(30 days)
No
The summary describes a physical orthodontic bracket system and its adhesive, with no mention of software, algorithms, or data processing that would indicate AI/ML.
No.
The device, 3M™ Clarity™ Ultra Brackets and Adhesive Coated Appliance System, is intended for orthodontic treatment to exert pressure on teeth, which aligns with the definition of a therapeutic device designed to treat or alleviate a condition. However, the FDA's definition of a therapeutic device generally refers to devices that restore health or alleviate a disease or condition, which casts doubt on the classification of the device as a therapeutic device. Orthodontic treatment, while corrective, is not typically classified as therapeutic as it does not treat a chronic disease or health condition.
No
The device is an orthodontic bracket system used for treating malocclusion by exerting pressure on teeth, which is a treatment modality, not a diagnostic one.
No
The device description clearly outlines physical components made of aluminum oxide and nickel titanium, which are hardware. The performance studies also focus on physical properties like bond strength and torque strength, further indicating a hardware device.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is "for use in orthodontic treatment." This involves physically manipulating teeth for alignment, which is a therapeutic procedure performed directly on the patient.
- Device Description: The description details a physical bracket system designed to be affixed to teeth. It describes the materials, mechanism, and features related to its physical application and function in the mouth.
- Lack of IVD Characteristics: An IVD device is used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. This device does not interact with or analyze any bodily specimens.
The device is clearly a medical device used for a therapeutic purpose (orthodontic treatment) directly on the patient's teeth, not for in vitro diagnostic testing.
N/A
Intended Use / Indications for Use
3M™ Clarity™ Ultra Brackets and Adhesive Coated Appliance System are intended for use in orthodontic treatment. The brackets are affixed to teeth so that pressure can be exerted on the teeth.
Product codes (comma separated list FDA assigned to the subject device)
NJM, DYH
Device Description
3M™ Clarity™ Ultra Brackets and Adhesive Coated Appliance System are intended for use in orthodontic treatment. Clarity Ultra Bracket is an esthetic bracket with a sliding door. The brackets are composed of aluminum oxide, which gives them a clear appearance. A nickel titanium wire serves as part of the door mechanism and is attached to the bracket using a cured adhesive. The brackets incorporate a water-soluble color placement indicator system. The archwire slot, vertical slot, and door are marked to facilitate bracket positioning. Tie wing(s) and/or door are color coded with dots to facilitate bracket identification. The brackets are available with or without APC™ Flash-Free pre-coated adhesive. The pre-coated adhesive ensures a consistent amount of adhesive on the bracket.
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
Not Found
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)
Bench testing consistent with the clinical application and intended use was used to evaluate the performance of Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System compared to the predicate devices, Clarity™ Advanced and Damon 4Clear. Properties evaluated include: rotation play angle, wire rotation strength, shear-peel bond strength, torque strength, and squeeze debond strength. 3M Health Care has tested Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System and has concluded that the performance tests results demonstrate substantial equivalence to the predicate devices.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.
Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.
Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).
Not Found
§ 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.
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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.
March 16, 2018
3M Health Care c/o Mark Job Responsible Third Party Official Regulatory Technology Services, LLC 1394 25th Street, NW Buffalo. Minnesota 55313
Re: K180404
Trade/Device Name: 3M™ Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System Regulation Number: 21 CFR 872.5470 Regulation Name: Orthodontic Plastic Bracket Regulatory Class: Class II Product Code: NJM, DYH Dated: February 12, 2018 Received: February 14, 2018
Dear Mark Job:
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.
1
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); 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.
Andrew I. Steen -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) K180404
Device Name
3M™ Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System
Indications for Use (Describe)
3M™ Clarity™ Ultra Brackets and Adhesive Coated Appliance System are intended for use in orthodontic treatment. The brackets are affixed to teeth so that pressure can be exerted on the teeth.
| Type of Use (Select one or both, as applicable) |
|---|
| ------------------------------------------------- |
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary
This 510(k) summary is submitted in accordance with the requirements of 21 CFR 807.92.
