Edge Upper Cervical System

K221307 · Spinal Simplicity, LLC · NKG · Jul 10, 2023 · Orthopedic

Device Facts

• Record ID: K221307
• Device Name: Edge Upper Cervical System
• Applicant: Spinal Simplicity, LLC
• Product Code: NKG · Orthopedic
• Decision Date: Jul 10, 2023
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3075
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Edge upper cervical system is intended to provide immobilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine (T1 to T3): Traumatic spinal fractures and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical/thoracic spine; degenerative disease, including intractable radiculopathy and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The Edge UCS is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion. The Edge UCS is intended for use only with the Innosys Anax™ OCT Spinal System.

Device Story

Edge Upper Cervical System (UCS) provides posterior spinal fixation; device clamps onto C1 posterior arch; connects to Innosys Anax OCT Spinal System via polyaxial rods to form posterior cervical construct. Used in surgical settings by surgeons; provides immobilization/stabilization of spinal segments. Additively manufactured titanium alloy clamp features fixation jaws and rod-receiving joints; accommodates bone graft placement. Benefits patients by stabilizing spinal column in presence of fractures, tumors, or degenerative disease. Output is mechanical stabilization of spinal segments; assists surgeon in achieving fusion or restoring spinal integrity.

Clinical Evidence

Bench testing only. Performance validated via ASTM F1717 (static/dynamic axial compression and torsion), ASTM F1798 (static axial/torsion grip), and custom pull-off testing. Bacterial endotoxin testing performed for sterile packaging. No clinical data provided.

Technological Characteristics

Additively manufactured titanium alloy (Ti6Al4V ELI). System comprises C1 clamp with two fixation jaws and inferior jaw base, plus two receiving joints for polyaxial rods. Three implant sizes available. Mechanical fixation principle; non-powered. Sterilized for clinical use.

Indications for Use

Indicated for patients with acute/chronic cervical (C1-C7) and thoracic (T1-T3) spine instabilities requiring immobilization as an adjunct to fusion, including traumatic fractures/dislocations, deformity, pseudarthrosis, tumors, and degenerative disc/facet disease. Also indicated for spinal column integrity restoration in patients with advanced cervical tumors where fusion is not achievable due to limited life expectancy.

Regulatory Classification

Identification

Posterior cervical screw systems are comprised of multiple, interconnecting components, made from a variety of materials that allow an implant system to be built from the occiput to the upper thoracic spine to fit the patient's anatomical and physiological requirements, as determined by preoperative cross-sectional imaging. Such a spinal assembly consists of a combination of bone anchors via screws (i.e., occipital screws, cervical lateral mass screws, cervical pedicle screws, C2 pars screws, C2 translaminar screws, C2 transarticular screws), longitudinal members (e.g., plates, rods, including dual diameter rods, plate/rod combinations), transverse or cross connectors, interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors), and closure mechanisms (e.g., set screws, nuts). Posterior cervical screw systems are rigidly fixed devices that do not contain dynamic features, including but not limited to: non-uniform longitudinal elements or features that allow more motion or flexibility compared to rigid systems.Posterior cervical screw systems are intended to provide immobilization and stabilization of spinal segments in patients as an adjunct to fusion for acute and chronic instabilities of the cervical spine and/or craniocervical junction and/or cervicothoracic junction such as: (1) Traumatic spinal fractures and/or traumatic dislocations; (2) deformities; (3) instabilities; (4) failed previous fusions (e.g., pseudarthrosis); (5) tumors; (6) inflammatory disorders; (7) spinal degeneration, including neck and/or arm pain of discogenic origin as confirmed by imaging studies (radiographs, CT, MRI); (8) degeneration of the facets with instability; and (9) reconstruction following decompression to treat radiculopathy and/or myelopathy. These systems are also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion.

Special Controls

*Classification.* Class II (special controls). The special controls for posterior cervical screw systems are:(1) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use. (2) Nonclinical performance testing must demonstrate the mechanical function and durability of the implant. (3) Device components must be demonstrated to be biocompatible. (4) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments. (5) Labeling must include the following: (i) A clear description of the technological features of the device including identification of device materials and the principles of device operation; (ii) Intended use and indications for use including levels of fixation; (iii) Device specific warnings, precautions, and contraindications that include the following statements: (A) “Precaution: Preoperative planning prior to implantation of posterior cervical screw systems should include review of cross-sectional imaging studies ( *e.g.,* CT and/or MRI) to evaluate the patient's cervical anatomy including the transverse foramen, neurologic structures, and the course of the vertebral arteries. If any findings would compromise the placement of these screws, other surgical methods should be considered. In addition, use of intraoperative imaging should be considered to guide and/or verify device placement, as necessary.”(B) “Precaution: Use of posterior cervical pedicle screw fixation at the C3 through C6 spinal levels requires careful consideration and planning beyond that required for lateral mass screws placed at these spinal levels, given the proximity of the vertebral arteries and neurologic structures in relation to the cervical pedicles at these levels.” (iv) Identification of magnetic resonance (MR) compatibility status; (v) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user, and; (vi) Detailed instructions of each surgical step, including device removal.

