K Number
K143552
Manufacturer
Date Cleared
2015-03-04

(79 days)

Product Code
Regulation Number
888.3660
Reference & Predicate Devices
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Simpliciti™ Shoulder System is indicated for severely painful and/or disabled joint resulting from osteoarthritis or traumatic arthritis.

The metaphyseal humeral stems are indicated for press-fit, un-cemented use.

The glenoid components are indicated for cemented use only and are indicated only for use with bone cement.

This device is for single use.

Device Description

The Simpliciti™ Shoulder System is intended for use in Total Shoulder Arthroplasty of the shoulder (TSA) application. As a Total shoulder, the system consists of a metaphyseal metal humeral component, a metal humeral head and an ultrahigh molecular weight polyethylene glenoid. Glenoid components are labeled "for cemented use only" and are indicated only for use with bone cement. The metaphyseal humeral components are indicated and labeled for press-fit un-cemented use.

The materials used in the manufacture of the Simpliciti™ Shoulder System implants are as follows:

  • Metaphyseal humeral component is made of titanium alloy (Ti-6AL-4V) in accordance to ASTM standard F136 with a sintered titanium (CP Ti) bead coating conforming to ASTM F-1580.
  • . The humeral heads are made off cobalt-chromium- alloy (CoCr) according to ASTM standard F1537.
  • The glenoid components are made of ultrahigh molecular weight polyethylene (UHMWPE) according to ASTM standard F648 or ISO 5834-2.
AI/ML Overview

Here's a breakdown of the acceptance criteria and study details for the Simpliciti™ Shoulder System, based on the provided document:

Acceptance Criteria and Device Performance

Validation and / or Verification MethodAcceptance Value / CriteriaVerification and Validation Results
CAD study to ensure acceptable geometryHead geometry is comparable to the Aequalis humeral headsAcceptable
Mechanical testing (fatigue)The nucleus shall survive a prescribed number of cycles at a prescribed load without fatigue, fracture, yielding, looseningAcceptable
Mechanical testing (lever out)Qualitative Comparison to Aequalis Resurfacing ShoulderAcceptable
Mechanical testing (pull out)Qualitative Comparison to Aequalis Resurfacing ShoulderAcceptable
Mechanical testing (torque out)Qualitative Comparison to Aequalis Resurfacing ShoulderAcceptable
Mechanical testing (taper disassociation testing)The Simpliciti Shoulder taper is equivalent to the taper of the Affiniti Shoulder SystemAcceptable
X-ray overlay validationNo impingement of the fin geometry on the inner cortex of the metaphysisAcceptable
Clinical Study Primary EndpointPercentage of subjects meeting all four criteria > 75% (historical control) + 10% (non-inferiority margin)88.74% (lower one-sided 95% confidence bound of 83.59%)
(Criteria: no continuous radiolucent line, adjusted Constant score > 85, no revision surgery, no system-related serious adverse event at 24 months)
Clinical Study Secondary ObjectivesPatient improvement in Quality of Life (QOL), range of motion, strengthAll secondary QOL objectives, on average, reported patient improvement.
Clinical Study Radiographic AssessmentNo instances of radiolucency, device migration, osteolysis, or subsidence of the glenoid component or nucleusThird-party radiologists determined no instances of these issues.
Clinical Study Safety (Adverse Events)Acceptable incidence of expected complications for total shoulder arthroplasty; no Unanticipated Adverse Device Effects (UADEs)No UADEs reported. System or procedure related events considered expected.

