(268 days)
Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories. This device includes a dental chair and is intended for use in the dental clinic environment and is designed for use by trained dental professionals, dentists and/or dental assistants.
The Luvis Chair (LC700C) includes a chair used by dentists to provide seating for patients during dental procedures. It is designed to position the patient during treatment. The chair consists of a seat, backrest, and armrests that can be adjusted to accommodate the patient's position. Additionally, it may feature a headrest to offer additional support. Dental unit chairs come equipped with various tools and attachments, including dental lights, suction devices, and air- water syringes. The chair's controls are usually located within reach of the dentist, allowing for quick adjustments during the procedure. The Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories.
This document is a 510(k) Premarket Notification for a dental chair (Luvis Chair LC700C). However, it does not contain acceptance criteria or a study proving the device meets acceptance criteria in the manner requested.
Instead, it asserts substantial equivalence to a predicate device based on similar intended use, principles of operation, and technological characteristics. It lists various standards the device complies with for safety, performance, and biocompatibility.
Therefore, I cannot populate the table and answer the questions as requested because the specific information about acceptance criteria and detailed study results (like sample sizes, ground truth establishment, expert qualifications, adjudication methods, or MRMC studies) are not present in this 510(k) summary.
The document indicates that "the conducted tests, as well as all verification and validation activities, demonstrate that the design specifications and technological characteristics of the Luvis Chair (LC700C) meet applicable requirements and standards." It also states, "The subject device had been subjected to the applicable safety and performance testing before release to ensure the device meets all its specifications." However, it does not provide the specific acceptance criteria (e.g., "device must perform with X% accuracy for Y function") or the detailed results of these tests for comparison or to be presented in a table format.
Summary of what is present:
- Device Name: Luvis Chair (LC700C)
- Intended Use: To supply power to and serve as a base for dental devices and accessories. It includes a dental chair for use in a dental clinic environment by trained dental professionals.
- Predicate Device: Osstem Implant Co., Ltd. K3 (K183347)
- Reference Device: MeqaGen Implant Co., Ltd. N2 (K211556)
- Testing Conducted (Non-Clinical Test Summary):
- Thermal, electrical, mechanical safety & Electromagnetic Compatibility (compliance with ANSI AAMI ES60601-1, IEC 60601-1-2, IEC 80601-2-60)
- Software Validations (basic documentation level, moderate level of concern, designed and developed according to a software development process, verified, and validated)
- Biocompatibility (in vitro cytotoxicity test, oral mucosa irritation test, skin sensitization test; in accordance with ISO 10993-1 and ISO 7405)
- Performance Test (in accordance with IEC 80601-2-60, ISO 7494-1, ISO 7494-2)
- Cleaning and Sterilization Validation (in accordance with FDA guidance for reprocessing, ISO 17665-1, ISO TS 17665-2, ISO 16954, ISO 19458)
- Conclusion: The device meets applicable requirements and standards, and the differences from predicate devices do not raise new questions of safety and effectiveness.
Missing Information (and why it's missing from this document):
The request for a detailed table of acceptance criteria vs. reported performance, sample sizes for test/training sets, data provenance, number and qualifications of experts, adjudication methods, MRMC studies, standalone performance, and ground truth types are typical for AI/ML-enabled devices or those requiring specific performance metrics (e.g., diagnostic accuracy). This document is for a dental chair, which is a Class I medical device. For such devices, "acceptance criteria" are usually defined by compliance with recognized electrical safety, mechanical safety, biocompatibility, and performance standards (like the ISO and IEC standards listed). The "study" proving it meets these is often a series of engineering tests and validations against those standards, rather than clinical trials or AI performance evaluations with detailed ground truth analysis as would be done for a diagnostic or image analysis device.
Therefore, the requested information (points 1-9) in the format of specific performance metrics is not applicable or not provided in this regulatory submission for a dental chair.
