K Number
K151360
Device Name
Inion Spinal Graft Containment System
Manufacturer
Date Cleared
2015-10-06

(139 days)

Product Code
Regulation Number
888.3060
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Inion spinal graft containment plate system, in conjunction with traditional rigid fixation, is intended for use in spinal fusion procedures as a means to maintain the relative position of weak bony tissue such as allografts or autografts. This device is not intended for load bearing indications.
Device Description
INION S-2™ Biodegradable Anterior Thoraco-Lumbar Fusion System plates are bioresorbable anterior thoraco-lumbar fusion devices for graft containment (screws and plates). The plates are made of degradable poly(L-lactide-co-D,L-lactide 80:20). Based on in vitro data: the implants retain most of their initial strength 16 weeks and gradually lose their strength thereafter. Bioresorption takes place within two to four years. The implants are provided sterile to the user and are non-collagenous. The shelf life of the device is 3 years. INION S-2™ Biodegradable Anterior Thoraco-Lumbar Fusion System devices provide fixation and are not intended to replace healthy tissues or withstand the stress of full load bearing. The purpose of this submission is a line extension for new sizes.
More Information

Not Found

No
The summary describes a biodegradable spinal graft containment plate system and its mechanical testing. There is no mention of AI or ML technology.

No.
Therapeutic devices are generally defined as intending to treat or cure a disease or condition. This device, while used in a medical procedure, is intended for "graft containment" and "fixation" during spinal fusion, helping to maintain the relative position of weak bony tissue. It supports the healing process but does not directly treat a disease itself, nor does it replace healthy tissue. It's a supportive device rather than a therapeutic one in the direct sense of treating a condition.

No

The device is a spinal graft containment plate system used in spinal fusion procedures. It is a surgical implant designed to help maintain the position of bony tissue, not to diagnose a condition.

No

The device description explicitly states the device is made of degradable poly(L-lactide-co-D,L-lactide 80:20) and is a physical plate and screws, indicating it is a hardware device.

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.
  • Device Description: The provided text describes a surgical implant (spinal graft containment plate system) used during a surgical procedure to physically support and contain bone grafts in the spine. It is a physical device implanted into the body.
  • Intended Use: The intended use clearly states it's for "spinal fusion procedures as a means to maintain the relative position of weak bony tissue". This is a structural and mechanical function within the body, not a diagnostic test performed on a sample outside the body.

The device is a Class II medical device (based on the K number and the nature of the device) used in surgery, not an IVD.

N/A

Intended Use / Indications for Use

The Inion spinal graft containment plate system, in conjunction with traditional rigid fixation, is intended for use in spinal fusion procedures as a means to maintain the relative position of weak bony tissue such as allografts or autografts. This device is not intended for load bearing indications.

Product codes

OJB

Device Description

INION S-2™ Biodegradable Anterior Thoraco-Lumbar Fusion System plates are bioresorbable anterior thoraco-lumbar fusion devices for graft containment (screws and plates). The plates are made of degradable poly(L-lactide-co-D,L-lactide 80:20). Based on in vitro data: the implants retain most of their initial strength 16 weeks and gradually lose their strength thereafter. Bioresorption takes place within two to four years. The implants are provided sterile to the user and are non-collagenous. The shelf life of the device is 3 years.

INION S-2™ Biodegradable Anterior Thoraco-Lumbar Fusion System devices provide fixation and are not intended to replace healthy tissues or withstand the stress of full load bearing.

The purpose of this submission is a line extension for new sizes.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Spinal, Anterior Thoraco-Lumbar

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

Mechanical testing was conducted to verify the strength and fixation properties of the new Inion S-2™ plates and to compare them to the predicate device. Testing included Graft push-off test, torsion test, axial tensile test, axial compression test, and cyclic compressive bending test. The results of each mechanical test show that the new plates perform within the performance range of the predicate device.

Functional and handling test and simulated clinical use test were performed to verify that the new plates, fixed with predicate device unmodified screws, using accessory instruments, packaging and Instructions for Use are functioning together as intended, and conform to the defined user needs and intended uses.

The data demonstrates that the intended use, material composition and scientific technology, degradation profile and mechanical properties of new Inion S-2™ line extension plates are substantially equivalent with the predicate device Inion Spinal Graft Containment System (K071810).

Key Metrics

Not Found

Predicate Device(s)

K071810

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

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" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, layered on top of each other.

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

October 6, 2015

Inion Oy % Ms. Kati Marttinen Quality and Regulatory Director Lääkärinkatu 2 Tampere, 33520 FINLAND

Re: K151360

Trade/Device Name: Inion Spinal Graft Containment System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: OJB Dated: August 20, 2015 Received: September 2, 2015

Dear Ms. Marttinen:

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 and the limitations described below. 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.

The Office of Device Evaluation has determined that there is a reasonable likelihood that this device will be used for an intended use not identified in the proposed labeling and that such use could cause harm. Therefore, in accordance with Section 513(i)(1)(E) of the Act, the following limitation must appear in the Precautions/Warnings/Contraindications section of the device's labeling:

1

"The safety and effectiveness of this device, as an adjunct to fusion, when used without rigid supplemental internal fixation has not been established. This device is not designed to withstand physiologic loads when used by itself."

