K Number
K143117
Device Name
Wire Sterilization Package with Indicators
Date Cleared
2015-10-29

(364 days)

Product Code
Regulation Number
880.6850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Wire Sterilization Package with Indicators is intended to be used to enclose and package American Orthodontics' line of Orthodontic Arch Wires. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. The indicators will display a visual color change to steam or ethylene oxide gas and distinguish between processed and unprocessed wire.
Device Description
American Orthodontics' Wire Sterilization Package with indicators is manufactured from bleached surgical paper and plastic film with external chemical process indicators. This packaging is a pouch that is enclosed on all four sides and contains a single arch wire. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. Upon completion of the sterilization process, the enclosed arch wire is intended to be used immediately. This packaging is not offered as a stand-alone product, but is strictly used for the packaging of American Orthodontics' Arch Wires (Classification Code: DZC; 510(k) Exempt). The bleached surgical paper conforms to the FDA 21CFR186.1673 and can be sterilized using steam or ethylene oxide gas. The plastic film is sealed to the bleached surgical paper and conforms to 21CFR177.1630 (Polyester), 21CFR175.105 (Adhesive) and 21CFR177.1520 (Polypropylene). The process indicators meet the performance requirements of AAMI/ANSI/ISO 11140-1:2014.
More Information

Not Found

No
The device is a sterilization package with chemical indicators, and the description focuses on material properties, sterilization validation, and indicator performance. There is no mention of AI/ML in the intended use, device description, or performance studies.

No.
The device is a sterilization package for orthodontic arch wires, not a device used to treat a medical condition or disease.

No

Explanation: The device is a sterilization package with chemical process indicators. Its function is to package and allow for sterilization of orthodontic arch wires, and its indicators show whether the sterilization process has occurred. It does not provide information about a patient's health status or diagnose any condition.

No

The device is a physical package made of paper and plastic film with chemical indicators, 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 package orthodontic arch wires for sterilization and to provide indicators that show whether the sterilization process has occurred. It is not intended to be used in vitro (outside the body) to examine specimens derived from the human body for the purpose of providing information for diagnosis, monitoring, or treatment.
  • Device Description: The device is a sterilization package with chemical indicators. It does not contain reagents, calibrators, controls, or other components typically associated with IVD tests.
  • Performance Studies: The performance studies focus on the sterilization process, material compatibility, indicator validation, and biocompatibility of the packaging and the enclosed arch wires. These are not studies related to the diagnostic performance of a test.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, detecting analytes, or providing diagnostic information.

The device is a medical device, specifically a sterilization packaging system with process indicators, but it does not fit the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

Wire Sterilization Package with Indicators is intended to be used to enclose and package American Orthodontics' line of Orthodontic Arch Wires. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. The indicators will display a visual color change to steam or ethylene oxide gas and distinguish between processed and unprocessed wire.

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

FRG; JOJ

Device Description

American Orthodontics' Wire Sterilization Package with indicators is manufactured from bleached surgical paper and plastic film with external chemical process indicators. This packaging is a pouch that is enclosed on all four sides and contains a single arch wire. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. Upon completion of the sterilization process, the enclosed arch wire is intended to be used immediately.

This packaging is not offered as a stand-alone product, but is strictly used for the packaging of American Orthodontics' Arch Wires (Classification Code: DZC; 510(k) Exempt).

The bleached surgical paper conforms to the FDA 21CFR186.1673 and can be sterilized using steam or ethylene oxide gas.

The plastic film is sealed to the bleached surgical paper and conforms to 21CFR177.1630 (Polyester), 21CFR175.105 (Adhesive) and 21CFR177.1520 (Polypropylene).

The process indicators meet the performance requirements of AAMI/ANSI/ISO 11140-1:2014.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

health provider (trained dental professional and/or Orthodontist)

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)

MATERIAL COMPATIBILITY TESTING
Material Compatibility Testing for the enclosed arch wires were conducted following ISO 15841:2014 Dentistry – Wires for Use in Orthodontics before and after the sterilization processes. Sterilization of the arch wires using Steam, Formaldehyde and Ethylene Oxide had no effect on the material or functionality of the arch wires.

PERFORMANCE TESTING
Performance Testing was conducted by placing spores in the most difficult to sterilize locations. Samples were processed at half cycle and biological indicators (BI) removed after exposure. Biological indicators were aseptically transferred to culture media and incubated. Performance testing validated that the cycles are able to achieve the desired Sterility Assurance Level (SAL).

