K Number
K191890
Device Name
Elos Accurate Customized Abutment
Date Cleared
2020-02-06

(206 days)

Product Code
Regulation Number
872.3630
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Elos Accurate® Customized Abutments are intended for attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to a dental implant using the included Elos Prosthetic screw. The Elos Accurate® Customized Abutments are compatible with the implant systems listed in table 1: Table 1. Elos Accurate Customized Abutment – Model Type | Platform compatibility | Platform diameter [mm] | Implant Body diameter [mm] ---|---|---|--- AB-ATO35 | Astra Tech 3.5/4.0 | 3.5 & 4 | 3.5 & 4 AB-ATO45 | Astra Tech 4.5/5.0 | 4.5 & 5 | 4.5 & 5 AB-ATE36 | Astra Tech EV 3.6 | 3.6 | 3.6 AB-ATE42 | Astra Tech EV 4.2 | 4.2 | 3.6 & 4.2 AB-ATE48 | Astra Tech EV 4.8 | 4.8 | 4.2 & 4.8 AB-ATE54 | Astra Tech EV 5.4 | 5.4 | 5.4 All digitally designed CAD/CAM customizations for the Elos Accurate® Customized Abutments are only intended to be sent and manufactured at a FDA registered Elos Medtech approved milling facility.
Device Description
The Elos Accurate® Customized Abutment is a patient specific abutment intended for attaching to dental implants in order to provide basis for single- or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to the implant using the included Elos Prosthetic Screw and attached to the crown/coping manually by cementation. The Elos Accurate® Customized Abutment consists of an Abutment Blank used in fabricating of a full patient-specific abutment in Titanium alloy per ASTM F136. The Abutment Blank used in creation of the Elos Accurate® Customized Abutment has a pre-manufactured connection interface that fits directly to a pre-specified dental implant. The customized shape of the abutment is intended to be manufactured by an Elos Medtech approved milling facility. The Elos Accurate® Customized Abutment is delivered nonsterile and the final restoration including corresponding Elos Prosthetic Screw is intended to be sterilized at the dental clinic before it is placed in the patient. The Elos Accurate® Customized Abutment provides clinicians and laboratories with a prosthetic device that can be used in definitive (permanent) single- or multi restorations.
More Information

No
The summary describes a CAD/CAM manufactured dental abutment and its compatibility with various implant systems. There is no mention of AI or ML in the intended use, device description, or performance studies.

No
The device is a dental abutment intended for attaching to dental implants to provide a basis for prosthetic restorations. It does not actively treat a disease or condition; rather, it serves as a structural component for a prosthetic.

No

This device is a customized abutment used for dental prosthetic restorations, not for diagnosing conditions.

No

The device description clearly states it is a physical abutment made of Titanium alloy, intended to be attached to dental implants. While it mentions digital design (CAD/CAM), the core device is a manufactured hardware component.

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

Here's why:

  • Intended Use: The intended use is to provide a basis for dental prosthetic restorations by attaching to dental implants. This is a mechanical function within the body.
  • Device Description: The device is a patient-specific abutment made of titanium alloy, designed to be attached to a dental implant and then to a crown/coping. It is a physical component used in a surgical and restorative procedure.
  • Lack of Diagnostic Function: There is no mention of the device being used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes.

IVD devices are typically used to test samples like blood, urine, or tissue to diagnose diseases, monitor health, or determine compatibility. This device is a physical implant component used in a dental restoration procedure.

N/A

Intended Use / Indications for Use

The Elos Accurate® Customized Abutments are intended for attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to a dental implant using the included Elos Prosthetic screw.

The Elos Accurate® Customized Abutments are compatible with the implant systems listed in table 1:

Table 1.

Elos Accurate Customized Abutment –Model TypePlatform compatibilityPlatform diameter [mm]Implant Body diameter [mm]
AB-ATO35Astra Tech 3.5/4.03.5 & 43.5 & 4
AB-ATO45Astra Tech 4.5/5.04.5 & 54.5 & 5
AB-ATE36Astra Tech EV 3.63.63.6
AB-ATE42Astra Tech EV 4.24.23.6 & 4.2
AB-ATE48Astra Tech EV 4.84.84.2 & 4.8
AB-ATE54Astra Tech EV 5.45.45.4

All digitally designed CAD/CAM customizations for the Elos Accurate® Customized Abutments are only intended to be sent and manufactured at a FDA registered Elos Medtech approved milling facility.

