(89 days)
Not Found
No
The device description and performance studies focus on the mechanical properties and materials of the interbody fusion system, with no mention of AI or ML technology.
Yes
The device is an intervertebral body fusion system intended for spinal fusion procedures following discectomy for degenerative disc disease, which serves to treat a medical condition.
No
The device description clearly states it is an "intervertebral body fusion system" made of various materials and designed to be implanted to promote spinal fusion. Its function is to provide structural support and facilitate bone growth, not to diagnose medical conditions.
No
The device description clearly outlines physical components made of various materials (PEEK, titanium, tantalum) and describes their physical features (teeth, porous geometry, graft aperture). This indicates a hardware-based medical device, not a software-only one.
Based on the provided text, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use clearly states the device is for spinal fusion procedures in the thoracolumbar spine. This is a surgical implant used directly in the body.
- Device Description: The description details the materials and design of intervertebral body fusion systems and fixation plates. These are physical implants.
- Lack of IVD Characteristics: There is no mention of the device being used to examine specimens from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or screening.
IVD devices are used in vitro (outside the body) to analyze biological samples. This device is used in vivo (inside the body) as a surgical implant.
N/A
Intended Use / Indications for Use
The ATEC Lateral Interbody System is indicated for spinal fusion procedures in skeletally mature patients at one or two contiguous levels in the thoracolumbar spine.
Thoracic: T1-T2 to T11-T12, or at the thoracolumbar junction (T12-L1), following discectomy for the treatment of a symptomatic degenerative disc disease (DDD), including thoracic disc hemiation (myelopathy with or without axial pain). The lateral approach is limited to levels T5-6 to T11-T12.
Lumbar: L1-L2 to L5-S1, 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 ATEC Lateral Interbody System is intended for use on patients who have had at least six months of non-operative treatment. It is intended for use with autograft and/or allograft comprised of cancellous and/or corticocancellous bone graft and supplemental fixation systems that are cleared by FDA for use in the thoracic and lumbar spine.
LIF Anti-Migration Plate (AMP) may be used with ATEC Lateral Interbody spacers to provide integrated fixation. Spacers with >20° lordosis must be used with LIF AMP integrated fixation to supplemental fixation.
Product codes
MAX, PHM, OVD
Device Description
The ATEC Lateral Interbody System includes IdentiTi LIF Porous Ti Interbody, Battalion LLIF Spacer System and LIF Interbody System. Any of the three subsystems may be used with LIF AMP integrated fixation. The ATEC Lateral Interbody System is an intervertebral body fusion system implanted from an anterolateral or lateral approach. The interbody implants consist of various lengths, widths, heights and degrees of lordosis to accommodate individual patient anatomy. These implants are manufactured PEEK (polyetheretherketone) Optima LT1 per ASTM F2026, titanium coating per ASTM F1580, tantalum per ASTM F560, titanium alloy (Ti- 6Al-4V ELI) per ASTM F136, and commercially pure titanium (CPTi Grade 2) per ASTM F67. The device includes rows of teeth on the surface of each end of the device which serve to grip the adjacent vertebrae to resist migration and expulsion of the device. Additionally, the commercially pure titanium implants are offered with a microstructure due to the layering of material that forms the porous geometry. This porous geometry extends to the superior and inferior surfaces of the device for implant fixation. All interbody implants feature an internal graft aperture for placement of bone graft to promote fusion through the cage.