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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 blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
September 6, 2024
DENTIS CO., LTD. Kaon Kim Junior Manager 99, Seongseoseo-Ro, Dalseo-Gu Daegu. 42718 SOUTH KOREA
Re: K233921
Trade/Device Name: Luvis Chair (LC700C) Regulation Number: 21 CFR 872.6250 Regulation Name: Dental Chair and Accessories Regulatory Class: Class I, reserved Product Code: KLC, EIA Dated: August 12, 2024 Received: August 12, 2024
Dear Kaon 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.
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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" (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 QS 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.
All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.
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-regulatory
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assistance/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, MChE, RAC, CQIA 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
Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.
Submission Number (if known)
Device Name
Luvis Chair (LC700C)
Indications for Use (Describe)
Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories. This Device includes a dental chair and is intended for use in the dental clinic environment and is designed for use by trained dental professionals, dentists and/or dental assistants.
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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Image /page/4/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved graphic. The graphic is a stylized representation of a dental tool or a tooth.
510(k) Summary - K233921
[As required by 21 CFR 807.92]
1. Date Prepared [21 CFR 807.92(a)(1)]
September 5th, 2024.
2. Submitter's Information [21 CFR 807.92(a)(1)]
- Name of Applicant: DENTIS CO., LTD. 99, Seongseoseo-Ro, Dalseo-Gu, Daegu, - Address: 42718, Korea, South - Name of Manufacturer: DENTIS MEDICAL DIVISION - Address: 6, Yuram-ro, Dong-gu, Daegu, 41065, Korea, South - Contact Person: Kaon Kim / Junior Manager - Telephone No.: +82-53-583-2804 - Fax No.: +82-53-583-2806 - Email Address: kaonkim@dentis.co.kr - Registration No.: 3010373494
3. Trade Name, Regulation Name, Classification [21 CFR 807.92(a)(2)]
| Device Name | Luvis Chair (LC700C) |
|---|---|
| Regulation Number | 21 CFR 872.6640 |
| Common/Usual Name | Dental Unit Chair |
| Regulatory Class | Class I |
| Product Code | EIA |
| Classification Name | unit, operative dental |
| Panel | Dental |
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Image /page/5/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, abstract symbol that resembles a flame or a stylized letter 'O'. The overall design is simple and clean, suggesting a professional or corporate identity.
4. Identification of Predicate Device(s) [21 CFR 807.92(a)(3)]
The identified predicate and reference devices within this submission are shown as follow;
Predicate device
- 510(k) Number: K183347
- Applicant: Osstem Implant Co., Ltd.
- Device Name: K3
- Regulation Number: 21 CFR 872.6640
- Regulation Name: Dental Operative Unit and Accessories
- Regulatory Class: Class I
- Product Code: EIA
- Classification Name: unit, operative dental
Reference device
- K211556 - 510(k) Number: - Applicant: MeqaGen Implant Co., Ltd. - Device Name: N2 - Regulation Number: 21 CFR 872.6640 - Regulation Name: Dental Operative Unit and Accessories - Requlatory Class: Class I - Product Code: EIA
- Classification Name: unit, operative dental
The Luvis Chair (LC700C) is substantially equivalent to the predicate devices with respect to intended use, principles of operation, and technological characteristics. The subject device has the same Indications for Use and similar technological characterizes as compared to the predicate and reference devices. Therefore, the Luvis Chair (LC700C) is considered substantially equivalent to the predicate and reference devices.
5. Description of the Device [21 CFR 807.92(a)(4)]
The Luvis Chair (LC700C) includes a chair used by dentists to provide seating for patients during dental procedures. It is designed to position the patient during treatment. The chair consists of a seat, backrest, and armrests that can be adjusted to accommodate the patient's position. Additionally, it may feature a headrest to offer additional support.
Dental unit chairs come equipped with various tools and attachments, including dental lights, suction devices, and air- water syringes. The chair's controls are usually located within reach of the dentist, allowing for quick adjustments during the procedure. The Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories.
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Image /page/6/Picture/0 description: The image contains the logo for DENTIS. The logo consists of an orange swirl shape on the left, followed by the word "DENTIS" in black, bold, sans-serif font. The swirl is a stylized representation of a tooth or dental element.
