JULIET® LL Lateral Lumbar Cage

K161888 · Spineart · MAX · Sep 12, 2016 · Orthopedic

Device Facts

• Record ID: K161888
• Device Name: JULIET® LL Lateral Lumbar Cage
• Applicant: Spineart
• Product Code: MAX · Orthopedic
• Decision Date: Sep 12, 2016
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

JULIET®LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). These spinal implants are to be used with autogenous bone graft. JULIET®LL Lumbar Interbody Device is to be used with supplemental fixation. Patients should have at least six (6) months of non-operative treatment with an intervertebral cage.

Device Story

JULIET® LL Lateral Lumbar Cage is an intervertebral body fusion device; used in lumbar spine surgery to facilitate fusion at L2-S1 levels. Device features a central cavity for autogenous bone graft packing; rectangular shape; various sizes/footprints to accommodate patient anatomy. Implanted by surgeons in clinical settings; requires supplemental fixation. Provides structural support to intervertebral space; promotes bone fusion; alleviates discogenic back pain. Modification adds lordotic versions to existing product range.

Clinical Evidence

Bench testing only. No clinical data provided. Previous mechanical testing (static axial compression, static shear compression per ASTM F2077, and subsidence per ASTM F2267) for the predicate range supports the safety and effectiveness of the added lordotic versions. Bacterial endotoxin testing per USP <85> is performed to meet a limit of 20 EU/device.

Technological Characteristics

Material: Titanium Ti 6Al-4V ELI (ASTM F136, ISO 5832-3). Form factor: Rectangular intervertebral spacer with central cavity. Dimensions: Width 17 mm, height 08-16 mm, length 40-60 mm. Energy source: None (mechanical implant). Sterilization: Not specified (instruments provided non-sterile). Connectivity: None.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1, including those with up to Grade 1 spondylolisthesis or retrolisthesis. Requires at least 6 months of prior 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

• JULIET® LL (K141135)

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

September 12, 2016

SPINEART Mr. Franck Pennesi Director of Industry & Quality International Center Cointrin 20 Route De Pré-bois CP1813 1215 Geneva, 15 SWITZERLAND

Re: K161888

Trade/Device Name: JULIET® LL Lateral Lumbar Cage Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: August 12, 2016 Received: August 15, 2016

Dear Mr. Pennesi:

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 Parts 801); medical device reporting (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set

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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" (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 [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely,

# Mark N. Melkerson -S

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.

K161888

Page 1 of 1

510(k) Number (if known) K161888

Device Name JULIET® LL Lateral Lumbar Cage

## Indications for Use (Describe)

JULIET®LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). These spinal implants are to be used with autogenous bone graft. JULIET®LL Lumbar Interbody Device is to be used with supplemental fixation. Patients should have at least six (6) months of non-operative treatment with an intervertebral cage.

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

2 Prescription Use (Part 21 CFR 801 Subpart D)

_ 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)

This section applies only to requirements of the Paperwork Reduction Act of 1995.

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# 510(k) SUMMARY

| Submitted by | SPINEART |
|-----------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | International Center Cointrin |
| | 20 route de pré-bois |
| | CP1813 |
| | 1215 GENEVA 15 |
| | SWITZERLAND |
| Contacts | Franck PENNESI Director of Industry & Quality |
| | Phone : [phone] Fax : [phone] |
| | Mail : [e-mail] |
| | Regulatory contact : Dr Isabelle DRUBAIX (Idée Consulting)<br>[e-mail] |
| | |
| Date Prepared | September 7th 2016 |
| Common Name | Intervertebral body fusion device |
| Trade Name | JULIET® LL Lateral Lumbar Cage |
| Classification Name | Intervertebral Fusion Device With Bone Graft, Lumbar |
| Class | II |
| Product Code | MAX |
| CFR section | 888.3080 |
| Device panel | ORTHOPEDIC |
| Legally marketed predicate device | Primary predicate: JULIET® LL (K141135) manufactured by Spineart |
| Indications for use | JULIET® LL Lumbar Interbody Device is indicated for intervertebral body fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). These spinal implants are to be used with autogenous bone graft. JULIET® LL Lumbar Interbody Device is to be used with supplemental fixation. Patients should have at least six (6) months of non-operative treatment prior to treatment |

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| Description of the device | The JULIETLL Titanium Lateral Lumbar cages are rectangle-shaped intervertebral body fusion devices with a central cavity that can be filled with bone graft (autograft) to facilitate fusion. The JULIETLL intervertebral body fusion spacer comes in various sizes and footprints in order to fulfill surgeons' needs and accommodate different patient anatomies.<br>The JULIETLL system is made of Titanium Ti 6Al-4V ELI conforming to ASTM F136 and ISO 5832-3.<br>The JULIETLL Titanium Lateral Lumbar cages are supplied with dedicated surgical instruments (reusable - provided non sterile). |
|-------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Technological Characteristics | The modification to JULIET®LL Titanium Lateral Lumbar cages consists of the addition of lordotic version of the range of existing spacers having a width of 17 mm, a height ranging from 08 to 16 mm, and a length ranging from 40 to 60 mm. |
| Discussion of Testing | The following non-clinical tests were initially conducted on JULIET®LL Titanium Lateral Lumbar cages (K141135): Static axial compression, Static shear compression according to ASTM F2077 and subsidence testing according to ASTM F2267. A rationale based on verification activity and validation activity demonstrate that the devices added to the JULIET®LL Titanium Lateral Lumbar range of products are as safe, as effective, and performs at least as safely and effectively as predicate JULIET®LL Titanium Lateral Lumbar cages (K141135). No additional testing has been performed.<br>Bacterial endotoxin testing as specified in USP <85> standard is used for pyrogenicity testing to achieve the Endotoxin limit of 20 EU / device. |
| Conclusion | The extended range of JULIET®LL Titanium Lateral Lumbar cages is substantially equivalent to its predicate devices in terms of intended use, labeling, material, design, mechanical properties and function. Verification Activity and Validation Activity demonstrate that the added devices are as safe, as effective, and perform at least as safely and effectively as its predicates (K141135). |