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510(k) Data Aggregation

    K Number
    K180502
    Date Cleared
    2018-06-14

    (108 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    S128 Anterior Lumbar Interbody Fusion (ALIF) System

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) of the lumbar spine at one or two contiguous levels from L2-S1. Degenerative disc disease is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These DDD patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). Renovis S128 ALIF System implants are to be used with autogenous bone graft. Patients should be skeletally mature and have at least six months of non-operative treatment. The Renovis S128 ALIF System is a stand-alone device and is intended to be used with the cover plate and screws provided and requires no additional supplementary fixation. The anterior cover plate must be utilized whenever the device is implanted using the bone screws provided. Should the physician choose to use fewer than the four screws provided, additional supplemental fixation cleared by the FDA for use in the lumbar spine must be used. Supplemental fixation, cleared by the FDA for use in the lumbosacral spine, must be used with implants ≥20°.

    Device Description

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is FDA cleared as K131122 and K140106 (sterile implants). This application describes additional cages offerings (new lengths, widths, and lordosis) and a packaging change.

    The S128 ALIF System includes cages of a variety of lengths, widths, heights, and lordosis to suit the individual pathology and anatomical conditions of the patient. The different shape of the footprint allows for different surgical approaches for insertion. S128 ALIF System cages are standalone for devices

    AI/ML Overview

    This document describes the FDA's decision regarding the Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System and focuses on its substantial equivalence to previously cleared devices rather than a study about AI performance. Therefore, many of the requested categories are not applicable.

    Here's the information extracted and interpreted based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't provide a typical "acceptance criteria" table with specific performance metrics for an AI device. Instead, it focuses on demonstrating substantial equivalence for a medical implant (ALIF System) by meeting established standards and performing tests relevant to its physical properties and function.

    Acceptance Criteria (Demonstrated Equivalence through)Reported Device Performance (Successful Testing)
    Functional Equivalence: Same Indications for UseThe modified cages (new lengths, widths, and lordosis) and packaging change have the same Indications for Use as the K140106 predicate cages.
    Material Equivalence: Manufactured from same materialsThe device is manufactured from the same materials as the predicate devices: Ti6Al4V (conforms to ASTM F136-13), PEEK (compliant with ASTM F2026-17), and Tantalum (compliant with ASTM F560-17). Instruments are stainless steel (compliant with ASTM A564/M564-13e1).
    Process Equivalence: Same manufacturing processesThe device uses the same manufacturing processes as the predicate devices. Titanium cages are additively manufactured then machined. PEEK implants are manufactured using traditional methods.
    Sterilization Equivalence: Same gamma sterilizationThe device is gamma sterilized, the same as the K140106 predicate cages. Complies with AAMI/ANSI/ISO 11137-2:2013 and AAMI/ANSI/ISO 11137-1:2006/(R)2010.
    Mechanical Performance: Dynamic Shear Compression strengthSuccessful Dynamic Shear Compression strength testing was performed per ASTM F2077-14.
    Mechanical Performance: Expulsion testingSuccessful Expulsion testing was performed.
    Risk Management: Assessed for risk under Design ControlsAll changes were assessed for risk and successfully tested under Design Controls.
    Biocompatibility: Biological evaluationComplies with AAMI/ANSI/ISO 10993-1:2009/(R)2013 Biological Evaluation Of Medical Devices.
    Endotoxin Testing: AAMI/ANSI ST72 standardComplies with AAMI/ANSI ST72:2011/(R)2016 Bacterial Endotoxins Test Methods.
    Additional Standards Compliance:Complies with ISO 17665-1 (Sterilization Of Health Care Products Moist Heat) and "Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Intervertebral Body Fusion Device, June 2007."

    2. Sample size used for the test set and the data provenance:

    • Sample Size for Test Set: Not applicable. This document describes the substantial equivalence of a physical medical implant (ALIF System) based on engineering tests, not a software device or AI algorithm evaluated on a data test set. The "tests" mentioned (Dynamic Shear Compression, Expulsion) refer to physical testing of the device itself.
    • Data Provenance: Not applicable for an AI or software study. The data is generated from physical material and mechanical testing of the device components.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. Ground truth, in the context of expert consensus, is not relevant for this type of device submission. The "ground truth" for the device's physical properties is established by adherence to ASTM standards and validated engineering test methods performed by qualified laboratories.

