K Number
K201919
Device Name
Blue Sky Bio TAD
Manufacturer
Date Cleared
2020-12-17

(160 days)

Product Code
Regulation Number
872.3640
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The proposed Blue Sky Bio TAD is intended to provide a fixed anchorage point for attachment of orthodonic appliances to facilitate the orthodontic movement of teeth. It is used temporarily and is removed after orthodontic treatment has been completed. Screws are intended for a single use only. For use in adolescents greater than age 12 and adults.
Device Description
The Blue Sky Bio TAD is fabricated from titanium Alloy without surface treatment, which meets the material requirements specified in the standard ASTM F-136-08. The head on the proximal portion of the screw incorporates a recess, which provides an option for the orthodontist to pass through a wire and tie it in the neck of the Blue Sky Bio TAD in the orthodontic treatment. Distal to the recess is a square indentation that is used as a screw head. The smooth neck distal to the proximal head employs a hole through which a wire can be passed to fix the mandible and maxilla in orthodontic treatment. Distal to the neck is the collar, which has a tapered design to protect the soft tissue. The distal portion of the proposed Blue Sky Bio TAD is threaded for quick insertion and provides stability and biomechanic retention once the screw is fully inserted. The distal tip of the screw is machined with high precision manufacturing.
More Information

No
The device description focuses on the physical characteristics and material of a temporary anchorage device (TAD) for orthodontic use, with no mention of software, algorithms, or AI/ML capabilities.

No.
The device facilitates orthodontic movement of teeth, which is a treatment, but the device itself is a fixed anchorage point and not considered a therapeutic device in the medical device regulatory context as it doesn't directly provide a therapeutic effect through its inherent mechanism.

No

The device is an orthodontic appliance used for anchorage in teeth movement, not for diagnosing medical conditions.

No

The device description clearly details a physical implantable screw made of titanium alloy, not software.

Based on the provided information, the Blue Sky Bio TAD is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • IVD Definition: In vitro diagnostic devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information about a person's health.
  • Blue Sky Bio TAD Function: The description clearly states that the Blue Sky Bio TAD is a physical device intended to be implanted into the bone to provide anchorage for orthodontic appliances. It is a mechanical device used in vivo (within the body) to facilitate tooth movement.
  • Lack of Specimen Analysis: There is no mention of the device being used to analyze any biological specimens. Its function is purely mechanical and structural.

Therefore, the Blue Sky Bio TAD falls under the category of a medical device, specifically an orthodontic appliance or accessory, but not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The proposed Blue Sky Bio TAD is intended to provide a fixed anchorage point for attachment of orthodonic appliances to facilitate the orthodontic movement of teeth. It is used temporarily and is removed after orthodontic treatment has been completed. Screws are intended for a single use only. For use in adolescents greater than age 12 and adults.

Product codes

OAT

Device Description

The Blue Sky Bio TAD is fabricated from titanium Alloy without surface treatment, which meets the material requirements specified in the standard ASTM F-136-08. The head on the proximal portion of the screw incorporates a recess, which provides an option for the orthodontist to pass through a wire and tie it in the neck of the Blue Sky Bio TAD in the orthodontic treatment. Distal to the recess is a square indentation that is used as a screw head.

The smooth neck distal to the proximal head employs a hole through which a wire can be passed to fix the mandible and maxilla in orthodontic treatment. Distal to the neck is the collar, which has a tapered design to protect the soft tissue. The distal portion of the proposed Blue Sky Bio TAD is threaded for quick insertion and provides stability and biomechanic retention once the screw is fully inserted. The distal tip of the screw is machined with high precision manufacturing.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

adolescents greater than age 12 and adults

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)

Non-clinical performance tests are:

  • Axial pull-out strength testing
    According to the test standard (ASTM F543), Pull-out strength testing is performed for the effectiveness of the mechanical design of the orthodontic mini implant and its elimination.

  • Peak Torque Value . The test was performed according to Article by Drs. Jolley and Chung Published in the Journal of Clinical Orthopedics.

  • Insertion Torque Test The test was performed in order to measure the torque required for insertion of the Blue Sky Bio TAD anchor, in the worst-case scenario version into a standard material, and to validate the surgical provided in the instructions for use.

  • Sterilization
    The subject device TAD implants are provided sterile and non-sterile.

The TAD implants that are provided sterile has been validated according to ISO 11137-1 Sterilization of health care products - Radiation - Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices and ISO 11137-2 Sterilization of health care products – Radiation - Part 2: Establishing the sterilization dose.

