(105 days)
The SpineMedica Paradís Vaso Shield™ is indicated as a cover for vessels following anterior vertebral surgery.
The SpineMedica Paradís Vaso Shield™ is a flexible sheet of 30 Wt.% polyvinyl alcohol (PVA) material with dimensions of 60 ±6 mm X 100 ±10 mm and a thickness of 1.0 ±0.2 mm. The corners of the sheet are rounded. There are no holes or perforations. There are no markings on either side of the sheet, raised (embossed) or printed. The sheet is provided sterile and hydrated in saline solution.
Here's an analysis of the provided text regarding the SpineMedica Paradís Vaso Shield™:
Acceptance Criteria and Study for SpineMedica Paradís Vaso Shield™
This 510(k) summary for the SpineMedica Paradís Vaso Shield™ largely focuses on establishing substantial equivalence to predicate devices rather than proving specific numerical performance metrics through a clinical study with predefined acceptance criteria. The "studies" mentioned are primarily non-clinical evaluations to demonstrate safety and effectiveness in line with its function as a vessel cover.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Acceptance Criteria | Reported Device Performance |
|---|---|---|
| Biocompatibility | Acceptable for use as a permanently implanted device. | Testing completed; "acceptable biocompatibility" for permanent implantation. |
| Simulated Clinical Env. | Device design meets user needs. | "Evaluated in a simulated clinical environment to demonstrate that the design of the device meets the needs of the user." |
| Dimensional Analysis | Within specified tolerances: 60 ±6 mm X 100 ±10 mm, thickness 1.0 ±0.2 mm. | "All testing results met required acceptance criteria." (Implies dimensions were within spec). |
| Package Integrity | Maintain sterility and product quality. | "All testing results met required acceptance criteria." |
| Suture Pull Out Strength | Sufficient to maintain device position and integrity. | "All testing results met required acceptance criteria." |
| Pyrogenicity | Non-pyrogenic (i.e., does not cause fever). | "All testing results met required acceptance criteria." |
| Shelf-Life | Maintain properties and sterility over time. | "All testing results met required acceptance criteria." (Initially cleared with a 6-month shelf life). |
| Distribution Simulation | Withstand typical shipping and handling. | "All testing results met required acceptance criteria." |
| Environmental Conditioning | Maintain properties under various environmental conditions. | "All testing results met required acceptance criteria." |
| Sterilization Validation | Achieve and maintain sterility. | "All testing results met required acceptance criteria." |
| Substantial Equivalence | Demonstrated to be substantially equivalent to previously cleared devices. | Shown to be substantially equivalent to predicate devices with the same indications for use, design, function, and/or materials. |
2. Sample Size Used for the Test Set and Data Provenance
The provided text does not specify sample sizes for any of the non-clinical tests. Since these were laboratory and engineering tests, the concept of "data provenance" (country of origin, retrospective/prospective) in the clinical sense doesn't directly apply here. The tests were likely conducted in a controlled laboratory environment.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
This information is not provided in the document. For non-clinical tests like dimensional analysis or biocompatibility, "ground truth" is typically established by validated testing methods and adherence to recognized standards, rather than expert consensus in the way it's used for diagnostic imaging studies.
4. Adjudication Method for the Test Set
This information is not applicable and not provided. Adjudication methods are typically used in clinical studies involving interpretation of data (e.g., medical images) by multiple experts. The tests performed for this device were primarily objective engineering or biological assessments.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, Effect Size of AI vs. Without AI Assistance
No. This device is a physical medical device (vessel shield), not an AI-powered diagnostic or assistive technology. Therefore, an MRMC study comparing human readers with and without AI assistance is not relevant and was not performed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
No. As noted above, this is a physical medical device, not an algorithm.
7. The Type of Ground Truth Used
For the non-clinical tests:
- Engineering Specifications: For dimensional analysis, package integrity, suture pull out strength, shelf-life, distribution simulation, environmental conditioning, and sterilization validation, the ground truth was established by predetermined engineering specifications, national/international standards, and regulatory requirements (e.g., ISO standards for biocompatibility/sterilization).
- Biological Response: For biocompatibility and pyrogenicity, ground truth was established by observing the biological response of cells/animals to the material in accordance with established biological safety testing protocols (e.g., ISO 10993 series).
- User Feedback (simulated clinical environment): For the simulated clinical environment, ground truth was likely based on user (surgeon) feedback and assessments that the device's design met their needs, though the specifics of this evaluation are not detailed.