[Note] The handpieces and scalers are not included within the scope of this submission. Furthermore, HVE and Saliva Ejector Tips are not included within the scope of the submission.
1) The Luvis Chair (LC700C) is classified as shown below:
LC700C consists of the following:
| ModelNumber | Chair Part | Unit Part | Dr. Table | AssistTable | FootController | Note |
|---|---|---|---|---|---|---|
| LC700C | • | •Dental Light:C700 | •MountType | • | • |
- Description of main components and specifications
The components of the Luvis Chair (LC700C) consist of following items:
| ModelNumber | Parts | Description | Note |
|---|---|---|---|
| LC700C | Chair Part | Chair Part | |
| Unit Part | Dental Light | C700 | |
| Instrument 1 | 3-Way Syringe | ||
| Dr. Table | Instrument 2,3(Air High) | 1. Air High Handpiece (Notincluded in the submission) | |
| Instrument 4(Air Low / Elec.Low) | 1. Air Low Handpiece (Notincluded in the submission)2. Elec. Low Handpiece (Notincluded in the submission) | ||
| Instrument 5(Scaler) | 1. Scaler (Not included in thesubmission) | ||
| Assist Table | Instrument 1 | Dry Air Syringe | |
| Instrument 2 | 3-Way Syringe | ||
| Instrument 3 | HVE | ||
| Instrument 4 | Saliva Ejector | ||
| FootController | Foot Controller |
6. Indications for Use [21 CFR 807.92(a)(5)]
Luvis Chair is intended to supply power to and serve as a base for dental devices and accessories. This device includes a dental chair and is intended for use in the dental clinic environment and is designed for use by trained dental professionals, dentists and/or dental assistants.
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Image /page/7/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved shape that resembles a flame or a stylized letter 'D'. The logo appears to be for a dental-related company or product, given the association with teeth.
7. Comparison of Technological Characteristics with the Predicate Device
Summary of technological characteristics of the device compared to the predicate device. [21 CFR 807.92(a)(6)]
| Applicant | DENTIS CO., LTD. | Osstem Implant Co., Ltd. | MegaGen Implant Co.,Ltd. | SE Note |
|---|---|---|---|---|
| Device Name | Luvis Chair (LC700C) | K3 | N2 | - |
| Subject Device | Predicate Device | Reference Device | - | |
| 510(k)Number | K233921 | K183347 | K211556 | - |
| Common/Usual Name | Dental Unit Chair | Unit, Operative Dental | Unit, Operative Dental | - |
| RegulationNumber | 21 CFR 872.6640 | 21 CFR 872.6640 | 21 CFR 872.6640 | - |
| Product Code | EIA | EIA | EIA | - |
| Class | Class I | Class I | Class I | - |
| ModelNumber | LC700C | K3 | N2 | - |
| Indicationsfor Use | Luvis Chair is intended tosupply power to and serveas a base for dentaldevices and accessories.This device includes adental chair and isintended for use in thedental clinic environmentand is designed for use bytrained dentalprofessionals, dentistsand/or dental assistants. | K3 is intended to supplypower to and serve as abase for dental devicesand accessories. Thisdevice includes a dentalchair and is intended foruse in the dental clinicenvironment and isdesigned for use by traineddental professionals,dentists and/or dentalassistants. | N2 is intended to supplypower to and serve as abase for dental devicesand accessories. Thisincludes a dental chair andis intended for use in thedental clinic environmentand is designed for use bytrained dentalprofessionals, dentistsand/or dental assistants. | Similar |
| DentistElement Type(Dr. TableType) | Mount Type | Mount Type, Cart Type | Mount Type, Cart Type | Similar |
| Unit Type | Single Type | Single Type | A Type, B Type | Same |
