K Number
K121765
Device Name
SCULPTOR ROBOTIC GUIDANCE ARM (RGA)
Date Cleared
2013-01-11

(210 days)

Product Code
Regulation Number
882.4560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Sculptor Robotic Guidance Arm (RGA) is intended to assist the surgeon in providing software-defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures. The Sculptor RGA is indicated for use in unicompartmental knee replacement, in which the use of stereotactic surgery may be appropriate, and where reference to rigid anatomical bony structures can be identified relative to a CT-based model of the anatomy.
Device Description
Stanmore Implants Sculptor RGA utilizes a robotic arm to limit the surgeon's operation of a milling (cutting) tool to a safe area and a tracking arm to determine and monitor the location of the patient, providing dynamic referencing relative to the position of the robotic arm and the surgical plan; the device allows the surgeon to remove bone corresponding to the implant's shape as determined pre/intra operatively.
More Information

Not Found

No
The summary describes a robotic guidance arm that uses software-defined spatial boundaries and tracking for navigation and bone preparation based on a CT model. There is no mention of AI, ML, or image processing that would suggest the use of these technologies for tasks like image analysis, decision support, or autonomous operation beyond pre-defined boundaries. The focus is on robotic assistance and navigation based on pre-operative planning and real-time tracking.

No.
The device is a surgical guidance system that assists the surgeon during orthopedic procedures by providing spatial boundaries for orientation and reference information. It does not directly treat or prevent a disease, but rather aids in the precise execution of a surgical procedure.

No

The device is described as assisting the surgeon in providing spatial boundaries and performing precise bone removal during orthopedic procedures, not in diagnosing a medical condition.

No

The device description explicitly states it utilizes a "robotic arm" and a "tracking arm," which are hardware components. The summary also mentions "Electromagnetic Compatibility and Electrical Safety testing," which are typically performed on hardware.

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • Sculptor RGA Function: The Sculptor RGA is a robotic guidance arm used during orthopedic surgery to assist the surgeon in preparing bone based on a pre-operative CT scan. It interacts directly with the patient's anatomy during the procedure, not with a specimen taken from the body.
  • Intended Use: The intended use clearly states it's for assisting the surgeon during orthopedic procedures by providing spatial boundaries and reference information to anatomical structures.
  • Device Description: The description details its use of a robotic arm to limit a cutting tool and a tracking arm to monitor patient location, all within the context of a surgical procedure.

The device is a surgical guidance system, not a diagnostic tool that analyzes biological samples.

N/A

Intended Use / Indications for Use

The Sculptor Robotic Guidance Arm (RGA) is intended to assist the surgeon in providing software-defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures.

The Sculptor RGA is indicated for use in unicompartmental knee replacement, in which the use of stereotactic surgery may be appropriate, and where reference to rigid anatomical bony structures can be identified relative to a CT-based model of the anatomy.

Product codes

OLO

Device Description

Stanmore Implants Sculptor RGA utilizes a robotic arm to limit the surgeon's operation of a milling (cutting) tool to a safe area and a tracking arm to determine and monitor the location of the patient, providing dynamic referencing relative to the position of the robotic arm and the surgical plan; the device allows the surgeon to remove bone corresponding to the implant's shape as determined pre/intra operatively.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

CT

Anatomical Site

Knee (femur, tibia)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Surgeon, Orthopedic procedures

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

Non Clinical Testing included FDA recommended Electromagnetic Compatibility and Electrical Safety testing, and verification and validation testing for a software controlled device. Verification testing was performed to verify the Sculptor RGA registration process, software flow, and device safety. This included: Touch screen calibration, Software and hardware setup and shutdown procedures, Individual hardware component function (e.g., Sculptor Arm, Tracking Arm), Correct interoperation of components, Registration procedures, Bone sculpting function and boundary data integrity, Software thresholding, segmentation, data import, 3D model creation, joint and implant selection, landmarking, frames of reference, planning, workflow, patient file management, data integrity and backup, and CD burning, System run-through. System level verification and validation testing was performed in the laboratory using Sawbone models to evaluate setup, registration, and overall accuracy and functionality of the system in supporting unicondylar knee replacement.

Clinical Case Series: A prospective, single site, clinical case series of 35 patients (36 knees) undergoing primary unicompartmental knee arthroplasty with a diagnosis of osteoarthritis. The study evaluated the ability of the Sculptor RGA to prepare the tibia and femur for accurate positioning of the components of a unicompartmental knee system. The study included a radiographic assessment of implant placement, Oxford Knee Score outcomes, and quality of life assessment. Assessments of lateral and A/P radiographs were performed by two orthopedic surgeons. Their analyses confirmed that the Sculptor accurately prepares the bone for unicompartmental knee replacement and validate the system's intended use.

Key Metrics

Not Found

Predicate Device(s)

K093425

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.4560 Stereotaxic instrument.

(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(b)
Classification. Class II (performance standards).

0

510(k) Summary

.

· ・・・・

JAN 1 1 2013

Preparation Date9 January 2013
Applicant/SponsorStanmore Implants Worldwide Ltd
210 Centennial Avenue
Centennial Park
Elstree
WD6 3SJ
Phone: +44 (0) 20 8238 6503
Facsimile: +44 (0) 20 8954 0351
Contact Person:Jon Charters
Director of Regulatory affairs
Stanmore Implants Worldwide Ltd.
+44 (0) 20 8238-6500
Prepared by:Musculoskeletal Clinical Regulatory Advisers, LLC
1331 H Street, NW, 12th Floor
Washington, DC 2005
202.552.5800 (phone)
202.552.5789 (fax)
Trade Name:Sculptor Robotic Guidance Arm (RGA)
Common Name:Orthopedic Stereotaxic Instrument
Classification:21 CFR 882.4560
ClassII
Product CodeOLO
Indications for UseThe Sculptor Robotic Guidance Arm (RGA) is intended to assist the
surgeon in providing software-defined spatial boundaries
for
orientation and reference information to anatomical structures during
orthopedic procedures.

