Patriot Spinal Fixation System

K180324 · Valorus Spine · NKB · Apr 6, 2018 · Orthopedic

Device Facts

• Record ID: K180324
• Device Name: Patriot Spinal Fixation System
• Applicant: Valorus Spine
• Product Code: NKB · Orthopedic
• Decision Date: Apr 6, 2018
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3070
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Patriot Spinal Fixation System, when used in the non-cervical posterior spine (TI to S1), 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: degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), spinal stenosis, tumor, pseudoarthrosis, and failed previous fusion. In addition, when used placed between L5 and S1, the Patriot Spinal Fixation System is indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) in skeletally mature patients receiving fusion with autologous bone graft.

Device Story

Patriot Spinal Fixation System; posterior, non-cervical spinal fixation system. Comprises rods, screws, and crosslinks of various shapes/sizes. Provides temporary internal fixation and stabilization during bone graft healing; adjunct to fusion of thoracic, lumbar, and sacral spine. Used by surgeons in clinical/OR settings. Mechanical stabilization of spinal segments; facilitates fusion. Benefits patient by immobilizing unstable spinal segments to promote healing of acute/chronic deformities or instabilities.

Clinical Evidence

No clinical data. Bench testing only. Performed static and dynamic compression and static torsion testing per ASTM F1717 to demonstrate mechanical equivalence to predicate devices.

Technological Characteristics

Posterior spinal fixation system consisting of rods, screws, and crosslinks. Mechanical stabilization principle. Materials and design are consistent with standard pedicle screw systems. Testing performed per ASTM F1717 for static/dynamic compression and static torsion.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization/stabilization as an adjunct to fusion in the non-cervical posterior spine (T1-S1). Treats degenerative spondylolisthesis with neurologic impairment, fracture, dislocation, deformities (scoliosis, kyphosis, lordosis), spinal stenosis, tumor, pseudoarthrosis, and failed fusion. Also indicated for Grade 3-4 severe spondylolisthesis at L5-S1 when used with autologous bone graft.

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

• DePuy (Acromed), Titanium Moss Miami Spinal System (K955348)
• Alphatec Spine, Arsenal Spinal Fixation System (K161363)
• Nexxt Spine LLC, Inertia Pedicle Screw System (K101278)

Submission Summary (Full Text)

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Image /page/0/Picture/0 description: The image contains the logos of the Department of Health and Human Services and the Food and Drug Administration (FDA). The Department of Health and Human Services logo is on the left, and the FDA logo is on the right. The FDA logo is a blue square with the letters "FDA" in white. The words "U.S. Food & Drug Administration" are written in blue to the right of the square.

April 6, 2018

Valorus Spine % Mr. Nicholas M. Cordaro CEO Watershed Idea Foundry 1815 Aston Avenue, Suite 106 Carlsbad, California 92008

Re: K180324

Trade/Device Name: Patriot Spinal Fixation System Regulation Number: 21 CFR 888.3070 Regulation Name: Thoracolumbosacral pedicle screw system Regulatory Class: Class II Product Code: NKB Dated: February 2, 2018 Received: February 5, 2018

Dear Mr. Cordaro:

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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## Indications for Use

510(k) Number (if known)

#### K180324

Device Name Patriot Spinal Fixation System

#### Indications for Use (Describe)

The Patriot Spinal Fixation System, when used in the non-cervical posterior spine (TI to S1), 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: degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), spinal

In addition, when used placed between L5 and S1, the Patriot Spinal Fixation System is indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) in skeletally mature patients receiving fusion with autologous bone graft.

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

Prescription Use (Part 21 CFR 801 Subpart D)

stenosis, tumor, pseudoarthrosis, and failed previous fusion.

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

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FOR FDA USE ONLY CONTRA

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

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K180324 Page 1 of 3

# 510(k) Summary (K180324)

### DATE PREPARED

January 11, 2018

### MANUFACTURER AND 510(k) OWNER

Valorus Spine 822 Hartz Way, Suite 230, Danville CA 94526, USA Telephone: Fax: [phone] Official Contact: Leah Fero, VP Engineering

## REPRESENTATIVE/CONSULTANT

Nicholas M. Cordaro Watershed Idea Foundry Telephone: Email: [e-mail]

### PROPRIETARY NAME OF SUBJECT DEVICE

Patriot Spinal Fixation System

### COMMON NAME

Pedicle Screw Spinal System

## DEVICE CLASSIFICATION

Thoracolumbosacral Pedicle Screw System (Classification Regulations: 21 CFR 888.3070, Product Code: NKB, Class: II)

### PREMARKET REVIEW

ODE/DOD/ Posterior Spine Devices Branch (PSDB) Orthopedic Panel

## INDICATIONS FOR USE

The Patriot Spinal Fixation System, when used in the non-cervical posterior spine (T1 to S1), 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: degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, deformities or curvatures (i.e., scoliosis, and/or lordosis), spinal stenosis, tumor, pseudarthrosis, and failed previous fusion.

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In addition, when used placed between L5 and S1, Patriot Spinal Fixation System is indicated for the treatment of severe spondylolisthesis (Grade 3 and 4) in skeletally mature patients receiving fusion with autologous bone graft.

# DEVICE DESCRIPTION

The Patriot Spinal Fixation System is a posterior, non-cervical, spinal fixation system consisting of a variety of shapes and sizes of rods, screws, and crosslinks, to provide temporary internal fixation and stabilization during bone graft healing as an adjunct to fusion of the thoracic, lumbar and sacral spine.

# PREDICATE DEVICE IDENTIFICATION

The Patriot Spinal Fixation System is substantially equivalent to the following predicates:

| 510(k) Number | Predicate Device Name / Manufacturer | Primary Predicate |
|---------------|-----------------------------------------------------|-------------------|
| K955348 | DePuy (Acromed), Titanium Moss Miami Spinal System, | |
| K161363 | Alphatec Spine, Arsenal Spinal Fixation System | ✓ |
| K101278 | Nexxt Spine LLC, Inertia Pedicle Screw System | |

# SUMMARY OF NON-CLINICAL TESTING

No FDA performance standards have been established for the Patriot Spinal Fixation System. The following tests were performed to demonstrate safety based on current industry standards:

- Static and dynamic compression (per ASTM F1717)
- . Static torsion (per ASTM F1717)

The results of these tests indication that the Patriot Spinal Fixation System is substantially equivalent to the predicate devices.

## EQUIVALENCE TO PREDICATE DEVICES

The Valorus Patriot Spinal Fixation System is similar to the cited predicate device in regards to components, device description, intended use/indications for use, technological characteristics (operating principle, design, materials, sterility, manufacturing, etc.) and performance (mechanical).

All implants are used to treat the same conditions, have essentially the same precautions and contraindications for use, and they represent a basic design concept in terms of safety and effectiveness, and differ only in design details and not functionality.

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# CONCLUSION

The Patriot Spinal Fixation System is considered substantially equivalent to the predicate devices based on the testing performed, the identical indications for use, and similar technological characteristics. Based on the testing performed, including static and dynamic compression as well as static torsion (per ASTM F1717), it can be concluded that that the subject device is substantially equivalent when compared to the predicate devices.