TSolution One Surgical System Model 210

K170430 · THINK Surgical, Inc. · OLO · Mar 6, 2017 · Neurology

Device Facts

• Record ID: K170430
• Device Name: TSolution One Surgical System Model 210
• Applicant: THINK Surgical, Inc.
• Product Code: OLO · Neurology
• Decision Date: Mar 6, 2017
• Decision: SESE
• Submission Type: Special
• Regulation: 21 CFR 882.4560
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The TSolution One® Surgical System Model 210 is intended for use as a device that 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/impacting techniques for femoral canal and acetabular cup preparation in primary cementless total hip arthroplasty (THA) using a posterior approach. The TSolution One® Surgical System Model 210 is indicated for orthopedic procedures in which the broaching, reaming and impacting techniques used in primary cementless total hip arthroplasty (THA) using a posterior approach may be considered to be safe and effective and where references to rigid anatomical structures may be made. The TSolution One® Surgical System Model 210 is also intended to assist the surgeon in determining reference alignment axes in relation to anatomical and instrumentation structures during stereotactic orthopedic surgical procedures. The TSolution One® Surgical System Model 210 facilitates accurate positioning of THA implants, relative to these alignment axes.

Device Story

System comprises TPLAN preoperative planning workstation and TCAT robotic system; TCAT includes electromechanical arm, control electronics, computer, display, and surgical accessories (cutters, probes, markers). Inputs: patient CT scan data. Process: surgeon uses TPLAN to create 3D preoperative plan; TCAT robotic arm, under surgeon direction, executes plan by performing femoral canal and acetabular cup preparation. Output: precise bone preparation and implant positioning. Used in OR by surgeons. Benefits: provides alternative to manual planning/preparation; facilitates accurate implant positioning relative to anatomical reference axes.

Clinical Evidence

Bench testing only. Verification and validation activities included software testing for TPLAN and TCAT functionality (including acetabular cup guidance) and surgical instrument testing. All tests passed.

Technological Characteristics

Stereotaxic orthopedic instrument; electromechanical robotic arm; CT-based 3D preoperative planning; point-to-surface registration; software-controlled robotic execution of bone preparation; includes cutters, drapes, irrigation sets, probes, and markers.

Indications for Use

Indicated for patients requiring primary cementless total hip arthroplasty (THA) using a posterior approach where manual broaching, reaming, and impacting techniques are considered safe and effective.

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

• TSolution One™ Cup1 Surgical System (K162195)

Submission Summary (Full Text)

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

March 6, 2017

Think Surgical Inc. % Glen Emelock Senior Partner The Cro Group, Inc. 32 Harrison St. Melrose, Massachusetts 02176

Re: K170430

Trade/Device Name: Tsolution One Surgical System Model 210 Regulation Number: 21 CFR 882.4560 Regulation Name: Stereotaxic Instrument Regulatory Class: Class II Product Code: OLO Dated: February 13, 2017 Received: February 13, 2017

Dear Glen 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 devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (OS) 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/ResourcesforYou/Industry/default.htm. 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 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,

# Mark N. Melkerson -S

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

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES

Food and Drug Administration

**Indications for Use**

| Form Approved: OMB No. | 0910-0120 |
|--------------------------|------------------|
| Expiration Date: | January 31, 2017 |
| See PRA Statement below. | |

| 510(k) Number ( <i>if known</i> ) | K170430 |
|-----------------------------------|------------------------------------------|
| Device Name | TSolution One® Surgical System Model 210 |

Indications for Use (*Describe*)

The TSolution One® Surgical System Model 210 is intended for use as a device that 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/impacting techniques for femoral canal and acetabular cup preparation in primary cementless total hip
arthroplasty (THA) using a posterior approach.

The TSolution One® Surgical System Model 210 is indicated for orthopedic procedures in which the broaching, reaming
and impacting techniques used in primary cementless total hip arthroplasty (THA) using a posterior approach may be
considered to be safe and effective and where references to rigid anatomical structures may be made.

The TSolution One® Surgical System Model 210 is also intended to assist the surgeon in determining reference alignment
axes in relation to anatomical and instrumentation structures during stereotactic orthopedic surgical procedures. The
TSolution One® Surgical System Model 210 facilitates accurate positioning of THA implants, relative to these alignment
axes.

