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510(k) Data Aggregation

    K Number
    K223454
    Date Cleared
    2023-04-17

    (152 days)

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

    Custom-made Invisible Aligners

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

    The Custom-made Invisible Aligners is indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e., all second molars). The Custom-made Invisible Aligner positions teeth by way of continuous gentle force.

    Device Description

    The Custom-made Invisible Aligners System is a series of dental aligners that fabricated of clear, thin thermoformed plastic to progressively reposition the teeth. The product is made from a composite multilayer material with thermoplastic polyurethane and polyethylene terephthalate-1, 4-cyclohexanedimethanol ester (TPU+PETG). Corrective force to reposition the teeth is delivered via minor changes into a position in each subsequent aligner. They are designed to move the teeth to the target position and deliver desired clinical effect.

    AI/ML Overview

    The provided text is a 510(k) summary for a medical device called "Custom-made Invisible Aligners." This document describes the device, its intended use, comparison to predicate devices, and the non-clinical testing performed to establish substantial equivalence.

    However, the 510(k) summary explicitly states:
    "H. Clinical Test Conclusion: No clinical study is included in this submission."

    Therefore, based on the provided text, there is no information available regarding acceptance criteria based on clinical performance, nor any study proving the device meets such criteria through human clinical data. The document focuses solely on non-clinical testing to demonstrate performance and safety.

    Even though the request asks for specific details about the study that proves the device meets the acceptance criteria, the provided document does not contain this information because no clinical studies were performed or included in the submission.

    To directly address the request while accurately reflecting the content of the document:

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

    Based on the non-clinical testing described, the acceptance criteria relate to material properties, manufacturing accuracy, and biocompatibility.

    Acceptance Criteria CategorySpecific Test/PropertyAcceptance Criteria (Implied/Directly Stated)Reported Device Performance
    Performance TestingThickness, appearance, odor, density, water absorption, dissolution, color stability, tear resistance, Tensile modulus of elasticityCompliance with pertinent standards and specifications, expectations of the dental community, and product labelingDevice is in compliance and demonstrates effectiveness. Results showed conformity with pre-established specifications and acceptance criteria.
    Manufacturing Accuracy3D molding and aligner molding accuracyMeet pre-established specificationsChecked for aligners from 12 different patient cases (beginning, middle, end of sequence); met pre-established specifications.
    Suitability, function, and form of the alignerComplied with pre-established specifications and acceptance criteria when compared to treatment design in software.Results complied with pre-established specifications and acceptance criteria.
    Shelf LifePerformance after accelerated aging (3 years shelf life)Conformity with pre-established specifications and acceptance criteriaTest results after 81 days of accelerated aging (at 60°C) showed conformity.
    BiocompatibilityCytotoxicityNon-toxicMet requirements of study protocols; considered non-toxic.
    IrritationNot an intracutaneous irritantMet requirements of study protocols; considered not an intracutaneous irritant.
    SensitizationNon-sensitizingMet requirements of study protocols; considered non-sensitizing.
    Sub chronic systemic toxicityMet requirements of study protocols (implies no significant toxicity)Met requirements of study protocols.
    GenotoxicityMet requirements of study protocols (implies no genotoxic effects)Met requirements of study protocols.
    Software V&VFunctionality, safety, effectivenessDevice is as safe and effective as the predicatesDocumentation provided as recommended by FDA guidance; "moderate" level of concern.

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

    • Sample Size: For manufacturing accuracy validation, aligners from "12 different patient case" were evaluated. No other specific sample sizes are mentioned for the general performance or biocompatibility testing (e.g., number of material samples for tensile strength).
    • Data Provenance: Not explicitly stated, but the applicant (Zhejiang Yinchili Medical Technology Co., Ltd.) is based in China, suggesting the testing was likely conducted in China or by labs contracted by a Chinese company.
    • Retrospective/Prospective: Not applicable, as these were non-clinical bench and lab tests, not clinical studies involving patients.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • Not applicable. The "ground truth" for non-clinical tests is established by adherence to recognized standards (e.g., ISO 10993) and pre-established specifications, not by expert consensus on clinical findings.

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

    • Not applicable. Adjudication methods like 2+1 are used in clinical studies for interpretation of results, especially imaging. This document describes non-clinical testing.

    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. The document explicitly states, "No clinical study is included in this submission." This device is a physical medical device (aligners), not an AI-based diagnostic or assistive software.

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

    • No. This section is generally relevant for AI/ML devices. The device described is a physical aligner. While there is software for ordering/processing, its V&V focused on its function in facilitating the device, not its standalone diagnostic performance.

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

    • For material performance and manufacturing accuracy: Ground truth was established by pre-established specifications, engineering principles, and compliance with recognized standards (e.g., ISO for biocompatibility).
    • For biocompatibility: Ground truth was based on the results of specific biological tests (cytotoxicity, irritation, sensitization, sub chronic systemic toxicity, genotoxicity) interpreted against the requirements of ISO 10993.

    8. The sample size for the training set:

    • Not applicable. This device is a physical product, not an AI/ML algorithm that requires a training set of data.

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

    • Not applicable (see point 8).
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    K Number
    K203624
    Date Cleared
    2022-06-16

    (552 days)

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

    Custom-made Invisible Aligners

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

    The Custom-made Invisible Aligners is indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e., all second molars). The Custom-made Invisible Aligner positions teeth by way of continuous gentle force.

    Device Description

    The Custom-made Invisible Aligners System is a series of dental aligners that are fabricated of clear, thin thermoformed Polyethylene terephthalate (PETG) plastic to progressively reposition the teeth. Corrective force to reposition the teeth is delivered via minor changes into a position in each subsequent aligner.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for a medical device, the "Custom-made Invisible Aligners." This type of submission aims to demonstrate that a new device is substantially equivalent to a legally marketed predicate device. For this submission, the manufacturer primarily relies on non-clinical performance testing and biocompatibility testing, rather than clinical studies or AI algorithm performance studies. Therefore, many of the requested items related to AI and human reader studies are not applicable.

    Here's an analysis based on the provided document:

    Acceptance Criteria and Reported Device Performance

    1. Table of acceptance criteria and the reported device performance:

    Test ItemTest Standard/MethodAcceptance CriteriaResult
    ThicknessInternal standard≤1.2mmPass
    Appearance"ZMT-FD-SS-052"No crack or bubbling; No defectsPass
    OdorInternal standardOdorlessPass
    DensityASTM D792-2013≤2.6g/cm³Pass
    Water absorptionISO20795.1-2013≤32 μg/mm³Pass
    DissolutionISO20795.1-2013≤1.6 μg/mm³Pass
    Color stabilityISO20795.1-2013No changePass
    Tear resistanceISO6383.1-2015>200N/cmPass
    Wear resistanceISO9352-2012
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