K Number
K191527
Device Name
Visalys CemCore, Visalys Cem Core Try In Paste
Date Cleared
2019-11-08

(151 days)

Product Code
Regulation Number
872.3275
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Visalys® CemCore is a dual-curing, adhesive cementation and core build-up composite, which is intended to be used for: a) Permanent cementation of · crowns, bridges, inlays, veneers and adhesive bridges made of metal, ceramic, composite, hybrid and oxide ceramics • root posts and indirect core build-ups b) Composite for · adhesive core build-ups Visalys® CemCore Try In Paste is a water-soluble polyethylene glycol paste for shade matching: · To check the shade selected prior to permanent cementation with Visalys® CemCore. · For covering the cement joint to reduce a layer of inhibition.
Device Description
Visalys® CemCore is a dual-curing composite containing fluoride for adhesive cementation of indirect restorations and root posts and can be used to fabricate radiopaque core build-ups and abutment fillings. Due to the Active-Connect-Technology (ACT) Visalys® CemCore includes an additional initiator system for the optimization of the adhesive bond. BPA or BPA precursors are not used in the manufacturing process of this device. Visalys® CemCore shall only be used in combination with self-etching Visalys® Tooth Primer. Visalys® Restorative Primer is recommended as the primer for the restoration surfaces. Visalys® CemCore is easy to use and has high adhesive strength and good flowability with stable consistency. Visalys® CemCore is offered in the shades Universal (A2/A3), Dark (A4), Opaque, Bleach and Translucent. The paste should be mixed and dispensed directly from a double syringe with the corresponding mixing tips blue (MLø 3.2 mm). Visalys® CemCore Try in Paste serves to simulate the shade effect of the selected Visalys® CemCore shade on ceramic restorations and for covering the cement joint to reduce a layer of inhibition. The water-soluble paste corresponds in shade and translucence with the completely cured Visalys® CemCore. Visalys® CemCore Try In Paste is offered in the shades Universal (A2/A3), Dark (A4), Opaque, Bleach and Translucent. The paste is dispensed from a syringe and syringe tip.
More Information

No
The device description and performance studies focus on the material properties and mechanical performance of a dental cement and core build-up composite, with no mention of AI or ML technology.

No.
The device is described as an adhesive cementation and core build-up composite used for permanent cementation of dental restorations and core build-ups. It helps in the mechanical attachment and support of dental structures rather than treating or preventing a disease or condition directly.

No

Visalys® CemCore is a dual-curing, adhesive cement and core build-up composite used for permanent cementation and core build-ups. While it includes a "Try In Paste" for shade matching, this is for aesthetic selection and not for diagnosing a medical condition.

No

The device description clearly describes a physical composite material (paste) used for dental procedures, not a software application.

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

Here's why:

  • Intended Use: The intended use clearly describes the device as a dental material for permanent cementation of restorations and core build-ups. This is a therapeutic and restorative application, not a diagnostic one.
  • Device Description: The description details the composition and properties of a dental composite material. It does not mention any components or functions related to analyzing biological samples or providing diagnostic information.
  • Lack of Diagnostic Elements: There is no mention of analyzing blood, urine, tissue, or any other biological sample. The device is applied directly to the tooth structure.
  • Performance Studies: The performance studies focus on biocompatibility and mechanical properties relevant to a dental restorative material, not diagnostic accuracy metrics like sensitivity, specificity, etc.

In vitro diagnostics are devices used to examine specimens from the human body to provide information for diagnosis, monitoring, or screening. This device does not fit that definition.

N/A

Intended Use / Indications for Use

Visalys® CemCore is a dual-curing, adhesive cementation and core build-up composite, which is intended to be used for: a) Permanent cementation of · crowns, bridges, inlays, veneers and adhesive bridges made of metal, ceramic, composite, hybrid and oxide ceramics • root posts and indirect core build-ups b) Composite for · adhesive core build-ups
Visalys® CemCore Try In Paste is a water-soluble polyethylene glycol paste for shade matching: · To check the shade selected prior to permanent cementation with Visalys® CemCore. · For covering the cement joint to reduce a layer of inhibition.

