K Number
K193038
Device Name
Comprehensive Shoulder System
Date Cleared
2020-10-28

(363 days)

Product Code
Regulation Number
888.3670
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
- 1. Non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis. - 2. Rheumatoid arthritis. - 3. Correction of functional deformity. - 4. Fractures of the proximal humerus, where other methods of treatment are deemed inadequate. 5. Difficult clinical management problems, including cuff arthropathy, where other methods of treatment may not be suitable or may be inadequate. Optional use in revision: in some medical conditions (e.g. revision when healthy and good bone stock exists), the surgeon may opt to use primary implants in a revision procedure. Humeral components with a porous coated surface coating are indicated for either cemented biological fixation applications. The Comprehensive Modular Hybrid Glenoid is intended to be implanted with bone cement. The optional porous titanium peg may be inserted without bone cement. The optional polyethylene peg should be inserted with bone cement. The Comprehensive Humeral Positioning Sleeves are for cemented use only and are intended for use with the Comprehensive Fracture Stem. The Versa-Dial Humeral Head Prosthesis is intended for use only with the Comprehensive Shoulder Stems (Fracture, Primary and Revision), and the glenoid components of the Comprehensive Shoulder System. The Titanium Versa-Dial Humeral Head Prosthesis is indicated for patients with suspected cobalt alloy sensitivity. The wear properties of Titanium and Titanium alloys are inferior to that of cobalt alloy. A Titanium humeral head is not recommended for patients who lack suspected material sensitivity to cobalt alloy.
Device Description
Comprehensive Shoulder System consists of partial and total shoulder replacement components use in cemented and uncemented applications. The devices are modular components consisting of humeral stems, modular heads and glenoid components.
More Information

No
The document describes a traditional mechanical shoulder replacement system and does not mention any AI or ML components or functionalities.

Yes
The device is a "Comprehensive Shoulder System" intended for "partial and total shoulder replacement," which are procedures to treat various medical conditions like osteoarthritis, rheumatoid arthritis, and fractures to restore function, thus qualifying it as a therapeutic device.

No

Explanation: The device is a shoulder replacement system (prosthesis), which is an implantable medical device used to treat joint diseases and fractures, not to diagnose them.

No

The device description clearly states it consists of physical components (humeral stems, modular heads, and glenoid components) used in shoulder replacement, indicating it is a hardware device, not software-only.

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

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant for replacing parts of the shoulder joint to treat various conditions like osteoarthritis, rheumatoid arthritis, fractures, and deformities. This is a therapeutic intervention, not a diagnostic test performed on samples taken from the body.
  • Device Description: The device is described as a system of modular components for shoulder replacement (humeral stems, heads, and glenoid components). These are physical implants.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens (blood, tissue, etc.) to provide information for diagnosis, monitoring, or screening. The performance studies focus on mechanical properties (fatigue, porous coating) and biocompatibility, which are relevant to surgical implants, not diagnostic tests.

Therefore, the Comprehensive Shoulder System is a surgical implant, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

    1. Non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis.
    1. Rheumatoid arthritis.
    1. Correction of functional deformity.
    1. Fractures of the proximal humerus, where other methods of treatment are deemed inadequate.
    1. Difficult clinical management problems, including cuff arthropathy, where other methods of treatment may not be suitable or may be inadequate.

Optional use in revision: in some medical conditions (e.g. revision when healthy and good bone stock exists), the surgeon may opt to use primary implants in a revision procedure.

Humeral components with a porous coated surface coating are indicated for either cemented biological fixation applications.

The Comprehensive Modular Hybrid Glenoid is intended to be implanted with bone cement. The optional porous titanium peg may be inserted without bone cement. The optional polyethylene peg should be inserted with bone cement.

The Comprehensive Humeral Positioning Sleeves are for cemented use only and are intended for use with the Comprehensive Fracture Stem.

The Versa-Dial Humeral Head Prosthesis is intended for use only with the Comprehensive Shoulder Stems (Fracture, Primary and Revision), and the glenoid components of the Comprehensive Shoulder System.

The Titanium Versa-Dial Humeral Head Prosthesis is indicated for patients with suspected cobalt alloy sensitivity. The wear properties of Titanium and Titanium alloys are inferior to that of cobalt alloy. A Titanium humeral head is not recommended for patients who lack suspected material sensitivity to cobalt alloy.

