K Number
K101255
Date Cleared
2010-07-21

(78 days)

Product Code
Regulation Number
888.3060
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Alphatec Spine Anterior Lumbar Plating System is intended for use as an anteriorly placed supplemental fixation device via the lateral or anterolateral surgical approach above the bifurcation of the great vessel or via the anterior surgical approach, below the bifurcation of the great vessels. The device is intended as a temporary fixation device until fusion is achieved.

The Alphatec Spine Anterior Lumbar Plating System is intended for anterior lumbar spine (L1-S1) fixation for the following indications:

  1. Degenerative disc disease (defined as back pain of discogenic origin with degenerative disc confirmed by history and radiographic studies)
  2. Pseudoarthrosis
  3. Spondylolysis
  4. Spondylolisthesis
  5. Trauma (i.e., fracture or dislocation)
  6. Spinal stenosis
  7. Unsuccessful previous fusion surgery
  8. Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
  9. Tumor

The Alphatec Spine Anterior Lumbar Plating System is intended to be used with autograft and/or allograft as an adjunct to fusion.

Device Description

The Alphatec Spine Anterior Lumbar Plating System is a spinal fixation system that consists of a variety of non-sterile, single-use plates and screws. All implants are manufactured from titanium alloy conforming to ASTM F136. The system also contains Class I manual instruments. The plates attach to the anterior or anterolateral aspect of the vertebral body of the lumbar/lumbosacral spine (levels L1-S1) providing temporary internal fixation and stabilization during bone graft healing and/or fusion mass development.

AI/ML Overview

The provided text describes a medical device, the "Alphatec Spine Anterior Lumbar Plating System," which is a spinal fixation system. However, the document is a 510(k) summary for regulatory clearance, which focuses on demonstrating substantial equivalence to predicate devices rather than providing a detailed study on acceptance criteria for a new device's performance against specific clinical outcomes.

This document details non-clinical performance data (mechanical testing) for the device's safety and effectiveness, but it does not contain information about studies involving human readers, AI, or clinical outcomes that would allow for a complete answer to your request in the context of device performance against specific acceptance criteria related to accuracy, sensitivity, specificity, etc.

Therefore, I cannot provide a table of acceptance criteria and reported device performance related to diagnostic accuracy, nor information on sample sizes for test sets (human or AI), expert qualifications, adjudication methods, multi-reader multi-case studies, standalone algorithm performance, or ground truth for training and test sets in the way you've outlined. This information is typically found in clinical validation studies for diagnostic devices or AI-powered systems.

Here's what can be extracted from the provided text, primarily regarding non-clinical performance:

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

The document primarily discusses non-clinical performance data related to mechanical testing to ensure safety and effectiveness.

Acceptance Criteria Category (Non-Clinical)Reported Device Performance
Mechanical Static PerformanceSatisfies requirements for anterolateral lumbar fixation
Mechanical Torsion PerformanceSatisfies requirements for anterolateral lumbar fixation
Dynamic Testing PerformanceSatisfies requirements for anterolateral lumbar fixation
Adherence to Consensus StandardsPerformed per recognized consensus standards
Adherence to Guidance DocumentPerformed per "Spinal System 510(k)s - Guidance for Industry and FDA Staff"

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

This information is not present for clinical or diagnostic performance. The document describes mechanical tests, not studies with human subjects or AI algorithms reviewing data.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This information is not present. The document discusses mechanical testing, not ground truth established by experts for diagnostic purposes.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

This information is not present. No such adjudication method would be relevant for the mechanical testing described.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

This information is not present. The device is a physical spinal implant, not an AI diagnostic tool that would involve human readers.

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

This information is not present. The device is a physical spinal implant.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

For the non-clinical mechanical testing, the "ground truth" or reference for performance is established by the recognized consensus standards and guidance documents for spinal systems.

8. The sample size for the training set

This information is not present. There is no mention of a "training set" as this is a physical medical device, not an AI algorithm.

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

This information is not present. Not applicable to the device described.

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K101255 Page 1/2

Image /page/0/Picture/1 description: The image shows the logo for Alphatec Spine. The logo consists of the Greek letter alpha above the words "Alphatec Spine". The word "Spine" is in a cursive font.

510(k) Summary Alphatec Spine, Inc. Alphatec Spine Anterior Lumbar Plating System

510(k) SUMMARY May 2010

Submitter:Alphatec Spine, Inc.5818 El Camino RealCarlsbad, CA 92008Direct: (760) 494-6739Fax: (760) 431-0289JUL 21 2010
Official Contact:Karla Schaffner, Regulatory Affairs Submissions Specialist
Trade/Model Name:Alphatec Spine Anterior Lumbar Plating System
Common Name:Spinal Intervertebral Body Fixation Orthosis
Classification Regulation:KWQ - 888.3060 - Appliance, Fixation, Spinal IntervertebralBody

Substantial Equivalence:

C

The Alphatec Spine Anterior Lumbar Plating System is substantially equivalent in intended use and function to the following predicate devices:

CompanySystemClearance
Spinal USAAnterior Lumbar Plate SystemK091044
Blackstone MedicalUnity Anterior Lumbar Plate Fixation SystemK043548
Blackstone MedicalUnity LX Anterolateral Lumbar Plate Fixation SystemK061229

Device Description:

The Alphatec Spine Anterior Lumbar Plating System is a spinal fixation system that consists of a variety of non-sterile, single-use plates and screws. All implants are manufactured from titanium alloy conforming to ASTM F136. The system also contains Class I manual instruments. The plates attach to the anterior or anterolateral aspect of the vertebral body of the lumbar/lumbosacral spine (levels L1-S1) providing temporary internal fixation and stabilization during bone graft healing and/or fusion mass development.

Intended Use

The Alphatec Spine Anterior Lumbar Plating System is intended for use as an anteriorly placed supplemental fixation device via the lateral or anterolateral surgical approach above the bifurcation of the great vessel or via the anterior surgical approach, below the bifurcation of the great vessels. The device is intended as a temporary fixation device until fusion is achieved.

The Alphatec Spine Anterior Lumbar Plating System is intended for anterior lumbar spine (L1-S1) fixation for the following indications:

Page 5-1

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101255 Page 2/2

α

Alphatec Spring

510(k) Summary Alphatec Spine, Inc. Alphatec Spine Anterior Lumbar Plating System

    1. Degenerative disc disease (defined as back pain of discogenic origin with degenerative disc confirmed by history and radiographic studies)
  • Pseudoarthrosis 2.
    1. Spondylolysis
    1. Spondylolisthesis
    1. Trauma (i.e., fracture or dislocation)
    1. Spinal stenosis
    1. Unsuccessful previous fusion surgery
    1. Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
    1. Tumor

The Alphatec Spine Anterior Lumbar Plating System is intended to be used with autograft and/or allograft as an adjunct to fusion.

Technological Characteristics Comparison:

The Alphatec Spine Anterior Lumbar Plating System is equivalent to the referenced device in that it is intended to be used to provide temporary internal lumbar/lumbosacral spine fixation and stabilization during bone graft healing and/or fusion mass development. It is similar in terms of general design, intended use, and technological characteristics to the predicate device.

Material composition is identical to numerous other Alphatec Spine products that have been cleared via the 510(k) process.

Nonclinical Performance Data:

Mechanical static compression and torsion and dynamic testing was performed which provides reasonable assurance of safety and effectiveness for its intended use. Performance testing was performed per the recognized consensus standards and per the guidance document. Spinal System 510(k)s - Guidance for Industry and FDA Staff. This testing clearly demonstrated that the performance characteristics satisfy the requirements of anterolateral lumbar fixation. As a results of this testing have demonstrated that the Alphatec Spine Anterior Lumbar Plating System is substantially equivalent to the Spinal USA predicate device.

page 2 of 2

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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the top half of the circle. Inside the circle is an image of an eagle with its wings spread, with three lines representing the feathers.

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

Alphatec Spine, Inc. % Ms. Karla Schaffner Regulatory Affairs Submission Specialist 5818 El Camino Real Carlsbad, California 92008

JUL 21 2010

Re: K101255

Trade/Device Name: Alphatec Spine Anterior Lumbar Plating System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: K WQ Dated: May 03, 2010 Received: May 04, 2010

Dear Ms. Schaffner:

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

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Page 2 - Ms. Karla Schaffner

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 device-related 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 go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHQtfices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Mark N. Melkerson Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Alphatec Spine Anterior Lumbar Plating System

$\alpha$

Section 4 Indications for Use Statement

510(k) Number (if known): TBD

< 01755

Device Name: Alphatec Spine Anterior Lumbar Plating System

Indications for Use:

The Alphatec Spine Anterior Lumbar Plating System is intended for use as an anteriorly placed supplemental fixation device via the lateral or anterolateral surgical approach above the bifurcation of the great vessel or via the anterior surgical approach, below the bifurcation of the great vessels. The device is intended as a temporary fixation device until fusion is achieved.

The Alphatec Spine Anterior Lumbar Plating System is intended for anterior lumbar spine (LJ-S1) fixation for the following indications:

    1. Degenerative disc disease (defined as back pain of discogenic origin with degenerative disc confirmed by history and radiographic studies)
  • Pseudoarthrosis 2.
  • Spondylolysis 3.
    1. Spondylolisthesis
    1. Trauma (i.e., fracture or dislocation) .
    1. Spinal stenosis
    1. Unsuccessful previous fusion surgery
    1. Deformities or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
    1. Tumor

.

The Alphatec Spine Anterior Lumbar Plating System is intended to be used with autograft and/or allograft as an adjunct to fusion.

Prescription Use(Per 21 CFR 801.109)X
---------------------------------------------

OR

Over-The Counter Use

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Division Sign-Off) Division of Surgical, Orthopedic, Restorative Devices

KIDIZES 510(k) Number.

Page 1 of

§ 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.