K223876 · Lima Corporate S.P.A. · MBF · Feb 3, 2023 · Orthopedic
Device Facts
Record ID
K223876
Device Name
SMR Shoulder System
Applicant
Lima Corporate S.P.A.
Product Code
MBF · Orthopedic
Decision Date
Feb 3, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 888.3670
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The SMR Shoulder System is intended for partial or total, primary or revision shoulder joint replacement. The SMR Anatomic Shoulder System is indicated for partial or total, primary or revision shoulder joint replacement in patients suffering from disability due to: non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis; inflammatory degenerative joint disease such as rheumatoid arthritis; treatment of acute fractures of the humeral head that cannot be treated with other fracture fixation methods; revision of a failed primary implant; in case of SMR Short Stems only if sufficient bone stock remains); cuff tear arthropathy (CTA Heads only); glenoid arthrosis without excessive glenoid bone loss: A1, A2 and B1 according to Walch classification (SMR TT Hybrid Glenoid only). The SMR Reverse Shoulder System is indicated for primary, fracture or revision total shoulder replacement in a grossly rotator cuff deficient joint with severe arthropathy (disabled shoulder). The patient's joint must be anatomically suited to receive the selected implants and a functional deltoid muscle is necessary to use the device. The SMR TT Hybrid Glenoid Reverse Baseplate must not be used in cases of excessive glenoid bone loss and/or when bone graft is needed.
Device Story
Modular shoulder prosthesis system for primary or revision total/partial joint replacement. Components include humeral stems, bodies, heads, adaptors, glenospheres, and glenoid baseplates. System allows cemented or uncemented fixation depending on construct. Used in clinical orthopedic settings by surgeons to restore joint function in patients with severe arthropathy or cuff deficiency. Device provides mechanical replacement of shoulder joint surfaces; output is a stable, articulated joint construct. Benefits include pain relief and improved range of motion. This submission introduces new component compatibilities: 5.0mm bone screws with SMR Metal Back Glenoid and SMR TT Baseplate; SMR TT Hybrid Glenoid Reverse Baseplate with 42mm Glenosphere.
Clinical Evidence
No clinical data. Substantial equivalence demonstrated via bench testing, specifically dynamic evaluation of glenoid loosening/disassociation per ASTM F2028 on worst-case configurations.
Technological Characteristics
Modular shoulder prosthesis. Materials: Ti6Al4V (ISO 5832-3, ASTM F1472), 3D printed Ti6Al4V, CoCrMo (ISO 5832-12, ASTM F1537), UHMWPE (ISO 5834-2, ASTM F648), LimaVit Vitamin E highly crosslinked UHMWPE (ASTM F2695, F2565), PoroTi coating (ASTM F1580), Tantalum (ISO 12782, ASTM F560). Fixation: Cemented or uncemented (screw-fixated).
Indications for Use
Indicated for partial/total, primary/revision shoulder joint replacement in patients with non-inflammatory/inflammatory degenerative joint disease (osteoarthritis, avascular necrosis, rheumatoid arthritis), acute humeral head fractures, failed primary implants, cuff tear arthropathy, or glenoid arthrosis. Reverse configuration indicated for grossly rotator cuff deficient joints with severe arthropathy; requires functional deltoid muscle and anatomically suitable joint. Contraindicated for excessive glenoid bone loss where bone graft is needed.
