(113 days)
Stratasys TrueDent™ is a light-curable resin indicated for the fabrication of dental appliances including removable full and partial dentures, denture bases, denture teeth, bridges, crowns, inlays, and veneers in dental laboratories. The material is an alternative to traditional heat-curable and auto polymerizing resins. Stratasys TrueDent™ is intended exclusively for professional dental work.
Stratasys TrueDent™ is a light-curable methacrylate-based resin, that enables fabrication of monolithic, high quality, functional, and aesthetic dental appliances, including full and partial removable dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays and veneers in a CAD/CAM additive manufacturing process. This material is intended to be used by trained dental professionals for the fabrication of various dental appliances in a CAD/CAM additive manufacturing process that includes the following components: digital dental files based on a digital impression, a Stratasys Poly Jet 3D printer, and curing light equipment. It is an alternative to traditional heat cured and auto polymerization resins. The predesigned color of the dental appliance is achieved by digitally mixing colored resins. The resins are available in five (5) different base colors (clear, white, cyan, magenta, and yellow). Stratasys TrueDent can be used only with Stratasys J5 Series printers. Stratasys J5 Series printers include a 3D printing system that utilizes PolyJet technology, with drop-on-demand inkjet printing process, 3 print heads, and a UV LED (395nm) curing process. The dental appliance is then cured in the Stratasys TrueDent™ Cure curing chamber and sent back to the dentist for try-in and final adjustment.
The provided text describes the regulatory clearance for the Stratasys TrueDent™ device and includes a comparison to predicate and reference devices. It details non-clinical performance data but does not include information about clinical studies with human subjects, AI assistance, or expert adjudication. Therefore, many of the requested items related to clinical studies and AI are not available in the given document.
Here's the information that can be extracted or inferred from the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are primarily defined by adherence to international standards for dental materials and biocompatibility. The reported device performance indicates that the Stratasys TrueDent™ meets these requirements.
| Acceptance Criteria (Standard) | Reported Device Performance (Stratasys TrueDent™) |
|---|---|
| ISO 10477 (Flexural Strength, Sorption, Solubility) | Meets requirements; similar to predicate/reference devices |
| ISO 4049 (Flexural Strength, Flexural Modulus, Sorption, Solubility) | Meets requirements; similar to predicate/reference devices |
| ISO 20795 (Flexural Strength, Flexural Modulus, Sorption, Solubility) | Meets requirements; similar to predicate/reference devices |
| ISO 7405 (Biocompatibility Categorization) | Surface device with permanent contact; successfully evaluated |
| ISO 10993 (Biocompatibility: Cytotoxicity, Sensitization, Irritation, Systemic Toxicity, Genotoxicity) | Deemed biocompatible; meets requirements; similar to predicate/reference devices |
| Shelf Life | 12 months (validated); 24 months (on-going validation) |
| FDA's "Technical Considerations for Additive Manufactured Medical Devices" Guidance | Evaluation of relevant properties of printed resin on permitted machines; tests based on orientation during manufacturing were performed. |
2. Sample size used for the test set and the data provenance
The document does not specify the sample sizes used for the non-clinical performance and biocompatibility tests. The data provenance is "Non-clinical testing data submitted to demonstrate substantial equivalence." No country of origin for the data is specified, but the manufacturer is Stratasys Ltd. based in Israel. The tests are non-clinical (bench testing), so the terms "retrospective or prospective" do not directly apply in the same way as clinical trials.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided in a clinical context. The provided study is non-clinical (bench testing and biocompatibility assessments). The "ground truth" for these types of tests is the established scientific and regulatory standards (e.g., ISO standards, FDA guidance).
4. Adjudication method for the test set
Not applicable, as this was a non-clinical study focused on meeting specified standards. There was no mention of human-in-the-loop performance or expert adjudication of outputs.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No such study was mentioned. The device is a dental material for fabrication of appliances, not an AI-powered diagnostic or assistive tool for human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This would not be applicable in the context of this device. The device itself (a resin) is the "standalone" component being evaluated for its physical, mechanical, and biocompatibility properties. The manufacturing process involves CAD/CAM, but the focus of the performance data is on the cured material, not an algorithm's diagnostic performance.
