(409 days)
The Genesys Spine 3DP Lumbar Interbody System is indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of non-operative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radios. The system is designed for use with supplemental fixation and with autograft to facilitate fusion.
The Genesys Spine 3DP Lumbar Interbody System is comprised of additively manufactured lumbar intervertebral body fusion devices. They are designed to provide mechanical support to the lumbar spine while arthrodesis occurs. Numerous styles, footprints, and sizes of interbodies are offered including PLIFs, TLIFs, ALIFs, and LLIFs. The 3DP Lumbar Interbody System implants are manufactured from titanium Ti-6AL-4V ELI alloy.
This document, K182987, is an FDA 510(k) Premarket Notification for the Genesys Spine 3DP Lumbar Interbody System. It details the device's indications for use and a comparison to predicate devices, but it does not contain information about a study that proves the device meets specific acceptance criteria in terms of performance measures such as sensitivity, specificity, or accuracy, as would be relevant for an AI/ML-based medical device.
The document primarily focuses on demonstrating substantial equivalence to legally marketed predicate devices based on design, materials, technological characteristics, and non-clinical performance evaluations (mechanical testing), not on clinical performance or diagnostic accuracy.
Therefore, I cannot provide the requested information regarding acceptance criteria and a study to prove they are met, as this document does not describe such a study for this type of medical device (physical implant).
Specifically, the information you requested that is NOT present in this document includes:
- A table of acceptance criteria and the reported device performance: This document reports mechanical test results for "worst-case components" (static compression, static torsion, etc.) but does not list performance metrics like sensitivity or specificity.
- Sample size used for the test set and the data provenance: Not applicable, as no clinical test set for AI performance is described.
- Number of experts used to establish the ground truth... and qualifications: Not applicable.
- Adjudication method for the test set: Not applicable.
- Multi Reader Multi Case (MRMC) comparative effectiveness study: Not applicable.
- Standalone (algorithm only without human-in-the-loop performance) study: Not applicable.
- The type of ground truth used: Not applicable (no ground truth for diagnostic performance).
- The sample size for the training set: Not applicable (no AI/ML training set is mentioned).
- How the ground truth for the training set was established: Not applicable.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
December 12, 2019
Genesys Spine Mr. William W. Sowers VP of Engineering 1250 South Capital of Texas Highway, Building 3 Suite 600 Austin, Texas 78746
Re: K182987
Trade/Device Name: Genesys Spine 3DP Lumbar Interbody System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: December 6, 2019 Received: December 9, 2019
Dear Mr. Sowers:
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/cdrh/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, 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
{1}------------------------------------------------
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 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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Brent Showalter, PhD Assistant Director (Acting) DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
510(k) Number (if known)
K182987
Device Name
Genesys Spine 3DP Lumbar Interbody System
Indications for Use (Describe)
The Genesys Spine 3DP Lumbar Interbody System is indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of non-operative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radios. The system is designed for use with supplemental fixation and with autograft to facilitate fusion.
| 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.
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 Drug 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}------------------------------------------------
Image /page/3/Picture/0 description: The image shows the logo for Genesys Spine. The logo has the word "Genesys" in gray and the word "spine" in red. The logo also has the text "K182987" and "Page 1 of 2" in the upper right corner of the image.
510(K) SUMMARY
| Submitter's Name: | Genesys Spine |
|---|---|
| Submitter's Address: | 1250 Capital of Texas Highway SouthBuilding Three, Suite 600Austin, Texas 78746 |
| Contact Name: | William W. Sowers |
| Submitter's Telephone: | 512-381-7080 |
| Submitter's Fax: | 512-381-7076 |
| Date Summary wasPrepared: | October 26, 2018 |
| Trade or Proprietary Name: | Genesys Spine 3DP Lumbar Interbody System |
| Common or Usual Name: | Intervertebral Fusion Device with Bone Graft, Lumbar |
| Classification Name: | Intervertebral Body Fusion Device |
| Classification: | Class II |
| Regulation Number: | 21 CFR §888.3080 |
| Product Codes: | MAX |
| Classification Panel: | Orthopedic Devices Panel |
| Legally Marketed(unmodified) devices toWhich SubstantialEquivalence is Claimed: | Primary Predicate: Apache Interbody Fusion System(Genesys Spine - K103034)Additional Predicates:Aries® Lumbar Interbodies (Osseus Fusion Systems, LLC – K181347)EIT Cellular Titanium® Cervical & Lumbar Cages(Emerging Implant Technologies – K170503),Apache Lateral Lumbar System (Genesys Spine – K161404),Apache Hyperlordotic ALIF System (Genesys Spine – K161438), and theApache Lumbar PEEK Interbodies (Genesys Spine - K153123) |
Device Description:
The Genesys Spine 3DP Lumbar Interbody System is comprised of additively manufactured lumbar intervertebral body fusion devices. They are designed to provide mechanical support to the lumbar spine while arthrodesis occurs. Numerous styles, footprints, and sizes of interbodies are offered
{4}------------------------------------------------
including PLIFs, TLIFs, ALIFs, and LLIFs. The 3DP Lumbar Interbody System implants are manufactured from titanium Ti-6AL-4V ELI alloy.
INDICATIONS FOR USE
The Genesys Spine 3DP Lumbar Interbody System is indicated for intervertebral body fusion of the lumbar spine, from L2 to S1, in skeletally mature patients who have had six months of nonoperative treatment. The device is intended for use at either one level or two contiguous levels for the treatment of degenerative disc disease (DDD) with up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. The system is designed for use with supplemental fixation and with autograft to facilitate fusion.
TECHNOLOGICAL COMPARISON TO PREDICATES
The Genesys Spine 3DP Lumbar Interbody System was compared to the predicate systems and the designs, materials, features, functions, and intended uses were found to be substantially the same.
NON-CLINICAL PERFORMANCE EVALUATION
Performance evaluations were conducted on constructs representing the worst-case components (including static compression, static torsion, static compression shear, dynamic compression, dynamic torsion, dynamic compression shear [in accordance with ASTM F2077], subsidence [in accordance with ASTM F2267 and expulsion). The Genesys Spine 3DP Lumbar Interbody System was found to be substantially the same as predicate devices.
CONCLUSION
There are no significant differences between the Genesys Spine 3DP Lumbar Interbody System and other systems currently being marketed which would adversely affect the use of the product. It is substantially equivalent in design, material, features, function, and intended use.
§ 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.