The TAD implants that are provided non-sterile are to be sterilized by the end user. The recommended moist heat (steam)sterilization cycle has been validated according to ISO 17665-1 Sterilization of health care products – Moist heat – Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices, and ISO 17665-2 Sterilization of health care products – Moist heat – Part 2: Guidance on the application of ISO 17665-1.

  • Shel Life
    All implant, sterile and non-sterile, are packaged in as single units sealed in a plastic pouch (polyethylene terephthalate/low density polyethylene, PET/LDPE) with a peelable chevron seal, and each sealed pouch is then inserted into a single unit plastic envelope (polyethylene terephthalate glycol-modified, PETG).

The sterile barrier shelf life for the subject device was determined by the following aging methods: Accelerated method and Real-time shelf life. For accelerated and real time, package integrity of the sterile barrier was confirmed by the following test method: Distribution testing according to ASTM D4169 Standard Practice for Performance Testing of Shipping Containers and Systems; Seal strength testing according to ASTM F88 Standard Test Method for Seal Strength of Flexible Barrier Materials; and Sterile barrier system Integrity by dye penetration testing.

  • Biocompatibility .
    The subject device implants are made of titanium alloy conforming to ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401). This titanium alloy is commonly used in endosseous dental implants and abutments, with a history of safe use, and is the same material used for predicate device OrthoFix previously cleared in K113650. The subject device is manufactured in the same facilities and use the same manufacturing process as used from Blue Sky Bio devices and components previously cleared. Therefore, no new biocompatibility testing has been performed as the subject device is identical to the predicate devices and reference devices with regards to materials and processing.

  • Pyrogenicity Blue Sky Bio LLC, conducts Pyrogenicity test to meet pyrogen limit specifications. This test will be conducted on every batch.

Clinical testing was not required to demonstrate the substantial equivalence of the Blue Sky Bio TAD to its predicate device.

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

Not Found

Predicate Device(s)

K113650

Reference Device(s)

K033767, K102034

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

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Image /page/0/Picture/0 description: The image shows 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, with the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in large, bold, blue letters, and the word "ADMINISTRATION" in smaller, blue letters below.

Blue Sky Bio, LLC % Juan Tezak Consultant Compliance 4 Devices 118 W Prive Cr. Delray Beach, Florida 33445

Re: K201919

Trade/Device Name: Blue Sky Bio TAD Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: Class II Product Code: OAT Dated: November 12, 2020 Received: November 19, 2020

Dear Juan Tezak:

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.

Andrew Steen Assistant 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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Image /page/2/Picture/1 description: The image shows the logo for Blue Sky Bio. The logo consists of a light blue swirl on the left and the text "BlueSkyBio" in yellow on the right. The swirl is a stylized representation of a vortex or spiral. The text is in a sans-serif font and is slightly bolded.

4. Indications for Use Statement

DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.

510(k) Number (if known)
--------------------------

K201919

Device Name

Blue Sky Bio TAD

Indications for Use (Describe)

The proposed Blue Sky Bio TAD is intended to provide a fixed anchorage point for attachment of orthodonic appliances to facilitate the orthodontic movement of teeth. It is used temporarily and is removed after orthodontic treatment has been completed. Screws are intended for a single use only. For use in adolescents greater than age 12 and adults.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

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

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

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

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Image /page/3/Picture/1 description: The image shows the logo for BlueSkyBio. The logo consists of a light blue swirl on the left and the text "BlueSkyBio" in yellow on the right. The swirl is made up of several curved lines that create a circular shape.

5. 510(k) Summary

K201919 Blue Sky Bio, LLC Blue Sky Bio TAD December 17th, 2020

ADMINISTRATIVE INFORMATION

Applicant

Blue Sky Bio, LLC 800 Liberty Dr. Libertyville, IL 60048

Phone: +1 718-376-0422

Establishment Registration Number

3003402534

Official Contact

Representative/Consultant

Sharon Nichols, Regulatory Representative

Juan Tezak Carlos Marín Compliance4Devices 118 W Prive Cr. Delray Beach Fl, 33445 Tel: +1 561-789-2411 e-mail: compliance4devices@gmail.com

DEVICE AND CLASSIFICATION NAME

Device Trade Name: Common Name: Classification Regulation: Classification Name: Device Classification: Classification Panel: Product Code:

Blue Sky Bio TAD Bone Screw, Orthodontic 21 CFR 872.3640 Endosseous dental implant Class II Dental OAT

PREDICATE DEVICES INFORMATION

Primary predicate K113650, OrthoFix Screw

Reference device K033767, Dual Top Anchor System Screw

K102034, Blue Sky Bio Dental Implant System

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Image /page/4/Picture/1 description: The image contains the logo for Blue Sky Bio. The logo consists of a light blue swirl on the left and the words "BlueSkyBio" in yellow on the right. The swirl is a stylized representation of a vortex or spiral.