Regulatory Classification
Identification
A shoulder joint metal/polymer/metal nonconstrained or semi-constrained porous-coated uncemented prosthesis is a device intended to be implanted to replace a shoulder joint. The device limits movement 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 (Co-Cr-Mo) and titanium-aluminum-vanadium (Ti-6Al-4V) alloys, and a glenoid resurfacing component made of ultra-high molecular weight polyethylene, or a combination of an articulating ultra-high molecular weight bearing surface fixed in a metal shell made of alloys such as Co-Cr-Mo and Ti-6Al-4V. The humeral component and glenoid backing have a porous coating made of, in the case of Co-Cr-Mo components, beads of the same alloy or commercially pure titanium powder, and in the case of Ti-6Al-4V components, beads or fibers of commercially pure titanium or Ti-6Al-4V alloy, or commercially pure titanium powder. The porous coating has a volume porosity between 30 and 70 percent, an average pore size between 100 and 1,000 microns, interconnecting porosity, and a porous coating thickness between 500 and 1,500 microns. This generic type of device is designed to achieve biological fixation to bone without the use of bone cement.
Special Controls
*Classification.* Class II (special controls). The special control for this device is FDA's “Class II Special Controls Guidance: Shoulder Joint Metal/Polymer/Metal Nonconstrained or Semi-Constrained Porous-Coated Uncemented Prosthesis.”
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February 3, 2023
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 consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.
LimaCorporate S.p.A. % Kenneth Newman Regulatory Affairs Associate Lima USA Inc. 2001 NE Green Oaks Blvd. Ste. 100 Arlington, Texas 76006
Re: K223876
Trade/Device Name: SMR Shoulder System Regulation Number: 21 CFR 888.3670 Regulation Name: Shoulder joint metal/polymer/metal nonconstrained or semi-constrained porouscoated uncemented prosthesis Regulatory Class: Class II Product Code: MBF, PHX, KWS, KWT, PAO Dated: December 22, 2022 Received: December 23, 2022
Dear Kenneth Newman:
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.
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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 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 (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Farzana
Digitally signed by
Farzana Sharmin -S
Sharmin -S Date: 2023.02.03
16:35:46 -05'00'
For Victoria Lilling, M.D. 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
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### Indications for Use
510(k) Number (if known)
#### K223876
Device Name
SMR Shoulder System
Indications for Use (Describe)
The SMR Shoulder System is intended for partial or total, primary or revision shoulder joint replacement.
The SMR Anatomic Shoulder System is indicated for partial or total, primary or revision shoulder joint replacement in patients suffering from disability due to:
- non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis;
- inflammatory degenerative joint disease such as rheumatoid arthritis; ●
- treatment of acute fractures of the humeral head that cannot be treated with other fracture fixation methods;
- revision of a failed primary implant; in case of SMR Short Stems only if sufficient bone stock remains);
- . cuff tear arthropathy (CTA Heads only);
- glenoid arthrosis without excessive glenoid bone loss: A1, A2 and B1 according to Walch classification (SMR TT Hybrid ● Glenoid only).
The SMR Reverse Shoulder System is indicated for primary, fracture or revision total shoulder replacement in a grossly rotator cuff deficient ioint with severe arthropathy (disabled shoulder). The patient's ion t must be anatomically suited to receive the selected implants and a functional deltoid muscle is neces sary to use the device.
The SMR TT Hybrid Glenoid Reverse Baseplate must not be used in cases of excessive glenoid bone loss and/or when bone graft is needed.
The Modular SMR Shoulder System allows the assembly of components in various humeral and glenoid constructs. The constructs are intended for cemented and uncemented use as specified in the following table.
In the Anatomic shoulder the humeral consists of the humeral stem, the humeral body, the adaptor taper and the humeral head. In the Reverse shoulder the humeral consists of the humeral stem, the reverse humeral body and the reverse liner. On the humeral side the fixation of the humeral stem determines if the construct is cemented.
The Anatomic glenoid construct consists of an all polyethylene glenoid, a polyethylene glenoid with metal peg or a metal back assembled with a liner; the Reverse glenoid consists of a metal back/connector/glenosphere of a peg/baseplate/glenosphere construct.
