Anteralign LS Spinal System with Titan nanoLOCK Surface Technology MAZORX Stealth(TM) Edition
K222383 · Medtronic Sofamor Danek USA, Inc. · OLO · Sep 29, 2022 · Neurology
Device Facts
| Record ID | K222383 |
| Device Name | Anteralign LS Spinal System with Titan nanoLOCK Surface Technology MAZORX Stealth(TM) Edition |
| Applicant | Medtronic Sofamor Danek USA, Inc. |
| Product Code | OLO · Neurology |
| Decision Date | Sep 29, 2022 |
| Decision | SESE |
| Submission Type | Special |
| Regulation | 21 CFR 882.4560 |
| Device Class | Class 2 |
| Attributes | Therapeutic |
Intended Use
Medtronic Surgical Instruments are intended to be used during preparation and placement of Medtronic implants during spinal surgery to assist in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Surgical Instruments are specifically designed for use with the Mazor X Stealth™ Edition, which is indicated for medical conditions in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy. Medtronic Surgical Instruments can be navigated or nonnavigated manual instruments that may or may not be guided through the Mazor X Stealth™ Edition Arm Guide. Medtronic surgical drills shall only be used through the Mazor X Stealth™ Edition arm guides, Medtronic cannulas, and Medtronic drill guides. Some of the Medtronic Surgical Instruments are also compatible with the IPC™ Powerease™ System or AO* style quick connect drilling motors. An instrument may incorporate a measuring function which has uses as described on the label and the instrument. Medtronic cannulas may or may not be used with Midas Rex [ 2 attachments and tools.
Device Story
Anteralign™ LS Navigated Reusable Surgical Instruments are high-grade stainless steel manual tools for spinal surgery; used for preparation and implant placement. Instruments integrate with NavLock trackers and sterile spheres to enable tracking by the Mazor X™ Stealth™ Edition computer-assisted surgery system. System inputs include CT/MR images, fluoroscopy, or digitized anatomical landmarks; system processes these to provide real-time navigation of instruments relative to patient anatomy. Used in OR by surgeons; output is visual guidance on system display. Navigation assists in precise anatomical localization; potentially improves surgical accuracy and patient outcomes. Instruments may be used with Mazor X™ arm guides, IPC™ Powerease™ motors, or Midas Rex™ attachments.
Clinical Evidence
Bench testing only. Performance data leveraged from predicate device included navigation accuracy analysis, anatomical simulated use, and navigated simulated use to confirm functionality under expected conditions.
Technological Characteristics
High-grade stainless steel manual surgical instruments. Features Titan nanoLOCK™ surface technology. Compatible with NavLock trackers and sterile spheres for optical/computer-assisted tracking. Compatible with Mazor X™ Stealth™ Edition arm guides, IPC™ Powerease™ systems, and AO* style motors. Sterilization method identical to predicate.
Indications for Use
Indicated for patients undergoing spinal surgery where stereotactic navigation is appropriate, specifically for preparation and placement of implants in open or minimally invasive procedures requiring reference to rigid anatomical structures (skull, long bone, vertebra) via CT, MR, fluoroscopy, or digitized landmarks.
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
- Anteralign™ TL Spinal System with Titan nanoLOCK™ Surface Technology Navigated Instruments Compatible with MAZOR X™ system (Stealth™ Edition) (K214011)
Reference Devices
- Anteralign Interbody System (K221180)
- StealthStation™ System
Related Devices
- K211441 — Navigated Anterolateral Disc Prep Instruments · Medtronic Sofamor Danek USA, Inc. · Jun 9, 2021
- K221180 — Anteralign(TM) Spinal System with Titan NanoLOCK Surface Technology Navigated Instruments · Medtronic Sofamor Danek USA, Inc. · May 25, 2022
- K203291 — CD Horizon Spinal System Instruments · Medtronic Sofamor Danek USA, Inc. · Dec 8, 2020
- K182731 — Corelink Navigation Instruments · Corelink, LLC · Dec 13, 2019
- K172517 — SeaSpine Navigation System · SeaSpine Orthopedics Corporation · May 11, 2018
Submission Summary (Full Text)
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains 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 blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
September 29, 2022
Medtronic Sofamor Danek USa, Inc. Elizabeth Hamilton Sr. Regulatory Affairs Specialist 1800 Pyramid Place Memphis, Tennessee 38132
Re: K222383
Trade/Device Name: Anteralign™ LS Spinal System with Titan nanoLOCK™ Surface Technology MAZORX Stealth(TM) Edition Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: August 30, 2022 Received: September 1, 2022
Dear Elizabeth Hamilton:
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.
