The ATEC Lateral Plate System is intended for use via the lateral surgical approach above the bifurcation of the great vessels in the treatment of thoracolumbar (T1-L5) spine instability or via the anterior surgical approach, below the bifurcation of the great vessels in the treatment of lumbosacral (L1- S1) spine instability as a result of fracture (including dislocation), tumor, degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), pseudoarthrosis, spondylolysis, spondylolisthesis, scoliosis, lordotic deformities of the spinal stenosis, or a failed previous spine surgery.

Device Description

The ATEC Lateral Plate System is implanted through a lateral or anterolateral surgical approach to the thoracolumbar spine to provide temporary stabilization until fusion has occurred. The system will be comprised of both implants manufactured from titanium alloy (Ti-6A1-4V ELI) per ASTM F136 for fixation and the required instruments to place them. ATEC Lateral Plate System implants will be provided in a range of sizes and lengths used to create a construct to immobilize the spinal segments.

AI/ML Overview

This document is a 510(k) summary for the ATEC Lateral Plate System. It describes the device, its indications for use, and a comparison to predicate devices, focusing on demonstrating substantial equivalence. It explicitly states that clinical data was "Not applicable" for the determination of substantial equivalence. Therefore, there is no study described in this document that proves the device meets specific acceptance criteria based on clinical performance.

Here's a breakdown of the requested information based on the provided text, primarily noting what is not present:

1. A table of acceptance criteria and the reported device performance

No acceptance criteria for performance (e.g., sensitivity, specificity, accuracy, etc.) are stated as this is not a diagnostic or AI/ML device requiring such metrics. The "device performance" in this context refers to nonclinical mechanical testing.

Acceptance Criteria (Not explicitly stated as such for performance)	Reported Device Performance (Nonclinical Testing)
(Implied) Mechanical performance comparable to predicate devices in:	Results demonstrate substantial equivalence to other predicate devices for nonclinical testing in:
- Static Axial Compression Bending	- Static Axial Compression Bending testing per ASTM F1717
- Dynamic Axial Compression Bending	- Dynamic Axial Compression Bending testing per ASTM F1717
- Static Torsion	- Static Torsion testing per ASTM F1717
- Static Screw Push-out	- Static Screw Push-out testing

2. Sample size used for the test set and the data provenance

Not applicable. There was no clinical test set used for performance evaluation that involved human data. The testing mentioned is nonclinical (mechanical) and typically uses a set number of manufactured devices.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

Not applicable. There was no clinical test set requiring expert-established ground truth.

4. Adjudication method for the test set

Not applicable. There was no clinical test set requiring an adjudication method.

5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done

No. An MRMC study was not done. The document explicitly states "Clinical Information: Not applicable; determination of substantial equivalence is not based on an assessment of clinical performance data."

6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done

Not applicable. This device is a medical implant (plate system for spinal fixation), not an algorithm or AI/ML product.

7. The type of ground truth used

Not applicable. Clinical ground truth (e.g., expert consensus, pathology, outcomes data) was not used as no clinical performance study was conducted. The "ground truth" for the nonclinical testing would be the physical properties and mechanical behavior of the tested devices against established ASTM standards and predicate device data.

8. The sample size for the training set

Not applicable. This device is a medical implant, not an AI/ML product that would require a training set.

9. How the ground truth for the training set was established

Not applicable. See response to #8.

Summary

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May 9, 2023

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the seal of the Department of Health & Human Services. To the right of the seal is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, and the word "ADMINISTRATION" in a smaller font size below it.

Alphatec Spine, Inc. Aditya Aiyer Regulatory Affairs Specialist 1950 Camino Vida Roble Carlsbad, California 92008

Re: K230721

Trade/Device Name: ATEC Lateral Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal Intervertebral Body Fixation Orthosis Regulatory Class: Class II Product Code: KWQ Dated: March 15, 2023 Received: March 15, 2023

Dear Aditya Aiyer:

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 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

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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 (QS) 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 medical devices and radiation-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,

Colin O'neill -S

Colin O'Neill, M.B.E. Assistant Director DHT6B: Division of Spinal Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K230721

Device Name ATEC Lateral Plate System

Indications for Use (Describe)

Type of Use (Select one or both, as applicable)
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X Prescription Use (Part 21 CFR 801 Subpart D)

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

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Image /page/3/Picture/1 description: The image shows the logo for "atec". The "a" is green, and the rest of the letters are dark blue. There is a trademark symbol to the right of the "c". There is a black line underneath the logo.