| 510(k) Submitter: | 3M Health Care
2510 Conway Avenue
St. Paul, MN 55144-1000 USA |
|----------------------------|-------------------------------------------------------------------------------------------------------------|
| Contact person: | Lam Duong
Regulatory Affairs Associate
Phone: (651) 733-5945
Fax: (651) 736-1599
lduong@mmm.com |
| Date Summary was Prepared: | 15 March 2018 |
| Trade Names: | 3MTM ClarityTM Ultra Self-Ligating
Brackets and Adhesive Coated Appliance
System |
| Classification Name: | Orthodontic Plastic Bracket |
| Regulation Number: | 21 CFR 872.5470 |
| Product Code: | NJM, DYH |
| Classification Panel: | Dental |
| Device Classification: | Class II |
Primary Predicate Device: ClarityTM Advanced Ceramic Brackets (K102803) Reference Predicate Device: Damon 4Clear (K081415) APC™ Flash-Free Adhesive (K113197)
4
Description of Device:
3MTM Clarity™ Ultra Brackets and Adhesive Coated Appliance System are intended for use in orthodontic treatment. Clarity Ultra Bracket is an esthetic bracket with a sliding door. The brackets are composed of aluminum oxide, which gives them a clear appearance. A nickel titanium wire serves as part of the door mechanism and is attached to the bracket using a cured adhesive. The brackets incorporate a water-soluble color placement indicator system. The archwire slot, vertical slot, and door are marked to facilitate bracket positioning. Tie wing(s) and/or door are color coded with dots to facilitate bracket identification. The brackets are available with or without APC™ Flash-Free pre-coated adhesive. The pre-coated adhesive ensures a consistent amount of adhesive on the bracket.
Indications for Use:
3M™ Clarity™ Ultra Brackets and Adhesive Coated Appliance System are intended for use in orthodontic treatment. The brackets are affixed to teeth so that pressure can be exerted on the teeth.
Performance Testing:
Bench testing consistent with the clinical application and intended use was used to evaluate the performance of Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System compared to the predicate devices, Clarity™ Advanced and Damon 4Clear. Properties evaluated include: rotation play angle, wire rotation strength, shear-peel bond strength, torque strength, and squeeze debond strength. 3M Health Care has tested Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System and has concluded that the performance tests results demonstrate substantial equivalence to the predicate devices.
Technological Characteristics:
Clarity Ultra Brackets are substantially equivalent in design feature to the predicate devices. Clarity Ultra, Clarity Advanced, and Damon 4Clear brackets all have a bracket body made of ceramic. Clarity Ultra and Damon 4 Clear both have a self-ligating ceramic door with a nickeltitanium spring mechanism. Clarity Ultra and Clarity Advanced both have a water-soluble placement indicator system and a glass-grit bonding base that can be pre-coated with APC Flash-Free adhesive.
Mechanism of Action:
Clarity Ultra Brackets are substantially equivalent in mechanism of action to the predicate devices. Clarity Advanced and Damon 4Clear brackets. Orthodontic brackets are affixed to teeth using an orthodontic adhesive. Pressure is exerted on a tooth when the brackets are used in combination with archwires and/or other intraoral modules. The pressure causes tooth movement.
Clarity Ultra and Damon 4Clear brackets both have a self-ligating mechanism that ligates the archwire and secures it inside the bracket's wire slot instead of using a manually-placed elastomeric or steel ligature.
Clarity Ultra and Clarity Advanced brackets can be pre-coated with APC Flash-Free adhesive. The methacrylate functionalities of the APC Flash-Free adhesive resins and surface-treated
5
fillers undergo a light-induced polymerization to form a hard composite that bonds the orthodontic appliance to a tooth and can be removed at the completion of the orthodontic treatment.
Biocompatibility Testing:
The biocompatibility evaluation for the device was conducted in accordance with the FDA Guidance Docket Number FDA-2013-D-0350 and International Standard ISO 10993-1:2009 "Biological Evaluation of Medical Devices - Part 1: Evaluation and Testing Within a Risk Management Process," as recognized by FDA. 3M™ Clarity™ Ultra Self-Ligating Brackets and Adhesive Coated Appliance System are considered mucosal membrane contacting for a duration of greater than 30 days. The following are some of the evaluated endpoints:
- . Cytotoxicity
- Sensitization ●
- Irritation ●
- Systemic Toxicity ●
- Pyrogenicity ●
- Genotoxicity ●
The results of the evaluation met the requirements of internationally recognized guidelines as mentioned above and further support a determination of substantial equivalence.
