CTC TCAT(R)-TPLAN(R) SURGICAL SYSTEM

K140585 · Curexo Technology Corporation · OJP · Aug 18, 2014 · Neurology

Device Facts

• Record ID: K140585
• Device Name: CTC TCAT(R)-TPLAN(R) SURGICAL SYSTEM
• Applicant: Curexo Technology Corporation
• Product Code: OJP · Neurology
• Decision Date: Aug 18, 2014
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 882.4560
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The TCAT™/TPLAN™ Surgical System is intended for use as a device which uses diagnostic images of the patient acquired specifically to assist the physician with presurgical planning and to provide orientation and reference information during intraoperative procedures. The robotic surgical tool, under the direction of the surgeon, precisely implements the presurgical software plan. The preoperative planning software and robotic surgical tool is used as an alternative to manual planning and broaching/reaming techniques for femoral canal preparation in primary total hip arthroplasty (THA). The TCAT™/TPLAN™ Surgical System is indicated for orthopedic procedures in which the broaching/reaming in primary total hip arthroplasty (THA) may be considered to be safe and effective and where references to rigid anatomical structures may be made.

Device Story

TCAT™/TPLAN™ Surgical System is a 3D graphical preoperative planning and robotic implementation tool for primary total hip arthroplasty (THA). System inputs include patient CT scan data. Surgeon uses TPLAN™ workstation to create a high-level operative plan; TCAT™ robotic system, comprising an electromechanical arm, control electronics, and computer, implements this plan. During surgery, the system provides orientation and reference information; the robotic arm performs precise bone preparation (broaching/reaming) under surgeon supervision. Registration is achieved via point-to-surface mapping. The device is used in clinical settings by surgeons to replace manual template planning and manual bone preparation techniques. Benefits include increased precision in femoral canal preparation. The system includes various accessories such as cutters, drapes, irrigation sets, probes, and markers.

Clinical Evidence

Bench testing only. Performance evaluation included functional software testing for the TPLAN™ workstation, hardware testing, user interface validation, and simulated clinical use of new/modified instruments and sterile disposable accessories.

Technological Characteristics

System consists of TPLAN™ planning workstation and TCAT™ robotic electromechanical arm. Features include CT-based 3D graphical planning, point-to-surface registration, and robotic end-effector bone preparation. Connectivity includes host computer and control electronics. Accessories include cutters, drapes, irrigation sets, probes, and markers. Software architecture supports preoperative planning and robotic control.

Indications for Use

Indicated for patients undergoing primary total hip arthroplasty (THA) where manual broaching/reaming is considered safe and effective and where rigid anatomical structures are available for reference.

Regulatory Classification

Identification

A stereotaxic instrument is a device consisting of a rigid frame with a calibrated guide mechanism for precisely positioning probes or other devices within a patient's brain, spinal cord, or other part of the nervous system.

Predicate Devices

• DigiMatch™ ROBODOC® Surgical System (K072629)

Submission Summary (Full Text)

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

August 18, 2014

Curexo Technology Corporation % Mr. Glen Emelock 32 Harrison Street Melrose, Massachusetts 02176

Re: K140585

Trade/Device Name: TCAT™/TPLANTM Surgical System Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic instrument Regulatory Class: Class II Product Code: OJP, HAW Dated: July 17, 2014 Received: July 21, 2014

Dear Mr. Emelock:

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 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

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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 contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours.

## Lori A. Wiggins -S

for Mark N. Melkerson Director Division of Orthopedic Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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# Indications for Use

K140585 510(k) Number:

Device Name: TCAT™/TPLAN™ Surgical System

### Indications For Use:

The TCAT™/TPLAN™ Surgical System is intended for use as a device which uses diagnostic images of the patient acquired specifically to assist the physician with presurgical planning and to provide orientation and reference information during intraoperative procedures. The robotic surgical tool, under the direction of the surgeon, precisely implements the presurgical software plan.

The preoperative planning software and robotic surgical tool is used as an alternative to manual planning and broaching/reaming techniques for femoral canal preparation in primary total hip arthroplasty (THA).

The TCAT™/TPLANTMSurgical System is indicated for orthopedic procedures in which the broaching/reaming in primary total hip arthroplasty (THA) may be considered to be safe and effective and where references to rigid anatomical structures may be made.

AND/OR

Prescription Use × (Part 21 CFR 801 Subpart D)

Over-The-C
(21 CFR §

Over-The-Counter Use (21 CFR 807 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH. Office of Device Evaluation (ODE)

TCAT™/TPLANTM

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### 510(k) Summary of Safety and Effectiveness

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

- Submitter Name: Submitter Address : Contact Person: Phone Number: Fax Number: Date Prepared: Device Trade Name: Device Common Name: Classification Name: Requlation Number: Predicate device: Reason for submission:
Curexo Technology Corp. 47320 Mission Falls Court Fremont. CA 94539 Glen Emelock [phone] [phone] March, 2014 TCAT™/TPLAN™ Surgical System Stereotaxic Instrument Orthopedic Computer Controlled Surgical System, OJP, HAW 21 CFR 882.4560 DigiMatch™ ROBODOC® Surgical System, K072629 Not previously marketed in the USA

