(100 days)
The Innovasis Oryx Cervical Plate System is intended for use in anterior cervical fixation for the following indications: i. Degenerative Disc Disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies), ii. Spondylolisthesis, iii. Trauma (i.e., fracture or dislocation) iv. Spinal stenosis. v. Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis), vi. Tumor, vii. Pseudoarthrosis: and viii. Previous failed fusion. The Innovasis Oryx Cervical Plate System is indicated for stabilizing the cervical spine from C2 to C7.
The Oryx Cervical Plate System consists of a number of plates and screws of varying lengths. The plates feature lordotic curvature and a transverse plane curvature for an anatomical fit. The set contains ancillary products and instruments. All implant components are machined from implant grade titanium alloy, Ti6Al4V (ELI) per ASTM F136.
The provided text describes the 510(k) premarket notification for the Innovasis Oryx™ Cervical Plate System. It details the device, its intended use, indications for use, and a comparison to a predicate device. However, it does not contain information about acceptance criteria, a specific study proving device performance against such criteria, sample sizes for test/training sets, data provenance, expert involvement, adjudication methods, or MRMC/standalone studies as typically expected for software-based medical devices or diagnostic tools.
The document focuses on demonstrating substantial equivalence to a previously cleared predicate device, the Synthes Anterior CSLP System (K030866), through non-clinical performance testing of the mechanical components.
Here's an analysis based on the provided text, highlighting what is present and what is missing based on your request:
1. A table of acceptance criteria and the reported device performance
The document mentions performance testing on plates per ASTM F1717 (Static and Dynamic Compression Bend and Static Torsion) and ASTM F543 (bone screw Axial Pull-Out, Insertion and Removal Torque and Torsional Yield Strength). It states that this testing indicates the Oryx Cervical Plate System is "substantially equivalent to the predicate device."
Missing: Specific quantitative acceptance criteria (e.g., "must withstand X N of force for Y cycles") and the precise reported performance values for the Oryx system are not explicitly detailed in a table format in this summary. The substantial equivalence claim implies that the performance met or exceeded the predicate's established performance, but the exact numbers are not given.
2. Sample sizes used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective)
Missing: This information is not relevant or present because the testing described is mechanical, non-clinical performance testing of a physical implant, not a study evaluating a software algorithm or diagnostic tool. Therefore, there's no "test set" in the sense of clinical or image data, nor is there data provenance as one might expect for an AI product.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience)
Missing: Not applicable. This device is a physical implant, not a diagnostic tool requiring expert interpretation for ground truth.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Missing: Not applicable for mechanical performance testing.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
Missing: Not applicable. This is a physical implant, not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Missing: Not applicable. This is a physical implant, not a software algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For mechanical testing: The "ground truth" is implicitly derived from the established performance standards of ASTM F1717 and F543, and the performance characteristics of the predicate device (Synthes Anterior CSLP System). These standards provide quantifiable metrics for material strength and mechanical behavior.
8. The sample size for the training set
Missing: Not applicable. This is a physical implant, not a software algorithm requiring a training set.
9. How the ground truth for the training set was established
Missing: Not applicable.
Summary of what is present:
- Acceptance Criteria Mentioned: Performance testing per ASTM F1717 (Static and Dynamic Compression Bend, Static Torsion) and ASTM F543 (bone screw Axial Pull-Out, Insertion and Removal Torque, Torsional Yield Strength).
- Reported Device Performance: The device's performance "indicates that the Oryx Cervical Plate System is substantially equivalent to the predicate device." This implies the device met or exceeded the performance thresholds expected for the predicate under these standards.
- Predicate Device: Synthes Anterior CSLP System (K030866).
- Materials: Ti6Al4V (ELI) per ASTM F136 for implants.
Conclusion based on the provided text:
The document focuses on demonstrating that the Innovasis Oryx™ Cervical Plate System is substantially equivalent to a legally marketed predicate device (Synthes Anterior CSLP System) based on non-clinical mechanical performance testing and material characterization. It explicitly states: "Performance data and rationales submitted herein demonstrate that the subject Oryx Cervical Plate System is substantially equivalent to the predicate device with regard to design, technological characteristics, materials, performance, intended use and indications for use."
The device is a physical orthosis, not a software or AI-driven diagnostic tool, which is why much of the information typically requested for AI/software (like sample sizes for test/training sets derived from clinical data, expert involvement, adjudication, MRMC studies, etc.) is not present in this 510(k) summary.
