Remex Spine Surgery Navigation Instrument

K243560 · Remex Medical Corp. · OLO · Dec 13, 2024 · Neurology

Device Facts

• Record ID: K243560
• Device Name: Remex Spine Surgery Navigation Instrument
• Applicant: Remex Medical Corp.
• Product Code: OLO · Neurology
• Decision Date: Dec 13, 2024
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 882.4560
• Device Class: Class 2

Intended Use

The Remex Spine Surgery Navigation instrument is designed for use with Anatase Spine Surgery Navigation System(K230783) and Remex Spine Surgery Navigation System II(K233513). The Anatase Spine Surgery Navigation System and Remex Spine Surgery Navigation System II are indicated for precise positioning of surgical instruments or spinal implants during general spine surgery when reference to a rigid anatomical structure, such as the vertebra, can be identified relative to a patient's fluoroscopic or CT imagery. It is intended as a planning and intraoperative guidance system to enable open or percutaneous image guided surgery by means of registering intraoperative 2D fluoroscopic projections to pre-operative 3D CT imagery. Example procedures include: Posterior-approach spinal implant procedures, such as pedicle screw placement, with the lumbar region.

Device Story

Remex Spine Surgery Navigation Instrument comprises Nav Awl, Nav Drill Guide, Nav Tap, Nav Screwdriver, and Nav Handle; used with Anatase Spine Surgery Navigation System (K230783) and Remex Spine Surgery Navigation System II (K233513). System registers intraoperative 2D fluoroscopic projections to pre-operative 3D CT imagery to provide intraoperative guidance. Surgeon uses instruments to create entry points, drill holes, tap threads, and drive screws into vertebrae. Operates in clinical setting; physician-operated. Provides visual guidance on system display to assist precise positioning of spinal implants. Benefits include improved accuracy and guidance during open or percutaneous spinal procedures.

Clinical Evidence

Bench testing only. Verification and validation activities performed in accordance with IEC 62304 (software), ISO 14971 (risk management), and ISO 10993-1 (biocompatibility). Design verification confirmed outputs meet all input requirements. No clinical data presented.

Technological Characteristics

Navigation instruments (Awl, Drill Guide, Tap, Screwdriver, Handle) for use with existing navigation systems. Materials evaluated per ISO 10993-1. Connectivity via integration with navigation system hardware. Software-based guidance using 2D-3D image registration. Sterilization method consistent with predicate devices.

Indications for Use

Indicated for patients undergoing general spine surgery, specifically posterior-approach spinal implant procedures such as pedicle screw placement in the lumbar region, where navigation relative to rigid anatomical structures (vertebrae) via fluoroscopic or CT imagery is required.

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

• Remex Spine Surgery Navigation System II (K233513)
• Anatase Spine Surgery Navigation System (K230783)

Submission Summary (Full Text)

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, with the letters "FDA" in a blue square. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 13, 2024

Remex Medical Corp. Cheng-Hsiung Wang Quality Representative I 4F, No.9, Jingke Road, Nantun District Taichung, 408209 Taiwan

Re: K243560

Trade/Device Name: Remex Spine Surgery Navigation Instrument Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: October 11, 2024 Received: November 18, 2024

Dear Cheng-Hsiung Wang:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"

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(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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

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

Sincerely,

# Shumaya Ali -S

Shumaya Ali, M.P.H. Assistant Director DHT6C: Division of Restorative, Repair and Trauma 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) K243560

Device Name Remex Spine Surgery Navigation Instrument

#### Indications for Use (Describe)

The Remex Spine Surgery Navigation instrument is designed for use with Anatase Spine Surgery Navigation System(K230783) and Remex Spine Surgery Navigation System II(K233513). The Anatase Spine Surgery Navigation System and Remex Spine Surgery Navigation System II are indicated for precise positioning of surgical instruments or spinal implants during general spine surgery when reference to a rigid anatomical structure, such as the vertebra, can be identified relative to a patient's fluoroscopic or CT imagery. It is intended as a planning and intraoperative guidance system to enable open or percutaneous image guided surgery by means of registering intraoperative 2D fluoroscopic projections to pre-operative 3D CT imagery. Example procedures include: Posterior-approach spinal implant procedures, such as pedicle screw placement, with the lumbar region.

