Signature ONE System

K190595 · Orthosoft Inc (D/B/A Zimmer Cas) · KWT · Jun 5, 2019 · Orthopedic

Device Facts

• Record ID: K190595
• Device Name: Signature ONE System
• Applicant: Orthosoft Inc (D/B/A Zimmer Cas)
• Product Code: KWT · Orthopedic
• Decision Date: Jun 5, 2019
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3650
• Device Class: Class 2

Intended Use

The Signature™ ONE System is indicated, based on patient-specific radiological images with identifiable placement anatomical landmarks, to assist in pre-operative planning and/or intra-operative guiding of surgical instruments for shoulder replacement surgical procedures on patients not precluded from being radiologically scanned. The Signature™ ONE System is to be used with the glenoid components of the following shoulder implant systems in accordance with their indications: Zimmer® Trabecular Metal™ Reverse Plus Shoulder, Comprehensive® Total Shoulder System, Comprehensive® Reverse Shoulder System and Comprehensive® Reverse Augmented Baseplates. The Signature™ ONE Guides and bone models are intended for single use only.

Device Story

System uses patient-specific radiological images to assist in pre-operative planning and intra-operative guidance for shoulder replacement. Surgeon interacts with Signature™ ONE Planner to review, modify, and approve surgical plans. System generates patient-specific guides and bone models via additive manufacturing (selective laser sintering) using polyamide (nylon). Guides/models are shipped non-sterile to hospitals for sterilization and single-use intra-operatively. Workflow involves imaging technician, surgeon, and Zimmer Biomet operators using internal manufacturing software. System facilitates accurate transfer of pre-operative plan to surgical site; allows conversion to conventional technique if needed. Benefits include improved surgical planning and instrument guidance for glenoid component placement.

Clinical Evidence

Bench testing only. Includes biocompatibility (ISO 10993), sterilization/shelf-life validation, physical/performance testing, engineering analysis, usability engineering, and validation lab testing using cadaveric specimens to confirm safety and effectiveness.

Technological Characteristics

Materials: Polyamide (nylon). Manufacturing: Additive manufacturing (selective laser sintering). Form factor: Patient-specific guides and bone models. Sterilization: Hospital-performed. Shelf life: 6 months. Software: Planning application and internal manufacturing software.

Indications for Use

Indicated for patients undergoing shoulder replacement surgery who are eligible for radiological scanning. Used to assist in pre-operative planning and intra-operative guidance for glenoid component placement in anatomic and reverse shoulder arthroplasty.

Regulatory Classification

Identification

A shoulder joint metal/polymer non-constrained cemented prosthesis is a device intended to be implanted to replace a shoulder joint. The device limits minimally (less than normal anatomic constraints) translation in one or more planes. It has no linkage across-the-joint. This generic type of device includes prostheses that have a humeral component made of alloys, such as cobalt-chromium-molybdenum, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, and is limited to those prostheses intended for use with bone cement (§ 888.3027).

Special Controls

*Classification.* Class II. The special controls for this device are:(1) FDA's: (i) “Use of International Standard ISO 10993 ‘Biological Evaluation of Medical Devices—Part I: Evaluation and Testing,’ ” (ii) “510(k) Sterility Review Guidance of 2/12/90 (K90-1),” (iii) “Guidance Document for Testing Orthopedic Implants with Modified Metallic Surfaces Apposing Bone or Bone Cement,” (iv) “Guidance Document for the Preparation of Premarket Notification (510(k)) Application for Orthopedic Devices,” and (v) “Guidance Document for Testing Non-articulating, ‘Mechanically Locked’ Modular Implant Components,” (2) International Organization for Standardization's (ISO): (i) ISO 5832-3:1996 “Implants for Surgery—Metallic Materials—Part 3: Wrought Titanium 6-Aluminum 4-Vandium Alloy,” (ii) ISO 5832-4:1996 “Implants for Surgery—Metallic Materials—Part 4: Cobalt-Chromium-Molybdenum Casting Alloy,” (iii) ISO 5832-12:1996 “Implants for Surgery—Metallic Materials—Part 12: Wrought Cobalt-Chromium-Molybdenum Alloy,” (iv) ISO 5833:1992 “Implants for Surgery—Acrylic Resin Cements,” (v) ISO 5834-2:1998 “Implants for Surgery—Ultra-high Molecular Weight Polyethylene—Part 2: Moulded Forms,” (vi) ISO 6018:1987 “Orthopaedic Implants—General Requirements for Marking, Packaging, and Labeling,” and (vii) ISO 9001:1994 “Quality Systems—Model for Quality Assurance in Design/Development, Production, Installation, and Servicing,” and (3) American Society for Testing and Materials': (i) F 75-92 “Specification for Cast Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implant Material,” (ii) F 648-98 “Specification for Ultra-High-Molecular-Weight Polyethylene Powder and Fabricated Form for Surgical Implants,” (iii) F 799-96 “Specification for Cobalt-28 Chromium-6 Molybdenum Alloy Forgings for Surgical Implants,” (iv) F 1044-95 “Test Method for Shear Testing of Porous Metal Coatings,” (v) F 1108-97 “Titanium-6 Aluminum-4 Vanadium Alloy Castings for Surgical Implants,” (vi) F 1147-95 “Test Method for Tension Testing of Porous Metal Coatings,” (vii) F 1378-97 “Specification for Shoulder Prosthesis,” and (viii) F 1537-94 “Specification for Wrought Cobalt-28 Chromium-6 Molybdenum Alloy for Surgical Implants.”

