K Number
K231672
Device Name
S1
Manufacturer
Date Cleared
2023-10-13

(127 days)

Product Code
Regulation Number
872.3930
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
S1 is intended for the following uses: · Augmentation or reconstructive treatment of the alveolar ridge; - · Filling of infrabony periodontal defects - · Filling of defects after root resection, apicocectomy, and cystectomy - · Filling of extraction sockets to enhance preservation of the alveolar ridge - · Elevation of the maxillary sinus floor · Filling of periodontal defects in conjuncts intended for Guided Tissue Regeneration (GTR) and Guided Bone Regeneration (GBR); and · Filling of peri-implant defects in conjunction with products intended for Guided Bone Regeneration (GBR).
Device Description
S1 is intended for filling and augmentation of bony voids and gaps in maxillofacial surgery, implantology, and periodontology according to the intended use of the product. S1 is serving as a matrix consisting of interconnected macro- and micropores. The material is porous and has inner surface area. S1 is a mixture of Hydroxyapatite (HAp) and hydroxypropyl methylcellulose (HPMC). Hydroxyapatite (HAp) is made from bovine cancellous bone and is mineralized hydroxyapatite. The bone particle size is 0.2 ~ 1.0mm for the powder type and 1.0 ~ 2.0 mm for the chip type. S1 is packaged in vials and it is supplied sterile by gamma irradiation and is for single use only.
More Information

No
The device description and performance studies focus on the material properties and biological performance of a bone graft substitute, with no mention of AI/ML or related concepts like image processing, training/test sets, or algorithmic analysis.

Yes
The device is described as augmenting and treating alveolar ridges, filling bone defects, and preserving the alveolar ridge, which are all therapeutic interventions for the human body.

No

The device description clearly states its purpose is for "filling and augmentation of bony voids and gaps" and "augmentative or reconstructive treatment," which are therapeutic and reconstructive functions, not diagnostic ones.

No

The device description clearly states that S1 is a physical material (mixture of Hydroxyapatite and hydroxypropyl methylcellulose) intended for filling and augmentation of bony voids and gaps. It is packaged in vials and supplied sterile. This is a physical medical device, not software.

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

Here's why:

  • Intended Use: The intended uses listed are all related to surgical procedures for bone augmentation and filling defects in the oral and maxillofacial region. These are therapeutic and reconstructive applications performed directly on the patient's body.
  • Device Description: The device is a material intended to be implanted or placed within the body to serve as a matrix for bone regeneration.
  • Lack of Diagnostic Function: There is no mention of the device being used to examine specimens derived from the human body (like blood, urine, tissue samples, etc.) to provide information for diagnosis, monitoring, or compatibility testing.

IVDs are devices used outside the body to examine samples and provide diagnostic information. This device is used inside the body for therapeutic purposes.

N/A

Intended Use / Indications for Use

S1 is intended for the following uses:
· Augmentation or reconstructive treatment of the alveolar ridge;

  • · Filling of infrabony periodontal defects
  • · Filling of defects after root resection, apicocectomy, and cystectomy
  • · Filling of extraction sockets to enhance preservation of the alveolar ridge
  • · Elevation of the maxillary sinus floor
    · Filling of periodontal defects in conjuncts intended for Guided Tissue Regeneration (GTR) and Guided Bone Regeneration (GBR); and
    · Filling of peri-implant defects in conjunction with products intended for Guided Bone Regeneration (GBR).

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

NPM

Device Description

S1 is intended for filling and augmentation of bony voids and gaps in maxillofacial surgery, implantology, and periodontology according to the intended use of the product.
S1 is serving as a matrix consisting of interconnected macro- and micropores. The material is porous and has inner surface area.
S1 is a mixture of Hydroxyapatite (HAp) and hydroxypropyl methylcellulose (HPMC). Hydroxyapatite (HAp) is made from bovine cancellous bone and is mineralized hydroxyapatite.
The bone particle size is 0.2 ~ 1.0mm for the powder type and 1.0 ~ 2.0 mm for the chip type. S1 is packaged in vials and it is supplied sterile by gamma irradiation and is for single use only.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Oral, periodontal

Indicated Patient Age Range

Adults ( => 22 years old )

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 testing data: The subject device was evaluated its substantial equivalence through physical tests according to ISO 13779-3:2018. Tests included Crystallinity Ratio, Ca/P ratio, Hydroxyapatite(HAp) Contents, and Heavy metals presence.
Sterilization Validation Test according to ISO 11137-1:2006, ISO 11137-2:2013, ISO 11137-3:2017.
Packaging and shelf-life testing according to ASTM F1980-16, ASTM F1980, ASTM F88-15, ASTM F1140, ASTM F2096, ASTM D4169-22, ISO 11607-1:2019, ISO 11607-2:2019, ASTM F1929-15, ISO 13779-3:2018, ISO 11737-2:2019.
Biocompatibility testing according to ISO 10993-1:2018, ISO 10993-3:2014. ISO 10993-4:2017, ISO 10993-5:2009, ISO 10993-6:2016, ISO 10993-10:2010 and ISO 10993-11:2017, ISO 10993-12:2012, ISO 10993-23:2021, USP (151).
Medical devices utilizing animal tissues and their derivatives according to ISO 22442-1:2020, ISO 22442-2:2020.
Virus Inactivation Testing according to ISO 22442-3:2007. Test results confirmed product safety. The product is sterilized to achieve a sterility assurance level SAL 1 X10-6.

