(137 days)
The SomnoDent Fusion is intended for the treatment of nighttime snoring and mild to moderate obstructive sleep apnea in patients 18 years of age or older.
The SomnoDent Fusion is an intraoral device intended for the treatment of nighttime snoring and mild to moderate obstructive sleep apnea in patients 18 years of age or older. The device functions as a mandibular repositioner, which acts to increase the patient's pharyngeal space during sleep. The increase in the patient's pharyngeal space improves their ability to exchange air during sleep. The device is patient specific (it is customized for each patient) and has an adjustable coupling mechanism enabling the amount of mandibular advancement to be set by the dentist or physician at the time of fitting the device. The SomnoDent Fusion is a modification to the SomnoDent Classic (K050592), SomnoDent Flex (K073004), SomnoDent G2 (K121340) and SomnoDent Herbst (K130558). The SomnoDent Fusion is identical to SomnoDent Classic, SomnoDent Flex, SomnoDent G2, and SomnoDent Herbst except for differences in the adjustment mechanism. Any differences introduced by these modifications, when compared to the predicate product, do not introduce new safety issues.
Here's the analysis of the acceptance criteria and the study that proves the device meets them, based on the provided text:
Device: SomnoDent Fusion (an intraoral device for snoring and mild to moderate obstructive sleep apnea)
1. A table of acceptance criteria and the reported device performance
Based on the provided document, the "acceptance criteria" are implied by demonstrating substantial equivalence to predicate devices through mechanical testing. The performance is reported as meeting this equivalence.
| Acceptance Criterion (Implied) | Reported Device Performance |
|---|---|
| Withstand applicable pressures (mechanical performance) | Testing results indicate that the mechanism withstands applicable pressures, ensuring the device is safe and effective. |
| Substantial equivalence to predicate device in mechanical performance | The testing concluded that the advancement of the subject device is substantially equivalent to the predicate device with regards to mechanical performance. |
2. Sample size used for the test set and the data provenance
The document states: "Mechanical testing was conducted on the calibration mechanism of the subject device." However, it does not specify the sample size for this mechanical testing. It also does not specify the data provenance (e.g., country of origin, retrospective or prospective) of this testing data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided in the document as the study described is mechanical testing, not a clinical study involving human assessment or ground truth established by experts.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
This information is not applicable as the described study is mechanical testing, not a clinical study involving human judgment or adjudication.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
A multi-reader multi-case (MRMC) comparative effectiveness study was not performed, nor is it applicable to this device. The SomnoDent Fusion is a physical intraoral device, not an AI or imaging diagnostic tool that would be evaluated with human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
A standalone performance test in the context of an algorithm or AI was not performed, nor is it applicable to this device. The device is a physical intraoral appliance. The "standalone" performance described is the mechanical testing of the device itself.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For the mechanical testing, the "ground truth" would be the engineering specifications and performance benchmarks established based on the predicate devices. The document implies that the "truth" is the "applicable pressures" and successful functioning compared to the predicate.
8. The sample size for the training set
This information is not applicable as the described study is mechanical testing for substantial equivalence, not a machine learning model requiring a training set.
9. How the ground truth for the training set was established
This information is not applicable as there is no training set for a machine learning model.
