CONFIDENCE HIGH VISCOSITY SPINAL CEMENT, 16G / 20G
K112907 · Medos International SARL · NDN · Dec 22, 2011 · Orthopedic
Device Facts
Record ID
K112907
Device Name
CONFIDENCE HIGH VISCOSITY SPINAL CEMENT, 16G / 20G
Applicant
Medos International SARL
Product Code
NDN · Orthopedic
Decision Date
Dec 22, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3027
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
CONFIDENCE High Viscosity Spinal Cement is indicated for the fixation of pathological fractures of the vertebral body using vertebroplasty or kyphoplasty procedures. Painful vertebral compression fractures may result from osteoporosis, benign lesions (haemangioma), or malignant lesions (metastatic cancers, myeloma).
Device Story
CONFIDENCE High Viscosity Spinal Cement is a self-curing, radiopaque PMMA bone cement used to fill spinal vertebral body defects. It provides vertebral body stabilization and pain relief. Used by physicians in clinical settings during vertebroplasty or kyphoplasty procedures. The cement is delivered into the vertebral body to fixate fractures. It benefits patients by stabilizing painful compression fractures caused by osteoporosis or lesions.
Clinical Evidence
No clinical data provided. Substantial equivalence is based on design, material, and performance testing comparisons to predicate devices.
Technological Characteristics
Self-curing, radiopaque polymethyl methacrylate (PMMA) bone cement. Supplied in 16g and 20g unit sizes. Sterilization method is the same as predicate devices.
Indications for Use
Indicated for fixation of pathological vertebral body fractures via vertebroplasty or kyphoplasty in patients with painful vertebral compression fractures due to osteoporosis, benign lesions (haemangioma), or malignant lesions (metastatic cancers, myeloma). Contraindicated in acute traumatic fractures, patients improving on medical therapy, prophylaxis in asymptomatic patients, spinal stenosis >20%, posterior wall/pedicle compromise, vertebral collapse >67% (height <1/3), vertebral plana (>90% collapse), active infection, coagulopathy, severe pulmonary insufficiency, or component sensitivity.
Regulatory Classification
Identification
Polymethylmethacrylate (PMMA) bone cement is a device intended to be implanted that is made from methylmethacrylate, polymethylmethacrylate, esters of methacrylic acid, or copolymers containing polymethylmethacrylate and polystyrene. The device is intended for use in arthroplastic procedures of the hip, knee, and other joints for the fixation of polymer or metallic prosthetic implants to living bone.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance Document: Polymethylmethacrylate (PMMA) Bone Cement.”
Predicate Devices
Disc-O-Tech Confidence High Viscosity Spinal Cement (K060300)
DePuy Spine Vertebroplastic™ Radiopaque Bone Cement (K071927)
Submission Summary (Full Text)
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i12907
# 510(k) Summary
# DEC 2 2 2011
| Date Summary Prepared: | 30 September 2011 |
|------------------------|-------------------|
|------------------------|-------------------|
510(k) Sponsor: Medos International SARL Chemin-Blanc 38 Le Locle CH 2400 Switzerland
#### Establishment Registration number: 3008114965
Contact Person:
Robin DiNardo Director, Regulatory Affairs DePuy Spine, Inc. 325 Paramount Drive Raynham MA 02767-0350 USA
Telephone: +1 508 828 3218 Fax: +1 508 828 3797 Email: rdinardo@its.jnj.com
Device Manufacturer: Medos International SARL Chemin-Blanc 38 Le Locle CH 2400 Switzerland
Trade Name of Device: CONFIDENCE High Viscosity Spinal Cement
Part Numbers: 183907001 (16 g Unit Size)
183901001 (20 g Unit Size)
Product Code: NDN
Cement, bone, vertebroplasty
Common Name: PMMA Bone Cement
Classification Name:
Equivalent to:
Disc-O-Tech Confidence High Viscosity Spinal Cement (K060300) DePuy Spine Vertebroplastic™ Radiopaque Bone Cement (K071927)
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#### Device Description:
CONFIDENCE High Viscosity Spinal Cement is self-curing, radiopaque, polymethyl methacrylate (PMMA) cement, for filling of spinal vertebral body defects, in order to provide stabilisation of the vertebral body and pain relief.
