K Number
K161360
Device Name
U2 Total Knee System, PSA Tibial Insert
Date Cleared
2017-02-01

(261 days)

Product Code
Regulation Number
888.3560
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
This device is indicated in knee arthroplasty in skeletally mature patients with severe knee pain and disability due to rheumatoid arthritis, osteoarthritis, primatic arthritis, polyarthritis, collagen disorders, avascular necrosis of the femoral condyle or pseudogout, posttraumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectorny, moderate valgus, varus, or flexion contraction. This device is intended for use in patients who require augmentations due to inadequate bone stock and/or require increased stabilization for tibiofemoral joint due to soft tissue imbalance. The femoral and tibial augments are to be attached to their respective components with a fixation screw or screws. Note: In the US, this device is for cemented use only.
Device Description
U2 Total Knee System - PSA Tibial Insert is an extended design of U2 Total Knee System - PSA Type (K082424) including XPE Tibal Insert, PSA and XPE Tibial Insert, PSA, LC. This System is a patellofemorotibial polymer / metal / polymer, semi-constrained, cemented knee prosthesis, which is intended for use in patients who require augmentation and/or stem extensions due to inadequate bone stock. U2 Total Knee System - PSA Tibial Inserts are available in a range of thicknesses and in two design configurations: PSA and PSA-LC type. For the PSA tibial insert, it is intended for use in patients who require constrained stabilization for tibiofemoral joint due to soft tissue imbalance. PSA-LC (low constrained) tibial insert provide less constrained stabilization than PSA tibial insert.
More Information

Not Found

No
The summary describes a mechanical knee implant system and does not mention any software, algorithms, or data processing that would indicate the use of AI or ML.

Yes
The device is a knee prosthesis, which is a medical implant intended to treat severe knee pain and disability.

No

This device is a knee prosthesis, which is an implant used for treatment (replacement of a joint), not for diagnosing a condition.

No

The device description explicitly states it is a "patellofemorotibial polymer / metal / polymer, semi-constrained, cemented knee prosthesis," indicating it is a physical implant, not software.

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

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant for knee arthroplasty to treat severe knee pain and disability due to various conditions. This is a therapeutic intervention, not a diagnostic test performed on samples taken from the body.
  • Device Description: The device is described as a "patellofemorotibial polymer / metal / polymer, semi-constrained, cemented knee prosthesis." This is a physical implant designed to replace a joint, not a reagent, instrument, or system used to examine specimens.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting specific analytes, or providing diagnostic information.

This device is a medical device, specifically a knee implant, used in a surgical procedure.

N/A

Intended Use / Indications for Use

This device is indicated in knee arthroplasty in skeletally mature patients with severe knee pain and disability due to rheumatoid arthritis, osteoarthritis, primatic arthritis, polyarthritis, collagen disorders, avascular necrosis of the femoral condyle or pseudogout, posttraumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectorny, moderate valgus, varus, or flexion contraction. This device is intended for use in patients who require augmentations due to inadequate bone stock and/or require increased stabilization for tibiofemoral joint due to soft tissue imbalance. The femoral and tibial augments are to be attached to their respective components with a fixation screw or screws.

Note: In the US, this device is for cemented use only.

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

JWH

Device Description

U2 Total Knee System - PSA Tibial Insert is an extended design of U2 Total Knee System - PSA Type (K082424) including XPE Tibal Insert, PSA and XPE Tibial Insert, PSA, LC. This System is a patellofemorotibial polymer / metal / polymer, semi-constrained, cemented knee prosthesis, which is intended for use in patients who require augmentation and/or stem extensions due to inadequate bone stock. U2 Total Knee System - PSA Tibial Inserts are available in a range of thicknesses and in two design configurations: PSA and PSA-LC type. For the PSA tibial insert, it is intended for use in patients who require constrained stabilization for tibiofemoral joint due to soft tissue imbalance. PSA-LC (low constrained) tibial insert provide less constrained stabilization than PSA tibial insert.

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 patients

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)

Non-clinical Performance:
Range of Motion and Spine Fatigue Test were conducted to evaluate the safety and effectiveness of the subjected device.
The subject U2 Total Knee System – PSA Tibial Insert has the same curvature design at the articular surface as U2 Total Knee system - PSA Type which was previously cleared by FDA (K082424). Thus, the constraint, contact area and contact pressure of the subject PSA Tibial Insert should be identical with U2 Total Knee system – PSA Type (K082424). In addition, the material, size distribution and the locking mechanism of the subject PSA-LC Tibial Insert is identical to the on-marketed PSA insert (K082424). The wear performance could be represented by the on-marketed U2 XPE Tibial Insert (K103733) due to the same contact area and size distribution.
Bacterial endotoxin testing was conducted and met the endotoxin limit as specified in USP .

Clinical Performance Data/Information:
None provided as a basis for substantial equivalence.

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.

K082424, K103733

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.

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus symbol, which is a staff with two snakes entwined around it. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the caduceus symbol.

