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510(k) Data Aggregation

    K Number
    K113146
    Device Name
    PCXX VARNISH
    Date Cleared
    2012-01-23

    (91 days)

    Product Code
    Regulation Number
    872.3260
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    PCXX VARNISH

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use
    • Treatment of hypersensitive teeth
    • Use on exposed dentin and root sensitivity
    • Under temporary restoratives and cements where post-operative sensitivity is of concern.
    Device Description

    PCxx Varnish is 5% Sodium Fluoride Varnish that reduces tooth sensitivity by forming a film when topically applied to enamel and dentin surfaces. The properties, intended use and composition are equivalent to the predicated devices and other current varnishes which are rosin based insoluble mixtures that form a film when applied to tooth surfaces. PCxx Varnish used the same rosin (colophony) and rosin derivatives that are used in predicate devices which include but are not limited to Duraflor, Duraphat and Fluorilaq. The product comes in a single unit dose package containing the varnish and separate applicator brush.

    AI/ML Overview

    The provided 510(k) summary for the PCXX Fluoride Varnish does not contain the information requested in points 1-9 regarding specific acceptance criteria and a study demonstrating the device meets those criteria.

    This 510(k) submission is for a medical device that is a cavity varnish, specifically a 5% Sodium Fluoride Varnish. The basis for substantial equivalence is the technological characteristics and composition being identical to predicate devices. It relies on the assertion that "There are no performance standards established for this product in an ethanol solution. There are no performance specifications to assess how it to be substantially equivalent, performance will be the same."

    Therefore, I cannot populate the table or answer the specific questions about acceptance criteria and a study, as this information is not present in the provided text.

    Here's a breakdown of what is stated, which indirectly addresses some points by explaining why the typical study information is absent in this type of submission:

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

    • Not provided. The submission explicitly states: "There are no performance standards established for this product... There are no performance specifications to assess how it to be substantially equivalent, performance will be the same." This indicates that the regulatory body does not require specific numerical performance criteria or a comparative performance study for this type of device to demonstrate substantial equivalence, as long as its composition and intended use are identical to established predicates.

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

    • Not applicable / Not provided. No test set or performance study data is presented.

    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 / Not provided. No ground truth establishment is described for a performance study.

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

    • Not applicable / Not provided. No test set or adjudication process is described.

    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. This device is a topical varnish, not an AI-assisted diagnostic or imaging device. Therefore, no MRMC study would be relevant or conducted.

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

    • Not applicable. This is a physical medical device (varnish), not an algorithm.

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

    • Not applicable / Not provided. No ground truth for device performance is mentioned as the submission relies on equivalency of composition and manufacturing.

    8. The sample size for the training set

    • Not applicable / Not provided. No training set for an algorithm is relevant here.

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

    • Not applicable / Not provided.

    Summary of the 510(k) Claim:

    The 510(k) submission for PCXX Varnish establishes substantial equivalence based on the following:

    • Identical Composition: "PCxx Varnish used the same rosin (colophony) and rosin derivatives that are used... include but are not limited to Duraflor, Duraphat and Fluorilaq."
    • Identical Intended Use: "PCxx Varnish is 5% Sodium Fluoride Varnish that reduces tooth sensitivity by forming a film when topically applied to enamel and dentin surfaces." This is presented as equivalent to predicate devices.
    • No Established Performance Standards: The key argument for not needing a performance study is the absence of specific performance standards for this type of product. The assumption is that if the composition and intended use are the same, the performance will also be the same.
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