K Number
K083186
Date Cleared
2010-03-04

(491 days)

Product Code
Regulation Number
888.3060
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Aesculap HydroLift VBR System is indicated for use in the thoracolumbar spine (T1 to L5) for partial or total replacement of a collapsed, damaged, or unstable vertebral body due to tumor or trauma (i.e. fracture). The Aesculap HydroLift VBR System is intended for use with supplemental spinal fixation systems such as the Aesculap MACS TL or S4 Systems. The Aescular HydroLift VBR System may be used with bone graft. The Aesculap HydroLiff VBR System is designed to provide anterior spinal column support even in the absence of fusion for a prolonged period.

Device Description

The Aesculap HydroLift VBR System is an adjustable vertebral body replacement device that is implanted into the vertebral body space to improve stability of the spine. The center column of the device can be adjusted to the exact length required by the patients anatomy after implantation. Once it is adjusted to the desired length the column is mechanically locked in place. Primary components are manufactured from titanium alloy (Ti6ANV).

AI/ML Overview

The provided text is a 510(k) Premarket Notification for the Aesculap HydroLift VBR System. However, it does not contain details about acceptance criteria or a specific study proving the device meets those criteria in the way a diagnostic AI device submission would.

Instead, this document describes a spinal implant and its substantial equivalence to existing predicate devices. The "performance data" section states:

"Static and dynamic testing of the Aesculap HydroLift VBR System was performed in accordance with ASTM F1717 as recommended by the FDA Guidance for Spinal System 510(k)'s."

This indicates that the device's performance was evaluated against a recognized standard for spinal implants, but the document does not provide the acceptance criteria (e.g., specific thresholds for fatigue life, displacement, or strength) nor the detailed results of these tests. It merely confirms that the tests were conducted.

Therefore, I cannot fill in the requested table and answer many of the questions, as the information is not present in the provided text.

Here is what can be inferred and explicitly stated from the given text:

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

    Acceptance CriteriaReported Device Performance
    Compliance with ASTM F1717 (Standard Specification for Spinal Implant Constructs in a Vertebral Body Replacement Device) as recommended by FDA Guidance."Static and dynamic testing... was performed in accordance with ASTM F1717."
    Specific quantitative acceptance criteria (e.g., fatigue limits, displacement thresholds, load-bearing capacity)Not provided in the document.
  2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample Size: Not specified.
    • Data Provenance: Not specified. The testing was done according to a US standard (ASTM F1717) and submitted to the US FDA, implying testing relevant to the US market, but the actual location of testing or origin of data is not stated.
  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)

    • This question is not applicable to this type of device submission. The device is a mechanical implant, and its "ground truth" for performance is established through engineering and mechanical testing standards, not expert clinical interpretation of data.
  4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • This question is not applicable to this type of device. Adjudication methods are relevant for clinical studies involving human interpretation or subjective endpoints, not mechanical 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

    • This question is not applicable to this type of device. An MRMC study is for diagnostic or AI-assisted devices involving human readers/interpreters. This is a spinal implant.
  6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • This question is not applicable to this type of device. This is a physical spinal implant, not an algorithm.
  7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    • The "ground truth" for this mechanical spinal implant is based on engineering performance standards (specifically ASTM F1717) and the ability to meet the mechanical and functional requirements for a vertebral body replacement device, such as stability, load-bearing capacity, and fatigue resistance. It is not clinical "ground truth" derived from patient data or expert consensus in the typical sense for diagnostic devices.
  8. The sample size for the training set

    • This question is not applicable to this type of device. There is no "training set" in the context of mechanical testing for a spinal implant.
  9. How the ground truth for the training set was established

    • This question is not applicable for the same reason as above.

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510(k) Premarket Notification

page 1 of 2

HydroLift VBR System

510(k) SUMMARY (as required by 21 CFR 807.92) B.