8. The Sample Size for the Training Set
This information is not applicable and not provided. As a physical device, there is no "training set" in the context of machine learning or AI algorithms. The design and manufacturing process would be informed by material science, engineering principles, and clinical need.
9. How the Ground Truth for the Training Set was Established
This information is not applicable and not provided. There is no "training set" for this type of device.
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510(k) Summary
APR 2 0 2009
| Contact: | Donald W. GuthnerOrgenix, LLC111 Hill RoadDouglassville, PA 19518(646) 460-2984 |
|---|---|
| Device Trade Name: | Paradís Vaso Shield™ |
| Manufacturer: | SpineMedica, LLC811 Livingstone Court, Suite EMarietta, GA 30067 |
| Classification: | 21 CFR §TBD, Vessel Guard |
| Class: | II |
| Product Code: | MFX |
Indications For Use:
The SpineMedica Paradís Vaso Shield™ is indicated as a cover for vessels following anterior vertebral surgery.
Device Description:
The SpineMedica Paradís Vaso Shield™ is a flexible sheet of 30 Wt.% polyvinyl alcohol (PVA) material with dimensions of 60 ±6 mm X 100 ±10 mm and a thickness of 1.0 ±0.2 mm. The corners of the sheet are rounded. There are no holes or perforations. There are no markings on either side of the sheet, raised (embossed) or printed. The sheet is provided sterile and hydrated in saline solution.
Predicate Device(s):
The SpineMedica Paradis Vaso Shield™ was shown to be substantially equivalent to previously cleared devices and has the same indications for use, design, function, and/or materials.
Performance Standards:
Testing performed indicates the SpineMedica Paradis Vaso Shield™ is substantially equivalent to predicate devices.
Summary of Safety and Effectiveness:
As part of the Pre-market Notification (510(k)) submission, non-clinical evaluation of the SpineMedica Paradis Vaso Shield™ included the following to establish safety and effectiveness:
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a. Biocompatibility Testing
Testing was completed to verify that the SpineMedica Paradis Vaso Shield™ composed of the SpineMedica hydrogel has acceptable biocompatibility for use as a permanently implanted device.
b. Evaluation of Device in a Simulated Clinical Environment The SpineMedica Paradis Vaso Shield™ was evaluated in a simulated clinical environment to demonstrate that the design of the device meets the needs of the user.
c. Clinical Literature Review A clinical literature review was conducted to validate the design of the SpineMedica Paradís Vaso Shield™.
d. Other Testing
Other testing included: dimensional analysis, package integrity, suture pull out strength, pyrogenicity, shelf-life, distribution simulation, environmental conditioning, and sterilization validation. All testing results met required acceptance criteria.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 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" arranged around the perimeter. Inside the circle is an abstract symbol resembling an eagle or bird in flight, composed of three curved lines.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
APR 2 0 2009
SpineMedica, LLC c/o Mr. Donald W. Guthner Orgenix, LLC 111 Hill Road Douglassville, PA 19518
Re: K090022
Trade Name: SpineMedica Paradís Vaso ShieldTM Regulation Number: 870.3470. Regulation Name: Intracardiac patch or pledget Regulatory Class: II (Two) Product Code: OMR Dated: April 14, 2009 Received: April 16, 2009
Dear Mr. Guthner:
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 with a 6 month shelf life, 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.
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 Warnings section of the device's labeling and any promotional materials:
The safety and effectiveness of this device for reducing the incidence, severity, and extent of post-operative adhesion formation have not been established.
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Furthermore, the indication for use as a cover for vessels following anterior vertebral surgery must be prominently displayed in all labeling, including pouch box, and carton labels, instructions for use, and other promotional materials, in close proximity to the trade name, of a similar point size, and in bold print.
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 (OS) 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 (240) 276-0120. 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
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toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Vacerth
Donna-Bea Tillman, Ph.D., M.P.A. Director Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Page 4 - Mr. Donald W. Guthner
Indications for Use
510(k) Number (if known): K090022
Device Name: SpineMedica Paradís Vaso Shield™
1
Indications For Use: The Paradís Vaso Shield™ is indicated for use as a cover for vessels following anterior vertebral surgery.
Prescription Use > (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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§ 870.3470 Intracardiac patch or pledget made of polypropylene, polyethylene terephthalate, or polytetrafluoroethylene.
(a)
Identification. An intracardiac patch or pledget made of polypropylene, polyethylene terephthalate, or polytetrafluoroethylene is a fabric device placed in the heart that is used to repair septal defects, for patch grafting, to repair tissue, and to buttress sutures.(b)
Classification. Class II (performance standards).