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510(k) Data Aggregation

    K Number
    K232271
    Device Name
    SIMDA abutment
    Manufacturer
    Date Cleared
    2023-10-26

    (87 days)

    Product Code
    Regulation Number
    872.3630
    Why did this record match?
    Device Name :

    SIMDA abutment

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

    SIMDA Abutments are intended for use with dental implants as a support for single or multiple tooth prostheses in the maxilla or mandible of a partially or fully edentulous patient.

    Device Description

    SIMDA Abutment is made of titanium alloy (Ti-6Al-4V ELI, ASTM F136) intended for use as an aid in prosthetic restoration. It consists of Pre-Milled Blank and Ti-Base abutment. It has a premanufactured connection interface that fits directly to an endosseous dental implant.

    AI/ML Overview

    This FDA 510(k) summary describes a dental device, the SIMDA Abutment. However, it does not include information that directly addresses the specific questions you've asked about acceptance criteria and a study proving a device meets them, particularly for an AI/ML powered device.

    Here's why and what information is provided:

    The document is a premarket notification for a Class II medical device, specifically dental implant abutments. These are physical components used in dental restorations, not an AI/ML powered diagnostic or therapeutic device. Therefore, the concepts of "acceptance criteria for an AI model," "test set," "ground truth," "MRMC studies," "effect size of human readers with AI assistance," or "standalone algorithm performance" are not applicable to this submission.

    The "studies" mentioned are non-clinical (mechanical, biological) tests demonstrating the physical safety and performance of the abutments and their compatibility with existing dental implant systems.

    Here's a breakdown of the relevant information provided, framed as closely as possible to your request, but acknowledging the device type:


    Device: SIMDA Abutments (K232271)
    Device Type: Endosseous Dental Implant Abutment (physical medical device, not AI/ML powered)

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

    The document sets design limits and then demonstrates conformity through non-clinical testing. The "acceptance criteria" here are rather design specifications and performance standards for dental abutments.

    Acceptance Criteria (Design Parameters/Limitations)Reported Device Performance (Demonstrated through testing)
    Pre-Milled Blank (for Patient-specific abutment):
    - Minimum and Maximum Gingival (Cuff) Height: 0.5~5mm"The minor difference between the two products in the design parameters [...] was evaluated as part of the performance testing and was determined to not impact the performance of the device." - Implies device meets these parameters and performs acceptably.
    - Minimum and Maximum diameter at abutment/implant interface: Ø4.0~Ø8.0
    - Minimum and Maximum length of abutment: 4.5~13mm
    - Minimum and Maximum length of abutment post (length above the abutment collar/gingival height): 4~8mm
    - Minimum wall thickness at abutment/implant interface: 0.4mm (Predicate: 0.4mm, Proposed: 0.39~0.55mm)"This change in technological characteristics [minimum thickness] was evaluated as part of the performance testing and was determined to not impact the performance of the device." - Indicates the slightly wider range for the proposed device (0.39-0.55mm) still met performance requirements.
    - Minimum and Maximum abutment angle: 0~25°
    Ti-Base (for Zirconia top-half):
    - Post Angle (°): 0~15Identical to predicate. Non-clinical testing results "demonstrated the substantial equivalence with the primary predicate."
    - Cuff Height (mm): 0.5~5.0
    - Post Length (mm): 4.0~6.0
    - Diameter (Ø, mm): 5.0~8.0
    - Thickness (mm): 0.4
    General Performance:
    - Fatigue Resistance: Must meet ISO 14801 and FDA special controls guidance.Fatigue testing followed ISO 14801 and the FDA special controls guidance document. Results "demonstrated the substantial equivalence with the primary predicate."
    - Sterilization Efficacy: Must meet ISO 17665-1:2006, 17665-2:2009, ANSI/AAMI ST79:2010.End User Steam Sterilization Test according to ISO 17665-1:2006, 17665-2:2009 and ANSI/AAMI ST79:2010. Results "demonstrated the substantial equivalence with the primary predicate."
    - Biocompatibility: Must meet ISO 10993-1:2009, ISO 10993-5:2009, and ISO 10993-10:2010.Biocompatibility tests according to ISO 10993-1:2009, ISO 10993-5:2009, and ISO 10993-10:2010. Results "demonstrated the substantial equivalence with the primary predicate."
    - MRI Safety: Must address magnetically induced displacement force and torque (per FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment")."Non-clinical worst-case MRI review was performed... using scientific rationale and published literature... Rationale addressed parameters per the FDA guidance... including magnetically induced displacement force and torque." - Implies the device is deemed safe in the MR environment based on this review.
    - Compatibility with OEM Implant Systems: Precision implant/abutment interface.Dimensional analysis and reverse engineering of critical features... Cross sectional images were provided to demonstrate substantially equivalent compatibility. The testing aided implant to abutment compatibility and has established substantial equivalency of the proposed device with the predicate device.

