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510(k) Data Aggregation

    K Number
    K250980
    Date Cleared
    2025-05-22

    (52 days)

    Product Code
    Regulation Number
    888.3565
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Physica system is indicated for use in knee arthroplasty in skeletally mature patients with the following conditions:

    • Non-inflammatory degenerative joint disease including
      • osteoarthritis
      • traumatic arthritis, and
      • avascular necrosis (not applicable to Physica TT Tibial Plate);
    • Inflammatory degenerative joint disease including rheumatoid arthritis;
    • Correction of functional deformity;
    • Revision procedures where other treatments or devices have failed; and
    • Treatment of fractures that are unmanageable using other techniques.

    Additional indications for Physica LMC component are:

    • Moderate varus, valgus, or flexion deformities.

    In patients with preserved and well functioning collateral ligaments, Physica PS, PS Pro and HPS components are also indicated for:

    • Absent or not-functioning posterior cruciate ligament;
    • Severe antero-posterior instability of the knee joint.

    Additional indications for Physica HPS component are:

    • Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy.
    • 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.
    • Collagen disorders, and/or avascular necrosis of the femoral condyle.
    • Moderate varus, valgus, or flexion deformities.

    Femoral, tibial and patellar components of the Physica system are intended for cemented use, with the exception of Physica Porous Femoral components and Physica TT Tibial Plates that are intended for uncemented use.

    Tibial liners can be used with cemented or uncemented tibial or femoral components.

    Device Description

    This 510(k) submission aims at introducing the Physica CR Porous Femoral components as part of the subject Physica system. The subject device components are intended to be used without cement, articulating with other components of the cleared Physica system. The Physica system (including subject Physica CR Porous Femoral components) is intended for a total knee replacement.

    Physica CR Porous Femoral components are designed based on the cemented Physica CR Femoral components already cleared (K151266). They are made of CoCrMo (ISO 5832-4 / ASTM F75) and are intended to replace the condyles of the distal femur. The femoral components are available in ten sizes (left and right) and are intended to replace the condyles of the distal femur. The femoral components are available in left and right versions and have an asymmetric anterior flange (to adapt left and right knees) with symmetric condyles for the articulation with the tibial liner.

    AI/ML Overview

    This FDA 510(k) clearance letter pertains to a medical device, specifically the Physica CR Porous Femoral components for total knee replacement, not an AI/Software as a Medical Device (SaMD).

    Therefore, the requested information (acceptance criteria and study that proves the device meets the acceptance criteria), which is typically associated with the validation of AI/SaMD, is not directly applicable to this document. The document describes the device, its intended use, and indicates that substantial equivalence to predicate devices was demonstrated through non-clinical mechanical testing and comparisons.

    Here's how I can describe the information requested if this were an AI/SaMD, and then explain what the provided document does say in terms of device performance:


    As this document describes a physical medical device (knee implant) and not an AI/SaMD, the requested information regarding acceptance criteria and studies for AI/SaMD performance validation (e.g., sample size for test set, expert qualifications, MRMC studies, standalone performance, training set details) is not present in the provided text.

    However, I can interpret your request in the context of the provided document by outlining the performance evaluation conducted for this physical device as presented in the 510(k) summary.


    Acceptance Criteria and Study for Physica CR Porous Femoral Components (Non-AI/SaMD Context)

    The primary method to demonstrate "acceptance criteria" and "device performance" for this type of medical device in a 510(k) submission is through substantial equivalence to legally marketed predicate devices, supported by non-clinical (mechanical) testing and material characterization.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Implied for Mechanical Performance)Reported Device Performance (from document)
    Fatigue Strength: Device withstands cyclic loading without failure.Fulfilled: Mechanical testing for fatigue (ASTM F3210-22e1) was performed on worst-case components/constructs, demonstrating that "the device performance fulfilled the intended use."
    Biocompatibility/Material Conformity: Materials used are safe for implantation.Fulfilled: PoroTi coating conforms to FDA Guidelines and referenced standards. Materials (CoCrMo, ISO 5832-4 / ASTM F75) are standard and cleared.
    Design Equivalence/Functionality: Design features allow for intended use and articulation.Fulfilled: Subject components have "same sizes, dimensions and design features of Physica CR Femoral components" (a cleared predicate), with minor differences (cement pockets) addressed by Design Control Activities.
    Overall Intended Use: Device is suitable for knee arthroplasty as specified.Fulfilled: "Mechanical tests demonstrated that the device performance fulfilled the intended use, and that the device is substantially equivalent to the predicate device."

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

    • Test Set Sample Size: The document mentions "worst case components or constructs" were used for mechanical testing. It does not specify a numerical sample size for these tests.
    • Data Provenance: The data comes from non-clinical mechanical testing conducted on physical components of the device, likely performed in a laboratory setting by the manufacturer (Limacorporate S.p.A. in Italy). It is not retrospective or prospective patient data.

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

    • This question is not applicable as the ground truth for a physical medical device like a knee implant is established through objective engineering standards and mechanical test results, not through expert consensus on diagnostic images or clinical outcomes in the same way as an AI/SaMD. The "experts" involved would be engineering and material science professionals conducting and interpreting the tests.

