PASS LP SPINAL SYSTEM

K141398 · Medicrea International SA · NKB · Jan 9, 2015 · Orthopedic

Device Facts

• Record ID: K141398
• Device Name: PASS LP SPINAL SYSTEM
• Applicant: Medicrea International SA
• Product Code: NKB · Orthopedic
• Decision Date: Jan 9, 2015
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic, Pediatric

Intended Use

The PASS LP Spinal System is a pedicle screw fixation system intended for 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 (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (e.g., fracture or dislocation), deformity or curvature (e.g., scoliosis, and/or lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed previous fusion. Except for rod plates, when used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS LP Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally, the system is intended to treat pediatric patients diagnosed with the following conditions: spondylolisthesis/spondylolysis and fracture caused by tumor and/or trauma. The PASS LP Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

Device Story

PASS LP Spinal System is a pedicle screw fixation system for surgical stabilization of thoracic, lumbar, and sacral spine. Components include pedicle screws, hooks, sacral plates, iliac screws, clamps, rod plates, and crosslinks. Used by surgeons in clinical settings to immobilize spinal segments as an adjunct to fusion. System provides rigid locking of constructs to correct deformities or stabilize instabilities. Benefits include structural support for spinal fusion, aiding in treatment of degenerative conditions, trauma, and scoliosis. Device is implanted during surgery; output is the mechanical stabilization of the spine.

Clinical Evidence

Bench testing only. Dynamic Compression Bending Tests were performed following ASTM F1717 standard test methods for spinal implant constructs in a vertebrectomy model to demonstrate mechanical safety and performance equivalence to predicate devices.

Technological Characteristics

Constructs consist of pedicle screws, hooks, sacral plates, iliac screws, clamps, rod plates, and crosslinks. Materials: Titanium alloy (Ti-6Al-4V ELI, ASTM F136/ISO 5832-3) and Cobalt-chromium-molybdenum alloy (Co-Cr28Mo6, ASTM F1537/ISO 5832-12). Mechanical fixation via rigid locking of components. Designed for posterior approach.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization/stabilization as adjunct to fusion for degenerative disc disease, spondylolisthesis, trauma, deformity/curvature (scoliosis/lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed fusion. Pediatric indication: adjunct to fusion for adolescent idiopathic scoliosis (excluding rod plates), spondylolisthesis/spondylolysis, and fracture caused by tumor/trauma. Pediatric use limited to posterior approach. Must be used with autograft/allograft.

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

• CD Horizon Spinal System (K140449)
• PASS LP Spinal System (K123138)

Submission Summary (Full Text)

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol resembling an eagle or a stylized human figure, composed of three interconnected profiles facing to the right.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

January 9, 2015

Medicrea® International S.A. Mr. David Ryan Marketing and Product Development Director 14 Porte du Grand Lyon Neyron 01700 France

Re: K141398

Trade/Device Name: PASS LP Spinal System Regulation Number: 21 CFR 888.3070 Regulation Name: Pedicle screw spinal system Regulatory Class: Class III Product Code: NKB, OSH, MNI, MNH, KWP Dated: December 5, 2014 Received: December 8, 2014

Dear Mr. Ryan:

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

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# Page 2 – Mr. David Ryan

(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.

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 yours,

Lori A. Wiggins -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: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K141398

Device Name PASS LP SPINAL SYSTEM

#### Indications for Use (Describe)

The PASS LP Spinal System is a pedicle screw fixation system intended for immobilization 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 (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondy lolisthesis, tracture or dislocation), deformity or curvature (e.g., scoliosis, and/or lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed previous fusion.

Except for rod plates, when used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS LP Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally, the system is intended to treat pediatric patients diagnosed with the following conditions: spondylolisthesis/spondylolysis and fracture caused by tumor and/or trauma. The PASS LP Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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## 510(k) SUMMARY

### MEDICREA INTERNATIONAL S.A.'s PASS LP - Additional Components

## 1. DEVICE SUBMITTER MEDICREA® INTERNATIONAL S.A.

14 Porte Du Grand Lyon

01700 NEYRON- France Phone: [phone]

Fax: [phone]

Contact Person: David RYAN Marketing and Product Development Director [e-mail]

Date Prepared: 12/05/2014

# 2. DEVICE

Name of Device: PASS LP Spinal System

Common or Usual Name: Spinal Lumbar Fixation System

Classification Name:

- > orthosis, spinal pedicle fixation per MNI 888.3070
- > orthosis, spondylolisthesis spinal fixation per MNH 888.3070
- > appliance, fixation, spinal interlaminal per KWP 888.3050
- > pedicle screw spinal system, Adolescent Idiopathic Scoliosis per OSH 888.3070
- > orthosis, spinal pedicle fixation, For Degenerative Disc Disease per NKB 888.3070

Regulatory Class: III

Product Code: NKB, OSH, MNI, MNH, KWP

# 3. PREDICATE DEVICES

CD Horizon Spinal System (MEDTRONIC, K140449) [Primary Predicate] PASS LP Spinal System (MEDICREA INTERNATIONAL, K123138)

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### 4. DEVICE DESCRIPTION

The PASS LP Spinal System is designed to contribute to correction and surgical stabilization of the thoracic, lumbar and sacral spine.

