Persona Revision Knee System

K191625 · Zimmer, Inc. · JWH · Sep 5, 2019 · Orthopedic

Device Facts

• Record ID: K191625
• Device Name: Persona Revision Knee System
• Applicant: Zimmer, Inc.
• Product Code: JWH · Orthopedic
• Decision Date: Sep 5, 2019
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3560
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

This device is indicated for patients with severe knee pain and disability due to: - Rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis. - Collagen disorders, and/or avascular necrosis of the femoral condyle. - Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy. - Moderate valgus, varus, or flexion deformities. - The salvage of previously failed surgical attempts or for a knee in which satisfactory stability in flexion cannot be obtained at the time of surgery. Porous components may be used cemented (biological fixation). Augments may be attached via bone cement or screw to the tibial plates and/or femoral components. Splined stem extension components are intended to be used press-fit (uncemented). All other femoral component, tibial plate, stem extension, and femoral and tibial augment components are indicated for cemented use only.

Device Story

Persona Revision Knee System is a semi-constrained total knee prosthesis for primary or revision total knee arthroplasty (TKA). System includes femoral components, articular surfaces, tibial components, stem extensions, augments, and cones. Modular design allows configuration to address specific patient bone and joint conditions. Implants are surgically placed by orthopedic surgeons in an operating room. Porous components allow cemented or uncemented (biological) fixation; splined stem extensions are press-fit; other components are cemented. System includes non-implantable instrumentation, cases, and trays for surgical implantation and sterilization. Modifications in this submission involve stem extensions, instruments, and case components. Device restores joint function and stability, reducing pain and disability for patients with severe knee pathology.

Clinical Evidence

No clinical data was deemed necessary for the subject device. Substantial equivalence is supported by non-clinical bench testing, including stem housing cantilever fatigue, four-point bending fatigue, functional relationship analysis, drill debris analysis, reliability verification, cadaveric design validation, distribution/handling verification (ASTM D4169), and bacterial endotoxin testing (ANSI/AAMI ST 72:2011).

Technological Characteristics

Semi-constrained total knee prosthesis. Modular components: femoral, tibial, articular, stem extensions, augments, cones. Materials identical to predicates. Fixation: cemented, uncemented (porous), or press-fit (splined stems). Instrumentation includes cases/trays. Sterilization: identical to predicates. Testing standards: ASTM D4169 (distribution), ANSI/AAMI ST 72:2011 (endotoxin), USP41-NF36 <161> (pyrogen).

Indications for Use

Indicated for patients with severe knee pain and disability due to rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis, collagen disorders, avascular necrosis of the femoral condyle, post-traumatic joint configuration loss, patellofemoral erosion/dysfunction, prior patellectomy, moderate valgus/varus/flexion deformities, or salvage of failed surgical attempts/knee instability.

Regulatory Classification

Identification

A knee joint patellofemorotibial polymer/metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a knee joint. The device limits translation and rotation in one or more planes via the geometry of its articulating surfaces. It has no linkage across-the-joint. This generic type of device includes prostheses that have a femoral component made of alloys, such as cobalt-chromium-molybdenum, and a tibial component or components and a retropatellar resurfacing component made of ultra-high molecular weight polyethylene. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).

Predicate Devices

• Persona Revision Knee System (K181947)
• Natural-Knee II System (K173057)
• Natural-Knee II System (K013031)
• Natural-Knee II System (K982903)
• Natural-Knee II System (K972501)

Submission Summary (Full Text)

{0}------------------------------------------------

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA acronym followed by the full name of the agency, "U.S. Food & Drug Administration," on the right. The FDA part of the logo is in blue.

September 5, 2019

Zimmer Inc. Nicole Meredith Regulatory Project Manager 1800 W. Center Street Warsaw, Indiana 46580

Re: K191625

Trade/Device Name: Persona Revision Knee System Regulation Number: 21 CFR 888.3565 Regulation Name: Knee Joint Patellofemorotibial Metal/Polymer Porous-Coated Uncemented Prosthesis Regulatory Class: Class II Product Code: MBH, JWH, OIY Dated: June 14, 2019 Received: June 18, 2019

Dear Nicole Meredith:

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

{1}------------------------------------------------

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 Ting Song, Ph.D. Acting Assistant Director DHT6A: Division of Joint Arthroplasty Devices OHT6: Office of Orthopedic Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

{2}------------------------------------------------

# Indications for Use

510(k) Number (if known) K191625

Device Name Persona® Revision Knee System

#### Indications for Use (Describe)

This device is indicated for patients with severe knee pain and disability due to:

- Rheumatoid arthritis, osteoarthritis, traumatic arthritis, polyarthritis.

- Collagen disorders, and/or avascular necrosis of the femoral condyle.

- Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy.

- Moderate valgus, varus, or flexion deformities.

- The salvage of previously failed surgical attempts or for a knee in which satisfactory stability in flexion cannot be obtained at the time of surgery.

