K Number
K200992
Date Cleared
2020-11-17

(216 days)

Product Code
Regulation Number
872.3640
Panel
Dental
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

S.I.N. Dental Implant System is intended for placement in the maxillary or mandibular arch to provide support for single-unit or multi-unit restorations. When a one-stage surgical approach is applied, the S.I.N. Dental Implant System is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

Device Description

The purpose of this submission is to add to the S.I.N. Dental Implant System components cleared in K170392 and K170398. This submission adds the following components to the S.I.N. Dental Implant System:

Tryon CM Conical implants, Tryon CM Cylindrical implants, Tryon CM Cylindrical Body and Conical Apex implants, and Strong SW implants, each with a Morse taper connection and the identical acidetched endosseous surface cleared in in K170392;

Strong SW Plus implants with a Morse taper connection and an endosseous surface produced by acidetching followed by application of a hydroxyapatite coating (HA™M) identical to the coating cleared in K170392:

conventional angled abutments and healing caps with a Morse taper connection that are compatible with the Strong SW CM implant line cleared in K170392;

conventional angled abutments and healing caps with a Morse taper connection that are compatible with the subject device Tryon CM implant lines, the subject device Strong SW/Plus implant lines, and the Unitite implant line cleared in K17039;

healing caps with a Morse taper connection that are compatible with the Unitite Compact implant line and the Unitite Slim implant line cleared in K170392;

healing caps with an external hex (HE) or internal hex (HI) connection that are compatible with the Strong SW HE, the Tryon HE implant lines, and the Strong SW HI implant lines, cleared in K170398;

abutment screws for use with the angled abutments or healing caps.

AI/ML Overview

This document is a 510(k) summary for the S.I.N. Dental Implant System. It primarily focuses on demonstrating substantial equivalence to previously cleared predicate devices rather than proving a device meets specific acceptance criteria through a standalone study with defined performance metrics.

However, the document does contain information about performance data used to support the substantial equivalence claim. Here's a breakdown of the relevant information:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not present acceptance criteria in a structured table with corresponding device performance metrics. Instead, it lists various non-clinical tests conducted and states that these tests demonstrate substantial equivalence to predicate devices, implying these tests met the necessary standards for such a claim.

Based on the "Performance Data" section (Page 6), the following can be inferred as the type of performance evaluation conducted:

Performance AreaAcceptance Criteria (Inferred from testing)Reported Device Performance
SterilizationSterility Assurance Level (SAL) of 10^-6Validated for all subject devices (dental implants, abutments, prosthetic components, healing caps) to a SAL of 10^-6 by selecting and substantiating a 25 kGy dose using method VDmax25, according to ISO 11137-1 and ISO 11137-2.
Bacterial EndotoxinLimit of < 20 EU/deviceTested on samples of water used in manufacturing weekly and on samples from sterilized product quarterly (referenced from K170398 and K170392) to demonstrate all sterile product meets a limit of < 20 EU/device.
Shelf LifePackaging sterile barrier integrity and sterility maintained after agingTested samples after 4 years of real-time aging according to ASTM F1929 and F88/F88M (packaging sterile barrier) and sterility testing of product (referenced from K170398 and K170392). The implication is that they met the requirements.
Biocompatibility (PEEK)Conformance to ISO 10993-5 (cytotoxicity) and ISO 10993-12Performed according to ISO 10993-5 (cytotoxicity) and ISO 10993-12. The implication is that they were found to be biocompatible.
Biocompatibility (HA™® coating)Conformance to ISO 10993-3, -5, -6, -10, -11Leveraged from and provided in K170392, included ISO 10993-3 (genotoxicity), ISO 10993-5 (cytotoxicity), ISO 10993-6 (implantation), ISO 10993-10 (sensitization, irritation), and ISO 10993-11 (systemic toxicity). The implication is that it was found to be biocompatible.
HA™® coating characterizationMicroscopic and spectroscopic analysis, adherence testingLeveraged from and provided in K170392, included scanning electron microscopy (SEM), x-ray photoelectron spectroscopy (XPS), transmission electron microscopy (TEM), x-ray diffraction (XRD), and testing of the adherence of the coating. The implication is that the coating structure and adherence were found to be consistent with previously cleared devices.
Mechanical Strength (Implants/Abutments)Conformance to ISO 14801 for static compression and compression fatigueStatic compression and compression fatigue testing performed according to ISO 14801 of worst-case constructs of subject device abutments and implants with 11.5° Morse taper, and of worst-case constructs of subject device abutments with 16° Morse taper and previously-cleared compatible implants. The implication is that these tests demonstrated sufficient mechanical strength for the intended use and were comparable to predicate devices.

2. Sample Size Used for the Test Set and Data Provenance

The document does not specify exact sample sizes for each test mentioned. For tests like sterilization, bacterial endotoxin, and shelf life, it generally states "samples" were tested.

  • Sterilization: "all subject devices"
  • Bacterial Endotoxin: "samples of water used in manufacturing on a weekly basis and on samples from sterilized product on a quarterly basis"
  • Shelf Life: "samples after 4 years of real time aging"
  • Biocompatibility (PEEK and HA™® coating): Not specified.
  • Mechanical Strength: "worst-case constructs" – implies a selection of representatives that challenge the design, but specific numbers are not given.

