Freedom Wrist Arthroplasty System

K233674 · Ascension Orthopedics, Inc. · JWJ · May 30, 2024 · Orthopedic

Device Facts

• Record ID: K233674
• Device Name: Freedom Wrist Arthroplasty System
• Applicant: Ascension Orthopedics, Inc.
• Product Code: JWJ · Orthopedic
• Decision Date: May 30, 2024
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 888.3800
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Freedom Wrist Arthroplasty System is intractable pain resulting from traumatic arthritis, osteoarthritis, rheumatoid arthritis, and trauma-induced osteoarthritis of the radial/carpal joint and is intended to replace functionality of the joint due to deformity or elements stated above. The Freedom Wrist Arthroplasty System is intended for cemented use.

Device Story

System replaces articulation of distal radius and proximal carpal row; components used as a system. Radial component: Cobalt Chrome Molybdenum (CrCoMo) alloy with concave articulating surface; stem fixed in radial intramedullary canal. Carpal implant: titanium plate fixed to carpal bones via cemented central peg and locking caps; convex Ultra-High-Molecular-Weight Polyethylene (UHMWPE) bearing locked onto plate. Device provides semi-constrained articulation. Used by orthopedic surgeons in clinical settings to treat joint pain and deformity. Output is a physical joint replacement; clinical decision-making involves surgical intervention to restore wrist function and alleviate pain.

Clinical Evidence

Bench testing only. Safety and compatibility in the MR environment were established via non-clinical testing addressing magnetically induced displacement force (ASTM F2052), torque (ASTM F2213), RF-induced heating (ASTM F2182), and image artifacts (ASTM F2119) per ASTM F2503 and FDA guidance.

Technological Characteristics

Semi-constrained cemented wrist prosthesis. Materials: Cobalt Chrome Molybdenum (CrCoMo) alloy (radial component), titanium (carpal plate), and Ultra-High-Molecular-Weight Polyethylene (UHMWPE) (bearing). Fixed via cement. MR Conditional labeling supported by testing per ASTM F2052, F2213, F2182, and F2119.

Indications for Use

Indicated for patients with intractable pain due to traumatic arthritis, osteoarthritis, rheumatoid arthritis, or trauma-induced osteoarthritis of the radial/carpal joint requiring joint replacement for deformity or functional restoration. Intended for cemented use.

Regulatory Classification

Identification

A wrist joint metal/polymer semi-constrained cemented prosthesis is a device intended to be implanted to replace a wrist 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 either a one-part radial component made of alloys, such as cobalt-chromium-molybdenum, with an ultra-high molecular weight polyethylene bearing surface, or a two-part radial component made of alloys and an ultra-high molecular weight polyethylene ball that is mounted on the radial component with a trunnion bearing. The metallic portion of the two-part radial component is inserted into the radius. These devices have a metacarpal component(s) made of alloys, such as cobalt-chromium-molybdenum. This generic type of device is limited to those prostheses intended for use with bone cement (§ 888.3027).

Predicate Devices

• Integra Freedom Wrist Arthroplasty System (K132250)

Submission Summary (Full Text)

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May 30, 2024

Image /page/0/Picture/1 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 seal on the left and the FDA acronym with the full name of the agency on the right. The FDA part of the logo is in blue, with the acronym in a square and the full name written out to the right of it. The seal is a symbol of the Department of Health & Human Services.

Ascension Orthopedics, Inc. Stephanie Rincones Regulatory Affairs Specialist 11101 Metric Blvd. Austin, Texas 78758

Re: K233674

Trade/Device Name: Freedom Wrist Arthroplasty System Regulation Number: 21 CFR 888.3800 Regulation Name: Wrist joint metal/polymer semi-constrained cemented prosthesis Regulatory Class: Class II Product Code: JWJ Dated: May 1, 2024 Received: May 1, 2024

Dear Stephanie Rincones:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 mediation-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,

Digitally signed by Farzana Farzana Sharmin -S Date: 2024.05.30 Sharmin -S 16:27:17 -04'00'