On the glenoid side, the fixation of all polyethylene glenoid with metal peg or the metal back determines if the construct is cemented or uncemented.
| System | | Components | Material | Use | |
|--------|---|---------------------------------------------------|----------|-----|------------|
| A | R | | | Cem | Not<br>Cem |
| ● | ● | SMR Stem (Cemented, Cemented Revision) | Ti6Al4V | X | |
| ● | ● | SMR Stem (Cementless Finned, Cementless Revision) | Ti6Al4V | | X |
| ● | ● | SMR Short Stem (Cementless Finned) | Ti6Al4V | | X |
| ● | ● | SMR Humeral Body (Trauma, Finned) | Ti6Al4V | X | X |
| ● | ● | SMR Reverse Humeral Body | Ti6Al4V | X | X |
| ● | ● | Humeral Extension | Ti6Al4V | X | X |
| ● | ● | SMR Humeral Head (Standard*, CTA) | CoCrMo | X | X |
| ● | ● | SMR Adaptor Taper (Neutral, Eccentric) | Ti6Al4V | X | X |
| ● | ● | SMR CTA Head Adaptor for Reverse Humeral Body | Ti6Al4V | X | X |
| | ● | SMR Glenosphere* | CoCrMo | | X |
| | ● | SMR Connector* | Ti6Al4V | | X |
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2023 See PRA Statement below.
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| | | | UHMWPE | X | X |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---|-------------------------------------------------|------------------------------------------------------|----|----|
| | ● | Reverse Liner | LimaVit™ (Vitamin E<br>highly crosslinked<br>UHMWPE) | X | X |
| ● | | SMR Cemented Glenoid | UHMWPE | X | |
| ● | | SMR 3 Pegs Cemented Glenoid | UHMWPE | X | |
| ● | * | SMR TT Hybrid Glenoid | UHMWPE+ Ti6Al4V 3D<br>printed +Ta | X | X |
| | ● | SMR TT Hybrid Glenoid Reverse Baseplate + Screw | Ti6Al4V | | X |
| ● | ● | SMR Metal Back Glenoid | Ti6Al4V+PoroTi | X* | X* |
| ● | ● | SMR TT Baseplate | Ti6Al4V | X* | X* |
| | ● | SMR TT Augmented 360 Baseplate | Ti6Al4V | | X |
| ● | ● | SMR TT Glenoid Peg | Ti6Al4V 3D printed | X | X |
| ● | | SMR Metal Back Liner | UHMWPE | X* | X* |
| * | ● | SMR Bone screw | Ti6Al4V | | X |
| Material Standards | | | | | |
| Ti6Al4V (ISO 5832-3 - ASTM F1472) – Ti6Al4V 3D printed (to meet the mechanical and chemical requirements of ISO 5832-3) -<br>CoCrMo (ISO 5832-12 - ASTM F1537) – UHMWPE (ISO 5834-2 - ASTM F648) - LimaVit™ (Vitamin E highly crosslinked<br>UHMWPE) (ISO 5834-2 - ASTM F648 - ASTM F2695 – ASTM F2565) - PoroTi Titanium Coating (ASTM F1580) - Ta<br>(ISO12782 - ASTM F560) | | | | | |
#### A= Anatomic / R=Reverse
*NOTE:
- When considering the humeral side, SMR Glenosphere 042 can be coupled only with PRIMA Humeral System.
- In the US, the SMR Metal Backed Glenoid/Liner construct, used as part of the SMR Anatomic Shoulder ● Replacement, is intended for use with bone cement and should be used without bone screws.
- . The SMR Metal Backed Glenoid/Connector/Glenosphere construct, used as part of the SMR Reverse Shoulder replacement, is intended for uncemented use with the addition of screws for fixation.
- SMR Lateralized Connectors are not indicated for use with glenoid bone grafting techniques. ●
- . In the US the SMR TT Metal Back Baseplateused as part of the SMR Anatomic Shoulder Replacement, is intended for use with bone cement and should be used without bone screws; while when used as part of the SMR Reverse Shoulder replacement, is intended for uncemented use with the addition of screws for fixation.
