K Number
K202207
Device Name
Materialise PKA Guide System
Manufacturer
Date Cleared
2020-10-02

(57 days)

Product Code
Regulation Number
888.3520
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Hardware · Guides The Materialise PKA Guides are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components and in guiding the marking of bone before cutting of the bone. The Materialise PKA Guides must be used in conjunction with the compatible prostheses families only: ZUK UNI. JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System. The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014. The Materialise PKA Guides are intended for single use only. • Models The Materialise PKA Models are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components. The Materialise PKA Models must be used in conjunction with the compatible prostheses families only: ZUK UNI, JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System. The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014. The Materialise PKA Models are intended for single use only. Software The SurgiCase Knee Planner is intended to be used as a pre-surgical planner for knee orthopedic surgery. The software is used to pre-operatively plan the positioning of knee components. The SurgiCase Knee Planner allows the surgeon to visualize, measure, reconstruct, annotate and edit pre-surgical plan data. The generation of a surgery report along with a pre-surgical plan data file which is used as input data to design the Materialise Knee Guides and Models.
Device Description
The Materialise PKA guide system is a medical device designed to implant a partial knee prosthesis during partial knee arthroplasty surgical procedures. The device is a system that consists of the following two functional components: - . A software component, branded as SurgiCase Knee Planner. This software is a planning tool used to generate a pre-surgical PKA plan for a specific patient. - . A hardware component, branded as Materialise PKA Guides and Models, which are patientspecific guides and models that are based on a pre-surgical plan. This pre-surgical plan is generated using the software component. Materialise PKA Guides and Models is an instrument set containing a femur and/or tibia guide (s) and bone models (optional). Both femoral and tibial guides are designed and manufactured to fit the anatomy of a specific patient. If the surgeon requests it, a bone model of the femur and tibia is delivered with the Materialise PKA Guides. The Materialise PKA Guides and Models assist in the intra-operative positioning of partial knee replacement components. The guides assist in guiding the marking of bone before cutting and cutting of the bone. The models serve as a visual reference for the surgeon in the operating room. The Materialise PKA Guides and Models must only be used within the intended use of the compatible components (510(k) cleared, legally marketed prosthesis).
More Information

P010014

No
The summary describes software for pre-surgical planning and patient-specific guides/models based on that plan. There is no mention of AI or ML in the intended use, device description, or performance studies. The software's function is described as visualization, measurement, reconstruction, annotation, and editing, which are standard image processing and planning tools, not indicative of AI/ML.

No
The device is a surgical instrument and planning tool used during partial knee arthroplasty, not a therapeutic device. It assists in positioning components and guiding bone marking/cutting, but does not directly treat or cure a disease or condition.

No

The device, described as "Materialise PKA Guide System," is intended for pre-surgical planning and intra-operative guidance for partial knee replacement, and it explicitly states its role in assisting in the positioning of components and guiding bone marking/cutting. It does not mention any diagnostic capabilities.

No

The device description explicitly states that the system consists of both a software component (SurgiCase Knee Planner) and a hardware component (Materialise PKA Guides and Models).

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health.
  • Device Function: The Materialise PKA Guide System is a surgical planning and guidance system used during surgery to assist in the positioning of knee replacement components and guide bone cutting. It uses patient imaging data (MRI) to create patient-specific guides and models.
  • Lack of Specimen Analysis: The device does not analyze any biological specimens from the patient. Its function is entirely focused on surgical planning and intra-operative guidance based on anatomical imaging.

Therefore, the device falls under the category of surgical instruments and planning software, not In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

Hardware

  • Guides
    The Materialise PKA Guides are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components and in guiding the marking of bone before cutting of the bone.

The Materialise PKA Guides must be used in conjunction with the compatible prostheses families only: ZUK UNI. JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System.

The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014.

The Materialise PKA Guides are intended for single use only.

  • Models
    The Materialise PKA Models are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components.

The Materialise PKA Models must be used in conjunction with the compatible prostheses families only: ZUK UNI, JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System.

The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014.

The Materialise PKA Models are intended for single use only.

Software

The SurgiCase Knee Planner is intended to be used as a pre-surgical planner for knee orthopedic surgery. The software is used to pre-operatively plan the positioning of knee components. The SurgiCase Knee Planner allows the surgeon to visualize, measure, reconstruct, annotate and edit pre-surgical plan data. The generation of a surgery report along with a pre-surgical plan data file which is used as input data to design the Materialise Knee Guides and Models.

