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510(k) Data Aggregation
(207 days)
Incision, excision, vaporization, ablation and coagulation of oral soft tissues including marginal and inter-dental gingival and epithelial lining of free gingiva and the following specific indications: Excisional and incisional biopsies Exposure of unerupted teeth Fibroma removal Frenectomy Frenotomy Gingival troughing for crown impressions Gingivectomy Gingivoplasty Gingival incision and excision Hemostasis and coagulation Implant recovery Incision and drainage of abscess Leukoplakia Operculectomy Oral papillectomies Pulpotomy Pulpotomy as an adjunct to root canal therapy Reduction of gingival hypertrophy Soft tissue crown lengthening Treatment of canker sores, herpetic and aphthous ulcers of the oral mucosa. Vestibuloplasty Laser Periodontal procedures, including: Laser soft tissue curettage Laser removal of diseased, infected, inflamed and necrosed soft tissue within the periodontal pocket Sulcular debridement (removal of diseased, infected, inflamed and necrosed soft tissue in the periodontal pocket to improve clinical indices including gingival index, gingival bleeding index, probe depth, attachment loss and tooth mobility.)
The EZLase™ dental diode laser system may be used to perform various soft tissue dental applications. The system uses advanced laser technology to incise, excise, vaporize, coagulate and ablate intra-oral soft tissues. A Gallium Aluminum Arsenide (GaAlAs) and/or an Indium Gallium Arsenide Phosphorous solid-state laser diode emit infrared laser energy to the various oral soft tissues targeted during procedure. This energy is transmitted via a flexible fiberoptic cable to the handpiece that emits the energy to the targeted tissue site. A visible light is emitted at the same time to visually pinpoint the treatment location. The power output and pulse width may be adjusted to specific user requirements.
This document is a 510(k) summary for the EZLase™ dental diode laser, which seeks substantial equivalence to already cleared devices. It does not contain a study demonstrating the device meets specific acceptance criteria in the way a clinical trial for a new therapeutic or diagnostic device would.
Instead, the submission for the EZLase™ dental diode laser relies on demonstrating substantial equivalence to predicate devices. This means that the device is shown to be as safe and effective as a legally marketed device that is not subject to PMA (Premarket Approval). The "acceptance criteria" here are met by proving this substantial equivalence, rather than by achieving specific performance metrics against a defined ground truth in a new clinical study.
Therefore, many of the requested sections (like sample size for test set, number of experts for ground truth, adjudication method, MRMC study, standalone performance, training set size, and how training set ground truth was established) are not applicable to this type of regulatory submission in the way they would be for a novel diagnostic AI algorithm.
Here's a breakdown based on the provided text, focusing on how substantial equivalence is demonstrated:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Demonstration of Substantial Equivalence) | Reported Device Performance (as stated in the document) |
---|---|
Equivalent Intended Use: The device performs the same indications for use as predicate devices. | The EZLase™ has the same Indications for Use as predicate devices (LaserSmile™, LVI Lase, DioDent II) for various soft tissue dental applications and laser periodontal procedures. These indications include incision, excision, vaporization, ablation, coagulation of oral soft tissues, and specific procedures like frenectomy, gingivectomy, and sulcular debridement. |
Equivalent Performance Specifications: The device's technical specifications are comparable to predicate devices. | The document states "Equivalent performance specification" but does not detail specific metrics or a comparative table. It implies that the underlying technology and output parameters are similar enough to achieve the same clinical effects. |
Equivalent Technology/Mechanism of Action: The device achieves its intended use through the same mechanism as predicate devices. | The EZLase™ uses a Gallium Aluminum Arsenide (GaAlAs) and/or Indium Gallium Arsenide Phosphorous (InGaAsP) solid-state laser diode to emit infrared laser energy transmitted via a flexible fiberoptic cable. This mechanism is implicitly considered equivalent to the predicate diode lasers. |
No Unique Applications, Indications, Materials or Specifications: The device does not introduce new features that raise different questions of safety or effectiveness. | The document states, "There are no unique applications, indications, materials or specifications presented herein." |
Feature Comparison: A comparison validates the equivalence of features. | A "Feature comparison table" is mentioned as evidence of equivalence, but the actual table is not provided in the excerpt. |
2. Sample size used for the test set and the data provenance
- Not Applicable in this context. This 510(k) submission relies on demonstrating substantial equivalence to existing legally marketed predicate devices, not on a new clinical study with a test set of patient data to prove effectiveness. The "data provenance" would refer to the existing regulatory clearances for the predicate devices.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not Applicable. No new ground truth needed to be established for this submission as it relies on substantial equivalence.
4. Adjudication method for the test set
- Not Applicable. No new test set requiring adjudication was performed.
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 device is a surgical laser, not an AI-assisted diagnostic or imaging device. Therefore, MRMC studies are not relevant to its regulatory submission.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. This is a hardware device (surgical laser), not an algorithm.
7. The type of ground truth used
- "Ground truth" here is embodied by the established safety and effectiveness of the predicate devices cleared by the FDA. The premise of a 510(k) is that if a new device is substantially equivalent to an already cleared device, then it is also safe and effective. The FDA's initial clearance of the predicate devices would have relied on various forms of evidence, potentially including clinical data, performance testing, and literature review, but not necessarily for this new device's submission.
8. The sample size for the training set
- Not Applicable. This is not a machine learning or AI device that requires a training set.
9. How the ground truth for the training set was established
- Not Applicable. As per point 8.
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