K Number
K102053
Device Name
BUTLER CALCI-FLOR PROPHYLAXIS PASTE
Date Cleared
2011-02-03

(196 days)

Product Code
Regulation Number
872.6030
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Butler® Calci-Flor Prophylaxis Paste is designed to clean and polish teeth during professionally administered dental hygiene prophylaxis treatments. Butler® Calci-Flor Prophylaxis Paste is intended for cleaning and polishing procedures as part of a professionally administered dental prophylaxis treatment.
Device Description
Butler® Calci-Flor Prophylaxis Paste is an oral cavity abrasive polishing agent that contains calcium and fluoride. This device is regulated by FDA as a Class I device. Butler® Calci-Flor Prophylaxis Paste is an abrasive oral prophylaxis paste (available in one of several levels of grit coarseness), which contains fluoride, calcium, humectants, bulking agents for proper paste formation, a sweetener, flavor, color, and preservatives. This device is intended for use by dental professionals, during professionally administered dental prophylaxis treatment (tooth-cleaning), to remove stain from and polish the teeth. Paste application is designed for use with a prophy angle with suitable cup. The device is to be limited to individuals who are professionally trained to perform dental prophylaxis.
More Information

Not Found

No
The device description and intended use clearly define it as a physical prophylaxis paste with no mention of software, algorithms, or AI/ML capabilities.

No.
The 'Intended Use' and 'Device Description' indicate that the paste is designed for cleaning and polishing teeth during professional dental hygiene prophylaxis treatments, which are preventative or maintenance procedures, not therapeutic ones.

No

The device is a prophylaxis paste designed to clean and polish teeth, not to diagnose a condition or disease. Its intended use is for tooth-cleaning procedures.

No

The device description clearly states it is an "oral cavity abrasive polishing agent" and a "paste," indicating a physical substance, not software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is to "clean and polish teeth during professionally administered dental hygiene prophylaxis treatments." This is a direct treatment/procedure performed on the patient's teeth, not a test performed on a sample taken from the body to diagnose a condition.
  • Device Description: The description clearly states it's an "oral cavity abrasive polishing agent" used for "removing stain from and polish the teeth." This aligns with a physical cleaning and polishing action, not a diagnostic test.
  • Lack of Diagnostic Language: There is no mention of analyzing samples, detecting biomarkers, diagnosing diseases, or providing information for diagnosis.
  • Anatomical Site: The anatomical site is the "Oral cavity / teeth," which is where the physical treatment is applied.
  • Performance Studies: The performance study mentioned is "Bench testing...to ascertain fluoride release data," which is related to the device's composition and function, not its diagnostic accuracy.

IVD devices are designed to perform tests on samples (like blood, urine, tissue) taken from the human body to provide information for the diagnosis, treatment, or prevention of disease. This device does not fit that description.

N/A

Intended Use / Indications for Use

Butler® Calci-Flor Prophylaxis Paste is designed to clean and polish teeth during professionally administered dental hygiene prophylaxis treatments.
Butler® Calci-Flor Prophylaxis Paste is intended for cleaning and polishing procedures as part of a professionally administered dental prophylaxis treatment.

Product codes (comma separated list FDA assigned to the subject device)

EJR

Device Description

Butler® Calci-Flor Prophylaxis Paste is an oral cavity abrasive polishing agent that contains calcium and fluoride. This device is regulated by FDA as a Class I device.
Butler® Calci-Flor Prophylaxis Paste is an abrasive oral prophylaxis paste (available in one of several levels of grit coarseness), which contains fluoride, calcium, humectants, bulking agents for proper paste formation, a sweetener, flavor, color, and preservatives. This device is intended for use by dental professionals, during professionally administered dental prophylaxis treatment (tooth-cleaning), to remove stain from and polish the teeth. Paste application is designed for use with a prophy angle with suitable cup. The device is to be limited to individuals who are professionally trained to perform dental prophylaxis.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

oral cavity / teeth

Indicated Patient Age Range

Not Found

Intended User / Care Setting

dental professionals, during professionally administered dental prophylaxis treatment

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Bench testing was performed on the Butler® Calci-Flor Prophylaxis Paste to ascertain fluoride release data. The results of this testing do not raise new questions of safety and effectiveness, and demonstrates that the device is at least as safe and effective as the legally marketed predicate device.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K952091, K912945, K062166

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 872.6030 Oral cavity abrasive polishing agent.

