K Number
K110362
Device Name
VANGUARD ASYMMETRICAL PATELLAR COMPONENT
Date Cleared
2011-02-28

(20 days)

Product Code
Regulation Number
888.3560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Vanguard® Asymmetrical Patella is intended for replacement of part of the knee joint in conjunction with a femoral and tibial component. 1. Painful and disabled knee joint resulting from osteoarthritis, rheumatoid arthritis traumatic arthritis where one or more compartments are involved; 2. Correction of varus, valgus, or posttraumatic deformity; 3. Correction or revision of unsuccessful osteotomy, arthrodesis, or failure of previous total joint replacement procedure. Femoral components and tibial tray components with porous coatings are indicated for cemented and un-cemented biological fixation application. Non-coated (Interlok) devices and all polyethylene patellar components are indicated for cemented application only.
Device Description
The Vanguard® Patellar Component is machined of polyethylene (UHMWPE) conforming to ASTM F-648.
More Information

K040770 Vanguard Patellar Components,K051977 Scorpio X3 UHMWPE Patellar Components

Not Found

No
The summary describes a physical implant (patellar component) made of polyethylene and focuses on its mechanical properties and equivalence to predicate devices. There is no mention of software, algorithms, image processing, or any terms related to AI/ML.

Yes.
The device is intended for replacement of a painful and disabled knee joint, correction of deformities, or revision of unsuccessful prior procedures, all of which aim to alleviate symptoms and restore function, classifying it as therapeutic.

No

This device is an orthopedic implant (a patellar component for knee replacement), which is a therapeutic device, not a diagnostic one. Its purpose is to replace part of a joint to treat conditions like osteoarthritis or deformities, not to diagnose them.

No

The device description explicitly states the device is machined of polyethylene (UHMWPE), indicating it is a physical implant, not software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly states the device is for "replacement of part of the knee joint". This is a surgical implant, not a test performed on a sample taken from the body to diagnose a condition.
  • Device Description: The device is described as a "Patellar Component" made of polyethylene, which is consistent with a physical implant.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), using reagents, or providing diagnostic information based on laboratory testing.

The device is a medical device, specifically a prosthetic implant for knee replacement surgery.

N/A

Intended Use / Indications for Use

The Vanguard® Asymmetrical Patella is intended for replacement of part of the knee joint in conjunction with a femoral and tibial component.

  1. Painful and disabled knee joint resulting from osteoarthritis, rheumatoid arthritis traumatic arthritis where one or more compartments are involved;

  2. Correction of varus, valgus, or posttraumatic deformity;

  3. Correction or revision of unsuccessful osteotomy, arthrodesis, or failure of previous total joint replacement procedure.

Femoral components and tibial tray components with porous coatings are indicated for cemented and un-cemented biological fixation application. Non-coated (interlok) devices and all polyethylene patellar components are indicated for cemented application only.

Product codes (comma separated list FDA assigned to the subject device)

JWH

Device Description

The Vanguard® Patellar Component is machined of polyethylene (UHMWPE) conforming to ASTM F-648.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

knee joint

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE
Performance Test Summary-New Device
The Vanguard® Asymmetrical Patellar component has the same technological characteristics as the predicate devices except for a slight modification to the general design as described in this 510(k) notification. A risk analysis was conducted along with an engineering rationale to demonstrate equivalence of the subject products to the predicate devices.

Comparative Performance Information Summary

CharacteristicRequirementNew DevicePredicate Device
Patellofemoral StabilityMeet or exceed parametersMeetK921182
Contact Area AnalysisMeet or exceed parametersMeetK921182
Peg Shear Area AnalysisMeet or exceed parametersMeetK040770

SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE AND/OR OF CLINICAL INFORMATION
Clinical Performance Data/Information: N/A

CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA
No clinical testing was necessary for a determination of substantial equivalence.

The results of mechanical testing indicated the devices performed within the intended use, did not raise any new safety and efficacy issues and were found to be substantially equivalent to the predicate devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K040770 Vanguard Patellar Components, K051977 Scorpio X3 UHMWPE Patellar Components

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 888.3560 Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis.

(a)
Identification. A knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a knee joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces. It has no linkage across-the-joint. This generic type of device includes prostheses that have a femoral component made of alloys, such as cobalt-chromium-molybdenum, and a tibial component or components and a retropatellar resurfacing component made of ultra-high molecular weight polyethylene. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).(b)
Classification. Class II.

0

K110362

FEB 2 8 2011

Image /page/0/Picture/2 description: The image shows the logo for Biomet Manufacturing Corp. The word "BIOMET" is in a stylized, blocky font with a small trademark symbol in the upper right corner. Below the logo, the words "MANUFACTURING CORP." are printed in a simple, sans-serif font.

