U.S. Food & Drug Administration
10903 New Hampshire Avenue D o c I D # 0 4 0 1 7 . 0 4 . 2 3
Silver Spring, MD 20993
www.fda.gov
April 2, 2021
OMNIlife science
Dipti Dharia
Chief Quality, Regulatory, & Clinical Officer
480 Paramount Drive
Raynham, Massachusetts 02767
Re: K201611/S001
Trade/Device Name: Apex Knee
TM
System
Regulation Number: 21 CFR 888.3560
Regulation Name: Knee Joint Patellofemorotibial Polymer/Metal/Polymer Semi-Constrained Cemented
Prosthesis
Regulatory Class: Class II
Product Code: JWH, MBH
Dated: February 19, 2021
Received: March 4, 2021
Dear Dipti Dharia:
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
statutes and regulations administered by other Federal agencies. You must comply with all the Act's
K201611 - Dipti Dharia Page
2
requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
801); medical device reporting (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-reporting-
combination-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-devices/medical-device-safety/medical-device-reporting-
mdr-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/medical-
devices/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-devices/device-advice-comprehensive-regulatory-
assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE
by email ([email protected]) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Ting Song, Ph.D., R.A.C.
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
Ting Song -S
13/71513/715
K201611
510(k) Summary
TABLE 1: 510(k) SUMMARY
06/12/2020
OMNIlife Science
480 Paramount Drive
Raynham, MA 02767
Dipti Dharia
Chief Quality, Regulatory & Clinical Officer
Corin Ltd.,
480 Paramount Drive
Raynham, MA 02767
Telephone: +1-732-754-5466
Email: Dipti.Dharia@coringroup.com
Secondary Contact:
Jack Liang
Senior Regulatory Affairs Specialist
Corin Ltd / Corin Australia
+61 2 9497 7400
J
ack.Liang
@coringroup.com
Apex Knee System
prosthesis, knee, patellofemorotibial, semi-constrained,
cemented, polymer/metal/polymer
prosthesis, knee, patello/femorotibial, semi-constrained,
uncemented, porous, coated
21 CFR 888.3560. Class II. Knee joint
patellofemorotibial polymer/metal/polymer semi-
constrained cemented prosthesis. JWH
21 CFR 888.3565. Class II. Knee joint
patellofemorotibial metal/polymer porous-coated
uncemented prosthesis. MBH
OMNI TiN Coated Apex Knee System- K191765
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K201611 page 1 of 4
This traditional 510(k) premarket notification is being
submitted to obtain clearance for the
modifications to
the Apex Knee System to
expand OMNI’s product
offering for total knee arthroplasty.
The Apex Knee™ System is intended for use as a
primary or revision total knee replacement. This
prosthesis may be used for the following conditions, as
appropriate:
Non-inflammatory degenerative joint disease,
including osteoarthritis and avascular necrosis;
Rheumatoid arthritis;
Correction of functional deformity;
Revision procedures where other treatments or
devices have failed;
The porous coated femoral component may be used
cemented or uncemented (biological fixation).
The Porous coated tibial baseplate is to be used
uncemented (biological fixation).
All other femoral, tibial baseplate, and patellar
components are indicated for cemented use only.
The Apex Knee™ Modular Tibia System Tibial
Augments are intended to be bolted to the Tibia
baseplate and cemented to the prepared tibia.
The proposed devices are intended to be used for
primary and revision total knee replacement.
The Pegged Tibial Baseplates offer additional torsional
stability by adding pegs to the posterior end of the
device.
The material of the proposed Pegged Tibial
Baseplates are Cobalt Chrome, CoCr (ASTM F75).
The ECiMa
tibial inserts are machined from
compression molded highly crosslinked polyethylene
with Vitamin E (VE-
XLPE) and attaches to the cobalt
chrome tibial baseplate via dovetails and a retaining
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K201611 page 2 of 4
bolt. The insert slides onto the baseplate from the front,
with the two dovetail-
shaped rails on the baseplate
engaging the mating slots in the insert, until the rails
contact the posterior end of the slots. The retaining bolt
completes the assembly.
The proposed devices undergo the same validated
sterilization process, using ethylene oxide (EO), as the
predicate devices (
K060192, K102578, K111184,
K112891)
under the sterility assurance level (SAL) of
10
-6
. All ethylene oxide
residuals are monitored and
well below standard limits.
In addition, OMNI has developed a plan to test
endotoxins on all OMNIlife science device groups
through Limulus amebocyte lysate (LAL) testing.
Products have been segregated into product families
bas
ed on manufacturing process and material type and
have generated 8 product groups that will be tested for
endotoxins on a quarterly basis on a yearly rotation, and
the
subject devices are included in one of the product
groups. Product will not be released if the 4 EU/device
limit is exceeded.
The proposed devices with modifications are
substantially equivalent to the existing Apex Knee™
System cleared in K191765 as the basic design,
interface, fundamental technology and intended use are
the same.
The use of the new Apex Knee™ System components
with the existing knee components do not introduce any
new risks of safety or efficacy.
Tibial Baseplate:
In addition to the testing performed for the Apex Knee
System, non-clinical testing specifically for the Pegged
Porous Coated Cementless Tibial Baseplates include
FEA simulation and peg location templating study.
The results of the testing show that the Apex Knee
Pegged Porous Coated Cementless Tibial Baseplates are
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K201611 page 3 of 4
safe and effective for the proposed indications and is
substantially equivalent to the predicate devices.
The justifications are described in Section 10, Device
Description.
ECiMa Tibial Inserts & Patellae
In addition to the testing already performed for the Apex
Knee System, non-clinical testing was conducted
specifically for the ECiMa Tibial Inserts & Patellae.
These tests include:
material characterization,
PS post strength testing,
insert disassembly strength testing,
wear testing.
Biological testing of the ECiMa material was conducted
for biocompatibility. These tests include:
intramuscular implantation in animal models,
implant toxicity and subcutaneous implantation in
animal models.
The results of the testing show that the Apex Knee
ECiMa Tibial Inserts & Patellae are safe and effective
for the proposed indications and is substantially
equivalent to the predicate devices.
Based on the design, fundamental technology, material,
intende
d use and technological characteristics,
OMNIlife science believes the proposed Apex Knee
System devices to be substantially equivalent to legally
marketed predicates.
The conclusions drawn from the nonclinical tests
demonstrate that the devices are safe, as effective, and
perform as well as or better than the legally marketed
device
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K201611 page 4 of 4