K Number
K214076
Device Name
EsCem
Manufacturer
Date Cleared
2022-12-19

(357 days)

Product Code
Regulation Number
872.3275
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Final cementation of all-ceramic, metal-based inlays, onlays, posts, crown and bridge
Device Description
EsCem is a dual-cured resin cement that can be self-etched and self-adhesive. It is classified as type 2 and class 3 according to ISO 4049. It is easy to handle with 'one step' system that does not need pre-treatment process, and it is easy to remove excess cement, so it is possible to perform quick operation. It is also easy to identify because it has a radio-opacity(1.2mm Al). And it offers various shades for aesthetics and color stable.
More Information

Not Found

No
The device description and performance studies focus on the material properties and handling characteristics of a dental resin cement, with no mention of AI or ML technologies.

No.
This device is a resin cement used for dental restorations, not a device that treats or prevents a disease or condition.

Cleaned Input:

Intended Use / Indications for Use

Final cementation of all-ceramic, metal-based inlays, onlays, posts, crown and bridge

Device Description

EsCem is a dual-cured resin cement that can be self-etched and self-adhesive. It is classified as type 2 and class 3 according to ISO 4049. It is easy to handle with 'one step' system that does not need pre-treatment process, and it is easy to remove excess cement, so it is possible to perform quick operation. It is also easy to identify because it has a radio-opacity(1.2mm Al). And it offers various shades for aesthetics and color stable.

Response:

No
This device is a dental resin cement used for the final cementation of various dental restorations. It does not perform any diagnostic function.

No

The device description clearly identifies EsCem as a dual-cured resin cement, which is a physical material, not software. The performance studies also focus on material properties and biocompatibility.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is the "Final cementation of all-ceramic, metal-based inlays, onlays, posts, crown and bridge." This describes a process of physically bonding dental restorations to teeth.
  • Device Description: The description details a "dual-cured resin cement" with properties related to its physical and chemical characteristics for bonding.
  • Lack of Diagnostic Purpose: An IVD is a device intended for use in vitro for the examination of specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. This device does not perform any such examination or provide diagnostic information. It is a material used in a dental procedure.

The information provided clearly indicates this is a dental cement used for restorative purposes, not a diagnostic tool.

N/A

Intended Use / Indications for Use

Final cementation of all-ceramic, metal-based inlays, onlays, posts, crown and bridge

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

EMA

Device Description

EsCem is a dual-cured resin cement that can be self-etched and self-adhesive. It is classified as type 2 and class 3 according to ISO 4049. It is easy to handle with 'one step' system that does not need pre-treatment process, and it is easy to remove excess cement, so it is possible to perform quick operation. It is also easy to identify because it has a radio-opacity(1.2mm Al). And it offers various shades for aesthetics and color stable.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Tooth

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Dentist

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)

The performance test was conducted to prove the substantially equivalence of the subject device, and the standards applied to the performance test are as follows.

PerformanceTest methodRequirement
Film thicknessISO 4049:2019-7.5 Measurement of film thickness of luting materialsshall be no greater than 50 μm.
Working timeISO 4049:2019-7.7 Working time, Class 1 and Class 3 luting materialsduring its formation there shall be no detectable change in its homogeneity.
Setting timeISO 4049:2019-7.8 Setting time, Class 1 and Class 3 materialsshall be no more than 10 min.
Flexural strengthISO 4049:2019-7.11 Flexural strengthshall be equal to or greater than 50 MPa
Water sorptionISO 4049:2019-7.12 Water sorption and solubilityshall be equal to or less than 40 µg/mm³.
SolubilityISO 4049:2019-7.12 Water sorption and solubilityshall be equal to or less than 7,5 µg/mm³.
Radio-opacityISO 4049:2019-7.14 Radio-opacityshall be equal to or greater than that of the same thickness of aluminium
Sensitivity to lightISO 4049:2019-7.9 Sensitivity to light, Class 2 materialsthe material shall remain physically homogeneous.
Color stabilityISO 4049:2019-7.13 Shade and colour stability after irradiation and water sorptionno more than a slight change in colour shall be observed

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

Not Found

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

K120243

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

Not Found

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

Not Found

§ 872.3275 Dental cement.

(a)
Zinc oxide-eugenol —(1)Identification. Zinc oxide-eugenol is a device composed of zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.(2)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 872.9.(b)
Dental cement other than zinc oxide-eugenol —(1)Identification. Dental cement other than zinc oxide-eugenol is a device composed of various materials other than zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.(2)
Classification. Class II.

