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510(k) Data Aggregation
(56 days)
Triathlon® Hinge Knee System is intended to be implanted with bone cement for the following condition(s):
- There is destruction of the joint surfaces, with or without significant bone deformity.
- The cruciate and/or collateral ligaments do not stabilize the knee joint.
- The ligaments are inadequate and/or the musculature is weak. And/or
- Revision is required of a failed prosthesis where there has been gross instability, with or without bone loss or inadequate soft tissue.
When used with MRH femur and/or MRH tibial baseplate replacement indicated in revision of an existing prosthesis:
- Revision is required of a failed prosthesis where there has been gross instability, with or without bone loss or inadequate soft tissue.
When used with compatible GMRS components:
- Where segmental resection and/or replacement of femur and/or proximal tibia is required
The subject THK components are a line extension of the previously cleared Triathlon® Hinge Knee System (K223528, K230416). The THK System (K223528, K230416) is a tricompartmental knee system consisting of a stemmed femoral component and a stemmed tibial bearing component connected by a set of previously cleared MRH or THK Bushings and an MRH or THK Axle (K994207, K002552, K223528, K230416). A bumper locks this assembly. This assembly provides motion through the MRH or THK Axle/Bushings combination in the flexion/extension plane. The articulation between the bearing surfaces on the underside of a tibial bearing component and a tibial insert provides motion in the rotating plane. A hinge tibial insert is assembled to a Triathlon® Hinge Revision Tibial Baseplate that incorporates a longitudinal bore to accept a previously cleared MRH Tibial Sleeve (K994207, K002552) or Triathlon Tibial Sleeve (K223528, K230416). Optional distal femoral and tibial augments are available to fill bone defects.
The subject Triathlon® Hinge Small Proximal Tibial Bearing Component and Triathlon® End Cap are sterile, single use devices intended for cemented use only and are being added to the previously cleared THK system (K223528, K230416) as an extension. They can be used with previously cleared MRH Knee components (K994207, K002552), GMRS (K023087, K222056), and Triathlon® Knee System components (K172634, K172326, K190991, K143393, K141056, K132624, K070095, K061521, K053514, K052917, K051948, K051146, K040267).
This FDA 510(k) clearance letter is for a mechanical medical device (a knee implant system), not an AI/software as a medical device. Therefore, the request for "acceptance criteria and the study that proves the device meets the acceptance criteria" using metrics relevant to AI/software (like sensitivity, specificity, MRMC studies, ground truth for training/test sets, etc.) is not applicable here.
The document provided details about the substantial equivalence of the "Triathlon® Hinge Knee System" to previously cleared predicate devices. The "study" proving the device meets acceptance criteria for a mechanical implant typically involves non-clinical (benchtop) testing and engineering analyses to demonstrate performance, material compatibility, and safety, rather than clinical trials or AI performance evaluations with ground truth.
Here's how the provided information relates to the typical evaluation of such a device, addressing the closest analogues to your requested points:
Acceptance Criteria and Device Performance for a Mechanical Implant:
For mechanical implants like the Triathlon® Hinge Knee System, "acceptance criteria" are generally tied to the successful completion of various non-clinical (benchtop) tests and analyses. These tests simulate the physical stresses and conditions the implant will experience in the human body. The "study" proving the device meets these criteria is the execution and successful outcome of these non-clinical tests.
No direct table of "acceptance criteria" vs. "reported device performance" in the AI sense is provided in this 510(k) summary. Instead, the summary lists the types of non-clinical tests performed to demonstrate performance and substantial equivalence to predicate devices. The implied acceptance is that the device passed these tests, meaning its performance in these simulated scenarios was deemed acceptable and comparable to existing, legally marketed devices.
