SAGICO IBF SYSTEM – ARIA LUMBAR, SAGICO IBF SYSTEM – ARION CERVICAL

K161710 · Spinal Analytics & Geometrical Impant Co, LLC · MAX · Jun 29, 2017 · Orthopedic

Device Facts

• Record ID: K161710
• Device Name: SAGICO IBF SYSTEM – ARIA LUMBAR, SAGICO IBF SYSTEM – ARION CERVICAL
• Applicant: Spinal Analytics & Geometrical Impant Co, LLC
• Product Code: MAX · Orthopedic
• Decision Date: Jun 29, 2017
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3080
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

SAGICO IBF System - ARIA Lumbar implants are interbody fusion devices intended for use in patients with degenerative disc disease (DDD) at one or two contiguous levels of the lumbosacral spine (L2-S1). DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and at least six (6) months of non-operative treatment. In addition, these patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). SAGICO IBF System - ARIA Lumbar are to be filled with autogenous bone graft material. The SAGICO IBF System -ARIA Lumbar implant is intended to be used with supplemental fixation cleared by the FDA to properly utilize this device. The SAGICO IBF System - ARION Cervical implant is interbody fusion device intended for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine with accompanying radicular symptoms at one disc level from (C2-T1). DDD is defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and at least six (6) weeks of non-operative treatment. The SAGICO IBF System - ARION Cervical implant is to be filled with autogenous bone graft material and placed via open anterior approach. The SAGICO IBF System – ARION Cervical implant must be used with additional internal fixation (e.g. anterior plate or cervical pedicle screws) cleared by the FDA to properly utilize this device.

Device Story

Interbody fusion devices providing structural stability post-discectomy; lumbar (ARIA) and cervical (ARION) variants. Implants feature hollow centers for autogenous bone graft; surface protrusions engage vertebral endplates to resist expulsion/rotation. ARION cervical implant includes internal titanium spin blade for expansion and low-profile insertion. Used in surgical settings by orthopedic/neurosurgical specialists; requires supplemental FDA-cleared internal fixation. Restores spinal integrity; facilitates fusion; benefits patients by stabilizing degenerated segments.

Clinical Evidence

Bench testing only. Performance supported by ASTM F2077 (static/dynamic compression, shear, torsion), ASTM F2267-04 (load-induced subsidence), and static push-out testing.

Technological Characteristics

Materials: PEEK Optima LT1 (ASTM F2026, ISO 10993-1, USP Class VI), Titanium Alloy (ASTM F136), Tantalum (ASTM F560). Mechanical: Interbody spacers with surface protrusions; ARION includes internal titanium expansion blade. Sterilization: Not specified. Connectivity: None.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) requiring interbody fusion. Lumbar: L2-S1, 1-2 levels, discogenic pain, failed 6 months non-operative treatment, up to Grade 1 spondylolisthesis/retrolisthesis. Cervical: C2-T1, 1 level, discogenic pain with radicular symptoms, failed 6 weeks 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

• Caliber Spacer (K102293)
• PATRIOT Lumbar Spacers (K072970)
• LDR Spine ROI-C Cervical Cage System (K150765)
• Valeo Spacer System (K113559)

Submission Summary (Full Text)

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines connecting them.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

Spinal Analytics & Geometrical Implant Co, LLC James J, Gibson, Jr., Ph.D. SAGICO Project Manager 2189 West Busch Boulevard Tampa, Florida 33612

June 29, 2017

Re: K161710 Trade/Device Name: SAGICO IBF SYSTEM - ARIA LUMBAR, SAGICO IBF SYSTEM - ARION CERVICAL Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX, OVE Dated: May 26, 2017 Received: May 31, 2017

Dear Dr. Gibson:

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 (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" (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.

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

510(k) Number (if known) K161710

Device Name SAGICO IBF System - ARIA LUMBAR

#### Indications for Use (Describe)

SAGICO IBF System - ARIA Lumbar implants are interbody fusion devices intended for use in patients with degenerative disc disease (DDD) at one or two contiguous levels of the lumbosacral spine (L2-S1). DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and at least six (6) months of non-operative treatment. In addition, these patients may have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s).