Animal Test: The performance of the beagle mandibular defect model was compared to the performance of the predicate device, Bio-Oss®. Radiographic, Micro CT, Histology and Histomorphometry analyses were conducted following implantation at 4, 8, and 12 weeks for the subject device, predicate device and negative control. The results demonstrated substantially equivalent performances under intended uses. The majority of the device will be resorbed by 24 months or more, similar to the predicate device Bio-Oss®.

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.

K122894

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.

K060732

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

§ 872.3930 Bone grafting material.

(a)
Identification. Bone grafting material is a material such as hydroxyapatite, tricalcium phosphate, polylactic and polyglycolic acids, or collagen, that is intended to fill, augment, or reconstruct periodontal or bony defects of the oral and maxillofacial region.(b)
Classification. (1) Class II (special controls) for bone grafting materials that do not contain a drug that is a therapeutic biologic. The special control is FDA's “Class II Special Controls Guidance Document: Dental Bone Grafting Material Devices.” (See § 872.1(e) for the availability of this guidance document.)(2) Class III (premarket approval) for bone grafting materials that contain a drug that is a therapeutic biologic. Bone grafting materials that contain a drug that is a therapeutic biologic, such as biological response modifiers, require premarket approval.
(c)
Date premarket approval application (PMA) or notice of product development protocol (PDP) is required. Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.

0

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October 13, 2023

MedPark Co., Ltd. Woojong Kim Official Correspondent Busan Venture Tower 606-ho, 22, Mora-ro Sasang-gu, Busan KOREA, SOUTH

Re: K231672

Trade/Device Name: S1 Regulation Number: 21 CFR 872.3930 Regulation Name: Bone Grafting Material Regulatory Class: Class II Product Code: NPM Dated: July 04, 2023 Received: July 17, 2023

Dear Woojong Kim:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device"

1

(https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.

Sherrill Lathrop Blitzer

for Andrew Steen Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices

2

Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

3

Indications for Use

510(k) Number (if known) K231672

Device Name

ਟ I

Indications for Use (Describe)

S1 is intended for the following uses:

· Augmentation or reconstructive treatment of the alveolar ridge;

  • · Filling of infrabony periodontal defects
  • · Filling of defects after root resection, apicocectomy, and cystectomy
  • · Filling of extraction sockets to enhance preservation of the alveolar ridge
  • · Elevation of the maxillary sinus floor

· Filling of periodontal defects in conjuncts intended for Guided Tissue Regeneration (GTR) and Guided Bone Regeneration (GBR); and

· Filling of peri-implant defects in conjunction with products intended for Guided Bone Regeneration (GBR).

Type of Use (Select one or both, as applicable)
Research involving NIH-funded Stem Cells Grantee-owned or held Stem Cells for future use

Prescription Use (Part 21 CFR 801 Subpart D)

| | Over-The-Counter Use (21 CFR 801 Subpart C)

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Your Reliable Partner | 510(k) Submission Files | Revision No.
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| | | Revision Date
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K231672

Submitter

MedPark Co., Ltd. Woojong Kim 24, Nakdong-daero 1570 beon-gil, Buk-gu, Busan Republic of Korea Email: qm@medpark.net Phone: +82-51-301-8777 Fax: +82-50-5877-7778

Official Correspondent

MedPark Co., Ltd. Woojong Kim Busan Venture tower 606-ho, 22, Mora-ro, Sasang-gu, Busan, Republic of Korea Email: qm@medpark.net Phone: +82-51-301-8777 Fax: +82-50-5877-7778

Device Information

  • Trade Name: S1
  • Common Name: Bone Grafting Material
  • Classification Name: Bone Grafting Material, Animal Source
  • Device Panel: Dental
  • Regulation Number: 21 CFR 872.3930
  • Product Code: NPM
  • Device Class: Class II
  • Date Prepared: O October/13/2023

Primary Predicate

The subject device is substantially equivalent to the following predicate device

  • · K122894, Geistlich Bio-Oss® manufactured by Geistlich Pharma AG

Reference Device

  • K060732, MBCP Gel™ manufactured by BIOMATLANTE

Indication for Use

S1 is intended for the following uses:

  • Augmentation or reconstructive treatment of the alveolar ridge

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  • . Filling of infrabony periodontal defects
  • Filling of defects after root resection, apicocectomy, and cystectomy
  • Filling of extraction sockets to enhance preservation of the alveolar ridge ●
  • Elevation of the maxillary sinus floor
  • · Filling of periodontal defects in conjunction with products intended for Guided Tissue Regeneration (GTR) and Guided Bone Regeneration (GBR)
  • Filling of peri-implant defects in conjunction with products intended for Guided Bone Regeneration (GBR)

Device Description

S1 is intended for filling and augmentation of bony voids and gaps in maxillofacial surgery, implantology, and periodontology according to the intended use of the product.

