K Number
K181266
Device Name
Implantswiss Dental Implant System, Implantswiss Dental Abutment System
Manufacturer
Date Cleared
2018-11-01

(171 days)

Product Code
Regulation Number
872.3640
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Implantswiss Dental Implant System is indicated to use for surgical placement in the upper and lower jaw arches, to provide a root form means for single and multiple units' prosthetic appliance attachment to restore a patient's chewing function. Implantswiss Dental Implant can be placed with a conventional two stage surgical process with an option for transmucosal healing or they can be placed in a single stage surgical process for immediate loading is restricted to the anterior mandible based on four splinted-interforminal placed implantswiss Dental Abutment System is used with a dental implant to provide support to prosthetic restorations such as crown, bridge and overdentures in partially or fully edentulous patients. Octa and Multi-Unit Abutment models that contain an abutment post height less than 4 mm are indicated only for multi-unit loading, such as a bridge or overdenture.
Device Description
The Implantswiss Dental Implant and Implantswiss Dental Abutment Systems are compatible titanium/titanium alloy dental implants and abutments. The Implantswiss Dental Implants are provided as bone level or tissue level type implants and their surface is modified by a Sandblasted Rough Acid-etched (SRA) process. The Implantswiss Bone Level Implants have diameters of 3.3mm, 3.7mm, 4.3mm and 4.8mm with lengths of 8mm, 12mm and 14mm; and diameter of 5.5mm with lengths of 8mm, 10mm and 12mm. The 3.3mm and 3.7mm diameter Bone Level Implants are composed of Titanium Ti6Al4V ELI – ASTM F136-13. The 4.3mm, 4.8mm and 5.5mm diameter Bone Level Implants are composed of Titanium Grade 4 – ASTM F67-13. The Implantswiss Tissue Level Implants have diameters of 3.7mm, 4.3mm and 4.8mm with lengths of 8mm, 10mm, 12mm and 14mm; and diameter of 5.5mm with lengths of 8mm, 10mm and 12mm. The Tissue Level Implants are composed of Titanium Grade 4 – ASTM F67-13. The Implantswiss Dental Abutment System consists of Couple, Angled, Solid, O-ring, Multi, Octa, Synocta, Healing, Locator and Multi-Unit Abutments.
More Information

No
The summary describes a physical dental implant and abutment system made of titanium/titanium alloy. There is no mention of software, algorithms, image processing, or any terms related to AI or ML. The performance studies focus on mechanical, biological, and sterilization testing of the physical device.

Yes
The device is described as a "Dental Implant System" whose intended use is "to provide a root form means for single and multiple units' prosthetic appliance attachment to restore a patient's chewing function", which falls under the definition of a therapeutic device as it treats a condition (missing teeth) and restores function.

No

Explanation: The device description and intended use clearly state that the Implantswiss Dental Implant System and Abutment System are used for surgical placement and attachment of prosthetic appliances to restore chewing function. There is no mention of the device being used for diagnosis, disease detection, or medical condition assessment. The performance studies focus on mechanical and biological properties relevant to implantation, not diagnostic capabilities.

No

The device description explicitly details physical components made of titanium/titanium alloy, including implants and abutments with specific dimensions and surface modifications. The performance studies also focus on physical testing of these components (biocompatibility, sterilization, fatigue, surface analysis).

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

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant and abutment system used to restore chewing function by providing a root form for prosthetic attachments in the jaw. This is a physical device used in vivo (within the body) for structural support.
  • Device Description: The description details the materials (titanium/titanium alloy), types (bone level, tissue level), dimensions, and surface modification of the implants and abutments. These are all characteristics of a physical implantable device.
  • Performance Studies: The performance studies focus on biocompatibility, sterilization, packaging, and fatigue testing. These are relevant tests for an implantable medical device, not for a diagnostic test that analyzes samples in vitro (outside the body).
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting specific analytes, or providing diagnostic information about a patient's health status.

In summary, the Implantswiss Dental Implant System and Implantswiss Dental Abutment System are medical devices intended for surgical implantation and prosthetic support, not for in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

Implantswiss Dental Implant System is indicated to use for surgical placement in the upper and lower jaw arches, to provide a root form means for single and multiple units' prosthetic appliance attachment to restore a patient's chewing function. Implantswiss Dental Implant can be placed with a conventional two stage surgical process with an option for transmucosal healing or they can be placed in a single stage surgical process for immediate loading. Immediate loading is restricted to the anterior mandible based on four splinted-interforminal placed implants. Implantswiss Dental Abutment System is used with a dental implant to provide support to prosthetic restorations such as crown, bridge and overdentures in partially or fully edentulous patients. Octa and Multi-Unit Abutment models that contain an abutment post height less than 4 mm are indicated only for multi-unit loading, such as a bridge or overdenture.

Product codes (comma separated list FDA assigned to the subject device)

DZE, NHA

Device Description

The Implantswiss Dental Implant and Implantswiss Dental Abutment Systems are compatible titanium/titanium alloy dental implants and abutments.