SAGICO IBF System - ARIA Lumbar are to be filled with autogenous bone graft material. The SAGICO IBF System -ARIA Lumbar implant is intended to be used with supplemental fixation cleared by the FDA to properly utilize this device.

X Prescription Use (Part 21 CFR 801 Subpart D)

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

# CONTINUE ON A SEPARATE PAGE IF NEEDED.

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# *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:

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# Indications for Use

510(k) Number (if known) K161710

Device Name SAGICO IBF System - ARION CERVICAL

### Indications for Use (Describe)

The SAGICO IBF System - ARION Cervical implant is interbody fusion device intended for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine with accompanying radicular symptoms at one disc level from (C2-T1). DDD is defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and at least six (6) weeks of non-operative treatment.

The SAGICO IBF System - ARION Cervical implant is to be filled with autogenous bone graft material and placed via open anterior approach. The SAGICO IBF System – ARION Cervical implant must be used with additional internal fixation (e.g. anterior plate or cervical pedicle screws) cleared by the FDA to properly utilize this device.

| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------|---------------------------------------------|
| <span style="text-decoration: overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |

### 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."

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Image /page/4/Picture/0 description: The image shows a logo for SAGICO. The logo is a stylized hexagon with the word "SAGICO" written across the top. The hexagon is made up of three parallel lines that form the shape. The logo is black and white.

# 510(k) Summary As required by section 807.92(c)

| Device Trade Name(s): | SAGICO IBF SYSTEM – ARIA LUMBAR<br>SAGICO IBF SYSTEM – ARION CERVICAL |
|------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------|
| Classification Panel: | Orthopedics |
| Class and Reference: | Class II (21 CFR Section 888.3080) |
| Product Code(s): | MAX, OVE |
| Classification Name(s): | Intervertebral Body Fusion Device |
| Regulation Number(s): | 888.3080 |
| Applicant/Official Contact Person: | James J. Gibson, Jr., PhD<br>SAGICO Project Manager<br>Email: [e-mail]<br>Tel. [phone] / Fax [phone] |
| Submitter/Manufacturer: | Spinal Analytics & Geometrical Implant Co, LLC<br>dba/ SAGICO<br>2189 West Busch Blvd<br>Tampa, Florida 33612<br>Tel. [phone] / Fax [phone] |
| Preparation Date: | June 28th, 2017 |

Predicate Devices:

| Legally Marketed Predicate Devices | Manufacturer Name | Predicate Device | Regulatory Class and Product Code | 510(K) Number |
|--------------------------------------|---------------------|------------------|-----------------------------------|---------------|
| Caliber Spacer | Globus Medical, Inc | Primary | MAX | K102293 |
| PATRIOT Lumbar Spacers | Globus Medical, Inc | Additional | MAX | K072970 |
| LDR Spine ROI-C Cervical Cage System | LDR Spine USA | Additional | OVE | K150765 |
| Valeo Spacer System | Amedica Corporation | Additional | OVE | K113559 |

These predicate devices are cleared and legally marketed, distributed for similar indications, and/or have similar design features. The SAGICO IBF Systems are substantially equivalent with respect to design, indication for use, technological characteristics, and principles of operation.

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Image /page/5/Picture/0 description: The image is a logo for SAGICO. The logo is a hexagon with the word "SAGICO" written across the top. Inside the hexagon are two stylized "S" shapes that are mirror images of each other. The logo is black and white.

## Device Description:

SAGICO IBF System - ARIA Lumbar implants are interbody fusion devices used to provide structural stability in skeletally mature individuals following discectomy. SAGICO IBF System - ARIA Lumbar implants are provided in different shapes to accommodate various surgical approaches to the lumbar spine (posterior, transforaminal [posterolateral] or lateral and can expand to the desired height. The SAGICO IBF System - ARIA Lumbar implants are available in various heights and geometric options to fit the anatomical needs of a wide variety of patients. The SAGICO IBF System - ARIA Lumbar implants are to be filled with autogenous bone graft material. Protrusions are located on the superior and inferior surfaces of each device grip the endplates of the adjacent vertebrae to resist expulsion.

