MEDICREA® INTERNATIONAL anterior lumbo-sacral plate system is designed to be used at L5/S1 level. It is intended for use as anteriorly placed supplemental fixation device via the anterior surgical approach below the great vessel bifurcation. The device is intended as a temporary fixation device until fusion is achieved.

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate system is intended for anterior lumbar spine at L5/S1 level, for the following indications:

Degenerative Disc Disease (DDD) at L5/S1 level. (DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies)
Pseudoarthrosis
Spondylolysis
Trauma (i.e., fracture or dislocation)
Spinal stenosis
Deformities and or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
Tumor
Failed previous fusion.

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate is intended to be used with autograft and or allograft as an adjunct to fusion.

Patients should have at least six (6) months of non-operative treatment with an intervertebral cage and a lumbo-sacral plate for degenerative conditions.

Device Description

The MEDICREA® Anterior Lumbo sacral Plate system is a stabilization device for use as an adjunct to fusion. The implant is composed of :

one lumbo sacral plate
either 3 or 4 anterior lumbar screws , depending on the lumbosacral plate considered in the range

The anterior lumbar screw is manufactured from titanium alloy meeting ASTM F136 and ISO 5832-3 standards, and the lumbosacral plate is manufactured from titanium alloy meeting ASTM F136 and ISO 5832-3 and PEEK OPTIMA® meeting the ASTM F 2026.

AI/ML Overview

Acceptance Criteria & Device Performance:

The provided document does not explicitly state "acceptance criteria" with numerical targets for device performance. Instead, it demonstrates substantial equivalence to predicate devices through a comparison of design, materials, and mechanical testing results. The "reported device performance" is essentially that it met the testing standards for spinal implants and performed comparably to predicate devices in those tests.

Therefore, the table below reflects what can be inferred as "acceptance criteria" (meeting the established standards and demonstrating equivalence) and the "reported device performance" (the device successfully underwent these tests).

Acceptance Criteria (Implied)	Reported Device Performance
Adherence to ASTM F1717 "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model" for mechanical properties.	Testing was performed on the MEDICREA® Anterior Lumbosacral Plate system following the protocols outlined in ASTM F1717. The following tests were successfully conducted: Static axial Compression, Static torsion, and Dynamic compression. The successful completion of these tests suggests the device's mechanical properties are suitable for its intended use and comparable to predicate devices which have also met similar standards.
Substantial Equivalence to Predicate Devices	The MEDICREA® Anterior Lumbosacral Plate system was found to be substantially equivalent to its predicate devices (Alphatec Spine Anterior Lumbar Plating System, Spinal USA Anterior Lumbar Plate System, and Pyramid® +4 Anterior Lumbar Plate System) in terms of indications for use, design, material, and function. The comparative table on page 3 further details the similarities in design (e.g., anchorage means, shape) and materials (Ti-6Al-4V, PEEK OPTIMA® LT1).

Acceptance Criteria (Implied)

Reported Device Performance

Adherence to ASTM F1717 "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model" for mechanical properties.

Testing was performed on the MEDICREA® Anterior Lumbosacral Plate system following the protocols outlined in ASTM F1717. The following tests were successfully conducted: Static axial Compression, Static torsion, and Dynamic compression. The successful completion of these tests suggests the device's mechanical properties are suitable for its intended use and comparable to predicate devices which have also met similar standards.

Substantial Equivalence to Predicate Devices

The MEDICREA® Anterior Lumbosacral Plate system was found to be substantially equivalent to its predicate devices (Alphatec Spine Anterior Lumbar Plating System, Spinal USA Anterior Lumbar Plate System, and Pyramid® +4 Anterior Lumbar Plate System) in terms of indications for use, design, material, and function. The comparative table on page 3 further details the similarities in design (e.g., anchorage means, shape) and materials (Ti-6Al-4V, PEEK OPTIMA® LT1).