7. The type of ground truth used
The ground truth for the non-clinical performance data (mechanical and physical properties) and biocompatibility data is defined by established international standards (ISO 10477, ISO 4049, ISO 20795 for mechanical properties; ISO 7405, ISO 10993 for biocompatibility). These standards specify the test methodologies and acceptance criteria.
8. The sample size for the training set
This information is not applicable. The device is a physical material (resin), not an AI model that requires a training set.
9. How the ground truth for the training set was established
Not applicable, as the device is not an AI model requiring a training set.
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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 FDA logo is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
July 7, 2022
Stratasys Ltd % Melissa Burbage Senior Regulatory Specialist PaxMed International, LLC 12264 El Camino Real, Suite 400 San Diego, California 92130
Re: K220771
Trade/Device Name: Stratasys TrueDent Regulation Number: 21 CFR 872.3760 Regulation Name: Denture Relining, Repairing, Or Rebasing Resin Regulatory Class: Class II Product Code: EBI, EBG, PZY, EBF Dated: April 7, 2022 Received: April 8, 2022
Dear Melissa Burbage:
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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's
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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 mediation-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 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
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Indications for Use
510(k) Number (if known) K220771
Device Name
Stratasys TrueDent™
Indications for Use (Describe)
Stratasys TrueDent™ is a light-curable resin indicated for the fabrication of dental appliances including removable full and partial dentures, denture bases, denture teeth, bridges, crowns, inlays, and veneers in dental laboratories. The material is an alternative to traditional heat-curable and auto polymerizing resins. Stratasys TrueDent™ is intended exclusively for professional dental work.
| 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) | X Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
| 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
K220771
Stratasys TrueDent™
Stratasys Ltd.
July 6, 2022
ADMINISTRATIVE INFORMATION
| Manufacturer Name | Stratasys Ltd. | ||
|---|---|---|---|
| 1 Holtzman Street St. Science Park | |||
| P.O. Box 2496 Rehovot, | |||
| 7612401, Israel | |||
| Telephone: | +972-74-745-4000 | ||
| Fax: | +972-74-745-4001 | ||
| Official Contact | Melanie Glennon, VP Quality & Regulatory Affairs | ||
| Representative/Consultant | Melissa Burbage, Senior Regulatory Specialist | ||
| Kevin 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: | mburbage@paxmed.com | ||
| kthomas@paxmed.com, flarson@paxmed.com |
DEVICE NAME AND CLASSIFICATION
| Trade/Device Name | Stratasys TrueDent™ |
|---|---|
| Common Name | Resin, Denture, Relining, Repairing, rebasing |
| Regulation Number | 21 CFR 872.3760 |
| Regulation Name | Denture Relining, Repairing, or Rebasing Resin |
| Regulatory Class | Class II |
| Product Code | EBI |
| Secondary Product Codes | EBG, PZY, EBF |
| Classification Panel | Dental |
| Reviewing Office | Office of Health Technology 1(OHT 1: Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices) |
| Reviewing Division | Division of Health Technology 1 B (Dental and ENT Devices) |
PREDICATE DEVICE INFORMATION
Primary Predicate: K210977, E-Dent 1000 (Flexcera Base & Smile), EnvisionTEC GmbH
Reference Devices: K203641, E-Denture Pro Resin, EnvisionTEC E-Denture Pro K201827, GR-17 Resin System, Pro3dure Medical GmbH
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510(k) Summary Page 2 of 7
INDICATIONS FOR USE STATEMENT
Stratasys TrueDent™ is a light-curable resin indicated for the fabrication of dental appliances including removable full and partial dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays, and veneers in dental laboratories. The material is an alternative to traditional heat-curable and auto polymerizing resins. Stratasys TrueDent™ is intended exclusively for professional dental work.
