(149 days)
The IS-III HActive Fixture is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function. It is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.
IS-III HActive Fixture is composed of fixtures and cover screw. Fixtures are thread type implants made of titanium alloy which will be placed in the alveolar bone to replace the function of the missing tooth. It is made of Titanium Alloy based on ASTM F136. Surface treatment is HA Coating. This device has connection between the upper prosthesis and the internal hex. Surface is treated with RBM (Resorbable Blasting Media) using Hydroxyapatite powder. Residues are removed through a washing procedure after Plasma-spray with Hydroxyapatite and formation of the HA coating. It is only part to be implanted into bone, and to provide connection of prosthetic devices or other components of a dental implant set with human body (mandibular or maxillary bone). The diameters are 3.5/4.0/4.5/5.0/6.0/7.0mm and the lengths are 7.3/ 8.5/10.0/ 11.5/13.0/15.0mm. (Do not offer 3.5 x 7.3mm implant, 6.0 x 15mm implant, or 7.0 x 15mm implant). Cover Screw intended to protect the inside of the implant during osseointegration. It is made of titanium alloy according to ASTM F136. The surface treatment of the cover Screw is anodizing or non-anodizing. The purpose of anodizing is to distinguish the sizes with the naked eyes for convenience. The diameter of cover screw is 3.45/3.6mm. IS-III HActive Fixture is enclosed with Cover Screw in a packing. IS-III HActive Fixture and Cover Screw can be packed separately for convenience.
The provided text describes the submission of a new dental implant device (IS-III HActive Fixture) to the FDA for substantial equivalence to existing predicate devices. It does not contain information about acceptance criteria or a study proving the device meets specific performance criteria in the way a diagnostic AI/ML device submission would.
The document focuses on demonstrating that the new device is as safe and effective as previously approved devices by comparing their characteristics (intended use, materials, design, etc.) and presenting results from non-clinical testing. This type of submission (510(k)) does not typically include clinical studies with acceptance criteria for device performance as would be seen for AI/ML-driven diagnostics.
Therefore, most of the requested information cannot be extracted from this document, as it pertains to a different type of device and regulatory submission.
However, I can extract the following relevant information:
1. A table of acceptance criteria and the reported device performance:
This document does not provide a formal table of acceptance criteria and reported device performance in the context of diagnostic accuracy (e.g., sensitivity, specificity, AUC). Instead, it refers to meeting criteria of various engineering and biocompatibility standards.
| Acceptance Criteria Category | Specific Standard/Test | Reported Performance (Summary) |
|---|---|---|
| Biocompatibility | ISO 10993-1:2009, ISO 10993-3:2014, ISO 10993-.5:2009, ISO 10993-6:2007, ISO 10993-10:2010 and ISO 10993-11:2006 | Device is biocompatible and substantially equivalent. |
| Mechanical Performance | Bench testing (visual, dimension, compressive loads, fatigue, adaptation accuracy, torque tests) | Met the criteria of the standards and demonstrated substantial equivalence. |
| Fatigue Life | ISO 14801:2016 (worst-case scenario) and "Guidance for Industry and Staff - Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Implant Abutments" | Performed with angled abutment of predicate device; results met criteria. |
| Sterilization | ISO 11137-1:2006, ISO 11137-2:2013, and ISO 11137-3:2006 | Met the criteria of the standards. |
| Shelf Life | ASTM F1980 | Met the criteria of the standards. |
| Endotoxin Levels | ANSI/AAMI ST72:2011, USP <161>, and USP <85> | Met the criteria of the standards. |
| Coating Adhesion | Comparative SEM surface evaluation | Demonstrated HA coating adhesion. |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not applicable. The document describes non-clinical bench testing and biocompatibility assessments, not a diagnostic test on a test set of human data.
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. Ground truth for diagnostic performance is not established in this type of submission. Performance is based on material properties and mechanical integrity.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable.
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
Not applicable. This is not an AI/ML device.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
Not applicable. This is not an AI/ML device.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
For the non-clinical testing, the "ground truth" or reference was based on established industry standards (ISO, ASTM, ANSI/AAMI, USP) and FDA guidance documents for mechanical, material, and biological properties of medical devices.
8. The sample size for the training set
Not applicable. This is not an AI/ML device.
9. How the ground truth for the training set was established
Not applicable.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.
