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510(k) Data Aggregation

    K Number
    K222231
    Date Cleared
    2022-10-27

    (94 days)

    Product Code
    Regulation Number
    872.3640
    Panel
    Dental
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    S.I.N. Dental Implant System is intended for placement in the maxillary or mandibular arch to provide support for single-unit or multi-unit restorations. When a one-stage surgical approach is applied, the S.I.N. Dental Implant System is intended for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

    S.I.N. Dental Implants with lengths of 18, 20, 22, or 24 mm be tilted up to 30°. When used in the mandible or maxilla with implants with lengths of 18, 20, 22, or 24 mm at an angulation of 30°, a minimum of four implants must be used and must be splinted. When placed in the maxilla with lengths of 18, 20, 22, or 24 mm at angulations between 0° and less than 30°, the S.I.N. Dental Implants are only indicated for multiple unit restorations in splinted applications that utilize at least two implants.

    Device Description

    The purpose of this submission is to add components to the S.I.N. Dental Implant System, which includes components cleared previously in K211921, K200992, and K170392.

    This submission includes dental implants Epikut S with a Morse taper (CM) abutment interface and an acid-etched endosseous surface, and Epikut S Plus implants with an endosseous surface produced by acidetching followed by application of a hydroxyapatite coating (HA™M). The implant design and endosseous surfaces are nearly identical to the Epikut Plus CM implants cleared in K211921, with the exception of the implant-abutment connection (subject device 16° Morse taper, K211921 11.5° Morse taper), the additional body/platform diameter (4.0 mm), and the longer lengths (18, 20, 22, and 24 mm).

    All subject device dental implants are manufactured from unalloyed titanium conforming to ASTM F67. The acid etching procedure is applied to all subject device dental implants. The acid etching process in this submission is identical to the process used to manufacture the dental implants cleared in K211921, and the HA100 surface treatment is identical to that cleared in K211921.

    AI/ML Overview

    This FDA 510(k) summary (K222231) describes a dental implant system and focuses on demonstrating substantial equivalence to previously cleared predicate devices, rather than on presenting a study with specific acceptance criteria, test sets, or performance metrics in the way these terms are typically used for AI/ML-based diagnostic devices.

    The document is a regulatory submission for a medical device (S.I.N. Dental Implant System), not a study evaluating algorithm performance. Therefore, it does not contain information about:

    • A table of acceptance criteria and reported device performance in the context of an algorithm's diagnostic accuracy.
    • Sample sizes, data provenance, number of experts, adjudication methods for a test set.
    • Multi-Reader Multi-Case (MRMC) comparative effectiveness studies.
    • Standalone algorithm performance.
    • Sample size for training sets or how ground truth for training sets was established.

    Instead, the document focuses on non-clinical performance data to show that the new components of the S.I.N. Dental Implant System (subject device) are as safe and effective as existing legally marketed devices.

    Here's an breakdown of the acceptance criteria (or rather, the demonstration of equivalence) and the studies (non-clinical tests and analyses) that prove the device meets these criteria, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria here are based on demonstrating that the subject device's design, materials, manufacturing, sterilization, and performance characteristics are substantially equivalent to predicate devices already cleared by the FDA. The performance data presented are non-clinical and relate to the physical and biological properties of the implant.