    4. Adjudication method for the test set:

    • Not applicable. There is no human expert adjudication of test results in the sense of consensus on medical images or diagnoses for this device. The physical tests are governed by standardized protocols.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • Not applicable. This submission is for a physical medical implant, not an AI or software device that would involve human readers or AI assistance.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • Not applicable. This is not an algorithm or AI device.

    7. The type of ground truth used:

    • The "ground truth" for this medical device's performance is based on established engineering standards and validated physical test methods. For example, ASTM F2077-14 for intervertebral body fusion devices sets the benchmark for acceptable mechanical performance. Material composition adherence to ASTM F136-13, F2026-17, F560-17, and A564/M564-13e1 provides the "ground truth" for material specifications. Sterilization validation using AAMI/ANSI/ISO standards establishes the "ground truth" for sterility.

    8. The sample size for the training set:

    • Not applicable. This is not an AI or machine learning device that requires a training set.

    9. How the ground truth for the training set was established:

    • Not applicable. No training set is involved for this type of device.
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    K Number
    K140106
    Date Cleared
    2014-03-27

    (71 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    S128 ANTERIOR LUMBAR INTERBODY FUSION (ALIF) SYSTEM

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) of the lumbar spine at one or two contiguous levels from L2-S1. Degenerative disc disease is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These DDD patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). Renovis S128 ALIF System implants are to be used with autogenous bone graft.

    Patients should be skeletally mature and have at least six months of non-operative treatment.

    The Renovis S128 ALIF System is a stand-alone device and is intended to be used with the cover plate and screws provided and requires no additional supplementary fixation. The anterior cover plate must be utilized whenever the device is implanted using the bone screws provided. Should the physician choose to use fewer than the four screws provided, additional supplemental fixation cleared by the FDA for use in the lumbar spine must be used.

    Device Description

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is cleared under K131122. The SI28 ALIF implants (cages) are to be used with the bone screws and anterior cover plate assembly and requires no additional supplementary fixation systems. The Renovis S128 ALIF System implants are available in a variety of sizes (widths, height, depths, and bone screw sizes; see below) to suit the individual pathology and anatomical conditions of the patient. The implants are manufactured from PEEK or additively manufactured and machined Titanium. The bone screws and cover plate assembly are both manufactured from Titanium alloy. The PEEK markers are manufactured from Tantalum.

    This Special 510(k) Premarket Notification is submitted for the additional offering of gamma sterilized S128 implants (PEEK cages; titanium cages, screws and cover plates).

    AI/ML Overview

    This document is a 510(k) Special Premarket Notification for the Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System, focusing on the addition of gamma sterilization for its implants. It primarily addresses the safety and effectiveness of the sterilization method and its impact on the device's materials, rather than a clinical study of the device's performance in patients.

    Therefore, the requested information focusing on clinical performance metrics, sample sizes for test/training sets, expert ground truth, and comparative effectiveness with AI is not directly applicable to this specific regulatory submission. This is because the submission is about a manufacturing change (sterilization method) to an already cleared device (K131122), not a new device or a clinical outcome study.

    However, I can extract the information relevant to the performance data for the sterilization process, which is the core of this submission.


    Acceptance Criteria and Reported Device Performance (for Gamma Sterilization)

    Acceptance Criteria CategoryAcceptance CriteriaReported Device Performance
    Sterility AssuranceSterilization validated to a sterility assurance level (SAL) of 10⁻⁶ by selecting and substantiating a 25 kGy dose using the VDmax 25 method, according to ISO 11137-1.Implants are sterilized by ⁶⁰Gamma irradiation validated to a sterility assurance level (SAL) of 10⁻⁶ by selecting and substantiating a 25 kGy dose by the VDmax 25 method, according to ISO 11137-1.
    Material Compatibility (Titanium)Titanium alloy components are not negatively affected by gamma sterilization and/or aging.Titanium alloy components are not affected by gamma sterilization and/or aging.
    Material Compatibility (PEEK)After an average dose of 200 kGy and accelerated aging (simulating 10+ years), PEEK components should not show any significant difference compared to untreated PEEK.PEEK components were tested to an average dose of 200 kGy and underwent accelerated aging to simulate 10 or more years. After aging, the samples were tested, and the results did not show any significant difference between untreated PEEK and gamma treated and aged PEEK.
    Packaging Sterility MaintenancePackaging validated to maintain sterility for 3 years, complying with ISO 11607-2 (accelerated aging simulation per ASTM F1980-07 and real-time aging) and performance following distribution per ISTA 2A.Packaging has been validated to maintain sterility for 3 years in compliance with ISO 11607-2, demonstrates compliance with accelerated aging simulation per ASTM F1980-07 and real-time aging; and performance following distribution per ISTA 2A.

