Predicate Devices

Reference Devices

AI/ML (Artificial Intelligence / Machine Learning)

No
The device description and performance studies focus on the chemical composition and physical properties of a dental varnish, with no mention of AI or ML technologies.

Therapeutic

Yes
Explanation: The device is intended for "Treating hypersensitive teeth" and "Treating exposed dentin and root sensitivity," which involve a therapeutic effect on a medical condition.

Diagnostic

No

The device is a coating for treating hypersensitive teeth and exposed dentin, not for diagnosing conditions.

SaMD (Software as a Medical Device)

No

The device description clearly states it is a "fluoride, calcium and phosphate containing coating" and an "alcohol/water-based solution of dental polymer resins," indicating it is a physical substance applied to teeth, not software.

IVD (In Vitro Diagnostic)

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

Here's why:

Intended Use: The intended use is for treating hypersensitive teeth and exposed dentin and root sensitivity. This is a therapeutic application, not a diagnostic one.
Device Description: The description details a coating applied to teeth to provide fluoride, calcium, and phosphate. This is a physical/chemical treatment, not a test performed on a sample from the body to diagnose a condition.
Performance Studies: The performance studies focus on properties like dentin tubule penetration and in vitro release of substances, which are relevant to the device's therapeutic function, not its diagnostic accuracy.

IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. Clinpro™ Varnish does not fit this definition.

PCCP (Predetermined Change Control Plan) Authorized

N/A

Overview

Intended Use / Indications for Use

Clinpro™ Varnish is a fluoride, calcium and phosphate containing coating for use in:

Treating hypersensitive teeth
Treating exposed dentin and root sensitivity

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

LBH

Device Description

Clinpro™ Varnish is a fluoride, calcium and phosphate containing coating for use in treating hypersensitive teeth and exposed dentin and root sensitivity. Clinpro™ Varnish is moisture and saliva-activated when applied to enamel and dentin. It will spread on and adhere to moist teeth. Clinpro™ Varnish is an alcohol/water-based solution of dental polymer resins. The product is sweetened with xylitol and sucralose. Clinpro™ Varnish contains two fluoride sources, 3% sodium fluoride and 3% strontium fluoride (equivalent to 2.26% fluoride ion). Clinpro™ Varnish provides both an initial release in the first hour and a continued release during the next 24 hours. Clinpro™ Varnish also contains sources of calcium and phosphate, including functionalized tri-calcium phosphate exclusively from 3M ESPE. Clinpro™ Varnish is supplied in unit-dose packages containing 0.50 ml of varnish coating. Each 0.50 ml of Clinpro™ Varnish contains 13.8 mg sodium fluoride and 13.8 mg strontium fluoride, equivalent to 10.4 mg total fluoride ion.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Teeth, dentin, root

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)

In vitro testing was conducted with Clinpro™ Varnish and the predicate devices, Vanish™ 5% Sodium Fluoride White Varnish, Pulpdent® Active Varnish and Duraphat® 5% Sodium Fluoride Varnish. Properties evaluated include dentin tubule penetration and in vitro fluoride, calcium and phosphate release. SEM and optical images show that the devices form a thin film penetrating dentin tubules. In vitro fluoride release testing shows that Clinpro™ Varnish provides both an initial release in the first hour and a continued release during the next 24 hours. Clinpro™ Varnish utilizes a resin polymer coating technology to incorporate the additional sources of fluoride, calcium and phosphate as compared to the predicate devices that utilize a rosin polymer coating.

All varnishes function as film forming materials that block dentin tubules for use in treating dental hypersensitivity. Clinpro™ Varnish and Varnish™ Varnish are indicated for use on exposed dentin and root sensitivity for treating dental hypersensitivity as well.

Stability testing was conducted by evaluating the physical properties of the device at various storage conditions to confirm a shelf life at room temperature of 24 months. Biocompatibility testing for the device included cytotoxicity, sensitization, irritation/ intracutaneous reactivity and acute systemic toxicity.

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.

K093620, K112946, 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

Regulation Number and Section

§ 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.

Summary

0

Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" written around it. Inside the circle is a stylized image of three human profiles facing to the right, stacked on top of each other.