The Implantswiss Dental Implants are provided as bone level or tissue level type implants and their surface is modified by a Sandblasted Rough Acid-etched (SRA) process.

The Implantswiss Bone Level Implants have diameters of 3.3mm, 3.7mm, 4.3mm and 4.8mm with lengths of 8mm, 12mm and 14mm; and diameter of 5.5mm with lengths of 8mm, 10mm and 12mm. The 3.3mm and 3.7mm diameter Bone Level Implants are composed of Titanium Ti6Al4V ELI – ASTM F136-13. The 4.3mm, 4.8mm and 5.5mm diameter Bone Level Implants are composed of Titanium Grade 4 – ASTM F67-13.

The Implantswiss Tissue Level Implants have diameters of 3.7mm, 4.3mm and 4.8mm with lengths of 8mm, 10mm, 12mm and 14mm; and diameter of 5.5mm with lengths of 8mm, 10mm and 12mm. The Tissue Level Implants are composed of Titanium Grade 4 – ASTM F67-13.

The Implantswiss Dental Abutment System consists of Couple, Angled, Solid, O-ring, Multi, Octa, Synocta, Healing, Locator and Multi-Unit Abutments.

Bone Level Couple Abutments have diameters Ø 3.7mm and Ø 4.5mm. Tissue Level Couple Abutments have diameters Ø 5.2mm and Ø 6.4mm.

Bone Level Angled Abutments with 15° angles have diameters Ø 3.7mm and Ø 4.5mm. Bone Level Angled Abutments with 25° angles have a diameter of Ø 4.5mm. Tissue Level Angled Abutments have 15° angles with diameter Ø 3.5mm.

Bone Level Solid Abutments have diameters of Ø 3.7mm and Ø 4.5mm. Tissue Level Solid Abutments have diameters of Ø 3.5mm and Ø 4.3mm.

Bone Level O-ring Abutments have diameters of Ø 2.9mm and Ø 4.5mm.

Bone Level Multi Abutments have diameters of Ø 3.7mm and Ø 4.5mm. Tissue Level Multi Abutments have a diameter of Ø 5.2mm.

Bone Level Octa Abutments have diameter of Ø 4.8mm. Tissue Leyel Octa Abutments have a diameter of Ø 3.5mm.

Tissue Level Synocta Abutments have a diameter of Ø 3.5mm.

Bone Level Healing Abutments have diameters of Ø 3.7mm and Ø 4.5mm. Tissue Level Healing Abutments have a diameter of Ø 5.2mm.

Bone Level Locator Abutments have diameter of Ø 3.86mm. Tissue Level Healing Locator have diameter of Ø 3.86 mm.

Bone Level Multi-Unit Abutments with 17 angle have a diameter Ø 4.8mm.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

upper and lower jaw arches

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)

Performance testing of the Implantswiss Dental Implant and Implantswiss Dental Abutment followed the FDA guidance Class II Special Controls Guidance Document: Rootform Endosseous Dental Implants and Endosseous Dental Abutments.

Biocompatibility testing was conducted according to ISO 10993-1:2009"Biological evaluation of medical devices-Part 1: Evaluation and testing within risk management process" and the biocompatibility evaluation flow chart according to the FDA Guidance document "Use of International Standard ISO 10993-1, 'Biological evaluation of medical devices-Part 1: Evaluation and testing within a risk management process', Guidance for Industry and Food and Drug Administration Staff, Document issued on: June 16, 2016" for each of the subject devices Fixture has been conducted the following biocompatibility test:

  • Cytotoxicity (in vitro) ISO 10993-5:2009.
  • Sensitization- ISO 10993-10:2010. - ISO 10993-12:2012
  • Irritation/ Intracutaneous Toxicity - ISO 10993-10:2010
  • . Implantation test - ISO 10993-6:2016
  • ISO 10993-12:2012
  • . Chemical Analysis - IS0 10993-12
  • Semivolatile Organics (SVOC) Method:8270D
  • Volatile Organic Compounds (VOC) Method: 8260C

Implantswiss Dental Implants are sterilized using a gamma ray sterilization process ISO 11137-1 and ISO 11737-2 that has been validated to ensure a SAL of 106. LAL testing was conducted in accordance with USP .

The Implantswiss Dental Abutment System is provided non-sterile. The recommended end-user steam gravity sterilization method and sterilization parameters have been validated to achieve an SAL of 10-6 according to ISO 17665-1. ISO 17665-2 and ISO 11737-2.

Packaging testing of accelerated aged and real-time aged product demonstrated that the sterility of the Implantswiss Dental Implant System is maintained over the 2-year shelf life period. Below tests are performed:
-Visual Inspection ASTM F1886
-Dye Penetration ASTM F1929-15
-Seal Peel Strength Test BS EN 868-5:2009
-Sterility test

Fatigue testing, in accordance with ISO 14801 Dentistry- Implants-Dynamic fatigue test for Endosseous Dental Implants, was performed on the worst-case bone level Implantswiss Dental Implant mated with the worst case Implantswiss Dental Abutment. Results of the fatigue testing found that the worst case (bone level) dental implant/abutment combinations was consistent with FDA Class II Special Controls guidance and ISO 14801.

