(90 days)
No
The summary describes a robotic-assisted surgical system with haptic guidance and software-defined spatial boundaries, but it does not mention or imply the use of AI or ML for tasks like image analysis, decision support, or predictive modeling. The term "intelligent" tool holder appears, but in the context of passive constraint based on software boundaries, not AI/ML.
No.
The device assists surgeons in orthopedic procedures by providing spatial boundaries and navigation, but it does not directly treat or diagnose a disease or condition.
No
The device is described as assisting the surgeon with surgical procedures and providing haptic guidance, pre-surgical planning, and intraoperative navigation. It does not provide a diagnosis.
No
The device description explicitly lists multiple hardware components including a robotic arm, integrated cutting system, optical detector, camera, computer, dedicated instrumentation, planning laptop, and tools and accessories.
Based on the provided information, the Mako System is not an IVD (In Vitro Diagnostic) device.
Here's why:
- Intended Use: The intended use clearly states that the Mako System is intended to "assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures." This describes a surgical guidance and assistance system, not a device used to examine specimens derived from the human body for the purpose of providing information for diagnosis, monitoring, or compatibility testing.
- Device Description: The description details a stereotactic instrument with a robotic arm, cutting system, optical detector, computer, etc., used for surgical planning and intraoperative navigation. This aligns with a surgical tool, not an IVD.
- Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, tissue, etc.), detecting analytes, or providing diagnostic information based on in vitro testing.
The Mako System is a surgical assistance and navigation system used during a surgical procedure, not a device used to perform tests outside the body on patient specimens.
N/A
Intended Use / Indications for Use
The Mako System is intended to assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures.
The Mako System is indicated for use in total hip arthroplasty procedures in which:
- the use of stereotactic surgery may be appropriate, and
- where reference to rigid anatomical bony structures can be identified relative to a CT-based model of the anatomy;
including revision total hip arthroplasty procedures where:
- the primary acetabular component is well-fixed to the pelvic anatomy, and
- the acetabular component can be revised with either a cup or cup and wedge augment construct.
These procedures include: Total Hip Arthroplasty (THA)
Product codes
OLO
Device Description
The Mako System with the subject Mako Total Hip Application is a stereotactic instrument that includes a robotic arm, an integrated cutting system, an optical detector, camera, a computer, dedicated instrumentation, operating software, a planning laptop, and tools and accessories.
The system's architecture is designed to support total and partial knee procedures and total hip procedures. With application specific hardware and software, the system provides haptic guidance during orthopedic surgical procedures by using patient CT data to assist a surgeon with pre-surgical planning, implant placement and interpretive / intraoperative navigation of the patient's anatomy.
Once configured for a specific application, the Mako robotic-arm can serve as the surgeon's "intelligent" tool holder or tool guide by passively constraining the preparation of an anatomical site for an orthopedic implant with software-defined spatial boundaries.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
CT
Anatomical Site
Hip (Pelvis, operative femur, non-operative femur)
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Surgeon, clinical setting (orthopedic procedures)
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)
The modified Mako System with the subject Mako Total Hip Application has been evaluated through the following non-clinical performance testing:
- Software testing
- Bone registration accuracy verification
- Bone resection accuracy verification
- System verification
- Simulated-Use Cadaveric Surgeon Validation
Conclusions:
The hardware and software of the subject Mako System with Mako Total Hip Application is similar to the hardware and software of the predicate Mako System with Mako Total Hip Application. The software modifications being made do not impact the intended use or the fundamental technology of the device. Furthermore, performance testing demonstrates that the characteristics of the subject Mako Total Hip Application are equivalent to the characteristics of the predicate device. The subject device is also as safe and as effective as the predicate device and does not raise different questions of safety and effectiveness. Therefore, the performance testing supports a determination of substantial equivalence.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 882.4560 Stereotaxic instrument.
(a)
Identification. A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.(b)
Classification. Class II (performance standards).
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March 5, 2025
Mako Surgical Corp. Rita Koremblum Senior Staff Regulatory Affairs Specialist 3365 Enterprise Avenue Weston, Florida 33331
Re: K243751
Trade/Device Name: Mako Total Hip Application 5.0 Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: December 4, 2024 Received: December 5, 2024
Dear Rita Koremblum:
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 (the 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 available 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.
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"
1
(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rue"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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
2
by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Shumaya Ali -S
Shumaya Ali, M.P.H. Assistant Director DHT6C: Division of Restorative, Repair and Trauma Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
3
Indications for Use
510(k) Number (if known) K243751
Device Name Mako Total Hip Application 5.0
Indications for Use (Describe)
The Mako System is intended to assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures.
The Mako System is indicated for use in total hip arthroplasty procedures in which:
- · the use of stereotactic surgery may be appropriate, and
- · where reference to rigid anatomical bony structures can be identified relative to a CT-based model of the anatomy;
including revision total hip arthroplasty procedures where:
- · the primary acetabular component is well-fixed to the pelvic anatomy, and
- · the acetabular component can be revised with either a cup or cup and wedge augment construct.