SUBJECT DEVICE DESCRIPTION
Stratasys TrueDent™ is a light-curable methacrylate-based resin, that enables fabrication of monolithic, high quality, functional, and aesthetic dental appliances, including full and partial removable dentures, denture bases, denture teeth, bridges, crowns, inlays, onlays and veneers in a CAD/CAM additive manufacturing process. This material is intended to be used by trained dental professionals for the fabrication of various dental appliances in a CAD/CAM additive manufacturing process that includes the following components: digital dental files based on a digital impression, a Stratasys Poly Jet 3D printer, and curing light equipment. It is an alternative to traditional heat cured and auto polymerization resins. The predesigned color of the dental appliance is achieved by digitally mixing colored resins. The resins are available in five (5) different base colors (clear, white, cyan, magenta, and yellow). Stratasys TrueDent can be used only with Stratasys J5 Series printers. Stratasys J5 Series printers include a 3D printing system that utilizes PolyJet technology, with drop-on-demand inkjet printing process, 3 print heads, and a UV LED (395nm) curing process. The dental appliance is then cured in the Stratasys TrueDent™ Cure curing chamber and sent back to the dentist for try-in and final adjustment.
PERFORMANCE DATA
Non-clinical testing data submitted to demonstrate substantial equivalence included: shelf life testing, biocompatibility testing, performance testing according to ISO 10477, ISO 4049, and ISO 20795, and other performance tests based on internal procedures. Biological test considerations for this categorization include cytotoxicity, sensitization, acute systemic toxicity, sub-chronic toxicity, implantation, and genotoxicity.
Testing, according to FDA's guidance Technical Considerations for Additive Manufactured Medical Devices, was performed and results were provided in the 510(k). These tests included evaluation of all relevant properties of the printed resin using the permitted machines. Further, tests based on considerations of the orientation during manufacturing were performed. Additional equipment post-510(k) clearance will be added to the labeling by means of the Quality System and within the company's validation plan.
Stratasys TrueDent has a shelf life of 12 months with on-going real-time validation testing for an ultimate shelf life of 24 months. The shelf-life testing is conducted with bench tests from ISO 20795 and other performance tests based on internal procedures.
EQUIVALENCE TO MARKETED DEVICES
Indications for Use Statements
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The subject device is indicated for fabrication of dental appliances, including removable full and partial dentures, denture bases, denture teeth and temporary bridges, in dental laboratories. The primary predicate (K210977) also has indications for individual and fixed permanent full single crowns, permanent partial crowns (also known as inlays and onlays) in anterior and posterior region, individual and fixed single veneers, artificial teeth for dental prostheses, individual and removable monolithic full and partial dentures. The slight differences in the language of the subject and primary predicate Indications for Use statements, however, do not affect the intended use. The main difference is that the subject device includes indications for bridges, which is not included in the indications of the primary predicate but is addressed by the reference device K201827. The Indications for Use for both the subject device and primary predicate include statements that the maternative to traditional lightcurable resin and is intended exclusively for professional dental work. Both the subject device and primary predicate require fabrication of these devices using a computer aided design and manufacturing (CAD/CAM) system. The subject device Indications for Use Statement does not list the process components, as it is not necessary that such components be listed in the Statement,
The indications for the reference device K203641 include fabrication of denture bases in dental laboratories for full removable dentures. This is the same indication as the subject device for full removable dentures. Slight differences in the language of the Indications for Use statements for the subject device and the reference device K203641 do not affect the intended use. Both the subject device and the reference device K203641 include statements that the maternative to traditional lightcurable and is intended exclusively for professional dental work. Both the subject device and the reference device K203641 require fabrication of these devices using a computer aided design and manufacturing (CAD/CAM) system.
The indications for the reference device K201827 include fabrication of temporary anterior dental restorations, temporary dental restorations and preformed denture teeth to be used in a denture. This is the same as the subject device for bridges and denture teeth, however, different language is used. Both the subject device and reference device K201827 include statements that the material is an alternative to traditional light-curable resin and is intended exclusively for professional dental work. Both the subject device and reference device K201827 require fabrication of these devices using a computer aided design and manufacturing (CAD/CAM) system, also known as additive manufacturing. The system component that is specified for reference device K201827 is an extra-oral curing light equipment.