#### Indications for Use:
CONFIDENCE High Viscosity Spinal Cement is indicated for the fixation of pathological fractures of the vertebral body using vertebroplasty or kyphoplasty procedures. Painful vertebral compression fractures may result from osteoporosis, benign lesions (haemangioma), or malignant lesions (metastatic cancers, myeloma).
#### Contra-indications for Use:
The use of CONFIDENCE High Viscosity Spinal Cement is contraindicated in patients presenting with any of the following conditions:
- Non-pathological, acute, traumatic fractures of the vertebra. .
- . Patient clearly improving on medical therapy.
- Prophylaxis in metastatic or osteoporotic patients with no evidence of acute fracture .
- Spinal stenosis (> 20% by retropulsed fragments). .
- . Compromise of the vertebral body or walls of the pedicles.
- . Compromise or instability of vertebral fractures due to posterior involvement.
- . Haemorrhagic diathesis.
- . Anatomical damage of the vertebra that prevents a safe access of the needle to the vertebral body.
- . Vertebral body collapse to less than 1/3 (33%) original height.
- Vertebral plana (collapse >90%). .
- Active or incompletely treated infection. .
- Coagulopathy or inability to reverse anti-coagulant therapy (both during and . approximately 24 hours post-procedure).
- . Severe pulmonary insufficiency.
- . Sensitivity to any of the components of the CONFIDENCE High Viscosity Spinal Cement.
### Basis for Substantial Equivalence:
The Medos International SARL CONFIDENCE High Viscosity Spinal Cement has identical intended use and indications for use to the predicate devices Disc-O-Tech Confidence High Viscosity Spinal Cement (K060300) and DePuy Spine Inc Vertebroplastic " Radiopaque Bone Cement (K071927).
The packaging of the subject device is equivalent to the predicate device Disc-O-Tech Confidence High Viscosity Spinal Cement (K060300), and the manufacturing and sterilization methods are the same as both predicate devices. Chemical composition of the Medos International SARL CONFIDENCE High Viscosity Spinal Cement is similar to
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subject devices, and testing has confirmed the devices to have comparable performance characteristics.
Based on the similarities in indications, intended use, design, materials, method of manufacture and the results of performance testing, Medos International SARL believes that the subject device CONFIDENCE High Viscosity Spinal Cement is substantially equivalent to the previously cleared devices.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three heads, representing the department's commitment to health, human services, and science. The eagle is positioned to the right of the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA", which is arranged in a circular fashion around the left side of the logo.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
DEC 2 2 2011
Medos International SARL % DePuy Spine, Inc. Ms. Robin DiNardo 325 Paramount Drive Raynham, Massachusetts 02767
Re: K112907
Trade/Device Name: CONFIDENCE High Viscosity Spinal Cement Regulation Number: 21 CFR 888.3027 Regulation Name: Polymethylmethacrylate (PMMA) bone cement Regulatory Class: Class II Product Code: NDN Dated: September 30, 2011 Received: October 03, 2011
Dear Ms. DiNardo:
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. 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
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Page 2 - Ms. Robin DiNardo
or any Federal 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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Mark N. McMullen
Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Device Name:
#### CONFIDENCE High Viscosity Spinal Cement
Indications for Use:
CONFIDENCE High Viscosity Spinal Cement is indicated for the fixation of pathological fractures of the vertebral body using vertebroplasty or kyphoplasty procedures. Painful vertebral compression fractures may result from osteoporosis, benign lesions (haemangioma), or malignant lesions (metastatic cancers, myeloma).
Prescription Use YES (Part 21 CFR 801 Subpart D)
Over-The-Counter Use NO AND/OR (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Offige of Device Evaluation (ODE)
signature
(DKIslon Sigilia :1) (Division Sign=on Surgical, Orthopedic, and Restorative Devices
510(k) Number K112907
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
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Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
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Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
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Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.