Study Details

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

    • Test Set Sample Size: 157 subjects were enrolled (out of 181 consented and screened).
    • Data Provenance: Prospective, multi-center study conducted at 14 sites in the US.
  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Number of Experts: "Third-party radiologists" were involved. The exact number is not specified.
    • Qualifications of Experts: General radiologists. Specific experience level (e.g., "10 years of experience") is not provided.
  3. Adjudication method for the test set:

    • The document primarily mentions "third-party radiologists" determining radiographic outcomes, implying a form of expert review for these specific criteria. For other criteria like Constant score, revision surgery, and adverse events, the primary endpoint suggests a direct assessment based on defined objective measures. No specific "adjudication method" like 2+1 or 3+1 is explicitly stated for the overall primary endpoint success.
  4. 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:

    • No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This study is for a medical device (shoulder system), not an AI algorithm, and therefore the concept of "human readers improve with AI" does not apply. The clinical study compared the device to a historical control group.
  5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

    • No. This study evaluates a physical medical device, not an algorithm.
  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • The ground truth for the clinical study was established through a combination of:
      • Outcome Data: Adjusted Constant score (> 85), instance of revision surgery, and system-related serious adverse events.
      • Expert Radiographic Review: Radiographic assessment by "third-party radiologists" for criteria like continuous radiolucent line, device migration, osteolysis, and subsidence.
  7. The sample size for the training set:

    • This study is about a physical medical device, not a machine learning model, so there is no concept of a "training set" in the context of AI. The "training set" for the device's design and manufacturing would be the iterative design and testing process, but not in the sense of data used to train an algorithm.
  8. How the ground truth for the training set was established:

    • Again, this is not applicable as it refers to a device, not an AI model. The "ground truth" for the device's development would be established through engineering principles, materials science, biomechanical testing standards (like ASTM and ISO mentioned), and clinical understanding of shoulder anatomy and biomechanics. The clinical study served as the primary validation of the device's performance against predefined endpoints.

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Image /page/0/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 an abstract symbol that resembles a stylized human figure or a group of people in profile. The logo is black and white.

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

March 4, 2015

Tornier, Incorporated Ms. Loucinda Biorklund Principal Regulatory Affairs Project Manager 10801 Nesbitt Avenue South Bloomington, Minnesota 55437

Re: K143552

Trade/Device Name: Simpliciti™ Shoulder System Regulation Number: 21 CFR 888.3660 Regulation Name: Shoulder joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: PKC Dated: December 12, 2014 Received: December 15, 2014

Dear Ms. Bjorklund:

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 - Ms. Loucinda Bjorklund

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 Industry and Consumer Education 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. 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 Industry and Consumer Education 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 vours.

Lori A. Wiggins -S

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

Enclosure

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INDICATIONS FOR USE

K143552 510(k) Number (if known):

Device Name: Simpliciti™ Shoulder System

Indications for Use:

The Simpliciti™ Shoulder System is indicated for severely painful and/or disabled joint resulting from osteoarthritis or traumatic arthritis.

The metaphyseal humeral stems are indicated for press-fit, un-cemented use.

The glenoid components are indicated for cemented use only and are indicated only for use with bone cement.

This device is for single use.

Prescription Use X Over-The-Counter Use Prescription Use _____________________________________________________________________________________________________________________________________________________________ (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)

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510(k) Summary

Date Prepared: February 28, 2015

I. Administrative Information

Name:Tornier, Inc.
Address:10801 Nesbitt Avenue SouthBloomington, MN 55437
Contact Person:Loucinda BjorklundPrincipal Regulatory Affairs Project Manage
Phone:952-683-7491
Fax:952-426-7601

II. Device Information

Name of Device:Simpliciti™ Shoulder System
Common Name:Shoulder Prosthesis
Classification Name:21 CFR 888.3660, shoulder joint metal/polymer semi-constrained cemented prosthesis
Regulatory Class:Class II
Product Code:PKC

III. Predicate Device Information

Affiniti Shoulder System, K103007

IV. Device Description

The Simpliciti™ Shoulder System is intended for use in Total Shoulder Arthroplasty of the shoulder (TSA) application. As a Total shoulder, the system consists of a metaphyseal metal humeral component, a metal humeral head and an ultrahigh molecular weight polyethylene glenoid. Glenoid components are labeled "for cemented use only" and are indicated only for use with bone cement. The metaphyseal humeral components are indicated and labeled for press-fit un-cemented use.