Product codes

MBF, KWT, KWS, HSD

Device Description

Comprehensive Shoulder System consists of partial and total shoulder replacement components use in cemented and uncemented applications. The devices are modular components consisting of humeral stems, modular heads and glenoid components.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Shoulder

Indicated Patient Age Range

Not Found

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 Tests:

  • Fatigue testing of Titanium Allov Forged Humeral Stems. Titanium Alloy Wrought Humeral Stems and Cobalt Alloy Humeral Stems was conducted. Five samples of each type were subjected to a fatigue load of 400N or greater for 5 million cycles in reverse configuration at a worst case orientation. All samples withstood the applied fatigue without fracture of the stem.
  • Porous coating characterization
  • Biocompatibility
    Clinical Tests:
  • None provided

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K060692

Reference Device(s)

K033506, K040610, K060694, K060716, K140390, K140652

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 888.3670 Shoulder joint metal/polymer/metal nonconstrained or semi-constrained porous-coated uncemented prosthesis.

(a)
Identification. A shoulder joint metal/polymer/metal nonconstrained or semi-constrained porous-coated uncemented prosthesis is a device intended to be implanted to replace a shoulder joint. The device limits movement in one or more planes. It has no linkage across-the-joint. This generic type of device includes prostheses that have a humeral component made of alloys such as cobalt-chromium-molybdenum (Co-Cr-Mo) and titanium-aluminum-vanadium (Ti-6Al-4V) alloys, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, or a combination of an articulating ultra-high molecular weight bearing surface fixed in a metal shell made of alloys such as Co-Cr-Mo and Ti-6Al-4V. The humeral component and glenoid backing have a porous coating made of, in the case of Co-Cr-Mo components, beads of the same alloy or commercially pure titanium powder, and in the case of Ti-6Al-4V components, beads or fibers of commercially pure titanium or Ti-6Al-4V alloy, or commercially pure titanium powder. The porous coating has a volume porosity between 30 and 70 percent, an average pore size between 100 and 1,000 microns, interconnecting porosity, and a porous coating thickness between 500 and 1,500 microns. This generic type of device is designed to achieve biological fixation to bone without the use of bone cement.(b)
Classification. Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance: Shoulder Joint Metal/Polymer/Metal Nonconstrained or Semi-Constrained Porous-Coated Uncemented Prosthesis.”

0

October 28, 2020

Image /page/0/Picture/1 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Biomet Manufacturing Corp. Patricia Beres Regulatory Affairs Principal 56 East Bell Drive Warsaw, Indiana 46580 USA

Re: K193038

Trade/Device Name: Comprehensive Shoulder System Regulation Number: 21 CFR 888.3670 Regulation Name: Shoulder joint metal/polymer/metal nonconstrained or semi-sonstrained porouscoated uncemented prosthesis Regulatory Class: Class II Product Code: MBF. KWT. KWS. HSD Dated: October 20, 2020 Received: October 21, 2020

Dear Patricia Beres:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

for Michael Owens Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K193038

Device Name Comprehensive Shoulder System

Indications for Use (Describe)

    1. Non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis.
    1. Rheumatoid arthritis.
    1. Correction of functional deformity.
    1. Fractures of the proximal humerus, where other methods of treatment are deemed inadequate.
  1. Difficult clinical management problems, including cuff arthropathy, where other methods of treatment may not be suitable or may be inadequate.

Optional use in revision: in some medical conditions (e.g. revision when healthy and good bone stock exists), the surgeon may opt to use primary implants in a revision procedure.

Humeral components with a porous coated surface coating are indicated for either cemented biological fixation applications.

The Comprehensive Modular Hybrid Glenoid is intended to be implanted with bone cement. The optional porous titanium peg may be inserted without bone cement. The optional polyethylene peg should be inserted with bone cement.

The Comprehensive Humeral Positioning Sleeves are for cemented use only and are intended for use with the Comprehensive Fracture Stem.

The Versa-Dial Humeral Head Prosthesis is intended for use only with the Comprehensive Shoulder Stems (Fracture, Primary and Revision), and the glenoid components of the Comprehensive Shoulder System.

The Titanium Versa-Dial Humeral Head Prosthesis is indicated for patients with suspected cobalt alloy sensitivity. The wear properties of Titanium and Titanium alloys are inferior to that of cobalt alloy. A Titanium humeral head is not recommended for patients who lack suspected material sensitivity to cobalt alloy.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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510(k) Summary

In accordance with 21 CFR §807.92 and the Safe Medical Devices Act of 1990, the following information is provided for the Comprehensive Shoulder System 510(k) premarket notification. The submission was prepared in accordance with the FDA guidance document, 'Format for Traditional and Abbreviated 510(k)s', issued on August 12, 2005.