#### Device Description:

The TCAT™ TPLAN™ Surgical System is a three-dimensional, graphical, preoperative planner and implementation tool for treatment of patients who require a total hip arthroplasty (THA) procedure. This device is intended as an alternative to manual template planning, broaching, and reaming techniques for the preparation of bone for patients requiring a THA procedure. The system consists of the TPLAN™ Preoperative Planning Workstation and TCAT™ , a robotic system composed of an electromechanical arm, arm base including control electronics and computer, display monitor, and miscellaneous accessories such as cutters, drapes, irrigation sets, probes, and markers. TPLAN™ and TCAT™ when used according to the instructions for use, make precision bone preparation possible before and during THA surgical procedures..

#### Intended Use:

The TCAT™/TPLAN™ Surgical System is intended for use as a device which uses diagnostic images of the patient acquired specifically to assist the physician with presurgical planning and to provide orientation and reference information during intraoperative procedures. The robotic surgical tool, under the direction of the surgeon, precisely implements the presuraical software plan,

The preoperative planning software and robotic surgical tool is used as an alternative to manual planning and broaching/reaming techniques for femoral canal preparation in primary total hip arthroplasty (THA).

The TCAT™/TPLAN™ Surgical System is indicated for orthopedic procedures in which the broaching/reaming in primary total hip arthroplasty (THA) may be considered to be safe and effective and where references to rigid anatomical structures may be made.

#### Predicate Device:

The TCAT™/TPLAN™ Surgical System is substantially equivalent to the DigiMatch™ ROBODOC® Surgical System, K072629.

#### Comparison of Technological Characteristics and Principles of Operation:

The TCAT™/TPLAN™ Surgical System is similar to the legally marketed device listed previously in that they share the same intended use and indications, technological characteristics, principles of operation and performance data as the predicate device.

Table 1 provides a comparison of technological characteristics and principles of operation between the TCAT™/TPLAN™ Surgical System and its predicate device.

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| | Table 1: Comparison of Technological Characteristics and Principles of Operation | | |
|--|----------------------------------------------------------------------------------|--|--|
| | | | |

| Device | Patient Image Data | Presurgical<br>Plan | Surgical<br>Plan Data | Machine<br>Instructions | Patient/Robot<br>Registration<br>Requirement | Robot<br>Electromechanical<br>Arm |
|-------------------------------------------|--------------------|---------------------|-----------------------------------------|-----------------------------------------------------------------------------------|----------------------------------------------|---------------------------------------------------------------------------------------------------------------------|
| DigiMatch™<br>ROBODOC®<br>Surgical System | Yes, CT Scan | Yes,<br>Presurgery | Yes, high<br>level<br>operative<br>plan | Yes, Robotic<br>Arm driven<br>by validated<br>control<br>software and<br>hardware | Yes, point to<br>surface<br>registration | Yes, robot with<br>single<br>electromechanical<br>arm and end<br>effector implement<br>control file<br>instructions |
| TCAT™/TPLAN™<br>Surgical System | Yes, CT Scan | Yes,<br>Presurgery | Yes, high<br>level<br>operative<br>plan | Yes, Robotic<br>Arm driven<br>by validated<br>control<br>software and<br>hardware | Yes, point to<br>surface<br>registration | Yes, robot with<br>single<br>electromechanical<br>arm and end<br>effector implement<br>control file<br>instructions |

Any minor differences between the TCAT™/TPLAN™Surgical System and its predicate device raise no new questions of safety or effectiveness nor change the device's intended therapeutic effect in comparison to its predicate.

#### Performance Data:

The TCAT™ Surgical System has been evaluated with non-clinical performance testing for the following modifications and or improvements:

- TPLAN™/TCAT™ host computer and operating system .
- TPLAN™/TCAT™ Graphical User Interface .
- TPLAN™/TCAT™ Software Architecture .
- . TPLAN™ addition of CT file complete/size check
- TPLAN™ CT Slice Region of Interest .
- TCAT™ Electromechanical Arm .
- TCAT™ Base Hardware .
- TCAT™ Bearing Sleeve .
- . TPLAN™/TCAT™ elimination of pin patient/robot registration
- . TCAT™ Two-Pin Registration Recovery
- TCAT™ Percutaneous Probe .
- . Change of TCAT™ Irrigation Set Length and Manufacturer
- TCAT™ Monitor Drape .

Bench and simulated use tests included functional software testing for the TPLAN™ Surgical Planning Workstation hardware, software, and user interface, and hardware, functional software, user interface, instrument/tool and sterile disposable accessory testing and simulated clinical use of new and changed instrument /tools for the TCAT™/TPLAN™ Surgical System.

#### Conclusions

In conclusion, based on the intended use, indications for use, technological characteristics and performance data the TCAT™TPLAN™ Surgical is substantially equivalent (SE) to the DigiMatch™ ROBODOC® Surgical System, K072629 predicate device.