K Number
K131376
Device Name
SMARTCOAT 2.5% NAF VARNISH
Manufacturer
Date Cleared
2013-08-27

(105 days)

Product Code
Regulation Number
872.3260
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
SmartCoat 2.5% NaF Varnish is intended for use on sensitive teeth, over exposed dentin . and root surface sensitivity, and under temporary restorations or cements where post operative sensitivity is of concern. . Rapid Desensitizer . Provides rapid relief from sensitive teeth due hypersensitivity
Device Description
SmartCoat 2.5% NaF Varnish is classified as a Cavity Varnish (21 CFR 872.3260) because it is a device that provides relief from tooth surface hypersensitivity when applied to dentin surfaces by forming a film that facilitates occlusion of compromised surfaces including open dentinal tubules. SmartCoat is a topically applied, flavored cavity varnish containing sodium fluoride in a shellac resin based preparation. The varnish is an insoluble viscous liquid that dries once applied to the teeth to form a surface film. The packaging provides an accurate dosing and uniform dispensing mechanism for consistent product mixing and delivery.
More Information

No
The document describes a dental varnish and its physical properties and performance in occluding dentinal tubules. There is no mention of AI or ML in the intended use, device description, or performance studies. The image analysis mentioned is likely standard image processing for measurement, not AI/ML-based analysis.

Yes
The device is described as providing "relief from sensitive teeth due to hypersensitivity" and "rapid relief from sensitive teeth" by forming a film that occludes compromised surfaces, including open dentinal tubules, which directly addresses a medical condition.

No
The device is a cavity varnish used to provide relief from tooth surface hypersensitivity by forming a film that occludes compromised surfaces. It is for treatment, not diagnosis. The performance studies describe evaluating the product’s effectiveness in occluding tubules, not diagnosing a condition.

No

The device is a physical varnish containing sodium fluoride and a shellac resin base, intended for topical application to teeth. It is classified as a Cavity Varnish, which is a physical medical device.

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

Here's why:

  • Intended Use: The intended use is for treating sensitive teeth, exposed dentin, and root surface sensitivity by being applied directly to these surfaces in the mouth. This is a therapeutic application, not a diagnostic one.
  • Device Description: The device is described as a "Cavity Varnish" that is "topically applied" to teeth. It works by forming a film to occlude dentinal tubules. This is a physical mechanism of action within the body, not an in vitro test performed on a sample taken from the body.
  • Anatomical Site: The anatomical site is teeth, dentin surfaces, and root surface, which are all within the body.
  • Performance Studies: The performance studies involve applying the varnish to human dentin slabs and examining the occlusion of tubules. While this involves some in vitro testing of the material's properties, the purpose is to demonstrate its effectiveness when applied in vivo to the tooth surface.

IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) 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

  • SmartCoat 2.5% NaF Varnish is intended for use on sensitive teeth, over exposed dentin . and root surface sensitivity, and under temporary restorations or cements where post operative sensitivity is of concern.
  • . Rapid Desensitizer
  • . Provides rapid relief from sensitive teeth due hypersensitivity

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

LBH

Device Description

SmartCoat 2.5% NaF Varnish is classified as a Cavity Varnish (21 CFR 872.3260) because it is a device that provides relief from tooth surface hypersensitivity when applied to dentin surfaces by forming a film that facilitates occlusion of compromised surfaces including open dentinal tubules.

SmartCoat is a topically applied, flavored cavity varnish containing sodium fluoride in a shellac resin based preparation. The varnish is an insoluble viscous liquid that dries once applied to the teeth to form a surface film. The packaging provides an accurate dosing and uniform dispensing mechanism for consistent product mixing and delivery.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Teeth, dentin, root surface

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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)

Summary of Physical Tests: Smart coat was tested using subjective light microscopy analysis at 500x magnification to determine dentin tubule occlusion. Human dentin slabs were prepared as described in the bench performance testing section (Section 18) and varnish was applied to the sample. The varnish was allowed to cure in an incubator and then placed in de-ionized water and stirred vigorously for 6 days. Images were taken immediately after application, and after 3 and 6 days. The specimens were examined for tubule occlusion by image analysis.

