K Number
K220483
Date Cleared
2022-09-23

(217 days)

Product Code
Regulation Number
888.3353
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Klassic HD® Hip System is intended for prosthetic replacement without bone cement in treatment of the following:

  • Patient conditions of non-inflammatory degenerative joint disease (NIDJD): avascular . necrosis, osteoarthritis, ankylosis, protrusio acetabuli and painful hip dysplasia.
  • Patient conditions of inflammatory joint disease (IJD): rheumatoid arthritis.
  • Those patients with failed previous surgery where pain, deformity, or dysfunction persists. ●
  • Revision of a previously failed hip arthroplasty. ●
  • Patients who require a total hip replacement. ●
Device Description

The Klassic HD Hip System employs prostheses designed to help surgeons restore hip joint biomechanics. The purpose of this 510(k) is to add the Platform Acetabular System consisting of the Platform Acetabular Shell with Ti-Coat and Platform Acetabular Inserts with E-Link (Neutral and Hooded) to the Klassic HD Hip System. The Platform Acetabular Shells are fabricated from Ti6Al4V per ASTM F136 and the Platform Acetabular Inserts with E-Link are made from Vitamin E. UHMWPE material. The subject acetabular components are available in various sizes ranging in outer diameters of 44mm to 64mm to match patient anatomy and are compatible with 28mm, 32mm, and 36mm heads. The subject components are provided sterile, for single use, by prescription only.

AI/ML Overview

The provided document is a 510(k) Premarket Notification from the U.S. Food and Drug Administration (FDA) for the Platform® Acetabular System. This document does not describe a study involving an AI/Machine Learning device, nor does it present acceptance criteria and performance data for such a device in the manner requested.

Instead, this document pertains to a hip joint prosthesis, specifically acetabular components (shells and inserts). The "performance data" discussed relates to mechanical and material testing of these implantable devices, not to an AI's diagnostic or predictive capabilities.

Therefore, I cannot fulfill the request to describe the acceptance criteria and the study proving the device (AI/ML) meets these criteria, as the provided text describes a medical implant. The information in the prompt about "AI vs without AI assistance," "standalone algorithm performance," "number of experts," and "ground truth" is not applicable to the content of this FDA clearance letter.

To answer your request, I would need a document describing the testing and validation of an AI/Machine Learning device.

However, I can extract the information relevant to the mechanical device described in this document:

1. Table of Acceptance Criteria and Reported Device Performance:

The document doesn't present a table with explicit "acceptance criteria" and "reported device performance" in the typical AI/ML context (e.g., sensitivity, specificity, AUC). Instead, it lists the types of non-clinical tests performed to demonstrate substantial equivalence to predicate devices. The implicit "acceptance criterion" for these tests is that the subject device's performance must be comparable to or better than the predicate devices and meet relevant ASTM/ISO standards to ensure safety and effectiveness.

Test PerformedImplied Acceptance Criterion (from a regulatory perspective)Reported Device Performance Summary (from document)
Push out testing (ASTM F1820-13)Performance comparable to predicate devices and within standard limits for secure fixation."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Lever out testing (ASTM F1820-13)Performance comparable to predicate devices and within standard limits."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Axial Torque Disassembly Testing (ASTM F1820-13)Performance comparable to predicate devices and within standard limits for construct stability."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Impingement Testing (ASTM F2582-20)Performance comparable to predicate devices and within standard limits for range of motion and impingement resistance."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Acetabular Shell Fatigue Testing (ASTM F3090-20)Resistance to fatigue comparable to predicate devices and meeting standard requirements for expected service life."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Deformation Testing (ISO 7206-12)Deformation properties comparable to predicate devices and within standard limits."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Material wear (engineering analysis)Wear characteristics comparable to predicate devices, demonstrating acceptable long-term performance."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
Range of motion (engineering analysis)Range of motion comparable to predicate devices, supporting intended function."Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate."
LAL testing requirementsCompliance with LAL (Limulus Amebocyte Lysate) testing for endotoxin levels to ensure sterility/safety."Additionally, the Klassic HD® Hip System is in compliance with LAL testing requirements for orthopedic implants."

2. Sample size used for the test set and data provenance:
This document describes physical and engineering tests on manufactured components (hip implants), not data analysis on a medical image dataset. Thus, "sample size for the test set" would refer to the number of physical components tested for each mechanical property, which is not specified in detail (e.g., "N=X components"). The "data provenance" is derived from these physical tests conducted by the manufacturer as part of their submission to the FDA. The tests are "non-clinical" (i.e., not involving human subjects).

3. Number of experts used to establish the ground truth for the test set and qualifications of those experts (e.g. radiologist with 10 years of experience):
Not applicable. "Ground truth" in this context refers to established engineering and material science standards (ASTM, ISO). Expert mechanical engineers and material scientists would design and interpret these tests, but it's not analogous to clinical expert consensus for image labeling.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
Not applicable. This is not a clinical study involving human readers or interpretation.

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:
Not applicable. This document is not about an AI device.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
Not applicable. This document is not about an AI device.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):
The "ground truth" for the material and mechanical properties of the device is established by ASTM and ISO international standards for orthopedic implants, and the comparative performance to legally marketed predicate devices.

8. The sample size for the training set:
Not applicable. This is not an AI/ML device that requires a training set.

9. How the ground truth for the training set was established:
Not applicable. This is not an AI/ML device.

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September 23, 2022

Total Joint Orthopedics, Inc. % Holly Rhodes Vice President, Orthopedic Regulatory Affairs MCRA, LLC 803 7th Street NW Washington, District of Columbia 20001

Re: K220483

Trade/Device Name: Platform® Acetabular System Regulation Number: 21 CFR 888.3353 Regulation Name: Hip joint metal/ceramic/polymer semi-constrained cemented or nonporous uncemented prosthesis Regulatory Class: Class II Product Code: LZO, LPH, MBL, OQG Dated: July 25, 2022 Received: July 25, 2022

Dear Holly Rhodes:

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.