The data provenance is internal to the manufacturer (S.I.N.-Sistema de Implante Nacional S.A.) via non-clinical testing. While some data is "referenced from K170398 and K170392" or "leveraged from and provided in K170392," these are prior 510(k) submissions for the same manufacturer, indicating a history of internal testing. The tests are non-clinical, so "country of origin" from a clinical data perspective (e.g., patient demographics) is not applicable. The tests are prospective in the sense that they are conducted to evaluate the device, not retrospectively analyzing past clinical outcomes.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications

This information is not applicable as the document describes non-clinical engineering and laboratory testing to establish performance, not expert-based ground truth for clinical evaluation.

4. Adjudication Method for the Test Set

This information is not applicable as the document describes non-clinical engineering and laboratory testing, which typically involves quantitative results against specifications or predicate comparisons, not expert adjudication.

5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study

No, a MRMC comparative effectiveness study was not done. The document explicitly states: "No clinical data were included in this submission." (Page 6).

6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

This concept is not applicable here. The device is a physical dental implant system, not an algorithm or AI system. The performance data presented are for the physical device components in a standalone context (e.g., testing the implant's strength, the coating's biocompatibility).

7. Type of Ground Truth Used

The ground truth used for these non-clinical tests is primarily engineering specifications, recognized standards (e.g., ISO, ASTM), and comparison to predicate device characteristics. For example, sterility is measured against a SAL standard, mechanical strength against ISO 14801, and biocompatibility against ISO 10993 series. The "truth" is whether the device meets these established technical benchmarks or is comparable to a predicate that has previously met them.

8. Sample Size for the Training Set

This information is not applicable. The device is a physical dental implant system, not a machine learning model that requires a training set.

9. How the Ground Truth for the Training Set Was Established

This information is not applicable. As stated above, there is no training set for a machine learning model.

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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.

November 17, 2020

S.I.N.-Sistema de Implante Nacional S.A. % Kevin Thomas Vice President and Director of Regulatory Affairs PaxMed International. LLC 12264 El Camino Real, Suite 400 San Diego, California 92130

Re: K200992

Trade/Device Name: S.I.N. Dental Implant System Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous dental implant Regulatory Class: Class II Product Code: DZE, NHA Dated: October 16, 2020 Received: October 16, 2020

Dear Kevin Thomas:

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 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

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Indications for Use

510(k) Number (if known)

K200992

Device Name

S.I.N. Dental Implant System

Indications for Use (Describe)

S.I.N. Dental Implant System is intended for placement in the maxillary or mandibular arch to single-unit or multi-unit restorations. When a one-stage surgical is applied, the S.I.N. Dental Implant System is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

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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510(k) Summary K200992 S.I.N. - Sistema de Implante Nacional S.A. S.I.N Dental Implant System

November 17, 2020

ADMINISTRATIVE INFORMATION

Manufacturer NameS.I.N. - Sistema de Implante Nacional S.A.
Avenida Vereador Abel Ferreira, 1100
São Paulo, São Paulo
03340-000 Brazil
Telephone: +55-11-21693000 ext 3236
Official ContactDenise Domiciano, Quality and Regulatory Manager
Representative/ConsultantKevin A. Thomas, PhD
Floyd G. Larson, MS, MBA
PaxMed International, LLC
12264 El Camino Real, Suite 400
San Diego, CA 92130
Telephone:+1 858-792-1235
Fax:+1 858-792-1236
Email:kthomas@paxmed.comflarson@paxmed.com

DEVICE NAME AND CLASSIFICATION

Trade/Proprietary NameS.I.N. Dental Implant System
Common NamesEndosseous dental implant
Regulation Number21 CFR 872.3640
Regulation NameEndosseous dental implant
Regulatory ClassClass II
Product CodeDZE
Secondary Product CodeNHA
Classification PanelDental
Reviewing OfficeOffice of Health Technology 1 (Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices)
Reviewing DivisionDivision of Health Technology 1 B (Dental Devices)

PREDICATE DEVICE INFORMATION

Primary Predicate Device K170392, S.I.N. Dental Implant System, S.I.N. - Sistema de Implante Nacional S.A.

Additional Predicate Devices

K170398, S.I.N. Dental Implant System, S.I.N. - Sistema de Implante Nacional S.A. K163194, Neodent Implant System - GM Line, JJGC Indústria e Comércio de Materiais Dentários SA K101945, Neodent Implant System, JJGC Indústria e Comércio de Materiais Dentários SA

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K961736, 17° Angulated Abutment, Nobel Biocare USA, LLC K905434, Angulated Abutment, Complete, Titanium SDCA 102, Nobelpharma USA, Inc. K161416, Multi-unit Abutment Plus, Nobel Biocare AB K052600, Zimmer Dental Incorporated, Zimmer Dental Hex-lock Prepared Abutment (Straight & Angled) K110955, MegaGen Company, Limited, AnyRidge Internal Implant System

INDICATIONS FOR USE STATEMENT

S.I.N. Dental Implant System is intended for placement in the maxillary or mandibular arch to provide support for single-unit or multi-unit restorations. When a one-stage surgical approach is applied, the S.I.N. Dental Implant System is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

SUBJECT DEVICE DESCRIPTION

The purpose of this submission is to add to the S.I.N. Dental Implant System components cleared in K170392 and K170398. This submission adds the following components to the S.I.N. Dental Implant System:

Tryon CM Conical implants, Tryon CM Cylindrical implants, Tryon CM Cylindrical Body and Conical Apex implants, and Strong SW implants, each with a Morse taper connection and the identical acidetched endosseous surface cleared in in K170392;

Strong SW Plus implants with a Morse taper connection and an endosseous surface produced by acidetching followed by application of a hydroxyapatite coating (HA™M) identical to the coating cleared in K170392:

conventional angled abutments and healing caps with a Morse taper connection that are compatible with the Strong SW CM implant line cleared in K170392;

conventional angled abutments and healing caps with a Morse taper connection that are compatible with the subject device Tryon CM implant lines, the subject device Strong SW/Plus implant lines, and the Unitite implant line cleared in K17039;

healing caps with a Morse taper connection that are compatible with the Unitite Compact implant line and the Unitite Slim implant line cleared in K170392;

healing caps with an external hex (HE) or internal hex (HI) connection that are compatible with the Strong SW HE, the Tryon HE implant lines, and the Strong SW HI implant lines, cleared in K170398;

abutment screws for use with the angled abutments or healing caps.

Implant LineBody Ø, mmPlatform Ø, mmLength, mm
Tryon CM Conical3.53.58.51011.51315
Tryon CM Conical4.54.58.51011.51315
Tryon CM Conical5.05.08.51011.51315
Tryon CM Cylindrical3.53.578.51011.51315
Tryon CM Cylindrical3.753.7578.51011.51315
Tryon CM Cylindrical4.04.078.51011.51315
Tryon CM Cylindrical5.05.078.51011.51315

The subject device dental implants are summarized in the following table.

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Implant LineBody Ø, mmPlatform Ø, mmLength, mm
Tryon CM Cylindrical Bodyand Conical Apex3.53.58.51011.51315
3.753.758.51011.51315
4.04.08.51011.51315
Strong SW3.53.58.51011.51315
3.83.88.51011.51315
Strong SW Plus4.54.58.51011.51315
5.05.08.51011.51315

All subject device dental implants are made of the same unalloyed titanium as the dental implants cleared in K170398 and K170392, and the Strong SW Plus implants have the identical HA™® surface cleared in K170392.

Prosthetic Components

The subject device prosthetic components are summarized in the following table.

TypesProsthetic Platform Ø, mmAngleMaterialsCompatible with
Abutment Cemented Morse Angled(16° Morse taper)3.3, 4.517°, 30°Titanium alloy
Abutment Angled Morse(16° Morse taper)3.5, 4.517°Titanium alloy
Abutment Mini Angled Morse(16° Morse taper)4.817°, 30°Titanium alloyStrong SW CMimplant line inK170392
Healing Cap Morse(16° Morse taper)n/an/aPEEK
Healing Cap Morse Indexed(16° Morse taper)n/an/aPEEK
Abutment Cemented Angled SIT(11.5° Morse taper)3.3, 4.517°, 30°Titanium alloy
Abutment Cemented Angled Indexed SIT(11.5° Morse taper)3.3, 4.517°, 30°Titanium alloyTryon CM implantlines, Strong SW,
Abutment Mini Angled(11.5° Morse taper)4.817°, 30°Titanium alloyStrong SW Plus (thissubmission);
Healing Cap(11.5° Morse taper)n/an/aPEEKUnitite implant line inK170392
Healing Cap Indexed(11.5° Morse taper)n/an/aPEEK
Healing Cap Compact(4° Morse taper)n/an/aPEEKUnitite Compactimplant line in
Healing Cap Compact Indexed(4° Morse taper)n/an/aPEEKK170392
Healing Cap Slim(3° Morse taper)n/an/aPEEKUnitite Slim implantline in K170392
Healing Cap Slim Indexed(3° Morse taper)n/an/aPEEK
Healing Cap HEn/an/aPEEKStrong SW HE andTryon HE implantlines in K170398
Healing Cap HE Indexedn/an/aPEEK
Healing Cap HIn/an/aPEEKStrong SW HI implant
Healing Cap HI Indexedn/an/aPEEKline in K170398

All subject device prosthetic components are manufactured from the same titanium alloy material conforming to ASTM F136 used to manufacture similar components abutments cleared in K170392 and K 170398, or from polyetheretherketone (PEEK) conforming to ASTM F2026.

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PERFORMANCE DATA

Non-clinical data submitted, referenced, or relied upon to demonstrate substantial equivalence included:

gamma irradiation sterilization validated for all subject devices (dental implants manufactured from unalloyed titanium with the acid-etched surface and implants with the HA™® hydroxyapatite coating, abutments and prosthetic components manufactured from titanium alloy, and healing caps manufactured from PEEK) to a sterility assurance level of 10th by selecting and substantiating a 25 kGy dose using method VDmax25, according to ISO 11137-1 and ISO 11137-2;

bacterial endotoxin testing (referenced from K170398 and K170392) including Limulus amebocyte lysate (LAL) test according to ANSI/AAMI ST72 on samples of water used in manufacturing on a weekly basis and on samples from sterilized product on a quarterly basis to demonstrate all sterile product meets a limit of < 20 EU/device:

shelf life testing (referenced from K170398 and K170392) including testing of samples after 4 years of real time aging according to ASTM F1929 and F88/F88M (packaging sterile barrier) and sterility testing of product:

biocompatibility testing for the subject device PEEK material performed according to ISO 10993-5 (cytotoxicity) and ISO 10993-12;