Fatigue testing, in accordance with ISO 14801 Dentistry- Implants-Dynamic fatigue test for Endosseous dental implants, referenced in K160221 was performed on the worst-case tissue level Implance Dental Implant (K160221) mated with the worst case Implance Dental Abutment (K160221). Results of the fatigue testing found that the worst case (tissue level) dental implant/abutment combinations was consistent with FDA Class II Special Controls guidance and ISO 14801.

Surface analysis of the implant body after the SRA process was conducted using Scanning Electron Microscopy (SEM) and Energy Dispersive X-ray Spectroscopy(EDS). SEM found that the implant surface had a homogeneous structure.

Non-clinical performance testing consistent with the FDA's Class II Special Controls guidance document and ISO 14801 support the substantial equivalence of the Implantswiss Dental Implant System and the Implantswiss Dental Abutment System.

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.

K160221

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.

K150938, K150295, K072570

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

§ 872.3640 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.

0

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the U.S. Food & Drug Administration (FDA). The Department of Health & Human Services logo is on the left, featuring a stylized human figure. To the right is the FDA logo, with the letters "FDA" in a blue square, followed by "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

November 1, 2018

Novodent SA % H. Semih Oktay, PhD President CardioMed Device Consultants, LLC 1783 Forest Drive #254 Annapolis, Maryland 21401

Re: K181266

Trade/Device Name: Implantswiss Dental Implantswiss Dental Abutment System Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: Class II Product Code: DZE, NHA Dated: September 27, 2018 Received: October 2, 2018

Dear H. Semih Oktay, PhD:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-

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 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)

K181266

Device Name

Implantswiss Dental Implant System, Implantswiss Dental Abutment System

Indications for Use (Describe)

Implantswiss Dental Implant System is indicated to use for surgical placement in the upper and lower jaw arches, to provide a root form means for single and multiple units' prosthetic appliance attachment to restore a patient's chewing function. Implantswiss Dental Implant can be placed with a conventional two stage surgical process with an option for transmucosal healing or they can be placed in a single stage surgical process for immediate loading is restricted to the anterior mandible based on four splinted-interforminal placed implantswiss Dental Abutment System is used with a dental implant to provide support to prosthetic restorations such as crown, bridge and overdentures in partially or fully edentulous patients. Octa and Multi-Unit Abutment models that contain an abutment post height less than 4 mm are indicated only for multi-unit loading, such as a bridge or overdenture.

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

SUBMITTER

NOVODENT SA

Y-PARC Technopole Avenue des Sciences 11 CH-1400 Yverdon-les-Bains Switzerland Office: +41 24 524 28 28 +41 24 524 28 25

Official Correspondent: H. Semih Oktay, Ph.D.

CardioMed Device Consultants, LLC

1783 FOREST DRIVE #254 ANNAPOLIS, MD 21401 USA Phone: (410) 674-2060 Email: soktay@cardiomedllc.com

Date of Summary: November 1, 2018

DEVICE

Proprietary nameImplantswiss Dental Implant System
Implantswiss Dental Abutment System
Common NameImplant, Endosseous, Root-Form
Classification NameEndosseous Dental Implant
Regulatory ClassII
Primary Product CodeDZE
Subsequent Product CodeNHA
Regulation Number21 CFR 872.3640

PREDICATE DEVICE

Primary Predicate Device:

Implance Dental Implant System, Implance Dental Abutment System - K160221

4

Reference Devices:

Straumann Dental Implant System - K150938

LOCATOR RTx - K150295

NobelActive Multi Unit Abutment - K072570

Device Description

The Implantswiss Dental Implant and Implantswiss Dental Abutment Systems are compatible titanium/titanium alloy dental implants and abutments.

The Implantswiss Dental Implants are provided as bone level or tissue level type implants and their surface is modified by a Sandblasted Rough Acid-etched (SRA) process.

The Implantswiss Bone Level Implants have diameters of 3.3mm, 3.7mm, 4.3mm and 4.8mm with lengths of 8mm, 12mm and 14mm; and diameter of 5.5mm with lengths of 8mm, 10mm and 12mm. The 3.3mm and 3.7mm diameter Bone Level Implants are composed of Titanium Ti6Al4V ELI – ASTM F136-13. The 4.3mm, 4.8mm and 5.5mm diameter Bone Level Implants are composed of Titanium Grade 4 – ASTM F67-13.

The Implantswiss Tissue Level Implants have diameters of 3.7mm, 4.3mm and 4.8mm with lengths of 8mm, 10mm, 12mm and 14mm; and diameter of 5.5mm with lengths of 8mm, 10mm and 12mm. The Tissue Level Implants are composed of Titanium Grade 4 – ASTM F67-13.

The Implantswiss Dental Abutment System consists of Couple, Angled, Solid, O-ring, Multi, Octa, Synocta, Healing, Locator and Multi-Unit Abutments.

Bone Level Couple Abutments have diameters Ø 3.7mm and Ø 4.5mm. Tissue Level Couple Abutments have diameters Ø 5.2mm and Ø 6.4mm.

