K Number
K160825
Device Name
MIDWEST RDH Freedom Cordless Prophy System with SmartMode Technology
Manufacturer
Date Cleared
2016-09-27

(186 days)

Product Code
Regulation Number
872.4200
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ is a high-performance cordless prophylaxis handpiece with an optional wireless foot pedal for use with NUPRO Freedom® disposable prophy angles in a hygiene operatory to perform cleaning and polishing procedures on teeth.
Device Description
The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is a cordless handpiece which is intended for use by a dental clinician during dental cleaning and polishing procedures. The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is comprised of an electric motor-driven prophylaxis cordless handpiece (consisting of an inner module and outer sheath), a direct current (DC) powered charging base for cordless handpiece, cradle for cordless handpiece, direct current (DC) power supply and cord, and uses proprietary disposable prophy angles (DPAs). The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, uses a USB mini connector to provide battery charging power to the charging base for the cordless handpiece and operates using Bluetooth low energy (BLE) wireless radio frequency. An optional wireless foot pedal is sold separately.
More Information

No
The summary mentions "SmartMode™ Technology" and performance testing related to it, but there is no mention of AI, ML, or any related concepts like training data, algorithms, or image processing that would indicate the use of AI/ML. The performance testing focuses on functional aspects like speed control, wireless functionality, and safety.

No.
The device is used for cleaning and polishing teeth, which are cosmetic and maintenance procedures, not therapeutic interventions for a disease or condition.

No

The device is described as a cordless prophylaxis handpiece for cleaning and polishing procedures on teeth, which is a therapeutic rather than a diagnostic function.

No

The device description explicitly lists multiple hardware components including a cordless handpiece, charging base, cradle, power supply, and disposable prophy angles. While it mentions "SmartMode™ Technology" and Bluetooth, the core functionality is driven by physical hardware.

Based on the provided text, this device is not an In Vitro Diagnostic (IVD).

Here's why:

  • Intended Use: The intended use is "to perform cleaning and polishing procedures on teeth." This is a direct treatment/procedure performed on the patient's teeth, not a test performed on a sample taken from the body.
  • Device Description: The description details a cordless handpiece, charging base, power supply, and disposable prophy angles. These are all tools used for a physical procedure on the teeth.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting analytes, or providing diagnostic information based on laboratory testing.

The device is clearly intended for a dental procedure performed directly on the patient's teeth, which falls outside the scope of In Vitro Diagnostics.

N/A

Intended Use / Indications for Use

The MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ is a high-performance cordless prophylaxis handpiece with an optional wireless foot pedal for use with NUPRO Freedom® disposable prophy angles in a hygiene operatory to perform cleaning and polishing procedures on teeth.

Product codes

EKX

Device Description

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is a cordless handpiece which is intended for use by a dental clinician during dental cleaning and polishing procedures.

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is comprised of an electric motor-driven prophylaxis cordless handpiece (consisting of an inner module and outer sheath), a direct current (DC) powered charging base for cordless handpiece, cradle for cordless handpiece, direct current (DC) power supply and cord, and uses proprietary disposable prophy angles (DPAs). The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, uses a USB mini connector to provide battery charging power to the charging base for the cordless handpiece and operates using Bluetooth low energy (BLE) wireless radio frequency. An optional wireless foot pedal is sold separately.

Accessories include single use, proprietary NUPRO Freedom® disposable prophy angles [(cleared under premarket notification K030603 in April, 2003 by Pac-Dent International, Inc. as ProAngle™ Disposable Prophy Angle (manufactured by Pac-Dent International, Inc.) and under premarket notification K954802 in November, 1995 by DENTSPLY International as Rite-Angle Disposable Prophy Angles (manufactured by Angstrom Manufacturing, Inc.)] which are sold separately and available in a 90 degree angle and contra angle with multiple cup options: firm cup, soft cup, spiral cup, pedo (pediatric) cup, pointed tip and tapered brush. An optional wireless foot pedal (cleared under premarket notification K110753 in June, 2011 as MIDWEST RDH Freedom Cordless System) is sold separately.

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, must be used with a Disposa-Shield® disposable barrier (cleared as Class II under premarket notification K160232 in June 2016 as Disposa-Shield Disposable Barrier for Midwest RDH Freedom with SmartMode Technology Inner Module), which is sold separately.

An FDA-Cleared lubricant can be used to lubricate the outer sheath nose of the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartModeTM Technology, only if the DPA does not spin freely. A coupler prevents lubricant from contacting the cordless handpiece inner module. If lubricant is applied, the outer sheath must be sterilized prior to use.

The cordless handpiece can be operated in SmartMode™ mode without using the optional wireless foot pedal (K110753). SmartMode™ Technology allows the output speed and torque of the cordless handpiece to be controlled by the amount of force the user applies from the disposable prophylaxis angle (DPA) (K030603; K954802) to the tooth without the use of the optional wireless foot pedal (K110753).