    4. Adjudication Method for the Test Set

    • Not applicable. Adjudication methods like 2+1 or 3+1 are used in evaluating subjective assessments (e.g., image interpretation). Mechanical testing results are objective measurements against defined standards.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs. Without AI Assistance

    • Not applicable. This device is a physical knee implant, not an AI or a system that assists human readers. Therefore, no MRMC study or AI-related comparative effectiveness was conducted or reported.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

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

    7. The Type of Ground Truth Used

    • For mechanical performance: The ground truth is defined by established engineering standards (e.g., ASTM F3210-22e1 for fatigue testing) and material specifications (e.g., ISO 5832-4 / ASTM F75 for CoCrMo, FDA Guidelines for PoroTi coating). The "ground truth" is that the device must meet these predetermined, objectively measurable criteria.
    • For substantial equivalence: The ground truth is the performance and characteristics of the legally marketed predicate devices.

    8. The Sample Size for the Training Set

    • Not applicable. This device does not use a "training set" in the context of machine learning or AI. Its design is based on established engineering principles and prior device designs.

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

    • Not applicable. See point 8. The design and development process for a physical implant involves engineering principles, CAD, materials science, and testing against known biomechanical principles, rather than AI training data.
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    K Number
    K243615
    Date Cleared
    2024-12-18

    (26 days)

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

    K210554

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

    Physica system is indicated for use in knee arthroplasty in skeletally mature patients with the following conditions:

    • · Non-inflammatory degenerative joint disease including
      o osteoarthritis
      o traumatic arthritis, and
      o avascular necrosis (not applicable to Physica TT Tibial Plate);
    • · Inflammatory degenerative joint disease including rheumatoid arthritis;
    • · Correction of functional deformity:
    • · Revision procedures where other treatments or devices have failed; and
    • · Treatment of fractures that are unmanageable using other techniques.

    Additional indications for Physica LMC component are:

    • · Moderate varus, valqus, or flexion deformities.
      In patients with preserved and well functioning collateral ligaments, Physica PS, PS Pro and HPS components are also indicated for:
    • · Absent or not-functioning posterior cruciate ligament;
    • · Severe antero-posterior instability of the knee joint.

    Additional indications for Physica HPS component are:
    · Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy.

    • · 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.
    • · Collagen disorders, and/or avascular necrosis of the femoral condyle.
    • · Moderate varus, valgus, or flexion deformities.

    AMF Revision TT Cones are intended for use in skeletally mature patients with bone defect or poor bone quality (osteoporotic bone) or in case of sclerotic bone that requires supplemental metaphyseal fixation in the clinical judgment of the surgeon.

    Femoral, tibial and patellar components of the Physica system are intended for cemented use, with the exception of Physica Porous Femoral components and Physica TT Tibial Plates that are intended for uncemented use, and tibial and femoral cones that are intended for uncemented fixation to the bone and are fixed to the femoral and tibial implants using bone cement.

    Tibial liners can be used with cemented or uncemented tibial or femoral components.

    Device Description

    Physica Porous Femoral Components have been cleared via K210554 with a Porous coating performed by a supplier. With this 510(k) submission, Limacorporate intends to add an additional coating vendor for these components. No other change is introduced on the Physica Porous Femoral Components: Intended use, design, material, sterilization, packaging and principle of operation are unchanged compared to the information approved in K210554.

    AI/ML Overview

    The provided text is a 510(k) premarket notification for a medical device called "Physica Porous Femoral Components." This document focuses on demonstrating substantial equivalence to a previously cleared predicate device, rather than proving that the device meets specific performance acceptance criteria via a clinical study with a detailed test set, ground truth, or expert review.

    Therefore, the document does not contain the information requested regarding acceptance criteria met by a study that proves the device meets them. Specifically:

    • No table of acceptance criteria and reported device performance: The document does not define specific performance metrics or acceptance thresholds that the device was tested against in a clinical setting.
    • No sample size used for the test set or data provenance: There is no clinical test set described.
    • No number of experts or their qualifications for ground truth: Since no clinical test set is described, there's no mention of experts establishing ground truth for it.
    • No adjudication method for the test set: Not applicable as there's no clinical test set.
    • No multi-reader multi-case (MRMC) comparative effectiveness study: The document explicitly states "Clinical testing was not necessary to demonstrate substantial equivalence of the new Physica Porous Femoral components to the predicate devices." This means no human-in-the-loop study was conducted.
    • No standalone (algorithm only) performance study: This is not an AI/algorithm-based device; it's a knee prosthesis component.
    • No type of ground truth used: Not applicable as there's no clinical test.
    • No sample size for the training set: Not applicable as this is a physical device and not an AI/ML model.
    • No description of how ground truth for the training set was established: Not applicable.

    What the document does state regarding demonstrating equivalence:

    The submission for the Physica Porous Femoral Components focuses on demonstrating substantial equivalence primarily through non-clinical testing and comparison of technological characteristics.

    • Non-clinical testing: "Mechanical and morphological characteristics of the coating of the subject cementless Physica Porous Femoral components were confirmed through a comparison with previously cleared (K210554) cementless Physica Porous Femoral components. The PoroTi coating of subject Porous Femoral components fulfills the conformity to the FDA guidelines and referenced standards and the analysis was performed on worst case components or constructs."
    • Comparison of technological characteristics: The document asserts that "The intended use, design, and materials of the subject Physica Porous Femoral components (part of Physica system) are substantially equivalent to those of the predicate devices."

    In essence, the "study" proving the device meets requirements for market clearance in this case is a non-clinical bench testing and design control process to ensure the new manufacturing of the porous coating is equivalent to a previously cleared version, which itself would have established safety and effectiveness through its own predicate or data. No new clinical or human performance data was required for this specific 510(k) submission.

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