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

NHA

Device Description

The Elos Accurate® Customized Abutment is a patient specific abutment intended for attaching to dental implants in order to provide basis for single- or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to the implant using the included Elos Prosthetic Screw and attached to the crown/coping manually by cementation. The Elos Accurate® Customized Abutment consists of an Abutment Blank used in fabricating of a full patient-specific abutment in Titanium alloy per ASTM F136. The Abutment Blank used in creation of the Elos Accurate® Customized Abutment has a pre-manufactured connection interface that fits directly to a pre-specified dental implant. The customized shape of the abutment is intended to be manufactured by an Elos Medtech approved milling facility. The Elos Accurate® Customized Abutment is delivered nonsterile and the final restoration including corresponding Elos Prosthetic Screw is intended to be sterilized at the dental clinic before it is placed in the patient. The Elos Accurate® Customized Abutment provides clinicians and laboratories with a prosthetic device that can be used in definitive (permanent) single- or multi restorations.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

dental implants

Indicated Patient Age Range

Not Found

Intended User / Care Setting

dental clinic

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)

Non clinical testing data submitted included:

  • engineering and dimensional analysis of original manufactures' components (abutments, implants & abutment screws) for determination of compatibility.
  • fatigue testing per ISO 14801 according to FDA guidance for Industry and FDA Staff "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments" dated May 12, 2004.
  • biocompatibility testing for cytotoxicity according to ISO 10993-5. Tests included covered:
    • non-coated prosthetic screw representative for subject device (test of primary predicate device K190299)
    • Elos accurate® Customized Abutment representative for subject devices (test of reference predicate device (K171799))

The fatigue test results of the subject devices compatible with Astra Tech 3.5 have been substantiated by the reference predicate device (K183518).

As the primary predicate device were tested according to ISO 17665-1 & ISO 17665-2. demonstrating a SAL of 106 no additional testing were necessary on the subject device.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K190299

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

K091239, K111287, K171799, K120414, K183518

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 872.3630 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

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

February 6, 2020

Elos Medtech Pinol A/S Tina Poulsen Head of Compliance Engvej 33 Goerloese, DK-3330 DENMARK

Re: K191890

Trade/Device Name: Elos Accurate® Customized Abutment Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: January 3, 2020 Received: January 6, 2020

Dear Tina Poulsen:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

1

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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.

Srinivas Nandkumar, Ph.D. for Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Traditional 510(k) Premarket Notification: Elos Accurate® Customized Abutment Elos Medtech Pinol A/S

INDICATIONS FOR USE

510(k) Number: K191890 Device Name: Elos Accurate® Customized Abutment

Indications for Use

The Elos Accurate® Customized Abutments are intended for attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to a dental implant using the included Elos Prosthetic screw.

The Elos Accurate® Customized Abutments are compatible with the implant systems listed in table 1:

Table 1.

| Elos Accurate Customized Abutment –
Model Type | Platform
compatibility | Platform
diameter
[mm] | Implant Body
diameter
[mm] |
|---------------------------------------------------|---------------------------|------------------------------|----------------------------------|
| AB-ATO35 | Astra Tech 3.5/4.0 | 3.5 & 4 | 3.5 & 4 |
| AB-ATO45 | Astra Tech 4.5/5.0 | 4.5 & 5 | 4.5 & 5 |
| AB-ATE36 | Astra Tech EV 3.6 | 3.6 | 3.6 |
| AB-ATE42 | Astra Tech EV 4.2 | 4.2 | 3.6 & 4.2 |
| AB-ATE48 | Astra Tech EV 4.8 | 4.8 | 4.2 & 4.8 |
| AB-ATE54 | Astra Tech EV 5.4 | 5.4 | 5.4 |

All digitally designed CAD/CAM customizations for the Elos Accurate® Customized Abutments are only intended to be sent and manufactured at a FDA registered Elos Medtech approved milling facility.

Prescription Use X AND/OR Over-The-Counter Use (Part 21 CFR 801 Subpart D) (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

3

510(k) Summary Elos Accurate® Customized Abutment January 3rd, 2020

This summary of 510(k) information is being submitted in accordance with the requirements of 21 CFR § 807.92.

I.Company:Elos Medtech Pinol A/S
Engvej 33
DK-3330 Goerloese
Denmark
Contacts:Tina Friis Poulsen
Head of Compliance
Tel: +45 27 77 11 17
E-mail: tina.poulsen@elosmedtech.com
Magnus Lynge Bergholt
Regulatory Affairs Manager
Tel: +45 48 21 64 58
E-mail: magnus.jacobsen@elosmedtech.com
II.Proprietary Trade Name:Elos Accurate® Customized Abutment
III.Classification Name:Endosseous Dental Implant Abutment
IV.Classification:Class II, 21 CFR 872.3630
V.Product Code(s):NHA

VI. Identification of Legally Marketed Devices:

The design features, materials and Indications for Use of the subject devices are substantially equivalent to the predicate devices noted below.

Primary Predicate Device:

  • K190299 / SE 06/26/2019 Elos Accurate® Customized Abutment .