biocompatibility testing for the HA100 hydroxyapatite coating leveraged from and provided in K170392 included ISO 10993-3 (genotoxicity), ISO 10993-5 (cytotoxicity), ISO 10993-6 (implantation), ISO 10993-10 (sensitization, irritation), and ISO 10993-11 (systemic toxicity);

characterization of the HAMM hydroxyapatite coating leveraged from and provided in K170392 included scanning electron microscopy (SEM), x-ray photoelectron spectroscopy (XPS), transmission electron microscopy (TEM), x-ray diffraction (XRD), and testing of the adherence of the coating;

and static compression and compression fatigue testing according to ISO 14801 of worst-case constructs of the subject device abutments and subject device implants with the 11.5° Morse taper connection, and of worst-case constructs of the subject device abutments with the 16° Morse taper connection and previously-cleared compatible implants (cleared in K170392 and K193096).

No clinical data were included in this submission.

EQUIVALENCE TO MARKETED DEVICES

The subject device is substantially equivalent in indications and design principles to the primary predicate device and the additional predicate devices listed above. Provided at the end of this summary is a table comparing the Indications for Use Statements and the technological characteristics of the subject device, the primary predicate device, and selected additional predicate devices.

The Indications for Use Statement (IFUS) for the subject device is substantially equivalent to that of the primary predicate K170392 and the additional predicate device K170398; slight differences in language of the Indications for Use statements do not affect the intended use as an endosseous dental implant abutment for support of a prosthesis to restore chewing function.

Minor differences between the IFUS for the subject device and the primary predicate K170392 include the exact wording regarding immediate loading and language concerning implants less than 7 mm in length. The minor differences between the IFUS for the subject device and the additional predicate device

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K170398 include the exact wording regarding immediate loading and language concerning the Revolution Compact implant.

Minor differences between the IFUS for the subject device and the additional predicate K163194 include the exact wording regarding immediate loading, language in K163194 concerning titanium base abutments (not applicable to the subject device), and language in K163194 regarding the temporary abutments. Minor differences between the IFUS for the subject device and the additional predicate K101945 include the exact wording regarding immediate loading and splinting of multiple tooth applications.

None of these minor differences impact safety or effectiveness because all IFUS express equivalent intended use to facilitate functional and esthetic rehabilitation of the edentulous mandible or maxilla, and the indications are expressed equivalently using different specific wording.

Subject Device Dental Implants

The subject device Strong SW and Strong SW Plus implants are similar in design and sizes to the Strong SW CM implants cleared in K170392. The subject device Strong SW and Strong SW Plus implants have an 11.5° Morse taper connection, whereas the Strong SW CM implants have a 16° Morse taper connection. The Unitite implant line also cleared in K170932 have the 11.5° Morse taper connection. The subject device Strong SW Plus implants have the identical HAnano surface cleared in K170392.

The subject device Tryon CM implant lines are substantially equivalent in design and sizes to the Tryon HE implants cleared in K170398. The subject device Tryon CM implant lines have the same 11.5° Morse taper connection as the Unitite implant line cleared in K170932.

The subject device dental implants are made of the same unalloyed titanium as the dental implants cleared in K170392 and K170398, and the identical HAnano surface cleared in K170392 (for the subject device Strong SW Plus implants).

The 1.5 mm sub-crestal placement of the subject device implants is substantially equivalent to the subcrestal placement of implants cleared in K170398, K163194, and K101945.

Subject Device Prosthetic Components

All subject device conventional abutments are manufactured from the same titanium alloy material conforming to ASTM F136 used to manufacture S.I.N. Dental Implant System abutments cleared in K170392 and K170398, or from polyetheretherketone (PEEK) conforming to ASTM F2026.

The subject device Abutment Cemented Morse Angled and Abutment Angled Morse (with 16° Morse taper) are substantially equivalent to the corresponding abutment Cemented Strong SW CM cleared in K170392, having the same sizes or ranges of sizes for prosthetic platform diameter and gingival height. The subject device Abutment Cemented Morse Angled and Abutment Angled Morse are substantially equivalent to the GM Exact Click Universal Abutment cleared in K163194 in terms of prosthetic diameter, indexing, and angulation. The additional predicate devices K05260 and K110955 are in support of substantial equivalence of the Abutment Angled Morse with 17° of angulation and gingival heights of 1 mm, 4 mm, and 5 mm.

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The subject device Abutment Mini Angled Morse (with 16° Morse taper) are substantially equivalent to the corresponding abutment design Mini Abutment Strong SW CM cleared in K170392, having the same sizes or ranges of sizes for prosthetic platform diameter and gingival height. The subject device Abutment Mini Angled Morse is substantially equivalent to the GM Mini Conical Abutment cleared in K163194 in terms of prosthetic diameter, indexing, and angulation. The additional predicates K961736, and K 161416 are in support of substantial equivalence of the Abutment Mini Angled Morse with 17° and 30° of angulation and a gingival height of 4 mm.

The subject device Abutment Cemented Angled SIT and Abutment Cemented Angled Indexed SIT (with 11.5° Morse taper) are substantially equivalent to the corresponding abutment design Abutment Cemented SIT Unitite cleared in K170392, having the same sizes of sizes for prosthetic platform diameter and gingival height. The subject device Abutment Cemented Angled SIT and Abutment Cemented Angled Indexed SIT are substantially equivalent to the CM Universal Abutment cleared in K101945 in terms of indexing and angulation.