21 CFR 807.92

Submitter Information
NameBiomet Manufacturing Corp.
Address56 East Bell Drive
Warsaw, IN 46581-0857
Phone number(574) 267-6639
Fax number(574) 371-1027
Establishment
Registration Number1825034
Name of contact
personTamara West
Date preparedFebruary 4, 2011
Name of device
Trade or proprietary
nameVanguard® Asymmetrical Patellar Component
Common or usual
nameKnee Prosthesis
Classification nameKnee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis (21CFR §888.3560)
Classification panelOrthopedic
Regulation21CFR §888.3560
Product Code(s)JWH
Legally marketed
device(s) to which
equivalence is claimedK040770 Vanguard Patellar Components
K051977 Scorpio X3 UHMWPE Patellar Components
Reason for 510(k)
submissionAddition of asymmetrical designed patella to the Vanguard® product line
Device descriptionThe Vanguard® Patellar Component is machined of polyethylene (UHMWPE) conforming to ASTM F-648.
Intended use of the
deviceThe Vanguard® Asymmetrical Patellar is intended for replacement of part of the knee joint in conjunction with a femoral and tibial component.
Indications for use1. Painful and disabled knee joint resulting from osteoarthritis, rheumatoid arthritis traumatic arthritis where one or more compartments are involved.
  1. Box 56

p. 1 of 3

1

KII0362

BIOMET®

MANUFACTURING CORP.

  1. Correction of varus, valqus, or posttraumatic deformity: 3. Correction or revision of unsuccessful osteotomy, arthrodesis, or failure of previous total joint replacement procedure.

Femoral components and tibial tray components with porous coatings are indicated for cemented and un-cemented biological fixation application. Non-coated (Interlok(8) devices and all polyethylene patellar components are indicated for cemented application only.

Summary of the technological characteristics of the device compared to the predicate

CharacteristicNew DevicePredicate
DesignAsymmetrical or medialized
domeK051977 & K040770
MaterialUHMWPEK040770
Principal of operationPrimary replacement of a
total knee jointK040770
Dimensions25, 28 & 31 x 8 mm
34 x 8.5 mm
37 & 40 x 10 mmK040770

PERFORMANCE DATA

SUMMARY OF NON-CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE

Performance Test Summary-New Device

The Vanguard® Asymmetrical Patellar component has the same technological characteristics as the predicate devices except for a slight modification to the general design as described in this 510(k) notification. A risk analysis was conducted along with an engineering rationale to demonstrate equivalence of the subject products to the predicate devices.

Comparative Performance Information Summary

CharacteristicRequirementNew DevicePredicate Device
Patellofemoral
StabilityMeet or exceed parametersMeetK921182
Contact Area
AnalysisMeet or exceed parametersMeetK921182
Peg Shear Area
AnalysisMeet or exceed parametersMeetK040770

PO Box 587
Warsaw. IN 46081-0557
Toll Free: 800.348.9500
Oficer 574 257,683
Main F74.2878137
wwww.bmet.an

. 2 of 3

2

Image /page/2/Picture/0 description: The image shows the logo for Biomet Manufacturing Corp. The logo consists of the word "BIOMET" in a stylized font, with the words "MANUFACTURING CORP." printed below. The font is blocky and sans-serif, and the letters are outlined in black.

SUMMARY OF CLINICAL TESTS CONDUCTED FOR DETERMINATION OF SUBSTANTIAL EQUIVALENCE AND/OR OF CLINICAL INFORMATION

Clinical Performance Data/Information: N/A

CONCLUSIONS DRAWN FROM NON-CLINICAL AND CLINICAL DATA

No clinical testing was necessary for a determination of substantial equivalence.

The results of mechanical testing indicated the devices performed within the intended use, did not raise any new safety and efficacy issues and were found to be substantially equivalent to the predicate devices.

PO Box 587

Warsaw, IN 46081-000?
Toll Free: 800 348.9000
Offor: 574 257.6833
Main Fax: 574.287.8137
www.comet.axn

p. 3 of 3

3

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized eagle-like symbol with three wing-like shapes above a wavy base, all rendered in black.

Public Health Service

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

Biomet Inc. % Ms. Tamara West Senior Regulatory Affairs Specialist 56 East Bell Drive, POB 587 Warsaw, Indiana 46581-0587

FEB 2 8 201

Re: K110362

Trade/Device Name: Vanguard® Asymmetrical Patellar components Regulation Number: 21 CFR 888.3560 Regulation Name: Knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: JWH Dated: February 04, 2011

Received: February 08, 2011

Dear Ms. West:

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

4

Page 2 - Ms. Tamara West

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 (OS) 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/CDRH0ffices/ycm115809.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,

yours,

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

Enclosure

5

Indications for Use

510(k) Number (if known):_ k1/0362

Device Name: Vanguard® Asymmetrical Patella

Indications For Use:

The Vanguard® Asymmetrical Patella is intended for replacement of part of the knee joint in conjunction with a femoral and tibial component.

  1. Painful and disabled knee joint resulting from osteoarthritis, rheumatoid arthritis traumatic arthritis where one or more compartments are involved;

  2. Correction of varus, valgus, or posttraumatic deformity;

  3. Correction or revision of unsuccessful osteotomy, arthrodesis, or failure of previous total joint replacement procedure.

Femoral components and tibial tray components with porous coatings are indicated for cemented and un-cemented biological fixation application. Non-coated (interlok) devices and all polyethylene patellar components are indicated for cemented application only.

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

Over-The-Counter Use no (21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

M. Melker

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

Page 1 of 1

510(k) Number K110362