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

HSX, OOG

Device Description

The Materialise PKA guide system is a medical device designed to implant a partial knee prosthesis during partial knee arthroplasty surgical procedures.

The device is a system that consists of the following two functional components:

  • . A software component, branded as SurgiCase Knee Planner. This software is a planning tool used to generate a pre-surgical PKA plan for a specific patient.
  • . A hardware component, branded as Materialise PKA Guides and Models, which are patientspecific guides and models that are based on a pre-surgical plan. This pre-surgical plan is generated using the software component. Materialise PKA Guides and Models is an instrument set containing a femur and/or tibia guide (s) and bone models (optional). Both femoral and tibial guides are designed and manufactured to fit the anatomy of a specific patient. If the surgeon requests it, a bone model of the femur and tibia is delivered with the Materialise PKA Guides. The Materialise PKA Guides and Models assist in the intra-operative positioning of partial knee replacement components. The guides assist in guiding the marking of bone before cutting and cutting of the bone. The models serve as a visual reference for the surgeon in the operating room.

The Materialise PKA Guides and Models must only be used within the intended use of the compatible components (510(k) cleared, legally marketed prosthesis).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

MRI images

Anatomical Site

Knee

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Qualified surgeon / 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

New software validation/verification testing of the SurgiCase Knee Planner was done in support of this premarket notification in the form of end-user evaluations.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The non-clinical performance testing indicates that the subject device is as safe, as effective, and performs as well as the predicate device. Therefore it can be concluded that the Materialise PKA Guide System is substantial equivalent to the predicate device. The Materialise PKA Guide System will be manufactured in compliance with FDA (CFR 820 & Part 11) and ISO quality system (13485) requirements.

Hardware: Previous testing for cleaning, debris, dimensional stability and packaging are applicable to the subject device and demonstrate substantial equivalence with the predicate device. Testing verified that the accuracy and performance of the system is adequate to perform as intended. The stability of the device placement, surgical technique, intended use and functional elements of the subject device are similar as that of the predicate device, and therefore previous simulated surgeries using rapid prototyped bone models and previous cadaver testing are considered applicable to the subject device.
-Biocompatibility re-evaluation according to the new ISO 10993-1:2008 was done. The subject device was shown to be non-cytotoxic, non-sensitizing, non-irritant, non-systematically toxic (acute) and nonpyrogenic.

  • Sterilization re-evaluation using an overkill method partial cycle in accordance with ISO 17665-1:2006 on a new worst case design. All samples passed the sterilization the applied sterilization parameters for the subject device.

Software: New software validation/verification testing of the SurgiCase Knee Planner was done in support of this premarket notification in the form of end-user evaluations.

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.

K173970

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.

P010014

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

§ 888.3520 Knee joint femorotibial metal/polymer non-constrained cemented prosthesis.

(a)
Identification. A knee joint femorotibial metal/polymer non-constrained cemented prosthesis is a device intended to be implanted to replace part of a knee joint. The device limits minimally (less than normal anatomic constraints) translation in one or more planes. It has no linkage across-the-joint. This generic type of device includes prostheses that have a femoral condylar resurfacing component or components made of alloys, such as cobalt-chromium-molybdenum, and a tibial component or components made of ultra-high molecular weight polyethylene and are intended for use with bone cement (§ 888.3027).(b)
Classification. Class II.

0

October 2, 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 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.

Materialise NV Veerle Vanderheyden Regulatory Affairs specialist Technologielaan 15 Leuven, 3001 Belgium

Re: K202207

Trade/Device Name: Materialise PKA Guide System Regulation Number: 21 CFR 888.3520 Regulation Name: Knee Joint Femorotibial Metal/Polymer Non-Constrained Cemented Prosthesis Regulatory Class: Class II Product Code: HSX, OOG Dated: August 4, 2020 Received: August 6, 2020

Dear Veerle Vanderheyden:

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

1

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 mediation-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, Ph.D., R.A.C. 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

2

Indications for Use

510(k) Number (if known) K202207

Device Name Materialise PKA Guide System

Indications for Use (Describe) Hardware

· Guides

The Materialise PKA Guides are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components and in guiding the marking of bone before cutting of the bone.

The Materialise PKA Guides must be used in conjunction with the compatible prostheses families only: ZUK UNI. JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System.

The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014.

The Materialise PKA Guides are intended for single use only.

• Models

The Materialise PKA Models are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components.

