It is intended that this device, in any system configuration be removed after development of solid fusion mass. Hook component indications are limited to T7-L5. Sacral screw indications are limited to the sacrum only.

The ZODIAC Polyaxial Pedicle Screw System, when used as a hook and sacral screw fixation system (nonpedicle screw) is intended for:
a. Patients having fractures of the thoracic and lumbar spine.
b. Patients having deformity (i.e., idioscoliosis, neuromuscular scoliosis, or kyphoscoliosis with associated paralysis or spasticity).
c. Patients having spondylolisthesis (i.e., isthmic spondylolisthesis, degenerative spondylolisthesis, and acute pars fracture allowing spondylolisthesis).
The ZODIAC Polyaxial Pedicle Screw System, when used as a pedicle screw system in the thoraco-lumbo-sacral region of the spine is intended for degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudoarthrosis).
In addition, the ZODIAC Polyaxial Pedicle Screw System, when used as a pedicle screw fixation system is intended for:
a. Patients receiving only autogenous bone graft.
b. Patients having the device fixed or attached to the lumbar and sacral spine and having severe spondylolisthesis grade 3 or 4 at the fifth lumbar-first sacral (L5-S1) vertebral joint.
The ZODIAC Polyaxial Pedicle Screw System, when used as a laminar hook and bone screw system is intended for:
a. Patients having fractures of thoracic and lumbar spine.
b. Patients having thoracolumbar deformity (i.e., idioscoliosis, neuromuscular scoliosis, or kyphoscoliosis with associated paralysis or spasticity).
c. Patients having spondylolisthesis (i.e., isthmic spondylolisthesis, degenerative spondylolistheses and acute pars fracture allowing spondylolisthesis).

Device Description

The ZODIAC Polyaxial Pedicle Screw System is comprised of various types and sizes of implantable components that are assembled to create a rigid spinal construct. System components are manufactured from titanium alloy, Ti6Al-4V ELI (ASTM F 136). System rods are available in titanium alloy or commercially pure titanium, CP Grade 4 (ASTM G67). The ZODIAC Polyaxial Pedicle Screw System is designed to facilitate optimal screw and rod placement.

AI/ML Overview

The provided text describes a medical device, the ZODIAC Polyaxial Pedicle Screw System, and its clearance through the 510(k) pathway. This pathway establishes substantial equivalence to already marketed predicate devices, primarily through performance data demonstrating comparable safety and effectiveness.

However, the 510(k) summary does not contain the level of detail requested for a typical AI/software device study (e.g., acceptance criteria, test set sample size, expert ground truth, MRMC study, standalone performance). This is because the ZODIAC system is a mechanical implant, and its performance evaluation relies on different methodologies, primarily mechanical and dynamic testing, rather than clinical efficacy studies with human readers or AI algorithms.

Therefore, many of the specific questions cannot be answered from the provided document. I will extract what information is present and indicate where the requested information is not available.

Acceptance Criteria and Device Performance (Based on Provided Text)

The "acceptance criteria" for a mechanical device like the ZODIAC system are met by demonstrating structural integrity and comparable mechanical performance to predicate devices. The document focuses on demonstrating substantial equivalence rather than listing specific numerical acceptance criteria.

Acceptance Criteria Category	Reported Device Performance (as per 510(k) Summary)
Mechanical Performance	"The test results demonstrate that the mechanical performance of the ZODIAC Polyaxial Pedicle Screw System is at least comparable to, if not better than, those of the predicate devices."
Dynamic Performance	"Mechanical and dynamic testing... was performed." (Implied comparable to predicates, though not explicitly stated as "better than" for dynamic performance specifically.)
Biocompatibility	Implied by use of standard implant materials (titanium alloy, commercially pure titanium) with established biocompatibility (ASTM F 136, ASTM G67). Not explicitly detailed as an acceptance criterion in the summary.

Missing Information: Specific numerical thresholds for mechanical strength, fatigue life, or other mechanical properties that would constitute "acceptance criteria" are not provided in this 510(k) summary. These would typically be found in detailed test reports, not the summary itself.

