K Number
K181306
Device Name
Actifuse Flow
Date Cleared
2018-08-17

(92 days)

Product Code
Regulation Number
888.3045
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Actifuse™ Flow is a bone void filler intended only for orthopedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse™ Flow can be injected into bony voids or gaps of the skeletal system, i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during process.
Device Description
Actifuse™ Flow Bone Graft Substitute is a bone void filler intended only for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse 11d Flow Bone Graft Substitute can be injected into bony voids or gaps of the skeletal system. i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during the healing process. Actifuse™ Flow is phase-pure silicon-substituted calcium phosphate osteoconductive bone void filler, comprising a single-phase calcium phosphate scaffold delivered in a matrix of resorbable polymer. The interconnected and open porous structure inherent of the source material for the mineral phase of Actifuse™ Flow is similar to human cancellous bone.
More Information

No
The summary describes a bone void filler material and its physical properties, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes

The device is a bone void filler intended for orthopedic applications as a filler for gaps and voids in the skeletal system, providing a scaffold for bone regeneration, which directly contributes to healing and restoring normal function.

No

The device is described as a bone void filler intended for orthopedic applications, which is a therapeutic function, not a diagnostic one.

No

The device description clearly states that Actifuse™ Flow is a bone void filler comprising a physical material (calcium phosphate scaffold in a polymer matrix) intended for injection into bony voids. This is a physical medical device, not software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that Actifuse™ Flow is a bone void filler for orthopedic applications. It is used to fill gaps and voids in bone during surgical procedures.
  • Device Description: The description details the material composition and function of the device as a bone void filler that is injected into the skeletal system.
  • Lack of Diagnostic Purpose: There is no mention of the device being used to diagnose a condition, analyze a sample from the human body, or provide information about a patient's health status through in vitro testing.

IVD devices are used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. Actifuse™ Flow is a therapeutic device used directly within the body during surgery.

N/A

Intended Use / Indications for Use

Actifuse™ Flow is a bone void filler intended only for orthopedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse™ Flow can be injected into bony voids or gaps of the skeletal system, i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during process.

Product codes (comma separated list FDA assigned to the subject device)

MOV

Device Description

Actifuse™ Flow Bone Graft Substitute is a bone void filler intended only for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse 11d Flow Bone Graft Substitute can be injected into bony voids or gaps of the skeletal system. i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during the healing process.

Actifuse™ Flow is phase-pure silicon-substituted calcium phosphate osteoconductive bone void filler, comprising a single-phase calcium phosphate scaffold delivered in a matrix of resorbable polymer. The interconnected and open porous structure inherent of the source material for the mineral phase of Actifuse™ Flow is similar to human cancellous bone.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

extremities, pelvis, and spine

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

The performance of the Actifuse™ Flow device after modifications made to the applicator syringe was assessed by analyzing the Actifuse™ Flow final product for chemical changes relative to the predicate product's specification. All testing confirmed that the modifications had no impact to the chemistry or structure of the Actifuse™ Flow product.

Biocompatibility assessments were conducted based on ISO-10993-1, Biological Evaluation of Medical Devices for permanent duration, implant device, tissue/bone contact, and FDA Guidance, Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process", as recommended in the "Class II Special Controls Guidance Document: Resorbable Calcium Salt Bone Void Filler Device: Guidance for Industry and FDA".

The Actifuse The Flow product line is sterilized with radiation. The minimum sterilizing dose (MSD) required to provide a 10-6 Sterility Assurance Level (SAL) for this (sub) category was established and validated at the manufacturing facility as described in ANSI/AAMI/ISO ISO 11137-2, "Sterilization of health care products- Radiation-Part 2: Establishing the Sterilization Dose." These products are labeled "Sterile". Package Verification testing is based on Visual Inspection, Seal Strength, and Bubble Leak testing.

Baxter has performed aging testing to support a shelf-life claim of two (2) years.

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.

K082073

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.

K081979, K130531, K071206, K090850

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

§ 888.3045 Resorbable calcium salt bone void filler device.