Bone Level Angled Abutments with 15° angles have diameters Ø 3.7mm and Ø 4.5mm. Bone Level Angled Abutments with 25° angles have a diameter of Ø 4.5mm. Tissue Level Angled Abutments have 15° angles with diameter Ø 3.5mm.

Bone Level Solid Abutments have diameters of Ø 3.7mm and Ø 4.5mm. Tissue Level Solid Abutments have diameters of Ø 3.5mm and Ø 4.3mm.

Bone Level O-ring Abutments have diameters of Ø 2.9mm and Ø 4.5mm.

Bone Level Multi Abutments have diameters of Ø 3.7mm and Ø 4.5mm. Tissue Level Multi Abutments have a diameter of Ø 5.2mm.

Bone Level Octa Abutments have diameter of Ø 4.8mm. Tissue Leyel Octa Abutments have a diameter of Ø 3.5mm.

5

Tissue Level Synocta Abutments have a diameter of Ø 3.5mm.

Bone Level Healing Abutments have diameters of Ø 3.7mm and Ø 4.5mm. Tissue Level Healing Abutments have a diameter of Ø 5.2mm.

Bone Level Locator Abutments have diameter of Ø 3.86mm. Tissue Level Healing Locator have diameter of Ø 3.86 mm.

Bone Level Multi-Unit Abutments with 17 angle have a diameter Ø 4.8mm.

Indication for Use

Implantswiss Dental Implant System is indicated to use for surgical placement in the upper and lower jaw arches, to provide a root form means for single and multiple units' prosthetic appliance attachment to restore a patient's chewing function. Implantswiss Dental Implant can be placed with a conventional two stage surgical process with an option for transmucosal healing or they can be placed in a single stage surgical process for immediate loading. Immediate loading is restricted to the anterior mandible based on four splintedinterforminal placed implants. Implantswiss Dental Abutment System is used with a dental implant to provide support to prosthetic restorations such as crown, bridge and overdentures in partially or fully edentulous patients. Octa and Multi-Unit Abutment models that contain an abutment post height less than 4 mm are indicated only for multi-unit loading, such as a bridge or overdenture.

Substantial Equivalence Comparison

The Implantswiss Dental Implant System is comparable to the K160221- Implance Dental Implant System, Implance Dental Abutment System as the primary predicate and the reference predicate device Straumann Dental Implant System (K150938).

The Implantswiss Dental Abutment System is comparable to the primary predicate devices Implance Dental Abutment System (K160221) and reference predicate devices LOCATOR RTx (K150295) and NobelActive Multi Unit Abutment (K072570).

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| | Implantswiss Dental
Implant System,
Implantswiss Dental
Abutment System | Primary Predicate
Implance Dental Implant
System,
Implance Dental
Abutment System | Reference Predicate
Straumann Dental Implant
System |
|--------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510k # | K181266 | K160221 | K150938 |
| Manufacturer | Novodent SA | AGS Medikal Urunleri Ith.
Ihr. Tic. Ltd. Sti. | Straumann USA, LLC |
| Indication | Implantswiss Dental
Implant System is indicated
to use for surgical
placement in the upper and
lower jaw arches, to
provide a root form means
for single and multiple
units' prosthetic appliance
attachment to restore a
patient's chewing function.
Implantswiss Dental
Implant can be placed with
a conventional two stage
surgical process with an
option for transmucosal
healing or they can be
placed in a single stage
surgical process for
immediate loading.
Immediate loading is
restricted to the anterior
mandible based on four
splinted-interforminal
placed implants.
Implantswiss Dental
Abutment System is used
with a dental implant to
provide support to
prosthetic restorations such
as crown, bridge and
overdentures in partially or
fully edentulous patients.
Octa and Multi-Unit
Abutment models that
contain an abutment post
height less than 4 mm are
indicated only for multi-
unit loading, such as a
bridge or overdenture. | Implance Dental Implant
System is indicated to use
for surgical placement in the
upper and lower jaw arches,
to provide a root form means
for single and multiple units'
prosthetic appliance
attachment to restore a
patient's chewing function.
Implance Dental Implant
can be placed with a
conventional two stage
surgical process with an
option for transmucosal
healing or they can be
placed in a single stage
surgical process for
immediate loading.
Immediate loading is
restricted to the anterior
mandible based on four
splinted-interforminal
placed implants.
Implance Dental Abutment
System is used with a
dental implant to provide
support to prosthetic
restorations such as crown,
bridge and overdentures in
partially or fully edentulous
patients. Octa Abutment
models that contain an
abutment post height less
than 4 mm are indicated
only for multi-unit loading,
such as a bridge or
overdenture. | Straumann Dental Implants are
indicated for oral endosteal
implantation in the upper and
lower jaw and for the
functional and esthetic oral
rehabilitation of edentulous
and partially dentate patients.
Straumann dental implants can
also be used for immediate or
early implantation following
extraction or loss of natural
teeth. Implants can be placed
with immediate function on
single-tooth and or multiple
tooth applications when good
primary stability is achieved
and appropriate occlusal
loading, to store chewing
function. The prosthetic
restorations used are single
crowns, bridge and partial or
full dentures, which are
connected to the implants by
the corresponding elements
(abutments). |