    Regarding the other requested information:

    1. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective):

      • This document does not describe a clinical test set with human subjects. The "test set" here refers to material samples (Titanium and PEEK) and packaging subjected to sterilization and aging simulations. The sample sizes for these material tests are not explicitly stated but are part of standard validation protocols for ISO 11137-1 and internal Renovis testing.
      • Data provenance is from internal testing and validation performed by Renovis Surgical Technologies, Inc. and its sterilization/packaging validation partners. No country of origin for clinical data is applicable.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience):

      • Not applicable as this is not a clinical study involving human expert interpretation of medical images or outcomes. Ground truth for material testing is based on established materials science and engineering principles and validated sterilization/packaging standards by qualified engineers and scientists.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable. Adjudication methods are relevant for subjective assessments (like image interpretation) where there might be disagreement among experts. Material and sterilization testing follows objective, quantifiable methods against pre-defined specifications.
    4. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

      • Not applicable. This submission is about a medical device (surgical implant) and a manufacturing process change (sterilization), not an AI-powered diagnostic tool or image analysis software.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable for the same reason as above.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

      • The "ground truth" for this submission is based on established international and national standards for medical device sterilization (ISO 11137-1, ANSI/AAMI/ISO 11137-2), packaging (ISO11607-2, ASTM F1980-07), and material specifications (ASTM F2026, ASTM F136, ASTM F 560-08). This is objective, measurable data comparing post-sterilization/aging material properties to baseline and specified requirements.
    7. The sample size for the training set:

      • Not applicable. There is no machine learning or AI training set described in this document.
    8. How the ground truth for the training set was established:

      • Not applicable.
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    K Number
    K131122
    Date Cleared
    2013-09-18

    (149 days)

    Product Code
    Regulation Number
    888.3080
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    S128 ANTERIOR LUMBAR INTERBODY FUSION (ALIF) SYSTEM

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) of the lumbar spine at one or two contiguous levels from L2-S1. Degenerative disc disease is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These DDD patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). Renovis S128 ALIF System implants are to be used with autogenous bone graft.

    Patients should be skeletally mature and have at least six months of non-operative treatment.

    The Renovis S128 ALIF System is a stand-alone device and is intended to be used with the cover plate and screws provided and requires no additional supplementary fixation. The anterior cover plate must be utilized whenever the device is implanted using the bone screws provided. Should the physician choose to use fewer than the four screws provided, additional supplemental fixation cleared by the FDA for use in the lumbar spine must be used.

    Device Description

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is to be used with the bone screws and anterior cover plate assembly and requires no additional supplementary fixation systems. The screws protrude through the interbody portion of the device and stabilize the vertebral body while preventing expulsion of the implant. The Renovis S128 ALIF System contains both fixed and variable angle screw options. The fixed angle screw option provides a tight fit with the cage. The variable angle screw option provides a slight clearance between the cage and the screw which allows for a small amount of variable screw angulations.

    The Renovis S128 ALIF System cages are intended to be used with autogenous bone graft. The accompanying cover plate is designed to prevent screw back-out and must be used when the screws are implanted. NOTE: The cover plate assembly and screw are part of the implant construct.

    The Renovis S128 ALIF System implants are available in a variety of sizes (widths, height, depths, and bone screw sizes) to suit the individual pathology and anatomical conditions of the patient. The implants are manufactured from PEEK or additively manufactured and machined Titanium. The bone screws and coverplate assembly are both manufactured from Titanium alloy. The PEEK markers are manufactured from Tantalum. The Renovis Si28 ALIF System is used with trials and implant specific manual instruments, and includes other class I manual orthopedic instruments.

    AI/ML Overview

    The Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System is an intervertebral fusion device. The acceptance criteria for the device were based on various mechanical performance tests as outlined by ASTM standards and specific FDA guidance documents. The study demonstrating the device meets these criteria involved physical performance testing of the device's components and the full implant system.

