(244 days)
Rodo Abutment System is intended to be used in conjunction with compatible implant systems in the maxillary or mandibular arch to provide support for crowns, bridges or overdentures.
The Rodo Abutment System includes the Rodo Abutment, Smileloc Sleeve, Silicone Seal, Titanium Coping, Temporary Cap, abutment screws, and Smileloc Activator (or Smileloc Remover). The Smileloc Sleeve is used to lock and unlock the Titanium Coping for final restoration to or from the abutment. This makes the prosthesis removable.
Rodo Abutment is provided in five series designs (100 F. 200 P. 300 S. 400 M. 500 D) with the 200 P and 500 D series having angled abutments (17°, 30°), for a total of nine designs. The 200 P and 500 D series are designed for multi-unit restorations only, the 300 S series is designed for limited occlusal space, and the 400 M series is designed for large interproximal spaces. Abutments are available in sizes ranging from 0 3.0 mm depending on the compatible implant system in use. Designs are available with engaging and non-engaging implant-abutment interfaces.
The provided document is a 510(k) summary for the Rodo Abutment System, a dental device. It outlines the device's indications for use, its classification, and a comparison to predicate devices, but does not contain information about acceptance criteria or a study designed to prove the device meets specific performance criteria in terms of algorithm-based metrics (like sensitivity, specificity, or AUC) as would be typical for an AI/ML device.
The closest information available that might relate to "acceptance criteria" for a medical device (not specifically an AI/ML device) typically involves demonstrating substantial equivalence to a legally marketed predicate device through various tests and comparisons.
Here's an analysis based on the provided document, addressing the requested points:
1. Table of Acceptance Criteria and Reported Device Performance
As this is a 510(k) submission for a physical dental abutment system and not an AI/ML device, there are no specific performance metrics like sensitivity, specificity, or accuracy mentioned as "acceptance criteria" for an algorithm. Instead, the "performance" is demonstrated through various non-clinical and clinical tests to show safety and effectiveness and substantial equivalence to predicate devices.
| Acceptance Criteria (Implied by Substantial Equivalence and Testing) | Reported Device Performance (from "Performance Data" & "Clinical Data" sections) |
|---|---|
| Sterility (SAL 10⁻⁶) | Validated according to ISO 17665-1 and ISO 17665-2, demonstrating a sterility assurance level (SAL) of 10⁻⁶. |
| Biocompatibility (Cytotoxicity, Sensitization, Irritation) | Tested according to ISO 10993-5 (cytotoxicity) and ISO 10993-10 (sensitization and irritation), demonstrating acceptable biocompatibility. |
| Electrical Safety (if applicable - though less relevant for an abutment) | Electrical safety analysis according to AAMI / ANSI ES60601-1:2005/(R) 2012 and related IEC standards, demonstrating acceptable electrical safety (though the relevance for a non-powered dental abutment is minimal, it was part of the submission). |
| Thermal Properties | Tested according to ASTM F2004, showing acceptable transition temperatures. |
| Corrosion Resistance | Tested according to ASTM G71 and ASTM F2129, and nickel leaching evaluation, showing acceptable corrosion resistance. |
| Retention Strength | Retention testing, showing acceptable retention strength. |
| Compatibility with OEM Implants | Reverse engineering and dimensional analysis of OEM devices, showing that the Rodo Abutment is compatible with corresponding OEM implants. |
| Mechanical Performance / Dynamic Compression-Bending | Dynamic compression-bending testing according to ISO 14801, showing mechanical performance sufficient for its intended use. |
| Clinical Safety & Effectiveness (for intended use) | A prospective multi-center clinical trial demonstrating safety and effectiveness. Overall conclusion: "Rodo Abutment System provides an appropriate method of attaching prosthetic restorations to dental implant abutments. If necessary, it allows repeated removal of the restoration, as is the case for screw-retained restorations on dental implant abutments." |
| Substantial Equivalence in Indications for Use | "The subject device is substantially equivalent in indications and design principles to the predicate devices shown above." Minor differences in Indications for Use language between the systems do not change the intended use. |
| Substantial Equivalence in Design/Technology | Similar technological characteristics, similar materials, similar range of physical dimensions (diameter, gingival height, angle), similar packaging and sterilization methods compared to predicate devices. |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size (Clinical Trial): 34 subjects were enrolled, 32 subjects received Rodo Abutments and restorations. Out of these, 3 subjects received 4 abutments each as part of full arch treatment, resulting in a total of 41 Rodo Abutments placed and restored.
