K Number
K200189
Device Name
Luna Dental Implant System- Healing Abutment
Date Cleared
2020-02-26

(30 days)

Product Code
Regulation Number
872.3630
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Luna Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function.
Device Description
The Luna Dental Implant System - Healing Abutment is to be connected to the implant and is to heal gingiva before setting abutment on the implant in the oral cavity. It is made of commercially pure titanium alloy Gr4. It offers narrow and regular platform types, and the narrow type has anodizing surface treatment in purple to be distinguished from the regular type.
More Information

No
The summary describes a standard dental implant system component (healing abutment) made of titanium. There is no mention of AI, ML, image processing, or any software-driven features that would suggest the use of these technologies. The performance studies focus on risk analysis and biocompatibility, not algorithmic performance.

Yes
The device is intended to restore the patient's chewing function by providing support for prosthetic devices, which aligns with the definition of a therapeutic device designed to treat or alleviate a medical condition.

No
The Luna Dental Implant System is intended for surgical placement to support prosthetic devices and restore chewing function, not for diagnosing medical conditions.

No

The device description explicitly states it is a "Healing Abutment" made of "commercially pure titanium alloy Gr4," indicating it is a physical hardware component, not software.

Based on the provided information, the Luna Dental Implant System is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • Intended Use: The intended use clearly states that the device is surgically placed in the bone to support prosthetic devices and restore chewing function. This is a direct therapeutic intervention within the body.
  • Device Description: The description details a physical implant system made of titanium alloy, designed for surgical placement and healing within the oral cavity.
  • Lack of IVD Characteristics: IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening. The Luna Dental Implant System does not interact with or analyze such specimens.

The device is a medical device, specifically a dental implant system, but it falls under the category of devices used for treatment and restoration within the body, not for in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

The Luna Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function.

Product codes

NHA

Device Description

The Luna Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function. This submission is to get clearance on the modification of the healing abutments that are used with the fixture cleared under K123155 and K160106.

The healing abutment is to be connected to the implant and is to heal gingiva before setting abutment on the implant in the oral cavity. It is made of commercially pure titanium alloy Gr4. It offers narrow and regular platform types, and the narrow type has anodizing surface treatment in purple to be distinguished from the regular type.

N (Narrow) Type

  • 4.3mm(Dia) x 9.2/10.2/11.2/12.2/13.2mm (Length)
  • 4.8mm(Dia) x 9.2/10.2/11.2/12.2/13.2mm (Length)

R (Regular) Type

  • 4.3mm(Dia) x 10/11/12/13/14mm (Length)
  • 4.8mm(Dia) x 10/11/12/13/14mm (Length)
  • 5.8mm(Dia) x 10/11/12/13/14mm (Length)
  • 6.3mm(Dia) x 10/11/12/13/14mm (Length)

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

bone of the upper or lower jaw arches

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Risk analysis was conducted according to ISO14971 to evaluate the effect of the modification. The risk assessment did not show that the device changes affected biocompatibility, sterilization, and shelf life such that the testing in the prior (predicate) file is still applicable.

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

Not Found

Predicate Device(s)

K123155, K121585

Reference Device(s)

K121585

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.)

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA text logo on the right. The text logo has the FDA acronym in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

February 26, 2020

SHINHUNG MST Co., Ltd. Priscilla Chung Regulatory Affairs Consultant LK Consulting Group USA. Inc. 1150 Roosevelt STE 200 Irvine, California 92620

Re: K200189

Trade/Device Name: Luna Dental Implant System - Healing Abutment Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: January 13, 2020 Received: January 27, 2020

Dear Priscilla Chung:

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.

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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.

for Srinivas Nandkumar, Ph.D. Director Implantable Dental Devices Team 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)

Device Name

Luna Dental Implant System - Healing Abutment

Indications for Use (Describe)

The Luna Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D)☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary (K200189)

This summary of 510(K) information is being submitted in accordance with requirements of 21 CFR Part 807.92.

Date: 02/26/2020

1. Submitter

SHINHUNG MST Co., Ltd. 110-2, Donghwagongdan-Ro Munmak-Eup Wonju Si, Gangweondo, Republic of Korea 220-801 Tel. +82-33-730-1901

2. Official Correspondent

Priscilla Chung LK Consulting Group USA, Inc. 1150 Roosevelt STE 200, Irvine CA 92620 Phone: 714.202.5789 Fax: 714-409-3357 Email: juhee.c@lkconsultinggroup.com

3. Device

  • . Trade Name: Luna Dental Implant System - Healing Abutment
  • Common Name: Implant Abutment
  • Classification Name: Endosseous Dental Implant Abutment
  • Product Code: NHA
  • . Classification regulation: 21CFR 872.3630

4. Predicate Device:

  • Luna Dental Implant System (K123155) by SHINHUNG MST Co., Ltd.
  • TS IMPLANT SYSTEM (K121585) by Osstem Co., Ltd.

