K Number
K103814
Device Name
PEZO INTERBODY CAGES SYSTEM
Date Cleared
2011-03-17

(78 days)

Product Code
Regulation Number
888.3080
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
pezo™ is indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of non-operative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The device is intended for use with supplemental fixation and with autograft to facilitate fusion.
Device Description
The pezo™ PEEK Cage Family is comprised of three principal interbody fusion cages. The pezo-P and pezo-T devices have a basic rectangular shape while the pezo-A devices have a basic kidney shape. All implants have a hollow center for placement of autograft. The pezo implants are available in an assortment of height, length, width and anteroposterior angulation combinations to accommodate a variety of anatomic requirements.
More Information

P960025, P950019, K073470, K082014, K083661, K090166

Not Found

No
The summary describes a physical implant (PEEK cage) and its mechanical testing, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is an intervertebral body fusion cage intended to facilitate fusion in patients with degenerative disc disease, directly treating a medical condition.

No

Explanation: The provided text describes the pezo™ device as an intervertebral body fusion cage intended for surgical implantation to facilitate fusion in patients with degenerative disc disease. Its purpose is therapeutic (fusion), not diagnostic (identifying or characterizing a medical condition).

No

The device description clearly states that the device is comprised of "three principal interbody fusion cages" made of PEEK, which are physical implants.

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 for intervertebral body fusion of the lumbar spine. This is a surgical procedure performed in vivo (within the body) to treat a structural issue.
  • Device Description: The device is described as a PEEK Cage Family designed to be implanted into the spine. This is a physical implant, not a reagent, instrument, or system used to examine specimens in vitro (outside the body).
  • No mention of in vitro testing: The document does not mention any analysis of biological samples (blood, urine, tissue, etc.) or any diagnostic testing performed outside the body.
  • Focus on mechanical performance: The performance studies described are mechanical tests (static dynamic compression, subsidence) relevant to the structural integrity and function of an implant, not diagnostic accuracy.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device is a therapeutic implant used to facilitate fusion within the body.

N/A

Intended Use / Indications for Use

pezo™ is indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of non-operative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The device is intended for use with supplemental fixation and with autograft to facilitate fusion.

Product codes

MAX

Device Description

The pezo™ PEEK Cage Family is comprised of three principal interbody fusion cages. The pezo-P and pezo-T devices have a basic rectangular shape while the pezo-A devices have a basic kidney shape. All implants have a hollow center for placement of autograft. The pezo implants are available in an assortment of height, length, width and anteroposterior angulation combinations to accommodate a variety of anatomic requirements.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

lumbar spine, from L2 to S1

Indicated Patient Age Range

skeletally mature patients

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

Mechanical testing of the worst case pezo™ device included static dynamic compression according to ASTM and F2077 and subsidence according to ASTM F2267.

The mechanical test results demonstrate that pezo™ performs as well as or better than the predicate devices and therefore that the device is as safe and as effective as the predicates.

Key Metrics

Not Found

Predicate Device(s)

P960025, P950019, K073470, K082014, K083661, K090166

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3080 Intervertebral body fusion device.

(a)
Identification. An intervertebral body fusion device is an implanted single or multiple component spinal device made from a variety of materials, including titanium and polymers. The device is inserted into the intervertebral body space of the cervical or lumbosacral spine, and is intended for intervertebral body fusion.(b)
Classification. (1) Class II (special controls) for intervertebral body fusion devices that contain bone grafting material. The special control is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intervertebral Body Fusion Device.” See § 888.1(e) for the availability of this guidance document.(2) Class III (premarket approval) for intervertebral body fusion devices that include any therapeutic biologic (e.g., bone morphogenic protein). Intervertebral body fusion devices that contain any therapeutic biologic require premarket approval.
(c)
Date premarket approval application (PMA) or notice of product development protocol (PDP) is required. Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.

