K Number
K162694
Device Name
Ayers Rock Cervical interbody fusion system
Manufacturer
Date Cleared
2017-01-12

(107 days)

Product Code
Regulation Number
888.3080
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Ayers Rock Cervical interbody fusion system is indicated for use in skeletally mature patients with degenerative disc disease (DDD) with accompanying radicular symptoms at one level from C2-T1. DDD is defined as neck pain of discogenic origin with degeneration of the disc confirmed by history of radiographic studies. These patients should have had 6 weeks of non-operative treatment. The Ayers Rock Cervical interbody fusion devices are to be used with autogenous bone graft and implanted via an open, anterior approach. The Ayers Rock Cervical interbody fusion system is to be used with supplemental fixation.
Device Description
The Avers Rock Cervical interbody fusion system consists of cervical spinal interbody fusion devices as well as instrumentation designed specifically for the implantation of these devices. The Ayers Rock Cervical interbody fusion system is manufactured from PEEK-OPTIMA® LT1 polymer and contains tantalum radiopaque markers. The Ayers Rock Cervical interbody fusion system is for single level anterior spinal use from the C2-C3 to C7-T1 disc levels.
More Information

Not Found

No
The 510(k) summary describes a physical implant and associated instrumentation for spinal fusion, with no mention of software, algorithms, or any terms related to AI or ML. The performance studies focus on mechanical testing of the device itself.

Yes
The device is described as an interbody fusion system used in patients with degenerative disc disease, which aims to treat a medical condition.

No
The device is described as an interbody fusion system used in surgical procedures to treat degenerative disc disease. Its purpose is fusion, not diagnosis. The "Intended Use" section explicitly states it is for implantation to treat DDD, not to diagnose it.

No

The device description clearly states it consists of physical cervical spinal interbody fusion devices made from PEEK polymer and tantalum, along with implantation instrumentation. This 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 clearly describes a surgical implant for spinal fusion, addressing degenerative disc disease. This is a therapeutic intervention, not a diagnostic test performed on samples from the human body.
  • Device Description: The device is a physical implant made of PEEK polymer and tantalum markers, designed for surgical implantation. This is consistent with a medical device used in surgery, not a diagnostic reagent or instrument.
  • Lack of Diagnostic Elements: There is no mention of the device being used to analyze biological samples (blood, urine, tissue, etc.) or to provide information about a patient's health status based on such analysis.
  • Performance Studies: The performance studies focus on mechanical testing of the implant's structural integrity and endurance, which is typical for surgical implants, not diagnostic devices.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. The Ayers Rock Cervical interbody fusion system does not fit this description.

N/A

Intended Use / Indications for Use

The Ayers Rock Cervical interbody fusion system is indicated for use in skeletally mature patients with degenerative disc disease (DDD) with accompanying radicular symptoms at one level from C2-T1. DDD is defined as neck pain of discogenic origin with degeneration of the disc confirmed by history of radiographic studies. These patients should have had 6 weeks of non-operative treatment. The Ayers Rock Cervical interbody fusion devices are to be used with autogenous bone graft and implanted via an open, anterior approach. The Ayers Rock Cervical interbody fusion system is to be used with supplemental fixation.

Product codes

ODP

Device Description

The Avers Rock Cervical interbody fusion system consists of cervical spinal interbody fusion devices as well as instrumentation designed specifically for the implantation of these devices. The Ayers Rock Cervical interbody fusion system is manufactured from PEEK-OPTIMA® LT1 polymer and contains tantalum radiopaque markers. The Ayers Rock Cervical interbody fusion system is for single level anterior spinal use from the C2-C3 to C7-T1 disc levels.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Cervical spine, one level from C2-T1, C2-C3 to C7-T1 disc levels

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

Mechanical testing, which characterized the mechanical performance and fatigue endurance to show the original performance requirements for Static Compression, Static Compression Shear, Static Torsion, Dynamic Compression, Dynamic Compression Shear and Dynamic Torsion per ASTM F2077-14, Subsidence per ASTM F2267-04 (reapproved 2011) and Expulsion testing per a recognized industry norm were met. No clinical testing was performed. Bacterial endotoxin testing per USP34 and NF 29.

Key Metrics

Not Found

Predicate Device(s)

K112801, K161407

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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

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 human figure in profile, with three overlapping faces suggesting community and support.

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

January 12, 2017

Spineway % Tamala Wampler Regulatory and Ouality Consultant Novus Management Group, LLC. 6686 Dimmick Road West Chester, Ohio 45069

Re: K162694

Trade/Device Name: Ayers Rock Cervical interbody fusion system Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: ODP Dated: December 14, 2016 Received: December 19, 2016

Dear Ms. Wampler:

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 forth in

1

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,

Vincent J. Devlin -S

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

Enclosure

2

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 on last page.

