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510(k) Data Aggregation
(132 days)
The OSSTEM Prosthetic system is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or over-dentures.
SS Abutment System is made of titanium alloy. SS Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures.
The medical device described in the document is the SS Abutment System from Osstem Implant Co., Ltd. This device is an endosseous dental implant abutment, classified as Class II under regulation 21 CFR 872.3630 with product code NHA.
Here's an analysis of the acceptance criteria and the study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
The submission claims substantial equivalence to predicate devices, focusing on design, function, indications for use, material, manufacturing process, and performance characteristics. The acceptance criteria are implicitly aligned with the performance characteristics of the predicate devices, particularly regarding mechanical properties, biocompatibility, sterilization, and MR compatibility.
Acceptance Criteria Category | Specific Criteria | Reported Device Performance |
---|---|---|
Mechanical Properties | Fatigue strength according to ISO 14801 standards and FDA guidance for Root-form Endosseous Dental Implants and Endosseous Dental Abutments. The criteria imply that the subject device's fatigue performance should be equal to or greater than that of the predicate devices, especially when dimensions differ (e.g., larger diameters or specific length variations that might impact stress distribution). The document explicitly mentions "not present a new worst case for performance testing." | For ComOcta Plus Abutment: Differing diameters (Ø5.5 ~ Ø7.6) and lengths (L 5, 6, 7, 7.5, 8, 9.5; L 7.5; L 5, 6, 7, 8, 8.5, 10; L 7.5; L 9.5; L 8.5; L 9.5) compared to predicate (Ø5.5 x L 6.5, 7.5, 8.5, 9.5; Ø6.5 x L 6.5, 7.5, 8.5, 9.5). Performance: "larger than predicate device, so it is considered to have equal to or greater performance than that of the predicate device." "fatigue of the proposed device is considered to be equal to or greater than that of the predicate device." Therefore, no additional fatigue testing was conducted. |
For ComOcta Milling Abutment: Lengths (L 14, L 14.35) not in predicate range, but diameter range is same. Performance: "fatigue of the proposed device is considered to be equal to or greater than that of the predicate device." No additional fatigue testing. Modifiability is within safe limits (min post height 4mm, gingival height 1-3mm, no angulation).
For Port Abutment: Larger diameter (Ø6.06) compared to predicate (Ø4.8), same length range. Performance: "added diameter is bigger than reference device and the lengths 3.5~6.5mm is same as the range of reference device." "not received single load because this is used for making overdenture that means load is dispersed to the full denture. Therefore, we don't consider additional fatigue testing."
For O-ring Abutment: Larger diameter (Ø4.3) compared to predicate (Ø3.5), same gingiva height range. Performance: "added diameter is bigger than reference device and the gingiva height 0~4mm is same as the range of predicate device." "not received single load because this is used for making overdenture that means load is dispersed to the full denture. Therefore, we don't consider additional fatigue testing."
For Closing Screw: Longer dimensions than predicate. Performance: "does not affect safety and effectiveness because it is used to protect the exposed platform of the implant during healing period." No additional fatigue testing. |
| Biocompatibility | Compliance with FDA Guidance Document Use of International Standard ISO 10993-1. The material composition of the device should be safe for biological contact. | "The SS Abutment System has same materials, manufacturer, manufacturing process etc., as predicate devices. Therefore, we didn't conduct additional biocompatibility test." |
| Sterilization Validation | Demonstrated sterility and maintenance of sterility throughout the claimed shelf-life. The sterilization process should be validated and consistent with predicate devices or established methods. | "Validation of the gamma irradiation process was previously conducted for the predicated device. There has been no change to the manufacturing or sterilization processes since then and the subject devices do not present a new worst case for sterilization validation; therefore, additional validation is not required." |
| Shelf-life | Stability and integrity of the device over its claimed shelf-life. | "SS Abutment System are made with titanium and titanium alloy we don't consider about shelf life of material by itself because this metal is widely known that it generally has no adversely affect by aging. Therefore we certify that product such like metal has no shelf life." The predicate device likely had an 8-year shelf life for some components (e.g., Closing Screw), and this is maintained where applicable. |
| MR Compatibility | Safety in the Magnetic Resonance (MR) Environment, including assessment of magnetically induced displacement force and torque, per FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment." | "Non-clinical worst-case MRI review was performed to evaluate the Subject device components in the MRI environment using scientific rationale and published literature (e.g., Woods, Terry O., Jana G. Delfino, and Sunder Rajan, "Assessment of Magnetically Induced Displacement Force and Torque on Metal Alloys Used in Medical Devices." Journal of Testing and Evaluation 49.2 (2019): 783-795), based on the entire system including all variations (all compatible implant bodies, abutments, and fixation screws) and material composition. Rationale addressed parameters per the FDA guidance." |
2. Sample size used for the test set and the data provenance
The document does not describe a traditional "test set" in the context of a clinical performance study. Instead, performance is established through non-clinical testing and comparison to predicate devices, often leveraging the fact that the subject device either has:
- Identical characteristics to a predicate.
