Mega Plus Spine System

K173180 · Bk Meditech, Co., Ltd. · NKB · Mar 15, 2018 · Orthopedic

Device Facts

• Record ID: K173180
• Device Name: Mega Plus Spine System
• Applicant: Bk Meditech, Co., Ltd.
• Product Code: NKB · Orthopedic
• Decision Date: Mar 15, 2018
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Mega Plus Spine System is 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: degenerative disc disease; spondylolisthesis; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis).

Device Story

Mega Plus Spine System is a posterior spinal fixation system; components include pedicle screws (multi-axial, mono, long-arm), iliac screws, rods, locking bolts, cross-links, and connectors. Surgeons use these components to build spinal implant constructs to stabilize and promote fusion. System is used in clinical settings by surgeons; components are non-sterile and single-use. Device provides mechanical immobilization of spinal segments to facilitate fusion in patients with acute or chronic spinal instabilities or deformities. Benefit is stabilization of the spine to treat conditions like degenerative disc disease or fractures.

Clinical Evidence

No clinical data. Substantial equivalence is supported by non-clinical bench testing, including static compression bending, static tension bending, static torsion, and dynamic axial compression bending fatigue per ASTM F1717-15, as well as component testing per ASTM F1798-13.

Technological Characteristics

Top-loading posterior spinal fixation system. Materials: Titanium alloy (Ti-6Al-4V ELI) conforming to ASTM F136. Components: Pedicle screws, iliac screws, rods, locking bolts, cross-links, connectors. Mechanical testing standards: ASTM F1717-15 (static/dynamic bending, torsion) and ASTM F1798-13 (component testing). Supplied non-sterile, single-use.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization and stabilization as an adjunct to fusion for thoracic, lumbar, and sacral spine conditions including degenerative disc disease, spondylolisthesis, fracture, dislocation, scoliosis, kyphosis, 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

• International Synergy™ VLS (K000236)
• S4 Spinal System (K050979)
• S 100 Pedicle Screw System (K111940)
• Firebird Spinal Fixation System (K130176)
• Click'X (K031175)
• Polaris Spinal System (K123549)
• XIA 3 Spinal System (K113666)

Submission Summary (Full Text)

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March 15, 2018

BK MEDITECH Co., Ltd. % Meredith L. May, MS, RAC Vice President, Empirical Consulting Empirical Testing Corporation 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K173180

Trade/Device Name: Mega Plus Spine System Regulation Number: 21 CFR 888.3070 Regulation Name: Thoracolumbosacral pedicle screw system Regulatory Class: Class II Product Code: NKB Dated: February 23, 2018 Received: February 28, 2018

Dear Ms. May:

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 (QS) regulation (21 CFR Part 820);

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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 mediation-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,

Ronald P. Jean -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 | Form Approved: OMB No. 0910-0120 |
|------------------------------------------------------------|----------------------------------------------------------------------|
| Food and Drug Administration<br><b>Indications for Use</b> | Expiration Date: January 31, 2017<br>See PRA Statement on last page. |

| 510(k) Number ( <i>if known</i> ) | K173180 |
|-----------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | Mega Plus Spine System |
| Indications for Use ( <i>Describe</i> ) | The Mega Plus Spine System is 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: degenerative disc disease; spondylolisthesis; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis). |

| Type of Use (Select one or both, as applicable) | <label><input checked="" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D)</label> <label><input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C)</label> |
|-------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
|-------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|

PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

| FORM FDA 3881 (9/13) | Page 1 of 1 | PSC Publishing Services [phone] EE |
|----------------------|-------------|-------------------------------------------|
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### 510(K) SUMMARY

| Submitter's Name: | BK MEDITECH CO., LTD. |
|----------------------------|--------------------------------------------------------------------------------------------|
| Submitter's Address: | 58, Eunhaengnamu-ro, Yanggam-myeon,<br>Hwaseong-si, Gyeonggi-do, 18633, KOREA, REPUBLIC OF |
| Submitter's Telephone: | 82-31-352-9135 |
| Contact Person: | Meredith L. May MS, RAC<br>Empirical Consulting<br>719-337-7579 |
| Date Summary was Prepared: | 27 September 2017 |
| Trade or Proprietary Name: | Mega Plus Spine System |
| Common or Usual Name: | Thoracolumbosacral Pedicle Screw System |
| Classification: | Class II per 21 CFR §888.3070 Device Classification |
| Product Code: | NKB |
| Classification Panel: | Division of Orthopedic Devices |

# DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:

The Mega Plus Spine System is a top-loading multiple component, posterior spinal fixation systems which consist of pedicle screws (multi-axial, multi-axial long-arm, mono and long-arm), iliac screws, rods, locking bolts, cross-links and connectors. The Mega Plus Spine System will allow surgeons to build a spinal implant construct to stabilize and promote spinal fusion. The Mega Plus Spine System implant components are supplied non-sterile, single use and fabricated from titanium alloy (Ti-6Al-4V ELI) that conforms to the ASTM F136. Various sizes of these implants are available. Specialized instruments are also available for the application and removal of the Mega Plus Spine System.

# INDICATIONS FOR USE

The Mega Plus Spine System is 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: degenerative disc disease; spondylolisthesis; fracture; dislocation; scoliosis; spinal tumor; and failed previous fusion (pseudarthrosis).

### TECHNOLOGICAL CHARACTERISTICS

The subject and predicate devices have nearly identical technological characteristics and the minor differences do not raise any new issues of safety and effectiveness. Specifically the following characteristics are identical between the subject and predicates:

- . Indications for Use

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- Principles of Operation ●
- Materials of Manufacture .
- Implant Sizes ●

Table 5-1: Predicate Devices

| 510k | Trade or Proprietary or | Manufacturer | Predicate |
|---------|----------------------------|---------------------------------|------------|
| Number | Model Name | | Type |
| K000236 | International Synergy™ VLS | INTERPORE CROSS | Primary |
| K050979 | S4 Spinal System | Aesculap®, Inc. | Additional |
| K111940 | S 100 Pedicle Screw System | Renovis | Additional |
| K130176 | Orthofix | Firebird Spinal Fixation System | Additional |
| K031175 | Click'X | Synthes | Additional |
| K123549 | Polaris Spinal System | Biomet | Additional |
| K113666 | XIA 3 Spinal System | Stryker Spine | Additional |

### PERFORMANCE DATA

The Mega Plus Spine System has been tested in the following test modes:

- Static compression bending per ASTM F1717-15 ●
- Static tension bending per ASTM F1717-15 ●
- Static torsion per ASTM F1717-15 .
- Dynamic axial compression bending fatigue per ASTM F1717-15 ●
- Component testing per ASTM F1798-13 ●

The results of this non-clinical testing show that the strength of the Mega Plus Spine System is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

# CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the Mega Plus Spine System is substantially equivalent to the predicate device.