Kalitec Direct InSePtion™ MIS Fixation System

K163471 · Kalitec Direct, LLC · PEK · Mar 16, 2017 · Orthopedic

Device Facts

• Record ID: K163471
• Device Name: Kalitec Direct InSePtion™ MIS Fixation System
• Applicant: Kalitec Direct, LLC
• Product Code: PEK · Orthopedic
• Decision Date: Mar 16, 2017
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3050
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Kalitec Direct InSePtion System is a posterior, non-pedicle supplemental fixation device, intended for use at a single level in the non-cervical spine (T1 - S1). It is intended for plate fixation/attachment to spinous processes for the purpose of achieving supplemental fusion in the following conditions: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies). spondylolisthesis, trauma (i.e. fracture or dislocation), and/or tumor. The Kalitec Direct InSePtion™ MIS Fixation System is not intended for standalone use, and is intended for use with autograft or allograft.

Device Story

Posterior, non-pedicle supplemental fixation system; used for spinous process plate attachment to achieve fusion in non-cervical spine (T1-S1). Device consists of titanium alloy plates; available in eight color-coded sizes (8mm to 18mm). Implanted by surgeons in clinical settings to stabilize spine segments during fusion procedures. System requires concurrent use of autograft or allograft. Provides mechanical support to facilitate bone healing; intended for non-standalone use.

Clinical Evidence

Bench testing only. Performance testing included static compression bending, static torsion, dynamic compression bending, and disassociation testing in UHMWPE test blocks per ASTM F1717. Finite Element Analysis was also conducted to characterize device performance.

Technological Characteristics

Titanium alloy construction; posterior non-pedicle spinous process fixation; eight color-coded sizes (8-18 mm). Mechanical performance testing conducted per ASTM F1717. No software or electronic components.

Indications for Use

Indicated for patients requiring posterior, non-pedicle supplemental fixation at a single level in the non-cervical spine (T1-S1) for degenerative disc disease, spondylolisthesis, trauma (fracture/dislocation), or tumor. Must be used with autograft or allograft; not for standalone use.

Regulatory Classification

Identification

A spinal interlaminal fixation orthosis is a device intended to be implanted made of an alloy, such as stainless steel, that consists of various hooks and a posteriorly placed compression or distraction rod. The device is implanted, usually across three adjacent vertebrae, to straighten and immobilize the spine to allow bone grafts to unite and fuse the vertebrae together. The device is used primarily in the treatment of scoliosis (a lateral curvature of the spine), but it also may be used in the treatment of fracture or dislocation of the spine, grades 3 and 4 of spondylolisthesis (a dislocation of the spinal column), and lower back syndrome.

Predicate Devices

• NuVasive Affix Spinous Process Plate System (K133052)
• Lanx Aspen Spinal Fixation System (K071877)
• Kalitec Direct CosmoLock Pedicle Screw System (K140678)

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

March 16, 2017

Kalitec Direct, LLC % Mr. Justin Eggleton Senior Director, Spine Regulatory Affairs Musculoskeletal Clinical Regulatory Advisers, LLC 1050 K Street Northwest, Suite 1000 Washington, District of Columbia 20001

Re: K163471

Trade/Device Name: Kalitec Direct InSePtion™ MIS Fixation System Regulation Number: 21 CFR 888.3050 Regulation Name: Spinal interlaminal fixation orthosis Regulatory Class: Class II Product Code: PEK Dated: February 16, 2017 Received: February 17, 2017

Dear Mr. Eggleton:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) 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" (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,

## 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

510(k) Number (if known) K163471

Device Name Kalitec Direct InSePtion™ MIS Fixation System

#### Indications for Use (Describe)

The Kalitec Direct InSePtion System is a posterior, non-pedicle supplemental fixation device, intended for use at a single level in the non-cervical spine (T1 - S1). It is intended for plate fixation/attachment to spinous processes for the purpose of achieving supplemental fusion in the following conditions: degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by history and radiographic studies). spondylolisthesis, trauma (i.e. fracture or dislocation), and/or tumor. The Kalitec Direct InSePtion™ MIS Fixation System is not intended for standalone use, and is intended for use with autograft or allograft.

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)

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#### FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

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# 510(k) Summary

| Device Trade Name: | Kalitec Direct InSePtion™ MIS Fixation System |
|---------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Manufacturer: | Kalitec Direct, LLC<br>618 E. South Street, Suite 500<br>Orlando, FL 32801 USA<br>Phone: [phone] |
| Contact: | Mr. Keith Cannan<br>Director, Quality Assurance and Regulatory Affairs<br>Kalitec Direct, LLC<br>618 E. South Street, Suite 500, Orlando, FL 32801 USA<br>Phone: [phone] |
| Prepared by: | Mr. Justin Eggleton<br>Senior Director, Spine Regulatory Affairs<br>Musculoskeletal Clinical Regulatory Advisers, LLC<br>1050 K Street NW, Suite 1000<br>Washington, DC 20001<br>Phone: [phone]<br>[e-mail] |
| Date Prepared: | March 14, 2017 |
| Classification: | 21 CFR §888.3050, Spinal interlaminal fixation orthosis |
| Class: | II |
| Product Codes: | PEK |
| Primary Predicate Device: | NuVasive Affix Spinous Process Plate System (K133052) |
| Additional Predicates: | Lanx Aspen Spinal Fixation System (K071877)<br>Kalitec Direct CosmoLock Pedicle Screw System (K140678) |
| Indications For Use: | The Kalitec Direct InSePtion™ MIS Fixation System is a posterior,<br>non-pedicle supplemental fixation device, intended for use at a<br>single level in the non-cervical spine (T1 – S1). It is intended for<br>plate fixation/attachment to spinous processes for the purpose of<br>achieving supplemental fusion in the following conditions:<br>degenerative disc disease (defined as back pain of discogenic origin<br>with degeneration of the disc confirmed by history and radiographic<br>studies), spondylolisthesis, trauma (i.e. fracture or dislocation),<br>and/or tumor. The Kalitec Direct InSePtion™ MIS Fixation System |

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is not intended for standalone use, and is intended for use with autograft or allograft.

- The Kalitec Direct InSePtion110 MIS Fixation System implant is a Device Description: posterior non-pedicle supplemental fixation device utilized to achieve supplemental fusion in the non-cervical spine. The system is made of titanium alloy and includes eight color coded sizes, ranging from 8 mm to 18 mm.
- Predicate Device: Kalitec Direct InSePtion™ MIS Fixation System was shown to be substantially equivalent to previously cleared devices and has the same indications for use, design, function, and materials used. These devices include the Lanx Spinous Process Fusion Plate (K071877) and the NuVasive Affix (K133052).
- Performance Testing: Testing performed on this device indicates that the Kalitec Direct InSePtionTM MIS Fixation System is substantially equivalent to predicate devices. ASTM F1717 performance standards were adhered to and all applicable requirements were met. This testing included static compression bending, static torsion, dynamic compression bending, and disassociation testing in UHMWPE test blocks. Finite Element Analysis was also performed to characterize device performance.
- The subject Kalitec Direct InSePtion™ MIS Fixation System is Substantial Equivalence: substantially equivalent to the predicate Lanx Aspen Spinal Fixation System (K071877) and NuVasive Affix Spinous Process Plate System (K133052) with respect to indications, design, materials, function, and performance.
- Kalitec Direct InSePtion™ MIS Fixation System is Conclusion: The substantially equivalent to predicate devices.