The materials used in the manufacture of the Simpliciti™ Shoulder System implants are as follows:

  • Metaphyseal humeral component is made of titanium alloy (Ti-6AL-4V) in ● accordance to ASTM standard F136 with a sintered titanium (CP Ti) bead coating conforming to ASTM F-1580.
  • . The humeral heads are made off cobalt-chromium- alloy (CoCr) according to ASTM standard F1537.
  • The glenoid components are made of ultrahigh molecular weight polyethylene (UHMWPE) according to ASTM standard F648 or ISO 5834-2.

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V. Intended Use

The Simpliciti™ Shoulder System is intended for Total Shoulder Arthroplasty

VI. Indications for Use

The Simpliciti Shoulder System is indicated for severely painful and/or disabled joint resulting from osteoarthritis or traumatic arthritis.

The metaphyseal humeral stems are indicated for press-fit, un-cemented use.

The glenoid components are indicated for cemented use only and are indicated only for use with bone cement.

This device is for single use.

VII. Comparison of Technological Characteristics with the Predicate Device

The Simpliciti Shoulder System has the same intended use and fundamental scientific technology as the predicate device. The Simplicit Shoulder System has the same intended use and fundamental scientific technology as the predicate device. The technological characteristics (material, design, sizing, indications, coating, packaging, shelflife, and sterilization) of the Simpliciti Shoulder System are substantially equivalent to the predicate device. The design differences have been demonstrated to not affect safety or effectiveness or raise new issues of safety or effectiveness.

CharacteristicSimpliciti Shoulder System(Subject Device)Affiniti Shoulder System(Predicate Device)
510(k) NumberTo be assignedK103007
Device ClassClass II
Device CodeKWSKWS, HSD
Regulation Classification21 CFR 888.366021 CFR 888.3660,21 CFR 888.3690
Intended UseThe Simpliciti Shoulder System isintended for total shoulderarthroplasty of the shoulder.The Affiniti Shoulder System isintended for use as a total or hemi-shoulder system.
Indications for UseThe Simpliciti Shoulder System isindicated for severely painful and/ordisabled joint resulting fromosteoarthritis and traumatic arthritis.The metaphyseal humeral stems areindicated for press-fit, un-cementeduse.The glenoid components areindicated for cemented use only andare indicated only for use with bonecement.The Affiniti Total and Hemi-Shoulder System is indicated for:A severely painful and / ordisabled joint resultingfrom osteoarthritis,traumatic arthritis orrheumatoid arthritis;Fracture / dislocations ofthe proximal humerus;where the articular surfaceis severely comminuted,separated from its bloodsupply or where thesurgeon's experience
CharacteristicSimpliciti Shoulder System(Subject Device)Affiniti Shoulder System(Predicate Device)K103007
methods of treatment are unsatisfactory;Other difficult clinical problems where shoulder arthrodesis or resection arthroplasty are not acceptable (e.g., revision of a failed primary component). The Affiniti Hemi-Shoulder System is also indicated for: Ununited humeral head fractures Avascular necrosis of the humeral head Rotator cuff tear arthropathy Note:Glenoid components labeled for “cemented use only” and are indicated only for use with bone cement. Humeral stems are indicated for press-fit un-cemented use or for use with bone cement.This is a single use device.
Humeral Stem (Nucleus)
Stem Component Material (Substrate)Titanium alloy (Ti-6Al-4V): conforms to ASTM F-136 or ISO 5832-3
Stem DesignThree fins that extend radially from the center and are equally spaced at 120°.Single post with a stem diameter range from 6 mm to 18 mm
Porous CoatedPorous coated and uncoated.
Stem Lengths18 mm to 24 mm110 mm to 220 mm
Porous Coating MaterialSintered titanium bead coating conforms to ASTM F-1580 or ISO 5832-2
Porous CoatingVolume Porosity30% to 70%
CharacteristicSimpliciti Shoulder System(Subject Device)Affiniti Shoulder System(Predicate Device)K103007
Porous CoatingAverage Pore Size100 μm to 1000 μm
Porous CoatingThickness500 μm to 1500 μm
PackagingPackaged into a polyethylene sleeve and placed into a Tyvek / Mylar pouch. Pouch is sealed and placed into a secondary Tyvek / Mylar pouch. Secondary pouch is sealed and placed into a labeled carton box.
Shelf Life5 Years
SterilizationGamma Irradiation
Humeral Head
Component MaterialCobalt Chromeconforms to ASTM F-1537, ISO 5832-7 or ISO 5832-12
Diameter39 mm to 56 mm
Head Thickness14 mm to 23 mm
PackagingPackaged in Double Tyvek pouch or a double foil pouch that is placed in an outer box and shrink wrapped.
Shelf Life5 Years
SterilizationGamma Irradiation
Glenoid
Component MaterialsUltra high molecular weight polyethylene conforming to ASTM F-648
SizesKeeled Glenoid40 XS, 40, 44, 48, 52, 56, 56XL
SizesPegged Glenoid40, 44, 48, 52, 56
PackagingPackaged in Double Tyvek pouch or a double foil pouch that is placed in an outer box and shrink wrapped.
Shelf Life5 Years

