| Device Definition |
Posterior lumbar fixation or fusion system, such as pedicle screws, rods, connectors, cross-links, and associated instruments |
Complete device description, intended use, anatomical indication, implant configuration, size range, materials, and compatible components |
Controlled product specifications, engineering drawings, catalog references, and device master records |
Essential |
Required before technical comparison |
| ASTM F1717 Testing |
ASTM F1717, Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model |
Test plan identifying the worst-case construct, loading configuration, specimen setup, test method, and rationale for the selected implant assembly |
Complete laboratory report with test setup photographs, construct configuration, load data, failure mode, and traceable specimen identification |
Essential |
Pass/fail must be reviewed with the test method and device configuration |
| Mechanical Performance |
Static and, when applicable, fatigue characterization of the complete construct |
Evidence covering axial compression, bending, torsion, fatigue behavior, subsidence-related considerations, and connector or interface performance where relevant |
Validated test reports, calibrated equipment records, raw data, acceptance criteria, and documented deviations |
Essential |
Accept only if the tested configuration represents the proposed product |
| Materials and Surface Finish |
Material identity and applicable implant-material specifications |
Material grade, chemical composition, heat-treatment condition, surface treatment, coating information, and component-to-component material compatibility |
Material certificates, supplier traceability, chemical analysis, dimensional inspection, and surface-finish records |
Essential |
Material and process traceability required for each production lot |
| ISO 10993 Biological Evaluation |
ISO 10993 series, selected according to the device contact type, duration, materials, manufacturing processes, and patient exposure |
Biological evaluation plan addressing patient-contacting materials, residues, sterilization effects, and any existing toxicological information |
Biological evaluation report, test reports where needed, chemical characterization, toxicological assessment, and justification for omitted tests |
Essential |
Testing must be risk-based; a generic certificate alone is insufficient |
| Chemical Characterization |
Characterization of potentially extractable or leachable substances from the finished device |
Extraction conditions, sample selection, analytical methods, detected substances, reporting limits, and toxicological evaluation |
Laboratory report using validated analytical methods and traceable finished-device samples |
Conditional |
Often needed when material, coating, adhesive, residue, or processing risk is not fully understood |
| Sterilization and Packaging |
Validated sterilization process or validated cleaning and packaging process for the supplied product state |
Sterilization method, sterility assurance approach, packaging configuration, shelf-life claim, shipping simulation, and product-release controls |
Validation summaries, packaging integrity data, accelerated or real-time aging data, and sterilization-cycle records |
Essential |
Requirements depend on whether the device is supplied sterile or non-sterile |
| FDA 510(k) Strategy |
510(k) pathway may be applicable when the device is substantially equivalent to a legally marketed predicate device |
Proposed device classification, intended use, technological characteristics, predicate rationale, and identification of differences requiring testing |
510(k) submission or clearance documentation, decision summary where available, labeling, and comparison table |
Essential |
510(k) clearance is not the same as FDA approval |
| Predicate and Indications Review |
Substantial-equivalence comparison based on intended use, indications, technological characteristics, and safety or performance data |
Clear mapping between the proposed device and the predicate, including differences in materials, geometry, fixation method, instrumentation, and use environment |
Regulatory comparison matrix, labeling comparison, risk analysis, and supporting bench or clinical evidence when applicable |
Essential |
Unresolved indication or technology differences may increase regulatory risk |
| Quality Management System |
Applicable medical-device quality-system requirements for design, purchasing, production, inspection, nonconformance, and corrective action |
Quality manual or equivalent overview, design-control process, supplier controls, complaint handling, change control, and traceability procedures |
Current quality-system certification or audit evidence, internal procedures, inspection records, and corrective-action history |
Essential |
Audit scope must cover the proposed product and manufacturing site |
| Design Verification and Validation |
Verification that design outputs meet requirements and validation that the device is suitable for its intended use |
Risk-based verification plan covering dimensions, fit, function, mechanical strength, instruments, packaging, sterilization, and usability where relevant |
Approved protocols and reports, requirements traceability matrix, failure investigations, and design-review records |
Essential |
Evidence should cover the final design, not only an early prototype |
| Risk Management |
Risk assessment for surgical, mechanical, biological, manufacturing, and use-related hazards |
Hazard analysis addressing loosening, breakage, migration, corrosion, tissue reaction, incorrect assembly, instrument misuse, and labeling risks |
Risk-management file, failure-mode analysis, risk-control verification, residual-risk evaluation, and benefit-risk rationale |
Essential |
Risk controls must be linked to verification evidence and instructions for use |
| Manufacturing Capability |
Repeatable production of critical dimensions, threads, interfaces, surface conditions, and cleanliness levels |
Process flow, equipment list, in-process controls, critical-to-quality characteristics, capacity, lead time, and subcontractor management |
Process-validation records, capability studies, inspection plans, lot-release criteria, and production samples |
Essential |
Sample quality should be confirmed through an independent first-article review |
| Documentation and Change Control |
Controlled technical documentation and notification of changes that may affect safety, performance, or regulatory status |
Document-control process, revision history, engineering-change procedure, notification timeline, and regulatory-impact assessment process |
Sample change-control records, revision-controlled drawings, approved specifications, and change-notification procedure |
Essential |
Uncontrolled design or material changes are a major supplier risk |
| Commercial and Supply Review |
Supply continuity for implants, instruments, packaging, replacement parts, and technical support |
Minimum order quantity, tooling ownership, production lead time, forecast flexibility, warranty terms, complaint response time, and business-continuity plan |
Signed quality agreement, supply agreement, service-level commitments, and documented escalation contacts |
Conditional |
Commercial suitability should be evaluated only after technical and regulatory screening |