Type of Use (*Select one or both, as applicable*)

| <span></span> Prescription Use (Part 21 CFR 801 Subpart D) | <span></span> Over-The-Counter Use (21 CFR 801 Subpart C) |
|------------------------------------------------------------|-----------------------------------------------------------|
|------------------------------------------------------------|-----------------------------------------------------------|

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| FORM FDA 3881 (8/14) | Page 1 of 1 | PSC Publishing Services [phone] | EF |
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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.

THINK Surgical. Inc.

Submitter Name: Submitter Address : Contact Person: Phone Number: Fax Number: Date Prepared: Device Trade Name: Device Common Name: Classification Name: Product Code: Predicate device: Reason for submission:

47201 Lakeview Blvd.. Fremont, CA 94538 Glen Emelock [phone] [phone] January 26, 2017 TSolution One® Surgical System Model 210 Orthopedic Stereotaxic Instrument 21 CFR 882.4560, Stereotaxic Instrument OLO TSolution One™ Cup1 Surgical System, K162195 Not previously marketed in the USA

#### Device Description:

The TSolution One® Surgical System Model 210 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, reaming and impacting techniques for the preparation of femoral canal and acetabular cup for patients requiring a primary 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 femoral canal and acetabular cup preparation possible before and during THA surgical procedures..

#### Indications for Use:

The TSolution One® Surgical System Model 210 is intended for use as a device that 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/impacting techniques for femoral canal and acetabular cup preparation in primary cementless total hip arthroplasty (THA) using a posterior approach.

The TSolution One® Surgical System Model 210 is indicated for orthopedic procedures in which the broaching, reaming and impacting techniques used in primary cementless total hip arthroplasty (THA) using a posterior approach may be considered to be safe and effective and where references to rigid anatomical structures may be made.

The TSolution One® Surgical System Model 210 is also intended to assist the surgeon in determining reference alignment axes in relation to anatomical and instrumentation structures during stereotactic orthopedic surgical procedures. The TSolution One® Surgical System Model 210 facilitates accurate positioning of THA implants, relative to these alignment axes.

#### Predicate Device:

The TSolution One® Surgical System Model 210 is substantially equivalent to the TSolution One® Cup1 Surgical System, K162195.

## Comparison of Technological Characteristics and Principles of Operation:

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The TSolution One® Surgical System Model 210 is very similar to the legally marketed predicate in that they share the same intended use and indications, same fundamental scientific technology, same principles of operation and similar technological characteristics and performance data as the predicate device.

Table 1 provides a comparison of technological characteristics and principles of operation between the The TSolution One® Cup1 Surgical System and its predicate devices.

| Device | Patient Image Data | Presurgical<br>Plan | Surgical<br>Plan Data | Machine<br>Instructions | Patient/Device<br>Registration<br>Requirement | Robot<br>Electromechanical<br>Arm |
|------------------------------------------------|--------------------|---------------------|-----------------------------------------|-----------------------------------------------------------------------------------|-----------------------------------------------|---------------------------------------------------------------------------------------------------------------------|
| TSolution One®<br>Cup1 Surgical<br>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 |
| TSolution One®<br>Surgical System<br>Model 210 | 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 |

Table 1: Comparison of Technological Characteristics and Principles of Operation

Any minor differences between the TSolution One® Surgical System Model 210 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 TSolution One® Surgical System Model 210 has been evaluated with non-clinical performance testing for the following modifications and or improvements:

- TPLAN Bug Fixes
- TCAT Bug Fixes
- TCAT Instrument Changes .
- TPLAN Operating System Upgrade .
- System User Manuals Changes .

#### Table 2: Verification / Validation Activities

| Verification / Validation Activity | Purpose | Results |
|-------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Software Testing | Verify TPLAN® presurgical planning and TCAT®<br>surgical system software function as intended to<br>successfully complete THA procedure including<br>Acetabular Cup Guidance | PASS |
| Support Surgical Instrument Testing | Verify TCAT® surgical support instruments<br>function as intended to successfully complete THA<br>procedure including Acetabular Cup Guidance and<br>meet user needs. | PASS |

In accordance with the Design Control process, risk analysis was conducted to evaluate the impact of modifications to the predicate instruments. Design validation testing were conducted on the subject instruments to confirm that the design input requirements and that each instrument is safe and effective for its intended use.

#### Conclusions

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The results of performance testing indicated the device performed within the intended use and the differences between the predicate and the TSolution One® Surgical System Model 210 do not raise any new safety or efficacy issues. Supporting included in this premarket submission confirms that the TSolution
One® Surgical System Model 210 is safe and effective for the intended use and i the predicate device.