NuVasive AttraX Putty

K191974 · Nu Vasive, Incorporated · MQV · Nov 3, 2019 · Orthopedic

Device Facts

• Record ID: K191974
• Device Name: NuVasive AttraX Putty
• Applicant: Nu Vasive, Incorporated
• Product Code: MQV · Orthopedic
• Decision Date: Nov 3, 2019
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3045
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

AttraX® Putty is an implant intended to fill bony voids or gaps of the skeletal system (i.e. posterolateral spine and pelvis) and may be used in combination with autogenous bone. These osseous defects may be surgically created of of traumatic injury to the bone and are not instrinsic to the stability of the bony structure. AttraX Putty resorbs and is replaced with bone during the healing process.

Device Story

Synthetic, osteoconductive, resorbable bone void filler; ceramic granules premixed with polymeric binder. Clinician manipulates putty to mold into specific shapes, mix with autograft, or contour into bone defects. Used in surgical settings for posterolateral spine and pelvis procedures. Device resorbs and is replaced by bone during healing. Benefits patient by providing scaffold for bone regeneration in non-structural defects.

Clinical Evidence

Level I clinical evidence from a patient and observer blinded, multicenter, prospective, randomized controlled trial. Evaluated AttraX Putty vs. autologous bone graft (iliac crest + local bone) in instrumented thoracolumbar posterolateral fusion. Study demonstrated non-inferiority of AttraX Putty to autologous bone graft.

Technological Characteristics

Synthetic ceramic granules with polymeric binder. Osteoconductive and resorbable. No software or electrical components.

Indications for Use

Indicated for patients requiring bone void filling in the skeletal system, specifically the posterolateral spine and pelvis, for surgically created or traumatic osseous defects not intrinsic to bony structure stability. May be used with autogenous bone.

Regulatory Classification

Identification

A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.

Special Controls

*Classification.* Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.

Predicate Devices

• Progentix AttraX Putty (K151584)
• CuriOs (AttraX Granules) (K090641)
• Actifuse Shape (K080736)
• OSferion (K061499)

Submission Summary (Full Text)

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NuVasive, Incorporated Jessica LeBlanc Senior Specialist, Regulatory Affairs 7475 Lusk Boulevard San Diego, California 92121

Re: K191974

Trade/Device Name: NuVasive® AttraX® Putty Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MOV Dated: October 3, 2019 Received: October 4, 2019

Dear Ms. Leblanc:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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) for

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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely.

Laurence D. Coyne, Ph.D. Acting Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

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# Indications for Use

510(k) Number (if known)

K191974

Device Name NuVasive® AttraX® Putty

### Indications for Use (Describe)

AttraX® Putty is an implant intended to fill bony voids or gaps of the skeletal system (i.e. posterolateral spine and pelvis) and may be used in combination with autogenous bone. These osseous defects may be surgically created of of traumatic injury to the bone and are not instrinsic to the stability of the bony structure. AttraX Putty resorbs and is replaced with bone during the healing process.

| Type of Use (Select one or both, as applicable) | |
|----------------------------------------------------------------------------------|---------------------------------------------------------------------------------|
| <div> <span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |

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Image /page/3/Picture/0 description: The image shows the logo for Nuvasive. The logo consists of a stylized purple and gray graphic to the left of the company name, "NUVASIVE", which is written in gray, sans-serif font. The graphic appears to be an abstract representation of an eye or a leaf.

## 510(k) Summary - K191974

In accordance with Title 21 of the Code of Federal Regulations, Part 807, and in particular 21 CFR §807.92, the following summary of information is provided:

#### Submitted by: A.

Jessica LeBlanc Senior Specialist, Regulatory Affairs NuVasive, Incorporated 7475 Lusk Blvd. San Diego, California 92121 Telephone: [phone]

Date Prepared: July 22, 2019

#### B. Device Name

| Trade or Proprietary Name: | <i>NuVasive</i> ® <i>AttraX</i> ® <i>Putty</i> |
|----------------------------|-------------------------------------------------|
| Common or Usual Name: | Bone void filler |
| Classification Name: | Resorbable calcium salt bone void filler device |

| Device Class: | Class II |
|---------------|-----------------|
| Regulation: | 21 CFR 888.3045 |
| Product Code: | MQV |

#### C. Predicate Devices

The subject AttraX Putty is substantially equivalent to multiple predicate devices. Progentix AttraX Putty (K151584) serves as the primary predicate device, CuriOs (AttraX Granules) (K090641). Actifuse Shape (K080736), and the OSferion (K061499) serve as additional predicates.

#### D. Device Description

NuVasive AttraX Putty is a synthetic, osteoconductive and resorbable bone void filler device consisting of ceramic granules premixed with a polymeric binder that provides cohesion between the granules. Pressure applied by user manipulation allows the AttraX Putty to be molded into specific shapes, mixed with autograft, or contoured into a bone defect, as desired by the clinician. The subject device is identical to the primary predicate device Progentix AttraX Putty (K151584). No changes to the design, materials, or methods of manufacture have been made for this submission.

The purpose of this 510(k) is to expand the indications for use as a bone graft replacement based on animal and clinical data.

#### E. Indications for Use

AttraX® Putty is an implant intended to fill bony voids or gaps of the skeletal system (i.e. posterolateral spine and pelvis) and may be used in combination with autogenous bone. These osseous defects may be surgically created or the result of traumatic injury to the bone and are not intrinsic to the stability of the bony structure. AttraX Putty resorbs and is replaced with bone during the healing process.

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Image /page/4/Picture/0 description: The image shows the Nuvasive logo. The logo consists of a stylized leaf-like shape in purple and gray on the left, followed by the word "NUVASIVE" in gray. The logo appears to be for a medical or healthcare-related company.

#### Technological Characteristics F.

As was established in this submission, the subject AttraX Putty is substantially equivalent to other predicate devices cleared by the FDA for commercial distribution in the United States. The subject device was shown to be substantially equivalent and have the same technological characteristics as its predicate devices through comparison in areas including design, intended use, material composition, and function. This device does not contain software or electrical equipment.

#### G. Performance Data

Non-clinical testing data submitted, referenced, or relied upon supports the in vivo safety of AttraX Putty. The data also demonstrates substantial equivalence to the predicate device including chemical composition, physical properties, biocompatibility, and performance characteristics.

In addition, AttraX Putty was clinically evaluated in instrumented thoracolumbar posterolateral fusion in a patient and observer blinded, multicenter, prospective, randomized controlled trial. The objective of the study was to evaluate whether AttraX Putty used alone as a bone void filler is non-inferior to autologous bone graft (iliac crest + local bone) in instrumented posterolateral fusion. The Level I clinical evidence from this randomized controlled trial demonstrates the non-inferiority of AttraX Putty versus autologous bone graft in instrumented posterolateral spinal fusion.

## H. Conclusions

Based on the indications for use, non-clinical and clinical data, and comparison to predicate devices, the subject AttraX Putty has been shown to be substantially equivalent to legally marketed predicate devices.