K Number
K150130
Manufacturer
Date Cleared
2015-05-28

(127 days)

Product Code
Regulation Number
888.3080
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Ascendant™ Cervical Spacer System is indicated for anterior cervical interbody fusion procedures in skeletally mature patients with degenerative disc disease at one disc level from C2-T1. Degenerative Disc Disease (DDD) is defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies. These patients should have had six weeks of non-operative treatment. The Ascendant™ Cervical Spacer System is to be used with autogenous bone graft and supplemental fixation (i.e., an anterior cervical plate), and is implanted via an open, anterior approach. Patients with previous non-fusion spinal surgery at involved level may be treated with the device.

Device Description

The Ascendant™ Cervical Spacer System is an anterior cervical interbody device consisting of a PEEK Optima® LT1 (polyetheretherkeytone) implant cage with CP titanium coating and tantalum radiographic markers. It is intended for use as an interbody fusion device and is offered in a variety of heights, footprints and lordotic angles to accommodate varying anatomical conditions. The device features an enclosed chamber intended to be filled with autogenous bone graft material.

The Ascendant™ Cervical Spacer System is intended to be used with supplemental fixation (i.e., an anterior cervical plate).

AI/ML Overview

The provided text is a 510(k) premarket notification for a medical device called the "Ascendant™ Cervical Spacer System." This document is for a spinal implant, not an AI/ML powered medical device or a diagnostic device. Therefore, the information required to answer the prompt, such as acceptance criteria for performance metrics like sensitivity, specificity, or AUC, as well as details about training/test sets, ground truth establishment, expert adjudication, or MRMC studies, is not present in this document. The document describes mechanical performance testing for the device's physical properties.

However, I can extract the information related to the device's mechanical performance and present it as acceptance criteria and reported performance, even though it doesn't align with the type of acceptance criteria typically expected for AI/ML devices.

Here's the information derived from the document:

1. Table of acceptance criteria and the reported device performance:

Test ModeAcceptance CriteriaReported Device Performance
Static Compressive ShearSufficient strengthSufficient strength
Static ExpulsionSufficient strengthSufficient strength
Dynamic Axial CompressionSufficient strengthSufficient strength
Dynamic Compressive ShearSufficient strengthSufficient strength
Dynamic TorsionSufficient strengthSufficient strength
Percent PorositySufficient strengthSufficient strength
Coating ThicknessSufficient strengthSufficient strength
Static ShearSufficient strengthSufficient strength
Static TensileSufficient strengthSufficient strength
Shear FatigueSufficient strengthSufficient strength
AbrasionSufficient strengthSufficient strength

Note: The document broadly states "The results of this non-clinical testing show that the strength of the Cervical Spacer System, Ti Coated is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices." Specific numerical acceptance values or reported outcomes are not provided in this summary, only the conclusion that the device's strength is sufficient.

2. Sample size used for the test set and the data provenance:

This information is not applicable to the mechanical testing described. Mechanical tests typically use a certain number of physical samples of the device, not a "test set" in the context of data or images. The document does not specify the number of device samples used for each test. Data provenance (country of origin, retrospective/prospective) is also not applicable for this type of mechanical testing.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

This information is not applicable. The "ground truth" for mechanical performance is determined by the physical properties of the material and design, measured against engineering standards (e.g., ASTM standards), not by human expert opinion.

4. Adjudication method for the test set:

This information is not applicable, as ground truth is based on engineering standards and physical measurements, not on human adjudication.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, if so, what was the effect size of how much human readers improve with AI vs without AI assistance:

This is not applicable. The device is a physical spinal implant; it is not an AI-powered diagnostic or assistive tool for human readers.

6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

This is not applicable as the device is a physical medical implant, not an algorithm.

7. The type of ground truth used:

The "ground truth" in this context is the established mechanical engineering standards (e.g., ASTM F2077, ASTM F1854-09, ASTM F1044-05, ASTM F1147-05, ASTM F1160-05, ASTM F1978-00) for intervertebral body fusion devices. The device's performance is measured against these standards to demonstrate its "sufficient strength" and substantial equivalence to predicate devices.

8. The sample size for the training set:

This is not applicable as the document describes mechanical testing of a physical device, not an AI/ML model.

9. How the ground truth for the training set was established:

This is not applicable as the document describes mechanical testing of a physical device, not an AI/ML model.

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Image /page/0/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 that resembles a stylized caduceus or a representation of the human form.

