K Number
K240810
Device Name
Anti Grinding Guard
Date Cleared
2024-05-24

(60 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Anti Grinding Guard is a mouth guard intended to protect against grinding and clenching.
Device Description
The Anti Grinding Guard is an over-the-counter (OTC), flexible and moldable one-piece dental mouth guard, which is used as a barrier between teeth for individual s who grind their teeth. The anti Grinding Guard is intended to be worn while sleeping. The guard is constructed of 100% thermoplastic ethylene-vinyl acetate copolymer. When heated it forms to the individual's teeth. It is non-flavored and has no color additives. The mouth guard Is one model/size, is reusable by a single individual at least eighteen (18) years of age and is supplied as non-sterile.
More Information

Not Found

No
The device description and performance studies focus on the physical properties and biocompatibility of a simple, moldable mouth guard. There is no mention of AI, ML, image processing, or data-driven algorithms.

Yes

Explanation: The device is intended to protect against grinding and clenching, which addresses a medical condition (bruxism) and provides therapeutic benefits by preventing tooth wear and associated symptoms.

No

The device description indicates it is a mouth guard intended to protect against grinding and clenching, acting as a barrier. The performance studies focus on material properties and physical performance rather than diagnostic capabilities. There is no mention of the device analyzing or providing information about a patient's condition for diagnosis.

No

The device description explicitly states it is a physical mouth guard made of thermoplastic material, which is a hardware component.

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

Here's why:

  • Intended Use: The intended use is to protect against grinding and clenching by acting as a physical barrier in the mouth. This is a mechanical function, not a diagnostic one.
  • Device Description: The description details a physical mouth guard made of thermoplastic material. It does not mention any components or processes related to analyzing biological samples (like blood, urine, tissue, etc.) to diagnose a condition.
  • Lack of Diagnostic Activity: There is no mention of the device being used to detect, measure, or analyze any substances or markers within the body or in biological samples.
  • Performance Studies: The performance studies focus on the physical properties and biocompatibility of the mouth guard (hardness, water absorption, wear, toxicity, etc.). These are relevant to a physical device worn in the mouth, not to a diagnostic test.

IVD devices are specifically designed to perform tests on samples taken from the human body to provide information for the diagnosis, monitoring, or treatment of a disease or condition. This mouth guard does not fit that description.

N/A

Intended Use / Indications for Use

The Anti Grinding Guard is a mouth guard intended to protect against grinding and clenching.

Product codes

OBR

Device Description

The Anti Grinding Guard is an over-the-counter (OTC), flexible and moldable one-piece dental mouth guard, which is used as a barrier between teeth for individual s who grind their teeth. The anti Grinding Guard is intended to be worn while sleeping. The guard is constructed of 100% thermoplastic ethylene-vinyl acetate copolymer. When heated it forms to the individual's teeth. It is non-flavored and has no color additives. The mouth guard Is one model/size, is reusable by a single individual at least eighteen (18) years of age and is supplied as non-sterile.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Oral cavity

Indicated Patient Age Range

Adults 18 and older

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)

Bench testing has demonstrated that the device is in compliance with pertinent standards and specifications, the expectations of the dental community and the product labeling. Performance testing was performed to the proposed device including hardness, water absorption and solubility testing, boiling/cooling water testing, impression test, and comparative wear test to demonstrate its effectiveness.

The non-clinical testing of Anti Grinding Guard demonstrates the device's performance in providing including hardness, water absorption and solubility testing, boiling/cooling water testing, impression test, separation test, and comparative wear test, which supports its substantial equivalence to the predicate device.

Additionally, the following tests for biocompatibility were conducted on the Mouth Guard.

  • Cytotoxicity
  • Oral Mucosa Irritation ●
  • Skin Sensitization
  • Acute systemic toxicity
  • Sub chronic systemic toxicity
  • Genotoxicity

The results of the testing met the requirements of the study protocols and the material is considered non-toxic, non-sensitizing and is not an intracutaneous irritant. The results of the studies further support a determination of substantial equivalence to the predicate.

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

Not Found

Predicate Device(s)

K181099

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

N/A

0

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May 24, 2024

Xiamen Yizhou Imp. & Exp. Co., Ltd. % Ivy Wang Technical Manager Shanghai Sungo Management Consulting Co. Ltd. 14th Floor, 1500# Century Avenue Shanghai, Shanghai 200122 CHINA

Re: K240810 Trade/Device Name: Anti Grinding Guard Regulatory Class: Unclassified Product Code: OBR Dated: March 25, 2024 Received: March 25, 2024

Dear Ivy Wang:

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"

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(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).

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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

Submission Number (if known)

K240810

Device Name

Anti Grinding Guard

Indications for Use (Describe)

The Anti Grinding Guard is a mouth guard intended to protect against grinding and clenching.

