K Number
K172347
Device Name
GMK Hinge, GMK Revision
Date Cleared
2017-11-01

(90 days)

Product Code
Regulation Number
888.3510
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The GMK HINGE knee prosthesis is designed for cemented use in total knee arthroplasty when the preoperative diagnosis of the joint determines that the bone and stability situation require the implantation of a constrained prosthesis. The GMK HINGE knee system is indicated in the following cases: · Severely painful and/or disabled joint as a result of arthritis, theumatoid arthritis or polyarthritis associated with bone loss and/or severe joint instability - · Considerable loss of function of the knee joint · High-grade joint destruction requiring additional stabilization with stems and reconstruction of bone defects with metal augmentation - · Failure of a primary prosthesis (e.g. infection, loosening) - · Former revision arthroplasty - Post traumatic loss of joint configuration - · Avascular necrosis of femoral condyle Tibial augmentations are to be screwed to the tibial baseplate with both of the two provided fixing screws. When a GMK HINGE implant is used it is mandatory to implant both the femoral and tibial components with an extension stem. The Evolis/GMK knee prosthesis is designed for cemented use in total knee arthroplasty, if there is evidence of sufficient sound bone to seat and support the components. This knee replacement system is indicated in the following cases: - · Severely painful and/or disabled joint as a result of arthritis, traumatoid arthritis, or polyarthritis - · Avascular necrosis of femoral condyle - Post traumatic loss of joint configuration - · Primary implantation failure Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement. The screwed tibial augments are for screwed fixation to the tibial baseplate. In case a semi-constrained liner is used, an extension stem must be implanted both on the tibial and on the femoral components. In case a GMK Revision tibial tray is used, an extension stem must be implanted.
Device Description
GMK Hinge: This extension to the GMK Hinge product family consists of screwed tibial augmentations (thicknesses 15 and 20 mm) and Ultra Congruent (UC) fixed tibial inserts. The tibial augmentations allow the surgeon to selectively fill bone deficiencies and to aid in restoring the joint line. The fixation between the augmentations and the tibial tray is assured by a screw fixation. The screwed tibial augmentations are manufactured from High Nitrogen Stainless Steel M30NW (ISO 5832-9). The tibial augmentation connection screws are manufactured from titanium alloy (Ti6Al4V; ISO 5832-3). The UC fixed tibial insert is fixed to the tibial component through a screw and is designed to provide high rotational control and a high varus/valgus constraint. The UC fixed tibial inserts are manufactured from type 1 Ultra High Molecular Weight Polyethylene (UHMWPE; ISO 5834-2) and Cobalt-Chromium-Molybdenum alloy (CoCrMo; ISO 5832-12). The fixation screws are manufactured from titanium alloy (Ti6A14V; ISO 5832-3). GMK Revision: This extension to the GMK Revision product family adds additional screwed tibial augmentations (thicknesses 15 and 20 mm) to the GMK Revision extension cleared under K123721. The tibial augments allow the surgeon to selectively fill bone deficiencies and to aid in restoring the joint line. The fixation between the augmentations and the tibial tray is assured by a screw fixation. The screwed tibial augmentations are manufactured from High Nitrogen Stainless Steel M30NW (ISO 5832-9). The tibial augmentation connection screws are manufactured from titanium alloy (Ti6Al4V; ISO 5832-3).
More Information

Not Found

No
The device description focuses solely on the mechanical components and materials of the knee prosthesis and its extensions. There is no mention of any software, algorithms, data processing, or learning capabilities that would indicate the presence of AI or ML.

Yes
The device is a knee prosthesis designed for total knee arthroplasty, which is a medical procedure to treat painful and/or disabled joints. This directly addresses health issues and aims to restore function, meeting the definition of a therapeutic device.

No

This device is a knee prosthesis designed for implantation in total knee arthroplasty, which is a therapeutic rather than a diagnostic function.

No

The device description clearly outlines physical components made of various materials (stainless steel, titanium alloy, UHMWPE, Cobalt-Chromium-Molybdenum alloy) that are implanted in the knee joint. This is a hardware medical device, not software.

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

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant for total knee arthroplasty. It is designed to replace or augment parts of the knee joint due to various conditions like arthritis, bone loss, or failed previous surgeries.
  • Device Description: The device description details the physical components of the knee prosthesis (femoral and tibial components, stems, augmentations, inserts) and the materials they are made from. These are all physical implants.
  • IVD Definition: In vitro diagnostics are tests performed on samples taken from the human body (like blood, urine, or tissue) to detect diseases, conditions, or infections. This device does not perform any such testing.

