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510(k) Data Aggregation
(82 days)
BIO PLANT SYSTEM (IMPLANTS AND ABUTMENTS)
BioPlant Systems refer to sets of root form endosseous dental implants and compatible implant abutment systems. BioPlant Systems are designed for use in dental implant surgery and are intended to be used in a manor in which they (the implants) integrate with the bone (osseointegration). The BioPlant abutment systems include various abutments designed to enable the implant process from healing thru final restoration. Clinical studies have demonstrated that, when surgically implanted under controlled conditions, a successfully osseointegrated implant will achieve a firm and direct connection between the living bone and surface of the titanium implant. BioPlant implants are for single or two-stage surgical procedures. Bio Plant Systems are intended for immediate placement in partially or fully edentulous mandibles and maxillae (type I or II bone), in support of single or multiple-unit restorations including; cemented retained, screw retained, or over-denture restorations, and terminal or intermediate abutment support for fixed bridgework. Multiple tooth applications may be splinted with a bar.
The Bio Plant System includes a variety of types and sizes of precision-machined self-tapping root-form implants, abutments and accessory fixtures manufactured from biocompatible, commercially pure (CP) titanium or biocompatible, wrought titanium or gold alloy. The implants are available with hex-lock features and either smooth (bright) or textured (abrasive blasted) surface finish. Implants range in diameter from 3.3 mm to 6.0 mm and in length from 7 mm to 18 mm. The implants are intended to be surgically inserted into the upper and/or lower jawbone and serve as a substitute or replacement tooth while providing a stable and secure foundation for restorations. Drill sequences, arms and insertion instruments, as specified, are available.
The provided text describes the Cowell Medi BioPlant System, an endosseous dental implant system, and its acceptance criteria as defined for its 510(k) submission to the FDA. The submission relies heavily on demonstrating substantial equivalence to predicate devices and provides non-clinical testing data to support this claim, rather than new clinical trials.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for the Cowell Medi BioPlant System are primarily based on demonstrating substantial equivalence to existing legally marketed predicate devices (Nobel Biocare's Brånemark System and Implant Innovations, Inc. (3i) Dental Implant Systems). The performance criteria are therefore linked to matching or being functionally equivalent to these predicates across various attributes.
Attribute / Characteristic | Acceptance Criteria (as per Predicate Devices) | Reported Device Performance (COWELL MEDI BIOPLANT SYSTEM) |
---|---|---|
K-numbers | N/A (Comparison to specific K-numbers of predicates) | K041655 |
Proprietary Name | Brånemark System® / 3i Restorative Dental Implant Systems | BioPlant System |
CFR Section | 872.3640 | SAME |
Pro-code | DZE & NHA | SAME |
Classification Name | Endosseous Dental Implant and Abutment Device | SAME |
Indications for Use | Functionally equivalent to predicates (e.g., for single/two-stage procedures, cement/screw retained restorations, integration with bone, immediate placement in specific bone types, anchor for prosthetic devices). | "BioPlant Systems refer to sets of root form endosseous dental implants and compatible implant abutment systems. BioPlant Systems are designed for use in dental implant surgery and are intended to be used in a manor in which they (the implants) integrate with the bone (osseointegration). The BioPlant abutment systems include various abutments designed to enable the implant process from healing thru final restoration. Clinical studies have demonstrated that, when surgically implanted under controlled conditions, a successfully osseointegrated implant will achieve a firm and direct connection between the living bone and surface of the titanium implant. BioPlant implants are for single or two-stage surgical procedures. Bio Plant Systems are intended for immediate placement in partially or fully edentulous mandibles and maxillae (type I or II bone), in support of single or multiple-unit restorations including; cemented retained, screw retained, or over-denture restorations, and terminal or intermediate abutment support for fixed bridgework. Multiple tooth applications may be splinted with a bar." |
Design (Implants) | Threaded, self-tapping, external hex, root-form | SAME (Threaded, self tapping, external hex, root-form) |
Diameter (Implants) | Predicates: 3.3 - 5.0 mm (Nobel Biocare), 3.25 - 6.0 mm (3i) | 3.3 - 6.0 mm |
Length (Implants) | 7.0 - 18 mm | SAME (7.0 - 18 mm) |
Material (Implants) | Commercially pure (CP) titanium (Ti) | SAME (Commercially pure (CP) titanium (Ti)) |
Coating (Implants) | Non-coated and Coated (HA) | Non-coated |
Surface Finish | Machined or roughened / textured (via proprietary roughening method). Transmucosal part smooth machined finish. | Machined or roughened / textured (abrasive blasted). If roughened, the transmucosal part maintains a smooth machined finish to allow for the attachment of epithelial tissue. (Described as EQUIVALENT to predicates) |
Design (Abutments) | Equivalent, including angled and universal abutments. | Abutments (straight, no angle): healing, cemented and non-cemented / screw attached. Miniscone, Estheticone, temporary and UCLA type, with associated cylinder and coping screws. (Described as EQUIVALENT to predicates, though predicates also include angled and universal abutments). This implies similarity in core functionality but not necessarily exact replication of all predicate types. |
Materials (Abutments) | CP Ti, Ti alloy, gold alloy, (Nobel Biocare also Ceramic, 3i also Plastic) | CP Ti, Ti alloy, or gold alloy |
Materials (Screws) | CP Ti, Ti alloy, or gold alloy | SAME |
Color additives | No color additives used. | SAME |
Accessories available | EQUIVALENT to point, twist, tap, pilot, countersink, hand-driver, machine driver, mount driver. | point, twist, tap, pilot, countersink, hand-driver, machine driver, mount driver (Described as EQUIVALENT to predicates) |
Provided Sterile? | YES | YES |
Sterilization Method(s) | Various Methods | Irradiation, SAL 10-6 |
Packaging (Implants) | Glass ampul in peel-open blister pack (Nobel Biocare) / Heat sealed peel-open nylon pouch (3i) | Polymeric ampul in peel-open blister pack |
Packaging (Abutments) | EQUIVALENT to various methods | Various methods (Described as EQUIVALENT to predicates) |