Study Information:

Sample size used for the test set and the data provenance:
- No human-based test set was used for this 510(k) submission. The "test set" refers to the specific device samples that underwent the non-clinical mechanical testing. The document does not specify the exact number of device samples used for each test (Static axial Compression, Static torsion, Dynamic compression).
- Data Provenance: The data provenance is from in vitro mechanical testing performed according to recognized ASTM standards. No human or animal data is involved. The testing was conducted by MEDICREA® INTERNATIONAL.
Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. The ground truth for mechanical testing is established by engineering principles and adherence to standardized testing protocols (ASTM F1717). No human expert consensus was required for establishing "ground truth" in this context.
Adjudication method for the test set:
- Not applicable. As this was non-clinical mechanical testing, there was no adjudication method in the sense of expert review of case outcomes. The results of the mechanical tests were directly measured and compared against the standards and predicate device characteristics.
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:
- Not applicable. This device is a spinal implant, not an AI-powered diagnostic or assistive tool. Therefore, no MRMC study or assessment of human reader improvement with AI assistance was performed.
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical medical implant, not a software algorithm.
The type of ground truth used:
- Mechanical Performance Ground Truth: The ground truth for the mechanical testing was defined by the requirements and methodologies outlined in ASTM F1717, a recognized standard for spinal implant constructs.
- Substantial Equivalence Ground Truth: The ground truth for demonstrating substantial equivalence was the characteristics and performance of the legally marketed predicate devices, as well as the established indications for use and material standards.
The sample size for the training set:
- Not applicable. As this is not a machine learning or AI device, there is no "training set."
How the ground truth for the training set was established:
- Not applicable, as there was no training set.

Summary

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K121323

JUI 18 2012

510(k) Summary for the MEDICREA® INTERNATIONAL anterior lumbo-sacral plate

In accordance with 21 CFR 807.92 of the Federal Code of Regulations the following 510(k) summary is submitted for the lumbo-sacral plate.

Date Prepared: 25/04/2012

Common Name:

1. Submitter:

Contact Person:

MEDICREA INTERNATIONAL	Laure AVIRON-VIOLET	MEDICREA INTERNATIONAL
14 Porte du Grand Lyon		14 Porte du Grand Lyon
NEYRON 01700		NEYRON 01700
FR		FR
Trade name:	Anterior Lumbo-Sacral Plate

Lumbar Stabilization Device

Classification Name: Spinal intervertebral body fixation orthosis

Classification and Regulation: KWQ-888.3060- Appliance, Fixation, Spinal Intervertebral Body,

3. Predicate or legally marketed devices which are substantially equivalent:

. The Alphatec Spine Anterior Lumbar Plating System, (Alphatec Spine, K101255)
The Spinal USA Anterior Lumbar Plate System (Spinal USA, K091044) .
. The Pyramid® +4 Anterior Lumbar Plate System (MEDTRONIC, K080429)

Description of the device: বা

The MEDICREA® Anterior Lumbo sacral Plate system is a stabilization device for use as an adjunct to fusion. The implant is composed of :

one lumbo sacral plate
either 3 or 4 anterior lumbar screws , depending on the lumbosacral plate considered in the range

Materials: Titanium alloy and PEEK OPTIMA® LT1

Function: The Anterior Lumbosacral Plate was developed as an implant:

to supplement an interbody device with an anterior fixation .
. provide anterior stabilization to the lumbar spine
to augment the development of a solid spinal fusion .
. to provide stability to ease fusion
. to be mechanically resistant to allow the fusion of the operated level

Ps 1 of 4/

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K121323

5. Intended Use

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate system is intended for anterior lumbar spine at L5/S1 level, for the following indications:

Degenerative Disc Disease (DDD) at L5/S1 level. (DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies)

1. Pseudoarthrosis
1. Spondylolysis
1. Trauma (i.e., fracture or dislocation)
1. Spinal stenosis
1. Deformities and or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
1. Tumor
1. Failed previous fusion.

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate is intended to be used with autograft and or allograft as an adjunct to fusion.

Patients should have at least six (6) months of non-operative treatment with an intervertebral cage and a lumbo-sacral plate for degenerative conditions.

6. Substantial equivalence claimed to predicate devices

MEDICREA® INTERNATIONAL Anterior Lumbosacral Plate is substantially equivalent to the Alphatec Spine Anterior Lumbar Plating System and Spinal USA anterior plate system, in terms of intended use, materials used, mechanical safety and performances, and the Pyramid in terms of intended use, design, materials used.