Table of Non-Clinical Tests (Analogous to Performance Metrics):
| Acceptance Criteria (Test Type) | Reported Device Performance (Implied "Pass") | Notes |
|---|---|---|
| Triathlon Hinge Bearing Component Varus/Valgus Fatigue | Met performance standards | Tests the component's ability to withstand repeated bending stresses in side-to-side directions, simulating loading during gait. |
| Triathlon Hinge Bearing Component Chair Rise Testing | Met performance standards | Simulates stresses experienced during a common activity (standing up from a chair). |
| Triathlon Hinge Full Construct Fatigue | Met performance standards | Evaluates the fatigue life of the entire assembled knee system under cyclic loading. |
| Wear Test Rationale for New Constructs | Acceptable wear characteristics demonstrated | Rationale provided to show that wear performance is acceptable, likely through comparison to predicate devices or established standards. Direct wear testing is implied by "wear test rationale". |
| Analysis of Contact Area/Contact Stress & Constraint Analysis | Acceptable contact mechanics & constraint | Computer modeling and/or benchtop tests to evaluate how the components interact under load, ensuring appropriate stress distribution and constrained movement. |
| Range of Motion and Rotational Freedom Analysis (ASTM F1223-20) | Met specified ranges and freedoms | Tested for flexion/extension, internal/external rotation, varus/valgus, and translation (medial/lateral, proximal/distal, anterior/posterior) to ensure physiological movement. |
| Total Femur Construct Compatibility & Triathlon Hinge Bushing/Axle Compatibility | Compatible with legacy components | Ensured new components integrate properly with existing cleared femoral and tibial components. |
| Triathlon Revision Baseplate-End Cap Locking Strength Analysis | Adequate locking strength | Evaluated the mechanical strength of the connection points. |
| Triathlon End Cap Tightening Analysis | Optimal tightening confirmed | Ensured secure fixation of the end cap. |
| Triathlon End Cap Load Carrying Capacity Rationale | Acceptable load capacity | Analysis provided to demonstrate the end cap can withstand expected loads. |
| Triathlon End Cap Stability Analysis | Stable under normal use | Evaluated the end cap's ability to remain in place and function without loosening. |
| MRI Testing (Safety for imaging) - Displacement, Torque, Artifacts, RF Heating | All MRI safety criteria met | Performed to confirm the device is safe for patients undergoing MRI procedures (e.g., no excessive magnetic pull, acceptable image distortion, no dangerous heating). Standards: ASTM F2052-15, ASTM F2213-17, ASTM F2119-07 (reapproved 2013), ASTM F2182-191ae. |
| Biocompatibility (ISO 10993-1:2020) | Biocompatible with human tissue | Testing to ensure the materials used in the implant do not cause adverse biological reactions in the body. |
| Shelf-life Validation (ISO 11607-1:2019, ISO 11607-2:2019, ASTM F1980-21) | Validated shelf-life | Ensures the sterility and integrity of the packaging system and the device itself are maintained over the specified shelf-life. Methods: ASTM F1886/F1886M-16, ASTM F88/88M-21, ASTM F2096-11(2019). |
| Bacterial Endotoxin Testing (ANSI/AAMI ST72:2019) | Endotoxin limit < 20EU/Device | Confirms the device is free from pyrogens (substances that can cause fever). |
Since this is for a mechanical knee implant system (not an AI/software device), most of the requested points related to AI are not applicable. Here's a breakdown based on the provided document:
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A table of acceptance criteria and the reported device performance:
- As shown above, the acceptance criteria are implicitly defined by the successful completion of the listed non-clinical tests and analyses. The performance is "Met performance standards" or "Acceptable," as detailed in the Notes column. The document doesn't provide specific numerical results of these tests (e.g., how many cycles endured, specific force resistance values) but states they were performed to determine substantial equivalence.
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Sample sized used for the test set and the data provenance:
- This concept (test set, data provenance) is typically for AI/software. For mechanical device testing, the "sample size" refers to the number of physical units tested according to each standard. These details are generally found in the full test reports, which are not part of the public 510(k) summary. The "data provenance" would refer to the lab where tests were conducted (e.g., an accredited testing lab).
- Not explicitly stated in the 510(k) summary.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- This is an AI/software concept. For mechanical device testing, "ground truth" is defined by established engineering and medical device standards (e.g., ASTM, ISO guidelines) and the physical properties and performance characteristics of the materials and design. Expert engineers and quality assurance specialists verify the test results against these standards.
- Not applicable for a mechanical device.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- This is an AI/software concept for resolving discordant expert opinions. For mechanical testing, test results are typically objective and quantitative, allowing for direct comparison against predefined acceptance criteria from standards.
- Not applicable for a mechanical device.
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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 an AI/software concept measuring clinical impact with human-AI interaction. For this mechanical device, the comparison is to legally marketed predicate devices through substantial equivalence, primarily based on design, materials, and non-clinical performance, rather than an MRMC study.
- No MRMC study was done, as it's not applicable to a mechanical implant.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- This refers to AI performance. For a mechanical device, its "standalone" performance is assessed through the non-clinical benchtop tests listed.
- The non-clinical tests listed in the summary represent the "standalone" performance assessment of the device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- For a mechanical implant, "ground truth" for performance is established by engineering principles, material science, and performance standards (e.g., ASTM, ISO). For biocompatibility, the ground truth is established per ISO 10993-1. For MRI safety, it's established by ASTM standards.
- Ground truth established by relevant engineering and medical device standards.
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The sample size for the training set:
- This refers to AI algorithm development. For a mechanical device, there isn't a "training set" in this sense. The
trainingfor the design of the device comes from established engineering principles, prior device designs, and material science research. - Not applicable for a mechanical device.
- This refers to AI algorithm development. For a mechanical device, there isn't a "training set" in this sense. The
-
How the ground truth for the training set was established:
- Again, this is an AI concept.