Implantswiss Dental Implant System Substantial Equivalence Comparison

7

| System
Components | Dental implant and closing
screw | Dental implant and closing
screw | Dental implant and transfer
piece |
|-------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Design | Threaded root-form bone
or tissue level implant with
hybrid and straight designs
and Morse taper internal
hexagon or internal
octagonal abutment
interface
Tissue Level Dental
implant' machined length
is 2.65 mm | Threaded root-form bone or
tissue level implant with
hybrid and straight designs
and Morse taper internal
hexagon or internal
octagonal abutment
interface | Implant-Abutment
connection for Bone Level:
-Narrow CrossFit (NC)
-Regular CrossFit (RC)
Implant-Abutment
connection for Tissue Level:
-Narrow Neck CrossFit
(NNC)
-Regular Neck (RN)
-Wide Neck (WN)
Tissue Level Dental implant'
machined length is 1.8 and
2.8 mm respectively Narrow
Neck CrossFit (NNC) and
both Regular Neck (RN) and
Wide Neck (WN) |
| Implant Sizes
Bone Level | 3.3x8, 3.3x10, 3.3x12,
3.3x14
3.7x8, 3.7x10, 3.7x12,
3.7x14
4.3x8, 4.3x10, 4.3x12,
4.3x14
4.8x8, 4.8x10, 4.8x12,
4.8x14
5.5x8, 5.5x10, 5.5x12 | 3.3x8, 3.3x10, 3.3x12,
3.3x14
3.7x8, 3.7x10, 3.7x12,
3.7x14
4.3x8, 4.3x10, 4.3x12,
4.3x14
4.8x8, 4.8x10, 4.8x12,
4.8x14
5.5x8, 5.5x10, 5.5x12 | 3.3x8, 3.3x10, 3.3x12,
3.3x14, 3.3x16
4.1x6, 4.1x8, 4.1x10, 4.1x12,
4.1x14, 4.1x16
4.8x6, 4.8x8, 4.8x10, 4.8x12,
4.8x14, 4.8x16 |
| Implant Sizes
Tissue Level | 3.7x8, 3.7x10, 3.7x12,
3.7x14
4.3x8, 4.3x10, 4.3x12,
4.3x14
4.8x8, 4.8x10, 4.8x12,
4.8x14
5.5x8, 5.5x10, 5.5x12 | 3.7x8, 3.7x10, 3.7x12,
3.7x14
4.3x8, 4.3x10, 4.3x12,
4.3x14
4.8x8, 4.8x10, 4.8x12,
4.8x14
5.5x8, 5.5x10, 5.5x12 | 3.3x8, 3.3x10, 3.3x12,
3.3x14, 3.3x16
4.1x6, 4.1x8, 4.1x10, 4.1x12.
4.1x14, 4.1x16
4.8x6, 4.8x8, 4.8x10, 4.8x12,
4.8x14, 4.8x16 |
| Materials | Commercially Pure
Titanium Grade 4 &
Titanium Ti6Al4V ELI | Titanium Grade 4 &
Titanium Ti6Al4V | Commercially Pure Titanium
Grade 4
Transfer piece-titanium-
6aluminum-7niobium alloy
(TAN) |
| Surface
treatment | Sandblasted Rough Acid-
etched (SRA) surface | Resorbable Blast Media
(RBM) surface treatment | Sandblasting Large grit Acid
etching (SLA) surface
treatment |
| Sterilization | Gamma | Gamma | Gamma |
| Standards for
Titanium | ASTM F-67 &
ASTM F-136 | ASTM F-67 &
ASTM F-136-13 | ASTM F-67 |

8

The Implantswiss Dental Implant System is the same or similar to the primary predicate Implance Dental Implant System with respect to indication for use, design, size and dimensions and material composition.

The Implantswiss Dental Implant System maximum implant diameter is the same as the primary predicate Implance Dental Implant System.

The Implantswiss Dental Implant System differs from the primary predicate with respect to the surface treatment.

The Implantswiss Dental Implant System is the same or similar to the reference predicate Straumann Dental Implant System with respect to indication for use, design, material composition and surface treatment. The Implantswiss Dental Implant System has the same surface modification which is sandblasted and following double acid-etching with reference predicate Straumann Dental Implant System (K150938). The Implantswiss Dental Implant System differs with respect to maximum implant diameter and minimum/maximum lengths. The Implantswiss Dental Implant has a maximum implant diameter of 5.5 mm while the reference predicate has a maximum implant diameter of 4.8 mm.

The Implantswiss Tissue Level Dental Implant's machined neck (cuff height) length is 2.65 mm while reference predicate Tissue Level Dental Implant's machined neck length is 1.8 and 2.8 mm respectively Narrow Neck CrossFit and both Regular Neck and Wide Neck. Minimum/maximum implant lengths for the Implantswiss Dental Implant System are 8 mm - 14 mm versus 6mm - 16mm for the reference predicate.

