The intended use of APC™ Flash-Free Adhesive is as a light cure orthodontic adhesive that is designed to be used in bonding orthodontic appliances for orthodontic treatment.

APC™ Flash-Free Adhesive is indicated for use in bonding orthodontic appliances for orthodontic treatment.

Device Description

It consists of a resin-saturated mat that is attached to the apprimated for Craceets, ceramic brackets, and bondable buccal tubes. The relatively low viscosity of the resin allows it to form a fillet at the edges of the bracket which reduces the need to remove excess adhesive, also known as flash.

AI/ML Overview

The acceptance criteria and study proving the device meets them are described below:

1. Table of Acceptance Criteria and Reported Device Performance

Test	Acceptance Criteria	Reported Device Performance
Bond Strength Test	Provide the minimum bond strength to hold a bracket to a tooth (comparable to predicate devices)	APC™ Flash-Free Adhesive performs comparably to the predicate devices (Adhesive Precoated Brackets and APC™ Plus Adhesive) and provides the minimum bond strength to hold a bracket to a tooth.
Primer Compatibility Test	Provide the minimum bond strength to hold a bracket to a tooth when used with specified primers (comparable to predicate device)	APC™ Flash-Free Adhesive performs comparably to APC™ Plus Adhesive and provides the minimum bond strength to hold a bracket to a tooth when used with Transbond MIP Primer and Transbond Plus SEP Primer.
Accelerated Aging (Thermocycling)	Provide the minimum bond strength to hold a bracket to a tooth following specified cycles (comparable to predicate device)	APC™ Flash-Free Adhesive performs comparably to APC™ Plus Adhesive and provides the minimum bond strength to hold a bracket to a tooth following a specified number of cycles between hot and cold environments.
Ambient Light Stability Test	Provide the minimum bond strength to hold a bracket to a tooth following ambient light exposure (comparable to predicate device)	APC™ Flash-Free Adhesive performs comparably to APC™ Plus Adhesive and provides the minimum bond strength to hold a bracket to a tooth following exposure to ambient light.

2. Sample Size for Test Set and Data Provenance

The document does not explicitly state the sample sizes used for each nonclinical performance test (bond strength, primer compatibility, accelerated aging, ambient light stability). However, these are bench tests, a common practice in dental material testing. The data provenance is from nonclinical, bench-top testing conducted by 3M Unitek Corporation. The country of origin for the data is not specified but implicitly assumed to be the United States, where the company is based and seeking FDA clearance. The data is prospective for the device being tested, in the sense that the tests were performed specifically to evaluate the performance of APC™ Flash-Free Adhesive.

3. Number of Experts and Qualifications for Ground Truth

No human experts were used to establish ground truth for the test set. All testing described is nonclinical bench testing to evaluate physical properties of the adhesive.

4. Adjudication Method for the Test Set

No adjudication method was used as the testing involved objective physical measurements (e.g., bond strength) rather than subjective human assessment.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No MRMC comparative effectiveness study was done, as this is a physical dental adhesive, not an imaging or diagnostic device requiring human interpretation of cases.

6. Standalone (Algorithm Only) Performance Study

No standalone (algorithm only) performance study was done, as this device is a physical product (an adhesive), not a software algorithm.

7. Type of Ground Truth Used

The ground truth used for these nonclinical tests was based on objective physical measurements (e.g., bond strength values) and comparison against the performance of legally marketed predicate devices, which are accepted as safe and effective.

8. Sample Size for the Training Set

This device is a physical product (adhesive), not an AI/ML algorithm requiring a training set. Therefore, there is no training set sample size.

9. How Ground Truth for Training Set Was Established

As there is no training set for a physical adhesive, this question is not applicable.

Summary

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510(k) Summary

FEB - 2 2012 14113197

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This 510(k) summary of safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92.

510(k) Submitter	3M Unitek Corporation, 2724 South Peck Road, Monrovia,CA 91016-5097
Contact person	Robert Wang, RACRegulatory AffairsPhone: (800) 423-4588 Ext. 4997(626) 574-4997 DirectFax: (626) 574-4894E-mail: rwang24@mmm.com
Additional Contact persons	Kathleen F. BaconGlobal Regulatory Affairs ManagerPhone: (626) 574-4212Fax: (626) 574-4894E-mail: kbacon@mmm.comJerold S. HornVice President, Quality and RegulatoryPhone: (626) 574-4462Fax: (626) 574-4894E-mail: jshorn1@mmm.com
Date Summary was Prepared	October 28, 2011
Trade /Device Name	APC™ Flash-Free Adhesive
Common Name	Adhesive, Bracket and Tooth Conditioner, Resin
Classification Name	Bracket adhesive resin and tooth conditioner(21 CFR 872.3750, Class II, Product Code: DYH,Subsequent Product Code: NJM and EJF)

Predicate Devices:

Company: 3M Unitek Corporation Device: Adhesive Precoated Brackets (K911271)

Company: 3M Unitek Corporation Device: APCTM Plus Adhesive (K020394)

Device Description:

Device Description. appliances for orthodontic treatment. It consists of a resin-saturated mat that is attached to the apprimated for Craceets, ceramic brackets, and bondable buccal tubes. The relatively low viscosity of the resin allows it to form a fillet at the edges of the bracket which reduces the need to remove excess adhesive, also known as flash.