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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 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-reporting-

combination-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,

Limin Sun, Ph.D. 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

· Patient conditions of inflammatory joint disease (IJD): rheumatoid arthritis.

510(k) Number (if known)

K220483

Device Name Platform® Acetabular System

Indications for Use (Describe)

ankylosis, protrusio acetabuli and painful hip dysplasia.

• Revision of a previously failed hip arthroplasty. · Patients who require a total hip replacement.

· Those patients with failed previous surgery where pain, deformity, or dysfunction persists.

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)

The Klassic HD Hip System is intended for prosthetic replacement in treatment of the following:

· Patient conditions of non-inflammatory degenerative joint disease (NIDJD): avascular necrosis, osteoarthritis,

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510(k) Summary

Manufacturer:Total Joint Orthopedics, Inc.1567 E. Stratford AvenueSalt Lake City, UT 84106Phone: 801.486.6070Fax: 801.486.6117
Contact:Mr. Chris WeaberDirector of Research and Development
Prepared By:MCRA, LLC803 7th Street NWWashington, DC 20001Phone: 202.552.5800Fax: 202.552.5798
Date Prepared:September 21, 2022
Device Trade Name:Platform® Acetabular System
Common Name:Acetabular Shell, Acetabular Inserts
Classifications:21 CFR 888.3353 - Hip joint metal/ceramic/polymer semi-constrained cemented or nonporous uncemented prosthesis21 CFR 888.3358 - Hip joint metal/polymer/metal semi-constrained porous-coated uncemented prosthesisClass II
Product Codes:LZO, LPH, MBL, OOG

Indications for Use:

The Klassic HD® Hip System is intended for prosthetic replacement without bone cement in treatment of the following:

  • Patient conditions of non-inflammatory degenerative joint disease (NIDJD): avascular . necrosis, osteoarthritis, ankylosis, protrusio acetabuli and painful hip dysplasia.
  • Patient conditions of inflammatory joint disease (IJD): rheumatoid arthritis.
  • Those patients with failed previous surgery where pain, deformity, or dysfunction persists. ●
  • Revision of a previously failed hip arthroplasty. ●
  • Patients who require a total hip replacement. ●

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Device Description:

The Klassic HD Hip System employs prostheses designed to help surgeons restore hip joint biomechanics. The purpose of this 510(k) is to add the Platform Acetabular System consisting of the Platform Acetabular Shell with Ti-Coat and Platform Acetabular Inserts with E-Link (Neutral and Hooded) to the Klassic HD Hip System. The Platform Acetabular Shells are fabricated from Ti6Al4V per ASTM F136 and the Platform Acetabular Inserts with E-Link are made from Vitamin E. UHMWPE material. The subject acetabular components are available in various sizes ranging in outer diameters of 44mm to 64mm to match patient anatomy and are compatible with 28mm, 32mm, and 36mm heads. The subject components are provided sterile, for single use, by prescription only.

Predicate Devices:

The modified Klassic HD Hip System is substantially equivalent to the predicate Klassic HD® Hip System (Primary predicate: K100445; Additional predicates: K141972, K173104, K180929) with respect to indications, design, material and function. The information summarized in this 510(k) demonstrates that the subject device is substantially equivalent to the identified predicate devices.

Comparison of Technological Characteristics:

The subject devices feature the same material (Ti6A14V per ASTM F136 and Vitamin E UHMWPE), same use as acetabular shells and liners, same articular interface design, same compatibility, and same sterilization as predicate shells and liners (K100445).

Discussion of Non-Clinical Testing/ Performance Data:

The subject device underwent push out testing, lever out testing, axial torque disassembly testing, impingement testing, acetabular shell fatigue testing, and deformation testing. In addition, engineering analysis was performed to evaluate material wear and range of motion for the subject devices. Additionally, the Klassic HD® Hip System is in compliance with LAL testing requirements for orthopedic implants.

Non-clinical testing and engineering analysis conducted to demonstrate substantial equivalence was as follows:

  • Material wear (via engineering analysis) of acetabular shells and liners ●
  • Range of motion (via engineering analysis)
  • Push out testing per ASTM F1820-13 ●
  • Lever out testing per ASTM F1820-13 ●
  • Axial Torque Disassembly Testing per ASTM F1820-13
  • Impingement Testing per ASTM F2582-20
  • Acetabular Shell Fatigue Testing per ASTM F3090-20
  • Deformation Testing per ISO 7206-12 .

Conclusion

Testing and engineering analyses demonstrated that the subject acetabular components perform as safe and effective compared to the predicate components and are substantially equivalent to the predicate.

§ 888.3353 Hip joint metal/ceramic/polymer semi-constrained cemented or nonporous uncemented prosthesis.

(a)
Identification. A hip joint metal/ceramic/polymer semi-constrained cemented or nonporous uncemented prosthesis is a device intended to be implanted to replace a hip joint. This device limits translation and rotation in one or more planes via the geometry of its articulating surfaces. It has no linkage across-the-joint. The two-part femoral component consists of a femoral stem made of alloys to be fixed in the intramedullary canal of the femur by impaction with or without use of bone cement. The proximal end of the femoral stem is tapered with a surface that ensures positive locking with the spherical ceramic (aluminium oxide, A12 03 ) head of the femoral component. The acetabular component is made of ultra-high molecular weight polyethylene or ultra-high molecular weight polyethylene reinforced with nonporous metal alloys, and used with or without bone cement.(b)
Classification. Class II.