- Data Provenance: The document states, "A prospective multi-center clinical trial... was conducted under an Investigational Device Exemption study according to FDA guidelines." This indicates it's prospective data. The document does not explicitly state the country of origin, but given the FDA submission context, it's presumed to be a US-based study or at least data acceptable for US regulatory purposes.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not provided in the document. For a physical device like a dental abutment, "ground truth" might refer to clinical outcomes assessed by trained dental professionals, but the study description does not detail the number or qualifications of experts involved in assessing device performance or generating the "ground truth" of safety and effectiveness outcomes beyond the medical staff conducting the trial.
4. Adjudication Method for the Test Set
This information is not provided in the document. Adjudication methods (like 2+1 or 3+1) are typically relevant for studies where multiple readers interpret data and discrepancies need to be resolved, which is common in imaging studies for AI/ML devices. For a clinical trial of a physical implant, such a method for "test set" adjudication is not typically described in this manner.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size
No, an MRMC comparative effectiveness study was not done. This type of study is specific to evaluating diagnostic performance, often of AI/ML systems or diagnostic tests, comparing multiple readers' interpretations of cases. The Rodo Abutment System is a physical dental device.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
No, a standalone algorithm performance study was not done. The Rodo Abutment System is a physical dental device, not an algorithm or AI system.
7. The Type of Ground Truth Used
For the clinical study, the "ground truth" for evaluating the Rodo Abutment System's safety and effectiveness was based on clinical outcomes data from human subjects who received the device. This included:
- Observation of adverse events (e.g., abutment screw loosening, crown separation, non-device related events).
- The overall clinical assessment that the system "provides an appropriate method of attaching prosthetic restorations to dental implant abutments" and "if necessary, it allows repeated removal of the restoration."
For non-clinical tests, the "ground truth" was based on engineering standards and direct measurement/testing results (e.g., SAL for sterility, acceptable ranges for biocompatibility, mechanical strength, corrosion resistance).
8. The Sample Size for the Training Set
This product is a physical medical device, not an AI/ML algorithm. Therefore, there is no "training set" in the context of machine learning. The clinical and non-clinical data collected serve as validation for the device's design and manufacturing rather than training an algorithm.
9. How the Ground Truth for the Training Set Was Established
As there is no training set for an AI/ML algorithm, this question is not applicable.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
November 21, 2016
Rodo Medical, Inc. c/o Ms. Linda Schulz Regulatory Affairs PaxMed International, LLC 12264 El Camino Real Suite 400 San Diego, California 92130
Re: K160786
Trade/Device Name: Rodo Abutment System Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: October 21, 2016 Received: October 24, 2016
Dear Ms. Linda Schulz:
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 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
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the quality systems (OS) 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/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 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.
Michael J. Ryan -S
for Tina Kiang, Ph.D. Acting 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 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)
K160786
Device Name
Rodo Abutment System
Indications for Use (Describe)
Rodo Abutment System is intended to be used in conjunction with compatible implant systems in the maxillary or mandibular arch to provide support for crowns, bridges or overdentures.
