K Number
K123167
Device Name
DEPUY PULSE ANTERIOR CERVICAL IN-LINE PLATE SYSTEM
Date Cleared
2012-12-28

(80 days)

Product Code
Regulation Number
888.3060
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The DePuy PULSE Anterior Cervical In-Line Plate System is intended for anterior cervical intervertebral body fixation. This system is indicated for patients in which stability is desired following anterior cervical fusion for the indications listed below. The intended levels for treatment range from C2 to T1. Indication includes symptomatic cervical spondylosis, trauma, fracture, post-traumatic kyphosis or lordosis, tumor, degenerative disc disease (defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies), spinal stenosis, re-operation for failed fusion, or instability following surgery for the above indications.
Device Description
The DePuy PULSE Anterior Cervical In-Line Plate System is intended for anterior screw fixation of the plate to the cervical spine. The fixation construct consists of a cervical plate that is attached to the vertebral body of the cervical spine with bone screws using an anterior approach. The DePuy PULSE Anterior Cervical In-Line Plate System consists of an assortment of implantable titanium alloy plates and screws in various sizes.
More Information

Not Found

No
The summary describes a mechanical implant system for spinal fixation and does not mention any AI/ML components or capabilities.

Yes.

This device is designed to provide stability following anterior cervical fusion for various medical conditions, including symptomatic cervical spondylosis, trauma, fracture, and degenerative disc disease, which are all therapeutic interventions.

No
Explanation: The DePuy PULSE Anterior Cervical In-Line Plate System is described as a system for anterior cervical intervertebral body fixation, which is a treatment or therapeutic device, not one used for diagnosis. Its purpose is to provide stability following anterior cervical fusion, and its description focuses on implants and mechanical tests, not on detecting or identifying medical conditions.

No

The device description explicitly states it consists of "implantable titanium alloy plates and screws," which are hardware components, not software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health. These tests are performed outside the body (in vitro).
  • Device Description: The DePuy PULSE Anterior Cervical In-Line Plate System is an implantable device designed for surgical fixation of the cervical spine. It is physically placed inside the body during surgery.
  • Intended Use: The intended use is for anterior cervical intervertebral body fixation, which is a surgical procedure.

The information provided clearly describes a surgical implant, not a device used for testing biological samples in a laboratory setting.

N/A

Intended Use / Indications for Use

The DePuy PULSE Anterior Cervical In-Line Plate System is intended for anterior cervical intervertebral body fixation. This system is indicated for patients in which stability is desired following anterior cervical fusion for the indications listed below. The intended levels for treatment range from C2 to T1.

Indication includes symptomatic cervical spondylosis, trauma, fracture, post-traumatic kyphosis or lordosis, tumor, degenerative disc disease (defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies), spinal stenosis, re-operation for failed fusion, or instability following surgery for the above indications.

Product codes

KWQ

Device Description

The DePuy PULSE Anterior Cervical In-Line Plate System is intended for anterior screw fixation of the plate to the cervical spine. The fixation construct consists of a cervical plate that is attached to the vertebral body of the cervical spine with bone screws using an anterior approach. The DePuy PULSE Anterior Cervical In-Line Plate System consists of an assortment of implantable titanium alloy plates and screws in various sizes.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cervical spine, C2 to T1

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 following mechanical tests were conducted:
• Static compression bending testing in accordance with ASTM F-1717 Standard Test Method for Spinal Implant Constructs in a Vertebrectomy Model. The acceptance criteria was/were met.
• Static torsion testing in accordance with ASTM F-1717 Standard Test Method for Spinal Implant Constructs in a Vertebrectomy Model. The acceptance criteria was/were met.
• Dynamic compression bending testing in accordance with ASTM F-1717 Standard Test Method for Spinal Implant Constructs in a Vertebrectomy Model. The acceptance criteria was/were met.
No clinical tests were performed.

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

Not Found

Predicate Device(s)

K914362, K042544, K103491, K112724

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

510(K) SUMMARY

Submitter:

Medos International Sàrl Chemin-Blanc 38 Le Locle, CH-NE 2400, Switzerland

Contact Person:

Eugene Bang Regulatory Affairs Associate Voice: (508) 977-3966 (508) 828-3797 Fax:

October 8, 2012

Class II

KWQ

888.3060

Date Prepared: Trade Name: Device Class: Product Code(s): Common Name: Classification Name: Regulation Number:

Predicate Devices:

Device Description:

AcroPlate Anterior Cervical Plate System (DePuy Spine) - K914362 Uniplate Anterior Cervical Plate System (DePuy Spine) - K042544 Skyline Anterior Cervical Plate System (DePuy Spine) - K 103491 PULSE Anterior Cervical Plate System (DePuy Spine) - K112724

DePuy PULSETM Anterior Cervical In-Line Plate System

Appliance, Fixation, Spinal Intervertebral Body

Spinal Intervertebral Body Fixation Orthosis

The DePuy PULSE Anterior Cervical In-Line Plate System is intended for anterior screw fixation of the plate to the cervical spine. The fixation construct consists of a cervical plate that is attached to the vertebral body of the cervical spine with bone screws using an anterior approach. The DePuy PULSE Anterior Cervical In-Line Plate System consists of an assortment of implantable titanium alloy plates and screws in various sizes.