This 510(k) summary of safety and effectiveness is being submitted in accordance with the requirements of 21 CFR 807.92.

I.	SUBMITTER:	Alphatec Spine, Inc.1950 Camino Vida RobleCarlsbad, CA 92008Phone: (760) 431-9286Fax: (760) 431-0289
	Contact Person:	Aditya AiyerRegulatory Affairs SpecialistContact Phone: (760) 494-6671
	Date Summary Prepared:	March 15, 2023
II.	DEVICE
	Name of Device:Common or Usual Name:Classification Name:	ATEC Lateral Plate SystemSpinal Intervertebral Body Fixation OrgSpinal Intervertebral Body Fixation Org

Regulatory Class: Product Code:

hosis hosis (21 CFR 888.3060) Class II KWQ

III. LEGALLY MARKETED PREDICATE DEVICES

510(k)	Product Code	Trade Name	Manufacturer
Primary Predicate Device
K202624	KWQ	Z-Span Plate System	Zavation
Additional Predicate/Reference Devices
K092108	KWQ	TRUSS™ Thoracolumbar PlateSystem	Globus
K180166	KWQ	Life Spine Lumbar Fixation System(SENTRY®)	Life Spine
K221926	PML, NKB,KWP, KWQ	Invictus® Bone Cement, InvictusSpinal Fixation System	Alphatec Spine
K182808	KWQ	Aspida Anterior Lumbar PlatingSystem	Alphatec Spine

IV. DEVICE DESCRIPTION

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ATEC Lateral Plate System implants will be provided in a range of sizes and lengths used to create a construct to immobilize the spinal segments.

The purpose of this submission is to seek initial clearance for the ATEC Lateral Plate System.

V. INDICATIONS FOR USE

The ATEC Lateral Plate System is intended for use via the lateral or anterolateral surgical approach above the bifurcation of the great vessels in the treatment of thoracic and thoracolumbar (T1-L5) spine instability or via the anterior surgical approach, below the bifurcation of the great vessels in the treatment of lumbar and lumbosacral (L1- S1) spine instability as a result of fracture (including dislocation and subluxation), tumor, degenerative disc disease (defined as back pain of discogenic origin with degeneration of the disc confirmed by patient history and radiographic studies), pseudoarthrosis, spondylolysis, spondylolisthesis, scoliosis, lordotic deformities of the spine, spinal stenosis, or a failed previous spine surgery

VI. TECHNOLOGICAL COMPARISON TO PREDICATES

The technological design features of the subject implants were compared to the predicates in intended use, indications for use, design, function and technology and it was demonstrated that they are substantially equivalent.

VII. PERFORMANCE DATA

Nonclinical testing performed on the subject ATEC Lateral Plate System, supports substantial equivalence to the other predicate devices. The following testing was performed:

Static Axial Compression Bending testing per ASTM F1717 ●
Dynamic Axial Compression Bending testing per ASTM F1717 ●
Static Torsion testing per ASTM F1717 ●
Static Screw Push-out testing ●

The results demonstrate that the subject ATEC Lateral Plate System is substantially equivalent to other predicate devices for nonclinical testing.

Clinical Information

Not applicable; determination of substantial equivalence is not based on an assessment of clinical performance data.

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VIII. CONCLUSION

Based upon the information provided in this 510(k) submission it has been determined that the subject devices are substantially equivalent to legally marketed devices in regard to indications for use, intended use, design, technology, and performance.

Regulation Number and Section

§ 888.3060 Spinal intervertebral body fixation orthosis.

(a)
Identification. A spinal intervertebral body fixation orthosis is a device intended to be implanted made of titanium. It consists of various vertebral plates that are punched into each of a series of vertebral bodies. An eye-type screw is inserted in a hole in the center of each of the plates. A braided cable is threaded through each eye-type screw. The cable is tightened with a tension device and it is fastened or crimped at each eye-type screw. The device is used to apply force to a series of vertebrae to correct “sway back,” scoliosis (lateral curvature of the spine), or other conditions.(b)
Classification. Class II.