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510(k) Data Aggregation

    K Number
    K192839
    Date Cleared
    2021-02-11

    (504 days)

    Product Code
    Regulation Number
    872.3640
    Why did this record match?
    Device Name :

    DSP Implant System

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

    The DSP Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.

    Device Description

    DSP Implant System is composed of the External Hex (HE) implant line is composed of implants and related prosthetic components available in multiple designs. DSP implants are made of commercially pure titanium (ASTM F67). DSP prosthetic components are made of commercially pure titanium or cobalt-molybdenum alloy (ASTM F1537). DSP implant system screws (abutment and prosthetic screws) are made of titanium alloy (ASTM F136). The HE implant line is named after the External Hex implant-to-abutment interface. It is subdivided in External Hex SLIM (HE SLIM), External Hex BIOFIT), External Hex SOULFIT (HE SOULFIT), External Hex PROPFIT (HE PROPFIT) and External Hex WAYFIT). The HE implants are bone-level implants. The subject device abutments components mate exclusively with the subject implants of the same line.

    AI/ML Overview

    This is a 510(k) summary for the DSP Implant System, a dental implant device. It establishes substantial equivalence to various predicate devices rather than providing performance data against specific acceptance criteria for the new device. Therefore, it does not present a typical study design with acceptance criteria and results in the way a clinical trial or device performance study would.

    However, based on the provided text, we can infer the approach taken by the manufacturer to demonstrate substantial equivalence, which serves as their "proof" that the device meets regulatory requirements.

    Here's an interpretation of the requested information based on the 510(k) summary:

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

    Since this is a 510(k) submission focusing on substantial equivalence, there isn't a table of discrete acceptance criteria and reported device performance in terms of clinical outcomes or specific quantitative measures as one might find in a standalone performance study. Instead, the "acceptance criteria" are implied by the characteristics of the legally marketed predicate devices, and the "reported device performance" is the demonstration that the subject device shares these characteristics or has equivalent performance as validated through non-clinical testing.

    The acceptance is based on demonstrating that the DSP Implant System is substantially equivalent to the predicate devices in terms of:

    • Intended Use: The indications for use statement of the subject device is equivalent to the primary predicate device K101207, and within the scope of reference devices.
    • Technological Characteristics: The subject device's design features, materials (CPTi Gr4, CoCr, POM, Ti6Al4V-ELI), sterilization methods (irradiation), and surface treatments (grit-blasted and acid-etched, machined collar) are compared to the predicate and reference devices. Minor differences are justified as not raising new questions of safety or effectiveness.
    • Performance: Non-clinical testing demonstrates that the device performs comparably to the predicate devices in relevant areas for dental implants.

    Implicit Acceptance Criteria and Reported Device Performance (based on substantial equivalence justification):