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

May 28, 2015

Exactech, Incorporated % Kenneth Maxwell Regulatory and Quality Specialist Empirical Testing Corporation 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K150130

Trade/Device Name: Ascendant™ Cervical Spacer System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: ODP Dated: April 27, 2015 Received: April 28, 2015

Dear Mr. Maxwell,

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

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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/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/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,

Mark N. Melkerson -S

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

Enclosure

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K150130

Page 1 of 1

DEPARTMENT OF HEALTH AND HUMAN SERVICESFood and Drug AdministrationForm Approved: OMB No. 0910-0120Expiration Date: January 31, 2017See PRA Statement on last page.
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Indications for Use

510(k) Number (if known)K150130
Device NameAscendant™ Cervical Spacer System
Indications for Use (Describe)

The Ascendant™ Cervical Spacer System is indicated for anterior cervical interbody fusion
procedures in skeletally mature patients with degenerative disc disease at one disc level from
C2-T1. Degenerative Disc Disease (DDD) is defined as discogenic pain with degeneration of
the disc confirmed by history and radiographic studies. These patients should have had six
weeks of non-operative treatment. The Ascendant™ Cervical Spacer System is to be used with
autogenous bone graft and supplemental fixation (i.e., an anterior cervical plate), and is
implanted via an open, anterior approach. Patients with previous non-fusion spinal surgery at
involved level may be treated with the device.

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)
--------------------------------------------------------------------------------

FORM FDA 3881 (9/13) for the sake of the project.

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510(K) SUMMARY

Submitter's Name:Exactech
Submitter's Address:2320 NW 66th Court
Gainesville, FL 32658
Submitter's Telephone:352.377.1140
Contact Person:Kenneth C. Maxwell
Empirical Testing Corp.
719.291.6874
Date Summary was Prepared:28 April 2015
Trade or Proprietary Name:Ascendant™ Cervical Spacer System
Common or Usual Name:Intervertebral Fusion Device With Bone Graft, Lumbar
Classification:Class II per 21 CFR §888.3080
Product Code:ODP
Classification Panel:Orthopedic

DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:

The Ascendant™ Cervical Spacer System is an anterior cervical interbody device consisting of a PEEK Optima® LT1 (polyetheretherkeytone) implant cage with CP titanium coating and tantalum radiographic markers. It is intended for use as an interbody fusion device and is offered in a variety of heights, footprints and lordotic angles to accommodate varying anatomical conditions. The device features an enclosed chamber intended to be filled with autogenous bone graft material.

The Ascendant™ Cervical Spacer System is intended to be used with supplemental fixation (i.e., an anterior cervical plate).

INDICATIONS FOR USE

The Ascendant™ Cervical Spacer System is indicated for anterior cervical interbody fusion procedures in skeletally mature patients with degenerative disc disease at one disc level from C2-T1. Degenerative Disc Disease (DDD) is defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies. These patients should have had six weeks of non-operative treatment. The Ascendant™ Cervical Spacer System is to be used with autogenous bone graft and supplemental fixation (i.e., an anterior cervical plate), and is implanted via an open, anterior approach. Patients with previous non-fusion spinal surgery at involved level may be treated with the device.

The indications for use for the Ascendant™ Cervical Spacer System, Ti Coated is identical to that of the Exactech Cervical Spacer System (K141129).

TECHNOLOGICAL CHARACTERISTICS

The subject device is identical to the primary predicate with the exception of the subject device being Ti coated.

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510k NumberTrade or Proprietary or Model NameManufacturerType
K141129Cervical Spacer SystemExactechPrimary
K123909CeSpace XP Intervertebral Body FusionSystemAesculapReference

Table 5-1 Predicate Devices

PERFORMANCE DATA

The Ascendant™ Cervical Spacer System, Ti Coated has been tested in the following test modes:

  • Static Compressive Shear per ASTM F2077 ●
  • Static Expulsion per ASTM F-04.25.02.02 ●
  • Dynamic Axial Compression per ASTM F2077 .
  • Dynamic Compressive Shear per ASTM F2077 ●
  • Dynamic Torsion per F2077 ●
  • Percent Porosity per ASTM F1854-09 .
  • Coating Thickness per ASTM F1854-09 .
  • Static Shear per ASTM F1044-05
  • Static Tensile per ASTM F1147-05 ●
  • Shear Fatigue per ASTM F1160-05 ●
  • Abrasion per ASTM F1978-00 ●

The results of this non-clinical testing show that the strength of the Cervical Spacer System, Ti Coated is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the Ascendant™ Cervical Spacer System, Ti Coated is substantially equivalent to the predicate device.

§ 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.