The Materialise PKA Models must be used in conjunction with the compatible prostheses families only: ZUK UNI, JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System.

The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014.

The Materialise PKA Models are intended for single use only.

Software

The SurgiCase Knee Planner is intended to be used as a pre-surgical planner for knee orthopedic surgery. The software is used to pre-operatively plan the positioning of knee components. The SurgiCase Knee Planner allows the surgeon to visualize, measure, reconstruct, annotate and edit pre-surgical plan data. The generation of a surgery report along with a pre-surgical plan data file which is used as input data to design the Materialise Knee Guides and Models.

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.

3

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4

510(k) Premarket Notification

1 510(k) Summary

The following section is included as required by the Safe Medical Devices Act (SMDA) of 1990 and 21CFR 807.92

Company nameMaterialise N.V.
Establishment registration number3003998208
Street AddressTechnologielaan 15
CityLeuven
Postal code3001
CountryBelgium
Phone number+32 16 39 62 80
Fax number+32 16 39 66 06
Principal Contact personVeerle Vanderheyden
Contact titleRegulatory Affairs Specialist
Contact e-mail addressRegulatory.Affairs@materialise.be
Additional contact personBrecht Heyde
Contact titleSoftware product manager
Contact e-mail addressBrecht.heyde@materialise.be

Submission date

The date of the Traditional 510(k) submission is August 4, 2020.

Submission information

Device NameMaterialise PKA Guide System
Trade NameMaterialise Knee Guides and Models
SurgiCase Knee Planner
Visionaire UNI Cutting Guides
Visionaire UNI Bone Model
Signature Guides
Zimmer Patient Specific Instruments
Zimmer Biomet Patient Specific Instruments.
Common Name3D planning software and patient specific instrumentation for
knee replacement
Classification NameKnee joint patellofemorotibial polymer /metal /polymer semi-
constrained cemented prosthesis
Primary product codeHSX (21 CFR 888.3520)
Subsequent product codesOOG

5

510(k) Premarket Notification

Predicate Device

The predicate device to which substantial equivalence is claimed:

Trade or proprietary or model nameMaterialise PKA Guide System
510(k) numberK173970
Decision dateJuly 6, 2018
Classification product codeHSX (21 CFR 888.3520)
Subsequent product codesOOG
ManufacturerMaterialise N.V.

Device Description

The Materialise PKA guide system is a medical device designed to implant a partial knee prosthesis during partial knee arthroplasty surgical procedures.

The device is a system that consists of the following two functional components:

  • . A software component, branded as SurgiCase Knee Planner. This software is a planning tool used to generate a pre-surgical PKA plan for a specific patient.
  • . A hardware component, branded as Materialise PKA Guides and Models, which are patientspecific guides and models that are based on a pre-surgical plan. This pre-surgical plan is generated using the software component. Materialise PKA Guides and Models is an instrument set containing a femur and/or tibia guide (s) and bone models (optional). Both femoral and tibial guides are designed and manufactured to fit the anatomy of a specific patient. If the surgeon requests it, a bone model of the femur and tibia is delivered with the Materialise PKA Guides. The Materialise PKA Guides and Models assist in the intra-operative positioning of partial knee replacement components. The guides assist in guiding the marking of bone before cutting and cutting of the bone. The models serve as a visual reference for the surgeon in the operating room.

The Materialise PKA Guides and Models must only be used within the intended use of the compatible components (510(k) cleared, legally marketed prosthesis).

6

510(k) Premarket Notification

Intended Use

Hardware

  • Guides
    The Materialise PKA Guides are intended to be used as a surgical instrument to assist in the intra-operative positioning of Partial Knee Replacement components and in guiding the marking of bone before cutting and to guide cutting of the bone.

The Materialise PKA Guides must be used in conjunction with the compatible prostheses families only: ZUK UNI, JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System.

The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014.

The Materialise PKA Guides are intended for single use only.

● Models

The Materialise PKA Models are intended to be used as a surgical instrument to assist in the intraoperative positioning of Partial Knee Replacement components.

The Materialise PKA Models must be used in conjunction with the compatible prostheses families only: ZUK UNI, JOURNEY™ UNI, JOURNEY II UNI, JZ (Hybrid) UNI knee systems, Vanguard™ M Unicompartmental Knee System, Oxford® Partial Knee System and Persona® Partial Knee System.

The Zimmer Biomet Patient Specific Instruments are compatible for use with the Oxford® Partial Knee System as approved in P010014.

