(116 days)
InFill® interbody fusion device is indicated for intervertebral body fusion of the spine in skeletally mature patients. InFill® interbody fusion device is designed for use with autogenous bone graft to facilitate fusion. InFill® interbody fusion device is intended for use at either one level or two contiguous levels in the lumbar spine, from L2 to S1, for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The lumbar devices are to be used in patients who have had at least six months of non-operative treatment. InFill® interbody fusion device is intended to be used with supplemental internal spinal fixation systems that are cleared by the FDA for use in the lumbar spine. These implants may be implanted via a variety of open or minimally invasive approaches. These approaches include anterior, lateral and transforaminal.
The InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF are radiolucent implantable devices manufactured from PEEK and tantalum (marker material). The implants are available in various sizes to suit the individual pathology and anatomical conditions of the patient. The InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF are provided sterile, for single use only.
Here's a breakdown of the acceptance criteria and study information for the InFill® Interbody Fusion Devices, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criterion (Performance Area) | Performance Standard / Test Type | Reported Device Performance |
|---|---|---|
| Mechanical Stability | Static Compression (ASTM F2077) | "All necessary performance testing... has been completed" |
| Dynamic Loading | Dynamic Compression (ASTM F2077) | "All necessary performance testing... has been completed" |
| Resistance to Subsidence | Static Subsidence (ASTM F2267) | "All necessary performance testing... has been completed" |
| Resistance to Expulsion | Expulsion (Specific ASTM standard not specified) | "All necessary performance testing... has been completed" |
| Substantial Equivalence | Comparison to predicate devices for: | Determined to be substantially equivalent to existing legally marketed devices. |
| - Intended Use | Similar | |
| - Principal of Operation | Similar | |
| - Technological Characteristics (Shape, bone-implant surface, bone graft support, primary implant material, surgical approach) | Similar (as illustrated in the technical characteristics table) |
2. Sample Size Used for the Test Set and Data Provenance
The provided text does not contain information regarding the sample size used for the test set (if applicable to the type of testing performed, i.e., clinical trials) or the data provenance (country of origin, retrospective/prospective). The performance data cited refers to mechanical testing, not clinical studies with patients.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This information is not applicable to this submission. The submission describes a device for intervertebral body fusion, and the testing outlined is primarily mechanical. There is no mention of establishing ground truth by expert consensus related to clinical outcomes or imaging interpretation.
4. Adjudication Method for the Test Set
This information is not applicable for the same reasons as point 3. The data presented is from mechanical performance testing, not studies requiring expert adjudication of results.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This type of study is typically associated with AI/CAD systems that assist human readers in interpreting medical images. The device in question is an implantable medical device, not an AI diagnostic tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone performance study in the context of an algorithm or AI system was not done. The device is a physical implant, not a software algorithm.
7. The Type of Ground Truth Used
For the mechanical testing, the "ground truth" would be the physical measurements and observations of the device's performance against established ASTM (American Society for Testing and Materials) standards. These standards define the acceptable range or thresholds for properties like compression strength, subsidence, and expulsion resistance.
8. The Sample Size for the Training Set
This information is not applicable. There is no mention of a "training set" as this device is a physical implant and not an AI/machine learning model.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable for the same reason as point 8.
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MAR 3 1 2014
6. 510(k) Summary
This 510(k) summary information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
| APPLICANT: | Pinnacle Spine Group, LLC |
|---|---|
| DATE PREPARED: | March 22, 2014 |
| CONTACT PERSON: | Rebecca K Pine1601 Elm Street, Suite 1930Dallas, TX 75201Phone: 760.809.5178Fax: 760.290.3216 |
| TRADE NAME: | InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and theInFill® 60-ALIF |
| COMMON NAME: | Spinal Implant |
| CLASSIFICATION NAME: | Intervertebral Body Fusion Device |
| DEVICE CLASSIFICATION: | Class II |
| REGULATION NUMBER | 888.3080 (product code: MAX) |
| PREDICATE DEVICES: | InFill Interbody Fusion Device (K103729, K121733, K124012)Novel TL Spinal Spacer System, (K080699)Calix-A Lumbar Spinal Implant System (K131350) |
Substantially Equivalent To:
The InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF devices are substantially equivalent in intended use, principal of operation and technological characteristics to the InFill Interbody Fusion Device, Novel Spinal Spacer System and the Calix-A Lumbar Spinal Implant System.
Description of the Device Subject to Premarket Notification:
The InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF are radiolucent implantable devices manufactured from PEEK and tantalum (marker material). The implants are available in various sizes to suit the individual pathology and anatomical conditions of the patient.