Study Details (Based on Provided Text)

Sample size used for the test set and the data provenance: Not applicable in the context of mechanical testing. The "test set" would refer to the number of devices or components tested. This number is not specified in the 510(k) summary. The data provenance would be from laboratory testing.
Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. For mechanical testing of implantable devices, "ground truth" is established through physical measurement and engineering analysis, not expert interpretation of data relevant to AI performance.
Adjudication method for the test set: Not applicable. Mechanical testing results are objective measurements and do not typically require adjudication in the way clinical diagnostic interpretations do.
If a multi-reader multi-case (MRMC) comparative effectiveness study was done: No, an MRMC study was not done. This type of study is relevant for diagnostic devices or AI algorithms that assist human readers in interpretation, which is not the function of a pedicle screw system.
If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: No, this is not applicable. The device is a mechanical implant, not an algorithm.
The type of ground truth used: For mechanical performance, the ground truth is derived from direct physical measurements (e.g., load-to-failure, cycles to fatigue) obtained in laboratory settings according to established industry standards or internal protocols.
The sample size for the training set: Not applicable. As a mechanical device, there is no "training set" in the context of machine learning. The design and manufacturing processes are informed by engineering principles and prior device experience, not by a data-driven training set.
How the ground truth for the training set was established: Not applicable. See point 7.

Summary of Non-Applicability:

The requested detailed information regarding acceptance criteria, study sample sizes, expert ground truth, and AI-specific study methodologies (MRMC, standalone performance, training sets) is largely not applicable to the ZODIAC Polyaxial Pedicle Screw System as described in this 510(k) summary. This is because it is a physical medical implant, and its regulatory clearance relies on demonstrating substantial equivalence through mechanical and dynamic testing against predicate devices, rather than clinical efficacy studies involving diagnostic interpretations or AI performance. The provided text indicates that mechanical and dynamic testing was performed and that the results demonstrated comparability to predicate devices.

Summary

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K033090
1 of 2

MAR 2 6 2004

ZODIAC Polyaxial Pedicle Screw System 510(k) SUMMARY November 2003

Company: Alphatec Manufacturing, Inc. 6110 Corte Del Cedro Carlsbad, CA 92009 USA Telephone: (760) 431-9286 Fax: (760) 431-9132
Contact Person: Ellen Yarnall, Director of Regulatory Affairs

Trade/Proprietary Name: ZODIAC Polyaxial Pedicle Screw System

Common Name: Pedicle Screw Spinal System

Classification Name: Spinal Interlaminal Fixation Orthosis (888,3050) Spondylolisthesis Spinal Fixation Device (888,3070) Pedicle Screw Spinal System (888.3070)

Product Description:

The ZODIAC Polyaxial Pedicle Screw System is comprised of various types and sizes of implantable components that are assembled to create a rigios annal construct. System components are manufactured from titanium alloy, Tri6Al-4V ELI (ASTM F 136). System rods are available in titanium allow or commercially pure titanium, CP Grade 4 (ASTM G67). The ZODIAC Polyaxial Pedicle Screw System is designed to facilitate optimal screw and rod placement.

Indications for Use:

It is intended that this device, in any system configuration be removed after development of solid fusion mass. Hook component indications are limited to T7-L.5. Sacral screw indications are limited to the sacrum only.

1. The ZODIAC Polyaxial Pedicle Screw System, when used as a hook and sacral screw fixation system (nonpedicle screw) is intended a noon
- a. Patients having fractures of the thoracic and lumbar spine.
- b. Patients having deformity (i.e., idioscoliosis, neuromuscular scoliosis, or kyphoscoliosis with associated paralysis or spasticity).
- c. Patients having spondylolisthesis (i.e., isthmic spondylolisthesis, degenerative spondylolisthesis, and acute pars fracture allowing spondylolisthesis).

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ZODIAC Polyaxial Pedicle Screw System 510(k) SUMMARY November 2003

2 Of 2

1. The ZODIAC Polyaxial Pedicle Screw System, when used as a pedicle screw system in the thoraco-lumbo-sacral region of the spine is intended for degenerative spondylolisthesis with objective evidence of neurologic impairment, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudoarthrosis).
1. In addition, the ZODIAC Polyaxial Pedicle Screw System, when used as a pedicle screw fixation system is intended for:
- a. Patients receiving only autogenous bone graft.
- b. Patients having the device fixed or attached to the lumbar and sacral spine and having severe spondylolisthesis grade 3 or 4 at the fifth lumbar-first sacral (L5-S1) vertebral joint.
1. The ZODIAC Polyaxial Pedicle Screw System, when used as a laminar hook and bone screw system is intended for:
- a. Patients having fractures of thoracic and lumbar spine.
- b. Patients having thoracolumbar deformity (i.e., idioscoliosis, neuromuscular scoliosis, or kyphoscoliosis with associated paralysis or spasticity).
c. Patients having spondylolisthesis (i.e., isthmic spondylolisthesis, degenerative spondylolistheses and acute pars fracture allowing spondylolisthesis).