Product codes

EBF

Device Description

Visalys® CemCore is a dual-curing composite containing fluoride for adhesive cementation of indirect restorations and root posts and can be used to fabricate radiopaque core build-ups and abutment fillings. Due to the Active-Connect-Technology (ACT) Visalys® CemCore includes an additional initiator system for the optimization of the adhesive bond. BPA or BPA precursors are not used in the manufacturing process of this device. Visalys® CemCore shall only be used in combination with self-etching Visalys® Tooth Primer. Visalys® Restorative Primer is recommended as the primer for the restoration surfaces. Visalys® CemCore is easy to use and has high adhesive strength and good flowability with stable consistency. Visalys® CemCore is offered in the shades Universal (A2/A3), Dark (A4), Opaque, Bleach and Translucent. The paste should be mixed and dispensed directly from a double syringe with the corresponding mixing tips blue (MLø 3.2 mm). Visalys® CemCore Try in Paste serves to simulate the shade effect of the selected Visalys® CemCore shade on ceramic restorations and for covering the cement joint to reduce a layer of inhibition. The water-soluble paste corresponds in shade and translucence with the completely cured Visalys® CemCore. Visalys® CemCore Try In Paste is offered in the shades Universal (A2/A3), Dark (A4), Opaque, Bleach and Translucent. The paste is dispensed from a syringe and syringe tip.

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

Biocompatibility tests have been performed to assure biological safety in accordance with the ISO 10993 family and ISO 7405. Tests in respect to cytotoxicity (ISO 10993-5), mutagenicity (OECD 487), sensitization (ISO 10993-10) and a chemical analysis (10993-18) showed, that the biocompatibility data of Visalys® CemCore is comparable to other materials on the market. Therefore no toxicological risks and resulting hazards for patients, users and third parties can be concluded. Additionally bench testing was performed to allow an evaluation of the mechanical properties of Visalys® CemCore in comparison to Visalys® Core (K143104/Secondary Predicate) and Multilink® Automix (K123397/Primary Predicate).

Key Metrics

Not Found

Predicate Device(s)

K123397, K143104, K002452

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 872.3275 Dental cement.

(a)
Zinc oxide-eugenol —(1)Identification. Zinc oxide-eugenol is a device composed of zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.(2)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 872.9.(b)
Dental cement other than zinc oxide-eugenol —(1)Identification. Dental cement other than zinc oxide-eugenol is a device composed of various materials other than zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.(2)
Classification. Class II.

0

Image /page/0/Picture/0 description: The image shows the logos of the Department of Health & Human Services and the Food and 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 letters "FDA" in a blue box, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

November 8, 2019

Kettenbach GmbH & Co. KG Katja Simon Regulatory Affairs Manager Im Heerfeld 7 Eschenburg, 35713 De

Re: K191527

Trade/Device Name: Visalys CemCore, Visalys Cem Core Try In Paste Regulation Number: 21 CFR 872.3690 Regulation Name: Tooth Shade Resin Material Regulatory Class: Class II Product Code: EBF Dated: August 9, 2019 Received: August 12, 2019

Dear Katja Simon:

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.

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

1

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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-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 Srinivas Nandkumar, Ph.D. Acting Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known) K191527

Device Name Visalys® CemCore Visalys® CemCore Try In Paste

Indications for Use (Describe)

Visalys® CemCore is a dual-curing, adhesive cementation and core build-up composite, which is intended to be used for: a) Permanent cementation of

· crowns, bridges, inlays, veneers and adhesive bridges made of metal,

ceramic, composite, hybrid and oxide ceramics

• root posts and indirect core build-ups

b) Composite for

· adhesive core build-ups

Visalys® CemCore Try In Paste is a water-soluble polyethylene glycol paste for shade matching:

· To check the shade selected prior to permanent cementation with Visalys® CemCore.

· For covering the cement joint to reduce a layer of inhibition.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

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"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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Image /page/3/Picture/0 description: The image contains the logo for KETTENBACH. The logo consists of a blue square with six white circles arranged in a triangular pattern at the top. Below the circles, the word "KETTENBACH" is written in a bold, sans-serif font. Underneath the company name, the tagline "Simply intelligent" is displayed in a smaller, sans-serif font.

