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510(k) Data Aggregation
(229 days)
To relieve dental hypersensitivity caused by bleaching procedures, cold, heat, acids, or sweets.
ReminGel is a convenient, premixed, ready-to-use, opaque aqueous-based gel. ReminGel consists of suspended hydroxyapatite and calcium and phosphate salts that help restore a tooth's hydroxyapatite structure through remineralization. This remineralization results in tubule occlusion and blocks fluid flow in dentinal tubules, thereby relieving dentinal sensitivity. ReminGel blocks nerve excitability through potassium release. ReminGel is packaged in a 3oz (90mL) tube. ReminGel is for prescription use (Rx) and over-the-counter (OTC) use. ReminGel can be applied to teeth using dental appliances (e.g. fluoride tray, whitening tray, periotray, etc.) or via a toothbrush.
Here's a breakdown of the acceptance criteria and study information for ReminGel, based on the provided FDA 510(k) summary:
Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Anticipated Performance) | Reported Device Performance (ReminGel) |
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Tubule Occlusion: Visibly occlude dentinal tubules to inhibit dentin sensitivity. | Visibly occluded dentinal tubules, demonstrating inhibition of dentin sensitivity. (Identical to predicate device Super Seal) |
Shelf-Life: Minimum of 2 years. | 2 years (determined through accelerated shelf-life testing; real-time aging ongoing). |
Transit Performance: Withstand simulated transit conditions. | Performed satisfactorily post-transit, confirming no negative effect on the product. |
Cytotoxicity: Demonstrate acceptable levels of biocompatibility. | Yielded better cytotoxicity results compared to the predicate device, SuperSeal. |
Irritation: Be a non-irritant. | Found to be a non-irritant. |
Sensitization: Be a non-sensitizing agent. | Found to be a non-sensitizing agent. |
Study Details
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Sample Size used for the test set and data provenance:
- Tubule Occlusion Testing: Resected human teeth were used. The exact sample size ("N") is not specified.
- Biocompatibility Testing (Cytotoxicity, Irritation, Sensitization): Not specified in terms of human subjects or teeth. These are in vitro and in vivo tests, typically performed on cell cultures or animal models for initial screening (as per ISO 10993 standards listed). The document does not provide details on the specific samples used for these tests.
- Shelf-Life Testing: Not specified.
- Transit Testing: Not specified.
- Data Provenance: Not explicitly stated, but based on the in vitro nature of the tubule occlusion study on "resected human teeth," it implies laboratory testing rather than a clinical trial in patients. The biocompatibility tests are also laboratory-based. It is retrospective in the sense that the results were gathered and submitted as part of the 510(k) submission, not a prospective clinical trial.
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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/Not specified. The studies cited are non-clinical (laboratory/bench testing). For tubule occlusion, the "ground truth" would be the visible occlusion as observed through microscopy, which doesn't directly involve multiple expert adjudicators for "truth" establishment in the way clinical images would.
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Adjudication method for the test set:
- Not applicable. As the studies are non-clinical, there is no expert adjudication method like 2+1 or 3+1 typically used for clinical image interpretation.
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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 conducted. This device (ReminGel) is a medical product (cavity varnish) and not an AI/software-as-a-medical-device that would typically involve human readers and AI assistance for interpretation.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an algorithm or AI device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Tubule Occlusion: Visual observation of dentinal tubule occlusion (likely microscopic evaluation).
- Shelf-Life: Measured physical and chemical properties over time.
- Transit, Cytotoxicity, Irritation, Sensitization: Results from standardized laboratory test methods (e.g., ISO 10993 series).
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The sample size for the training set:
- Not applicable. This is a medical product, not a machine learning/AI model that requires a training set.
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How the ground truth for the training set was established:
- Not applicable, as there is no training set for this type of device.
Overall Context: The 510(k) summary focuses on demonstrating substantial equivalence to a predicate device (Super Seal) and a reference device (Senzzzz Away) through non-clinical performance and biocompatibility testing, rather than extensive clinical efficacy trials. Clinical performance was explicitly "not deemed necessary" for this submission, likely due to the established mechanism of action and similarity to legally marketed devices.
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(279 days)
Treatment of dentinal hypersensitivity. For use in adults over the age of 21.
Riva Star is a two-component device made up of Riva Star Step 1, containing silver diamine fluoride liquid, and Riva Star Step 2, containing aqueous potassium iodide liquid. Riva Star Step 1 silver diamine fluoride solution is applied to the tooth, immediately followed by Riva Star Step 2 aqueous potassium iodide, which forms an immediate reaction precipitate of silver iodide, thereby reducing tooth sensitivity by physically occluding the open dentinal tubules. Riva Star as well as predicates are liquids or gels that are applied to the teeth using an applicator brush or similar application.
The provided text describes the performance and equivalency of the device "Riva Star" to predicate devices, primarily "Advantage Arrest" and "Super Seal," for the treatment of dentinal hypersensitivity. However, the text does not contain a formal table of "acceptance criteria" and subsequent "reported device performance" against those criteria in a structured format. Instead, it discusses comparability to predicate devices and results from various tests, which indirectly serve as evidence of the device's acceptable performance.
Based on the information provided, here's a structured response outlining the key aspects:
1. Table of Acceptance Criteria and Reported Device Performance
As there is no explicit table of quantitative acceptance criteria provided in the text, I will infer what appears to be the implicit acceptance criteria from the non-clinical and clinical performance testing sections and present the reported performance of Riva Star against those objectives. The primary objective is substantial equivalence to predicate devices.