9

Subject DeviceReference Predicate Device
ManufacturerNOVODENT SAAGS Medikal Urunleri Ith. Ihr. Tic. Ltd. Sti.
Trade NameImplantswiss Dental Implant SystemImplance Dental Implant System
510(k) No.K181266K160221
IndicationImplantswiss Dental Implant System is
indicated to use for surgical placement in
the upper and lower jaw arches, to
provide a root form means for single and
multiple units' prosthetic appliance
attachment to restore a patient's chewing
function. Implantswiss Dental Implant
can be placed with a conventional two
stage surgical process with an option for
transmucosal healing or they can be
placed in a single stage surgical process
for immediate loading. Immediate
loading is restricted to the anterior
mandible based on four splinted-
interforminal placed implants.
Implantswiss Dental Abutment System is
used with a dental implant to provide
support to prosthetic restorations such as
crown, bridge and overdentures in
partially or fully edentulous patients.
Octa and Multi-Unit Abutment models
that contain an abutment post height less
than 4 mm are indicated only for multi-
unit loading, such as a bridge or
overdentureImplance Dental Implant System is indicated
to use for surgical placement in the upper and
lower jaw arches, to provide a root form
means for single and multiple units' prosthetic
appliance attachment to restore a patient's
chewing function.
Implance Dental Implant can be placed with
a conventional two stage surgical process
with an option for transmucosal healing or
they can be placed in a single stage surgical
process for immediate loading. Immediate
loading is restricted to the anterior mandible
based on four splinted-interforminal placed
implants.
Implance Dental Abutment System is used
with a dental implant to provide support to
prosthetic restorations such as crown, bridge
and overdentures in partially or fully
edentulous patients. Octa Abutment models
that contain an abutment post height less
than 4 mm are indicated only for multi-unit
loading, such as a bridge or overdenture.
MaterialBone Level: Titanium Ti6Al4V ELI
ASTM F-136
Tissue Level: Commercially Pure
Titanium Grade 4 ASTM F-67
Screw: Titanium Ti6Al4V ELI ASTM
F136Bone Level: Titanium Ti6Al4V ASTM F-
136
Tissue Level: Titanium Grade 4 ASTM F-67
Screw: Titanium Ti6Al4V ASTM F136
Surface
TreatmentMachine SurfaceMachine Surface
SterileSteam Sterilization by user
(Delivered non sterile)Steam Sterilization by user
(Delivered non sterile)
Couple
Abutment
DesignImage: Couple Abutment DesignImage: Couple Abutment Design
Couple
Abutment
Diameters
(mm)Bone Level Implant: Ø 3.7 mm, Ø 4.5 mm
Tissue Level Implant: Ø 5.2 mm, Ø 6.4 mmBone Level Implant: Ø 3.7 mm, Ø 4.5 mm, Ø 5.5 mm, Ø 6.5 mm
Tissue Level Implant: Ø 5.2 mm, Ø 6.4 mm
Angled
Abutment
DesignImage: Angled Abutment DesignImage: Angled Abutment Design
Angled
Abutment
Diameters
(mm)Bone Level Implant (15°): Ø 3.7 mm,
Bone Level Implant (25°): Ø 4.5 mm,
Tissue Level Implant (15°): Ø 3.5 mmBone Level Implant (15°): Ø 3.7 mm,
Bone Level Implant (15°, 25°): Ø 4.5 mm, Ø 5.5 mm, Ø 6.5 mm
Solid
Abutment
DesignImage: Solid Abutment DesignImage: Solid Abutment Design
Solid
Abutment
Diameters
(mm)Bone Level Implant: Ø 3.7 mm, Ø 4.5 mm
Tissue Level Implant: Ø 3.5 mm, Ø 4.3 mmBone Level Implant: Ø 3.7 mm, Ø 4.5 mm, Ø 5.5 mm, Ø 6.5 mm
Tissue Level Implant: Ø 3.5 mm, Ø 4.3 mm
O-ring
Abutment
DesignImage: O-ring Abutment DesignImage: O-ring Abutment Design
Diameters
(mm)Bone Level Implant: Ø 2.9 mm, Ø 4.5 mm,Bone Level Implant: Ø 2.9 mm, Ø 3.42 mm, Ø 3.5 mm, Ø 4.5 mm,
Tissue Level Implant: Ø 3.5 mm
Multi
Abutment
DesignImage: Multi Abutment DesignImage: Multi Abutment Design
Diameters
(mm)Bone Level Implant: Ø 3.7 mm, Ø 4.5mm
Tissue Level Implant: Ø 5.2 mmBone Level Implant: Ø 3.7 mm, Ø 4.5 mm, Ø 5.5 mm
Tissue Level Implant: Ø 5.2 mm
Octa
Abutment
DesignImage: Octa Abutment DesignImage: Octa Abutment Design
Diameters
(mm)Bone Level Implant: Ø 4.8 mm
Tissue Level Implant: Ø 3.5 mmBone Level Implant: Ø 3.7 mm, Ø 4.5 mm,
Ø 5.5 mm, Ø 6.5 mm
Tissue Level Implant: Ø 3.7 mm, Ø 6.4 mm
Syoncta
Abutment
DesignImage: Syoncta Abutment DesignImage: Syoncta Abutment Design
Diameters
(mm)Tissue Level Implant: Ø 3.5 mmTissue Level Implant: Ø 3.5 mm
Healing
Abutment
DesignImage: Healing Abutment DesignImage: Healing Abutment Design
Diameters
(mm)Bone Level Implant: Ø 3.7 mm, Ø 4.5
mm
Tissue Level Implant: Ø 5.2 mmBone Level Implant: Ø 3.7 mm, Ø 4.5 mm,
Ø 5.5 mm, Ø 6.5 mm
Tissue Level Implant: Ø 3.7 mm, Ø 6.4 mm
Brief
ComparisonThe subject device is similar in size and
features as the predicate device
(K160221).