The ATEC Lateral Interbody System includes LIF Anti-Migration Plate (AMP) integrated fixation that may be used with all ATEC Lateral Interbody offerings. The LIF AMP integrated fixation includes fixation plates, center locking screws and bone screws manufactured from titanium alloy per ASTM F136. This 510(k) submission seeks clearance to add size options to the LIF AMP portfolio.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Thoracic: T1-T2 to T11-T12, or at the thoracolumbar junction (T12-L1)
Lumbar: L1-L2 to L5-S1
Indicated Patient Age Range
skeletally mature patients
Intended User / Care Setting
Prescription Use
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 performed on the ATEC Lateral Interbody System supports substantial equivalence to other predicate devices. The following testing was performed:
- Dynamic axial compression testing per ASTM F2077
- Dynamic compression-shear testing per ASTM F2077
- Subsidence analysis
- Push-out analysis
- Particulate and gravimetric analysis per ASTM F1877 and ASTM F1714
- Bacterial endotoxin testing (BET) per ANSI/AAMI ST72:2011/(R)2016
The results demonstrate that the subject ATEC Lateral Interbody System is substantially equivalent to other predicate devices for nonclinical testing.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
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/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & 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.
August 12, 2019
Alphatec Spine, Inc. Cynthia Adams Project Manager, Regulatory Affairs 5818 El Camino Real Carlsbad, California 92008
Re: K191311
Trade/Device Name: ATEC Lateral Interbody System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX, PHM, OVD Dated: July 16, 2019 Received: July 17, 2019
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. 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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
1
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 (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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-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,
for Melissa Hall Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K191311
Device Name ATEC Lateral Interbody System
Indications for Use (Describe)
The ATEC Lateral Interbody System is indicated for spinal fusion procedures in skeletally mature patients at one or two contiguous levels in the thoracolumbar spine.
Thoracic: T1-T2 to T11-T12, or at the thoracolumbar junction (T12-L1), following discectomy for the treatment of a symptomatic degenerative disc disease (DDD), including thoracic disc hemiation (myelopathy with or without axial pain). The lateral approach is limited to levels T5-6 to T11-T12.
Lumbar: L1-L2 to L5-S1, 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 ATEC Lateral Interbody System is intended for use on patients who have had at least six months of non-operative treatment. It is intended for use with autograft and/or allograft comprised of cancellous and/or corticocancellous bone graft and supplemental fixation systems that are cleared by FDA for use in the thoracic and lumbar spine.
LIF Anti-Migration Plate (AMP) may be used with ATEC Lateral Interbody spacers to provide integrated fixation. Spacers with >20° lordosis must be used with LIF AMP integrated fixation to 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) |
|---|---|
| -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------- |
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Image /page/3/Picture/0 description: The image shows the logo for ATEC. The logo consists of a green square with a white "a" inside of it, followed by the word "tec" in white. The background of the logo is a dark blue color.
| I. SUBMITTER: | Alphatec Spine, Inc.
5818 El Camino Real
Carlsbad, CA 92008
Phone: (760) 431-9286
Fax: (760) 431-0289 |
|------------------------|----------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Cynthia Adams
Project Manager, Regulatory Affairs
Contact Phone: (760) 494-6740 |
| Date Summary Prepared: | May 14, 2019 |
| II. DEVICE | |
| Name of Device: | ATEC Lateral Interbody System |
| Common or Usual Name: | Intervertebral fusion device with bone graft, lumbar
Intervertebral fusion device with integrated fixation lumbar |
| Classification Name: | Intervertebral body fusion device
(21 CFR 888.3080) |
| Regulatory Class: | Class II |
| Product Code: | MAX, PHM, OVD |
LEGALLY MARKETED PREDICATE DEVICES III.
| 510(k) | Product Code | Trade Name | Manufacturer |
|---|---|---|---|
| Primary Predicate Device | |||
| K183705 | PHM, MAX, OVD, ODP | IdentiTi Porous Ti Interbody System | Alphatec Spine |
| Additional Predicate Devices | |||
| K182746 | PHM, MAX, OVD | ATEC ALIF and LLIF Spacer System | Alphatec Spine |
| K173892 | MAX, OVD | XLX Interbody System | NuVasive, Inc |
IV. DEVICE DESCRIPTION
The ATEC Lateral Interbody System includes IdentiTi LIF Porous Ti Interbody, Battalion LLIF Spacer System and LIF Interbody System. Any of the three subsystems may be used with LIF AMP integrated fixation. The ATEC Lateral Interbody System is an intervertebral body fusion system implanted from an anterolateral or lateral approach. The interbody
4
Image /page/4/Picture/1 description: The image shows the logo for Atec. The logo consists of a green square with a white curved line inside, followed by the word "atec" in white. The letters are lowercase, and there is a trademark symbol after the "c". The background is a dark blue color.