| Implant Line | OEM Platform Size | OEM Body Size |
|---|---|---|
| Straumann Bone Level | NC, RC | 3.3, 4.1, 4.8 |
| Neodent Drive CM | 3.5, 4.3, 5.0 | 3.5, 4.3, 5.0 |
| Neodent Titamax CM | 3.5, 3.75, 4.0, 5.0 | 3.5, 3.75, 4.0, 5.0 |
| Neodent Alvim CM | 3.5, 4.3, 5.0 | 3.5, 4.3, 5.0 |
| NobelActive | 3.0, NP, RP, WP | 3.0, 3.5, 4.3, 5.0, 5.5 |
| Nobel Replace Conical | NP, RP | 3.5, 4.3, 5.0 |
| NobelReplace Straight | NP, RP, WP | 3.5, 4.0, 5.0 |
| NobelReplace Tapered | NP, RP, WP, 6.0 | 3.5, 4.3, 5.0, 6.0 |
| NobelSpeedy Replace | NP, RP, WP, 6.0 | 3.5, 4.0, 5.0, 6.0 |
Compatible Systems
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary Rodo Medical, Inc. Rodo Abutment System K160786
November 21, 2016
ADMINISTRATIVE INFORMATION
| Manufacturer Name | Rodo Medical, Inc. |
|---|---|
| 690 Saratoga Ave., Suite 100 | |
| San Jose, CA 95129 | |
| Telephone: +1 (408) 245-7636 | |
| Fax: +1 (408) 338-6940 | |
| Official Contact | Michael Parsons |
| Executive Vice President | |
| Representative/Consultant | Linda K. Schulz, BSDH, RDH |
| Kevin A. Thomas, PhD | |
| PaxMed International, LLC | |
| 12264 El Camino Real, Suite 400 | |
| San Diego, CA 92130 | |
| Telephone: +1 (858) 792-1235 | |
| Fax: +1 (858) 792-1236 | |
| Email: lschulz@paxmed.com | |
| kthomas@paxmed.com |
DEVICE NAME AND CLASSIFICATION
| Trade/Proprietary Name | Rodo Abutment System |
|---|---|
| Common Name | Endosseous dental implant abutment |
| Classification Name | Endosseous dental implant abutment |
| Classification Regulations | 21 CFR 872.3630, Class II |
| Product Code | NHA |
| Classification Panel | Dental Products Panel |
| Reviewing Branch | Dental Devices Branch |
PREDICATE DEVICE INFORMATION
Primary Predicate K120414, OsseoSpeed™ Plus, Astra Tech AB
Reference Predicates Abutment Design K092341, Low Profile Abutment, Biomet 3i
Compatibility
K062129, P.004 Implants, Institut Straumann AG K101945, Neodent Implant System, JJGC Indústria e Comércio de Materiais Dentários SA K 123022, Neodent Implant System, JJGC Indústria e Comércio de Materiais Dentários SA K142260, NobelActive®, Nobel Biocare AB
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K073142, NobelReplace Hexagonal Implants, Nobel Biocare AB K050705, TiUnite® Implants, Nobel Biocare USA LLC K050406, NOBELSPEEDY® Implants, Nobel Biocare AB K142118. Inclusive® Titanium Abutments compatible with: Straumann Bone Level, Nobel Biocare Branemark, and Nobel Biocare NobelActive Implants, Prismatik Dentalcraft, Inc.
INDICATIONS FOR USE
Rodo Abutment System is intended to be used in conjunction with compatible implant systems in the maxillary or mandibular arch to provide support for crowns, bridges or overdentures.
| Implant Line | OEM Platform Size | OEM Body Size |
|---|---|---|
| Straumann Bone Level | NC, RC | 3.3, 4.1, 4.8 |
| Neodent Drive CM | 3.5, 4.3, 5.0 | 3.5, 4.3, 5.0 |
| Neodent Titamax CM | 3.5, 3.75, 4.0, 5.0 | 3.5, 3.75, 4.0, 5.0 |
| Neodent Alvim CM | 3.5, 4.3, 5.0 | 3.5, 4.3, 5.0 |
| NobelActive | 3.0, NP, RP, WP | 3.0, 3.5, 4.3, 5.0, 5.5 |
| Nobel Replace Conical | NP, RP | 3.5, 4.3, 5.0 |
| NobelReplace Straight | NP, RP, WP | 3.5, 4.0, 5.0 |
| NobelReplace Tapered | NP, RP, WP, 6.0 | 3.5, 4.3, 5.0, 6.0 |
| NobelSpeedy Replace | NP, RP, WP, 6.0 | 3.5, 4.0, 5.0, 6.0 |
Compatible Systems
DEVICE DESCRIPTION
The Rodo Abutment System includes the Rodo Abutment, Smileloc Sleeve, Silicone Seal, Titanium Coping, Temporary Cap, abutment screws, and Smileloc Activator (or Smileloc Remover). The Smileloc Sleeve is used to lock and unlock the Titanium Coping for final restoration to or from the abutment. This makes the prosthesis removable.
