(403 days)
- Permanent obturation of the root canal following vital pulp-extirpation
- Permanent obturation of the root canal following removal of infected or necrotic pulp and placement of intracanal dressings.
ENDOSEAL MTA is an endodontic sealer based on MTA, providing a biocompatible and effective root canal filling. It is premixed and pre-loaded in a syringe, which allows a complete filling of the entire root canal including accessory and lateral canals. The product is eugenol-free and will not impede adhesion inside the root canal.
Below is a summary of the acceptance criteria and study information for the Endoseal MTA device, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
| Test Parameter | Acceptance Criteria (from referenced standards) | Reported Device Performance |
|---|---|---|
| ISO 6876 | Visual, Capacity, Packaging, Flow, Setting time, Film Thickness, Solubility, Radiopacity | All test results met the preset test criteria. |
| Shelf Life Test | Visual, Packaging, Setting time, Solubility (as per ISO 6876) | All test results met the preset test criteria. |
| ISO 10993-5 (Cytotoxicity) | Not explicitly stated, but implies compliance for biocompatibility | Test results supported substantial equivalence to predicate devices (near identical composition of products after setting with predicate devices, and similar cytotoxicity test results). |
| ISO 10993-10 (Maximization test for delayed hypersensitivity (LLNA)) | Not explicitly stated, but implies compliance for biocompatibility | Test results supported substantial equivalence to predicate devices. |
| ISO 10993-11 (Acute systemic toxicity) | Not explicitly stated, but implies compliance for biocompatibility | Test results supported substantial equivalence to predicate devices. |
| ISO 10993-6 (Implantation) | Not explicitly stated, but implies compliance for biocompatibility | Test results supported substantial equivalence to predicate devices. |
| ISO 10993-3 (AMES & Mammalian Erythrocyte Micronucleus) | Not explicitly stated, but implies compliance for biocompatibility | Test results supported substantial equivalence to predicate devices. |
| Material Composition | Comparable properties to predicate devices, demonstrating similar performance specifications. | The main ingredients are similar to predicate devices. Despite some differences in other ingredients, biocompatibility and performance test results supported substantial equivalence. |
| Indications for Use | Same as predicate devices. | Same as predicate devices. |
| Shelf Life | 2 years | 2 years |
2. Sample Size and Data Provenance
The provided text does not specify the sample sizes used for the test set in any of the performance or biocompatibility tests.
The data provenance is from non-clinical testing conducted by MARUCHI, as presented in the 510(k) submission. The country of origin of data is implicitly the Republic of Korea, where MARUCHI is located. The studies are retrospective in the sense that they are summary test results, not prospective trials.
3. Number of Experts and Qualifications for Ground Truth
This information is not applicable to this type of device submission. The "ground truth" for this medical device (a root canal filling resin) is established by adherence to recognized international standards (ISO) for material properties and biocompatibility, as well as by comparison to legally marketed predicate devices. The performance is assessed through laboratory testing, not through expert consensus on diagnostic images or patient outcomes in the same way an AI diagnostic device would be.
4. Adjudication Method for the Test Set
This information is not applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or studies involving expert review of data (e.g., imaging) where there might be disagreement in interpretations. For performance and biocompatibility testing of a material, the results are typically quantitative or qualitative based on established standard methods, and adjudication is not usually applied in this context.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
A multi-reader multi-case (MRMC) comparative effectiveness study was not conducted for this device. This type of study is relevant for diagnostic or AI-assisted devices where human readers interpret medical images or data. The Endoseal MTA is a material used in a dental procedure.
6. Standalone Performance Study
Yes, a standalone performance study was done in the sense that the device was subjected to a series of bench and biocompatibility tests without human intervention or interpretation of the material's properties by human operators with respect to its performance against the set standards. The tests were performed on the device itself to verify its physical, chemical, and biological properties.
7. Type of Ground Truth Used
The ground truth used for this device is based on established international standards (ISO 6876, ISO 10993 series) for the physical, chemical, and biological properties of root canal filling materials. The device's performance is measured against the criteria defined by these standards, and its safety and effectiveness are supported by demonstrating substantial equivalence to legally marketed predicate devices that also comply with these standards.
8. Sample Size for the Training Set
This information is not applicable. This device is a medical material, not an AI or machine learning algorithm that requires a training set. The "training set" concept is not relevant for evaluating the performance of a physical material.
9. How the Ground Truth for the Training Set was Established
This information is not applicable, as there is no training set for this type of device.