The cordless handpiece can also be operated by using the optional wireless foot pedal (K110753) and the amount of vertical displacement corresponds to the output speed of the cordless handpiece supplied to the DPA (K030603; K954802). The optional wireless foot pedal (K110753) operates using Bluetooth low energy (BLE) communication. Engaging the optional wireless foot pedal (K110753) activates the Bluetooth low energy (BLE) mode of both the cordless handpiece and the optional wireless foot pedal (K110753), and will override the SmartMode™ mode for operation of the cordless handpiece.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

teeth

Indicated Patient Age Range

Not Found

Intended User / Care Setting

dental clinician / hygiene operatory

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)

Performance testing focused on verification of design, prophylaxis cleaning and polishing performance, and safety of the MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology. The tests performed are:

  • TP-566 Bluetooth Compatibility: Verify Foot Pedal can communicate with handpiece at distances of 15 Feet, when exposed to RF interference from other systems. Result: Pass
  • TP-513 SmartMode™ Performance: Verify performance of SmartMode, including ability of the user to override and motor stop features. Result: Pass
  • TP-602 SmartMode Technology Performance with Various Types of DPAs: Verify performance of SmartMode when using different types of DPAs. Result: Pass
  • TP-509 Cordless Handpiece Inner Module Push Button, Battery Indicator, Sleep Mode Functionality: Verify functionality of the Inner Module button and battery indicator and proper functionality of sleep mode. Result: Pass
  • TP-507 Speed Control and Level of Usage on a Single Charge: Verify that the Inner Module capable of performing one day's worth of procedures (10 procedures) on a single charge. Result: Pass
  • TP-506 Speed Torque Performance: Verify that the speed performance of the Inner Module meets specifications when various loads are applied to simulate actual use. Result: Pass
  • TP-515 Outer Sheath Insertion/Extraction Forces: Verify that the force required to insert and extract the Outer Sheath from the Inner Module is acceptable per the design specifications. Result: Pass
  • TP-505 System Component Physical Attributes: Verify that the general size, shape, weight, and center of gravity attributes are acceptable per the design specifications. Result: Pass
  • TP-517 Cordless Handpiece Inner Module Liquids Ingress Test: Verify that fluid does not accumulate in the Inner Module. Result: Pass
  • TP-508 Foot Pedal Performance: To verify foot pedal battery capacity and the ability for it to operate on a fully drained battery when plugged in to the power supply. Result: Pass

Clinical Performance Data: Professional evaluations were conducted by practicing registered dental hygienists on dental typodonts to simulate intended use, users, and use environments. Data gathered supports the assessment that the risk of potential for tissue damage has been adequately mitigated and no unacceptable risks or unacceptable use related hazards related to SmartModeTM Technology were identified.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K110753

Reference Device(s)

K030603, K954802, K160232

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 872.4200 Dental handpiece and accessories.

(a)
Identification. A dental handpiece and accessories is an AC-powered, water-powered, air-powered, or belt-driven, hand-held device that may include a foot controller for regulation of speed and direction of rotation or a contra-angle attachment for difficult to reach areas intended to prepare dental cavities for restorations, such as fillings, and for cleaning teeth.(b)
Classification. Class I.

0

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

September 27, 2016

Dentsply Sirona Helen Lewis Director, Corporate Regulatory Affairs 221 West Philadelphia Street Suite 60 York, Pennsylvania 17404

Re: K160825

Trade/Device Name: MIDWEST® RDH Freedom® Cordless Prophy System With SmartMode™ Technology Regulation Number: 21 CFR 872.4200 Regulation Name: Dental Handpiece And Accessories Regulatory Class: Class I Product Code: EKX Dated: August 29, 2016 Received: August 30, 2016

Dear Helen Lewis:

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 device

1

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/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 D. 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

2

Indications for Use

510(k) Number (if known)

Device Name

MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology

Indications for Use (Describe)

The MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ is a high-performance cordless prophylaxis handpiece with an optional wireless foot pedal for use with NUPRO Freedom® disposable prophy angles in a hygiene operatory to perform cleaning and polishing procedures on teeth.

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)

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3

Dentsply Sirona 221 West Philadelphia Street Suite 60 York, PA 17404

Image /page/3/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized leaf-like shape on the left, followed by the text "Dentsply" on the top line and "Sirona" on the bottom line. The text and the leaf are in a gray color.

510(k) SUMMARY

for

MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology

Submitter Information:

Dentsply Sirona 221 West Philadelphia Street Suite 60 York, PA 17401

Contact Person:Helen Lewis
Telephone Number:717-487-1332
Fax Number:717-849-4343

Date Prepared: 16 September 2016

Device Name:

| • Proprietary Name: | MIDWEST® RDH Freedom® Cordless Prophy
System with SmartMode™ Technology |
|------------------------|----------------------------------------------------------------------------|
| • Classification Name: | Dental Handpiece and Accessories |
| • Common Name: | Prophy System |
| • CFR Number: | 21 CFR 872.4200 |
| • Device Class: | I |
| • Product Code: | EKX |

Predicate Device:

Predicate Device Name510(k)Company Name
MIDWEST® RDH Freedom® Cordless
SystemK110753DENTSPLY International Inc.

