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510(k) Data Aggregation

    K Number
    K122500
    Date Cleared
    2013-05-03

    (260 days)

    Product Code
    Regulation Number
    888.3560
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K120313, K072619, K042271, K991581, K031729

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The NEO™ PS Knee System components are indicated for use in skeletally mature individuals, with severe knee pain and disability, with excised posterior cruciate ligament, undergoing surgery for total knee replacement due to:
    . Osteoarthritis, rheumatoid arthritis, post-traumatic arthritis, moderate deformities and femoral condyle osteonecrosis.
    . Failed osteotomies, partial knee replacement, or failed prior total knee replacement whose age, weight and activity level are compatible with an adequate long-term result.
    . Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy.
    . Moderate valgus, varus, or flexion deformities.
    NEO™ PS Total Knee System components are indicated for use only with cement and are single use devices.

    Device Description

    The NEO PS Knee System includes components designed for total knee replacement. The system includes femoral components, tibial inserts, tibial trays, patellar components and surgical instrumentation:
    The Neo PS Knee System femoral component, when used with the Neo PS articular surfaces, is designed to achieve flexion at high angles and provide a clinical ROM up to 150 degrees.

    AI/ML Overview

    The provided text describes a medical device, the NEO PS Knee System, and its clearance process through the FDA's 510(k) pathway. This pathway establishes substantial equivalence to predicate devices rather than proving safety and effectiveness through clinical trials with defined acceptance criteria. Therefore, the information requested regarding acceptance criteria and a study proving the device meets those criteria, as typically understood in the context of diagnostic accuracy or performance, is not directly applicable to this submission.

    However, based on the provided document, we can infer the "acceptance criteria" and "study" in the context of a 510(k) submission as demonstrating substantial equivalence to predicate devices through various performance tests.

    Here's an analysis of the information that can be extracted or reasonably inferred from the document:

    1. A table of acceptance criteria and the reported device performance:

    Since this is a 510(k) submission for a knee implant, the "acceptance criteria" are not reported as specific statistical thresholds for diagnostic accuracy (e.g., sensitivity, specificity). Instead, they are implied to be achieving comparable or acceptable performance in mechanical and functional tests as benchmarked against predicate devices and relevant industry standards.

    Acceptance Criteria (Inferred from 510(k) Process)Reported Device Performance (from "Performance Testing" section)
    Mechanical Strength & Durability (comparable to predicate devices and standards)Evaluated for:
    • Tibial tray fatigue strength
    • Insert locking mechanism strength
    • PS post strength |
      | Functional Range of Motion (comparable to predicate devices and patient needs) | Evaluated for:
    • Femorotibial range of motion
    • Femorotibial range of constraint
    • Patellofemoral range of constraint |
      | Contact Mechanics (comparable to predicate devices to minimize wear and stress) | Evaluated for:
    • Femorotibial contact areas/contact stress
    • Patellofemoral contact area and contact stress |
      | Material Compliance (meeting established biomedical standards) | "The metals and standard UHMWPE material from which the components are manufactured are the same materials used in the predicate knee systems and comply with applicable implantable materials standards." |
      | Overall Substantial Equivalence | "All evaluations determined that the NEO PS Knee System is substantially equivalent to the predicate devices." |

    2. Sample size used for the test set and the data provenance:

    • Sample Size for Test Set: Not applicable in the context of a clinical test set for diagnostic performance. The "test set" here refers to the physical devices undergoing various mechanical and material tests. The specific number of physical samples tested for each mechanical test is not disclosed in this summary.
    • Data Provenance: The tests are likely conducted in a controlled laboratory environment by the manufacturer (Pipeline Orthopedics) or a contract testing laboratory. The country of origin for these tests is not specified but is presumably the US, where the company is based. The data would be considered prospective in the sense that the tests are designed and performed to evaluate the new device's characteristics.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    This information is not applicable to this type of submission. "Ground truth" in the context of a 510(k) for a medical implant refers to established engineering principles, material standards, and the performance characteristics of legally marketed predicate devices. The "experts" involved are likely biomechanical engineers, material scientists, and regulatory experts who interpret test results against these standards and predicate device data. The document does not specify the number or detailed qualifications of such experts involved in the testing or the substantial equivalence determination beyond the general regulatory process.