- Not applicable for a mechanical device.
In conclusion, the Triathlon® Hinge Knee System is a physical implant, and its clearance is based on demonstrating substantial equivalence to existing legally marketed devices through a series of rigorous non-clinical (benchtop) tests and engineering analyses that confirm its material properties, mechanical performance, biocompatibility, and safety (e.g., MRI compatibility, sterility). Clinical testing was explicitly stated as not required for this 510(k) submission, a common occurrence for devices demonstrating substantial equivalence through non-clinical data.
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(92 days)
Triathlon® Hinge Knee System:
Rotating Hinge Knee System is intended to be implanted with bone cement for the following condition(s):
- · There is destruction of the joint surfaces, with or without significant bone deformity.
- · The cruciate and/or collateral ligaments do not stabilize the knee joint.
- · The ligaments are inadequate and/or the musculature is weak. And/or
- · Revision is required of a failed prosthesis where has been gross instability, with or without bone loss or inadequate soft tissue.
- · And/or where segmental resection and replacement of the distal femur is required.
Triathlon® Revision Insert X3®:
General Total Knee Arthroplasty (TKR) Indications:
· Painful, disabling joint disease of the knee resulting from: noninflammatory degenerative joint disease (including osteoarthritis, traumatic arthritis, or avascular necrosis), rheumatoid arthritis or post-traumatic arthritis.
· Post-traumatic loss of knee joint configuration and function.
· Moderate varus, valgus, or flexion deformity in which the ligamentous structures can be returned to adequate function and stability.
· Revision of previous unsuccessful knee replacement or other procedure.
· Fracture of the distal femur and/or proximal tibia that cannot be standard fracture-management techniques. Additional Indications for Total Stabilizer (TS) Components:
- · Ligamentous instability requiring implant bearing surface geometries with increased constraint.
- · Absent or non-functioning posterior cruciate ligament.
- · Severe anteroposterior instability of the knee joint.
- · Severe instability of the knee secondary to compromised collateral ligament integrity or function.
The previously cleared Triathlon® Hinge Knee (THK) System (K223528) is a tricompartmental knee system consisting of a stemmed femoral component and a stemmed tibial bearing component connected by a set of Modular Rotating Hinge (MRH) bushings and MRH axle (K222056, K002552, K994207). A bumper locks this assembly. This assembly provides motion through the MRH axle/bushing combination in the flexion/extension plane. The articulation between bearing surfaces on the underside of a tibial bearing component and a hinge tibial insert provide motion in the rotating plane. A hinge tibial insert is assembled to a revision tibial baseplate which incorporates a longitudinal bore to accept a Triathlon® tibial sleeve or an MRH tibial sleeve. Optional distal femoral and tibial augments are available to fill bone defect. The Instructions for Use and package labels for the THK components are being updated to bear the MR Conditional symbol and MR Conditional parameters.
The subject Triathlon® Bushing and Axle (Standard Assembly Pack) contains sterile, singleuse devices that are being added to the previously cleared THK System (K223528) as an alternate option to MRH bushings and MRH axle to connect a stemmed femoral component and a stemmed tibial bearing component and provide motion through the flexion/extension plane.
This premarket notification also introduces the subject Triathlon® Revision Insert X3®, which is a sterile, single-use device that is intended for use in a total knee arthroplasty with the previously cleared Triathlon® Revision Tibial Baseplate (K223528) and Triathlon® TS Femoral Component (K172326, K141056, K070095) as part of the Triathlon® Total Knee System. The subject insert is available in seven sizes, and each size is available in seven different thicknesses. The subject insert is packaged together with Cobalt-Chrome (CoCr) stabilizer pin and filler bushing subcomponents that are assembled intraoperatively. The subject insert is assembled to the previously cleared Triathlon® Revision Baseplate (K223528), which incorporates a longitudinal bore to accept the filler bushing subcomponent. The stabilizer pin is inserted through the subject Triathlon® Revision Insert X3® and extends into filler bushing assembled within the Triathlon® Revision Tibial Baseplate to provide additional stability in the insert post.
This FDA K-number document (K230416) is for a medical device, specifically orthopaedic implants (knee systems), and thus does not involve acceptance criteria or studies related to AI/ML device performance. The document only lists pre-clinical (non-clinical) testing performed on the device components, such as materials characterization, wear analysis, fatigue testing, and biocompatibility, to demonstrate substantial equivalence to predicate devices. There is no mention of an algorithm or AI model, nor any associated acceptance criteria, study designs, or ground truth establishment relevant to AI/ML performance.
Therefore, I cannot fulfill your request for information related to AI/ML device acceptance criteria and study details based on the provided document. The document explicitly states: "Clinical testing was not required as a basis for substantial equivalence."
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