(137 days)
The Inclusive® Titanium Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid in prosthetic rehabilitation. They are compatible with Straumann Standard Plus Tissue Level Implants in RN (4.1mm and 4.8 mm) and WN (4.8 mm) sizes.
Inclusive® Titanium Abutments are endosseous implant abutments which are placed into the dental implant to provide support for a prosthetic restoration. The abutment is placed over the implant shoulder and is mounted into the implant with a screw. Abutments and screws are made of titanium alloy (Ti-6AL-4V ELI) and meet ASTM F136 Standard. They are compatible with Straumann Standard Plus Tissue Level Implants in RN (4.1 mm and 4.8 mm) and WN (4.8 mm) sizes. Prismatik Dentalcraft. Inc. provides premanufactured titanium abutments of a stock type with no inherent angulation which require further modification to obtain the desired shape before being used. The modifications are intended to be performed by dental laboratories with laboratory hand tools, as delineated in the device's instructions for use.
This document describes a 510(k) premarket notification for Inclusive® Titanium Abutments compatible with the Straumann synOcta Implant System. As such, it focuses on demonstrating substantial equivalence to predicate devices rather than providing detailed acceptance criteria and a study proving the device meets those criteria in the same way a de novo or PMA submission might.
Therefore, the information you've requested regarding acceptance criteria, device performance, sample sizes, ground truth establishment, expert adjudication, and MRMC studies is not explicitly present in the provided text. The document employs a different regulatory strategy, relying on demonstrating that the new device is as safe and effective as devices already on the market through comparison and non-clinical testing.
Here's an analysis based on the available information, noting where specific requested details are not provided:
1. Table of Acceptance Criteria and Reported Device Performance
The submission does not present a table of explicit acceptance criteria with numerical targets and reported performance in the way a clinical trial or performance study would. Instead, substantial equivalence is demonstrated through a comparison table of attributes (Indications for Use, Dimensions, Connection, Sterility, Material, Abutment Angle, Abutment Seat, Screw Seat, Anatomical Site, Construction) where the proposed device is shown to be similar to legally marketed predicate devices.
The "reported device performance" is summarized by the outcome of non-clinical testing, which aimed to show implant-to-abutment compatibility and substantial equivalence, rather than meeting specific performance metrics against pre-defined acceptance criteria.
Summary of Comparative Attributes (from pages 6-7):
| Attributes | Proposed Device | Similarities / Differences |
|---|---|---|
| Indications for Use | Inclusive Titanium Abutments are pre-manufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid to prosthetic rehabilitation. They are compatible with Straumann Standard Plus Tissue Level Implants in RN (implant diameter: 4.1 mm and 4.8 mm) and WN (implant diameter: 4.8 mm) sizes. | Same as primary predicate |
| Dimensions | Cylindrical Diameter: 9.4mm RN: diameter 4.8mm; WN: diameter 6.5mm | Same as Primary Predicate Device and Reference Device #2 |
| Connection | Octagonal | Same as Primary Predicate Device and Reference Device #2 |
| Sterility | Packaged Non-sterile | Same |
| Material | Titanium Alloy, Grade 23 | Same (Implicitly, as it notes "Same" and the primary predicate is Grade 23. Reference 1 is Grade 24, Reference 2 is Ti-6AL-7Nb) |
| Abutment Angle | 0°-30° | Same as the Reference Device 1 (Primary Predicate had "None") |
| Abutment Seat | Sits on a taper | Same |
| Screw Seat | Sits on a taper | Same |
| Anatomical Site | Oral Cavity | Same |
| Construction | Machined | Same |
Study Details:
The study referenced is a non-clinical "Performance Data" study (Section G).
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not explicitly stated. The document refers to "testing finished assembled implant/abutment systems of the worst case scenario," implying a limited number of samples chosen to represent the most challenging conditions rather than a statistically powered test set sample size.
- Data Provenance: Not specified, but generally, such non-clinical testing would be conducted in a laboratory setting by the manufacturer (Prismatik Dentalcraft, Inc.), which is based in Irvine, California, USA. It is prospective testing designed to evaluate the physical properties of newly manufactured components.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Number of Experts & Qualifications: Not applicable for this type of non-clinical, substantial equivalence submission. Ground truth in this context typically refers to objective material properties, mechanical integrity, and compatibility, which are established through standardized engineering tests rather than expert consensus on medical images or clinical outcomes.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Adjudication Method: Not applicable. Non-clinical mechanical testing does not involve adjudication. Results are typically determined by direct measurement and adherence to specifications or established test methods (e.g., ASTM standards).
