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510(k) Data Aggregation

    K Number
    K190665

    Validate with FDA (Live)

    Date Cleared
    2019-12-23

    (283 days)

    Product Code
    Regulation Number
    880.6850
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Neodent Instrument Kit Cases are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. Neodent Instrument Kit Cases are intended to allow sterilization of the enclosed medical devices. Neodent Instrument Kit Cases require the use of FDA cleared wrap to maintain the sterility of the enclosed devices.

    The kits are to be enclosed in a sterilization wrap that is FDA-cleared for the indicated cycles, and moist heat (steam) sterilized using one of the following cycles:

    Fractionated vacuum (pre-vacuum) - Exposure at 132 °C for 4 minutes, 30-minute dry time (for GM Zygomatic Surgical Kit Case) or 20-minute dry time (for GM Helix LG Compact Surgical Kit Case)

    Gravity displacement - Exposure at 132 °C for 15 minutes, 20-minute dry time (only for GM Helix LG Compact Surgical Kit Case)

    Neodent Instrument Kit Cases are intended for sterilization of non-porous loads.

    The combined weight of the GM Zygomatic Surgical Kit Case and the instruments is 738.1 g. The weight of the empty kit case is 515 g.

    The combined weight of the GM Helix LG Compact Kit Case and the instruments is 297.3 g. The weight of the empty kit case is 236 g.

    Neodent Instrument Kit Cases should not to be stacked during sterilization.

    Device Description

    The subject device kit cases are reusable rigid containers, comprising a case bottom (or base), a removable inner tray, and tray lid (lid). The subject device kits are to be used to organize and protect instruments and accessories that are to be sterilized by the healthcare provider. The subject devices include two (2) such kit cases. The lids are manufactured from injection molded polyphenylsulfone resin, the tray and base are manufactured from injection molded polysulfone resin. The designs include grommets and inserts of various geometries manufactured from molded silicone that retain the instruments within the tray and base. The subject device kit cases are provided nonsterile to the end-user.

    AI/ML Overview

    The medical device in question is the Neodent Instrument Kit Cases, intended for use in sterilizing other medical devices by healthcare providers using moist heat (steam). The provided documentation details the acceptance criteria and the studies conducted to demonstrate its performance.

    Here's a breakdown of the requested information:

    1. A table of acceptance criteria and the reported device performance

    Acceptance CriteriaReported Device Performance
    Manual Cleaning Validation
    Hemoglobin Test: - < 0.50 µg/mL - < 55 µg/article - < 0.0078 µg/cm²Passed
    Micro BCA Protein Test: - < 1.1 µg/mL - < 220 µg/article - < 0.018 µg/cm²Passed
    Sterilization Validation (Sterilant penetration and drying time)
    Sterility Assurance Level (SAL) of 10⁻⁶Passed
    Life Cycle (Simulated Usage) Testing (100 cycles)
    Visual and functional inspection following 100 cyclesPassed
    Biocompatibility Testing (Cytotoxicity)
    < 30% inhibition of proliferation of protein contentPassed

    2. Sample size used for the test set and the data provenance

    The document does not specify the exact sample sizes used for each test. For instance, it doesn't state how many kit cases were subjected to manual cleaning validation or how many sterility tests were performed.

    Regarding data provenance:

    • The tests were nonclinical performance data.
    • The document does not explicitly state the country of origin of the data, but the sponsor is "JJGC Indústria e Comércio de Materiais Dentários SA" located in Curitiba, Parana, Brazil. Therefore, the data likely originates from Brazil or a laboratory contracted by the sponsor.
    • The tests as described (validation studies) are inherently retrospective in nature, as they involve testing the manufactured device against pre-defined criteria.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not provided in the document. The studies are nonclinical performance tests and do not involve human expert interpretation of device performance in a medical context where ground truth needs to be established by experts (e.g., radiologists interpreting images). The "ground truth" for these tests is based on objective laboratory measurements and industry standards.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    This is not applicable/not provided. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies involving multiple human readers to resolve discrepancies in their interpretations. The tests described are laboratory-based performance validations against defined physical and biological criteria, not human-in-the-loop assessments.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    No, an MRMC comparative effectiveness study was not done. This type of study is relevant for AI-powered diagnostic or assistive devices, which is not what the Neodent Instrument Kit Cases are. This device is a sterilization accessory.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    No, a standalone algorithm-only performance study was not done. This device is a physical instrument kit case, not a software algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    The "ground truth" for the nonclinical performance data is based on:

    • Objective laboratory measurements and chemical/biological assays for manual cleaning validation (hemoglobin and protein levels).
    • Sterility Assurance Level (SAL) of 10⁻⁶ which is a a quantitative measure of the probability of a single viable microorganism occurring on an item after sterilization. This is established through microbiological testing.
    • Visual and functional inspection for life cycle testing, against manufacturing specifications.
    • Measurement of cell proliferation inhibition percentage for cytotoxicity testing, an objective biological response measurement.

    These are all objective, measurable criteria derived from recognized standards rather than subjective expert consensus, pathology reports, or patient outcomes data.

    8. The sample size for the training set

    This information is not applicable/not provided. The "Neodent Instrument Kit Cases" is a physical medical device, not an AI, machine learning, or software device that requires a training set.

    9. How the ground truth for the training set was established

    This information is not applicable/not provided as the device is not an AI/ML system requiring a training set.

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