ZIMMER SEGMENT SYSTEM TRABECULAR METAL PROXIMAL TIBIAL COMPONENT, TRABECULAR METAL PROXIMAL COMPONENT, ADDITIONAL SEGMEN
Applicant
Zimmer, Inc.
Product Code
KRO · Orthopedic
Decision Date
Jul 1, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3510
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Zimmer Segmental System is intended to replace the proximal femur, mid-shaft femur, distal femur, proximal tibia and/or total knee in cases that require extensive resection and restoration. The Segmental System provides for cross compatibility between selected components from the MOST Options® System and NexGen® Rotating Hinge Knee System. A total mid-calf to hip replacement can be achieved using the Segmental System. The cleared distal femoral component and the proposed proximal tibial component are designed to be compatible with standard NexGen patella components. The proximal femoral components are designed to be compatible with various Zimmer femoral heads with a 12/14 taper. The Trabecular Metal Proximal Femoral Component is designed to replace the proximal femur and is available in two sizes (38mm and 46mm offsets). The Trabecular Metal Proximal Tibial Component is designed to replace the proximal tibia and is available in three sizes. The Segment with Male/Female Taper components are designed to be used with Segmental System Stem Extensions in combination with a proximal femoral component, a distal femoral component, and/or a proximal tibial component, or intercalary segments, in order to replace portions of the proximal femur, mid-shaft femur, distal femur, and/or proximal tibia.
Device Story
Modular orthopedic prosthesis system for extensive bone resection and reconstruction of proximal/distal femur and proximal tibia. Components include Trabecular Metal proximal femoral/tibial segments and male/female taper segments. System integrates with existing MOST Options and NexGen Rotating Hinge Knee components. Used by orthopedic surgeons in clinical settings for complex joint replacement. Provides structural restoration of bone and joint function; enables total femoral or total knee replacement constructs. Operates via mechanical fixation; specific constructs require bone cement (PMMA) for stem/collar-to-bone interface, while others allow uncemented use. Benefits patients by restoring mobility and stability in cases of severe bone loss or failed prior surgeries.
Clinical Evidence
No clinical data provided. Safety and effectiveness established via non-clinical bench testing, including fatigue testing of proximal femoral, proximal tibial, and segment components.
Technological Characteristics
Modular orthopedic prosthesis system featuring Trabecular Metal components. Materials include metal/polymer/ceramic. Fixation methods include cemented and uncemented options depending on construct. Connectivity: N/A (mechanical device). Sterilization: Not specified. Software: None.
Indications for Use
Indicated for patients with moderate to severe knee instability, significant bone loss, or ligament deficiencies due to neoplasms, trauma, rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis, collagen disorders, or avascular necrosis of the proximal/distal femur or proximal tibia. Also indicated for valgus, varus, or flexion deformities and salvage of failed surgical attempts.
Regulatory Classification
Identification
A knee joint femorotibial metal/polymer constrained cemented prosthesis is a device intended to be implanted to replace part of a knee joint. The device limits translation or rotation in one or more planes and has components that are linked together or affined. This generic type of device includes prostheses composed of a ball-and-socket joint located between a stemmed femoral and a stemmed tibial component and a runner and track joint between each pair of femoral and tibial condyles. The ball-and-socket joint is composed of a ball at the head of a column rising from the stemmed tibial component. The ball, the column, the tibial plateau, and the stem for fixation of the tibial component are made of an alloy, such as cobalt-chromium-molybdenum. The ball of the tibial component is held within the socket of the femoral component by the femoral component's flat outer surface. The flat outer surface of the tibial component abuts both a reciprocal flat surface within the cavity of the femoral component and flanges on the femoral component designed to prevent distal displacement. The stem of the femoral component is made of an alloy, such as cobalt-chromium-molybdenum, but the socket of the component is made of ultra-high molecular weight polyethylene. The femoral component has metallic runners which align with the ultra-high molecular weight polyethylene tracks that press-fit into the metallic tibial component. The generic class also includes devices whose upper and lower components are linked with a solid bolt passing through a journal bearing of greater radius, permitting some rotation in the transverse plane, a minimal arc of abduction/adduction. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).