Mechanical and Biological Properties
The physical, mechanical, and chemical properties of the subject device, the primary predicate device (K210977) and the two reference devices (K203641 and K201827) are very similar. They all are light-curable, methacrylate-based resins that are cured by UV light. They are all delivered in the form of a liquid intended to be used in additive manufacturing.
The subject device, the primary predicate device (K210977), and the two reference devices (K203641 and K201827) are all used in additive manufacturing processes. The type of printing process for reference device K201827 is unknown as it is not stated in the 510(k) Summary. The subject device, the primary predicate device (K210977), and reference device K203641 utilize a photopolymer resin 3D printing process that prints the material layer by layer. These are similar in that the print geometry is exposed to UV light that cures the material. The subject device is different in that it uses drop on demand (DOD) printing and the primary predicate device (K210977) and reference device K203641 use digital light processing (DLP) printing. DOD and DLP printing are similar in that they both use voxels for printing
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resolution, print using similar materials (resin), cure the resin with UV light, and print support structures that are removed after printing. The main difference is how the material is printed.
DLP uses a vat of resin and a digital light projector to build parts. The projector flashes UV light onto the layer of resin, selectively solidifying the part. This exposure cures and solidifies the pattern and joins the material to the layer below as the build platform is lowered to create the next layer. To ensure good print quality in monolithic full dentures support structures are built using the same material as the printed part and are removed during post processing. DLP uses the same material color for the entire fabrication, which requires post-processing to apply esthetic treatment (coloring).
DOD printing, as used for the subject device resin, works like an inkjet printer. The printer builds parts by jetting photopolymer droplets onto a build platform and solidifying them with UV light. The printer builds layer on top of layer. Similarly to DLP, support structures are also built to ensure good print quality. however a different material is used for the support material. which is also removed after the printing process. DOD printing allows different colors (same base resin with color agent) to be printed at the same time, which allow esthetic denture bases and teeth to be printed together, eliminating the secondary step of applying light curing color composite pastes or liquids to provide an esthetic result.
The differences in printing technology do not raise different questions of safety and effectiveness, as all manufacturing technologies produce a dental device from light-curing acrylic resins that may appropriately be characterized using standard FDA-recognized mechanical testing and biocompatibility evaluation. Performance testing and biocompatibility testing and evaluation were conducted 220771as appropriate mitigation measures for evaluation of substantial equivalence of the subject device, predicate device and reference devices, and the results demonstrate that the subject device is substantially equivalent.
For mechanical properties, the subject device as well as the primary predicate and both reference devices were tested in accordance with ISO 20795. ISO 4049, and ISO 10477. The subject device meets the requirements of these standards for flexural strength, flexural modulus, sorption, and solubility, similar to the primary predicate and both reference devices. The flexural strength meets the requirements of ISO 20795, ISO 4049, and ISO 10477, and results are similar to those of the primary predicate. The flexural modulus meets the requirements of ISO 20795 and ISO 4049, and results are similar to those of reference device K201827. The sorption and solubility meet the requirements of ISO 20795, ISO 4049. and ISO 10477, and results are similar to those of reference device K201827 (these values are not available for the primary predicate device and reference device K203641). The mechanical properties results demonstrate that the subject device is substantially equivalent to the predicate and reference devices.
Biocompatibility studies were performed on the subject device in accordance with ISO 7405 and ISO 10993. The subject device is categorized, according to ISO 7405 as a surface device with permanent contact. Biological test considerations for this categorization include cytotoxicity, sensitization, irritation, acute systemic toxicity, sub-chronic toxicity, implantation, and genotoxicity. The subject device was successfully evaluated for all such considerations using testing and scientific rationale. Based on the completed test results, the subject device is deemed biocompatible and meets the requirements of ISO 10993-1. Results of biocompatibility evaluation and testing demonstrate that the subject device is substantially equivalent to the predicate and reference devices.