Description of Device:

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is a cordless handpiece which is intended for use by a dental clinician during dental cleaning and polishing procedures.

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is comprised of an electric motor-driven prophylaxis cordless handpiece (consisting of an inner module and outer sheath), a direct current (DC) powered charging base for cordless handpiece, cradle for cordless handpiece, direct current (DC) power supply and cord, and uses proprietary disposable prophy angles (DPAs). The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System

4

with SmartMode™ Technology, uses a USB mini connector to provide battery charging power to the charging base for the cordless handpiece and operates using Bluetooth low energy (BLE) wireless radio frequency. An optional wireless foot pedal is sold separately.

Accessories include single use, proprietary NUPRO Freedom® disposable prophy angles [(cleared under premarket notification K030603 in April, 2003 by Pac-Dent International, Inc. as ProAngle™ Disposable Prophy Angle (manufactured by Pac-Dent International, Inc.) and under premarket notification K954802 in November, 1995 by DENTSPLY International as Rite-Angle Disposable Prophy Angles (manufactured by Angstrom Manufacturing, Inc.)] which are sold separately and available in a 90 degree angle and contra angle with multiple cup options: firm cup, soft cup, spiral cup, pedo (pediatric) cup, pointed tip and tapered brush. An optional wireless foot pedal (cleared under premarket notification K110753 in June, 2011 as MIDWEST RDH Freedom Cordless System) is sold separately.

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, must be used with a Disposa-Shield® disposable barrier (cleared as Class II under premarket notification K160232 in June 2016 as Disposa-Shield Disposable Barrier for Midwest RDH Freedom with SmartMode Technology Inner Module), which is sold separately.

An FDA-Cleared lubricant can be used to lubricate the outer sheath nose of the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartModeTM Technology, only if the DPA does not spin freely. A coupler prevents lubricant from contacting the cordless handpiece inner module. If lubricant is applied, the outer sheath must be sterilized prior to use.

The cordless handpiece can be operated in SmartMode™ mode without using the optional wireless foot pedal (K110753). SmartMode™ Technology allows the output speed and torque of the cordless handpiece to be controlled by the amount of force the user applies from the disposable prophylaxis angle (DPA) (K030603; K954802) to the tooth without the use of the optional wireless foot pedal (K110753).

The cordless handpiece can also be operated by using the optional wireless foot pedal (K110753) and the amount of vertical displacement corresponds to the output speed of the cordless handpiece supplied to the DPA (K030603; K954802). The optional wireless foot pedal (K110753) operates using Bluetooth low energy (BLE) communication. Engaging the optional wireless foot pedal (K110753) activates the Bluetooth low energy (BLE) mode of both the cordless handpiece and the optional wireless foot pedal (K110753), and will override the SmartMode™ mode for operation of the cordless handpiece.

Indications for Use:

The Midwest® RDH Freedom® Cordless Prophy System with SmartMode™ Technology is a high-performance cordless prophylaxis handpiece with an optional wireless foot pedal for use with NUPRO Freedom® disposable prophy angles in a hygiene operatory to perform cleaning and polishing procedures on teeth.

5

Identification of Risk Analysis Method

Risk analysis was performed on the MidWest® RDH Freedom® Cordless Prophy System with SmartMode™ Technology utilizing an FMEA process based on ISO 14971:2007 (Corrected 2007-10-01). The results of the risk analysis performed on the MidWest® RDH Freedom® Cordless Prophy System with SmartMode™ Technology concluded that all device design controls and process controls will be able to mitigate known potential failures and effects. In addition, performance testing, electrical safety and electromagnetic compatibility testing were performed to mitigate other potential risks. New biocompatibility testing was not required as the materials, manufacturing methods, and sterilization for the outer sheath are the same as the predicate device, MidWest® RDH Freedom® Cordless System (K110753). An FDA-cleared lubricant can be used to lubricate the outer sheath nose of the proposed device, MIDWEST® RDH Freedom Cordless Prophy System with SmartMode™ Technology, only if the DPA does not spin freely. A coupler prevents lubricant from contacting the cordless handpiece inner module. If lubricant is applied, the outer sheath must be sterilized prior to use.