. The InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF are provided sterile, for single use
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only.
Indication for Use:
InFill® interbody fusion device is indicated for intervertebral body fusion of the spine in skeletally mature patients. InFill® interbody fusion device is designed for use with autogenous bone graft to facilitate fusion. InFill® interbody fusion device is intended for use at either one level or two contiguous levels in the lumbar spine, from L2 to S1, for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The lumbar devices are to be used in patients who have had at least six months of non-operative treatment. InFill® interbody fusion device is intended to be used with supplemental internal spinal fixation systems that are cleared by the FDA for use in the lumbar spine. These implants may be implanted via a variety of open or minimally invasive approaches. These approaches include anterior, lateral and transforaminal.
Technical Characteristics:
The InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF have similar physical and technical characteristics to the predicate devices, as illustrated in the table below.
| TechnicalCharacteristics | In Fill®intervertebralbody fusiondevices, (41-TLIF ConvexOblique, 43-/44-TLIFContourOblique, 60-ALIF) | In Fill®intervertebralbody fusiondevice(K103729,K121733,K124012) | Novel TLSpinal SpacerSystem,(K080699) | Calix-ALumbarSpinalImplantSystem(K131350) | BiometEnclave(K081636) |
|---|---|---|---|---|---|
| Shape | Box-shaped,bullet noseOval shape,bullet noseBanana-shaped,bullet nosed | Box-shaped,bullet nose | Banana-shaped,bullet nosed | Oval shape,bullet nose | Ovalshape,bullet nose |
| Bone to implantsurface | Surface teeth | SAME | SAME | SAME | SAME |
| Bone graftsupport feature | Centralfenestration | SAME | SAME | SAME | SAME |
| Primaryimplantmaterial | PEEK OPTIMA® | SAME | SAME | SAME | SAME |
| SurgicalApproach | TransforaminalAnterior | LateralTransforaminal | Transforaminal | Anterior | Anterior |
Pinnacle Spine Group, LLC InFill® Product Family
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Performance Data:
All necessary performance testing, has been completed for the InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF devices including static/dynamic compression (ASTM F2077), static subsidence (ASTM F2267) and expulsion to assure substantial equivalence to the predicate devices.
Basis for Determination of Substantial Equivalence:
Upon reviewing the performance data provided in this submission and comparing intended use, design, materials, principle of operation and overall technological characteristics, the InFill® 41-TLIF Convex Oblique device, InFill® 43-TLIF Contour Oblique, InFill® 44-TLIF Contour Oblique and the InFill® 60-ALIF devices are determined by Pinnacle Spine Group, LLC, to be substantially equivalent to existing legally marketed devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 31, 2014
Pinnacle Spine Group, LLC % Ms. Rebecca K. Pine Consultant 1601 Elm Street, Suite 1930 Dallas, Texas 75201
Re: K133721
Trade/Device Name: Infill® Interbody Fusion Devices (Infill® 41-TLIF Convex Oblique, Infill® 43-TLIF Contour Oblique, Infill® 44-TLIF Contour Oblique, and the Infill® 60-ALIF)
Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: January 9, 2014 Received: January 10, 2014
Dear Ms. Pine:
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 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
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Page 2 - Ms. Rebecca K. Pine
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 contact the Division of Small Manufacturers. International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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/McdicalDevices/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/ResourcesforYou/Industry/default.htm.
Sincerely yours.
Ronald P. Jean -S for
Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K133721
Device Name InFill® Interbody Fusion Devices
Indications for Use (Describe)
InFill® interbody fusion device is indicated for intervertebral body fusion of the spine in skeletally mature patients. InFill® interbody fusion device is designed for use with autogenous bone graft to facilitate fusion. InFill® interbody fusion device is intended for use at either one levels in the lumbar spine, from L2 to S1, for the treatment of degenerative disc disease (DD) with up to Grade I spondylolisthesis. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The lumbardevices are to be used in patients who have had at least six months of non-operative treatment. InFill® interbody fusion device is intended to be used with supplemental internal spinal fixation systems that are cleared by the FDA for use in the lumbar spine. These implants may be implanted via a variety of open or minimally invasive approaches. These approaches include anterior, lateral and transforaminal.
Type of Use (Select one or both, as applicable)
2 Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
球的方法: 大利亚 FOR FDA USE ONLY ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
Anton E. Dmitriev, PhD
Division of Orthopedic Devices
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§ 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.