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510(k) Data Aggregation

    K Number
    K192846
    Manufacturer
    Date Cleared
    2020-02-10

    (130 days)

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

    Argen Clear Aligner, Argen Clear Aligner Premium

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

    The Argen Clear Aligner and Argen Clear Aligner Premium are indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e. all second molars). The aligner positions teeth by way of continuous gentle force.

    Device Description

    The Argen clear aligners are comprised of series of clear plastic removable aligner trays that are designed to correct tooth malocclusions without the use of conventional wire and bracket orthodontic technology. A dental health professional (e.g. orthodontist or dentist) prescribes the Argen Clear Aligner or the Argen Clear Aligner Premium based on an assessment of the patient's teeth. The dental health professional (dentist/orthodontist) takes intraoral scans or physical impressions of the patient's teeth, determines a course of treatment with the system, and completes a prescription form using a standard dental software used for tooth alignment. The series of plastic trays are designed in accordance with the physician's prescription using standard dental software for planning the tooth alignment. The software system used is Ortho Analyzer, 2019 ver 1.8.1.0 by 3Shape A/S (K180941). It is used for management of 3D scanned orthodontic models, orthodontic diagnosis by measuring, analyzing, inspecting and visualizing 3D scanned orthodontic models, virtual planning of orthodontic treatments by simulating tooth movements, and design of orthodontic appliances based on 3D scanned orthodontic models. The prescribing physician reviews and approves the model scheme before the molds are produced. Once approved, Argen produces trays, which are formed of clear, thin, thermoformed plastic. The trays are provided to the dental health care professional who provides them to the patient, confirming fit and design. The thermoplastic materials used in the manufacture of the Argen aligners are similar to the materials commonly used in many dental and orthodontic appliances including clear aligners. The Argen Clear Aligner is made of a thermoplastic polyurethane resin and the Argen Clear Aligner Premium is made of a thermoplastic polyurethane-polyester composite resin.

    AI/ML Overview

    The provided text describes the "Argen Clear Aligner" and "Argen Clear Aligner Premium" devices. These are orthodontic devices, and the information is from an FDA 510(k) summary, which focuses on substantial equivalence to predicate devices rather than detailed performance studies for AI/software components as would be described for diagnostic AI tools.

    Therefore, many of the requested details, such as specific acceptance criteria related to diagnostic performance metrics, sample sizes for test sets (in the context of AI models), number of experts, adjudication methods, MRMC studies, standalone performance, training set details, and ground truth establishment for AI performance, are not applicable for this type of medical device submission.

    This document describes a physical medical device (clear aligners) and its manufacturing process, incorporating a software system (Ortho Analyzer) for treatment planning and design. The "performance data" referred to in Section VII of the 510(k) summary (page 3) relates to physical properties and biocompatibility testing, and verification and validation activities to ensure consistency between the aligner series' design and manufactured aligners. This is distinct from the performance evaluation of a diagnostic AI algorithm.

    Here's a breakdown of the requested information based on the provided text, indicating where information is not applicable or not provided:

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

    The document does not explicitly state acceptance criteria in terms of diagnostic performance metrics (e.g., sensitivity, specificity, AUC) because it's not a diagnostic AI device. The "acceptance criteria" mentioned refer to the manufacturing and design consistency of the physical aligners.

    Acceptance Criteria (General)Reported Device Performance (Summary)
    Material Properties:Thermoplastic polyurethane resin (Argen Clear Aligner) and thermoplastic polyurethane-polyester composite resin (Argen Clear Aligner Premium) are similar to materials commonly used in many dental and orthodontic appliances, including clear aligners. Biocompatibility shown to meet requirements (referenced from predicate device submissions).
    Manufacturing Consistency:Verification and validation activities were assessed on the proposed device to ensure consistency between the aligner series' design and manufactured aligners. The results show the proposed device met all pre-defined acceptance criteria (specific criteria are not detailed in this summary, but would typically relate to dimensional accuracy, fit, and material integrity as per design specifications).
    Intended Use:The device performs its intended use of treating tooth malocclusion in patients with permanent dentition by positioning teeth via continuous gentle force. This is affirmed through a substantial equivalence determination to predicates with established safe and effective use. The software system, Ortho Analyzer, is used for management of 3D scanned orthodontic models, orthodontic diagnosis by measuring/analyzing/inspecting/visualizing 3D scanned models, virtual planning of orthodontic treatments by simulating tooth movements, and design of orthodontic appliances. The prescribing physician reviews and approves the model scheme before production.
    Safety:A Risk Analysis was performed according to ISO 14971:2012, assessing the modification (material change) and its impact on performance and safety.

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

    This information is not applicable as the device is a physical orthodontic aligner, and its 510(k) submission primarily relies on substantial equivalence and engineering/biological verification and validation, not a clinical study involving a "test set" of patient data for AI performance evaluation. The "software" mentioned (Ortho Analyzer) is a tool for design and planning, not a diagnostic AI.

    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)

    This information is not applicable for the reasons stated above.

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

    This information is not applicable for the reasons stated above.

    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

    This information is not applicable for the reasons stated above.

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

    This information is not applicable. While there is software involved in the design and planning of the aligners (Ortho Analyzer), it is not described as a standalone diagnostic AI algorithm. The process explicitly involves a "dental health professional (dentist/orthodontist)" who "determines a course of treatment" and a "prescribing physician reviews and approves the model scheme." This indicates a human-in-the-loop design and prescription process.

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

    This information is not applicable in the context of diagnostic AI performance. For the aligners, the "ground truth" would relate to successful orthodontic treatment outcomes, which are assessed clinically by the treating dentist/orthodontist over time, not through a single reference standard for an AI algorithm.

    8. The sample size for the training set

    This information is not applicable. The device itself is a physical product. While the "Ortho Analyzer" software likely has an underlying model or algorithm for generating treatment plans, the document does not provide details of its training set, as this is not an AI diagnostic submission.

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

    This information is not applicable for the reasons stated above.

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