S1 is serving as a matrix consisting of interconnected macro- and micropores. The material is porous and has inner surface area.

S1 is a mixture of Hydroxyapatite (HAp) and hydroxypropyl methylcellulose (HPMC). Hydroxyapatite (HAp) is made from bovine cancellous bone and is mineralized hydroxyapatite.

The bone particle size is 0.2 ~ 1.0mm for the powder type and 1.0 ~ 2.0 mm for the chip type. S1 is packaged in vials and it is supplied sterile by gamma irradiation and is for single use only.

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Summary of Technological Characteristics

Descriptive InformationSubject DevicePrimary PredicateReference PredicateRemark
K numberUnknownK122894K060732
ManufacturerMedPark Co., Ltd.Geistlich Pharma AgBIOMATLANTE
Model (Device name)
/ Type (Product name)S1Bio-Oss®MBCP Gel™
Product CodeNPMNPMLYCSame
Regulation number21CFR872.393021CFR872.393021CFR872.3930Same
Intended UseIntended for filling of bone
defects and bone augmentationIntended for filling of bone
defects and bone augmentationIntended for use as bone
grafting material to fill,
augment or reconstruct osseous
bone defects in particular in
periodontal oral/maxillofacial
applications.Same
Target PopulationAdults ( => 22 years old )AdultsAdultsSame
Anatomical siteOral, periodontalOral, periodontalOral, periodontalSame
Device
DesignSource
BoneBovine bone
  • Cancellous | Bovine bone
  • Cancellous | Biphasic Calcium Phosphate
    (60% Hydroxyapatite and 40%
    beta-Tricalcium Phosphate) | Similar |
    | | Particle size
    range | 0.2 - 1.0 mm
    1.0 - 2.0 mm | 0.25 - 1.0 mm
    1.0 - 2.0 mm | 0.5 - 1.0 mm | Similar |
    | | Form | Granules | Granules | Granules (Putty type) | Same |
    | | Reusable | Single Use only | Single Use only | Single Use only | Same |
    | | Sterilization | Gamma Irradiation | Gamma Irradiation | Not identified | Same |
    | Composition
    of Materials | Chemical
    composition | Hydroxyapatite with excipient
    vehicle of pharmaceutical grade
    quality (hydroxypropyl-
    methylcellulose) | Hydroxyapatite | Biphasic Calcium Phosphate
    with excipient vehicle of
    pharmaceutical grade quality
    (hydroxypropyl-
    methylcellulose) | Different
    (Biocompatibility,
    animal
    performance, and
    bench testing was
    performed to |

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| | | | | | demonstrate
substantial
equivalence.) |
|------------------------|-----------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------|
| Physical
Properties | Phase
purity | Ca5(PO4)3(OH) (≥95%) | Ca5(PO4)3(OH) (≥95%) | Not identified | Same |
| Shelf-life | | 2 years | 3 years | Not identified | The Validation of
Gamma
Sterilization
(Report No.
210107-E-2) |
| Performance | | Bone formation | Bone formation | Bone formation | Same |
| Biocompatibility | | Yes | Yes | Yes | Same |
| Indication for use | | S1 is intended for the following
uses:
• Augmentation or
reconstructive treatment of the
alveolar ridge;
• Filling of infrabony
periodontal defects;
• Filling of defects after root
resection, apicoectomy, and
cystectomy;
• Filling of extraction sockets
to enhance preservation of the
alveolar ridge;
• Elevation of the maxillary
sinus floor;
• Filling of periodontal
defects in conjunction with
products intended for Guided
Tissue Regeneration (GTR) and
Guided Bone Regeneration
(GBR); and
• Filling of peri-implant | Bio-OSS® is intended for the
following uses:
• Augmentation or
reconstructive treatment of the
alveolar ridge;
• Filling of infrabony
periodontal defects;
• Filling of defects after root
resection, apicoectomy, and
cystectomy;
• Filling of extraction sockets
to enhance preservation of the
alveolar ridge;
• Elevation of the maxillary
sinus floor;
• Filling of periodontal
defects in conjunction with
products intended for Guided
Tissue Regeneration (GTR) and
Guided Bone Regeneration
(GBR); and
• Filling of peri-implant | MBCP Gel™ is intended for
use as a bone grafting material
to fill, augment or reconstruct
osseous bone defects in
aprticular in periodontal or
oral/maxillofacial application.
Theses defects may be
surgically created osseous
defects or osseous defects
created from traumatic injury to
the bone.
MBCP Gel™ can generally be
used for bone filling in closed
cavities.
MBCP Gel™ can be used with
autogenous bone grafting
materials.
Typical uses include but are not
limited to:
• Periodontal/Infrabony defects
• Ridge augmentation | Same |