| Supply Mains | 100-120/220-240 Va.c.,50/60 Hz | 100-120/220-240 Va.c.,50/60 Hz | 100-120/220-240 Va.c.,50/60 Hz | Same |
| Utility Supply | Compressed air, andWater | Compressed air, andWater | Compressed air, andWater | Same |
| MainComponents | Chair Part, Unit Part,Table(Dr. Table, AssistTable), Chair Seat, Stool,Monitor Arm, CompactConsole | Chair, Unit, Table, Seat,Stool, Monitor Arm*,Hanaro Console* (Note: K3Cart* model applied ONLY) | Chair, Unit, Table, Seat,Stool, Monitor Arm,Operation Table | Similar |
| DentistElement(Dr. Table) | 1) Accessories: 3-WaySyringe2) Control of Water Supply,Scaler Vibration Power,Table Height, Patient ChairPositioning, Light On/Off,Handpiece Function,Timer, Mode Selection,LED Display | 1) Accessories: 3-WaySyringe2) Control of Water Supply,Scaler Vibration Power,Table Height, PatientPosition, System Power,Film Viewer, Patient ChairPositioning, Light On/Off,Handpiece Function,Timer, Mode Selection,LED Display | 1) Accessories: 3-WaySyringe2) Control of Water Supply,Scaler Vibration Power,Table Height, Patient ChairPositioning, HandpieceFunction, Timer, LEDDisplay | Similar |
| AssistElement(Assist Table) | 1) Accessories: Suction(Saliva Ejector, HVE), DryAir Syringe, 3-Way Syringe2) Light On/Off,Cup/Spittoon WaterDispenser, Changing theSettings, PositionMemories, 1 PersonHelper System | 1) Accessories: SalivaEjector (Small, Large), 3-Way Syringe2) Light On/Off,Cup/Spittoon WaterDispenser, Changing theSettings, PositionMemories | 1) Accessories: SalivaEjector, HVE (Small,Large), 3-Way Syringe2) Second Assi PowerSwitch, Waterline PowerSwitch, Control of Water,Light On/Off, PositionMemories, Spittoon Wash | Similar |
| Syringe | Dry Air Syringe, 3-WaySyringe | 3-Way Syringe | 3-Way Syringe | Similar |
| Control ofWater and Air | Uses pneumaticallycontrolled valves to watercontrol the flow of air andwater.On/Off and intensitycontrolled by foot pedal | Uses pneumaticallycontrolled valves to watercontrol the flow of air andwater.On/Off and intensitycontrolled by foot pedal | Uses pneumaticallycontrolled valves to watercontrol the flow of air andwater.On/Off and intensitycontrolled by foot pedal | Same |
| Water System | City Water Supply | City Water Supply | City Water Supply | Same |
| Cleaning | Cleaning method providedfor Chair Upholstery, TrayTable, Assist Table, Dr. Table,Spittoon, Suction Filter,Suction(Saliva Ejector,HVE), Dry Air Syringe, 3-Way Syringe, andWaterline | - | Waterline cleaningaccording to ISO 16954- Waterline: Routine (Daily)- Shock Treatment(2weeks)Water Flushing (eachpatient) | - |
| Warmer | Heating Method: HeatingCoilStorage ContainerTemperature: Max. 40°CWater Temperature: Avg.33 ~ 35°CTemperature Sensor: Bi-metallic Thermostats | - | Heating Method: HeatingCoilStorage ContainerTemperature: Max. 40°CWater Temperature: Avg.33 ~ 35°CTemperature Sensor: Bi-metallic Thermostats | - |
| WaterSanitationSystem | Distilled water container | Distilled water container | Distilled water container | Same |
| Suction | 1) HVE (High VolumeEvacuator)2) Saliva Ejector3) 1 Person Helper System | 1) HVE (High VolumeEvacuator)2) Saliva Ejector | 1) HVE (High VolumeEvacuator)2) Saliva Ejector3) Second Assi | Same |
| Air Pressure | 500kPa(Min) /750kPa(Max) | 500kPa(Min) /750kPa(Max) | 500kPa(Min) /750kPa(Max) | Same |
| WaterPressure | 215kPa(Min) /275kPa(Max)(2.5 ± 0.3 kgf/cm2) | 250kPa(Min) /600kPa(Max) | 245 kPa(Max) | Similar |
| Patient Load | Max. 150 kg | Max. 135 kg | Max. 150 kg | Similar |
| Chair Height | Max. 770±50mm,Min. 480±50mm | Max. 795±10mm,Min. 365±10mm | Max. 700±10mm,Min. 400±10mm | Similar |
| Back Rest | 0°±5° to 65°±5° | 0°±5° to 67°±5° | 0°±3° to 68°±3° | Similar |
