K Number
K131385
Device Name
EASY-GRAFT
Date Cleared
2013-09-27

(136 days)

Product Code
Regulation Number
872.3930
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
easy-graft™ is indicated for the treatment of intraoral / maxillofacial osseous defects. Dental and maxillo-facial Indications may include: - . Extraction defects (alveolar ridge preservation) - Periodontal defects . - Peri-implant defects . - Augmentation of deficient alveolar crest (e.g. Guided Bone Regeneration, GBR) ・ - Sinus floor augmentation . - Defects after surgical extractions - - Defects after removal of bone cysts - Defects after root resection or apicoectorny - Defects after removal of autotogous bone .
Device Description
easy-graft™ contains: - Syringe containing beta-tricalcium phosphate (β-TCP) granules coated with poly(lactide-co-alvcolide) (PLGA) - Ampule containing BioLinker™ (N-methyl-2-pyrrolidone and water) . easy-graft™ is a bioresorbable, synthetic, porous bone graft substitute. It consists of two components: granules (supplied in a syringe) and BioLinker™ (supplied in an ampule). After mixing the components together, easy-graft" forms a moldable mass that can be applied directly from the syringe into the bone defect. easy-graft™ hardens in contact with body fluids, allowing a working time of approximately one minute after application into the bone defect. Depending on · blood inflow, hardening may take longer. easy-graft™ is provided in the particle sizes of 500 – 630 µm for smaller defects and 500 – 1000 um for larger defects. easy-graft™ is a biocompatible and osteoconductive material that allows for complete resorption by the body. easy-graft™ can be used in combination with dental membranes. easy-graft" contains no animal or human derived substances. β-TCP and PLGA are derived from synthetic raw materials.
More Information

Not Found

No
The device description focuses on the material composition and physical properties of a bone graft substitute, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes.
The device is indicated for the treatment of various intraoral/maxillofacial osseous defects, functioning as a bone graft substitute to aid in bone regeneration, which is a therapeutic purpose.

No

This device is a bioresorbable, synthetic, porous bone graft substitute used for treating osseous defects. It is a therapeutic device, not a diagnostic one.

No

The device description clearly states that easy-graft™ is a physical bone graft substitute consisting of granules and a liquid component, which are mixed and applied to a bone defect. This is a physical medical device, not a software-only one.

Based on the provided information, the easy-graft™ device is not an In Vitro Diagnostic (IVD).

Here's why:

  • Intended Use: The intended use is for the treatment of intraoral/maxillofacial osseous defects by acting as a bone graft substitute. This is a therapeutic application, not a diagnostic one.
  • Device Description: The device is a material (granules and a linker) that is applied directly into a bone defect to promote bone regeneration. It does not analyze samples from the body to provide diagnostic information.
  • Lack of Diagnostic Elements: There is no mention of the device being used to test samples (like blood, tissue, etc.) or to provide information about a patient's health status or disease.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. easy-graft™ does not fit this description.

N/A

Intended Use / Indications for Use

easy-graft™ is indicated for the treatment of intraoral / maxillofacial osseous defects. Dental and maxillo-facial indications may include:

  • Extraction defects (alveolar ridge preservation) -
  • -Periodontal defects
  • Peri-implant defects -
  • -Augmentation of deficient alveolar crest (e.g. Guided Bone Regeneration, GBR)
  • -Sinus floor augmentation
  • -Defects after surgical extractions
  • -Defects after removal of bone cysts
  • ・ Defects after root resection or apicoectorny
  • -Defects after removal of autologous bone

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

LYC

Device Description

easy-graft™ contains:

  • Syringe containing beta-tricalcium phosphate (β-TCP) granules coated with poly(lactide-co-alvcolide) (PLGA)
  • Ampule containing BioLinker™ (N-methyl-2-pyrrolidone and water) .

easy-graft™ is a bioresorbable, synthetic, porous bone graft substitute. It consists of two components: granules (supplied in a syringe) and BioLinker™ (supplied in an ampule). After mixing the components together, easy-graft" forms a moldable mass that can be applied directly from the syringe into the bone defect. easy-graft™ hardens in contact with body fluids, allowing a working time of approximately one minute after application into the bone defect. Depending on · blood inflow, hardening may take longer.
easy-graft™ is provided in the particle sizes of 500 – 630 µm for smaller defects and 500 – 1000 um for larger defects.
easy-graft™ is a biocompatible and osteoconductive material that allows for complete resorption by the body.
easy-graft™ can be used in combination with dental membranes.
easy-graft" contains no animal or human derived substances. β-TCP and PLGA are derived from synthetic raw materials.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

