MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix are to be combined with autogenous bone marrow and are indicated for bony voids or gaps that are not intrinsic to the stability of the bony structure and can be used as a bone graft extender.

The device is to be gently packed into bony voids or gaps of the skeletal system (i.e., the posterolateral spine, pelvis, ilium, and/or extremities). These defects may be surgically created osseous defects or osseous defects created from traumatic injury to the bone. The device resorbs and is replaced with bone during the healing process.

Device Description

MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix consist of a combination of medical grade purified collagen of bovine origin and biphasic calcium phosphate ceramic. In the MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix devices, the collagen is a highly purified (>95%) Type I bioresorbable Iyophilized collagen. The biphasic ceramic portion of MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix is provided in a 15 percent hydroxyapatite and 85 percent B-tricalcium phosphate formulation.

MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix are supplied sterile in a premixed strip form for single patient use.

MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix devices are biocompatible, osteoconductive, porous implants that allow for bony ingrowth across the graft site while resorbing at a rate consistent with bone healing. The devices readily absorbs bone marrow aspirate and had been shown to heal bone defects.

The purpose of this Special 510(k) application is to add additional sizes (known as MASTERGRAFT® UltraMatrix 5cc, 10cc, and 20cc) to the previously cleared MASTERGRAFT® Strip product family. The sizes proposed in this Special 510(k) were part of the original product design for MASTERGRAFT® Strip device, and were included in the design verification and validation activities reported in K082166.

AI/ML Overview

The provided text is a 510(k) Summary for a medical device (MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix), which focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study with specific acceptance criteria and performance metrics in the way one would for a novel device or AI.

The core of this document is a comparison to a previously cleared predicate device (MASTERGRAFT® Strip, K082166). The "study" here is essentially the non-clinical testing performed to show that the new device sizes (MASTERGRAFT® UltraMatrix 5cc, 10cc, and 20cc) are "substantially equivalent" to an existing, cleared device. This means the acceptance criteria are largely based on meeting recognized consensus standards for medical device materials, biocompatibility, and manufacturing, and showing that the new device has the same technological characteristics and performance as the predicate.

Here's an breakdown based on the information provided, keeping in mind the context of a 510(k) for a substantially equivalent device:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria Category	Specific Criteria / Standard	Reported Device Performance (vs. Predicate)
Indications for Use	Identical to K082166	Identical
Fundamental Scientific Technology	Identical to K082166 (Operating Principle, Mechanism of Action)	Identical
Basic Design	Identical to K082166	Identical
Performance	Equivalent to K082166	Identical
Manufacturing Principles	Identical to K082166	Identical
Sterilization	Identical to K082166	Identical
Shelf-Life	Identical to K082166	Identical
Packaging	Identical to K082166	Identical
Material Composition	Identical to K082166 (Collagen, Biphasic Calcium Phosphate Granules)	Identical
Need for Rigid Fixation	Identical to K082166	Identical
Safety and Effectiveness Profile	Identical to K082166	Identical
Biocompatibility	Conformance to ISO 10993 series (Parts 3, 4, 5, 6, 10, 11, 12)	Demonstrated conformance in predicate K082166; new device sizes are identical in material and processing.
Material Composition (Specific)	Conformance to ASTM F1185-03 (Hydroxyapatite) & ASTM F1088-04a (ß-tricalcium Phosphate)	Demonstrated conformance in predicate K082166; new device sizes are identical in material.
Animal Tissue Management	Conformance to ISO 22442 series (Parts 1, 2, 3)	Demonstrated conformance in predicate K082166; new device sizes are identical in material.
Device Size (Minor Variation)	New proposed sizes within product family (5cc, 10cc, 20cc) as part of original design verification/validation of predicate	Reported new sizes: 5cc (L: 4.7cm, W: 1.0cm, T: 1.1cm), 10cc (2x 5cc), 20cc (L: 4.7cm, W: 1.9cm, T: 1.1cm)

2. Sample Size for Test Set and Data Provenance

The document explicitly states: "The sizes proposed in this Special 510(k) were part of the original product design for MASTERGRAFT® Strip device, and were included in the design verification and validation activities reported in K082166." This indicates that the supporting data comes from the initial clearance of the predicate device (K082166). The document does not specify exact sample sizes for each non-clinical test mentioned, nor does it specify the country of origin of the data or if it was retrospective or prospective, beyond stating it was "non-clinical testing."

3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications

Not applicable in the context of this 510(k). This submission relies on non-clinical (laboratory/material) testing and comparison to a predicate device, not expert human assessment of diagnostic images or clinical outcomes that would require ground truth established by experts.