The device is a medical device, specifically a surgical implant, used in vivo (within the body) during a surgical procedure.

N/A

Intended Use / Indications for Use

The GMK HINGE knee prosthesis is designed for cemented use in total knee arthroplasty when the preoperative diagnosis of the joint determines that the bone and stability situation require the implantation of a constrained prosthesis.

The GMK HINGE knee system is indicated in the following cases:

· Severely painful and/or disabled joint as a result of arthritis, theumatoid arthritis or polyarthritis associated with bone loss and/or severe joint instability

  • · Considerable loss of function of the knee joint
    · High-grade joint destruction requiring additional stabilization with stems and reconstruction of bone defects with metal augmentation
  • · Failure of a primary prosthesis (e.g. infection, loosening)
  • · Former revision arthroplasty
  • Post traumatic loss of joint configuration
  • · Avascular necrosis of femoral condyle

Tibial augmentations are to be screwed to the tibial baseplate with both of the two provided fixing screws.

When a GMK HINGE implant is used it is mandatory to implant both the femoral and tibial components with an extension stem.

The Evolis/GMK knee prosthesis is designed for cemented use in total knee arthroplasty, if there is evidence of sufficient sound bone to seat and support the components.

This knee replacement system is indicated in the following cases:

  • · Severely painful and/or disabled joint as a result of arthritis, traumatoid arthritis, or polyarthritis
  • · Avascular necrosis of femoral condyle
  • Post traumatic loss of joint configuration
  • · Primary implantation failure

Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement.

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

KRO, JWH

Device Description

GMK Hinge:

This extension to the GMK Hinge product family consists of screwed tibial augmentations (thicknesses 15 and 20 mm) and Ultra Congruent (UC) fixed tibial inserts.

The tibial augmentations allow the surgeon to selectively fill bone deficiencies and to aid in restoring the joint line. The fixation between the augmentations and the tibial tray is assured by a screw fixation. The screwed tibial augmentations are manufactured from High Nitrogen Stainless Steel M30NW (ISO 5832-9). The tibial augmentation connection screws are manufactured from titanium alloy (Ti6Al4V; ISO 5832-3).

The UC fixed tibial insert is fixed to the tibial component through a screw and is designed to provide high rotational control and a high varus/valgus constraint. The UC fixed tibial inserts are manufactured from type 1 Ultra High Molecular Weight Polyethylene (UHMWPE; ISO 5834-2) and Cobalt-Chromium-Molybdenum alloy (CoCrMo; ISO 5832-12). The fixation screws are manufactured from titanium alloy (Ti6A14V; ISO 5832-3).

GMK Revision:

This extension to the GMK Revision product family adds additional screwed tibial augmentations (thicknesses 15 and 20 mm) to the GMK Revision extension cleared under K123721. The tibial augments allow the surgeon to selectively fill bone deficiencies and to aid in restoring the joint line. The fixation between the augmentations and the tibial tray is assured by a screw fixation. The screwed tibial augmentations are manufactured from High Nitrogen Stainless Steel M30NW (ISO 5832-9). The tibial augmentation connection screws are manufactured from titanium alloy (Ti6Al4V; ISO 5832-3).

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

Prescription Use (Part 21 CFR 801 Subpart D)

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 Studies

  • sterilization validation in accordance with ISO 11137-1:2006, ISO 11137-2:2006, and ISO 11135-1:2007;
  • ethylene oxide residuals in accordance with ISO 10993-7:1995(R)2001; ●
  • shelf life studies in accordance with ASTM F1980-07 (2011), ISO 11607-1:2006 and ISO 11607-2:2006;
  • pyrogenicity testing (LAL Method);
  • range of motion and rotational freedom evaluation; ●
  • wear testing;
  • static shear testing; and
  • dynamic testing.
    Key Results: The information provided above supports that the GMK Hinge and GMK Revision are as safe and effective as their respective predicate devices. Although minor differences in design exist between the subject and predicate device tibial augmentation components, these differences are addressed by the performance testing included in this submission. Therefore, it is concluded that the GMK Hinge and GMK Revision system components are substantially equivalent to their respective 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.

K130299, K123721

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

§ 888.3510 Knee joint femorotibial metal/polymer constrained cemented prosthesis.