- Dimensions that are considered to offer equivalent or superior performance (e.g., larger diameter on an implant component).
- A different intended use/loading condition (e.g., overdenture dispersing load) that mitigates concerns about increased stress from dimensional changes.
Therefore, there is no sample size for a "test set" from patients or images. The "samples" would be the configurations of the devices tested in laboratory settings (e.g., for fatigue), or the material samples for biocompatibility, or the specific device designs analyzed for MR compatibility. The document does not specify the number of units tested for any of these non-clinical evaluations, but refers to "worst-case scenarios" for mechanical testing, which implies selection of specific configurations deemed most challenging.
Data Provenance: Not applicable as no human or image data is used for performance testing. The "data" comes from laboratory physical testing, material standards, and scientific literature.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
Not applicable. As this is a non-clinical submission based on substantial equivalence to predicate devices and established standards (e.g., ISO, ASTM, FDA guidance), there is no "ground truth" derived from expert consensus on patient data. The "truth" is based on adherence to engineering and material science principles, and regulatory guidelines.
4. Adjudication method for the test set
Not applicable for the reasons outlined in point 3.
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 physical dental implant abutment, not an AI-powered diagnostic or assistive tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical medical device, not a software algorithm.
7. The type of ground truth used
The "ground truth" for this submission is based on:
- Standards and Guidance Documents: ISO 14801 for fatigue testing, ISO 10993-1 for biocompatibility, and FDA guidance documents for dental implants and MR compatibility.
- Material Science: Established properties of Titanium Alloy (ASTM F136), Titanium Gr 3 & 4 (ASTM F67), and POM (Polyoxymethylene).
- Existing Validations: Relying on previous biocompatibility, sterilization, and shelf-life validations performed for predicate devices with identical materials, manufacturing processes, or for which the subject device does not represent a new worst-case.
- Scientific Rationale: For MR compatibility, scientific literature and rationale are used.
8. The sample size for the training set
Not applicable. This is a physical medical device, not a machine learning model requiring a training set.
9. How the ground truth for the training set was established
Not applicable for the reasons outlined in point 8.
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(336 days)
The OSSTEM Implant System - Abutment is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures.
The OSSTEM Implant System - Abutment is intended for use as an aid in prosthetic restoration. It consists of Abutments, components and Abutment Screws.
This document is a 510(k) Premarket Notification of the OSSTEM Implant System - Abutment, indicating it is a dental device and not an AI/ML medical device. Therefore, the information requested in the prompt, which pertains to the acceptance criteria and study proving an AI/ML device meets those criteria, cannot be fully provided from this document.
The document discusses the substantial equivalence of the OSSTEM Implant System - Abutment to predicate devices. This typically involves demonstrating that the new device is as safe and effective as a legally marketed predicate device, often through material comparisons, design comparisons, and performance testing for mechanical properties and biocompatibility, rather than clinical studies or performance against defined efficacy metrics tied to patient outcomes.
However, I can extract information related to the device and the type of testing performed that is relevant to its acceptance for market.
Here's a breakdown based on the provided text, addressing the points of your prompt where applicable, and highlighting what's not present due to the nature of the device:
Device Description: The OSSTEM Implant System - Abutment is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures. It consists of Abutments, components, and Abutment Screws.