(a)
Identification. An oral cavity abrasive polishing agent is a device in paste or powder form that contains an abrasive material, such as silica pumice, intended to remove debris from the teeth. The abrasive polish is applied to the teeth by a handpiece attachment (prophylaxis cup).(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 872.9.

0

(02053

FEB - 3 2011

Date of Summary07/16/2010
Submitter/Contact
PersonH. Carl Jenkins
The Wood Burditt Group
10 E. Scranton Ave., Suite 201
Lake Bluff, IL 60044
(ph) (847) 234-7500 x 205
(fax) (847) 574-0728
(email) hcjenkins@woodburditt.com
Applicant
4635 W. Foster Ave.
Chicago, IL 60630
(ph) 773-777-4000
(fax) 773-777-1417
Device NameButler® Calci-Flor Prophylaxis Paste
Common NameOral cavity abrasive polishing agent
ClassificationOral cavity abrasive polishing agent
Regulation Number: 21 CFR 872.6030
Product Code: EJR
Panel Code: Dental
Device Class: I
Legally Marketed
Predicate DevicesBUTLER G.U.M. WITH FLUORIDE
JOHN O. BUTLER CO.
K952091
ProCode: JES
SATIN PROPHYLAXIS PASTE
DENTSPLY INTL.
K912945
ProCode: EJR
Device Description
PREMIER DENTAL PRODUCTS CO.
K062166
ProCode: EJR
Butler® Calci-Flor Prophylaxis Paste is an oral cavity abrasive
polishing agent that contains calcium and fluoride. This device is
regulated by FDA as a Class I device.
Butler® Calci-Flor Prophylaxis Paste is an abrasive oral
prophylaxis paste (available in one of several levels of grit
coarseness), which contains fluoride, calcium, humectants, bulking
agents for proper paste formation, a sweetener, flavor, color, and
preservatives. This device is intended for use by dental
professionals, during professionally administered dental
prophylaxis treatment (tooth-cleaning), to remove stain from and
polish the teeth. Paste application is designed for use with a
prophy angle with suitable cup. The device is to be limited to
individuals who are professionally trained to perform dental
prophylaxis.
Intended Use and
IndicationsButler® Calci-Flor Prophylaxis Paste is designed to clean and
polish teeth during professionally administered dental hygiene
prophylaxis treatments.
Summary of
technological
characteristics
compared to predicate
devicesButler® Calci-Flor Prophylaxis Paste is made of the same
ingredient component materials that are used in lawfully marketed
predicate devices, with the same type and durations of patient
contact.
Butler® Calci-Flor Prophylaxis Paste has the same indications for
use and intended use as lawfully marketed predicate devices.
Performance Testing /
Summary of
Substantial
Equivalence (SE)Bench testing was performed on the Butler® Calci-Flor
Prophylaxis Paste to ascertain fluoride release data. The results of
this testing do not raise new questions of safety and effectiveness,
and demonstrates that the device is at least as safe and effective as
the legally marketed predicate device.

1

2

Image /page/2/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a stylized eagle with three lines representing its wings and body. The eagle is positioned in the center of a circular border, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the border.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring. MD 20993-0002

Sunstar Americas, Incorporated C/O Mr. Carl Jenkins The Wood Burditt Group 10 E. Scranton Avenue, Suite 201 Lake Bluff, Illinois 60044

FEB - 3 20d

Re: K102053

Trade/Device Name: Butler® Calci-Flor Prophylaxis Paste Regulation Number: 21 CFR 872.6030 Regulation Name: Oral Cavity Abrasive Polishing Agent Regulatory Class: I Product Code: EJR Dated: July 19, 2010 Received: July 22, 2010

Dear Mr. Jenkins:

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 899. In addition, FDA may publish further announcements concerning your device in the Federal Register. Comments of the country of the country of the 1

3

Page 2- Mr. Jenkins

Enclosure

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 device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) 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 go to

http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Susan Runnes

Anthony D. Watson, B.S., M.S., M.B.A. Director

Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

4

  1. Indications for Use Statement

Indications for Use

510(k) Number (if known): KJO2053

Device Name: Butler® Calci-Flor Prophylaxis Paste

Indications for Use:

Butler® Calci-Flor Prophylaxis Paste is intended for cleaning and polishing procedures as part of a professionally administered dental prophylaxis treatment.

Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR

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

(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-Uff) Division of Anesthesiology, General Hospital Infection Control, Dental Devices

510(k) Number: K102053

  1. Indications for Use Statement

Page 4.1 of 4.1