K Number
K040047
Device Name
POLYGRAFT BGS; BONE GRAFT SUBSTITUTE
Date Cleared
2004-12-17

(340 days)

Product Code
Regulation Number
888.3045
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The PolyGraft™ BGS is to be used to fill bony voids or gaps caused by trauma or surgery that are not intrinsic to the stability of the bony structure. The PolyGraff™ BGS is intended to be gently packed into bony voids or gaps of the skeletal system (i.e., the extremities, spine and pelvis). These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced with bone during the healing process. The PolyGraft™ BGS may be combined with autogenous blood products, such as platelet rich plasma, and/or sterile fluids, such as saline or Ringer's solution. The addition of these autogenous products does not alter the performance of the device.
Device Description
PolyGraft™ BGS is manufactured using a blend of poly(D,L-lactide-coglycolide), calcium sulfate, polyglycolide fibers and surfactant. The PolyGrafi™ BGS will be provided in a variety of shapes and sizes ranging from small, porous granules to preformed cylindrical plugs.
More Information

Not Found

No
The summary describes a bone graft substitute material and its physical properties and performance in animal studies. There is no mention of any software, algorithms, or data processing that would indicate the use of AI or ML.

Yes
The device is intended to fill bony voids or gaps caused by trauma or surgery, helping in the healing process by promoting bone replacement, which is a therapeutic function.

No
The device is a bone void filler intended for surgical repair, not for diagnosing medical conditions.

No

The device description clearly states the device is manufactured using a blend of physical materials (polymers, calcium sulfate, fibers, surfactant) and is provided in physical shapes and sizes (granules, plugs). This indicates it is a physical medical device, not software-only.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that the device is used to "fill bony voids or gaps caused by trauma or surgery." This is a therapeutic and structural application within the body.
  • Device Description: The device is described as a "bone void filler" made of materials like poly(D,L-lactide-coglycolide), calcium sulfate, etc., and provided in shapes like granules and plugs. This is consistent with a medical device implanted or used within the body.
  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body (like blood, urine, tissue) to detect diseases, conditions, or infections. This device does not perform any such testing.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, detecting biomarkers, or providing diagnostic information.

Therefore, the PolyGraft™ BGS is a medical device intended for surgical use within the skeletal system, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The PolyGraft™ BGS is to be used to fill bony voids or gaps caused by trauma or surgery that are not intrinsic to the stability of the bony structure. The PolyGraff™ BGS is intended to be gently packed into bony voids or gaps of the skeletal system (i.e., the extremities, spine and pelvis). These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced with bone during the healing process. The PolyGraft™ BGS may be combined with autogenous blood products, such as platelet rich plasma, and/or sterile fluids, such as saline or Ringer's solution. The addition of these autogenous products does not alter the performance of the device.

Product codes

MQV

Device Description

PolyGraft™ BGS is manufactured using a blend of poly(D,L-lactide-coglycolide), calcium sulfate, polyglycolide fibers and surfactant. The PolyGrafi™ BGS will be provided in a variety of shapes and sizes ranging from small, porous granules to preformed cylindrical plugs.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

skeletal system (i.e., the extremities, spine and pelvis)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Testing: Biocompatibility assessment performed by independent certified laboratories demonstrated the biocompatibility of the materials used for this device. Degradation testing performed in a simulated body fluid at 37° C showed that the degradation rate is substantially equivalent to the predicate devices. OsteoBiologics performed a rabbit metaphyseal defect study to compare the bone formation of the PolyGraft™ BGS to the predicate device. The PolyGrafi™ BGS combined with autogenous blood products histologically showed bone formation similar to the predicate device (PolyGraft™ BGS alone) at different endpoints. The result from this sideby-side in vivo comparison demonstrated the expanded indications that PolyGraff™ BGS in combination with autogenous blood products are substantially equivalent to PolyGraft™ BGS alone, therefore supporting the suitability of the PolyGraft™ BGS combined with autogenous blood products for use in a clinical situation.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K030288

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3045 Resorbable calcium salt bone void filler device.

(a)
Identification. A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.