DEC 2 8 2012

1

| Indications: | The DePuy PULSE Anterior Cervical In-Line Plate System is intended for
anterior cervical intervertebral body fixation. This system is indicated for patients
in which stability is desired following anterior cervical fusion for the indications
listed below. The intended levels for treatment range from C2 to T1. |
|------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Indication includes symptomatic cervical spondylosis, trauma, fracture, post-
traumatic kyphosis or lordosis, tumor, degenerative disc disease (defined as
discogenic pain with degeneration of the disc confirmed by history and
radiographic studies), spinal stenosis, re-operation for failed fusion, or instability
following surgery for the above indications. |
| Materials: | Manufactured from titanium alloy (Ti-6Al-4V ELI) per ASTM F-136. |
| Comparison to
Predicate Device: | The substantial equivalence of the subject device to the predicates indentified
above is based upon the equivalence of intended use, design (fundamental
scientific technology), materials, manufacturing methods, performance, sterility,
biocompatibility, safety and packaging design. |
| Non-clinical Test
Summary: | The following mechanical tests were conducted:
• Static compression bending testing in accordance with ASTM F-1717
Standard Test Method for Spinal Implant Constructs in a Vertebrectomy
Model. The acceptance criteria was/were met.
• Static torsion testing in accordance with ASTM F-1717 Standard Test
Method for Spinal Implant Constructs in a Vertebrectomy Model. The
acceptance criteria was/were met.
• Dynamic compression bending testing in accordance with ASTM F-1717
Standard Test Method for Spinal Implant Constructs in a Vertebrectomy
Model. The acceptance criteria was/were met. |
| Clinical Test
Summary: | No clinical tests were performed. |
| Conclusion: | Based on the predicate comparison and testing, the subject device DePuy PULSE
Anterior Cervical In-Line Plate System is substantially equivalent to the
predicate devices. |

and the same of the same of the same of the same of

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. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2

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" around the perimeter. Inside the circle is an abstract symbol resembling an eagle or bird-like figure with three stylized lines forming its body and wings.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002

Letter dated: December 28, 2012

Medos International, Sarl % John & Johnson Company Mr. Eugene Bang Regulatory Affairs Associate 325 Paramount Drive Raynham, Massachusetts 02767

Re: K123167

Trade/Device Name: DePuy PULSE™ Anterior Cervical In-Line Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal Intervertebral Body Fixation Orthosis Regulatory Class: Class II Product Code: KWQ Dated: October 08, 2012 Received: October 09, 2012

Dear Mr. Bang:

We have reviewed your Section 510(k) premarket notification of intent to market the device we nave reviewe 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, de noos that have been 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 manier the Act include requirements for annual registration, listing of I ho general bonators proving practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability addition: Triouse noter, 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 may be subject to additions, 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 I least of advisou that I Drivice and sever device complies with other requirements of the Act that I Dri has made a and regulations administered by other Federal agencies. You must or any I ederal statures and regimments, including, but not limited to: registration and listing (21 Comply with an the Act 8 require mart 801); medical device reporting (reporting of medical CITY att 6077, laboring (21 CFR 803); good manufacturing practice requirements as set

3

Page 2 - Mr. Eugene Bang

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,

Mark N. Melkerson

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

Enclosure

4

INDICATIONS FOR USE STATEMENT

510(k) Number (if known): K123167

Device Name: DePuy PULSE™ Anterior Cervical In-Line Plate System

Indications For Use:

The DePuy PULSE Anterior Cervical In-Line Plate System is intended for anterior cervical intervertebral body fixation. This system is indicated for patients in which stability is desired following anterior cervical fusion for the indications listed below. The intended levels for treatment range from C2 to T1.

Indication includes symptomatic cervical spondylosis, trauma, fracture, post-traumatic kyphosis or lordosis, tumor, degenerative disc disease (defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies), spinal stenosis, re-operation for failed fusion, or instability following surgery for the above indications.

Prescription Use __ X

AND/OR

Over-The-Counter Use _

(Part 21 CFR 801 Subpart D)

(Part 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)

Image /page/4/Picture/13 description: The image shows the name "Colin O'Neill" in a stylized font. The first name, "Colin," is written in a bold, sans-serif font, while the last name, "O'Neill," is written in a similar font but with a more decorative design. The letters in "O'Neill" have a geometric pattern, giving the name a unique and modern look.

(Division Sign-Off) Division of Orthopedic Devices 510(K) Number: K123167