Aesculap HydroLift VBR System01 March 2010MAR - 4 2010
COMPANY:Aesculap®Implant Systems, Inc.3773 Corporate ParkwayCenter Valley, PA 18034Establishment Registration Number: 3005673311
CONTACT:Matthew M. Hull800-258-1946 (phone)610-791-6882 (fax)
TRADE NAME:Aesculap HydroLift VBR System
COMMON NAME:Adjustable Vertebral Body Replacement Device
CLASSIFICATION NAME:Spinal Vertebral Body Replacement Device
REGULATION NUMBER:868.3060
PRODUCT CODE:MQP

SUBSTANTIAL EQUIVALENCE

Aesculap® Implant Systems, Inc. believes that the Aesculap HydroLift VBR System is substantially equivalent to:

  1. SynEx Spacer System by Synthes (K003836)

  2. Lift VB Spinal System by Medtronic Sofamor Danek, Inc. (K010930)

DEVICE DESCRIPTION

The Aesculap HydroLift VBR System is an adjustable vertebral body replacement device that is implanted into the vertebral body space to improve stability of the spine. The center column of the device can be adjusted to the exact length required by the patients anatomy after implantation. Once it is adjusted to the desired length the column is mechanically locked in place. Primary components are manufactured from titanium alloy (Ti6ANV).

INDICATIONS FOR USE

The Aesculap HydroLift VBR System is indicated for use in the thoracolumbar spine (T1 to L5) for partial or total replacement of a collapsed, damaged, or unstable vertebral body due to tumor or trauma (i.e. fracture). The Aesculap HydroLift VBR System is intended for use with supplemental spinal fixation systems such as the Aesculap MACS TL or S4 Systems. The Aescular HydroLift VBR System may be used with bone graft. The Aesculap HydroLiff VBR System is designed to provide anterior spinal column support even in the absence of fusion for a prolonged period.

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Page 2 of 2

HydroLift VBR System

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TECHNOLOGICAL CHARACTERISTICS(compared to Predicates)

The Aesculap HydroLift VBR System is a mechanically adjustable vertebral body replacement device as are the predicates. The HydroLift's height is precisely adjusted using either a manual hydraulic pump or a mechanical distractor. Once the device is at the desired height locking screws are employed to fix that position. The Synthes SynEx Spacer uses a ratcheting cylinder with discreet increments (2.5mm) and endplates to adjust it's height. Medtronic SD's Lift VB uses a screw type center cylinder with two endplates to adjust it's height. All three devices utilize locking screws to secure the desired height adjustment has been made. The HydroLift has pivoting endplates for precise lordotic anqulation while the predicate devices offer a selection of endplates at set lordotic angles. The endplates of all three devices utilize small spikes and/or teeth to prevent migration. The material used for the Aesculap device is the same as that used to manufacture the predicate devices. Sterile saline solution serves as the fluid for the hydraulic mechanism.

PERFORMANCE DATA

Static and dynamic testing of the Aesculap HydroLift VBR System was performed in accordance with ASTM F1717 as recommended by the FDA Guidance for Spinal System 510(k)'s.

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Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an emblem featuring a stylized depiction of a bird-like figure, possibly representing an eagle or other national symbol. The emblem is rendered in a simple, graphic style.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room W-O66-0609 Silver Spring, MD 20993-0002

Aesculap® Implant Systems, Inc. % Mr. Matthew M. Hull, RAC Manager, Regulatory Affairs 3773 Corporate Parkway Center Valley, Pennsylvania 18034

Re: K083186

Trade/Device Name: Aesculap HydroLift VBR System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: MQP Dated: August 31, 2009 Received: September 01, 2009

Dear Mr. Hull:

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. 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.

MAR ~ 4 2010

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

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Page 2 - Mr. Matthew M. Hull, RAC

CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); 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 advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely vours.

Sincerely, yours,

Mark A. Wilkerson

Mark N. Melkerson Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Page 1 of 1

INDICATIONS FOR USE STATEMENT A.

KUS 31860 510(k) Number:_

Device Name:

Indications for Use:

The Aesculap HydroLift VBR System is indicated for use in the thoracolumbar spine (T1 to L5) for partial or total replacement of a collapsed, or unstable vertebral body due to tumor or trauma (i.e. fracture). The Aesculap HydroLift VBR System is intended for use with supplemental spinal fixation systems such as the Aesculap MACS TL or S4 Systems. The Aesculap HydroLift VBR System may be used with bone graft. The Aesculap HydroLift VBR System is designed to provide anterior spinal column support even in the absence of fusion for a prolonged period.

Prescription Use (per 21 CFR 801.109)

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)

IMAGE

(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices

510(k) NumberK083186
------------------------

002

§ 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.