S128 ANTERIOR LUMBAR INTERBODY FUSION (ALIF) SYSTEM

K140106 · Renovis Surgical Technologies, Inc. · OVD · Mar 27, 2014 · Orthopedic

Device Facts

• Record ID: K140106
• Device Name: S128 ANTERIOR LUMBAR INTERBODY FUSION (ALIF) SYSTEM
• Applicant: Renovis Surgical Technologies, Inc.
• Product Code: OVD · Orthopedic
• Decision Date: Mar 27, 2014
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Indications for 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 Story

S128 ALIF System consists of intervertebral body fusion cages, bone screws, and anterior cover plate; used for lumbar spinal fusion. Implants manufactured from PEEK or Titanium alloy; Tantalum markers. Device implanted by surgeons in clinical settings to treat discogenic back pain. System functions as stand-alone device; requires cover plate and screws for stability. Provides structural support to vertebral space during fusion process; benefits patients by stabilizing spinal segments and facilitating bone growth. This submission introduces gamma sterilization for existing implant components.

Clinical Evidence

Bench testing only. Sterility validation performed per ISO 11137-1/2 (VDmax 35 method). Accelerated aging testing per ASTM F1980-7 and real-time aging confirmed PEEK and Titanium components maintain integrity after gamma sterilization. Packaging validated per ISO 11607-2 and ISTA 2A.

Technological Characteristics

Materials: PEEK (ASTM F2026), Titanium alloy Ti-6Al-4V (ASTM F136), Tantalum (ASTM F560-08). Components: Cages, bone screws, anterior cover plate. Sterilization: Gamma irradiation (25 kGy). Dimensions: A/P 26-30mm, M/L 30-38mm, H 11-21mm, Lordosis 7°-12°. Stand-alone fixation system.

Indications for Use

Indicated for intervertebral body fusion in skeletally mature patients with lumbar degenerative disc disease (DDD) at one or two contiguous levels (L2-S1). Includes patients with up to Grade 1 spondylolisthesis or retrolisthesis. Requires autogenous bone graft and at least six months of prior non-operative treatment.

Regulatory Classification

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.

Special Controls

*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.

Predicate Devices

• Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System (K131122)

Submission Summary (Full Text)

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# ORENOVIS

MAR 2 7 2014

### Special 510(k) Summary as required by 21 CFR 807.92(a) K140106

- Renovis Surgical Technologies, Inc. A ) Submitted by: 1901 W. Lugonia Ave, Ste 340 Redlands, CA 92374 Phone: [phone] Fax: [phone]
- Official Contact: Anthony DeBenedictis Vice President of Quality Assurance
- Sharyn Orton, Ph,D. Consultant: MEDIcept, Inc. 200 Homer Ave Ashland, MA 01721

February 28, 2014 Date:

B)

| Device Name: | Intervertebral Fusion Device With Bone Graft, Lumbar |
|------------------------------|------------------------------------------------------|
| Common Name: | Intervertebral body fusion device |
| Proprietary Name: | S128 Anterior Lumbar Interbody Fusion (ALIF) System |
| Device Class: | Class II – 888.3080 |
| Regulation and Product code: | 888.3080, OVD - Intervertebral body fusion device |

Classification panel: Orthopedic

#### C) Predicates:

- K131122 Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System .
#### D) Device Description:

The Renovis \$128 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

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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).

E) Indications For 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.

| | Renovis<br>S128 ALIF System | Renovis<br>S128 ALIF System<br>K131122 |
|---------------------------------------------------------|------------------------------------------------------------------------|----------------------------------------|
| Product code | OVD | |
| Implant Material<br>(cages, cover plate, and<br>screws) | PEEK (ZA-500) per ASTM F2026<br>Titanium alloy Ti-6Al-4V per ASTM F136 | |
| PEEK marker material | Tantalum per ASTM F 560-08 | |
| Dimensions (mm) | | |
| A/P | 26, 28, 30 | |
| M/L | 30, 34, 38 | |
| H | 11 - 21 | |
| Lordosis | 7°, 12° | |
| Number of screws | 4 | |
| Screw Diameter (mm) | 4.5, 5. | |
| Screw Length (mm) | 20, 25, 30, 35 | |
| Cover plate (mm) | 8.3 x 22 | |
| Provided sterile? | Yes - gamma | No |

F) Substantial Equivalence Comparison and Discussion

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#### Conclusion

Based upon the same intended use, design, function, technology, and materials, the Renovis SI28 ALIF System is substantially equivalent to the predicate devices and does not raise new issues of safety or effectiveness.