    Acceptance Criteria (Implied from Predicate Device Characteristics)Reported Device Performance (DSP Implant System's Characteristics & Non-Clinical Testing)
    Intended Use: Support prosthetic devices (artificial teeth) to restore chewing function; single-stage or two-stage procedures; single/multiple unit restorations; immediate loading with good primary stability and appropriate occlusal loading.Equivalent: "The DSP Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices, such as artificial teeth, to restore chewing function. It may be used with single stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading." (Matches K101207, with one phrase "multiple tooth application may be rigidly splinted" removed as it's a technique choice).
    Implant-to-Abutment Connection: e.g., External Hex (HE).Equivalent: HE connection for all subject implants (HE SLIM, HE BIOFIT, HE SOULFIT, HE WAYFIT, HE PROPFIT) and abutment components (CoCr Base UCLA, CoCr UCLA, Titanium Abutments, Mini Conical Abutments, Anatomical Abutments, O'ring Abutment, Temporary Coping, CoCr Base Coping, One Step Hybrid Coping).
    Raw Materials: Commercially Pure Titanium (CPTi Gr4), Titanium alloys (ASTM F136), Cobalt-Chromium alloys, Polyoxymethylene (POM).Equivalent: Implants are CPTi Gr4. Prosthetic components use CPTi Gr4, CoCr alloy, CoCr/POM, and Ti alloy (ASTM F136). These match or are comparable to predicate/reference device materials.
    Surface Treatment: Grit-blasted and acid-etched (and/or machined collar).Equivalent: Implants are treated. Grit-blasted and acid-etched. Machined collars are specified (e.g., h 1.0 mm for HE SLIM, h 0.3 mm for HE BIOFIT). EDS analysis confirmed no contaminating metal particles.
    Sterilization: Sterile by irradiation (or ethylene oxide for predicates).Equivalent/Validated: Provided sterile by irradiation. Sterilization validated according to ISO 11137-1, ISO 17665-1, ISO 17665-2. Sterile barrier shelf life testing (ASTM F1980), package integrity (ASTM F1929, ASTM F88/F88M), sterility of content (ISO 11737-2).
    Biocompatibility: Materials are biocompatible.Validated: Biocompatibility of materials supported by testing according to ISO 10993-5 (likely ISO 10993-1 as well, given the guidance document reference).
    Pyrogenicity: Device is non-pyrogenic.Validated: Pyrogenicity monitoring according to AAMI/ANSI ST72. Bacterial Endotoxin Test (BET) performed according to USP using photometric technique. Representative samples selected for testing.
    Dimensions/Geometry: Range of diameters and lengths for implants and abutments.Equivalent: Tables 5.2-5.17 detail the diameter and length ranges for various implants and abutments, comparing them to predicate/reference devices. The text explicitly states that the subject implants and abutments are "substantially equivalent" to predicate/reference devices in design and range of dimensions, with specific predicate/reference devices covering particular dimensions or features. For example, K101207 covers 17mm length for HE SLIM, while K170398 covers other dimensions and body geometrical features.
    Functional Equivalence: e.g., Screw-retained, Cement-retained, Overdenture prosthesis attachment; Single-unit, Multi-unit restoration.Equivalent: All subject implants and abutments support screw-retained, cement-retained, and/or overdenture prosthesis attachment, and single-unit or multi-unit restorations, consistent with the predicate devices.

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

    • Sample Size for Test Set: Not applicable for a typical clinical or performance study as presented in this 510(k). The "testing" referred to is non-clinical bench testing (sterilization, biocompatibility, pyrogenicity, material analysis). These tests typically use a representative sample size specified by the relevant standard (e.g., a certain number of devices for sterility testing). The document does not specify these individual sample sizes.
    • Data Provenance: The data is non-clinical (bench testing) and generated by the manufacturer to support device characteristics. The 510(k) is submitted by a Brazilian manufacturer (D.S.P. Industrial Eireli) and prepared by a Brazilian regulatory affairs specialist (PR Servicos Regulatorios Administrarivos Ltda). The location of the actual testing labs is not specified. The studies are not clinical, so concepts like "retrospective" or "prospective" do not apply.

    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. This is a non-clinical submission. Ground truth, in the sense of expert opinion on clinical data, is not established. The "ground truth" for the non-clinical tests is established by the specifications of the referenced international and national standards (ISO, ASTM, USP, AAMI/ANSI).

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

    • Not applicable. Adjudication methods are typically for evaluation of conflicting expert opinions or clinical outcomes, which is not the nature of this non-clinical submission.

    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 submission for a dental implant system (hardware), not an AI/software device. An MRMC study is not relevant.

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

    • No. This is a physical medical device. Not an algorithm.

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

    • For the non-clinical performance data, the "ground truth" is defined by the requirements and test methodologies of the referenced industry standards (e.g., ISO 11137 for sterilization, ISO 10993-5 for biocompatibility, AAMI/ANSI ST72 and USP for pyrogenicity, SEM/EDS for material analysis). The demonstration is that the device conforms to these standards and shares equivalent characteristics with legally marketed predicate devices.

    8. The sample size for the training set

    • Not applicable. This is a physical medical device, not an AI/software device that requires a training set.

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

    • Not applicable, as there is no training set for this type of device.
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