- If a SMR TT Hybrid Glenoid is in place and revision to a reverse prosthesis is required, the patient can be revised by removing the polyethylene baseplate, leaving the metal peg in place and by connecting it to the SMR TT Hybrid Glenoid Reverse Baseplate. The SMR TT Hybrid Glenoid Reverse Baseplate is intended for uncemented use with the addition of screws for fixation.
- The Dia. 50. 52 and 54mm Humeral Heads with + 3mm increased height cannot be coupled to the Long Adaptor . Tapers (both concentricand eccentric). The Dia. 52 and 54mm Humeral Heads with + 2mm increased height cannot be coupled to the Long Adaptor Tapers (both concentric and eccentric).
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
Date: January 31st, 2023
Manufacturer: Limacorporate S.p.A. Via Nazionale, 52 33038 - Villanova di San Daniele Udine - Italy
U.S. Contact Person: Kenneth Newman Kenneth.Newman@limacorporate.c om Lima USA Inc. 2001 NE Green Oaks Blvd. Ste.100 Arlington, Texas 76006, USA www.limacorporate.com Cell Phone: 682-597-3381
Trade name: SMR Shoulder System Common name: Glenoid Shoulder Prosthesis
| Classification Name: | |
|----------------------|----------------------------------------------------------------------------------------------------------------------------|
| Product Code | Regulation and Classification Name |
| MBF | § 888.3670 - Shoulder joint metal/polymer/metal nonconstrained or<br>semi-constrained porous-coated uncemented prosthesis. |
| PHX | § 888.3660 - Shoulder joint metal/polymer semi-constrained<br>cemented prosthesis. |
| KWS | § 888.3660 - Shoulder joint metal/polymer semi-constrained<br>cemented prosthesis. |
| KWT | § 888.3650 - Shoulder joint metal/polymer non-constrained<br>cemented prosthesis. |
| PAO | § 888.3660 - Shoulder joint metal/polymer semi-constrained<br>cemented prosthesis. |
## Classification Name:
### Description:
The SMR Shoulder System is a complete system intended to be used in primary or revision total shoulder joint replacement in either anatomic or reverse configurations. The SMR Shoulder System was cleared via several 510(k) submission, up to the latest approval under K220792.
The new compatibilities introduced with this 510(k) are related to the system when used in reverse shoulder configuration only.
The SMR Reverse Shoulder System is indicated for primary, fracture or revision total shoulder replacement in a grossly rotator cuff deficient joint with severe arthropathy (disabled shoulder). The patient's joint must be anatomically and structurally suited to receive the selected implants and a functional deltoid muscle is necessary to use the device. The SMR Shoulder System in reverse configuration consists of humeral stems, reverse humeral bodies, reverse liners, glenospheres, metal back glenoid components and pegs. The metal back glenoid component, when used as part of a reverse shoulder replacement, is intended for cementless fixation with bone screws.
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Glenoid components of the SMR Shoulder System are cleared for use also with the humeral components of the PRIMA Humeral System (K212800). When used in combination with the PRIMA Humeral System, the device consists of a humeral stem, tray, reverse insert, glenospheres, metal back glenoid components and pegs.
With this Traditional 510(k) submission, new compatibilities between already cleared devices of the SMR Shoulder System are introduced:
- Bone Screws dia. 5.0 mm (K210717) compatible with SMR Metal Back Glenoid -(K113254) and SMR TT Baseplate (K133349);
- -SMR TT Hybrid Glenoid Reverse Baseplate (K163397) compatible with SMR Glenosphere dia. 42 mm (K212800).
No changes in indications for use, materials, manufacturing processes, packaging and sterilization are introduced with this 510(k) on already cleared devices.