Porous components may be used cemented (biological fixation). Augments may be attached via bone cement or screw to the tibial plates and/or femoral components. Splined stem extension components are intended to be used press-fit (uncemented). All other femoral component, tibial plate, stem extension, and femoral and tibial augment components are indicated for cemented 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) |

#### CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff [e-mail]

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

{3}------------------------------------------------

K191625 - Page 1 of 4

## 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 Persona Revision Knee 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: | Zimmer Inc.<br>1800 W. Center Street<br>Warsaw, IN 46580<br>Establishment Registration Number: 1822565 | |
|--------------------|--------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact Person: | Nicole J. Meredith<br>Regulatory Affairs Project Manager<br>Telephone: [phone]<br>Fax: [phone] | |
| Date: | August 19, 2019 | |
| Subject Device: | Trade Name: Persona® Revision Knee System | |
| | Common Name: Knee Prosthesis | |
| | Classification Name: | |
| | • | MBH – Prosthesis, Knee, Patello/Femorotibial,<br>Semi-Constrained, Uncemented, Porous, Coated,<br>Polymer/Metal/Polymer (21 CFR 888.3565) |
| | • | JWH – Prosthesis, Knee, Patellofemorotibial, Semi-<br>Constrained, Cemented, Polymer/Metal/Polymer (2<br>CFR 888.3560) |
| | • | OIY – Prosthesis, Knee, Patellofemorotibial, Semi-<br>Constrained, Cemented, Polymer +<br>Additive/Metal/Polymer + Additive (21 CFR<br>888.3560) |
| Predicate Devices: | Persona Revision Knee System | K181947 |
| | Natural-Knee II System | K173057<br>K013031<br>K982903<br>K972501 |

{4}------------------------------------------------

### Purpose and Device Description:

The purpose of this submission is for modifications to the Persona Revision stem extensions, several instruments, and the associated case components of the Persona Revision Knee System. These modifications do not change the intended use or fundamental scientific technology of the device.

The Persona Revision Knee System is a semi-constrained total knee prosthesis consisting of anatomically shaped components designed to resurface the articulating surface of the femoral and tibial bones including:

- Femoral components
- Articular surfaces ●
- Tibial components
- Stem extensions ●
- Femoral and tibial augments ●
- Femoral and tibial cones .

The large modularity of the componentry of the Persona Revision knee system including articular surfaces with different levels of constraint, augments, cones and stem extensions provides numerous possible configurations to optimally address the bone and joint condition of the patient in a primary or revision TKA surgery.

The Persona Revision Knee System also includes nonimplantable tools, or instrumentation, that facilitate the implantation of above described implant components as well as cases and trays to hold these instruments during sterilization and their subsequent storage.

## Intended Use and Indications for Use:

This device is indicated for patients with severe knee pain and disability due to:

- Rheumatoid arthritis, osteoarthritis, traumatic arthritis, । polyarthritis.
- Collagen disorders, and/or avascular necrosis of the femoral condyle.
- । Post-traumatic loss of joint configuration, particularly when there is patellofemoral erosion, dysfunction or prior patellectomy.
- Moderate valgus, varus, or flexion deformities. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

{5}------------------------------------------------

- The salvage of previously failed surgical attempts or | for a knee in which satisfactory stability in flexion cannot be obtained at the time of surgery.
Porous components may be used cemented or uncemented (biological fixation). Augments may be attached via bone cement or screw to the tibial plates and/or femoral components. Splined stem extension components are intended to be used press-fit (uncemented). All other femoral component, tibial plate, stem extension, and femoral and tibial augment components are indicated for cemented use only.

## Summary of Technological Characteristics:

The rationale for substantial equivalence is based on consideration of the following characteristics:

- Intended Use: Identical to the predicates ●
- Indications for Use: Identical to the predicates ●
- Materials: Identical to the predicates ●
- Design Features: Similar to the predicates ●
- . Sterilization: Identical to the predicates

Summary of Performance Data (Nonclinical and/or Clinical)

#### Non-Clinical Tests: . Stem Extensions

- Stem housing cantilever fatigue per internal test o method
- Four-point bending fatigue strength per internal O test method

#### Instrumentation

- Functional relationship analyses (tolerance stack o up)
- Drill debris analysis per internal test method O
- Reliability verification per internal test method O
- O Cadaveric design validation

## Cases and Trays

- Distribution and handling verification per ASTM о D4169
#### System

- Bacterial Endotoxin Test (BET) per ANSI/AAMI o ST 72:2011as part of cleaning validation

{6}------------------------------------------------

K191625 - Page 4 of 4

demonstrating implants meet the limit of ≤20 Endotoxin units (EU)/Device per USP41-NF36 Chapter <161> Medical Devices - Bacterial Endotoxin and Pyrogen Tests

#### Clinical Tests: ●

- o Clinical data was not deemed necessary for the subject device.
The subject device has the same intended use and indications for use as the predicate devices. The subject device has similar technological characteristics to the predicates, and the performance data and analyses demonstrate that:

- any differences 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 devices.

## Substantial Equivalence Conclusion