K Number
K190082
Device Name
Straumann BLX Variobase Abutment
Date Cleared
2019-04-17

(90 days)

Product Code
Regulation Number
872.3630
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Straumann® Variobase® prosthetic components directly or indirectly connected to the endosseous dental implant are intended for use as an aid in prosthetic rehabilitations. The prosthetic restoration (crowns) can be cemented onto the Straumann® Variobase® prosthetic components. A temporary restoration can be used prior to the insertion of the final components to maintain, stabilize and shape the soft tissue during the healing phase. They must be placed out of occlusion. Final abutments and restorations may be placed into occlusion when the implant is fully osseointegrated. All digitally designed copings and/or crowns for use with the Straumann® Variobase® Abutment system are intended to be sent to Straumann for manufacture at a validated milling center.
Device Description
BLX Variobase abutments are two-piece abutments composed of the following components: Variobase™ Abutment (Ti-base), Prosthetic restoration (coping or crown), Basal Screw. The BLX Variobase abutments are titanium bases to be used as the lower part of two-piece abutments. The upper part of the two-piece abutment is a CAD/CAM designed and manufactured restoration. The planning and milling of the customized restoration must be made using the validated Straumann CARES Visual, Dental Wings software using the Straumann CARES Visual Plug-In. All digitally designed copings and/or crowns for use on the Variobase abutments are intended to be manufactured at a validated milling center. The BLX Variobase Abutments are manufactured from TAN (titanium-aluminum-niobium alloy) and are available in different gingiva heights and diameters. The abutments are delivered with the corresponding basal screw. The prosthetic restoration (copings/crowns) can be cemented onto the Variobase abutment and then the set is screwed on the implant using the basal screw. The BLX Variobase Abutments will be marketed as a stand-alone component or through the CARES® X-Stream™ workflow (prosthetic restoration designed and manufactured through CARES® Visual/validated Straumann milling and then shipped together with the Straumann® BLX Variobase® Abutment and basal screw in the same shipment). The BLX Variobase abutments are cleared under K173961. The purpose of this premarket notification is to extend the Straumann BLX Implant System portfolio with additional materials for customized restorations (upper part of the two-piece abutment) for use with the BLX Variobase abutments (lower part of the twopiece abutment).
More Information

No
The summary describes a dental implant abutment system and its components, focusing on materials, manufacturing processes (CAD/CAM, milling), and mechanical testing. There is no mention of AI or ML in the intended use, device description, or performance studies. The software mentioned (Straumann CARES Visual, Dental Wings) is for CAD/CAM design, not AI/ML analysis.

No
The device, Straumann® Variobase® prosthetic components, is described as an aid in prosthetic rehabilitations for dental implants, and its function is to serve as a base for crowns, not to directly treat or cure a disease or condition.

No

Explanation: The device described, Straumann® Variobase® prosthetic components, is intended for use in prosthetic rehabilitations by connecting to dental implants for various types of restorations (crowns, copings). It is a structural component used to aid in the physical placement and support of dental prostheses. There is no mention of it collecting or analyzing data from the patient's body for diagnostic purposes within the provided text. Its function is restorative, not diagnostic.

No

The device description clearly outlines physical components (titanium bases, basal screws, prosthetic restorations) and manufacturing processes (milling), indicating it is a hardware device with associated software for design.

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

Here's why:

  • Intended Use: The intended use clearly states the device is for "prosthetic rehabilitations" and is "directly or indirectly connected to the endosseous dental implant." This describes a physical component used in a surgical and restorative procedure within the body.
  • Device Description: The description details a "two-piece abutment" made of titanium alloy, designed to be screwed onto a dental implant. This is a mechanical device for supporting a dental restoration.
  • Lack of IVD Characteristics: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue, etc.) to provide information for diagnosis, monitoring, or treatment. The device itself is the treatment component.
  • Performance Studies: The performance studies described are "Dynamic fatique tests" on the implant-abutment system, which are mechanical tests, not diagnostic performance studies.

Therefore, the Straumann® Variobase® prosthetic components are a medical device used in dental surgery and prosthetics, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

Straumann® Variobase® prosthetic components directly or indirectly connected to the endosseous dental implant are intended for use as an aid in prosthetic rehabilitations. The prosthetic restoration (crowns) can be cemented onto the Straumann® Variobase® prosthetic components. A temporary restoration can be used prior to the insertion of the final components to maintain, stabilize and shape the soft tissue during the healing phase. They must be placed out of occlusion. Final abutments and restorations may be placed into occlusion when the implant is fully osseointegrated. All digitally designed copings and/or crowns for use with the Strauman® Variobase® Abutment system are intended to be sent to Straumann for manufacture at a validated milling center.