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VIII. Performance Data

Non-clinical performance bench testing (mechanical testing) was performed to demonstrate substantial equivalence to the predicate device.

Validation and / orVerification MethodAcceptance Value / CriteriaVerification andValidation Results
CAD study to ensureacceptable geometryHead geometry is comparable to the Aequalishumeral headsAcceptable
Mechanical testing(fatigue)The nucleus shall survive a prescribed number ofcycles at a prescribed load without fatigue,fracture, yielding, looseningAcceptable
Mechanical testing (leverout)Qualitative Comparison to Aequalis ResurfacingShoulderAcceptable
Mechanical testing (pullout)Qualitative Comparison to Aequalis ResurfacingShoulderAcceptable
Mechanical testing (torqueout)Qualitative Comparison to Aequalis ResurfacingShoulderAcceptable
Mechanical testing (taperdisassociation testing)The Simpliciti Shoulder taper is equivalent to thetaper of the Affiniti Shoulder SystemAcceptable
X-ray overlay validationNo impingement of the fin geometry on the innercortex of the metaphysisAcceptable
Non-clinical Performance Testing Summary for Simpliciti Shoulder System

IX. Clinical Study

The Simpliciti Shoulder System study was a prospective, single arm, multi-center study conducted at 14 sites in the US which enrolled 157 subjects (181 consented and screened). The purpose of the Simpliciti IDE study was to demonstrate safety and effectiveness of the Simpliciti system in total shoulder arthroplasty at 24 months. Subject outcomes were compared to results of a historical control group with a primary diagnosis of osteoarthritis or traumatic arthritis and implanted with a FDA cleared, Tornier stemmed humeral prosthesis. A subject was a success at 24 months if: there was no continuous radiolucent line around the prosthesis, the adjusted Constant score was > 85, they did not have revision surgery, and they did not have a systemrelated serious adverse event. Secondary objectives included quality of life, range of motion, strength, and radiographic device assessment.

The percentage of subjects who met all four criteria is 88.74% with a lower one-sided 95% confidence bound of 83.59%. As the lower bound is greater than the percentage of success observed in the historic control (75% and the non-inferiority margin (10%), the null hypothesis is rejected in favor of the alternative hypothesis that the primary endpoint is greater than 75%.

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All secondary QOL objectives, on average, reported patient improvement. Additionally, third party radiologists determined there were no instances of radiolucency, device migration, osteolysis, or subsidence of the glenoid component or nucleus.

There were 228 reported Adverse Events (AEs) occurring in 103 of the study subjects. Study investigators classified relatedness of all AEs as definitely related, possibly related, unknown relatedness, or not related to the study system or procedure. There were 22 (22/228, 9.6%) AEs in 21 subjects (21/157, 13.4%) that were considered related to the system or procedure. One (0.4%) AE for aseptic glenoid loosening was considered possibly related to the system. Ten (4.4%) events were reported as definitely related to the procedure and 11 (4.8%) were reported as possibly related to the procedure. Adverse events definitely related to the procedure included: infection (2), shoulder stiffness (2), paresthesia (2), ecchymosis (1), mental status changes (1), scarring (1), and keloid scar (1). Adverse events possibly related to the procedure included: paresthesia (4), weakness (2), tendonitis (1), pain (1), hematoma (1), arthrofibrosis (1), and osteoarthritis (1). All system or procedure related events were considered expected complications for total shoulder arthroplasty; thus, there were no Unanticipated Adverse Device Effects (UADEs).

