K Number
K143488
Device Name
InFill Graft Delivery System
Date Cleared
2014-12-17

(9 days)

Product Code
Regulation Number
880.5860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The InFill™ Graft Delivery System is intended to be used for the delivery of hydrated allograft, autograft or synthetic bone graft material to an orthopedic surgical site.
Device Description
The modified InFill™ Graft Delivery System is comprised of a disposable medical piston syringe, a cannulated applicator tip and accessories for mixing bone graft materials and filling of the system. The modified InFill™ Graft Delivery System is provided sterile, for single use only.
More Information

Not Found

No
The summary describes a mechanical device for delivering bone graft material and does not mention any AI/ML components or functions.

No.
The device is described as a delivery system for bone graft material to a surgical site, which is an instrument used during treatment, not a therapeutic agent itself.

No
The device is described as a "Graft Delivery System" intended for the delivery of bone graft material, and the performance studies focus on mechanical aspects like force and leakage, not diagnostic capabilities.

No

The device description explicitly states it is comprised of physical components like a syringe and applicator tip, indicating it is a hardware device, not software-only.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the "delivery of hydrated allograft, autograft or synthetic bone graft material to an orthopedic surgical site." This describes a device used during a surgical procedure to deliver material to the body, not a device used to test samples outside the body to diagnose a condition.
  • Device Description: The description details a syringe-like system for delivering bone graft material. This aligns with a surgical delivery device, not an IVD which would typically involve reagents, test strips, or analytical components for testing biological samples.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Testing of biological samples (blood, urine, tissue, etc.)
    • Diagnosis, monitoring, or screening of diseases or conditions
    • Use of reagents or analytical methods
    • Measurement of biomarkers or other indicators

In summary, the InFill™ Graft Delivery System is a surgical device for delivering bone graft material, not a device for performing in vitro diagnostic tests.

N/A

Intended Use / Indications for Use

The InFill™ Graft Delivery System is intended to be used for the delivery of hydrated allograft, autograft or synthetic bone graft material to an orthopedic surgical site.

Product codes

FMF

Device Description

The modified InFill™ Graft Delivery System is comprised of a disposable medical piston syringe, a cannulated applicator tip and accessories for mixing bone graft materials and filling of the system. The modified InFill™ Graft Delivery System is provided sterile, for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

orthopedic surgical site

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)

All necessary testing has been performed for the InFill™ Graft Delivery System to assure substantial equivalence to the predicate device and demonstrate the device performs as intended. All testing was performed on test units representative of finished devices.

The device design was qualified through the following tests:

  • . Simulated Use Testing
  • Volume Verification
  • . Maximum Force Verification
  • Force to Dispense Verification ●
  • Separation Force Testing .
  • Liquid Leak Testing ●

The modified InFill™ Graft Delivery System met all specified criteria and did not raise new safety or performance questions.

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

Not Found

Predicate Device(s)

InFill™ graft Delivery System (K121476)

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 880.5860 Piston syringe.

(a)
Identification. A piston syringe is a device intended for medical purposes that consists of a calibrated hollow barrel and a movable plunger. At one end of the barrel there is a male connector (nozzle) for fitting the female connector (hub) of a hypodermic single lumen needle. The device is used to inject fluids into, or withdraw fluids from, the body.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. In the center of the seal is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

December 17, 2014

Pinnacle Spine Group, LLC Ms. Rebecca K Pine Official Correspondent 1601 Elm Street, Suite 300 Dallas. Texas 75201

Re: K143488

Trade/Device Name: InFill™ Graft Delivery System Regulation Number: 21 CFR 880.5860 Regulation Name: Regulatory Class: Class II Product Code: FMF Dated: December 4, 2014 Received: December 8, 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

1

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 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" (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 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,

Binita S. Ashar -S

Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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5. Indications for Use Statement

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120
Expiration Date: January 31, 2017
See PRA Statement below.
510(k) Number (if known)K143488
Device NameInFill™ Graft Delivery System
Indications for Use (Describe)The InFill™ Graft Delivery System is intended to be used for the delivery of hydrated allograft, autograft or synthetic bone graft material to an orthopedic surgical site.
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)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the
time to review instructions, search existing data sources, gather and maintain the data needed and complete
and review the collection of information. Send comments regarding this burden estimate or any other aspect
of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services

Food and Drug Administration

Office of Chief Information Officer

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PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB number."