5. Description:

The Luna Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function. This submission is to get clearance on the modification of the healing abutments that are used with the fixture cleared under K123155 and K160106.

The healing abutment is to be connected to the implant and is to heal gingiva before

4

setting abutment on the implant in the oral cavity. It is made of commercially pure titanium alloy Gr4. It offers narrow and regular platform types, and the narrow type has anodizing surface treatment in purple to be distinguished from the regular type.

N (Narrow) Type

  • . 4.3mm(Dia) x 9.2/10.2/11.2/12.2/13.2mm (Length)
  • . 4.8mm(Dia) x 9.2/10.2/11.2/12.2/13.2mm (Length)

R (Regular) Type

  • 4.3mm(Dia) x 10/11/12/13/14mm (Length) ●
  • . 4.8mm(Dia) x 10/11/12/13/14mm (Length)
  • 5.8mm(Dia) x 10/11/12/13/14mm (Length)
  • 6.3mm(Dia) x 10/11/12/13/14mm (Length)

6. Indication for use:

The Luna Dental Implant System is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, and to restore the patient's chewing function.

5

7. Basis for Substantial Equivalence

The Luna Dental Implant System - Healing Abutment is substantially equivalent to its predicate device (K123155) in terms of indications for use, raw material, and design. The differences are in body design and size range. The design change does not raise a question in substantial equivalence since the change is not significant. We have identified a reference device that encompass the size range of the subject device. Based on the information submitted here in we conclude that the subject device is substantially equivalent to the predicate devices.

Device NameSubject DevicePredicate DeviceReference Device
ManufacturerSHINHUNG MST Co.,
LtdSHINHUNG MST Co.,
LtdOsstem Co., Ltd.
510(k) NumberK200189K123155K121585
Device NameLuna Dental Implant
System - Healing
AbutmentLuna Dental Implant
SystemTS IMPLANT SYSTEM
FormAbutmentImplant and AbutmentImplant and Abutment
Indications for
useThe Luna Dental Implant
System is intended to be
surgically placed in the
bone of the upper or
lower jaw arches to
provide support for
prosthetic devices, such as
artificial teeth, and to
restore the patient's
chewing function.The Luna Dental Implant
System is intended to be
surgically placed in the
bone of the upper or
lower jaw arches to
provide support for
prosthetic devices, such as
artificial teeth, and to
restore the patient's
chewing function.The TS Implant System
is indicated for use in
partially or roily
edentulous mandibles
and maxillae, in support
of single or multiple-unit
restorations including:
cemented retained, screw
retained, or overdenture
restorations, and final or
temporary abutment
support for fixed
bridgework. It is
intended for delayed
loading. The abutment is
intended for use with a
dental implant fixture to
provide support for
prosthetic restorations
such as crowns, bridges,
or overdenture. TS
Implant System is
compatible with
abutment in the ET/SS
Implant System.
SterilizationIt is supplied sterile
(Gamma radiation)It is supplied sterile
(Gamma radiation)It is supplied sterile
(Gamma radiation)

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NP(Anodizing)NP (Anodizing)(Non-Anodizing)
ShapeImage: NP(Anodizing)Image: NP (Anodizing)Image: (Non-Anodizing)
RP(Non-Anodizing)RP(Anodizing)
MaterialTi-Gr4Ti-Gr4Ti-Gr4
Size1) N type
-Diameter: 4.3~4.8mm
-Height:
4.0, 5.0, 6.0, 7.0, 8.0mm1) N type
-Diameter: 4.5~6.0mm
-Height:
2.0, 3.5, 5.0, 7.0mm1) N type
-Diameter: 4.0~4.5mm
-Height: 3.0, 4.0, 5.0, 7.0, 9.0mm
2) R type
-Diameter: 4.3~6.3mm
-Height:
4.0, 5.0, 6.0, 7.0, 8.0mm2) R type
-Diameter: 4.5~7.0mm
-Height:
2.0, 3.5, 5.0, 7.0mm2) R type
-Diameter: 4.0~8.0mm
-Height: 3.0, 4.0, 5.0, 7.0, 9.0mm

8. Non-Clinical Testing

Risk analysis was conducted according to ISO14971 to evaluate the effect of the modification. The risk assessment did not show that the device changes affected biocompatibility, sterilization, and shelf life such that the testing in the prior (predicate) file is still applicable.

9. Conclusion

The subject devices and the predicate device have the same intended use and have the same technological characteristics.

Overall, the Luna Dental Implant System - Healing Abutment has the following similarities to the predicate device:

    • have the same intended use,
    • use the same operating principle,
    • incorporate the similar design,
    • incorporate the same material and the sterilization method.

Based on the similarities, we conclude that the Luna Dental Implant System - Healing Abutment is substantially equivalent to the predicate device.