510(k) Number (if known) K162694 Device Name

Ayers Rock Cervical interbody fusion system

Indications for Use (Describe)

The Ayers Rock Cervical interbody fusion system is indicated for use in skeletally mature patients with degenerative disc disease (DDD) with accompanying radicular symptoms at one level from C2-T1. DDD is defined as neck pain of discogenic origin with degeneration of the disc confirmed by history of radiographic studies. These patients should have had 6 weeks of non-operative treatment. The Ayers Rock Cervical interbody fusion devices are to be used with autogenous bone graft and implanted via an open, anterior approach. The Ayers Rock Cervical interbody fusion system is to be used with supplemental fixation.

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)

Page 1 of 2

PSC Publishing Services (301) 443-6740 ER

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 Druq Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff 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."

3

510(K) SUMMARY

Submitter's Name:Spineway
Submitter's Address:7 Allee Moulin Berger
Ecully France 69130
Submitter's Telephone:+33(0)4 72 77 01 52
Company Contact Person:Mr. Nicolas Roth
RA/QA Manager
Contact Person:Tamala J. Wampler
Novus Management Group, LLC.
513-593-4944
Date Summary was Prepared:12/13/2016
Trade or Proprietary Name:Ayers Rock Cervical interbody fusion system
Common or Usual Name:Intervertebral body fusion device
Classification:Class II per 21 CFR §888.3080
Product Code:ODP
Classification Panel:Division of Orthopedic Devices
Panel Code:87

DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:

The Avers Rock Cervical interbody fusion system consists of cervical spinal interbody fusion devices as well as instrumentation designed specifically for the implantation of these devices. The Ayers Rock Cervical interbody fusion system is manufactured from PEEK-OPTIMA® LT1 polymer and contains tantalum radiopaque markers. The Ayers Rock Cervical interbody fusion system is for single level anterior spinal use from the C2-C3 to C7-T1 disc levels.

INDICATIONS FOR USE

The Ayers Rock Cervical interbody fusion system is indicated for use in skeletally mature patients with degenerative disc disease (DDD) with accompanying radicular symptoms at one level from C2-T1. DDD is defined as neck pain of discogenic origin with degeneration of the disc confirmed by history of radiographic studies. These patients should have had 6 weeks of non-operative treatment. The Ayers Rock Cervical interbody fusion devices are to be used with autogenous bone graft and implanted via an open, anterior approach. The Ayers Rock Cervical interbody fusion system is to be used with supplemental fixation.

4

SUMMARY OF TECHNOLOGICAL CHARACTERISTICS

The subject device is substantially equivalent to the predicate devices. The subject device is equivalent to the predicates in regards to technological characteristics including design, indication for use, intended use, material composition, and function.

PREDICATES

Ayers Rock Cervical interbody fusion system is made PEEK-OPTIMA® LT1. The subject and predicate devices have identical technological characteristics. Specifically, the following characteristics are identical between the subject and predicates:

  • Indications for Use (identical) ●
  • Materials of manufacture (identical)
  • Structural support mechanism (identical) ●

Table 5-1 Predicate Devices

| 510k
Number | Trade or Proprietary or
Name | Model | Manufacturer | Type |
|----------------|---------------------------------|-------|---------------|------------|
| K112801 | Ayers Rock | | Qualgenix | Primary |
| K161407 | Ascential IBD PEEK Spacer | | Stryker Spine | Additional |

PERFORMANCE TESTING

The Avers Rock Cervical interbody fusion system was evaluated to demonstrate equivalence to the predicate devices. Mechanical testing, which characterized the mechanical performance and fatigue endurance to show the original performance requirements for Static Compression, Static Compression Shear, Static Torsion, Dynamic Compression, Dynamic Compression Shear and Dynamic Torsion per ASTM F2077-14, Subsidence per ASTM F2267-04 (reapproved 2011) and Expulsion testing per a recognized industry norm were met. No clinical testing was performed. Bacterial endotoxin testing per USP34 and NF 29.

CONCLUSION

The Avers Rock Cervical interbody fusion system has been tested per ASTM F2077 in Static Compression, Static Compression Shear, Static Torsion, Dynamic Compression, Dynamic Compression Shear, Dynamic Torsion and ASTM F2267 Subsidence as well as expulsion testing and were considered substantially equivalent to other legally marketed devices. The subject Ayers Rock Cervical interbody fusion system has similar intended uses, indications, technological characteristics, and principles of operation as the predicate devices. The overall technology characteristics lead to the conclusion that the Ayers Rock Cervical interbody fusion system is substantially equivalent to the predicate devices.