K Number
K191786
Device Name
Cyclops™ Anterior Cervical Plate System
Manufacturer
Date Cleared
2019-08-30

(58 days)

Product Code
Regulation Number
888.3060
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The DeGen Medical Cyclops™ Anterior Cervical Plate System is intended for use as an aid in cervical spinal fusion and is intended for unilateral fixation. The Cyclops™ Anterior Cervical Plate system is intended for anterior intervertebral screw fixation of the cervical spine at levels C2 to T1. The system is indicated for temporary stabilization of the anterior spine during the development of cervical spine fusions in patients with following indications: - · Degenerative Disc Disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies) - Spinal Stenosis . - Trauma (i.e. fracture or dislocation) . - Deformity or curvatures (including scoliosis, kyphosis, or lordosis) . - . Spinal Tumors - Pseudoarthrosis or failed previous fusion . - Spondylolisthesis . - Decompression of the spinal following total or partial cervical vertebrectomy .
Device Description
The DeGen Medical Cyclops™ Anterior Cervical Plate Systems (CACP) consists of cervical plates and bone screws. All implants are intended to provide stabilization of the cervical vertebrae. The CACP provides anterior fixation from either fixed or variable angle construct in self-tapping or self-drilling bone screw options. The system is provided non-sterile and is constructed from Titanium alloy (Ti-6Al-4V ELI) per ASTM F136.
More Information

Not Found

No
The summary describes a mechanical implant (plate and screws) for spinal fusion and the performance studies are mechanical tests. There is no mention of software, image processing, or AI/ML terms.

Yes
The device is described as an "aid in cervical spinal fusion" and is intended for "temporary stabilization of the anterior spine during the development of cervical spine fusions" for various conditions like degenerative disc disease, spinal stenosis, and trauma. This falls under the definition of a therapeutic device as it treats or alleviates a medical condition.

No
The device is described as an anterior cervical plate system intended for stabilization of the cervical spine during fusion, which is a treatment, not a diagnostic, function.

No

The device description explicitly states it consists of cervical plates and bone screws, which are physical hardware components made of Titanium alloy.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states that the device is for "anterior intervertebral screw fixation of the cervical spine at levels C2 to T1" and is used as an "aid in cervical spinal fusion." This describes a surgical implant used directly on the patient's body.
  • Device Description: The description details physical components like "cervical plates and bone screws" made of "Titanium alloy." These are physical implants, not reagents or instruments used to test samples outside the body.
  • IVD Definition: In Vitro Diagnostics (IVDs) are medical devices used to perform tests on samples taken from the human body (like blood, urine, or tissue) to provide information about a person's health. This device does not perform any such tests.

The information provided describes a surgical implant used for spinal fixation, which is a completely different category of medical device than an IVD.

N/A

Intended Use / Indications for Use

The DeGen Medical Cyclops™ Anterior Cervical Plate System is intended for use as an aid in cervical spinal fusion and is intended for unilateral fixation. The Cyclops™ Anterior Cervical Plate system is intended for anterior intervertebral screw fixation of the cervical spine at levels C2 to T1. The system is indicated for temporary stabilization of the anterior spine during the development of cervical spine fusions in patients with following indications:

  • Degenerative Disc Disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies)
  • Spinal Stenosis .
  • Trauma (i.e. fracture or dislocation) .
  • Deformity or curvatures (including scoliosis, kyphosis, or lordosis) .
  • . Spinal Tumors
  • Pseudoarthrosis or failed previous fusion .
  • Spondylolisthesis .
  • Decompression of the spinal following total or partial cervical vertebrectomy .

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

KWQ

Device Description

The DeGen Medical Cyclops™ Anterior Cervical Plate Systems (CACP) consists of cervical plates and bone screws. All implants are intended to provide stabilization of the cervical vertebrae. The CACP provides anterior fixation from either fixed or variable angle construct in self-tapping or self-drilling bone screw options. The system is provided non-sterile and is constructed from Titanium alloy (Ti-6Al-4V ELI) per ASTM F136.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

cervical spine at levels C2 to T1

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Prescription Use (Part 21 CFR 801 Subpart D)

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)

Non-clinical testing was performed to demonstrate the DeGen Medical Cyclops™ Anterior Cervical Plate System (CACP) is substantially equivalent to other predicate devices in accordance with "Guidance for Industry and FDA Staff, Guidance for Spinal System 510(k)s", May 3, 2004. The following tests were performed:
Static and dynamic compression testing per ASTM F1717 Static torsion testing per ASTM F1717 Screw strength via ASTM F543 Push-out testing for Screws The results of these studies show the subject DeGen Medical Cyclops™ Anterior Cervical Plate System (CACP) meets or exceeds the performance of the predicate devices, and the device was therefore found to be substantially equivalent.

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.

K150759, K971883, K030866, K031276, K926453, K945700, K052292, K013877, K121658, K080646, K133518

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

§ 888.3060 Spinal intervertebral body fixation orthosis.

(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.