Predicate Devices

• neon3™ universal OCT by ulrich GmbH & Co. KG (K161032)

Reference Devices

• Depuy Synthes Symphony OCT System (K192646)
• Medtronic Vertex Select (K123906)

Submission Summary (Full Text)

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July 10, 2023

Spinal Simplicity LLC Mr. Adam Rogers Vice President of Regulatory and Engineering 6363 College Boulevard, Suite 320 Overland Park, Kansas 66211

Re: K221307

Trade/Device Name: Edge Upper Cervical System Regulation Number: 21 CFR 888.3075 Regulation Name: Posterior cervical screw system Regulatory Class: Class II Product Code: NKG, KWP Dated: June 5, 2023 Received: June 6, 2023

Dear Mr. Rogers:

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

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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 ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

Ronald P. Jean -S

for 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) K221307

#### Device Name

Edge Upper Cervical System (UCS)

#### Indications for Use (Describe)

The Edge upper cervical system is intended to provide immobilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine (T1 to T3):

· Traumatic spinal fractures and/or traumatic dislocations;

- · instability or deformity:
- · failed previous fusions (e.g., pseudarthrosis);
- · tumors involving the cervical/thoracic spine;

· degenerative disease, including intractable radiculopathy and/or arm pain of discogenic origin as confirmed by radiographic studies, and

· degenerative disease of the facets with instability.

The Edge UCS is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion. The Edge UCS is intended for use only with the Innosys Anax™ OCT Spinal System.

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

| Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-size: 20px;">☑</span> |
|----------------------------------------------|-----------------------------------------|
| Over-The-Counter Use (21 CFR 801 Subpart C) | ☐ |

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# 510(k)Summary

#### Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared:

Spinal Simplicity LLC 6363 College Blvd Suite 320 Overland Park, KS 66211 Phone: [phone] Facsimile: [phone]

Contact Person: Adam Rogers

Date Prepared: October 24, 2022

### Name of Device:

Edge Upper Cervical System

### Common / Classification Name:

Posterior Cervical Screw System, 21 CFR 888.3075, Class II / Appliance, Fixation, Spinal Interlaminal, 21 CFR 888.3050, Class II Product codes: NKG/KWP

# Predicate Devices:

neon3™ universal OCT by ulrich GmbH & Co. KG (K161032) - Primary Predicate Depuy Synthes Symphony OCT System (K192646) – Reference Device Medtronic Vertex Select (K123906) - Reference Device

# Intended Use / Indications for Use:

The Edge upper cervical system is intended to provide immobilization and stabilization of spinal segments as an adjunct to fusion for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine (T1 to T3):

- Traumatic spinal fractures and/or traumatic dislocations; ●
- instability or deformity; ●
- failed previous fusions (e.g., pseudarthrosis); .
- tumors involving the cervical/thoracic spine: ●
- degenerative disease, including intractable radiculopathy and/or myelopathy, neck ● and/or arm pain of discogenic origin as confirmed by radiographic studies, and
- . degenerative disease of the facets with instability.

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The Edge UCS is also intended to restore the integrity of the spinal column even in the absence of fusion for a limited time period in patients with advanced stage tumors involving the cervical spine in whom life expectancy is of insufficient duration to permit achievement of fusion. The Edge UCS is intended for use only with the Innosys Anax OCT Spinal System.

#### Technological Characteristics:

The Edge UCS consists of a main body that clamps on to the posterior arch of C1 to provide fixation and stability. The Edge UCS is then connected to the Innosys Anax OCT instrumentation using polyaxial rods to form a posterior cervical construct, similar to that of the predicate devices. The Edge device is an additively manufactured clamp composed of two fixation jaws superior to the C1 posterior arch, an inferior jaw base, and two receiving joints for polyaxial rods. The Edge UCS accommodates varying patient anatomy by providing three implant sizes. The Edge UCS is additively manufactured from titanium alloy Ti6Al4V ELI and is designed with areas for bone graft to be placed on the medial and lateral bone contacting regions of the device.

### Performance Data:

Test data and/or engineering analyses have been provided to describe the performance of the Edge UCS in the following test modalities:

- ASTM F1717 Static Axial Compression ●
- ASTM F1717 Static Torsion
- ASTM F1717 Dynamic Axial Compression
- ASTM F1717 Dynamic Torsion ●
- ASTM F1798 Static Axial Grip and Torsion Grip ●
- Custom Sawbones Pull Off Test ●

The data demonstrates that the subject Edge UCS device presents sufficient mechanical performance to support its intended use.

Bacterial endotoxin testing will be performed on all batches of sterile packed devices.

#### Substantial Equivalence:

The Spinal Simplicity Edge UCS is as safe and effective as the identified predicate device. The Edge device has the same intended use, indications for use, and similar technological characteristics and principles of operation as its predicate device. Differences between the subject and predicate devices are minor and do not raise any new issues of safety or effectiveness.