M.U.S.T. MINI Posterior Cervical Screws System Extension

K220570 · Medacta International S.A. · NKG · Apr 26, 2022 · Orthopedic

Device Facts

• Record ID: K220570
• Device Name: M.U.S.T. MINI Posterior Cervical Screws System Extension
• Applicant: Medacta International S.A.
• Product Code: NKG · Orthopedic
• Decision Date: Apr 26, 2022
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3075
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The M.U.S.T. Mini posterior cervical screw system is intended to provide immobilization of spinal segments as an adjunct to fusion, in skeletally mature patient, for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fraumatic dislocations; instability or deformity; failed previous (e.g., pseudarthrosis); tumors involving the cervical spine; degenerative disease, including intractable radior myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability. The M.U.S.T. Mini posterior cervical screw system 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. In order to achieve additional levels of fixation, the M.U.S.T. Mini posterior cervical screw system may be connected to the M.U.S.T. system rods with the M.U.S.T. Mini rod connectors. Transition rods with differing diameters may also be used to connect the M.U.S.T. Mini posterior cervical screw system to the M.U.S.T. system. Refer to the M.U.S.T. system package insert for a list of the M.U.S.T. indications of use. When used with the occipital plate the M.U.S.T. Mini posterior cervical screw system is also intended to provide immobilization and stabilization for the occipito-cervico-thoracic junction (occiput - T3) in treatment of the instabilities mentioned above, including occipitocervical dislocation.

Device Story

System extension for M.U.S.T. MINI Posterior Cervical Screws; includes polyaxial screws (4-6mm diameter, 20-50mm length) and top-load cross connectors. Used by surgeons in clinical settings to provide spinal immobilization/stabilization via posterior cervical/thoracic fixation. Implants connect to M.U.S.T. system rods or transition rods to achieve multi-level fixation. Provides structural support to spinal column; facilitates fusion or temporary stabilization in tumor cases. Output is physical stabilization of spinal segments.

Clinical Evidence

No clinical data. Evidence based on bench testing: design validation, geometrical comparison, and mechanical testing (dynamic axial compression bending per ASTM F2706 and ASTM F1717). Biocompatibility and pyrogenicity (LAL/USP <151>) testing performed.

Technological Characteristics

Materials: Ti6Al4V ELI (ISO 5832-3, ASTM F136-13). Components: Polyaxial screws (solid/cannulated, 4-6mm diameter, 20-50mm length) and top-load cross connectors. Mechanical fixation via screw-rod construct. Non-active, mechanical implant system.

Indications for Use

Indicated for skeletally mature patients requiring spinal immobilization/stabilization (C1-T3) for traumatic fractures/dislocations, instability/deformity, failed fusions, tumors, or degenerative disease (radiculopathy, myelopathy, discogenic pain, facet instability). Also indicated for temporary stabilization in advanced tumor patients where fusion is not feasible.

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

• M.U.S.T. MINI Posterior Cervical Screws System (K171369)
• M.U.S.T. MINI Posterior Cervical Screws System Extension (K200130)
• BRIDALVEIL Occipital Cervical Thoracic System (K171250)

Reference Devices

• M.U.S.T. Pedicle Screw System (K121115)
• M.U.S.T. Pedicle Screw System Extension Straight Connectors and Additional Screws (K171170)

Submission Summary (Full Text)

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April 26, 2022

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

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

Re: K220570

Trade/Device Name: M.U.S.T. MINI Posterior Cervical Screws System Extension Regulation Number: 21 CFR 888.3075 Regulation Name: Posterior Cervical Screw System Regulatory Class: Class II Product Code: NKG, KWP Dated: February 25, 2022 Received: February 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

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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 (OS) 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)

K220570

### Device Name

M.U.S.T. MINI Posterior Cervical Screws System Extension

### Indications for Use (Describe)

The M.U.S.T. Mini posterior cervical screw system is intended to provide immobilization of spinal segments as an adjunct to fusion, in skeletally mature patient, for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fraumatic dislocations; instability or deformity; failed previous (e.g., pseudarthrosis); tumors involving the cervical spine; degenerative disease, including intractable radior myelopathy, neck and/or arm pain of discogenic origin as confirmed by radiographic studies, and degenerative disease of the facets with instability.

The M.U.S.T. Mini posterior cervical screw system 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.

In order to achieve additional levels of fixation, the M.U.S.T. Mini posterior cervical screw system may be connected to the M.U.S.T. system rods with the M.U.S.T. Mini rod connectors. Transition rods with differing diameters may also be used to connect the M.U.S.T. Mini posterior cervical screw system to the M.U.S.T. system. Refer to the M.U.S.T. system package insert for a list of the M.U.S.T. indications of use.

When used with the occipital plate the M.U.S.T. Mini posterior cervical screw system is also intended to provide immobilization and stabilization for the occipito-cervico-thoracic junction (occiput - T3) in treatment of the instabilities mentioned above, including occipitocervical dislocation.

