K Number
K230246
Device Name
Dentis s-Clean SQ-SL Narrow Implant System
Manufacturer
Date Cleared
2023-05-25

(115 days)

Product Code
Regulation Number
872.3630
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Dentis s-Clean SQ-SL Narrow Implant System is intended for surgical placement in the upper and lower jaw arches, to provide a root form means for single or multiple units' prosthetic attachment to restore a patient's chewing function. The Dentis s-Clean SQ-SL Narrow Implant System is limited to the replacement of maxillary lateral incisors and mandibular incisors. It is intended for delayed loading. The Dentis s-Clean SQ-SL Narrow Implant System may be used as an artificial root structure for single tooth replacement of mandibular central and lateral incisors and maxillary lateral incisors. The implants may be restored immediately 1) with a temporary prosthesis that is not in functional occlusion, 2) when splinted together as an artificial root structure for multiple tooth replacement of mandibular incisors, or 3) for denture stabilization using multiple implants in the anterior mandible and maxilla. The implants may be placed in immediate function when good primary stability has been achieved and with appropriate occlusal loading.
Device Description
The Dentis s-Clean SQ-SL Narrow Implant System is used to replace missing teeth in various situations ranging from a single tooth loss to the complete loss of incisors teeth. This system is restricted to substitute the maxillary lateral incisors and mandibular incisors. It is one and two stage endosseous screw type implant with internal connection, intended for single use. Dentis s-Clean SQ-SL Narrow Implant System is a suitable treatment option when the possibility of placing a standard implant is limited due to physical conditions, where the horizontal space is limited by adjacent teeth and roots, or in situations with a narrow alveola ridge.
More Information

No
The summary describes a dental implant system and its mechanical and biological performance, with no mention of AI or ML technology.

Yes
The device is described as an implant system intended for surgical placement to restore a patient's chewing function and act as an artificial root structure for tooth replacement, which directly addresses a health condition (missing teeth) and improves body function (chewing).

No

This device is an implantable system for replacing missing teeth, not for diagnosing medical conditions.

No

The device description clearly states it is an "endosseous screw type implant with internal connection," which is a physical hardware component. The performance studies also focus on hardware testing (fatigue, biocompatibility, sterilization, surface modification, MRI review).

Based on the provided text, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use clearly describes a surgical implant for replacing missing teeth and restoring chewing function. This is a therapeutic and structural purpose, not a diagnostic one.
  • Device Description: The description details a screw-type implant used to replace teeth, again focusing on a structural and functional role.
  • Lack of Diagnostic Elements: There is no mention of analyzing samples from the body (like blood, urine, tissue), detecting diseases, or providing information for diagnosis.
  • Performance Studies: The performance studies focus on mechanical properties (fatigue), biocompatibility, sterilization, and MRI compatibility – all relevant to a surgical implant, not an IVD.

IVD devices are used to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. This device does not fit that description.

N/A

Intended Use / Indications for Use

The Dentis s-Clean SQ-SL Narrow Implant System is intended for surgical placement in the upper and lower jaw arches, to provide a root form means for single or multiple units' prosthetic attachment to restore a patient's chewing function. The Dentis s-Clean SQ-SL Narrow Implant System is limited to the replacement of maxillary lateral incisors and mandibular incisors. It is intended for delayed loading.

Product codes

NHA

Device Description

The Dentis s-Clean SQ-SL Narrow Implant System is used to replace missing teeth in various situations ranging from a single tooth loss to the complete loss of incisors teeth. This system is restricted to substitute the maxillary lateral incisors and mandibular incisors. It is one and two stage endosseous screw type implant with internal connection, intended for single use. Dentis s-Clean SQ-SL Narrow Implant System is a suitable treatment option when the possibility of placing a standard implant is limited due to physical conditions, where the horizontal space is limited by adjacent teeth and roots, or in situations with a narrow alveola ridge.

The dimensions of abutments are as following:

No.Device NameDimension RangesAngulation
1s-Clean TiN Half Coating Angled Abutment (Narrow)Ø4.0 (D) X 10.26, 10.76, 12.26 and 12.76mm (L)15°
2s-Clean Temporary Abutment (Narrow)Ø4.0 (D) X 12.5, 13, 14.5 and 15mm (L)

Tolerance of dimension for Abutments shall be within ± 1% range.