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

    • This information is not provided. For physical tests (fatigue, biocompatibility, sterilization), sample sizes would typically be determined by the relevant ISO standards.

    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. "Ground truth" in the context of AI/ML is not relevant here. The "truth" is established by physical measurement, adherence to material standards, and documented mechanical performance.

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

    • Not applicable. Adjudication methods are typically for subjective assessments, whereas these are objective physical tests.

    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 is a physical dental device, not an AI-assisted diagnostic tool.

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

    • Not applicable. This is a physical dental device.

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

    • For physical tests, the "ground truth" is defined by the ISO standards and FDA guidance documents to which the device is tested. This includes established methods for fatigue testing, biocompatibility evaluation, and sterilization efficacy. For compatibility, it's about precise dimensional matching and mechanical fit to existing OEM implant systems.

    8. The sample size for the training set

    • Not applicable. This is a physical dental device, not an AI/ML powered device that requires a "training set."

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

    • Not applicable. See point 8.

    In summary, this document is for a traditional medical device (dental abutments), and thus the questions formulated for an AI/ML device do not directly apply. The acceptance criteria are based on established engineering and materials standards, and performance is demonstrated through non-clinical laboratory testing rather than clinical or observational studies on diagnostic performance.

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    K Number
    K223663
    Device Name
    SIMDA Abutment
    Manufacturer
    Date Cleared
    2023-05-24

    (168 days)

    Product Code
    Regulation Number
    872.3630
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    SIMDA Abutment

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

    SIMDA Abutments are intended for use with dental implants as a support for single or multiple tooth prostheses in the maxilla or mandible of a partially or fully edentulous patient.

    It is compatible with the following systems:

    Compatible System Implant Body Diameter(mm) Implant Platform
    Osstem TS (K121995) 3.5, 3.75 Mini
    Osstem TS (K121995) 3.75, 3.77, 4.2, 4.25, 4.4, 4.6, 4.63, 4.65, 4.9, 5.05, 5.08, 5.1 Regular
    Straumann Bone Level (only the Roxolid® implants from K140878) 3.3 NC
    Straumann Bone Level (only the Roxolid® implants from K140878) 4.1, 4.8 RC
    All digitally designed abutments for use with SIMDA Abutments are intended to be sent to a SIMDA validated milling center for manufacture.

    Device Description

    SIMDA Abutment is made of titanium alloy (Ti-6A1-4V ELI. ASTM F136) intended for use as an aid in prosthetic restoration. It consists of Pre-Milled Blank and Ti-Base abutment. It has a premanufactured connection interface that fits directly to an endosseous dental implant.

    Pre-Milled Blank Design Limitation for Patient-specific abutment:

    Design parameter (Patient-specific abutment) Subject System Design Limit
    Minimum and Maximum Gingival (Cuff) Height 0.55mm
    Minimum and Maximum diameter at abutment/implant interface ⌀4.0
    ⌀8.0
    Minimum and Maximum length of abutment 4.513mm
    Minimum and Maximum length of abutment post (length above the abutment collar/gingival height) 4
    8mm
    Minimum wall thickness at abutment/implant interface 0.4mm
    Minimum and Maximum abutment angle 0~25°

    Ti Base consists of a two-piece abutment, where the titanium base is a pre-manufactured abutment that will be used to support a CAD/CAM-designed zirconia superstructure (the second part of the two-piece abutment) that composes the final abutment.

    Pre-Milled Blank and Ti Base are provided non-sterile therefore must be sterilized after the cementation of the patient-specified superstructure.

    Raw material blanks

    • InCoris Zi (ZrO2) by Sirona Dental Systems GmbH, L size blanks, cleared under K123664. ●
      Cement
    • . RelyX Unicem 2Automix by 3M ESPE, cleared under K100756.

    Design Limitation for Zirconia superstructure:

    Design Limits for Zirconia top-half (Min. ~ Max.)

    • Post Angle (°): 0~15
    • Cuff Height (mm): 0.55.0
      -Post Length (mm): 4.0
      6.0
      -Diameter (Ø, mm): 5.0~8.0
      -Thickness (mm): 0.4
    AI/ML Overview

    This FDA 510(k) summary (K223663) concerns a dental implant abutment, not an AI/ML medical device. Therefore, the information required to populate the fields related to AI/ML model performance, such as test set sample size, expert ground truth establishment, MRMC studies, and training set information, is not available in the provided document.

    The document discusses the substantial equivalence of the SIMDA Abutment to existing predicate devices based on non-clinical testing for mechanical properties (fatigue), sterilization, and biocompatibility.

