K Number
K191806
Device Name
Propex IQ Apex Locator
Manufacturer
Date Cleared
2019-10-03

(90 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Propex IQ® Apex Locator supports the dentist in the determination of the working length during the endodontic treatment. The use of this product is intended exclusively for duly qualified dental practitioners.
Device Description
The proposed Propex IQ® Apex Locator is a microprocessor-controlled device that supports the dentist during endodontic treatments for the determination of the file to the reference point for endodontic working length determination. To do so, the proposed Propex IQ® Apex Locator assesses the electrical resistance of the tooth and surrounding tissues while the file is inserted and moving along the root canal. The proposed Propex IQ® Apex Locator product configuration consists of the following components: - The proposed Propex IO® Apex Locator - The proposed Propex IQ® Apex Locator Measurement cable - The Proposed X-Smart IO® Measurement Cable - The proposed Propex IQ® Apex Locator External Tester - The Propex IQ® Disposable Barrier Sleeve - The proposed Propex IQ® Lip clip - The proposed Propex IQ® File clip - The proposed Propex IQ® Clamp - Propex IQ® Charger and AC Adapter Plugs
More Information

No
The description focuses on electrical resistance measurement and microprocessor control, with no mention of AI/ML terms or related concepts like training/test data.

No.
The device determines the working length during endodontic treatment, but it does not directly treat a condition or disease.

Yes

Explanation: The device is described as supporting "the dentist in the determination of the working length during the endodontic treatment" by assessing "the electrical resistance of the tooth and surrounding tissues." This function of providing information for diagnosis (determining working length) during a medical procedure qualifies it as a diagnostic device.

No

The device description explicitly lists multiple hardware components, including the device itself, cables, an external tester, clips, a clamp, and a charger. The performance studies also include hardware requirements verification tests.

Based on the provided information, the Propex IQ® Apex Locator is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • Intended Use: The intended use is to "support the dentist in the determination of the working length during the endodontic treatment." This is a direct measurement taken in vivo (within the living patient's tooth and surrounding tissues) to guide a surgical procedure (endodontic treatment).
  • Device Description: The device assesses "electrical resistance of the tooth and surrounding tissues while the file is inserted and moving along the root canal." This is a physical measurement of electrical properties within the body, not an analysis of a sample taken from the body.
  • Lack of Sample Analysis: IVD devices typically analyze samples taken from the human body (like blood, urine, tissue, etc.) to provide information about a patient's health or condition. This device does not analyze any such sample.

The Propex IQ® Apex Locator is a medical device used in vivo to assist in a dental procedure. It falls under the category of devices used for measurement and guidance during treatment, not for diagnostic testing of biological samples.

N/A

Intended Use / Indications for Use

Propex IQ® Apex Locator supports the dentist in the determination of the working length during the endodontic treatment. The use of this product is intended exclusively for duly qualified dental practitioners.

Product codes

LQY

Device Description

The proposed Propex IQ® Apex Locator is a microprocessor-controlled device that supports the dentist during endodontic treatments for the determination of the file to the reference point for endodontic working length determination. To do so, the proposed Propex IQ® Apex Locator assesses the electrical resistance of the tooth and surrounding tissues while the file is inserted and moving along the root canal. The proposed Propex IQ® Apex Locator product configuration consists of the following components:

  • The proposed Propex IO® Apex Locator
  • The proposed Propex IQ® Apex Locator Measurement cable
  • The Proposed X-Smart IO® Measurement Cable
  • The proposed Propex IQ® Apex Locator External Tester
  • The Propex IQ® Disposable Barrier Sleeve
  • The proposed Propex IQ® Lip clip
  • The proposed Propex IQ® File clip
  • The proposed Propex IQ® Clamp
  • Propex IQ® Charger and AC Adapter Plugs

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Tooth / root canal

Indicated Patient Age Range

Not Found

Intended User / Care Setting

duly qualified dental practitioners / hospital environments, clinics or dental offices / professional healthcare facility environment