The Sculptor RGA is indicated for use in unicompartmental knee
replacement, in which the use of stereotactic surgery may be
appropriate, and where reference to rigid anatomical bony structures
can be identified relative to a CT-based model of the anatomy. |
| Device Description: | Stanmore Implants Sculptor RGA utilizes a robotic arm to limit the
surgeon's operation of a milling (cutting) tool to a safe area and a
tracking arm to determine and monitor the location of the patient,
providing dynamic referencing relative to the position of the robotic
arm and the surgical plan; the device allows the surgeon to remove
bone corresponding to the implant's shape as determined pre/intra operatively. |

1

Predicate Devices

Technological Characteristics Compared to Predicate Device The Sculptor RGA is substantially equivalent to MAKO Surgical's Robotic Arm Interactive Orthopaedic System (K093425).

| Technological
Characteristics | Stanmore Sculptor
RGA | MAKO Surgical
RIO (K093425) |
|----------------------------------|------------------------------------------------------------------------|----------------------------------------------------------------|
| Major Components | Robotic arm,
tracking arm, drill
system, Touch
Screen Monitor | Guidance module,
robotic arm, camera
stand, drill system |
| Tools/Accessories | Cutting tools
Bone interlock for
tracking | Various probes,
arrays tracked by
optical camera |
| Images Used | CT | CT |

Performance Data:

Non Clinical Testing

Performance testing of the Sculptor RGA included the FDA recommended Electromagnetic Compatibility and Electrical Safety testing, and verification and validation testing for a software controlled device. Verification testing was performed to verify the Sculptor RGA registration process, software flow, and device safety. The following activities were verified:

  • Touch screen calibration t
  • . Software and hardware setup and shutdown procedures
  • Individual hardware component function (e.g., Sculptor Arm, . Tracking Arm)
  • · Correct interoperation of components
  • Registration procedures .
  • Bone sculpting function and boundary data integrity .
  • . Software thresholding, segmentation, data import, 3D model creation, joint and implant selection, landmarking, frames of reference, planning, workflow, patient file management, data integrity and backup, and CD burning
  • System run-through .

System level verification and validation testing was performed in the laboratory using Sawbone models to evaluate setup, registration, and overall accuracy and functionality of the system in supporting unicondylar knee replacement.

Clinical Case Series

Results from a prospective, single site, clinical case series of patients undergoing primary unicompartmental knee arthroplasty with a diagnosis of osteoarthritis demonstrate the ability of the Sculptor RGA to prepare the tibia and femur for accurate positioning of the components of a unicompartmental knee system. The case series involved 35 patients (36 knees) and included a radiographic assessment of implant placement. Oxford Knee Score outcomes, and quality of life assessment.

2

Assessments of lateral and A/P radiographs were performed by two orthopedic surgeons. Their analyses confirmed that the Sculptor accurately prepares the bone for unicompartmental knee replacement and validate the system's intended use.

Testing performed on this device indicates that the Sculptor RGA is Substantial substantially equivalent to the predicate device. Performance testing Equivalence: of the Sculptor RGA included the FDA recommended verification and validation testing. System level verification and validation testing was performed in the laboratory using Sawbone models to evaluate setup, registration, and overall accuracy and functionality of the system in supporting unicondylar knee replacement. A prospective, single arm clinical study conducted in the United Kingdom demonstrated good radiographic outcomes with respect to implant placement when the Sculptor RGA was used to prepare the bone for implantation.

The Sculptor RGA is shown to be substantially equivalent to Conclusion previously cleared devices with respect to its intended use, indications for use, technological characteristics, and performance characteristics.

3

Image /page/3/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the logo is a stylized image of what appears to be a caduceus, a symbol often associated with healthcare.

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

Stanmore Implants Worldwide, Limited % Musculoskeletal Clinical Regular Advisers, LLC Ms. Hollace Saas Rhodes 1331 H. Street Northwest, 12th Floor Washington. District of Columbia 20005

Re: K121765

Trade/Device Name: Sculptor Robotic Guidance Arm (RGA) Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic instrument Regulatory Class: Class II Product Code: OLO Dated: December 21, 2012 Received: December 26, 2012

Dear Ms. Rhodes:

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

January 11, 2013

4

Page 2 - Ms. Hollace Saas Rhodes

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,

Peter D.,Rumm -S

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

Enclosure

5

INDICATIONS FOR USE STATEMENT

510(k) Number (if known): K121765

Device Name: Sculptor Robotic Guidance Arm (RGA)

Indications for Use:

The Sculptor Robotic Guidance Arm (RGA) is intended to assist the surgeon in providing software-defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures.

The Sculptor RGA is indicated for use in unicompartmental knee replacement, in which the use of stereotactic surgery may be appropriate, and where reference to rigid anatomical bony structures can be identified relative to a CT-based model of the anatomy.

Prescription Use_ X

AND/ OR

Over-The-Counter Use

(Per 21 CFR 801 Subpart D)

(Per 21 CFR 801 Subpart C)

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Dwight Yen 2013.01.11 11:03:00 -05'00'

(Division Sign-Off) Division of Surgical Devices 510(k) Number: K121765