Implantswiss Dental Abutment System Substantial Equivalence Comparison

10

11

Implantswiss Locator abutment

Subject DeviceReference Predicate Device
ManufacturerNOVODENT SAZest Anchors, LLC
Trade NameImplantswiss Dental Implant
SystemLOCATOR RTx
510(k) No.K181266K150295
Indication for UseImplantswiss Dental Implant
System is indicated to use for
surgical placement in the upper
and lower jaw arches, to provide a
root form means for single and
multiple units' prosthetic
appliance attachment to restore a
patient's chewing function.
Implantswiss Dental Implant can
be placed with a conventional two
stage surgical process with an
option for transmucosal healing or
they can be placed in a single
stage surgical process forThe LOCATOR® RTx Attachment
System is designed
for use with overdentures or
partial dentures, retained in
whole or in part, by endosseous
implants in the mandible or
maxilla. LOCATOR®RTx
Attachment System is compatible
with the following implant systems.
Implant Manufacturer - System
BioHorizons - Internal Hex (3.0, 3.5,
4.5, 5.7mm) External Hex (3.5, 4.0,
5.0mm)
Biomet 3i - Certain Internal (3.4, 4.1,
5.0, 6.0 mm) External Hex (3.4, 4.1,
5.0, 6.0 mm)
immediate loading. Immediate
loading is restricted to the anterior
mandible based on four splinted-
interforminal placed implants.
Implantswiss Dental Abutment
System is used with a dental
implant to provide support to
prosthetic restorations such as
crown, bridge and overdentures in
partially or fully edentulous
patients. Octa and Multi-Unit
Abutment models that contain an
abutment post height less than 4
mm are indicated only for multi-
unit loading, such as a bridge or
overdenture.Camlog - Camlog and Conelog (3.3,
3.8, 4.3, 5.0 mm) iSy (3.8, 4.4, 5.0
mm)
Dentsply - Ankylos (3.5, 4.5, 5.5, 7.0
mm) XiVE/FRIALIT-2 (3.4, 3.8, 4.5,
5.5 mm) Astra Tech OsseoSpeed EV
(3.6, 4.2, 4.8mm)
MIS Implants - Internal Hex (3.75,
4.5 mm)
Nobel Biocare - Replace: Internal
(3.5, 4.3, 5.0, 6.0 mm) MobelActive:
Internal Conical (3.0, 3.5, 4.3, 5.0
mm) Branemark: External Hex (3.3,
3.75, 4.0, 5.0 mm)
Straumann - Tissue Level (3.5, 4.8,
6.5 mm) Bone Level (3.3, 4.1, 4.8
mm)
Zimmer - Tapered Screw Vent:
Internal Hex (3.5, 4.5, 5.7 mm) Spline
(3.25, 4.0, 5.0 mm) Swiss Plus:
Internal Octagon (3.8, 4.8 mm)
MaterialAbutments- Titanium Ti6Al4V
ELI ASTM F-136Abutments- Titanium Ti6Al4V
ELI ASTM F-136
SterileSteam Sterilization by user
(Delivered non sterile)Steam Sterilization by user
(Delivered non sterile)
Locator
Abutment DesignImage: Locator Abutment DesignImage: Locator Abutment Design
Diameters
(mm)Bone Level Implant: Ø 3.86 mm
Tissue Level Implant: Ø 3.86 mmDiameter: Ø 3.0 mm to Ø 7.0 mm
Bone Level: Ø 3.3 mm, Ø 4.1 mm, Ø 4.8 mm
Tissue Level: Ø 3.5 mm, Ø 4.8 mm, Ø 6.5 mm
Brief ComparisonThe Implantswiss Locator abutment is different than the LOCATOR
RTx, Reference Predicate Device (K150295) in the size of the
abutment.