    4. Adjudication method for the test set:

    This concept is not applicable here. Adjudication methods like 2+1 or 3+1 typically refer to the process of resolving discrepancies in expert interpretations of medical data (e.g., image readings). For a medical implant's mechanical testing, the "adjudication" is inherent in the test protocols themselves, the calculation of results, and the comparison against predefined acceptance criteria or predicate device performance. Any discrepancies would relate to test execution or interpretation which would be resolved through standard engineering and quality control procedures.

    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:

    This is not applicable. An MRMC study is relevant for diagnostic devices (e.g., imaging software) where human interpretation is involved and improved with AI assistance. The NEO PS Knee System is a joint implant, not a diagnostic tool.

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

    This is not applicable. This question pertains to AI/algorithm performance. The NEO PS Knee System is a physical knee implant.

    7. The type of ground truth used:

    The "ground truth" for this 510(k) submission is primarily established through:

    • Predicate Device Performance: Benchmarking against the mechanical and functional characteristics of the legally marketed predicate devices (NEO CR Knee System, NexGen® LPS-Flex Knee System, Triathlon PS Knee System).
    • Industry Standards: Compliance with "applicable implantable materials standards" (e.g., ASTM, ISO standards for biocompatibility, mechanical properties, etc., though not explicitly named).
    • Engineering Principles: The tests conducted (fatigue, strength, ROM, contact stress) are based on established biomechanical and engineering principles to ensure the device can withstand anticipated physiological conditions.

    8. The sample size for the training set:

    This is not applicable. A "training set" refers to data used to train an AI algorithm. The NEO PS Knee System is a physical implant.

    9. How the ground truth for the training set was established:

    This is not applicable for the same reason as point 8.

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    K Number
    K122745
    Manufacturer
    Date Cleared
    2012-12-05

    (89 days)

    Product Code
    Regulation Number
    888.3565
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K113369, K072160, K023211, K072619

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    This device is indicated for patients with severe knee pain and disability due to:

    • Rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.
    • Collagen disorders, and/or avascular necrosis of the femoral condyle.
    • Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy.
    • Moderate valgus, varus, or flexion deformities.
    • The salvage of previously failed surgical attempts or for a knee in which satisfactory stability in flexion cannot be obtained at the time of surgery.

    Porous coated components may be used cemented or uncemented (biological fixation). All other femoral, tibial baseplate, and all-polyethylene (UHMWPE and VEXLPE) patella components are indicated for cemented use only.

    Device Description

    The Persona™ Personalized Knee System is a semiconstrained modular knee prosthesis designed to resurface the articulating surface of the femoral, tibial and patellar bones. The Persona Knee System utilizes a modular design between the tibial plates and articular surfaces. The addition of the Trabecular Metal™ femoral component will provide surgeons with the ability to implant with, or without cement (biological fixation).

    AI/ML Overview

    The Zimmer® Persona™ Personalized Knee System is a medical device for knee replacement. The provided document is a 510(k) summary, which focuses on demonstrating substantial equivalence to predicate devices rather than providing an extensive study report with detailed acceptance criteria and performance metrics typically found in efficacy trials.

    Here's a breakdown based on the information provided:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document states that "Clinical data and conclusions were not needed for this device" because it is a Class II device demonstrating substantial equivalence to existing predicate devices. Therefore, the acceptance criteria are met by demonstrating that the new device exhibits similar or identical performance characteristics to these predicate devices through non-clinical (bench) testing. The acceptance criteria are implicit in the FDA guidance documents followed for testing.

