The Vantage PSI System is intended to be used as patient specific surgical planning and instrumentation to assist in the positioning of total ankle replacement components intraoperatively, and in guiding bone cutting. The Vantage PSI System is intended for use with Exactech's Vantage Total Ankle System and its cleared indications for use.

Device Description

3D System's Vantage PSI System is patient-specific guides created to fit the contours of the patient's distal tibial and proximal talar anatomy. The guides and models are designed and manufactured from patient imaging data (CT) and are made from biocompatible nylon. The surgical guides in combination with Exactech Vantage Total Ankle reusable instruments, facilitate the positioning of Vantage Total Ankle Implants. 3D System's Vantage PSI System produces a variety of patient specific outputs including surgical guides, anatomic models, and case reports for use with Exactech's Vantage Total Ankle System (K152217 and K183343).

AI/ML Overview

Here's an analysis of the provided text regarding the acceptance criteria and study for the Vantage PSI System:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not provide a specific table of acceptance criteria with numerical targets and the corresponding device performance tied to those targets. Instead, it describes general compliance with standards and successful meeting of "all test method acceptance criteria" or "pre-defined acceptance criteria."

However, we can infer some performance aspects from the Cadaver Study / Design Validation.

Acceptance Criteria (Inferred from Study Design)	Reported Device Performance
Process Qualification: Manufacturing process and operator repeatability within digital workflow met design specifications.	All test method acceptance criteria were met.
Cleaning Validation: Post-cleaning bioburden, protein, and hemoglobin levels met criteria.	All test method acceptance criteria were met.
Sterilization Validation: Steam sterilization achieved a sterility assurance level (SAL) of 10^-6.	All test method acceptance criteria were met.
Biocompatibility Validation: Cytotoxicity, sensitization, irritation, and acute systemic toxicity of polyamide and titanium alloy met criteria.	The battery of cytotoxicity, sensitization, irritation, and acute systemic toxicity testing conducted on the subject devices manufactured from polyamide and titanium alloy are within the pre-defined acceptance criteria. The results of the testing adequately address biocompatibility for the output devices and their intended use.
Packaging Validation: Compliance with 3D Systems Transportation Test Standard.	All test method acceptance criteria were met.
Shelf Life Validation: Verification of stated shelf life duration.	All test method acceptance criteria were met.
Debris Validation: Debris generation equivalent or better than published data.	The results of the testing perform equivalent or better than the values found in literature.
Cadaver Study / Design Validation: • 2D analysis: AP tibia varus/valgus, bearing-to-bearing, and lateral tibia measurement accuracy compared to pre-operative plan. • 3D analysis: Final implant placement accuracy (translations and rotations) compared to pre-operative plan. • Performance equivalent or better than standard instrumentation.	The results of both 2D and 3D analysis demonstrate the subject device performing equivalent or better than the Vantage Total Ankle standard instrumentation.

2. Sample Size Used for the Test Set and the Data Provenance

Sample Size for Cadaver Study: The document states that the cadaver and design validation studies utilized three surgeon users and compared the subject device to standard instrumentation. The number of cadavers or individual surgical procedures performed is not explicitly stated.
Data Provenance: Not specified, but given the nature of cadaver studies for device validation, it would be prospective data collection. The country of origin is not mentioned.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

The cadaver study involved three surgeon users.
Their specific qualifications (e.g., years of experience, subspecialty) are not provided. They are simply referred to as "surgeon users."
It's implied these surgeons contributed to evaluating the outcome, but the document doesn't explicitly state they established the "ground truth." The ground truth appears to be derived from objective measurements (2D and 3D analysis) comparing actual placement to pre-operative plans.

4. Adjudication Method for the Test Set

The document does not specify an adjudication method for the cadaver study's results. It describes 2D and 3D analysis conducted but doesn't detail how discrepancies or interpretations between the three surgeon users, or between the measurements and the pre-operative plan, were resolved or adjudicated.

5. 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, an MRMC comparative effectiveness study was not done. The Vantage PSI System is a patient-specific surgical guide intended for use with total ankle replacement components and guiding bone cutting, not an AI-based diagnostic or interpretative system where human readers would interpret results with or without AI assistance.
The cadaver study was a comparative performance study between the device and standard instrumentation, not an AI assistance study.