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February 26, 2018
Maruchi Priscilla Chung Regulatory Affairs Consultant LK Consulting Group USA, Inc 800 Roosevelt STE 417 Irvine, California 92620
Re: K170175
Trade/Device Name: Endoseal MTA Regulation Number: 21 CFR 872.3820 Regulation Name: Root Canal Filling Resin Regulatory Class: Class II Product Code: KIF Dated: January 17, 2018 Received: January 26, 2018
Dear Priscilla Chung:
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 of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820);
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and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Mary S. Runner -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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Indications for Use
510(k) Number (if known)
Device Name
ENDOSEAL MTA
Indications for Use (Describe)
· Permanent obturation of the root canal following vital pulp-extirpation
• Permanent obturation of the root canal following removal of infected or necrotic pulp and placement of intracanal dressings.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| V D--------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | O -- TL- O- -- L--- II-- II-- IO4 OFF OOL O I---- |
|| | Prescription Use (Part 21 CFR 801 Subpart D)
|__| Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary
(K170175)
This summary of 510(k)-safety and effectiveness information is being submitted in accordance with requirements of 21 CFR Part 807.92.
Date: 01/17/2018__
Applicant / Submitter: 1.
MARUCHI 2-208, 42-10, Taejanggongdan-gil, Wonju-si, Gangwon-do, 26311, Republic of Korea Tel: +82-33-734-0330 Fax:+82-33-746-2804
2. Submission Correspondent:
Priscilla Chung LK Consulting Group USA, Inc. 800 Roosevelt STE 417 Irvine CA 92620 Phone: 714-202-5789 Fax: 714-409-3357 Email: juhee.c@lkconsultinggroup.com
3. Device:
| Proprietary Name: | ENDOSEAL MTA |
|---|---|
| Common Name: | Root Filling Material |
| Classification Name: | Root Canal Filling Resin |
| Classification: | Class II, 21 CFR 872.3820 |
| Classification Product Code: | KIF |
4. Predicate Device:
ENDOSEAL (K133054) by MARUCHI MTA Fillapex (K113568) by Angelus Industria de Produtos Odontologicos IROOT SP (K080917) by Innovative BioCeramix Inc.
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5. Device Description:
ENDOSEAL MTA is an endodontic sealer based on MTA, providing a biocompatible and effective root canal filling. It is premixed and pre-loaded in a syringe, which allows a complete filling of the entire root canal including accessory and lateral canals. The product is eugenol-free and will not impede adhesion inside the root canal.
6. Indications for Use
- Permanent obturation of the root canal following vital pulp-extirpation
- · Permanent obturation of the root canal following removal of infected or necrotic pulp and placement of intracanal dressings.
7. Performance Data(Non-Clinical):
The following properties were tested based on the referenced standard. All the test results met the preset test criteria.
- = ISO 6876 Visual, Capacity, Packaging, Flow, Setting time, Film Thickness, Solubility and Radiopacity
- = Shelf Life Test ISO 6876 (Visual, Packaging, Setting time, Solubility)
- ISO 10993-5 Cytotoxicity
- ISO 10993-10 Maximization test for delayed hypersensitivity (LLNA)
- ISO 10993-11 Acute systemic toxicity
- ISO 10993-6 Implantation
- ISO 10993-3 AMES & Mammalian Erythrocyte Micronucleus
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8. Substantial Equivalence
| Proposed Device | Predicate Device | Predicate Device | Predicate Device | Discuss/Justify the | |
|---|---|---|---|---|---|
| (K170175) | (K133054) | (K113568) | (K080917) | Differences | |
| Trade Name | ENDOSEAL MTA | ENDOSEAL | MTA Fillapex | IROOT SP | |
| Device | ENDOSEAL MTA is | The raw materials of | MTA Fillapex is a | iRoot SP Root Canal | Equivalent |
| Description | an endodontic sealer | the ENDOSEAL are | mineral trioxide | Sealer(IRoot SP) is | |
| based on MTA, | Natural Pure Cement, | aggregate(MTA) and | premixed ready-to-use | ||
| providing a root canal | Zirconium dioxide, | resin root canal sealer | injectable white | ||
| filling. It is premixed | and | used during | hydraulic cement | ||
| and pre-loaded in a | Citric acid anhydrous. | endodontic treatment | paste developed for | ||
| syringe, which allows | It is prepared as a | to permanently fill the | permanent root canal | ||
| a complete filling of | mixture of powder | canal system | filling and sealing | ||
| the entire root canal | and water, and it is | following | applications. iRoot SP | ||
| including accessory | used in a putty | debridement and | is an insoluble. | ||
| and lateral canals. | form which gradually | disinfection. It | radiopaque and | ||
| hardens in the oral | consists of two | aluminum-free | |||
| environment. | component pastes that | material based on a | |||
| are combined in a dual | calcium silicate | ||||
| barrel syringe for ease | composition, which | ||||
| of dispensing and | requires the presence | ||||
