(29 days)
The 3i Locator Implant Anchor Abutment for Endosseous Dental Implants is appropriate for use with overdentures retained in whole or in part by endosseous implants in the mandible or maxilla.
The 3i Locator Abutment System consists of a titanium alloy socket that is attached to a dental implant having an internal threaded socket. Both devices have a nylon component that has a shape on one end that mates into the socket. The other end of the nylon component is attached to the denture. This arrangement provides snap-fit retention of the denture. The system is identical to the predicate devices, except for a modification to allow use with 3i's Osseotite implant, and a modification of the system prior to distribution by 3i.
This document describes modifications to the "3i Locator Abutment System," which is a component of a dental implant system. The submission is a 510(k) premarket notification, indicating that the manufacturer is seeking to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving novel safety and effectiveness. Therefore, the "acceptance criteria" and "device performance" are framed in terms of demonstrating equivalence to the predicate device, the "Zest Locator® Anchor System."
Here's an analysis of the provided information, addressing your specific points:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Demonstrates Substantial Equivalence to Predicate) | Reported Device Performance |
|---|---|
| Retention and Withstanding Occlusal Forces: Performance must be equivalent to the Zest Locator Anchor System. | "All previously submitted bench testing of the Zest Locator Anchor System has established its effectiveness in retention and withstanding occlusal forces." The modifications "would not demonstrate significantly different results." |
| Fatigue Strength of Attachment Components: Fatigue strength must be at least 175 pounds after 5 million cycles. | "The system was also fatigue tested to 5 million cycles, and demonstrated that the fatigue strength of the attachment components is still at least 175 pounds." |
| Sterilized Component Performance: Sterilized Nylon 101 components (replacement males) must perform equivalently to non-sterilized components. | "Sterilized Nylon 101 components (replacement males) were fatigue tested in 2001, and found to be substantially equivalent to non-sterilized components." |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document mentions "Sterilized Nylon 101 components (replacement males)" were fatigue tested in 2001, but does not specify the sample size used for this particular test set.
- Data Provenance: The testing appears to be retrospective in the sense that it relies on "previously submitted bench testing" for the predicate device and internal testing done by the company (or a contracted lab) for the modified components. The country of origin is not explicitly stated, but given it's an FDA submission, the testing would generally need to adhere to US regulatory standards.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
This type of information is not applicable to this submission. The "ground truth" for demonstrating substantial equivalence here is based on engineering principles and objective physical measurements (retention, occlusal forces, fatigue strength), not on expert clinical interpretation of data like images or patient outcomes.
4. Adjudication Method for the Test Set
This is not applicable. Adjudication methods like 2+1 or 3+1 are used in studies involving human interpretation or subjective assessments where discrepancies need to be resolved. This submission relies on objective bench testing.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, an MRMC comparative effectiveness study was not done. This type of study is typically used for diagnostic devices involving human interpretation (e.g., radiologists reading images) to assess the impact of AI assistance on reader performance. This submission is for a mechanical dental device.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Yes, in essence. The performance data presented is "standalone" in the sense that it's the device's inherent mechanical performance measured through bench testing, not influenced by human interaction or interpretation beyond setting up the test. There is no "algorithm" in the AI sense; rather, it's the physical device's mechanical performance.
7. The Type of Ground Truth Used
The ground truth used is primarily engineering specifications and benchmarked mechanical performance. Specifically:
- Established effectiveness in retention and withstanding occlusal forces, as demonstrated by the predicate device's prior testing.
- A specific fatigue strength threshold (at least 175 pounds after 5 million cycles).
- Equivalence in performance between sterilized and non-sterilized components.
8. The Sample Size for the Training Set
Not Applicable. There is no "training set" in the context of this device. This is a mechanical device, not an AI/ML algorithm that requires training data.
9. How the Ground Truth for the Training Set Was Established
Not Applicable. As there is no training set, this point is not relevant.
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Implant Innovations, Inc. Implant Innovations, Inc.
510(k) Premarket Notification for Modification to Locator® Anchor System
Image /page/0/Picture/2 description: The image is a logo for Implant Innovations, Inc., a Biomet company. The logo features a stylized "3i" in bold, black font. Below the "3i" are the words "IMPLANT INNOVATIONS, INC." in a smaller, sans-serif font, and below that is the text "A BIOMET COMPANY".
KO/2911
Summary of Safety & Effectiveness
COMPANY: Implant Innovations, Inc. 4555 Riverside Drive Palm Beach Gardens, FL 33410
CONTACT:
Jacquelyn A. Hughes, RAC Tacqueryn A. Regulatory Affairs & Quality Assurance Telephone: 561-776-6819 FAX: 561-776-6852 E-mail: jhughes@3implant.com
DATE PREPARED: August 29, 2001
NAME OF THE DEVICE: 3i Locator@Abutment System Classification: DZE Classinonene: Abutment for Endosseous Implant
PREDICATE DEVICES:
Zest Locator® Anchor System
DEVICE DESCRIPTION:
DEVICE DESCRIPTION:
The 3i Locator Abutment System consists of a titanium alloy socket that is attached to a The 31 Locator Abutilent System consisted on umplants having an internal threaded socket. Both devices have a nylon component hat has a shape on one end that mates into socket. Both devices nave a hylon componities mass artached to the denture. This arrangement provides snap-fit retention of the system is identical to the arrangement provides shap-in relemon or the allow use with 37's Ossectite implant,
predicate devices, except for a modification to allow use with 31's from by 31 predicate devices, except for a modification of the system prior to distribution by 3i.
INTENDED USE:
INTENDED USE:
The 3i Locator Implant Anchor Abutment for Endosseous Dental Implants is appropriate The 31 Locator Imprain Anchor Abdulentures retained in whole or in part by endosseous implants in the mandible or maxilla.