RESIDUAL TESTING
Residual testing was conducted following ISO 10993-7:2008/(R) 2012 Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide Sterilization Residuals. Test samples met reference guidelines.

INDICATOR VALIDATION
Indicator Validation testing was conducted following AAMI/ANSI ISO 11140-1 Sterilization of Health Care Products – Chemical Indicators – Part 1: General Requirements. Results verified that the chemical indicators tested changed to an appropriate signal color when tested under the "Pass Cycle" conditions and met the "Pass Cycle" requirements for Class I process indicators.

BIOCOMPATIBILITY/LEACHABILITY: CYTOTOXICITY TESTING
Cytotoxicity Testing was conducted after sterilization processes following ISO 10993-5: Biological Evaluation of Medical Devices – Part 5: Tests for In-Vitro Cytotoxicity and United States Pharmacopeia/National Foundry, Biological Reactivity Test, In Vitro; Elution Test. American Orthodontics' Wire Sterilization Package with Indicators do not come into contact with patients. The enclosed archwires met the USP and ISO 10993-5 requirements for the test. All test samples PASSED.

BIOCOMPATIBILITY - (ENCLOSED ARCHWIRES)
Archwires were sent to independent labs for biocompatibility testing before sterilization according to ISO 10993-5:2009, Biological Evaluation of Medical Devices – Part 5: Tests for In Vitro Cytotoxicity and ISO 10993-10, Tests for Irritation and Sensitization - Sensitization Test. All test samples PASSED.

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.

K112591, K951113

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

§ 880.6850 Sterilization wrap.

(a)
Identification. A sterilization wrap (pack, sterilization wrapper, bag, or accessories, is a device intended to be used to enclose another medical device that is to be sterilized by a health care provider. It is intended to allow sterilization of the enclosed medical device and also to maintain sterility of the enclosed device until used.(b)
Classification. Class II (performance standards).

0

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-000

October 29, 2015

American Orthodontics Ms. Trang Adams Regulatory Affairs Specialist 3524 Washington Avenue Sheboygan, WI 53081

Re: K143117

Trade/Device Name: Wire Sterilization Package with Indicators Regulation Number: 21 CFR 880.6850 Regulation Name: Sterilization Wrap Regulatory Class: II Product Code: FRG; JOJ Dated: September 21, 2015 Received: September 29, 2015

Dear Ms. Adams,

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.

1

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 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/ResourcesforYou/Industry/default.htm.

Sincerely yours.

Tejashri Purohit-Sheth, M.D.

Tejashri Purohit-Sheth, M.D. Clinical Deputy Director DAGRID/ODE/CDRH FOR

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

2

Indications for Use

510(k) Number (if known) K143117

Device Name Wire Sterilization Package with Indicators

Indications for Use (Describe)

Wire Sterilization Package with Indicators is intended to be used to enclose and package American Orthodontics' line of Orthodontic Arch Wires. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. The indicators will display a visual color change to steam or ethylene oxide gas and distinguish between processed and unprocessed wire.

STERILIZATION PARAMETERS

Ethylene Oxide [100% E.O.] Gas

    1. EO Concentration: 725 mg/L
    1. Exposure Temperature: 130°F (55°C)
    1. Exposure Time: 1 hour
    1. Aeration Time: 8 hours

Upon completion of the process, the EO color indicator will change from Blue to Cocoa Brown.

Steam - Gravity

    1. Exposure Temperature: 270°F (132°C)
    1. Exposure Time: 15 minutes
    1. Dry Time: 30 minutes

Upon completion of the process, the STEAM color indicator will change from Blue to Black.

Please Note: Upon completion of the process, the archwire is to be used immediately.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

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"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

3

Image /page/3/Picture/0 description: The image shows the logo for American Orthodontics. The logo consists of the letters "AO" in a stylized font on the left, followed by the words "AMERICAN" and "ORTHODONTICS" stacked on top of each other on the right. The letters and words are all in a dark blue color. The logo is simple and modern, and it is likely used to represent the company's brand.

www.americanortho.com

1 800 558 7687 +1 920 457 5051 office +1 920 457 1485 fax

Page 5-1

510(k) Summary 21CFR807.92

Date Prepared: October 23, 2015

Company Information:

American Orthodontics 3524 Washington Avenue Sheboygan, WI 53081 Phone: 920-457-5051 Fax: 920-457-5773

Contact Information:

Trang Adams / Regulatory Affairs Specialist

Device Information:

Trade Name: Wire Sterilization Package with Indicators Common Name: Wire Sterilization Package with Indicators Classification Name: Sterilization Wrap; Sterilization Process Indicator 510(k) Number: K143117 Classification Code: FRG; JOJ Regulation Number (21CFR): 880.6850; 880.2800

Component Device Information:

Common Name: Orthodontic Arch Wires Classification Name: Wire, Orthodontic 510(k) Number: Exempt (Class I) Classification Code: DZC Regulation Number (21CFR): 872.5410 American Orthodontics' Models: Stainless Steel Wires, Nickel Titanium (NiTi) Wires, Beta Titanium Wires, Chromium Cobalt (CrCo) Wires, Copper Nickel Titanium (CuNiTi) Wires

Predicate Devices Information:

Primary Predicate:

Product/Trade Name: Safe Secure Sterilization Pouch with Steam and Ethylene Oxide Process Indicators Manufacturer: Safe Secure Packaging Company, Limited 510(k) #: K112591 Classification Name: Sterilization Wrap Classification Code: FRG Regulation Number (21CFR): 880.6850

4

Image /page/4/Picture/0 description: The image shows the logo for American Orthodontics. The logo consists of the letters "AO" in a stylized font on the left, followed by the words "AMERICAN" and "ORTHODONTICS" stacked on top of each other on the right. The letters and words are all in a dark blue color. The logo is simple and modern, and it is likely used to represent the company's brand.

www.americanortho.com

1 800 558 7687 +1 920 457 5051 office +1 920 457 1485 fax

Page 5-2

Secondary Predicate: Product/Trade Name: Cross-Checks Indicator Manufacturer: SteriTec Products Mfg. Co., Inc 510(k) #: K951113 Classification Name: Sterilization Process Indicator Classification Code: JOJ Regulation Number (21CFR): 880.2800

American Orthodontics' new device combines a sterilizable pouch (Classification Code: FRG) with sterilization process indicators (Classification Code: JOJ) that contains an Arch Wire (Classification Code: DZC). It was deemed appropriate to choose two predicates containing the classification codes that were suitable to the Wire Sterilization Package with Indicators to demonstrate substantial equivalency.

Description of the Device:

American Orthodontics' Wire Sterilization Package with indicators is manufactured from bleached surgical paper and plastic film with external chemical process indicators. This packaging is a pouch that is enclosed on all four sides and contains a single arch wire. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. Upon completion of the sterilization process, the enclosed arch wire is intended to be used immediately.

This packaging is not offered as a stand-alone product, but is strictly used for the packaging of American Orthodontics' Arch Wires (Classification Code: DZC; 510(k) Exempt).

The bleached surgical paper conforms to the FDA 21CFR186.1673 and can be sterilized using steam or ethylene oxide gas.

The plastic film is sealed to the bleached surgical paper and conforms to 21CFR177.1630 (Polyester), 21CFR175.105 (Adhesive) and 21CFR177.1520 (Polypropylene).

The process indicators meet the performance requirements of AAMI/ANSI/ISO 11140-1:2014.

5

Image /page/5/Picture/0 description: The image shows the logo for American Orthodontics. The logo consists of the letters "AO" in a stylized font, followed by the words "AMERICAN ORTHODONTICS" in a smaller, sans-serif font. The color of the logo is a dark blue. The logo is simple and modern, and it is likely used to represent the company's brand.

www.americanortho.com

1 800 558 7687 +1 920 457 5051 office +1 920 457 1485 fax

Page 5-3

Indications for Use:

Wire Sterilization Package with Indicators is intended to enclose and package American Orthodontics' line of Orthodontic Arch Wires. These packages are shipped unsterile and for single-use only. This packaging offers the health provider (trained dental professional and/or Orthodontist) the option of sterilizing the enclosed arch wire using steam or ethylene oxide gas. The indicators will display a visual color change to signify exposure to steam or ethylene oxide gas and distinguish between processed and unprocessed wire.

STERILIZATION PARAMETERS

Ethylene Oxide [100% E.O.] Gas

    1. EO Concentration: 725 mg/L
  • Exposure Temperature: 130°F (55°C) 2.
    1. Exposure Time: 1 hour
    1. Aeration Time: 8 hours

Upon completion of the process, the EO color indicator will change from Blue to Cocoa Brown.

Steam – Gravity

    1. Exposure Temperature: 270°F (132°C)
    1. Exposure Time: 15 minutes
    1. Dry Time: 30 minutes

Upon completion of the process, the STEAM color indicator will change from Blue to Black/Brownish Black.