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| Feature | Subject Device | Primary PredicateDevice | Reference Device | Reference Device | Conclusion |
|---|---|---|---|---|---|
| Stratasys TrueDent™Stratasys, Ltd. | E-Dent 1000EnvisionTEC GmbHK210977 | E-Denture Pro ResinEnvisionTEC GmbHK203641 | GR-17 Resin SystemPro3dure Medical GmbHK201827 | ||
| Product Code | EBI, EBG, PZY, EBF | EBF, EBI, ELM | EBI | EBG, PZY | Similar |
| Regulation | 872.3760: Resin,Denture, Relining,Repairing, Rebasing872.3770: Crown AndBridge, TemporaryResin872.3590: Denture,Plastic, Teeth872.3690: Material,Tooth Shade, Resin | 872.3690: Material,Tooth Shade, Resin872.3760: Resin,Denture, Relining,Repairing, Rebasing872.3590: Denture,Plastic, Teeth | 872.3760: Resin,Denture, Relining,Repairing, Rebasing | 872.3770: Crown andBridge, Temporary Resin872.3590: AdditivelyManufacture, Preformed,Resin Denture Teeth | Similar |
| Intended Use | Removable full andpartial dentures, denturebases, denture teeth,bridges, crowns, inlays,onlays, and veneersdental laboratories. | • Individual and fixedpermanent full singlecrowns, permanentpartial crowns in frontand posterior area,• Individual and fixedsingle veneers,• Artificial teeth fordental prostheses, whichare used for removablepermanent full dentures,• Individual andremovable monolithicfull and partial dentures | Removable full dentures | Temporary anteriordental restorations (crownand bridge) and dentureteeth. | Similar |
| Indications | Stratasys TrueDent™ isa light-curable resinindicated for thefabrication of dentalremovable full andpartial dentures, denturebases, denture teeth,bridges, crowns, inlays,onlays, and veneers indental laboratories. Thematerial is analternative to traditionalheat-curable and autopolymerizing resins.Stratasys TrueDent™ isintended exclusively forprofessional dentalwork. | E-Dent 1000 is a light-curable resin indicatedfor the fabrication of:• individual and fixedpermanent full singlecrowns, permanentpartial crowns in frontand posterior area,• individual and fixedsingle veneers,• artificial teeth fordental prostheses, whichare used for removablepermanent full dentures,• individual andremovable monolithicfull and partial denturesin dental laboratories.The material is analternative to traditionalrestorative dentalmaterial. E-Dent 1000 isintended exclusively forprofessional dentalwork. Fabrication ofdental applications withE-Dent 1000 requires acomputer aided andmanufacturing(CAD/CAM) systemthat includes thefollowing components:digital dental files basedon a digital impressionor in case of artificialteeth for dentalprostheses the digitaldental files based onmanufacturer's data, adigital light processing(DLP) printer, andcuring light equipment. | E-Denture Pro is a light-curable resin indicatedfor the fabrication ofdenture bases fabricatedin dental laboratories forfull removable dentures.The material is analternative to traditionalheat-curable and autopolymerizing resins. E-Denture Pro is intendedexclusively forprofessional dentalwork. Fabrication ofdenture bases with E-Denture Pro requires acomputer-aided andmanufacturing(CAD/CAM) systemthat includes thefollowing components:digital denture base filesbased on a digitalimpression, a digitallight processing (DLP)printer, and curing lightequipment. | The GR-17 Resin Systemis a light-curablepolymerizable resinintended to be used inconjunction with extra-oral curing lightequipment.The GR-17 temporary isindicated for thefabrication, by additivemanufacturing, oftemporary anterior dentalrestorations.The GR-17.1 temporaryis indicated for thefabrication, by additivemanufacturing, oftemporary dentalrestorations, and for thefabrication, by additivemanufacturing, ofpreformed denture teethto be used in a denture. | Similar |
| ChemicalDescription | Methacrylate-basedresin | Methacrylate-basedresin | Methacrylate-basedresin | Methacrylate-based resin | Same |
| Material Type | Light-curable Resin | Light-curable Resin | Light-curable Resin | Light-curable Resin | Same |