These procedures include: Total Hip Arthroplasty (THA)
| Type of Use (Select one or both, as applicable) |
|---|
| ------------------------------------------------- |
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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K243751 510(k) SUMMARY
| Sponsor: | Mako Surgical Corp.
3365 Enterprise Ave
Weston, FL 33331 |
|------------------------|------------------------------------------------------------------------------------------------------------|
| Contact Person: | Rita Koremblum
Senior Staff Regulatory Affairs Specialist
rita.koremblum@stryker.com
201-565-6636 |
| Date Prepared: | |
| Proprietary Name: | Mako Total Hip Application |
| Common Name: | Total Hip Application (THA) |
| Regulation Name: | Stereotaxic Instrument |
| Regulation Number: | 21 CFR Section 882.4560 |
| Device Classification: | Class II |
| Product Code: | OLO |
Substantial Equivalence Claimed To:
The subject device, the Mako Total Hip Application, is substantially equivalent to the predicate device, Mako Total Hip Application, cleared via K193128.
Device Modifications:
The following changes have been made to the Mako Total Hip Application:
Indications For Use: A revision indication has been added to the Mako Total Hip Application Indications for Use statement.
Integration with the updated Mako 4 Hardware: The subject Mako Total Hip software application has been integrated with the new Mako 4 hardware platform, recently cleared in K241011.
Clinical Software Application:
- New implant system compatibility for revision indication .
5
- Screw planning and intraoperative screw trajectory
- Augment planning, preparation and plane capture
- . Additional cup, augment and stem planning features
- Pelvic registration for revision indication
- Bone mapping
- . Pre-impaction and post-impaction clocking
Additional Software Changes:
- Update to robotic arm software CRISIS to enable compatibility with the updated . Mako 4 hardware operating system (Flex OS).
- MGo: Minor updates to MGo were required for compatibility with the Flex 0S. .
- Treatment Design Application (TDA): A newer version (1.10) of TDA has been . released that supports segmentation of Total Hip Application (THA) revision cases in TDA. Specifically, for revision cases, primary implant surfaces can be segmented in addition to the pelvis, operative femur, and non-operative femur.
Description:
The Mako System with the subject Mako Total Hip Application is a stereotactic instrument that includes a robotic arm, an integrated cutting system, an optical detector, camera, a computer, dedicated instrumentation, operating software, a planning laptop, and tools and accessories.
The system's architecture is designed to support total and partial knee procedures and total hip procedures. With application specific hardware and software, the system provides haptic guidance during orthopedic surgical procedures by using patient CT data to assist a surgeon with pre-surgical planning, implant placement and interpretive / intraoperative navigation of the patient's anatomy.
Once configured for a specific application, the Mako robotic-arm can serve as the surgeon's "intelligent" tool holder or tool guide by passively constraining the preparation of an anatomical site for an orthopedic implant with software-defined spatial boundaries.
Summary of Technological Characteristics Compared to Predicate Device:
The technological characteristics of the Mako Total Hip Application compared to the predicate device are listed below:
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| Technological
Characteristics | Mako Total Hip Application | Mako Total Hip Application –
K193128 |
|----------------------------------|--------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------|
| Major Components | Stryker Q-Guidance System, robotic
arm, cutting system, preoperative
planning laptop | Robotic Arm, Guidance Module,
Camera Stand, cutting system,
preoperative planning laptop |
| Tools/accessories | Various reusable and disposable
instruments | Various reusable and disposable
instruments |
| Image Use | CT | CT |
Intended Use
The subject device has the same intended use as that specified in the cleared 510(k) premarket notification for the predicate device listed in this 510(k) premarket notification.
Indications for Use: Mako Total Hip Application
The Mako System is intended to assist the surgeon in providing software defined spatial boundaries for orientation and reference information to anatomical structures during orthopedic procedures.
The Mako System is indicated for use in total hip arthroplasty procedures in which:
- the use of stereotactic surgery may be appropriate, and
• where reference to rigid anatomical bony structures can be identified relative to a CT-based model of the anatomy;
including revision total hip arthroplasty procedures where:
- the primary acetabular component is well-fixed to the pelvic anatomy, and
- the acetabular component can be revised with either a cup or cup and wedge augment construct.
These procedures include: Total Hip Arthroplasty (THA)
Performance Data – The modified Mako System with the subject Mako Total Hip Application has been evaluated through the following non-clinical performance testing:
- Software testing
- Bone registration accuracy verification
- Bone resection accuracy verification ●
- System verification
- Simulated-Use Cadaveric Surgeon Validation
Conclusions:
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Image /page/7/Picture/0 description: The image shows the word "stryker" in a bold, sans-serif font. The letters are black and the background is white. The word is written in all lowercase letters.
The hardware and software of the subject Mako System with Mako Total Hip Application is similar to the hardware and software of the predicate Mako System with Mako Total Hip Application. The software modifications being made do not impact the intended use or the fundamental technology of the device. Furthermore, performance testing demonstrates that the characteristics of the subject Mako Total Hip Application are equivalent to the characteristics of the predicate device. The subject device is also as safe and as effective as the predicate device and does not raise different questions of safety and effectiveness. Therefore, the performance testing supports a determination of substantial equivalence.