4. Adjudication Method for the Test Set

Not applicable. The testing described is non-clinical (material characterization, biocompatibility, etc.) and does not involve human adjudication of results in the way a diagnostic study would.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size

No. This document does not describe an MRMC study. The device is a bone void filler, not an imaging or diagnostic AI device that would typically undergo such a study.

6. If a Standalone (Algorithm Only Without Human-in-the-Loop) Performance Was Done

Not applicable. The product is a physical bone void filler, not a software algorithm.

7. The Type of Ground Truth Used

The "ground truth" here is the established scientific and regulatory standards for medical device materials, biocompatibility, and performance, as well as the performance and characteristics of the legally marketed predicate device. This is primarily based on:

Expert Consensus Standards: such as ASTM and ISO standards listed (e.g., ISO 10993 for biocompatibility, ASTM for material composition).
Predicate Device Performance: The "truth" is that the new sizes of the device are identical in all critical aspects and therefore perform equivalently to the predicate (K082166), which has already been found safe and effective.

8. The Sample Size for the Training Set

Not applicable. This device does not involve a "training set" in the context of machine learning or AI.

9. How the Ground Truth for the Training Set Was Established

Not applicable for the same reason as point 8.

Summary

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30335 SE I OF 5

APR 1 9 2013

510(K) Summary

I. SUBMITTER NAME & ADDRESSS:	Medtronic Sofamor Danek1800 Pyramid PlaceMemphis, Tennessee
-------------------------------	---------------------------------------------------------------------

CONTACT PERSON:

DATE PREPARED:

mor Danek USA, Inc lace Memphis, Tennessee 38132 Telephone: (901) 396-3133 -Fax: (901) 346-9738 Establishment Registration: 1030489 Ryan Massey · Principal Regulatory Affairs Specialist February 8, 2013

II. PROPOSED PROPRIETARY TRADE NAME: MASTERGRAFT® Strip MASTERGRAFT® UltraMatrix

DEVICE CLASSIFICATION NAME: Resorbable Calcium Salt Bone Void Filler REGULATION NUMBER: 21 CFR 888.3045 CLASSIFICATION PRODUCT CODE: MQV CLASS: I I

III. IDENTIFICATION OF LEGALLY MARKETED DEVICES: MASTERGRAFT® Strip K082166 (S.E. 06/02/2009)

IV. DEVICE DESCRIPTION:

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biphasic ceramic portion of MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix is provided in a 15 percent hydroxyapatite and 85 percent B-tricalcium phosphate formulation.

MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix are supplied sterile in a premixed strip form for single patient use.

V. INDICATIONS FOR USE:

MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix are to be combined with autogenous bone marrow and is indicated for bony voids or gaps that are not intrinsic to the stability of the bony structure and can be used as a bone graft extender.

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VI. SUMMARY OF THE TECHNOLOGICAL CHARACTERISTICS:

Comparison Feature	SubjectMASTERGRAFT®UltraMatrix	PredicateMASTERGRAFT® Strip
Indication for Use	Identical	K082166 (S.E. 06/02/2009)
Fundamental ScientificTechnology• Operating Principle• Mechanism of Action	Identical	K082166 (S.E. 06/02/2009)
Basic Design	Identical	K082166 (S.E. 06/02/2009)
Performance	Identical	K082166 (S.E. 06/02/2009)
Manufacturing principles	Identical	K082166 (S.E. 06/02/2009)
Sterilization	Identical	K082166 (S.E. 06/02/2009)
Shelf-Life	Identical	K082166 (S.E. 06/02/2009)
Packaging	Identical	K082166 (S.E. 06/02/2009)
Material Composition• Collagen• Granules	Identical	K082166 (S.E. 06/02/2009)
Use of rigid fixation	Identical	K082166 (S.E. 06/02/2009)
Safety and Effectivenessprofile	Identical	K082166 (S.E. 06/02/2009)
Size	5cc ProductLength: 4.7 cm ± 0.5 cmWidth: 1.0 cm ±0.3 cmThickness: 1.1 cm ±0.3cm	12cc ProductLength: 10.0cm +/- 0.5cmWidth: 2.0cm +/- 0.3cmThickness: 0.6cm +/-0.2cm
	10cc Product (2 x 5cc)Length: 4.7 cm ± 0.5 cmWidth: 1.0 cm ± 0.3 cmThickness: 1.1 cm ± 0.3cm
	20cc ProductLength: 4.7 cm ± 0.5 cmWidth: 1.9 cm ± 0.4 cmThickness: 1.1 cm ±0.3 cm	43cc ProductLength: 36.0cm +/- 1.0cmWidth: 2.0cm +/- 0.3cmThickness: 0.6cm +/-0.2cm