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Image /page/0/Picture/0 description: The image contains 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, which is a blue square with the letters "FDA" in white. To the right of the FDA logo is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
November 8, 2019
Innovasis, Inc. Marshall C. McCarty, RAC Director QA/RA 614 East 3900 South Salt Lake City, Utah 84107
Re: K192049
Trade/Device Name: Oryx™ Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: KWQ Dated: August 13, 2019 Received: August 14, 2019
Dear Mr. McCarty:
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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Ronald P. Jean, Ph.D. Director (Acting) DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K192049
Device Name OryxTM Cervical Plate System
Indications for Use (Describe)
- The Innovasis Oryx Cervical Plate System is intended for use in anterior cervical fixation for the following indications: i. Degenerative Disc Disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc
- confirmed by history and radiographic studies),
- ii. Spondylolisthesis,
- iii. Trauma (i.e., fracture or dislocation)
- iv. Spinal stenosis.
- v. Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis),
- vi. Tumor,
- vii. Pseudoarthrosis: and
- viii. Previous failed fusion.
The Innovasis Oryx Cervical Plate System is indicated for stabilizing the cervical spine from C2 to C7.
| 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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Image /page/3/Picture/1 description: The image shows the logo for Innovasis. The logo is black and features the word "INNOVASIS" in a bold, sans-serif font. Below the logo is the text "INNOVATE / INVOLVE / INVENT" in a smaller font. The logo is simple and modern, and the text below it suggests that the company is focused on innovation.
510(k)
510(k) Summary Report: 5.0
Oryx™ Cervical Plate System
| Company: | Innovasis, Inc. |
|---|---|
| 614 E. 3900 South | |
| Salt Lake City, UT 84107 |
Contact: Marshall McCarty Alternate: Michael Thomas Phone: (801) 261-2236 x8012 mmccarty@innovasis.com
(801) 261-2236 x8002 mthomas@innovasis.com
- Trade Name: Oryx™ Cervical Plate System
- Common Name: Anterior cervical fixation system
Regulation No.: 21CFR 888.3060 Spinal Intervertebral Body Fixation Orthosis Classification: Class 2 Product Code: KWQ Review Panel: Orthopedic Review Team: ISDT
- Primary Predicte: K030866 Synthes Anterior CSLP System
- Additional: K061147 Innovasis Opteryx Anterior Cervical Plate System
- Device Description: The Oryx Cervical Plate System consists of a number of plates and screws of varying lengths. The plates feature lordotic curvature and a transverse plane curvature for an anatomical fit. The set contains ancillary products and instruments. All implant components are machined from implant grade titanium alloy, Ti6Al4V (ELI) per ASTM F136.
- (Non-clinical)—Performance testing on plates per ASTM F1717 Performance Data: for Static and Dynamic Compression Bend and Static Torsion and ASTM F543 for bone screw Axial Pull-Out, Insertion and Removal Torque and Torsional Yield Strength indicates that the Oryx Cervical Plate System is substantially equivalent to the predicate device.
- Materials: The Oryx implants are machined from medical grade Ti6Al4V (ELI) per ASTM F136. The Orvx instruments/accessories are machined from Surgical Stainless Steel per ASTM F899 and some have medical grade Silicone handles.
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| INNOVASISINNOVATE / INVOLVE / INVENT | Oryx™ Cervical Plate System | 510(k)July 31, 2019Page 11 of 107 |
|---|---|---|
| ------------------------------------------ | ----------------------------- | ------------------------------------------- |
The Oryx sterilization trays are comprised of Anodized 5052 Aluminum and have components made of Nylon. Stainless Steel. Polypropylene, and Radel per ASTM D6394 SP031.
The Oryx Cervical Plate System is intended for use in Anterior Intended Use: Cervical Discectomy and Fusion (ACDF) procedures. Users of these products are limited to physicians trained in orthopedic surgery. Clinical locations include hospitals and surgery sites equipped to perform spinal surgery.
Indications for Use: The Innovasis Oryx Cervical Plate System is intended for use in anterior cervical fixation for the following indications:
i. Degenerative Disc Disease (DDD) (defined as neck pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies).
ii. Spondvlolisthesis.
iii. Trauma (i.e., fracture or dislocation)
- iv. Spinal stenosis.
v. Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis).
vi. Tumor.
- vii. Pseudarthrosis; and
viii. Previous failed fusion.
The Innovasis Oryx Cervical Plate System is indicated for stabilizing the cervical spine from C2 to C7.
Comparison of the Technological Characteristics with Predicate Device:
The Innovasis Oryx Cervical Plate System has been subjected to risk analysis, engineering analysis and testing to recognized standards and has been shown to be substantially equivalent to the Synthes Anterior CSLP System (K030866) predicate.
- . Design configurations are substantially equivalent.
- . Applied mechanical loads are substantially equivalent.
- . Materials used are substantially equivalent.
- Biocompatibility requirements have been demonstrated. ●
- Intended Use and Indications for Use are substantially equivalent.
- Conclusion: Performance data and rationales submitted herein demonstrate that the subject Oryx Cervical Plate System is substantially equivalent to the predicate device with regard to design, technological characteristics, materials, performance, intended use and indications for use.
§ 888.3060 Spinal intervertebral body fixation orthosis.
(a)
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.(b)
Classification. Class II.