    Acceptance Criteria (Demonstrated Equivalence to Predicate Devices)Reported Device Performance (as demonstrated by non-clinical studies/analysis)
    Intended Use (Functional and esthetic rehabilitation of edentulous mandible or maxilla)Equivalent to K211921, K203725, K170392, and K050406. The subject device's Indications for Use statement is largely identical or similar to the predicate devices, with specific language related to tilting angles and required number of implants/splinting justified by K050406 and K203725.
    Material Composition (Unalloyed titanium, ASTM F67)Equivalent to K211921, K203725, K170392. All subject device implants are manufactured from the same material.
    Endosseous Surface Treatment (Acid-etched; HA™ for Epikut S Plus)Equivalent to K211921 and K170392 for acid-etching. The HA™ treatment is identical to that cleared in K211921. Characterization (SEM, XPS, TEM, XRD, adherence) from K211921 leveraged.
    Sterilization Method & Sterility Assurance Level (SAL) (Gamma irradiation to 10⁻⁶ SAL at 25 kGy)Equivalent to K211921 and K203725. Sterilization method selected and substantiated according to ISO 11137-1 and ISO 11137-2.
    Bacterial Endotoxin Limit (< 20 EU/device)Equivalent to K211921. Demonstrated via Limulus amebocyte lysate (LAL) testing according to ANSI/AAMI ST72 on samples from manufacturing water (weekly) and sterilized product (quarterly).
    Shelf Life/Packaging Integrity (4 years real-time aging)Equivalent to K211921. Testing of samples after 4 years of real-time aging according to ASTM F1929 and F88/F88M (packaging sterile barrier) and sterility testing of product.
    BiocompatibilityEquivalent to K211921. Biological evaluation performed according to ISO 10993-1, with test results leveraged from K211921.
    MR Safety (Magnetically induced displacement force, torque, RF heating, image artifact)Non-clinical analysis and testing performed according to ASTM F2052, ASTM F2213, ASTM F2182, ASTM F2119, and FDA guidance. Results demonstrate safety in the MR environment.
    Mechanical Performance / Implant-Abutment Connection (Engineering analysis of new components)Equivalent to K200992 (for mechanical testing applicability). Engineering analysis demonstrated that the subject device implants, with compatible previously-cleared abutments, do not create a new worst-case construct, thus making previous mechanical testing applicable. (Note: Specific mechanical test results/values are not provided in this summary, but the applicability of prior testing is the demonstration of equivalence here).
    Physical Dimensions (Body/platform diameters and lengths, including new 4.0mm diameter and 18-24mm lengths)Equivalent or within the range of previously cleared devices. New 4.0mm diameter is within the range of K170392. 18-24mm lengths are similar to K203725.

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

    This is not applicable as this document describes a 510(k) submission for a physical medical device, not an algorithm's test set. The "test sets" here refer to batches of physical devices or materials undergoing non-clinical laboratory testing. The provenance of the data is the manufacturer (S.I.N. - Sistema de Implante Nacional S.A.) or its testing facilities, and the studies are non-clinical evaluations.

    3. Number of Experts Used to Establish the Ground Truth and Qualifications

    This is not applicable for a non-clinical device submission. Ground truth, in this context, would relate to objective measurements against established standards (e.g., ASTM, ISO standards) rather than expert consensus on medical images.

    4. Adjudication Method

    Not applicable. Adjudication methods are typically associated with resolving discrepancies in expert interpretations during clinical or algorithm performance studies. The non-clinical tests described have defined protocols and objective pass/fail criteria.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. This type of study is relevant for evaluating the impact of an AI algorithm on human reader performance, which is not the subject of this 510(k) submission for a dental implant.

    6. Standalone Performance Study

    No. This refers to the performance of an algorithm without human intervention. This document details the performance characteristics of a physical implant device, not an algorithm.

    7. The Type of Ground Truth Used

    The "ground truth" for the non-clinical tests is established by compliance with recognized consensus standards (e.g., ISO, ASTM, AAMI) and the device's adherence to its design specifications, materials testing, and performance against these standards. For example:

    • Sterility: Achieved according to ISO 11137-1 and ISO 11137-2.
    • Bacterial Endotoxin: Meets limits (< 20 EU/device) as per ANSI/AAMI ST72.
    • Packaging: Integrity verified against ASTM F1929 and F88/F88M.
    • Biocompatibility: Evaluated against ISO 10993-1.
    • MR Safety: Assessed against ASTM F2052, F2213, F2182, F2119.
    • Mechanical Performance: Demonstrated through engineering analysis applying previous mechanical testing (K200992).
    • Material Composition: Conforms to ASTM F67.

    8. The Sample Size for the Training Set

    Not applicable. This is not an AI/ML device.

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

    Not applicable. This is not an AI/ML device.

    In summary, this 510(k) pertains to a physical dental implant and uses non-clinical testing and engineering analysis to establish substantial equivalence to previously cleared predicate devices, rather than performing clinical studies or AI/ML algorithm validation.

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