Acceptance Criteria and Device Performance (General):
For this type of device, "acceptance criteria" revolve around demonstrating substantial equivalence to existing, legally marketed predicate devices. This means proving the new device is as safe and effective as the predicate. The performance is assessed through:
- Material composition: Comparing the materials used (e.g., Titanium Alloy, Zirconia, PEEK, PC, POM).
- Design and dimensions: Comparing the shapes, diameters, and lengths.
- Intended use: Confirming the device serves the same purpose.
- Technological characteristics: Ensuring the fundamental mechanism of action is similar.
- Nonclinical testing: Biocompatibility, sterilization validation, and mechanical properties.
Table of Acceptance Criteria and Reported Device Performance (as inferred from a 510(k) for a non-AI/ML device):
Acceptance Criteria Category | Specific Criteria (Inferred for a Dental Abutment) | Reported Device Performance (as demonstrated by comparison to predicates) |
---|---|---|
Intended Use | Must be for use with dental implants to support prosthetic restorations. | Identical to predicate devices for all components. (e.g., page 7: "Indication for use of subject device is slight differences in phrase with predicate but fundamental Indication is same") |
Materials | Must use materials with established biocompatibility and mechanical properties for dental implants. | Identical to predicate devices (e.g., Titanium Alloy (Ti-6Al-4V), Zirconia, PEEK, PC, POM), or demonstrating equivalence if slight variations exist. (e.g., page 7: "Material: Zirconia, Identical"; page 8: "Material: Titanium Alloy PEEK, Identical") |
Design/Dimensions | Must be geometrically compatible with specified implant systems and suitable for intended restorations. | Substantially Equivalent or Identical designs and dimensions. Some new dimensions are added but fall within accepted ranges, or minor cosmetic/functional modifications are made that do not raise new safety/effectiveness questions. (e.g., page 7 "Connection structure is different (Hex and Non-Hex) but Design is Substantial Equivalence"; page 8 "Diameter 4.0mm is added"; page 9 "Design is Substantial Equivalence With highlighted predicate with red Box") |
Technological Characteristics | Must function physically in a manner similar to predicate dental abutments (e.g., cement-retained, screw-retained). | Identical to predicate devices (e.g., page 7 "Use for making general cement-type prosthesis. Identical"; page 8 "Cement retained restoration. Capable of altering/removing shape of plastic material. Two piece (Abutment + Screw) Identical") |
Biocompatibility | Must be biocompatible, as per ISO 10993 standards. | Relying on identical materials and manufacturing processes as previously cleared predicate devices. "Therefore, no additional testing is necessary." (page 11) |
Sterilization | Must be able to be sterilized to an appropriate Sterility Assurance Level (SAL). | For Custom Healing Abutment, leveraged data from predicate device (ISO 11137-1, -2, -3 and shelf life testing). For other non-sterile devices, steam sterilization validation conducted per ISO 17665-1 and -2. (page 11) |
Mechanical Performance | Must withstand normal forces and maintain integrity in the oral cavity. Generally, this would be mechanical testing. | The document does not explicitly detail the mechanical performance results in a table format, but states that the device is "substantially equivalent in design, function and intended use" to predicates. This implies mechanical performance is considered equivalent due to material and design similarity, and potentially prior testing on the predicate devices. The listed nonclinical tests (like "tensile test (ASTM F882), seal peel test (ASTM F88/EN868-5), burst test (ASTM F1140), dye penetration (ASTM F1929), bubble test (ASTM F2096)") mentioned under sterilization validation are related to packaging and sterility, not the inherent mechanical strength of the abutment itself, which would be covered by separate mechanical testing for dental implants if required for initial approval. For this 510(k), they rely on the substantial equivalence premise. |
Here's how the remaining points of your prompt are addressed:
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Sample sized used for the test set and the data provenance:
- Test set sample size: Not applicable in the context of an AI/ML algorithm's test set. The "testing" here refers to nonclinical lab tests and comparison to predicates.
- Data provenance: Not directly applicable. The "data" are internal company reports demonstrating compliance with standards or comparisons to their own previously cleared devices. The manufacturer is OSSTEM Implant Co., Ltd. and their correspondent is HIOSSEN Inc., based in Republic of Korea and Pennsylvania, USA, respectively. The data are typically generated in a prospective manner for regulatory submission (i.e., tests are performed specifically for the submission).