K191527 510(k) Summary

A. Name and address of manufacturer:

Kettenbach GmbH & Co KG Im Heerfeld 7 35713 Eschenburg Germany Establishment Registration No.: 9681356 Owner/Operator Number: 9022134

Name, title and phone number of official correspondent:

Simon, Katja Requlatory Affairs Manager Im Heerfeld 7 35713 Eschenburg Germany Phone: + 49 277 4705 0 E-mail:_katja.simon@kettenbach.com

Name, title and phone number of U.S. Agent (Contact):

Roggenbau, Wilfried InterGest North America LLC. 400 Oser Ave., Suite 1650 Hauppauge, NY 11788 Phone: 631 5010500 ext Fax: 631 5011060 Email: roggenbauw@intergestna.com

Date of preparation:

October 30th, 2019

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Image /page/4/Picture/0 description: The image is a logo for KETTENBACH. The logo features a blue square with the word "KETTENBACH" in white letters. Above the word is a graphic of six white circles arranged in a triangular shape. Below the word is the phrase "Simply intelligent" in black letters. To the right of the blue square is a circled R symbol.

| B. Device Identification:
Device Trade Name:
Versions: | Visalys® CemCore
Visalys® CemCore
Universal (A2/A3), Dark (A4), Opaque, Bleach,
Translucent |
|--------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | Dual-curing, adhesive cementation and core build-up
composite |
| Device Identification:
Device Trade Name:
Versions: | Visalys® CemCore Try In Paste
Visalys® CemCore Try In Paste
Universal (A2/A3), Dark (A4), Opaque, Bleach,
Translucent |
| Common Name: | Water-soluble polyethylene glycol paste for shade
matching |

Classification of the device (Visalys® CemCore/Visalys® CemCore Try In Paste):

  • Device Classification Name: Dental cement 1. Product Code: EMA 2. Product Code: EBF Device Classification No.: Part 872.3690 Panel: Dental Regulatory Status: Class II
    tus:
    DC
    CH

C. Predicate devices:

| Applicant Product | Product Type | Product
Code | Predicate
Device | 510(k) No. | Product Code | Applicant |
|-------------------------|---------------|-----------------|---------------------------------------------|------------|--------------|-----------------------------|
| Visalys CemCore | Dental Cement | EBF | Visalys Core
(Secondary
Predicate) | K143104 | EBF | Kettenbach
GmbH & Co. KG |
| | | | Multilink Automix
(Primary
Predicate) | K123397 | EBF | Ivoclar Vivadent |
| Visalys Try In
Paste | Try In Paste | EBF | RelyX™ Try-In
Paste | K002452 | EMA | 3M Espe |

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Image /page/5/Picture/0 description: The image is a logo for KETTENBACH. The logo is set against a blue square background. The logo consists of seven white circles arranged in a triangular shape, with six circles forming the base and one circle at the apex. Below the circles, the word "KETTENBACH" is written in a bold, sans-serif font. Below the company name is the slogan "Simply intelligent".

D. Device Description:

Visalys® CemCore is a dual-curing composite containing fluoride for adhesive cementation of indirect restorations and root posts and can be used to fabricate radiopaque core build-ups and abutment fillings. Due to the Active-Connect-Technology (ACT) Visalys® CemCore includes an additional initiator system for the optimization of the adhesive bond. BPA or BPA precursors are not used in the manufacturing process of this device.

Visalys® CemCore shall only be used in combination with self-etching Visalys® Tooth Primer. Visalys® Restorative Primer is recommended as the primer for the restoration surfaces. Visalys® CemCore is easy to use and has high adhesive strength and good flowability with stable consistency.

Visalys® CemCore is offered in the shades Universal (A2/A3), Dark (A4), Opaque, Bleach and Translucent.

The paste should be mixed and dispensed directly from a double syringe with the corresponding mixing tips blue (MLø 3.2 mm).

Visalys® CemCore Try in Paste serves to simulate the shade effect of the selected Visalys® CemCore shade on ceramic restorations and for covering the cement joint to reduce a layer of inhibition. The water-soluble paste corresponds in shade and translucence with the completely cured Visalys® CemCore.

