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510(k) Data Aggregation

    K Number
    K190068
    Manufacturer
    Date Cleared
    2019-06-04

    (140 days)

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

    K121771, K150090

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    1. Painful and disabled knee joint resulting from osteoarthritis, or traumatic arthritis, or traumatic arthritis where one or more compartments are involved.

    2. Correction of varus, valgus, or posttraumatic deformity.

    3. Correction or revision of unsuccessful osteotomy, arthrodesis, or failure of previous total joint replacement procedure.

    Femoral components and tibial tray components with porous coatings are indicated for cemented biological fixation application. Non-coated (Interlok) femoral components and all polyethylene patellar components are indicated for cemented application only.

    Device Description

    The Vanguard XP Knee System is a total knee replacement system that consists of a femoral component composed of cobalt-chromium-molybdenum (Co-Cr-Mo), two styles of tibial trays manufactured out of Co-Cr-Mo (with locking bar), and dual bearings machined of Vivacit-E Vitamin-E Highly Crosslinked Polyethylene (VEHXPE). Biomet patellae can be used with the Vanguard XP Knee System. The subject Vanguard XP tibial components are available with a porous plasma spray (PPS®) of titanium alloy powder for uncemented or cemented fixation or with Biomet's Interlok coarse blasted finish for cemented fixation only. The Vanguard XP Knee System offers the flexibility to retain the ACL and PCL ligaments, retain just the PCL ligament and accommodate an intact, partially functioning PCL within a single system.

    AI/ML Overview

    The provided document, a 510(k) premarket notification for the Vanguard XP Knee System, primarily focuses on demonstrating substantial equivalence to predicate devices for a knee implant, specifically a modification to the tibial bearings. It does not contain information about acceptance criteria or a study that proves the device meets those criteria in the context of an Artificial Intelligence (AI) / Machine Learning (ML) enabled medical device.

    The document discusses:

    • Device Identity: Vanguard XP Knee System, a total knee replacement system.
    • Modification: A modification to the tibial bearings within the system.
    • Purpose of Submission: To demonstrate that this modification does not adversely affect safety and efficacy and that the modified device remains substantially equivalent to predicate devices.
    • Testing: Engineering analysis and non-clinical tests (e.g., material characteristics, stress analysis, MRI compatibility, non-pyrogenicity).
    • Clinical Data: Explicitly states, "Clinical data was not deemed necessary for the subject device." This indicates that no human clinical study was conducted for this specific 510(k) submission, and certainly not a study related to AI/ML performance.

    Therefore, I cannot fulfill the request to describe the acceptance criteria and study proving an AI/ML device meets them based on the provided text. The document pertains to a traditional orthopedic implant, not an AI/ML medical device.

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    K Number
    K161592
    Manufacturer
    Date Cleared
    2016-11-03

    (147 days)

    Product Code
    Regulation Number
    888.3520
    Why did this record match?
    Reference Devices :

    K113369, K121771, K150090, K141407, K122160

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

    Indications for Persona Partial Knee System:

    The Persona Partial Knee system is limited to the medial tibiofemoral compartment of the knee intended for patients with painful and/or disabling knee joints due to the following indications:

    • Noninflammatory degenerative joint disease (NIDJD), e.g., osteoarthritis, avascular necrosis;

    • traumatic arthritis;

    • previous tibial condyle or plateau fractures with loss of anatomy or function;

    • varus deformities; and

    • revision of the articular surface of a previously implanted Persona Partial Knee Systemknee surgeries providing that the tibial plate locking mechanism is not compromised and tibial plate components remain well fixed and undamaged.

    The Persona Partial Knee System is a single use implantation with bone cement.

    Indications for combined Persona Partial Knee System and Zimmer Gender Solutions Patello-Femoral Joint (PFJ):

    • Osteoarthritis, traumatic arthritis, and/or severe chondrocalcinosis of the patellofemoral joint.

    • The salvage of previously failed surgical attempts (e.g., arthroscopy, lateral release, cartilage transplantation).

    • History of patellar dislocation or patella fracture.

    • Dysplasia-induced degeneration.

    These indications will be used for the combined medial unicompartmental and patello-femoral implant device, whereby a single condyle and patello-femoral regions have been affected by one or more of these conditions.

    Combined Persona Partial Knee System and Zimmer Gender Solutions Patello-Femoral Joint (PFJ) implants are intended for implantation with bone cement.

