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510(k) Data Aggregation
(50 days)
Irritrol, EDS Combo-Rinse
Irritrol™ is intended to cleanse and disinfect root canal systems after endodontic instrumentation.
Irritrol™ is an aqueous solution for use during the irrigation phase of endodontic root canal preparation procedures. This multi-purpose device disinfects the root canal, flushes out any loosened debris, and removes the smear layer produced from root canal instrumentation.
The provided text describes the submission for a medical device (Irritrol™) to the FDA for a 510(k) premarket notification. This type of submission aims to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving novel effectiveness through clinical trials. As such, the information you're requesting regarding acceptance criteria and a study proving a device meets those criteria, particularly in the context of an AI device with specific performance metrics, is not directly applicable to this document.
However, I can extract the information that is present and frame it in a way that aligns with your request where possible, while clearly indicating when specific aspects (like AI performance metrics or human reader studies) are not pertinent to this traditional medical device submission.
Here's an analysis based on the provided text:
Device: Irritrol™ (Root Canal Cleanser)
Purpose of Submission: Demonstrate substantial equivalence to a predicate device (QMix™ 2in1 Endodontic Irrigating Solution) for regulatory clearance, not to prove meeting specific performance criteria for an AI algorithm.
1. Table of Acceptance Criteria and Reported Device Performance
For this type of device (a chemical solution), "acceptance criteria" and "device performance" are typically related to its physical properties, biocompatibility, and intended functions (antimicrobial activity, smear layer removal) compared to its predicate. There isn't a direct "acceptance criteria" in the sense of accuracy, sensitivity, or specificity as one would find for an AI diagnostic tool.
Acceptance Criteria (Implied from Predicate Comparison & Testing) | Reported Device Performance (Irritrol™) |
---|---|
Safety: Biocompatibility | Demonstrates equivalence in safety to the predicate device per ISO 10993 (results of five biocompatibility tests). |
Efficacy (Antimicrobial): Ability to suppress Enterococcus faecalis growth | Demonstrates equivalence in ability to suppress Enterococcus faecalis growth compared to predicate (comparative in vitro antimicrobial testing). |
Efficacy (Smear Layer Removal): Ability to remove smear layer from instrumented root canals | Demonstrates equivalence in ability to remove smear layer from instrumented root canals compared to predicate (comparative smear layer removal testing). |
Physical Properties: | Clear, green, odorless liquid solution |
- pH | Slightly basic solution |
- Shelf Life | 2 years |
Intended Use: Cleanses and disinfects root canal systems | Intended to cleanse and disinfect root canal systems after endodontic instrumentation (identical to predicate). |
2. Sample Size Used for the Test Set and Data Provenance
This information is not directly provided in the submission summary. The non-clinical tests were "in vitro," meaning conducted in a lab setting, not on human patients. Therefore, terms like "test set" in the context of patient data or data provenance (country of origin, retrospective/prospective) are not applicable.
- Sample Size: Not specified for the in vitro tests (e.g., number of bacterial cultures, number of teeth/root canals tested).
- Data Provenance: Not applicable as these were laboratory tests (in vitro), not human data.
3. Number of Experts Used to Establish Ground Truth and Qualifications
This is not applicable to the submitted document. Ground truth for an AI device involves expert consensus on medical images or clinical outcomes. For this chemical solution, "ground truth" relates to the objective outcomes of the in vitro tests (e.g., bacterial growth measurements, microscopic evaluation of smear layer removal), which are typically determined by laboratory methods and instrumentation, not expert human interpretation in the sense of diagnostic imaging.
4. Adjudication Method
Not applicable. Adjudication methods (e.g., 2+1, 3+1) are used for resolving discrepancies among human experts in establishing ground truth for diagnostic decisions, which is not relevant for this device.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done
No. An MRMC study is designed for AI-assisted diagnostic devices to assess how the AI impacts human reader performance. This device is a chemical solution used in a procedure, not a diagnostic tool read by humans.
6. If a Standalone (Algorithm Only) Performance Study Was Done
Again, this is not applicable. This device is not an algorithm. The performance studies mentioned (biocompatibility, antimicrobial, smear layer removal) assess the chemical properties and effects of the solution itself, not an algorithm.