(a)
Identification. A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.

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August 17, 2018

Baxter Healthcare Corporation Daniel Davis Senior Manager, Global Regulatory Affairs 32650 North Wilson Road Round Lake, Illinois 60073

Re: K181306

Trade/Device Name: Actifuse™M Flow Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MOV Dated: July 18, 2018 Received: July 20, 2018

Dear Mr. Davis:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrl/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, 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

1

801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Laurence D. Coyne -S

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

Enclosure

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Form Approved: OMB No. 0910-0120

Expiration Date: January 31, 2017

See PRA Statement below.

Indications for Use

510(k) Number (if known) K181306

Device Name Actifuse TM Flow

Indications for Use (Describe)

Actifuse™ Flow is a bone void filler intended only for orthopedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse™ Flow can be injected into bony voids or gaps of the skeletal system, i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during process.

Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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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:

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Section 5. 510(k) Summary

May 22, 2018

OWNER:

Baxter Healthcare Corporation One Baxter Parkway Deerfield, Illinois 60015

CONTACT PERSON:

Daniel Davis Senior Manager, Global Regulatory Affairs 32650 N. Wilson Road Round Lake, IL 60073 Telephone: (224) 948-3775 Fax: (224) 270-4119

IDENTIFICATION OF THE DEVICE:

Common Name: Filler, bone void, calcium compound Trade Name: Actifuse™ Flow Bone Graft Substitute Classification Panel: Orthopaedic and Rehabilitation Devices Panel Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler devices Regulatory Class: Class II Product Code: MQV

Model NumberName
506005078076Actifuse Flow Bone Graft Substitute, 1.5ml
506005078077Actifuse Flow Bone Graft Substitute, 3.0ml
506005078078Actifuse Flow Bone Graft Substitute, 5.0ml

Table 1. Model Numbers for Actifuse™ Flow

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PREDICATE DEVICE:

Table 2. Predicate Device

DeviceCompanyPredicate 510(k)Clearance Date
ActifuseTM Flow Bone
Graft SubstituteApaTech Limited
370 Centennial Avenue
Elstree, Hertfordshire
WD6 3TJ
United Kingdom.1K082073September 11, 2008

1 ApaTech Limited was acquired by Baxter Healthcare Corporation in 2010

DeviceCompanyReference 510(k)Clearance Date
Actifuse™ Flow Bone
Graft Substitute,
Actifuse™ Shape Bone
Graft Substitute,
Actifuse™ ABX E-Z fil
Putty, Actifuse™ Bone
Graft SubstituteApaTech Limited
370 Centennial Avenue
Elstree, Hertfordshire
WD6 3TJ
United Kingdom.1K081979November 6, 2008
Altapore™ Bone Graft
SubstituteApaTech Limited
370 Centennial Avenue
Elstree, Hertfordshire
WD6 3TJ
United Kingdom.1K130531April 8, 2014
Actifuse™ ABX E-Z fil
Putty Bone Graft
SubstituteApaTech Limited
370 Centennial Avenue
Elstree, Hertfordshire
WD6 3TJ
United Kingdom.1K071206May 31, 2007
Actifuse™ Bone Graft
Substitute
Actifuse™
Microgranules Bone
Graft Substitute
Actifuse™ E-Z-Prep
Actifuse™ ABX Bone
Graft Substitute
Actifuse™ MIS
Actifuse™ Shape Bone
Graft Substitute
Actifuse™ Flow Bone
Graft SubstituteApaTech Limited
370 Centennial Avenue
Elstree, Hertfordshire
WD6 3TJ
United Kingdom.1K090850July 30, 2009
1 ApaTech Limited was acquired by Baxter Healthcare Corporation in 2010

Table 3. Reference 510(k)

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DESCRIPTION OF THE DEVICE:

Actifuse™ Flow Bone Graft Substitute is a bone void filler intended only for orthopaedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse 11d Flow Bone Graft Substitute can be injected into bony voids or gaps of the skeletal system. i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during the healing process.