Product codes

NHA

Device Description

BLX Variobase abutments are two-piece abutments composed of the following components:

  • Variobase™ Abutment (Ti-base)
  • Prosthetic restoration (coping or crown)
  • Basal Screw

The BLX Variobase abutments are titanium bases to be used as the lower part of two-piece abutments. The upper part of the two-piece abutment is a CAD/CAM designed and manufactured restoration. The planning and milling of the customized restoration must be made using the validated Straumann CARES Visual, Dental Wings software using the Straumann CARES Visual Plug-In. All digitally designed copings and/or crowns for use on the Variobase abutments are intended to be manufactured at a validated milling center.

The BLX Variobase Abutments are manufactured from TAN (titanium-aluminum-niobium alloy) and are available in different gingiva heights and diameters. The abutments are delivered with the corresponding basal screw.

The prosthetic restoration (copings/crowns) can be cemented onto the Variobase abutment and then the set is screwed on the implant using the basal screw.

The BLX Variobase Abutments will be marketed as a stand-alone component or through the CARES® X-Stream™ workflow (prosthetic restoration designed and manufactured through CARES® Visual/validated Straumann milling and then shipped together with the Straumann® BLX Variobase® Abutment and basal screw in the same shipment).

The BLX Variobase abutments are cleared under K173961.

The purpose of this premarket notification is to extend the Straumann BLX Implant System portfolio with additional materials for customized restorations (upper part of the two-piece abutment) for use with the BLX Variobase abutments (lower part of the twopiece abutment).

Prosthetic Restoration Design and Materials
The following is an overview of the possible coping/crown materials:

  • Digital materials:
    • coron® (subject to this submission)
    • zerion® LT, ML or UTML (subject to this submission)
    • IPS e.max CAD (cleared by K173961)
    • polycon® ae (for temporary restorations, cleared by K173961)

The manufacturing of the coping and/or crown should follow the standard procedure according to the material manufacturer's instructions for use. The design of the digital coping and/or crown should follow the standard procedure according to the material manufacturer's instructions for use and Straumann's instructions for use.

Basal screws are used to fix the BLX Variobase Abutments to the dental implant, and can be also used during lab procedures to fix lab prosthetic parts on implant analogs. There is one basal screw for the RB platform and one for the WB platform. They have identical designs and differ only in color-coding (violet for RB and brown for WB) to ease the handling. They are provided along the abutments but they are also provided as standalone (replacement) screws. The BLX basal screws are manufactured from TAN.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

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:
Sterilization and Shelf Life:
The sterilization process for the BLX Variobase Abutments as recommended in the labeling was validated according to applicable recommendations in the FDA guidance document "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling, issued on March 17, 2015" and according to ISO 17655-1, Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices."

Biocompatibility:
Biocompatibility was evaluated according to ISO 10993-1:2009 "Biological evaluation of medical devices – Part 1: Evaluation and testing within a 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. No new issues of biocompatibility are raised for the subject devices and therefore, no additional biocompatibility testing was required.

Performance Testing Bench:
Dynamic fatique tests for the implant-abutment system were conducted according to the FDA guidance document "Guidance for Industry and FDA Staff – Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments" and according to ISO 14801, "Dentistry -- Implants -- Dynamic loading test for endosseous dental implants". The test results demonstrated the Straumann® BLX Implant/Variobase final abutment system is equivalent to the predicate and reference devices. The test environment was 0.9% NaCl at 37°.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K173961

Reference Device(s)

K170356, K162890, K142890

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 872.3630 Endosseous dental implant abutment.

(a)
Identification. An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.(b)
Classification. Class II (special controls). 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.)