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
- MRMC Study: No. This submission is for a physical medical device (dental abutments), not an AI-powered diagnostic tool. Therefore, MRMC studies and AI assistance are not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Performance: Not applicable. This is a physical medical device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Type of Ground Truth: For the non-clinical testing, the "ground truth" would be objective measurements derived from mechanical tests, such as fatigue strength, static load failure, and dimensional compatibility, compared against established engineering standards (e.g., ASTM F136 for material, and potentially other ISO or FDA recognized standards for dental implants/abutments). The document explicitly states testing was "in accordance with FDA Guidance 'Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Implant Abutments'."
8. The sample size for the training set
- Sample Size for Training Set: Not applicable. This is not an AI/machine learning device, so there is no "training set."
9. How the ground truth for the training set was established
- Ground Truth for Training Set: Not applicable, as there is no training set for this device.
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Image /page/0/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal features the department's name encircling a symbol of three stylized human profiles facing right. The profiles are stacked on top of each other, with the top profile being the most prominent and the bottom profile being the least prominent. The seal is black and white.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 16, 2015
PRISMATIK DENTALCRAFT, INC. Mr. Armin Zehtabchi Senior RA 2212 Dupont Drive, Suite P Irvine, California 92612
Re: K151798
Trade/Device Name: Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant System Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: II Product Code: NHA Dated: October 14, 2015 Received: October 16, 2015
Dear Mr. Zehtabchi:
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. 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 (reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Tina Kiang
for Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital. Respiratory. Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K151798
Device Name
Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant System
Indications for Use (Describe)
The Inclusive® Titanium Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid in prosthetic rehabilitation.
They are compatible with Straumann Standard Plus Tissue Level Implants in RN (4.1mm and 4.8 mm) and WN (4.8 mm) sizes.
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CER 801 Subpart D) |
|---|
| Over-The-Counter Use (21 CFR 801 Subpart C) |
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Image /page/3/Picture/0 description: The image shows the logo for Prismatik Dentalcraft, Inc. On the left is a triangle with a rainbow color scheme. To the right of the triangle is the company name in blue text. The text is stacked, with "PRISMATIK" on top, "DENTALCRAFT" in the middle, and ", INC." on the bottom.
B.
006_510 (K)-K151798 Summary-807.92(c)
This 510 (k) summary is being submitted in accordance with the requirements of SMDA of 1990 and 21 CFR 807.92.
SUBMITTER INFORMATION A.
| Company Name: | Prismatik Dentalcraft, Inc. |
|---|---|
| Company Address: | 2212 Dupont Dr., Suite P,Irvine, CA 92612 |
| Company Phone: | 949-225-1269 |
| Company FAX: | 949-553-0924 |
| Facility Registration Number: | 3005477956 |
| Primary Contact Person: | Armin Zehtabchi, (949) 225-1234Senior RA Specialist |
| Secondary Contact Person: | Marilyn Pourazar, (949) 225-1269Senior Director, RA/QA |
| Date Summary Prepared: | November 16, 2015 |
| DEVICE IDENTIFICATION | |
| Trade/Proprietary Name: | Inclusive® Titanium Abutments compatiblewith: Straumann synOcta Implant System |
| 21 CFR Reference: | 21 CFR 872.3630 |
| 21 CFR Common Name: | Abutment, implant, dental, endosseous |
| Classification: | Class II, NHA |
| Panel: | Dental |
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Image /page/4/Picture/0 description: The image contains the logo for Prismatik Dentalcraft, Inc. On the left side of the logo is a triangle with a color gradient. The colors in the triangle range from blue to pink to yellow. To the right of the triangle is the text "PRISMATIK DENTALCRAFT, INC." in a blue sans-serif font.
C. IDENTIFICATION OF PREDICATE DEVICE
Trade/Proprietary Name: Primary Predicate Device: Inclusive® Titanium Abutments compatible with: Straumann Tissue Level Implants, (K141211)
Reference Device 1: Inclusive Titanium Abutments for NobelActive, Straumann Bone Level, Branemark, (K142118)
Reference Device 2: ITI synOcta Meso Abutments, (K033243)
D. PROPOSED DEVICE DESCRIPTION
Inclusive® Titanium Abutments are endosseous implant abutments which are placed into the dental implant to provide support for a prosthetic restoration. The abutment is placed over the implant shoulder and is mounted into the implant with a screw. Abutments and screws are made of titanium alloy (Ti-6AL-4V ELI) and meet ASTM F136 Standard. They are compatible with Straumann Standard Plus Tissue Level Implants in RN (4.1 mm and 4.8 mm) and WN (4.8 mm) sizes.
Prismatik Dentalcraft. Inc. provides premanufactured titanium abutments of a stock type with no inherent angulation which require further modification to obtain the desired shape before being used. The modifications are intended to be performed by dental laboratories with laboratory hand tools, as delineated in the device's instructions for use.
