Trifore(tm) Cervical Plating System

K171112 · Neurostructures, Inc. · KWQ · Jun 8, 2017 · Orthopedic

Device Facts

• Record ID: K171112
• Device Name: Trifore(tm) Cervical Plating System
• Applicant: Neurostructures, Inc.
• Product Code: KWQ · Orthopedic
• Decision Date: Jun 8, 2017
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3060
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Trifore™ Cervical Plating System is intended for anterior cervical fixation (C2-T1) for the following indications: degenerative disc disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion.

Device Story

Trifore™ Cervical Plating System is a spinal fixation device consisting of titanium alloy bone plates and screws. Plates feature preassembled locking pins to cover screw heads, preventing screw back-out. Used by surgeons in clinical settings for anterior cervical fixation (C2-T1). Implantation is facilitated by associated surgical instruments. Device provides mechanical stabilization of the cervical spine to support fusion and treat conditions like DDD, trauma, and deformities. Clinical benefit derived from restoring spinal stability and facilitating bone healing.

Clinical Evidence

Bench testing only. Testing included static axial compression bending, static torsion, and dynamic axial compression bending fatigue per ASTM F1717-14. Results demonstrate mechanical strength sufficient for intended use.

Technological Characteristics

Materials: Titanium alloy (ASTM F136). Components: Bone plates with preassembled locking pins and bone screws. Principle: Mechanical fixation via screw-plate construct. Sterilization: Not specified. Connectivity: None. Software: None.

Indications for Use

Indicated for patients requiring anterior cervical fixation (C2-T1) due to degenerative disc disease, spondylolisthesis, trauma (fracture/dislocation), spinal stenosis, spinal deformities (scoliosis, kyphosis, lordosis), tumor, pseudoarthrosis, or failed previous fusion.

Regulatory Classification

Identification

A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.

Predicate Devices

• Transom™ Cervical Plating System (K142060)
• Tempus™ Cervical Plating System (K120515)
• Tempus™ Cervical Plating System (K131374)
• CSLP System (K030866)

Submission Summary (Full Text)

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

NeuroStructures, Inc. % Mr. Kenneth C. Maxwell II Regulatory and Quality Specialist Empirical Testing Corp. 4628 Northpark Drive Colorado Springs, Colorado 80918 June 8, 2017

Re: K171112

Trade/Device Name: Trifore™ Cervical Plating System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal Intervertebral Body Fixation Orthosis Regulatory Class: Class II Product Code: KWO Dated: April 12, 2017 Received: April 14, 2017

Dear Mr. Maxwell:

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

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Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) 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/ResourcesforYou/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.

# Mark N. Melkerson -S

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<br>Food and Drug Administration | | Form Approved: OMB No. 0910-0120<br>Expiration Date: January 31, 2017<br>See PRA Statement on last page. |
|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|
| <b>Indications for Use</b> | | |
| 510(k) Number (if known) | K171112 | |
| Device Name | Trifore™ Cervical Plating System | |
| Indications for Use (Describe) | The Trifore™ Cervical Plating System is intended for anterior cervical fixation (C2-T1) for the following indications: degenerative disc disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion. | |
| Type of Use (Select one or both, as applicable) | <label><input checked="checked" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D)</label> <label><input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C)</label> | |
| PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON A SEPARATE PAGE IF NEEDED. | | |
| FOR FDA USE ONLY | | |
| Concurrence of Center for Devices and Radiological Health (CDRH) (Signature) | | |
| FORM FDA 3881 (9/13) | Page 1 of 2 | PSC Publishing Services [phone] EF |

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| Submitter's Name | NeuroStructures, Inc. |
|------------------------------|------------------------------------------------------------------------------------------------------|
| Submitter's Address | 16 Technology Drive, Suite 165<br>Irvine, CA 92618 |
| Company Contact Person | Kathleen Wong<br>[e-mail]<br>949.370.4497 |
| Contact Person | Kenneth C. Maxwell II<br>Empirical Testing Corp.<br>719.291.6874<br>[e-mail] |
| Date Summary was<br>Prepared | 12 April 2017 |
| Trade or Proprietary Name | Trifore™ Cervical Plating System |
| Common or Usual Name | Appliance, Fixation, Spinal Intervertebral Body |
| Classification | Class II per 21 CFR §888.3060 |
| Product Code | KWQ |
| Classification Panel | Division of Orthopedic Devices |

#### 510(K) SUMMARY

### DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION

The Trifore™ Cervical Plating System consists of a variety of bone plates and screws. Fixation is achieved by inserting bone screws through the openings in the vertebral bodies of the cervical spine. The Trifore™ Plates include locking pins that cover the heads of the bone screws to reduce the potential for screw back-out. The locking pins come preassembled to the plate. Associated instruments are available to facilitate the implantation of the device. The Trifore™ Cervical Plating System implant components are made from titanium alloy such as described by ASTM F136.

#### INDICATIONS FOR USE

The Trifore™ Cervical Plating System is intended for anterior cervical fixation (C2-T1) for the following indications: degenerative disc disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), spondylolisthesis, trauma (i.e., fracture or dislocation), spinal stenosis, deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), tumor, pseudoarthrosis, and failed previous fusion.

The indications for use for the Trifore™ Cervical Plating System are similar to that of the predicate devices listed in Table 5-1 Predicate Devices.

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## TECHNOLOGICAL CHARACTERISTICS

The subject and predicate devices have nearly identical technological characteristics and the minor differences do not raise any new issues of safety and effectiveness. Specifically the following characteristics are the same between the subject and predicates:

- Indications for Use
- Materials of manufacture ●
- Principle of operation ●

#### Table 5-1: Predicate Devices

| 510k Number | Trade or Proprietary or Model Name | Manufacturer | Predicate Type |
|------------------|------------------------------------|-----------------------|----------------|
| K142060 | Transom™ Cervical Plating System | NeuroStructures, Inc. | Primary |
| K120515, K131374 | Tempus™ Cervical Plating System | NeuroStructures, Inc. | Additional |
| K030866 | CSLP System | Synthes | Additional |

## PERFORMANCE DATA

The Trifore™ Cervical Plating System has been tested in the following test modes:

- Static axial compression bending per ASTM F1717-14 ●
- . Static torsion per ASTM F1717-14
- Dynamic axial compression bending fatigue per ASTM F1717-14 o

The results of this non-clinical testing show that the strength of the Trifore™ Cervical Plating System is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

## CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the Trifore™ Cervical Plating System is substantially equivalent to the predicate device.