NexGen® Complete Knee Solutions Rotating Hinge Knee System (K013385)
Submission Summary (Full Text)
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Image /page/0/Picture/0 description: The image contains a logo and some handwritten text. The logo is a circle with a stylized letter "Z" inside, and below it, the word "zimmer" is printed in a bold, sans-serif font. To the left of the logo, there is handwritten text that appears to be "K110940" and "p.1/4".
JUL - 1 2011
## Summary of Safety and Effectiveness
| Sponsor: | Zimmer, Inc.<br>P.O. Box 708<br>Warsaw, IN 46581-0708 |
|------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Mark D. Warner<br>Specialist, Regulatory Affairs<br>Telephone: 574-372-4150<br>Fax: (574) 372-4605 |
| Date: | April 1, 2011 |
| Trade Name: | Zimmer® Segmental System Trabecular Metal™<br>Proximal Tibial Component, Trabecular Metal<br>Proximal Femoral Component, and additional<br>Segment with Male/Female Taper components |
| Common Name: | Total Hip Prosthesis (proximal femoral component,<br>segment components) |
| | Total Knee Prosthesis (proximal tibial component,<br>segment components) |
| Classification Name and Reference: | LPH - Prosthesis, Hip, Semi-Constrained,<br>Metal/Polymer, Porous Uncemented;<br>21 CFR § 888.3358 |
| | LWJ - Prosthesis Hip, Semi-Constrained,<br>Metal/Polymer, Uncemented; 21 CFR § 888.3360 |
| | JDI - Prosthesis, Hip, Semi-Constrained,<br>Metal/Polymer, Cemented; 21 CFR § 888.3350 |
| | LZO - Prosthesis, Hip, Semi-Constrained,<br>Metal/Ceramic/Polymer, Cemented or Non-Porous,<br>Uncemented; 21 CFR § 888.3353 |
| | KWY - Prosthesis, Hip, Hemi-, Femoral,<br>Metal/Polymer, Cemented or Uncemented;<br>21 CFR § 888.3390 |
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110940 \$ 2/4
#### Predicate Devices:
Device Description:
KWL - Prosthesis, Hip, Hemi-, Femoral, Metal; 21 CFR § 888.3360
KWZ - Prosthesis, Hip, Constrained, Cemented or Uncemented, Metal/Polymer; 21 CFR § 888.3310
KRO - Prosthesis, Knee, Femorotibial, Constrained, Cemented, Metal/Polymer; 21 CFR & 888.3510
Zimmer Segmental System, manufactured by Zimmer Inc. (K070978, cleared July 3, 2007)
Zimmer Segmental System Proximal Femoral Component, manufactured by Zimmer Inc. (K101296, cleared July 30, 2010)
MOST System, manufactured Intermedics Orthopedics, Inc. (K964350, cleared January 16, 1997)
MOST Options System, manufactured Sulzer Orthopaedics (K013031, cleared December 7, 2001)
NexGen® Complete Knee Solutions Rotating Hinge Knee System, manufactured by Zimmer, Inc. (K013385, cleared January 9, 2002)
The Zimmer Segmental System is intended to replace the proximal femur, mid-shaft femur, distal femur, proximal tibia and/or total knee in cases that require extensive resection and restoration. The Segmental System provides for cross compatibility between selected components from the MOST Options® System and NexGen® Rotating Hinge Knee System. A total mid-calf to hip replacement can be achieved using the Segmental System. The cleared distal femoral component and the proposed proximal tibial component are designed to be compatible with standard NexGen patella components. The proximal femoral components are designed to be compatible with various Zimmer femoral heads with a 12/14 taper.
The Trabecular Metal Proximal Femoral Component is designed to replace the proximal femur and is available in two sizes (38mm and
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# K110940 08/4
Intended Use:
46mm offsets). The Trabecular Metal Proximal Tibial Component is designed to replace the proximal tibia and is available in three sizes. The Segment with Male/Female Taper components are designed to be used with Segmental System Stem Extensions in combination with a proximal femoral component, a distal femoral component, and/or a proximal tibial component, or intercalary segments, in order to replace portions of the proximal femur, mid-shaft femur, distal femur, and/or proximal tibia.
This Segmental System is indicated for:
- -
- । Significant bone loss and/or ligament deficiencies caused by neoplasms, trauma, rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis, collagen disorders, and/or avascular necrosis of the proximal and/or distal femur and/or proximal tibia
- Valgus, varus or flexion deformities ।
- । The salvage of previously failed surgical attempts
- A total femoral replacement construct consisting . of the MOST Options or Segmental proximal femoral, Segmental System segments and Segmental System distal femoral components may be used without cement.