    Property or CharacteristicAcceptance Criteria (Implicit from FDA Guidance)Reported Device Performance
    Posterior Condyle Fatigue Testing in a Cantilever Loading Condition of the Persona™ Trabecular Metal™ femoral componentAdequate posterior condyle fatigue strength as defined by FDA Guidance: Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses. (The specific quantitative acceptance value is not stated in this summary, but would be detailed in the full test report).Demonstrated adequate posterior condyle fatigue strength of the uncemented Persona™ Trabecular Metal™ femoral component in the cantilever loading condition.
    Posterior Condyle Fatigue of Persona™ Trabecular Metal™ femoral component in three-point Bend Loading ConditionAdequate posterior condyle fatigue performance as defined by FDA Guidance: Class II Special Controls Guidance Document: Knee Joint Patellofemorotibial and Femorotibial Metal/Polymer Porous-Coated Uncemented Prostheses. (The specific quantitative acceptance value is not stated in this summary).Demonstrated adequate posterior condyle fatigue performance of the Persona™ Trabecular Metal™ femoral component in a 3-point bend loading condition.
    Modified Metallic Surface Characterization for the Persona™ Trabecular Metal™ Porous femoral knee component with Trabecular Metal™Mechanical, physical, and chemical analyses in accordance with the Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement. (Specific quantitative acceptance metrics for these analyses are not stated in this summary).Mechanical, physical, and chemical analyses of Trabecular Metal™ were assessed in accordance with the Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement. (Implied that the results met the requirements of the guidance).
    Static Tensile, Static Shear and Shear Fatigue of Trabecular Metal™ Diffusion Bonded to Zimaloy-One Hour Cycles, 0.28mm Ti Sheet InterlayerBond strength that met the 20 MPa static tensile test and static shear acceptance criteria. (The specific acceptance criteria for shear fatigue, if numerical, are not explicitly stated, but are implied to be met).Demonstrated that one hour diffusion bonding cycles for Trabecular Metal™ produces a bond that met the 20 MPa static tensile test and static shear acceptance criteria.
    Evaluation of Interactions of the Zimmer Legacy Knee and Persona Primary Implant Systems with the Magnetic Fields in the Magnetic Resonance Imaging (MRI) EnvironmentSafety and compatibility within the MRI environment, as defined by FDA Guidance: Establishing Safety and Compatibility of Passive Implants in the Magnetic Resonance (MR) Environment. (Specific quantitative acceptance metrics for MR safety, such as temperature rise or artifact size, are not stated in this summary).Demonstrated safety and compatibility within the MRI environment.

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

    • Sample Size: The document does not specify the exact sample sizes (number of components tested) for each non-clinical bench test. These details would typically be found in the full test protocols and reports, but are not included in this summary.
    • Data Provenance: The data provenance is "Non-Clinical Performance and Conclusions," meaning the tests were conducted in a laboratory setting (bench testing) rather than on human subjects. This is not retrospective or prospective clinical data. The location of the testing laboratories is not specified.

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

    This is not applicable. For bench testing of medical devices like knee implants, ground truth is established by engineering specifications, material properties, and relevant industry standards (e.g., ISO, ASTM), rather than expert medical consensus on patient cases. The "experts" involved are likely engineering and materials science professionals who design and conduct the tests according to the FDA guidance.

    4. Adjudication Method for the Test Set:

    This is not applicable. Adjudication methods like 2+1 or 3+1 refer to how discrepancies in expert opinions on clinical data are resolved. Since this submission relies on non-clinical bench testing, such an adjudication method is not relevant. The "adjudication" is essentially the adherence to pre-defined test protocols and acceptance criteria based on FDA guidance and engineering standards.

    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 device is a knee implant, not an AI-powered diagnostic tool requiring MRMC studies to assess the impact of AI on human reader performance.

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

    Not applicable. As above, this is a physical implant, not an algorithm.

    7. The Type of Ground Truth Used:

    The ground truth used for these non-clinical tests is established by:

    • Engineering Specifications: Designed tolerances, material strengths, and fatigue limits.
    • Industry Standards: ASTM, ISO, and other relevant standards for orthopedic implant testing.
    • FDA Guidance Documents: The specific guidance documents cited (e.g., Class II Special Controls Guidance Document for Knee Joints, Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces, Guidance for MR Safety) define the methods and performance expectations for validating the device's properties.

    8. The Sample Size for the Training Set:

    Not applicable. This device is not an AI/ML algorithm that requires a training set. The "training" for such a device would be the extensive research and development phases involving finite element analysis, material science studies, and repeated experimental bench testing, but these are not considered "training sets" in the context of AI.

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

    Not applicable, as there is no "training set" in the AI sense for this device.

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