| Sponsor: | Biomet Inc.
56 East Bell Drive
PO Box 587
Warsaw, IN 46581
Establishment Registration Number: 1825034 |
|-----------------|-------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Patricia Sandborn Beres
Regulatory Affairs Principal
Telephone: (574-267-6639 ext. 1278)
Fax: fax (574-372-1683) |
| Date: | October 8, 2020 |
| Subject Device: | Trade Name: Comprehensive Shoulder System
Common Name: Shoulder replacement prosthesis |
| | Classification Name: |
| | • MBF - Shoulder joint metal/polymer/metal nonconstrained or
semi-constrained porous-coated uncemented prosthesis (21 CFR
888.3670) |
| | • HSD – Shoulder joint humeral (hemi-shoulder) metallic
uncemented prosthesis (21 CFR 888.3690) |
| | • KWS - Shoulder joint, metal/polymer, semi-constrained, cemented
prosthesis (21 CFR 888.3660) |
| | • KWT - Shoulder joint metal/polymer non-constrained cemented
prosthesis (21 CFR 888.3650) |

Predicate Device(s):

Primary Predicate510(k) Number
Comprehensive Primary ShoulderK060692
Reference Predicates510(k) Number
Comprehensive Humeral Fracture Positioning SleevesK033506
Versa-Dial Humeral Head ProsthesesK040610
Comprehensive Modular Hybrid GlenoidK060694
Versa-Dial Humeral HeadsK060716
Titanium Versa-Dial Humeral HeadsK140390
Comprehensive Porous Coated Fracture StemK140652

4

Purpose and Device

Comprehensive Shoulder System consists of partial and total shoulder replacement components use in cemented and uncemented applications. The devices are modular components consisting of humeral stems, modular heads and glenoid components.

The components of the Comprehensive Anatomic Shoulder System contained in this submission have all previously been cleared. The purpose of this submission is:

  • . To update the indications to meet global regulatory requirements;
  • · To document changes made to the system since original clearance;
  • To insure that all of the instrumentation/accessories for use with this system are . appropriately associated with a 510(k)

Intended Use and Indications for Use:

    1. Non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis.
  • Rheumatoid arthritis. 2.
    1. Correction of functional deformity.
    1. Fractures of the proximal humerus, where other methods of treatment are deemed inadequate.
    1. Difficult clinical management problems, including cuff arthropathy, where other methods of treatment may not be suitable or may be inadequate.

Optional use in revision: in some medical conditions (e.g. revision when healthy and good bone stock exists), the surgeon may opt to use primary implant in a revision procedure.

Humeral components with a porous coated surface coating are indicated for either cemented or uncemented biological fixation applications.

The Comprehensive Modular Hybrid Glenoid is intended to be implanted with bone cement. The optional porous titanium peg may be inserted without bone cement. The optional polyethylene peg should be inserted with bone cement.

The Comprehensive Humeral Positioning Sleeves are for cemented use only and are intended for use with the Comprehensive Fracture Stem.

The Versa-Dial Humeral Head Prosthesis is intended for use only with the Comprehensive Shoulder Stems (Fracture, Primary and Revision), and the glenoid components of the Comprehensive Shoulder System.

The Titanium Versa-Dial Humeral Head Prosthesis is indicated for patients with suspected cobalt alloy sensitivity. The wear properties of Titanium alloys are inferior to that of cobalt alloy. A Titanium humeral head is not recommended for patients who lack suspected material sensitivity to cobalt alloy.

5

Summary of Technological

The rationale for substantial equivalence is based on consideration of Characteristics: the following characteristics:

  • Intended Use: Similar to predicate ●
  • Indications for Use: Identical to predicate ●
  • Materials: Identical to predicate; alternate for humeral stems and ● humeral heads
  • Design Features: Identical to predicate ●
  • Sterilization: Identical to predicate ●

Summary of Performance Data

(Nonclinical and/or Clinical)

  • . Non-Clinical Tests:
    • o Fatigue testing of Titanium Allov Forged Humeral Stems. Titanium Alloy Wrought Humeral Stems and Cobalt Alloy Humeral Stems was conducted. Five samples of each type were subjected to a fatigue load of 400N or greater for 5 million cycles in reverse configuration at a worst case orientation. All samples withstood the applied fatigue without fracture of the stem.
    • o Porous coating characterization
    • o Biocompatibility
  • . Clinical Tests:
    • 0 None provided

Substantial Equivalence

Conclusion

The proposed Comprehensive Shoulder System has the same intended use and indications for use as the predicate devices. The proposed devices have similar technological characteristics to the predicates, and the information provided herein demonstrates that:

  • any differences do not raise new questions of safety and ● effectiveness; and
  • . the proposed devices are at least as safe and effective as the legally marketed predicate devices.