Substantial Equivalence Comparison:
The following table compares the Clarity Ultra Brackets to the predicate devices, Clarity Advanced and Damon 4Clear brackets with respect to intended use, technological characteristics, and principles of operation.
| | 3M™ Clarity™ Ultra
Brackets and
Adhesive Coated
Appliance System | Clarity™ Advanced
Ceramic Brackets | Damon 4Clear |
|--------------------------------|---------------------------------------------------------------------------------------|---------------------------------------|------------------------------------|
| Premarket Notification | New Device | K102803 | K081415 |
| Manufacturer | 3M Health Care | 3M Unitek
Corporation | Sybron Dental
Specialties, Inc. |
| Regulation Numbers | 21 CFR 872.5470 | 21 CFR 872.5470 | 21 CFR 872.5470 |
| Device Classification
Names | Orthodontic
Plastic Bracket,
Bracket Adhesive
Resin and Tooth
Conditioner | Orthodontic
Plastic Bracket | Orthodontic Plastic
Bracket |
| Product Codes | NJM, DYH | NJM | NJM |
| Device Class | Class II | Class II | Class II |
| Intended Use | Orthodontic
brackets | Orthodontic
brackets | Orthodontic brackets |
6
| | 3M™ Clarity™ Ultra
Brackets and
Adhesive Coated
Appliance System | Clarity™ Advanced
Ceramic Brackets | Damon 4Clear |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use¹ | 3M™ Clarity™
Ultra Brackets and
Adhesive Coated
Appliance System
are intended for use
in orthodontic
treatment. The
brackets are affixed
to teeth so that
pressure can be
exerted on the teeth. | Clarity™
Advanced
Ceramic Brackets
are intended for
use in orthodontic
treatment. The
brackets are
affixed to teeth so
that pressure can
be exerted on the
teeth. | The Damon 4Clear is
a ceramic bracket
system intended to
aid in the movement
of patient teeth
during orthodontic
treatment. |
| Composition
• Bracket body | Micro-fine alumina
ceramic | Micro-fine alumina
ceramic | Alumina ceramic |
| •Door | Micro-fine alumina
ceramic | None | Micro-fine alumina
ceramic |
| • Bonding base
• Water-soluble indicators | Glass-grit
Color slots & dots | Glass-grit
Color slots & dots | Laser-etched alumina
None |
| Device Design
• Tie wing undercut
• Base flange
• Parallel sides
• Molded ceramic
• Optional Hook
• Vertical slot
• Stress concentrator
• Self-ligating mechanism | √
√
√
√
√
√
√
√ | √
√
√
√
√
√
√
-
| √
√
√
√ |
| Available with pre-coated
adhesive | Yes | Yes | No |
7
| | 3MTM ClarityTM Ultra
Brackets and
Adhesive Coated
Appliance System | ClarityTM Advanced
Ceramic Brackets | Damon 4Clear |
|--------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| FDA-recognized
standards followed | Risk Management:
ISO 14971
Biocomp stds:
ISO 10993-1
ISO 10993-3
ISO 10993-4
ISO 10993-5
ISO 10993-6
ISO 10993-10
ISO 10993-11
ISO 10993-12
ISO 7405
Labeling:
ISO 15223-1
ASTM F603-12
ASTM F2063-12
ISO 27020 | Risk Management:
ISO 14971
Biocomp stds:
ISO 10993-1
ISO 10993-3
ISO 10993-5
ISO 10993-10
ISO 10993-11
ISO 7405
ISO 6872
ASTM F603-00
ASTM G133-05 | NA2 |
1 Indications from FDA 510(k) clearance letter enclosure
2 Not Available, details not disclosed by manufacturer
Clarity Ultra Brackets have substantially equivalent Indications for Use as the identified predicate devices. The verbiage of the Indications for Use of the subject device is slightly different than the predicate devices; however these slight differences do not alter the intended therapeutic use of the device as compared to the predicates.
The technological characteristics, how the device functions, and the mechanical properties of Clarity Ultra Brackets compared to the predicates have not fundamentally changed. Orthodontic brackets are designed to be affixed to teeth and to hold an archwire so that pressure can be exerted to move the teeth to new positions. Bench testing shows that Clarity Ultra Brackets are substantially equivalent in performance to the predicate devices.
Conclusion
3M™ Clarity™ Ultra Brackets and Adhesive Coated Appliance System are substantially equivalent to the predicate devices in terms of intended use, indications for use, design, performance, technological characteristics, mechanism of action, composition, and biocompatibility.