| Head Rest | Double-articulatingheadrestFirst joint: -$-150° | -10 °to 45° | -50° to 14°±2° | Similar |
| Lift Motor | Hydraulic Electromotor | Hydraulic Electromotor | Hydraulic Electromotor | Same |
| Dental Light | Available | Available | Available | Same |
| Foot Control | Available | Available | Available | Same |
| ElectricalSafety | Complied with IEC 60601-1 | Complied with IEC 60601-1 | Complied with IEC 60601-1 | Same |
| ElectromagneticCompatibility | Complied with IEC 60601-1-2 | Complied with IEC 60601-1-2 | Complied with IEC 60601-1-2 | Same |
| PatientContactingComponents | Seat: Polyvinyl Chloride,PolyesterWaterline: Polyurethane,Polyamide 66+ GF25%,Stainless Steel (Chromiumplated), C3604 (Chromiumplated)Airline: Polyurethane,Polyamide 66+ GF25%,C3604 (Chromium plated),Aluminum AlloyHVE: Aluminum Alloy3-Way Syringe: C3604(Chromium plated)Dry Air Syringe: C3604(Chromium plated)Saliva Ejector: AluminumAlloyWarmer: Stainless Steel(Chromium Plated) | - | Seat: Polyvinyl Chloride,PolyesterWaterline: Polyurethaneresin, Polyamide 66+GF25%, Stainless Steel,C3604, SiliconAirline: Polyurethane,Polyamide 66+ GF25%,Aluminum AlloyHVE: Aluminum Alloy3-Way Syringe: C3604(Chromium Plated),Aluminum AlloySaliva Ejector: AluminumAlloyWarmer: Stainless Steel304 (Chromium Plated)Water Block: C3604(Chromium Plated) | Similar |
| Principle ofOperation | The chair is operated, therising S/W is activated andthe chair is hydraulicallyoperated.The handpiece is operated,pressing the foot controlpedal opens the air supplyvalve to rotate thehandpiece turbine.The 3-Way Syringe isoperated by air pressure orelectronic circuit S/W | The chair is operated, therising S/W is activated andthe chair is hydraulicallyoperated.The handpiece is operated,pressing the foot controlpedal opens the air supplyvalve to rotate thehandpiece turbine.The 3-Way Syringe isoperated by air pressure orelectronic circuit S/W | The chair is operated, therising S/W is activated andthe chair is hydraulicallyoperated.The handpiece is operated,pressing the foot controlpedal opens the air supplyvalve to rotate thehandpiece turbine.The 3-Way Syringe isoperated by air pressure orelectronic circuit S/W | Similar |
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Image /page/8/Picture/0 description: The image contains the word "DENTIS" in bold, black letters. To the left of the word is an orange, spiral-like graphic. The graphic appears to be a stylized representation of a tooth or a dental instrument. The overall design is clean and modern.
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Image /page/9/Picture/0 description: The image shows the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved shape that resembles a flame or a stylized letter "D". The logo appears to be for a dental-related company or product, given the association with the word "dentis".
b) Substantial Equivalence Discussion
The Luvis Chair (LC700C) is substantially equivalent to the predicate and reference devices identified above with respect to intended use, principles of operation, and technological characteristics. The subject device has the same Indications for Use and similar technological characterizes as compared to the predicate and reference devices. Therefore, the Luvis Chair (LC700C) is considered substantially equivalent to the predicate devices.
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Image /page/10/Picture/0 description: The image contains the logo for DENTIS. The logo consists of an orange abstract shape on the left, resembling a stylized flame or a curved, layered design. To the right of the shape is the word "DENTIS" in bold, black capital letters.
