The Reliance Anterior Cervical Plate System is indicated for stabilization of the anterior cervical spine from C2 to C7 employing unicortical screw fixation at the anterior face of the vertebral bodies. Specific clinical indications for anterior plating include:

instability caused by trauma or fracture; .
instability associated with correction of cervical lordosis and kyphosis deformity; ●
. instability associated with pseudoarthosis as a result of previously failed cervical spine surgery;
instability associated with major reconstructive surgery for primary tumors or metastatic . malignant tumors of the cervical spine;
instability associated with single or multiple level corpectomy in advanced degenerative . · disk disease (defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies), spinal canal stenosis and cervical myelopathy.

This device is not approved for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic, or lumbar spine.

Device Description

The Reliance Anterior Cervical Plate System device is intended to be used as an anterior cervical plate device. The Reliance Anterior Cervical Plate System is comprised of implant and instrument components. The Reliance Anterior Cervical Plate implant device is manufactured from Titanium alloy as specified by ASTM F-136. The Reliance Anterior Cervical Plate is a combination of the plate, cover plate, set screw, and bone screw components. The cover plate is attached to the plate by means of the set screw.

AI/ML Overview

1. Acceptance Criteria and Reported Device Performance:

Acceptance Criteria (Study Type)	Reported Device Performance
Static Compression Bending (ASTM F-1717)	Substantially equivalent to predicate devices
Static Torsion (ASTM F-1717)	Substantially equivalent to predicate devices
Dynamic Compression Bending (ASTM F-1717)	Substantially equivalent to predicate devices
Sterilization	Substantially equivalent to predicate devices
Biocompatibility	Substantially equivalent to predicate devices

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

The provided document describes mechanical and other non-clinical performance testing. It does not mention a "test set" in the context of clinical data, human subjects, or data provenance from specific regions. The testing was conducted on samples of the Reliance Anterior Cervical Plate System itself.

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):

Not applicable. This was a non-clinical performance study involving mechanical testing and assessments of material properties, not a study requiring expert clinical review to establish ground truth.

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

Not applicable. Adjudication methods are relevant for clinical studies where expert consensus is needed to establish ground truth. This document describes non-clinical performance testing.

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:

Not applicable. This device is a spinal implant, not an AI-assisted diagnostic or imaging device, so an MRMC study is not relevant.

6. 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.

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

The "ground truth" for this performance study was established through standardized mechanical testing protocols (ASTM F-1717) and assessments of material properties (sterilization, biocompatibility). The comparison was made against the performance of legally marketed predicate devices.

8. The sample size for the training set:

Not applicable. This document describes non-clinical performance testing of a physical device, not a machine learning model that requires a training set.

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

Not applicable, as no training set for a machine learning model was used.

Summary

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K122216 Page 115

SEP 5 2012

510(k) Summary

21 August 2012

Reliance Medical Systems, LLC 545 West 500 South. Suite 100 Bountiful, UT 84010 Telephone: 801-295-3280 Fax: 801-294-0079

Contact: Bret M. Berry Member-Manager

510(k) Number: Common or Usual Name: Proposed Proprietary or Trade Name: Classification Name: Regulation Number: Product Code:

Anterior Cervical Plate Reliance Anterior Cervical Plate System Spinal Intervertebral Body Fixation Orthosis 21 CFR 888.3060 KWQ .

Substantial Equivalence

The Reliance Anterior Cervical Plate is substantially equivalent to the legally marketed Synthes Anterior Cervical Vertebral Plate (K030866, K945700), the Interpore Cross C-Tek (K042798), the Altiva cerView ACP (K070891), the Blackstone Hallmark Anterior Cervical Plate System (K100614), Pioneer PAC Anterior Cervical Plate (K083663), X-Spine Spider Plate (K052292), and the Aesculap Caspar Plate (K953720). The Reliance Anterior Cervical Plate is equivalent to these commercially available devices in terms of material, intended use, levels of attachment, size range, and strength.

Device Description

Intended Use/Indications for Use

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K122216 Page 2/7

instability caused by trauma or fracture; .
instability associated with correction of cervical lordosis and kyphosis deformity; ●
. instability associated with pseudoarthosis as a result of previously failed cervical spine surgery;
instability associated with major reconstructive surgery for primary tumors or metastatic . malignant tumors of the cervical spine;
instability associated with single or multiple level corpectomy in advanced degenerative . · disk disease (defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies), spinal canal stenosis and cervical myelopathy.

This device is not approved for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic, or lumbar spine.

Performance Data and Substantial Equivalence

Mechanical testing was performed on the Reliance Anterior Cervical Plate System following ASTM F-1717 (static compression bending, static torsion, and dynamic compression bending). The Reliance Anterior Cervical Plate System was found to be substantially equivalent to the predicate devices. Additionally, the Reliance Cervical Plate System is substantially equivalent to the predicate devices in terms of sterilization and biocompatibility.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized symbol resembling an eagle or bird in flight, composed of three curved lines. To the left of the symbol, there is a circular arrangement of text that reads "DEPARTMENT OF HEALTH & HUMAN SERVICES USA".

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

Reliance Medical Systems, LLC % Mr. Bret M. Berry Member-Manager 545 West 500 South, Suite 100 Bountiful, Utah 84010

SEP 5 2012

Re: K122216

Trade/Device Name: Reliance Anterior Cervical Plate System Regulation Number: 21 CFR 888.3060 Regulation Name: Spinal intervertebral body fixation orthosis Regulatory Class: Class II Product Code: KWQ Dated: July 24, 2012 Received: July 25, 2012

Dear Mr. Berry:

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 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

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Page 2 - Mr. Bret M. Berry

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,

Mark N. Molkerson

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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Indications for Use

510(k) Number (if known): K122216

Device Name: Reliance Anterior Cervical Plate System

Indications for Use:

. instability caused by trauma or fracture;
instability associated with correction of cervical lordosis and kyphosis deformity; .
instability associated with pseudoarthosis as a result of previously failed cervical spine . surgery;
instability associated with major reconstructive surgery for primary turnors or metastatic . malignant tumors of the cervical spine;
instability associated with single or multiple level corpectomy in advanced degenerative . disk disease (defined as discogenic pain with degeneration of the disc confirmed by history and radiographic studies), spinal canal stenosis and cervical myelopathy.

This device is not approved for screw attachment or fixation to the posterior elements (pedicles) of the cervical, thoracic, or lumbar spine.

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use _ (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)

Carol-Rti-

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

510(k) Number K122216

Page 1 of 1

Regulation Number and Section

N/A