K171425 · Medos International SARL · MAX · Jul 20, 2017 · Orthopedic
Device Facts
Record ID
K171425
Device Name
CONCORDE LIFT
Applicant
Medos International SARL
Product Code
MAX · Orthopedic
Decision Date
Jul 20, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3080
Device Class
Class 2
Attributes
Therapeutic
Intended Use
The CONCORDE LIFT Expandable Interbody Device is a lumbar intervertebral body fusion device, and is indicated for use with autogenous bone graft and/or allograft comprised of cancellous bone graft in patients with degenerative disc disease (DDD) at one or two contiguous levels of the lumbar spine, L2 to S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The CONCORDE LIFT Expandable Interbody Device can be implanted via posterior, transforaminal or lateral approach. DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Candidates for surgery should be skeletally mature and have had a six-month course of conservative treatment. These patients may have had primary or secondary surgery, but no previous fusion at the involved levels. The device is not intended to be used as a stand-alone device. It must be used with supplemental internal spinal fixation systems that have been cleared for use in the lumbar spine.
Device Story
CONCORDE LIFT is an expandable interbody fusion device for lumbar spine surgery. Implanted via posterior, transforaminal, or lateral approach by surgeons. Device features internal cavity for autogenous or allogenic bone graft to facilitate fusion. Available in convex and lordotic configurations. Must be used with supplemental internal spinal fixation. Provides structural support to intervertebral space during fusion process. Benefits patients by stabilizing spinal segments affected by degenerative disc disease. Device is MR Conditional.
Clinical Evidence
No clinical data provided. Substantial equivalence supported by bench testing, including MR safety testing (displacement force, image artifacts, RF-induced heating, torque) and bacterial endotoxin monitoring.
Technological Characteristics
Constructed from titanium alloy (Ti-6Al-4V) per ASTM F136. Expandable interbody fusion device design. Gamma sterilized, single-use. MR Conditional. No software or electronic components.
Indications for Use
Indicated for skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous lumbar levels (L2-S1), including those with up to Grade I spondylolisthesis or retrolisthesis. Requires six-month conservative treatment history. Not for patients with previous fusion at involved levels.
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.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 20, 2017
Medos International, SARL % Ms. Desiree Saracino Regulatory Affairs Specialist DePuv Synthes 325 Paramount Drive Raynham, Massachusetts 02767
Re: K171425
Trade/Device Name: CONCORDE LIFT™ Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: MAX Dated: June 27, 2017 Received: June 30, 2017
Dear Ms. Saracino:
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
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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 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 (800) 638-2041 or (301) 796-7100 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 (800) 638-2041 or (301) 796-7100 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) K171425
Device Name CONCORDE LIFT™
### Indications for Use (Describe)
The CONCORDE LIFT Expandable Interbody Device is a lumbar intervertebral body fusion device, and is indicated for use with autogenous bone graft and/or allograft comprised of cancellous bone graft in patients with degenerative disc disease (DDD) at one or two contiguous levels of the lumbar spine, L2 to S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The CONCORDE LIFT Expandable Interbody Device can be implanted via posterior, transforaminal or lateral approach.
DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Candidates for surgery should be skeletally mature and have had a six-month course of conservative treatment. These patients may have had primary or secondary surgery, but no previous fusion at the involved levels.
The device is not intended to be used as a stand-alone device. It must be used with supplemental internal spinal fixation systems that have been cleared for use in the lumbar spine.
Type of Use (Select one or both, as applicable)
| <span> <span></span>Prescription Use (Part 21 CFR 801 Subpart D) </span> |
|----------------------------------------------------------------------------|
| <span> <span></span>Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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## 510(k) Summary
B.
C.
D.
