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510(k) Data Aggregation
(1 days)
3M Company, Unitek Orthodontic Products
3M™ Clarity™ Aligners with Quick Attachments are indicated for the alignment of teeth during orthodontic treatment of malocclusion.
3M™ Clarity™ Aligners with Quick Attachments, is a clear plastic sequential aligner that offer a solution for patients who want an aesthetic orthodontic treatment by utilizing a set of removable aligners to correct tooth malocclusions without the use of conventional wire and bracket orthodontic technology. 3M™ Clarity™ Aligners with Quick Attachments utilize the option of pre-formed and pre-cured attachments offering a more accurately shaped attachment. Attachments help create forces on the tooth which can assist aligner retention or optimized aligner force system for tooth movement. 3M Clarity Aligners with Quick Attachments provide the option to form the attachments via an empty attachment template that is filled with adhesive and cured on the teeth or by pre-formed 3D printed custom attachments. The aligners, with or without attachments, are for orthodontic treatment of malocclusions.
The provided document describes the 3M™ Clarity™ Aligners with Quick Attachments and its substantial equivalence to a predicate device, 3M™ Clarity™ Aligners (K231464).
Acceptance Criteria and Device Performance:
The document states that the proposed Quick Attachment alternative attachment delivery mechanism completed functional and performance testing, including but not limited to abrasion, bond strength, flexural strength, and stain resistance. The conclusion drawn is that the alternative Quick Attachment delivery mechanism does not impact the safety and effectiveness profile of the 3M™ Clarity™ Aligners and is substantially equivalent to the predicate device.
However, the document does not provide a specific table of acceptance criteria with numerical targets and the reported device performance against those targets. It only states that testing was performed and that the device met the safety and effectiveness profile.
Regarding the study that proves the device meets the acceptance criteria, the following information is available from the document:
This document summarizes a 510(k) premarket notification, which establishes substantial equivalence, implying that the new device is as safe and effective as a legally marketed predicate device. In this context, detailed "acceptance criteria" and "study results" in the format typically seen for a new drug or high-risk medical device might not be explicitly outlined with quantitative data in this summary. Instead, the focus is on demonstrating that the modifications (Quick Attachments) do not alter the safety and efficacy profile from the predicate device.
1. Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Maintenance of Safety and Effectiveness Profile of Predicate Device (3M™ Clarity™ Aligners) | The alternative Quick Attachment delivery mechanism does not impact the safety and effectiveness profile of the predicate device. |
Acceptable Abrasion Resistance | Testing completed, considered acceptable. |
Acceptable Bond Strength | Testing completed, considered acceptable. |
Acceptable Flexural Strength | Testing completed, considered acceptable. |
Acceptable Stain Resistance | Testing completed, considered acceptable. |
Note: The specific numerical acceptance criteria and detailed quantitative results for abrasion, bond strength, flexural strength, and stain resistance are not provided in this 510(k) summary.
2. Sample Size Used for the Test Set and Data Provenance:
The document does not specify the sample size used for the functional and performance testing for the Quick Attachments. It also does not mention the data provenance (e.g., country of origin, retrospective or prospective).
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications:
This information is not provided in the document. The tests mentioned (abrasion, bond strength, flexural strength, stain resistance) are typically objective laboratory or mechanical tests rather than those requiring expert ground truth in a clinical sense.
4. Adjudication Method for the Test Set:
This information is not applicable and is not provided in the document, as the tests described are objective performance tests.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
No MRMC comparative effectiveness study is mentioned. This type of study is more relevant for diagnostic imaging devices where human readers interpret results.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study:
Not applicable. The device is a physical orthodontic product, and the testing described relates to its physical and material properties. There is no mention of an algorithm or AI component in this context.
7. Type of Ground Truth Used:
The "ground truth" for the functional and performance testing (abrasion, bond strength, flexural strength, stain resistance) would be the established scientific and engineering standards and methods for measuring these material properties. It is not an expert consensus, pathology, or outcomes data in the clinical sense for this type of device.
8. Sample Size for the Training Set:
Not applicable. The document describes functional and performance testing of a physical device component, not an AI or algorithm that would require a training set.
9. How the Ground Truth for the Training Set Was Established:
Not applicable, as there is no training set mentioned or implied for this device.
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(3 days)
3M Company, Unitek Orthodontic Products
3M™ Clarity™ Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion.