There were a total of 55 reported serious AEs (SAEs). Three (3/55, 5.5%) SAEs were possibly (2/55, 3.6%) or definitely (1/55, 1.8%) related to the procedure and one (1/55, 1.8%) SAE was considered possibly related to the system. The aseptic glenoid loosening is the only SAE with a possible relationship to the system. The SAEs possibly related to the procedure included weakness (1) and arthrofibrosis (1) and the SAE definitely related to the procedure was an infection (1).

There were five subjects with revisions (3) and explants (2) of the Simpliciti system. The three revisions were for: nucleus upsize during initial implant (1), infection 4 weeks post-implant (1), and aseptic glenoid loosening 17 months post-implant (1). The two explants were for poor bone quality during the initial implant and subscapularis insufficiency 467 days post-implant.

The Simpliciti IDE study suggests that the Simpliciti system equivalently to currently marketed shoulder devices for the treatment of osteo- and traumatic arthritis.

X. Conclusions

The Simpliciti Shoulder System described in this section has the same intended use and the same fundamental scientific technology as the cleared Affiniti Shoulder System. Based on the testing presented for the design differences between the subject and predicate devices, Tornier concludes that subject device is substantially equivalent to the predicate device.

§ 888.3660 Shoulder joint metal/polymer semi-constrained cemented prosthesis.

(a)
Identification. A shoulder joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a shoulder 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 humeral resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, and is limited to those prostheses intended for use with bone cement (§ 888.3027).(b)
Classification. Class II. The special controls for this device are:(1) FDA's:
(i) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ”
(ii) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),”
(iii) “Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement,”
(iv) “Guidance Document for the Preparation of Premarket Notification (510(k)) Application for Orthopedic Devices,” and
(v) “Guidance Document for Testing Non-articulating, ‘Mechanically Locked’ Modular Implant Components,”
(2) International Organization for Standardization's (ISO):
(i) ISO 5832-3:1996 “Implants for Surgery—Metallic Materials—Part 3: Wrought Titanium 6-aluminum 4-vandium Alloy,”
(ii) ISO 5832-4:1996 “Implants for Surgery—Metallic Materials—Part 4: Cobalt-chromium-molybdenum casting alloy,”
(iii) ISO 5832-12:1996 “Implants for Surgery—Metallic Materials—Part 12: Wrought Cobalt-chromium-molybdenum alloy,”
(iv) ISO 5833:1992 “Implants for Surgery—Acrylic Resin Cements,”
(v) ISO 5834-2:1998 “Implants for Surgery—Ultra-high Molecular Weight Polyethylene—Part 2: Moulded Forms,”
(vi) ISO 6018:1987 “Orthopaedic Implants—General Requirements for Marking, Packaging, and Labeling,” and
(vii) ISO 9001:1994 “Quality Systems—Model for Quality Assurance in Design/Development, Production, Installation, and Servicing,” and
(3) American Society for Testing and Materials':
(i) F 75-92 “Specification for Cast Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implant Material,”
(ii) F 648-98 “Specification for Ultra-High-Molecular-Weight Polyethylene Powder and Fabricated Form for Surgical Implants,”
(iii) F 799-96 “Specification for Cobalt-28 Chromium-6 Molybdenum Alloy Forgings for Surgical Implants,”
(iv) F 1044-95 “Test Method for Shear Testing of Porous Metal Coatings,”
(v) F 1108-97 “Specification for Titanium-6 Aluminum-4 Vanadium Alloy Castings for Surgical Implants,”
(vi) F 1147-95 “Test Method for Tension Testing of Porous Metal,”
(vii) F 1378-97 “Standard Specification for Shoulder Prosthesis,” and
(viii) F 1537-94 “Specification for Wrought Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implants.”