E. INDICATIONS FOR USE
Inclusive® Titanium Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid in prosthetic rehabilitation.
They are compatible with Straumann Standard Plus Tissue Level Implants in RN (implant diameter: 4.1 mm and 4.8 mm) and WN (implant diameter: 4.8 mm) sizes.
F. DETERMINATION OF SUBSTANTIAL EQUIVALENCE
The comparison table below outlines and provides the similarities and the substantial equivalency of the Primary Predicate Device, the Inclusive® Titanium Abutments for Straumann Tissue Level Implants, K141211 (cleared by FDA on 10/22/2014), the Reference Device 1, the Inclusive Titanium Abutments for NobelActive, Straumann Bone Level, Branemark, (K142118), the Reference Device 2, the ITI synOcta Meso Abutments, (K033243) and the proposed device, the Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant
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Image /page/5/Picture/0 description: The image contains the logo for Prismatik Dentalcraft, Inc. On the left side of the logo is a triangle with a gradient of colors, including pink, red, yellow, green, blue, and purple. To the right of the triangle is the text "PRISMATIK DENTALCRAFT, INC." in a blue sans-serif font. The text is stacked, with "PRISMATIK" on the top line, "DENTALCRAFT, INC." on the bottom line.
System. The platform diameters and connection are the same for the Proposed Device and the Reference Device 2 (K033243). The connection for the Proposed Device and the Primary Predicate Device (K141211) is also the same.
Prismatik believes that the comparative data presented in the preceding paragraphs demonstrate that proposed device, Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant System is substantially equivalent to currently marketed devices for the same indications for use, and supports our claim of substantial equivalence to predicate Class II devices under the classification of abutment, implant, dental, endosseous (21 CFR 872.3630) that have previously been found to be substantially equivalent. Any differences between the proposed device, the Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant System, and the predicate device do not introduce any new issues of safety or effectiveness.
(See Comparison Table below)
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Image /page/6/Picture/0 description: The image shows the logo for Prismatik Dentalcraft, Inc. The logo consists of a colorful triangle on the left and the company name on the right. The triangle is divided into several sections, each with a different color. The company name is written in a sans-serif font and is blue.
| Attributes | Primary Predicate Device | Reference Device (1) | Reference Device (2) | Proposed Device | Similarities /Differences |
|---|---|---|---|---|---|
| Inclusive TitaniumAbutments compatible with:Straumann Tissue LevelImplants (K141211) | Inclusive TitaniumAbutmentscompatible with:Straumann BoneLevel Implants (K142118) | ITI synOcta Meso Abutments(K033243) | Inclusive® TitaniumAbutments compatible with:Straumann Tissue LevelsynOcta Implant System | ||
| (Prismatik Dentalcraft, Inc.) | (Prismatik Dentalcraft, Inc.) | Straumann USA | (Prismatik Dentalcraft, Inc.) | ||
| Indicationsfor Use | Inclusive Titanium Abutmentsare pre-manufacturedprosthetic components directlyconnected to endosseousdental implants and areintended for use as an aid toprosthetic rehabilitation.Inclusive Titanium Abutmentsare compatible withStraumann StandardPlus Tissue Level Implants inRN (4.1 mm and 4.8 mm) andWN (4.8mm) sizes. | Inclusive TitaniumAbutments arepremanufactured prostheticcomponentsdirectly connected toendosseous dentalimplants and are intendedfor use as anaid in prostheticrehabilitation.Inclusive® TitaniumAbutments are compatiblewith:- Straumann: Bone LevelNC and RC implant sizes- Nobel Biocare: BranemarkRP size implant- Nobel BiocareNobelActive NP and RPinternal connection implants | Abutments are intended to beplaced into dental implants toprovide support for prostheticreconstructions such as crowns orbridges. The ITI synOcta Mesoabutments are indicated forcemented restorations in estheticareas of the mouth. The abutmentcan be used in single toothreplacements and multiple toothrestorations. | Inclusive Titanium Abutmentsare pre-manufactured prostheticcomponents directly connectedto endosseous dental implantsand are intended for use as anaid to prosthetic rehabilitation.They are compatible withStraumann Standard PlusTissue Level Implants in RN(implant diameter: 4.1 mm and4.8 mm) and WN (implantdiameter: 4.8 mm) sizes. | Same asprimarypredicate |
| Attributes | Primary Predicate Device | Reference Device (1) | Reference Device (2) | Proposed Device | Similarities /Differences |
| Inclusive TitaniumAbutments compatible with:Straumann Tissue LevelImplants (K141211) | Inclusive TitaniumAbutmentscompatible with:Straumann BoneLevel Implants (K142118) | ITI synOcta Meso Abutments(K033243) | Inclusive® TitaniumAbutments compatible with:Straumann Tissue LevelsynOcta Implant System | ||
