(90 days)
The AccuLIF TL and PL Cages are indicated for intervertebral body fusion with autograft and/or allogenic bone graft comprised of cancellous and/or corticocancellous bone graft when the subject device is used as an adjunct to fusion in patients with degenerative disc disease (DDD) at one level or two contiguous levels from L2 to S1. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These DDD patients may also have up to Grade I spondylolisthesis at the involved level(s). These patients should be skeletally mature and have completed six months of non-operative treatment.
Additionally, the AccuLIF TL and PL Cages can be used as an adjunct to fusion in patients diagnosed with degenerative scoliosis.
The AccuLIF TL and PL Cages are always to be used with supplemental internal spinal fixation. Additionally, the AccuLIF TL and PL Cages are to be used with autograft and/or allogenic bone graft comprised of cancellous and/or corticocancellous bone graft when the subject device is used as an adjunct to fusion.
The AccuLIF TL and PL Cage device is an expandable interbody fusion cage manufactured from implant grade Titanium alloy (TI6A14V ELI) as per ASTM F136-08, Stainless Steel (316 LVM) as per ASTM F138– 08, and Silicone Rubber (MED-4870). As with the predicate expandable AccuLIF TL and PL Cage devices, the device is inserted in unexpanded state with a delivery handle and expanded in-situ to the required height via 2 hydraulic cylinder and piston arrangements using a hydraulic system comprising disposable flexible expansion tubing set and inflation syringe. The device automatically locks at 1mm increments as it expands. The AccuLIF TL and PL Cage come in a variety of sizes, shapes, and lordotic angles to accommodate patient anatomy.
This document is a 510(k) premarket notification for the Stryker AccuLIF® TL and PL Cage, specifically for modifications made to the AccuLIF Pressure Syringe. It's a regulatory document demonstrating substantial equivalence to a predicate device, not a study proving the device meets performance acceptance criteria via clinical outcomes or algorithm performance.
Therefore, I cannot provide the requested information about acceptance criteria, device performance, sample sizes for test/training sets, expert ground truth establishment, adjudication methods, or MRMC studies. These elements are typically found in clinical study reports or performance validation reports for devices that rely on diagnostic accuracy or AI performance, which this submission does not cover.
The document states that "Design verification testing was conducted to assess the device modification. The non-clinical test results demonstrate that the modified device is substantially equivalent to the predicate." This refers to engineering and bench testing to ensure the modified syringe still functions as intended and does not negatively impact the implant's performance, maintaining its substantial equivalence to the previously cleared predicate device.
Here's what I can extract from the provided text based on the nature of this 510(k) submission:
1. Table of Acceptance Criteria and Reported Device Performance:
There is no table of acceptance criteria or reported device performance in the sense of clinical outcomes, accuracy metrics, or algorithm performance. The submission focuses on demonstrating substantial equivalence of a modified accessory (the pressure syringe) to a predicate device based on non-clinical (design verification) testing.
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set (for the syringe modification): Not explicitly stated in terms of a "test set" for clinical evaluation. The document mentions "Design verification testing," which implies engineering tests to validate the syringe's function. The sample size for these engineering tests is not provided.
- Data Provenance: The nature of the submission (510(k) for an accessory modification) suggests that data would primarily be from internal engineering and lab testing conducted by Stryker Corporation. There is no mention of country of origin for clinical data, as no clinical study demonstrating device performance is presented. The testing is non-clinical.
3. Number of Experts Used to Establish Ground Truth and Qualifications:
Not applicable. For a 510(k) submission concerning an accessory modification and relying on non-clinical design verification, expert consensus for ground truth on clinical outcomes or image interpretations is not typically required or mentioned.
4. Adjudication Method for the Test Set:
Not applicable. Adjudication methods are relevant for clinical studies or studies involving expert review of data (e.g., image interpretation), which this document does not describe.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
No. This document does not mention an MRMC study. MRMC studies are used to assess the impact of a diagnostic device or AI on human reader performance, which is not the subject of this 510(k).
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) was done:
No. This device is an intervertebral body fusion cage and its accessory (a pressure syringe), not an algorithm or AI-based device. Hence, standalone algorithm performance is not applicable.
7. The Type of Ground Truth Used:
Not applicable in the context of clinical "ground truth" (e.g., pathology, outcomes data). The "truth" for this submission revolves around the functional equivalence of the modified pressure syringe to its predicate, established through engineering design verification tests.
8. The Sample Size for the Training Set:
Not applicable. This is not an AI/ML device that requires a training set.
9. How the Ground Truth for the Training Set was Established:
Not applicable. As this is not an AI/ML device, there is no training set or ground truth in that context.