Neobiotech Co., Ltd. April Lee Consultant Withus Consulting Inc 106 Superior Irvine, California 92620
June 1, 2018
Re: K173938
Trade/Device Name: IS-III HActive Fixture Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous dental implant Regulatory Class: Class II Product Code: DZE, NHA Dated: April 24, 2018 Received: May 23, 2018
Dear April Lee:
This letter corrects our substantially equivalent letter of May, 24, 2018.
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 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
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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); 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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
510(k) Number (if known) K173938
Device Name IS-III HActive Fixture
Indications for Use (Describe)
The IS-III HActive Fixture is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function. It is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.
| 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
Submitter
Neobiotech, Co., Ltd. Young-Ku, Heo #312-1, 36, Digital-ro 27 gil Guro-gu, Seoul 08381 South Korea Email: samw728@@neobiotech.co.kr Tel. +82-2-582-2885 Fax. +82-2-3282-3646
Official Correspondent
Withus Group Inc April Lee 106 Superior, Irvine, CA 92620 USA Email: withus6664@gmail.com Phone: 1-909-274-9971 Fax: 1-909-460-8122
Device Information
- Trade Name: IS-III HActive Fixture ●
- Common Name: Endosseous Dental Implant
- Classification Name: Implant, Endosseous, Root-Form ●
- Primary Product Code: DZE
- Secondary Product Code: NHA ●
- Panel: Dental ●
- Regulation Number: 21 CFR 872.3640
- Class II ● Device Class:
- . Date Prepared: 05/23/2018
General Description
IS-III HActive Fixture is composed of fixtures and cover screw. Fixtures are thread type implants made of titanium alloy which will be placed in the alveolar bone to replace the function of the missing It is made of Titanium Alloy based on ASTM F136. Surface treatment is HA Coating. This tooth. device has connection between the upper prosthesis and the internal hex.
Surface is treated with RBM (Resorbable Blasting Media) using Hydroxyapatite powder. Residues are removed through a washing procedure after Plasma-spray with Hydroxyapatite and formation of the HA coating.
It is only part to be implanted into bone, and to provide connection of prosthetic devices or other components of a dental implant set with human body (mandibular or maxillary bone).
The diameters are 3.5/4.0/4.5/5.0/6.0/7.0mm and the lengths are 7.3/ 8.5/10.0/ 11.5/13.0/15.0mm. (Do not offer 3.5 x 7.3mm implant, 6.0 x 15mm implant, or 7.0 x 15mm implant)
|--|
| K number | List of Abutments |
|---|---|
| K113554 | Healing Abutment, Abutment(Cemented(Hex/non-Hex), Angled, SCRP), SolidAbutment, UCLA Gold Abutment, Ball Abutment, and Temporary Abutment) |
Cover Screw intended to protect the inside of the implant during osseointegration. It is made of titanium alloy according to ASTM F136. The surface treatment of the cover Screw is anodizing or non-anodizing. The purpose of anodizing is to distinguish the sizes with the naked eyes for convenience. The diameter of cover screw is 3.45/3.6mm
IS-III HActive Fixture is enclosed with Cover Screw in a packing. IS-III HActive Fixture and Cover Screw can be packed separately for convenience.
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Indication for Use:
The IS-III HActive Fixture is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function. It is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.
Materials:
The fixtures and cover screws are fabricated from Ti-6A1-4V ELI of ASTM F136.
Predicate Devices:
The subject device is substantially equivalent to the following predicate devices:
- o K120503, CMI Implant IS II active manufactured by Neobiotech Co., Ltd.
- K113554, CMI Implant IS System manufactured by Neobiotech Co., Ltd. ●
- K073033, Legacy System Dental Implant With HA Coating manufactured by Implant Direct LLC ●
- K111364, Dentis HAPTITE Implant System, manufactured by Dentis Co.,Ltd. .