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

September 18, 2015

3M Company Shari Myszka, R.Ph., Pharm.D. Regulatory Affairs Specialist 2510 Conway Avenue St. Paul, Minnesota 55144-1000

Re: K151302

Trade/Device Name: Clinpro™ Varnish Regulation Number: 21 CFR 872.3260 Regulation Name: Cavity Varnish Regulatory Class: II Product Code: LBH Dated: August 10, 2015 Received: August 12, 2015

Dear Dr. Myszka:

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

Page 2 - Shari Myszka, R.Ph., Pharm.D.

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 Industry and Consumer Education 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. 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 Industry and Consumer Education 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,

Tina
Kiang -S

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 Statement 4.

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K151302

Device Name Clinpro™ Varnish

Indications for Use (Describe)

Clinpro IM Varnish is a fluoride, calcium and phosphate containing coating for use in:

· Treating hypersensitive teeth

· Treating exposed dentin and root sensitivity

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.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

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

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"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."

FORM FDA 3881 (8/14)

Page 1 of 1

POC Publishing Services (101)-443-6740 HF

3

3M ES

3. 510(k) Summary

3M ESPE Dental

2510 Conway Avenue St. Paul, MN 55144-1000

Image /page/3/Picture/4 description: The image shows the 3M logo. The logo consists of the number '3' and the letter 'M' in a bold, sans-serif font. The color of the logo is red. The background is white.

510(k) Summary

This summary of 510(k) summary is submitted in accordance with the requirements of 21 CFR 807.92.

| 510(k) Submitter | 3M ESPE Dental
2510 Conway Avenue
St. Paul, MN 55144-1000 USA |
|----------------------|--------------------------------------------------------------------------------------------------------------------------------------|
| Contact | Shari L. Myszka, R.Ph., Pharm.D
Regulatory Affairs Specialist
Phone: (651) 736-6955
Fax: (651) 737-9665
slmyszka@mmm.com |
| Submission Date | May 13, 2015 |
| Device Name | Clinpro™ Varnish |
| Classification Name | Cavity Varnish |
| Regulation Number | 21 CFR 872.3260 |
| Product Code | LBH |
| Classification Panel | Dental |
| Classification | Medical Device, Class II |

Device 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.

Indications for Use: Clinpro™ Varnish is a fluoride, calcium and phosphate containing coating for use in:

. Treating hypersensitive teeth
. Treating exposed dentin and root sensitivity

Predicate Devices:

Vanish™ 5% Sodium Fluoride White Varnish (K092141) Pulpdent® Fluoride Varnish (K093620) Pulpdent® Activ Varnish (K112946) Duraphat® 5% Sodium Fluoride Varnish (K945794)

4

3M ESPE

Description of Device:

Clinpro™ Varnish is a fluoride, calcium and phosphate containing coating for use in treating hypersensitive teeth and exposed dentin and root sensitivity. Clinpro™ Varnish is moisture and saliva-activated when applied to enamel and dentin. It will spread on and adhere to moist teeth. Clinpro™ Varnish is an alcohol/water-based solution of dental polymer resins. The product is sweetened with xylitol and sucralose. Clinpro™ Varnish contains two fluoride sources, 3% sodium fluoride and 3% strontium fluoride (equivalent to 2.26% fluoride ion). Clinpro™ Varnish provides both an initial release in the first hour and a continued release during the next 24 hours. Clinpro™ Varnish also contains sources of calcium and phosphate, including functionalized tri-calcium phosphate exclusively from 3M ESPE. Clinpro™ Varnish is supplied in unit-dose packages containing 0.50 ml of varnish coating. Each 0.50 ml of Clinpro™ Varnish contains 13.8 mg sodium fluoride and 13.8 mg strontium fluoride, equivalent to 10.4 mg total fluoride ion.

Technological Characteristics:

The basic composition, fundamental technology and intended use of Clinpro™ Varnish are substantially equivalent to the predicate devices. Clinpro™ Varnish is a fluoride, calcium and phosphate containing coating to provide immediate and sustained relief of dental pain or hypersensitivity. The immediate relief of hypersensitivity is achieved by the hardened resin film that forms immediately after application and occludes the dentin tubules. Clinpro™ Varnish is unique formulation that utilizes novel resin polymer coating technology to incorporate the additional sources of fluoride, calcium and phosphate. In vitro fluoride release testing shows that Clinpro™ Varnish provides both an initial release in the first hour and a continued release during the next 24 hours.

