(64 days)
H030009
No
The device description and performance studies focus on mechanical properties and clinical outcomes related to surgical implantation and expansion, with no mention of AI or ML.
Yes
The device is intended to treat Thoracic Insufficiency Syndrome by mechanically stabilizing and correcting thoracic deformities to support respiration and lung growth, which is a therapeutic purpose.
No
The device is described as a mechanical implant (VEPTR/VEPTR II) designed to stabilize and correct thoracic deformities in patients with Thoracic Insufficiency Syndrome, allowing for chest and lung growth. Its function is to treat or manage a condition, not to diagnose it.
No
The device description clearly outlines a physical implantable device made of titanium, designed to mechanically stabilize and correct thoracic deformities. It mentions attachment to ribs, vertebrae, and pelvis, and describes mechanical testing. There is no mention of software as the primary or sole component.
Based on the provided information, the VEPTR/VEPTR II 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, or tissue) to provide information about a person's health.
- VEPTR/VEPTR II Function: The description clearly states that the VEPTR/VEPTR II device is a mechanical implant used to stabilize and correct thoracic deformities and allow for chest and lung growth. It is surgically attached to the patient's ribs, vertebrae, and pelvis.
- Lack of Sample Testing: There is no mention of the device being used to test samples from the body. Its function is entirely structural and mechanical within the patient's body.
Therefore, the VEPTR/VEPTR II device falls under the category of a surgical implant or orthopedic device, not an In Vitro Diagnostic.
N/A
Intended Use / Indications for Use
The VEPTR/VEPTR II device is indicated for skeletally immature patients with severe, progressive spinal deformities and/or three dimensional deformity of the thorax associated with or at risk of Thoracic Insufficiency Syndrome (TS). TIS is defined as the inability of the thorax to support normal respiration or lung growth. This would include patients with progressive congenital, neuromuscular, idiopathic, or syndromic scoliosis.
Product codes
MDI
Device Description
In children with or at risk of developing Thoracic Insufficiency Syndrome, the natural course of lung development is arrested due to constriction by the thorax. The VEPTR/VEPTR II devices mechanically stabilize and/or correct thoracic deformities to allow the chest and lungs to grow.
The VEPTR devices are attached perpendicularly to the subject's natural ribs and lumbar vertebra or pelvis. This mechanically stabilizes the chest wall and enlarges the thorax to improve respiration and lung growth. Once the VEPTR/VEPTR II device is in place, its design allows for expansion, anatomic distraction, and replacement of component parts through less invasive surgery.
The VEPTR/VEPTR II devices allow assembly in a number of different configurations. All of these configurations are required to accommodate the wide variety of anatomical deformities encountered by the clinician in treating patients with or at risk of developing Thoracic Insufficiency Syndrome.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
ribs, lumbar vertebra, pelvis, thorax, chest wall
Indicated Patient Age Range
skeletally immature 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 (study type, sample size, AUC, MRMC, standalone performance, key results)
Non-clinical testing on the VEPTR/VEPTR II devices included mechanical testing, static compressive bending and dynamic compressive bending according to the methods outlined in ASTM 1717. Results of these tests demonstrate that the VEPTR device performs in a manner substantially equivalent to the predicate device.
The results of the HDE (H030009) post-market follow-up demonstrate that the device can be used safely with probable benefit for the indications stated. In addition, the clinical data presented demonstrated a substantially equivalent safety and effectiveness profile as the cited predicate growing spine systems (K133904 and K1411509) for the indications presented.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
H030009
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 888.3070 Thoracolumbosacral pedicle screw system.
(a)
Identification. (1) Rigid pedicle screw systems are comprised of multiple components, made from a variety of materials that allow the surgeon to build an implant system to fit the patient's anatomical and physiological requirements. Such a spinal implant assembly consists of a combination of screws, longitudinal members (e.g., plates, rods including dual diameter rods, plate/rod combinations), transverse or cross connectors, and interconnection mechanisms (e.g., rod-to-rod connectors, offset connectors).(2) Semi-rigid systems are defined as systems that contain one or more of the following features (including but not limited to): Non-uniform longitudinal elements, or features that allow more motion or flexibility compared to rigid systems.