0

KIO3814

MAR 1 7 2011

Image /page/0/Picture/2 description: The image shows the logo for Ulrich medical USA. The logo consists of the word "Ulrich" in a bold, sans-serif font, with the "U" stylized to appear as if it is emerging from a black square. Below the word "Ulrich" is the phrase "medical USA" in a smaller, sans-serif font.

510(k) Summary

Date:22 December 2010
Sponsor:ulrich GmbH & Co. KG
Buchbrunnenweg 12
89081 Ulm
Germany
Phone: +49 (0) 731-9654-1304
Fax: +49 (0) 731-9654-2802
Contact Person:Hans Stover
ulrich medical USA, Inc.
612 Trade Center Blvd.
Chesterfield, MO 63005
(636) 519-0268 Office
(636) 519-0271 Fax
Proposed Trade
Name:pezo™ PEEK Cage Family
Device ClassificationClass II
Classification Name:Intervertebral body fusion device
Regulation:888.3080
Device Product
Code:MAX
Device Description:The pezo™ PEEK Cage Family is comprised of three principal
interbody fusion cages. The pezo-P and pezo-T devices have a
basic rectangular shape while the pezo-A devices have a basic
kidney shape. All implants have a hollow center for placement of
autograft. The pezo implants are available in an assortment of
height, length, width and anteroposterior angulation combinations to
accommodate a variety of anatomic requirements.
Intended Use:pezo™ is indicated for intervertebral body fusion of the lumbar spine,
from L2 to S1, in skeletally mature patients who have had six months
of non-operative treatment. The device is intended for use at either
one level or two contiguous levels for the treatment of degenerative
disc disease (DDD) with up to Grade I spondylolisthesis or
retrolisthesis. DDD is defined as back pain of discogenic origin with
degeneration of the disc confirmed by history and radiographic
studies. The device is intended for use with supplemental fixation
and with autograft to facilitate fusion.
Materials:pezo™ components are manufactured from polyetheretherketone
(PEEK Optima LT1) as described by ASTM F2026. Integral markers
are manufactured from tantalum according to ASTM F560.

. :

Pg 1 of 2

1

K103814

Predicate Devices:

Technological Characteristics:

Lumbar I/F Cage® (P960025)

Ray TFC™ Device (P950019)

AVS PEEK Spacers (K073470, K082014, K083661 and K090166)

pezo™ possesses the same technological characteristics as one or more of the predicate devices. These include:

  • . intended use (as described above)
  • basic design (hollow structure for the containment of autograft), .
  • . material (polymer),
  • sizes (dimensions are comparable to those offered by the . predicate systems) and

The fundamental scientific technology of pezo™ is the same as previously cleared devices.

Performance Data:

Mechanical testing of the worst case pezo™ device included static dynamic compression according to ASTM and F2077 and subsidence according to ASTM F2267.

The mechanical test results demonstrate that pezo™ performs as well as or better than the predicate devices and therefore that the device is as safe and as effective as the predicates.

Confidential: pezo
TM Family

2

Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter of the circle. In the center of the circle is an abstract image of an eagle.

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

ulrich GmbH & Co. KG % ulrich medical USA. Inc. Mr. Hans Stover President and CEO 612 Trade Center Boulevard Chesterfield, Missouri 63005

MAR 1 7 2011

Re: K103814

Trade/Device Name: pezo™ PEEK Cage Family Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: December 22, 2010 Received: December 29, 2010

Dear Mr. Stover:

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.

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

3

Page 2 - Mr. Hans Stover

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/ReportalProblem/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/ResourcesforYou/Industry/default.htm.

Sincerely yours,

A
for
B.R h

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

Enclosure

4

Indications for Use Statement

510(k) Number:_K103814

Device Name: pezo™ PEEK Cage Family

Indications for Use:

pezo™ is indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of non-operative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis, DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The device is intended for use with supplemental fixation and with autograft to facilitate fusion.

Prescription Use _ X (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)

Division Sign-Off

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

KI03814 510(k) Number.