implants consist of various lengths, widths, heights and degrees of lordosis to accommodate individual patient anatomy. These implants are manufactured PEEK (polyetheretherketone) Optima LT1 per ASTM F2026, titanium coating per ASTM F1580, tantalum per ASTM F560, titanium alloy (Ti- 6Al-4V ELI) per ASTM F136, and commercially pure titanium (CPTi Grade 2) per ASTM F67. The device includes rows of teeth on the surface of each end of the device which serve to grip the adjacent vertebrae to resist migration and expulsion of the device. Additionally, the commercially pure titanium implants are offered with a microstructure due to the layering of material that forms the porous geometry. This porous geometry extends to the superior and inferior surfaces of the device for implant fixation. All interbody implants feature an internal graft aperture for placement of bone graft to promote fusion through the cage.
The ATEC Lateral Interbody System includes LIF Anti-Migration Plate (AMP) integrated fixation that may be used with all ATEC Lateral Interbody offerings. The LIF AMP integrated fixation includes fixation plates, center locking screws and bone screws manufactured from titanium alloy per ASTM F136. This 510(k) submission seeks clearance to add size options to the LIF AMP portfolio.
INDICATIONS FOR USE V.
The ATEC Lateral Interbody System is indicated for spinal fusion procedures in skeletally mature patients at one or two contiguous levels in the thoracolumbar spine.
Thoracic: T1-T2 to T11-T12, or at the thoracolumbar junction (T12-L1), following discectomy for the treatment of a symptomatic degenerative disc disease (DDD), including thoracic disc herniation (myelopathy and/or radiculopathy with or without axial pain). The lateral approach is limited to levels T5-6 to T11-T12.
Lumbar: L1-L2 to L5-S1, 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 ATEC Lateral Interbody System is intended for use on patients who have had at least six months of non-operative treatment. It is intended for use with autograft and/or allograft comprised of cancellous and/or corticocancellous bone graft and supplemental fixation systems that are cleared by FDA for use in the thoracic and lumbar spine.
LIF Anti-Migration Plate (AMP) may be used with ATEC Lateral Interbody spacers to provide integrated fixation. Spacers with >20° lordosis must be used with LIF AMP integrated fixation in addition to supplemental fixation.
5
Image /page/5/Picture/1 description: The image shows the logo for Atec. The logo consists of a green square with a white stylized "a" inside of it. To the right of the square is the word "tec" in white font. There is a trademark symbol to the upper right of the "c".
VI. TECHNOLOGICAL COMPARISON TO PREDICATES
The technological design features of the subject implants were compared to the predicates in intended use, indications for use, design, function and technology and it was demonstrated that they are substantially equivalent.
PERFORMANCE DATA VII.
Nonclinical testing performed on the ATEC Lateral Interbody System supports substantial equivalence to other predicate devices. The following testing was performed:
- Dynamic axial compression testing per ASTM F2077
- Dynamic compression-shear testing per ASTM F2077 ●
- . Subsidence analysis
- Push-out analysis
- . Particulate and gravimetric analysis per ASTM F1877 and ASTM F1714
- . Bacterial endotoxin testing (BET) per ANSI/AAMI ST72:2011/(R)2016
The results demonstrate that the subject ATEC Lateral Interbody System is substantially equivalent to other predicate devices for nonclinical testing.
Clinical Information
Not applicable; determination of substantial equivalence is not based on an assessment of clinical performance data.
VIII. CONCLUSION
Based upon the information provided in this 510(k) submission, it has been determined that the subject devices are substantially equivalent to legally marketed devices in regards to indications for use, intended use, design, technology, and performance.