Intended Use

The proposed Blue Sky Bio TAD is intended to provide a fixed anchorage point for attachment of orthodontic appliances to facilitate the orthodontic movement of teeth. It is used temporarily and is removed after orthodontic treatment has been completed. Screws are intended for a single use only. For use in adolescents greater than age 12 and adults.

Device Description

The Blue Sky Bio TAD is fabricated from titanium Alloy without surface treatment, which meets the material requirements specified in the standard ASTM F-136-08. The head on the proximal portion of the screw incorporates a recess, which provides an option for the orthodontist to pass through a wire and tie it in the neck of the Blue Sky Bio TAD in the orthodontic treatment. Distal to the recess is a square indentation that is used as a screw head.

The smooth neck distal to the proximal head employs a hole through which a wire can be passed to fix the mandible and maxilla in orthodontic treatment. Distal to the neck is the collar, which has a tapered design to protect the soft tissue. The distal portion of the proposed Blue Sky Bio TAD is threaded for quick insertion and provides stability and biomechanic retention once the screw is fully inserted. The distal tip of the screw is machined with high precision manufacturing.

Equivalence to Marketed Devices

Blue Sky Bio TAD is substantially equivalent to the predicated device and reference devices. In further support of a substantial equivalence determination, here-under is a comparison chart with the submitted device, the predicate device and reference device.

FeatureSubject DevicePredicate DeviceReference deviceReference device
Blue Sky Bio, LLC
Blue Sky Bio TAD
K201919BonaFix Surgical &
Dental Implants, LLC
OrthoFix Screw
K113650Jeil Medical Corp.
Dual Top Anchor
System Screw
K033767Blue Sky Bio, LLC
Blue Sky Bio Dental
Implant System
K102034
MaterialMedical Grade
Titanium Alloy
ASTM 136Medical Grade
Titanium Alloy
ASTM 136Medical Grade
Titanium Alloy
ASTM 136Medical Grade
Titanium Alloy
ASTM 136
Surface
treatmentNoNoNoYes
Design Screw
HeadIncorporates a recessIncorporates a recessIncorporates a recess
Design NeckThrough holeThrough holeThrough hole
Design CollarTaperedTaperedTapered
Principle of
OperationProvide fixed
anchorage for
orthodontic
movement of teethProvide fixed
anchorage for
orthodontic
movement of teethProvide fixed
anchorage for
orthodontic
movement of teeth
Diameter1.6 and 1.8 mm1.6 and 1.8 mm1.4, 1.6 & 2.0 mm
Length6 and 9mm6 and 9mm6, 8, 10 & 12 mm
Indications for
UseThe proposed Blue
Sky Bio TAD isThe device is
intended to provideThe device is
intended to provide

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Image /page/5/Picture/1 description: The image contains the logo for BlueSkyBio. On the left side of the logo is a light blue swirl. To the right of the swirl is the company name, BlueSkyBio, in yellow font.

| | intended to provide a
fixed anchorage point
for attachment of
orthodontic
appliances to
facilitate the
orthodontic
movement of teeth. It
is used temporarily
and is removed after
orthodontic
treatment has been
completed. Screws
are intended for a
single use only. For
use in adolescents
greater than age 12
and adults. | fixed anchorage point
for attachment of
orthodontic
appliances to
facilitate the
orthodontic
movement of teeth. It
is used temporarily
and is removed after
orthodontic
treatment has been
completed. Screws
are intended for
single use only. For
use in adolescents
greater than age 12
and adults | fixed anchorage point
for attachment of
orthodontic
appliances to
facilitate the
orthodontic
movement of teeth. It
is used temporarily
and is removed after
orthodontic
treatment has been
completed. Screws
are intended for
single use only. For
use in adults over the
age of 12 | |
|------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Single use | Yes | Yes | Yes | Yes |
| Sterility | Provided sterile and
Non-sterile | Provided sterile | Provided Non-sterile | Provided sterile |
| Packaging | Packaged in as single
units sealed in a
plastic pouch
(polyethylene
terephthalate/low
density polyethylene,
PET/LDPE) with a
peelable chevron
seal, and each sealed
pouch is then
inserted into a single
unit plastic envelope
(polyethylene
terephthalate glycol-) | | | Packaged in as single
units sealed in a
plastic pouch
(polyethylene
terephthalate/low
density polyethylene,
PET/LDPE) with a
peelable chevron
seal, and each sealed
pouch is then
inserted into a single
unit plastic envelope
(polyethylene
terephthalate glycol-) |

Blue Sky Bio TAD is substantially equivalent in design, function, operating principle, material, sizes, and Indications for Use to predicate device OrthoFix Screw (K113650) and reference device Dual Top Anchor System Screw (K033767).