    1. Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria (Test Standard)Reported Device Performance
    Static Compression per ASTM F2077Successfully undergone
    Dynamic Compression per ASTM F2077Successfully undergone
    Static Shear-Compression per ASTM F2077Successfully undergone
    Dynamic Shear-Compression per ASTM F2077Successfully undergone
    Expulsion Testing w/screws per ASTM Draft Standard F04.25.02.02Successfully undergone
    Expulsion Testing w/o screws per ASTM Draft Standard F04.25.02.02Successfully undergone
    Subsidence testing per ASTM F2267Successfully undergone
    Shear testing of metallic coatings per ASTM F1044Sample coupons of Titanium porous structure successfully undergone testing
    Tensile testing of metallic coatings per ASTM F1147Sample coupons of Titanium porous structure successfully undergone testing
    Abrasion per ASTM F1978Sample coupons of Titanium porous structure successfully undergone testing
    Porosity-and microstructure per ASTM F1854Sample coupons of Titanium porous structure successfully undergone testing
    Compliance with FDA Guidance: "Intervertebral Body Fusion Device"Complies
    Compliance with FDA Guidance: "Spinal System 510(k)s"Complies
    ASTM F 983-86 (Reapproved 2009) Standard Practice for MarkingComplies
    ASTM F 565-04 (Reapproved 2009)e1 Standard Practice for Care/HandlingComplies
    ASTM F2026 Standard Specification for PEEK PolymersComplies
    ASTM F-136 Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELIComplies
    ASTM F 560-08 Standard Specification for Unalloyed TantalumComplies
    ASTM A564 Standard Specification for Hot-Rolled and Cold-Finished Age-Hardening Stainless Steel Bars and ShapesComplies
    ASTM F138 - Standard Specification for Wrought 18Chromium-14Nickel-2.5Molybdenum Stainless Steel Bar and WireComplies

    2. Sample Size Used for the Test Set and Data Provenance:

    The document states that "worst case constructs" of the Renovis S128 ALIF System implants were used for mechanical testing and "sample coupons" of the Titanium porous structure were tested. However, the exact numerical sample sizes for each test are not specified in the provided text. The data provenance is pre-market performance bench testing, indicating it is prospective data obtained specifically for regulatory submission, and not from clinical trials or retrospective patient data. The country of origin for the data generation (e.g., in which lab/country testing was conducted) is not specified, though Renovis Surgical Technologies is located in Redlands, CA, USA.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:

    This information is not applicable as the evaluation of this medical device's performance is based on standardized mechanical testing against pre-defined engineering criteria (ASTM standards and FDA guidance) rather than subjective expert assessment of clinical data or images. "Ground truth" in this context refers to the verifiable performance against these objective mechanical benchmarks.

    4. Adjudication Method for the Test Set:

    This information is not applicable as the device's performance was assessed through objective mechanical testing against established standards, not through a process requiring expert adjudication of subjective outcomes.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the Effect Size of how much human readers improve with AI vs without AI assistance:

    This is not applicable as the document describes a pre-market notification for an intervertebral fusion device, which is an implantable medical device, not an AI-powered diagnostic tool. Therefore, no MRMC study involving human readers with or without AI assistance was conducted or would be relevant.

    6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done:

    This is not applicable as the device is a physical implant, not an algorithm.

    7. The Type of Ground Truth Used:

    The ground truth used for this device's evaluation is defined by established engineering and material standards and FDA guidance documents. Specifically, successful performance in physical and mechanical tests (e.g., static/dynamic compression, shear, expulsion, subsidence) as per ASTM F2077, ASTM F2267, ASTM F1044, ASTM F1147, ASTM F1978, ASTM F1854, and various material specifications (e.g., PEEK, Titanium, Tantalum). The device's substantial equivalence is based on its ability to meet these objective, measurable criteria, indicating it performs comparably to predicate devices in mechanical integrity and material properties.

    8. The Sample Size for the Training Set:

    This information is not applicable. The context provided is for a traditional medical device (spinal implant) undergoing a 510(k) submission, which relies on demonstrating substantial equivalence through engineering testing and material characterization, not machine learning or AI models that require training sets.

    9. How the Ground Truth for the Training Set Was Established:

    This information is not applicable for the reasons stated in point 8.

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