Farzana Sharmin, Ph.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

Submission Number (if known)

K233674

Device Name

Freedom Wrist Arthroplasty System

Indications for Use (Describe)

The Freedom Wrist Arthroplasty System is indicated for intractable pain resulting from traumatic arthritis, osteoarthritis, rheumatoid arthritis, and trauma-induced osteoarthritis of the radial/carpal joint and is intended to replace functionality of the joint due to deformity or elements stated above. The Freedom Wrist Arthroplasty System is intended for cemented use.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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| K233674 - Page 1 of 2 | | |
|------------------------------------|----------------------------------------------------------------------------|-------------------------|
| 510(k) Summary | | Prepared on: 2023-11-15 |
| Contact Details | | 21 CFR 807.92(a)(1) |
| Applicant Name | Ascension Orthopedics, Inc. | |
| Applicant Address | 11101 Metric Blvd. Austin TX 78758 United States | |
| Applicant Contact Telephone | 737-270-8239 | |
| Applicant Contact | Ms. Stephanie Rincones | |
| Applicant Contact Email | [e-mail] | |
| Device Name | | 21 CFR 807.92(a)(2) |
| Device Trade Name | Freedom Wrist Arthroplasty System | |
| Common Name | Wrist Prosthesis | |
| Classification Name | Wrist joint metal/polymer semi-constrained cemented prosthesis | |
| Regulation Number | 21 CFR 888.3800 | |
| Product Code | JWJ, Prosthesis, Wrist, 3 Part Metal-Plastic-Metal Articulation, Semi-Cons | |
| Legally Marketed Predicate Devices | | 21 CFR 807.92(a)(3) |
| Predicate # | Predicate Trade Name (Primary Predicate is listed first) | Product Code |
| K132250 | Integra Freedom Wrist Arthroplasty System | JWJ |
| Device Description Summary | | 21 CFR 807.92(a)(4) |

## Device Description Summary

The Freedom Wrist Arthroplasty System consists of components to replace the articulation of the distal radius and proximal row of carpal bones of the wrist joint. The components are intented together as a system, not individually as hemi-arthroplasty components. The radial component is made of Cobalt Chrome Molybenum Alloy (CrCoMo) and has a concave articulating surface and is fixed by means of a stem which is inserted into the radial intramedullary canal. The carpal implant is an assembly consisting of a titanium carpal plate, which is fixed into the carpal bones with a cemented central peg and locking caps. A convex Ultra-High-Molecular-Weight Polyethylene (UHMWPE) bearing is locked onto the carpal plate to articulate with the radial component.

### Intended Use/Indications for Use

The Freedom Wrist Arthroplasty System is intractable pain resulting from traumatic arthritis, osteoarthritis, rheumatoid arthritis, and trauma-induced osteoarthritis of the radial/carpal joint and is intended to replace functionality of the joint due to deformity or elements stated above. The Freedom Wrist Arthroplasty System is intended for cemented use.

21 CFR 807.92(a)(5)

21 CFR 807.92(a)(5)

21 CFR 807.92(a)(6)

## Indications for Use Comparison

The subject device has the same intended use and indications for use as the predicate device.

# Technological Comparison

The subject device introduces MR conditional labeling when compared to the wise, the subject device has the same

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technological characteristics as the predicate device.

#### Non-Clinical and/or Clinical Tests Summary & Conclusions 21 CFR 807.92(b)

Safety and compatibility in the magnetic resonance (MR) environment was established through non-clinical testing that addressed applicable MR safety hazards per ASTM F2503 (Standard Practice for Marking Medical Devices and Other Items for Safety in the Magnetic Resonance Environment) and FDA Guidance (Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment). Testing addressed the following: Magnetically Induced Displacement Force (ASTM F2052), Magnetically Induced Toque (ASTM F2213), RF-Induced Heating (ASTM F2182), and Image Artifacts (ASTM F2119).

Non-clinical testing supports the addition of MR Conditional labeling to the subject device by demonstrating that it can be safely scanned under defined conditions that are clinically relevant.