Rodo Abutment is provided in five series designs (100 F. 200 P. 300 S. 400 M. 500 D) with the 200 P and 500 D series having angled abutments (17°, 30°), for a total of nine designs. The 200 P and 500 D series are designed for multi-unit restorations only, the 300 S series is designed for limited occlusal space, and the 400 M series is designed for large interproximal spaces. Abutments are available in sizes ranging from 0 3.0 mm depending on the compatible implant system in use. Designs are available with engaging and non-engaging implant-abutment interfaces.
PERFORMANCE DATA
Non-clinical testing data submitted or relied upon to demonstrate substantial equivalence included: steam sterilization validation according to ISO 17665-1 and ISO 17665-2, demonstrating a sterility assurance level (SAL) of 10°; biocompatibility testing according to ISO 10993-5 (cytotoxicity) and ISO 10993-10 (sensitization and irritation). demonstrating acceptable biocompatibility; electrical safety analysis according to AAMI / ANSI ES60601-1:2005/(R) 2012 and A1:2012, c1:2009/(R) 2012 and a2:2010/(r) 2012, IEC 60601-1-2 and IEC 62366 and risk analysis according to ISO 14971, demonstrating acceptable electrical safety; thermal properties testing according to ASTM F2004, showing acceptable transition temperatures; corrosion testing according to ASTM G71 and ASTM F2129 and nickel leaching evaluation, showing acceptable corrosion resistance; retention testing, showing acceptable retention strength; reverse engineering and dimensional analysis of OEM devices, showing that the Rodo Abutnent is compatible with corresponding OEM implants; and dynamic compression-bending testing according to ISO 14801, showing mechanical performance sufficient for its intended use.
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CLINICAL DATA
A prospective multi-center clinical trial, designed to evaluate the safety and effectiveness of the Rodo Abutment System for dental implants, was conducted under an Investigational Device Exemption study according to FDA guidelines. The Rodo Abutment System was used with corresponding compatible implant systems. A total of thirtyfour (34) subjects (17 male, 17 female), with previously implants ready for restoration, were enrolled at two study centers. Thirty-two subjects received Rodo Abutments and restorations. Three of these subjects each received four Rodo abutments as part of their full arch, immediate load treatment. In total, 41 Rodo Abutments were placed and restored.
Of the nine adverse events recorded over the duration of the study, two were abutment screw loosening (resolved by re-tightening the screw), one was separation of the crown from the coping due to inadequate bonding in the laboratory (resolved by re-bonding in the laboratory), and the remaining six events were not device related. No adverse events were related to the Smileloc sleeve or attachment of the prosthesis to the abutment.
The overall conclusion from the study was that the Rodo Abutment System provides an appropriate method of attaching prosthetic restorations to dental implant abutments. If necessary, it allows repeated removal of the restoration, as is the case for screw-retained restorations on dental implant abutments.
EQUIVALENCE TO MARKETED DEVICE
The subject device is substantially equivalent in indications and design principles to the predicate devices shown above.
Rodo Abutment System is substantially equivalent to the OsseoSpeed Plus implant system (K120414) and Low Profile Abutment (K092341). Rodo Abutment System has two coping designs for Smileloc-retained (Smileloc Sleeve) prostheses while OsseoSpeed Plus (K1204140 has three different coping types for the fabrication of screwretained prostheses (prosthetic screw). Both prosthetic coping systems are for single or multi-unit restorations that are removable. Rodo Abutment System and Low Profile Abutment (K092341) are available with 17° and 30° angled abutments.
Rodo Abutment System abutments range in size from Ø 3.0 mm. OsseoSpeed Plus Abutments range in size from Ø 3.0 mm to Ø 5.4 mm. Low Profile Abutments range in size from Ø 3.0 mm.
The Indications for Use for the Rodo Abutment System are substantially equivalent to those of OsseoSpeed Plus and Low Profile Abutment. Minor differences in Indications for Use language between the systems do not change the intended use of support for prostheses in the maxillary or mandibular arch.
Below is a summary table comparing the Indications for Use and the technological characteristics of the subject device and the predicate devices.