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)

  • Biocompatibility: "The patient contacting part of the proposed Propex IQ® Apex Locator (the lip clip component) is composed of identical materials and fabricated using the same methods as the same component used with the primary predicate device (K131907). Therefore, no new biocompatibility data is included in support of substantial equivalence."
  • Electrical safety: "The proposed Propex IQ® Apex Locator was tested for Electrical safety and Electromagnetic testing." Standard: "IEC 60601-1:2005 (Third Edition) + CORR. 1:2006 + CORR. 2:2007 + A1:2012 (or IEC 60601-1: 2012 reprint) Medical electrical equipment - Part 1 : general requirements for safety". Results: "The proposed Propex IQ® Apex Locator conforms to the standard requirements."
  • Electromagnetic compatibility: "The proposed Propex IQ® Apex Locator was tested for Electrical safety and Electromagnetic testing." Standard: "IEC 60601-1-2:2014 (Fourth Edition) Medical electrical equipment - Part 1-2 : General requirements for basic safety and essential performance - Collateral standard: electromagnetic compatibility Requirements and tests". Results: "The proposed Propex IQ® Apex Locator conforms to the standard requirements."
  • Software Verification and Validation: "Software Verification and Validation tests were conducted in accordance with IEC 62304:2015 and FDA software validation guidance "General Principles of Software Validation; Final Guidance for Industry and FDA Staff, Document issued on: January 11, 2002"."
  • Accuracy Testing with RAYPEX® 6 (K131907): Internal test method. Results: "It is shown that the performance of the proposed Propex IQ® Apex Locator is equivalent to that of primary predicate device RAYPEX6 (K131907) within the scope of this test."
  • Accuracy Testing with Root ZX II Apex Locator (K071190): Internal test method. Results: "It is shown that the performance of the proposed Propex IQ® Apex Locator is equivalent to that of reference device: Root ZX II Apex Locator (K071190) within the scope of this test."
  • Disinfectant Resistance Testing: Standard: "ISO 21530 (Dentistry -- Materials used for dental equipment surfaces -- Determination of resistance to chemical disinfectants)". Results: "Applicable device components were assessed for resistance to chemical disinfectants and the results support substantial equivalence."
  • Information display latency: Internal test method. Results: "Device display latency in all modes was assessed and the results support substantial equivalence."
  • Hardware requirements verification tests: Internal Test Methods. Results: "Verification testing of the device hardware requirements including: battery performance, audio alarm performance, temperature testing, liquid ingress resistance, and mating components connection cycling is included, and the results support substantial equivalence."
  • Wireless coexistence: Standards: "AAMI TIR69: Risk Management of Radio-frequency Wireless Coexistence for Medical Devices and Systems ANSI C63.27-2017 American National Standard for Evaluation of Wireless Coexistence". Results: "The proposed Propex IQ® Apex Locator maintained functional wireless performance in the presence of unintended signals."
  • Usability Study: Standards/Guidance: "FDA Guidance: "Applying Human Factors and Usability Engineering to Medical Devices - Guidance for Industry and Food and Drug Administration Staff ANSI-AAMI_HE75:2009/ (R) 2013 Human factors engineering - Design of medical devices AAMI / ANSI / IEC 62366-1:2015 Medical devices -Part 1: Application of usability engineering to medical devices (General I (QS/RM)) IEC TR 62366-2:2016 Medical devices – Part 2: Guidance on the application of usability engineering to medical devices IEC 60601-1-6 Edition 3.1 2013-10 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability". Results: "Usability Studies conducted showed that users were able to use the device correctly and safely without use error."
  • Clinical Performance Data: "No human clinical data were included to support substantial equivalence."