6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done

The device itself (Vantage PSI System) is a physical surgical guide designed from imaging data via software, not a standalone algorithm that provides a diagnosis or output without human intervention. The "design and development process" involves software creating the guides based on patient imaging. The "performance testing" described primarily pertains to the physical aspects of the device and its manufacturing process, along with its accuracy in facilitating surgical procedures as a tool.
The closest to "algorithm only" performance would be the accuracy of the software-generated patient-specific guides and models against the patient data, which is implicitly covered by the "Process Qualification" and the "Cadaver Study / Design Validation" where the physical output is compared to the pre-operative plan. However, it's not a standalone diagnostic algorithm.

7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

For the cadaver study, the ground truth appears to be based on objective measurements derived from post-operative imaging (CT scans for 3D analysis, fluoroscopic images for 2D analysis) compared against the pre-operative plan. This combines objective measurement with a pre-defined target.

8. The Sample Size for the Training Set

The document does not provide information on a separate "training set" sample size. The Vantage PSI System involves designing patient-specific guides based on individual patient imaging (CT data), rather than a machine learning model that requires a discrete training dataset for algorithm development. The "design and development process" converts the CT data into a guide.

9. How the Ground Truth for the Training Set Was Established

As there is no explicit mention of a "training set" in the context of a machine learning algorithm, the process of establishing ground truth for such a set is not applicable based on the provided text. The "ground truth" for the device's function is the patient's anatomy derived from imaging and the surgeon's pre-operative plan based on that anatomy.

Summary

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November 9, 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.

3D Systems Kim Torluemke Vice President, Quality & Regulatory, Healthcare 5381 South Alkire Circle Littleton, Colorado 80127

Re: K193432

Trade/Device Name: Vantage PSI System Regulation Number: 21 CFR 888.3110 Regulation Name: Ankle Joint Metal/Polymer Semi-Constrained Cemented Prosthesis Regulatory Class: Class II Product Code: OYK Dated: November 5, 2020 Received: November 6, 2020

Dear Kim Torluemke:

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 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

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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 (OS) 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,

Ting Song, PhD, RAC Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known)

K193432

Device Name Vantage PSI System

Indications for Use (Describe)

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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510(K) SUMMARY

1. INTRODUCTION

This document contains the 510(k) summary for the Vantage™ PSI System. The content of this summary is based on the requirements of 21 CFR 807.92.

2. SUBMITTER

Name:	Medical Modeling - A 3D Systems Company
Address:	5381 South Alkire CircleLittleton, CO 80127, USAPhone: (720) 643-1001Fax: (720) 643-1009
Official Contact:	Kim TorluemkeVice President, Quality and Regulatory, Healthcare
Date Prepared:	November 5, 2020
DEVICE
Trade Name:	Vantage PSI System
Common Name:	Ankle surgical guide system
Classification Name:	Ankle Arthroplasty Implantation System
Classification:	Class II, 21 CFR 888.3110

Product Code: ОУК

4. PREDICATE DEVICES

Predicate device:

· PROPHECY® INVISION® Preoperative Navigation Alignment Guides, Wright Medical Technology, Inc.(K170968)
Reference devices:
VSP® Orthopedics System, 3D Systems Inc. (K190044)

5. DESCRIPTION OF THE DEVICE

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Image /page/4/Picture/0 description: The image shows the 3D Systems logo. The logo consists of a stylized cube with the number "3D" on its faces, followed by the text "3D SYSTEMS" in a simple, sans-serif font. The cube is rendered in a metallic silver color, giving it a modern and technological appearance. The text is in a similar color, creating a cohesive and professional brand identity.

Vantage Total Ankle Implants. 3D System's Vantage PSI System produces a variety of patient specific outputs including surgical guides, anatomic models, and case reports for use with Exactech's Vantage Total Ankle System (K152217 and K183343).

6. INTENDED USE

7. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE

The intended use and technological characteristics of the subject device (Vantage PSI System) are either identical or substantially equivalent to the predicate device (PROPHECY® Preoperative Navigation Alignment System):

The principles of operation and technological characteristics are all substantially equivalent between the Vantage PSI System and the identified predicate device. Specifically, the predicate device includes 3D printing of patient specific anatomical models and surgical guides with polyamide materials. Both have stainless steel accessories produced from a common subtractive manufacturing process.

The Vantage PSI System uses the same fundamental technologies as its predicate device. These include image transformation and manipulation via software that is subsequently used for 3D printing of anatomical models and guides and for surgical planning, only potentially differing in the software applications.

The outputs of the Vantage PSI System include materials commonly used in surgical instruments (stainless steel) and for surgical guides and anatomical models (biocompatible polyamide). These materials are substantially equivalent to those employed by the predicate, which also uses a polyamide material and stainless steel surgical instruments.

