BridalVeil Navigated Instruments

K182982 · Astura Medical · OLO · Jan 4, 2019 · Neurology

Device Facts

• Record ID: K182982
• Device Name: BridalVeil Navigated Instruments
• Applicant: Astura Medical
• Product Code: OLO · Neurology
• Decision Date: Jan 4, 2019
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 882.4560
• Device Class: Class 2

Intended Use

The BRIDALVEIL NAVIGATED INSTRUMENTS are intended to be used in the preparation and placement of BRIDALVEIL screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic StealthStation® System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra, can be identified relative to a CT or MR based model, fluoroscopy images, or digitized landmarks of the anatomy.

Device Story

BridalVeil Navigated Instruments consist of non-sterile, reusable manual surgical tools, including taps and drivers; used for preparation and placement of spinal screws. Instruments feature a 'Navlock' mechanism for integration with the Medtronic StealthStation® System. System tracks instrument position relative to patient anatomy (vertebra) using CT/MR models, fluoroscopy, or digitized landmarks. Operated by surgeons in OR settings; provides real-time navigation to assist in precise anatomical localization during open or minimally invasive spinal procedures. Benefits include enhanced surgical accuracy and guidance during screw placement.

Clinical Evidence

No clinical studies were performed. Substantial equivalence is supported by non-clinical bench testing, including dimensional analysis and anatomical simulated use testing to verify navigation accuracy.

Technological Characteristics

Reusable manual surgical instruments (taps, drivers) manufactured from stainless steel per ASTM F899. Features a Navlock interface for integration with the Medtronic StealthStation® System. No internal energy source; passive navigation components.

Indications for Use

Indicated for use in spinal surgery to assist surgeons in precisely locating anatomical structures during the preparation and placement of BRIDALVEIL screws in open or minimally invasive procedures. Designed for use with the Medtronic StealthStation® System for conditions where stereotactic surgery is appropriate.

Regulatory Classification

Identification

A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.

Predicate Devices

• Medtronic Instruments (K143628, K143375, K140454)

Reference Devices

• BRIDALVEIL Occipital Cervical Thoracic System, (Screws) (K171250)
• OLYMPIC Navigated Instruments (K172166)

Submission Summary (Full Text)

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January 4, 2019

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: on the left, there is an emblem of the Department of Health & Human Services, and on the right, there is the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue. The emblem features a stylized depiction of a bird or eagle, while the text clearly identifies the organization as the FDA.

Astura Medical Parker Kelch Quality Manager 3186 Lionshead Ave. Suite 100 Carlsbad, California 92010

Re: K182982

Trade/Device Name: BridalVeil Navigated Instruments Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: December 6, 2018 Received: December 7, 2018

## Dear Parker Kelch:

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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

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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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

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,

# Shumaya Ali -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)

K182982

Device Name BRIDALVEIL NAVIGATED INSTRUMENTS

#### Indications for Use (Describe)

The BRIDALVEIL NAVIGATED INSTRUMENTS are intended to be used in the preparation and placement of BRIDALVEIL screws during spinal surgery to assist the surgeon in precisely locating anatomical structures in either open or minimally invasive procedures. These instruments are designed for use with the Medtronic StealthStation® System, which is indicated for any medical condition in which the use of stereotactic surgery may be appropriate, and where reference to a rigid anatomical structure, such as a skull, a long bone, or vertebra, can be identified relative to a CT or MR based model, fluoroscopy images, or digitized landmarks of the anatomy.

| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------|
| <div> <span> ☒ Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> □ Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |

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## 510(k) Summary: BRIDALVEIL NAVIGATED INSTRUMENTS

In accordance with 21 CFR 807.92 of the Federal Code of Regulations

| Date Prepared | October 26, 2018 |
|--------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitted By | Astura Medical |
| | 3186 Lionshead Ave, Suite 100 |
| | Carlsbad, Ca 92010 |
| | Phone: [phone] |
| Contact | Parker Kelch |
| | 3186 Lionshead Ave, Suite 100 |
| | Carlsbad, Ca 92010 |
| | Phone: [phone] |
| | Email: [e-mail] |
| Trade Name | BRIDALVEIL Navigated Instruments |
| Common Name | Navigated instruments |
| Classification Name | Stereotaxic instrument |
| Class | Class II |
| Product Code | OLO |
| Cfr Section | 21 CFR Section 882.4560 |
| Device Panel | Orthopedic |
| Primary Predicate Device | Medtronic Instruments (K143628, K143375, K140454) |
| Reference Device(s) | BRIDALVEIL Occipital Cervical Thoracic System, (Screws) (K171250) |
| | OLYMPIC Navigated Instruments (K172166) |
| Device Description | The BRIDALVEIL Navigated Instruments are comprised of nonsterile, |
| | reusable instruments including taps and drivers that can be operated |
| | manually. These instruments are intended to be used with the Medtronic |
| | StealthStation® System (v 2.1.0) and are manufactured from stainless |
| | steel, as specified in ASTM F899. |
| Materials | Stainless Steel per ASTM F899 |
| Substantial Equivalence | The BRIDALVEIL Navigated Instruments are substantially equivalent to the |
| Claimed to Predicate | predicate BRIDALVEIL devices in terms of intended use, materials used, |
| Devices | mechanical safety and performances. The changes in design on the |
| | instruments are the addition of a Navlock feature, this is equivalent to the |
| | Navlock found on Medtronic Navigated instruments and intended for use |
| | with the Medtronic StealthStation® System. |
| Indications for Use | The BRIDALVEIL NAVIGATED INSTRUMENTS are intended to be used in |
| | the preparation and placement of BRIDALVEIL screws during spinal |
| | surgery to assist the surgeon in precisely locating anatomical structures in |
| | either open or minimally invasive procedures. These instruments are |
| | designed for use with the Medtronic StealthStation® System, which is |
| | indicated for any medical condition in which the use of stereotactic |
| | surgery may be appropriate, and where reference to a rigid anatomical |
| | structure, such as a skull, a long bone, or vertebra, can be identified |
| | relative to a CT or MR based model, fluoroscopy images, or digitized<br>landmarks of the anatomy. |
| NON-CLINICAL TEST | The following analyses were conducted: |
| SUMMARY | |
| | Dimensional analysis compared to predicate<br>• |
| | • Anatomical simulated use and navigation accuracy<br>The results of these evaluations indicate that the BRIDALVEIL NAVIGATED<br>INSTRUMENTS are equivalent to the predicate devices. |
| CLINICAL TEST SUMMARY | No clinical studies were performed |
| CONCLUSIONS: NON-<br>CLINICAL AND CLINICAL | Astura medical considers the BRIDALVEIL NAVIGATED INSTRUMENTS to<br>be equivalent to the predicate devices listed above. This conclusion is<br>based upon the devices' similarities in principles of operation,<br>technology, materials, and indications for use. |

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