3M™ Clarity™ Aligners (3M™ Clarity™ Aligners-Force. 3M™ Clarity™ Aligners-Flex) are a series of clear plastic aligners that offer a solution for patients who want an aesthetic orthodontic treatment by utilizing a set of removable aligners to correct tooth malocclusions without the use of conventional wire and bracket orthodontic technology. The present Premarket Submission is for the simplification in the number of formulations of the aligner material. This simplification allows for streamlined manufacturing processes so that both 3M Clarity Aligners-Flex and 3M Clarity Aligners-Force can be composed of the same material with differing flexibilities. The aligners will still be named 3M™ Clarity™ Aligners (3M™ Clarity™ Aligners-Force, 3M™ Clarity™ Aligners-Flex).
3M is offering a treatment plan with two different aligner flexibilities where the dental health professional will determine which degree of flexibility to use during the treatment plan. 3M Clarity Aligners-Flex is designed to be more flexible thereby increasing patient comfort and ease of insertion and removal. 3M Clarity Aligners-Force is designed to be more rigid increasing the force persistence. 3M will continue to offer the option of combination treatment plans where both 3M Clarity Aligners-Flex and 3M Clarity Aligners-Force can be used.
A dental health professional (e.g., orthodontist or dentist), prescribes 3M™ Clarity™ Alieners (3MTM Clarity™ Aligners-Force, 3MTM Clarity™ Aligners-Flex) based on an assessment of the patient's teeth and determines a course of treatment with the system. Patient data is collected via intra-oral scanning or taking physical impressions. The prescribing physician reviews and approves the model scheme before the molds are produced. Once approved. 3M produces trays, which are formed of clear, thin, thermoformed plastic. The trays are sent back to the dental health care professional who then provides them to the patient, confirming fit and design. The dental care professional monitors treatment from the first aligner is delivered to when the final aligner is delivered. The trays are held in place by pressure and can be removed by the patient at any time.
This document is a 510(k) Premarket Notification for the 3M™ Clarity™ Aligners. The core purpose of the submission is to demonstrate substantial equivalence to a previously cleared predicate device (K211190) rather than to present a study proving the device meets specific acceptance criteria for clinical performance that would allow it to be used as a standalone diagnostic or screening tool.
The "acceptance criteria" and "study that proves the device meets the acceptance criteria" in this context refer to the performance testing conducted to show that the new material formulation of the aligners does not negatively impact safety and effectiveness compared to the predicate device. The information provided heavily focuses on bench testing and biocompatibility rather than clinical efficacy studies.
Here's a breakdown based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't provide a direct table of acceptance criteria with numerical targets and corresponding device performance values in detail. Instead, it states that "All performance testing shows acceptable results for all tested samples." The acceptance is based on demonstrating that the subject device's performance is comparable or equivalent to the predicate device, especially considering the change in material.
Feature Assessed (Acceptance Criteria Implicitly: Comparable to Predicate) | Reported Device Performance |
---|---|
Translucency properties | Acceptable results |
Abrasion resistance | Acceptable results |
Formability | Acceptable results |
Mechanical stability | Acceptable results |
Dimensional stability | Acceptable results |
Force persistence | Acceptable results |
Fatigue cracking resistance | Acceptable results |
Chemical staining resistance | Acceptable results |
Transportation | Acceptable results |
Use life | Acceptable results |
Biocompatibility (various endpoints) | Safe for its intended use |
2. Sample Size Used for the Test Set and Data Provenance:
The document does not specify the exact sample sizes for each type of performance testing (translucency, abrasion, etc.). It generally refers to "all tested samples" from "bench testing." The data provenance is internal to 3M™ Company, arising from their in vitro and ex vivo laboratory testing. This is retrospective data collected for regulatory submission purposes. There is no information about country of origin for the data that would be relevant to clinical studies in this context.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:
This question is not directly applicable in the context of this 510(k) submission, as it relates to clinical efficacy studies or diagnostic performance evaluations. The "ground truth" here is established by the accepted scientific and engineering principles for material and device performance testing. For biocompatibility, a "Diplomate of the American Board of Toxicology" assessed the safety.
