Streamline OCT Occipito-Cervico-Thoracic System

K161498 · Pioneer Surgical Technology, Inc. (Dba Rti Surgical, Inc.) · NKG · Aug 22, 2016 · Orthopedic

Device Facts

• Record ID: K161498
• Device Name: Streamline OCT Occipito-Cervico-Thoracic System
• Applicant: Pioneer Surgical Technology, Inc. (Dba Rti Surgical, Inc.)
• Product Code: NKG · Orthopedic
• Decision Date: Aug 22, 2016
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3075
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Streamline OCT Occipito-Cervico-Thoracic System is intended to provide immobilization of spinal segments as an adjunct to fusion when using autograft for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine (T1 to T3): traumatic spinal fractures and/ or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical/thoracic spine; and degenerative disease, including intractable radiculopathy and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The system is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion. In order to achieve additional levels of fixation, the Streamline OCT System may be connected to the Quantum Spinal Fixation System, Streamline MIS Spinal Fixation System or Streamline TL Spinal System using connectors and/or transition rods.

Device Story

The Streamline OCT System is a posterior spinal fixation construct consisting of rods, hooks, polyaxial screws, high-angle screws, locking caps, occipital plates, and occipital screws. It is used by surgeons in an operating room setting to immobilize and stabilize spinal segments. The system components are assembled to create a rigid construct that provides mechanical support to the craniocervical, cervical, and thoracic spine. It may be connected to other RTI spinal systems (Quantum, MIS, TL) via transition rods or connectors to extend fixation levels. The device benefits patients by providing structural stability for fusion or temporary support in palliative tumor cases, thereby addressing spinal instability and associated pain or neurological symptoms.

Clinical Evidence

No clinical trials were conducted. Evidence of substantial equivalence is based on engineering analysis, mechanical testing (ASTM F1717 and ASTM F2706), and a review of published literature. Testing demonstrated that the subject system performs comparably to predicate devices, with no new risks to safety or effectiveness identified.

Technological Characteristics

Construct components manufactured from ASTM F136 titanium alloy and ASTM F1537 cobalt chromium molybdenum alloy. System includes rods, hooks, polyaxial/high-angle screws, locking caps, and occipital plates. Mechanical testing performed per ASTM F1717 and ASTM F2706. Non-active, mechanical implant system.

Indications for Use

Indicated for patients with acute/chronic instabilities of the craniocervical junction, cervical spine (C1-C7), and thoracic spine (T1-T3) requiring immobilization as an adjunct to fusion. Conditions include traumatic fractures/dislocations, instability/deformity, pseudarthrosis, tumors, and degenerative disease (radiculopathy, arm pain, facet instability). Also indicated for spinal column integrity restoration in patients with advanced cervical tumors and limited life expectancy where fusion is not achievable.

Regulatory Classification

Identification

Posterior cervical screw systems are comprised of multiple, interconnecting components, made from a variety of materials that allow an implant system to be built from the occiput to the upper thoracic spine to fit the patient's anatomical and physiological requirements, as determined by preoperative cross-sectional imaging. Such a spinal assembly consists of a combination of bone anchors via screws (i.e., occipital screws, cervical lateral mass screws, cervical pedicle screws, C2 pars screws, C2 translaminar screws, C2 transarticular screws), longitudinal members (e.g., plates, rods, including dual diameter rods, plate/rod combinations), transverse or cross connectors, interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors), and closure mechanisms (e.g., set screws, nuts). Posterior cervical screw systems are rigidly fixed devices that do not contain dynamic features, including but not limited to: non-uniform longitudinal elements or features that allow more motion or flexibility compared to rigid systems.Posterior cervical screw systems are intended to provide immobilization and stabilization of spinal segments in patients as an adjunct to fusion for acute and chronic instabilities of the cervical spine and/or craniocervical junction and/or cervicothoracic junction such as: (1) Traumatic spinal fractures and/or traumatic dislocations; (2) deformities; (3) instabilities; (4) failed previous fusions (e.g., pseudarthrosis); (5) tumors; (6) inflammatory disorders; (7) spinal degeneration, including neck and/or arm pain of discogenic origin as confirmed by imaging studies (radiographs, CT, MRI); (8) degeneration of the facets with instability; and (9) reconstruction following decompression to treat radiculopathy and/or myelopathy. These systems are also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

Special Controls

*Classification.* Class II (special controls). The special controls for posterior cervical screw systems are:(1) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use. (2) Nonclinical performance testing must demonstrate the mechanical function and durability of the implant. (3) Device components must be demonstrated to be biocompatible. (4) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments. (5) Labeling must include the following: (i) A clear description of the technological features of the device including identification of device materials and the principles of device operation; (ii) Intended use and indications for use including levels of fixation; (iii) Device specific warnings, precautions, and contraindications that include the following statements: (A) “Precaution: Preoperative planning prior to implantation of posterior cervical screw systems should include review of cross-sectional imaging studies ( *e.g.,* CT and/or MRI) to evaluate the patient's cervical anatomy including the transverse foramen, neurologic structures, and the course of the vertebral arteries. If any findings would compromise the placement of these screws, other surgical methods should be considered. In addition, use of intraoperative imaging should be considered to guide and/or verify device placement, as necessary.”(B) “Precaution: Use of posterior cervical pedicle screw fixation at the C3 through C6 spinal levels requires careful consideration and planning beyond that required for lateral mass screws placed at these spinal levels, given the proximity of the vertebral arteries and neurologic structures in relation to the cervical pedicles at these levels.” (iv) Identification of magnetic resonance (MR) compatibility status; (v) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user, and; (vi) Detailed instructions of each surgical step, including device removal.