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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K240810 510(K) Summary

Prepared date: 2024-03-18 A. Applicant: Xiamen Yizhou Imp. & Exp. Co., Ltd. Address: 2F, 1#, Huli Industrial Park, Meixi Road, Tong An District, Xiamen City, Fujian, China Contact Person: Elaine Huang Tel: + 86 13859990367 Email: xmyizhou@hotmail.com

Submission Correspondent: Primary contact: Ms. Ivy Wang Shanghai SUNGO Management Consulting Co., Ltd. Room 1401, Dongfang Building, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-58817802 Email: haiyu.wang@sungoglobal.com Secondary contact: Mr. Raymond Luo Room 1401, Dongfang Building, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-68828050 Email: zxfda@sungoglobal.com

B. Device:

Trade Name: Anti Grinding Guard Common Name: Over-the-Counter Dental Guard Model: YZ9003

Regulatory Information Classification Name: Mouthguard, Over-the Counter Regulation Number: N/A Product Code: OBR Unclassified Device Class: Review Panel: Dental

C. Predicate device:

510(k) Number: K181099 Trade Name: Bright Guard Manufacturer: Koncept Innovators, LLC.

D. Indications for use of the device:

The Anti Grinding Guard is a mouth guard intended to protect against grinding and clenching.

E. Device Description:

The Anti Grinding Guard is an over-the-counter (OTC), flexible and moldable one-piece dental

5

mouth guard, which is used as a barrier between teeth for individual s who grind their teeth. The anti Grinding Guard is intended to be worn while sleeping. The guard is constructed of 100% thermoplastic ethylene-vinyl acetate copolymer. When heated it forms to the individual's teeth. It is non-flavored and has no color additives. The mouth guard Is one model/size, is reusable by a single individual at least eighteen (18) years of age and is supplied as non-sterile.

Table 1 General Comparison
DeviceProposed DevicePredicate DeviceResult
510K number-K181099-
Model nameAnti Grinding GuardBright Guard-
ClassificationUnclassifiedUnclassifiedSame
RegulationN/AN/ASame
Product codeOBROBRSame
Indications for useThe Anti Grinding Guard is a mouth guard intended to protect against grinding and clenching.Bright Guard is a mouth guard intended to protect against grinding and clenching.Same
Intended useKeep upper and lower teeth separated during sleep.Keep upper and lower teeth separated during sleep.Same
OTC useYesYesSame
Target populationAdults 18 and olderAdults 18 and olderSame
Technological characteristicsFlexible, moldable guard used as a barrier between teeth.Flexible, moldable guard used as a barrier between teeth.Same
Molding MethodBoil and Bite Method (Heat & Bite Self-Fit)Boil and Bite Method (Heat & Bite Self-Fit)Same
MaterialEthylene-vinyl acetate copolymerEthylene-vinyl acetate copolymerSame
Location of UseUpper Arch TeethUpper Arch TeethSame
Method of manufactureInjection moldingInjection moldingSame
Molding timeIn hot water time: 15-20 seconds
Mouth molding time: 20-25 secondsIn hot water time: 15-20 seconds
Mouth molding time:
20-25 secondsSame
Wear TimeFour (4) months wear time until replacement with new mouth guardFour (4) months wear time until replacement with new mouth guardSame
Worn during sleeping for no
more than twelve (12) hours per
day.Worn during sleeping for no
more than twelve (12) hours
per day.
SterilityNon-SterileNon-SterileSame
Anatomical site of
useOral cavityOral cavitySame
BiocompatibilityISO 10993 compliesISO 10993 compliesSame

F. Comparison with predicate device

2

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G. Non-Clinical Test Conclusion

Bench testing has demonstrated that the device is in compliance with pertinent standards and specifications, the expectations of the dental community and the product labeling. Performance testing was performed to the proposed device including hardness, water absorption and solubility testing, boiling/cooling water testing, impression test, and comparative wear test to demonstrate its effectiveness.

The non-clinical testing of Anti Grinding Guard demonstrates the device's performance in providing including hardness, water absorption and solubility testing, boiling/cooling water testing, impression test, separation test, and comparative wear test, which supports its substantial equivalence to the predicate device.

Additionally, the following tests for biocompatibility were conducted on the Mouth Guard.

  • Cytotoxicity
  • Oral Mucosa Irritation ●
  • Skin Sensitization
  • Acute systemic toxicity
  • Sub chronic systemic toxicity
  • Genotoxicity

The results of the testing met the requirements of the study protocols and the material is considered non-toxic, non-sensitizing and is not an intracutaneous irritant. The results of the studies further support a determination of substantial equivalence to the predicate.

H. Clinical Test Conclusion

No clinical study is included in this submission.

I. Conclusion

The conclusions drawn from the nonclinical tests demonstrate that the subject device is as safe, as effective, and performs as well as the legally marketed predicate device K181099.