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

Not Found

Predicate Device(s)

K131907

Reference Device(s)

K161213, K071190

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

N/A

0

Image /page/0/Picture/0 description: The image contains two logos. On the left is the Department of Health & Human Services logo. On the right is the FDA logo, which includes the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

October 3, 2019

Dentsply Sirona Karl Nittinger Director, Corporate Regulatory Affairs 221 West Philadelphia Street Suite 60W York, Pennsylvania 17401

Re: K191806

Trade/Device Name: Propex IQ Apex Locator Regulatory Class: Unclassified Product Code: LQY Dated: September 4, 2019 Received: September 5, 2019

Dear Karl Nittinger:

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

Indications for Use

510(k) Number (if known) K191806

Device Name Propex IQ® Apex Locator

Indications for Use (Describe)

Propex IQ® Apex Locator supports the dentist in the determination of the working length during the endodontic treatment. The use of this product is intended exclusively for duly qualified dental practitioners.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

[ ] Over-The-Counter Use (21 CFR 801 Subpart C)

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3

Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401

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SECTION 5. 510(k) SUMMARY

for K191806 Propex IQ® Apex Locator

1. Submitter Information:

Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401

Contact Person:Karl Nittinger
Telephone Number:717-849-4424
Fax Number:717-849-4343

Date Prepared: September 20, 2019

2 Device Name:

  • Propex IQ® Apex Locator Proprietary Name: .
    • Classification Name: Locator, Root Apex
  • CFR Number: N/A .
  • Device Class: Unclassified ●
  • Product Code: LOY .

3. Primary Predicate Device:

.

  • Primary Predicate Device Name: RAYPEX® 6 ●
  • 510(k): K131907
  • Company Name: Dentsply Sirona

Reference Devices:

  • Reference Device: X-Smart IQ® 1. 510(k): K161213 Company Name: Dentsply Sirona
    1. Reference Device: Root ZX II Apex Locator 510(k): K071190 Company Name: J. Morita Manufacturing Corp.
    1. Description of Device:

The proposed Propex IQ® Apex Locator is a microprocessor-controlled device that supports the dentist during endodontic treatments for the determination of the file to the reference point for endodontic working length determination. To do so, the proposed Propex IQ® Apex Locator assesses the electrical resistance of the tooth and surrounding tissues while the file is inserted and moving along the root canal. The proposed Propex IQ® Apex Locator product configuration consists of the following components:

4

  • The proposed Propex IO® Apex Locator ●
  • The proposed Propex IQ® Apex Locator Measurement cable
  • The Proposed X-Smart IO® Measurement Cable
  • . The proposed Propex IQ® Apex Locator External Tester
  • The Propex IQ® Disposable Barrier Sleeve
  • The proposed Propex IQ® Lip clip
  • The proposed Propex IQ® File clip
  • The proposed Propex IQ® Clamp
  • Propex IQ® Charger and AC Adapter Plugs

Modes of Operation:

The proposed Propex IQ® Apex Locator can be used with X-Smart IQ® Handpiece (K161213) and/or Endo IQ® App (K161213) in different modes. Summary of different modes of operations of the proposed Propex IQ® Apex Locator along with its interaction with X-Smart IQ®Handpiece (K161213) and Endo IQ® App (K161213) is summarized in the Table 5.1 below ("Yes" indicates that the device or components is utilized in the referenced Mode, "No" indicates that it is not utilized in the referenced Mode):

Table 5.1 Summary of the different modes of Operation of the proposed Propex IQ®
Apex Locator
ModeProposed
Propex IQ®
Apex LocatorX-Smart IQ®
HandpieceEndo IQ®
App
Uncombined, Unconnected
(Stand-Alone)yesnono
Combined, Unconnected
(combined with X-Smart IQ®
Handpiece) (stand-alone connected
to the iPad application)yesyesno
Uncombined, Connected (combined
with X-Smart IQ® Handpiece) (stand-
alone, connected to the Endo IQ®
App)yesnoyes
Combined, Connected
(combined to X-Smart IQ®
Handpiece and connected to the Endo
IQ® App)yesyesyes

റ Indications for Use:

Propex IQ® Apex Locator supports the dentist in the determination of the working length during the endodontic treatment. The use of this product is intended exclusively for duly qualified dental practitioners.