Substantial Equivalence:

The ZODIAC Polyaxial Pedicle Screw System is substantially equivalent to the following predicate devices:

Trade/Proprietary Name	Manufacturer	Clearance
Optima Spinal System	U&I America	K031585
Global Spinal Fixation System	U&I America	K001668
Moss-Miami Spinal System	Depuy Inc.	K982320
Universal Spine System	Synthes	K022949

Performance Data:

Mechanical and dynamic testing of the ZODIAC Polyaxial Pedicle Screw System was performed. The test results demonstrate that the mechanical performance of the ZODIAC Polyaxial Pedicle Screw System is at least comparable to, if not better than, those of the predicate devices.

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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized eagle with three stripes forming its body and wing. The eagle is positioned to the right of a circular seal that contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" arranged around the perimeter.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

MAR 2 6 2004

Ms. Ellen Yarnell Director, Regulatory Affairs Alphatec Manufacturing Incorporated 6110 Corte Del Cedro Carlsbad, California 92009

Re: K033090

Trade Name: ZODIAC Pedicle Screw System Regulation Number: 21 CFR 888.3050 and 888.3070 (b) (1) Regulation Name: Spinal Interlaminal Fixation Orthosis and Pedicle Screw Spinal System Regulatory Class: Class II Product Code: KWP, MNI, MNH Dated: January 8, 2004 Received: January 9, 2004

Dear Ms. Yarnell:

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 such 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.

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Page 2 - Ms. Ellen Yarnell

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); 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. This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4659. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). 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 (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.

Sincerely yours,

Mark A. Milkum

Celia M. Witten, Ph.D., M.D. Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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MAR 2 6 2004

510(k) Number (if known): K033090

Device Name: ZODIAC Polyaxial Pedicle Screw System

Indications for Use:

lt is intended that this device, in any system configuration be removed after it is intended that this dones, in any system indications are limited to T7-L5. Sacral screw indications are limited to the sacrum only.

1. The ZODIAC Polyaxial Pedicle Screw System, when used as a hook and sacral screw fixation system (nonpedicle screw) is intended for:
- a. Patients having fractures of the thoracic and lumbar spine.
- b. Patients having deformity (i.e., idioscoliosis, neuromuscular scoliosis, or kyphoscoliosis with associated paralysis or spasticity).
- c Soliobio, or Ryphoondylolisthesis (i.e., isthmic spondylolisthesis, degenerative spondylolisthesis, and acute pars fracture allowing spondylolisthesis).
1. The ZODIAC Polyaxial Pedicle Screw System, when used as a pedicle screw system in the thoraco-lumbo-sacral region of the spine is intended for degenerative spondylolisthesis with objective evidence of intentod for abgonent, fracture, dislocation, scoliosis, kyphosis, spinal tumor and failed previous fusion (pseudoarthrosis).
1. In addition, the ZODIAC Polyaxial Pedicle Screw System, when used as a pedicle screw fixation system is intended for:
- a. Patients receiving only autogenous bone graft.
- b. Patients having the device fixed or attached to the lumbar and sacral spine and having severe spondylolisthesis grade 3 or 4 at the fifth lumbar-first sacral (L5-S1) vertebral joint.
1. The ZODIAC Polyaxial Pedicle Screw System, when used as a laminar hook and bone screw system is intended for:
- a. Patients having fractures of thoracic and lumbar spine.
- b. Patients having thoracolumbar deformity (i.e., idioscoliosis, neuromuscular scoliosis, or kyphoscoliosis with associated paralysis or spasticity).

Mark Milan

(Division Sign-Off)

Division of General, Restorative,
and Neurological Devices

K033090

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c. Patients having spondylolisthesis (i.e., isthmic spondylolisthesis, r ationto having spondylistheses and acute pars fracture allowing spondylolisthesis).

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use
(Per 21 CFR 801.109)

Over-The Counter Use _________________________________________________________________________________________________________________________________________________________

Mark N. Mikkelson

On), Restorative, Division of Ge Division of General ,
and Neurological Devices KO 33090

510(k) Number

Regulation Number and Section

§ 888.3050 Spinal interlaminal fixation orthosis.

(a)
Identification. A spinal interlaminal fixation orthosis is a device intended to be implanted made of an alloy, such as stainless steel, that consists of various hooks and a posteriorly placed compression or distraction rod. The device is implanted, usually across three adjacent vertebrae, to straighten and immobilize the spine to allow bone grafts to unite and fuse the vertebrae together. The device is used primarily in the treatment of scoliosis (a lateral curvature of the spine), but it also may be used in the treatment of fracture or dislocation of the spine, grades 3 and 4 of spondylolisthesis (a dislocation of the spinal column), and lower back syndrome.(b)
Classification. Class II.