletal Clinical Regulatory Advisers, LLC 1331 H Street Northwest, 12th Floor Washington, District of Columbia 20005

Re: K150184

Trade/Device Name: Dymaxeon Spine System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, MNI, MNH Dated: May 13, 2015 Received: May 14, 2015

Dear Mr. Pollard:

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 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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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 contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely vours.

# Mark N. Melkerson -S

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

Enclosure

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## Indications for Use

510(k) Number (if known) K150184

Device Name Dymaxeon Spine System

#### Indications for Use (Describe)

The Dymaxeon Spine System is intended to provide immobilization of spinal segments in skeletally mature patients as an adjunct to fusion of the following acute and chronic instabilities or deformities of thoracic, lumbar, and sacral/iliac spine (T1-S1/Ileum): degenerative disc disease (defined as discogenic back pain with degeneration of disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, soliosis, spinal tumor, and failed previous fusion (pseudarthrosis).

Type of Use (Select one or both, as applicable)

2 Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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## 510(k) Summary

| Device Trade Name: | Dymaxeon Spine System |
|--------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer: | BACK 2 BASICS DIRECT, LLC<br>6701 Rockside Road; Suite 200<br>Independence, OH 44131 |
| Contact: | Scot Miller, DO, MBA, FACS<br>Principal<br>6701 Rockside Road; Suite 200<br>Independence, OH 44131<br>Phone: [phone]<br>Fax: [phone]<br>[e-mail] |
| Prepared by: | Samuel Pollard<br>Musculoskeletal Clinical Regulatory Advisers, LLC<br>1331 H Street NW, 12th Floor<br>Washington, DC 20005<br>Phone: [phone]<br>Fax: [phone]<br>[e-mail] |
| Date Prepared: | May 13, 2015 |
| Classification: | 21 CFR 888.3070: Pedicle screw spinal system |
| Class: | III |
| Product Code: | NKB, MNI, MNH |

### Indications for Use:

The Dymaxeon Spine System is intended to provide immobilization 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 thoracic, lumbar, and sacral/iliac spine (T1 -S1/lleum): degenerative disc disease (defined as discogenic back pain with degeneration of disc confirmed by history and radiographic studies), degenerative spondylolisthesis with objective evidence of neurological impairment, fracture, dislocation, scoliosis, spinal tumor, and failed previous fusion (pseudarthrosis).

### Purpose of Submission:

The purpose of this 510(k) is to add additional rod, pedicle screw, transverse connectors, and hooks to the previously cleared Dymaxeon Spine System. Specifically, B2B Direct is adding a

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Ø5.5 mm rod component option, a cannulated screw option to the currently marketed Ø6.0 mm rods and solid screws cleared in K121786, a transverse connector to increase torsional rigidity, and hook options (laminar, pedicular, and offset) to provide the surgeon with more support options. The transverse connector is available in non-axial and multi-axial configurations.

## Device Description:

The Dymaxeon Spine System is a posterior pedicle screw system manufactured from titanium alloy (Ti6Al4V ELI per ASTM F136) designed for temporary stabilization of the spine during the development of spinal fusion. The Dymaxeon Spine System is comprised of polyaxial pedicle screws and rods. The Dymaxeon Spine System can be used for single or multiple level fixations.

The additional Ø5.5mm rod, cannulated screw, transverse connector, and hook components will be used in conjunction with the predicate Dymaxeon Spine System during the fixation of the spine. The components are manufactured from titanium alloy and come in a variety of lengths.

No other modifications have been made to the Dymaxeon Spine System.

### Predicate Devices:

The Ø5.5mm rod, cannulated screw, and transverse connector components are substantially equivalent to the primary predicate Dymaxeon Spine System (K121786). Additional predicate devices include the Corelink Tiger Spine System (K113058), the Blackstone SFS Parallel Rod Connectors (K080407), the Synthes Anterior CSLP System (K000536), and the Stryker Xia Spinal System (K071373).

### Technological Characteristics:

The Ø5.5mm rod, cannulated screw, and transverse connector components are substantially equivalent to the referenced predicates with respect to its intended use, material, geometry, and method of fixation.

### Preclinical Testing:

The non-clinical tests performed by the company include static compression bending, static torsion, and dynamic compression bending testing per ASTM F1717 of the Ø5.5mm rod and cannulated screw components. The results of the performed tests demonstrate that the Dymaxeon Spine System with Ø5.5mm rod, cannulated screw, and transverse connector components is substantially equivalent to legally marketed predicate devices.

### Conclusion:

The information summarized in the Design Control Activities Summary demonstrates that the Ø5.5mm rod. cannulated screw, transverse connectors, and hooks are substantially equivalent to the predicate device as demonstrated by mechanical testing.