The Materialise PKA Models are intended for single use only.

Software

The SurqiCase Knee Planner is intended to be used as a pre-surgical planner for knee orthopedic surgery. The software is used to pre-operatively plan the positioning of knee components. The SurgiCase Knee Planner allows the surgeon to visualize, measure, reconstruct, annotate and edit pre-surgical plan data. The software leads to the generation of a surgery report along with a pre-surgical plan data file which is used as input data to design the Materialise Knee Guides and Models.

Functioning of the Device

The Materialise PKA Guide System generates a pre-surgical plan based on MRI images using the SurgiCase Knee Planner. The SurgiCase Knee Planner then is used pre-operatively by a qualified surgeon to inspect, fine-tune and approve the pre-surgical plan. Next, Materialise PKA Guides and Models (models are optional) are designed and manufactured based on the approved pre-surgical plan. Moterialise PKA Guides are patient specific templates which transfer the pre-operatively determined positioning of the chosen partial knee replacement components to the patient intra-operatively, assisting the surgeon in positioning and aligning the actual partial knee replacement components by guiding the marking of bone before cutting and to guide cutting of the bone. The models serve as a visual reference for the surgeon in the operating room.

7

510(k) Summary

510(k) Premarket Notification

Technological Characteristics

The Materialise PKA Guide System has an equivalent intended use and the same fundamental scientific technology as the predicate device. The subject device's software is intended simulation and planning of preoperational intervention, and for positioning knee components, i.e. tibia and femur components (same as the predicate device). The subject device's hardware is intended for positioning knee components intra-operatively and in guiding the marking of bone before cutting and to guide cutting of the bone (same as the predicate device).

Software

The subject software device employs similar fundamental technologies as the predicate software device. Technological similarities include:

  • . Device functionality: The planning functionality, visualization options and planning features are the same for the knee planning of the subject device as for the predicate device.
  • o Software technology: The subject device has the same code base as the predicate device and uses exactly the same methods for design and verification and validation as the predicate device.

Following technological differences exist between the subject device software and the predicate device software:

  • The main difference between the subject device and previously cleared predicate device K173970 is the addition of the Persona® Partial Knee (PPK) implants and instruments in the software component of the subject device for the surgeon to select during the planning stage.
    The subject software technology differences have been demonstrated to not affectiveness or raise new issues of safety or effectiveness compared to the predicate device.

Hardware

The subject hardware device is substantially equivalent in intended use, design, functionality, operating principles, materials and performance characteristics to the predicate device.

The main difference between the subject device and previously cleared predicate device K173970 include:

  • The addition of Materialise PKA Guides and Models that are compatible with the Persona® Partial Knee (PPK) system. This resulted in the update of non-critical features of the PKA tibia guide that will be used for this system.

Performance Data (non-clinical)

Hardware

Previous testing for cleaning, debris, dimensional stability and packaging are applicable to the subject device and demonstrate substantial equivalence with the predicate device. Testing verified that the accuracy and performance of the system is adequate to perform as intended. The stability of the device placement, surgical technique, intended use and functional elements of the subject device are similar as that of the predicate device, and therefore previous simulated surgeries using rapid prototyped bone models and previous cadaver testing are considered applicable to the subject device.

8

K202207 Page 5 of 5

Materialise PKA Guide System

510(k) Summary

510(k) Premarket Notification

Although no additional tests in comparison with the predicate device testing were required to support substantial equivalence, new biocompatibility and sterilization testing has been done for other reasons as explained in section below.

  • -Biocompatibility re-evaluation according to the new ISO 10993-1:2008 was done. The subject device was shown to be non-cytotoxic, non-sensitizing, non-irritant, non-systematically toxic (acute) and nonpyrogenic.
  • Sterilization re-evaluation using an overkill method partial cycle in accordance with ISO 17665-1:2006 on a new worst case design. All samples passed the sterilization the applied sterilization parameters for the subject device.

Software

New software validation/verification testing of the SurgiCase Knee Planner was done in support of this premarket notification in the form of end-user evaluations.

Summary

The non-clinical performance testing indicates that the subject device is as safe, as effective, and performs as well as the predicate device. Therefore it can be concluded that the Materialise PKA Guide System is substantial equivalent to the predicate device. The Materialise PKA Guide System will be manufactured in compliance with FDA (CFR 820 & Part 11) and ISO quality system (13485) requirements.