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510(k) Summary (21 CFR 807.92)
JUN 2 0 2014
Page 1 of 4
510(k) Number: К | Чб278
| Submission Owner: | SomnoMed, Inc. |
|---|---|
| 7460 Warren Parkway | |
| Suite 190 | |
| Frisco, TX 75034 | |
| Phone: 888-447-6673 x106 | |
| Fax: 972-377-3404 | |
| Email: kjayne@somnomed.com | |
| Official Correspondent: | Kathryn A. Jayne |
| Date Prepared: | January 31, 2014 |
| Trade Name: | SomnoDent® Fusion |
| Common Name: | Intraoral device for snoring and mild to moderate obstructive |
| sleep apnea (OSA) | |
| Classification Name: | Device, Anti-Snoring |
| Regulation Number: | 21 CFR 872.5570 |
| Product Code: | LRK |
| Class: | II |
| Panel: | Dental |
| Predicate Devices: | K050592, SomnoDent Classic |
| K073004, SomnoDent Flex | |
| K121340, SomnoDent G2 |
Description of the device:
The SomnoDent Fusion is an intraoral device intended for the treatment of nighttime snoring and mild to moderate obstructive sleep apnea in patients 18 years of age or older. The device functions as a mandibular repositioner, which acts to increase the patient's pharyngeal space during sleep. The increase in the patient's pharyngeal space improves their ability to exchange air during sleep. The device is patient specific (it is customized for each patient) and has an adjustable coupling mechanism enabling the amount of mandibular advancement to be set by the dentist or physician at the time of fitting the device. The SomnoDent Fusion is a modification to the SomnoDent Classic (K050592), SomnoDent Flex (K073004), SomnoDent G2 (K121340) and SomnoDent Herbst (K130558). The SomnoDent Fusion is identical to SomnoDent Classic, SomnoDent Flex, SomnoDent G2, and SomnoDent Herbst except for differences in the adjustment mechanism. Any differences introduced by these modifications, when compared to the predicate product, do not introduce new safety issues.
Indications for Use:
The SomnoDent Fusion is intended for the treatment of nighttime snoring and mild to moderate obstructive sleep apnea in patients 18 years of age or older.
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Image /page/1/Picture/0 description: The image shows the logo for SomnoMed. The logo consists of a stylized graphic above the company name. Below the name, the words "Dental * Sleep * Medical" are printed in a smaller font.
510(k) Summary (21 CFR 807.92)
Substantial Equivalence:
Substantial Equivalence Table
| SomnoDentFusion | SomnoDentClassicK050592 | SomnoDentFlexK073004 | SomnoDentG2K121340 | SomnoDentHerbstK130558 | |
|---|---|---|---|---|---|
| Intended Use | |||||
| Intended as anintraoral device | Yes | Yes | Yes | Yes | Yes |
| Intended toreduce snoringor help alleviatesnoring | Yes | Yes | Yes | Yes | Yes |
| Treatment ofmild tomoderateobstructivesleep apnea | Yes | Yes | Yes | Yes | Yes |
| Intended fornighttime use | Yes | Yes | Yes | Yes | Yes |
| Indicated forsingle patientmultiuse | Yes | Yes | Yes | Yes | Yes |
| Indicated foruse at home orsleeplaboratories | Yes | Yes | Yes | Yes | Yes |
| Targetpopulation:adults | Yes | Yes | Yes | Yes | Yes |
| Prescriptiondevice | Yes | Yes | Yes | Yes | Yes |
| Design | |||||
| Customized fitfor each patient(patientspecific) | Yes | Yes | Yes | Yes | Yes |
| Separate upperand lower traypieces | Yes | Yes | Yes | Yes | Yes |
| Works bymandibularadvancement | Yes | Yes | Yes | Yes | Yes |
| SomnoDentFusion | SomnoDent ClassicK050592 | SomnoDent FlexK073004 | SomnoDent G2K121340 | SomnoDent HerbstK130558 | |
| Can beadjusted or refit | Yes | Yes | Yes | Yes | Yes |
| Lower jawadjustmentusing suppliedcomponents | Yes | Yes | Yes | Yes | Yes |
| Permits patientto breathethrough mouth | Yes | Yes | Yes | Yes | Yes |
| Upper andlower traysdisengage foreasy removal | Yes | Yes | Yes | Yes | Yes |
| Cleaned andinspected dailyby patient | Yes | Yes | Yes | Yes | Yes |
| Material | |||||
| Traysconstructedfrom a softlining materialadhered to ahard surfaceacrylic | Yes(Flex retention)No(Classic retention) | No | Yes | Yes(Flex retention)No(Classic retention) | Yes(Flex retention)No(Classic retention) |
| Advancementmechanismconstructed ofsurgical gradestainless steel | Yes | Yes | Yes | No | Yes |
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510(k) Summary (21 CFR 807.92) Page 4 of 4
SomnoMed SomnoDent Fusion 510(k) Submission
5 - 4
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510(k) Summary (21 CFR 807.92) Page 4 of 4
Substantial equivalence discussion:
The SomnoDent Fusion is considered to be substantially equivalent to the SomnoDent Classic, Flex, G2, and Herbst device. The SomnoDent Fusion and predicate devices function as a mandibular repositioner, which acts to increase the patient's pharyngeal space during sleep. The increase in the patient's pharyngeal space improves their ability to exchange air during sleep. The devices are patient specific (customized for each patient) and have an adjustable coupling mechanism enabling the amount of mandibular advancement to be set by the dentist or physician at the time of fitting the device. The SomnoDent Fusion is identical to SomnoDent Classic, Flex, G2, and SomnoDent Herbst except for differences in the adjustment. The SomnoDent Fusion will be available in one of two material types, acrylic (identical to SomnoDent Classic) or soft lining adhered to acrylic (SomnoDent Flex). Any differences introduced by these modifications, when compared to the predicate product, do not introduce new safety issues.