0

Indications for Use

510(k) Number (if known) K190082

Device Name Straumann® BLX Variobase Abutment

Indications for Use (Describe)

Straumann® Variobase® prosthetic components directly or indirectly connected to the endosseous dental implant are intended for use as an aid in prosthetic rehabilitations. The prosthetic restoration (crowns) can be cemented onto the Straumann® Variobase® prosthetic components. A temporary restoration can be used prior to the insertion of the final components to maintain, stabilize and shape the soft tissue during the healing phase. They must be placed out of occlusion. Final abutments and restorations may be placed into occlusion when the implant is fully osseointegrated. All digitally designed copings and/or crowns for use with the Strauman® Variobase® Abutment system are intended to be sent to Straumann for manufacture at a validated milling center.

Type of Use (Select one or both, as applicable)

☑ Prescription Use (Part 21 CFR 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801

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Subpart C)

1

Straumann®BLX Variobase Abutment

510(k) Summary

510(k) Summary 5

Submitter's Contact Information 5.1

Straumann USA, LLC (on behalf of Institut Straumann AG)

60 Minuteman Road

Andover, MA 01810

Phone Number:1-978-747-2509
-------------------------------

Fax Number: 1-978-747-0023

Contact Person: Jennifer M. Jackson, MS

Prepared by: Viviana Horhoiu

Date of Submission: April 16, 2019

5.2 Name of the Device

Trade Names:Straumann® BLX Variobase Abutment
Common Name:Endosseous Dental Implant Abutment
Classification Name:Endosseous Dental Implant Abutment
Regulation Number:21 CFR 872.3630
Classification:Class II
Product Codes:NHA

5.3 Predicate Device(s)

Primary Predicate Device:

  • . K173961 – Straumann BLX Implant System
    Reference Devices:

  • K170356 Straumann Variobase Abutments .

  • K162890 Small Diameter Implant (SDI) ●

  • . K142890 – Straumann® Variobase Abutments

2

Straumann®BLX Variobase Abutment

510(k) Summary

5.4 Device Description

BLX Variobase abutments are two-piece abutments composed of the following components:

  • . Variobase™ Abutment (Ti-base)
  • Prosthetic restoration (coping or crown) .
  • . Basal Screw

The BLX Variobase abutments are titanium bases to be used as the lower part of two-piece abutments. The upper part of the two-piece abutment is a CAD/CAM designed and manufactured restoration. The planning and milling of the customized restoration must be made using the validated Straumann CARES Visual, Dental Wings software using the Straumann CARES Visual Plug-In. All digitally designed copings and/or crowns for use on the Variobase abutments are intended to be manufactured at a validated milling center.

The BLX Variobase Abutments are manufactured from TAN (titanium-aluminum-niobium alloy) and are available in different gingiva heights and diameters. The abutments are delivered with the corresponding basal screw.

The prosthetic restoration (copings/crowns) can be cemented onto the Variobase abutment and then the set is screwed on the implant using the basal screw.

The BLX Variobase Abutments will be marketed as a stand-alone component or through the CARES® X-Stream™ workflow (prosthetic restoration designed and manufactured through CARES® Visual/validated Straumann milling and then shipped together with the Straumann® BLX Variobase® Abutment and basal screw in the same shipment).

The BLX Variobase abutments are cleared under K173961.

The purpose of this premarket notification is to extend the Straumann BLX Implant System portfolio with additional materials for customized restorations (upper part of the two-piece abutment) for use with the BLX Variobase abutments (lower part of the twopiece abutment).

Prosthetic Restoration Design and Materials

The following is an overview of the possible coping/crown materials:

3

Straumann® BLX Variobase Abutment

510(k) Summary

  • Digital materials: .
    • coron® (subject to this submission)
    • o zerion® LT, ML or UTML (subject to this submission)
    • IPS e.max CAD (cleared by K173961) o
    • o polycon® ae (for temporary restorations, cleared by K173961)

The manufacturing of the coping and/or crown should follow the standard procedure according to the material manufacturer's instructions for use. The design of the digital coping and/or crown should follow the standard procedure according to the material manufacturer's instructions for use and Straumann's instructions for use.

Basal screws are used to fix the BLX Variobase Abutments to the dental implant, and can be also used during lab procedures to fix lab prosthetic parts on implant analogs. There is one basal screw for the RB platform and one for the WB platform. They have identical designs and differ only in color-coding (violet for RB and brown for WB) to ease the handling. They are provided along the abutments but they are also provided as standalone (replacement) screws. The BLX basal screws are manufactured from TAN.