The Vantage PSI System Accessories are standardized stainless steel fluoroscopic inserts that are inserted into patient-specific guides to assist in alignment operations. The accessories are similar to those included with the predicate device, but differ in shape. The predicate device utilizes standard surgical pins. The subject device includes a specific single use tool to be used exclusively with the system. These accessories are sterilized by the healthcare facility with the same cycle as the other system outputs. The minor differences in accessory geometry does not change the intended use of the system, and does not raise new questions of safety and effectiveness.

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8. SUMMARY OF PERFORMANCE TESTING

The testing outlined below was intended to show that the output of the design and development process demonstrated compliance with the device specifications. Bench and cadaveric testing was conducted to prove the subject device performs in accordance with its intended use and is substantially equivalent to the listed predicate device.

The following testing was conducted in accordance with the listed consensus standards for the Vantage PSI System:

· Process Qualification

Process qualification was conducted to assess the manufacturing process as well as operator repeatability within the digital workflow. Cases utilized for testing were representative of ankle reconstruction procedures within the subject device's intended use. Both digital and physical outputs from all manufacturing processes were verified against design specifications. All test method acceptance criteria were met.

· Cleaning Validation

Cleaning validations were performed in accordance with AAMI TIR 30. Following soiling and cleaning of the subject devices, bioburden, protein levels, and hemoglobin levels were examined. All test method acceptance criteria were met.

• Sterilization Validation

Steam sterilization validations were performed for the dynamic-air-removal cycle in accordance with ISO 17665-1:2006 to a sterility assurance level (SAL) of 10* using the biological indicator (BI) overkill method. All test method acceptance criteria were met.

• Biocompatibility Validation

Biocompatibility endpoints were evaluated in accordance with ISO 10993-1. The battery of cytotoxicity, sensitization, irritation, and acute systemic toxicity testing conducted on the subject devices manufactured from polyamide and titanium alloy are within the pre-defined acceptance criteria. The results of the testing adequately address biocompatibility for the output devices and their intended use.

• Packaging Validation

Packaging validation was performed on all packaging configurations of the system. Testing was performed in accordance with the 3D Systems Transportation Test Standard (based on ASTM and National Motor Freight Classification standards). All test method acceptance criteria were met.

• Shelf Life Validation

Shelf life validation was conducted in accordance with ASTM F1980-16 to verify the stated shelf life duration. All test method acceptance criteria were met.

• Debris Validation

Debris generation validation was performed utilizing standard orthopedic instrumentation. Debris generation was evaluated and compared to published data. The results of the testing perform equivalent or better than the values found in literature.

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Image /page/6/Picture/0 description: The image shows the 3D Systems logo. The logo consists of a stylized 3D cube on the left and the text "3D SYSTEMS" on the right. The text is in a sans-serif font and is gray in color. The logo is clean and modern in appearance.

• Cadaver Study / Design Validation

Cadaveric and design validation studies were performed to compare the subject device to Vantage Total Ankle standard instrumentation. The cadaver and design validation studies utilized three surgeon users. 2D analysis was conducted by measuring AP tibia varus/valgus, bearing-to-bearing, and lateral tibia from intra-operative fluoroscopic images, and compared to the pre-operative plan. 3D analysis was conducted by comparing final implant placement to pre-operative implant placement. The 3D analysis consisted of post-operative CT image segmentation, STL alignments, and measurements. Translations were analyzed across three axis (medial/lateral, anterior/posterior, and distal/proximal) and rotations were analyzed across three axis (varus/valgus, plantarflexion/dorsiflexion, and internal/external). The results of both 2D and 3D analysis demonstrate the subject device performing equivalent or better than the Vantage Total Ankle standard instrumentation.

Summary

All design, process, and other verification and validation testing, which were conducted as a result of risk analyses and design impact assessments, showed conformity to pre-established specifications and acceptance criteria. The acceptance criteria was established in support of device performance, and testing demonstrated substantial equivalence of the system to the predicate device.

9. CONCLUSION

Based on a comparison of the intended use and technological characteristics, the Vantage PSI System is substantially equivalent to the identified predicate device. Minor differences in the indications for use, technological and performance characteristics do not raise new or different questions of safety and effectiveness. Additionally, the non-clinical testing supports that the system performs in accordance with its intended use and is as safe, as effective, and performs as well as the predicate device.

Regulation Number and Section

§ 888.3110 Ankle joint metal/polymer semi-constrained cemented prosthesis.

(a)
Identification. An ankle joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace an ankle joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces and has no linkage across-the-joint. This generic type of device includes prostheses that have a talar resurfacing component made of alloys, such as cobalt-chromium-molybdenum, and a tibial 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.