Predicate Devices

• Medtronic VERTEX Reconstruction System (K143471)
• Streamline OCT Spinal System (K150254)
• DePuy Mountaineer OCT Spinal System (K151885)

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

August 22, 2016

Pioneer Surgical Technology, Incorporated (DBA RTI Surgical, Incorporated) Ms. Sarah Pleaugh Regulatory Affairs Specialist 375 River Park Circle Marquette, Michigan 49855

Re: K161498

Trade/Device Name: Streamline OCT Occipito-Cervico-Thoracic System Regulatory Class: Unclassified Product Code: NKG, KWP Dated: May 31, 2016 Received: June 1, 2016

Dear Ms. Pleaugh:

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 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)

#### K161498

#### Device Name

Streamline OCT Occipito-Cervico-Thoracic System

#### Indications for Use (Describe)

The Streamline OCT Occipito-Cervico-Thoracic System is intended to provide immobilization of spinal segments as an adjunct to fusion when using autograft for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine (T1 to T3): traumatic spinal fractures and/ or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical/thoracic spine; and degenerative disease, including intractable radiculopathy and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability.

The system is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

In order to achieve additional levels of fixation, the Streamline OCT System may be connected to the Quantum Spinal Fixation System, Streamline MIS Spinal Fixation System or Streamline TL Spinal System using connectors and/or transition rods.

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

| <span> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> | <span> <span style="font-size: 16px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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#

Prepared: August 17, 2016

| Company: | Pioneer Surgical Technology, Inc.<br>(DBA RTI Surgical, Inc.)<br>375 River Park Circle<br>Marquette, MI 49855 USA<br>Phone: [phone]<br>Fax: [phone] |
|---------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Sarah Pleaugh, Regulatory Affairs Specialist |
| Trade name: | Streamline OCT Occipito-Cervico-Thoracic System |
| Device name: | Streamline OCT Occipito-Cervico-Thoracic System |
| Classification: | Unclassified; Pre-amendment device<br>(Product Code NKG, KWP) |
| Panel: | Panel Code 87 |
| Primary Predicate: | Medtronic VERTEX Reconstruction System (K143471) |
| Additional Predicates: | Streamline OCT Spinal System (K150254)<br>DePuy Mountaineer OCT Spinal System (K151885) |
| Description: | The Streamline OCT System consists of a variety of rods, hooks, polyaxial screws, high-angle screws, locking caps, occipital plates, occipital screws, and connecting components used to build an occipito-cervico-thoracic spinal construct. System components are manufactured from ASTM F136 medical grade titanium alloy and ASTM F1537 medical grade cobalt chromium molybdenum alloy. Medical grade titanium alloy and medical grade cobalt chromium molybdenum alloy may be used together. The system should be implanted using only the surgical instruments designed for the system.<br>The purpose of this submission is to: expand the use of the system to include the use of screws in the posterior cervical spine, add line extension components and modify an existing component. |
| Indications for Use: | The Streamline OCT Occipito-Cervico-Thoracic System is intended to provide immobilization and stabilization of spinal segments as an adjunct to fusion when using autograft and/or allograft for the following acute and chronic instabilities of the craniocervical junction, the cervical spine (C1 to C7) and the thoracic spine (T1 to T3): traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical/thoracic spine; and degenerative disease, including intractable radiculopathy and/or myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability.<br>The system is also intended to restore the integrity of the spinal column |
| | even in the absence of fusion for a limited time period in patients with<br>advanced stage tumors involving the cervical spine in whom life<br>expectancy is of insufficient duration to permit achievement of fusion.<br><br>In order to achieve additional levels of fixation, the Streamline OCT<br>System may be connected to the Quantum Spinal Fixation System,<br>Streamline MIS Spinal Fixation System or Streamline TL Spinal System<br>using connectors and/or transition rods. |
| Summary of<br>Technological<br>Characteristics: | The subject system has a similar fundamental scientific technology as<br>the predicate K143471 Medtronic VERTEX Reconstruction System<br>(primary predicate) and reference devices. The subject system utilizes<br>equivalent surgical approaches, fundamental technology, designs,<br>materials, sterilization and packaging as the predicate devices. |
| Discussion of<br>Supporting Clinical<br>Evidence and Non-<br>Clinical Testing: | Engineering analysis was presented to confirm that the subject components<br>do not introduce new worst-case components or impact previously<br>completed construct testing. For device modifications, re-creation testing<br>was completed to demonstrate the modifications improve performance. In<br>support of the indications for use change, published literature and<br>previously completed mechanical testing (ASTM F1717 and ASTM<br>F2706) demonstrate that the subject and predicate systems are substantially<br>equivalent. No new risks to safety or effectiveness were raised by the<br>published literature search or non-clinical testing. |
| Substantial<br>Equivalence and<br>Comparison to<br>Legally Marketed<br>Devices: | The subject system is substantially equivalent to the K143471 Medtronic<br>VERTEX Reconstruction System (primary predicate) and K151885<br>DePuy Mountaineer OCT Spinal System (reference device). With<br>respect to the implants used to create the constructs utilized for the<br>indications sought, the subject devices are the same or similar in design<br>to the Streamline OCT devices most recently cleared in K150254<br>(earlier clearances of the system are noted in this submission for<br>reference purposes).<br><br>The design features, materials, indications for use, surgical approach,<br>and fundamental technology are substantially equivalent to predicate<br>devices. Previously completed mechanical testing and the clinical<br>evidence provided in this submission demonstrate there are no new risks<br>to safety or efficacy raised by the subject Streamline OCT System |

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