SPINEFRONTIER ARENA-C HA PEEK CERVICAL INTERVERTEBRAL BODY FUSION DEVICE

K142026 · Spinefrontier, Inc. · ODP · Oct 20, 2014 · Orthopedic

Device Facts

• Record ID: K142026
• Device Name: SPINEFRONTIER ARENA-C HA PEEK CERVICAL INTERVERTEBRAL BODY FUSION DEVICE
• Applicant: Spinefrontier, Inc.
• Product Code: ODP · Orthopedic
• Decision Date: Oct 20, 2014
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The SpineFrontier Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is a spinal intervertebral body fusion device intended for intervertebral body fusion of the spine of skeletally mature patients, using autogenous bone graft to facilitate fusion. The device is indicated for use in patients with degenerative disc disease (DDD) of the cervical spine at one disc level from the C2-C3 disc to the C7-T1 disc. The SpineFrontier® Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is intended to be used with supplemental spinal fixation system(s) cleared for use in the cervical spine (example: Anterior Cervical Plate Fixation). Degenerative disc disease is defined as discogenic pain with degeneration of the disc confirmed by history or radiographic studies. These patients should be skeletally mature and have had six (6) weeks of non-operative treatment prior to treatment with an intervertebral cage.

Device Story

Spinal intervertebral body fusion device; used in cervical spine (C2-T1) for degenerative disc disease. Implanted by surgeons; requires supplemental fixation (e.g., anterior cervical plate). Device provides structural support; facilitates fusion via autogenous bone graft. Features raised contours for stability; includes tantalum markers for radiographic visualization. Available in straight and lordotic (6°) configurations; various footprints and heights. Non-sterile; single-use.

Clinical Evidence

Bench testing only. Mechanical testing included static/dynamic axial compression, torsion, compressive shear (ASTM F2077), subsidence (ASTM F2267), and expulsion (ASTM Draft F-04.25.02.02). Biocompatibility testing per ISO 10993 included a large animal in-bone study and fusion assessment. Material characterization confirmed retention of HA and mechanical performance after artificial aging.

Technological Characteristics

Materials: PEEK-OPTIMA HA, tantalum markers. Form factor: Cervical intervertebral cage, straight or 6° lordotic, various footprints/heights. Mechanical testing standards: ASTM F2077, ASTM F2267. Biocompatibility: ISO 10993. Non-sterile, single-use.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) of the cervical spine at one level (C2-C3 to C7-T1) requiring intervertebral body fusion with autogenous bone graft. Requires use with supplemental cervical spinal fixation. Patients must have failed 6 weeks of 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

• Arena-C Cervical Intervertebral Body Fusion System (K113518)
• Interbody Fusion System (Copperhead) (K090064)
• Daytona Anterior Cervical Cage (K110733)

Submission Summary (Full Text)

{0}------------------------------------------------

Image /page/0/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a stylized image of three human profiles facing right, with flowing lines connecting them. The profiles are arranged in a way that suggests unity and connection. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the image.

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

October 20, 2014

SpineFrontier, Incorporated % Meredith L. May, MS, RAC Empirical Consulting, LLC 4628 Northpark Drive Colorado Springs, Colorado 80918

Re: K142026

Trade/Device Name: Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: ODP Dated: July 23, 2014 Received: July 25, 2014

Dear Ms. May:

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

{1}------------------------------------------------

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 Industry and Consumer Education at its toll-free 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 Industry and Consumer Education 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 DAJean -S for

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

Enclosure

{2}------------------------------------------------

K142026 Page 1 of 2

| DEPARTMENT OF HEALTH AND HUMAN SERVICES<br>Food and Drug Administration | Form Approved: OMB No. 0910-0120<br>Expiration Date: January 31, 2017<br>See PRA Statement on last page. |
|-------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|
|-------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|

**Indications for Use**

| 510(k) Number (if known) | K142026 |
|--------------------------------|-------------------------------------------------------------|
| Device Name | Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device |
| Indications for Use (Describe) | |

The SpineFrontier Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is a spinal intervertebral body fusion device intended for intervertebral body fusion of the spine of skeletally mature patients, using autogenous bone graft to facilitate fusion. The device is indicated for use in patients with degenerative disc disease (DDD) of the cervical spine at one disc level from the C2-C3 disc to the C7-T1 disc.

The SpineFrontier® Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is intended to be used with supplemental spinal fixation system(s) cleared for use in the cervical spine (example: Anterior Cervical Plate Fixation).

