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510(k) Data Aggregation

    K Number
    K242864
    Date Cleared
    2024-10-18

    (28 days)

    Product Code
    Regulation Number
    882.4560
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ROSA® Knee System, for use with the ROSA® RECON platform, is indicated as a stereotaxic instrumentation system for total knee replacement (TKA) surgery. It is to assist the surgeon in providing software-defined spatial boundaries for orientation and reference information to identifiable anatomical structures for the accurate placement of knee implant components.

    The robotic arm placement is performed relative to anatomical landmarks as recorded using the system intraoperatively, and based on a surgical plan optionally determined pre-operatively using compatible X-ray or MRI based surgical planning tools.

    It includes a robotic arm, an optical tracking system and accessories, software system, surgical instruments and accessories.

    The ROSA Knee System is designed for use on skeletally mature patient population. The targeted population has the same characteristics as the population that is suitable for the implants compatible with the ROSA Knee System.

    The ROSA Knee System is to be used with the following fixed bearing knee replacement systems in accordance with their indications and contraindications: NexGen® CR, NexGen CR-Flex, NexGen CR-Flex Gender, NexGen LPS, NexGen LPS-Flex, NexGen LPS-Flex Gender, Persona® CR, Persona PS, Persona Ti-Nidium® CR, Persona Ti-Nidium PS, Persona IQ®,Vanguard® CR, and Vanquard PS.

    Device Description

    The ROSA® Knee System for use with the ROSA® RECON platform is used to assist surgeons in performing Total Knee Arthroplasty (TKA) with features to assist with the bone resections as well as assessing the state of the soft tissues to facilitate implant positioning intra-operatively.

    The ROSA® Knee System uses a Non-Device Medical Device Data System (MDDS) called the Zimmer Biomet Portal which manages the creation and tracking of surgical cases. The cases reside on the portal until they are uploaded to the ROSA® RECON Platform before surgeries.

    If the case is image-based, a 3D virtual bone model is generated pre-operatively by the PSI systems (X-PSI Knee System-K171269 or CAS PSI Knee System-K131409) to create a 3D model of the patient's femur/tibia and allows the preparation of a pre-operative surgical plan as well as visualization of planned cuts. The pre-operative plan is then matched to the landmarks taken intra-operatively on the patient's bony anatomy. An imageless option is also available where landmarks taken intra-operatively on the patient's bony anatomy are used to create the surgical plan. Accuracy of resections, knee state evaluation, and soft tissue assessment are the same between image-based and imageless options as they are always based on intraoperative landmarks.

    The intraoperative workflow and surgical concepts implemented in the ROSA Knee System remain close to the conventional TKA workflow. As such, at the time of the surgery, the system mainly assists the surgeon in (1) Determining reference alignment axes in relation to anatomical landmarks, (2) planning the orthopedic implants location based on these reference alignment axes and orthopedic implant geometry (planning optionally based on a pre-operative plan using pre-operative imaging), and (3) precisely positioning the cut guide relative to the planned orthopedic implant location by using a robotic arm.

    The purpose of the submission is additional compatibility (Persona IQ 30 mm) with the FDA cleared tibial extension implant (stem), Canturio Smart Extension with Canary Health Implanted Reporting Processor (CHIRP) System, FDA 510(k) number K234056 to the subject device: ROSA Knee System.

    AI/ML Overview

    This submission, K242864, is a Special 510(k) for the ROSA® Knee System. Special 510(k)s are typically used for modifications to a manufacturer's own legally marketed device, where the modification does not alter the fundamental scientific technology of the device and the performance data demonstrates that the modified device is as safe and effective as the predicate device. In such cases, the manufacturer generally relies on existing performance data of the predicate device and provides a rationale for how that data still applies to the modified device.

    The provided document states: "The purpose of the submission is additional compatibility (Persona IQ 30 mm) with the FDA cleared tibial extension implant (stem), Canturio Smart Extension with Canary Health Implanted Reporting Processor (CHIRP) System, FDA 510(k) number K234056 to the subject device: ROSA Knee System."

    It further states: "The existing performance data that was performed for the predicate device remains unchanged and is still applicable for the proposed device." and "The subject device, ROSA Knee System, has the same Intended Use, Indications for Use, technological characteristics, and performance data as its predicate device, ROSA Knee System (K230243) and the information provided demonstrates: In sum, any differences between the devices do not raise new questions of safety and effectiveness: and the proposed device is at least as safe and effective as the legally marketed predicate device."

    Therefore, for this specific 510(k) submission (K242864), a new study was not performed, and the device's acceptance criteria and proven performance rely on the predicate device (ROSA® Knee System, K230243). The document does not provide details of the original study that supported the predicate device.

    Based on the provided information, I cannot complete the requested tables and descriptions because the submission itself explicitly states that no new performance data was generated for K242864 beyond relying on the predicate device's data.

    To provide the detailed information requested, I would need access to the original 510(k) submission for the predicate device, K230243, which would contain the performance data and study details.

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    K Number
    K232425
    Date Cleared
    2023-12-12

    (123 days)

    Product Code
    Regulation Number
    888.3660
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The Signature™ ONE System is indicated, based on patient-specific radiological images with identifiable placement anatomical landmarks, to assist in pre-operative planning and/or intra-operative guiding of surgical instruments for shoulder replacement surgical procedures on patients not precluded from being radiologically scanned.

