Vertaplex® High Viscosity (HV) Radiopaque Bone Cement
Applicant
Stryker Corporation
Product Code
NDN · Orthopedic
Decision Date
Jun 12, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3027
Device Class
Class 2
Attributes
Therapeutic, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K150582 · Jun 12, 2015
Vertaplex® High Viscosity (HV) Radiopaque Bone Cement
Stryker Corporation
Published clinical literature
The sponsor conducted an extensive literature review to support the safety and efficacy of PMMA bone cement when used in the sacrum and for sacral vertebroplasty/sacroplasty procedures.
Literature review; Sacroplasty; PMMA bone cement; Clinical outcomes
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Extensive literature review of PMMA use in the vertebral body and sacrum; Literature review
Patients undergoing sacral vertebroplasty or sacroplasty
Not applicable for this study
Safety and efficacy of PMMA in sacral procedures
Indications for Use
VertaPlex HV Radiopaque Bone Cement is indicated for the fixation of pathological fractures of the vertebral body using vertebroplasty or kyphoplasty. It is also indicated for the fixation of pathological fractures of the sacral vertebral body or ala using sacral vertebroplasty or sacroplasty. Painful vertebral compression fractures may result from osteoporosis, benign lesions (hemangioma), and malignant lesions (metastatic cancers, myeloma).
Device Story
VertaPlex HV Radiopaque Bone Cement is a PMMA-based bone cement consisting of a powder component (polymer and barium sulfate) and a liquid monomer component. Components are mixed to initiate polymerization, creating a pourable, injectable material that cures into a hardened acrylic structure. Used by physicians trained in vertebral augmentation and acetabuloplasty to provide long-term load support and bone augmentation for pathological fractures of the vertebral body and sacrum. The device is administered intraoperatively under imaging guidance. The hardened cement stabilizes the fracture site, potentially reducing pain and restoring structural integrity to the affected bone. No software or electronic components are involved.
Clinical Evidence
No clinical trials were performed. Evidence consists of a cadaveric study (n=not specified) comparing long-axis vs. short-axis techniques for sacroplasty to assess cement extravasation. Results showed zero instances of extravasation using either technique when performed with meticulous imaging guidance and post-procedural positioning. Supporting evidence includes an extensive literature review on the safety and efficacy of PMMA in the vertebral body and sacrum.
Technological Characteristics
PMMA bone cement consisting of polymer powder (14g), monomer liquid (9.5ml), and barium sulfate (6g) for radiopacity. Polymerization-based hardening. Sterilization via Ethylene Oxide (EO). No electronic, software, or connectivity components.
Indications for Use
Indicated for fixation of pathological fractures of vertebral body or sacral vertebral body/ala via vertebroplasty, kyphoplasty, or sacroplasty. Patient population includes those with painful vertebral compression fractures due to osteoporosis, benign lesions (hemangioma), or malignant lesions (metastatic cancers, myeloma).
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
Stryker® VertaPlex HV Radiopaque Bone Cement (K091606)
Submission Summary (Full Text)
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 12, 2015
Stryker Corporation Ms. Kristi Ashton Staff Regulatory Affairs Specialist 4100 East Milham Avenue Kalamazoo, Michigan 49001
Re: K150582
Trade/Device Name: VertaPlex® High Viscosity (HV) Radiopaque Bone Cement Regulation Number: 21 CFR 888.3027 Regulation Name: Polymethylmethacrylate (PMMA) bone cement Regulatory Class: Class II Product Code: NDN, LOD Dated: May 15, 2015 Received: May 18, 2015
Dear Ms. Ashton:
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 - Ms. Kristi Ashton
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 (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely vours.
## Lori A. Wiggins -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
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.
510(k) Number (if known) K150582
Device Name Vertaplex® High Viscosity (HV) Radiopaque Bone Cement
- Indications for Use (Describe) vertaPlex HV Radiopaque Bone Cement is indicated for the fixation of patholoqical fractures of the vertebral body usinq vertebroplasty or kyphoplasty. It is also indicated for the fixation of pathological fractures of the sacral vertebral body or ala using sacral vertebroplasty or sacroplasty. Painful vertebral compression fractures may result from osteoporosis, benign lesions (hemangioma), and malignant lesions (metastatic cancers, myeloma).
Type of Use (*Select one or both, as applicable*)
| <div> <b> <span style="font-size:14px">✘</span> </b> Prescription Use (Part 21 CFR 801 Subpart D) </div> |
|-----------------------------------------------------------------------------------------------------------------|
| <div> <span>☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
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# 510(k) Summary
#### l. Contact Details
| a. 510(k) Owner: | Stryker Instruments<br>4100 E. Milham Avenue<br>Kalamazoo, Michigan 49001<br>USA<br>Ph: +1-269-323-7700<br>Fax: +1-269-324-5412 |
|----------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|
| b. FDA Establishment<br>Registration Number: | 1811755 |
| c. Contact Person: | Kristi Ashton<br>Ph: +1-269-389-5929<br>Fax: +1-269-389-5412<br>Kristi.Ashton @ Stryker.com |
| d. Date Submitted: | June 11, 2015 |
#### II. Subject Device Name
| Table 5-1-Subject Devices | |
|---------------------------|---------------------------------------------------------------|
| Name | Stryker® VertaPlex High Viscosity (HV) Radiopaque Bone Cement |
| Product code | NDN (primary)<br>LOD (secondary) |
| Class | II |
| Regulation | 21 CFR 888.3027 Polymethylmethacrylate (PMMA) bone cement |
| Part Names and Numbers | 0406-622-000- VertaPlex HVTM (Dual Pack) |
| | 0406-622-015- VertaPlex HVTM (Single Pack) |
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#### III. Legally Marketed Predicate Device (s)
| Predicate Devices | |
|-----------------------------|----------------------------------------------------------------------------------------|
| Table 5-2- Predicate Device | |
| Name | Stryker® VertaPlex HV Radiopaque Bone Cement |
| 510(k) Number | K091606 |
| Product Code(s) | NDN (primary)<br>LOD (secondary) |
| Regulation | 21 CFR 888.3027 (Polymethylmethacrylate (PMMA) bone cement |
| Class | II |
| Part Names and Numbers | 0406-622-000- VertaPlex HVTM (Dual Pack)<br>0406-622-015- VertaPlex HVTM (Single Pack) |
## dicate Devices
Tables 5-1 and 5-2 identify and describe the predicate device that is currently in commercial distribution, and the subject device of this premarket notification.
## IV. Device Description
VertaPlex® HV Radiopaque Bone Cement is comprised of a liquid component and powder component which when mixed together polymerize to form a hardened acrylic polymer. The mixture is in a pourable and injectable state for a period of time, before it cures to form a hardened structure, capable of long-term load support and bone augmentation in the treatment of symptomatic osteoporotic vertebral compression fractures.
The powder component of VertaPlex® HV Radiopaque Bone Cement is EO(Ethylene Oxide) sterilized and is packaged in a polyethylene/foil pouch while the liquid monomer is aseptically filled into an amber glass ampoule which is EO sterilized. The device contains the following components: Polymer powder (14g), Monomer liquid (9.5ml), and Barium Sulfate (6g
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#### V. Indications for use
VertaPlex HV Radiopaque Bone Cement is indicated for the fixation of pathological fractures of the vertebral body using vertebroplasty or kyphoplasty. It is also indicated for the fixation of pathological fractures of the sacral vertebral body or ala using sacral vertebroplasty or sacroplasty. Painful vertebral compression fractures may result from osteoporosis, benign lesions (hemangioma), and malignant lesions (metastatic cancers, myeloma).
## VI. Substantial Equivalence Comparison
Stryker® VertaPlex HV Radiopaque Bone Cement is substantially equivalent to the predicate Stryker® VertaPlex HV Radiopaque Bone Cement (K091606). Stryker® VertaPlex HV Radiopaque Bone Cement has an equivalent intended use, mechanism for use, and mode of action as compared to the predicate device. There have been no changes to the device's fundamental scientific technology or intended use, and yielded no increased risk to safety or effectiveness.
| Feature | VertaPlex HV<br>(Subject) | VertaPlex HV<br>(Predicate)<br>K091606 | Explanation of<br>Differences |
|------------------------------------|----------------------------------------------|----------------------------------------------|-------------------------------|
| Classification | Class II | Class II | Identical |
| Primary Product<br>Code | NDN | NDN | Identical |
| Primary<br>Regulation | 888.3027<br>(Cement,Bone,<br>Vertebroplasty) | 888.3027<br>(Cement,Bone,<br>Vertebroplasty) | Identical |
| Secondary<br>Product Code | LOD | LOD | Identical |
| Regulation | 888.3027<br>(Bone Cement) | 888.3027 (Bone<br>Cement) | Identical |
| Regulation<br>description | Polymethylmethacrylate<br>(PMMA) bone cement | Polymethylmethacrylate<br>(PMMA) bone cement | Identical |
| Regulation<br>Medical<br>Specialty | Orthopedic | Orthopedic | Identical |
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Instruments
| Feature | VertaPlex HV<br>(Subject) | VertaPlex HV<br>(Predicate)<br>K091606 | Explanation of<br>Differences |
|------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------|
| Indications for<br>Use | VertaPlexHV<br>Radiopaque Bone<br>Cement is indicated for<br>the fixation of<br>pathological fractures of<br>the vertebral body using<br>vertebroplasty or<br>kyphoplasty. It is also<br>indicated for the fixation<br>of pathological fractures<br>of the sacral vertebral<br>body or ala using sacral<br>vertebroplasty or<br>sacroplasty. Painful<br>vertebral compression<br>fractures may result<br>from osteoporosis,<br>benign lesions<br>(hemangioma), and<br>malignant lesions<br>(metastatic cancers,<br>myeloma). | VertaPlex HV<br>Radiopaque Bone<br>Cement both are<br>indicated for the fixation<br>of pathological fractures<br>of the vertebral body<br>using vertebroplasty or<br>kyphoplasty<br>procedures. Painful<br>vertebral compression<br>fractures may result<br>from osteoporosis,<br>benign lesions<br>(hemangioma), and<br>malignant lesions<br>(metastatic cancers,<br>myeloma). | Expanded indication<br>to include vertebral<br>body and sacrum<br>and use in sacral<br>vertebroplasty or<br>sacroplasty. |
| Anatomical Sites | Vertebral body and<br>sacrum | Vertebral body | Addition of<br>Indications for Use<br>to include the<br>vertebral body and<br>sacrum |
## VII. Non-Clinical
A cadaveric study in support of the expanded indication was completed. entitled: A Study of Extravasation of Stryker® VertaPlex® HV Radiopaque Bone Cement Comparing the Meticulous Intraoperative Long Axis Versus Short Axis Techniques for Sacroplasty in Osteoporotic Cadavers. This cadaveric study was conducted to provide data and guidelines as to the most conservative approach
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for sacroplasty procedures, to mitigate the risk for extravasation in sacroplasty procedures.
No instances of cement extravasation after administration of VertaPlex HV Radiopaque Bone Cement were observed in the cadavers included in this study, using the long-axis technique or the short-axis technique. The results of this cadaveric study demonstrate no difference in the occurrence of cement extravasation after administration of VertaPlex HV Radiopaque Cement between the long- and short-axis techniques when the sacroplasty procedure is performed with meticulous imaging quidance by a physician who is trained and experienced in vertebral augmentation and acetabuloplasty and when careful post-procedural positioning is used.
Risk of extravasation specific to the new expanded anatomical area can be mitigated with the use of the guidance developed through completion of the cadaveric study which established surgical guidelines. These surgical guidelines, established by Stryker, are titled "Surgical Procedure - Long and Short Axis Sacroplasty Techniques with Post-Procedure Positioning and CT Evaluation."
## VIII. Substantial Equivalence Conclusion
There have been no changes to the device since the previous clearance. Minor modifications to the packaging had no impact on the device's fundamental scientific technology or intended use, and yielded no increased risk to safety or effectiveness.
The additional Indications for Use to include the vertebral body and sacrum and sacroplasty procedures are supported by the clinical literature and the cadaveric study report. The cadaveric study vielded information to help mitigate the risk of extravasation with the use of the guidance established by Stryker titled "Surgical Procedure - Long and Short Axis Sacroplasty Techniques with Post-Procedure Positioning and CT Evaluation." In addition, the extensive literature review reveals the safety and efficacy of PMMA when used in the vertebral body and sacrum and in sacral vertebroplasty or sacroplasty procedures.
The information submitted herein supports the substantial equivalence of Stryker® Verteplex® HV Radiopaque Bone Cement for use in the vertebral body and sacrum and in sacral vertebroplasty or sacroplasty procedures.
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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).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
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.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
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.
7. Product codes and the regulations tree
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What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
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.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
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.