The subject device Abutment Mini Angled (with 11.5° Morse taper) are substantially equivalent to the corresponding abutment design Mini Abutment Unitite cleared in K170392, having the same sizes or ranges of sizes for prosthetic platform diameter and gingival height. The subject device Abutment Mini Angled is substantially equivalent to the CM Mini Conical Abutment cleared in K101945 in terms of indexing and angulation.

The subject device Healing Cap Morse and Healing Cap Morse Indexed (with 16° Morse taper) are substantially equivalent to the corresponding design Healing Abutment Strong SW CM cleared in K170392, and to the GM Pro PEEK (Temporary) Abutment cleared in K163194. The GM Pro PEEK (Temporary) Abutment is for support of substantial equivalence of the PEEK material.

The subject device Healing Cap and Healing Cap Indexed (with 11.5° Morse taper) are substantially equivalent to the corresponding design Healing Abutment Unitite cleared in K 170392, and to the GM Pro PEEK (Temporary) Abutment cleared in K163194. The GM Pro PEEK (Temporary) Abutment is for support of substantial equivalence of the PEEK material.

The subject device Healing Cap Compact and Healing Cap Compact Indexed (with 4° Morse taper) are substantially equivalent to the corresponding design Healing Abutment Unitite Compact cleared in K 170392, and to the GM Pro PEEK (Temporary) Abutment cleared in K163194. The GM Pro PEEK (Temporary) Abutment is for support of substantial equivalence of the PEEK material.

The subject device Healing Cap Slim and Healing Cap Slim (with 3° Morse taper) are substantially equivalent to the corresponding design Healing Abutment Unitite Slim cleared in K170392, and to the GM Pro PEEK (Temporary) Abutment cleared in K163194. The GM Pro PEEK (Temporary) Abutment is for support of substantial equivalence of the PEEK material.

The subject device Healing Cap HE and Healing Cap HE Indexed (external hex interface) are substantially equivalent to the corresponding designs Healing Abutment and Cover Screw with external hex interfaces cleared in K170398, and to the GM Pro PEEK (Temporary) Abutment cleared in K163194. The GM Pro PEEK (Temporary) Abutment is for support of substantial equivalence of the PEEK material. The additional predicate K110955 is in support of substantial equivalence of the Healing Cap HE and Healing Cap HE Indexed with a coronal diameter of 8 mm and a gingival height of 6.8 mm.

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The subject device Healing Cap HI and Healing Cap HI Indexed (internal hex interface) are substantially equivalent to the corresponding designs Healing Abutment and Cover Screw with internal hex interfaces cleared in K170398, and to the GM Pro PEEK (Temporary) Abutment cleared in K163194. The GM Pro PEEK (Temporary) Abutment is for support of substantial equivalence of the PEEK material. The additional predicate K110955 also is in support of substantial equivalence of the Healing Cap HI and Healing Cap HI Indexed with a coronal diameter of 8 mm and a gingival height of 6.8 mm.

All subject device healing caps are designed for the healing period between implant placement and final abutment placement, and are not intended to support a temporary prosthesis. The GM Pro PEEK (Temporary) Abutment cleared in K163194 is used to support a provisional prosthesis. This difference does not impact the substantial equivalence of the use of PEEK material for a healing cap or healing abutment.

Minor differences in the exact dimensions of the subject device abutments as compared to the primary predicate and additional predicate devices does not impact safety, effectiveness, or substantial equivalence.

The subject device abutments screws are substantially equivalent in material (titanium alloy) and designs to abutment screws cleared in K170392 and K170398. Selected abutments manufactured from titanium alloy are anodized using a standard anodization process is identical to the anodization process used on abutments cleared in K170392 and K170398.

All subject device components are provided sterile by gamma irradiation, the same sterilization method used in K170392 and K170398.

CONCLUSION

The subject device, the primary predicate device, and the additional predicate devices have the same intended use, have similar technological characteristics, and are made of identical or similar materials. The subject device, the primary predicate, and the additional predicate devices encompass the same range of physical dimensions, are packaged in similar materials, and are sterilized using similar methods.

The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.