#### Intended Use:
#### Indications
The SMR Shoulder System is intended for partial or total, primary or revision shoulder joint replacement. The SMR Anatomic Shoulder System is indicated for partial or total, primary or revisionshoulder jointreplacement in patients suffering from disability due to:
- non-inflammatory degenerative joint disease including osteoarthritis and avascular necrosis; ●
- inflammatory degenerative joint disease such as rheumatoid arthritis;
- treatment of acute fractures of the humeral head that cannot be treated with other fracture fixation methods; ●
- . revision of a failed primary implant; in case of SMR Short Stems only if sufficient bone stock remains);
- . cuff tear arthropathy (CTA Heads only);
- . glenoid arthrosis without excessive glenoid bone loss: A1, A2 and B1 according to Walch classification (SMR TT Hybrid Glenoid only).
The SMR Reverse Shoulder System is indicated for primary, fracture or revision total shoulder replacement in a grossly rotator cuff deficient joint with severe arthropathy (disabled shoulder). The patient's joint must be anatomically and structurally suited to receive the selected implants and a functional deltoid muscle is necessary to use the device.
The SMR TT Hybrid Glenoid Reverse Baseplate must not be used in cases of excessive glenoid bone loss and/or when bone graft is needed.
The Modular SMR Shoulder System allows the assembly of components in various humeral and glenoid constructs. The constructs are intended for cemented and uncemented use as specified in the following table.
In the Anatomic shoulder the humeral consists of the humeral stem, the humeral body, the adaptor taper and the humeral head. In the Reverse shoulder the humeral consists of the humeral stem, the reverse humeral body and the reverse liner. On the humeral side the fixation of the humeral stem determines if the construct is cemented or uncemented.
The Anatomic glenoid construct consists of an all polyethylene glenoid, a polyethylene glenoid with metalpeg or a metal back assembled with a liner; the Reverse glenoid consists of a metal back/comnector/glenosphere construct or of a peg/baseplate/glenosphere construct.
On the glenoid side, the fixation of all polyethylene glenoid, the polyethylene glenoid with metal peg or the metal back determines if the construct is cemented or uncemented.
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| System | | | | Use | |
|--------|-----|---------------------------------------------------|------------------------------------------------------|-----|------------|
| A | R | Components | Material | Cem | Not<br>Cem |
| ● | ● | SMR Stem (Cemented, Cemented Revision) | Ti6Al4V | X | |
| ● | ● | SMR Stem (Cementless Finned, Cementless Revision) | Ti6Al4V | | X |
| ● | ● | SMR Short Stem (Cementless Finned) | Ti6Al4V | | X |
| ● | | SMR Humeral Body (Trauma, Finned) | Ti6Al4V | X | X |
| ● | ● | SMR Reverse Humeral Body | Ti6Al4V | X | X |
| ● | ● | Humeral Extension | Ti6Al4V | X | X |
| ● | | SMR Humeral Head (Standard*, CTA) | CoCrMo | X | X |
| ● | | SMR Adaptor Taper (Neutral, Eccentric) | Ti6Al4V | X | X |
| ● | | SMR CTA Head Adaptor for Reverse Humeral Body | Ti6Al4V | X | X |
| | ● | SMR Glenosphere* | CoCrMo | | X |
| | ● | SMR Connector* | Ti6Al4V | | X |
| | | | UHMWPE | X | X |
| | ● | Reverse Liner | LimaVit™ (Vitamin<br>E highly crosslinked<br>UHMWPE) | X | X |
| ● | | SMR Cemented Glenoid | UHMWPE | X | |
| ● | | SMR 3 Pegs Cemented Glenoid | UHMWPE | X | |
| ● | ● * | SMR TT Hybrid Glenoid | UHMWPE+ Ti6Al4V<br>3D printed +Ta | X | X |
| | ● | SMR TT Hybrid Glenoid Reverse Baseplate + Screw | Ti6Al4V | | X |
| ● | ● | SMR Metal Back Glenoid | Ti6Al4V+PoroTi | X* | X* |
| ● | ● | SMR TT Baseplate | Ti6Al4V | X* | X* |
| | ● | SMR TT Augmented 360 Baseplate | Ti6Al4V | | X |
| ● | ● | SMR TT Glenoid Peg | Ti6Al4V 3D printed | X | X |
| ● | | SMR Metal Back Liner | UHMWPE | X* | X* |
| ● * | ● | SMR Bone screw | Ti6Al4V | | X |
Ti6Al4V (ISO 5832-3 - ASTM F1472) – Ti6A14V 3D printed (to meet the mechanical and chemical requirements of ISO 5832-3) - CoCrMo (ISO 5832-12 - ASTM F1537) - UHMWPE (ISO 5834-2 - ASTM F648) - Lima Vit'M (Vitamin E highly crosslinked UHMWPE) (ISO 5834-2 - ASTM F648 - ASTM F2695 – ASTM F2565) - PoroTi Titanium Coating (ASTM F1580) - Ta (ISO13782 - ASTM F560)
A= Anatomic / R=Reverse
*NOTE:
- When considering the humeral side, SMR Glenosphere Ø42 can be coupled only with PRIMA ● Humeral System.