#### G) Performance Data

Implants are sterilized by 60 Gamma irradiation validated to a sterility assurance level (SAL) of 10th by selecting and substantiating a 25 kGy dose by the VDmax 35 method, according to ISO 11137-1. Titanium alloy components are not affected by gamma sterilization and/or aging. PEEK components were tested to an average dose of 200kGy and underwent accelerated aging to simulated 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 has been validated to maintain sterility for 3 years in compliance with ISO 11607-2 demonstrates compliance with accelerated aging simulation per ASTM F1980-7 and real time aging; and performance following distribution per ISTA 2A.

#### Conclusion

Gamma sterilization does not have a negative effect on Renovis S128 ALIF System implants.

H) Compliance with Design Controls

The results of design validation support that the Renovis S128 ALIF System is substantially equivalent to the predicate device and the offering of gamma irradiated implant components does not raise new issues of safety or effectiveness.

I) Compliance with Consensus Standards and FDA Guidance

#### Standards - Renovis complies with:

- ASTM F2026 Standard Specification for PEEK Polymers for Surgical Implant . Applications
- ASTM F136 Standard Specification for Wrought Titanium-6Aluminum-4Vanadium ELI . (Extra Low Interstitial) Alloy for Surgical Implant Applications, and
- ASTM F 560-08, Standard Specification for Unalloyed Tantalum for Surgical Implant . Applications
- . ISO 11137-1: 2006; Sterilization of health care products -- Radiation -- Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices
- ANSI/AAMI/ISO 11137-2:2006 Sterilization of health care products -- Radiation -- Part . 2: Establishing the sterilization dose
- ISO11607-2: 2006 Packaging for terminally sterilized medical devices -- Part 2: . Validation requirements for forming, sealing and assembly processes
- ASTM F1980-07: 2007 Standard Guide for Accelerated Aging of Sterile Barrier Systems . for Medical Devices

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- ASTM D4169:2009 Standard Practice for Performance Testing of Shipping Containers . and Systems
- ISTA 2A, 2011 Partial-Simulation Performance Test Procedure: Packaged Products . 150lb (68 kg) or Less

## FDA guidance:

- Updated 510(k) Sterility Review Guidance K90-1; Guidance for Industry and FDA, . August 2002
- . Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Intervertebral Body Fusion Device, October 2007
- Labeling Reusable Medical Devices for Reprocessing in Health Care Facilities: FDA . Review Guidance, April 1996
- Guidance for Industry and FDA Staff Spinal System 510(k)'s, May 2004 (for labeling . language)

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Image /page/4/Picture/0 description: The image shows the logo for the Department of Health & Human Services - USA. The logo features a stylized eagle or bird-like symbol with three curved lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the symbol.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

March 27, 2014

Renovis Surgical Technologies, Incorporated % Sharyn Orton, Ph.D. MEDIcept, Incorporated 200 Homer Avenue Ashland, Massachusetts 01721

Re: K140106

Trade/Device Name: Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: OVD Dated: March 5, 2014 Received: March 7, 2014

Dear Dr. Orton:

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 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

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#### Page 2 – Sharvn Orton. Ph.D.

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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number [phone] or [phone] or at its Internet address -

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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

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 [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

# Ronald P. Jean -S for

Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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#### Indications for Use Statement

510(k) Number (if known): K140106

Device Name: Renovis S128 Anterior Lumbar Interbody Fusion (ALIF) System

Indications for 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 I 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.

Prescription Use______________________________________________________________________________________________________________________________________________________________ (21 CFR 801, Subpart D)

Over-the-Counter Use _________________________________________________________________________________________________________________________________________________________ (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NECESSARY) NECESSARY)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Anton E. Dmitriev, PhD

Division of Orthopedic Devices