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510(k) Data Aggregation

    K Number
    K201859
    Date Cleared
    2020-09-11

    (67 days)

    Product Code
    Regulation Number
    872.3930
    Panel
    Dental
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Porcine Mineral Collagen Composite Moldable is indicated for:

    • · Augmentation or reconstructive treatment of alveolar ridge
    • · Filling of infrabony periodontal defects
    • · Filling of defects after root resection, apicoectomy, and cystectomy
    • · Filling of extraction sockets to enhance preservation of the alveolar ridge
    • · Elevation of maxillary sinus floor
    • · Filling of periodontal defects in conjuncts intended for Guided Tissue Regeneration (GTR) and Guided Bone Regeneration (GBR)
    • · Filling of peri-implant defects in conjunction with products intended for Guided Bone Regeneration.
    Device Description

    Porcine Mineral Collagen Composite Moldable is an osteoconductive bone mineral with collagen composite for bone grafting in periodontal, oral and maxillofacial surgery. The device is composed of 90% anorqanic bone mineral granules derived from porcine cancellous bone and 10% collagen from porcine Achilles tendon in a composite matrix. The product is supplied sterile, non-pyrogenic and for single use only.
    Porcine Mineral Collagen Composite Moldable is provided in a block form and is available in three sizes, 0.5cc, 1.0cc, and 2.0cc.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and the study that proves the device meets those criteria:

    Device Name: Porcine Mineral Collagen Composite Moldable (K201859)

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria here are based on demonstrating substantial equivalence to predicate devices (K140714 and K033815, K110600, K122115) through a series of non-clinical tests. The criteria used are the standards and expected outcomes for these tests.

    Test CategoryAcceptance Criteria (e.g., standard, expected outcome for equivalence)Reported Device Performance (Results)
    BiocompatibilityIn accordance with ISO 10993-1 and FDA Guidance
    CytotoxicityNon-cytotoxicNon-cytotoxic
    Genotoxicity (Mouse Lymphoma Assay)No increase in mutant frequency / not mutagenicNo evidence of causing increase in the mean mutant frequency; not mutagenic
    Genotoxicity (Ames Assay)Non-mutagenicNon-mutagenic to Salmonella typhimurium and Escherichia coli strain WP2uvra
    SensitizationNo evidence of dermal contact sensitizationNo evidence of causing delayed dermal contact sensitization in the guinea pig
    Irritation Intracutaneous ReactivityNo evidence of irritation or toxicityNo evidence of irritation or toxicity
    Acute Systemic ToxicityNo mortality or systemic toxicityNo mortality or evidence of systemic toxicity
    PyrogenicityNon-pyrogenicNon-pyrogenic
    ImplantationMinimum tissue reaction, no adverse tissue reactionMinimum tissue reaction up to 13 weeks of implantation and no adverse tissue reaction to the host
    Subacute / Subchronic / Chronic ToxicityMinimum tissue reaction, no adverse tissue reactionMinimum tissue reaction up to 13 weeks of implantation and no adverse tissue reaction to the host
    Bench TestingSimilar to predicate device, appropriate characteristics
    Mineral ContentSimilar to predicate deviceMineral content similar to predicate device
    SizeVolumes similar to predicate deviceVolumes similar to predicate device
    Calcium to Phosphate Ratio (mineral only)Similar to predicate deviceRatio similar to predicate device
    Scanning Electron Micrograph (SEM)Morphologies similar to reference deviceMorphologies similar to reference device
    X-Ray DiffractionSimilar diffraction patterns to reference deviceSimilar diffraction patterns to reference device
    IR SpectroscopySimilar functional groups to reference deviceSimilar functional groups to reference device
    DensityAppropriate density for sufficient porosityAppropriate density for sufficient porosity
    pHSimilar to predicate devicepH similar to predicate device
    AbsorbencySimilar to predicate deviceAbsorbency similar to predicate device
    PyrogenicityNon-pyrogenicNon-pyrogenic
    Animal TestingPerformance substantially equivalent to reference devicePerformance substantially equivalent to the reference device Bio-Oss Collagen when used as intended (Radiographic, Micro CT, Histology and Histomorphometry analyses at 4, 8, and 13 weeks)
    SterilizationIn accordance with ISO 11137-1Sterilization validation performed in accordance with ISO 11137-1
    Shelf Life & StabilityDetermined using real-time aging data, performance testing of packagingProduct and packaging stability determined using real-time aging data. Packaging system tested per ASTM D4169.
    Viral InactivationPerformed in accordance with ISO 22442-3Viral inactivation studies performed in accordance with ISO 22442-3

    2. Sample Size Used for the Test Set and Data Provenance

    The document does not explicitly state numeric "sample sizes" in terms of "test sets" for many of the individual tests beyond the animal study.