Visalys® CemCore Try In Paste is offered in the shades Universal (A2/A3), Dark (A4), Opaque, Bleach and Translucent.

The paste is dispensed from a syringe and syringe tip.

6

Image /page/6/Picture/0 description: The image is a logo for Kettenbach, a company that uses the tagline "Simply intelligent". The logo is set against a blue background and features a geometric design of six white circles arranged in a triangular shape. The company name "KETTENBACH" is printed in bold, sans-serif font below the geometric design. To the right of the geometric design is the registered trademark symbol.

E. Indications for Use:

Visalys® CemCore is a dual-curing, adhesive cementation and core build-up composite, which is intended to be used for:

  • Permanent cementation of a)
  • · crowns, bridges, inlays, veneers and adhesive bridges made of metal, ceramic, composite, hybrid and oxide ceramics
  • root posts and indirect core build-ups
  • b) Composite for
  • adhesive core build-ups

Visalys® CemCore Try In Paste water-soluble polyethylene glycol paste for shade matching

  • To check the shade selected prior to permanent cementation with Visalys® CemCore.
  • · For covering the cement joint to reduce a layer of inhibition.

7

Image /page/7/Picture/0 description: The image contains the logo for Kettenbach. The logo features a blue square with six white circles arranged in a pyramid shape at the top. Below the circles, the word "KETTENBACH" is written in a bold, sans-serif font, and below that, the phrase "Simply intelligent" is written in a smaller, sans-serif font.

F. Table 1: Comparison of technological characteristic with the predicate devices
------------------------------------------------------------------------------------
F. Table 1: Comparison of technological characteristic with the predicate devices
Predicate DevicesSubstantial Equivalent DeviceConclusion
ProductVisalys® Core (Secondary
Predicate)Multilink® Automix (Primary
predicate)Visalys® CemCore
ManufacturerKettenbachIvoclar VivadentKettenbach GmbH & Co. KG
Cure typeDual cureDual cureDual cure
Product
DescriptionVisalys Core is a dual-curing,
fluoride-containing composite
used for the fabrication of
radiopaque core build-ups and
core fillings.Multilink® Automix is a self-
curing luting composite with
light-curing option for the
adhesive luting of indirect
restorations made of metal,
metal-ceramic,
all-ceramic and composite.Visalys® CemCore is a dual-
curing adhesive containing
fluoride for adhesive
cementation of indirect
restorations and root posts.
Moreover, Visalys® CemCore
can be used to fabricate
radiopaque core build-ups
and abutment fillings.Visalys®
CemCore is
similar to
Multilink® Automix
(Primary
Predicate).
Additionally,
Visalys®
CemCore could
also be used for
adhesive core
build-ups.
Indication- Different types of core build-
ups
  • Luting of root posts | Multilink Automix and
    Multilink Primer are used for
    the permanent cementation
    of indirect restorations where
    a strong bond is desired:
  • Inlays, onlays, crowns,
    bridges and root posts made
    of
  • metal and metal-ceramics
  • all-ceramics, in particular
    opaque zirconium oxide
    ceramics
  • composites and fibre-
    reinforced composites | Permanent cementation of:
  • crowns, bridges, inlays,
    onlays, veneers and
    adhesive bridges made of
    metal, ceramic, composite,
    hybrid and oxide ceramics.
  • root posts and indirect core
    build-ups
    Composite for:
  • adhesive core build-ups | Visalys®
    CemCore is
    similar to
    Multilink® Automix
    (Primary
    Predicate).
    Visalys®
    CemCore could
    also be used for
    adhesive core
    build-ups as well
    as Visalys
    Core(Secondary
    Predicate) |
    | | Predicate Devices | Substantial Equivalent
    Device | Conclusion | |
    | Product | Visalys® Core (Secondary
    Predicate) | Multilink® Automix (Primary
    predicate) | Visalys® CemCore | |
    | Manufacturer | Kettenbach | Ivoclar Vivadent | Kettenbach GmbH & Co. KG | |
    | Cure type | Dual cure | Dual cure | Dual cure | |
    | Storage
    temperature | 4-24 °C / 40-75 °F | 2-28°C | 2-8 °C/36-46 °F | A storage in a
    fridge is for
    Visalys®
    CemCore
    recommended |
    | Available Shades | Dentin, White, Blue | Shades
    Multilink Automix is available
    in four shades with different
    degrees of
    translucency:
    – transparent (high
    translucency)
    – yellow (high translucency)
    – opaque (low translucency)
    – white (medium
    translucency) | Shades: Universal
    (A2/A3), Dark (A4), Opaque,
    Bleach und Translucent. | Similar to
    Multilink® Automix
    (Primary
    Predicate),
    Visalys®
    CemCore uses
    the same color
    range, an
    additional color
    Dark (A4) was
    included |
    | Application system | 1:1 cartridge
    1:1 syringe | 1:1 syringe | 1:1 syringe | Identical to
    Multilink® Automix
    (Primary
    Predicate) and
    Visalys® Core
    (Secondary
    Predicate). All
    uses the identical
    syringe system |

