Spineology Navigation Instruments

K172518 · Spineology, Inc. · OLO · Jan 5, 2018 · Neurology

Device Facts

• Record ID: K172518
• Device Name: Spineology Navigation Instruments
• Applicant: Spineology, Inc.
• Product Code: OLO · Neurology
• Decision Date: Jan 5, 2018
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 882.4560
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic StealthStation® System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, long bone, or vertebra, can be identified relative to a CT- or MR-based model, fluoroscopic images, or digitalized landmarks of the anatomy.

Device Story

Spineology Navigation Instruments consist of manual, reusable surgical tools (awls, bone taps, drills, screwdrivers) used to prepare and place pedicle screws. Instruments integrate with Medtronic StealthStation® System for image-guided surgery. Surgeon attaches NavLock™ Tracker to instruments; system registers instruments to patient anatomy (CT/MR/fluoroscopy). Navigation provides real-time visual feedback on instrument position relative to anatomical structures. Used in OR by surgeons to improve precision during spinal fixation procedures. Benefits include enhanced accuracy in screw trajectory and placement, potentially reducing surgical complications.

Clinical Evidence

Bench testing only. Verification testing included instrument mating (NavLock™ Tracker connection), registration to StealthStation® system, and side-by-side accuracy comparison against predicate devices. No clinical data provided.

Technological Characteristics

Stainless steel (ASTM F899). Manual, non-sterile, reusable orthopedic stereotaxic instruments. Includes awls, taps, drills, screwdrivers. Compatible with Medtronic StealthStation® System (v2.1.0) via NavLock™ Tracker interface. No internal software or electronics; passive navigation components.

Indications for Use

Indicated for use during spinal surgery in skeletally mature patients requiring pedicle screw fixation (Fortress, Threshold V2, Palisade systems) for treatment of acute/chronic instabilities or deformities of the thoracic, lumbar, and sacral spine. Used to assist surgeons in locating anatomical structures during open or minimally invasive procedures via stereotactic navigation.

Regulatory Classification

Identification

A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.

Predicate Devices

• Medtronic Navigated Reusable Instruments for Use with StealthStation® and IPC® Powerease Systems (K170679)
• Navigation Instruments (K153203)

Submission Summary (Full Text)

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January 5, 2018

Image /page/0/Picture/1 description: The image contains the logos of the Department of Health and Human Services (HHS) and the Food and Drug Administration (FDA). The HHS logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. Food & Drug Administration" in blue text.

Spineology Inc. Jacqueline Hauge Regulatory Affairs Manager 7800 3rd Street N.. Suite 600 Scandia, Minnesota 55128

Re: K172518

Trade/Device Name: Spineology Navigation Instruments Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: December 5, 2017 Received: December 6, 2017

Dear Jacqueline Hauge:

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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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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.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

# Katherine D. Kavlock -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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### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

# Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known)

K172518

Device Name Spineology Navigation Instruments

### Indications for Use (Describe)

Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic StealthStation® System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, long bone, or vertebra, can be identified relative to a CT- or MR-based model, fluoroscopic images, or digitalized landmarks of the anatomy.

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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Image /page/3/Picture/1 description: The image shows the word "Spineology" in bold, black font. To the right of the word is a graphic of a cluster of purple dots. The dots are arranged in a circular pattern, with one large dot in the center and several smaller dots surrounding it.

# 510(k) Summary

| Date Prepared: | December 5, 2017 |
|-----------------|-------------------------------------------------------------------------------------------------------------------------------|
| Submitter: | Spineology Inc.<br>7800 3rd Street North<br>Suite 600<br>Saint Paul, MN 55128 |
| | Establishment Registration Number: 2135156 |
| Contact Person: | Jacqueline A. Hauge<br>Regulatory Affairs Manager<br>Phone: [phone]<br>Fax: [phone]<br>Email: [e-mail] |

## Device Name and Classification

| Trade Name: | Spineology Navigation Instruments |
|----------------------|-----------------------------------|
| Common Name: | Orthopedic Stereotaxic instrument |
| Classification Name: | Stereotaxic Instrument |
| Product Codes: | OLO |
| Regulatory Class: | Class II |
| Regulation Number: | 21 CFR 882.4560 |
| Panel: | Orthopedic |

# Predicate Devices

| Primary: | K170679 | Medtronic Navigated Reusable Instruments for Use with StealthStation®<br>and IPC® Powerease Systems (Medtronic Sofamor Danek) |
|-------------|---------|-------------------------------------------------------------------------------------------------------------------------------|
| Additional: | K153203 | Navigation Instruments (Globus Medical) |

#### 1. Purpose

The purpose of this Premarket Notification is to obtain initial FDA clearance for Spineology Navigation Instruments which are intended for use with Spineology's Fortress, Threshold, Threshold V2, and Palisade Pedicular Fixation Systems and the Medtronic StealthStation® System.

#### 2. Device Description

#### Spineology Navigation Instruments A.

Spineology Navigation Instruments are non-sterile, reusable instruments; including awls, bone taps, drills, and screwdrivers that are operated manually. These instruments are manufactured from stainless steel in accordance with ASTM F899 and are intended to be used within the context and limitations of the indications for use for Spineology's FDA-cleared Fortress, Threshold V2, and Palisade Pedicular Fixation Systems and the Medtronic Synergy Experience StealthStation System 57 (v2.1.0).

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510(k) Summary

Image /page/4/Picture/1 description: The image shows the word "Spineology" in a bold, sans-serif font. The word is black, and the "o" in "Spineology" is slightly larger than the other letters. To the right of the word is a cluster of purple dots arranged in a circular pattern. The dots are of varying sizes, with the largest dot in the center and the smaller dots surrounding it.

#### B. Spineology Pedicular Fixation Systems

Spineology Fortress, Threshold V2, and Palisade Pedicular Fixation Systems consist of screws, curved and straight rods, and Connector devices to allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. All screws are available with or without a hydroxyapatite coating. These 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 screws can be placed in the pedicles in a variety of trajectories ranging from the standard anatomic transpedicular path projected medially toward the ventral vertebral body, to a caudocephalad path sagittally and a laterally directed path in the transverse plane.

#### 3. Indications for Use

Spineology Navigation Instruments are intended to be used during the preparation and placement of Spineology's Fortress, Threshold V2, and Palisade pedicle screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic StealthStation® System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, long bone, or vertebra, can be identified relative to a CT- or MR-based model, fluoroscopic images, or digitalized landmarks of the anatomy.

#### 4. Technological Characteristics

When compared to the predicate devices, Spineology Navigation Instruments have the same intended use and similar technological characteristics, including:

- Design
- Materials of Construction
- Fundamental Scientific Technology
- Principle of Operation
- Function/Performance ●

#### ഗ് Non-Clinical Testing

Design verification testing, including mating, registration, and accuracy, was conducted to ensure that Spineology Navigation Instruments are safe and effective for their intended use, to ensure functionality and compatibility with the Medtronic StealthStation®, and to demonstrate substantial equivalence to the predicate device.

- . Instrument mating testing evaluated the connection between the NavLock™ Tracker and Spineology Navigation Instruments.
- Registration testing was performed to ensure that Spineology Navigation Instruments can be registered to the StealthStation® System.
- Accuracy testing included a side-by-side comparison of Spineology Navigation Instruments to the predicate device.

#### 6. Conclusion

Based on the intended use, technological characteristics, and comparison to the predicate devices, Spineology Navigation Instruments have been shown to be substantially equivalent to the legally marketed predicate devices.