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510(k) Data Aggregation
(216 days)
Soundly Anti Snoring Device
The Soundly Mandibular Advancement Device is intended to reduce or alleviate snoring and mild to moderate Obstructive Sleep Apnea (OSA) whilst sleeping, in adults
The Soundly Device is a mandibular advancement device to be worn by the patient in their own home at night whilst asleep. The advancement of the lower mandibular is an accepted method of reducing the incidence of light to moderate Obstructive Sleep Apnea (OSA). The Soundly Device consists of the following components:
- . A single lower jaw splint that covers the lower teeth to the gum line. The lower splint has two wedge-shaped projections on its upper surface. These indentations are shaped to receive complementary wedges on the upper splint and so advance the lower jaw compared to the natural positioning.
- . A set of three different upper jaw splints that cover the upper teeth to the gum line. Each upper jaw splint has a pair of wedges on its lower surface that interlock with the wedge indentation on the lower jaw. The set of three upper splints offer different amounts of mandibular advancement: They individually offer 40%, 60% or 70% of the maximum mandibular advancement that the patient's jaw can accommodate. The 70% value has an absolute maximum of 12 mm of mandibular advancement.
The dental impressions of the lower and upper jaw and a bite registration of the patient at maximum comfortable mandibular advancement are made by the prescribing dentist. The impressions are sent to the Soundly labs for processing. The impressions are turned into plaster models in the usual method and then the plaster models are subject to 3D scanning to make electronic 3D models of the mandibular arches. The 3D models are processed in 3D design software into the set of splints, which are then 3D printed in a biocompatible photopolymer. The finished set of splints are returned to the prescribing dentist for final fitting on the patient.
The provided FDA 510(k) summary for the Soundly Mandibular Advancement Device (K220330) primarily focuses on establishing substantial equivalence to predicate devices based on technological characteristics and non-clinical testing. It does not include a clinical study detailing acceptance criteria for device performance in terms of reducing snoring or OSA with corresponding performance metrics.
Therefore, the following response will highlight that the document primarily relies on non-clinical testing and comparison to predicate devices, and that a clinical study with detailed acceptance criteria and performance results is not present in the provided text.
Summary of Device Acceptance Criteria and Study Findings (Based on Provided Document)
The provided submission does not contain a clinical study with acceptance criteria and measured device performance related to its intended use (reducing snoring and OSA). Instead, the submission relies on demonstrating substantial equivalence through a comparison of technological characteristics with predicate devices and non-clinical testing of the manufacturing process, physical properties, and biocompatibility.
1. Table of Acceptance Criteria and Reported Device Performance
As a clinical performance study with specific acceptance criteria is not detailed in the provided document, a table directly addressing that is not possible. The acceptance criteria and "device performance" in this context refer to the non-clinical testing outlined.
Acceptance Criterion (Non-Clinical) | Reported Device Performance (Non-Clinical) |
---|---|
Additive Manufacture Consistency | |
Accuracy with source 3D CAD file (aged resin) | >80% of splint dimensions within 150 micron of CAD file dimension. |
Consistency across different print bed locations and runs | Confirmed as fit for use by independent orthodontist (no air bubbles, inclusions, proper fit on models). |
Physical Properties Testing | |
Resistance to accidental dropping (4, 5, 6 feet) | Splints survived drops; breakage only occurred from 7 feet (complete breakage, not minor chipping). |
Biocompatibility (based on ISO 10993 and ISO 7405) | |
Cytotoxicity, Sensitization, Irritation, Acute systemic toxicity, Material mediated pyrogenicity, Subacute/Subchronic toxicity, Genotoxicity, Implantation | Material passed each and all test requirements. |
2. Sample Size Used for the Test Set and Data Provenance
- For Additive Manufacture Consistency: The sample size is not explicitly stated as a number of devices. The description mentions "All splints printed" for accuracy and "The consistency of the printed splints... across three different print runs" for consistency. The data provenance is internal testing performed by Greystone IP Ltd.
- For Physical Properties (Drop Tests): "The same splints were used for all of the tests." A specific number of splints is not provided, but it implies a small sample. The provenance is internal testing by Greystone IP Ltd.
- For Biocompatibility: The biocompatibility data was provided by the material manufacturer (Formlabs) in a separate cover to the FDA. The sample size for their testing and provenance (country of origin, retrospective/prospective) is not detailed in this document.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- For Additive Manufacture Consistency: An "independent practicing Orthodontist" inspected the printed splints. The number of orthodontists is stated as one. Their specific qualifications (e.g., years of experience) are not provided.
- For other non-clinical tests (physical properties, biocompatibility): Ground truth was established through adherence to recognized standards and protocols (e.g., ISO for biocompatibility) and direct physical measurements/observations by internal personnel or testing labs. External expert involvement for establishing ground truth is not mentioned beyond the orthodontist.
4. Adjudication Method for the Test Set
- For Additive Manufacture Consistency: The orthodontist's inspection appears to be the primary adjudication. No explicit multi-reader/adjudication method (e.g., 2+1, 3+1) is described for these non-clinical tests.
- For other non-clinical tests: Adjudication would follow the protocols of the respective testing standards and internal quality control processes.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No MRMC comparative effectiveness study was mentioned or performed. The submission does not include any clinical trial data or a study comparing human reader (patient) improvement with/without AI assistance. The device is a physical medical device, not an AI diagnostic tool that assists human readers.
6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study
- Not applicable. The Soundly Mandibular Advancement Device is a physical device, not an algorithm, and therefore a standalone algorithm performance study is not relevant to this submission.
7. Type of Ground Truth Used
- For Additive Manufacture Consistency: Ground truth was established by the 3D CAD file dimensions and the "fit for use" judgment of the independent orthodontist against the plaster models.
- For Physical Properties: Ground truth was established by direct observation of breakage and adherence to predefined drop test protocols.
- For Biocompatibility: Ground truth was established by the results of tests performed according to ISO 10993 and ISO 7405 standards.
8. Sample Size for the Training Set
- Not applicable. This device is a physical medical device, not an AI/ML algorithm that requires a "training set" in the conventional sense. The manufacturing process does not involve machine learning training on a dataset.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. As there is no AI/ML training set, this question is not relevant. The "ground truth" for manufacturing relies on initial design specifications (CAD files), material properties, and quality control checks.
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