(b)
Classification. (1) Class II (special controls), when intended to provide immobilization and stabilization of spinal segments in skeletally mature patients as an adjunct to fusion in the treatment of the following acute and chronic instabilities or deformities of the thoracic, lumbar, and sacral spine: severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra; degenerative spondylolisthesis with objective evidence of neurologic impairment; fracture; dislocation; scoliosis; kyphosis; spinal tumor; and failed previous fusion (pseudarthrosis). These pedicle screw spinal systems must comply with the following special controls:(i) Compliance with material standards;
(ii) Compliance with mechanical testing standards;
(iii) Compliance with biocompatibility standards; and
(iv) Labeling that contains these two statements in addition to other appropriate labeling information:
“Warning: The safety and effectiveness of pedicle screw spinal systems have been established only for spinal conditions with significant mechanical instability or deformity requiring fusion with instrumentation. These conditions are significant mechanical instability or deformity of the thoracic, lumbar, and sacral spine secondary to severe spondylolisthesis (grades 3 and 4) of the L5-S1 vertebra, degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor, and failed previous fusion (pseudarthrosis). The safety and effectiveness of these devices for any other conditions are unknown.”
“Precaution: The implantation of pedicle screw spinal systems should be performed only by experienced spinal surgeons with specific training in the use of this pedicle screw spinal system because this is a technically demanding procedure presenting a risk of serious injury to the patient.”
(2) Class II (special controls), when a rigid pedicle screw system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion in the treatment of degenerative disc disease and spondylolisthesis other than either severe spondylolisthesis (grades 3 and 4) at L5-S1 or degenerative spondylolisthesis with objective evidence of neurologic impairment. These pedicle screw systems must comply with the following special controls:
(i) The design characteristics of the device, including engineering schematics, must ensure that the geometry and material composition are consistent with the intended use.
(ii) Non-clinical performance testing must demonstrate the mechanical function and durability of the implant.
(iii) Device components must be demonstrated to be biocompatible.
(iv) Validation testing must demonstrate the cleanliness and sterility of, or the ability to clean and sterilize, the device components and device-specific instruments.
(v) Labeling must include the following:
(A) A clear description of the technological features of the device including identification of device materials and the principles of device operation;
(B) Intended use and indications for use, including levels of fixation;
(C) Identification of magnetic resonance (MR) compatibility status;
(D) Cleaning and sterilization instructions for devices and instruments that are provided non-sterile to the end user; and
(E) Detailed instructions of each surgical step, including device removal.
(3) Class II (special controls), when a semi-rigid system is intended to provide immobilization and stabilization of spinal segments in the thoracic, lumbar, and sacral spine as an adjunct to fusion for any indication. In addition to complying with the special controls in paragraphs (b)(2)(i) through (v) of this section, these pedicle screw systems must comply with the following special controls:
(i) Demonstration that clinical performance characteristics of the device support the intended use of the product, including assessment of fusion compared to a clinically acceptable fusion rate.
(ii) Semi-rigid systems marketed prior to the effective date of this reclassification must submit an amendment to their previously cleared premarket notification (510(k)) demonstrating compliance with the special controls in paragraphs (b)(2)(i) through (v) and paragraph (b)(3)(i) of this section.
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July 29, 2022
Depuy Synthes Spine, Inc. Catherine Kilshaw Senior Regulatory Affairs Associate 325 Paramount Drive Raynham, Massachusetts 02767
Re: K142587
Trade/Device Name: DePuy Synthes Spine Vertical Expandable Prosthetic Titanium Rib (VEPTR/VEPTR II) Regulation Number: 21 CFR 888.3070 Regulation Name: Thoracolumbosacral pedicle screw system Regulatory Class: Class II Product Code: MDI
Dear Catherine Kilshaw:
The Food and Drug Administration (FDA) is sending this letter to notify you of an administrative change related to your previous substantial equivalence (SE) determination letter dated November 18, 2014. Specifically, FDA is updating this SE Letter because FDA has better categorized your device technology under regulation number, 21 CFR 888.3070.
Please note that the 510(k) submission was not re-reviewed. For questions regarding this letter please contact Ronald Jean, OHT6: Office of Orthopedic Devices, (301)796-5650, Ronald.Jean@fda.hhs.gov.
Sincerely,
Ronald P. Jean -S
Ronald P. Jean, Ph.D. Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
1
Image /page/1/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features the department's emblem, which consists of a stylized human figure with three faces in profile, representing the department's focus on people and health. The emblem is encircled by the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" in a circular arrangement. The emblem and text are in a dark color, likely black or a dark shade of blue, against a white background.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 18, 2014
DePuy Synthes Spine Ms. Catherine Kilshaw Senior Regulatory Affairs Associate 325 Paramount Drive Raynham, Massachusetts 02767
Re: K142587
Trade/Device Name: DePuy Synthes Spine Vertical Expandable Prosthetic Titanium Rib (VEPTR/VEPTR II)
Regulatory Class: Unclassified Product Code: MDI Dated: September 12, 2014 Received: September 15, 2014
Dear Ms. Kilshaw:
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 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.