#### Submitter Information A.
| 510(k) Sponsor: | Medos International, SARL |
|-------------------------------------------|-------------------------------------------------------------------------------|
| Contact Person: | Desiree Saracino<br>DePuy Synthes<br>325 Paramount Drive<br>Raynham, MA 02767 |
| Telephone number: | (508) 977-3842 |
| Fax number: | (508) 828-3797 |
| Email: | Dsaracin@its.jnj.com |
| Date Prepared | July 18, 2017 |
| Device Name | |
| Trade/Proprietary Name: | CONCORDE LIFT™ |
| Common/Usual Name: | Intervertebral Body Fusion Device |
| Device Classification<br>and Regulation: | Class II per 21 CFR § 888.3080 |
| Classification Product and Panel<br>Code: | MAX; Orthopedic |
| Predicate Device Name | |
| Primary: | K160464: Opticage™ Expandable Interbody Fusion Device |
K152156: Opticage™ Expandable Interbody Fusion Device Additional: K113527: Opticage™ Expandable Interbody Fusion Device K162879: Elite™ Expandable Interbody Fusion Device (Spineology Inc.)
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#### E. Device Description
The CONCORDE LIFT Expandable Interbody Devices are provided gamma sterilized and are for single use only. The devices are designed for lumbar intervertebral body fusion via posterior, transforaminal or lateral approach. They are fabricated from titanium alloy (Ti-6Al-4V) as per ASTM F136. A cavity internal to each device is intended to hold autogenous bone and/or allogenic bone graft comprised of cancellous and/or corticocancellous bone graft. The CONCORDE LIFT is available in both a convex configuration and a lordotic configuration.
The purpose of this submission is to add MR Conditional labeling, expanded indications and to document minor design modifications.
#### F. Indications for Use
The CONCORDE LIFT Expandable Interbody Device is a lumbar intervertebral body fusion device, and is indicated for use with autogenous bone graft and/or allograft comprised of cancellous and/or corticocancellous bone graft in patients with degenerative disc disease (DDD) at one or two contiguous levels of the lumbar spine, L2 to S1. These DDD patients may also have up to Grade I spondylolisthesis or retrolisthesis at the involved level(s). The CONCORDE LIFT Expandable Interbody Device can be implanted via posterior, transforaminal or lateral approach.
DDD is defined as discogenic back pain with degeneration of the disc confirmed by history and radiographic studies. Candidates for surgery should be skeletally mature and have had a six-month course of conservative treatment. These patients may have had primary or secondary surgery, but no previous fusion at the involved levels.
The device is not intended to be used as a stand-alone device. It must be used with supplemental internal spinal fixation systems that have been cleared for use in the lumbar spine.
#### G. Summary of Similarities and Differences in Technological Characteristics, Performance and Intended Use
The technological characteristics, including material, design and performance of the CONCORDE LIFT Expandable Interbody Fusion Device are consistent with those of the predicate devices.
#### H. Materials
The CONCORDE LIFT Expandable Interbody Device is manufactured from titanium alloy (Ti-6Al-4V) conforming to ASTM F136.
#### I. Performance Data
The CONCORDE LIFT Expandable Interbody Device was tested in accordance with the standards listed below.
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ASTM F2052-15 Standard Test Method for Measurement of Magnetically Induced Displacement Force on Medical Devices in the Magnetic Resonance Environment
ASTM F2119-07 Standard Test Method for Evaluation of MR Image Artifacts from Passive Implants
ASTM F2182-11a Standard Test Method for Measurement of Radio Frequency Induced Heating on or Near Passive Implants During Magnetic Resonance Imaging
ASTM F2213-06 Standard Test Method for Measurement of Magnetically Induced Torque on Medical Devices in the Magnetic Resonance Environment
ANSI/AAMI ST72 Bacterial endotoxins - Test methods, routine monitoring, and alternatives to batch testing
#### J. Conclusion
Based on the indications for use, technological characteristics, and comparison to the predicate devices, the CONCORDE LIFT Expandable Interbody Device is substantially equivalent to the legally marketed predicate devices.
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