Comparison to Predicate Devices:
| 1) Fixture |
|---|
| Subject Device | Primary PredicateDevice | Reference Device | Reference Device | |
|---|---|---|---|---|
| Company | Neobiotech Co., Ltd | Neobiotech Co., Ltd. | Implant Direct LLC | Dentis Co.,Ltd. |
| Device Name | IS-III HActive Fixture | CMI Implant IS IIactive | Legacy SystemDental Implant WhitHA Coating | Dentis HAPTITEImplant System |
| 510(k) Number | N/A | K120503 | K073033 | K111364 |
| DeviceClassificationName | Implant, Endosseous,Root-Form | Implant, Endosseous,Root-Form | Implant, Endosseous,Root-Form | Implant, Endosseous,Root-Form |
| Product Code | DZE | DZE | DZE | DZE |
| RegulationNumber | 872.3640 | 872.3640 | 872.3640 | 872.3640 |
| Intended Use | The IS-III HActiveFixture is intended tobe surgically placed inthe bone of the upperor lower jaw arches toprovide support forprosthetic devices,such as artificial teeth,and to restore thepatient's chewingfunction. It is intendedfor immediate loadingwhen good primary | The CMI Implant IS IIactive is intended to besurgically placed in thebone of the upper orlower jaw arches toprovide support forprosthetic devices,such as artificial teeth,and to restore thepatient's chewingfunction. It is intendedfor immediate loadingwhen good primary | The intended use ofthe Legacy SystemImplants with HACoating is identicalto the intended use ofthe predicateabutments. Theseimplants are two-piece implants forsingle-stage or two-stage surgicalprocedures. TheLegacy implants | The Dentis ImplantSystem is indicatedfor use in partially orfully edlentulousmandibles andmaxillae, in supportof single or multiple-unit restorationsincluding; cementedretained, screwretained, oroverdenturerestorations, and |
| stability is achievedand with appropriateocclusal loading. | stability is achievedand with appropriateocclusal loading. | are intended for usein the mandible andmaxilla, in support ofsingle or multipleunitcement or screwreceiving fixedrestorations and forretention and supportof overdentures. Theimplants are intendedfor immediateplacement andfunctionfor support of singletooth and/or multipletooth restorations,recognizing bonestability andappropriate occlusalload requirements | terminal orintermediateabutment support forfixedbridgework. Thissystem is dedicatedfor one and two stagesurgical proceduresand not dedicated forimmediate loading.This system isintended for delayedloading. | |
| Material | Ti-6Al-4V ELI ofASTM F136 | Pure Titanium ofASTM F 67 | Ti-6Al-4V ELI ofASTM F136 | Pure Titanium ofASTM F 67 |
| Design | Image: dental implant | Image: dental implant | Image: dental implant | Image: dental implant |
| Anti-RotationalFeature | Internal Hex | Internal Hex | Internal Hex | Internal Hex |
| Diameters(mm) | 3.5/4.0/4.5/5.0/5.5/6.0/7.0 | 3.5/4.0/4.5/5.0/5.5/6.0/7.0/8.0 | 3.2/3.7/4.2/4.7/5.2/5.7/7.0 | 3.7/4.1/4.3/4.8/5.5/6.0/6.5/7.0 |
| Surface | HA Coating | S.L.A | HA Coating | HA Coating |
| Lengths(mm) | 7.3/8.5/10.0/11.5/13.0/15.0 | 7.3/8.5/10.0/11.5/13.0/15.0 | 6/8/10/11.5/13/16 | 7/8/9/10/12/14/16 |
| Sterilization | Gamma Sterilization | Gamma Sterilization | Gamma Sterilization | Gamma Sterilization |
| Principle ofOperation | This product is a root-type fixture which isinserted in the alveolarbone. It replaces thefunctions of themissing teeth as adental implant fixture. | This product is a root-type fixture which isinserted in the alveolarbone. It replaces thefunctions of themissing teeth as adental implant fixture. | This product is aroot-type fixturewhich is inserted inthe alveolar bone. Itreplaces thefunctions of themissing teeth as adental implantfixture. | This product is aroot-type fixturewhich is inserted inthe alveolar bone. Itreplaces thefunctions of themissing teeth as adental implantfixture. |
| Shelf Life | 3 Years | 5 Years | - | - |
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-
- Cover Screw
| 2) Cover Screw | ||
|---|---|---|
| Subject Device | Predicate Device | |
| Company | Neobiotech Co., Ltd | Neobiotech Co., Ltd. |
| Device Name | IS-III HActive Fixture | CMI Implant IS System |
| 510(k) Number | N/A | K113554 |
| Device ClassificationName | Abutment, Endosseous,Root-Form | Abutment, Endosseous,Root-Form |
| Product Code | NHA | NHA |
| Intended Use | The IS-III HActive Fixture isintended to be surgically placedin the bone of the upper orlower jaw arches to providesupport for prosthetic devices,such as artificial teeth, and torestore the patient's chewingfunction. It is intended forimmediate loading when goodprimary stability is achievedand with appropriate occlusalloading. | The CMI Implant IS System is indicated for use inpartially or fully edentulous mandibles and maxillae, insupport of single or multiple-unit restorations including;cemented retained, screwretained, or overdenture restorations, and terminal orintermediate abutment support for fixed bridgework. ISSystem is dedicated for two stage surgical proceduresand for immediate loading whenthere is good primary stability and an appropriateocclusal load. Also, implants with diameters larger than5 mm are indicated for molar regions. |