Reference Devices:

  • K091239 / SE 09/22/2009 ASTRA TECH IMPLANT SYSTEM ●
  • K111287 / SE 09/26/2011 - ASTRA TECH IMPLANT SYSTEM
  • K171799 / SE 01/15/2018 Elos Accurate® Customized Abutment ●
  • K120414 / SE 07/31/2012 OsseoSpeedTM Plus ●
  • . K183518 / SE 03/18/2019- Preat Abutments

4

VII. Product Description:

The Elos Accurate® Customized Abutment is a patient specific abutment intended for attaching to dental implants in order to provide basis for single- or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to the implant using the included Elos Prosthetic Screw and attached to the crown/coping manually by cementation. The Elos Accurate® Customized Abutment consists of an Abutment Blank used in fabricating of a full patient-specific abutment in Titanium alloy per ASTM F136. The Abutment Blank used in creation of the Elos Accurate® Customized Abutment has a pre-manufactured connection interface that fits directly to a pre-specified dental implant. The customized shape of the abutment is intended to be manufactured by an Elos Medtech approved milling facility. The Elos Accurate® Customized Abutment is delivered nonsterile and the final restoration including corresponding Elos Prosthetic Screw is intended to be sterilized at the dental clinic before it is placed in the patient. The Elos Accurate® Customized Abutment provides clinicians and laboratories with a prosthetic device that can be used in definitive (permanent) single- or multi restorations.

VIII. Indications for Use:

The Elos Accurate® Customized Abutments are intended for attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations. The Elos Accurate® Customized Abutment will be attached to a dental implant using the included Elos Prosthetic screw.

The Elos Accurate® Customized Abutments are compatible with the implant systems listed in table 1:
Table 1.

| Elos Accurate
Customized
Abutment –
Model Type | Platform compatibility | Platform diameter
[mm] | Implant Body
diameter
[mm] |
|---------------------------------------------------------|------------------------|---------------------------|----------------------------------|
| AB-ATO35 | Astra Tech 3.5/4.0 | 3.5 & 4 | 3.5 & 4 |
| AB-ATO45 | Astra Tech 4.5/5.0 | 4.5 & 5 | 4.5 & 5 |
| AB-ATE36 | Astra Tech EV 3.6 | 3.6 | 3.6 |
| AB-ATE42 | Astra Tech EV 4.2 | 4.2 | 3.6 & 4.2 |
| AB-ATE48 | Astra Tech EV 4.8 | 4.8 | 4.2 & 4.8 |
| AB-ATE54 | Astra Tech EV 5.4 | 5.4 | 5.4 |

All digitally designed CAD/CAM customizations for the Elos Accurate® Customized Abutments are only intended to be sent and manufactured at a FDA registered Elos Medtech approved milling facility.

5

IX. Summary of the Technological Characteristics:

The subject devices provide additional restorative options for connection to existing implant platforms. The subject devices has similar Indications for Use, intended use, designs, sizes and configurations, materials, and principles of operation as the primary predicate device Elos Accurate® Customized Abutment (K190299 / SE 06/26/2019). In order to determine nominal dimensions and tolerances of the Elos Accurate® Customized Abutment products, measuring- and dimensional analyses of original manufacturers' components (abutments, implants & abutment screws) have been made.

Comparing to the primary predicate device, the specific language (wording) of the Indications for Use Statements are identical except for implant system compatibility. The implant system compatibility of the subject device is extended to include compatibility other implant platforms. The difference in implant system compatibility have been substantiated by engineering and dimensional analysis of original manufactures' components (abutments, implants & abutment screws) for determination of compatibility and fatigue testing.

6

Element of ComparisonIndications for Use
Subject Device

Elos Accurate® Customized
Abutment | The Elos Accurate® Customized Abutments are intended for attaching to
dental implants in order to provide basis for single or multiple tooth
prosthetic restorations. The Elos Accurate® Customized Abutment will be
attached to a dental implant using the included Elos Prosthetic screw.
The Elos Accurate® Customized Abutments are compatible with the implant
systems listed in table 1:
Table 1.
Elos
Accurate
Customized
Abutment –
Model Type Platform
compatibility Platform
diameter
[mm] Implant
Body
diameter
[mm] AB-ATO35 Astra Tech 3.5/4.0 3.5 & 4 3.5 & 4 AB-ATO45 Astra Tech 4.5/5.0 4.5 & 5 4.5 & 5 AB-ATE36 Astra Tech EV 3.6 3.6 3.6 AB-ATE42 Astra Tech EV 4.2 4.2 3.6 & 4.2 AB-ATE48 Astra Tech EV 4.8 4.8 4.2 & 4.8 AB-ATE54 Astra Tech EV 5.4 5.4 5.4 All digitally designed CAD/CAM customizations for the Elos Accurate®
Customized Abutments are only intended to be sent and manufactured at a
FDA registered Elos Medtech approved milling facility. | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| Primary Predicate Device
(K190299)