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

February 1, 2017

United Orthopedic Corporation Karen Ho Regulatory Affairs Manager No 57, Park Ave 2, Science Park Hsinchu 300 Taiwan

Re: K161360 Trade/Device Name: U2 Total Knee System, PSA Tibial Insert 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: December 13, 2016 Received: December 14, 2016

Dear Karen Ho:

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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

1

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

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K161360

Device Name

U2 Total Knee System - PSA Tibial Insert

This device is indicated in knee arthroplasty in skeletally mature patients with severe knee pain and disability due to rheumatoid arthritis, osteoarthritis, primatic arthritis, polyarthritis, collagen disorders, avascular necrosis of the femoral condyle or pseudogout, posttraumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectorny, moderate valgus, varus, or flexion contraction. This device is intended for use in patients who require augmentations due to inadequate bone stock and/or require increased stabilization for tibiofemoral joint due to soft tissue imbalance. The femoral and tibial augments are to be attached to their respective components with a fixation screw or screws.

Note: In the US, this device is for cemented use only.

Type of Use (Select one or both, as applicable)X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary of Safety and Effectiveness

Submitter Information

NameUnited Orthopedic Corporation
AddressNo 57, Park Ave 2, Science Park, Hsinchu 300, Taiwan
Phone Number+886-3-5773351 ext. 2212
Fax Number+886-3-577156
Name of Contact PersonKaren Ho
Regulation and Document Management
Date preparedMay 12, 2016
Name of Device
Trade NameU2 Total Knee System – PSA Tibial Insert
Common NameTibial Insert
Regulation Name and
NumberThe device classification for U2 Total Knee System - PSA
Tibial Insert is “Knee joint patellofemorotibial
polymer/metal/polymer semi-constrained cemented
prosthesis” and is contained in the Code of Federal
Regulation, under 21CFR 888.3560. This falls under the
Orthopedic Panel.
Device ClassClass II
Classification PanelOrthopaedics
Product CodeJWH
Predicate Device1. “UNITED” U2 Total Knee System – PSA Type (K082424)
  1. “UNITED” U2 XPE Total Knee System (K103733) |

Device Description:

U2 Total Knee System - PSA Tibial Insert is an extended design of U2 Total Knee System - PSA Type (K082424) including XPE Tibal Insert, PSA and XPE Tibial Insert,

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O U2 Total Knee System - PSA Tibial Insert

PSA, LC. This System is a patellofemorotibial polymer / metal / polymer, semi-constrained, cemented knee prosthesis, which is intended for use in patients who require augmentation and/or stem extensions due to inadequate bone stock. U2 Total Knee System - PSA Tibial Inserts are available in a range of thicknesses and in two design configurations: PSA and PSA-LC type. For the PSA tibial insert, it is intended for use in patients who require constrained stabilization for tibiofemoral joint due to soft tissue imbalance. PSA-LC (low constrained) tibial insert provide less constrained stabilization than PSA tibial insert.

Indications for Use:

This device is indicated in knee arthroplasty in skeletally mature patients with severe knee pain and disability due to rheumatoid arthritis, osteoarthritis, primary and secondary traumatic arthritis, polyarthritis, collagen disorders, avascular necrosis of the femoral condyle or pseudogout, posttraumatic loss of joint configuration, particularly when there is patellofemoral joint surface erosion, dysfunction or prior patellectomy, moderate valgus, varus, or flexion contraction. This device is intended for use in patients who require augmentation and/or stem extensions due to inadequate bone stock and/or require increased stabilization for tibiofemoral joint due to soft tissue imbalance. The femoral and tibial augments are to be attached to their respective components with a fixation screw or screws.

Note: In the US, this device is for cemented use only.

Comparison to Predicate Device:

U2 Total Knee System - PSA Tibial Insert has the same basic design, intended use, materials, locking mechanism and sterilization as the predicate devices, U2 Total Knee System - PSA Type (K082424) and U2 XPE Total Knee System (K103733). The only difference between the subject and the predicate devices is the profile design of the spine. However, the performance evaluation of the subject device was conducted and would not post issues about safety and effectiveness. Thus, we believe that the subjected U2 Total Knee System - PSA Tibial Insert is substantially equivalent to the predicate device.

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Performance Data:

● Non-clinical Performance

Range of Motion and Spine Fatigue Test were conducted to evaluate the safety and effectiveness of the subjected device.

The subject U2 Total Knee System – PSA Tibial Insert has the same curvature design at the articular surface as U2 Total Knee system - PSA Type which was previously cleared by FDA (K082424). Thus, the constraint, contact area and contact pressure of the subject PSA Tibial Insert should be identical with U2 Total Knee system – PSA Type (K082424). In addition, the material, size distribution and the locking mechanism of the subject PSA-LC Tibial Insert is identical to the on-marketed PSA insert (K082424). The wear performance could be represented by the on-marketed U2 XPE Tibial Insert (K103733) due to the same contact area and size distribution.

Bacterial endotoxin testing was conducted and met the endotoxin limit as specified in USP .

● Clinical Performance Data/Information

None provided as a basis for substantial equivalence.