intraoral / maxillofacial osseous defects

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 Nonclinical Testing:
Chemical composition testing and physical characterization demonstrate the equivalence between easy-graft™ and its predicate devices. The biocompatibility tests and the sterility testing conclude that easy-graft™ is biologically safe for its intended use. easy-graft™ and the predicate device Bio-Oss were compared in an animal implantation test. No significant differences were detected in terms of osseointegration of the material, bone formation, or defect bridging. Degradation of the graft particles of easy-graft™ was evident. Clinical case reports confirmed bone formation at the site of device application of the device. No new issues of safety or effectiveness were identified during the testing of the 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.

K042583, K051443, K952618 / K970321 / K033815, K041324, K082383, K955838 / K982865, K033074

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

§ 872.3930 Bone grafting material.

(a)
Identification. Bone grafting material is a material such as hydroxyapatite, tricalcium phosphate, polylactic and polyglycolic acids, or collagen, that is intended to fill, augment, or reconstruct periodontal or bony defects of the oral and maxillofacial region.(b)
Classification. (1) Class II (special controls) for bone grafting materials that do not contain a drug that is a therapeutic biologic. The special control is FDA's “Class II Special Controls Guidance Document: Dental Bone Grafting Material Devices.” (See § 872.1(e) for the availability of this guidance document.)(2) Class III (premarket approval) for bone grafting materials that contain a drug that is a therapeutic biologic. Bone grafting materials that contain a drug that is a therapeutic biologic, such as biological response modifiers, require premarket approval.
(c)
Date premarket approval application (PMA) or notice of product development protocol (PDP) is required. Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.

0

510(k) Summary of Safety and Effectiveness Information ട്

| Applicant: | Degradable Solutions AG
Wagistrasse 23
CH-8952 Schlieren
Switzerland |
|-------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Phone Number: | +41 43 433 62 00 |
| Fax Number: | +41 43 433 62 01 |
| Official Correspondent: | M Squared Associates, Inc.
Deborah Lavoie Grayeski
901 King Street, Suite 101
Alexandria, VA 22314
Phone: 703-562-9800 ext. 250
Fax: 703-562-9797
Email: dgrayeski@msquaredassociates.com |
| Date of Preparation: | June 5, 2013 |

Submitter Information

Device Name

Trade Name:easy-graft™
Common/Usual Name:Bone Grafting Material, Synthetic
Classification Name:Bone Grafting Material (21 CFR 872.3930, Product code LYC)

Device Description

easy-graft™ contains:

  • Syringe containing beta-tricalcium phosphate (β-TCP) granules coated with poly(lactide-co-alvcolide) (PLGA)
  • Ampule containing BioLinker™ (N-methyl-2-pyrrolidone and water) .

easy-graft™ is a bioresorbable, synthetic, porous bone graft substitute. It consists of two components: granules (supplied in a syringe) and BioLinker™ (supplied in an ampule). After mixing the components together, easy-graft" forms a moldable mass that can be applied directly from the syringe into the bone defect. easy-graft™ hardens in contact with body fluids, allowing a working time of approximately one minute after application into the bone defect. Depending on · blood inflow, hardening may take longer.

1

easy-graft™ is provided in the particle sizes of 500 – 630 µm for smaller defects and 500 – 1000 um for larger defects.

easy-graft™ is a biocompatible and osteoconductive material that allows for complete resorption by the body.

easy-graft™ can be used in combination with dental membranes.

easy-graft" contains no animal or human derived substances. β-TCP and PLGA are derived from synthetic raw materials.

Intended Use/Indications:

easy-graft™ is indicated for the treatment of intraoral / maxillofacial osseous defects. Dental and maxillo-facial indications may include:

  • Extraction defects (alveolar ridge preservation) -
  • -Periodontal defects
  • Peri-implant defects -
  • -Augmentation of deficient alveolar crest (e.g. Guided Bone Regeneration, GBR)
  • -Sinus floor augmentation
  • -Defects after surgical extractions
  • -Defects after removal of bone cysts
  • ・ Defects after root resection or apicoectorny
  • -Defects after removal of autologous bone

Technological Characteristics Summary

Comparison to Predicate Devices

The predicate devices of easy-graft™ are:

  • · calc-i-oss™ bone graft substitutes (K042583) ("calc-i-oss"),
  • · Cerasorb® M Dental and Cerasorb® Perio (K051443) ("Cerasorb"),
  • Bio-Oss®, Bio-Oss® Blocks and Bio-Oss® Collagen (K952618 / K970321 / K033815) ("Bio-Oss"),

2

  • · CalMatrix™ (K041324) ("CalMatrix"),
  • Fortoss® Vital (K082383) ("Fortoss Vital")
  • · Atrisorb® Bioabsorbable Guided Tissue Regeneration (GTR) Barrier (K955838 / K982865) ("Atrisorb") and the
  • . Inion GTR™ Biodegradable Membrane System (K033074) ("Inion Membrane").

