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510(k) Data Aggregation

    K Number
    K232611
    Manufacturer
    Date Cleared
    2023-11-30

    (94 days)

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

    TruLift Micro Expandable Spacer System & TruLift Expandable Spacer System

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

    When used as an interbody fusion device, the TruLift® Micro Expandable System is intended for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels (L2-S1). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. DDD patients may also have up to Grade 1 spondylolisthesis at the involved level(s). It is to be used in patients who have had at least six months of non-operative treatment. Patients with previous non-fusion spinal surgery at involved level(s) may be treated with the device. This device is intended to be used with autograft bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone and a supplemental internal spinal fixation system (e.g., pedicle screw or anterolateral plating system) that is cleared for use in the lumbosacral spine.

    When used as an interbody fusion device, the TruLift® Expandable System is intended for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels (L2-S1). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies. DDD patients may also have up to Grade 1 spondylolisthesis at the involved level(s). It is to be used in patients who have had at least six months of non-operative treatment. Patients with previous non-fusion spinal surgery at involved level(s) may be treated with the device. This device is intended to be used with autograft bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone and a supplemental internal spinal fixation system (e.g., pedicle screw or anterolateral plating system) that is cleared for use in the lumbosacral spine.

    Device Description

    The TruLift® Micro Expandable System is available in a range of sizes and footprints and can expand to the desired height (8mm to 16mm) to suit the individual pathology and anatomical conditions of the patient. It is fabricated and manufactured from titanium alloy (Ti-6Al-4V ELI) and Cobalt Chrome (CO-26Cr-6MO) as described by ASTM F136and ASTM F1537. The implant allows packing of autograft bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone to help promote fusion. The superior and inferior surfaces have teeth to assist in the interface with the vertebral bodies to prevent rotation and/or migration. All implants are provided sterile and intended for SINGLE USE ONLY and should not be reused under any circumstances. Do not use any of the TruLift® Micro Expandable System components with components from any other system or manufacturer. The TruLift® Micro Expandable System components should never be reused under any circumstances.

    The TRULIFT® Expandable Spacer System is available in a range of sizes and footprints and can expand to the desired height (8mm to 16mm) to suit the individual pathology and anatomical conditions of the patient.
    · The 8mm-9mm width implants are fabricated and manufactured from titanium alloy (Ti-6Al-4V ELI) and Cobalt Chrome (CO-26Cr-6MO) as described by ASTM F136 & ASTM F1537
    · The 10mm-12mm width implants are fabricated and manufactured from titanium alloy (Ti-6Al-4V ELI) as described by ASTM F136.

    The implant allows packing of autograft bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone to help promote fusion. The superior and inferior surfaces have teeth to assist in the interface with the vertebral bodies to prevent rotation and/or migration.

    All implants are provided sterile and intended for SINGLE USE ONLY and should not be reused under any circumstances. Do not use any of the TRULIFT® Expandable Spacer System components with components from any other system or manufacturer. The TRULIFT® Expandable Spacer System components should never be reused under any circumstances.

    AI/ML Overview

    This FDA 510(k) summary describes the TruLift Micro Expandable Spacer System & TruLift Expandable Spacer System, an intervertebral body fusion device. The document focuses on demonstrating substantial equivalence to predicate devices rather than providing a detailed study proving the device meets specific acceptance criteria in the context of an AI/ML medical device.

    Therefore, many of the requested categories (e.g., sample size for test set, number of experts, adjudication method, MRMC study, standalone performance, training set details) are not applicable as this pertains to a physical orthopedic implant, not an AI/ML algorithm or software.

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for this type of medical device generally revolve around demonstrating mechanical performance equivalence to legally marketed predicate devices. The reported performance refers to the results of these mechanical tests.

    Acceptance Criteria CategorySpecific Acceptance Criteria (Implied)Reported Device Performance (Summary)
    Mechanical PerformanceStatic Axial Compression performance equivalent to predicate devices.Static Axial Compression testing according to ASTM F2077 was presented to demonstrate the substantial equivalency. (Specific numerical reported performance is not detailed in this summary, but the conclusion states "substantial equivalency" was shown.)
    Dynamic Axial Compression performance equivalent to predicate devices.Dynamic Axial Compression testing according to ASTM F2077 was presented to demonstrate the substantial equivalency.
    Static Shear performance equivalent to predicate devices.Static Shear testing according to ASTM F2077 was presented to demonstrate the substantial equivalency.
    Dynamic Shear performance equivalent to predicate devices.Dynamic Shear testing according to ASTM F2077 was presented to demonstrate the substantial equivalency.
    BiocompatibilityMaterials used are biocompatible and equivalent to predicate devices.The device is fabricated from titanium alloy (Ti-6Al-4V ELI) and Cobalt Chrome (Co-26Cr-6Mo) per ASTM F136 and ASTM F1537, which are "the same material used in the predicate devices." Implied acceptance is that these materials are already established as biocompatible for this application.
    Design and FunctionDesign and function are substantially equivalent to predicate devices.The device is available in a range of sizes and footprints, expands to desired height (8mm to 16mm), allows packing of bone graft, and has superior/inferior teeth – all described as substantially equivalent to predicate systems in terms of design, materials, indications for use, and sizing.
    SterilityProvided sterile and intended for single use."All implants are provided sterile and intended for SINGLE USE ONLY." (This is a design and labeling requirement, not a performance metric in the same sense as mechanical testing, but crucial for safety).
    Indications for UseIndications for Use are equivalent to predicate devices.The stated Indications for Use (spinal fusion for DDD at one or two contiguous levels L2-S1, up to Grade 1 spondylolisthesis, after 6 months non-operative treatment, with autograft/allograft and supplemental fixation) are stated to be substantially equivalent to predicate devices.

    The study that proves the device meets the acceptance criteria is the demonstration of substantial equivalence through mechanical performance testing (Static Axial Compression, Dynamic Axial Compression, Static Shear, and Dynamic Shear according to ASTM F2077), and comparison of materials, design, and indications for use to legally marketed predicate devices.

    Information Not Applicable to This Device (AI/ML Specifics)

    1. Sample size used for the test set and the data provenance: Not applicable. This is a physical implant, not an AI/ML algorithm evaluated on a data set. The "test set" here refers to physical specimens subject to mechanical testing. The provenance isn't described in terms of "country of origin of data" but rather the standards (ASTM F2077) governing the testing.
    2. Number of experts used to establish the ground truth... and qualifications: Not applicable. Ground truth for an orthopedic implant's mechanical performance is established by standardized material and mechanical tests (e.g., ASTM standards), not expert interpretation of images or clinical data.
    3. Adjudication method: Not applicable for a physical implant's mechanical testing.
    4. Multi-reader multi-case (MRMC) comparative effectiveness study: Not applicable. This is a physical medical device, not an AI assistance tool for human readers.
    5. Standalone (i.e. algorithm only without human-in-the-loop performance): Not applicable. This is a physical implant.
    6. The type of ground truth used: For mechanical properties, the "ground truth" is defined by the physical properties measured under standardized testing conditions and compared against performance of predicate devices. For biocompatibility, it's the established safety profile of the materials. For indications for use, it's alignment with predicate devices.
    7. The sample size for the training set: Not applicable. This is not an AI/ML model that undergoes "training."
    8. How the ground truth for the training set was established: Not applicable.

    In summary, for K232611, the "study" demonstrating device acceptance is the suite of mechanical tests and comparative analysis against predicate devices, which collectively establish substantial equivalence as required for 510(k) clearance by the FDA. The specifics of these mechanical tests (e.g., number of samples per test type, detailed results) are typically found in the full 510(k) submission, not in the public summary.

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