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three faces in profile, overlapping each other to create a sense of depth and unity. The faces are simple and abstract, with no distinct features other than the outline of the head and neck.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 15, 2015
Stryker Corporation Mr. Aakash Jain Regulatory Affairs Specialist 2 Pearl Court Allendale, New Jersey 07401
Re: K152651
Trade/Device Name: AccuLIF® TL and PL Cage Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: November 16, 2015 Received: November 17, 2015
Dear Mr. Jain:
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 Parts 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
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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" (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,
Mark N. Melkerson -S
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)
Device Name AccuLIF® TL and PL Cage
Indications for Use (Describe)
The AccuLIF TL and PL Cages are indicated for intervertebral body fusion with autograft and/or allogenic bone graft comprised of cancellous and/or corticocancellous bone graft when the subject device is used as an adjunct to fusion in patients with degenerative disc disease (DDD) at one level or two contiguous levels from L2 to S1. DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. These DDD patients may also have up to Grade I spondylolisthesis at the involved level(s). These patients should be skeletally mature and have completed six months of non-operative treatment.
Additionally, the AccuLIF TL and PL Cages can be used as an adjunct to fusion in patients diagnosed with degenerative scoliosis.
The AccuLIF TL and PL Cages are always to be used with supplemental internal spinal fixation. Additionally, the AccuLIF TL and PL Cages are to be used with autograft and/or allogenic bone graft comprised of cancellous and/or corticocancellous bone graft when the subject device is used as an adjunct to fusion.
| 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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| Stryker Spine AccuLIF® TL and PL Cage 510(k) Summary | |
|---|---|
| Submitter | Stryker Spine2 Pearl CourtAllendale, NJ 07401 |
| Contact Person | Aakash JainRegulatory Affairs SpecialistPhone: 201-749-8074Fax: 201-962-4074E-mail: aakash.jain@stryker.com |
| Date Prepared | September 10, 2015 |
| Trade Name | AccuLIF® TL and PL Cage |
| Common Name | Intervertebral Fusion Device With Bone Graft, Lumbar |
| Proposed Class | Class II |
| Classification Nameand Number | Intervertebral body fusion device, 21 CFR 888.3080 |
| Product Codes | MAX |
| Predicate Devices | The AccuLIF® TL and PL Cage was shown to be substantiallyequivalent to the device listed below:• Primary Predicate: Stryker Spine, ACCULIF® TL and PL CageK143616 |
| Device Description | The AccuLIF TL and PL Cage device is an expandable interbody fusioncage manufactured from implant grade Titanium alloy (TI6A14V ELI)as per ASTM F136-08, Stainless Steel (316 LVM) as per ASTM F138–08, and Silicone Rubber (MED-4870). As with the predicate expandableAccuLIF TL and PL Cage devices, the device is inserted in unexpandedstate with a delivery handle and expanded in-situ to the required heightvia 2 hydraulic cylinder and piston arrangements using a hydraulicsystem comprising disposable flexible expansion tubing set andinflation syringe. The device automatically locks at 1mm increments asit expands. The AccuLIF TL and PL Cage come in a variety of sizes,shapes, and lordotic angles to accommodate patient anatomy. |
| Indications for Use | The AccuLIF TL and PL Cages are indicated for intervertebral bodyfusion with autograft and/or allogenic bone graft comprised ofcancellous and/or corticocancellous bone graft when the subject deviceis used as an adjunct to fusion in patients with degenerative disc disease(DDD) at one level or two contiguous levels from L2 to S1. DDD isdefined as back pain of discogenic origin with degeneration of the discconfirmed by history and radiographic studies. These DDD patients mayalso have up to Grade I spondylolisthesis or retrolisthesis at the involved |
| level(s). These patients should be skeletally mature and have completedsix months of non-operative treatment. | |
| Additionally, the AccuLIF TL and PL Cages can be used as an adjunctto fusion in patients diagnosed with degenerative scoliosis. | |
| The AccuLIF TL and PL Cages are always to be used withsupplemental internal spinal fixation. Additionally, the AccuLIF TL andPL Cages are to be used with autograft and/or allogenic bone graftcomprised of cancellous and/or corticocancellous bone graft when thesubject device is used as an adjunct to fusion. | |
| Summary of | The purpose of this 510(k) is to introduce modifications to the AccuLIF |
| Technological | Pressure Syringe. There have been no changes to the AccuLIF TL and |
| Characteristics | PL Cage implants as a result of the proposed modifications to the |
| AccuLIF Pressure Syringe. The AccuLIF TL and PL Cage and the | |
| predicate device are both expandable, have similar design features, are | |
| both used in the anterior column of the spine, and both use Titanium | |
| alloy as the main device material. | |
| The modified AccuLIF Pressure Syringe continues to function as the | |
| predicate AccuLIF Pressure Syringe - to pressurize saline in order to | |
| expand the AccuLIF TL and PL Cage implants. | |
| Summary of the | Design verification testing was conducted to assess the device |
| Performance Data | modification. The non-clinical test results demonstrate that the modifieddevice is substantially equivalent to the predicate. |
| Conclusion | The modified accessory to the AccuLIF TL and PL Cage has identical |
| indications, technological characteristics, and principles of operation as | |
| its predicate. Thus, the modified device was shown to be substantially | |
| equivalent to the AccuLIF TL and PL Cage. |
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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.