| Material | Ti-6Al-4V ELI of ASTM F136 | Ti-6Al-4V ELI of ASTM F136 |
| Design | Image: Two dental implants, one gold and one silver | Image: Dental implant |
| Diameters (mm) | 3.45/3.6 | 3.19/3.35 |
| Surface | Anodized/Non-Anodized | Non-anodized |
| Lengths (mm) | 6.4/7.4/8.0/5.85/6.85/7.45mm | 5.45/5.85mm |
| Sterilization | Gamma Sterilization | Gamma Sterilization |
| Principle of Operation | Cover screw as a set of medicaldevices is used for protectinginner hole and connecting partwith exposed upper part ofstructure during the healingperiod after inserting dentalimplant fixture. When insertingthe abutment, Cover screw isremoved. | Cover screw as a set of medical device is used forprotecting inner hole and connecting part with exposedupper part of structure during the healing period afterinserting dental implant fixture. When inserting theabutment, Cover screw is removed. |
| Shelf Life | 3 Years | 5 Year |
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Substantial Equivalence Discussion
Similarities:
The IS-III HActive Fixture has same device characteristics with the Primary predicate devices, CMI Implant IS System and CMI Implant IS-II active such as diameters, Length, intended use, general shape (Design), structure and applied production method are similar.
The subject device has been supposed to performance and product validations prior to release. Testing including biocompatibility tests and fatigue test has been performed to ensure the devices comply with the applicable International and US FDA Guidance.
Differences:
The differences between the subject device and the primary predicate device are surface treatment. The surface treatment method of the predicate fixture is SLA (sandblasted and acid-etched). The surface treatment method of the subject device is RBM (Resorbable Blasting Media) using hydroxyapatite powder and Plasma-spray with Hydroxyapatite for formation of the HA coating. The surface treatment of the subject cover screw is anodized.
Non-clinical testing data:
The subject device was tested to evaluate its substantial equivalence according to the following standards.
- Biocompatibility testing according to ISO 10993-1:2009, ISO 10993-3:2014, ISO 10993-. 5:2009, ISO 10993-6:2007, ISO 10993-10:2010 and ISO 10993-11:2006 on fixtures
- Bench testing such as visual test, dimension test, compressive loads, fatigue, adaptation ● accuracy, and torque tests on fixture and cover screw
- Fatigue Testing according to ISO 14801:2016 under the worst-case scenario ●
- Sterilization Testing according to ISO 11137-1:2006, ISO 11137-2:2013, and ISO 11137-● 3:2006
- Shelf Life Testing according to ASTM F1980
- Bacterial Endotoxin Test Report according to ANSI/AAMI ST72:2011, USP <161>, and ● USP <85>
- Adhesion Testing
The results of the above tests have met the criteria of the standards and demonstrated the substantial equivalence with the predicate device.
Biocompatibility Test was conducted for the subject devices and it demonstrates that the subject device is biocompatible and substantial equivalence with the predicate device, K120503. Fatigue evaluation was performed with the angled abutment of the predicate device under the worst-case scenario in accordance with ISO 14801 and "Guidance for Industry and Staff - Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Implant Abutments".
The comparative SEM surface evaluation of the subject and reference device after insertion into a cow bone to demonstrate HA coating adhesion.
The non-clinical testing results demonstrate that the subject device is substantially equivalent to the predicate device.
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Conclusion
IS-III HActive Fixture constitutes a substantially equivalent medical device, meeting all the declared requirements of its intended use. This system has the same intended use and fundamental scientific technology as its predicate devices. Therefore, IS-III HActive Fixture and its predicates are substantially equivalent.
§ 872.3640 Endosseous dental implant.
(a)
Identification. An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.(b)
Classification. (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. 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.)(2)
Classification. Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.