0

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. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 19, 2022

Spident Co., Ltd. Eunok Choi Manager 203 & 312, Korea Industrial Complex, 722 Gojan-Dong, Namdong-Gu, Incheon 405-821 SOUTH KOREA

Re: K214076

Trade/Device Name: EsCem Regulation Number: 21 CFR 872.3275 Regulation Name: Dental Cement Regulatory Class: Class II Product Code: EMA Dated: November 9, 2022 Received: November 18, 2022

Dear Eunok Choi:

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

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

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal

1

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 (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Michael E. Adjodha -S

Michael E. Adjodha, M.ChE. Assistant Director DHT1B: Division of Dental and ENT 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) K214076

Device Name EsCem

Indications for Use (Describe)

Final cementation of all-ceramic, metal-based inlays, onlays, posts, crown and bridge

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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K214076

Image /page/3/Picture/1 description: The image shows the word "SPIDENT" in green font. The letters are enclosed in a green box. The box is open on the top and left sides, with the letters "SP" outside of the box and the letters "IDENT" inside of the box. The background is white.

SPIDENT CO., LTD.

203 & 312, Korea Industrial Complex, 722, Gojan-Dong, Namdong-Gu, Incheon, Korea 405-821 Tel : +82-32-821-0071 Fax : + 82-32-821-0074

Section 5. 510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of 21 CFR Part 807.92(c).

Date: December 22, 2021

1. Company and Correspondent making the submission:

Company Name : SPIDENT CO., LTD. Address : 203 & 312 Korea Industrial Complex, 722, Gojan-Dong, Namdong-Gu, Incheon, Korea 405-821 Tel : +82-32-821-0071 Fax : + 82-32-821-0074 Company Contact : J.M. Ahn / President

2. Device Name and Classification

Proprietary Name : EsCem Common name : Self-Adhesive Resin Cement Classification name : Dental Cement [CFR 872.3275] Product code : EMA Class : II

3. Predicate Devices (Legally Marketed Devices)

The predicate devices for EsCem is :

  • G-CEM LinkAce (GAM-200), GC AMERICA INC., K120243

4. Description:

EsCem is a dual-cured resin cement that can be self-etched and self-adhesive. It is classified as type 2 and class 3 according to ISO 4049. It is easy to handle with 'one step' system that does not need pre-treatment process, and it is easy to remove excess cement, so it is possible to perform quick operation. It is also easy to identify because it has a radio-opacity(1.2mm Al). And it offers various shades for aesthetics and color stable.

4

Image /page/4/Picture/0 description: The image is a logo for Spident. The logo is green and features the word "SPIDENT" in a bold, sans-serif font. The word is enclosed in a square frame, with the top and bottom lines of the frame extending beyond the sides of the word. The logo is simple and modern, and the green color gives it a fresh and natural feel.

SPIDENT CO., LTD.

203 & 312, Korea Industrial Complex, 722, Gojan-Dong, Namdong-Gu, Incheon, Korea 405-821 Tel : +82-32-821-0071 Fax : + 82-32-821-0074

5. Indications for Use

Final cementation of all-ceramic, metal-based inlays, onlays, posts, crown and bridge

6. Performance Testing - Bench

The performance test was conducted to prove the substantially equivalence of the subject device, and the standards applied to the performance test are as follows.

PerformanceTest methodRequirement
Film thicknessISO 4049:2019
-7.5 Measurement of film thickness of luting materialsshall be no greater than 50 μm.
Working timeISO 4049:2019
-7.7 Working time, Class 1 and Class 3 luting materialsduring its formation there shall be no detectable change in its homogeneity.
Setting timeISO 4049:2019
-7.8 Setting time, Class 1 and Class 3 materialsshall be no more than 10 min.
Flexural strengthISO 4049:2019
-7.11 Flexural strengthshall be equal to or greater than 50 MPa
Water sorptionISO 4049:2019
-7.12 Water sorption and solubilityshall be equal to or less than 40 µg/mm³.
SolubilityISO 4049:2019
-7.12 Water sorption and solubilityshall be equal to or less than 7,5 µg/mm³.
Radio-opacityISO 4049:2019
-7.14 Radio-opacityshall be equal to or greater than that of the same thickness of aluminium
Sensitivity to lightISO 4049:2019
-7.9 Sensitivity to light, Class 2 materialsthe material shall remain physically homogeneous.
Color stabilityISO 4049:2019
-7.13 Shade and colour stability after irradiation and water sorptionno more than a slight change in colour shall be observed
  • · ISO 4049:2019, Dentistry Polymer-based restorative materials

7. Biocompatibility

Biocompatibility tests and biological safety evaluation were performed and the results proved that the subject device is at least as biocompatible and biologically safe as the predicate device.

The standards applied are as follows.

  • · ISO 10993-1:2018, Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process
  • · ISO 10993-3:2014, Biological evaluation of medical devices Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicity
  • · ISO 10993-5:2009, Biological evaluation of medical devices Part 5: Tests for in

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Image /page/5/Picture/0 description: The image shows the logo for SPIDENT. The logo is green and features the word "SPIDENT" in a sans-serif font. The letters are enclosed in a square-shaped border that is open on the left and right sides. The logo is simple and modern.