    Here's an attempt to answer the relevant sections based on the provided text, and noting where information is not applicable or unavailable for an AI/ML device:


    Acceptance Criteria and Device Performance for SIMDA Abutment

    Since this is a non-AI/ML device (a dental abutment), the "acceptance criteria" are related to mechanical and biological performance rather than AI/ML algorithm metrics. The study described is a non-clinical study to demonstrate substantial equivalence to predicate devices.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Test/Parameter (Acceptance Criteria)Reported Device Performance / Evaluation
    Mechanical PerformanceFatigue testing (ISO 14801, FDA Special Controls Guidance) for worst-case scenarios of assembled implant/abutment systems."The results of the above tests have demonstrated the substantial equivalence with the primary predicate." (Implies meeting or exceeding predicate performance/safety).
    Material CompositionTi-6Al-4V ELI (ASTM F136) for Pre-Milled Blank and Ti-Base abutment."SIMDA Abutment is made of titanium alloy (Ti-6A1-4V ELI. ASTM F136)..." and "Material: Ti-6Al-4V ELI (ASTM F136) Zirconia"
    SterilizationEnd User Steam Sterilization Test (ISO 17665-1:2006, 17665-2:2009, ANSI/AAMI ST79:2010)."The results of the above tests have demonstrated the substantial equivalence with the primary predicate." (Implies effective and compliant sterilization). "Pre-Milled Blank and Ti Base are provided non-sterile therefore must be sterilized after the cementation of the patient-specified superstructure." and "Sterile: steam sterilized before use"
    BiocompatibilityBiocompatibility tests (ISO 10993-1:2009, ISO 10993-5:2009, ISO 10993-10:2010)."The results of the above tests have demonstrated the substantial equivalence with the primary predicate." (Implies biocompatibility).
    Dimensional CompatibilityDimensional analysis and reverse engineering of critical features and tolerances of the implant-to-abutment connection platform (OEM implant body, abutment, screw). Cross-sectional images."Cross sectional images wre provided to demonstrate substantially equivalent compatibility." and "The testing aided implant to abutment compatibility and has established substantial equivalency of the proposed device with the predicate devices."
    MR Environment CompatibilityEvaluation of metallic components in MR environment using scientific rationale and published literature per FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment.""Non-clinical worst-case MRI review was performed to evaluate the metallic SIMDA abutment in the MRI environment using scientific rationale and published literature..."
    Design LimitsSpecific ranges for gingival cuff height, diameter at interface, length of abutment, post length, wall thickness, and abutment angle must fall within established safe/effective ranges relative to predicates.The document provides design limits for "Patient-specific abutment" and "Zirconia superstructure" and compares them to predicate devices, discussing minor differences and concluding that performance testing demonstrated substantial equivalence. (e.g., "Even though there are some minor differences in dimensions, performance testing demonstrated that the subject device has substantially equivalent fatigue performance.")

    2. Sample size used for the test set and the data provenance:

    • Sample Size for Test Set: Not explicitly stated in the document. Non-clinical mechanical fatigue testing typically uses a small number of samples (e.g., 5-10 per test condition) to demonstrate compliance with standards.
    • Data Provenance: The tests are non-clinical (laboratory) studies. The manufacturer is SIMDA Co., Ltd. from REPUBLIC OF KOREA. The studies are prospective in the sense that they were designed and conducted to evaluate the device for this submission.

    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 for this type of device/study. This section typically applies to AI/ML devices where human expert consensus is used to label medical images for ground truth. For a dental abutment, "ground truth" is established by engineering and material science standards, measurements, and physical testing.

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

    • Not applicable. Adjudication methods are relevant for resolving discrepancies in human expert labeling of data, which is not part of the non-clinical testing for a dental abutment.

    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 was not done. An MRMC study is performed for AI/ML devices to assess the impact of AI assistance on human reader performance. This is not applicable to a physical dental abutment. The document explicitly states: "Clinical testing was not necessary to establish substantial equivalency of the device."

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

    • Not applicable. This pertains to AI/ML algorithm performance in isolation. The product is a physical dental abutment.

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

    • Engineering and material science standards, physical measurements, and established performance criteria. Ground truth is implicitly defined by the referenced ISO standards (e.g., ISO 14801 for fatigue testing, ISO 17665-1 for sterilization) and the performance characteristics of the predicate devices. The "worst-case scenarios" were tested to ensure safety and effectiveness.

    8. The sample size for the training set:

    • Not applicable. There is no "training set" as this is not an AI/ML device.

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

    • Not applicable. There is no "training set."

    Summary of what the study did prove:
    The study proved that the SIMDA Abutment is substantially equivalent to a legally marketed predicate device (TiGEN Abutment, ZrGEN Abutment and Scan Healing Abutment K220562, and others) by demonstrating comparable:

    • Intended Use
    • Material composition
    • Mechanical properties (through fatigue testing)
    • Sterilization efficacy
    • Biocompatibility
    • Dimensional compatibility with specified implant systems
    • Safety in an MR environment

    The conclusion is based on non-clinical testing, which was deemed sufficient by the FDA to demonstrate substantial equivalence without the need for clinical studies.

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