(114 days)
3Shape Ortho System™ for dental retainers is intended for use as a medical front-end device providing tools for management of orthodontic models, systematic inspection, detailed analysis, treatment simulation and virtual appliance design based on 3D models of the patient's dentition before the start of an orthodontic treatment.
The use of the Ortho System™ requires the user to have the necessary training and domain knowledge in the practice of orthodontics, as well as to have received a dedicated training in the use of the software.
3Shape's Ortho System™ is a software system used for the management of 3D scanned orthodontic models of the patients, orthodontic diagnosis by measuring, analyzinq, inspecting and visualize 3D scanned orthodontic models, virtual planning of orthodontic treatments by simulating tooth movements, virtual placement of orthodontic brackets on the 3D models and design of orthodontic appliances based on 3D scanned orthodontic models. Output includes Dental Retainers. All devices are to be fabricated from FDA cleared or listed materials currently available in the software.
The device has no patient contact.
Here's an analysis of the provided text regarding the acceptance criteria and the study proving the device meets them:
The document provided is a 510(k) summary for the 3Shape Ortho System™ software. It is a premarket notification to the FDA to demonstrate substantial equivalence to a legally marketed predicate device.
Key takeaway: This document does not describe a study that establishes acceptance criteria for performance metrics (e.g., sensitivity, specificity, accuracy) using a defined test set with human expert adjudicated ground truth. Instead, it focuses on demonstrating substantial equivalence to a predicate device through a comparison of features, technical characteristics, and intended use, along with software verification and validation.
Therefore, many of the requested points cannot be directly extracted from this document as the type of study described (e.g., clinical performance study with AI assistance, standalone algorithm performance) was not performed.
Here's how to address your specific points based on the provided text:
1. A table of acceptance criteria and the reported device performance
The document does not specify quantitative acceptance criteria for device performance (e.g., accuracy, sensitivity, specificity) in the way one would for an AI-driven diagnostic or measurement device. The "performance" demonstrated here is primarily about functional equivalence and safety/effectiveness relative to a predicate device.
The closest to "acceptance criteria" are implied by the comparison table of features and the statement "All test results have been reviewed and approved, showing the Ortho System™ to be substantially equivalent to the predicates."
Implied "Acceptance Criteria" (Substantial Equivalence to Predicate):
| Acceptance Criteria Category | Reported Device Performance (3Shape Ortho System™ K163677) |
|---|---|
| Intended Use | Same as predicate (K152086) - management of orthodontic models, systematic inspection, detailed analysis, treatment simulation, virtual appliance design. |
| Technical Characteristics | Generally same as predicate (K152086) across all listed features (managing patient data, study material collection/alignment/measurement/analysis, treatment simulation, virtual appliance design). |
| Supported Anatomic Areas | Same as predicate (Maxilla, Mandible). |
| Supported PC Formats | Same as predicate (Windows). |
| Device Output | Largely same as predicate, with the addition of "Dental Retainers" as an output, which is the specific focus of this 510(k) for "dental retainers." Other outputs (Custom Metal Bands, Export Models, Directly Printed Transfer Tray, Vacuum Pressed Transfer Media) are also same. |
| Safety and Effectiveness | Found to be as safe and effective as the predicate device based on comparison and nonclinical testing. |
| Software Verification & Validation | Performed in accordance with FDA Guidance, all test results reviewed and approved. |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- The document states "Clinical testing is not a requirement and has not been performed." Therefore, there is no specific test set of patient data used for performance evaluation in the context of diagnostic accuracy, sensitivity, etc.
- The nonclinical testing mentioned is "Software, hardware, and integration verification and validation testing," which refers to standard software quality assurance and testing procedures on the software itself, not on a dataset of patient cases.
- Data Provenance: Not applicable as a clinical test set based on patient data was not used.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Not applicable. No clinical test set with ground truth established by experts was used for performance evaluation in this 510(k) submission.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No clinical test set.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No. The document explicitly states "Clinical testing is not a requirement and has not been performed." This type of study would fall under clinical testing.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This type of performance study was not conducted as "Clinical testing is not a requirement and has not been performed." The device is a software suite providing tools for orthodontists, implying a human-in-the-loop operation for diagnosis and planning.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable. Since no clinical performance study was conducted on patient data to evaluate diagnostic or measurement accuracy, no "ground truth" for such purposes was established or used. The ground truth for the software testing would be the expected functional behavior and calculations according to the software requirements and design specifications.