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable as this is a physical medical device, not an AI/ML algorithm requiring ground truth from experts for image interpretation or diagnosis.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. This concept pertains to consolidating expert opinions for ground truth in AI/ML performance studies.
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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:
- No MRMC study was done, as this is not an AI/ML device. The document explicitly states: "No clinical studies are submitted." (page 12)
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable, as this is not an AI/ML device.
-
The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable. For this device, "ground truth" is embodied by established engineering specifications, material properties, and performance benchmarks for dental implants, which are verified through nonclinical laboratory testing against international standards (e.g., ISO, ASTM) and comparison to predicate device characteristics.
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The sample size for the training set:
- Not applicable. There is no concept of a "training set" for this type of conventional physical device.
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How the ground truth for the training set was established:
- Not applicable. (See #7).
Summary of Acceptance:
The device's acceptance (clearance) by the FDA is based on demonstrating substantial equivalence to existing predicate devices (listed in section 3 and 6) in terms of:
- Indications for Use: Identical.
- Technological Characteristics: Very similar, with minor differences in design/dimensions that do not raise new safety/effectiveness concerns.
- Materials: Identical.
- Performance (Nonclinical): Biocompatibility is leveraged from predicate devices; sterilization validated according to relevant ISO standards.
The document explicitly states: "No clinical studies are submitted." This reinforces that the acceptance was based on nonclinical testing and comparison to predicates, as is common for many Class II medical devices in the 510(k) pathway.
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(411 days)
ET System: The HIOSSEN Prosthetic system is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or over-dentures.
US/SS System: The OSSTEM Prosthetic system is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or over-dentures.
The ET US SS Prosthetic system is intended for use as an aid in prosthetic restoration. It is consisted of abutments, components and abutment screws.
The provided document is a 510(k) Premarket Notification from the FDA for a dental prosthetic system. It details the device, its intended use, and its substantial equivalence to predicate devices based on nonclinical testing. However, it does not contain acceptance criteria for device performance, nor does it describe a study proving the device meets specific performance criteria in terms of clinical effectiveness or accuracy.
Instead, the document focuses on demonstrating substantial equivalence to existing legally marketed devices, which is a different regulatory pathway than proving novel performance. Substantial equivalence is established by showing that the new device has the same intended use and the same technological characteristics as the predicate device, or, if it has different technological characteristics, that the different characteristics do not raise new questions of safety and effectiveness and that the device is as safe and effective as the predicate device.
Here's an analysis of the information available in the document, keeping in mind that it's a substantial equivalence filing rather than a performance validation study against acceptance criteria:
1. Table of Acceptance Criteria and Reported Device Performance
This information is not provided in the document. The document primarily identifies the device's characteristics (materials, dimensions, intended use) and compares them to predicate devices to establish substantial equivalence. It does not list quantitative acceptance criteria for clinical performance (e.g., accuracy, sensitivity, specificity, or success rates) or specific performance metrics that the device is intended to meet.
2. Sample Size Used for the Test Set and Data Provenance
This information is not applicable in the context of the provided document. The submission explicitly states:
- "No clinical studies are submitted." (Page 22)
- The nonclinical testing primarily involves fatigue testing and biocompatibility evaluations, which are typically performed on samples of the device components rather than a "test set" of patient data. The sample sizes for these engineering tests are not specified in this summary.
- Data provenance for clinical data is not applicable as no clinical data was submitted.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This information is not applicable as no clinical studies with a test set requiring ground truth establishment by experts were submitted.
4. Adjudication Method for the Test Set
This information is not applicable as no clinical studies with a test set requiring adjudication were submitted.
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 information is not applicable. The device described is a physical dental prosthetic system (abutments, screws, caps), not an AI-powered diagnostic or assistive tool. Therefore, an MRMC study and AI-related effect sizes are not relevant to this submission.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was Done
This information is not applicable for the same reason as point 5. The device is a physical prosthetic, not an algorithm.
7. The Type of Ground Truth Used
This information is not applicable as no clinical studies requiring ground truth were submitted. The basis for safety and effectiveness is substantial equivalence to predicate devices, supported by nonclinical testing (fatigue, biocompatibility, sterilization validation).
8. The Sample Size for the Training Set
This information is not applicable. There is no mention of a "training set" as this device is not an AI/machine learning product and no clinical data or algorithms are being trained.