Summary of Testing:
To demonstrate substantial equivalence, testing was conducted on the advancement mechanism to ensure the device performed as intended and is safe and effective. Mechanical testing was conducted on the calibration mechanism of the subject device. Testing results indicate that the mechanism withstands applicable pressures, ensuring the device is safe and effective. The testing concluded that the advancement of the subject device is substantially equivalent to the predicate device with regards to mechanical performance. Testing demonstrates that the subject device, the SomnoDent Fusion, is as safe, as effective, and performs as well as or better than the predicate devices, the SomnoDent Classic, SomnoDent Flex, SomnoDent G2, and SomnoDent Herbst.
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Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
June 20, 2014
SomnoMed. Incorporated Ms. Kathryn Jayne Regulatory Affairs/Quality Assurance Manager 7460 Warren Parkway, Suite 190 Frisco, TX 75034
Re: K140278
Trade/Device Name: SomnoDent Fusion Classic, Somnodent Fusion Flex Regulation Number: 21 CFR 872.5570 Regulation Name: Intraoral devices for snoring and intraoral devices for snoring and obstructive sleep apnea Regulatory Class: Il
Product Code: LRK Dated: June 4, 2014 Received: June 5, 2014
Dear Ms. Jayne:
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 10 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 - Ms. Jayne
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 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/Resourcesfor You/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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
Mary S. Runner -S
Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF KEALTH AND HUMAN SERVICES
Food and Drug Administration Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.
.
610(k) Number (if known)
Device Name SonnoDent Fusion
Indications for Use (December)
Indications for Use (Decorde)
The Sommonlews Fission is imment of sightines maring and mild to modests obstructive sloep spass in patients 18 years of age or older.
| Type of Use (Select one or both, as applicable) | Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C) |
|---|---|
| ------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- |
PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
FOR FDA USE ONLY
| Concurrence of Center for Devices and Radiological Health (CDRH) (Signature) | Sheena A. Green -S |
|---|---|
| 2014.06.20 13:21:29 -04'00' | |
| FORM FDA 3881 (1/14) | Page 1 of 2 |
CONFIDENTIAL SomnoMed SomnoDent Fusion Special 510(k) Submission
4 - 2
§ 872.5570 Intraoral devices for snoring and intraoral devices for snoring and obstructive sleep apnea.
(a)
Identification. Intraoral devices for snoring and intraoral devices for snoring and obstructive sleep apnea are devices that are worn during sleep to reduce the incidence of snoring and to treat obstructive sleep apnea. The devices are designed to increase the patency of the airway and to decrease air turbulence and airway obstruction. The classification includes palatal lifting devices, tongue retaining devices, and mandibular repositioning devices.(b)
Classification. Class II (special controls). The special control for these devices is the FDA guidance document entitled “Class II Special Controls Guidance Document: Intraoral Devices for Snoring and/or Obstructive Sleep Apnea; Guidance for Industry and FDA.”