(a)
Identification. A knee joint femorotibial metal/polymer constrained cemented prosthesis is a device intended to be implanted to replace part of a knee joint. The device limits translation or rotation in one or more planes and has components that are linked together or affined. This generic type of device includes prostheses composed of a ball-and-socket joint located between a stemmed femoral and a stemmed tibial component and a runner and track joint between each pair of femoral and tibial condyles. The ball-and-socket joint is composed of a ball at the head of a column rising from the stemmed tibial component. The ball, the column, the tibial plateau, and the stem for fixation of the tibial component are made of an alloy, such as cobalt-chromium-molybdenum. The ball of the tibial component is held within the socket of the femoral component by the femoral component's flat outer surface. The flat outer surface of the tibial component abuts both a reciprocal flat surface within the cavity of the femoral component and flanges on the femoral component designed to prevent distal displacement. The stem of the femoral component is made of an alloy, such as cobalt-chromium-molybdenum, but the socket of the component is made of ultra-high molecular weight polyethylene. The femoral component has metallic runners which align with the ultra-high molecular weight polyethylene tracks that press-fit into the metallic tibial component. The generic class also includes devices whose upper and lower components are linked with a solid bolt passing through a journal bearing of greater radius, permitting some rotation in the transverse plane, a minimal arc of abduction/adduction. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).(b)
Classification. Class II.

0

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

Medacta International SA % Roshana Ahmed Associate Director, Regulatory Affairs Mapi USA. Inc. 2343 Alexandria Drive Suite 100 Lexington, Kentucky 40504

November 1, 2017

Re: K172347

Trade/Device Name: GMK Hinge, GMK Revision Regulation Number: 21 CFR 888.3510 Regulation Name: Knee Joint femorotibial metal/polymer constrained cemented prosthesis Regulatory Class: Class II Product Code: KRO. JWH Dated: August 3, 2017 Received: August 3, 2017

Dear Roshana Ahmed:

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 mav, 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 adverse events) (21 CFR 803); good

U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov

1

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 (DICE) at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevicesforYou/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 (DICE) 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,

Mark N. Melkerson -S

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

Enclosure

2

Form Approved: OMB No. 0910-0120

Expiration Date: January 31, 2017

See PRA Statement below.

Indications for Use

510(k) Number (if known)

K172347

Device Name GMK Hinge

Indications for Use (Describe)

The GMK HINGE knee prosthesis is designed for cemented use in total knee arthroplasty when the preoperative diagnosis of the joint determines that the bone and stability situation require the implantation of a constrained prosthesis.

The GMK HINGE knee system is indicated in the following cases:

· Severely painful and/or disabled joint as a result of arthritis, theumatoid arthritis or polyarthritis associated with bone loss and/or severe joint instability

  • · Considerable loss of function of the knee joint
    · High-grade joint destruction requiring additional stabilization with stems and reconstruction of bone defects with metal augmentation

  • · Failure of a primary prosthesis (e.g. infection, loosening)

  • · Former revision arthroplasty

  • Post traumatic loss of joint configuration

  • · Avascular necrosis of femoral condyle

Tibial augmentations are to be screwed to the tibial baseplate with both of the two provided fixing screws.

When a GMK HINGE implant is used it is mandatory to implant both the femoral and tibial components with an extension stem.

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

See PRA Statement below.

Form Approved: OMB No. 0910-0120

Expiration Date: January 31, 2017

Indications for Use

510(k) Number (if known)

K172347

Device Name GMK Revision

Indications for Use (Describe)

The Evolis/GMK knee prosthesis is designed for cemented use in total knee arthroplasty, if there is evidence of sufficient sound bone to seat and support the components.

This knee replacement system is indicated in the following cases:

  • · Severely painful and/or disabled joint as a result of arthritis, traumatoid arthritis, or polyarthritis
  • · Avascular necrosis of femoral condyle
  • Post traumatic loss of joint configuration
  • · Primary implantation failure

Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement.

The screwed tibial augments are for screwed fixation to the tibial baseplate.

In case a semi-constrained liner is used, an extension stem must be implanted both on the femoral components.

In case a GMK Revision tibial tray is used, an extension stem must be implanted.