Predicate Devices

• Zimmer PSI Shoulder (K150730)
• Signature Personalized Patient Care System- Glenoid Guide System (K130126)

Reference Devices

• CAS PSI Knee System (K131409)

Submission Summary (Full Text)

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June 05, 2019

Image /page/0/Picture/1 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Orthosoft, Inc (d/b/a Zimmer CAS) Paul Hardy Regulatory Affairs Senior Specialist 75 Queen Street Suite 3300 Montreal, QC, CANADA H3C 2N6

Re: K190595

Trade/Device Name: Signature™ ONE System Regulation Number: 21 CFR 888.3660 Regulation Name: Shoulder joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: QHE, KWT, KWS, PHX, MBF Dated: March 6, 2019 Received: March 7, 2019

Dear Paul Hardy:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

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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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

For CAPT Raquel Peat, PhD, MPH, USPHS Director OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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# Indications for Use

510(k) Number (if known) K190595

Device Name Signature™ ONE System

#### Indications for Use (Describe)

The Signature™ ONE System is indicated, based on patient-specific radiological images with identifiable placement anatomical landmarks, to assist in pre-operative planning and/or intra-operative guiding of surgical instruments for shoulder replacement surgical procedures on patients not precluded from being radiologically scanned.

The Signature™ ONE System is to be used with the glenoid components of the following shoulder implant systems in accordance with their indications: Zimmer® Trabecular Metal™ Reverse Plus Shoulder, Comprehensive® Total Shoulder System, Comprehensive® Reverse Shoulder System and Comprehensive® Reverse Augmented Baseplates.

The Signature™ ONE Guides and bone models are intended for single use only.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 801 Subpart C)

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## 510(k) Summary

In accordance with 21 CFR §807.92 and the Safe Medical Devices Act of 1990, the following information is provided for the Signature™ ONE System 510(k) premarket notification. The submission was prepared in accordance with the FDA guidance document, 'Format for Traditional and Abbreviated 510(k)s', issued on August 12, 2005.

| Sponsor: | Orthosoft, Inc (d/b/a Zimmer CAS)<br>75 Queen St., Suite 3300<br>Montreal, QC, CANADA H3C 2N6<br>Establishment Registration Number: 9617840 |
|-----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Paul Hardy<br>Regulatory Affairs Sr. Specialist<br>Telephone: [phone] |
| Date: | June 5, 2019 |
| Subject Device: | Trade Name: Signature™ ONE System<br>Common Name: Shoulder Arthroplasty implantation<br>system |
| | Classification Name:<br>• QHE-Shoulder Arthroplasty implantation system (21<br>CFR 888.3660) |
| | Additional Product Codes |
| | • KWT- Shoulder joint metal/polymer non-constrained<br>cemented prosthesis<br>• KWS- Shoulder joint metal/polymer semi-constrained<br>cemented prosthesis<br>• PHX- Shoulder joint metal/polymer non-constrained<br>cemented prosthesis<br>• MBF- Shoulder joint metal/polymer/metal non-<br>constrained or semi-constrained porous coated<br>uncemented prosthesis |

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| Manufacturer | Device Name | 510(k) Number |
|---------------------------------|------------------------------------------------------------------------------|---------------|
| Zimmer CAS<br>*Primary | Zimmer PSI<br>Shoulder | K150730 |
| Biomet | Signature<br>Personalized Patient<br>Care System-<br>Glenoid Guide<br>System | K130126 |
| Zimmer CAS<br>*Reference Device | CAS PSI Knee<br>System | K131409 |

# Predicate Device(s):

## Purpose and Device Description:

The Signature™ ONE System is developed to assist in pre-operative planning of the glenoid component for Total Shoulder Arthroplasty (using the Signature™ ONE Planner) and to accurately transfer a pre-operative plan to orthopedic surgical procedures (using the Signature™ ONE Guides) if desired. Both anatomic and reverse (TSA and RSA respectively) approaches are supported.