5

6. Substantial Equivalence:

Table 5.2 compares the proposed device, Propex IQ® Apex Locator, and the primary predicate device, RAYPEX 6®. Technological similarities and differences are as follows:

Table 5.2 Comparison between the primary predicate device, RAYPEX® 6 (K131907), and the proposed, Propex IQ® Apex Locator
ElementPrimary Predicate
Device
RAYPEX® 6 (K131907)Proposed Device
Propex IQ® Apex LocatorSimilarities/Differences
Indication for
UseRAYPEX® 6 is a microprocessor controlled
device used for locating the apex.Propex IQ® Apex Locator supports the dentist in the
determination of the working length during the
endodontic treatment. The use of this product is
intended exclusively for duly qualified dental
practitioners.Both the proposed Propex
IQ® Apex Locator and the
primary predicate
RAYPEX® 6 (K131907)
are indicated to assist in the
determination of the length
of the root canal space.
Use with X-
Smart IQ®
Handpiece
(Product code:
EBW, K161213)Cannot be used with any hand-pieceCan be used with only X-Smart IQ® Handpiece
(K161213) (in combined mode).The proposed Propex IQ® is
designed to function in
combined mode with the
reference X-Smart IQ®
handpiece (K161213).
Combined mode facilitates
consolidation of working
steps when the X-Smart IQ®
Handpiece (K161213) is
used.
Use with Endo
IQ® App
(K161213)Cannot be used with Endo IQ® App
(K161213)Can be used in standalone mode without Endo
IQ® App (K161213) or with the Endo IQ® AppEndo IQ® App (K161213)
gives interactive
information (real time
graphs, images) and
access to pre- and post-
operation information. The
predicate device
(K131907) incorporates
interactive real-time
information in its integral
user interface display.
Table 5.2 Comparison between the primary predicate device, RA YPEX® 6 (K131907), and the proposed, Propex IQ® Apex Locator
ElementPrimary Predicate
Device
RAYPEX® 6 (K131907)Proposed Device
Propex IQ® Apex LocatorSimilarities/Differences
BluetoothNo Bluetooth functionalityCan be connected to Endo IQ® App (K161213)
via Bluetooth and have Bluetooth function to
transfer the data to the Endo IQ® AppBluetooth is used to connect
and transfer the data with Endo
IQ® App. The Endo IQ® App
(K161213) interactive
information (real time graphs,
images) and access to pre- and
post- operation information.
The predicate device
(K131907) incorporates
interactive real-time
information in its integral user
interface display.
Working
EnvironmentThis product must be used in hospital
environments, clinics or dental offices by
qualified dental personnel.This product must be used in professional
healthcare facility environment by qualified dental
personnel.The proposed Propex IQ®
Apex Locator and the predicate
RAYPEX® 6 (K131907) are
both intended for use within
the same clinical environments.