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)☑ Prescription Use (Part 21 CFR 801 Subpart D)☐ Over-The-Counter Use (21 CFR 801 Subpart C)
☑ Prescription Use (Part 21 CFR 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

4

3.0 510(k) Summary

I. Submitter

Medacta International SA Strada Regina 6874 Castel San Pietro (CH) Switzerland Phone (+41) 91 696 60 60 Fax (+41) 91 696 60 66

Contact Person: Stefano Baj, Regulatory Affairs Manager Date Prepared: August 2, 2017

II. Device

Device Proprietary Name:GMK Hinge and GMK Revision
Common or Usual Name:Total Knee Prosthesis
Classification Name:Prosthesis knee, Femorotibial, Constrained Cemented,
Metal/Polymer
Knee joint, patellofemorotibial polymer/metal/polymer sem
constrained cemented prosthesis
Regulation Number:21 CFR 888.3510
21 CFR 888.3560
Product Code:KRO
JWH
Device Classification2

III. Predicate Device

Substantial equivalence is claimed to the following devices:

  • GMK Hinge, K130299, Medacta International SA ●
  • GMK Revision Extension, K123721, Medacta International SA ●

5

IV. Device Description

GMK Hinge:

This extension to the GMK Hinge product family consists of screwed tibial augmentations (thicknesses 15 and 20 mm) and Ultra Congruent (UC) fixed tibial inserts.

The tibial augmentations allow the surgeon to selectively fill bone deficiencies and to aid in restoring the joint line. The fixation between the augmentations and the tibial tray is assured by a screw fixation. The screwed tibial augmentations are manufactured from High Nitrogen Stainless Steel M30NW (ISO 5832-9). The tibial augmentation connection screws are manufactured from titanium alloy (Ti6Al4V; ISO 5832-3).

The UC fixed tibial insert is fixed to the tibial component through a screw and is designed to provide high rotational control and a high varus/valgus constraint. The UC fixed tibial inserts are manufactured from type 1 Ultra High Molecular Weight Polyethylene (UHMWPE; ISO 5834-2) and Cobalt-Chromium-Molybdenum alloy (CoCrMo; ISO 5832-12). The fixation screws are manufactured from titanium alloy (Ti6A14V; ISO 5832-3).

GMK Revision:

This extension to the GMK Revision product family adds additional screwed tibial augmentations (thicknesses 15 and 20 mm) to the GMK Revision extension cleared under K123721. The tibial augments allow the surgeon to selectively fill bone deficiencies and to aid in restoring the joint line. The fixation between the augmentations and the tibial tray is assured by a screw fixation. The screwed tibial augmentations are manufactured from High Nitrogen Stainless Steel M30NW (ISO 5832-9). The tibial augmentation connection screws are manufactured from titanium alloy (Ti6Al4V; ISO 5832-3).

-----------------------This space intentionally left blank-----------------------

6

V. Indications for Use

GMK Hinge:

The GMK HINGE knee prosthesis is designed for cemented use in total knee arthroplasty when the preoperative diagnosis of the joint determines that the bone and stability situation require the implantation of a constrained prosthesis.

The GMK HINGE knee system is indicated in the following cases:

  • Severely painful and/or disabled joint as a result of arthritis, traumatic arthritis, rheumatoid arthritis or polyarthritis associated with bone loss and/or severe joint instability
  • Considerable loss of function of the knee joint
  • High-grade joint destruction requiring additional stabilization with stems and ● reconstruction of bone defects with metal augmentation
  • Failure of a primary prosthesis (e.g. infection, loosening)
  • Former revision arthroplasty
  • Post traumatic loss of joint configuration
  • Avascular necrosis of femoral condyle

Tibial augmentations are to be screwed to the tibial baseplate with both of the two provided fixing screws.

When a GMK HINGE implant is used it is mandatory to implant both the femoral and tibial components with an extension stem.

GMK Revision:

The Evolis/GMK knee prosthesis is designed for cemented use in total knee arthroplasty, if there is evidence of sufficient sound bone to seat and support the components.

This knee replacement system is indicated in the following cases:

  • Severely painful and/or disabled joint as a result of arthritis, traumatic arthritis, ● rheumatoid arthritis, or polyarthritis
  • . Avascular necrosis of femoral condyle
  • . Post traumatic loss of joint configuration
  • Primary implantation failure

Tibial wedges cemented are to be attached to the tibial baseplate with both the fixing cylinders and bone cement.

7

The screwed tibial augments are for screwed fixation to the tibial baseplate.

In case a semi-constrained liner is used, an extension stem must be implanted both on the tibial and on the femoral components.

In case a GMK Revision tibial tray is used, an extension stem must be implanted.