Please Note: Upon completion of the process, the archwire is to be used immediately.

The Indications for Use statement for American Orthodontics' Wire Sterilization Package with indicators is not identical to the predicates however, the differences do not alter the intended use or safety and effectiveness of the device relative to the predicates. Both devices have the same intended use, to be able to distinguish between processed and unprocessed devices.

6

Image /page/6/Picture/0 description: The image shows the logo for American Orthodontics. The logo consists of the letters "AO" in a stylized font, followed by the words "AMERICAN" and "ORTHODONTICS" stacked on top of each other. The logo is in a dark blue color. The logo is simple and modern, and it is likely used to represent the company's brand.

www.americanortho.com

1 800 558 7687 +1 920 457 5051 office +1 920 457 1485 fax

Page 5-4

Device Comparison:

For detailed comparisons, please reference Section 12: Substantial Equivalence Discussion.

The table below outlines comparisons of the predicates and American Orthodontics' Wire Sterilization Packaging with Indicators to show substantial equivalency.

Device Name / Manufacturer
ElementSafe Secure Sterilization Pouch
with Steam and Ethylene Oxide
Process Indicators / Safe Secure
Packaging Company, LimitedCross-Checks / SteriTec
Products Mfg. Co., IncWire Sterilization
Packaging with
Indicators/ American
OrthodonticsSubstantial
Equivalence
Analysis
510(k) NumberK112591K951113K143117N/A
Classification
Code/Regulation
NumberFRG
880.6850JOJ
880.2800FRG/JOJ
880.2800/880.6850N/A
Intended UseSafe Secure Sterilization Pouch with
Steam and Ethylene Oxide Process
Indicators Models: ABHSP, ABSSP, is
intended to be used to enclose
another medical device that is to be
sterilized by a health provider by
gravity steam and ethylene oxide
(EtO). The recommended steam
sterilization cycle parameters are 30
minutes at 121°C (250°F). The
recommended EtO gas sterilization
cycle is 735mg/L of ethylene oxide
(EtO) for 1 hour at 55°C (130°F) and
50% to 80% RH. The pouch's
external chemical ink indicators on
the pouches are intended to
demonstrate that the device has been
exposed to steam or EtO sterilization
process and to distinguish between
processed and unprocessed devices.
The pouch is intended to allow
sterilization of the enclosed medical
device.SteriTec CROSS-CHECKS
sterilization chemical
monitoring strips are
designed to be utilized in
steam sterilizer operating
at 132°C to 135°C (270°F
to 276°F). When used as
directed, the SteriTec
Cross-Checks indicator
strips give visible
indication that sterilizing
conditions were met.
During steam
sterilization, the check
mark at the end of the
strip changes from white
to black, becoming as
dark or darker in
intensity than the black
reference arrow printed
on the strip.Wire Sterilization Package
with Indicators is intended
to be used to enclose and
package American
Orthodontics' line of
Orthodontic Arch Wires.
These packages are shipped
unsterile and for single-use
only. This packaging offers
the health provider (trained
dental professional and/or
Orthodontist) the option of
sterilizing the enclosed arch
wire using steam or
ethylene oxide gas. The
indicators will display a
visual color change to
signify exposure to steam or
ethylene oxide gas and
distinguish between
processed and unprocessed
wire.Equivalent
Device Design &
ComponentsPouch: 2-30" Wx2-30"L, Medical-
grade paper or Tyvek, Plastic Film
Chemical Indicator:
not disclosed; printed on surgical
paperStrip: 0.5625"W x 7.66"
L, 80 lbs Cover
Chemical Indicator:
White to Dark; printed on
paper strip over laminate
of PETPouch: 3.5" Wx4.5"L,
60g/m² Surgical Paper, Blue
Film
Chemical Indicator:
Steam: Blue to Brownish
Black/Black; Ethylene
Oxide: Blue to Coco BrownEquivalent
Indicator AgentIndicating Ink: Proprietary to Safe
Secure, yields a color-changeIndicating Ink: Lead
based agent to yield
color-changeSteam Indicating Ink: Lead
based agent to yield color-
change
Ethylene Oxide Indicating
Ink: Water based agent to
yield color-changeEquivalent
Sterilization
MethodsSteam: 121°C for 30 minutes.
Ethylene Oxide gas : 55°C for 1 hourSteam: 132°C - 134°C for
3 minutesSteam: 132°C for 15
minutes
Ethylene Oxide: 55°C for 1
hourEquivalent
Standards MetISO 11140-1 (Indicators)ISO 11140-1 (Indicators)ISO 11140-1 (Indicators)Equivalent

