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510(k) Data Aggregation
(308 days)
BTI Extra-Short Dental Implant System UnicCa
The BTI Dental Implant System UnicCa® for oral implant surgery is to be used for the partial or total replacement of teeth in edentulate patients. Once attached to the bone, the implants act as an anchor for various fixed or removable prosthetic solutions that can be used to improve or restore a patient's mastication function.
In the case of 5.5 - 6.5mm long UnicCa® implants: These implants should be used in a two-stage surgical procedure. These implants are indicated for delayed loading. These implants are indicated only for straight abutments and to support permanently fixed restorations.
In the case of Tiny® 3.0 UnicCa® implants: These implants shall be used only to replace maxillary lateral incisors and mandibular lateral and central incisors. Immediate loading is recommended when there is good primary stability and an appropriate occlusal load.
The BTI Dental Implant System UnicCa® is a self-tapping, threaded, root form dental titanium implant provided with two types of connections; external (i.e., Externa®) and internal (i.e., Interna®), in a variety of platforms and range of diameters (3.0 - 6.0 mm) and lengths (5.5 - 18.0 mm). BTI Dental Implant System UnicCa® features an implant surface treatment that improves the hydrophilicity of the implant.
The purpose of this 510(k) is to allow B.T.I. Biotechnology Institute, S.L. to expand the product offering for the Universal and Universal Plus Interna® implant platforms. Specifically, the currently cleared Universal Interna® implants with diameters ranging from 4.0 to 4.25 mm and the 6.0 mm diameter Universal Plus Interna® implants will be provided in shorter lengths of 5.5 and 6.5 mm. The implants subject of this premarket notification, collectively referred to as BTI Extra-Short Dental Implant System UnicCa®, are summarized in Table 5-1.
This document is a 510(k) Premarket Notification from the FDA, determining substantial equivalence for a dental implant system. As such, it does not contain information about a study that proves the device meets specific acceptance criteria in the manner of a clinical trial for a novel device or software. Instead, it demonstrates substantial equivalence to predicate devices through non-clinical testing and comparison of characteristics.
Therefore, many of your requested points related to acceptance criteria for a study proving performance, sample sizes for test/training sets, expert adjudication, or MRMC studies, are not applicable here. This document leverages existing predicate devices and non-clinical testing to argue that the new, shorter versions of the implant are safe and effective.
Here's a breakdown of the information that is available or implicitly addressed, and what is not applicable based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
This 510(k) submission doesn't present a table of acceptance criteria and performance results in the context of a "study proving the device meets criteria" as one might expect for a new AI or diagnostic device. Instead, it relies on demonstrating substantial equivalence to existing predicate devices (K151391 as primary, K133049 and K170392 as reference devices) through a comparison of technological characteristics and non-clinical testing.
The "acceptance criteria" here are implicitly that the new device configuration (shorter lengths of existing implants) should be as safe and effective as the predicate devices, as demonstrated by:
- Identical Indications for Use
- Identical Operating Principle
- Identical Materials
- Identical Surface Treatment
- Identical Shelf Life
- Identical Packaging and Sterilization materials and processes
- Compliance with relevant ISO standards and FDA guidance for non-clinical testing.
The "reported device performance" is not expressed in measured outcomes against specific clinical performance thresholds, but rather in the statement of "substantial equivalence" based on the comparisons provided.
Relevant Data from Tables 5-3 and 5-4, representing the "performance" by demonstrating similarity to predicates:
Characteristic | Subject Device (BTI Extra-Short Dental Implant System UnicCa®) | Primary Predicate (K151391, BTI Dental Implant System UnicCa®) | Substantial Equivalence Discussion / Performance Implication |
---|---|---|---|
Product Classification | Class II, 21 CFR 872.3640, Product Code DZE | Class II, 21 CFR 872.3640, Product Code DZE | Identical. Implies similar regulatory oversight and general safety/effectiveness expectations. |
Indications for Use | Same as predicate, with specific instructions for 5.5-6.5mm UnicCa® implants (two-stage, delayed loading, straight abutments, fixed restorations) and Tiny® 3.0 UnicCa® implants (maxillary lateral incisors & mandibular lateral/central incisors, immediate loading with good primary stability). | Same as subject device. | Identical. This is a primary driver for substantial equivalence, implying the device performs the same function under the same clinical conditions. |
Implant Design/Geometry | Threaded, root form | Threaded, root form | Identical. Implies similar mechanical integration with bone. |
Material | Commercially pure titanium grade 4 | Commercially pure titanium grade 4 | Identical. Implies similar biocompatibility and mechanical properties. |
Abutment Compatibility/Connection | Internal (Interna) | Internal (Interna) and External (Externa) | Identical for the Interna connection. The subject device is an expansion of the Interna platform, maintaining compatibility. External connection is not part of this submission. |
