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510(k) Data Aggregation
(45 days)
SMH Flex "S" is intended for the laboratory fabrication of dental prosthesis including the repair and relining of complete and/or partial dentures, occlusal splints, night guards, tooth positioners, snoring and sleep apnea devices, and other appliances as prescribed.
The submitted device SMH Flex "S" is a pre-mixed acrylic resin for use in the laboratory fabrication of dental prosthesis such as the repair and relining of complete and/or partial dentures, dental appliances including, occlusal splints, night guards, tooth positioners, snoring and sleep apnea devices.
The provided 510(k) summary for the SMH Flex "S" device does not contain the detailed information necessary to answer all aspects of your request regarding acceptance criteria and a study proving the device meets those criteria, particularly in the context of AI-driven medical devices. Much of the request asks about elements common in studies for AI/ML performance (e.g., sample size for test sets, ground truth establishment, MRMC studies), which are not relevant to this traditional material device.
However, I can extract the information that is present and explain why other parts are not applicable.
Here's an analysis based on the provided text:
Acceptance Criteria and Device Performance
The "acceptance criteria" for a material device like SMH Flex "S" are typically defined by demonstrating substantial equivalence to a predicate device through comparative testing of its physical, chemical, and biological properties, rather than specific performance metrics like sensitivity, specificity, or AUC as one might see for diagnostic AI. The document confirms that specific tests were performed, and the results "support the safety and effectiveness."
1. Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criterion (Test Performed) | Reported Device Performance |
---|---|
Mechanics | Not explicitly detailed, but implied to be similar to predicate. |
Water Absorption & Solubility | Not explicitly detailed, but implied to be similar to predicate. |
Rest Monomer Concentration | Not explicitly detailed, but implied to be similar to predicate. |
Biocompatibility | - L929 Mem Elution Test: Non Cytotoxic |
- Intracutaneous Injection Test: Non Irritant
- Kligman Maximization Test: Non Sensitivity |
| Opaque Factor | Not explicitly detailed, but implied to be similar to predicate. |
| Density & Consistency | Not explicitly detailed, but implied to be similar to predicate. |
2. Sample size 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 in the 510(k) summary. For material characterization and biocompatibility tests, specific sample sizes (e.g., number of specimens for mechanical testing, number of animals for in-vivo biocompatibility tests, replicates for in-vitro assays) would have been used, but these details are not disclosed in this summary. Data provenance information like country of origin or retrospective/prospective status is also not applicable or not provided for these types of bench and in-vitro/in-vivo physical property tests.
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):
This question is not applicable to the type of device (dental resin) and the tests performed. "Ground truth" as a concept for expert consensus or pathology is typically used for diagnostic or imaging devices where human interpretation is involved. For material characteristic or biocompatibility tests, the "ground truth" is derived from standardized laboratory procedures and measurements.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
This question is not applicable for the reasons stated above. Adjudication methods are relevant for expert review processes, which are not described for this device's evaluation.
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:
This question is not applicable. SMH Flex "S" is a dental resin, not an AI-assisted diagnostic or imaging device. Therefore, MRMC studies and "human readers improving with AI" are entirely irrelevant to its evaluation.
6. If a standalone (i.e. algorithm only, without human-in-the-loop performance) was done:
This question is not applicable. The device is a material, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" for this device's evaluation is based on standardized laboratory measurements and accepted scientific principles for material properties and biocompatibility testing standards (e.g., ISO standards for cytotoxicity, irritation, sensitization).
8. The sample size for the training set:
This question is not applicable. The device is a material, not a machine learning model, so there is no "training set" in the AI/ML context.
9. How the ground truth for the training set was established:
This question is not applicable for the reasons stated above.
Summary of the Study that Proves the Device Meets Acceptance Criteria:
The "study" in this context is a series of laboratory tests and analyses comparing SMH Flex "S" to its predicate devices (Talon & Revere, Ivocap Elastomer) and conducting specific biocompatibility assays.
- Study Design: Comparative testing and in-vitro/in-vivo biocompatibility assays. The comparison focused on "Technological Characteristics Compared with Predicate Device: Mechanics, Water Absorption & Solubility, Rest Monomer Concentration, Biocompatibility, Opaque Factor and Density & Consistency."
- Key Findings: The device demonstrated non-cytotoxic, non-irritant, and non-sensitizing properties in the specific biocompatibility tests. The summary concludes that "the similarity in composition between SMH Flex "S" and the predicate we coincided that the performance data and biocompatibility results, supports the safety and effectiveness of SMH Flex "S" for the indicated uses."
- Conclusion for 510(k): The FDA determined the device to be "substantially equivalent" to legally marketed predicate devices, meaning it meets the necessary safety and effectiveness standards for its intended use.
In essence, for a material such as dental resin, the "acceptance criteria" are met by demonstrating that the new device has similar characteristics and performs comparably to already approved, predicate devices, and that it is shown to be biocompatible through standard biological tests. The concept of "ground truth" and specific sample sizes for clinical studies (as would be relevant for diagnostic devices) are not presented in this type of 510(k) submission summary for a material.
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