4. Adjudication Method for the Test Set:
Not applicable, as this is primarily a bench testing and material change submission, not focused on human interpretation of clinical data in a test set.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
Not applicable. This submission is for an orthodontic aligner device, not an AI-assisted diagnostic or imaging device.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Not applicable. This is a physical medical device, not a software algorithm. While software is used in the manufacturing process, the submission does not present performance data for the software itself in a standalone context.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for the performance testing is based on established scientific and engineering standards for material properties and device functionality, often evaluated against the previous (predicate) device's performance, as well as relevant ISO standards (e.g., ISO 10993 for biocompatibility) and FDA guidance documents. For biocompatibility, the assessment by a board-certified toxicologist serves as the expert evaluation.
8. The Sample Size for the Training Set:
Not applicable. This submission focuses on a physical device and its material properties, not an AI algorithm requiring a training set.
9. How the Ground Truth for the Training Set was Established:
Not applicable, as there is no training set for an AI algorithm.
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(2 days)
3M Company, Unitek Orthodontic Products
3M™ Clarity™ Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion.
The 3M Clarity Aligners, 3M Clarity Aligners-Flex and 3M Clarity Aligners-Force are a series of clear plastic aligners that offer a solution for patients who want an aesthetic orthodontic treatment by utilizing a set of removable aligners to correct tooth malocclusions without the use of conventional wire and bracket orthodontic technology. The present Premarket Submission is for the addition of a new form of the aligner called 3M Clarity Aligners-Flex to the 3M Clarity Aligner system. 3M will continue to offer aligners composed of the same material as previously cleared (K192119) as 3M Clarity Aligners-Force. 3M will offer the option of combination treatment plans where both 3M Clarity Aligners-Flex and 3M Clarity Aligners-Force can be used.
A dental health professional (e.g. orthodontist or dentist), prescribes 3M Clarity Aligners, 3M Clarity-Flex, 3M Clarity Aligners-Force based on an assessment of the patient's teeth and determines a course of treatment with the system. Patient data is collected via intra-oral scanning or taking physical impressions. The prescribing physician reviews and approves the model scheme before the molds are produced. Once approved, 3M produces trays, which are formed of clear, thin, thermoformed plastic. The trays are sent back to the dental health care professional who then provides them to the patient, confirming fit and design. The dental care professional monitors treatment from the moment the first aligner is delivered to when the final aligner is delivered. The trays are held in place by pressure and can be removed by the patient at any time.
This document outlines the acceptance criteria and the study proving the device meets these criteria for the 3M™ Clarity™ Aligners (Force and Flex), based on the provided FDA 510(k) submission summary.
Executive Summary:
The 3M™ Clarity™ Aligners-Flex device is being introduced as an addition to the already cleared 3M™ Clarity™ Aligner system (predicate device K192119). The primary difference is the introduction of a new material, "3M Flex Thermoplastic Material", alongside the existing "3M Force Thermoplastic Material". The submission argues for substantial equivalence by demonstrating that the new material and combination treatment plans do not alter the fundamental indications for use, manufacturing processes, design, or device features as compared to the predicate device. Performance testing confirms acceptable results for optical properties, mechanical stability, staining, transportation, use life, force, and conditioning. Biocompatibility testing was also conducted and found the product safe for its intended use.
Acceptance Criteria and Device Performance Study
The provided 510(k) summary does not detail explicit quantitative acceptance criteria with specific performance metrics such as sensitivity, specificity, accuracy, or AUC that would typically be associated with AI/ML diagnostic or prognostic devices. Instead, the acceptance criteria appear to be qualitative and relate to demonstrating that the new 3M™ Clarity™ Aligners-Flex are substantially equivalent to the predicate device (3M™ Clarity™ Aligners, K192119) across various performance aspects, particularly concerning its physical and material properties, and its continued safety and efficacy for its stated indications.
The "study" in this context refers to the performance testing conducted to support the substantial equivalence claim, rather than a clinical trial comparing the diagnostic accuracy of an AI system.
