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510(k) Data Aggregation

    K Number
    K192670
    Date Cleared
    2019-12-18

    (84 days)

    Product Code
    Regulation Number
    880.6850
    Reference & Predicate Devices
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Neodent Instrument Kit Cases are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. Neodent Instrument Kit Cases are intended to allow sterilization of the enclosed medical devices. Neodent Instrument Kit Cases require the use of FDA cleared wrap to maintain the sterility of the enclosed devices.

    The kits are to be enclosed in a sterilization wrap that is FDA-cleared for the indicated cycles, and moist heat (steam) sterilized using one of the following cycles:

    Fractionated vacuum (pre-vacuum) - Exposure at 132 °C for 4 minutes, 20-minute dry time.

    Gravity displacement - Exposure at 132 °C for 15 minutes, 40-minute dry time.

    Neodent Instrument Kit Cases are intended for sterilization of non-porous loads.

    The combined weight of the GM Surgical Kit Case and the associated instruments is 613.1 g. The weight of the empty Kit Case is 510 grams.

    Neodent Instrument Kit Cases should not to be stacked during sterilization.

    Indications for Use for GM Helix Compact Surgical Kit Case:

    Neodent Instrument Kit Cases are intended to be used to enclose other medical devices that are to be sterilized by a health care provider. Neodent Instrument Kit Cases are intended to allow sterilization of the enclosed medical devices. Neodent Instrument Kit Cases require the use of FDA cleared wrap to maintain the sterility of the enclosed devices.

    The kits are to be enclosed in a sterilization wrap that is FDA-cleared for the indicated cycles, and moist heat (steam) sterilized using one of the following cycles:

    Fractionated vacuum (pre-vacuum) - Exposure at 132 °C for 4 minutes, 20-minute dry time

    Gravity displacement - Exposure at 132 °C for 15 minutes, 20-minute dry time.

    Neodent Instrument Kit Cases are intended for sterilization of non-porous loads.

    The combined weight of the GM Helix Compact Surgical Kit Case and the associated instruments is 308.2 g. The weight of the empty Kit Case is 231 grams.

    Neodent Instrument Kit Cases should not to be stacked during sterilization.

    Device Description

    The subject device kit cases are reusable rigid containers, comprising a case bottom (or base), a removable inner tray, and tray lid (lid). The subject device kits are to be used to organize and protect instruments and accessories that are to be sterilized by the healthcare provider. The subject devices include two (2) such kit cases. The lids are manufactured from injection molded polyphenylsulfone resin, the tray and base are manufactured from injection molded polysulfone resin. The designs include grommets and inserts of various geometries manufactured from molded silicone that retain the instruments within the tray and base. The subject device kit cases are provided nonsterile to the end-user.

    AI/ML Overview

    The provided text describes the acceptance criteria and a study proving the device meets these criteria for the Neodent Instrument Kit Cases (K192670).

    Here's the breakdown of the information requested:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance CriterionReported Device Performance
    Manual Cleaning Validation
    Hemoglobin Test: < 0.50 µg/mLPassed
    Hemoglobin Test: < 55 µg/articlePassed
    Hemoglobin Test: < 0.0078 µg/cm²Passed
    Micro BCA Protein Test: < 1.1 µg/mLPassed
    Micro BCA Protein Test: < 220 µg/articlePassed
    Micro BCA Protein Test: < 0.018 µg/cm²Passed
    Sterilization Validation (including sterilant penetration and drying time)
    SAL (Sterility Assurance Level) of 10⁻⁶Passed
    Life Cycle (simulate usage) Testing
    Visual and functional inspection following 100 cycles (assembled/disassembled, cleaned, sterilized; component dimensional fit verification; functional closure verification)Passed
    Biocompatibility (Cytotoxicity)
    < 30% inhibition of proliferation of protein contentPassed
    Sterilization Parameters for GM Surgical Kit Case (110.288):
    Fractionated vacuum (pre-vacuum): Exposure at 132 °C for 4 minutes, 20-minute dry timeValidated (implicitly by "Passed" for sterilization validation)
    Gravity displacement: Exposure at 132 °C for 15 minutes, 40-minute dry timeValidated (implicitly by "Passed" for sterilization validation)
    Sterilization Parameters for GM Helix Compact Surgical Kit Case (110.297):
    Fractionated vacuum (pre-vacuum): Exposure at 132 °C for 4 minutes, 20-minute dry timeValidated (implicitly by "Passed" for sterilization validation)
    Gravity displacement: Exposure at 132 °C for 15 minutes, 20-minute dry timeValidated (implicitly by "Passed" for sterilization validation)

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

    The document does not explicitly state the specific "sample size for the test set" in terms of number of devices or data points used for each test. However, it indicates that testing was performed on the "subject devices" (plural), which refers to the two models: GM Surgical Kit Case (110.288) and GM Helix Compact Surgical Kit Case (110.297).

    The data provenance is from Brazil, as the sponsor is "JJGC Indústria e Comércio de Materiais Dentários SA" located in Curitiba, Parana, Brazil. The study appears to be retrospective in the sense that the testing was conducted and results presented as evidence for the premarket notification.

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

    This information is not provided in the document. The document refers to validation testing (e.g., manual cleaning validation, sterilization validation, life cycle testing, cytotoxicity) according to established standards (Custom, ANSI/AAMI/ISO 17665-1, ANSI/AAMI/ISO 17665-2, "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling Guidance for Industry and Food and Drug Administration Staff," ANSI/AAMI/ISO 10993-5). These tests rely on objective measurements against defined criteria rather than expert consensus on "ground truth" in the way an AI diagnostic study might.

    4. Adjudication Method for the Test Set

    This information is not applicable for this type of device and testing. Adjudication methods (like 2+1, 3+1) are typically used in clinical studies where multiple human readers interpret data, and a robust method is needed to establish a "ground truth" diagnosis. The tests performed here are objective performance tests (e.g., chemical residue levels, sterility assurance level, physical integrity).

    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

    An MRMC comparative effectiveness study was not performed. This type of study is relevant for AI-assisted diagnostic devices, which is not the nature of the "Neodent Instrument Kit Cases."

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

    A standalone performance study was not performed in the context of an AI algorithm. The device is a physical instrument kit case, not a software algorithm. The "standalone" performance here refers to the physical device's ability to meet performance criteria (e.g., cleaning, sterilization, durability) without human intervention beyond the standardized operating procedures for use.

    7. The Type of Ground Truth Used

    The "ground truth" for the device's performance is established by objective laboratory measurements and tests against predefined acceptance criteria derived from recognized industry standards and guidance documents (e.g., Hemoglobin concentration readings, protein concentration readings, Sterility Assurance Level of 10⁻⁶, visual and functional inspection results after simulated use, cytotoxicity inhibition percentage). It is not based on expert consensus, pathology, or outcomes data in a clinical sense.

    8. The Sample Size for the Training Set

    This information is not applicable. The "Neodent Instrument Kit Cases" is a physical medical device, not a machine learning or AI algorithm, therefore there is no "training set."

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

    This information is not applicable, as there is no training set for this device.

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