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510(k) Data Aggregation

    K Number
    K233257
    Date Cleared
    2023-09-29

    (1 days)

    Product Code
    Regulation Number
    872.5470
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M™ Clarity™Aligners with Quick Attachments

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3M™ Clarity™ Aligners with Quick Attachments are indicated for the alignment of teeth during orthodontic treatment of malocclusion.

    Device Description

    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.

    AI/ML Overview

    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 ResistanceTesting completed, considered acceptable.
    Acceptable Bond StrengthTesting completed, considered acceptable.
    Acceptable Flexural StrengthTesting completed, considered acceptable.
    Acceptable Stain ResistanceTesting 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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    K Number
    K231464
    Date Cleared
    2023-05-22

    (3 days)

    Product Code
    Regulation Number
    872.5470
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M™ Clarity™ Aligners (3M™ Clarity™ Aligners-Force, 3M™ Clarity™ Aligners-Flex)

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3M™ Clarity™ Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion.

    Device Description

    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.

    AI/ML Overview

    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 propertiesAcceptable results
    Abrasion resistanceAcceptable results
    FormabilityAcceptable results
    Mechanical stabilityAcceptable results
    Dimensional stabilityAcceptable results
    Force persistenceAcceptable results
    Fatigue cracking resistanceAcceptable results
    Chemical staining resistanceAcceptable results
    TransportationAcceptable results
    Use lifeAcceptable 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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    K Number
    K211190
    Date Cleared
    2021-04-23

    (2 days)

    Product Code
    Regulation Number
    872.5470
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M Clarity Aligners (3M Clarity Aligners-Force, 3M Clarity Aligners-Flex)

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3M™ Clarity™ Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion.

    Device Description

    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.

    AI/ML Overview

    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 AspectAcceptance Criteria (Implied)Reported Device Performance
    Indications for UseMust 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 ProcessMust 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/FeaturesMust 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).
    SoftwareMust 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 PropertiesMust 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 StabilityMust 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 ResistanceMust 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 StabilityMust 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 ApplicationMust 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.
    ConditioningMust 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."
    BiocompatibilityMust 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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    K Number
    K192119
    Manufacturer
    Date Cleared
    2019-09-05

    (30 days)

    Product Code
    Regulation Number
    872.5470
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M Clarity Aligners

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3M™ Clarity™ Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion

    Device Description

    The 3M Clarity Aligners 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.

    A dental health professional (e.g. orthodontist or dentist), using a standard personal computer prescribes 3M Clarity Aligners based on an assessment of the patient's teeth, determines a course of treatment with the system, takes molds of the patient's teeth and completes a prescription form using a standard dental software used for tooth alignment, 3M then designs a series of plastic trays intended to gradually realign the patient's teeth in accordance with the physician's prescription using a standard dental software used for tooth alignment. 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. Over a period, additional trays are provided sequentially to the patient by the dental health professional to gradually move the target teeth to the designed position. 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.

    There are no changes being made to the 3M Clarity Aligners themselves. Both the proposed 3M Clarity Aligners and the primary predicate 3M Clarity Aligners (K183159) have the same indications for use. The present premarket submission is to account for the overall software cumulative changes including the integration of the ULab software (K171295).

    AI/ML Overview

    The provided document is a 510(k) summary for the 3M Clarity Aligners. It describes the device, its intended use, and its substantial equivalence to a predicate device. However, it does not include detailed information regarding specific acceptance criteria, a standalone study with performance metrics, human reader studies (MRMC), or a detailed breakdown of sample sizes, ground truth establishment, or expert qualifications for testing and training sets.

    The relevant section for performance testing states:
    "Results of verification and validation testing demonstrate the proposed 3M Clarity Aligners showed conformity with pre-established specifications and acceptance criteria. Software testing was conducted in accordance with "General Principles of Software Validation; Final Guidance for Industry and FDA Staff'' dated January 11, 2002 and Medical Device Software - Software Life Cycle Processes; ANSI/AAMI/IEC 62304:2015."

    This statement confirms that testing was performed against acceptance criteria and established standards, but it does not provide the acceptance criteria themselves, nor the specific performance results or details of the study proving the device met them.

    Therefore, I cannot fulfill your request for:

    1. A table of acceptance criteria and the reported device performance.
    2. Sample size used for the test set and the data provenance.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts.
    4. Adjudication method for the test set.
    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, or the effect size of human improvement.
    6. If a standalone performance (algorithm only) was done (beyond the general statement of "conformity with pre-established specifications").
    7. The type of ground truth used.
    8. The sample size for the training set.
    9. How the ground truth for the training set was established.

