FlareHawk Interbody Fusion System

K220453 · Integrity Implants, Inc. · MAX · Mar 24, 2022 · Orthopedic

Device Facts

Record IDK220453
Device NameFlareHawk Interbody Fusion System
ApplicantIntegrity Implants, Inc.
Product CodeMAX · Orthopedic
Decision DateMar 24, 2022
DecisionSESE
Submission TypeSpecial
Regulation21 CFR 888.3080
Device ClassClass 2
AttributesTherapeutic

Intended Use

The FlareHawk Interbody Fusion System is indicated for spinal intervertebral body fusion with autogenous bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone in skeletally mature individuals with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1, following discectomy. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should have at least six (6) months of non-operative treatment. Additionally, these patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). FlareHawk system spacers are intended to be used with supplemental fixation instrumentation, which has been cleared for use in the lumbar spine.

Device Story

Expandable lumbar intervertebral body fusion device; consists of PEEK shell and titanium alloy shim. Inserted into disc space in non-expanded form; shim inserted to expand shell to desired height/lordosis; components lock to provide structural stability. Used in lumbosacral spine (L2-S1) following discectomy. Requires supplemental fixation. Implanted by surgeons in clinical setting. Restores disc height; provides anterior column support; facilitates fusion. Includes manual surgical instruments for delivery and disc preparation.

Clinical Evidence

Bench testing only. No clinical data provided. Performance verified via static and dynamic axial compression and compression shear testing per ASTM F2077.

Technological Characteristics

Materials: PEEK (ASTM F2026), titanium alloy (ASTM F136), tantalum markers (ASTM F560), CP titanium coating (ASTM F67). Expandable shell/shim mechanism. Manual delivery instruments. Sterilization: Steam or gamma. No software/electronics.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1, following discectomy. Includes patients with up to Grade 1 spondylolisthesis or retrolisthesis. Requires 6 months of failed non-operative treatment. Contraindications include skeletal immaturity.

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

Related Devices

Submission Summary (Full Text)