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INDICATIONS FOR USE:
- Tissue supported overdentures on 2 to 4 implants ●
- Partially edentulous overdentures with one or more implants .
- Farthany edentures with a minimum of 3.17mm of interarch distance .
- Overdentures with a milling greater than 40° of divergence between them .
CONTRAINDICATIONS:
- INTRAINDICATIOND.
Multiple implants with greater than 40° of divergence between them ● - Overdentures with more than 4 implants .
PERFORMANCE DATA:
PERFORMANCE DATA.
All previously submitted bench testing of the Zest Locator Anchor System has All previously submitted belief tosting of an essess in retention and withstanding occlusal forces. The system was also fatigue tested to 5 million cycles, and demonstrated that the fatigue strength of the attachment components is still at least 175 pounds. There are no modifications to the system in the 31 Locator Abutment System that would demonstrate modifications to the system in the St Locations (replacement males) were fatigue different results. Stermized Nyfon 101 components (2001) of non-sterilized components.
In conclusion, this 510(k) supports the substantial equivalence of the 3i Locator In Concrusion, this 510(x) Seppedicate, the Zest Locator Anchor System.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the seal of the U.S. Department of Health and Human Services. The seal is circular and contains the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the seal is a stylized caduceus, a symbol often associated with medicine and healthcare. The caduceus consists of a staff with two snakes coiled around it and a pair of wings at the top.
Public Health Service
SEP 2 8 2001
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Ms. Jacqueline A. Hughes Director of R/A & Q/A Implant Innovations, Incorporated 4555 Riverside Drive Palm Beach Gardens, Florida 33410
Re: K012911
K012911
Trade/Device Name: 31 Locater Abutment System Regulation Number: 872.3640 Regulation Names Endosseous Dental Implant Regulatory Class: III Product Code: DZE Dated: August 29, 2001 Received: August 30, 2001
Dear Ms. Hughes:
We have reviewed your Section 510(k) premarket notification of intent to market the device the We have reviewed your Section 310(x) pendice is substantially equivalent (for the referenced above and have determined the device to legally marketed predicate devices marketed in
indications for use stated in the enclosure was an anteger dies of the Meal indications for use stated in the enclosules to the enactment date of the Medical Device interstate commerce prior to May 20, 1970, the condance with the provisions of
Amendments, or to devices that have been recorders approval of a premarket Amendments, or to devices that have occi receive approval of a prematice approval of a premarket
the Federal Food, Drug, and Cosmetic Act (Act) that douice, subject to the ge the Federal Food, Drug, and Cosment Act (100) market the device, subject to the general
approval application (PMA). You may, therefore, market the device, subject to the ge approval application (FMA). Tou may, and controls provisions of the Act include controls provisions of the Act. The general of devices, good manufacturing practice,
requirements for annual registration, listing of devices, good manufacturing practice, requirements for annual regional misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III
ns affect If your device is classined (see above) into entrols. Existing major regulations affecting (PMA), it may be subject to such additional controllations, Title 21, Parts 800 to 898. In
your device can be found in the Code of Federal Regulations, Title 21, Federal your device can be found in the Code of Peacharies, would been and one in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not Please be advised that FDA S Issualice of a savice complies with other requirements
mean that FDA has made a determination that your device complies with other Federal agenc mean that FDA has made a delemination that your as a secures and regulations and registes.
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Page 2 - Ms. Hughes
You must comply with all the Act's requirements, including, but not limited to: registration and I ou must comply while an labeling (21 CFR Part 801); good manufacturing practice nstilly (21 CFR Part 807), accems (QS) regulation (21 CFR Part 820); and if requirements as set form in the quality by examp (section 531-542 of the Act, 21); CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your 510(k) premated notification. The FDA finding of substantial equivalence of your device to a legally marketed nounceaton. The PDA income of succeantary vour device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and 11 you desire specific advice for your do to contact the Office of Compliance at additionally 809.10 for m vito diagnestions on the promotion and advertising of your device, (301) 594-4613. entitled, "Misbranding by reference to premarket notification" (21CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Information on your responsional Assistance at its toll-free number (800) 638-2041 or Manufacturers, International ant ediress http://www.fda.gov/cdrh/dsma/dsmamain.html.
Sincerely yours,
Timothy A. Ulatowski Director Division of Dental, Infection Control and General Hospital Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Implant Innovations, Inc. Implant Innovations, Inc.
510(k) Premarket Notification for Modification to Locator® Anchor System
510(k) Number (if known): K012291
Device Name: _________________________________________________________________________________________________________________________________________________________________
Intended Use
The 3i Locator Abutment System for endosseous dental implants is appropriate for use The 3i Locator Abutment System for endosseous denar mipans in 1-11-11-11 in the mandible or maxilla.
Indications for Use
- Tissue supported overdentures on 2 to 4 implants .
- I issue supported ous overdentures with one or more implants �
- Partially edentureds overseinm of 3.17mm of interarch distance .
- Overdentures with a minimum of STFAMIL to advergence between them ●
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
| Concurrence of CDRH, Office of Device Evaluation (ODE) | |
|---|---|
| -- | -------------------------------------------------------- |
Susan Runner
(Division Sign-Off)
Division of Dental, Infection Control,
and General Hospital Devices
| 510(k) Number | K012911 |
|---|---|
| --------------- | --------- |
| Prescription Use: | |
|---|---|
| (Per 21 CFR 801.109) | OR |
| Over the Counter Use: |
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§ 872.3640 Endosseous dental implant.
(a)
Identification. An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.(b)
Classification. (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. 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.)(2)
Classification. Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.