7

Image /page/7/Picture/0 description: The image shows the logo for American Orthodontics. The logo consists of the letters "AO" in a stylized font, with the word "AMERICAN" written to the right of the letters. Below the word "AMERICAN" is the word "ORTHODONTICS" in a smaller font. The logo is in a dark blue color.

www.americanortho.com

1 800 558 7687 +1 920 457 5051 office +1 920 457 1485 fax

Page 5-5

Performance Data:

Please reference Section 15: Biocompatibility and Section 18: Performance Testing - Bench for more details.

The following performance data were provided:

MATERIAL COMPATIBILITY TESTING

Material Compatibility Testing for the enclosed arch wires were conducted following ISO 15841:2014 Dentistry – Wires for Use in Orthodontics before and after the sterilization processes. Sterilization of the arch wires using Steam, Formaldehyde and Ethylene Oxide had no effect on the material or functionality of the arch wires.

PERFORMANCE TESTING

Performance Testing was conducted by placing spores in the most difficult to sterilize locations. Samples were processed at half cycle and biological indicators (BI) removed after exposure. Biological indicators were aseptically transferred to culture media and incubated. Performance testing validated that the cycles are able to achieve the desired Sterility Assurance Level (SAL).

RESIDUAL TESTING

Residual testing was conducted following ISO 10993-7:2008/(R) 2012 Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide Sterilization Residuals. Test samples met reference guidelines.

INDICATOR VALIDATION

Indicator Validation testing was conducted following AAMI/ANSI ISO 11140-1 Sterilization of Health Care Products – Chemical Indicators – Part 1: General Requirements. Results verified that the chemical indicators tested changed to an appropriate signal color when tested under the "Pass Cycle" conditions and met the "Pass Cycle" requirements for Class I process indicators.

BIOCOMPATIBILITY/LEACHABILITY: CYTOTOXICITY TESTING

Cytotoxicity Testing was conducted after sterilization processes following ISO 10993-5: Biological Evaluation of Medical Devices – Part 5: Tests for In-Vitro Cytotoxicity and United States Pharmacopeia/National Foundry, Biological Reactivity Test, In Vitro; Elution Test. American Orthodontics' Wire Sterilization Package with Indicators do not come into contact with patients. The enclosed archwires met the USP and ISO 10993-5 requirements for the test. All test samples PASSED.

8

Image /page/8/Picture/0 description: The image shows the logo for American Orthodontics. The logo consists of the letters "AO" in a stylized font, followed by the words "AMERICAN ORTHODONTICS" in a sans-serif font. The letters and words are all in a dark blue color. The logo is simple and modern, and it is likely used to represent the company's brand.

www.americanortho.com

1 800 558 7687 +1 920 457 5051 office +1 920 457 1485 fax

Page 5-6

BIOCOMPATIBILITY - (ENCLOSED ARCHWIRES)

Archwires were sent to independent labs for biocompatibility testing before sterilization according to ISO 10993-5:2009, Biological Evaluation of Medical Devices – Part 5: Tests for In Vitro Cytotoxicity and ISO 10993-10, Tests for Irritation and Sensitization - Sensitization Test. All test samples PASSED.

Biocompatibility Justification for stainless steel archwires is included in Section 15: Biocompatibility.

Summary:

The Wire Sterilization Package with Indicators is provided as a convenient and purely optional method for the trained dental professional and/or Orthodontist to sterilize American Orthodontics' arch wires. This does not affect the function of the enclosed arch wires, nor does it affect the original purpose of the package – which is to store and ship individual arch wires.

Conclusion:

American Orthodontics' Wire Sterilization Package with Indicators has the following similarities to those legally marketed under 510(k) numbers K112591 (Primary Predicate) and K951113 (Secondary Predicate):

  • . Same intended use; and
  • Same technological characteristics through device design, indicator agent, sterilization . method and incorporation of similar materials.

Generated testing data in accordance to "ANSI/AAMI/ISO 11140-1:2014 Sterilization of health care products – Chemical indicators" demonstrates that the indicators on American Orthodontics' Wire Sterilization Package with Indicators are substantially equivalent to the predicate devices.

Any slight differences do not affect the original function or intended purpose of the device.

Information contained in this 510(k) does not raise new questions or safety and effectiveness, and, demonstrates it is at least as safe and effective as the listed predicates.