Key results: All dentinal tubules that were initially covered at time 0 remained covered through the entire treatment period well enough that nearly no dentinal tubules were visible in the coated area. The only visible tubules were still covered by a layer of SmartCoat, however the layer was transparent in a small area near the border. The amount of remaining tubule covering was ranked on a scale of 1-6 with 1 = no occlusion, 2 = 25-50% or less occlusion, 3 = 25-50% occlusion, 4 = 50-75% occlusion, 5 = more than 75% occlusion, and 6 = complete occlusion. At all measured time points occlusion ratings for SmartCoat Varnish were 6.

It was concluded that SmartCoat varnish will occlude exposed tubules and therefore the varnish should provide relief from tooth hypersensitivity.

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.

K092141

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.

K030922, K945794

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

§ 872.3260 Cavity varnish.

(a)
Identification. Cavity varnish is a device that consists of a compound intended to coat a prepared cavity of a tooth before insertion of restorative materials. The device is intended to prevent penetration of restorative materials, such as amalgam, into the dentinal tissue.(b)
Classification. Class II (special controls). The device, when it is an external cleaning solution, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 872.9.

0

Image /page/0/Picture/1 description: The image shows the logo for Elevate Oral Care. The logo consists of a stylized globe on the left, followed by the word "elevate" in a lowercase, sans-serif font. Below "elevate" are the words "ORAL CARE" in a smaller, sans-serif font.

5. 510(k) Summary

Submitter:

Company:Elevate Oral Care
Street:346 Pike Road, Suite 5
City, State Zip:West Palm Beach, FL 33411
Country:USA
Estab. Registration #:3009603151
Correspondent:Steve Pardue
Managing Member
Phone:877-866-9113
Fax:561-244-1927
Email:spardue@elevateoralcare.com
Date:May 10, 2013

ww.elevateoralcare.com

346 Pike Road, Suite 5 . West Palm Beach, FL 3341 1 Phone: 877-866-9113 · Fox: 561-244-1927

AUG 27 2013

Name of Device

Proprietary Name:SmartCoatTM 2.5% NaF Varnish
Classification Name:Cavity Varnish, Dental
21 CFR 872.3260 as Class II device
Common Name:Cavity Varnish

Predicate Devices

Device510(k)
Vanish 5% NaF VarnishK092141
VivaSensK030922
Duraphat 5% NaF VarnishK945794

Description

SmartCoat 2.5% NaF Varnish is classified as a Cavity Varnish (21 CFR 872.3260) because it is a device that provides relief from tooth surface hypersensitivity when applied to dentin surfaces by forming a film that facilitates occlusion of compromised surfaces including open dentinal tubules.

SmartCoat is a topically applied, flavored cavity varnish containing sodium fluoride in a shellac resin based preparation. The varnish is an insoluble viscous liquid that dries once applied to the teeth to form a surface film. The packaging provides an accurate dosing and uniform dispensing mechanism for consistent product mixing and delivery.

For Total Body Health

1

Indications for Use

  • SmartCoat 2.5% NaF Varnish is intended for use on sensitive teeth, over exposed dentin . and root surface sensitivity, and under temporary restorations or cements where post operative sensitivity is of concern.
  • . Rapid Desensitizer
  • . Provides rapid relief from sensitive teeth due hypersensitivity

Technological Characteristics

The chemical composition of SmartCoat is similar to the predicate devices and other fluoride varnishes which have been in use for many decades. These products use resins, rosins, modified rosins, hydroxypropyl cellulose, polyurethane, methacrylates, polyethyleneglycol dimethacrylate, and other film forming ingredients to cover dentinal tubules and provide relief from dentinal hypersensitivity.

Shellac resin was chosen as the film forming agent for SmartCoat Varnish due to its extensive safe history in dental and food applications as a film forming barrier and properties similar to existing resins in the Cavity Varnish category. The use of this ingredient rather than colophony rosin eliminates the concern of colophony rosin allergies experienced by some varnishes. Shellac has been used in denture trays and base plates for many years; these trays and plates are currently considered 510(k) exempt (regulation numbers 872.3670, 872.6200).

