MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides

K220888 · Medacta International S.A. · QSR · May 24, 2022 · Orthopedic

Device Facts

• Record ID: K220888
• Device Name: MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides
• Applicant: Medacta International S.A.
• Product Code: QSR · Orthopedic
• Decision Date: May 24, 2022
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3040
• Device Class: Class 2

Intended Use

MySpine S2-Alar/Alar-Iliac and MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides are intended to be used with any 510(k) cleared, legally marketed, pedicle screw system (for its approved indications for use) and its respective compatible components for non-cervical open, posterior spinal fixation procedures intended for fusion. The SI trajectory of the MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guide is only intended to be used with M.U.S.T. SI Headless Screw System and its cleared indications for use. The MySpine S2-Alar/Alac and MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides (hereinafter referred to as "MySpine guides") are intended to be used as anatomical perforating guides, specific to a patient's anatomy, to assist intraoperatively in the screw trajectory in S1, S2 and in the Ilium. The guides are created using a surgical planning software which pre-operatively plans the positions of the components based upon radiological images of the patients' anatomical landmarks and the selected surgical equipment. The MySpine guides are intended for single use only.

Device Story

Patient-specific, single-use anatomical perforating guides; assist intraoperative screw trajectory in S1, S2, and Ilium. Input: patient spinal CT scans. Process: surgical planning software creates 3D model of vertebrae; generates patient-matched guides based on anatomical landmarks and selected surgical equipment. Output: physical guide used by surgeon in OR to direct screw placement. Benefit: improved accuracy of screw trajectory during spinal fixation. Used with 510(k) cleared pedicle screw systems; SI trajectory specifically for M.U.S.T. SI Headless Screw System.

Clinical Evidence

No clinical studies were conducted. Evidence consists of non-clinical bench testing, including software validation, cadaver testing, and guide accuracy assessment. Biocompatibility and sterilization data were leveraged from predicate devices.

Technological Characteristics

Patient-specific, single-use guides. Manufactured via 3D modeling from patient CT scans. Materials, biocompatibility, and sterilization methods are identical to previously cleared MySpine predicates.

Indications for Use

Indicated for patients undergoing non-cervical open, posterior spinal fixation procedures intended for fusion, requiring assistance with screw trajectory in S1, S2, and the Ilium.

Regulatory Classification

Identification

A smooth or threaded metallic bone fixation fastener is a device intended to be implanted that consists of a stiff wire segment or rod made of alloys, such as cobalt-chromium-molybdenum and stainless steel, and that may be smooth on the outside, fully or partially threaded, straight or U-shaped; and may be either blunt pointed, sharp pointed, or have a formed, slotted head on the end. It may be used for fixation of bone fractures, for bone reconstructions, as a guide pin for insertion of other implants, or it may be implanted through the skin so that a pulling force (traction) may be applied to the skeletal system.

Predicate Devices

• MySpine Pedicle Screw Placement Guides Extension (K203673)
• MySpine S2-Alar/Alac Pedicle Screw Placement Guides (K200792)

Reference Devices

• M.U.S.T. SI Headless Screw System

Submission Summary (Full Text)

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May 24, 2022

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Medacta International SA % Chris Lussier Senior Director, Quality, Regulatory and Clinical Research Medacta USA 3973 Delp Street Memphis, Tennessee 38118

# Re: K220888

Trade/Device Name: MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides Regulation Number: 21 CFR 888.3040 Regulation Name: Smooth or threaded metallic bone fixation fastener Regulatory Class: Class II Product Code: QSR, PQC Dated: March 25, 2022 Received: March 28, 2022

# Dear Mr. Lussier:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

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801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4. Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

Colin O'Neill, M.B.E. Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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# Indications for Use

510(k) Number (if known)

K220888

### Device Name

MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides

## Indications for Use (Describe)

MySpine S2-Alar/Alar-Iliac and MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides are intended to be used with any 510(k) cleared, legally marketed, pedicle screw system (for its approved indications for use) and its respective compatible components for non-cervical open, posterior spinal fixation procedures intended for fusion. The SI trajectory of the MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guide is only intended to be used with M.U.S.T. SI Headless Screw System and its cleared indications for use. The MySpine S2-Alar/Alac and MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides (hereinafter referred to as "MySpine guides") are intended to be used as anatomical perforating guides, specific to a patient's anatomy, to assist intraoperatively in the screw trajectory in S1, S2 and in the Ilium. The guides are created using a surgical planning software which pre-operatively plans the positions of the components based upon radiological images of the patients' anatomical landmarks and the selected surgical equipment. The MySpine guides are intended for single use only.

