F3D Cervical Stand-Alone Interbody Fusion System

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June 15, 2020 CoreLink, LLC % Nathan Wright, MS Engineer & Regulatory Specialist Empirical Testing Corp. 4628 Northpark Drive Colorado Springs, Colorado 80918 Re: K200087 Trade/Device Name: F3D Cervical Stand-Alone Interbody Fusion System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral Body Fusion Device Regulatory Class: Class II Product Code: OVE Dated: May 12, 2020 Received: May 15, 2020 Dear Mr. Wright: 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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 {1}------------------------------------------------ requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems. For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100). Sincerely, Brent Showalter, Ph.D. Acting Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement on last page. - 510(k) Number (if known) K200087 Device Name F3D Cervical Stand-Alone Interbody Fusion System Indications for Use (Describe) The F3D Cervical Stand-Alone System is a stand-alone anterior cervical interbody fusion system indicated for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine with accompanying radicular symptoms at one or two contiguous disc levels. DDD is defined as discogenic pain with degeneration of the disc confirmed by patient history and radiographic studies. The F3D Cervical Stand-Alone System is used to facilitate intervertebral body fusion in the cervical spine and is placed via an anterior approach at one- or two-disc levels (C2-T1) using autograft bone. Patients should have at least six (6) weeks of non-operative treatment prior to treatment. The F3D Cervical Stand-Alone Interbody Fusion System is intended to be used with the bone screw fixation provided and requires no additional fixation. {3}------------------------------------------------ # 510(K) SUMMARY | Submitter's Name: | CoreLink, LLC | |----------------------------|------------------------------------------------------------------------------------------| | Submitter's Address: | 2072 Fenton Logistics Park Blvd.<br>St. Louis, Missouri 63026 | | Submitter's Telephone: | 888-349-7808 | | Contact Person: | Nathan Wright MS<br>Empirical Testing Corp.<br>719-351-0248<br>nwright@empiricaltech.com | | Date Summary was Prepared: | 14-Jan-2020 | | Trade or Proprietary Name: | F3D Cervical Stand-Alone Interbody Fusion System | | Common or Usual Name: | Intervertebral Fusion Device with Integrated Fixation, Cervical | | Classification: | Class II per 21 CFR §888.3080 | | Product Code: | OVE | | Classification Panel: | Division of Orthopedic Devices | ### DESCRIPTION OF THE DEVICE SUBJECT TO PREMARKET NOTIFICATION: The CoreLink F3D Cervical Stand-Alone Interbody Fusion System is a collection of additively and subtractively manufactured implants and associated instruments for surgical site preparation and implantation. The subject cages are additively manufactured from Ti-6Al-4V per ASTM F3001. The subject screws are machined from Ti-6Al-4V per ASTM F136. The F3D Cervical Stand-Alone Interbody Fusion System includes additively manufactured interbody spacers. The spacer and screw components are available in an assortment of dimensional combinations to accommodate the individual anatomic and clinical circumstances of each patient. The basic shape of the spacer is a trapezoidal column to provide surgical stabilization of the spine. The inferior/superior aspects of the spacer incorporate a vertical cavity which can be packed with bone graft. #### INDICATIONS FOR USE The F3D Cervical Stand-Alone System is a stand-alone anterior cervical interbody fusion system indicated for use in skeletally mature patients with degenerative disc disease (DDD) of the cervical spine with accompanying radicular symptoms at one or two contiguous disc levels. DDD is defined as discogenic pain with degeneration of the disc confirmed by patient history and radiographic studies. The F3D Cervical Stand-Alone System is used to facilitate intervertebral body fusion in the cervical spine and is placed via an anterior approach at one- or two-disc levels (C2-T1) using autograft bone. Patients should have at least six (6) weeks of nonoperative treatment prior to treatment. The F3D Cervical Stand-Alone Interbody Fusion System is intended to be used with the bone screw fixation provided and requires no additional fixation. {4}------------------------------------------------ ### TECHNOLOGICAL CHARACTERISTICS The F3D Cervical Stand-Alone Interbody Fusion System is made from titanium alloy that conforms to ASTM F3001, ISO 5832-3, and ASTM F136. The subject and predicate devices have nearly identical technological characteristics and the minor differences do not raise any new issues of safety and effectiveness. Specifically, the following characteristics are identical between the subject and predicates: - Indications for Use - Materials of manufacture ● - Structural support mechanism ● | 510k Number | Trade or Proprietary or<br>Model Name | Manufacturer | Predicate<br>Type | |-------------|-----------------------------------------------|-----------------------------------------|-------------------| | K190546 | Matrixx Stand Alone<br>Cervical System | Nexxt Spine LLC | Primary | | K173115 | COALITION® MIS<br>SPACER | Globus Medical Inc. | Additional | | K190655 | Shoreline™ ACS System | SeaSpine®<br>Orthopedics<br>Corporation | Additional | | K152793 | Unison-C Anterior Cervical<br>Fixation System | RTI Surgical, Inc. | Additional | | K171489 | Acapella Cervical Spacer<br>System | Choice Spine, LP. | Additional | | K162496 | Foundation™ 3D Interbody | CoreLink, LLC | Reference | ## Performance Data The F3D Cervical Stand-Alone Interbody Fusion System has been tested in the following test modes: - Static and dynamic axial compression per ASTM F2077 ● - Static and dynamic compression shear per ASTM F2077 - Static and dynamic torsion per ASTM F2077 ● - Subsidence per ASTM F2267 ● - . Expulsion The results of this non-clinical testing show that the strength of the F3D Cervical Stand-Alone Interbody Fusion System is sufficient for its intended use and is substantially equivalent to legally marketed predicate devices. {5}------------------------------------------------ ### CONCLUSION The overall technology characteristics and mechanical performance data lead to the conclusion that the F3D Cervical Stand-Alone Interbody Fusion System is substantially equivalent to the predicate device.