5.5 Indications for Use

Straumann® Variobase® prosthetic components directly or indirectly connected to the endosseous dental implant are intended for use as an aid in prosthetic rehabilitations. The prosthetic restoration (crowns) can be cemented onto the Straumann® Variobase® prosthetic components. A temporary restoration can be used prior to the insertion of the final components to maintain, stabilize and shape the soft tissue during the healing phase. They must be placed out of occlusion. Final abutments and restorations may be placed into occlusion when the implant is fully osseointegrated. All digitally designed copings and/or crowns for use with the Straumann® Variobase® Abutment system are intended to be sent to Straumann for manufacture at a validated milling center.

Technological Characteristics 5.6

The technological characteristics of the subject devices are compared to the primary predicate and reference devices in Table 1.

4

Straumann® BLX Variobase Abutment

510(k) Summary

SUBJECT DEVICEPRIMARY PREDICATEREFERENCE DEVICES
FEATUREStraumann BLX
Variobase AbutmentK173961
Straumann BLX
Implant SystemK170356
Straumann Variobase
AbutmentsK162890
Small Diameter Implant
(SDI)K142890
Straumann® Variobase
Abutments
Indications for
UseStraumann® Variobase®
prosthetic components
directly or indirectly
connected to the
endosseous dental implant
are intended for use as an
aid in prosthetic
rehabilitations. The
prosthetic restoration
(crowns) can be cemented
onto the Straumann®
Variobase® prosthetic
components. A temporary
restoration can be used prior
to the insertion of the final
components to maintain,
stabilize and shape the soft
tissue during the healing
phase; they must be placed
out of occlusion. Final
abutments and restorations
may be placed into
occlusion when the implant
is fully osseointegrated. All
digitally designed copings
and/or crowns for use with
the Straumann® Variobase®
Abutment system are
intended to be sent to
Straumann for manufacture
at a validated milling center.Straumann® Variobase®
prosthetic components
directly or indirectly
connected to the
endosseous dental implant
are intended for use as an
aid in prosthetic
rehabilitations. The
prosthetic restoration
(crowns) can be cemented
onto the Straumann®
Variobase® prosthetic
components. A temporary
restoration can be used prior
to the insertion of the final
components to maintain,
stabilize and shape the soft
tissue during the healing
phase; they must be placed
out of occlusion. Final
abutments and restorations
may be placed into
occlusion when the implant
is fully osseointegrated. All
digitally designed copings
and/or crowns for use with
the Straumann® Variobase®
Abutment system are
intended to be sent to
Straumann for manufacture
at a validated milling center.The Straumann® Variobase®
Abutment is a titanium base
placed onto Straumann
dental implants to provide
support for customized
prosthetic restorations.
Straumann® Variobase®
Abutments are indicated for
screw-retained single tooth
or cement-retained single
tooth and bridge
restorations. All digitally
designed copings and/or
crowns for use with the
Straumann® Variobase®
Abutment system are
intended to be sent to
Straumann for manufacture
at a validated milling center.Straumann® SC Variobase®
abutments are indicated for
use as an aid in prosthetic
rehabilitations. The
prosthetic restoration can be
cemented on the
Straumann® SC Variobase®
prosthetic components. A
temporary restoration can
be used prior to the insertion
of the final components to
maintain, stabilize and form
the soft tissue during the
healing phase. Final
abutments and restorations
may be placed into
occlusion when the implant
is fully osseointegrated. All
digitally designed copings
and/or crowns for use with
the Straumann® Variobase®
Abutment system are
intended to be sent to
Straumann for manufacture
at a validated milling center.The Straumann® Variobase®
Abutment is a titanium base
placed onto Straumann
dental implants to provide
support for customized
prosthetic restorations.
Straumann® Variobase®
Abutments are indicated for
screw-retained single tooth
or cement-retained single
tooth and bridge
restorations. All digitally
designed copings and/or
crowns for use with the
Straumann® Variobase®
Abutment system are
intended to be sent to
Straumann for manufacture
at a validated milling center.
MaterialTi-6Al-7NbTi-6Al-7NbTi-6Al-7NbTi-6Al-7NbTi-6Al-7Nb
Implant to
Abutment
ConnectionBLX
(with conical fitting)BLX
(with conical fitting)CrossFit®Small CrossFit® (SC)CrossFit®
synOcta® (RN/WN)
Prosthetic
Platform
DiameterØ 3.8 to 5.5 mmØ 3.8 to 5.5 mmØ 3.9 and 7.0 mmØ 3.3/4.3 mm
(minor/major oval
dimension)Ø 3.9 – 7.0 mm
SUBJECT DEVICEPRIMARY PREDICATEREFERENCE DEVICES
FEATUREStraumann BLX
Variobase AbutmentK173961
Straumann BLX
Implant SystemK170356
Straumann Variobase
AbutmentsK162890
Small Diameter Implant
(SDI)K142890
Straumann® Variobase
Abutments
Gingival Heights0.75 - 3.5 mm0.75 — 2.5 mm1.0 - 3.0 mm1.0 - 3.0 mm1.0 - 3.0 mm
Chimney
Heights5.5 mm
(can be reduced)5.5 mm
(can be reduced)3.5 - 4.5 mm6.7 – 8.7 mm
(overall height)3.5 - 4.5 mm
Design WorkflowWax-up or Straumann
CARES® Visual, Dental
Wings software using the
Straumann CARES
Visual Plug-In and
3ShapeWax-up or Straumann
CARES® Visual, Dental
Wings software using the
Straumann CARES
Visual Plug-In and
3ShapeWax-up or CADWax-up or Open CAD
CARES® VisualWax-up or Open CAD
Abutment
AngulationUp to 30°Up to 30°Up to 30°Up to 30°Up to 30°
Manufacturing
WorkflowStraumann MillingStraumann MillingStraumann MillingTraditional casting or
pressing or Straumann
MillingTraditional casting or
pressing or Straumann
Milling
Coping/ Crown
MaterialDigital materials:
coron®
zerion® LT
zerion® ML and UTMLDigital materials:
IPS e.max CAD
polycon® aeDigital materials:
zerion® ML and UTMLCast materials:
Type 4 metals (ISO 22674)
Base metal alloys (e.g.,
cobalt-chromium (CoCr))
Noble metal alloys (e.g.,
gold alloy)