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510(k) Summary
Page 4 of 5
Table of Substantial Equivalence
| Subject Device | Primary Predicate | Reference Predicate | Reference Predicate | |
|---|---|---|---|---|
| Rodo Medical, Inc.Rodo Abutment System | Astra Tech ABOsseoSpeed™ Plus | Biomet 3iLow Profile Abutment | Prismatik Dentalcraft, Inc.,Inclusive® TitaniumAbutments compatible with:Straumann Bone Level, NobelBiocare Branemark, and NobelBiocare NobelActive Implants | |
| K160786 | K120414 | K092341 | K142118 | |
| Indicationsfor Use | Rodo Abutment System is intended to be used in conjunctionwith compatible implant systems in the maxillary ormandibular arch to provide support for crowns, bridges oroverdentures. | Implants:The Astra Tech Dental Implants are intended for bothone- and two-stage surgical procedures in thefollowing situations and with the following clinicalprotocols: | BIOMET 3i Low ProfileAbutments are intended foruse as accessories toendosseous dental implantsto support a prostheticdevice in a partially orcompletely edentulouspatient. A dental abutment isintended for use to supportsingle and multiple toothprosthesis, in the mandibleor maxilla. The prosthesis isscrew retained to theabutment. | Inclusive® Titanium Abutmentsare premanufactured prostheticcomponents directly connected toendosseous dental implants andare intended for use as an aid inprosthetic rehabilitation.Inclusive® Titanium Abutmentsare compatible with:- Straumann: Bone Level NC andRC implant sizes- Nobel Biocare: Branemark RPsize implant- Nobel Biocare NobelActive NPand RP internal connectionimplants |
| Compatible Systems | · replacing single and multiple missing teeth in themandible and maxilla,· immediate placement in extraction sites and insituations with a partially or completely healedalveolar ridge,· especially indicated for use in soft bone applicationswhere implants with other implant surface treatmentsmay be less effective,· immediate loading in all indications, except insingle tooth situations on implants shorter than 8 mmor in soft bone (type IV) where implant stability maybe difficult to obtain and immediate loading may notbe appropriate. | |||
| Implant Line | ||||
| OEM PlatformSize | ||||
| OEM Body Size | ||||
| Straumann Bone Level | NC, RC | 3.3, 4.1, 4.8 | ||
| Neodent Drive CM | 3.5, 4.3, 5.0 | 3.5, 4.3, 5.0 | ||
| Neodent Titamax CM | 3.5, 3.75, 4.0, 5.0 | 3.5, 3.75, 4.0, 5.0 | ||
| Neodent Alvim CM | 3.5, 4.3, 5.0 | 3.5, 4.3, 5.0 | ||
| NobelActive | 3.0, NP, RP, WP | 3.0, 3.5, 4.3, 5.0, 5.5 | ||
| Nobel Replace Conical | NP, RP | 3.5, 4.3, 5.0 | ||
| NobelReplace Straight | NP, RP, WP | 3.5, 4.0, 5.0 | ||
| NobelReplace Tapered | NP, RP, WP, 6.0 | 3.5, 4.3, 5.0, 6.0 | ||
| NobelSpeedy Replace | NP, RP, WP, 6.0 | 3.5, 4.0, 5.0, 6.0 | ||
| The intended use for OsseoSpeed™ Plus 3.0S islimited to replacement of maxillary lateral incisorsand mandibular incisors.Abutments:Astra Tech Implant System Plus abutments areintended to be used in conjunction with Astra TechImplant System Plus in fully edentulous or partiallyedentulous maxillary and/or mandibular arches toprovide support for crowns, bridges or overdentures. | ||||
| Design | ||||
| ProsthesisAttachment | Smileloc Sleeve (Nitinol alloy) | Screw-retained, Cement-retained | Screw Retained | Screw-retained |
| Restoration | Single-unit, Multi-units | Single-unit, Multi-unit | Single-unit, Multi-unit | Single-unit, Multi-unit |
| AbutmentPlatformDiameters | 3.0 mm - 6.0 mm | 3.0 mm - 5.4 mm | 3.4 mm - 5.0 mm | 3.3 - 4.8 mm |
| AbutmentMaterial | Titanium alloy | Titanium alloy | Titanium alloy | Titanium alloy |
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CONCLUSION
The subject device and the predicate devices have intended use, have similar technological characteristics, and are made of similar materials. The subject devices encompass the same range of physical dimensions, including diameter, gingival height, and angle of the abutments. The subject and predicate devices are packaged in similar materials and are to be sterilized using similar methods.
The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.
§ 872.3630 Endosseous dental implant abutment.
(a)
Identification. An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.(b)
Classification. Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)