Actifuse™ Flow is phase-pure silicon-substituted calcium phosphate osteoconductive bone void filler, comprising a single-phase calcium phosphate scaffold delivered in a matrix of resorbable polymer. The interconnected and open porous structure inherent of the source material for the mineral phase of Actifuse™ Flow is similar to human cancellous bone.

INDICATIONS FOR USE:

Actifuse™ Flow is a bone void filler intended only for orthopedic applications as a filler for gaps and voids that are not intrinsic to the stability of the bony structure. Actifuse™ Flow can be injected into bony voids or gaps of the skeletal system, i.e., extremities, pelvis, and spine, including use in posterolateral spinal fusion procedures with appropriate stabilizing hardware. These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The product provides a bone void filler that resorbs and is replaced by bone during the healing process.

PURPOSE OF SUBMISSION:

The basis for this premarket notification is modifications to the Actifuse™ Flow product line. The modifications consist of applicator syringe design changes (both material and dimensional changes) to create a ready-to-use version of the Actifuse™ Flow device. The proposed new applicator syringe materials are currently used in Baxter's Altapore and Actifuse™ ABX Bone Graft substitute product lines and have been previously cleared under 510(k) premarket notifications K130531 (cleared date 8th Apr, 2014) and K071206 (cleared date 31st May, 2007) respectively. The hydroxyapatite granules used in Actifuse ABX. Actifuse Flow, and Altapore are all chemically identical. These modifications do not impact the intended use or the fundamental technology of the devices.

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TECHNOLOGICAL CHARACTERISTICS AND SUBSTANTIAL EQUIVALENCE:

The proposed devices have equivalent technological characteristics as Baxter's currently cleared Actifuse™ Flow product line, cleared under 510(k) premarket notification K082073 (cleared September 11, 2008).

DISCUSSION OF NON-CLINICAL DATA:

Baxter Healthcare Corporation conducts risk analyses and design verification tests based on the result of these analyses. All test results meet the acceptance criteria, and support that the proposed devices are appropriately designed for their intended use. All testing was performed on the configuration of the devices presented in this premarket notification.

Performance Data

The performance of the Actifuse™ Flow device after modifications made to the applicator syringe was assessed by analyzing the Actifuse™ Flow final product for chemical changes relative to the predicate product's specification. All testing confirmed that the modifications had no impact to the chemistry or structure of the Actifuse™ Flow product.

Biocompatibility

All materials found in these devices that are the subject of this submission have been previously cleared under Baxter's 510(k) premarket notifications K082073 (clearance date September 11, 2008), K130531 (clearance date April 8, 2014) and K071206 (clearance date 31st May, 2007).

Biocompatibility assessments were conducted based on ISO-10993-1, Biological Evaluation of Medical Devices for permanent duration, implant device, tissue/bone contact, and FDA Guidance, Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process", as recommended in the "Class II Special Controls Guidance Document: Resorbable Calcium Salt Bone Void Filler Device: Guidance for Industry and FDA".

Sterility

The Actifuse The Flow product line is sterilized with radiation. The minimum sterilizing dose (MSD) required to provide a 10-6 Sterility Assurance Level (SAL) for this (sub) category was established and validated at the manufacturing facility as described in

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ANSI/AAMI/ISO ISO 11137-2, "Sterilization of health care products- Radiation-Part 2: Establishing the Sterilization Dose."

These products are labeled "Sterile". Package Verification testing is based on Visual Inspection, Seal Strength, and Bubble Leak testing.

Shelf Life

Baxter has performed aging testing to support a shelf-life claim of two (2) years.

CONCLUSION:

Actifuse™ Flow Bone Graft Substitute is as safe and effective as the predicate Actifuse™ Flow Bone Graft Substitute. Both devices share indications for use, technological characteristics, and principles of operation. The only differences between the two devices are the changes to the dimensions and materials of the syringes housing the devices. The non-clinical data demonstrate that the subject device is substantially equivalent and performs comparably to the predicate device.