6

7

Table 5.2 Comparison between the primary predicate device, RAYPEX® 6 (K131907), and the proposed, Propex IQ® Apex Locator
ElementPrimaryPredicate
Device
RAYPEX® 6 (K131907)Proposed Device
Propex IQ® Apex
LocatorSimilarities/Differences
Means of inputOn/off pushbutton
Touch Panel• On/off pushbutton
• Bluetooth button
• Endo IQ® App (K161213)The proposed Propex IQ® Apex
Locator can be connected to
Endo IQ® App (K161213) via
Bluetooth. In Stand-alone mode
it can be used without Endo IQ®
App (K161213) using on/off
push buttons. The predicate
RAYPEX® 6 (K1311907)
incorporates an integral touch
screen user interface.
Patient contacting
components
material
compositionLip Clip: Stainless steel
File Clip: Gold plated beryllium copper, glass filled nylonLip Clip: Stainless Steel
File Clip: Gold plated beryllium copper, glass
filled nylonThe proposed Propex® IQ Apex
Locator and the predicate device
(K131907) utilize the same
patient contacting accessory
components.
Power supplyRechargeable Ni-MH batteryRechargeable Ni-MH batteriesBoth the proposed Propex® IQ
Apex locator and the predicate
device (K131907) utilize
rechargeable Ni-MH batteries.
Table 5.2 Comparison between the primary predicate device, RAYPEX® 6 (K131907), and the proposed, Propex IQ® Apex Locator
ElementPrimary Predicate
Device
RAYPEX® 6 (K131907)Proposed Device
Propex IQ® Apex
LocatorSimilarities/Differences
Display3.5 inch color display.No display on the device, only multi-color LEDs to indicate status during the working length determination.Different user interface, no screen in Propex IQ® Apex Locator. When working in unconnected mode, the proposed Propex IQ® Apex Locator gives an indication of estimated file position using visual signals (the color of the central LED) and auditory signals. When connected to Endo IQ® App (K161213), the larger display of the iPad® will display the file progression along the root canal in the form of colored bars.
Adjustment
before
measurementNot requiredNot requiredNeither the proposed Propex IQ® Apex Locator nor the predicate device (K131907) require adjustment prior to estimation of the length of the root canal space.
CalibrationNot requiredNot requiredNeither the proposed Propex IQ® Locator nor the predicate RAYPEX® 6 (K131907) require calibration prior to estimation of the length of the root canal space.
Table 5.2 Comparison between the primary predicate device, RAYPEX® 6 (K131907), and the proposed, Propex IQ® Apex Locator
ElementPrimary Predicate
Device
RAYPEX® 6 (K131907)Proposed
Device Propex
IQ® Apex
LocatorSimilarities/Differences
Electronic
designThe electronic design utilizes
microcontroller based electronic circuit and
TFT color matrix graphic display.The electronic design is based on a custom PCB
design with miniaturized electronic components.
A Bluetooth module is included for connectivity
with iPad. The audio-visual feedback to the user
is generated using a buzzer for sound emission
and multi-color LEDs for visual feedback. No
screen or graphic display is available on the
device, there are only multi-colored LEDs for
visual feedback.The difference in electronic
design of two devices relates to
functionality, performance and
dimensions of the proposed
device.
SterilizationLip clip and file clip are user sterilized by
steam sterilizationLip clip and file clip are user sterilized by
steam sterilization.Both the proposed Propex® IQ
Apex Locator and the predicate
device utilize the same lip clip
and file clip accessory
components to facilitate the
estimation of the length of the
root canal space. These reusable
components are intended in both
cases as reusable accessories
which are end-user sterilized by
steam sterilization.

8

9

10

7. Summary of Non-Clinical Performance Data

Biocompatibility: The patient contacting part of the proposed Propex IQ® Apex Locator (the lip clip component) is composed of identical materials and fabricated using the same methods as the same component used with the primary predicate device (K131907). Therefore, no new biocompatibility data is included in support of substantial equivalence.

Electromagnetic compatibility and electrical safety:

The proposed Propex IQ® Apex Locator was tested for Electrical safety and Electromagnetic testing. Table 5.3 below summarizes EMC and Electrical safety testing.

Table 5.3 Summary of Electrical safety and Electromagnetic compatibility
TestStandardResults
Electrical safetyIEC 60601-1:2005 (Third Edition) + CORR.
1:2006 + CORR. 2:2007 + A1:2012 (or IEC
60601-1: 2012 reprint) Medical electrical
equipment - Part 1 : general requirements for
safetyThe proposed Propex IQ®
Apex Locator conforms to
the standard requirements.
Electromagneti
c compatibilityIEC 60601-1-2:2014 (Fourth Edition)
Medical electrical equipment - Part 1-2 :
General requirements for basic safety and
essential performance - Collateral
standard: electromagnetic compatibility
Requirements and testsThe proposed Propex IQ®
Apex Locator conforms to
the standard requirements.