The Abutments have below featured:

NameUsesSurfaceConnection
s-Clean TiN Half Coating Angled Abutment (Narrow)The Abutment is connected with fixture and it supports prosthesis which restores tooth function.TiN CoatingScrew Retained
s-Clean Temporary Abutment (Narrow)Arbitrarily shaped upper structure used to restore masticatory movement temporarily by using prosthesis made according to patient's conditionN/AScrew Retained

The s-Clean TiN Half Coating Angled Abutment (Narrow) and s-Clean Temporary Abutment (Narrow) intended for use with the s-Clean OneQ-SL Fixture in K161244.

The s-Clean Temporary Abutment (Narrow) is not intended to be cast at angulation or placed to provide angular correction.

Materials:

  • . s-Clean TiN Half Coating Angled Abutment (Narrow) is fabricated from Ti-6Al-4V ELI of ASTM F136
  • The s-Clean Temporary Abutment (Narrow) is fabricated from PEEK material.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Upper and lower jaw arches, maxillary lateral incisors and mandibular incisors.

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

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

Not Found

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

Not Found

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

Non-Clinical Test Data:

  • Fatigue Testing under the worst-case scenario according to ISO 14801:2016.
  • Biocompatibility testing on Abutment according to ISO 10993-1:2009 referenced in K171694.
  • End User Sterilization Validation Test Report on Abutments according to ANSI/AAMI ST79, ISO 17665-1,-2, ISO 11737-1,-2, and ISO 11138-1 referenced in K171694 and K171027.
  • Comparison of surface modification information with TiN Coating for Abutments between the subject and predicate devices (K171694), including chemical composition, SEM, EDS, adhesion and thickness.

Key results:

  • The end user sterilization test was performed for predicate device (K171694 and K171027) and leveraged for the subject device because the product category, material, manufacturing process, facility, and packaging of both products are exactly same.
  • The Biocompatibility Test was conducted on the predicate device and leveraged for the subject device because both products are manufactured with same materials and manufacturing process. It demonstrates that the subject device is biocompatible and substantial equivalence with the predicate.
  • The Fatigue Testing was performed under the worst-case scenario according to ISO 14801:2016.
  • Non-clinical worst-case MRI review was performed to evaluate the metallic Dentis SQ-SL Implant System in the MRI environment using scientific rationale and published literature, based on the entire system including all variations (all compatible implant bodies, dental abutments, and fixation screws) and material composition.
  • Rationale addressed parameters per the FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment," including magnetically induced displacement force and torque.
  • Clinical testing was not necessary to establish substantial equivalency of the device.

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

Not Found

Predicate Device(s)

K161244

Reference Device(s)

K182194, K210080, K171027, K171694

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 872.3630 Endosseous dental implant abutment.

(a)
Identification. An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.(b)
Classification. Class II (special controls). The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)

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Image /page/0/Picture/0 description: The image 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 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.

Dentis Co., Limited % April Lee Consultant Withus Group Inc 106 Superior Irvine, California 92620

Re: K230246

Trade/Device Name: Dentis s-Clean SQ-SL Narrow Implant System Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: April 28, 2023 Received: April 28, 2023

Dear April Lee:

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 (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 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.

Andrew I. Steen -S

Andrew I. Steen Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K230246

Device Name Dentis s-Clean SQ-SL Narrow Implant System

Indications for Use (Describe)

The Dentis s-Clean SQ-SL Narrow Implant System is intended for surgical placement in the upper and lower jaw arches, to provide a root form means for single or multiple units' prosthetic attachment to restore a patient's chewing function. The Dentis s-Clean SQ-SL Narrow Implant System is limited to the replacement of maxillary lateral incisors and mandibular incisors. It is intended for delayed loading.