SPIDENT CO., LTD.

203 & 312, Korea Industrial Complex, 722, Gojan-Dong, Namdong-Gu, Incheon, Korea 405-821 Tel : +82-32-821-0071 Fax : + 82-32-821-0074

vitro cytotoxicity

  • ISO 10993-6:2016, Biological evaluation of medical devices Part 6: Tests for local effects after implantation
  • · ISO 10993-10:2010, Biological evaluation of medical devices. Tests for irritation and skin sensitization
  • ISO 10993-11:2017, Biological evaluation of medical devices Part 11: Tests for systemic toxicity
  • ISO 7405:2018, Dentistry Evaluation of biocompatibility of medical devices used in dentistry
Product NameEsCemG-CEM LinkAce
510(k)N/AK120243
ManufacturerSPIDENT CO., LTD.GC Corporation
Product descriptionEsCem is a dual-cured resin cement
that can be self-etched and self-
adhesive and is classified as type 2
and class 3 according to ISO 4049.
It is easy to handle with 'one step'
system that does not need pre-
treatment process, and it is easy to
remove excess cement, so it is
possible to perform quick
operation. It is also easy to identify
because it has a radiopaque. And it
offers various shades for aesthetics.GC G-CEM LinkAce is a dual-cure
self-adhesive universal resin luting
cement delivered in double barrel
automix syringe, designed for the
adhesive luting of all-ceramic,
metal or composite indirect
restorations.
Chemical
composition of
ResinMethacrylate monomer
Filler
Initiator
Inhibitor
pigmentMethacrylate monomer
Filler
Initiator
Inhibitor
pigment
Indications for useFinal cementation of all-ceramic,
metal-based inlays, onlays, posts,
crown and bridge- Cementation of all types of all
ceramic, resin and metal-based
inlays, onlays, crowns and bridges.
  • Cementation of metal, ceramic,
    fibre posts, and cast post and cores. |
    | Principle of
    operation | Dual cured | Dual cured |

8. Substantial Equivalence Discussion

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Image /page/6/Picture/0 description: The image shows the logo for SPIDENT. The logo is green and features the word "SPIDENT" in a bold, sans-serif font. The word is enclosed in a square bracket that is missing the top right corner. The logo is simple and modern.

SPIDENT CO., JLTD.
203 & 312, Korea Industrial Complex, 722, Gojan-Dong, NamdongGu, Incheon, Korea 405-821
Tel : +82-32-821-0071 Fax : + 82-32-821-0074

| Mechanical

Properties
• Setting time (sec)Less than 600 secLess than 600 sec
• Flexural strength
(MPa)More than 50More than 50
• Film thickness
(μm)Less than 50Less than 50
• Water sorption
(µg/mm³)Less than 40Less than 40
• Solubility
(µg/mm³)Less than 7.5Less than 7.5
• Radio-opacity
(mmAl)More than 1 mmMore than 1 mm
Standard
conformedISO 4049ISO 4049
BiocompatibilityYesYes
Light Curing Time20 Seconds20 Seconds
Application AreaToothTooth
Target PopulationDental patientDental patient
Intended OperatorDentistDentist
Storage condition2-27°C4-25°C
ShadeA2, A3, TWA2, AO3, BO1, Translucent

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Image /page/7/Picture/0 description: The image shows the logo for Spident. The logo is green and features the word "SPIDENT" in a sans-serif font. The letters are all capitalized and are a light shade of green. The word is enclosed in a square border that is also green.

SPIDENT CO., LTD.

203 & 312, Korea Industrial Complex, 722, Gojan-Dong, Namdong-Gu, Incheon, Korea 405-821 Tel : +82-32-821-0071 Fax : + 82-32-821-0074

9. Similarities and Differences with Marketed Devices:

The subject device, EsCem and the predicate device, G-CEM LinkAce (GAM-200) was compared as above. Both products have the similar product description as a dental cement. In case of composition, two products contain slightly different raw materials, but the subject device and the predicate device show the same performance as monomer, filler, photo inhibitor (stabilizer), self-cure initiator, photo initiator and pigment. For this reason, despite difference in material, both the subject device and the equivalent device have no problem in terms of the clinical performance.

Indication for use of the two products are almost same and both products can be used as dual cure. The performance results of the two products are not the same, but both products meet the requirements of ISO 4049. Biocompatibility, Light Curing Time, Application Area, Target Population, Intended Operator of both products are the same. In case of Storage condition and Shade, there is a slight difference but performance and biocompatibility test showed that these differences would not raise any new questions of safety and effectiveness. Therefore, EsCem is substantially equivalent with predicate device, G-CEM LinkAce, and at least as safe and effective as the predicate device.

10. Conclusion

Based on a comparison of subject device, EsCem (SPIDENT CO., LTD) and predicate device, G-CEM LinkAce (GC America INC.), it is confirmed that the subject device is substantially equivalent to predicate device.