| Curing Method | UV Light | UV Light | UV Light | UV Light | Same |
| Product State | Liquid | Liquid | Liquid | Liquid | Same |
| ManufacturingTechnology Type | Additive | Additive | Additive | Additive | Same |
| Product Characteristics | |||||
| Standards | ISO 10477ISO 4049ISO 20795 | ISO 10477ISO 4049ISO 20795 | ISO 20795 | ISO 10477ISO 4049ISO 22112 | Similar |
| Physical andMechanicalProperties | Flexural StrengthFlexural ModulusSorptionSolubility | Flexural StrengthFlexural ModulusSorptionSolubility | Flexural StrengthFlexural ModulusSorptionSolubility | Flexural StrengthFlexural ModulusSorptionSolubility | Same |
| BiocompatibilityStandards | ISO 7405ISO 10993 | ISO 10993 | ISO 10993 | ISO 7405ISO 10993 | Similar |
| Cytotoxicity (Part 5)Sensitization (Part 10)Irritation (Part 10)Systemic Toxicity (Part11) Genotoxicity (Part3) | Cytotoxicity (Part 5)Sensitization (Part 10)Irritation (Part 10)Systemic Toxicity (Part11) | Cytotoxicity (Part 5)Sensitization (Part 10)Irritation (Part 10)Systemic Toxicity (Part11) | |||
| Workflow | |||||
| AdditiveManufacturing | Testing, according toFDA's guidanceTechnicalConsiderations forAdditive ManufacturedMedical Devices, wasperformed and resultswere provided in the510(k). These testsincluded evaluation ofall relevant properties ofthe printed resin usingthe permitted machines.Further, tests based onconsiderations of theorientation duringmanufacturing wereperformed. | Testing, according toFDA's guidanceTechnicalConsiderations forAdditive ManufacturedMedical Devices, wasperformed and resultswere provided in the510(k). These testsincluded evaluation ofall relevant properties ofthe printed resin usingthe permitted machines.Further, tests based onconsiderations of theorientation duringmanufacturing wereperformed. | Testing, according toFDA's guidanceTechnicalConsiderations forAdditive ManufacturedMedical Devices, wasperformed and resultswere provided in the510(k). These testsincluded evaluation ofall relevant properties ofthe printed resin usingthe permitted machines.Further, tests based onconsiderations of theorientation duringmanufacturing wereperformed. | Not stated in summary | Similar |
| Printer | Stratasys J5 DentaJet | EnvisionTECsPerfactory® 3D-PrinterDLP models designedand validated for usewith the E-Dent 1000light cured resin are:• EnvisionOnecDLM,with LED• Micro series, withLED• Vida Series, with LED• P4K Series, with LED• D4K Series, with LED | EnvisionTECsPerfactory® 3D-Printermodels designed andvalidated for use withthe E-Denture Pro lightcured resin are:EnvisionOne cDLM,with LEDVida Series, with LEDP4K Series, with LEDD4K Series, with LED | Not stated in summary | Similar |
| Post Cure | TrueDent™ Cure | Not listed in summary | Not listed in summary | Curing system such asNyomo, Rapidshape,Envisiontec or AsigaSystems | Similar |
| How Provided | |||||
| Sterility | Non-sterile | Non-sterile | Non-sterile | Non-sterile | Same |
| Shelf Life | 2 years (12 months attime of submission) | 2 years (4 months attime of K210977) | 3 years | 2 years | Similar |
| Color options | 5 colors | Base: 5 ShadesSmile: 5 Shades | 6 colors | 7 shades | Similar |
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CONCLUSION
The subject device, the primary predicate device, and the reference devices have the same intended use, have similar technological characteristics, made of the similar materials, and manufactured using additive manufacturing processes. The data included in this submission demonstrate substantial equivalence to the primary predicate and reference devices.
§ 872.3760 Denture relining, repairing, or rebasing resin.
(a)
Identification. A denture relining, repairing, or rebasing resin is a device composed of materials such as methylmethacrylate, intended to reline a denture surface that contacts tissue, to repair a fractured denture, or to form a new denture base. This device is not available for over-the-counter (OTC) use.(b)
Classification. Class II.