Predicate Device Comparison Table

FeatureComparison
Intended Useeasy-graft™ is used in the same indications as the predicate devices.
easy-graft™ and its predicate devices (calc-i-oss, Cerasorb, Bio-Oss and
FortOss Vital) are intended to be used as a bone graft substitute for intraoral /
maxillofacial osseous defects
Materialseasy-graft™ and the predicate devices calc-i-oss and Cerasorb are equivalent
by using porous β-TCP and conform to the standard specifications of ASTM F
1088-04a for a medical grade β-TCP.
easy-graft™ and the predicated devices Atrisorb and Inion Membrane use
PLA polymers and N-methyl-2-pyrrolidone as a temporal plasticizer.
Formeasy-graft™ has the same handling properties as the predicate devices
CalMatrix and Fortoss Vital (moldable, implant, hardening in the defect).
easy-graft™ and the predicate device calc-i-oss are identical with regards to
the shape and the size of the granules.
Porosityeasy-graft™ is porous like its predicate devices calc-i-oss, Cerasorb and
BioOss.
Resorption /
Bone Growtheasy-graft™ resorbs and is replaced with bone during the healing process like
its predicate devices calc-i-oss, Cerasorb and FortOss Vital.
Mode of actionNewly forming autogenous bone tissue will grow into the pore volume of easy-
graft™ and, in the course of material degradation, into the space previously
occupied by easy-graft™. easy-graft™ displays the same mode of action as
its predicate bone graft substitute devices (calc-i-oss, Cerasorb).

Risk Analysis and Test Methods:

The risks identified in the FDA Guidance Class II Special Controls Guidance Document: Dental Bone Grafting Material Devices (4/28/2005) were addressed by the risk miligation measures suggested therein as suggested in the following Table.

3

Risk Mitigation Measures

Identified RisksMitigation Measures
Ineffective Bone
FormationPhysical characterization according to FDA Guidance Class II
Special Controls Guidance Document: Dental Bone Grafting Material
Devices (4/28/2005) Chemical composition testing according to FDA Guidance Class II
Special Controls Guidance Document: Dental Bone Grafting Material
Devices (4/28/2005) Animal Testing Labeling
Adverse Tissue
Reaction ·Physical characterization according to FDA Guidance Class II
Special Controls Guidance Document: Dental Bone Grafting Material
Devices (4/28/2005) Chemical composition testing according to FDA Guidance Class II
Special Controls Guidance Document: Dental Bone Grafting Material
Devices (4/28/2005) Biocompatibility in accordance with #G95-1 (FDA Blue Book
Memorandum, Use of International Standard ISO-10993, "Biological
Evaluation of Medical Devices Part 1: Evaluation and Testing). Animal Testing Labeling
InfectionSterilization according to ISO 11137 (SAL Trade/Device Name: easy-grafi™ Regulation Number: 21 CFR 872.3930 Regulation Name: Bone Grafting Material Regulatory Class: Class II Product Code: LYC Dated: August 29, 2013 Received: August 30. 2013

Dear Ms. Grayeski:

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.

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

5

Page 2 - Ms. Grayeski

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 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" (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 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.

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

6

4 Indications for Use Statement

510(k) Number:

· K131385

Device Name: easy-graft™

Indications for Use:

easy-graft™ is indicated for the treatment of intraoral / maxillofacial osseous defects. Dental and maxillo-facial Indications may include:

  • . Extraction defects (alveolar ridge preservation)
  • Periodontal defects .
  • Peri-implant defects .
  • Augmentation of deficient alveolar crest (e.g. Guided Bone Regeneration, GBR) ・
  • Sinus floor augmentation .
  • Defects after surgical extractions -
  • Defects after removal of bone cysts
  • Defects after root resection or apicoectorny
  • Defects after removal of autotogous bone .

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 OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Andrew.J.Steen
2013.09.27 14:51:11 -04'00'