Elos Accurate® Customized
Abutment | The Elos Accurate® Customized Abutments are intended for attaching to
dental implants in order to provide basis for single or multiple tooth
prosthetic restorations. The Elos Accurate® Customized Abutment will be
attached to a dental implant using the included Elos Prosthetic screw.
The Elos Accurate® Customized Abutments are compatible with the implant
systems listed in table 1:
Table 1.
Elos Accurate
Customized
Abutment –
Model Type Platform
compatibility Platform
diameter
[mm] Implant
Body
diameter
[mm] AB-NBR35 Nobel Replace NP 3.5 3.5 AB-NBA30 Nobel CC 3.0 3 3 AB-NBA43 Nobel CC RP 3.9 4.3 & 5 AB-NBA60 Nobel CC WP 5.1 5.5 AB-SBO33 Straumann Bone Level 3.3 3.3 AB-SBO41 Straumann Bone Level 4.1 & 4.8 4.1 & 4.8 All digitally designed CAD/CAM customizations for the Elos Accurate®
Customized Abutments are only intended to be sent and manufactured at a
FDA registered Elos Medtech approved milling facility. | | | | | | | | | | | | | | | | | | | | | | | | | | | | |

7

Element of ComparisonSubject DevicePrimary Predicate Device (K190299)
FDA Classification & Product Code21 CFR 872.3630: NHA
Endosseous Dental Implant
Abutment21 CFR 872.3630: NHA
Endosseous Dental Implant
Abutment
Base MaterialsElos Accurate® Customized Abutments:
Titanium Alloy 6Al-4V ELI, medical grade 5

Elos Prosthetic screws:
Titanium Alloy 6Al-4V ELI, medical grade 5 | Elos Accurate® Customized Abutments:
Titanium Alloy 6Al-4V ELI, medical grade 5

Elos Prosthetic screws:
Titanium Alloy 6Al-4V ELI, medical grade 5 |
| Surface Finish | Elos Accurate® Customized Abutment:
Non-coated

Elos Abutment screws:
Non-coated | Elos Accurate® Customized Abutment:
Non-coated

Elos Abutment screws:
MediCarb (DLC)
Non-coated |
| Implant interface | Indexed | Indexed |
| Connection type | Conical | Flat top and conical |
| Abutment diameter | Ø3.5 – Ø5.4 mm | Ø3.0 – Ø6.0 mm |
| Prosthesis attachment | Cement-retained | Cement-retained |
| Restoration | Single-unit &Multi-unit | Single-unit &Multi-unit |
| Abutment Design Matrix | Up to 30° | Up to 30° |
| Sterility | Provided non-sterile | Provided non-sterile |
| Sterilization method | Steam sterilization | Steam sterilization |
| Digital CAD Systems | 510(k) cleared CAD software
Minimum wall thickness: 0.4 mm | 510(k) cleared CAD software
Minimum wall thickness: 0.4 mm |
| Abutment Design Matrix | Maximum post height: 13 mm | Maximum post height: 13 mm |
| | Maximum angulation: 30° | Maximum angulation: 30° |
| | Maximum diameter: 12 mm | Maximum diameter: 12 mm |
| | Minimum post height: 4mm | Minimum post height: 4mm |
| | Minimum gingiva height: 0.5mm
Maximum gingiva height: 5mm | Minimum gingiva height: 0.5mm
Maximum gingiva height: 5mm |

The data included in this submission demonstrate substantial equivalence to the predicate device and/or reference device listed above.

8

Overall, the subject device has the following substantial equivalencies to the predicate device:

  • has the same intended use.
  • . uses the same operating principle.
  • . incorporates the same basic design.
  • incorporates the same or very similar materials, and ●
  • . is to be sterilized using the same processes.

X. Discussion of the Non-Clinical Testing:

Non clinical testing data submitted included:

  • . engineering and dimensional analysis of original manufactures' components (abutments, implants & abutment screws) for determination of compatibility.
  • . fatigue testing per ISO 14801 according to FDA guidance for Industry and FDA Staff "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments" dated May 12, 2004.
  • biocompatibility testing for cytotoxicity according to ISO 10993-5. Tests included covered: ●
    • non-coated prosthetic screw representative for subject device (test of primary predicate device K190299)
    • Elos accurate® Customized Abutment representative for subject devices (test of reference predicate device (K171799))

The fatigue test results of the subject devices compatible with Astra Tech 3.5 have been substantiated by the reference predicate device (K183518).

As the primary predicate device were tested according to ISO 17665-1 & ISO 17665-2. demonstrating a SAL of 106 no additional testing were necessary on the subject device.

XI. Conclusions:

Based on the test results and additional supporting documentation provided in this premarket notification, the subject devices demonstrated substantial equivalence to the previously listed predicate devices.