    Device Description

    The Persona Partial Knee (PPK) System is a partial knee replacement for the medial compartment of the knee and is modular in design consisting of three components: a unicondylar cobalt-chromium-molybdenum (Co-Cr-Mo) alloy femoral component, a unicondylar titanium (Ti-6Al-4V) alloy tibial tray, and a unicondylar articular surface manufactured using the previously cleared Vivacit-E ® Vitamin-E Highly Crosslinked Polyethylene (VEHXPE).

    The Persona Partial Knee System is compatible with the following devices:

    • Zimmer Patellofemoral Joint Prosthesis (K070695)
    AI/ML Overview

    The provided text is a 510(k) Summary for the Persona Partial Knee System, a medical device. This document focuses on demonstrating substantial equivalence to previously marketed predicate devices, rather than establishing acceptance criteria and proving performance through a standalone study in the way a de novo or PMA submission might.

    Therefore, the typical acceptance criteria and study design for validating an AI/ML device's performance are not applicable here. The device is a physical knee implant, not a software algorithm, and the submission does not describe a clinical study in the traditional sense, but rather non-clinical mechanical testing and engineering analyses.

    Here's an breakdown based on the information provided, highlighting why many requested points are not present in this type of submission:


    1. Table of Acceptance Criteria and Reported Device Performance

    This information is not provided in a table format and does not represent clinical "performance" in the sense of accuracy, sensitivity, or specificity as would be expected for an AI/ML device. Instead, it lists mechanical tests and analyses performed to demonstrate the physical device's safety and effectiveness compared to predicates.

    Test/Analysis PerformedDescription / Purpose
    Femoral Component
    Cantilever fatiguePer internal test method
    3-Point Bending FatiguePer internal test method
    Articular Surfaces
    Contact areaPer ASTM F2083
    ConstraintPer ASTM F2083 and ASTM F1223
    Posterior Crush and Lift OffPer internal test method
    WearPer engineering analysis
    Static locking mechanism strengthPer internal test method
    Tibial Components
    3-Point bending fatiguePer internal test method
    System Compatibility
    Patellar component and PFJ compatibilityPer engineering analysis
    MR compatibilityPer engineering analysis
    Bacterial Endotoxin Testing (BET)To demonstrate pyrogen limit specifications have been met

    Acceptance Criteria: The document states that "Results from mechanical tests and engineering analyses demonstrate the proposed PPK components are substantially equivalent to the predicate devices." While specific numerical acceptance criteria (e.g., maximum deflection, minimum fatigue cycles) are implied by performing these tests to a standard or internal method and achieving "substantial equivalence," they are not explicitly listed in this summary. The general acceptance is that the device performs comparably or better than the predicate devices under these conditions.


    Regarding other requested information points:

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Not applicable. This submission focuses on non-clinical mechanical testing and engineering analyses, not human clinical data or AI/ML model performance on a test set. There isn't a "test set" of patient data in this context.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not applicable. This submission relies on engineering and material science principles, not expert consensus on medical images or diagnoses.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. No adjudication process is described as there is no clinical test set involved.

    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 is a physical implant, not an AI/ML diagnostic or assistive device. No MRMC study was performed. The document explicitly states: "No animal or clinical testing was required to support substantial equivalence."

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

    • Not applicable. This is a physical medical device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Not applicable / Implied: For the mechanical tests, the "ground truth" would be established engineering standards (like ASTM F2083, ASTM F1223) or validated internal test methods, and the performance of the predicate devices. The aim is to show the new device meets these engineering benchmarks or performs comparably to the predicates.

    8. The sample size for the training set

    • Not applicable. There is no "training set" as this is not an AI/ML device.

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

    • Not applicable. There is no "training set" for this device.

    Conclusion from document:

    The Persona Partial Knee System gained 510(k) clearance (K161592) based on demonstrating substantial equivalence to existing legally marketed predicate devices. This was achieved through:

    • Similar intended use (limited to medial tibiofemoral compartment, cemented use).
    • Use of similar materials (Co-Cr-Mo alloy for femoral, Ti-6Al-4V alloy for tibial, Vivacit-E Vitamin E Highly Crosslinked Polyethylene for articular surfaces), which are already used in predicate/reference devices.
    • Similar design features.
    • Similar sterilization methods.
    • Non-clinical mechanical tests and engineering analyses that showed the device performed comparably or acceptably against established engineering standards and predicate device performance. The specific quantitative acceptance criteria for each test are not detailed in this summary document but would have been part of the full 510(k) submission.
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