{10}------------------------------------------------

Table of Substantial Equivalence

icateAdditional Predicate
Subject DevicePrimary Predicate DeviceAdditional PredicateAdditional Predicatem - GM LineMateriais Dentários SAK101945Neodent Implant SystemJJGC Indústria e Comércio de Materiais Dentários SA
K200992S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.K170392S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.K170398S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.K163194Neodent Implant SystemJJGC Indústria e Comércio de Maconventional abutments:to be surgically placed inovide support for, to restore chewingge or two-stageestorations, and may bestability is achieved andse abutments:ase placed onto Neodentastomized prostheticcrown, or crown alone,gle or multi-unittorations. All digitallywith the Neodentnded to be sent tod milling center.butments:to be used on Neodentor prosthesis structure foror two stage proceduresood primary stability.The Neodent Implant System is intended to be surgicallyplaced in the bone of the upper or lower jaw to providesupport for prosthetic devices such as artificial teeth, torestore chewing function. It may be used with single-stageor two-stage procedures, for single or multiple unitrestorations, and may be loaded immediately when goodprimary stability is achieved and with appropriateocclusal loading. Multiple tooth applications may berigidly splinted.
Indications for Use StatementS.I.N. Dental Implant System is intended for placementin the maxillary or mandibular arch to provide support forsingle-unit or multi-unit restorations. When a one-stagesurgical approach is applied, the S.I.N. Dental ImplantSystem is intended for immediate loading when goodprimary stability is achieved and with appropriateocclusal loading.S.I.N. Dental Implant System is intended for placement inthe maxillary or mandibular arch to provide support forsingle-unit or multi-unit restorations. When a one-stagesurgical approach is applied, the S.I.N. Dental ImplantSystem is intended for immediate loading when goodprimary stability is achieved and with appropriateocclusal loading. Implants with lengths less than 7 mmare intended for delayed loading only.S.I.N. Dental Implant System is intended for placement inthe maxillary or mandibular arch to provide support forsingle-unit or multi-unit restorations. When a one-stagesurgical approach is applied, the S.I.N. Dental ImplantSystem is intended for immediate loading when goodprimary stability is achieved and with appropriateocclusal loading. Revolution Compact with a 6 mmlength is intended for delayed loading only.Indications for Use for GM implants andThe Neodent Implant System is intended forthe bone of the upper or lower jaw to provideprosthetic devices such as artificial teeth, tofunction. It may be used with single-stageprocedures, for single or multiple unit restorations,loaded immediately when good primary stabilitywith appropriate occlusal loading.Indications for Use for GM Titanium Base Abutment:Titanium Base Abutment is a titanium base fordental implants to provide support for customrestorations. It is used with a coping and or capand is indicated for cement-retained single unitrestorations, or screw-retained single restorations,designed copings and/or crowns for use with theTitanium Base Abutment System are intended byStraumann for manufacture at a validated site.Indications for Use for GM Pro Peek Abutment:The Pro PEEK Abutments are indicated to supportimplants to provide temporary support for upup to 6 months. They can be used in one or two stageand also immediate load when there is gooddesignsMaterialAbutment designs
Reason for Predicate /Reference DevicesNot applicableImplant designs; abutment designs;HAnano implant surfaceImplant designs; abutment designsAbutment designs;PEEK materialDZE, NHA
Product CodesDZE, NHADZE, NHADZE, NHADZE, NHAbilitation of theor maxillaFunctional and esthetic rehabilitation of theedentulous mandible or maxilla
Intended UseFunctional and esthetic rehabilitation of theedentulous mandible or maxillaFunctional and esthetic rehabilitation of theedentulous mandible or maxillaFunctional and esthetic rehabilitation of theedentulous mandible or maxillaFunctional and esthetic rehabilitation ofedentulous mandible or maxillaMorse taper (CM, 11.5°)
Implant DesignsImplant linesTitamax and Alvim implant lines3.5/3.5 - 5.0/5.08 - 18Morse taper (CM, 11.5°)
Prosthetic Interface ConnectionsMorse taper (CM, 11.5°)Morse taper (CM, various angles)External hex (HE), Internal hex (HI)Morse taper (CM, 16°; "GM")
Body/Platform Diameters, mmLengths, mmInterfaceStrong SW / Strong SW Plus3.5/3.5; 3.8/3.8; 4.5/4.5; 5.0/5.08.5, 10, 11.5, 13, 15Morse taper interface (CM, 11.5°)Strong SW CM3.5/3.5; 3.8/3.8; 4.5/4.5; 5.0/5.08.5, 10, 11.5, 13, 15Morse taper interface (CM, 16°)Titamax, Helix, and Drive inplant3.5/3.5 - 5.0/5.08 - 18Morse taper (CM, 16°, "GM")
Body/Platform Diameters, mmLengths, mmInterfaceUnitite, Unitite Slim, Unitite CompactVarious sizes, 2.9/2.9 to 6.0/6.0Various lengths, 5 mm to 15 mmReference for HAnano surfaceMorse taper interfaces (CM):Unitite 11.5°, Unitite Slim 3°, Unitite Compact 4°Strong SW HE3.5/3.65; 3.75/4.1; 4.0/4.1; 4.5/4.5; 5.0/5.07*, 8.5, 10, 11.5, 13, 15* no 7 mm length for 4.5 mm bodyExternal hex interface (HE)K10(k) Summary)1-2 sub-crestally (in public labeling)
Body/Platform Diameters, mmLengths, mmInterfaceStrong SW HI3.8/3.8; 4.5/4.5; 5.0/5.08.5, 10, 11.5, 13, 15Internal hex interface (HI)Unalloyed titanium
Body/Platform Diameters, mmLengths, mmBody/Platform Diameters, mmLengths, mmBody/Platform Diameters, mmLengths, mmInterfaceTryon CM Conical3.5/3.5, 4.0/4.0; 5.0/5.08.5, 10, 11.5, 13, 15Tryon CM Cylindrical3.5/3.5, 3.75/3.75, 4.0/4.0; 5.0/5.07, 8.5, 10, 11.5, 13, 15Tryon CM Cylindrical Body and Conical Apex3.5/3.5, 3.8/3.8, 4.5/4.5; 5.0/5.08.5, 10, 11.5, 13, 15Morse taper interface (CM, all implants 11.5°)Tryon HE3.25/4.1; 3.75/4.1; 4.0/4.1; 5.0/5.07*, 8.5, 10, 11.5, 13, 15* no 7 mm length for 3.25 mm bodyExternal hex interface (HE)etched ("Neoporos")drophilic treatmentAll implants: grit-blasted, acid etched ("Neoporos")
Implant Placement Level1.5 mm sub-crestallyCrestally1-2 mm sub-crestallyUp to 2 mm sub-crestally (in situ)
Implant MaterialAll implants: unalloyed titanium, ASTM F67All implants: unalloyed titanium, ASTM F67All implants: unalloyed titanium, ASTM F67Unalloyed titanium
Implant Endosseous SurfaceAll implants: acid-etched;HAnano applied to the Strong SW Plus implant lineonlyAll implants: acid-etched;HAnano applied to the Unitite, Unitite Slim, andUnitite Compact dental implant linesAll implants: acid-etchedAll implants: grit-blasted, acid etchedSelected implants additional hydroxyapatite(

