NOVEL SPINAL SPACER SYSTEM

K080699 · Alphatec Spine, Inc. · MQP · May 21, 2008 · Orthopedic

Device Facts

• Record ID: K080699
• Device Name: NOVEL SPINAL SPACER SYSTEM
• Applicant: Alphatec Spine, Inc.
• Product Code: MQP · Orthopedic
• Decision Date: May 21, 2008
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3060
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

Intervertebral Body Fusion The Novel® Spinal Spacer System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). These patients should have had six months of non-operative treatment. The Novel® Spinal Spacer System is to be used with a supplemental fixation system and autogenous bone graft. Vertebral Body Replacement The Novel® Spinal Spacer System is intended for use in the thoracolumbar spine (T1-L5) to replace a collapsed, damaged or unstable vertebral body due to tumor or trauma (i.e. fracture). The Novel® Spinal Spacer System is intended for use with supplemental spinal fixation system. Specifically the Novel® Spinal Spacer System is to be used with Alphatec Zodiac Polyaxial Spinal Fixation System or the Alphatec Mirage Top Tightening Spinal System. Furthermore the Novel® Spinal Spacer System is intended for use with allograft.

Device Story

Novel® Spinal Spacer System is an implantable orthopedic device; used for intervertebral body fusion or vertebral body replacement. Device consists of PEEK and titanium alloy components; available in various shapes/sizes to accommodate patient anatomy. Implanted by surgeons in clinical settings; requires use with supplemental spinal fixation systems (e.g., Alphatec Zodiac or Mirage systems) and bone graft (autogenous or allograft). Device provides structural support to the spine; facilitates fusion or replaces damaged vertebral bodies. Benefits include stabilization of the spinal column in patients with DDD, tumor, or trauma.

Clinical Evidence

Bench testing only.

Technological Characteristics

Materials: PEEK and titanium alloy. Form factor: various shapes and sizes for spinal implantation. Energy source: none (passive implant). Connectivity: none. Sterilization: not specified.

Indications for Use

Indicated for skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels (L2-S1) with/without Grade 1 spondylolisthesis/retrolisthesis, failing 6 months non-operative treatment; also indicated for thoracolumbar (T1-L5) vertebral body replacement due to tumor or trauma.

Regulatory Classification

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.

Reference Devices

• Alphatec Zodiac Polyaxial Spinal Fixation System
• Alphatec Mirage Top Tightening Spinal System

Submission Summary (Full Text)

{0}------------------------------------------------

## 510(k) SUMMARY

# MAY 2 1 2008

## Novel® Spinal Spacer System 510(k) SUMMARY March 2008

| Company: | Alphatec Spine, Inc.<br>2051 Palomar Airport Road #100<br>Carlsbad, CA 92011 USA<br>Direct: [phone]<br>Fax: [phone] |
|-------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Mary Stanners, Regulatory Affairs Specialist |
| Trade/Proprietary Name: | Novel® Spinal Spacer System |
| Common Name: | Vertebral Body Replacement Device<br>Intervertebral Body Fusion Device |
| Classification Name: | Spinal Intervertebral Body Fixation Orthosis<br>Intervertebral Body Fusion Device |
| Classification Number(s)/Product Code(s): | 21 CFR 888.3060 (MQP)<br>21 CFR 888.3080 (MAX) |

## Product Description:

The Novel® Spinal Spacer System is an implantable device manufactured from PEEK and titanium alloy that is available in a variety of different shapes and sizes to suit individual pathology and anatomical conditions of the patient.

## Indications for Use:

.

:

Intervertebral Body Fusion

The Novel® Spinal Spacer System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). These patients should have had six months of non-operative treatment. The Novel® Spinal Spacer System is to be used with a supplemental fixation system and autogenous bone graft.

Vertebral Body Replacement

The Novel® Spinal Spacer System is intended for use in the thoracolumbar spine (T1-L5) to replace a collapsed, damaged or unstable vertebral body due to tumor or trauma (i.e. fracture). The Novel® Spinal Spacer System is intended for use with supplemental spinal fixation

Page 1 of 2

{1}------------------------------------------------

system. Specifically the Novel® Spinal Spacer System is to be used with Alphatec Zodiac Polyaxial Spinal Fixation System or the Alphatec Mirage Top Tightening Spinal System. Furthermore the Novel® Spinal Spacer System is intended for use with allograft.

## Substantial Equivalence:

Data was provided which demonstrated the Novel® Spinal Spacer System to be substantially equivalent to previously cleared devices. The substantial equivalence is based upon equivalence in indications for use, design, material and function.

## Performance Data:

The test results demonstrate that the mechanical performance of the Novel® Spinal Spacer System is substantially equivalent to the predicate device.

{2}------------------------------------------------

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three stripes forming its body and wing. The eagle's head is facing to the left. Encircling the eagle is the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - (USA)" in a circular arrangement.

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

MAY 2 1 2008

Alphatec Spine, Inc. % Ms. Mary Stanners Regulatory Affairs Specialist 2051 Palomar Airport Road, #100 Carlsbad, CA 92011

K080699 Re:

> Trade/Device Name: Novel® Spinal Spacer System Regulation Number: 21 CFR 888.3080 Regulation Name: Intervertebral body fusion device Regulatory Class: Class II Product Code: MAX, MQP Dated: March 10, 2008 Received: March 12, 2008

Dear Ms. Stanners:

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.

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.

{3}------------------------------------------------

#### Page 2 - Ms. Mary Stanners

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 Center for Devices and Radiological Health's (CDRH's) Office of Compliance at [phone]. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at [phone]. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at [phone]. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at toll-free number [phone] or [phone] or the Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours.

Mark N. Willson

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{4}------------------------------------------------

#### INDICATIONS FOR USE

#### 510(k) Number (if known): K080699

## Device Name: Novel® Spinal Spacer System

#### Indications for Use:

#### Intervertebral Body Fusion

The Novel® Spinal Spacer System is indicated for spinal fusion procedures in skeletally mature patients with degenerative disc disease (DDD) at one or two contiguous levels from L2-S1. DDD is defined as discogenic back pain with degeneration of the disc confirmed by patient history and radiographic studies. These DDD patients may also have up to Grade 1 spondylolisthesis or retrolisthesis at the involved level(s). These patients should have had six months of non-operative treatment. The Novel® Spinal Spacer System is to be used with a supplemental fixation system and autogenous bone graft.

## Vertebral Body Replacement

The Novel® Spinal Spacer System is intended for use in the thoracolumbar spine (T1-I.5) to replace a collapsed, damaged or unstable vertebral body due to tumor or trauma (i.e. fracture). The Novel® Spinal Spacer System is intended for use with supplemental spinal fixation system. Specifically the Novel® Spinal Spacer System is to be used with Alphatec Zodiac Polyaxial Spinal Fixation System or the Alphatec Mirage Top Tightening Spinal System. Furthermore the Novel® Spinal Spacer System is intended for use with allograft.

Prescription Use X (Per 21 CFR 801.109)

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)

Neil R. Ogles for MKM

(Division Sign Division of General, Restorative, and Neurological Devices

510(k) Number K080699