Software Verification and Validation: Software Verification and Validation tests were conducted in accordance with IEC 62304:2015 and FDA software validation guidance "General Principles of Software Validation; Final Guidance for Industry and FDA Staff, Document issued on: January 11, 2002".

Performance Testing: In addition to biocompatibility, electrical safety, EMC and software testing, the following non-clinical tests are included in support of substantial equivalence.:

Table 5.4 Performance testing on the proposed Propex IQ® Apex Locator
TestStandard/MethodResults
Accuracy
Testing with
RAYPEX®
6 (K131907)Internal test methodIt is shown that the performance of the
proposed Propex IQ® Apex Locator is
equivalent to that of primary predicate
device RAYPEX6 (K131907) within the
scope of this test.

11

Table 5.4 Performance testing on the proposed Propex IQ® Apex Locator
TestStandard/MethodResults
Accuracy
Testing with
Root ZX II
Apex
Locator
(K071190)Internal test methodIt is shown that the performance of the
proposed Propex IQ® Apex Locator is
equivalent to that of reference device: Root
ZX II Apex Locator (K071190) within the
scope of this test.
Disinfectant
Resistance
TestingISO 21530 (Dentistry --
Materials used for dental
equipment surfaces --
Determination of resistance to
chemical disinfectants)Applicable device components were assessed
for resistance to chemical disinfectants and
the results support substantial equivalence.
Information
display
latencyInternal test methodDevice display latency in all modes was
assessed and the results support substantial
equivalence.
Hardware
requirements
verification
tests.Internal Test MethodsVerification testing of the device hardware
requirements including: battery performance,
audio alarm performance, temperature testing,
liquid ingress resistance, and mating
components connection cycling is included,
and the results support substantial
equivalence.
Wireless
coexistenceAAMI TIR69: Risk
Management of Radio-
frequency Wireless
Coexistence for Medical
Devices and Systems
ANSI C63.27-2017 American
National Standard for
Evaluation of Wireless
CoexistenceThe proposed Propex IQ® Apex Locator
maintained functional wireless performance
in the presence of unintended signals.

12

Table 5.5 Usability testing on the proposed Propex IQ® Apex Locator
TestStandard/GuidanceResults
Usability
StudyFDA Guidance: "Applying Human Factors and
Usability Engineering to Medical Devices -
Guidance for Industry and Food and Drug
Administration Staff ANSI-AAMI_HE75:2009/ (R) 2013 Human factors
engineering - Design of medical devices AAMI / ANSI / IEC 62366-1:2015 Medical devices
-Part 1: Application of usability engineering to
medical devices (General I (QS/RM)) IEC TR 62366-2:2016 Medical devices – Part 2:
Guidance on the application of usability engineering
to medical devices IEC 60601-1-6 Edition 3.1 2013-10 Medical
electrical equipment - Part 1-6: General
requirements for basic safety and essential
performance - Collateral standard: UsabilityUsability Studies
conducted showed
that users were able
to use the device
correctly and safely
without use error.

Clinical Performance Data 8.

No human clinical data were included to support substantial equivalence.

  • Conclusion Regarding Substantial Equivalence 9.
    Information included in this premarket notification supports the substantial equivalence of the proposed Propex IQ® Apex Locator. The proposed device has the identical intended use as the primary predicate device cleared under premarket notification K131907. The proposed Propex IQ® Apex Locator also has similar indications for use and incorporates the same fundamental technology as the primary predicate device (K131907).

Performance, safety, and software validation test data demonstrate the performance of the subject Propex IQ® Apex Locator device against its design, functional, and safety requirements. The results of the testing support a determination of substantial equivalence.