K Number
K102937
Device Name
OSTEOPHIL BETA-TCP
Manufacturer
Date Cleared
2010-12-27

(84 days)

Product Code
Regulation Number
888.3045
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Osteophil B-TCP is a resorbable bone void filler intended to fill bony void or gaps of the extremities, posterolateral spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.
Device Description
Osteophil B-TCP is a porous calcium phosphate resorbable bone void filler for the repair of bony defects. The product consists of beta-Tricalcium Phosphate and is about 80% porous. The product is provided sterile and is available in granules 1-4 mm². Osteophil B-TCP has a multidirectional interconnected porosity structure, similar to that of human cancellous bone. Osteophil B-TCP slowly resorbs during the remodeling and bone defect repair process and is progressively replaced with bone and soft tissues. The progressive resorption of Osteophil B-TCP resorbable bone filler is intended to prevent premature resorption.
More Information

Not Found

No
The summary describes a bone void filler made of calcium phosphate with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is a bone void filler intended to fill bony voids or gaps caused by trauma or surgery, thereby aiding in the repair and remodeling process of bone defects. This function aligns with the definition of a therapeutic device designed to treat or alleviate a condition.

No

Explanation: This device is a bone void filler used to treat bony defects, not to diagnose a condition.

No

The device description clearly states it is a porous calcium phosphate resorbable bone void filler, which is a physical material, not software.

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 Osteophil B-TCP is a "resorbable bone void filler intended to fill bony void or gaps...". This describes a device that is implanted or used directly on the patient's body to facilitate bone repair.
  • Device Description: The description details the material (beta-Tricalcium Phosphate), structure (porous), and function (resorption and replacement with bone/soft tissues). This aligns with a medical device used in surgical procedures, not a diagnostic test performed on samples outside the body.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting specific analytes, or providing diagnostic information about a patient's health status.

IVDs are devices used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. Osteophil B-TCP does not fit this definition.

N/A

Intended Use / Indications for Use

Osteophil B-TCP is a resorbable bone void filler intended to fill bony void or gaps of the extremities, posterolateral spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.

Product codes (comma separated list FDA assigned to the subject device)

MQV

Device Description

Osteophil B-TCP is a porous calcium phosphate resorbable bone void filler for the repair of bony defects. The product consists of beta-Tricalcium Phosphate and is about 80% porous. The product is provided sterile and is available in granules 1-4 mm².

Osteophil B-TCP has a multidirectional interconnected porosity structure, similar to that of human cancellous bone. Osteophil B-TCP slowly resorbs during the remodeling and bone defect repair process and is progressively replaced with bone and soft tissues. The progressive resorption of Osteophil B-TCP resorbable bone filler is intended to prevent premature resorption.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

extremities, posterolateral 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)

The characteristics were evaluated by performing testing using standardized laboratory test methods. The test results demonstrate the substantial equivalence of the technical characteristics of Osteophil B-TCP to the predicate.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K050357

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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.

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Chapter 5 510(k) Summary [per 21 CFR 807.92(c)]

r

5. 510(k) Summary as required by section 807.92(c)DEC 27 2010
5.1. FDA Contact Person5.3. 510(k) Preparer/submitter
Victor BowersVictor Bowers
VP Medical AffairsVP Medical Affairs
Phone (262) 642-2765
Cell (262) 581-5161
Fax (262) 642-2745
Email vbowers@cytophil.comCytophil, Inc.
5.2. 510(k) Owner2485 Corporate Circle, Suite 2
William G. Hubbard Ph.D.East Troy, WI 53120
President & CEOPhone (262)642-2765
Cytophil, Inc.Cell (262) 581-5161
2485 Corporate Circle, Suite 2Fax (262) 624-2745
East Troy, WI 53120Email vbowers@cytophil.com
Phone (262)642-2765
Cell (262) 757-3081
Fax (262) 624-2745
Email bhubbard@cytophil.com
[807.92(a)(1)]
5.4. Device Name[per 807.92(a)(2)]
Trade (proprietary) name :Osteophil B-TCP
Common name:Synthetic Bone Graft Material

Resorbable Calcium Salt Bone Void Filler Classification name:

5.5. Legally Marketed device to which your firm is claiming equivalence [807.92(a)(3)]

f

1

Equivalent legally marketed Device title510(k) number
CAMCERAM TCPK050357

5.6. Description of the device [807.92(a)(4)]

Osteophil B-TCP is a porous calcium phosphate resorbable bone void filler for the repair of bony defects. The product consists of beta-Tricalcium Phosphate and is about 80% porous. The product is provided sterile and is available in granules 1-4 mm².