Type of Use (Select *one* or *both*, as applicable)X Prescription Use (Part 21 CFR 801 Subpart D)

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

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## 510(k) Summary

| Submitted By | REMEX MEDICAL CORP.<br>4F., No.9 Jingke Rd., Nantun District, Taichung, TW 408209<br>Tel. [phone]<br>Fax.[phone] | |
|--------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person | Cheng-Hsiung Wang<br>[e-mail] | |
| Date Prepared | October 11th, 2024 | |
| Device Name | Remex Spine Surgery Navigation Instrument | |
| Classification Name | Stereotaxic instrument | |
| Regulation Number | 882.4560 | |
| Product Codes | OLO | |
| Device Class | Class II | |
| Predicate Devices<br>Information | K233513, Remex Spine Surgery Navigation System II (primary)<br>K230783, Anatase Spine Surgery Navigation System | |
| Device Description | The Remex Spine Surgery Navigation Instrument is designed for use with<br>Anatase Spine Surgery Navigation System (K230783) and Remex Spine Surgery<br>Navigation System II (K233513).<br>The Remex Spine Surgery Navigation Instrument consists of the Nav Awl, Nav<br>Drill Guide, Nav Tap, Nav Screwdriver and Nav Handle.<br>1. Nav Awl: The subject device is intended to support the surgeon to create an<br>entry point before implanting the screw.<br>2. Nav Drill Guide: The subject device is intended to assist in drilling holes to a<br>desired depth and ensuring proper orientation.<br>3. Nav Tap: The subject device is intended to create screw threads.<br>4. Nav Screwdriver: The subject device is intended to driver the screw into the<br>vertebra.<br>Nav Handle: The subject device is intended to connected with Nav Awl, Nav Tap<br>or Nav Screwdriver for navigation tracking purpose. | |
| Indications for Use | The Remex Spine Surgery Navigation Instrument is designed for use with<br>Anatase Spine Surgery Navigation System (K230783) and Remex Spine Surgery<br>Navigation System II (K233513).<br>The Anatase Spine Surgery Navigation System and Remex Spine Surgery<br>Navigation System II, are indicated for precise positioning of surgical<br>instruments or spinal implants during general spinal surgery when reference to a<br>rigid anatomical structure, such as the vertebra, can be identified relative to a<br>patient's fluoroscopic or CT imagery. It is intended as a planning and<br>intraoperative guidance system to enable open or percutaneous image guided | |
| surgery by means of registering intraoperative 2D fluoroscopic projections to | | |
| pre-operative 3D CT imagery. | | |
| Example procedures include: | | |
| Posterior-approach spinal implant procedures, such as pedicle screw placement, | | |
| within the lumbar region. | | |
| Technological<br>Characteristics | The subject devices have the same intended use, same indications for use, same<br>sterilization method, same fundamental technology, and similar materials, similar<br>design as the predicate devices, Anatase Spine Surgery Navigation System<br>(K230783) and Remex Spine Surgery Navigation System II (K233513). | |
| | The difference between the subject devices and the predicate devices are the<br>upgrade of the system software version, and new instruments for corresponding<br>compatible devices. However, these modifications share same function and<br>fundamental technology with the predicate devices. | |
| Performance Data | Verification and validation activities have been completed to provide sufficient<br>assurance that the subject device meets the performance requirements under its<br>indications for use conditions. Below is a summary of all performance tests which<br>should carried out on the subject device to demonstrated that the subject device<br>performs as safely and effectively as the predicate device. | |
| | Test | Description |
| | Software | Software is verified and validated in accordance with FDA<br>guidance for the content of premarket submissions for<br>software contained in medical devices and IEC 62304. |
| | Risk Assessment | The effectiveness of all risk control measures is verified in<br>accordance with ISO 14971. |
| | Design<br>Verification | The design output fulfills all design input requirements. |
| | Biocompatibility<br>Evaluation | The materials that contact with human tissue, blood or<br>bone must be considered for biocompatibility to ensure no<br>rejection, allergic and adverse reactions occur. The subject<br>device is evaluated in accordance with FDA guidance for<br>the use of international standard ISO 10993-1, "Biological<br>evaluation of medical devices - Part 1: Evaluation and<br>testing within a risk management process" and ISO 10993-<br>1. |
| | The intended use and fundamental technology of the device are identical to the<br>predicate device, and could share the same testing methods as the predicate<br>devices. All the results are passed. Therefore, REMEX believes the testing<br>demonstrated that the subject devices are as safe and effective as the predicate<br>devices. | |
| Conclusion | The Remex Spine Surgery Navigation Instrument and the predicate devices have<br>the same intended use and have the same or similar technological characteristics.<br>Moreover, the information contained in this submission demonstrates that any<br>differences in their technological characteristics do not raise new issues of safety | |

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Image /page/5/Picture/0 description: The image shows the word "REMEX" in a sans-serif font. The letters are gray, except for a green leaf-like shape that replaces the bottom left portion of the "R". The word is presented in a clear and legible manner, with a modern and professional aesthetic.

Remex Medical Corporation 4F, No. 9, Jingke Road, Nantun District, Taichung City408209, Taiwan

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Image /page/6/Picture/0 description: The image shows the word "REMEX" in a sans-serif font. The letters are gray, except for a green leaf-like shape in the lower-left corner of the "R". The text is centered and appears to be a logo or brand name.

Remex Medical Corporation 4F, No. 9, Jingke Road, Nantun District, Taichung City408209, Taiwan

| or effectiveness. Hence, The Remex Spine Surgery Navigation Instrument is |
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| substantially equivalent to the predicate devices. |