9. How the Ground Truth for the Training Set Was Established
This information is not applicable as there is no training set mentioned in relation to this device.
Summary of the Study and "Acceptance Criteria" (as interpreted from the document's context):
The "study" described in the document is primarily focused on nonclinical testing and demonstrating substantial equivalence to predicate devices rather than fulfilling specific performance acceptance criteria for clinical outcomes.
Acceptance Criteria (Implicit from Substantial Equivalence):
From the context of a 510(k) submission, the "acceptance criteria" are implicitly met if the device can demonstrate that it is as safe and effective as a legally marketed predicate device. This is achieved by showing:
- Same Intended Use: The ET US SS Prosthetic system is intended for use with a dental implant to provide support for prosthetic restorations (crowns, bridges, over-dentures), which is identical to the indications for use of its identified predicate and reference predicate devices (e.g., K062030, K130662).
- Same Technological Characteristics OR Equivalent Safety/Effectiveness with Different Characteristics:
- Material: Titanium Alloy, PEEK, Polymer (Polycarbonate, POM) – consistent with predicate devices.
- Design & Function: Described as similar in various components (e.g., Quick Temporary Abutment, Solid Abutment, ComOcta Abutment, Healing Abutment, Ti Screw, O-ring Abutment, Multi Angled Abutment, Esthetic-low Temporary Cylinder). Where there are differences (e.g., new dimensions, slight shape changes, different connection structures for Multi Angled Abutments), the submission asserts that these differences "do not raise new questions of safety and effectiveness" and that the device maintains "same principles of operation, function, material, characteristic and intended use."
- Biocompatibility: Stated to be the same as predicates, thus requiring no additional testing.
- Sterilization: For Cover Screw and Healing Abutment, considered substantially equivalent to a predicate. Other components are non-sterile and require steam sterilization validation according to ISO 17665-1:2006. The results implicitly meet the standard.
- Fatigue Testing: Performed according to "Guidance for industry and FDA staff Class II Special Controls Guidance Document Root-form Endosseous Dental Implants and Endosseous Dental Abutment" with a worst-case scenario. The implied acceptance is that the device met the fatigue strength requirements comparable to the predicate devices or within safe limits for its intended use, ensuring structural integrity. Specific results or detailed criteria are not laid out, but the successful completion of these tests supports substantial equivalence.
Reported Device Performance (from the perspective of 510(k) substantial equivalence):
The document reports the device's performance by demonstrating its similarities to predicate devices across various characteristics:
- Materials: Predominantly Titanium Alloy (ASTM F 136), Titanium (ASTM F 67), and various polymers (PEEK, Polycarbonate, PolyOxy Methylene). These are well-established materials in dental prosthetics, matching those of the predicate devices.
- Dimensions: Various diameters and heights are listed for each component, often including new dimensions that are added to existing product lines. The claim is that these new dimensions do not alter the fundamental safety or effectiveness and maintain the "same principles of operation, function, material, characteristic and intended use" as the predicate devices.
- Functional Principles: Described for each component (e.g., "Used to make temporary prosthesis," "Used in producing ordinary cement-retained prosthetics," "Connect an abutment with fixture by screw"). These are consistently aligned with the predicate device functions.
- Nonclinical Test Results:
- Biocompatibility: Implicitly deemed acceptable due to using the same materials, manufacturing processes, surface treatments, and sterilization methods as legally marketed predicate devices.
- Sterilization Validation: Cover Screw and Healing Abutment results are "considered to be substantial equivalent" to a specific predicate, indicating adequate sterilization protocols. Other non-sterile devices underwent steam sterilization validation to ISO 17665-1:2006, implying successful validation.
- Fatigue Testing: Performed on a "worst-case scenario" sample, suggesting that the device's mechanical durability was assessed and found satisfactory based on the relevant guidance document, thereby supporting its structural integrity and equivalence.
In conclusion, the document demonstrates that the ET US SS Prosthetic System meets the "acceptance criteria" for a 510(k) submission by establishing its substantial equivalence to predicate devices through a comparison of technological characteristics and successful nonclinical testing for biocompatibility, sterilization, and fatigue. No clinical performance criteria or studies are presented.
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