PASS XS Spinal System

K160640 · Medicrea International SA · NKB · Sep 23, 2016 · Orthopedic

Device Facts

• Record ID: K160640
• Device Name: PASS XS Spinal System
• Applicant: Medicrea International SA
• Product Code: NKB · Orthopedic
• Decision Date: Sep 23, 2016
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic, Pediatric

Intended Use

The PASS XS Spinal System is a pedicle screw fixation system intended for 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 the thoracic, lumbar, and sacral spine: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, tracture or dislocation), deformity or curvature (e.g., scoliosis, and/or lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed previous fusion. When used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS XS Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. The PASS XS Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

Device Story

PASS XS Spinal System; pedicle screw fixation system for spinal stabilization/immobilization; used as adjunct to fusion. Components: pedicle screws, rods, connectors, nuts, crosslinks. Material: titanium alloy (Ti-6Al-4V ELI) and cobalt-chromium molybdenum alloy. Surgeon-implanted via posterior approach; construct tailor-made for individual patient anatomy. Provides rigid fixation for thoracic, lumbar, sacral segments. Benefits: correction/stabilization of spinal deformities/instabilities. Smaller version of PASS-LP system.

Clinical Evidence

No clinical data. Bench testing only. Mechanical testing included static axial compression, static torsion, dynamic axial compression (ASTM F1717), and axial/torsional gripping and flexion-extension (ASTM F1798).

Technological Characteristics

Materials: Titanium alloy (Ti-6Al-4V ELI per ASTM F136/ISO 5832-3) and Co-Cr-Mo alloy (per ISO 5832-12/ASTM F1537). Mechanical fixation via pedicle screws, rods, connectors, nuts, crosslinks. Rigid locking configuration. Non-powered, mechanical implant system.

Indications for Use

Indicated for skeletally mature patients with thoracic, lumbar, or sacral spine instabilities/deformities (DDD, spondylolisthesis, trauma, scoliosis/lordosis, tumor, stenosis, pseudoarthrosis, failed fusion) and pediatric patients with adolescent idiopathic scoliosis (posterior approach only).

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

• Medicrea Pass LP Spinal System (K141398)

Reference Devices

• Synthes Spine USS Small Stature Spinal System (K994121)
• Globus Medical Revere 4.5 Spinal Stabilization System (K113395)
• Depuy Moss Miami SS System (K964024)

Submission Summary (Full Text)

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

September 23, 2016

Medicrea® International S.A. Mr. David Rvan VP Product Development and Marketing 14 Porte du Grand Lyon 01700 Neyron FRANCE

Re: K160640

Trade/Device Name: PASS XS Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, OSH, MNI, MNH Dated: August 29, 2016 Received: August 30, 2016

Dear Mr. Ryan:

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 Parts 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,

# Vincent J. Devlin -S

for

- 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) K160640

Device Name PASS XS Spinal System

#### Indications for Use (Describe)

The PASS XS Spinal System is a pedicle screw fixation system intended for 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 the thoracic, lumbar, and sacral spine: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, tracture or dislocation), deformity or curvature (e.g., scoliosis, and/or lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed previous fusion.

When used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS XS Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. The PASS XS Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|---------------------------------------------|
| × 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 SUBMITTER

MEDICREA® INTERNATIONAL S.A. 14 Porte Du Grand Lyon 01700 NEYRON- France

Phone: [phone] Fax: [phone]

Contact Person: David RYAN VP PRODUCT DEVELOPMENT AND MARKETING [e-mail]

Date Prepared: 09/21/2016

# DEVICE

Name of Device: PASS XS Spinal System

Common or Usual Name: Pediatric Thoracolumbar Fixation System

Classification Name: Pedicle Screw Spinal System (21 CFR 888.3070)

Regulatory Class: III

Product Code: NKB, OSH, MNI, MNH

# PREDICATE DEVICES

Medicrea Pass LP Spinal System, K141398 (primary). Synthes Spine USS Small Stature Spinal System, K994121 (additional). Globus Medical Revere 4.5 Spinal Stabilization System, K113395 (additional). Depuy Moss Miami SS System, K964024 (additional).

## DEVICE DESCRIPTION

The PASS XS Spinal System is designed to contribute to the correction and surgical stabilization of the thoracic, lumbar and sacral spine.

The system consists of pedicle screws, connectors, rods, nuts, and crosslink components. It can be used for single or multiple level fixations. Components are manufactured from titanium alloy (Ti-6Al-4V ELI) that conforms to ASTM F136 and ISO5832-3 and cobaltchromium molybdenum alloy Co-Cr28Mo6 that conforms to ISO 5832-12 and ASTM F1537.

The PASS XS components can be rigidly locked into a variety of configurations, with each construct being tailor-made for the individual case.

The purpose of this submission is to introduce the PASS XS Spinal System which is, essentially, a smaller version of the PASS-LP system.

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# INDICATIONS FOR USE

The PASS XS Spinal System is a pedicle screw fixation system intended for 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: degenerative disc disease (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (e.g., fracture or dislocation), deformity or curvature (e.g., scoliosis, kyphosis, and/or lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed previous fusion.

When used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS XS Spinal System implants are indicated as an adjunct to treat adolescent idiopathic scoliosis. The PASS XS Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

# COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH PREDICATE DEVICES

The PASS XS Spinal System and the PASS LP Spinal System (K141398, primary) have the same technological characteristics and principles of operation. The PASS XS Spinal System and the USS Small Stature Spinal System (K994121, reference) have the same intended use and more restrictive indications for use. The PASS XS Spinal System and the Globus Medical Revere 4.5 Spinal Stabilization System (K113395, reference) have the same intended use and similar indications for use, and share similar key implant dimensions. Performance testing has demonstrated comparable safety and performance to Medicrea PASS LP Spinal System (K141398, primary) and Depuy Moss Miami SS System (K964024, reference). Thus, the PASS XS Spinal System is substantially equivalent to the PASS LP Spinal System (K141398, primary).

# PERFORMANCE DATA

The following performance data were provided in support of the substantial equivalence determination.

### Biocompatibility Testing

The PASS XS Spinal System implants are made from the same materials as their predicates.

#### Mechanical testing

The tests performed on the PASS XS Spinal System (static axial compression, static torsion and dynamic axial compression according to ASTM F1717, and axial gripping, torsional gripping and flexion-extension according to ASTM F1798) indicate that the product is as mechanically sound as other devices commercially available.

### Animal study

No animal studies were performed.

### Clinical study

No clinical studies were performed.

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# CONCLUSION

The Medicrea PASS XS Spinal System is substantially equivalent to its predicate devices in terms of indications for use, design, material and function.