2
Page 2 - Ms. Catherine Kilshaw
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education 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. 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/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 Industry and Consumer Education 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,
Vincent J. Devlin -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) K142587
Device Name
DePuy Synthes Spine Vertical Expandable Prosthetic Titanium Rib (VEPTR/VEPTR II)
Indications for Use (Describe)
The VEPTR/VEPTR II device is indicated for skeletally immature patients with severe, progressive spinal deformities and/or three dimensional deformity of the thorax associated with or at risk of Thoracic Insufficiency Syndrome (TS). TIS is defined as the inability of the thorax to support normal respiration or lung growth. This would include patients with progressive congenital, neuromuscular, idiopathic, or syndromic scoliosis.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| Prescription Use (Part 21 CFR 801 Subpart D) | |
| Over-The-Counter Use (21 CFR 801 Subpart C) |
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510(k) Summary
Date Prepared: October 24, 2014
| Submitter: | DePuy Synthes Spine
325 Paramount Drive
Raynham, MA 02767 |
|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Catherine Kilshaw
Sr. Regulatory Affairs Associate
Telephone: (508) 880-8412
Fax: (508) 828-3797 |
| Trade Name: | DePuy Synthes Spine Vertical Expandable Prosthetic Titanium Rib
(VEPTR/VEPTR II) |
| Device Class: | II |
| Product Code: | MDI |
| Common Name: | Prosthesis, Rib Replacement |
| Classification Name: | Unclassified |
| Regulation Number: | Pre-Amendment Unclassified |
| Primary Predicate Device: | Medtronic CD HORIZON® Growth Rod Conversion Set (K133904) |
| Additional Predicate Devices: | Medos Sarl ISOLA® and EXPEDIUM® Growing Spine Systems (K141509) |
| Reference Devices: | Harrington Spinal Rod System (Pre-Amendment), Vertical Expandable
Prosthetic Titanium Rib VEPTR and VEPTR II (H030009) |
| Device Description: | In children with or at risk of developing Thoracic Insufficiency Syndrome, the
natural course of lung development is arrested due to constriction by the
thorax. The VEPTR/VEPTR II devices mechanically stabilize and/or correct
thoracic deformities to allow the chest and lungs to grow.
The VEPTR devices are attached perpendicularly to the subject's natural ribs and
lumbar vertebra or pelvis. This mechanically stabilizes the chest wall and
enlarges the thorax to improve respiration and lung growth. Once the
VEPTR/VEPTR II device is in place, its design allows for expansion, anatomic
distraction, and replacement of component parts through less invasive surgery. |
| | The VEPTR/VEPTR II devices allow assembly in a number of different
configurations. All of these configurations are required to accommodate the
wide variety of anatomical deformities encountered by the clinician in treating
patients with or at risk of developing Thoracic Insufficiency Syndrome. |
| Indications: | The VEPTR/VEPTR II device is indicated for skeletally immature patients with
severe, progressive spinal deformities and/or three dimensional deformity of
the thorax associated with or at risk of thoracic Insufficiency Syndrome
(TIS). TIS is defined as the inability of the thorax to support normal respiration
or lung growth. This would include patients with progressive congenital,
neuromuscular, idiopathic, or syndromic scoliosis. |
| Materials: | All VEPTR/VEPTR II components are manufactured from titanium alloy, Ti-6Al-
7Nb (ASTM F1295), with the exception of the sacral S-Hook, S-Rod, and 2mm
rod. The S-Hooks and S-Rods are manufactured from commercially pure
titanium, CP Ti Grade 4 (ASTM F67). The 2mm rods are manufactured from
commercially pure titanium, CP Ti Grade 1 (ASTM F67). |
| Comparison to
Predicate Devices: | The substantial equivalence of the subject device to the predicates identified
above is based upon the similarity of intended use, design (fundamental
scientific technology) materials, performance, sterility and biocompatibility. |
| Non-clinical Test
Summary: | Non-clinical testing on the VEPTR/VEPTR II devices included mechanical testing,
static compressive bending and dynamic compressive bending according to the
methods outlined in ASTM 1717. Results of these tests demonstrate that the
VEPTR device performs in a manner substantially equivalent to the predicate
device. |
| Clinical Test
Summary: | The results of the HDE (H030009) post-market follow-up demonstrate that the
device can be used safely with probable benefit for the indications stated. In
addition, the clinical data presented demonstrated a substantially equivalent
safety and effectiveness profile as the cited predicate growing spine systems
(K133904 and K1411509) for the indications presented. |
| Conclusion: | Based upon the side-by-side predicate comparison, clinical performance data
for the intended use, and pre-clinical testing, the proposed device is
substantially equivalent to the predicate device |
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