0

August 30, 2019

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DeGen Medical INC % Linda Braddon President/CEO Secure BioMed Evaluations 7828 Hickory Flat Highway Suite 120 Woodstock, Georgia 30188

Re: K191786

Trade/Device Name: CyclopsTM Anterior Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal Intervertebral Body Fixation Orthosis Regulatory Class: Class II Product Code: KWQ Dated: July 31, 2019 Received: August 1, 2019

Dear Linda Braddon:

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

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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 RPJ

Ronald Jean, Ph.D. Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K191786

Device Name

Cyclops™ Anterior Cervical Plate System

Indications for Use (Describe)

The DeGen Medical Cyclops™ Anterior Cervical Plate System is intended for use as an aid in cervical spinal fusion and is intended for unilateral fixation. The Cyclops™ Anterior Cervical Plate system is intended for anterior intervertebral screw fixation of the cervical spine at levels C2 to T1. The system is indicated for temporary stabilization of the anterior spine during the development of cervical spine fusions in patients with following indications:

  • · Degenerative Disc Disease (as defined by neck pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies)
  • Spinal Stenosis .
  • Trauma (i.e. fracture or dislocation) .
  • Deformity or curvatures (including scoliosis, kyphosis, or lordosis) .
  • . Spinal Tumors
  • Pseudoarthrosis or failed previous fusion .
  • Spondylolisthesis .
  • Decompression of the spinal following total or partial cervical vertebrectomy .
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)

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Image /page/3/Picture/0 description: The image features the logo for Degen Medical. The logo consists of a stylized graphic above the text "DEGEN MEDICAL". The graphic is composed of three curved lines that converge at a point on the left and terminate in circles on the right. The lines are blue, and the circles are solid blue. The text "DEGEN" is in a bold, sans-serif font, and "MEDICAL" is in a smaller, sans-serif font below it.

510(k) Summary of Safety and Effectiveness

In accordance with 21 CFR 807.87 (h) and 21 CRF 807.92, the 510(k) summary for the DeGen Medical Cyclops Anterior Cervical Plate (CACP) is provided below.

DateJuly 2, 2019
SponsorDeGen Medical, Inc.
1321-C North Cashua Drive
Florence, SC 29501
Phone 877-240-7838
Fax 843-407-0545
510(k) ContactSecure BioMed Evaluations
Linda Braddon, Ph.D.
7828 Hickory Flat Highway
Suite 120
Woodstock, GA 30188
770-837-2681
Regulatory@SecureBME.com
Trade NameCyclops™ Anterior Cervical Plate System
Common NameSpinal Intervertebral Body Fixation Orthosis
Code -ClassificationKWQ
21 CFR 888.3060: Class II
Primary PredicateK150759 Hyper-C Anterior Cervical Plate System
Additional PredicatesK971883 Synthes Small Stature Anterior Cervical Locking Plate System
K030866, K031276, K926453, K945700 Synthes CSLP
K052292 X-Spine Spider Cervical Plate
K013877, K121658 Orthofix Hallmark Anterior Cervical Plate System
K080646, K133518 Biomet Maxan Anterior Cervical Plate System
Device DescriptionThe DeGen Medical Cyclops™ Anterior Cervical Plate Systems (CACP) consists of cervical
plates and bone screws. All implants are intended to provide stabilization of the cervical
vertebrae. The CACP provides anterior fixation from either fixed or variable angle
construct in self-tapping or self-drilling bone screw options. The system is provided non-
sterile and is constructed from Titanium alloy (Ti-6Al-4V ELI) per ASTM F136.
Indications for UseThe DeGen Medical Cyclops™ Anterior Cervical Plate system is intended for use as an
aid in cervical spinal fusion and is intended for unilateral fixation. The Cyclops™
Anterior Cervical Plate system is intended for anterior intervertebral screw fixation of
the cervical spine at levels C2 to T1. The system is indicated for temporary stabilization
of the anterior spine during the development of cervical spine fusions in patients with
following indications:
Degenerative Disc Disease (as defined by neck pain of discogenic origin with
degeneration of the disc confirmed by patient history and radiographic studies) Spinal Stenosis Trauma (i.e. fracture or dislocation) Deformity or curvatures (including scoliosis, kyphosis, or lordosis) Spinal Tumors Pseudoarthrosis or failed previous fusion Spondylolisthesis Decompression of the spinal following total or partial cervical vertebrectomy
Technological
CharacteristicsAs was established in this submission, the subject Cyclops™ Anterior Cervical Plate
System (CACP) 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 has the same technological characteristics to its predicate
devices through comparison in areas including design, intended use, material
composition, function, and range of sizes.
Non-Clinical
Performance Testing
ConclusionNon-clinical testing was performed to demonstrate the DeGen Medical Cyclops™
Anterior Cervical Plate System (CACP) is substantially equivalent to other predicate
devices in accordance with "Guidance for Industry and FDA Staff, Guidance for Spinal
System 510(k)s", May 3, 2004. The following tests were performed:
Static and dynamic compression testing per ASTM F1717 Static torsion testing per ASTM F1717 Screw strength via ASTM F543 Push-out testing for Screws The results of these studies show the subject DeGen Medical Cyclops™ Anterior Cervical
Plate System (CACP) meets or exceeds the performance of the predicate devices, and
the device was therefore found to be substantially equivalent.
Substantial
Equivalence Summary
(Conclusion)Based on the indications for use, technological characteristics, performance testing, and
comparison to predicate devices, the subject DeGen Medical Cyclops™ Anterior Cervical
Plate System (CACP) has been shown to be substantially equivalent to legally marketed
predicate devices.

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Image /page/4/Picture/1 description: The image shows the logo for Degen Medical. The logo features a stylized blue graphic above the words "DEGEN" and "MEDICAL", which are stacked on top of each other. The graphic consists of three curved lines, each with a blue circle at the end, resembling a stylized representation of medical technology or innovation.