K Number
K014200
Device Name
OPTIMESH
Manufacturer
Date Cleared
2003-11-26

(705 days)

Product Code
Regulation Number
878.3300
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

OptiMesh is intended to maintain the relative position of bone graft material (such as autograft or allograft) within a vertebral body defect (e.g. tumor) that does not impact the stability of the vertebral body and does not include the vertebral endplates.

Device Description

OptiMcsh is a sterile, three-dimensional surgical mesh container made of knitted polyester yarn and offered in a range of sizes. The device is packaged in double Tyvek/Mylar pouches and a cardboard carton, and terminally sterilized.

AI/ML Overview

The provided document is a 510(k) premarket notification letter and summary for a surgical mesh device called OptiMesh. It does not contain the acceptance criteria or a study proving the device meets acceptance criteria in the way typically expected for an AI/ML device (e.g., performance metrics like sensitivity, specificity, accuracy against a ground truth).

Instead, this document is focused on establishing substantial equivalence to a predicate device based on intended use, materials, and configuration. The "performance data" mentioned in the "Technological Characteristic Comparisons" section likely refers to bench testing or material property tests to show the device's physical properties are safe and effective for its intended mechanical function, not a clinical performance study with human subjects or AI-driven analysis.

Therefore, most of the requested information cannot be extracted from this document, as it pertains to a different type of device evaluation.

However, I can provide what is available or infer from the document:

1. A table of acceptance criteria and the reported device performance

The document does not specify quantitative acceptance criteria or reported device performance in terms of clinical outcomes (e.g., success rates, complication rates) or AI-specific metrics (e.g., accuracy, sensitivity). The "acceptance" in this context refers to the FDA finding of substantial equivalence.

Criteria (Implied)Reported Performance (Implied from Substantial Equivalence)
Substantially equivalent to predicate in intended useYes, for maintaining bone graft material in a vertebral body defect.
Substantially equivalent to predicate in materialsYes, polyester yarn for mesh, similar to predicate.
Substantially equivalent to predicate in configurationYes, 3D surgical mesh container.
No new concerns about safety or effectivenessPerformance data provided to demonstrate this (details not included).

2. Sample size used for the test set and the data provenance

No clinical test set or data provenance is detailed in this document. The evaluation is based on technological characteristics comparison to predicate devices, not human subject data for performance.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

Not applicable, as no clinical test set or ground truth derived from expert review is described.

4. Adjudication method for the test set

Not applicable.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done

No, this type of study is not mentioned as this device is a surgical mesh, not a diagnostic or AI-assisted interpretation device.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Not applicable, as this is a physical medical device (surgical mesh), not software/AI.

7. The type of ground truth used

For the purpose of substantial equivalence, the "ground truth" is established by the predicate device's characteristics and its prior regulatory approval. The safety and effectiveness of the predicate device implicitly serves as the benchmark.

8. The sample size for the training set

Not applicable, as this is not an AI/ML device requiring a training set.

9. How the ground truth for the training set was established

Not applicable.

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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Ms. Pamela Snyder Director of Clinical and Regulatory Affairs Spineology, Inc. 1815 Northwestern Avenue Stillwater, Minnesota 55082-6500

Re: K014200 Device: OptiMesh™ Regulation Number: 21 CFR 878.3300 Regulation Name: Surgical Mesh Regulatory Class: II Product Code: EZX Dated: July 30, 2003 Received: August 1, 2003

Dear Ms. Snyder:

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). You may, therefore, market the device, subject to the general controls provisions of the Act and the limitations described below. 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.

NOV 2 6 2003

The Office of Device Evaluation has determined that there is a reasonable likelihood that this device will be used for an intended use not identified in the proposed labeling and that such use could cause harm. Therefore, in accordance with Section 513(i)(1)(E) of the Act, the following limitation must appear in the Contraindications section of your device's labeling:

Do not use this device in patients with instability (e.g. resected or collapsed vertebral bodies or fracture of the anterior column). This device does not provide structural support.

In addition, the following warning must appear in a black box immediately below your indications for use statement of the device's labeling:

The safety and effectiveness of this device used for fusion of the interbody space has not been established.

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Page 2 - Ms. Pamela Snyder

Please note that the above labeling limitations are required by Section 513(i)(1)(E) of the Act. Therefore, a new 510(k) is required before these limitations are modified in any way or removed from the device's labeling.

The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and permits your device to proceed to the market. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification if the limitation statement described above is added to your labeling.

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 801); 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 information about the application of other labeling requirements to your device (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International, and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.

Sincerely yours,

Daniel Schultz, M.D Director Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Page 1 of 1

510(k) Number (if known): K014200

Device Name:_OptiMesh™

FDA's Statement of the Indications For Use for device:

OptiMesh is intended to maintain the relative position of bone graft material (such as autograft or allograft) within a vertebral body defect (e.g. tumor) that does not impact the stability of the vertebral body and does not include the vertebral endplates.

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JAN-06-2004 12:36 Spineology

P.02/02

Spineology Inc. Premarket Notification: OptiMesh K014200

510(k) Summary

Submitter Information
Manufacturer's Name & AddressManufacturer's Contact Person
Spineology Inc.Pamela Snyder
1815 Northwestern AvenueDirector of Clinical & Regulatory
Stillwater, MN 55082Phone: 651-351-1011
Fax: 651-351-0712
Device Names
Proprietary Name:OptiMesh
Classification Name:888.3060, appliance, fixation, spinal device;878.3300 surgical mesh
Device Product Code:KWQ, EZX

Predicate Devices

The subject device is substantially equivalent to the predicate device, MacroPore OS Spinal System, K010911, and related predicate device, MERSILENE Mesh, a preamendment device.

Device Description

OptiMcsh is a sterile, three-dimensional surgical mesh container made of knitted polyester yarn and offered in a range of sizes. The device is packaged in double Tyvek/Mylar pouches and a cardboard carton, and terminally sterilized.

Intended Use

OptiMesh is intended to maintain the relative position of bone graft material (such as autograft or allograft) within a vertebral body defect (e.g. tumor) that does not impact the stability of the vertebral body and does not include the vertebral endplates.

The safety and effectiveness of this device used for fusion of the interbody space has not been established.

Technological Characteristic Comparisons

The device was shown to be substantially equivalent to the intended use, materials and configuration of the predicate products. Where technological differences exist, performance data was provided to demonstrate that the questions raised no new concerns about safety or effectiveness.

§ 878.3300 Surgical mesh.

(a)
Identification. Surgical mesh is a metallic or polymeric screen intended to be implanted to reinforce soft tissue or bone where weakness exists. Examples of surgical mesh are metallic and polymeric mesh for hernia repair, and acetabular and cement restrictor mesh used during orthopedic surgery.(b)
Classification. Class II.