The Alphatec Spine Anterior Lumbar Plating System, (Alphatec Spine, K101255) .
The Spinal USA Anterior Lumbar Plate System (Spinal USA, K091044) ●
. The Pyramid® +4 Anterior Lumbar Plate System (MEDTRONIC, K080429)

Pg 2 of 4

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K121323

The table below compares the features and characteristics of MEDICREA® INTERNATIONAL Anterior Lumbosacral Plate to these predicate devices.

Device	STABOLTLumbo sacralplate	ASPIDA(AlphatecSpine)	Lumbar Plate(Spinal USA)	Pyramid +4Anteriorlumbar plate(Medtronic)
510(k)number		K101255	K091044	K080429
Intendeduse
Lumbarspine(L5/S1)	Yes	Yes	Yes	Yes
AnteriorApproachbelow thegreat vesselbifurcation	Yes	Yes	Yes	Yes
DesignAnchoragemean	3 or 4 screws	4 screws	4 screws	3 or 4 screws
Securityfeatures	Screws clippedwithin thePEEKOPTIMA® LT1insert	Screws clippedwithin thetitanium plate	Rotating anti-out backsystem	A cover plate
Shape	Triangularshape	Rectangularshape	Rectangularshape	Triangularshape
Materials
Stabilizationdevice	Ti-6Al-4V(ASTM F136 &ISO 5832-3)	Ti-6Al-4V(ASTM F136 &ISO 5832-3)	Ti-6Al-4V(ASTM F136 &ISO 5832-3)	Ti-6Al-4V(ASTM F136 &ISO 5832-3)
Securityfeatures	PEEKOPTIMA® LT1(ASTMF2026)	Ti-6Al-4V(ASTM F136 &ISO 5832-3)	Ti-6Al-4V(ASTM F136 &ISO 5832-3)	Ti-6Al-4V(ASTM F136 &ISO 5832-3)

Material composition is identical to other MEDICREA® INTERNATIONAL products that have been cleared via the 510(k) process.

7. Non-clinical Test Summary:

Testing was performed on the MEDICREA® Anterior Lumbosacral Plate system following the protocols outlined in ASTM F1717 "Standard Test Methods for Spinal Implant Constructs in a Vertebrectomy Model".

The following tests were conducted:

. Static axial Compression
. Static torsion
Dynamic compression .

8. Clinical Test Summary

No clinical studies were performed

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K121323

9. Conclusions Nonclinical and Clinical

MEDICREA® Anterior Lumbosacral Plate system is substantially equivalent to its predicate devices in terms of indications for use, design, material and function.

Ps 4 of 4

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three tail feathers, representing the department's commitment to health, services, and people. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES. USA" are arranged in a circular pattern around the eagle.

Public Health Service

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

Medicrea International % Ms. Laure Aviron-Violet Regulatory Affairs Manager 14 Porte du Grand Lyon Neyron France 01700

Re: K121323

Trade/Device Name: Anterior Lumbo-Sacral Plate Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: KWQ Dated: April 27, 2012 Received: May 02, 2012

Dear Ms. Aviron-Violet:

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

JUL 188 2012

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Page 2 - Ms. Laure Aviron-Violet

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/CDRHOffices/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,

Erin Keith

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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K121323

Statement of Indications for Use

510(k) Number (if known):

Device Name:

Lumbo-Sacral Plate

Indications for Use:

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate system is designed to be used at L5/S1 level. It is intended for use as anteriorly placed supplemental fixation device surgical approach below the great vessel bifurcation. The device is intended as a temporary fixation device until fusion is achieved.

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate system is intended for anterior lumbar spine at L5/S1 level, for the following indications:

Degenerative Disc Disease (DDD) at L5/S1 level. (DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies)

1. Pseudoarthrosis
1. Spondylolysis

Trauma (i.e., fracture or dislocation)

1. Spinal stenosis

Deformities and or curvatures (i.e., scoliosis, kyphosis, and/or lordosis)
Tumor
Failed previous fusion.

MEDICREA® INTERNATIONAL anterior lumbo-sacral plate is intended to be used with autograft and or allograft as an adjunct to fusion.

Patients should have at least six (6) months of non-operative treatment with an intervertebral cage and a lumbo-sacral plate for degenerative conditions.

Prescription Use Over-The-Counter Use AND/OR (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division Sign-Off) Bivision of Surgical, Orthopedic, and Restorative Devices

510(k) Number K121323

Regulation Number and Section

N/A