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

| <span style="font-size:10pt"><input checked="" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D)</span> | <span style="font-size:10pt"><input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
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# 510(k) Summary

#### I. Submitter

Medacta International SA Strada Regina 6874 Castel San Pietro (CH) Switzerland Phone [phone] Fax [phone]

Contact Person: Stefano Baj, Regulatory and Compliance Director, Medacta International SA Applicant Correspondent: Chris Lussier, Senior Director of Quality and Regulatory, Medacta USA Date Prepared: February 25, 2022 Date revised: April 20, 2022

#### II. Device

| Device Proprietary Name: | M.U.S.T. MINI Posterior Cervical Screws System Extension |
|--------------------------|----------------------------------------------------------|
| Common or Usual Name: | Orthosis Cervical Pedicle Screw Spinal Fixation |
| Classification Name: | Posterior Cervical Screw System |
| Primary Product Code | NKG |
| Secondary Product Code: | KWP |
| Regulation Number: | 21 CFR 888.3075, 21 CFR 888.3050 |
| Device Classification | II |

#### III. Predicate Device

Substantial equivalence is claimed to the following predicate devices:

Primary predicate device:

- > M.U.S.T. MINI Posterior Cervical Screws System, K171369, Medacta International SA
Additional predicate devices:

- > M.U.S.T. MINI Posterior Cervical Screws System Extension, K200130, Medacta International SA
- BRIDALVEIL Occipital Cervical Thoracic System, K171250, Astura Medical A

Reference devices:

- > M.U.S.T. Pedicle Screw System, Medacta International, K121115, Medacta International SA
- > M.U.S.T. Pedicle Screw System Extension Straight Connectors and Additional Screws, Medacta International, K171170, Medacta International SA

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#### IV. Device Description

The subject M.U.S.T. MINI Posterior Cervical Screws System Extension is a Medacta M.U.S.T. MINI Posterior Cervical Screws System line extension. Specifically, the current submission includes the following implants:

- M.U.S.T. MINI Polyaxial screw dual lead solid and cannulated with diameters ranging from 4 to . 6mm and lengths from 20 to 50mm;
- M.U.S.T. MINI cross connector top load, four sizes. ●

The subject devices are made of Ti6A14V ELI according to ISO 5832-3 Implants for surgery -- Metallic materials -- Part 3: Wrought titanium 6-aluminium 4-vanadium alloy and ASTM F136-13 Standard Specification for Wrought Titanium-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications.

#### V. Indications for Use

The M.U.S.T. Mini posterior cervical screw system is intended to provide immobilization and stabilization of spinal segments as an adjunct to fusion, in skeletally mature patient, for the following acute and chronic instabilities of the cervical spine (C1 to C7) and the thoracic spine from T1-T3: traumatic spinal fractures, and/or traumatic dislocations; instability or deformity; failed previous fusions (e.g., pseudarthrosis); tumors involving the cervical 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.

The M.U.S.T. Mini posterior cervical screw system 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.

In order to achieve additional levels of fixation, the M.U.S.T. Mini posterior cervical screw system may be connected to the M.U.S.T. system rods with the M.U.S.T. Mini rod connectors. Transition rods with differing diameters may also be used to connect the M.U.S.T. Mini posterior cervical screw system to the M.U.S.T. system. Refer to the M.U.S.T. system package insert for a list of the M.U.S.T. indications of use.

When used with the occipital plate the M.U.S.T. Mini posterior cervical screw system is also intended to provide immobilization and stabilization for the occipito-cervico-thoracic junction (occiput - T3) in treatment of the instabilities mentioned above, including occipitocervical dislocation.

#### VI. Comparison of Technological Characteristics

The subject devices are substantially equivalent to the predicate (K171369 and for the screws also K200130 and K171250) with regards to the following characteristics:

- connectors fixation method; .

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- lengths: ●
- . materials:
- biocompatibility; ●
- device usage;
- . sterility;
- shelf-life; and
- packaging.

The subject implants differ from the predicate devices (K171369 and for the screws also K200130 and K171250) as follows:

- design; and
- diameters. ●

## Discussion

Medacta International SA has not made any change to the indications for use, general design and shape, fixation, device usage, biocompatibility, sterility, shelf life, and packaging of the subject devices respect to the predicate devices.

Based on the comparison of technological characteristics and performance data provided within this submission, the data supports the substantial equivalence of the M.U.S.T. MINI Posterior Cervical Screws System Extension implants to the identified predicate devices.

#### VII. Performance Data

Based on the risk analysis, performance testing was conducted to written protocols. The following tests and rationales are provided in support of the substantial equivalence determination:

## Non-Clinical Studies

- . DESIGN VALIDATION
- 0 MUST MINI Cross connectors top loading line extension Design Validation Report
- PERFORMANCE TESTING
- MUST MINI Poly-axial screws line extension Geometrical comparison rationale O
- Dynamic axial compression bending on Occipital-Cervical bilateral construct according to O ASTM F2706
- Dynamic compression bending on cervical bilateral construct according to ASTM F1717 O
- PYROGENICITY ●
- Bacterial endotoxin test (LAL test) according to European Pharmacopoeia §2.6.14 (which is о equivalent to USP chapter <85>)
- Pyrogen test according to USP chapter <151> for pyrogenicity determination o
- The subject devices are not labeled as non-pyrogenic or pyrogen free. o
- BIOCOMPATIBILITY evaluation

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- SHELF-LIFE evaluation .
## Clinical Studies:

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

The information provided above supports that the M.U.S.T. MINI Posterior Cervical Screws System Extension implants are substantially equivalent to the predicate devices.