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Image /page/8/Picture/0 description: The image shows the logo for Kettenbach. The logo features a blue square with six white circles arranged in a triangular pattern. Below the square, the word "KETTENBACH" is written in a bold, sans-serif font. Underneath the company name is the tagline "Simply intelligent".

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Image /page/9/Picture/0 description: The image contains a logo for KETTENBACH. The logo features a blue square with six white circles arranged in a triangular pattern at the top. Below the circles, the word "KETTENBACH" is written in white, and below that, the phrase "Simply intelligent" is written in black.

G. Table 2: Device comparison Visalys® CemCore Try In Paste

Predicate DevicesSubstantial Equivalent DeviceConclusion
ProductRelyX™ Try-In PasteVisalys® Try In Paste
Manufacturer3M EspeKettenbach GmbH & Co. KG
Product DescriptionRelyX™ Try-In Pastes are used to guide the dentist
in the selection of the shade required for the final
cementation with 3M™ ESPE™ RelyX™ Veneer
cement and RelyX Utlimate adhesive resin cement.
The shades of RelyX Try-In paste specifically
match the final cured shade of RelyX Veneer
cement and RelyX Ultimate cement.Visalys® CemCore Try In Paste serves to simulate
the shade effect of the selected Visalys®
CemCore shade on ceramic restorations. The
water-soluble paste corresponds in shade and
translucence with the completely cured Visalys®
CemCore. Visalys® CemCore Try In Paste is
offered in the shades Universal (A2/A3), Dark
(A4), Opaque, Bleach and Translucent. Note:
Only once the cementation composite Visalys®
CemCore is fully polymerized and has attained its
final shade, the shade coordination with the try-in
paste is attained. Visalys® CemCore Try In Paste
only corresponds with the shades of Visalys®
CemCore.Similar,
Visalys®
CemCore Try
in Paste and
the predicate
have the same
indication.
IndicationsPaste for shade matching- Paste for shade matching
  • For covering the cement joint to reduce a layer
    of inhibition | The indication
    of both devices
    is identical.
    Visalys® Try In
    Paste can also
    be used for
    covering the
    cement joint to
    reduce a layer
    of inhibition |
    | Storage temperature | 2-25 °C/36 – 77 °F. | 15 - 25 °C/59 -77 °F. | For Visalys®
    CemCore Try
    in Paste
    storage at room
    Temperature is
    recommended. |
    | Application system | Syringe | Syringe | Similar |
    | | The results demonstrated the substantial equivalence to the predicate devices. | | |

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Image /page/10/Picture/0 description: The image is a logo for KETTENBACH. The logo is set on a blue background and features six white circles arranged in a triangular shape. Below the circles, the word "KETTENBACH" is written in a bold, sans-serif font. Underneath "KETTENBACH", the phrase "Simply intelligent" is written in a smaller, sans-serif font.

H. Substantial Equivalance:

Visalys® CemCore / Visalys® CemCore Try In Paste have the same indication as the above listed predicate devices (Table 1 and 2).