Substantial Equivalence:
--------------------------
Substantial Equivalence:
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
510(k)K160825K110753N/A
Indications for
UseThe Midwest® RDH
Freedom® Cordless
Prophy System with
SmartMode™ Technology
is a high-performance
cordless prophylaxis
handpiece with an optional
wireless foot pedal for use
with NUPRO Freedom®
disposable prophy angles
in a hygiene operatory to
perform cleaning and
polishing procedures on
teeth.The Midwest® RDH
Freedom™ Cordless
System is a high-
performance cordless
prophylaxis handpiece
with a wireless foot
pedal for use with
Freedom® disposable
prophylaxis angles in a
hygiene operatory to
perform cleaning and
polishing procedures on
teeth.The wireless foot
pedal is an option
rather than a
requirement for
operation of the
cordless handpiece
for the proposed
device. Use of
SmartMode™
provides the same
level of operation
and does not have a
negative effect on
the performance of
the device when
used as labeled.
AccessoriesNUPRO Freedom®
Disposable Prophy Angles
Removable, autoclavable
outer sheathNUPRO Freedom®
Disposable Prophy
Angles
Removable, autoclavable
outer sheathNone
Elimination of
aesthetic color ring
and pins for
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODE™
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
Power supply and cord –
AC/DC wall plug adapterPower supply and cord–
AC/DC wall plug
adaptercordless handpiece
inner module does
not impact
substantial
equivalence.
Cradle for cordless
handpieceCradle for cordless
handpieceNone
Optional wireless foot
pedalRequired wireless foot
pedalUser has the choice
to use the optional
wireless foot pedal
for proposed device
but is required to
use the predicate
device foot pedal.
Material
CompositionOuter Sheath –
Aluminum with
stainless steel tip Cordless Handpiece
Inner Module Housing
– Plastic Charging Base for
Cordless Handpiece
Housing – Plastic Cradle for Cordless
Handpiece – Plastic Foot Pedal Housing –
PlasticOuter Sheath –
Aluminum with
stainless steel tip Cordless Handpiece
Inner Module
Housing - Plastic Charging Base for
Cordless Handpiece
Housing - Plastic Cradle for Cordless
Handpiece - Plastic Foot Pedal Housing -
PlasticNone
Cordless
Handpiece
ControlThe cordless handpiece can
be controlled without a
foot pedal via
SmartMode™ Technology,
or with an optional
wireless foot pedal.The cordless handpiece
is controlled exclusively
by the required wireless
foot pedal.The wireless foot
pedal is an option
rather than a
requirement for
operation of the
cordless handpiece
for the proposed
device. Use of
SmartMode™
provides the same
level of operation.
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOMTM
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
SmartMode™
TechnologyThis device has
SmartMode™ Technology.
The output speed and
torque of the cordless
handpiece are controlled
by the amount of force the
user applies from the DPA
to the tooth, without the
use of the optional wireless
foot pedal.This device does not
have SmartMode™
Technology. The output
speed and torque of the
cordless handpiece are
controlled by the amount
of force applied to the
required wireless foot
pedal.Addition of
SmartMode™
feature allows the
user to conduct
procedures without
use of the wireless
foot pedal, provides
the same level of
operation and does
not have a negative
effect on the
performance of the
device when used
as labeled.
Cordless
Handpiece
Bluetooth
Wireless
Technology
CapabilitiesThe cordless handpiece has
Bluetooth low energy
(BLE) wireless technology
capabilities when used
with the optional wireless
foot pedal.The cordless handpiece
has Zigbee wireless
technology capabilities
when used with the
required wireless foot
pedalSimilar wireless
technology which
results in the same
level of operation.
Cordless
Handpiece
Maximum
Speed;Optional Wireless Foot
Pedal no load
$3400\pm300$ rpmRequired Wireless Foot
Pedal no load
$3300\pm300$ rpmWhen used with the
optional wireless
foot pedal at no
load, the cordless
handpiece of the
proposed device
provides equivalent
speed compared to
the handpiece speed
at no load of the
predicate device
which uses the
required wireless
foot pedal.
Maximum
Torque using
Foot Pedal$9$ mNm maximum load
$3000\pm10%$ rpm$10$ mNm maximum load
$3000\pm10%$ rpm
Cordless
Handpiece
Maximum$9$ mNm maximum load
$3000\pm10%$ rpmSmartMode™
technology is not
offered.Addition of
SmartMode™
technology allows
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
Speed;
Maximum
Torque using
SmartMode™
(without Foot
Pedal)the user to perform
cleaning procedures
without the use of a
wireless foot pedal.
Cordless
Handpiece
InterfaceThe cordless handpiece has
a user pushbutton that
controls mode selection:
SmartMode™ or Foot
Pedal UseThe handpiece has one
user interface: Foot
Pedal Use.Addition of mode
control and ability
to make a selection
on the cordless
handpiece allows
the user to see the
current mode and to
change modes.
Cordless
Handpiece
On/Off SwitchThe cordless handpiece has
a user pushbutton that
controls power on/off.The cordless handpiece
does not have a power
on/off control.The proposed
device has a user
pushbutton on the
cordless handpiece
that controls power
on/off and offers
the user direct
control of the
power status.
Cordless
Handpiece
Power LightThe indicator "on" light is
illuminated when the
power is on.The indicator "on" light
is illuminated when the
power is on.None
Cordless
Handpiece
Visual Status
IndicatorsA range of steady and
blinking LED indicator
lights on the cordless
handpiece display the
handpiece statusA range of steady and
blinking LED indicator
lights on the cordless
handpiece display the
handpiece statusThe increased
number of indicator
colors on the
proposed device
Mode Status:
• Standby = Green
• SmartMode™
Operation = Purple
• Foot Mode Operation =
Blue
• Internal Temperature of
55°C or above =
OrangeMode Status:
• Standby = Green
• Internal Temperature
of 55°C or above =
Orangeprovides more
information to user
regarding mode
status, charging
status, level of
charge,
synchronization
status, and over-
temperature
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOMTM
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
Battery State of Charge:
• Level of Charge =
Green
• Needs to be Charged =
OrangeBattery State of Charge:
• Level of Charge =
Green
• Needs to be Charge =
Orangecondition.
Synchronization Status:
• Ready = Blue
• Success = Green
• Unsuccessful = OrangeSynchronization Status:
• Positioned Properly in
charging base = Green
• Ready = Scrolling
Green and Orange
• Successful = Green
• Unsuccessful =
Orange
Cordless
Handpiece
Visual AlarmCordless handpiece Mode
indicator shows Orange
when internal printed
circuit board (PCB)
temperature is above
normal. Operator should
refrain from using the
handpiece for several