Please see MySpine guides labelling for compatibility requirements between the MySpine guides and the 510(k) cleared pedicle screw system intended to be used.

| Type of Use (Select one or both, as applicable) |
|-----------------------------------------------------------------------------------------------------|
| <span style="text-align:left;"> Prescription Use (Part 21 CFR 801 Subpart D) </span> |
| <span style="text-align:left;"> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |

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# 510(k) Summary

#### I. Submitter

Medacta International SA

c/o Chris Lussier, Senior Director, Quality, Regulatory and Clinical Research Medacta USA 3973 Delp Street Memphis, Tennessee 38118 [phone]

Additional Contact Person: Stefano Baj, Regulatory and Compliance Director, Medacta International SA Date Prepared: March 25, 2022 Date Revised: May 19, 2022

#### II. Device

| Device Proprietary Name: | MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides |
|--------------------------------|---------------------------------------------------------------------------------------------------------------------|
| Common or Usual Name: | Screw Placement Guide |
| Product Code, Name, Regulation | 1) QSR, Sacroiliac Screw Placement Guide, 21 CFR 888.3040<br>2) PQC, Pedicle Screw Placement Guide, 21 CFR 888.3070 |
| Device Classification | II |

#### III. Predicate Device

Substantial equivalence is claimed to the following primary predicate device:

- > MySpine Pedicle Screw Placement Guides Extension, K203673, Medacta International SA
In addition the following predicate device is referenced within the submission :

- > MySpine S2-Alar/Alac Pedicle Screw Placement Guides, K200792, Medacta International SA
#### IV. Device Description

The MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides are a line extension to Medacta's MySpine Pedicle Screw Placement Guides. Identically to the other Medacta MySpine products, the MySpine S2-S1 Pedicle and Sacro-Iliac Screw Placement Guides are a patient matched, pedicle targeted, technology involving the production of patient specific guides for placement of pedicle and sacro-iliac screws based on patient's anatomy. Specifically, the subject MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides are intended to be used as anatomical perforating guides to assist intra-operatively in the preparation of the screw trajectory in S1, S2 and in the Ilium.

The MySpine software platform allows the surgeon to complete 3D pre-operative planning based on the patient's spinal CT scans. CT images are used to create a 3D model of the vertebrae that will

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represent the template used to generate the corresponding MySpine Screw Placement Guides fitting the patient's vertebral anatomy.

The MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides as well as their bone models are single-use and they can be provided in sterile or non-sterile version.

#### Indications for Use V.

MySpine S2-Alar/Alar-Iliac and MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides are intended to be used with any 510(k) cleared, legally marketed, pedicle screw system (for its approved indications for use) and its respective components for non-cervical open, posterior spinal fixation procedures intended for fusion. The SI trajectory of the MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guide is only intended to be used with M.U.S.T. SI Headless Screw System and its cleared indications for use. The MySpine S2-Alar/Alar-Iliac and MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides (hereinafter referred to as "MySpine guides") are intended to be used as anatomical perforating guides, specific to a patient's anatomy, to assist intraoperatively in the preparation of the screw trajectory in S1, S2 and in the Ilium. The guides are created using a surgical planning software which pre-operatively plans the positions of the components based upon radiological images of the patients' anatomical landmarks and the selected surgical equipment. The MySpine guides are intended for single use only.

Please see MySpine guides labelling for compatibility requirements between the MySpine guides and the 510(k) cleared pedicle screw system intended to be used.

#### VI. Comparison of Technological Characteristics

The MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides and the predicate MySpine S2-Alar/Alar-Iliac Pedicle Screw Placement Guides share the following characteristics:

- body region of use; ●
- manufacturing process; ●
- material; ●
- biocompatibility; ●
- device usage;
- sterility;
- shelf life; and ●
- packaging. ●

The MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides differs from the predicate device, MySpine S2-Alar/Alac Pedicle Screw Placement Guides, with regards to the following characteristics:

- design; and
- instruments compatibility. ●

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Discussion

The differences between the subject and predicate devices do not raise new questions of safety and effectiveness. Medacta International SA has not made any changes to the manufacturing process, material, device usage, biocompatibility, sterility, shelf life, and packaging of the subject devices respect to the predicate devices.

The comparison of technological characteristics and performance data provided within this submission. shows that there are no new risks associated with the subject devices design, and supports the substantial equivalence of the MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides to the identified predicate devices.

#### VII. Performance Data

Based on the risk analysis, testing activities were conducted to written protocols. The following validation and tests are being provided in support of the substantial equivalence determination:

# Non-Clinical Studies

- · Software validation
- · Cadaver testing;
- · Guide accuracy.

Biocompatibility data and sterilization studies submitted in support of the predicate devices were leveraged.

# Clinical Studies:

- No clinical studies were conducted. ●
#### Conclusion VIII.

The information provided above supports that the MySpine S2-SI Pedicle and Sacro-Iliac Screw Placement Guides are substantially equivalent to the identified predicate devices.