The Signature ONE Guides and Bone Model are designed and manufactured of polyamide (nylon) using additive manufacturing (selective laser sintering), based on the approved/finalized pre-surgical plan and shipped prior to surgery. The guides and bone models are provide nonsterile and sterilized at the hospital. They are used intraoperatively to assist the surgeon in reproducing the plan. The Signature ONE System surgical technique remains close to the conventional shoulder arthroplasty to allow converting to standard surgical technique at any time if needed during the operation.

The Signature™ ONE System uses the Zimmer Biomet Drive Portal for the interaction with external users (i.e. imaging technician and the surgeon). The internal users (i.e. the Zimmer Biomet operators) use manufacturing software applications to prepare the patient cases for the surgeon.

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| Indications for Use: | The Signature™ ONE System is indicated, based on<br>patient-specific radiological images with identifiable<br>placement anatomical landmarks, to assist in pre-operative<br>planning and/or intra-operative guiding of surgical<br>instruments for shoulder replacement surgical procedures<br>on patients not precluded from being radiologically<br>scanned. |
|----------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | The Signature™ ONE System is to be used with the<br>glenoid components of the following shoulder implant<br>systems in accordance with their indications and<br>contraindications: Zimmer® Trabecular Metal™ Reverse<br>Plus Shoulder, Comprehensive® Total Shoulder System,<br>Comprehensive® Reverse Shoulder System and<br>Comprehensive® Reverse Augmented Baseplates. |
| | The Signature™ ONE Guides and Bone Models are<br>intended for single use only. |
| Differences in Indications for Use | The proposed device offers options specific to the<br>compatible implant components that are not present in the<br>primary predicate device |
| Summary of Technological<br>Characteristics: | The rationale for substantial equivalence is based on<br>consideration of the following characteristics:<br>The proposed and predicate device are intended to assist in<br>pre-operative planning and/or intraoperative guiding of<br>surgical instruments for shoulder replacement surgical procedures The proposed and predicate device both utilize preoperative<br>images, intraoperative guidance of instruments, and<br>assistance of glenoid component placement The proposed and predicate device utilize 3D printing (SLS) |
| | to manufacture the guides, the guides are non-sterile single-<br>use, and have a shelf life of 6 months<br>The proposed and predicate device utilize internal<br>manufacturing software applications and a planning<br>application that the surgeon interacts with to review, modify and approve the plan |

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### Summary of Performance Data (Nonclinical and/or Clinical)

The following performance data was provided in support of the substantial equivalence determination:

### Biocompatibility Testing

The biocompatibility evaluation for Signature™ ONE System was conducted in accordance with ISO 10993. The evaluation reveals that the Signature™ ONE System device meets biocompatibility requirements.

### Sterilization and Shelf-Life

This analysis was conducted to ensure that the cleaning and sterilization instructions for the Signature™ ONE System parts respect the acceptable residual levels that should be achieved by the cleaning and sterilization method, as required by the applicable standards. Testing was also conducted to ensure the acceptance criteria was met of the guides keeping their dimensional integrity throughout their shelf life of 6 months.

#### Device Performance Testing

Verification and Validation Testing for Signature™ ONE System was conducted with the following aspects:

- Physical/Performance Tests- to ensure the performance of o the implemented features and verify related design inputs
- Engineering Analysis- to ensure the performance of the o implemented features and verify related design inputs
- Usability Engineering- addressed user interactions with the O Signature™ ONE System
- Validation Lab- performed to validate that using the O Signature™ ONE System is safe and effective and that the performances of the Signature™ ONE System are acceptable under full simulated use on cadaveric specimens

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#### Software Verification and Validation Testing

Software tests were conducted to satisfy the requirements of the FDA Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices and IEC 62304 (Medical Device Software- Life Cycle Process). The software is considered a "moderate" level of concern, a malfunction in the device could lead to a minor injury. The testing demonstrates that the Signature™ ONE System does not raise any new issues of safety and effectiveness as compared to the predicate device(s).

### Substantial Equivalence Conclusion

The proposed and predicate device(s) have the same intended use and similar technological characteristics and the same principles of operation. The proposed device offers options specific to the compatible implant components that are not present in the predicate device as well as the option for the user to end the preoperative workflow after planning without ordering guides. In addition, the proposed device pin guide provides a larger contact surface than found on the predicate device. In sum, any differences between the devices do not raise new questions of safety and effectiveness and the proposed device is at least as safe and effective as the legally marketed predicate device(s).