8. The sample size for the training set
- Not applicable. The 3Shape Ortho System™ software, as described, appears to be a rule-based or calculative software tool for orthodontic planning, not a machine learning or AI model that requires a "training set" in the sense of a dataset of labeled patient examples to learn from. Its "scientific concept" is described as applying "digital imaging tools."
9. How the ground truth for the training set was established
- Not applicable. As it does not appear to be a machine learning model, there is no "training set" and therefore no need to establish ground truth for it.
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized image of three human profiles facing right, stacked on top of each other. The profiles are black and have a flowing, abstract design. The logo also includes the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular pattern around the image.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
April 20, 2017
3Shape A/S Hanne Nielsen Regulatory Affairs Manager Holmens Kanal 7 Copenhagen, 1060 DENMARK
Re: K163677
Trade/Device Name: 3Shape Ortho System™ Software Regulation Number: 21 CFR 872.5470 Regulation Name: Orthodontic plastic bracket Regulatory Class: Class II Product Code: PNN Dated: March 9, 2017 Received: March 13, 2017
Dear Hanne Nielsen:
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. Iisting 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
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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/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of 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,
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) K163677
Device Name 3Shape Ortho System™
Indications for Use (Describe)
3Shape Ortho System™ for dental retainers is intended for use as a medical front-end device providing tools for management of orthodontic models, systematic inspection, detailed analysis, treatment simulation and virtual appliance design based on 3D models of the patient's dentition before the start of an orthodontic treatment.
The use of the Ortho System™ requires the user to have the necessary training and domain knowledge in the practice of orthodontics, as well as to have received a dedicated training in the use of the software.
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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510(K) SUMMARY - Traditional 510(K)
Submitter Information
| A | Company Name: | 3Shape A/S |
|---|---|---|
| B | Company Address: | Holmens Kanal 7DK-1060 Copenhagen K |
| C | Company Phone:Company Fax: | +45 7027 2620+45 7027 2621 |
| D | Contact Person: | Hanne NielsenRegulatory Affairs Manager |
| E | Date Summary Prepared: | March 6, 2017 |
| Device Identification | ||
| A | Trade/proprietary Name: | 3Shape Ortho System™ |
| B | Common Name: | Dental Retainers |
| C | Device Classification Name: | Orthodontic Plastic Bracket |
| C | Regulation Number: | 872.5470 |
D Product Code: PNN (Orthodontic Software)
Predicate Device
The 3Shape Ortho System™ intended for dental retainers has the same intended use and technical characteristics as the predicate Ortho System (K152086) from 3Shape A/S as listed in "Volume 005, Comparison to Predicate Devices, Table 1: Predicates".
Based on the information and supporting documentation provided, the 3Shape Ortho System™ and the predicate (K152086) have same intended use. Both software devices are used by Dental Professionals in orthodontic treatment planning (before, durinq, after treatment) covering management of patients and models, inspection, 2D and 3D measurement and orthodontic analysis of models, 2D & 3D treatment simulation, as well as virtual appliance preparation, handling and export, and they are both providing device output. Therefore, the 3Shape Ortho System™ and the predicate (K152086) are found to be similar in their intended use, supported anatomic areas and the majority of the available features and functionalities.
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Indications for Use
3Shape Ortho System™ for dental retainers is intended for use as a medical frontend device providing tools for management of orthodontic models, systematic inspection, detailed analysis, treatment simulation and virtual appliance design based on 3D models of the patient's dentition before the start of an orthodontic treatment.
The use of the Ortho System™ requires the user to have the necessary training and domain knowledge in the practice of orthodontics, as well as to have received a dedicated training in the use of the software.
Device Description
3Shape's Ortho System™ is a software system used for the management of 3D scanned orthodontic models of the patients, orthodontic diagnosis by measuring, analyzinq, inspecting and visualize 3D scanned orthodontic models, virtual planning of orthodontic treatments by simulating tooth movements, virtual placement of orthodontic brackets on the 3D models and design of orthodontic appliances based on 3D scanned orthodontic models. Output includes Dental Retainers. All devices are to be fabricated from FDA cleared or listed materials currently available in the software.
The device has no patient contact.
Scientific Concept
The underlying scientific concept of the 3Shape Ortho System™ is to apply digital imaging tools for in orthodontic case archiving, diagnosis, treatment planning and CAD design of customized appliances.