12

13

Subject DeviceReference Predicate Device
ManufacturerNOVODENT SANobel Biocare AB
Trade NameImplantswiss Dental Implant
SystemNobelActive Multi Unit
Abutment
510(k) No.K181266K072570
IndicationImplantswiss Dental Abutment
System is used with a dental
implant to provide support to
prosthetic restorations such as
crown, bridge and overdentures in
partially or fully edentulous
patients. Implantswiss Multi-Unit
Supports prosthetic restoration for
bridge.NobelActive Multi Unit
Abutment is a pre-manufactured
prosthetic component directly
connected to the endosseous
dental implant and is intended
for use as an aid in prosthetic
rehabilitation.
MaterialAbutments and screws: Titanium
Ti6Al4V ELI ASTM F-136Abutments and screws - Titanium
vanadium alloy
SterileSteam Sterilization by user
(Delivered non sterile)Steam Sterilization by user
(Delivered non sterile)
Multi-Unit
Abutment DesignImage: Multi-Unit Abutment DesignImage: Multi-Unit Abutment Design
DiametersØ 4.8 (17°) mmØ 4.8 (0°, 17°, 30°) mm
Brief ComparisonThe Implantswiss Multi-Unit abutment is different than the Reference
Predicate Device (K072570) NobelActive Multi Unit Abutment, in the
angulation of the abutment.

Implantswiss Multi-Unit Abutment

The Implantswiss Dental Abutment System is the same or similar with respect to indication for use, material composition and basic design features as the predicate Implance Dental Abutments (K160221). The Implantswiss Locator abutment is different than the LOCATOR RTx, Reference Predicate Device (K150295) in the size of the abutment.

Multi-Unit abutments supports prosthetic restoration for bridge. Angular correction cannot be fabricated into the design of any of the Octa and Multi-Unit Abutment models when combined with casting plastic or cylinder during patient-specific customization. The Implantswiss Multi-Unit abutment is different than the Reference Predicate Device (K072570) NobelActive Multi Unit Abutment in the angulation of the abutment.

14

Summary of Non-clinical Testing

Performance testing of the Implantswiss Dental Implant and Implantswiss Dental Abutment followed the FDA guidance Class II Special Controls Guidance Document: Rootform Endosseous Dental Implants and Endosseous Dental Abutments.

Biocompatibility

Biocompatibility testing was conducted according to ISO 10993-1:2009"Biological evaluation of medical devices-Part 1: Evaluation and testing within risk management process" and the biocompatibility evaluation flow chart according to the FDA Guidance document "Use of International Standard ISO 10993-1, 'Biological evaluation of medical devices-Part 1: Evaluation and testing within a risk management process', Guidance for Industry and Food and Drug Administration Staff, Document issued on: June 16, 2016" for each of the subject devices Fixture has been conducted the following biocompatibility test:

  • Cytotoxicity (in vitro) ISO 10993-5:2009 .
  • Sensitization- ISO 10993-10:2010 . - ISO 10993-12:2012
  • Irritation/ Intracutaneous Toxicity - ISO 10993-10:2010
  • . Implantation test - ISO 10993-6:2016
    • ISO 10993-12:2012
  • . Chemical Analysis - IS0 10993-12
    • Semi volatile Organics (SVOC) Method:8270D
    • Volatile Organic Compounds (VOC) Method: 8260C

Sterilization and Shelf Life

Implantswiss Dental Implants are sterilized using a gamma ray sterilization process ISO 11137-1 and ISO 11737-2 that has been validated to ensure a SAL of 106. LAL testing was conducted in accordance with USP .

The Implantswiss Dental Abutment System is provided non-sterile. The recommended end-user steam gravity sterilization method and sterilization parameters have been validated to achieve an SAL of 10-6 according to ISO 17665-1. ISO 17665-2 and ISO 11737-2.

15

Packaging testing of accelerated aged and real-time aged product demonstrated that the sterility of the Implantswiss Dental Implant System is maintained over the 2-year shelf life period. Below tests are performed:

-Visual Inspection ASTM F1886 -Dye Penetration ASTM F1929-15 -Seal Peel Strength Test BS EN 868-5:2009 -Sterility test

Mechanical Testing

Fatigue testing, in accordance with ISO 14801 Dentistry- Implants-Dynamic fatigue test for Endosseous Dental Implants, was performed on the worst-case bone level Implantswiss Dental Implant mated with the worst case Implantswiss Dental Abutment. Results of the fatigue testing found that the worst case (bone level) dental implant/abutment combinations was consistent with FDA Class II Special Controls guidance and ISO 14801.

Fatigue testing, in accordance with ISO 14801 Dentistry- Implants-Dynamic fatigue test for Endosseous dental implants, referenced in K160221 was performed on the worst-case tissue level Implance Dental Implant (K160221) mated with the worst case Implance Dental Abutment (K160221). Results of the fatigue testing found that the worst case (tissue level) dental implant/abutment combinations was consistent with FDA Class II Special Controls guidance and ISO 14801.

Surface analysis of the implant body after the SRA process was conducted using Scanning Electron Microscopy (SEM) and Energy Dispersive X-ray Spectroscopy(EDS). SEM found that the implant surface had a homogeneous structure.

Non-clinical performance testing consistent with the FDA's Class II Special Controls guidance document and ISO 14801 support the substantial equivalence of the Implantswiss Dental Implant System and the Implantswiss Dental Abutment System.

Conclusion

Based on the similar designs, materials and applicable performance data, the Implantswiss Dental Implant System is substantially equivalent to the identified predicate devices.