Furthermore, the indication for use must be prominently displayed in all labeling, including pouch box, and carton labels, instructions for use, and other promotional materials, in close proximity to the trade name, of a similar point size, and in bold print.

Please note that the above labeling limitations are required by Section 513(i)(1)(E) of the Act. Therefore, a new 510(k) is required before these limitations are modified in any way or removed from the device's labeling.

The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and permits your device to proceed to the market. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification if the limitation statement described above is added to your labeling.

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 devicerelated 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.

2

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,

William H. Maisel - S

William H. Maisel, MD, MPH Director (Acting) Office of Device Evaluation Deputy Center Director for Science Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known)

K151360

Device Name

Inion Spinal Graft Containment System

Type of Use (Select one or both, as applicable)

Indications for Use (Describe)

The Inion spinal graft containment plate system, in conjunction with traditional rigid fixation, is intended for use in spinal fusion procedures as a means to maintain the relative position of weak bony tissue such as allografts or autografts. This device is not intended for load bearing indications.

区 Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) SUMMARY Inion Spinal Graft Containment System

| Manufacturer and submitter: | Inion Oy,
Lääkärinkatu 2,
FIN-33520 Tampere, FINLAND |
|----------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| Date | August 20, 2015 |
| Contact person | Kati Marttinen, Quality and Regulatory Director
Phone: +358 10 830 6600
Fax: +358 10 830 6691
kati.marttinen@inion.com |
| Establishment registration number | 9710629 |
| Trade name of the device | Inion Spinal Graft Containment System |
| Device classification | Class II |
| Product code | OJB |
| Review panel | Orthopedic |
| Common name | Graft containment plate |
| Classification name | Spinal intervertebral body fixation orthosis |
| Regulation number | 888.3060 |
| Predicate device | Inion Spinal Graft Containment System (K071810) |
| Conformance with performance standards | Compliance to voluntary consensus standards is listed in the application. |

Device description and principles of operation

INION S-2™ Biodegradable Anterior Thoraco-Lumbar Fusion System plates are bioresorbable anterior thoraco-lumbar fusion devices for graft containment (screws and plates). The plates are made of degradable poly(L-lactide-co-D,L-lactide 80:20). Based on in vitro data: the implants retain most of their initial strength 16 weeks and gradually lose their strength thereafter. Bioresorption takes place within two to four years. The implants are provided sterile to the user and are non-collagenous. The shelf life of the device is 3 years.

INION S-2™ Biodegradable Anterior Thoraco-Lumbar Fusion System devices provide fixation and are not intended to replace healthy tissues or withstand the stress of full load bearing.

The purpose of this submission is a line extension for new sizes.

5

510(k) SUMMARY Inion Spinal Graft Containment System

Indications for use

The Inion Spinal Graft Containment plate system, in conjunction with traditional rigid fixation, is intended for use in spinal fusion procedures as a means to maintain the relative position of weak bony tissue such as allografts or autografts. This device is not intended for load bearing indications.

Similarities to predicate device

In comparison to predicate device, the new plates have the same indications for use, material composition, manufacturing steps, sterilization method, packaging, shelf life and degradation profile. The new plates are inserted using the predicate device Inion S-2™ system screws unmodified, and same accessory instrumentation.

Differences to predicate device

In comparison to predicate device, the new plates have different dimensions. Width is 15 mm (predicate device 28 - 120 mm). Height range is 31-40 mm (predicate device 37 - 80 mm). Thickness is 3.2 mm which is within the range of predicate device (0.75 - 4.5 mm). The new plates have also less screw holes, one at each end, and are therefore fixed with 2 screws. The predicate device plates have 4-6 screw holes, 2-3 at each end respectively. The new plates do not contain radiographic tantalum markers, while majority of the predicate device plates contain 2 tantalum markers.

Accessory instruments

Surgical instruments include plate templates, plate holders, drill bits and bone taps, screwdrivers, temporary fixation screw, awl and alike. The instruments are made of surgical grade stainless steel or titanium. The instruments are provided nonsterile and reusable, intended to be steam sterilized by the user prior to use. Instructions for cleaning and steam sterilization are provided with the instruments.

Performance testing for substantial equivalence determination

Mechanical testing was conducted to verify the strength and fixation properties of the new Inion S-2™ plates and to compare them to the predicate device. Testing included Graft push-off test, torsion test, axial tensile test, axial compression test, and cyclic compressive bending test. The results of each mechanical test show that the new plates perform within the performance range of the predicate device.

Functional and handling test and simulated clinical use test were performed to verify that the new plates, fixed with predicate device unmodified screws, using accessory instruments, packaging and Instructions for Use are functioning together as intended, and conform to the defined user needs and intended uses.

6

510(k) SUMMARY Inion Spinal Graft Containment System

The data demonstrates that the intended use, material composition and scientific technology, degradation profile and mechanical properties of new Inion S-2™ line extension plates are substantially equivalent with the predicate device Inion Spinal Graft Containment System (K071810).