Contraindications | Functionally equivalent to standard contraindications for dental implants (e.g., insufficient jawbone, poor bone quality, poor oral hygiene, heavy smoking/tobacco abuse, medical conditions like blood disorders/uncontrolled diabetes, general oral surgical procedure unfitness). | "Bio Plant System implants should not be placed in patients where the retaining jawbone is too diminished to provide adequate width or height to surround the implant. Failure to osseointegration or subsequent loss of osseointegration may occur in cases where there is insufficient available bone, poor bone quality, poor oral hygiene, heavy smoking or tobacco abuse, or medical conditions such as blood disorders or uncontrolled diabetes." Also lists possible and temporary contraindications, and anatomical/pathological contraindications. (Described as FUNCTIONALLY EQUIVALENT to predicates). |
Precautions/Warnings | Functionally equivalent to general precautions and warnings for dental implant procedures (e.g., proper technique, acknowledging contraindications, no modification of components, use only designated components, risk of failure/harm). | "Content of the precaution and warning sections for the (IFU) package insert generally refer to the need for practitioners to lean and employ proper technique, to appropriately acknowledge contraindications, not to modify any components or instrumentation, to utilized only components and instrumentation designated by the manufacturer and that failure to observe cautions and warnings could result in failure of the procedure and or harm to the patient." (Described as FUNCTIONALLY EQUIVALENT to predicates). |
Mechanical Fatigue | Similar testing performed and similar outcomes achieved by predicate devices (implied that devices withstand expected forces and cycles). | "Mechanical fatigue testing under shear force with a 25kg load, and static shear testing was performed to establish the mechanical properties of the BioPlant System and to confirm fixture/implant-abutment compatibility. ... Assembled implant-abutment samples were subjected to 5 million cycles (2-14 Hz) under shear forces with 25kg loads applied 30° off the center axis of the implant-abutment system. All samples survived. Assembled implant-abutment samples were also subjected to static shear testing to establish the yield point of the fixture and abutment fixed with a screw. All samples exhibited acceptable yield points and no fractures or crack occurred prior to yield." |
2. Sample Size Used for the Test Set and Data Provenance
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Test Set (Non-clinical): For the mechanical fatigue and static shear testing, the document states: "BioPlant System production unit implant-abutment system samples, considered physically representative of the design most prone to worst-case mechanical loading following implantation, were subjected to testing per part 5 of ISO 14801."
- The exact sample size (number of units tested) is not explicitly stated in the provided text, beyond "All samples survived" and "All samples exhibited acceptable yield points."
- Data Provenance: The document does not specify the country of origin for the non-clinical testing data directly. Given that the manufacturer is Cowell Medi Co., Ltd. from Busan, Korea, it's reasonable to infer the testing was likely conducted in Korea or by an accredited lab on behalf of the manufacturer. The testing adheres to ISO 14801, an international standard. The data is prospective in the sense that custom tests were performed on the BioPlant System samples to demonstrate performance against established standards.
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Test Set (Clinical): No new clinical test set was used for the BioPlant System itself. The submission explicitly states: "Cowell Medi perceives the adequacy of such existing documentation substantiates the exclusion of both animal and human clinical studies protocols or data." Instead, they rely on "Abundant, significant, peer reviewed documentation supporting the successful clinical performance of root-form endosseous dental implants and abutment systems exists." This refers to retrospective evidence from the wider body of literature and the predicate devices.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- Non-clinical Testing: For the mechanical and static shear testing, ground truth is established by objective engineering standards (ISO 14801) and the physical properties of the materials and design, not by expert consensus. There are no "experts" establishing unique ground truth in this context; rather, the tests measure objective performance metrics.
- Clinical Ground Truth: No new clinical ground truth was established by experts for the BioPlant System specifically. The submission relies on existing "peer-reviewed documentation" and the clinical history of the predicate devices. The "ground truth" for clinical performance, in this case, is derived from the established safety and effectiveness of similar devices in the medical literature.
4. Adjudication Method for the Test Set
- Non-clinical Testing: Not applicable. The mechanical and static shear tests have objective pass/fail criteria (e.g., survival after 5 million cycles, acceptable yield points, no fractures prior to yield). There's no human adjudication of ambiguous results.
- Clinical Testing: Not applicable, as no new clinical studies were 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. The document describes a dental implant system, not a diagnostic AI device requiring multi-reader, multi-case studies or assessment of human reader improvement with AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was Done
- Not applicable. The device is a physical medical device (dental implants and abutments), not an algorithm or AI system.
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
- Non-clinical: Objective physical and mechanical standards (ISO 14801), laboratory measurements of fatigue resistance and yield strength.
- Clinical: The clinical ground truth for showing "successful osseointegration" and "firm and direct connection between the living bone and surface of the titanium implant" is based on the general body of "Abundant, significant, peer reviewed documentation" for root-form endosseous dental implants. This implies reliance on historical outcomes data and expert consensus within the dental community regarding the performance of similar, established devices.
8. The Sample Size for the Training Set
- Not applicable. This is not an AI or machine learning device requiring a training set. The device design and manufacturing processes are likely informed by years of engineering knowledge and clinical experience with dental implants, rather than a quantifiable training dataset in the AI sense.
9. How the Ground Truth for the Training Set was Established
- Not applicable. As stated above, this is not an AI device.
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