Type of Use (Select one or both, as applicable)

☑ Prescription Use (Part 21 CER 801 Subpart D)
☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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3

510(K) Summary

Submitter

Dentis Co., Ltd. EunJin, Shin 99, Seongseoseo-ro, Dalseo-gu Daegu, 42718 Korea Email: ej0616@dentis.co.kr Tel. +82-53-589-3646 Fax. +82-53-289-7922

Device Information

  • Trade Name: Dentis s-Clean SQ-SL Narrow Implant System
  • Common Name: Dental Implant Abutment
  • Classification Name: Abutment, Implant, Dental, Endosseous ●
  • Product Code: NHA
  • . Panel: Dental
  • Regulation Number: 872.3630
  • Device Class: Class II
  • Date Prepared: 05/25/2023

Predicate Devices:

Primary Predicate

  • K161244, s-Clean OneQ-SL Narrow Implant System

Reference devices

  • K182194, UV Active Implant System manufactured by DIO Corporation
  • K210080, Dentis s-Clean s-Line Mini manufactured by Dentis Co., Ltd.
  • K171027, Dentis Dental Implant System by Dentis Co., Ltd.
  • K171694, s-Clean TiN Coating Abutments by Dentis Co., Ltd.

Indication for Use:

The Dentis s-Clean SQ-SL Narrow Implant System may be used as an artificial root structure for single tooth replacement of mandibular central and lateral incisors and maxillary lateral incisors.

The implants may be restored immediately

    1. with a temporary prosthesis that is not in functional occlusion,
    1. when splinted together as an artificial root structure for multiple tooth replacement of mandibular incisors, or
    1. for denture stabilization using multiple implants in the anterior mandible and maxilla.

The implants may be placed in immediate function when good primary stability has been achieved and with appropriate occlusal loading.

  • Official Correspondent Withus Group Inc. April Lee 106 Superior, Irvine, CA 92620 USA Email: withus6664@gmail.com Phone: 1-909-274-9971 Fax: 1-909-460-8122

4

Device Description:

The Dentis s-Clean SQ-SL Narrow Implant System is used to replace missing teeth in various situations ranging from a single tooth loss to the complete loss of incisors teeth. This system is restricted to substitute the maxillary lateral incisors and mandibular incisors. It is one and two stage endosseous screw type implant with internal connection, intended for single use. Dentis s-Clean SQ-SL Narrow Implant System is a suitable treatment option when the possibility of placing a standard implant is limited due to physical conditions, where the horizontal space is limited by adjacent teeth and roots, or in situations with a narrow alveola ridge.

The dimensions of abutments are as following:

No.Device NameDimension RangesAngulation
1s-Clean TiN Half Coating Angled
Abutment (Narrow)Ø4.0 (D) X 10.26, 10.76, 12.26 and 12.76mm (L)15°
2s-Clean Temporary Abutment
(Narrow)Ø4.0 (D) X 12.5, 13, 14.5 and 15mm (L)

Tolerance of dimension for Abutments shall be within ± 1% range.

The Abutments have below featured:

NameUsesSurfaceConnection
s-Clean TiN Half Coating
Angled Abutment (Narrow)The Abutment is connected with fixture and it
supports prosthesis which restores tooth function.TiN CoatingScrew
Retained
s-Clean Temporary Abutment
(Narrow)Arbitrarily shaped upper structure used to restore
masticatory movement temporarily by using
prosthesis made according to patient's conditionN/AScrew
Retained

The s-Clean TiN Half Coating Angled Abutment (Narrow) and s-Clean Temporary Abutment (Narrow) intended for use with the s-Clean OneQ-SL Fixture in K161244.

The s-Clean Temporary Abutment (Narrow) is not intended to be cast at angulation or placed to provide angular correction.