    • Animal Study (Implantation/Toxicity/Performance): The text mentions "Implantation in Canine Intrabony Defect Model" and "performance of the device in a canine one-wall intrabony defect model." It refers to "the subject device, reference device and sham negative control." While it doesn't give an exact number of dogs or defects, it implies experimental groups were used for comparison.
    • Biocompatibility Tests: These tests typically use standardized biological samples (e.g., L929 cells for cytotoxicity, guinea pigs for sensitization, rabbits for irritation, mice for acute systemic toxicity). The specific sample numbers for each of these tests are not provided but are generally dictated by the referenced ISO standards.
    • Bench Testing: These tests assess material properties and are performed on samples of the device and predicate/reference devices. Specific sample numbers (e.g., how many units were tested for mineral content, density, pH) are not specified.
    • Data Provenance: The studies are described as non-clinical (in vitro, bench, and animal testing). The country of origin for the data is not specified, but the use of international standards (ISO, ASTM, USP) suggests these are likely standardized laboratory tests. The nature of these tests is prospective within the context of the study design for each specific test, as the device was manufactured and then subjected to these evaluations according to pre-defined protocols.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    • Not applicable in the conventional sense. This is a non-clinical device submission for a bone grafting material. The "ground truth" for these tests refers to the established scientific principles, standardized test methods (like ISO, ASTM, USP), and documented performance of predicate devices. There wouldn't be "experts" establishing a "ground truth" for a test set in the same way clinical image interpretation requires expert radiologists. The "truth" is determined by the objective measurements and observations defined by the test protocols and standards.
    • For the Animal Testing, the "ground truth" for efficacy (performance) would be established by objective measurements (Radiographic, Micro CT, Histology, Histomorphometry analyses) performed by trained scientists/pathologists in accordance with the study protocol. Their qualifications are not specified but would typically involve veterinary expertise, histology pathology, and imaging interpretation.

    4. Adjudication Method for the Test Set

    • Not applicable. As this is a non-clinical submission relying on objective measurement and comparison to predicate devices and standards, there is no "adjudication" in the sense of resolving conflicting interpretations by multiple human readers. The results of the tests (e.g., non-cytotoxic, similar mineral content, substantially equivalent performance in canines) are based on pre-defined criteria within the test protocols.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and the effect size of how much human readers improve with AI vs without AI assistance

    • No. This is a submission for a medical device (bone grafting material), not an AI-powered diagnostic or assistive tool. Therefore, an MRMC comparative effectiveness study involving human readers and AI assistance is not relevant and was not performed.

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

    • No. As explained above, this device is a physical bone grafting material, not a software algorithm. Therefore, "standalone" algorithm performance is not applicable.

    7. The Type of Ground Truth Used

    The "ground truth" for this device's evaluation is primarily based on:

    • Standardized Test Outcomes: Adherence to established international standards (ISO, ASTM, USP) for biocompatibility, material properties, sterility, etc. The results are compared against the pass/fail criteria or expected values defined by these standards.
    • Comparison to Predicate Device Performance: Demonstrating that the subject device's performance (e.g., physical, chemical, biological characteristics, and performance in animal models) is "substantially equivalent" to legally marketed predicate devices. This is achieved by showing similar results across various tests.
    • Histopathology/Imaging (for Animal Study): For the animal study, the ground truth for biological response and bone regeneration comes from objective analyses like radiography, Micro CT, histology, and histomorphometry of tissue samples, interpreted by experts in these fields.

    8. The Sample Size for the Training Set

    • Not applicable. This submission describes the evaluation of a manufactured medical device. There is no concept of a "training set" in the context of machine learning for this type of product. The device itself is the product being tested, not an algorithm that learns from data.

    9. How the Ground Truth for the Training Set Was Established

    • Not applicable. Since there is no "training set," the establishment of its ground truth is not relevant.
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