| consistent dosage. | of water to set and | ||||
| harden. iRoot SP is | |||||
| packaged in a pre- | |||||
| loaded syringe and is | |||||
| supplied with | |||||
| disposable Intra Canal | |||||
| Tips. | |||||
| Common Name | Root Filling Material | Root Filling Material | Root Filling Material | Root Filling Material | Equivalent |
| Classification | Root Canal Filling | Root Canal Filling | Root Canal Filling | Root Canal Filling | Equivalent |
| Name | Resin | Resin | Resin | Resin | |
| Class | Class II | Class II | Class II | Class II | Equivalent |
| Product Code | KIF | KIF | KIF | KIF | Equivalent |
| Indications | ▪ Permanent | ■ Repair of perforation | MTA Fillapex is a | ▪ Permanent | Equivalent |
| for Use | obturation of the root | ▪ Root canal filling | root canal sealer | obturation of the root |
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| canal following vitalpulp-extirpation▪ Permanentobturation of the rootcanal followingremoval of infected ornecrotic pulp andplacement ofintracanal dressings. | intended for thepermanent sealing ofroot canals and maybe used incombination with rootcanal obturationmaterials. | canal following vitalpulp-extirpation▪ Permanentobturation of the rootcanal followingremoval of infected ornecrotic pulp andplacement ofintracanal dressings.iRoot SP is suitablefor use in the singlecone and lateralcondensationtechnique. | |||
|---|---|---|---|---|---|
| Shelf Life | 2 years | 2 years | 2 years | Equivalent | |
| Standards | ISO 6876 | ISO 6876 | ISO 6876 | ISO 6876 | Equivalent |
| Basic ChemicalComposition | Natural pure cementZirconium dioxideBismuth trioxideBentonite Clay | Natural pure cementZirconium dioxideCitric acid anhydrous | Dicalcium andtricalcium silicate,tricalcium aluminate,calcium oxide, | Zirconium oxideCalcium silicatesCalcium phosphatemonobasic | The main ingredientsare similar but someother ingredients aredifferent. However, |
| n-Methyl-2-PyrrolidoneHypromellose | pentaerythritolrosinate, n-ethyl-o,p-toluenesulfonamidesalicylate resin,bismuth oxide, fumedsilica, titaniumdioxide | Calcium hydroxideFiller and thickeningagents | the biocompatibilityand the performancetest results supportedthat the subject deviceis substantiallyequivalent to thepredicate devices. | ||
| Liquid Formula | Premixed type | Mixing with distilledwater | Mixing through a dualbarrel syringe | Premixed type | Equivalent |
| Packaging | Pre-loaded syringe | Vial | Dual barrel syringe | Pre-loaded syringe | Equivalent |
| Sterile | Non-sterile | Non-sterile | Non-sterile | Non-sterile | Equivalent |
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ENDOSEAL MTA has the same indications for use and the principle of operations as the predicate devices. It has similar physical and biocompatible properties, and demonstrates comparable performance specifications to the predicate devices. In addition, ENDOSEAL MTA has a comparable delivery system to IROOT SP.
Endoseal MTA and all of the predicate devices are equivalent as they all release calcium silicate oxide and calcium hydroxide by undergoing setting reactions when water reacts with calcium oxide. The reaction results in near identical composition of products after setting, as all of liquid components would have expelled during the setting reaction. Hence, all of the products resulted in similar test results including the cytotoxicity test.
The material compositions might slightly different from the predicate devices, however, despite of this difference, the test results of biocompatibility and performance tests show that the subject device is substantially equivalent to the predicate devices.
The bench and biocompatibility testing performed demonstrates that any differences in their technological characteristics do not raise any new questions as to safety and effectiveness. Therefore, it is concluded that ENDOSEAL MTA is substantially equivalent to the predicate devices.
9. Conclusion:
Based on the testing results, MARUCHI concludes that the ENDOSEAL MTA is substantially equivalent to the predicate devices.
§ 872.3820 Root canal filling resin.
(a)
Identification. A root canal filling resin is a device composed of material, such as methylmethacrylate, intended for use during endodontic therapy to fill the root canal of a tooth.(b)
Classification. (1) Class II if chloroform is not used as an ingredient in the device.(2) Class III if chloroform is used as an ingredient in the device.
(c)
Date PMA or notice of completion of a PDP is required. A PMA or a notice of completion of a PDP is required to be filed with the Food and Drug Administration on or before December 26, 1996 for any root canal filling resin described in paragraph (b)(2) of this section that was in commercial distribution before May 28, 1976, or that has, on or before December 26, 1996 been found to be substantially equivalent to a root canal filling resin described in paragraph (b)(2) of this section that was in commercial distribution before May 28, 1976. Any other root canal filling resin shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.