The subject device has two presentations, sterile and non-sterile. Regarding to sterile product, subject device is substantially equivalent to predicate device OrthoFix Screw (K113650); and to non-sterile product is substantially equivalent to the reference device Dual Top Anchor System Screw (K033767).

The packaging of the subject device is going to be the same in design, materials and dimensions as the reference Blue Sky Bio Implant System (K102034). The device reference packaging validation to maintain a sterile barrier for the entirety of the proposed shelf life was applied.

Non-Clinical Testing Summary

Non-clinical performance tests are:

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Image /page/6/Picture/1 description: The image shows the logo for Blue Sky Bio. The logo consists of a light blue swirl on the left and the words "BlueSkyBio" in yellow on the right. The swirl is a stylized representation of a vortex or spiral.

  • . Axial pull-out strength testing
    According to the test standard (ASTM F543), Pull-out strength testing is performed for the effectiveness of the mechanical design of the orthodontic mini implant and its elimination.

  • Peak Torque Value . The test was performed according to Article by Drs. Jolley and Chung Published in the Journal of Clinical Orthopedics.

  • . Insertion Torque Test The test was performed in order to measure the torque required for insertion of the Blue Sky Bio TAD anchor, in the worst-case scenario version into a standard material, and to validate the surgical provided in the instructions for use.

  • . Sterilization

The subject device TAD implants are provided sterile and non-sterile.

The TAD implants that are provided sterile has been validated according to ISO 11137-1 Sterilization of health care products - Radiation - Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices and ISO 11137-2 Sterilization of health care products – Radiation - Part 2: Establishing the sterilization dose.

The TAD implants that are provided non-sterile are to be sterilized by the end user. The recommended moist heat (steam)sterilization cycle has been validated according to ISO 17665-1 Sterilization of health care products – Moist heat – Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices, and ISO 17665-2 Sterilization of health care products – Moist heat – Part 2: Guidance on the application of ISO 17665-1.

  • Shel Life ●
    All implant, sterile and non-sterile, are packaged in as single units sealed in a plastic pouch (polyethylene terephthalate/low density polyethylene, PET/LDPE) with a peelable chevron seal, and each sealed pouch is then inserted into a single unit plastic envelope (polyethylene terephthalate glycol-modified, PETG).

The sterile barrier shelf life for the subject device was determined by the following aging methods: Accelerated method and Real-time shelf life. For accelerated and real time, package integrity of the sterile barrier was confirmed by the following test method: Distribution testing according to ASTM D4169 Standard Practice for Performance Testing of Shipping Containers and Systems; Seal strength testing according to ASTM F88 Standard Test Method for Seal Strength of Flexible Barrier Materials; and Sterile barrier system Integrity by dye penetration testing.

  • Biocompatibility .
    The subject device implants are made of titanium alloy conforming to ASTM F136, Standard Specification for Wrought Titanium-6 Aluminum-4 Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401). This titanium alloy is commonly used in endosseous dental implants and abutments, with a history of safe use, and is the same material used for predicate device OrthoFix previously cleared in K113650. The subject device is manufactured in the same facilities and use the same manufacturing process as used from Blue Sky Bio devices and components previously cleared. Therefore, no new biocompatibility

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Image /page/7/Picture/1 description: The image shows the logo for Blue Sky Bio. On the left side of the logo is a light blue swirl. To the right of the swirl is the company name, "BlueSkyBio" in yellow font.

testing has been performed as the subject device is identical to the predicate devices and reference devices with regards to materials and processing.

  • . Pyrogenicity Blue Sky Bio LLC, conducts Pyrogenicity test to meet pyrogen limit specifications. This test will be conducted on every batch.

Clinical Testing Summary

Clinical testing was not required to demonstrate the substantial equivalence of the Blue Sky Bio TAD to its predicate device.

Conclusion

  • . The subject device is made of the same materials and is identical in regards to dimensions and characteristics as the primary predicate device.
  • . The subject device is manufactured from Titanium Alloy that is widely used in this kind of endosseous dental implant systems.
  • . The subject device is manufactured in the same facilities using the same manufacturing processes were Blue Sky Bio LLC manufacture others implants and components that were previously cleared by the FDA.
  • . The subject device and predicate device are substantially equivalent in their intended use, technological characteristics and performance.

We conclude that the Blue Sky Bio TAD is substantial equivalent to the predicate devices listed above.