VI. Comparison of Technological Characteristics

The GMK Hinge and GMK Revision tibial augmentations share the following characteristics with the predicate devices:

  • materials of construction;
  • device size;
  • device usage;
  • connection with the tibial tray; ●
  • method of fixation to the bone; and
  • sterilization method.

The GMK Hinge and GMK Revision tibial augmentations are technologically different from the predicate devices as follows:

  • greater thickness, and
  • provided in RM/LL and LM/RL configurations. ●

The GMK Hinge and GMK Revision tibial augmentation screws are identical to those cleared under K130299 and K123721.

The GMK Hinge UC Fixed Tibial Inserts share the following characteristics with the predicate devices:

  • materials of construction; .
  • device size and thickness; ●
  • device usage; and
  • sterilization method.

Comparisons between the subject and predicate devices are provided in the tables below.

8

Medacta International SA


| | GMK Hinge | GMK Hinge
(K130299) |
|----------------------------------------|----------------------------------------------------------|------------------------|
| Tibial Augmentations | | |
| Material of Construction | High Nitrogen Stainless Steel M30NW
(ISO 5832-9) | Same |
| Sterilization Method | Gamma Irradiation | Same |
| Device Usage | Single Use | Same |
| Sizes | S1 - S6 | SO - S6 |
| Thickness | 15 mm
20 mm | 5 mm
10 mm |
| Configurations | Right medial, left lateral
Left medial, right lateral | Symmetric |
| Shape | Tapered side | Straight side |
| Tibial Augmentation Connection Screws | | |
| Material of Construction | Ti6Al4V (ISO 5832-3) | Same |
| Sterilization Method | Gamma Irradiation | Same |
| Device Usage | Single Use | Same |
| Dimensions | 10 mm | Same |
| UC Fixed Tibial Inserts | | |
| Materials of Construction | UHMWPE (ISO 5834 -2)
CoCrMo (ISO 5832-12) | Same |
| Sterilization Method | Ethylene Oxide | Same |
| Device Usage | Single Use | Same |
| Sizes | S1 - S6 | Same |
| Thickness | 12 mm - 26 mm | Same |
| UC Fixed Tibial Insert Fixation Screws | | |
| Material of Construction | Ti6Al4V (ISO 5832-3) | Same |
| Sterilization Method | Gamma Irradiation | Same |
| Device Usage | Single Use | Same |
| Dimensions | M4 x 8.5 | Same |

| | GMK Revision | GMK Revision
(K123721) |
|----------------------------|----------------------------------------------------------|---------------------------|
| Tibial Augmentations | | |
| Material of Construction | High Nitrogen Stainless Steel M30NW
(ISO 5832-9) | Same |
| Sterilization Method | Gamma Irradiation | Same |
| Device Usage | Single Use | Same |
| Sizes | S1 - S6 | S0 - S6 |
| Thickness | 15 mm
20 mm | 5 mm
10 mm |
| Configurations | Right medial, left lateral
Left medial, right lateral | Symmetric |
| Tibial Augmentation Screws | | |
| Material of Construction | Ti6Al4V (ISO 5832-3) | Same |
| Sterilization Method | Gamma Irradiation | Same |
| Device Usage | Single Use | Same |
| Dimensions | 10 mm | Same |

9

Discussion

As seen above, the differences between the subject and predicate device tibial augmentations are the component thickness, configuration, and shape. These technological differences do not raise different questions of safety or effectiveness and the differences are addressed by performance data identified below.

VII. Performance Data

The following performance data were provided in support of the substantial equivalence determination.

Non-Clinical Studies

  • sterilization validation in accordance with ISO 11137-1:2006, ISO 11137-2:2006, and ISO 11135-1:2007;
  • ethylene oxide residuals in accordance with ISO 10993-7:1995(R)2001; ●
  • shelf life studies in accordance with ASTM F1980-07 (2011), ISO 11607-1:2006 and ISO 11607-2:2006;
  • pyrogenicity testing (LAL Method);
  • range of motion and rotational freedom evaluation; ●
  • wear testing;
  • static shear testing; and
  • dynamic testing.

VIII. Conclusion

The information provided above supports that the GMK Hinge and GMK Revision are as safe and effective as their respective predicate devices. Although minor differences in design exist between the subject and predicate device tibial augmentation components, these differences are addressed by the performance testing included in this submission. Therefore, it is concluded that the GMK Hinge and GMK Revision system components are substantially equivalent to their respective predicate devices.