The system consists of pedicle screws, hooks, sacral plates, iliac screws, clamps, rod plates and crosslink components. It can be used for single or multiple level fixations. Components are manufactured from titanium alloy (Ti-6Al-4V ELI) that conforms to ASTM F136 or cobaltchromium molybdenum alloy Co-Cr28Mo6 that conforms to ISO 5832-12 and ASTM F1537.

The purpose of this submission is to add components to the PASS LP implant range to treat Pars interarticularis fracture.

A subset of PASS LP Spinal System components may be used for posterior pedicle screw fixation in pediatrics cases. These constructs may be comprised of a variety of shapes and sizes of rods, hooks, sacral hooks, sacral plates, iliac screws, clamps, nuts and crosslink components. These components can be rigidly locked into a variety of configurations.

### 5. INDICATIONS FOR USE

The PASS LP Spinal System is a pedicle screw fixation system intended for 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 (defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (e.g., fracture or dislocation), deformity or curvature (e.g., scoliosis, and/or lordosis), tumor, spinal stenosis, pseudoarthrosis, or failed previous fusion.

Except for rod plates, when used for posterior non-cervical pedicle screw fixation in pediatric patients, the PASS LP Spinal System implants are indicated as an adjunct to fusion to treat adolescent idiopathic scoliosis. Additionally, the system is intended to treat pediatric patients diagnosed with the following conditions: spondylolisthesis/spondylolysis and fracture caused by tumor and/or trauma. The PASS LP Spinal System is intended to be used with autograft and/or allograft. Pediatric pedicle screw fixation is limited to a posterior approach.

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# 6. COMPARISON OF TECHNOLOGICAL CHARAGTERISTICS WITH THE PREDICATE DEVICE

The table below compares the features and characteristics of MEDICREA® INTERNATIONAL S.A. PASS LP Spinal System – Additional components to their predicate devices.

| Device | PASS LP -<br>Additional components | CD Horizon<br>Spinal System<br>(MEDTRONIC) | PASS LP<br>Spinal System<br>(MEDICREA<br>INTERNATIONAL) | PASS LP<br>Spinal System<br>(MEDICREA<br>INTERNATIONAL) |
|--------------------|--------------------------------------------------------|--------------------------------------------|-------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------|
| 510(k) number | K141398 | K140449 | K123138 | K123138 |
| Intended use | | | | |
| Thoracic | Yes | Yes | Yes | Yes |
| Lumbar | Yes | Yes | Yes | Yes |
| Posterior Approach | Yes | Yes | Yes | Yes |
| Design | | | | |
| Rod Diameters | Ø4mm | Ø3,5mm to<br>Ø6,35mm | Ø5.5 and Ø6 mm | Ø5.5 and Ø6 mm |
| Hooks | Yes<br>One size available<br>Left and Right<br>version | Yes<br>Several Options | Yes<br>Several Options | Yes<br>Several Options |
| Crosslink | Yes | Yes | Yes | Yes |
| Materials | | | | |
| | Ti-6Al-4V (ASTM<br>F136 & ISO<br>5832-3) | Titanium Alloy or<br>Stainless Steel | Ti-6Al-4V (ASTM<br>F136 & ISO<br>5832-3)<br>Or Co-Cr<br>28Mo6 alloy 1<br>(following the<br>ASTMF1537<br>and ISO 5832-3) | Ti-6Al-4V (ASTM<br>F136 & ISO<br>5832-3)<br>Or Co-Cr<br>28Mo6 alloy 1<br>(following the<br>ASTMF1537<br>and ISO 5832-3) |

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## 7. PERFORMANCE DATA

The following performance data were provided in support of the substantial equivalence determination.

To determine substantial equivalence of the PASS LP components to its predicate, Dynamic Compression Bending Tests, following the ASTM F1717 "Standard Test Methods for Spinal Implants Constructs in a Vertebrectomy Model" were carried out. Those tests demonstrated substantially equivalent performance of the components to its predicate.

# 8. CONCLUSION

MEDICREA® INTERNATIONAL S.A. PASS LP Spinal System - additional components are substantially equivalent to the already cleared PASS LP components (MEDICREA INTERNATIONAL, K123138) and the CD Horizon Spinal System (MEDTRONIC, K140449) in terms of intended use, materials used, sterilization, mechanical safety and performances.