Degenerative disc disease is defined as discogenic pain with degeneration of the disc confirmed by history or radiographic studies. These patients should be skeletally mature and have had six (6) weeks of non-operative treatment prior to treatment with an intervertebral cage.

| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|
| <span style="font-family: DejaVu Sans, sans-serif">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="font-family: DejaVu Sans, sans-serif">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |

PLEASE DO NOT WRITE BELOW THIS LINE – CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

FORM FDA 3881 (9/13)

PSC Publishing Services [phone] EF

{3}------------------------------------------------

This section applies only to requirements of the Paperwork Reduction Act of 1995. *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: Department of Health and Human Services

Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff [e-mail]

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

FORM FDA 3881 (9/13)

{4}------------------------------------------------

## 510(K) SUMMARY

| Submitter's Name: | SpineFrontier Inc. |
|----------------------------|---------------------------------------------------------------------|
| Submitter's Address: | 500 Cummings Center, Suite 3500<br>Beverly, MA 01915, U.S.A. |
| Submitter's Telephone: | 978.232.3990 x116 |
| Contact Person: | Meredith L. May MS, RAC<br>Empirical Consulting LLC<br>719.337.7579 |
| Date Summary was Prepared: | October 8, 2014 |
| Trade or Proprietary Name: | Arena-C® HA PEEK Cervical Intervertebral Body Fusion<br>Device |
| Common or Usual Name: | Intervertebral Fusion Device With Bone Graft, Cervical |
| Classification: | Class II per 21 CFR §888.3080 |
| Product Code: | ODP |

DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION:

The Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is a spinal intervertebral body fusion device intended for intervertebral body fusion of the spine of skeletally mature patients, using autogenous bone graft to facilitate fusion. The device is indicated for use in patients with degenerative disc disease (DDD) of the cervical spine at one disc level from the C2-C3 disc to the C7-T1 disc. The system is comprised of devices made of PEEK OPTIMA® HA, with various heights to fit the anatomical needs of a wide variety of patients. The device has raised contours on the superior and inferior surfaces that will resist the device movement following implantation.

The implants are provided in two configurations: straight and lordotic (6°) implant sizes for both configurations are offered in three footprints (12x14mm, 11x17mm) and heights from 5mm - 12mm, in 1mm increments.

The SpineFrontier Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is intended to be used with supplemental spinal fixation system(s) cleared for use in the cervical spine (example: Anterior Cervical Plate Fixation).

Degenerative disc disease is defined as discogenic pain with degeneration of the disc confirmed by history or radiographic studies. These patients should be skeletally mature and have had six (6) weeks of non-operative treatment prior to treatment with an intervertebral cage.

The Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device components are supplied non-sterile, are single use, and are fabricated from PEEK-OPTIMA® HA and contain tantalum markers for radiographic visualization.

Indications for Use

{5}------------------------------------------------

The SpineFrontier Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is a spinal intervertebral body fusion device intended for intervertebral body fusion of the spine of skeletally mature patients, using autogenous bone graft to facilitate fusion. The device is indicated for use in patients with degenerative disc disease (DDD) of the cervical spine at one disc level from the C2-C3 disc to the C7-T1 disc.

The SpineFrontier Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device intended to be used with supplemental spinal fixation system(s) cleared for use in the cervical spine (example: Anterior Cervical Plate Fixation).

Degenerative disc disease is defined as discogenic pain with degeneration of the disc confirmed by history or radiographic studies. These patients should be skeletally mature and have had six (6) weeks of non-operative treatment prior to treatment with an intervertebral cage.

The indications for use for the Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is identical to that of the Arena-C® Cervical Intervertebral Body Fusion System (K113518).

## TECHNOLOGICAL CHARACTERISTICS

The SpineFrontier Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device was shown to be substantially equivalent to predicate devices through comparison of indications for use, function, operating principles, and materials. Specifically the following characteristics were compared between the subject and predicates:

- Indications for Use ●
- Structural support mechanism ●
- Materials of manufacture ●

| Table 5-1 Primary Predicate Device | |
|------------------------------------|--|
|------------------------------------|--|

| 510k Number | Trade or Proprietary or Model Name | Manufacturer |
|-------------|----------------------------------------------------|---------------|
| K113518 | Arena-C Cervical Intervertebral Body Fusion System | SpineFrontier |

#### Table 5-2 Additional Predicate Devices

| 510k Number | Trade or Proprietary or Model Name | Manufacturer |
|-------------|--------------------------------------|---------------|
| K090064 | Interbody Fusion System (Copperhead) | Eminent Spine |
| K110733 | Daytona Anterior Cervical Cage | SpineNet |

{6}------------------------------------------------

## PERFORMANCE DATA

The Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device has been tested in the following test modes:

- Mechanical Testing on both the final device and artificially aged device. ●
- Static Axial Compression per ASTM F2077 о
- Static Torsion per ASTM F2077 O
- o Static Compressive Shear per ASTM F2077
- Static Testing in Subsidence per ASTM F2267 O
- Static Testing in Expulsion per ASTM Draft Standard F-04.25.02.02 O
- Dynamic Axial Compression per ASTM F2077 O
- o Dynamic Torsion per ASTM F2077
- Material Characterization ●
- o Biocompatibility of PEEK-OPTIMA® HA Enhanced per ISO 10993. o including an in bone study using a large animal model, and fusion assessment.
- o Material characterization, retention of HA and mechanical performance of o PEEK-OPTIMA HA Enhanced following artificial aging.

The results of this non-clinical testing show that the strength of the Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices.

## CONCLUSION

The overall technology characteristics and mechanical performance data lead to the conclusion that the Arena-C® HA PEEK Cervical Intervertebral Body Fusion Device is substantially equivalent to the predicate device.