    The Signature™ ONE System is designed for use on a skeletally mature patient population. The targeted population has the same characteristics as the population that is suitable for the implants compatible with the Signature™ ONE System.

    The Signature™ ONE System is to be used with the glenoid components of the following shoulder implant systems in accordance with their indications: Zimmer® Trabecular Metal Reverse Plus® Shoulder. Comprehensive® Total Shoulder System, Comprehensive® Reverse Shoulder System, Comprehensive® Reverse Augmented Baseplates and Alliance® Glenoid System.

    The Signature™ ONE System pre-operative planning is also compatible with the humeral components of the following shoulder implant systems in accordance with their indications: Comprehensive® Total Shoulder System, Comprehensive® Reverse Shoulder System, and Identity™ Shoulder System.

    The Signature™ ONE System Guides and bone models are intended for single use only.

    Device Description

    The Signature™ ONE System is developed to assist in preoperative planning (using the Signature™ ONE Planner) and to accurately transfer a pre-operative plan to orthopedic surgical procedures (using the Signature™ ONE Guides and bone model) if desired in skeletally mature individuals for Total Shoulder Arthroplasty. Both anatomic and reverse (TSA and RSA respectively) approaches are supported.

    The Signature ONE Guides and Bone Models are designed and manufactured of polyamide (nylon) using additive manufacturing selective laser sintering (SLS), based on the approved/finalized pre-surgical plan and shipped prior to surgery. The guides and bone models are provided nonsterile and sterilized at the hospital. They are used intraoperatively to assist the surgeon in reproducing the plan on the scapula. The Signature ONE System surgical technique remains close to the conventional shoulder arthroplasty workflow.

    The Signature™ ONE System uses a Non-Device Medical Device Data System (MDDS) called the Zimmer Biomet Portal for the interaction with external users (i.e. imaging technician and the surgeon). The internal users (i.e. the Zimmer Biomet operators) use manufacturing software applications to prepare the patient cases for the surgeon.

    The purpose of this submission is to introduce new hardware kits for the existing compatible Comprehensive Reverse Augment implants and to include the addition of pre-operative planning of humeral components. A Rotational Guide component will be available as part of these two kits. Modifications have been made to the software applications to accommodate the new guide ordering option. The overall manufacturing process, materials, sterilization methods, have not changed from the previous primary predicate and principal of operation remains similar.

    AI/ML Overview

    The provided text does not contain detailed acceptance criteria or a comprehensive study report with the specific performance metrics typically found in such documents. The "Summary of Performance Data (Nonclinical and/or Clinical)" section is quite generic, listing categories of tests rather than specific results or acceptance criteria.

    Therefore, I cannot fulfill all components of your request with the information provided. However, I can extract what is available and highlight what is missing.

    Here's a summary of the available information and what is absent:

    Missing Information:

    • Specific Acceptance Criteria and Reported Device Performance (Table): The document lists categories of tests (Performance Tests, Engineering Analysis, Usability Engineering, Validation, Software V&V) but does not provide quantitative acceptance criteria (e.g., accuracy thresholds, precision targets) or the actual reported performance values for the device against these criteria.
    • Sample size for the test set and data provenance: The document mentions "Verification and Validation Testing" but does not specify the number of cases or subjects in the test set, nor the country of origin or whether the data was retrospective or prospective.
    • Number of experts used to establish ground truth and their qualifications: No information is provided about the experts involved in establishing ground truth for any test sets.
    • Adjudication method for the test set: No information is provided regarding adjudication methods.
    • Multi-reader multi-case (MRMC) comparative effectiveness study: The document does not mention an MRMC study or any results regarding human reader improvement with AI assistance.
    • Standalone (algorithm-only) performance: While software verification and validation are mentioned, specific standalone performance metrics (e.g., sensitivity, specificity, accuracy) for the algorithm are not provided.
    • Type of ground truth used: The description of "Validation... to validate related user needs, intended use and safety and effectiveness" is generic and does not specify how ground truth was established (e.g., expert consensus, pathology, outcome data).
    • Sample size for the training set: There is no mention of a training set or its size.
    • How the ground truth for the training set was established: Since a training set is not mentioned, the method for establishing its ground truth is also not provided.

    Available Information (Indirectly related to performance):

    The document primarily focuses on establishing substantial equivalence to a predicate device (K212560 and K211359) by demonstrating that the new device, the Signature™ ONE System, does not raise new questions of safety or effectiveness despite new features.

    The performance data mentioned in the document is categorized as:

    • Device Performance Testing:
      • Performance Tests: Documented to ensure performance of implemented features and verify related design inputs.
      • Engineering Analysis: Documented to ensure performance of implemented features and verify related design inputs.
      • Usability Engineering: Performance of the system in regards to human factors engineering.
      • Validation: Performed to validate related user needs, intended use, and safety and effectiveness.
    • Software Verification and Validation Testing: Conducted to satisfy requirements of the "Content of Premarket Submissions for Device Software Functions Guidance" and IEC 62304. This testing aims to demonstrate the system "does not raise any new issues of safety and effectiveness as compared to the predicate devices."

    Conclusion from the document:

    The conclusion drawn by the submitter is that "any differences between the subject and predicate devices do not raise different questions of safety and effectiveness and the proposed device is at least as safe and effective as the legally marketed predicate devices." This implies that the performance data (though not detailed here) was sufficient to demonstrate this equivalence.

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