minutes. The light will turn
off when the temperature
returns to normal.Cordless handpiece LED
indicator light shows
Orange when internal
PCB temperature is
above normal. Operator
should refrain from
using the handpiece for
several minutes. The
light will turn off when
the temperature returns
to normal.None
Cordless
Handpiece
PowerThe cordless handpiece can
be turned on and off
manually.The cordless handpiece
does not have an on/off
button. The cordless
handpiece will not
activate when the
required wireless foot
pedal is more than 30
degrees from horizontal.The addition of an
on/off button on the
proposed device
allows the user to
have control over
power status of the
cordless handpiece.
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODE™
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
When not in the charging
base for cordless
handpiece, the cordless
handpiece enters a low
current mode after 1
minute of inactivity. The
cordless handpiece
"wakes-up" when the
On/Off/Mode button on the
cordless handpiece is
depressed or automatically
when it is picked up.When not in the
charging base for
cordless handpiece, the
cordless handpiece will
enter a low current
(sleep) mode 1 within 1
minute of inactivity.
"Wake-up" occurs by
moving the handpiece by
45 degrees in any axis.Actions to initiate
"wake-up" of the
devices differ
slightly but result in
the same operation
and do not affect
substantial
equivalence.
When not in the charging
base for cordless
handpiece, the cordless
handpiece enters a "Sleep"
mode after 24 hours of
inactivity. The cordless
handpiece "wakes-up"
when the On/Off/Mode
button on the cordless
handpiece is depressed, or
when placed in the
charging base for the
cordless handpiece.When not in the
charging base for
cordless handpiece, the
cordless handpiece
enters a lower current
(sleep) mode 2 within a
time period of inactivity
after 7 days but not more
than 14 days of
inactivity. "Wake-up"
occurs by placing the
handpiece on the charger
for 5 seconds to enter
normal operating mode.The proposed
handpiece enters a
lower current state
after 1 day rather
than 7 days for the
predicate. This
permits the battery
saving operation to
initiate more
quickly. Actions to
initiate "wake-up"
of the devices differ
slightly but result in
the same operation
and do not affect
substantial
equivalence.
Cordless
Handpiece
Battery
Recharging
CapabilityThe 3.7 volt Lithium Ion
handpiece battery is
recharged by placing the
cordless handpiece in the
included charging base for
the cordless handpiece.The 3.7 volt Lithium Ion
handpiece battery is
recharged by placing the
cordless handpiece in the
included charging base
for the cordless
handpiece.None
Cordless
Handpiece
Power
ConnectorA 5 volt power supply and
cord provides battery
charging power through a
USB mini connector to the
charging base for theA 5 volt power supply
and cord provides
battery charging power
through a barrel
connector to theThe proposed
device provides
power through a
USB mini
connector rather
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODE™
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
cordless handpiece.charging base for the
cordless handpiece.than a barrel
connector
Handpiece
Battery PowerThe handpiece battery has
sufficient power to
complete a day's worth of
hygiene procedures on a
single charge (average of
10 procedures of an
average 3 minutes each, or
30 minutes total).The handpiece battery
has sufficient power to
complete a day's worth
of hygiene procedures on
a single charge (average
of 10 procedures of an
average 3 minutes each.
or 30 minutes total).None
Handpiece
Battery Quick
ChargeThe handpiece battery
permits the system to have
the capability of
completing one typical 3
minute cleaning procedure
after only fifteen minutes
of charging.The handpiece battery
permits the system to
have the capability of
completing one typical 3
minute cleaning
procedure after only
fifteen minutes of
charging.None
Handpiece
Battery
ReplacementThe handpiece
rechargeable battery can be
replaced by factory
personnel only.The handpiece
rechargeable battery can
be replaced by factory
personnel only.None
Outer SheathIncludes removable,
autoclavable outer sheath
to reduce the risk of patient
cross-contamination.Includes removable,
autoclavable outer
sheath to reduce the risk
of patient cross-
contamination.None
Outer Sheath
SurfaceThe outer sheath includes a
roughened surface for grip.The outer sheath
includes a roughened
surface for grip.None
Outer Sheath
Housing DesignThe outer sheath housing
has an angled cut design
connection to the cap with
an angled termination of
the shot blast grip area.The outer sheath housing
has a swoop cut design
connection to the cap
with a straight
termination of the shot
blast grip area.The angled cut
design of the
proposed device is
an aesthetic choice
and does not affect
substantial
equivalence.
Outer Sheath
Housing
RemovalThe outer sheath housing
does not have an aesthetic
color ring and does not
have pins. The outer sheathThe outer sheath housing
has a rubber aesthetic
color ring to cover press
fit pins that are used forThe proposed
device does not
have the aesthetic
color ring covering
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
is removed by holding the
cap to rotate and slide the
outer sheath up the plastic
ramp of the handpiece
inner module or to pull the
sheath straight.the twist-to-remove
sheath design.press fit pins on the
predicate. The
plastic ramp on the
cordless handpiece
inner module on the
proposed device
serves the same
function as the
press fit pins on the
predicate outer
sheath. Removal of
the press fit pins
eliminates the need
for the aesthetic
color ring, the
requirement for the
user to remove the
color ring from the
outer sheath, and to
sterilize the color
ring and outer
sheath separately
and does not affect
substantial
equivalence.
Elimination of the
color ring and pins
from the outer
sheath of the
proposed device
does not affect
substantial
equivalence.
Foot Pedal
Wireless
Technology
CapabilitiesThe optional wireless foot
pedal has Bluetooth Low
Energy (BLE) wireless
technology capabilities
when used with the
cordless handpiece.The required wireless
foot pedal has Zigbee
wireless technology
capabilities when used
with the cordless
handpiece.Bluetooth wireless
radio frequency
provides the same
operational
capabilities as the
predicate, and does
not affect
substantial
equivalence.
ELEMENTPROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGYPREDICATE
DEVICE:
MIDWEST® RDH
FREEDOM™
CORDLESS SYSTEMDIFFERENCES
WITH
PREDICATE
DEVICE
Foot Pedal
Visual Status
IndicatorsA range of steady and
blinking LED indicator
lights in the optional
wireless foot pedal display
the foot pedal mode status
in 3 different colors:
• Ready to Sync = Blue
• Successful Sync =
Green
• Sync not Successful =
Orange