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K 20335 AGE 4 OF 5

VII. DISCUSSION OF NON-CLINICAL TESTING:

Non-clinical testing was performed in accordance with FDA Recognized Consensus Standards and FDA Guidelines wherever they are applicable. Data to support these rationales are provided to demonstrate that the subject devices are substantially equivalent to the predicate device.
Previously submitted non-clinical testing was performed in accordance with the following standards:
ASTM F1185-03: 2009, Specification for Composition of Ceramic . Hydroxyapatite for Surgical Implants
. ASTM F1088-04a: 2010, Specification for ß-tricalcium Phosphate for Surgical Implantation
. ISO 22442-1: Animal Tissues and Their Derivatives Utilized in the Manufacture of Medical Devices -- Part 1 Analysis and Risk Management
ISO 22442-2: Animal Tissues and Their Derivatives Utilized in the Manufacture . of Medical Devices -- Part 2 Controls on Sourcing, Collection, and Handling
. ISO 22442-3: Animal Tissues and Their Derivatives Utilized in the Manufacture of Medical Devices -- Part 3 Validation of the Elimination and/or Inactivation of Virus and Transmissible Agents
ISO 10993-3: 2003/(R) 2009, Biological evaluation of medical devices -- Part 3 . Tests for genotoxicity, carcinogenicity, and reproductive toxicity. (Biocompatibility)
ISO10993-4: 2009, Biological evaluation of medical devices -- Part 4: Selection . of tests for interactions with blood
. ISO 10993-5: 2009, Biological evaluation of medical devices -- Part 5: Tests for In Vitro cytotoxicity. (Biocompatibility)
ISO 10993-6: 2007, Biological evaluation of medical devices -- Part 6: Tests for . local effects after implantation. (Biocompatibility)

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ISO 10993-10: 2010, Biological evaluation of medical devices -- Part 10: Tests for . irritation and skin sensitization. (Biocompatibility)
ISO 10993-11: 2006, Biological evaluation of medical devices -- Part 11: Tests for . systemic toxicity. (Biocompatibility)
ISO 10993-12: 2008, Biological evaluation of medical devices -- Part 12: Sample . preparation and reference materials. (Biocompatibility)

VIII. CONCLUSION:

Documentation provided in this submission demonstrates that the subject device is substantially equivalent to the previously cleared bone void filler MASTERGRAFT® Strip (K082166, SE 06/02/2009).

The subject device is substantially equivalent to predicate MASTERGRAFT® Strip in several categories including: indication, material composition (including biphasic calcium phosphate granules and collagen), biodegradability, shelf-life, need for rigid fixation, biocompatibility and the ability to resorb during the healing process.

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Image /page/5/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three tail feathers, representing the department's commitment to health, human services, and well-being. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular fashion around the eagle symbol.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

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

Medtronic Sofamor Danek USA, Incorporated % Mr. Ryan Massey Principal Regulatory Affairs Specialist 1800 Pyramid Place Memphis, Tennessee 38132

Letter dated: April 19, 2013

Re: K130335

Trade/Device Name: MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix Regulation Number: 21 CFR 888.3045 Regulation Name: Resorbable calcium salt bone void filler device Regulatory Class: Class II Product Code: MQV Dated: March 20, 2013 Received: March 22, 2013

Dear Mr. Massey:

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. Ryan Massev

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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Mark Nighterson -S

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

Enclosure

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510(k) Number (if known):

Device Name: MASTERGRAFT® Strip and MASTERGRAFT® UltraMatrix

Indications for Use:

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use

(21 CFR 807 Subpart C)

Laurence D. Coyne -A

(Division Sign-Off) Division of Orthopedic Devices 510(k) Number: K130335

Regulation Number and Section

§ 888.3045 Resorbable calcium salt bone void filler device.

(a)
Identification. A resorbable calcium salt bone void filler device is a resorbable implant intended to fill bony voids or gaps of the extremities, spine, and pelvis that are caused by trauma or surgery and are not intrinsic to the stability of the bony structure.(b)
Classification. Class II (special controls). The special control for this device is the FDA guidance document entitled “Class II Special Controls Guidance: Resorbable Calcium Salt Bone Void Filler Device; Guidance for Industry and FDA.” See § 888.1(e) of this chapter for the availability of this guidance.