| Dimensions | Cylindrical Diameter: 9.4mmRN: diameter 4.8mm;WN: diameter 6.5mm | Cylindrical Diameter:9.4mm Connection Length:2.735mm | synOcta RN 4.8 mmsynOcta WN 6.5 mm | Cylindrical Diameter: 9.4mmRN: diameter 4.8mm;WN: diameter 6.5mm | Same asPrimaryPredicateDevice andReferenceDevice # 2 |
| Connection | Octagonal | Slot | Octagonal | Octagonal | Same asPrimaryPredicateDevice andReferenceDevice # 2 |
| Sterility | Packaged Non-sterile | Packaged Non-sterile | Packaged Non-sterile | Packaged Non-sterile | Same |
| Material | Titanium Alloy, Grade 23 | Titanium Alloy, Grade 24 | Ti-6AL-7Nb | Titanium Alloy, Grade 23 | Same |
| Picture ofAbutment | Image: abutment | Image: abutment | Image: abutment | Image: abutment | - |
| Attributes | Primary Predicate Device | Reference Device (1) | Reference Device (2) | Proposed Device | Similarities /Differences |
| Inclusive TitaniumAbutments compatible with:Straumann Tissue LevelImplants (K141211) | Inclusive TitaniumAbutmentscompatible with:Straumann BoneLevel Implants (K142118) | ITI synOcta Meso Abutments(K033243) | Inclusive® TitaniumAbutments compatible with:Straumann Tissue LevelsynOcta Implant System | ||
| Picture ofScrew | Image: Primary Predicate Device Screw | Image: Reference Device (1) Screw | Image: Reference Device (2) Screw | Image: Proposed Device Screw | - |
| AbutmentAngle | None | 0°-30° | - | 0°-30° | Same as theReferenceDevice 1 |
| AbutmentSeat | Sits on a taper | Sits on a taper | Sits on a taper | Sits on a taper | Same |
| Screw Seat | Sits on a taper | Sits on a taper | Sits on a taper | Sits on a taper | Same |
| AnatomicalSite | Oral Cavity | Oral Cavity | Oral Cavity | Oral Cavity | Same |
| Construction | Machined | Machined | Machined | Machined | Same |
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Image /page/7/Picture/0 description: The image contains the logo for Prismatik Dentalcraft, Inc. The logo consists of a colorful triangle on the left and the company name on the right. The triangle is divided into several sections, each with a different color. The company name is written in a sans-serif font.
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Image /page/8/Picture/0 description: The image contains the logo for Prismatik Dentalcraft, Inc. The logo consists of a colorful triangle on the left and the company name on the right. The triangle is divided into several sections, each with a different color. The company name is written in a sans-serif font.
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Image /page/9/Picture/0 description: The image shows the logo for Prismatik Dentalcraft, Inc. On the left is a triangle with a color gradient, transitioning from blue to pink. To the right of the triangle is the company name, "PRISMATIK DENTALCRAFT, INC.", written in a blue sans-serif font. The logo is clean and professional, suggesting a modern and innovative dental company.
SUMMARY OF NON-CLINICAL TESTING (PERFORMANCE DATA) G.
Non-clinical test data was used to evaluate the proposed device's substantial equivalence compared to the predicate device.
Clinical testing was not necessary to establish substantial equivalency of the device.
Non-clinical testing was performed in accordance with FDA Guidance "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Implant Abutments" and it consisted of testing finished assembled implant/abutment systems of the worst case scenario, through Reliability Calculation and Testing, as well as Fatigue Strength Testing and Static Load Failure Testing.
The testing performed demonstrated implant to abutment compatibility and has established substantial equivalency of the proposed device with predicate devices.
H. CONCLUSION FROM THE NON-CLINICAL TESTING (PERFORMANCE DATA)
The proposed device, the Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant System has the same performance specifications, fundamental scientific technology and intended use as that of the Prismatik's Primary Predicate device, the Inclusive® Titanium Abutments compatible with: Straumann Tissue Level Implants, K141211 (cleared by FDA on 10/22/2014), the Reference Device 1, the Inclusive Titanium Abutments for NobelActive, Straumann Bone Level, Branemark, K142118 (cleared by FDA on 11/25/2014) and the Reference Device 2, the ITI synOcta Meso Abutments, (K033243). These devices are substantially equivalent, and that any differences between the proposed device, the Inclusive® Titanium Abutments compatible with: Straumann synOcta Implant System and the cited primary predicate and reference devices do not introduce any new issues or concerns.
§ 872.3630 Endosseous dental implant abutment.
(a)
Identification. An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.(b)
Classification. Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)