A range of steady and
blinking LED indicator
lights in the optional
wireless foot pedal display
the foot pedal battery state
of charge in 2 different
colors:
• Charged = Green
• Requires Charging =
Orange | A range of steady and
blinking LED indicator
lights in the required
wireless foot pedal
display the foot pedal
mode status in 2
different colors:
• Ready to Sync =
Orange
• Successful Sync =
Green
• Sync not Successful =
Orange

Battery state of charge is
not shown on the
required wireless foot
pedal, but is shown by
an LED indicator light
on the cordless
handpiece:
• Standby = Green
• Requires Charging =
Orange | Proposed device
optional wireless
foot pedal shows
the foot pedal state
of charge and
synchronization
state. Proposed
device cordless
handpiece does not
display optional
wireless foot pedal
state of charge but
does show
synchronization
state. For the
predicate, the
required wireless
foot pedal state of
charge was shown
on the predicate
handpiece. There is
no negative impact
on substantial
equivalence. The
addition of the
color LED display
provides more
information to user
regarding mode and
charging status. |
| Foot Pedal
Battery | The optional wireless foot
pedal includes a
rechargeable Lithium Ion
(Lithium Cobalt Dioxide)
battery, with a protection
circuit. | The required wireless
foot pedal includes a
rechargeable Lithium
Ion (Lithium Cobalt
Dioxide) battery, with a
protection circuit. | None |
| Foot Pedal
Recharging
Capability | The 3.7 volt Lithium Ion
battery for the optional
wireless foot pedal can be
recharged multiple times
by inclusion of a power
supply and cord. | The 3.7 volt Lithium Ion
battery for the required
wireless foot pedal can
be recharged multiple
times by inclusion of a
power supply and cord. | None |
| ELEMENT | PROPOSED DEVICE:
MIDWEST® RDH
FREEDOM®
CORDLESS PROPHY
SYSTEM WITH
SMARTMODETM
TECHNOLOGY | PREDICATE DEVICE:
MIDWEST® RDH
FREEDOMTM
CORDLESS SYSTEM | DIFFERENCES
WITH
PREDICATE
DEVICE |
| Foot Pedal
Readiness | The optional wireless foot
pedal enters low current
mode after approximately
1 minute of inactivity;
wake-up occurs when the
foot pedal cover is
depressed.