Materials:

  • . s-Clean TiN Half Coating Angled Abutment (Narrow) is fabricated from Ti-6Al-4V ELI of ASTM F136
  • The s-Clean Temporary Abutment (Narrow) is fabricated from PEEK material. ●

5

Summaries of Technological Characteristics & Substantial Equivalence Discussion

Subject DevicePrimary PredicateReference Predicate
K numberK230246K161244K182194
ManufacturerDentis Co., Ltd.Dentis Co., Ltd.DIO CORPORATION
Trade NameDentis s-Clean SQ-SL Narrow
Implant Systems-Clean OneQ-SL Narrow
Implant SystemUV Active Implant System
Indications for
UseThe Dentis s-Clean SQ-SL
Narrow Implant System may be
used as an artificial root structure
for
single tooth replacement of
mandibular central and lateral
incisors and maxillary lateral
incisors.
The implants may be restored
immediately
  1. with a temporary prosthesis
    that is not in functional
    occlusion,
  2. when splinted together as an
    artificial root structure for
    multiple tooth replacement of
    mandibular incisors, or
  3. for denture stabilization
    using multiple implants in the
    anterior mandible and maxilla.
    The implants may be placed in
    immediate function when good
    primary stability has been
    achieved and with appropriate
    occlusal loading. | The s-Clean OneQ-SL Narrow
    Implant System may be used as
    an artificial root structure for
    single tooth replacement of
    mandibular central and lateral
    incisors and maxillary lateral
    incisors.
    The implants may be restored
    immediately
  4. with a temporary prosthesis
    that is not in functional
    occlusion,
  5. when splinted together as an
    artificial root structure for
    multiple tooth replacement of
    mandibular incisors, or
  6. for denture stabilization
    using multiple implants in the
    anterior mandible and maxilla.
    The implants may be placed in
    immediate function when good
    primary stability has been
    achieved and with appropriate
    occlusal loading. | The UV Active Implant System is
    indicated for surgical placement
    in the upper and lower jaw arches,
    to provide a root
    form means for single or multiple
    units' prosthetic attachment to
    restore a patient's chewing
    function.
    The narrow (Ø3.0, Ø3.3) implant
    is limited to the replacement of
    maxillary lateral incisors and
    mandibular incisors. It is
    intended for delayed loading.
    The Regular (Ø3.8 ~ Ø5.5)
    implants can be placed with a
    conventional two stage surgical
    process with an option for
    transmucosal healing or they can
    be placed in a single stage
    surgical process for immediate
    loading when good primary
    stability is achieved with
    appropriate occlusal loading.
    The Wide (Ø6.0 ~ Ø6.4) implants
    can be placed with a conventional
    two stage surgical process with an
    option for
    transmucosal healing and are
    indicated for the molar region
    with delayed loading. |
    | Design | Image: Two implants | - | Image: Two implants |
    | Diameter | Ø4.0 | - | Ø4.0, 4.5 and 5.5 |
    | Gingival
    Height | 1.8 and 3.8mm | - | 1.5, 2.0, 3.0, 4.0 and 5.0 mm |
    | Angled | 15° | - | 15° and 25° |
    | Coating | TiN Coating | - | TiN Coating |
    | Material | Ti-6Al-4V ELI | - | Ti-6Al-4V ELI |
    | Sterilization | End User Sterilization | End User Sterilization | End User Sterilization |
    | Comparison | The subject device and reference predicate, K182194 have same intended use, material, coating
    and sterilization method. The differences between the two devices are dimensions and
    indications. The dimensions of the subject device are in range of the predicate device and the
    indications for use of the subject device is exactly same as the primary predicate, K161244;
    therefore, the subject device is substantial equivalent. | | |

s-Clean TiN Half Coating Angled Abutment (Narrow)

6

s-Clean Temporary Abutment (Narrow)