SAGICO IBF System - ARION Cervical implants are interbody fusion devices used to provide structural stability in skeletally mature individuals following discectomy. SAGICO IBF System - ARION Cervical implant is intended to be used between two contiguous levels from C2 to T1 and placed via an open anterior surgical approach. The implants are available in various heights and geometric options to fit the anatomical needs of a wide variety of patients. SAGICO IBF System - ARION Cervical implants are comprised of PEEK Optima LT1 and include large central hollow window to be filled with autogenous bone graft material. SAGICO IBF System - ARION Cervical implants features protrusions located on the top and bottom surfaces of PEEK spacers to engage with superior and inferior endplates of the adjacent vertebrae to resist rotational and expulsion. SAGICO IBF System - ARION Cervical includes internal titanium spin blade offering internal fixation and expansion of 1mm in height allowing low profile insertion. SAGICO IBF System - ARION Cervical implant is intended to be used with FDA cleared supplemental fixation to properly utilize the device.

The SAGICO IBF System ARIA Lumbar and ARION Cervical implants are manufactured from medical Grade PEEK (Polyetheretherketone) OPTIMAT LT I (Invibio"") per ISO 10993-1 USP Class VI, and ASTM F2026, Titanium Alloy per ASTM F136 and Tantalum beads /rods to be Grade IINS R05200, IINS R05400 according to ASTM F560.

The SAGICO IBF System ARIA Lumbar and ARION Cervical implants are intervertebral body fusion devices to help restore integrity to the spine in the cervical and lumbar regions.

### INDICATIONS FOR USE:

SAGICO IBF System - ARIA Lumbar implants are interbody fusion devices intended for use in patients with degenerative disc disease (DDD) at one or two contiguous levels of the lumbosacral spine (L2-S1). DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiosraphic studies. These patients should be skeletally mature and have had at least six (6) months of non-operative treatment. In addition, these patients may have up to Grade 1 spondylolisthesis at the involved level(s). SAGICO IBF System - ARIA Lumbar are to be filled with autogenous bone graft material. The SACICO IBF System - ARIA Lumbar implant is intended to be used with supplemental fixation cleared by the FDA to properly utilize this device.

The SAGICO IBF System - ARION Cervical implant is interbody fusion device intended for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine with accompanying radicular symptoms at one disc level from (C2-T1). DDD is defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies. These patients should be skeletally mature and have had at least six (6) weeks of non-operative treatment.

The SAGICO IBF System - ARION Cervical implant is to be filled with autogenous bone graft material and placed via open anterior approach. The SAGICO IBF System – ARION Cervical implant must be used with additional internal fixation (e.g. anterior plate or cervical pedicle screws) cleared by the FDA to properly utilize this device.

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Image /page/6/Picture/0 description: The image is a logo for SAGICO. The logo is a stylized hexagon with the word "SAGICO" written across the top. The hexagon is made up of several lines that create a geometric pattern. The logo is black and white.

# NON-CLINICAL PERFORMANCE DATA:

Non-clinical performance data testing conducted to support substantial equivalence for the SAGICO IBF System - ARIA Lumbar and ARION Cervical devices included:

### ASTM F2077

Standard Test Methods for Intervertebral Body Fusion Devices

- . Static and Dynamic Compression Test
- Static and Dynamic Compression Shear Test
- . Static and Dynamic Torsion Test

#### ASTM F2267-04

Standard Test Method for Measuring Load Induced Subsidence of Intervertebral Body Fusion Device under Static Axial Compression

#### ASTM F04.25.02.02

Static Push-out Test

Conclusion: The results of this non-clinical testing demonstrate that the performance of the SAGICO IBF System - Aria Lumbar and Arion Cervical are substantially equivalent to legally marketed predicate devices.

## SUBSTANTIAL EQUIVALENCE CONCLUSION:

The SAGICO IBF Systems – ARIA Lumbar and ARION Cervical implants are similar to the predicate devices with respect to design, indication for use, performance and technical characteristics.

The information provided within this premarket notification supports substantial equivalence of the SAGICO IBF Systems - ARIA Lumbar and ARION Cervical implants to the cited predicate devices.