- In the US, the SMR Metal Backed Glenoid/Liner construct. used as part of the SMR Anatomic Shoulder Replacement, is intended for use with bone cement and should be used without bone screws.
- . The SMR Metal Backed Glenoid/Connector/Glenosphere construct, used as part of the SMR Reverse Shoulder replacement, is intended for uncemented use with the addition of screws for fixation.
- . SMR Lateralized Connectors are not indicated for use with glenoid bone grafting techniques.
- . In the US the SMR TT Metal Back Baseplate used as part of the SMR Anatomic Shoulder Replacement, is intended for use with bone cement and should be used without bone screws; while
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when used as part of the SMR Reverse Shoulder replacement, is intended for uncemented use with the addition of screws for fixation.
- If a SMR TT Hybrid Glenoid is in place and revision to a reverse prosthesis is required, the patient ● can be revised by removing the polyethylene baseplate, leaving the metal peg in place and by connecting it to the SMR TT Hybrid Glenoid Reverse Baseplate. The SMR TT Hybrid Glenoid Reverse Baseplate is intended for uncemented use with the addition of screws for fixation.
- . The Dia. 50. 52 and 54mm Humeral Heads with + 3mm increased height cannot be coupled to the Long Adaptor Tapers (both concentric and eccentric). The Dia. 52 and 54mm Humeral Heads with + 2mm increased height cannot be coupled to the Long Adaptor Tapers (both concentric and eccentric).
#### Predicate Devices:
The predicate device is the SMR Shoulder System cleared by LimaCorporate via K220792.
### Summary of technology comparison:
The subject device has the exact same principles of operation, materials, and performance characteristics of the predicate SMR Shoulder System cleared via K220792.
The only differences between the subject and the predicate device are the addition of new compatibilities between already cleared devices:
- Bone Screws dia. 5.0 mm (K210717) compatible with SMR Metal Back -Glenoid (K113254) and SMR TT Baseplate (K133349)
- -SMR TT Hybrid Glenoid Reverse Baseplate (K163397) compatible with SMR Glenosphere dia. 42 mm (K212800).
The indications for use of the subject SMR Shoulder System are the same as the predicate SMR Shoulder System.
### Non-clinical testing
Mechanical tests demonstrated that device performance fulfilled the intended use and that the devices is substantially equivalent to the predicate devices. Dynamic Evaluation of the Glenoid Loosening or Disassociation (ASTM F2028) was performed on worst case components.
## Clinical testing
Clinical testing was not necessary to demonstrate substantial equivalence of the SMR Shoulder System to the predicate device.
#### Conclusions
Based upon a comparison of intended use, materials, summary of technological characteristics, and preclinical testing, SMR Shoulder System with new compatibilities is substantially equivalent to the predicate device identified in this premarket notification.
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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.
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You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
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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.
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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.