FORM FDA 3881 (1/14)

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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:December 4, 2014
CONTACT PERSON:Rebecca K Pine
1601 Elm Street, Suite 300
Dallas, TX 75201
Phone: 760.809.5178
Fax: 760.290.3216
TRADE NAME:InFill™ Graft Delivery System
COMMON NAME:Piston Syringe
CLASSIFICATION
NAME:Piston Syringe
DEVICE
CLASSIFICATION:Class 2, per 21 CFR 880.5860
PRODUCT CODEFMF
PREDICATE DEVICES:InFill™ graft Delivery System (K121476)

Substantially Equivalent To:

The modified InFill™ Graft Delivery System is substantially equivalent in intended use, principal of operation and technological characteristics to the InFill™ Graft Delivery System cleared under premarket notification K121476

Description of the Device Subject to Premarket Notification:

The modified InFill™ Graft Delivery System is comprised of a disposable medical piston syringe, a cannulated applicator tip and accessories for mixing bone graft materials and filling of the system. The modified InFill™ Graft Delivery System is provided sterile, for single use only.

Indication for Use:

The InFill™ Graft Delivery System is intended to be used for the delivery of hydrated allograft, autograft or synthetic bone graft material to an orthopedic surgical site.

Technical Characteristics:

The modified InFill™ Graft Delivery System has the same technological characteristics and is similar in overall design, materials and configuration compared to the current InFill™ Graft Delivery System as shown in the table below.

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Modified InFill™ Graft Delivery SystemInFill™ Graft Delivery System (K121476)
MaterialsSAMEMedical grade polymers
Method of fillingSAMEFront-loaded via barrel
How suppliedSAMESterile, single use only
Syringe
Syringe typeSAMEPiston
Plunger ActuationSAMEScrew
Principle of operationSAMEFacilitates delivery of bone graft material.
Material useSAMEBone graft materials
Bone graft pre-loadedSAMENo
Tip typeSAMELuer lock
Syringe VolumeSAME12cc
Barrel markingsSAMEMilliliter, graduated
Barrel transparencySAMEClear
Cannula
Cannula length300mm
275mm
150mm275mm (10.8 in)
Cannula tipSAMESmooth, atraumatic
MarkingSAMENo
Cannula OD3.5mm
4.8mm
8.0mm4.8mm
HubSAMEThreaded screw
Accessories
Mixing accessoriesSAMEMixing plunger, closed syringe cap (optional)
Filling accessoriesSAMEFunnel, stand (optional)
Graft removal accessorySAMEStylet (optional)

Performance Data:

All necessary testing has been performed for the InFill™ Graft Delivery System to assure substantial equivalence to the predicate device and demonstrate the device performs as intended. All testing was performed on test units representative of finished devices.

The device design was qualified through the following tests:

  • . Simulated Use Testing

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  • Volume Verification
  • . Maximum Force Verification
  • Force to Dispense Verification ●
  • Separation Force Testing .
  • Liquid Leak Testing ●

The modified InFill™ Graft Delivery System met all specified criteria and did not raise new safety or performance questions.

Basis for Determination of Substantial Equivalence:

The Indication/Intended Use and the fundamental scientific technology of the modified device have not been changed and are the same as those described in the unmodified predicate device. The modified InFill™ Graft Delivery System is found to have a safety and effectiveness profile that is similar to the predicate device and is determined by Pinnacle Spine Group LLC, to be substantially equivalent to the InFill™ Graft Delivery System (K121476).