ENDOSKELETON TT INTERBODY FUSION DEVICE (IBD)

K083714 · Titan Spine, LLC · MAX · Apr 15, 2009 · Orthopedic

Device Facts

• Record ID: K083714
• Device Name: ENDOSKELETON TT INTERBODY FUSION DEVICE (IBD)
• Applicant: Titan Spine, LLC
• Product Code: MAX · Orthopedic
• Decision Date: Apr 15, 2009
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Endoskeleton® TT IBD is indicated for use 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. Patients should have received 6 months of non-operative treatment prior to treatment with the devices. The device must be used with supplemental fixation. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). It is indicated to be used with autograft bone.

Device Story

Endoskeleton® TT IBD is an intervertebral body fusion device designed for spinal fusion procedures. It consists of titanium alloy (Ti6A14V-ELI) implants available in various sizes to match patient anatomy. Used by surgeons in clinical settings to treat degenerative disc disease at L2-S1 levels. The device acts as a structural spacer to facilitate fusion when used with autograft bone and supplemental fixation. It provides mechanical stability to the intervertebral space, supporting the fusion process and potentially alleviating discogenic back pain.

Clinical Evidence

Bench testing only. No clinical data provided.

Technological Characteristics

Medical grade titanium alloy (Ti6A14V-ELI). Intervertebral body fusion device. Dimensions vary to accommodate patient anatomy. Standalone implant system requiring supplemental fixation.

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 I spondylolisthesis or retrolisthesis. Requires 6 months of prior non-operative treatment. Must be used with supplemental fixation and autograft bone.

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

• BAK Interbody Fusion Device (P950002)
• Inter Fix Threaded Fusion Device (P970015)
• Ray Threaded Fusion Cage (P950019)
• Brantigan Cage (P960025)

Reference Devices

• Titan Spine Endoskeleton® TA IBD (K080615)
• Abbott Spine Infix Anterior Lumbar Spacer (031672)
• Spinal Elements Lucent Interbody Device (K071724)

Submission Summary (Full Text)

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Ko8 3712

APR 1 5 2009

# 4. 510(k) Summary according to 807.92(c)

Contact:

Kevin Gemas President 866-822-7800 Titan Spine, LLC Mequon Research Center 6140 W. Executive Drive. Suite A Mequon, WI 53092

| Trade Name: | Endoskeleton® TT IBD |
|-----------------|--------------------------------------------------|
| Product Class: | Class II |
| Classification: | 21 CFR §888.3080 Orthosis, intervertebral fusion |
| Product Codes: | MAX |
| Panel Code: | 87 |

### Indications for Use:

The Endoskeleton® TT IBD is indicated for use 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. Patients should have received 6 months of non-operative treatment prior to treatment with the devices. The device must be used with supplemental fixation. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). It is indicated to be used with autograft bone.

#### Device Description:

The Endoskeleton® TT IBD is comprised of a variety of implant sizes to accommodate various patient anatomy and pathology, and associated instrumentation. All implantable components are manufactured from medical grade titanium alloy (Ti6A14V-ELI),

#### Predicate Device(s):

The Endoskeleton® TT IBD was shown to be substantially equivalent to previously cleared devices and has the same indications for use, design, function, and materials used. . The four formerly Class III predicate devices include the BAK Interbody Fusion Device (Spine-Tech, P950002), Inter Fix Threaded Fusion Device (Sofamor Danek, P970015), the Ray Threaded Fusion Cage (Surgical Dynamics, P950019) and the Brantigan Cage (P960025). In addition, other Class II products including the Titan Spine Endoskeleton® TA IBD (K080615), the Abbott Spine Infix Anterior Lumbar Spacer (031672) and the Spinal Elements Lucent Interbody Device (K071724) provide features that are substantially equivalent to the Titan Spine Endoskeleton® TT IBD.

### Performance Testing:

The pre-clinical testing performed indicated that the Endoskeleton® TT IBD is adequate for the intended use.

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Image /page/1/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle or bird-like figure with three curved lines representing its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES . USA" is arranged in a circular pattern around the bird.

#### Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

Titan Spine, LLC % Richard Jansen, Pharm. D. 13540 Guild Avenue Apple Valley, Minnesota 55124

APR 1 5 2009

Re: K083714

Trade/Device Name: Endoskeleton TT Interbody Fusion Device (IBD) Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX Dated: April 10, 2009 Received: April 13, 2009

Dear Dr. Jansen:

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.

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 r lowe or acrised 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 medicaldevice-related 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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at [phone]. 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 contact the CDRH/Office of Surveillance and Biometrics/Division of Postmarket Surveillance at 240-276-3464. For more information regarding the reporting of adverse events, please go to http://www.fda.gov/cdrh/mdr/.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number [phone] or [phone] or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Mark N. Melker Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## 3. Statement of Indications for Use

510(k) Number (if known): KO& 3714

Indications for Use:

The Endoskeleton® TT IBD is indicated for use 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. Patients should have received 6 months of non-operative treatment prior to treatment with the devices. The device must be used with supplemental fixation. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). It is indicated to be used with autograft bone.

Prescription Use 4 (Part 21 CFR 801 Subpart D)

AND/OR

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

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Starlone Buelin
Division Sign-Off

Division of General, Restorative. and Neurological Devices

**510(k) Number** K083714

Concurrence of CDRH, Office of Device Evaluation (ODE)