Implicit Acceptance Criterion | Reported Riva Star Performance |
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I. Substantial Equivalence to Predicate Devices | |
1. Similar Indications for Use | Met: Indications for Use are identical to primary predicate device Advantage Arrest ("Treatment of dentinal hypersensitivity. For use in adults over the age of 21."). Differences in phrasing with reference predicates do not change the overall intended purpose. |
2. Similar Technological Characteristics/Mode of Action | Met: Both Riva Star and primary predicate Advantage Arrest employ silver diamine fluoride to form precipitates and occlude open dentinal tubules. While Riva Star uses potassium iodide for an immediate silver iodide precipitate, and Advantage Arrest reacts with hydroxyapatite, both achieve tubule occlusion. This is considered substantially equivalent. The mode of action (tubule occlusion) is also similar to the oxalate-based reference predicates. |
3. Effective Reduction of Fluid Flow through Dentin (Hydraulic Conductance) | Met: Hydraulic Conductance study demonstrated Riva Star is an effective agent to reduce fluid flow through dentine and is "substantially equivalent to Super Seal in treating dentinal hypersensitivity." |
4. Formation of Precipitate to Occlude Dentinal Tubules (SEM) | Met: Scanning electron microscope (SEM) images showed both Riva Star and Super Seal formed a precipitate to occlude the open dentinal tubules. |
5. Safety (Biocompatibility/Ion Release) | Met: |
- Ion Release: Riva Star released less fluoride and silver ions compared to primary predicate Advantage Arrest in a 7-day in vitro study, "demonstrating that Riva Star is as safe as Advantage Arrest."
- Biocompatibility: Passed Cytotoxicity (ISO Agarose, ISO Direct contact), Sensitisation (ISO Guinea Pig Maximization Sensitization), Oral Mucosal Irritation (Hamsters, collar method, 7 day), and Oral Acute Toxicity (Mice - 7 day) tests, providing "evidence of biocompatibility." Cytotoxicity results were "equivalent" to Advantage Arrest. |
| 6. Shelf Life | Met: Stability testing established a shelf life of "25 months when stored between 2ºC (35ºF) to 8ºC (45ºF)." |
| 7. Clinical Effectiveness in Reducing Dentinal Hypersensitivity | Met: A double-blind randomized clinical trial showed that "Riva Star was more effective than Super Seal in reducing dentine hypersensitivity after 7 days." This demonstrates clinical effectiveness, furthering the case for substantial equivalence. |
2. Sample Size Used for the Test Set and Data Provenance
- Non-Clinical Hydraulic Conductance Study: Not explicitly stated how many dentin samples were used.
- Non-Clinical In Vitro Ion Release Study: Not explicitly stated how many samples of Riva Star and Advantage Arrest were tested.
- Biocompatibility Studies (Animals):
- Sensitization: Guinea Pigs (sample size not specified)
- Oral Mucosal Irritation: Hamsters (sample size not specified)
- Oral Acute Toxicity: Mice (sample size not specified)
- Clinical Performance Testing:
- Sample Size: Patients with "recognisable tooth sensitivity on both sides of their upper arch" (Exact number of patients/teeth not specified, but implied to be sufficient for a randomized clinical trial).
- Data Provenance: The study was a "double blind randomised clinical trial on patients." The country of origin is not explicitly stated in the provided text.
- Retrospective or Prospective: Prospective (clinical trial).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
- Clinical Performance Testing: Ground truth (reduction in dentinal hypersensitivity) was established by patient responses recorded on a Visual Analogue Scale (VAS). This indicates self-reported patient pain levels, not expert consensus as the primary ground truth.
- Non-Clinical Studies: Ground truth for hydraulic conductance, SEM imaging, ion release, and biocompatibility was established through objective laboratory measurements and biological assays, not expert consensus on images or interpretations.
4. Adjudication Method for the Test Set
- Clinical Performance Testing: The primary "ground truth" was patient-reported pain levels via Visual Analogue Scale (VAS). This is a self-adjudication method. The trial was "double blind randomized," suggesting measures were taken to prevent bias in data collection and interpretation. No external expert adjudication method (e.g., 2+1, 3+1) is mentioned for the clinical trial.
- Non-Clinical Studies: No adjudication method as these involved objective laboratory measurements.
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
- No, an MRMC comparative effectiveness study involving human readers or AI assistance was not mentioned. The device, Riva Star, is a dental product (tooth desensitizer), not an imaging or diagnostic AI-powered device that would typically undergo such a study design.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. Riva Star is a physical product (liquid solution) applied by a clinician, not an algorithm.
7. The Type of Ground Truth Used
- Non-Clinical Studies (Hydraulic Conductance, SEM, Ion Release, Stability): Objective laboratory measurements and observations (e.g., fluid flow rate, microscopic images showing precipitate formation, ion concentrations, physical property measurements).
- Biocompatibility Studies: Biological assay results (e.g., cell viability, observed irritation/sensitization responses in animal models).
- Clinical Performance Testing: Patient-reported outcomes (self-reported pain levels) using a Visual Analogue Scale (VAS).
8. The Sample Size for the Training Set
- Not applicable. Riva Star is a physical medical device, not an AI/machine learning algorithm requiring a training set.
9. How the Ground Truth for the Training Set was Established
- Not applicable, as there is no training set for this device.
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