{1}------------------------------------------------
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) 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 medical devices and radiation-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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
For: Shumaya Ali, M.P.H. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
# Indications for Use
510(k) Number (if known) K222383
#### Device Name
Anteralign(TM) LS Spinal System with Titan nanoLOCK(TM) Surface Technology Navigated Instruments with Mazor X(TM) (Stealth Edition)
## Indications for Use (Describe)
Medtronic Surgical Instruments are intended to be used during preparation and placement of Medtronic implants during spinal surgery to assist in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Surgical Instruments are specifically designed for use with the Mazor X Stealth™ Edition, which is indicated for medical conditions in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy. Medtronic Surgical Instruments can be navigated or nonnavigated manual instruments that may or may not be guided through the Mazor X Stealth™ Edition Arm Guide. Medtronic surgical drills shall only be used through the Mazor X Stealth™ Edition arm guides, Medtronic cannulas, and Medtronic drill guides. Some of the Medtronic Surgical Instruments are also compatible with the IPC™ Powerease™ System or AO* style quick connect drilling motors. An instrument may incorporate a measuring function which has uses as described on the label and the instrument. Medtronic cannulas may or may not be used with Midas Rex [ 2 attachments and tools.
| 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)
## CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
# K222383 - 510(k) SUMMARY MEDTRONIC Sofamor Danek 23 September 2022
| Submitter: | Medtronic Sofamor Danek, USA Inc.<br>1800 Pyramid Place<br>Memphis, Tennessee 38132<br>Telephone: (901)399-3395<br>Fax: (901) 346-9738 |
|---------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Primary Contact | Elizabeth Hamilton<br>Sr. Regulatory Affairs Specialist<br>Email : elizabeth.c.hamilton@medtronic.com |
| Alternate Contact: | Raphael McInnis<br>Sr. Regulatory Affairs Manager<br>Email : raphael.mcinniss@medtronic.com |
| Date Prepared: | 23 September 2022 |
| Name of Device | Anteralign™ LS Spinal System with Titan nanoLOCK™ Surface<br>Technology Navigated Instruments with MAZOR X™ (Stealth™<br>Edition) |
| Common Name | Navigated Instruments |
| Classification Name | Stereotaxic Instruments (21 CFR 882.4560) |
| Regulatory Class | Class II |
| Product Code | OLO |
| Predicate Devices | Primary Predicate -Anteralign™ TL Spinal System with Titan<br>nanoLOCK™ Surface Technology Navigated Instruments Compatible<br>with MAZOR X™ system (Stealth™ Edition) (K214011, S.E.<br>02/09/2022) |
{4}------------------------------------------------
## Description of Device
The Anteralign™ LS Navigated Reusable Surgical Instruments are spine preparation instruments made of high-grade stainless steel. The subject navigated instruments consist of existing navigated trials and a navigated interbody inserter, which were recently cleared in K221180, S.E. 5/25/22 for use in Anteralign Interbody System procedures where the use of stereotaxic surgery may be appropriate with the StealthStation™ System. Per this 510(k) submission, Medtronic is seeking clearance of the navigated instruments to also be compatible with the MAZOR X™ Stealth Edition. The instruments are compatible with NavLock trackers and Medtronic single -use sterile spheres to allow the Medtronic computer-assisted surgery system, such as the Stealth Station System and MAZOR X™ System (Stealth™ Edition), to track the instruments in the surgical field.
## Indications for Use
## Medtronic Surgical Instruments for Use with MAZOR X™ Stealth™Edition
Medtronic Surgical Instruments are intended to be used during preparation and placement of Medtronic implants during spinal surgery to assist in precisely locating anatomical structures in either open, or minimally invasive, procedures. Medtronic Surgical Instruments are specifically designed for use with the Mazor X™ Stealth™ Edition, which is indicated for medical conditions in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra can be identified relative to a CT or MR-based model, fluoroscopy images, or digitized landmarks of the anatomy. Medtronic Surgical Instruments can be navigated or non-navigated manual instruments that may or may not be guided through the Mazor X™ Stealth™ Edition Arm Guide. Medtronic surgical drills shall only be used through the Mazor X™ Stealth™ Edition arm guides, Medtronic cannulas, and Medtronic drill guides. Some of the Medtronic Surgical Instruments are also compatible with the IPC™ Powerease™ System or AO* style quick connect drilling motors. An instrument may incorporate a measuring function which has uses as described on the instrument. Medtronic cannulas may or may not be used with Midas Rex™ attachments and tools.
{5}------------------------------------------------
## Comparison of Technological Characteristics with Predicate Devices
The subject Anteralign™ LS Spinal System with Titan nanoLOCK" Surface Technology Navigated Instruments have an identical intended use, fundamental scientific technology, sterilization method, materials, and compatibilities with StealthStation™ System as the recently cleared predicate devices listed above. The subject devices are seeking compatibility with MAZOR X™ system, which is identical to the Primary Predicate's Indications for Use.
Performance Data Previous testing completed on the predicate device was leveraged for the subject devices. The subject instruments do not represent a new worst-case and the testing previously performed for the predicate devices is deemed applicable for the subject devices as there are no changes to the methods in which these instruments are used within the procedure. The following table summarizes the performance testing that was rationalized:
| Test | Description |
|------------------------------|----------------------------------------------------------------------------|
| Navigation Accuracy Analysis | Confirmed navigated instrument accuracy |
| Anatomical Simulated Use | Confirmed instrument functionality under<br>expected use conditions |
| Navigated Simulated Use | Confirmed navigation system functionality<br>under expected use conditions |
## Conclusion
Based on the information contained in this submission, Medtronic believes that the subject instruments are substantially equivalent to the predicate device.