Press materials:
IPS e.max® Press Ceramic

Digital materials:
coron®
zerion® LT
polycon® ae | Traditional Workflow:
Type 4 Metals (ISO 22674)
IPS e.max® Press Ceramic

Digital Workflow:
polycon® ae (temporary)
zerion® (permanent)
IPS e.max® CAD Ceramic
(permanent)
coron® (permanent) |
| Sterilization
Method | Non-sterile/
End user sterilized | Non-sterile/
End user sterilized | Non-sterile/
End user sterilized | Non-sterile/
End user sterilized | Non-sterile/
End user sterilized |

5

Straumann® BLX Variobase Abutment

510(k) Summary

Table 1 - Comparison of subject device versus reference devices (BLX Variobase Abutments)

6

Straumann® BLX Variobase Abutment

510(k) Summary

5.7 Performance Testing

Sterilization and Shelf Life:

The sterilization process for the BLX Variobase Abutments as recommended in the labeling was validated according to applicable recommendations in the FDA guidance document "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling, issued on March 17, 2015" and according to ISO 17655-1, Sterilization of health care products -- Moist heat -- Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices."

Biocompatibility:

Biocompatibility was evaluated according to ISO 10993-1:2009 "Biological evaluation of medical devices – Part 1: Evaluation and testing within a 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. No new issues of biocompatibility are raised for the subject devices and therefore, no additional biocompatibility testing was required.

Performance Testing Bench:

Dynamic fatique tests for the implant-abutment system were conducted according to the FDA guidance document "Guidance for Industry and FDA Staff – Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments" and according to ISO 14801, "Dentistry -- Implants -- Dynamic loading test for endosseous dental implants". The test results demonstrated the Straumann® BLX Implant/Variobase final abutment system is equivalent to the predicate and reference devices. The test environment was 0.9% NaCl at 37°.

5.8 Conclusion

The documentation submitted in this premarket notification demonstrates the BLX Variobase Abutments are substantially equivalent to the primary predicate and reference devices.

7

Image /page/7/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, and the FDA logo is on the right. The FDA logo includes the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue.

April 17, 2019

Institut Straumann AG % Jennifer Jackson Director, Regulatory Affairs Straumann USA, LLC 60 Minuteman Road Andover, Massachusetts 01810

Re: K190082

Trade/Device Name: Straumann® BLX Variobase Abutment Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: January 16, 2019 Received: January 17, 2019

Dear Jennifer Jackson:

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.

8

Page 2

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.htm); 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 1000-1050.

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 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,

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