K Number
K152170
Device Name
Exactech Optetrak Logic Enhanced Assembly
Manufacturer
Date Cleared
2015-09-03

(30 days)

Product Code
Regulation Number
888.3560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The OPTETRAK Comprehensive Knee Systems are indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, theumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revious reconstructions where sufficient bone stock and soft tissue integrity are present. In the USA, the OPTETRAK Comprehensive Knee Systems are indicated for cemented use only, except for the OPTETRAK Logic PS and CR Porous Femoral Components, which are indicated for cemented or cementless use. The OPTETRAK Logic CC Total Knee System is indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, theumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revious reconstructions where sufficient bone stock and soft tissue integrity are present. The OPTETRAK Logic CC Total Knee System is indicated for cemented use only.
Device Description
This submission proposes dimensional modifications to features common to all Optetrak Logic tibial inserts, Optetrak Logic trapezoidal tibial trays, and Optetrak Logic Combo tibial trays. These modifications are designed to enhance intraoperative assembly.
More Information

Not Found

No
The summary describes a knee replacement system with dimensional modifications and mechanical testing, with no mention of AI or ML.

Yes
The device is a total knee replacement system, which is used to treat medical conditions like osteoarthritis and rheumatoid arthritis, indicating a therapeutic purpose.

No

The device is a knee replacement system used in surgery, not for diagnosing conditions.

No

The device description clearly states it involves dimensional modifications to physical components (tibial inserts, tibial trays), and the performance studies involve mechanical testing, indicating a hardware device.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • Device Description and Intended Use: The provided text clearly describes a knee replacement system intended for surgical implantation in skeletally mature individuals undergoing total knee replacement. This is a surgical implant, not a device used for testing biological samples.
  • Lack of IVD Indicators: The text does not mention any of the typical characteristics of an IVDs, such as:
    • Testing of biological samples
    • Detection of biomarkers, diseases, or conditions through laboratory analysis
    • Use in a laboratory setting

Therefore, based on the provided information, the OPTETRAK Comprehensive Knee Systems and OPTETRAK Logic CC Total Knee System are surgical implants and not In Vitro Diagnostic devices.

N/A

Intended Use / Indications for Use

Optetrak Logic Total Knee System:

The OPTETRAK Comprehensive Knee Systems are indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, theumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revious reconstructions where sufficient bone stock and soft tissue integrity are present. In the USA, the OPTETRAK Comprehensive Knee Systems are indicated for cemented use only, except for the OPTETRAK Logic PS and CR Porous Femoral Components, which are indicated for cemented or cementless use.

Optetrak Logic CC Total Knee System:

The OPTETRAK Logic CC Total Knee System is indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, theumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revious reconstructions where sufficient bone stock and soft tissue integrity are present.

The OPTETRAK Logic CC Total Knee System is indicated for cemented use only.

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

JWH

Device Description

This submission proposes dimensional modifications to features common to all Optetrak Logic tibial inserts, Optetrak Logic trapezoidal tibial trays, and Optetrak Logic Combo tibial trays. These modifications are designed to enhance intraoperative assembly.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Knee

Indicated Patient Age Range

skeletally mature individuals

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)

This submission includes references to the following mechanical testing:

  • . Micromotion testing
  • Shear testing

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.

K093360, K111400, K121307, K110547, K123342, K132161, K150890, K101981

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

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

September 3, 2015

Exactech, Incorporated Mr. Patrick Hughes Senior Regulatory Affairs Specialist 2320 Northwest 66th Court Gainesville, Florida 32653

Re: K152170

Trade/Device Name: Exactech Optetrak Logic Enhanced Assembly Regulation Number: 21 CFR 888.3560 Regulation Name: Knee joint patellofemorotibial polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: JWH Dated: July 31, 2015 Received: August 4, 2015

Dear Mr. Hughes,

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 of medical device-related

1

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 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/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 yours.

Mark N. Melkerson -S

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

Enclosure

2

Indications for Use

510(k) Number (if known) K152170

Device Name Exactech Optetrak Logic Enhanced Assembly

Indications for Use (Describe)

Optetrak Logic Total Knee System:

The OPTETRAK Comprehensive Knee Systems are indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, theumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revious reconstructions where sufficient bone stock and soft tissue integrity are present. In the USA, the OPTETRAK Comprehensive Knee Systems are indicated for cemented use only, except for the OPTETRAK Logic PS and CR Porous Femoral Components, which are indicated for cemented or cementless use.

Optetrak Logic CC Total Knee System:

The OPTETRAK Logic CC Total Knee System is indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, theumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revious reconstructions where sufficient bone stock and soft tissue integrity are present.

The OPTETRAK Logic CC Total Knee System is indicated for cemented use only.

Type of Use (Select one or both, as applicable)
-------------------------------------------------
Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

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Exactech® Optetrak Logic® Enhanced Assembly Special 510(k) - 510(k) Summary of Safety and Effectiveness

| Sponsor: | Exactech, Inc.
2320 N.W. 66th Court
Gainesville, FL 32653 |
|----------|-----------------------------------------------------------------|
| Phone: | (352) 377-1140 |
| Fax: | (352) 378-2617 |
| | FDA Establishment Number 1038671 |
| Contact: | Patrick Hughes
Senior Regulatory Affairs Specialist |
| Date: | July 31, 2015 |

Trade or Proprietary or Model Name(s):

Exactech® Optetrak Logic® Total Knee System & Exactech® Optetrak Logic® CC Total Knee System

Common Name:

Cemented Total Knee Prosthesis

Classification Name:

Prosthesis, Knee, Patellofemorotibial, Semi-Constrained, Cemented, Polymer/Metal/Polymer

Information on devices to which substantial equivalence is claimed:

510(k) NumberTrade or Proprietary Model NameManufacturer
K093360Optetrak Logic PS
K111400Optetrak Logic CR, Sizes 1-5
K121307Optetrak Logic CR, Sizes 0 & 6
K110547Optetrak Logic PSCExactech, Inc
K123342Optetrak Logic CRC
K132161Optetrak Logic 17mm & 19mm Tibial Inserts
K150890Optetrak Logic CC
K101981Optetrak Logic Combo Trays

Indications for Use:

The OPTETRAK Comprehensive Knee Systems are indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, rheumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revision of failed previous reconstructions where sufficient bone stock and soft tissue integrity are present. In the USA, the OPTETRAK Comprehensive Knee Systems are indicated for cemented use only,

4

Exactech® Optetrak Logic® Enhanced Assembly Special 510(k) - 510(k) Summary of Safety and Effectiveness

except for the OPTETRAK Logic PS and CR Porous Femoral Components, which are indicated for cemented or cementless use.

The Optetrak Logic CC Total Knee System is indicated for use in skeletally mature individuals undergoing primary surgery for total knee replacement due to osteoarthritis, osteonecrosis, rheumatoid arthritis and/or post-traumatic degenerative problems. They are also indicated for revision of failed previous reconstructions where sufficient bone stock and soft tissue integrity are present.

The Optetrak Logic CC Total Knee System is indicated for cemented use only.

Device Description:

This submission proposes dimensional modifications to features common to all Optetrak Logic tibial inserts, Optetrak Logic trapezoidal tibial trays, and Optetrak Logic Combo tibial trays. These modifications are designed to enhance intraoperative assembly.

Testing Description:

This submission includes references to the following mechanical testing:

  • . Micromotion testing
  • Shear testing

Substantial Equivalence Conclusion:

Results of engineering studies referenced in this 510(k) submission demonstrate proposed Optetrak Logic and Optetrak Logic CC devices are substantially equivalent to cited cleared predicate Optetrak Logic devices.