{11}------------------------------------------------

510(k) Summary

Page9of10
Subject DevicePrimary Predicate DeviceAdditional PredicateAdditional Predicate
K200992S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.K170392S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.K170398S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.K163194Neodent Implant SystemJJGC Indústria e Comércio de Materiais Médicos e Odontológicos S.A.
Abutment Designs
Cemented AbutmentsMorse taper interface (CM, 16°)Abutment Cemented Morse AngledMorse taper interface (CM, 16°)Prosthetic platform Ø: 3.3, 4.5 mmGingival height: 1.5-3.5 mmAngle 17°, 30°IndexedAbutment Cemented Strong SW CMMorse taper interface (CM 16°)Prosthetic platform Ø 3.5, 4.5 mmGingival height: 1, 2, 3, 4, 5 mmAngle 0°Non-indexedGM Exact Click Universal AbutmentMorse taper interface (CM 16°)Prosthetic platform Ø 3.3, 4.5 mmGingival height, straight: 0.8-5.5 mmGingival height, angled: 1.5-3.5 mmAngle Straight (0°), 17°, 30°Indexed
Abutment Angled MorseMorse taper interface (CM, 16°)Prosthetic platform Ø: 3.5, 4.5 mmGingival height: 1, 2, 3, 4, 5 mmAngle 17°Indexed
Mini AbutmentsMorse taper interface (CM, 16°)Abutment Mini Angled MorseMorse taper interface (CM, 16°)Prosthetic platform Ø: 4.8 mmGingival height: 2, 3, 4 mmAngle 17°, 30°Indexed and non-indexedMini Abutment Strong SW CMMorse taper interface (CM 16°)Prosthetic platform Ø 4.8 mmGingival height: 1, 2, 3, 4 mmAngle 0°Non-indexedGM Mini Conical AbutmentMorse taper interface (CM 16°)Prosthetic platform Ø: 4.8 mmGingival height: 1.5-3.5 mmAngle 17°, 30°Indexed
Cemented Abutment SITMorse taper interface (CM, 11.5°)Abutment Cemented Angled SITMorse taper interface (CM, 11.5°)Prosthetic platform Ø: 3.3, 4.5 mmGingival height: 1.5-3.5 mmAngle 17°, 30°Non-indexedAbutment Cemented SIT UnititeMorse taper interface (CM 11.5°)Prosthetic platform Ø 3.3 mm, 4.5 mmGingival height: 0.8-5.5 mmAngle 0°Non-indexed
Abutment Cemented Angled Indexed SITMorse taper interface (CM, 11.5°)Prosthetic platform Ø: 3.3, 4.5 mmGingival height: 1.5-3.5 mmAngle 17°, 30°Indexed
Mini AbutmentsMorse taper interface (CM, 11.5°)Abutment Mini AngledMorse taper interface (CM, 11.5°)Prosthetic platform Ø: 4.8 mmGingival height: 1.5-3.5 mmAngle 17°, 30°Indexed and non-indexedMini Abutment UnititeMorse taper interface (CM 11.5°)Prosthetic platform Ø 4.8 mmGingival height: 0.8-5.5 mmAngle 0°Non-indexed
Healing CapsMorse taper interface (CM, 16°)Healing Cap Morse /Healing Cap Morse IndexedMorse taper interface (CM, 16°)Coronal Ø: 5, 8 mmGingival Height: 4, 8 mmNon-indexed and indexedPEEKHealing Abutment Strong SW CMMorse taper interface (CM, 16°)Coronal Ø: 3.5, 4.5 mmGingival Height: 2-6 mmNon-indexedTitanium alloy, ASTM F136GM Pro PEEK (Temporary)Morse taper interface (CM, 16°)Coronal Ø: 4.5, 6 mmGingival Height: 0.8-5.5 mmIndexedTitanium alloy and PEEK
Healing CapsMorse taper interface (CM, 11.5°)Healing Cap / Healing Cap IndexedMorse taper interface (CM, 11.5°)Coronal Ø: 5, 8 mmGingival Height: 4, 8 mmNon-indexed and indexedPEEKHealing Abutment UnititeMorse taper interface (CM, 11.5°)Coronal Ø: 3.3, 4.5 mmGingival Height: 0.8-5.5 mmNon-indexedTitanium alloy, ASTM F136
redicateAdditional Predicate
94stem - GM Linee Materiais Dentários SAK101945Neodent Implant SystemJJGC Indústria e Comércio de Materiais Dentários SA
Abutment(16°)1.5 mm3.5-5.5 mm1.5-3.5 mm
nt(16°)m
CM Universal AbutmentMorse taper interface (CM 11.5°)Prosthetic platform – not in 510(k) SummaryGingival height: 1.5-3.5 mmAngle 17°, 30°Indexed and non-indexed
CM Mini Conical AbutmentMorse taper interface (CM 11.5°)Prosthetic platform - not in 510(k) SummaryGingival height: 1.5-3.5 mmAngle 17°, 30°Indexed
y) Abutment
(16°)