0

KD40047

DEC 17 2004

510(k) SUMMARY

SubmitterContact
Image: OBI LogoGabriele G. Niederauer, Ph.D.
OsteoBiologics, Inc.Director of Research and Development
12500 Network, Suite 112Phone: 210-690-2131 (ext. 228)
San Antonio, Texas 78249,
USAFax: 210-690-2559
E-mail: gabi@obi.com
Date of Summary:January 9, 2004
Revised:November 16, 2004
Common Name:Resorbable Bone Void Filler
Proprietary Name:PolyGraft™ BGS
Device Classification:Resorbable calcium salt bone void filler (Product Code 87MQV) is a Class II device, per 21 CFR 888.3045
510(k) Number:K040047

Description of Device: PolyGraft™ BGS is manufactured using a blend of poly(D,L-lactide-coglycolide), calcium sulfate, polyglycolide fibers and surfactant. The PolyGrafi™ BGS will be provided in a variety of shapes and sizes ranging from small, porous granules to preformed cylindrical plugs.

Intended Use: The PolyGraft™ BGS is to be used to fill bony voids or gaps caused by trauma or surgery that are not intrinsic to the stability of the bony structure. The PolyGraft™ BGS is intended to be gently packed into bony voids or gaps of the skeletal system (i.e., the extremities, spine and pelvis). These defects may be surgically created osseous defects or os the offects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced with bone during the healing process. The PolyGraft™ RGS may he combined with autogenous blood products, such as platelet rich plasma, and/or sterile fluids, such as saline or Ringer's solution. The addition of these autogenous products does not alter the performance of the device.

Substantial Equivalence: The PolyGraft™ BGS is substantially equivalent in design, function and performance to the PolyGraft™ BGS cleared as K030288 on July 17, 2003.

Testing: Biocompatibility assessment performed by independent certified laboratories demonstrated the biocompatibility of the materials used for this device. Degradation testing performed in a simulated body fluid at 37° C showed that the degradation rate is substantially equivalent to the predicate devices. OsteoBiologics performed a rabbit metaphyseal defect study to compare the bone formation of the PolyGraft™ BGS to the predicate device. The PolyGrafi™ BGS combined with autogenous blood products histologically showed bone formation similar to the predicate device (PolyGraft™ BGS alone) at different endpoints. The result from this sideby-side in vivo comparison demonstrated the expanded indications that PolyGraff™ BGS in combination with autogenous blood products are substantially equivalent to PolyGraft™ BGS alone, therefore supporting the suitability of the PolyGraft™ BGS combined with autogenous blood products for use in a clinical situation.

1

Public Health Service

Image /page/1/Picture/2 description: The image shows the seal of the Department of Health & Human Services (HHS). The seal features a stylized caduceus, a symbol often associated with medicine and healthcare, consisting of a staff with two snakes coiled around it. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

DEC 17 2004

Gabriele G. Niederauer, Ph.D. Director of Research and Development Osteobiologics 12500 Network, Suite 112 San Antonio, TX 78249-3308

Re: K040047

Trade Name: PolyGraft BGS Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MQV Dated: November 15, 2004 Received: November 16, 2004

Dear Dr. Niederauer:

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. 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.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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

2

Page 2 - Gabriele G. Niederauer, Ph.D.

manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 manufacturing practicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

This letter will allow you to begin marketing your device as described in your Section This letter will anow you to ough inding of substantial equivalence of your device 510(x) prematical predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), If you desire specific at no row pliance at (240) 276-0120. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Inter other 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,

Sincerely, yours,

Mark A. Mulkern

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

3

Indications for Use (Form)

INDICATIONS FOR USE

510(K) Number (if known): K040047

Device Name:

PolyGraft™ BGS (Bone Graft Substitute)

Indications for Use:

The PolyGraft™ BGS is to be used to fill bony voids or gaps caused by trauma or surgery that are not intrinsic to the stability of the bony structure. The PolyGraff™ BGS is intended to be gently packed into bony voids or gaps of the skeletal system (i.e., the extremities, spine and pelvis). These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced with bone during the healing process. The PolyGraft™ BGS may be combined with autogenous blood products, such as platelet rich plasma, and/or sterile fluids, such as saline or Ringer's solution. The addition of these autogenous products does not alter the performance of the device.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

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

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

R. Mark N. Milliken

and Neurologic

510(k) Numbe

K040047

510(k) Premarket Notification: PolyGraft™ BGS - Expanded Claims

Confidential