Many cavity varnishes contain sodium fluoride, calcium phosphates or other mineral ingredients to help occlude tubules. SmartCoat contains sodium fluoride and hydroxyapatite to help occlude tubules.

Summary of Physical Tests

Smart coat was tested using subjective light microscopy analysis at 500x magnification to determine dentin tubule occlusion. Human dentin slabs were prepared as described in the bench performance testing section (Section 18) and varnish was applied to the sample. The varnish was allowed to cure in an incubator and then placed in de-ionized water and stirred vigorously for 6 days. Images were taken immediately after application, and after 3 and 6 days. The specimens were examined for tubule occlusion by image analysis.

All dentinal tubules that were initially covered at time 0 remained covered through the entire treatment period well enough that nearly no dentinal tubules were visible in the coated area. The only visible tubules were still covered by a layer of SmartCoat, however the layer was transparent in a small area near the border. The amount of remaining tubule covering was ranked on a scale of 1-6 with 1 = no occlusion, 2 = 25-50% or less occlusion, 3 = 25-50% occlusion, 4 = 50-75% occlusion, 5 = more than 75% occlusion, and 6 = complete occlusion. At all measured time points occlusion ratings for SmartCoat Varnish were 6.

2

It was concluded that SmartCoat varnish will occlude exposed tubules and therefore the varnish should provide relief from tooth hypersensitivity.

Description of Safety and Substantial Equivalence

The chemical components in SmartCoat Varnish have been used in predicate devices, are listed as GRAS ingredients, or both. Shellac and ammonium phosphate have extensive use in food preparation and coatings as well as dental applications that provide significant history of safe use. We believe these facts well support the compatibility of SmartCoat Varnish, and the safety of the applicant device is substantially equivalent to the predicate devices in properties, intended use and composition.

Information provided in this submission confirms the substantial equivalence to the predicate devices with common indications. The data provided in this 510(k) submission also shows that the composition is safe for its intended use based on the biocompatibility assessment and risk assessment conduced according to ISO 10993 and ISO 14971.

3

Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or bird in flight, composed of three curved lines.

Public Health Service

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

August 27, 2013

Elevate Oral Care Mr. Steve Pardue Managing Member 346 Pike Road, Suite 5 WEST PALM BEACH, FL 33411

Re: K131376

Trade/Device Name: SmartCoat™ 2,5% NaF Varnish Regulation Number: 21 CFR 872.3260 Regulation Name: Cavity Varnish Regulatory Class: II Product Codes: LBH Dated: June 10, 2013 Received: June 11, 2013

Dear Mr. Pardue:

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.

4

Page 2 - Mr. Pardue

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 (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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree 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" (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,

Image /page/4/Picture/7 description: The image shows the name "Mary S. Runner -S" in a simple, sans-serif font. The text is horizontally oriented and appears to be a name or title. The letters are black against a white background, providing a clear contrast.

Kwame Ulmer M.S. Acting Division Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

4. Indications for Use Statement

Indications for Use

510(k) Number (if known):

Device Name: SmartCoat 2.5% NaF Varnish

Indications for Use:

  • . SmartCoat 2.5% NaF Varnish is intended for use on sensitive teeth, over exposed dentin and root surface sensitivity, and under temporary restorations or cements where post operative sensitivity is of concern.
  • Rapid Desensitizer .
  • Provides rapid relief from sensitive teeth duc to hypersensitivity .

Prescription Use _____________________________________________________________________________________________________________________________________________________________ (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 OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

| | Sheena A. Green -S
2013.08.27 15:30:24 -04'00' |
|-----------------------------------------------------------------------------------|---------------------------------------------------|
| | for M. Susan Runner, DDS, MA |
| | Page __ of __ |
| (Division Sign-Off) | |
| Division of Anesthesiology, General Hospital
Infection Control, Dental Devices | |
| 510(k) Number: | K131374 |