Osteophil B-TCP has a multidirectional interconnected porosity structure, similar to that of human cancellous bone. Osteophil B-TCP slowly resorbs during the remodeling and bone defect repair process and is progressively replaced with bone and soft tissues. The progressive resorption of Osteophil B-TCP resorbable bone filler is intended to prevent premature resorption.

5.7. Intended use of the device [807.92(a)(5)]

Osteophil B-TCP is a resorbable bone void filler intended to fill bony void or gaps of the extremities, posterolateral spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.

This intended use of the device is identical to and, therefore, equivalent to predicate K050357 -CAMCERAM TCP.

5.8. Summary of the technological characteristics of your device compared to the predicate device. [807.92(a)(6)]

Osteophil B-TCP has the same technological characteristics (i.e., design, material, chemical composition, energy source) as the predicate device, K050357 - CAMCERAM TCP. Following is a summary of the technological characteristics of Osteophil B-TCP in comparison to those of the predicate device, K050357 - CAMCERAM TCP.

CharacteristicSubstantially Equivalent?Impact on Safety & Performance
Device
DesignYESNone
Material CharacterizationYESNone
BiocompatibilityYESNone
SterilizationYESNone
Physical Properties
Identification of Device MaterialYESNone
AdditivesNANA
Ca/Phosphorus RatioYESNone

² 1-4 mm equals 1000 – 4000 um

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Elemental AnalysisYESNone
X-Ray Diffraction PatternsYESNone
Dimensional SpecificationsYESNone
Physical Form of the DeviceYESNone
Device DensityYESNone
Device MassYESNone
Device VolumeYESNone
Device Porosity
• Total Porous VolumeYESNone
• Pore DiameterYESNone
• InterconnectednessYESNone
pH TestingYESNone
Dissolution Testing (mg/L/hr)YESNone
Energy SourceNANA

Osteophil B-TCP has substantially equivalent critical specifications as CAMCERAM TCP -K050357.

Osteophil B-TCP has substantially equivalent technical characteristics as the predicate K050357 -CAMCERAM TCP. The chemical and physical characteristics are compared in section 11.2. These characteristics include the following:

  • . Chemical Composition by XRD spectra
    • o Phases present
    • o Ca:P ratio
  • . Physical Properties
    • o Physical Form
    • Dimensional Specifications o
    • Porosity o
    • Bulk density o
  • . Performance Testing
    • o pH
    • o In vitro dissolution rate
    • Animal testing to determine bone in-growth and resorption of the implant over o time

The characteristics were evaluated by performing testing using standardized laboratory test methods. The test results demonstrate the substantial equivalence of the technical characteristics of Osteophil B-TCP to the predicate.

3

Image /page/3/Picture/0 description: The image shows a logo for the Department of Health & Human Services. The logo features a stylized eagle or bird-like symbol with three curved lines forming its body and wings. The text "DEPARTMENT OF HEALTH & S" is arranged vertically along the left side of the logo.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

Cytophil, Inc. % Victor M. Bowers 2485 Corporate Circle, Suite 2 East Troy. WI 53120

DEC 2 7 2010

Re: K102937

Trade/Device Name: Osteophil B-TCP Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MQV Dated: September 28, 2010 Received: October 4, 2010

Dear Mr. Bowers:

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. Ilsting 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 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); 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.

4

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutlTDA/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 yours.

Neil Ogden for

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

Enclosure

5

4. Indication for Use Statement

DEC 2 7 2010

4.1. 510(k) Number

(If known): K 102937

4.2. Device Name

Osteophil B-TCP

4.3. Indications for Use

Osteophil B-TCP is a resorbable bone void filler intended to fill bony void or gaps of the extremities, posterolateral spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use X or Over-the-Counter Use _ [Per 21 CFR 801.109]

Nilk & Oyler
(Division Sign-Off)
for mxm

Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K102937