7. The Type of Ground Truth Used
The "ground truth" for the non-clinical tests would have been established through:
- Biocompatibility: Standardized toxicological endpoints as per ISO 10993 (e.g., cell viability, irritation indices).
- Antimicrobial testing: Direct measurement of bacterial growth/inhibition (e.g., colony counts, zones of inhibition).
- Smear layer removal testing: Likely microscopic evaluation (e.g., SEM) of instrumented root canal walls to assess the presence or absence of smear layer.
This is objective, laboratory-based measurement, not expert consensus on diagnostic images or clinical outcomes.
8. The Sample Size for the Training Set
Not applicable. This device does not involve an AI algorithm, and therefore there is no "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no AI algorithm or training set for this device.
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(113 days)
EDS COMBO-RINSE
EDS Combo-Rinse is intended to cleanse root canal systems by irrigating root canals.
EDS Combo-Rinse is an aqueous solution for use during the irrigation phase of endodontic root canal preparation procedures. The device has a dual purpose of flushing out any loosened debris and removing the smear layer produced from root canal instrumentation.
The provided text describes a 510(k) summary for the EDS Combo-Rinse device, which is an aqueous solution for use during root canal preparation. The submission focuses on demonstrating substantial equivalence to a predicate device (QMix™ 2in1 Endodontic Irrigating Solution). Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are framed in terms of equivalence to the predicate device, rather than independent performance metrics defined specifically for EDS Combo-Rinse.
Here's the breakdown of the information based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (based on predicate device equivalence) | Reported Device Performance (for EDS Combo-Rinse) |
---|---|
Biocompatibility equivalent to predicate device (QMix™ 2in1 Endodontic Irrigating Solution) | Demonstrated equivalence to the predicate device in five biocompatibility tests according to ISO 10993. |
Smear layer removal performance equivalent to predicate device (QMix™ 2in1 Endodontic Irrigating Solution) | Demonstrated equivalence to the predicate device in smear layer removal performance. |
Safety equivalent to legally marketed devices containing the same components | Prior use of components in legally marketed devices (including predicate devices with common components) supports safety. |
Effectiveness equivalent to legally marketed devices containing the same components | Prior use of components in legally marketed devices (including predicate devices with common components) supports effectiveness. |
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state sample sizes for the biocompatibility or smear layer removal testing.
Regarding data provenance:
- The tests were conducted to determine equivalence to the predicate device.
- The document implies these were non-clinical tests.
- Country of origin is not specified but is assumed to be part of the manufacturer's testing process.
- The studies were retrospective in the sense that they compared the new device to existing predicate devices, but the testing itself would have been prospective for the EDS Combo-Rinse samples.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. The "ground truth" here is the established safety and performance profile of the predicate device and the accepted standards (ISO 10993). There is no mention of human experts establishing ground truth for a test set in the context of device performance. The assessment is based on laboratory test results against established benchmarks.
4. Adjudication Method for the Test Set
Not applicable. There was no explicit adjudication method for a test set described, as the evaluation was based on objective, standardized tests (biocompatibility according to ISO 10993, and smear layer removal testing).
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. This type of study is not relevant for a root canal irrigating solution and was not performed. The device is a physical/chemical irrigant, not an imaging or diagnostic AI tool.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Yes, in a sense. The biocompatibility and smear layer removal tests are standalone evaluations of the device's physical and chemical properties and performance, without human intervention in the device's function during testing. This is a "device only" performance assessment.
7. The Type of Ground Truth Used
The ground truth used for comparison was:
- Established performance of the predicate device: QMix™ 2in1 Endodontic Irrigating Solution, particularly its biocompatibility and smear layer removal capabilities.
- International standards: ISO 10993 for biocompatibility testing.
- Regulatory precedence: The fact that components have been "used in legally marketed devices and were found safe for dental use."
8. The Sample Size for the Training Set
Not applicable. This device is not an AI/ML algorithm that requires a training set. The term "training set" is not relevant to this type of device submission.
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set for this device.
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