The technological characteristics of Visalys® CemCore / Visalys® CemCore Try In Paste are also substantially equivalent (Table 1 and 2).

l. Non-Clinical Performance Testing:

Visalys® CemCore

Biocompatibility tests have been performed to assure biological safety in accordance with the ISO 10993 family and ISO 7405. Tests in respect to cytotoxicity (ISO 10993-5), mutagenicity (OECD 487), sensitization (ISO 10993-10) and a chemical analysis (10993-18) showed, that the biocompatibility data of Visalys® CemCore is comparable to other materials on the market. Therefore no toxicological risks and resulting hazards for patients, users and third parties can be concluded.

Additionally bench testing was performed to allow an evaluation of the mechanical properties of Visalys® CemCore in comparison to Visalys® Core (K143104/Secondary Predicate) and Multilink® Automix (K123397/Primary Predicate).

Working timeacc. to ISO 4049 / 7.6_7.7 and ASTM D 4473
Cure pointacc. to ISO 4049 / 7.8 and ASTM D 4473
Depth of cureacc. to ISO 4049 / 7.10
Film thicknessacc. to ISO 4049 / 7.5
Volume shrinkageacc. to ISO 4049 /17304
Water sorptionacc. to ISO 4049 / 7.12
Solubilityacc. to ISO 4049 / 7.12
Radio-opacityacc. to ISO 4049 / 7.14
E-Modulus
(self-cure)acc. to ISO 4049 / 7.11
Flexural strength
(self-cure)acc. to ISO 4049 / 7.11
Compressive strength (self-
cure)acc. to ISO 9917-1, Annex D
Diametral tensile strength
(light-cure)acc. to ADA Specification No. 27 section 4.3.7
Shade consistencyReproduction of color shades/ANSI ADA Spec.
80
Color stabilityacc. to ISO 4049, section 7.13 and
ISO 7491/ANSI ADA Spec. 80 acc. to ISO 7491,
section 3.2.3
Visual comparison Visalys
CemCore / Visalys
CemCore Try In PasteColor comparison according to ISO 7491,
section 3.2.3, with three persons who perceive
color normally

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Image /page/11/Picture/0 description: The image contains the logo for KETTENBACH. The logo consists of a blue square with seven white circles arranged in a triangular pattern at the top. Below the circles, the word "KETTENBACH" is written in a bold, sans-serif font. Underneath the company name, the tagline "Simply intelligent" is written in a smaller, less bold font.

Rheological propertiesinternal test method
Shear bond strengthISO 20922/16506
ISO 16506 (Chapter A 2.2.5).

Visalys® CemCore Try In Paste

Biocompatibility tests have been performed to assure biological safety in accordance with the ISO 10993 family and ISO 7405. Tests in respect to cytotoxicity (ISO 10993-5) and a chemical analysis (10993-18) showed, that the biocompatibility data of Visalys® CemCore Try In Paste is comparable to other materials on the market. Therefore no toxicological risks and resulting hazards for patients, users and third parties can be concluded.

Additionally bench testing was performed to allow an evaluation of the properties of Visalys® CemCore Try In Paste

Visual comparison Visalys®Color comparison according to ISO 7491, section
CemCore / Visalys® CemCore Try
In Paste3.2.3, with three persons who perceive color
Layer of inhibitionnormally.
Internal test: Comparison between the surfaces with and without Visalys®CemCore Try In Paste, with three persons which haptically evaluated the stickiness of the different surfaces after curing with or without the previous application of the Visalys®CemCore Try In Paste

J. Clinical Performance Data

Visalys® CemCore / Visalys® CemCore Try In Paste Data from clinical studies was not provided.

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Image /page/12/Picture/0 description: The image is a logo for KETTENBACH. The logo is a blue square with six white circles arranged in a triangular shape at the top. Below the circles, the word "KETTENBACH" is written in white, sans-serif font. Underneath the company name is the slogan "Simply intelligent" in black, sans-serif font. To the right of the blue square is the registered trademark symbol.

K. Conclusion:

Based on similarities in technology and on indications for use, together with results nonclinical performance testing, we believe that Visalys® CemCore and Visalys® CemCore Try In Paste are substantially equivalent to the predicate devices.