Subject DevicePrimary PredicateReference Device
K numberK230246K161244K210080
ManufacturerDentis Co., LtdDentis Co., LtdDentis Co., Ltd
Trade NameDentis s-Clean SQ-SL Narrow
Implant Systems-Clean OneQ-SL Narrow
Implant SystemDentis s-Clean s-Line
Mini
Indications for
UseThe Dentis s-Clean SQ-SL Narrow
Implant System may be used as an
artificial root structure for
single tooth replacement of mandibular
central and lateral incisors and
maxillary lateral incisors.
The implants may be restored
immediately
  1. with a temporary prosthesis that is
    not in functional occlusion,
  2. when splinted together as an
    artificial root structure for multiple
    tooth replacement of mandibular
    incisors, or
  3. for denture stabilization using
    multiple implants in the anterior
    mandible and maxilla.
    The implants may be placed in
    immediate function when good primary
    stability has been achieved and with
    appropriate occlusal loading. | The s-Clean OneQ-SL Narrow
    Implant System may be used as an
    artificial root structure for
    single tooth replacement of
    mandibular central and lateral incisors
    and maxillary lateral incisors.
    The implants may be restored
    immediately
  4. with a temporary prosthesis that is
    not in functional occlusion,
  5. when splinted together as an
    artificial root structure for multiple
    tooth replacement of mandibular
    incisors, or
  6. for denture stabilization using
    multiple implants in the anterior
    mandible and maxilla.
    The implants may be placed in
    immediate function when good
    primary stability has been achieved
    and with appropriate occlusal loading. | Dentis s-Clean s-Line Mini
    is indicated for use in
    partially or fully
    edentulous mandibles and
    maxillae, in support of
    single or multiple unit
    restorations including;
    cemented retained, screw
    retained, or overdenture
    restorations, and terminal
    or intermediate abutment
    support for fixed
    bridgework. This system is
    dedicated for one and two
    stage surgical
    procedures. This system is
    intended for delayed
    loading. |
    | Design | Image: Subject Device Design | Image: Primary Predicate Design | Image: Reference Device Design |
    | Diameter | $Ø4.0$ | - | $Ø4.0$ , 4.5 and 5.5 |
    | Length | 12.5, 13, 14.5 and 15 mm | - | 13.45, 13.7, 15.45 and
    15.7mm |
    | Coating | Non | - | Non |
    | Material | PEEK | - | PEEK |
    | Sterilization | End User Sterilization | - | End User Sterilization |
    | Comparison | The subject device and reference device, K210080 have the same material and applications and
    similar dimensions. The differences between two devices are lengths and indications for use. The
    length difference is not important factor for performance because this device is used temporarily and
    the indications for use of the subject device is exactly same as the primary predicate, K161244;
    therefore, the subject device is substantial equivalent. | | |

7

Non-Clinical Test Data

Below tests were performed on subject device:

  • Fatigue Testing under the worst-case scenario according to ISO 14801:2016 ●
    Below tests were performed for predicate devices and leveraged for the subject device:

  • Biocompatibility testing on Abutment according to ISO 10993-1:2009 referenced in K171694

  • . End User Sterilization Validation Test Report on Abutments according to ANSI/AAMI ST79, ISO 17665-1,-2, ISO 11737-1,-2, and ISO 11138-1 referenced in K171694 and K171027

The surface modification information with TiN Coating for Abutments was provided. To compare surface modification between the subject and predicate devices, K171694 and , chemical composition, SEM, EDS, adhesion and thickness were provided, and it demonstrate the substantial equivalence.

The end user sterilization test was performed for predicate device. K171694 and K171027 and leveraged for the subject device because the product category, material, manufacturing process, facility, and packaging of both products are exactly same.

The Biocompatibility Test was conducted on the predicate device and leveraged for the subject device because both products are manufactured with same materials and manufacturing process. It demonstrates that the subject device is biocompatible and substantial equivalence with the predicate.

The Fatigue Testing was performed under the worst-case scenario according to ISO 14801:2016.

MR Environment Condition

Non-clinical worst-case MRI review was performed to evaluate the metallic Dentis SQ-SL Implant System in the MRI environment using scientific rationale and published literature (e.g., Woods, Terry O., Jana G. Delfino, and Sunder Rajan. "Assessment of Magnetically Induced Displacement Force and Torque on Metal Alloys Used in Medical Devices." Journal of Testing and Evaluation 49.2 (2019): 783-795). based on the entire system including all variations (all compatible implant bodies, dental abutments, and fixation screws) and material composition.

Rationale addressed parameters per the FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment," including magnetically induced displacement force and torque.

Clinical testing was not necessary to establish substantial equivalency of the device.

Conclusion

Dentis s-Clean SQ-SL Narrow Implant System constitutes a substantially equivalent medical device, meeting all the declared requirements of its intended use. This system has the same intended use and fundamental scientific technology as its predicate devices. Therefore, Dentis s-Clean SO-SL Narrow Implant System and its predicates are substantially equivalent.