- Variable Stiffness stem extensions require the . use of either a smooth or Trabecular Metal stem collar, which must be cemented to the stem. Following cementing to the stem, the smooth collar must be cemented against the bone. The remainder of the stem must be used uncemented.
- . Fluted stem extensions require the use of either a smooth or Trabecular Metal stem collar, which must be cemented to the stem. Following cementing to the stem extension, the smooth collar must be cemented against the bone. The remainder of the stem must also be cemented against the bone.
- The Trabecular Metal collar may be used . cemented or uncemented against the bone.
- All other constructs are for cemented use only. .
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Comparison to Predicate Device:
K110940
p4/4
Performance Data (Nonclinical and/or Clinical):
The proposed Segmental System components are similar or identical in intended use, materials, sterility, and performance characteristics to the predicate devices.
Non-Clinical Performance and Conclusions:
The results of non-clinical (lab) performance testing demonstrate that the devices are safe and effective and substantially equivalent to the predicate devices. Performance testing included: proximal femoral component fatigue test, proximal tibial component fatigue test, segment component fatigue test.
Clinical Performance and Conclusions:
Clinical data and conclusions were not needed for this device.
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Image /page/4/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a stylized image of an eagle with its wings spread, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circle around the eagle. The eagle is drawn with thick, black lines, and the text is in a simple, sans-serif font.
Food and Drug Administration 10903 New Hamoshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Zimmer, Inc. % Mr. Mark D. Warner Specialist, Regulatory Affairs P.O. Box 708 Warsaw, Indiana 46581-0708
JUL - 1 2011
Re: K110940
Trade/Device Name: Zimmer Segmental System Trabecular Metal Proximal Tibial Component. Trabecular Metal Proximal Femoral Component, and additional sizes of Male-Female Segments
Regulation Number: 21 CFR 888.3510 Regulation Name: Knee joint femorotibial metal/polymer constrained cemented prosthesis Regulatory Class: II Product Codes: KRO: LZO, JDI, LPH, LWJ, KWZ, KWL, KWY Dated: April 1, 2011 Received: April 4, 2011
Dear Mr. Warner:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA), You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21
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Page 2 – Mr. Mark D. Warner
CFR Part 807): labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
E.J. Keith
Fr Mark N. Melkerson Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## Indications for Use
KI10940
## 510(k) Number (if known):
Device Name:
Zimmer Segmental System Trabecular Metal Proximal Tibial Component, Trabecular Metal Proximal Femoral Component, and additional Segment with Male/Female Taper components
#### Indications for Use:
- · This device is indicated for:
- Moderate to severe knee instability ເ
- Significant bone loss and/or ligament deficiencies caused by neoplasms, trauma, । rheumatoid arthritis, osteoarthritis, traumatic arthritis, collagen disorders, and/or avascular necrosis of the proximal and/or distal femur and/or proximal tibia.
- Valgus, varus or flexion deformities -
- । The salvage of previously failed surgical attempts
- · A total femoral replacement construct consisting of the MOST Options® or Segmental proximal femoral, Segmental System segments and Segmental System distal femoral components may be used without cement.
- · Variable Stiffness stem extensions require the use of either a smooth or Trabecular Metal stem collar, which must be cemented to the stem. Following cementing to the stem, the smooth collar must be cemented against the bone. The remainder of the stem must be used uncemented.
- · Fluted stem extensions require the use of either a smooth or Trabecular Metal stem collar, which must be cemented to the stem. Following cementing to the stem extension, the smooth collar must be cemented against the bone. The remainder of the stem must also be cemented against the bone.
- · The Trabecular Metal collar may be used cemented or uncemented against the bone.
- · All other constructs are for cemented use only.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
। ર
(Please do not write below this line -- Continue on another page if needed)
Concurrence of CDRH, Office of Device Evaluation (ODE)
| | for M. Melkeron | Page 1 of 1 |
|--|-----------------|-------------|
|--|-----------------|-------------|
(Division Sign-Off)
Division of Surgical, Orthopedic,
and Restorative Devices
| 510(k) Number | K110940 |
|---------------|---------|
|---------------|---------|
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.