{12}------------------------------------------------

510(k) Summary

Subject DeviceK200992S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.Primary Predicate DeviceK170392S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.Additional PredicateK170398S.I.N. Dental Implant SystemS.I.N. - Sistema de Implante Nacional S.A.Additional PredicateK163194Neodent Implant SystemJJGC Indústria e Comércio de Máquinas e Equipamentos Odontológicos S/A
Healing CapsMorse taper interface (CM, 4°)Healing Cap Compact /Healing Cap Compact IndexedMorse taper interface (CM, 4°)Coronal Ø: 5, 8 mmGingival Height: 4, 8 mmNon-indexed and indexedPEEKHealing Abutment Unitite CompactMorse taper interface (CM, 4°)Coronal Ø: 4.0 mmGingival Height: 2-6 mmNon-indexedTitanium alloy, ASTM F136GM Pro PEEK (Temporary)Morse taper interface (CM, 16°)Coronal Ø: 4.5, 6 mmGingival Height: 0.8-5.5 mmIndexedTitanium alloy and PEEK
Healing CapsMorse taper interface (CM, 3°)Healing Cap Slim /Healing Cap Slim IndexedMorse taper interface (CM, 3°)Coronal Ø: 4 mmGingival Height: 4, 8 mmNon-indexed and indexedPEEKHealing Abutment Unitite SlimMorse taper interface (CM, 3°)Prosthetic platform Ø: 3.3 mmGingival Height: 1.5-4.5 mmNon-indexedTitanium alloy, ASTM F136
Healing CapsExternal hex interface (HE)Healing Cap HE / Healing Cap HE IndexedExternal hex interface (HE)Platform Ø: 3.4, 3.5, 4.1, 5.0 mmCoronal Ø: 5, 8 mmGingival Height: 6.8 mmNon-indexed and indexedPEEKHealing AbutmentExternal hex interface (HE)Platform Ø 3.65, 4.1, 5.0 mmCoronal Ø: 4.1, 5.0 mmGingival height: 2, 4, 6, 8 mmTitanium alloy, ASTM F136Cover ScrewExternal hex interface (HE)Platform Ø 3.4, 3.65, 4.1, 5.0 mmCoronal Ø: 3.5-5.0 mmTitanium alloy, ASTM F136GM Pro PEEK (Temporary)Morse taper interface (CM, 16°)Coronal Ø: 4.5, 6 mmGingival Height: 0.8-5.5 mmIndexedTitanium alloy and PEEK
Healing CapsInternal hex interface (HI)Healing Cap HI / Healing Cap HI IndexedExternal hex interface (HI)Platform Ø: 3.8, 4.5 mmCoronal Ø: 5, 8 mmGingival Height: 6.8 mmNon-indexed and indexedPEEKHealing AbutmentExternal hex interface (HI)Platform Ø 3.8, 4.5 mmCoronal Ø: 4, 5 mmGingival height: 2, 4, 6 mmTitanium alloy, ASTM F136Cover ScrewExternal hex interface (HI)Platform Ø 3.8, 4.5, 5.0 mmCoronal Ø: 3.8, 4.5, 5.0 mmTitanium alloy, ASTM F136GM Pro PEEK (Temporary)Morse taper interface (CM, 16°)Coronal Ø: 4.5, 6 mmGingival Height: 0.8-5.5 mmIndexedTitanium alloy and PEEK
Abutment MaterialsTitanium alloy, ASTM F136PEEK, ASTM F2026Titanium alloy, ASTM F136Cobalt-chromium alloy, ASTM F1537Titanium alloy, ASTM F136Cobalt-chromium alloy, ASTM F1537Titanium alloyPEEK
Abutment Screw MaterialsTitanium alloy, ASTM F136Titanium alloy, ASTM F136Titanium alloy, ASTM F136Titanium alloy
How Provided
ImplantsAll sterile by gamma irradiationAll sterile by gamma irradiationAll sterile by gamma irradiationAll sterile by gamma irradiation
AbutmentsAll sterile by gamma irradiationAll sterile by gamma irradiation, except:Provisional, SIT Provisional Cap, and UCLA-typeabutmentsNon-sterile components to be moist heat sterilizedby end userAll sterile by gamma irradiation, except:Provisional and UCLA-type abutmentsNon-sterile components to be moist heat sterilizedby end userAll sterile by EO exposure
Abutment ScrewsAll sterile by gamma irradiationAll sterile by gamma irradiationAll sterile by gamma irradiationAll sterile by EO exposure
UsageSingle patient, single useSingle patient, single useSingle patient, single useSingle patient, single use

Page 10 of 10

licateAdditional Predicate
m - GM LineK101945Neodent Implant System
teriais Dentários SAJJGC Indústria e Comércio de Materiais Dentários SA
Abutment
)
Abutment
)
Abutment
)
Titanium alloy
Titanium alloy
All sterile by gamma irradiation
All sterile by EO exposure
All sterile by EO exposure
Single patient, single use

§ 872.3640 Endosseous dental implant.

(a)
Identification. An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that 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, in order to restore a patient's chewing function.(b)
Classification. (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. 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.)(2)
Classification. Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.