Dimensions (mm) | Interna: Diameter: 4.0 to 6.0, Lengths: 5.5 and 6.5 (New shorter lengths for specific platforms) | Interna: Diameter: 3.3 to 6.0, Lengths: 5.5 to 18.0 | Similar. The new diameters and lengths are already encompassed in the primary predicate's overall range or are explicitly being added as shorter versions of existing platforms, evaluated for safety (e.g., fatigue). |
Roughness | Neck: Sq = 0.7 ± 0.1 µm; Sdr = 50 ± 10%. Thread: Sq ≥ 1.2 µm; Sdr ≥ 200%. Valleys: Sq = 1.0 ± 0.2 µm; Sdr = 85 ± 15%. | Neck: Sq = 0.7 ± 0.1 µm; Sdr = 50 ± 10%. Thread: Sq ≥ 1.2 µm; Sdr ≥ 200%. Valleys: Sq = 1.0 ± 0.2 µm; Sdr = 85 ± 15%. | Identical. Implies similar osseointegration characteristics. |
Mechanical properties (Material) | In compliance with ISO 5832-2 and ASTM F67 | In compliance with ISO 5832-2 and ASTM F67 | Identical. Ensures material strength and biocompatibility compliance. |
Mechanical properties (Fatigue) | Evaluated according to ISO 14801. Analysis showed subject device did not represent a new worst case. | Evaluated under ISO 14801. | Identical evaluation method. The critical point is that the shorter implant configurations were not determined to be a new worst-case in fatigue, implying they maintain acceptable mechanical performance. |
Hydrophilicity | Calcium surface treatment | Calcium surface treatment | Identical. Implies similar biological response and osseointegration. |
Sterile/Sterilization/SAL/Packaging/Shelf-Life | Yes, Gamma radiation, 1 x 10-6, vial with clamp, 5 years. | Yes, Gamma Radiation, 1 x 10-6, vial with clamp, 5 years. | Identical. Ensures continued sterility and product integrity over shelf life. |
Biocompatibility | Conformance with ISO 10993-1:2018 and FDA guidance. All biological endpoints for a long-term implant addressed with satisfactory results. | (Leveraged from K151391) - not explicitly itemized in table, but stated in Section VII. | Demonstrated through compliance. Indicates the device is biologically safe for its intended long-term use. |
Comparative Area Analyses | Performed for full external area and for bone resorption of 3 mm, and immediate bone to implant contact per surgical protocol. Results showed subject device is substantially equivalent. | (Referenced implicitly from predicate's established performance) | Confirms that the geometric changes (shorter length) do not negatively impact critical biological interactions like bone contact and resorption behavior compared to the predicate/reference devices. |
2. Sample size used for the test set and the data provenance
- Sample Size for Test Set: Not applicable in the context of a clinical test set with patient data. The "tests" are non-clinical (biocompatibility, corrosion, fatigue, comparative area analyses, sterilization, packaging, endotoxin). The sample sizes for these engineering bench tests are not specified in the summary document.
- Data Provenance (e.g., country of origin of the data, retrospective or prospective): Not applicable, as no clinical data or patient data is mentioned or used for proving substantial equivalence of these specific design changes. The data provenance would be from the B.T.I. Biotechnology Institute, S.L. in Spain (the submitter) for the non-clinical testing performed.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable. This submission relies on non-clinical engineering and biological testing, not on human expert review of clinical cases to establish ground truth for a test set. Substantial equivalence is determined by the FDA reviewing the provided engineering, material, and performance data against established predicate devices and standards.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. No expert adjudication of a test set occurred.
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
- No. This is a dental implant (physical device), not an AI or diagnostic imaging device. Therefore, no MRMC study was conducted.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not applicable. This is a physical dental implant, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- Not applicable in the sense of clinical ground truth. For a physical device like a dental implant seeking substantial equivalence for a dimension change, the "ground truth" for the non-clinical testing performed (biocompatibility, fatigue, etc.) is the adherence to material specifications (e.g., Titanium CP4), compliance with established international standards (ISO 10993-1, ISO 14801, ISO 11137-1/2, ISO 17665-1/2, ANSI/AAMI ST72), and the established safety and performance profile of the predicate device.
8. The sample size for the training set
- Not applicable. There is no "training set" in the context of this 510(k) submission for a physical device.
9. How the ground truth for the training set was established
- Not applicable. There is no "training set" in the context of this 510(k) submission for a physical device.
In summary, this FDA 510(k) clearance is based on demonstrating substantial equivalence of new, shorter versions of an existing dental implant system to established predicate devices through a comprehensive battery of non-clinical (bench) testing and comparison of physical and material characteristics, rather than through new clinical trials or performance studies against specific acceptance criteria for a novel device or software.
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