    The document focuses on the claim of substantial equivalence based on the device's identical indications for use, technological characteristics (except for software improvements), and manufacturing processes compared to its predicate device. The software changes are noted to include the integration of ULab software, which allows the Dental Health Professional to directly own and submit the treatment planning process for manufacturing without interaction with 3M technicians.

    In summary, while the document states performance testing was conducted, it does not disclose the detailed results or methodologies required to answer your specific questions.

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    K Number
    K183159
    Manufacturer
    Date Cleared
    2018-11-26

    (11 days)

    Product Code
    Regulation Number
    872.5470
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    3M Clarity Aligners

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    3M™ Clarity™ Aligners are indicated for the alignment of teeth during orthodontic treatment of malocclusion.

    Device Description

    The 3M Clarity Aligners 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.

    AI/ML Overview

    The provided document is a 510(k) summary for the 3M Clarity Aligners. It describes that this submission is primarily to change the Indications for Use by removing a treatment limitation. It explicitly states: "No additional testing has been included on this submission. Biocompatibility tests, performance testing and software verification and validation testing data was previously submitted and reviewed to support clearance of the predicate device 3M Clear Tray Aligner under premarket notification K163689."

    Therefore, based on the provided document, there is no new study or acceptance criteria analysis present for the 3M Clarity Aligners in this particular submission (K183159). The substantial equivalence relies on previous clearances.

    However, I can extract the information related to the device's characteristics and the basis for its substantial equivalence to its predicates.

    Here's a breakdown of the requested information based on the provided text, with the understanding that new testing was not performed for this specific submission:

    1. A table of acceptance criteria and the reported device performance

    • Acceptance Criteria for K183159: The primary acceptance criterion for this submission (K183159) is that the 3M Clarity Aligners, with the revised Indications for Use, remain substantially equivalent to the predicate devices (Invisalign® System (K081960) and 3M Clear Tray Aligner (K163689)). This is based on the argument that the change in indication does not affect design, material, manufacturing processes, or software, which were all previously cleared.
    • Reported Device Performance: The document does not report new performance data for K183159. It asserts that the device's technological characteristics, design, material composition, device features, and manufacturing processes remain the same as the previously cleared 3M Clear Tray Aligner (K163689).
    Feature / Criteria (for this submission K183159)Reported Device Performance (3M Clarity Aligners)
    Indications for Use (Expansion)Expanded to "alignment of teeth during orthodontic treatment of malocclusion," removing the previous limitation of "patients with permanent dentition (i.e., all second molars)." This matches the primary predicate Invisalign.
    Technological CharacteristicsIdentical to the previously cleared 3M Clear Tray Aligner (K163689). This includes design, material composition, device features, and manufacturing processes.
    Material CompositionThermoplastic, identical to 3M Clear Tray Aligner (K163689). Different from primary predicate Invisalign, but considered equivalent due to previous clearance of K163689.
    SoftwareNo changes compared to existing 3M Clarity Aligners; design, development, methodology, process, and environment are identical to the predicate device.
    BiocompatibilityPreviously tested and reviewed for K163689.
    Performance TestingPreviously tested and reviewed for K163689.
    Software Verification & ValidationPreviously tested and reviewed for K163689.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • The document explicitly states: "No additional testing has been included on this submission." Therefore, no new sample size or data provenance information from a test set is provided for this specific submission. The reliance is on data from the K163689 submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not applicable for this submission (K183159) as no new testing was performed.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable for this submission (K183159) as no new testing was performed.

    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 device is a physical aligner and not an AI/imaging diagnostic device that would involve human readers or AI assistance in that context.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not applicable. This device is a physical aligner. The software mentioned is for the "Ordering Workflow" and not for diagnostic or treatment planning automation that would typically require standalone performance testing in the context of an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Not applicable for this submission (K183159) as no new testing was performed. For the original clearance of K163689 (or the predicate Invisalign K081960), the "ground truth" for orthodontic devices typically refers to their ability to achieve desired tooth movements as planned by orthodontists, potentially validated through clinical outcomes, but this document does not detail such studies for K163689 either.

    8. The sample size for the training set

    • Not applicable for this submission (K183159) as no new testing was performed for a modeling or AI component that would require a training set. The software is for ordering workflow.

    9. How the ground truth for the training set was established

    • Not applicable for this submission (K183159) as no new testing was performed for a modeling or AI component that would require a training set.
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