8. Non-Clinical Test Summary
The Luvis Chair (LC700C) is verified and validated according to the FDA design control requirements, 21 CFR 820. The subject device had been subjected to the applicable safety and performance testing before release to ensure the device meets all its specifications. The quality assurance measures applied to the design and development of the subject device include, but not limited to risk analysis, verification and validation, product specifications and design reviews.
1) Thermal, electrical, mechanical safety & Electromagnetic Compatibility
The Luvis Chair (LC700C) complies with the electrical safety and electromagnetic compatibility requirements established by the standards below:
-
ANSI AAMI ES60601-1 General requirements for basic safety and essential performance - IEC 60601-1-2 General requirements for basic safety and essential performance -Collateral Standard: Electromagnetic disturbances
-
IEC 80601-2-60 Particular requirements for the basic safety and essential performance of dental equipment
2) Software Validations
The Luvis Chair (LC700C) utilizes original software. The Luvis Chair (LC700C) contains Basic documentation level, and MODERATE level of concern software. Software was designed and developed according to a software development process and was verified and validated.
Software information is provided in accordance with FDA guidance: "Guidance for the Content of Premarket Submissions for Software Functions, issued on June 14, 2023."
3) Biocompatibility
The biocompatibility evaluation for the Luvis Chair (LC700C) was conducted in accordance with FDA guidance:
-
"Guidance for the Use of International Standard ISO 10993-1, "Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process, issued on September 8, 2023"
-
ISO 7405 Dentistry - Evaluation of biocompatibility of medical devices used in dentistry
The biocompatibility testing included the following tests:
- In vitro cytotoxicity test
- Oral mucosa Irritation test
- Skin sensitization test
- In vitro cytotoxicity test Agar diffusion method
- In vitro cytotoxicity test Filter diffusion method
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Image /page/11/Picture/0 description: The image contains the word "DENTIS" in bold, black letters. To the left of the word is an orange, curved graphic. The graphic is a stylized representation of a flame or a curved shape.
4) Performance Test
The performance test for Luvis Chair (LC700C) was conducted in accordance with the standards below:
-
IEC 80601-2-60 Particular requirements for the basic safety and essential performance of dental equipment
-
ISO 7494-1 Dentistry - Stationary dental units and dental patient chairs - Part 1: General requirements
-
ISO 7494-2 Dentistry - Dental units - Part 2: Air, water, suction and waste water systems
5) Cleaning and Sterilization Validation
Reprocessing validation testing has conducted in accordance with FDA guidance:
"Guidance for Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling, issued on March 17, 2015"
The cleaning and sterilization was conducted in accordance with the standards below:
-
ISO 17665-1 Sterilization of health care products - Moist heat - Part 1: Requirements for the development, validation and routine control of a sterilization process for medical devices
-
ISO TS 17665-2 Sterilization of health care products - Moist heat - Part 2: Guidance on the application of ISO 17665-1
Dental unit waterline biofilm treatment testing has conducted in accordance with the standards below:
-
ISO 16954 Dentistry - Test methods for dental unit waterline biofilm treatment
-
ISO 19458 Water quality - Sampling for microbiological analysis
9. Conclusions [21 CFR 807.92(b)(3)]
In conclusion, the conducted tests, as well as all verification and validation activities, demonstrate that the design specifications and technological characteristics of the Luvis Chair (LC700C) meet applicable requirements and standards. The testing and validation activities conducted demonstrate that any differences between the subject device and the predicate devices do not raise new questions of safety and effectiveness compared to the predicate and reference devices. Therefore, the Luvis Chair (LC700C) is substantially equivalent to the predicate and reference devices.
§ 872.6250 Dental chair and accessories.
(a)
Identification. A dental chair and accessories is a device, usually AC-powered, in which a patient sits. The device is intended to properly position a patient to perform dental procedures. A dental operative unit may be attached.(b)
Classification. Class I. The dental chair without the operative unit device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter.