PROW FUSION

K151654 · Nlt Spine, Ltd. · MAX · Jul 17, 2015 · Orthopedic

Device Facts

• Record ID: K151654
• Device Name: PROW FUSION
• Applicant: Nlt Spine, Ltd.
• Product Code: MAX · Orthopedic
• Decision Date: Jul 17, 2015
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The PROW FUSION Intervertebral body fusion device is indicated for spinal fusion procedures at one or two contiguous levels from L2 through S1 in skeletally mature patients with degenerative disc disease (DDD). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by the history and radiographic studies. DDD patients may also have up to Grade I Spondylolisthesis or retrolisthesis at the involved levels. The patient may have had a previous non-fusion spinal surgery at the involved spinal level(s). The device is intended to be used with supplemental spinal fixation systems that have been cleared for use in the lumbosacral spine (e.g. posterior pedicle screw and rod systems). The device is intended to be used with autogenous bone graft. Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the PROW FUSION device. The PROW FUSION intervertebral body fusion device must be inserted using a transforaminal approach.

Device Story

Intervertebral body fusion device; used for spinal fusion procedures via transforaminal approach. Implant consists of PEEK mid-segments and titanium end-segments; segments connected by PEEK strip. Surgeon pulls distal segment proximally to form ring-shaped, closed-configuration implant within disc space. Used with autogenous bone graft and supplemental posterior pedicle screw/rod fixation. Implanted by orthopedic or neurosurgeons in clinical/OR setting. Provides structural support to disc space to facilitate fusion; benefits patients with DDD by stabilizing spinal segments and reducing pain.

Clinical Evidence

Bench testing only. Performed static axial compression testing per ASTM F2077, cadaver testing, and deployment force testing to demonstrate equivalence to predicate.

Technological Characteristics

System includes single-use PEEK and titanium alloy implant and reusable delivery instruments. Implant features 4 PEEK mid-segments, titanium end-segments with coarse surfaces, and titanium pins. Ring-shaped configuration achieved via PEEK strip pull mechanism. Static axial compression testing per ASTM F2077.

Indications for Use

Indicated for spinal fusion at one or two contiguous levels (L2-S1) in skeletally mature patients with degenerative disc disease (DDD), including those with up to Grade I Spondylolisthesis or retrolisthesis, or prior non-fusion surgery. Requires 6 months of failed 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

• PROW FUSION (K130254)

Submission Summary (Full Text)

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

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized human figure.

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

July 17, 2015

NLT SPINE, Limited % Mr. Jonathan S. Kahan Partner Hogan Lovells US LLP 555 Thirteenth Street, NW Washington, District of Columbia 20004

Re: K151654

Trade/Device Name: PROW FUSION Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: June 18, 2015 Received: June 18, 2015

Dear Mr. Kahan:

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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

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

Page 2 - Mr. Jonathan S. Kahan

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/Resourcesfor You/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 vours.

Mark N. Melkerson -S

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

Enclosure

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

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

#### Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known)

K151654

Device Name PROW FUSION

Indications for Use (Describe)

The PROW FUSION Intervertebral body fusion device is indicated for spinal fusion procedures at one or two contiguous levels from L2 through SI in skeletally mature patients with degenerative disc disease (DDD). DDD is defined as back pain of discogenic origin with degeneration of the history and radiographic studies. DDD patients may also have up to Grade I Spondylolisthesis or retrolisthesis at the involved levels. The patient may have had a previous non-fusion spinal surgery at the involved spinal level(s).

The device is intended to be used with supplemental spinal fixation systems that have been cleared for use in the lumbosacral spine (e.g. posterior pedicle screw and rod systems). The device is intended to be used with autogenous bone graft.

Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the PROW FUSION device.

The PROW FUSION intervertebral body fusion device must be inserted using a transforaminal approach.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

#### CONTINUE ON A SEPARATE PAGE IF NEEDED.

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 comblete 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 PRAStaff(@fda.hhs.gov

"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."

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

Image /page/3/Picture/0 description: The image shows the logo for NLT Spine NonLinear Technologies. The logo features a stylized spine graphic on the left, composed of several blue squares stacked vertically in a curved shape. To the right of the spine graphic, the text "NLTSPine" is displayed in a sans-serif font, with "NonLinear Technologies" written in a smaller font size below it.

# 510(k) SUMMARY

## NLT SPINE's PROW FUSION

## Sponsor:

NLT SPINE Ltd. 6 Yad Harutzim St. Kfar-Saba Israel 44641

#### Contact Person:

Eti Zinger VP Regulatory Affairs NLT SPINE Ltd. Tel: [phone] Fax: [phone] [e-mail]

| Date Prepared: | July 17, 2015 |
|-----------------------|--------------------------------------------------------------------------------------------------------|
| Name of Device: | PROW FUSION |
| Common or Usual Name: | Intervertebral body fusion device |
| Classification Name: | Intervertebral body fusion device<br>21 C.F.R. § 880.3080, class II medical device<br>Product Code MAX |

## Primary Predicate Device

NLT SPINE, PROW FUSION (K130254)

## Intended Use / Indications for Use

The PROW FUSION Intervertebral body fusion device is indicated for spinal fusion procedures at one or two contiguous levels from L2 through S1 in skeletally mature patients with degenerative disc disease (DDD). DDD is defined as back pain of discogenic origin with degeneration of the disc confirmed by the history and radiographic studies. DDD patients may also have up to Grade I Spondylolisthesis or retrolisthesis at the involved levels. The patient may have had a previous nonfusion spinal surgery at the involved spinal level(s).

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

Image /page/4/Picture/0 description: The image contains the logo for NLT Spine. The logo consists of a stylized spine graphic on the left, followed by the text "NLTSPINE" in a larger, bolder font. Below "NLTSPINE" is the text "NonLinear Technologies" in a smaller, lighter font. The spine graphic is composed of several blue squares arranged in a curved line, resembling the shape of a human spine.

The device is intended to be used with supplemental spinal fixation systems that have been cleared for use in the lumbosacral spine (e.g. posterior pedicle screw and rod systems). The device is intended to be used with autogenous bone graft.

Patients must have undergone a regimen of at least six (6) months of non-operative treatment prior to being treated with the PROW FUSION device.

The PROW FUSION intervertebral body fusion device must be inserted using a transforaminal approach.

## Purpose of the Special 510(k) notice:

The PROW FUSION is a modification to NLT's previously cleared K130254 PROW FUSION. Specifically, the submission adds intermediate diameter and heights and made some modifications to the instrumentation to improve the surgical technique.

## Technological Characteristics

The PROW FUSION Intervertbral Body Fusion Device system is comprised of two components. One component is the single-use PROW FUSION implant (intervertebral body fusion device) of various heights and the second component is a set of reusable instruments (the PROW FUSION Delivery System) used for its implantation. The implant is made from PEEK and titanium alloy. The implant features 4 PEEK mid segments and titanium end segments has coarse surface on the superior and inferior surfaces and are attached with titanium pins.

The PROW FUSION intervertebral body fusion implant is inserted using a transforaminal approach. The proximal and the distal segments are bound together by PEEK strip is used to pull the distal segment proximally to form a ring-shaped, closed-configuration implant in the disc space.

## Performance Data

Performance testing, including static axial compression testing per ASTM F2077, cadaver testing, and deployment force testing demonstrated that the PROW FUSION is substantially equivalent to its predicate PROW FUSION (K130254).

## Substantial Equivalence

The PROW FUSION is as safe and effective as its predicate device, PROW FUSION (K130254). The PROW FUSION has substantially similar indications for use and technological characteristics as compared to the predicate device. Any minor differences between the device and predicates do not raise new questions of safety and effectiveness. Further, performance testing has established that the PROW FUSION has equivalent performance and safety as compared to the claimed predicate. Thus, the device is substantially equivalent to its predicate device.