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food & Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue. March 24, 2022 Integrity Implants Inc. Anne Mulvihill Senior Regulatory Affairs Specialist 354 Hiatt Drive Palm Beach Gardens, Florida 33418 Re: K220453 Trade/Device Name: FlareHawk Interbody Fusion System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: March 18, 2022 Received: March 21, 2022 Dear Anne Mulvihill: 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 {1}------------------------------------------------ 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 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 (OS) 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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100). Sincerely, Brent Showalter, Ph.D. Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ ## Indications for Use 510(k) Number (if known) K220453 Device Name FlareHawk® Interbody Fusion System ### Indications for Use (Describe) The FlareHawk Interbody Fusion System is indicated for spinal intervertebral body fusion with autogenous bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone in skeletally mature individuals with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1, following discectomy. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should have at least six (6) months of non-operative treatment. Additionally, these patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). FlareHawk system spacers are intended to be used with supplemental fixation instrumentation, which has been cleared for use in the lumbar spine. Type of Use (Select one or both, as applicable) | <div> <span> <b> ☑ </b> </span> <span>Prescription Use (Part 21 CFR 801 Subpart D)</span> </div> | |-----------------------------------------------------------------------------------------------------------| | <div> <span> <b>□</b> </span> <span>Over-The-Counter Use (21 CFR 801 Subpart C)</span> </div> | 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 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 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}------------------------------------------------ # 510(k) SUMMARY ## FlareHawk® Interbody Fusion System February 15, 2022 | I. Company: | Integrity Implants Inc.<br>354 Hiatt Drive<br>Palm Beach Gardens, FL 33418<br>Telephone: 561-529-3861 | |------------------------------|-------------------------------------------------------------------------------------------------------| | II. Contact: | Anne Mulvihill<br>Senior Regulatory Affairs Specialist | | III. Proprietary Trade Name: | FlareHawk® Interbody Fusion System | | IV. Common Name: | Intervertebral Body Fusion Device<br>with Bone Graft, Lumbar | | V. Classification Name: | Intervertebral Body Fusion Device (21 CFR 888.3080) | | Class: | II | | Product Code: | MAX | #### VI. Product Description The Integrity Implants FlareHawk Interbody Fusion System is an expandable lumbar intervertebral body fusion device intended for use in the lumbosacral spine from L2 to S1. The FlareHawk interbody fusion device consists of a shell and a shim component that are offered in various lengths, heights, and lordotic angles to accommodate variations in patient anatomy. When the FlareHawk device is deployed within the intervertebral disc space, the shell and shim components lock together to create a complete implant construct to provide structural stability for interbody fusion. The final dimensions of the deployed device construct are determined by the dimensions of the selected shell and {4}------------------------------------------------ shim. Once implanted, the FlareHawk interbody fusion device is designed to restore intervertebral disc height, provide anterior column support, and maintain structural stability of the motion segment to facilitate intervertebral body fusion. The FlareHawk interbody fusion device is intended to be used with autogenous bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone, and with supplemental fixation instrumentation that has been cleared for use in the lumbar spine. The FlareHawk Interbody Fusion System includes manual surgical instruments for delivery of the implant device and for disc preparation. #### VII. Indications for Use The FlareHawk Interbody Fusion System is indicated for spinal intervertebral body fusion with autogenous bone graft and/or allogeneic bone graft composed of cancellous and/or corticocancellous bone in skeletally mature individuals with degenerative disc disease (DDD) at one or two contiguous levels from L2 to S1, following discectomy. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should have at least six (6) months of non-operative treatment. Additionally, these patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). FlareHawk system spacers are intended to be used with supplemental fixation instrumentation, which has been cleared for use in the lumbar spine. #### Summary of Technological Characteristics VIII. The subject FlareHawk Interbody Fusion System has substantially similar fundamental scientific technology as the predicate FlareHawk Interbody Fusion System. Like the predicate FlareHawk Interbody Fusion System, the shell component of the subject FlareHawk Interbody Fusion System implants is a rectangular frame that is inserted into the disc space in a non-expanded form, with subsequent in-situ expansion resulting from the insertion of the shim component. The shim locks to both the shell core and the posterior of the shell when the implant is deployed. {5}------------------------------------------------ Like the predicate FlareHawk Interbody Fusion System, the subject shell component is manufactured from PEEK per ASTM F2026, and incorporates an integrated core manufactured from titanium alloy per ASTM F136, and tantalum markers per ASTM F560 for imaging purposes. The subject shell components are offered in both non-coated and coated with CP titanium (Grade 2 commercially pure titanium that meets the chemical composition requirements of ASTM F67) versions. The shell component features a bulleted nose designed to facilitate ease of insertion, as well as directional teeth on its superior and inferior surfaces to resist expulsion. Like the predicate FlareHawk Interbody Fusion System, the shim component of the subject FlareHawk Interbody Fusion System implants has a tapered front end that inserts into and expands the shell component to the desired height and lordosis. The shim is manufactured from titanium alloy per ASTM F136 and are color anodized for differentiation. Like the predicate FlareHawk Interbody Fusion System, the subject shells and shims are offered in both non-sterile (and intended to be steam sterilized by the user) and gamma sterilized versions. ### IX. Identification of Legally Marketed Predicate Devices Used to Claim Substantial Equivalence To demonstrate the substantial equivalence of the subject FlareHawk Interbody Fusion System to legally marketed predicate devices, FlareHawk Interbody Fusion System, K202198 (SE 11/03/2020), is used as the primary predicate device. Integrity Implants' FlareHawk Interbody Fusion System, K182114 (SE 01/07/2019) and K183184 (SE 04/03/2019) are also used as predicates for this submission. Additionally, Amplify Surgical's DualX™ Dual Expanding Interbody Fusion System, K181397 (SE 09/27/2018) is used as a predicate for this submission. {6}------------------------------------------------ #### X. Brief Discussion of the Non-Clinical and Clinical Tests Submitted A risk analysis of the device modifications was completed in accordance with Integrity Implants design control procedures. Verification and validation activities, including engineering rationales, demonstrated that no new risks have been introduced to FlareHawk Interbody Fusion System by the addition of the subject devices, and that the addition of the subject devices does not create a new worst case for the overall FlareHawk Interbody Fusion System. Confirmatory bench performance testing conducted in support of this premarket notification submission included: - Static Axial Compression in accordance with ASTM F2077 . - . Dynamic Axial Compression in accordance with ASTM F2077 - Static Compression Shear in accordance with ASTM F2077 - . Dynamic Compression Shear in accordance with ASTM F2077 #### Conclusions Drawn for the Non-Clinical and Clinical Tests XI. Based on the engineering rationales, confirmatory bench performance testing, and other supporting documentation provided in this premarket notification, the subject FlareHawk® Interbody Fusion System demonstrates substantial equivalence to legally marketed predicate devices, including the previously cleared FlareHawk® Interbody Fusion System.
Innolitics
510(k) Summary
Decision Summary
Classification Order
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