The optional wireless foot
pedal does not offer an
even lower current (sleep)
mode. | The required wireless
foot pedal enters low
current (sleep) mode 1
within 1 minute of
inactivity; wake-up
occurs when the cover is
depressed by
approximately 25%.

The required wireless
foot pedal enters low
current (sleep) mode 2
after 7 days but not more
than 14 days of
inactivity; wake-up
occurs when the cover is
depressed by
approximately 25%. | The optional foot
pedal of the
proposed device
enters battery-
saving mode at the
same point at the
predicate but does
not have a lower
current (sleep)
mode. There is no
impact on
substantial
equivalence. |
| Foot Pedal
Safety
Mechanism | The optional wireless foot
pedal has a power button
situated on the bottom side
of the unit to prevent
accidentally turning on the
foot pedal and does not
require a safety
mechanism. | The required wireless
foot pedal does not have
a power button. If the
required wireless foot
pedal is more than 30
degrees from horizontal,
it will not request that
the cordless handpiece
rotate its motor, even
when pressed. | The presence and
location of a power
button on the
optional wireless
foot pedal offers
the user control of
power being turned
on for the optional
wireless foot pedal. |
| Sheath
Sterilization | Outer sheath steam
sterilizable at 135°C | Outer sheath steam
sterilizable at 135°C | None |
| Material
Compatibility | Biocompatibility meets
requirements | Biocompatibility meets
requirements | None |
| Electromagnetic
Compatibility
and Electrical
Safety | Meets requirements | Meets requirements | None |

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The difference in Indications for Use between the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, and the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753) is that use of the wireless foot pedal (K110753) is optional for the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology.

15

Use of SmartMode™ technology to operate the cordless handpiece meets the same intended use as that of the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753). When activated, SmartMode™ mode operates the cordless handpiece with similar speeds and torques as the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753), and does not affect the substantial equivalenceof the device when used as labeled.

The user has the option to use an optional wireless foot pedal (K110753) with the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, which is similar to the required foot pedal (K110753) of the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753).

The MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™M Technology, and the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753) use the same materials and energy source with essentially the same design.

Non-Clinical Performance Data:

Because the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, and the predicate device. MIDWEST® RDH Freedom® Cordless System (K110753) use the same materials and energy source with essentially the same design, new biocompatibility testing was not required for the outer sheath to support substantial equivalence. Biocompatibility testing was submitted with the predicate device, MIDWEST® RDH Freedom® Cordless System, and cleared under premarket notification K110753 in June, 2011.

An FDA-Cleared lubricant can be used to lubricate the outer sheath nose of the proposed device. MIDWEST® RDH Freedom® Cordless Prophy System with SmartModeTM Technology, only if the DPA does not spin freely. A coupler prevents lubricant from contacting the cordless handpiece inner module. If lubricant is applied, the outer sheath should be sterilized prior to use.

The NUPRO Freedom® disposable prophy angles were previously cleared under premarket notification K030603 in April, 2003 by Pac-Dent International, Inc. as ProAngle™ Disposable Prophy Angle (manufactured by Pac-Dent International, Inc.) and under premarket notification K954802 in November, 1995 by DENTSPLY International as Rite-Angle Disposable Prophy Angles (manufactured by Angstrom Manufacturing. Inc.

An optional wireless foot pedal was cleared under premarket notification K110753 in June, 2011 by DENTSPLY International Inc. as MIDWEST® RDH Freedom® Cordless System.

A Disposa-Shield® disposable barrier was cleared as Class II under premarket notification K160232 in June 2016 as Disposa-Shield Disposable Barrier for Midwest RDH Freedom with SmartMode Technology Inner Module.