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| defects in conjunction with
products intended for Guided
Bone Regeneration (GBR). | defects in conjunction with
products intended for Guided
Bone Regeneration (GBR). | • Extractions sites (implant
preparation/placement)
• Sinus lifts
• Cystic cavities |

--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

Similarity and Equivalence Discussion

Device characteristics with the Primary predicate device, suceal shape, sizes, structure, findamental technologies and applied production method are equivalent.

  • The new device has the same intended use (as discussed above).
  • . The main material of both the primary predicate device and S1 is the Hydroxyapatite (HAp).
  • Through the Biocompatibility Test and Animal Performance Test, it was verformance of S1 are equivalent . to the Primary Predicate device.

Difference Discussion

The difference compared to the primary predicate device(Bio-Oss® K122894) is that S1 is provided as a mixture of Hydroxyapatite (HAp) and hydroxypropyl methylcellulose (HPMC).

The hydroxypropyl methylcellulose (HPMC) used as an additive is pharmaceutical grade, and was also used in Reference Predicate Device.

Through the Biocompatibility Test and Animal Test, it was verformance of S1 were equivalent to that of the Primary Predicate device.

Non-clinical testing data

  • The subject device was evaluated its substantial equvalence through physical tests according to ISO 13779-3:2018 as the below table.

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Test ItemMethods/StandardsCriteriaResult
Crystallinity RatioISO 13779-3The crystallinity ratio
should be more than 95%.100 %
Ca/P ratioISO 13779-3Ratio of calcium (Ca) and
phosphate (P) must be
$1.66\pm0.1$ .1.66
Hydroxyapatite(HAp)
ContentsISO 13779-3The content of
Hydroxyapatite(HAp)
should be more than 97
wt%.100 wt%
Heavy metalsASTM F1581-08,
ISO 13779-3As $\leq$ 3 mg/kg
Pb $\leq$ 30 mg/kg
Hg $\leq$ 5 mg/kg
Cd $\leq$ 5 mg/kg
(The total contents of
heavy metal shall be less
than 50 mg/kg.)As: Not Detected
Pb: 0.8 mg/kg
Hg: 0.012 mg/kg
Cd: Not Detected
  • Sterilization Validation Test according to ISO 11137-1:2006 , ISO 11137-2:2013, ISO ● 11137-3:2017
  • Packaging and shelf-life testing according to ASTM F1980-16, ASTM F1980, ASTM F88-15, ASTM F1140, ASTM F2096, ASTM D4169-22, ISO 11607-1:2019, ISO 11607-2:2019, ASTM F1929-15, ISO 13779-3:2018, ISO 11737-2:2019
  • Biocompatibility testing according to ISO 10993-1:2018, ISO 10993-3:2014. ISO 10993-4:2017, ISO 10993-5:2009, ISO 10993-6:2016, ISO 10993-10:2010 and ISO 10993-11:2017, ISO 10993-12:2012, ISO 10993-23:2021, USP (151)
  • Medical devices utilizing animal tissues and their derivatives according to ISO 22442-1:2020, ISO 22442-2:2020
  • Virus Inactivation Testing according to ISO 22442-3:2007

S1 was the subject of the full range of biocompatibility test recommended in the FDA's "Class II Special Controls Guidance Documents: Dental Bone Grafting Devices" and in accordance with ISO 10993-1. Test results confirmed product safety. In addition, virus inactivation study was conducted. Further, the product is sterilized to achieve a sterility assurance level SAL 1 X10-6.

The results of these studies confirm the substantial equivalence of S1 to its predicate devices.

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Animal Test

The performance of the beagle mandibular defect model was compared to the performance of the predicate device, Bio-Oss®. Radiographic, Micro CT, Histology and Histomorphometry analyses were conducted following implantation at 4, 8, and 12 weeks for the subject device, predicate device and negative control.

The predicate device Bio-Oss® and the subject device S1 were compared in the preclinical study, and the results demonstrated substantially equivalent performances under intended uses.

Eventually, the majority of the device will be resorbed by 24 months or more, and was found to be similar to the predicate device Bio-Oss®.

Conclusion

S1 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. The conclusions drawn from the nonclinical tests demonstrate that the device is substantially equivalent to its predicate devices.