The system supports the following types of digital data: DICOM, STL, JPG, BMP, PNG.
Summary of the technological characteristics
3Shape Ortho System™ is a software only device programmed in Delphi and has the following PC/laptop hardware requirements:
| Item | Minimum Requirements |
|---|---|
| OS: | Windows 7 or 8 64-bit |
| RAM: | 8 GB |
| Monitor Resolution: | 1280x800 or similar |
| Video Card Memory: | 1 GB GeForce |
| Available HDD Space: | 250 GB |
| CPU: | IntelCore i5 or equivalent |
| Network: | Network Internet connection |
| Mouse: | With the wheel button |
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The 3Shape Ortho System™ Software has the same intended uses and technical
characteristics as Ortho System™ (K152086) from 3Shape A/S:
| Feature name | 3ShapeOrtho System™K163677 | 3ShapeOrtho System™K152086 |
|---|---|---|
| Supported anatomic areas | Maxilla | Maxilla |
| Mandible | Mandible | |
| Intended use | ||
| Managing patient and case base data | Yes | Yes |
| Collection of study material | Yes | Yes |
| Alignment of study material | Yes | Yes |
| Measuring study material | Yes | Yes |
| Analyzing study material | Yes | Yes |
| Treatment simulation | Yes | Yes |
| Virtual appliance design | Yes | Yes |
| Supported PC formats | Windows | Windows |
| Managing patient and case base data | ||
| Creating, editing, deleting and copying patient data | Yes | Yes |
| Creating, editing, deleting and copying case data | Yes | Yes |
| Collection of study material | ||
| Surface scan for intra-oral scanner | Yes | Yes |
| Surface scan from STL file | Yes | Yes |
| CT image data | DICOM | DICOM |
| 2D overlay | PNG, JPG, BMP | PNG, JPG, BMP |
| Feature name | 3ShapeOrtho System™K163677 | 3ShapeOrtho System™K152086 |
| Alignment of study material | ||
| Aligning surface scan and CT image | Yes | Yes |
| Aligning cephalometric images | Yes | Yes |
| Alignment of 2D overlays (e.g. ideal arch) | Yes | Yes |
| Ability to check/adjust DICOM visibility | Yes | Yes |
| DICOM scan segmentation | No | No |
| Measuring study material | ||
| 2D measurement toolbox | Yes | Yes |
| 3D measurement toolbox | Yes | Yes |
| Analyzing study material | ||
| Arch shape | Yes | Yes |
| Wire length | Yes | Yes |
| Tooth width | Yes | Yes |
| Bolton | Yes | Yes |
| Space analysis | Yes | Yes |
| Overjet/overbite | Yes | Yes |
| Occlusion map | Yes | Yes |
| Treatment simulation | ||
| 2D & 3D simulation | Yes | Yes |
| Virtual appliance design | ||
| Orthodontic appliance search | Yes | Yes |
| Orthodontic appliance virtual preparation | Yes | Yes |
| Orthodontic appliance design | Yes | Yes |
| Orthodontic appliance export | Yes | Yes |
| Output | ||
| Custom Metal Bands | Yes | Yes |
| Export Models | Yes | Yes |
| Directly Printed Transfer Tray | Yes | Yes |
| Vacuum Pressed Transfer Media | Yes | Yes |
| Dental Retainers | Yes | No |
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3SHAPE ORTHO SYSTEM™ SOFTWARE 510(K) SUBMISSION
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AD
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3SHAPE ORTHO SYSTEM™ SOFTWARE 510(K) SUBMISSION
Nonclinical Testing
Software, hardware, and integration verification and validation testing was performed in accordance with the FDA Guidance Document "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices" (Issued on May 11, 2005).
The validation suite includes validation of implemented mitigations related to device hazards identified in the risk management procedures.
All test results have been reviewed and approved, showing the Ortho System™ to be substantially equivalent to the predicates.
Clinical Testing
Clinical testing is not a requirement and has not been performed.
Conclusion
Based on a comparison of intended use, indications, principle of operations, features and technical data, and the test results, the 3Shape Ortho System™ is found to be as safe and effective as the predicate device. Intended use and performance is found to be substantially equivalent to the Predicate Device.
§ 872.5470 Orthodontic plastic bracket.
(a)
Identification. An orthodontic plastic bracket is a plastic device intended to be bonded to a tooth to apply pressure to a tooth from a flexible orthodontic wire to alter its position.(b)
Classification. Class II.