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Intended Use of The Device:

The intended use of APC™ Flash-Free Adhesive is as a light cure orthodontic adhesive that is designed to be used in bonding orthodontic appliances for orthodontic treatment.

Technological Characteristics:

APC™ Flash-Free is substantially equivalent in design features to the predicate devices. These features include an adhesive pre-applied to a bracket bonding base and then light-cured to adhere the appliance to the tooth.

Device Material:

APCTM Flash-Free Adhesive and the predicate devices Adhesive Precoated Brackets and APC™ Plus Adhesive are substantially equivalent in composition. All three devices contain methacrylate based resins and fillers. Additionally, all three devices are cured by exposure to visible light.

Device Design:

APC™ Flash-Free Adhesive and the predicate devices Adhesive Precoated Brackets and APC™ Plus Adhesive are substantially equivalent in design. All three devices consist of an orthodontic appliance which is delivered with a methacrylate-based adhesive precoated (pre-applied) to the bonding base and packaged in a heat sealed plastic blister. Further, all three devices are cured via exposure to visible light.

Nonclinical Performance Testing:

The nonclinical testing performance analysis shows that APC™ Flash-Free Adhesive performs comparably to the predicate devices as follows:

The bond strength test demonstrates that Adhesive Precoated Brackets, APC™ Plus 1. Adhesive, and APC™ Flash-Free Adhesive perform comparably and provide the minimum bond strength to hold a bracket to a tooth.
1. The primer compatibility test demonstrates that APC™ Plus Adhesive and APC™ Flash-Free Adhesive perform comparably and provide the minimum bond strength to hold a bracket to a tooth when used with Transbond MIP Primer (3M™ Dent System, K962785), and Transbond Plus SEP Primer (Modification to Prompt™ L-Pop™, K001494).
1. Accelerated aging of bonds by thermocycling demonstrates that APC™ Plus Adhesive and APC™ Flash-Free Adhesive perform comparably and provide the minimum bond strength to hold a bracket to a tooth following a specified number of cycles between hot and cold environments.
1. The ambient light stability test demonstrates that APC™ Plus Adhesive and APC™ Flash-Free Adhesive perform comparably and provide the minimum bond strength to hold a bracket to a tooth following exposure to ambient light.

Clinical Performance Testing:

No clinical performance testing was conducted with APC™ Flash-Free Adhesive.

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Substantial Equivalence:

Information provided in this 510(k) submission ahows that APCTM Flash-Free Adhesive is substantially equivalent to the predicate devices, Adhesive Precoated Brackets and APC™ Plus Adhesive, in terms of intended use, indications for use, composition, performance and Adhesive, in terms of intended asse, increations drawn from the nonclinical performance (bench) testing and the biocompatibility assessment demonstrate that APC™ Flash-Free Adhesive is safe and effective for the circumputed use and performs as well as the predicate devices.

This 510(k) submission includes data from bench testing to evaluate the performance of APC™ Flash-Free Adhesive compared to the predicate devices. The properties evaluated include Flash-Free Aunch VC Compared to the processed Aging of Bonds by Thermocycling, and Ambient Light Stability.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/3/Picture/1 description: The image is a seal for the Department of Health & Human Services - USA. The seal is circular and contains an image of an eagle with three lines coming from its head. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is written around the top of the circle.

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

Mr. Robert Wang Regulatory Affairs 3M Unitek Corporation 2724 South Peck Road Monrovia, CA 91016-5097

FEB - 2 2012

· Re: K113197

Trade/Device Names: APC™ Flash-Free Adhesive Regulation Number: 21 CFR 872.3750 Regulation Name: Bracket Adhesive Resin and Tooth Conditioner Regulatory Class: II Product Codes: DYH, EJF, and NJM Dated: January 25, 2012 Received: January 26, 2012

Dear Mr. Wang:

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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Page 2 - Mr. Wang

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 vours,

hh foi

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

Enclosure

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APC™ Flash-Free Adhesive Traditional 510(k) Premarket Notification

Submitter: 3M Unitek Corporation

12 113 197

Indications for Use

510(k) Number (if known):

Device Name: APC™ Flash-Free Adhesive

Indications for Use:

APC™ Flash-Free Adhesive is indicated for use in bonding orthodontic appliances for orthodontic 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 Runyre

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

510(k) Number: K113 197

Regulation Number and Section

§ 872.3750 Bracket adhesive resin and tooth conditioner.

(a)
Identification. A bracket adhesive resin and tooth conditioner is a device composed of an adhesive compound, such as polymethylmethacrylate, intended to cement an orthodontic bracket to a tooth surface.(b)
Classification. Class II.