16

Comparison of Performance Data/Physical Properties
Physical PropertyTest DescriptionStandardProposed Device
Midwest® RDH
Freedom® Cordless
Prophy System with
SmartMode™M
Technology(K160825)Predicate Device
Midwest® RDH
Freedom® Cordless
System (K110753)
TP-566 Bluetooth
CompatibilityVerify Foot Pedal can
communicate with handpiece
at distances of 15 Feet, when
exposed to RF interference
from other systems.DENTSPLY Professional
Internal Test MethodPass
BluetoothPass
Zigbee
TP-513 SmartMode™
PerformanceVerify performance of
SmartMode, including
ability of the user to override
and motor stop features.DENTSPLY Professional
Internal Test MethodPassN/A *
TP-602 SmartMode
Technology Performance
with Various Types of
DPA'sVerify performance of
SmartMode when using
different types of DPA's.DENTSPLY Professional
Internal Test MethodPassN/A *
TP-509 Cordless Handpiece
Inner Module Push Button,
Battery Indicator, Sleep
Mode FunctionalityVerify functionality of the
Inner Module button and
battery indicator and proper
functionality of sleep mode.DENTSPLY Professional
Internal Test MethodPassN/A **
TP-507 Speed Control and
Level of Usage on a Single
ChargeVerify that the Inner Module
capable of performing one
day's worth of procedures
(10 procedures) on a single
charge.DENTSPLY Professional
Internal Test MethodPassPass
Comparison of Performance Data/Physical Properties
Physical PropertyTest DescriptionStandardProposed Device
Midwest® RDH
Freedom® Cordless
Prophy System with
SmartMode™M
Technology(K160825)Predicate Device
Midwest® RDH
Freedom® Cordless
System (K110753)
TP-506 Speed Torque
PerformanceVerify that the speed
performance of the Inner
Module meets specifications
when various loads are
applied to simulate actual
use.DENTSPLY Professional
Internal Test MethodPassPass
TP-515 Outer Sheath
Insertion/Extraction ForcesVerify that the force required
to insert and extract the
Outer Sheath from the Inner
Module is acceptable per the
design specifications.DENTSPLY Professional
Internal Test MethodPassPass
TP-505 System Component
Physical AttributesVerify that the general size,
shape, weight, and center of
gravity attributes are
acceptable per the design
specifications.DENTSPLY Professional
Internal Test MethodPassPass
TP-517 Cordless Handpiece
Inner Module Liquids
Ingress TestVerify that fluid does not
accumulate in the Inner
Module.DENTSPLY
Professional Internal
Test Method/IECPassPass
TP-508 Foot Pedal
PerformanceTo verify foot pedal battery
capacity and the ability for it to
operate on a fully drained
battery when plugged in to the
power supply.DENTSPLY
Professional Internal
Test MethodPassPass

17

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Performance testing focused on verification of design, prophylaxis cleaning and polishing performance, and safety of the MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology. Below is a list of the standards to which testing was performed:

  • AAMI ANSI ES 60601-1 Medical Electrical Equipment Part 1: General requirements for basic safety and essential performance (2005; reapproved 2012)
  • -IEC 60601-1-2 Medical Electrical Equipment PART 1-2: General Requirements for Basic Safety and Essential Performance Collateral Standard: Electromagnetic Compatibility (2007)
  • FDA Dental Handpieces Premarket Notification [510(k)] Submissions -
  • -FDA - Guidelines for the Content of Premarket Submissions for Software Contained in Medical Devices- Software Validation

The results of these performance tests support the substantial equivalence of the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartModeTM Technology, with the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753).

Clinical Performance Data.

Professional evaluations were conducted considering the proposed device intended use, users, and use environments. All studies were completed by practicing registered dental hygienists on dental typodonts to simulate intended use, users, and use environments.

As a result of multiple professional evaluations with typodonts and clinical human factor validations involving performance testing, data was gathered to support our assessment that the risk of potential for tissue damage has been adequately mitigated and no unacceptable risks or unacceptable use related hazards related to SmartModeTM Technology were identified.

Conclusion Regarding Substantial Equivalence

The proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, is a high-performance cordless prophylaxis handpiece with an optional wireless foot pedal (K110753) for use with proprietary disposable prophy angles (K030603; K954802) which is intended to clean and polish teeth. The MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, has the same intended use, incorporates the same fundamental technology, and has similar indications for use as the predicate, MIDWEST® RDH Freedom® Cordless Prophy System (K110753). MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, uses the same material and energy source, and has essentially the same design as the predicate device. MIDWEST® RDH Freedom® Cordless System (K110753).

Use of SmartMode™ technology to operate the cordless handpiece meets the same intended use as that of the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753). When activated. SmartMode™ drives operation of the cordless handpiece with similar speeds and torques as the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753), and does not affect the device when used as labeled. The user has the option to use an optional wireless foot pedal (K110753) with the

19

proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, which is similar to the required foot pedal (K110753) of the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753).

Test data to verify the performance of the proposed device, MIDWEST® RDH Freedom® Cordless Prophy System with SmartMode™ Technology, have been provided including: wireless functionality; SmartMode™ performance; module and indicator functionality; speed control and level of usage for a single charge; speed, current and torque; cordless handpiece inner module and outer sheath insertion/extraction forces; system physical dimensions and weight; liquids ingress; and foot pedal performance.

The results of this performance testing, combined with the design and intended use comparison with the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753), support substantial equivalence to, the predicate device, MIDWEST® RDH Freedom® Cordless System (K110753).