The table below summarizes the basic composition, fundamental technology and intended use of Clinpro™ Varnish and the predicate varnishes:

5

Vanish™	Pulpdent®	Pulpdent®	Duraphat®	Clinpro™
5% Sodium
Fluoride
White Varnish	Fluoride
Varnish	Activ
Varnish	5% Sodium
Fluoride
Varnish	Varnish
Primary
Predicate	Reference
Predicate	Reference
Predicate	Reference
Predicate	Subject
Device
K092141	K093620	K112946	K945794	K151302
Basic Composition
Rosin Varnish	Rosin Varnish	Rosin Varnish	Rosin Varnish	Polymer Resin
Varnish*
Fundamental Technology
Dentin Tubule
Occlusion	Dentin Tubule
Occlusion	Dentin Tubule
Occlusion	Dentin Tubule
Occlusion	Dentin Tubule
Occlusion
Indication for Use
Treatment of
Hypersensitive
Teeth and
Exposed Dentin
and Root
Sensitivity	Treatment of
Dental
Hypersensitivity	Treatment of
Dental
Hypersensitivity	Treatment of
Dental
Hypersensitivity	Treatment of
Hypersensitive
Teeth and
Exposed Dentin
and Root
Sensitivity

The polymer resin varnish and the predicate rosin varnishes are film forming materials that block dentin tubules and act as carriers for the fluoride, calcium and phosphate. The synthetic polymer resin was selected due to its lower variability in composition and properties as compared to the naturally-sourced rosins and is substantially equivalent in performance to the rosin varnishes.

Performance Data:

In vitro testing was conducted with Clinpro™ Varnish and the predicate devices, Vanish™ 5% Sodium Fluoride White Varnish, Pulpdent® Active Varnish and Duraphat® 5% Sodium Fluoride Varnish. Properties evaluated include dentin tubule penetration and in vitro fluoride, calcium and phosphate release. SEM and optical images show that the devices form a thin film penetrating dentin tubules. In vitro fluoride release testing shows that Clinpro™ Varnish provides both an initial release in the first hour and a continued release during the next 24 hours. Clinpro™ Varnish utilizes a resin polymer coating technology to incorporate the additional sources of fluoride, calcium and phosphate as compared to the predicate devices that utilize a rosin polymer coating.

All varnishes function as film forming materials that block dentin tubules for use in treating dental hypersensitivity. Clinpro™ Varnish and Varnish™ Varnish are indicated for use on exposed dentin and root sensitivity for treating dental hypersensitivity as well.

Stability testing was conducted by evaluating the physical properties of the device at various storage conditions to confirm a shelf life at room temperature of 24 months. Biocompatibility testing for the device included cytotoxicity, sensitization, irritation/ intracutaneous reactivity and acute systemic toxicity.

6

3M ESPI

Performance Standards:

Clinpro™ Varnish complies with the following ISO standards:

· ISO 14971:2007, Medical Devices - Application of Risk Management to Medical Devices

• ISO 10993-1:2009, Biological Evaluation of Medical Devices – Part 1:

Evaluation and Testing Within a Risk Management Process

· ISO 10993-3:2009, Biological Evaluation of Medical Devices - Part 3: Tests for Genotoxicity and Reproductive Toxicity

· ISO 10993-5:2009, Biological Evaluation of Medical Devices - Part 5: Tests for In Vitro Cytotoxicity

· ISO 10993-10:2010, Biological Evaluation of Medical Devices - Part 10: Tests for Irritation and Skin Sensitization

· ISO 10993-11:2006, Biological Evaluation of Medical Devices - Part 11: Tests for Systemic Toxicity

• ISO 10993-12:2012, Biological Evaluation of Medical Devices – Part 12: Sample Preparation and Reference Materials

• ISO 7405:2008, Dentistry – Evaluation of Biocompatibility of Medical Devices Used in Dentistry

Substantial Equivalence Statement:

Results of the nonclinical and clinical testing demonstrate that Clinpro™ Varnish is substantially equivalent to the legally marketed predicate devices in terms of intended use, indications for use, basic composition, fundamental technology, delivery presentation, directions for use, physical properties and biocompatibility.