(57 days)
Not Found
No
The summary describes a physical implantable device for spinal fusion and does not mention any software, algorithms, or data processing capabilities that would indicate the use of AI/ML. The performance studies focus on mechanical testing of the implant.
Yes
The device is used for spinal fusion procedures to treat degenerative disc disease, which involves directly intervening to correct a medical condition.
No
The device is described as an interfixated interbody system for spinal fusion procedures, specifically intended for treatment (implantation) rather than diagnosis.
No
The device description clearly states that the Foundation-LL System is an interfixated interbody system manufactured from physical materials like PEEK, titanium, and tantalum, and includes bone screws. This indicates it is a physical medical device, not software-only.
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, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
- Device Description and Intended Use: The provided text clearly describes a surgical implant (an interbody system) used in spinal fusion procedures. It is a physical device implanted into the body to provide structural support and promote bone growth.
- Lack of Diagnostic Function: The device's purpose is therapeutic (spinal fusion), not diagnostic. It does not analyze biological samples or provide information about a patient's health status based on such analysis.
The information provided focuses on the device's materials, design, surgical application, and performance in mechanical testing, all of which are characteristic of a surgical implant, not an IVD.
N/A
Intended Use / Indications for Use
The Foundation-LL System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels in the lumbar spine (L2 to S1). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved levels. These patients may have had a previous nonfusion spinal surgery at the involved level(s). The Foundation-LL System is intended for use with autograft. The Foundation-LL System must be used with supplemental internal spinal fixation systems (i.e., posterior pedicle screw and rod system) that are cleared by the FDA for use in the lumbar spine.
Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the Foundation-LL System.
Product codes
OVD
Device Description
The NuVasive Foundation-LL System is an interfixated interbody system manufactured from PEEK-Optima LT-1 conforming to ASTM F2026, with commercially pure titanium coating conforming to ASTM F1580 and internal screw hole rings made of titanium allov (Ti-6Al-4V ELI) conforming to ASTM F136 and ISO 5832-3. The tantalum radiographic markers conform to ASTM F560. The bone screws are made of titanium allov (Ti-6AI-4V ELI) conforming to ASTM F136 and ISO 5832-3. The NuVasive Foundation-LL System is available in a variety of different shapes and sizes to suit the individual pathology and anatomical conditions of the patient. The Foundation-LL System consists of a PEEK interbody or PEEK interbody with a commercially pure titanium plasma coating, and three (3) titanium alloy bone screws. The Foundation-LL System must be used with supplemental internal spinal fixation systems (i.e. posterior pedicle screw and rod system) that are cleared by the FDA for use in the lumbar spine.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Lumbar spine (L2 to S1)
Indicated Patient Age Range
Skeletally mature 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)
Nonclinical testing was performed to demonstrate that the subject Foundation-LL System is substantially equivalent to other predicate devices. The following testing was performed:
- Static and dynamic compression testing (axial and shear) per ASTM F2077
- Wear Debris Testing per ASTM F2077, ASTM F1714, ASTM F1877
- Static Push-out Testing per ASTM Work Item Z8423Z
- Subsidence Testing per ASTM 2267
- o Screw Push-out Testing
The results of these studies show that the subject Foundation-LL System meets or exceeds the performance of the predicate device and does not introduce any new risks; therefore, the system is substantially equivalent to the predicate device.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.
K151214, K123045, K140319, K073109, K071795
Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).
Not Found
§ 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.
0
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
December 1, 2015
NuVasive, Incorporated Ms. Cynthia Adams Regulatory Affairs Specialist 7475 Lusk Boulevard San Diego, California 92121
Re: K152943
Trade/Device Name: NuVasive® Foundation-LL System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: OVD Dated: October 2, 2015 Received: October 5, 2015
Dear Ms. Adams:
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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set
1
Page 2 - Ms. Cynthia Adams
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.
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 N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
2
Indications for Use
510(k) Number (if known) K152943
Device Name NuVasive® Foundation-LL System
Indications for Use (Describe)
The Foundation-LL System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels in the lumbar spine (L2 to S1). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved levels. These patients may have had a previous nonfusion spinal surgery at the involved level(s). The Foundation-LL System is intended for use with autograft. The Foundation-LL System must be used with supplemental internal spinal fixation systems (i.e., posterior pedicle screw and rod system) that are cleared by the FDA for use in the lumbar spine.
Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the Foundation-LL System.
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
In accordance with Title 21 of the Code of Federal Regulations, Part 807, and in particular 21 CFR §807.92, the following summary of information is provided:
A. Submitted by:
Ms. Cynthia Adams Regulatory Affairs Specialist NuVasive, Incorporated 7475 Lusk Blvd. San Diego, California 92121 (858) 909-1800
Date Prepared: October 2, 2015
B. Device Name
| Trade or Proprietary Name: | NuVasive® Foundation-LL System |
|---|---|
| Common or Usual Name: | Intervertebral Body Fusion Device |
| Classification Name: | Intervertebral Body Fusion Device |
| Device Class: | Class II |
| Classification: | 21 CFR § 888.3080 |
| Product Code: | OVD |
C. Predicate Devices
The subject NuVasive Foundation-LL System is substantially equivalent to the following devices:
Primary Predicate
-
K151214 NuVasive ALIF Interfixated System ●
Additional Predicates -
K123045 NuVasive Brigade Hyperlordotic System 0
-
K140319 NuVasive CoRoent Ti-C System ●
-
K073109 - Surgicraft Limited STALIF TT Intervertebral Body Fusion System
-
K071795 NuVasive CoRoent System ●
Device Description D.
The NuVasive Foundation-LL System is an interfixated interbody system manufactured from PEEK-Optima LT-1 conforming to ASTM F2026, with commercially pure titanium coating conforming to ASTM F1580 and internal screw hole rings made of titanium allov (Ti-6Al-4V ELI) conforming to ASTM F136 and ISO 5832-3. The tantalum radiographic markers conform to ASTM F560. The bone screws are made of titanium allov (Ti-6AI-4V ELI) conforming to ASTM F136 and ISO 5832-3. The NuVasive Foundation-LL System is available in a variety of different shapes and sizes to suit the individual pathology and anatomical conditions of the patient. The Foundation-LL System consists of a PEEK interbody or PEEK interbody with a commercially pure titanium plasma coating, and three (3) titanium alloy bone screws. The Foundation-LL System must be used with
4
Image /page/4/Picture/0 description: The image shows the Nuvasive logo. The logo consists of a purple and gray abstract shape on the left, followed by the word "NUVASIVE" in gray. Below the word "NUVASIVE" is the phrase "Speed of Innovation" in a smaller font.
supplemental internal spinal fixation systems (i.e. posterior pedicle screw and rod system) that are cleared by the FDA for use in the lumbar spine.
E. Indications for Use
The Foundation-LL System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels in the lumbar spine (L2 to S1). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies. DDD patients may also have up to Grade 1 spondylolisthesis at the involved levels. These patients may have had a previous non-fusion spinal surgery at the involved level(s). The Foundation-LL System is intended for use with autograft.
The Foundation-LL System must be used with supplemental internal spinal fixation systems (i.e., posterior pedicle screw and rod system) that are cleared by the FDA for use in the lumbar spine.
Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the Foundation-LL System.
F. Technological Characteristics
As was established in this submission, the subject Foundation-LL System is substantially equivalent to other predicate devices cleared by the FDA for commercial distribution in the United States. The subject device was shown to be substantially equivalent and have the same technological characteristics to its predicate devices through comparison in areas including design, intended use, material composition, function, and range of sizes.
G. Performance Data
Nonclinical testing was performed to demonstrate that the subject Foundation-LL System is substantially equivalent to other predicate devices. The following testing was performed:
- Static and dynamic compression testing (axial and shear) per ASTM F2077
- Wear Debris Testing per ASTM F2077, ASTM F1714, ASTM F1877 ●
- Static Push-out Testing per ASTM Work Item Z8423Z ●
- Subsidence Testing per ASTM 2267 ●
- o Screw Push-out Testing
The results of these studies show that the subject Foundation-LL System meets or exceeds the performance of the predicate device and does not introduce any new risks; therefore, the system is substantially equivalent to the predicate device.
H. Conclusions
Based on the indications for use, technological characteristics, performance testing, and comparison to predicate devices, the subject Foundation-LL System has been shown to be substantially equivalent to legally marketed predicate devices.