Here's an interpretation of the acceptance criteria and reported performance based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
Category / Performance Aspect | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Indications for Use | Must align with the predicate device (alignment of teeth during orthodontic treatment of malocclusion). | "Clarity Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion." (Identical to predicate). The addition of 3M Clarity Aligners-Flex and combination treatment plans maintains this indication. |
Manufacturing Process | Must be consistent with or equally robust as the predicate device's automated state-of-the-art process. | "No change" compared to the predicate device's manufacturing process. |
Device Design/Features | Must maintain the same design and device features as the predicate device. | "3M Clarity Aligners-Flex and the previously cleared 3M Clarity Aligners (K192119) have the same design, device features, software as well as their manufacturing processes." Also, "Orthodontic tooth movements occur through forces applied to the dentition as each tooth follows the programmed displacement based on a doctor's prescription" (No change). |
Software | Must be unchanged from the predicate device's proprietary manufacturing software. | "There are no changes in the software compared to the existing 3M Clarity Aligners (K192119)." |
Optical Properties | Must meet predefined standards for clarity, transparency, or other relevant optical attributes for clear aligners. | "Results of optical properties... are included in this Premarket submission which showed acceptable results for all tested samples." |
Mechanical Stability | Must demonstrate sufficient strength, durability, and resistance to deformation under typical use conditions. | "Results of... mechanical stability... are included in this Premarket submission which showed acceptable results for all tested samples." |
Staining Resistance | Must resist common staining agents encountered during oral use to maintain aesthetic appearance. | "Results of... staining... are included in this Premarket submission which showed acceptable results for all tested samples." |
Transportation Stability | Must withstand typical shipping and handling conditions without degradation. | "Results of... transportation... are included in this Premarket submission which showed acceptable results for all tested samples." |
Use Life (Durability) | Must maintain performance and integrity throughout the prescribed wear period. | "Results of... use life... are included in this Premarket submission which showed acceptable results for all tested samples." |
Force Application | Must consistently apply forces necessary for programmed tooth movement, comparable to the predicate device. | "Results of... force... are included in this Premarket submission which showed acceptable results for all tested samples." While the material is different, the "Technical Features and Properties" section states "No change" implying similar force application principles. |
Conditioning | Must retain properties after exposure to environmental conditions (e.g., temperature, humidity) throughout its lifecycle. | "Results of... conditioning among others are included in this Premarket submission which showed acceptable results for all tested samples." |
Biocompatibility | Must be safe for mucosal membrane contact for greater than 30 days, adhering to relevant FDA guidelines. | "The biocompatibility evaluation for the device was conducted in accordance with US FDA Docket Number FDA-2013-D-0350 edition dated: September 4, 2020. The aligner is considered mucosal membrane contacting device that is intended to be in contact with the body for greater than 30 days. The evaluation found this product to be safe for its intended use." |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document states "acceptable results for all tested samples" for the performance testing (optical properties, mechanical stability, etc.). However, it does not specify the exact number of samples used for each test.
- Data Provenance: The document does not specify the country of origin of the data. It's implicitly retrospective in the sense that the testing was conducted prior to submission to demonstrate equivalency, but it's not a clinical study on patients. The data is derived from laboratory and material testing.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- This information is not applicable to this submission. The "ground truth" here is not based on expert clinical consensus or interpretation of medical images/data, but rather on direct physical and material property measurements and biocompatibility testing against established standards. The device is a physical orthodontics product, not an AI diagnostic tool requiring expert ground truth for a test set.
4. Adjudication Method for the Test Set
- This is not applicable. There is no "adjudication" in the sense of resolving discrepancies in expert interpretations, as the testing involves objective physical measurements and adherence to material standards.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and its effect size
- This is not applicable. The device is an orthodontic aligner, not an AI diagnostic or assistive tool. Therefore, no MRMC study, AI assistance, or human reader improvement effect size is relevant to this submission.
6. If a Standalone (algorithm only without human-in-the-loop performance) was done
- This is not applicable. This describes a physical medical device (orthodontic aligner) and not an AI algorithm. While it leverages proprietary CAD/CAM software in its manufacturing, the submission does not present performance data for the software in a standalone "algorithm only" context, as the software's performance is intrinsically linked to the physical output of the aligners.
7. The Type of Ground Truth Used
- The "ground truth" for this device is based on objective physical and chemical properties measurements, engineering specifications, and established biocompatibility standards. It's not clinical outcomes data, pathology, or expert consensus in a diagnostic sense. The ground truth for the "acceptability" of these measurements is predefined by internal company specifications and relevant industry/regulatory standards (e.g., ISO standards for plastics, FDA guidance for biocompatibility).
8. The Sample Size for the Training Set
- This is not applicable. The device is a manufactured physical product. There is no "training set" in the context of machine learning or AI algorithm development. The manufacturing processes are established through engineering design, material science, and quality control, not data training.
9. How the Ground Truth for the Training Set was Established
- This is not applicable for the same reason as point 8.
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