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510(k) Data Aggregation
(80 days)
DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
All digitally designed custom abutments for use with DESS Bases or Pre-milled Blanks are to be sent to a Terrats Medical validated milling center for manufacture, or to be designed and manufactured according to the digital dentistry workflow. The digital dentistry workflow integrates multiple components: scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, ceramic material, milling machine, and associated tooling and accessories.
The purpose of this submission is to expand the DESS Dental Smart Solutions abutment system cleared under K221301 and K240982 to allow additional options of zirconia material, scanners, CAM software, and milling machines to the digital dentistry workflow. The subject devices are to be sent to Terrats Medical validated milling centers for manufacture, or to be designed and manufactured via a digital dentistry workflow. The digital dentistry workflow integrates multiple components: scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, titanium and ceramic material, milling machine, and associated tooling and accessories. There are no changes to the abutment design, implant compatibilities, or design parameters. All part numbers have been cleared for manufacturing via a validated milling center and digital dentistry workflows (also referred to as point of care) under K221301 and K240982.
The subject device DESS Dental Smart Solutions abutments provide a range of prosthetic solutions for dental implant restoration. DESS abutments are offered in a variety of connection types to enable compatibility with currently marketed dental implants. All abutments are provided non-sterile, and each abutment is supplied with the appropriate abutment screw (if applicable) for attachment to the corresponding implant.
Subject device Base Abutments are designed for fabrication of a patient-specific CAD/CAM zirconia superstructure on which a crown may be placed. They are two-piece abutments for which the second part (or top half) is the ceramic superstructure. They also may be used for support of a crown directly on the abutment.
All patient-specific custom abutment fabrication for Base Abutments and Pre-milled (Blank) Abutments is by prescription on the order of the clinician. The subject device Pre-milled (Blank) Abutments and all zirconia superstructures for use with the subject device Ti Base Interface, DESS Aurum Base, ELLIPTIBase, and DESS C-Base will be manufactured using a validated milling center or a digital dentistry workflow. A validated milling center will be under FDA quality system regulations. The digital dentistry workflow scans files from intra-oral and lab (desktop) scanners, CAD software, CAM software, titanium and ceramic material, milling machine and associated tooling and accessories.
The digital dentistry workflow uses scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
The provided 510(k) summary for DESS Dental Smart Solutions focuses on demonstrating substantial equivalence to predicate devices for dental implant abutments. It primarily addresses the expansion of compatible materials, scanners, CAM software, and milling machines within an existing digital dentistry workflow. The document does not describe an AI/ML-based device that would typically have acceptance criteria related to diagnostic performance.
Therefore, many of the requested items related to AI/ML device performance (like acceptance criteria for diagnostic metrics, sample size for test sets, data provenance, expert qualifications, adjudication methods, MRMC studies, standalone performance, and training set details) are not applicable to this submission.
The acceptance criteria and supporting "study" (non-clinical data) for this device are related to its mechanical performance, biocompatibility, and integration within the digital workflow, demonstrating that the expanded components maintain the safety and effectiveness of the previously cleared predicate devices.
Here's a breakdown based on the information provided and the non-applicability of AI/ML-specific questions:
1. A table of acceptance criteria and the reported device performance
Since this is not an AI/ML diagnostic device, the acceptance criteria are not in terms of traditional diagnostic metrics (sensitivity, specificity, AUC). Instead, they are related to material properties, mechanical integrity, and the digital workflow's accuracy.
Acceptance Criteria Category | Reported Device Performance (Summary from Submission) |
---|---|
Mechanical Integrity / Compatibility | - Fatigue testing of OEM implant bodies with patient-specific abutments made at worst-case angled conditions. (Implies successful completion to similar or better standards than predicate.) |
Biocompatibility | - Biocompatibility testing according to ISO 10993-5 and ISO 10993-12. (Implies successful demonstration of biocompatibility.) |
Sterilization | - Sterilization validation according to ISO 17665-1, ISO 17665-2, and ISO 14937. (Implies successful validation for sterilization.) |
CAD Design Restrictions | - Software verification included testing of restrictions that prevent design of components outside of the stated design parameters. |
- Abutment design library validated to demonstrate established design limitations are locked and cannot be modified by the user. (Implies successful implementation and verification of design constraints.) |
| CAM Restriction Zones / Manufacturing Accuracy | - Validation testing of CAM restriction zones conducted, including verification to show avoidance of damage or modifications of the connection geometry, and locking of restriction zones from user editing in CAM software. (Implies successful validation to ensure manufacturing precision and prevent damage.) |
| Material Conformance | - Zirconia materials conform to ISO 6872. - Titanium alloy conforms to ASTM F136.
- Co-Cr-Mo alloy conforms to ASTM F15337. (Implies materials meet standards.) |
| Physical Dimensions | - Device encompasses the same range of physical dimensions as the predicate device. (Implies dimensional equivalence.) |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: Not explicitly stated in terms of a "test set" for diagnostic performance. The validation involved physical testing of components (e.g., fatigue testing) and software verification. The specific number of abutments or digital design instances used for these non-clinical tests is not detailed in this summary.
- Data Provenance: Not applicable in the context of patient data for an AI/ML device. The "data" here refers to engineering and material testing results, likely conducted in controlled lab environments (implied to be in accordance with international standards like ISO and ASTM). The manufacturer is Terrats Medical SL, in Spain, so testing would likely originate from their facilities or contracted labs.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. This is not a diagnostic device requiring expert interpretation for ground truth. The "ground truth" for this device relates to engineering specifications and material science.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is not a diagnostic device involving expert review adjudication.
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 not an AI-assisted diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an AI/ML algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
For this device, the "ground truth" is based on:
- Engineering Specifications: Defined design parameters (e.g., minimum wall thickness, post height, angulation limits).
- Material Standards: Conformance to international standards such as ASTM F136, ISO 6872.
- Benchmarking/Predicate Equivalence: Performance is assessed against established performance of the predicate devices and OEM implant systems.
- Software Validation Logic: Verification that software correctly enforces design rules and CAD/CAM restrictions.
8. The sample size for the training set
Not applicable. This device does not involve a machine learning training set.
9. How the ground truth for the training set was established
Not applicable. This device does not involve a machine learning training set.
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(138 days)
DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
The purpose of this submission is to expand the DESS Dental Smart Solutions abutment system cleared under K221301 to add the ability for the subject device Base Abutments and Pre-milled (Blank) Abutments to be designed using AbutmentCAD software in the digital dentistry workflow, as well as add angulation to some of the Pre-Milled (Blank) Abutments. The subject devices are to Terrats Medical validated milling centers for manufacture, or to be designed and manufactured via a digital dentistry workflow. The digital dentistry workflow integrates multiple components: scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, titanium and ceramic material, milling machine, and associated tooling and accessories. The proposed change is to allow the subject devices to be designed using AbutmentCAD by exocad GmbH, the current workflow allows only the use of 3Shape by 3Shape A/S for the design software. Another purpose of this submission is to expand the design parameters to allow angulation (up to 30°) on Pre-milled (Blank) Abutments that are compatible with Neodent Grand Morse, Nobel Active/Nobel Parallel Conical 3.0 mm, and Straumann BLX implants. There are no changes to the abutment design or implant compatibilities. All part numbers have been cleared for manufacturing via a validated milling center and digital dentistry workflows in under K221301.
The subject device DESS Dental Solutions abutments provide a range of prosthetic solutions for dental implant restoration. DESS abutments are offered in a variety of connection types to enable compatibility with currently marketed dental implants. All abutments are provided non-sterile, and each abutment is supplied with the appropriate abutment screw (if applicable) for attachment to the corresponding implant.
Subject device Base Abutments are designed for fabrication of a patient-specific CAD/CAM zirconia superstructure on which a crown may be placed. They are two-piece abutments for which the second part (or top half) is the ceramic superstructure. They also may be used for support of a crown directly on the abutment.
All patient-specific custom abutment fabrication for Base Abutments and Pre-milled (Blank) Abutments is by prescription on the order of the clinician. The subject device Pre-milled (Blank) Abutments and all zirconia superstructures for use with the subject device Ti Base Interface, DESS Aurum Base, ELLIPTIBase, and DESS C-Base will be manufactured using a validated milling center or a digital dentistry workflow. A validated milling center will be under FDA quality system regulations. The digital dentistry workflow scans files from intra-oral and lab (desktop) scanners, CAD software, titanium and ceramic material, milling machine and associated tooling and accessories.
The digital dentistry workflow uses scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories. The digital workflow includes the following products (not subject devices of this submission):
- Ceramic material: VITA YZ ST and VITA YZ XT (K180703)
- . Cement: Ivoclar Vivadent Multilink Hybrid Abutment Cement (K130436)
- . Intraoral Scanner: 3Shape TRIOS A/S Series Intraoral Scanner (510(k) exempt under 21 CFR 872.3661)
- Desktop scanner: 3Shape D900 Dental Lab Scanner (510(k) exempt under 21 CFR 872.3661)
- Abutment design software: 3Shape Abutment Designer Software (K151455) and AbutmentCAD ● (K193352)
- . Milling machine: VHF R5 by vhf camfacture AG with DentalCAM and DentalCNC 7 software
The provided text describes a 510(k) premarket notification for DESS Dental Smart Solutions, which are dental implant abutments. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving a device's effectiveness through clinical performance studies with specific statistical acceptance criteria for accuracy, sensitivity, or specificity.
Therefore, the document does not contain the information requested regarding:
- A table of acceptance criteria and reported device performance (in terms of clinical metrics like accuracy, sensitivity, specificity).
- Sample size used for the test set or its provenance.
- Number of experts used to establish ground truth or their qualifications.
- Adjudication method for the test set.
- Multi-Reader Multi-Case (MRMC) comparative effectiveness study or its effect size.
- Standalone (algorithm only) performance.
- Type of ground truth used (expert consensus, pathology, outcomes data).
- Sample size for the training set.
- How the ground truth for the training set was established.
The study described in this document focuses on non-clinical performance data to demonstrate substantial equivalence, specifically:
- Sterilization validation: According to ISO 17665-1, ISO 17665-2, and ISO 14937.
- Biocompatibility testing: According to ISO 10993-5 and ISO 10993-12.
- Fatigue testing and reverse engineering analysis: Of OEM implant bodies, OEM abutments, and OEM abutment screws to confirm compatibility. This includes fatigue testing of OEM implant bodies with patient-specific abutments made at worst-case angled conditions.
- MR Conditional labeling.
- Validation testing of CAM restriction zones: Including verification to show avoidance of damage or modifications of the connection geometry, and locking of restriction zones from user editing in the CAM software.
- Software verification: Included testing of restrictions that prevent design of components outside of the stated design parameters. The abutment design library was validated to demonstrate that established design limitations and specifications are locked and cannot be modified by the user.
The acceptance criteria and reported "performance" for this submission are based on these engineering and design validations, ensuring the device meets safety and performance standards equivalent to the predicate device, K221301. The key "performance" metrics are about maintaining physical and material integrity and compatibility.
The core of the submission is to expand the DESS Dental Smart Solutions abutment system to:
- Allow design using AbutmentCAD software (in addition to 3Shape software).
- Add angulation (up to 30°) to some Pre-milled (Blank) Abutments for specific implant systems.
The document explicitly states: "No clinical data were included in this submission." and "The subject device, the predicate device, and reference devices have the same intended use, technological characteristics, and are materials. The subject device, the predicate device, and reference devices encompass the same range of physical dimensions, manufactured by similar methods, are packaged in similar materials, and are to be sterilized using similar methods. The data included in this submission demonstrate substantial equivalence to the predicate devices listed above."
Therefore, this FDA submission is for a physical medical device (dental implant abutment) and its manufacturing/design software modifications, not an AI or diagnostic device that would involve clinical performance metrics like sensitivity or specificity.
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(246 days)
The Zfx Abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandbular arch to provide support for prosthetic restorations.
All digitally designed custom abutments or superstructures and/or hybrid abutment crowns for use with Zfx TiBase or Pre-Milled Blank Abutments are intended to be sent to a Zfx validated milling center for manufacture.
The Zfx TiBase abutments for the 03.25 mm Certain implant bodies, and 03.1 mm Eztetic implant bodies are indicated for maxillary lateral and mandibular central/lateral incisors only.
The subject device, Zfx Abutments, consists of two abutment types, a TiBase and a Pre-milled Abutment Blank, with corresponding retaining screws. Zfx Abutments are offered in a variety of connections compatible with ZimVie dental implants. All abutments and screws are provided non-sterile.
TiBase Abutments: Subject device TiBases are two-piece abutments. The pre-manufactured titanium base component is the apical part. The coronal part of the two-piece abutment is a CAD/CAM designed and manufactured superstructure. The subject device TiBase abutments are available in hexed/engaging and non-hexed/nonengaging configurations. The engaging TiBase abutments are intended for single and multi-unit restorations and the non-engaging TiBases are intended for multi-unit restorations. The superstructure is intended to be manufactured at a Zfx validated milling center.
Pre-milled Abutment Blanks: The Pre-milled Abutment Blank is a cylindrical titanium alloy abutment designed for patient-specific abutment fabrication with CAD/CAM technology. The patient-specific abutment milled from a Pre-milled Abutment Blank is secured directly to the implant using a retaining screw. Pre-milled Abutment Blanks are available in an engaging/hexed design only for single-unit and multi-unit restorations.
Retaining Screws: Corresponding retaining screws are packaged with the abutment and replacement screws are available individually. All screws are compatible with the corresponding ZimVie dental implants.
Material Composition: All subject device abutments are made of titanium alloy Ti-6Al-4V ELI conforming to ASTM F136. Screws are made of either titanium alloy Ti-6A1-4V ELI conforming to ASTM F136, or Gold-Tite® screws with stainless steel conforming to ASTM F138. Gold-Tite screws have a gold-plating conforming to ASTM B488 and ASTM B571. Zirconia superstructures for use with the TiBase Abutments are made of zirconia conforming to ISO 13356.
The provided text is an FDA 510(k) clearance letter for Zfx Abutments, and as such, it focuses on demonstrating substantial equivalence to a predicate device rather than presenting a performance study with detailed acceptance criteria and supporting data in the way a clinical study report or a formal performance evaluation report would.
Therefore, the information required to answer many of the questions regarding acceptance criteria, sample sizes, expert involvement, and ground truth establishment is not present in this document. The document primarily outlines the device's technical specifications, indications for use, and a comparison to predicate devices, supported by non-clinical testing data (mechanical testing, biocompatibility, sterilization, etc.).
However, I can extract the information that is available and explain why other requested details are missing.
Acceptance Criteria and Device Performance (Based on "Equivalence to Marketed Devices" and "Performance Data" sections):
This document describes a substantial equivalence submission, meaning the acceptance criteria are primarily demonstrated by showing the device is as safe and effective as a legally marketed predicate device. The performance is assessed through non-clinical testing to ensure it meets established standards comparable to the predicate.
Acceptance Criterion (Implicit for Substantial Equivalence) | Reported Device Performance (Non-Clinical/Design) |
---|---|
Indications for Use Equivalence | "Zfx Abutments (subject device) are substantially equivalent in design, function, material, and Indications for Use to the Primary Predicate, DESS Dental Smart Solutions abutments cleared in K222288. All are intended for use with endosseous dental implants in the maxilla and mandible to provide support for single and multi-unit restorations." |
Material Equivalence | "All subject device abutments are made of titanium alloy Ti-6Al-4V ELI conforming to ASTM F136." "Screws are made of either titanium alloy Ti-6A1-4V ELI conforming to ASTM F136, or Gold-Tite® screws with stainless steel conforming to ASTM F138." "Zirconia superstructures for use with the TiBase Abutments are made of zirconia conforming to ISO 13356." This is compared to comparable materials in the predicate. |
Product Design and Manufacturing Process Equivalence | "All digitally designed subject device abutments and primary predicate abutments are to a validated milling center for manufacture. Subject device abutments are similar in range of sizes, connections, and technological characteristics to the DESS Dental Smart Solutions, K22288." "Design parameters for the TiBase CAD/CAM zirconia superstructure are listed in the following tables (Tables 2-5)." "Design parameters for the CAD/CAM patient-specific abutment using a Pre-milled Abutment Blank are included in Table 6." |
Sterilization Efficacy (Non-clinical) | "sterilization validation according to ISO 17665-1" |
Biocompatibility (Non-clinical) | "biocompatibility testing according to ISO 10993-1 Table A-1, ISO 10993-5, and ISO 10993-10" |
Reprocessing Validation (Non-clinical) | "reprocessing validation according to ISO 17665-2" |
Mechanical Strength/Fatigue (Non-clinical) | "mechanical testing according to ISO 14801 to determine that the subject device has sufficient strength for its intended use." |
MR Safety (Non-clinical) | "MR Safety testing was conducted according to ASTM F2052, ASTM F2213, ASTM F2182, and ASTM F2119 for a determination of MR Conditional." |
Compatibility with Existing Systems | "reverse engineering analysis to confirm compatibility with the Sirona inCoris Meso Blocks" (for TiBase). |
Missing Information and Explanations:
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Sample size used for the test set and the data provenance (e.g., country of origin of the data, retrospective or prospective):
- Not provided. This document details a 510(k) submission based on non-clinical testing for substantial equivalence, not a clinical trial or performance study with human data. The "Performance Data" section explicitly states: "No clinical data were included in this submission." Therefore, there is no "test set" in the context of clinical images or patient data to analyze. The "samples" used were physical samples for mechanical, sterilization, and biocompatibility testing. The data provenance would be from laboratory tests.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g., radiologist with 10 years of experience):
- Not applicable/Not provided. As no clinical data or clinical "test set" was used, there was no need for expert adjudication to establish ground truth from patient data. The ground truth for mechanical and material properties is established by engineering specifications and industry standards.
-
Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable/None. No clinical test set to adjudicate.
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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:
- Not applicable. This device (Zfx Abutments) is a physical dental implant component, not an AI software/device. Therefore, an MRMC study or AI assistance is not relevant to its performance evaluation for this submission.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. As above, this is a physical medical device, not an algorithm or AI.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- The "ground truth" for demonstrating substantial equivalence for this device relies on engineering specifications, material standards (e.g., ASTM, ISO), mechanical test results (e.g., forces to fracture), and comparative analysis with the predicate device's established safe and effective performance. There is no clinical outcomes ground truth cited here.
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The sample size for the training set:
- Not applicable. This refers to a dataset for training an AI model. This device is not an AI/software.
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How the ground truth for the training set was established:
- Not applicable. As above, no training set for an AI model.
In summary, this document is a regulatory clearance letter focused on substantial equivalence for a physical dental device. The "study" proving it meets acceptance criteria consists of various non-clinical bench tests and a comparison to a predicate device's specifications and performance, rather than a clinical study with patients or an AI model's performance evaluation.
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(112 days)
For the implants:
The Single Platform SP1 Implant System is intended for surgical placement in the upper or lower jaw to provide a means for prosthetic attachment of crowns, bridges or overdentures utilizing delayed or immediate loading. The Single Platform SP1 Implant System is intended for immediate function when good primary stability with appropriate occlusal loading is achieved.
The Single Platform SP1 implants in lengths 20, 22 and 24 mm when placed in the maxilla are only indicated for multiple unit restorations in splinted applications that utilize at least two implants.
For the conventional abutment and screws:
The Conventional Abutments and Prosthetic Screws are premanufactured prosthetic components directly connected to endosseous dental implants and intended for use in fully edentulous maxilla and/or maxilla and/or mandible to provide support for crowns, bridges or overdentures.
For the Titanium Abutment Bases and Passive Abutments:
The TIB and Passive Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid in prosthetic rehabilitation. The TIB and Passive abutments consist of two major parts. Specifically, the titanium base and mesostructure components make up a two-piece abutment. The system integrates multiple components of the digital dentistry workflow: Scan files from desktop scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
For the Temporary Titanium Cylinders:
The Southern Implants Temporary Titanium Abutments are prosthetic components directly connected to endosseous dental implants and are intended for provisional use up to 180 days as an aid in prosthetic rehabilitation.
This submission includes fully threaded root-form dental implants with an internal cone and hexagon interface and mating abutments. The implants are provided in three diameters: Ø3.5, Ø4.0 and Ø5.0 mm. The implants are provided in a straight (0° angled) configuration only, with a 3.0 mm extended machined coronal section. The implants are provided in one prosthetic diameter (2.95 mm implants are provided in overall leneths of 8, 10, 11.5, 13, 16, 18 and 20 mm. The Ø4.0 mm implants are provided in overall lengths of 8, 10, 11.5, 13, 16, 18, 20, 22 and 24 mm. The Ø5.0 mm implants are provided in overall lengths of 8, 10, 11.5, 13, 16, and 18 mm.
This submission also includes: a Cover Screw, Healing Abutments in four diameters and multiple gingival heights, Titanium Cylinder Abutments for temporary restorations, Passive Abutments with a plastic burn-out component, Equator Overdenture Abutments in multiple gingival heights, Compact Conical Abutments in straight (0) and angled (17° and 30°) designs, TIB Abutment Bases, and abutment screws.
The Passive Abutments may be restored using either traditional cast-on workflows or digital CAD/CAM workflows using milled zirconia restorations (similar use to the TIB Abutment Bases).
Using the traditional cast-on workflow, the Passive Abutments function as UCLA castable abutments which interface with a plastic, burn-out sleeve used to fabricate a prosthesis that is bonded directly to the top of the abutment, limited to a straight (0°) restoration when utilizing precious metal cast-on restorations.
Using digital CAD/CAM workflows, the TIB Abutment Bases and Passive Abutments function as two-piece abutment designs, consisting of standard premanufactured titanium alloy abutments for supporting the second half (or top-half) of the abutment, a hybrid/crown dental restoration and mesostructure (SageMaxx Zirconia) bonded with cement (Ivoclar Vivadent Multilink Hybrid cement). The dental laboratory is to fabricate the mesostructure restoration by CAD/CAM technique out of zirconia. The TIB Abutment Bases and Passive Abutments then serves as the interface between the endosseous implant and the Zirconia restoration. The TIB Abutment Bases and Passive Abutments are designed to support the restoration on an endosseous implant in order to restore chewing function for the patient.
The mesostructured restoration is a CAD/CAM designed prosthesis milled out of Zirconia (SageMaxx Zirconia), which is designed to fit the abutment base in order to restore chewing function for the patient. Each restoration is custom designed using 3Shape Abutment Designer Software in order to meet the requirements of each patient on a case-by-case basis. Limitations have been put in place in 3Shape Abutment Designer in order to prevent malfunctioning of the restoration and a maximum allowable angulation of 20° for the mesostructured component.
All Single Platform SP1 implants are manufactured from unalloyed titanium conforming to ASTM F67, with a smooth machined collar (extended machined surface of 3 mm). The remainder of the entire endosseous threaded surface) is grit-blasted. The subject device implant material and surface is identical to the implants cleared in K222457 and K163060. The Cover Screw and Healing Abutments are manufactured from unalloyed titanium conforming to ASTM F67. The remaining Abutments are manufactured from titanium alloy conforming to ASTM F136. The abutment screws are manufactured from titanium alloy conforming to ASTM F136. All subject device components are manufactured in the same facilities using the same materials and manufacturing processes as used for the Southern Implants devices previously cleared in K222457 and K163060.
The provided text describes a 510(k) premarket notification for the "Single Platform SP1 Implant System." This document focuses on demonstrating substantial equivalence to existing, legally marketed predicate devices, rather than proving that the device meets specific acceptance criteria through a clinical study or a standalone algorithm performance test.
Therefore, the requested information regarding "acceptance criteria" and "study that proves the device meets the acceptance criteria" in terms of clinical performance with statistical measures, expert reading, and ground truth establishment is not present in the provided document. The 510(k) pathway for medical devices typically relies on demonstrating that a new device is as safe and effective as a predicate device, rather than requiring new clinical efficacy studies unless there are significant technological differences or new intended uses that raise new safety or effectiveness questions.
The "Performance Data" section explicitly states: "No clinical data were included in this submission."
However, I can extract information related to the non-clinical performance data provided to support substantial equivalence and the device's characteristics compared to predicates.
Here's a breakdown of what is available:
1. Table of Acceptance Criteria and Reported Device Performance:
The document does not define specific "acceptance criteria" for clinical performance (e.g., sensitivity, specificity, accuracy) or report device performance against such metrics. Instead, it demonstrates through non-clinical testing that the device's mechanical, material, and functional properties are substantially equivalent to marketed predicate devices.
Here's a table summarizing the non-clinical performance data and findings:
Acceptance Criteria (Proxy: Demonstration of Substantial Equivalence via Non-Clinical Performance) | Reported Device Performance (Findings) |
---|---|
Engineering Analysis | Demonstrated equivalence. |
Dimensional Analysis | Demonstrated equivalence. |
Sterilization Validation (ISO 11137-1, ISO 17665-1, ISO 17665-2) | Validated. |
Bacterial Endotoxin (USP 39-NF 34) | Tested according to standard. |
Static and Dynamic Compression-Bending (ISO 14801 Dentistry - Implants - Dynamic fatigue test for endosseous dental implants) | Results demonstrated fatigue performance of the subject device that exceeds its indication. |
Scanning and Milling Validation for Passive Abutments | Validated. |
MR Safety Testing (FDA Guidance Document "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment" - ASTM F2503, ASTM F2052, ASTM F2213, ASTM F2182, ASTM F2119) | Subject devices "can be considered equally MR Safe as the predicate devices" (as tested on previously cleared devices and compared). |
Biocompatibility Evaluations (ISO 10993-1) | Supported by identical materials, processing, and storage conditions as predicate devices (referenced from K222457 and K163060). |
Sterile Barrier Shelf Life | Referenced from K222457. |
Validated Steam Sterilization Instructions (ISO 17665-2) | Referenced from K193084 (for non-sterile components intended for end-user sterilization). |
Software Validation Testing (FDA Guidance Document for Off-The-Shelf Software Use in Medical Devices) | Software verification and validation testing provided for abutment design library, including restrictions to prevent designs outside allowable limits and locked design limitations/specifications. (referenced from K193084, applicable to TIB Abutment Bases and Passive Abutments for digital CAD/CAM workflows). |
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set Sample Size: Not applicable in the context of clinical efficacy; the "test set" here refers to the non-clinical testing of the physical device. For example, "dynamic compression-bending testing was performed on worst-case subject device constructs." The exact number of constructs tested is not specified but would be dictated by the ISO standard.
- Data Provenance: The document does not specify the country of origin for the non-clinical testing data directly, but the manufacturer is Southern Implants (Pty) Ltd from Irene, Gauteng, SOUTH AFRICA. The data is retrospective in the sense that it supports a submission for a new device, often using internal lab data.
3. Number of Experts Used to Establish Ground Truth and Qualifications:
- This information is not applicable as no clinical study with human readers or ground truth established by experts for diagnostic performance was conducted or reported.
4. Adjudication Method for the Test Set:
- Not applicable, as there was no human reader interpretation or clinical assessment requiring adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study:
- No MRMC comparative effectiveness study was done. The submission explicitly states: "No clinical data were included in this submission." Therefore, no effect size of human readers improving with AI vs. without AI assistance is reported.
6. Standalone (Algorithm-Only) Performance:
- Not applicable. This is a physical dental implant system, not an AI algorithm. The only "software" mentioned is for design (CAD/CAM workflow), and its validation is to ensure it prevents designs outside of allowable limitations.
7. Type of Ground Truth Used:
- For the non-clinical performance data, the "ground truth" is established by adherence to recognized international standards (ISO, ASTM, USP) and internal engineering specifications. For instance, the "ground truth" for fatigue performance is the passing criteria defined by ISO 14801.
8. Sample Size for the Training Set:
- Not applicable. This product does not involve machine learning or AI models that require a training set.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable as there is no training set for an AI/ML model.
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(124 days)
The Angulated Screw Channel (ASC) Solution Abutments and SI-BASE Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid in prosthetic rehabilitation. The ASC Solution Abutments and SI-BASE Abutments consist of two major parts. Specifically, the titanium base and mesostructure components make up a multi-piece abutment. The system integrates multiple components of the digital dentistry workflow: Scan files from desktop scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
The intended use for the engaging ASC Solution Abutments and SI-BASE Abutments used with the Ø3.0 External-Hex implants, Ø3.3 PROVATA implants and Ø3.5/Ø4.0 Deep Conical implants are intended for use with a straight mesostructure component.
The intended use for the engaging ASC Solution Abutments and SI-BASE Abutments used with the Ø3.4 and Ø4.0 External-Hex implants. PROVATA implants and 03.5 and 04.3 TRI-NEX implants is limited to replacement of maxillary and mandibular lateral and central incisors.
The ASC Solution Abutments and SI-BASE Abutments for Compact Conical Abutments are intended for use on straight Compact Conical Abutments with a straight mesostructure component.
This submission includes two major components which make up the ASC Solution and SI-BASE Abutments - The ASC Solution and SI-BASE Abutment Base and the mesostructure restoration. Twopiece and three-piece abutments models are included. Two-piece abutments consist of the ti-base abutment and mesostructure. Three-piece abutments consist of the ti-base abutment, mesostructure, and compatible compact conical abutments.
The ASC Solution and SI-BASE Abutments are standard premanufactured titanium alloy abutments for supporting a dental restoration and mesostructure. The dental laboratory is to fabricate the mesostructure restoration by CAD/CAM technique out of zirconia. The ASC Solution and SI-BASE Abutments then serve as the interface between the endosseous implant and the zirconia restoration. The abutments are designed to support the restoration on an endosseous implant in order to restore chewing function for the patient.
The mesostructured restoration is a CAD/CAM designed prosthesis milled out of zirconia, which is designed to fit the abutment base in order to restore chewing function for the patient. Each restoration is custom designed using 3Shape Abutment Designer Software in order to meet the requirements of each patient on a case-by-case basis. Limitations have been put in place in 3Shape Abutment Designer in order to prevent malfunctioning of the restoration.
The ASC Solution and SI-BASE Abutments are compatible with the Southern Implants' Deep Conical, External Hex, Provata and Tri-Nex implants and screws. The abutments are manufactured from Titanium alloy conforming to ASTM F136 and are color coded by Titanium nitride coating (ASC Solution Abutments) or yellow anodizing (SI-BASE Abutments). The TiN coating and anodization processes are the same as used for previously cleared anodized titanium alloy devices in K163634. The Mesostructure restoration is to be manufactured from Zirconia - Sage Max NexxZr which has been previously cleared for use in K130991.
The digital workflow includes the following products (not subject devices to this submission):
- Ceramic material: Sage Max NexxZr Zirconia Restorative material (K130991)
- Cement: Ivoclar Vivadent Multilink Hybrid Abutment Cement (K130436)
- Intra-oral scanner: 3Shape E3 Desktop Scanner
- Abutment design software: 3Shape Abutment Designer Software (K151455)
- Milling machine: Roland DWX51D Milling Unit
The provided text describes the Angulated Screw Channel (ASC) Solution Abutments and SI-BASE Abutments for dental implants. The document is a 510(k) summary submitted to the FDA to demonstrate substantial equivalence to legally marketed predicate devices.
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state "acceptance criteria" in a quantitative manner with defined thresholds. Instead, it demonstrates compliance through comparison to predicate devices and adherence to relevant standards and guidance documents. The "reported device performance" is largely qualitative and comparative, focusing on demonstrating equivalence rather than meeting specific numerical performance targets.
However, based on the "PERFORMANCE DATA" section and "Table of Substantial Equivalence", we can infer the following:
Acceptance Criteria (Inferred from regulatory requirements and predicate comparison) | Reported Device Performance (as demonstrated by the study) |
---|---|
Biocompatibility: Meet FDA Guidance Document for ISO 10993-1 and ISO 10993-5 (In-Vitro Cytotoxicity) | Materials are identical in formulation, processing, component interactions, and storage conditions to predicate device K193084. Performed biocompatibility testing per ISO 10993-1. |
Sterilization: Validation per ISO 17665-1 and ISO 17665-2 | Validated sterilization instructions per ISO 17665-1 and ISO 17665-2 (though the device is provided non-sterile, indicating the sterilization protocol is for other components or processes). |
Software Validation: Meet FDA Guidance Document for Off-The-Shelf Software Use in Medical Devices | Software validation testing performed per FDA Guidance Document. Verification and validation testing conducted for the abutment design library to demonstrate that restrictions prevent design outside allowable limitations. |
Mechanical Performance (Fatigue): Meet ISO 14801 (dynamic compression-bending) | Dynamic testing performed on worst-case subject device constructs. Results demonstrated fatigue performance exceeding its indication and supported by bench testing previously cleared in K173706 and K222457. |
MR Safety: Meet FDA Guidance Document "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment" | MR safety testing performed on previously cleared devices (K222457). Subject devices compared to predicates and considered "equally MR Safe" as they are not worst-case in terms of material, size, or shape. |
Design Workflow: Equivalent design and manufacturing workflows to predicates | Uses the same scanners (3Shape E3 Desktop Scanner) and software (3Shape Abutment Designer Software, WorkNC CAM software) and milling unit (Roland DWX51D) as the primary predicate. |
Material Equivalence: Identical or similar materials to predicates | Titanium Grade 5 Alloy (ASTM F136) for abutments and screws, Zirconia (Sage Maxx NexxZr, K130991) for restoration material, consistent with predicates. |
Indications for Use: Similar to predicate and reference devices | Indications for use statement is very similar to predicate and reference devices, differing only in device name and specific application paragraphs, but expressing shared intended use. |
2. Sample sizes used for the test set and the data provenance
- Sample Sizes for Test Set:
- Biocompatibility: Not explicitly stated as a number of devices. The statement mentions "materials are identical in formulation, processing, component interactions, and storage conditions to the predicate device" and "biocompatibility testing per the FDA Guidance Document for Use of Standard ISO 10993-1... and ISO 10993-5 'Biological Evaluation of Medical Devices - Part 5: Tests for In-Vitro Cytotoxicity' was performed." This implies biological samples were used for in-vitro cytotoxicity, but the number is not specified.
- Mechanical Performance (Fatigue): "Dynamic testing was performed on worst-case subject device constructs." The exact number is not provided, but typically, mechanical fatigue testing involves a statistically significant number of samples per "worst-case construct" to establish fatigue limits.
- Software Validation: Not explicitly stated as a numerical sample size. It involved verification and validation for the "abutment design library" and screenshots under user verification testing, indicating a functional test rather than a numerical sample size.
- MR Safety: Not explicitly stated for the subject device. It refers to testing performed on "previously cleared devices, K222457, PROVATA Implant System."
- Data Provenance: Not explicitly stated for any of the tests. Given it's a 510(k) summary, the testing was likely conducted by or on behalf of Southern Implants (Pty) Ltd, which is located in "Irene, Gauteng, 0062 South Africa." The studies appear to be non-clinical (bench testing) and retrospective in the sense that they rely on comparisons to previously cleared devices and established standards, rather than new prospective human clinical trials.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not provided in the document. The studies described are primarily non-clinical bench testing, software validation, and biocompatibility assessments, which typically do not involve establishing "ground truth" through expert consensus in the way a diagnostic AI device would. Instead, performance is measured against engineering specifications, standards (like ISO 14801), and equivalence to predicate devices.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
This information is not applicable to the types of non-clinical, hardware-focused studies described. Adjudication methods are typically used in clinical studies or studies evaluating subjective interpretations (e.g., image reading) to establish a consensus ground truth.
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
There was no MRMC comparative effectiveness study and no mention of AI assistance. This device is a component for dental implants (abutments), not a diagnostic AI system or an AI-assisted diagnostic tool.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done
This information is not applicable. The device is a physical medical component (dental abutment) and related software for design. While software validation was performed, it's for design limitations and functionality, not for an "algorithm only" performance in a diagnostic or interpretive sense. The "standalone" concept typically applies to AI algorithms that provide a diagnosis or interpretation without human intervention.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The concept of "ground truth" as it applies to diagnostic or prognostic data is not directly applicable to these non-clinical studies. Instead, the "truth" or reference for the tests described is:
- Biocompatibility: Established biological safety standards (ISO 10993-1, ISO 10993-5) and comparison to predicate device materials.
- Mechanical Performance: International standard ISO 14801 for dynamic fatigue testing of dental implants and abutments. This involves objective physical measurements.
- Software Validation: Functional specifications of the software and demonstration that defined design limitations are enforced.
- MR Safety: FDA guidance document recommendations and physical testing methods to determine MR compatibility.
8. The sample size for the training set
This information is not applicable. This device is not an AI diagnostic or predictive algorithm that requires a training set in the conventional sense. The "design workflow" involves CAD/CAM software but this refers to a process for custom fabrication, not machine learning model training.
9. How the ground truth for the training set was established
This information is not applicable for the same reasons as point 8.
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(156 days)
The Genesis ACTIVE Implant System is intended for use in single-stage or two-stage surgical procedures for replacing single or multiple missing teeth in partially or fully edentulous mandibles and maxillae. The Genesis ACTIVE Implant System supports single or multiple-unit restorations to re-establish patient chewing function and esthetics. Genesis ACTIVE implants are intended for placement following natural tooth loss or for immediate placement into an extraction socket. Immediate function may be achieved when good primary stability is established, and appropriate occlusal loading is applied.
All digitally designed custom abutments for use with Genesis ACTIVE Implants are to be sent to a Keystone Dental validated milling center for manufacture.
The KDG-Osteon Precision Milled Suprastructure is indicated for attachment to the Genesis ACTIVE Multi-Unit abutments in the treatment of partially or fully edentulous jaws for the purpose of restoring chewing function. The KDG-Osteon Precision Milled Suprastructure is intended for attachment to a minimum of two (2) abutments.
The purpose of this submission is for the marketing clearance for the Genesis ACTIVE Implant System which comprises endosseous root-form dental implants, mating compatible abutments, abutment screws, and other associated components for single-unit, multi-unit, and overdenture restorations.
Endosseous dental implants are surgically implanted into a patient's mouth to provide support for prosthetic devices, such as artificial teeth, in order to restore the patient's chewing function. Endosseous dental implant abutments are secured to dental implants with a retaining screw to provide support for prosthetic devices, such as artificial teeth, in order to restore the patient's chewing function. Prosthetic devices used with the dental implant abutments in this submission may be screw-retained or cement-retained.
The Genesis ACTIVE Implant System includes endosseous screw type dental implants which can be used in either single- or two-stage surgeries with associated compatible abutments, screws, and other associated accessory components. The Genesis ACTIVE Implant System includes eleven (11) compatible implant abutment designs: Healing Abutments, Straight, Angled Multi-Unit, Angled Multi-Unit, PEEK Straight Temporary, PEEK Angled Temporary, Temporary Cylinder, Titanium Temporary Immediate, Titanium Blank. There are four minor variations of the Titanium Base design: Ti-Base, ANGLEBase®, C-Base®, and ELLIPTIBase®. Prosthetic devices used with the dental implant abutments in this submission may be screw-retained or cemented.
The KDG-Osteon Precision Milled Suprastructure is an overdenture bar which is compatible with the Subject device Multi-Unit abutments. The overdenture bar is a dental restorative device that is intended for screw-retained attachment to dental abutments to aid in the treatment of partial or totally edentulous patients for the purpose of restoring their chewing function. The KDG-Osteon Precision Milled Suprastructure is fabricated by means of CAD/CAM technology by a Keystone Dental Group company and is used to facilitate the attachment of both fixed and removable prostheses.
Subject device implants are manufactured from Commercially Pure (CP) – Grade 4 titanium conforming to ISO 5832-2, Implants for surgery — Metallic materials — Part 2: Unalloyed titanium and ASTM F67, Standard Specification for Unalloyed Titanium, for Surgical Implant Applications (UNS R50250, UNS R50550, UNS R50700). They are anodized pink (AnaTite™) to provide a pink color and have the BioSpark™ surface treatment which results in a hydrophilic surface enriched with calcium and phosphorous ions.
All titanium Subject device abutments, accessories and screws are manufactured from titanium alloy conforming to ASTM F136, Standard Specification for Wrought Titanium-4Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R5640). Except for the Titanium Blank abutment design, all titanium Subject device abutments are anodized pink. Post surfaces of select abutments receive a media blasting treatment referred to as AnaTite™ or TiPink.
Subject device PEEK temporary abutments are fabricated from PEEK (PolyEther Ether Ketone) material.
All implants and prosthetic components are one-time use devices. All Subject device components are provided sterile and sterilized by gamma irradiation, except for Titanium Blank abutments and the KDG-Osteon Precision Milled Suprastructure which are provided non-sterile. Devices provided non-sterile or modified are sterilized by steam.
The provided text describes the 510(k) summary for the Keystone Dental Inc. "Genesis ACTIVE Implant System." It focuses on demonstrating substantial equivalence to predicate devices through technical comparisons and non-clinical performance testing. The document explicitly states that no clinical data were included in this submission, which means there was no study proving the device meets acceptance criteria related to human performance or clinical outcomes.
Therefore, many of the requested information points, particularly those pertaining to acceptance criteria for AI performance, sample sizes for test sets in clinical studies, expert involvement in ground truth establishment for such studies, MRMC studies, and standalone performance, cannot be answered from the provided text.
The document primarily discusses bench testing and material/design comparisons to establish equivalence, rather than clinical performance acceptance criteria or studies involving human readers or AI.
Here's what can be extracted from the provided text:
1. A table of acceptance criteria and the reported device performance:
The document focuses on non-clinical performance testing (bench testing) and material/design specifications for establishing substantial equivalence, rather than specific performance metrics or acceptance criteria typically seen for AI/diagnostic devices in clinical settings. The acceptance is based on demonstrating the new device performs similarly and is as safe and effective as the predicate device through these non-clinical tests.
Acceptance Criteria Category (based on description) | Reported Device Performance/Testing Confirmation |
---|---|
Fatigue Testing (Mechanical) | Performed according to ISO 14801:2016 ("Dentistry – Implants – Dynamic loading test for Endosseous Dental Implants"). Worst-case scenarios were chosen based on FDA Guidance. Results "demonstrate conformance with testing requirements and support a finding of substantial equivalence." |
Biocompatibility | Performed according to ISO 10993-1. Supports that the Subject device uses "nearly identical manufacturing processes to the K210117 Reference device, with slight differences in surface treatment." Biological Evaluation addressed differences with internal routine monitoring data. |
Cytotoxicity | Performed according to ISO 10993-5 on subject device or suitable test specimens to "support suitable biocompatibility." |
Endotoxin Testing | Performed following USP on subject device or suitable test specimens according to the sponsor's endotoxin sampling plan. |
Sterilization Validation (Gamma) | Performed according to ISO 11137-1:2019, ISO 11137-2:2015, and ISO/TS 13004:2013 to "demonstrate suitable sterilization of the Subject device sterile components." |
Sterilization Validation (Steam) | Leveraged from sponsor's K220200 Reference device according to ISO 17665-1:2009 for non-sterile and modified components. |
MRI Safety (Non-clinical worst-case review) | Performed using scientific rationale and published literature (e.g., Woods et al., 2019). Rationale addressed parameters per FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment," including magnetically induced displacement force and torque. |
Material Composition | Implants: Commercially Pure (CP) – Grade 4 titanium (ISO 5832-2, ASTM F67). Abutments, accessories, screws: Titanium alloy (ASTM F136). PEEK temporary abutments: PEEK material. Zirconia custom abutments: ISO 13356. |
Physical Dimensions Range (Implants) | Implant diameters (3.5, 3.8, 4.5, 5.5 mm), Lengths (8.5 - 16 mm). Stated as supported by predicate/reference devices. Minor differences in thread design and interface do not affect substantial equivalence. |
Physical Dimensions Range (Abutments) | Gingival Height (0.5-7 mm), Prosthetic diameters (3-6 mm). Stated as highly similar to and encompassed by predicate/reference devices. Minor differences are mitigated by mechanical performance testing. |
2. Sample sizes used for the test set and the data provenance:
- Sample Size for Test Set: Not applicable in the context of this 510(k) submission, as it relies on non-clinical data (bench testing) rather than a clinical test set. The number of samples for each bench test is not specified in this summary document.
- Data Provenance: Not applicable for clinical data. For non-clinical (bench) testing, the tests were conducted according to recognized international standards (e.g., ISO, ASTM, USP).
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. No clinical test set or ground truth established by experts is described, as the submission focuses on non-clinical data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. No test set requiring adjudication in a human reader study is described.
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 MRMC study was done. The document explicitly states: "No clinical data were included in this submission."
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device is a physical dental implant system, not an AI algorithm. Its "performance" is mechanical and biological, not diagnostic or algorithmic.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable for clinical ground truth. The "ground truth" for this submission are the standards and specifications (e.g., ISO 14801 for mechanical fatigue, ISO 10993 for biocompatibility) against which the device's physical and material properties are tested in a lab setting.
8. The sample size for the training set:
- Not applicable. This is not an AI/machine learning device that requires training data.
9. How the ground truth for the training set was established:
- Not applicable. This is not an AI/machine learning device.
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(308 days)
DESS Dental Smart Solutions abutments are intended to be used in conjunction with endosseous dental implants in the maxillary or mandibular arch to provide support for prosthetic restorations.
All digitally designed custom abutments for use with DESS Bases or Pre-milled Blanks are to be sent to a Terrats Medical validated milling center for manufacture, or to be designed and manufactured according to the digital dentistry workflow integrates multiple components: scan files from intra-oral and lab (desktop) scanners, CAM software, ceramic material, milling machine, and associated tooling and accessories.
The purpose of this submission is to expand the DESS Dental Smart Solutions abutment system cleared under K22288 to add the ability for the subject device Base Abutments and Pre-milled (Blank) Abutments to be manufactured via a digital dentistry workflow by using scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories. There are no changes to the abutment design or implant compatibilities, however, there is a new material for the zircomia superstructure. All part numbers have been cleared within previous submissions for manufacturing at a validated milling center. The purpose of this submission is to allow manufacturing via digital dentistry workflow and to add a new zirconia material for the superstructures of the two-piece abutment.
The subject device DESS Dental Smart Solutions abutments provide a range of prosthetic solutions for dental implant restoration. DESS abutments are offered in a variety of connection types to enable compatibility with currently marketed dental implants. All abutments are provided non-sterile, and each abutment is supplied with the appropriate abutment screw (if applicable) for attachment to the corresponding implant.
Subject device Base Abutments are designed for fabrication of a patient-specific CAD/CAM zirconia superstructure on which a crown may be placed. They are two-piece abutments for which the second part (or top half) is the ceramic superstructure. They also may be used for support of a crown directly on the abutment.
All patient-specific custom abutment fabrication for Base Abutments and Pre-milled (Blank) Abutments is by prescription on the order of the clinician. The subject device Pre-milled (Blank) Abutments and all zirconia superstructures for use with the subject device Ti Base Interface, DESS Aurum Base, ELLIPTIBase, and DESS C-Base will be manufactured using a digital dentistry workflow by using scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
The digital dentistry workflow uses scan files from intra-oral and lab (desktop) scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
The provided text is a 510(k) summary for a dental device, specifically DESS Dental Smart Solutions abutments. It focuses on demonstrating substantial equivalence to predicate devices rather than proving performance against specific acceptance criteria for an AI/ML-based device.
Therefore, I cannot provide the requested information as the document does not contain details about:
- Acceptance criteria for an AI/ML device: This document is about dental implant abutments, not a medical device driven by AI/ML.
- Study proving device meets acceptance criteria: There is no performance study described for an AI/ML component. The "Performance Data" section refers to non-clinical data for biocompatibility and fatigue testing of the physical dental abutments, and software verification to ensure design parameters are met and restriction zones are locked, not AI/ML performance.
- Sample size for test set and data provenance: Not applicable to a non-AI/ML device.
- Number of experts and their qualifications for ground truth: Not applicable.
- Adjudication method for the test set: Not applicable.
- Multi-reader multi-case (MRMC) comparative effectiveness study: Not applicable.
- Standalone (algorithm only) performance: Not applicable.
- Type of ground truth used: Not applicable.
- Sample size for training set: Not applicable.
- How ground truth for training set was established: Not applicable.
The document describes the physical characteristics, materials, manufacturing processes (including digital dentistry workflows), and compatibility of the dental abutments, and asserts their substantial equivalence to previously cleared devices. It does not mention any AI/ML components or their performance evaluation.
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(203 days)
The Provata Implant System is intended for surgical placement in the upper or lower jaw to provide a means for prosthetic attachment of crowns, bridges or overdentures utilizing delayed or immediate loading. The Provata Implant System is intended for immediate function when good primary stability with appropriate occlusal loading is achieved. The intended use for the Ø3.30 Provata implants is limited to replacement of maxillary and mandibular lateral and central incisors. The 12° angled Co-Axis Provata Implants are intended to only be used with straight abutments.
The TIB Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for use as an aid in prosthetic rehabilitation. The TIB abutments consist of two major parts. Specifically, the titanium base and mesostructure components make up a two-piece abutment. The system integrates multiple components of the digital dentistry workflow: Scan files from desktop scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
The Conventional Abutments and Prosthetic Screws are premanufactured prosthetic components directly connected to endosseous dental implants and intended for use in fully edentulous or partially edentulous maxilla and/or mandible to provide support for crowns, bridges or overdentures.
The Southern Implants PEEK Abutments are premanufactured prosthetic components directly connected to endosseous dental implants and are intended for provisional use up to 180 days as an aid in prosthetic rehabilitation.
The Southern Implants Temporary Titanium Abutments are prosthetic components directly connected to endosseous dental implants and are intended for provisional use up to 180 days as an aid in prosthetic rehabilitation.
This submission includes fully threaded root-form dental implants with an internal hexagon interface and mating abutments. The implants are provided in two diameters: Ø3.30 and Ø4.07 mm. The Ø3.30 implants are provided in two designs: Straight and Co-Axis (prosthetic platform inclined 12° from orthogonal to the long axis of the implant). Both the Straight and Co-Axis versions are available in fully roughened and 3 mm machined coronal section configurations. The Ø3.30 Straight and Co-Axis implants are each provided in in one prosthetic diameter (2.90 mm), and in overall lengths of 8.5, 10, 11.5, 13, 15, 18 mm. The Co-Axis implants are to be used with straight abutments only.
The Ø4.07 implants subject to this submission are provided in length 6.4mm and as Straight (0°) implants only. The Ø4.07 implants are provided with a 3.575 mm prosthetic diameter and are available in fully roughened and 2 mm machined coronal section configurations.
This submission also includes: a Cover Screw (one design/size); Healing Abutments in two diameters (3.5 and 4.5 mm) each in three gingival heights (3, 4, and 6 mm); Titanium Cylinder Abutments for temporary restorations in one size and two designs (engaging and non-engaging); Passive Abutments with a plastic burn-out component, in one size and two designs (engaging and non-engaging); PEEK Abutments for temporary restorations in one size and two designs (engaging and non-engaging); Compact Conical Abutments in straight (0°) and 20°, angled design for multi-unit restorations: Narrow TIB Abutment Bases (engaging): and abutment screws.
Passive Abutments are UCLA castable abutments which interface with a plastic, burn-out sleeve used to fabricate a prosthesis that is bonded directly to the top of the abutment, limited to a straight (0°) restoration.
The Narrow and Compact Conical TIB Abutment bases are two-piece abutment designs, consisting standard premanufactured titanium alloy abutments for supporting a hybrid/crown dental restoration and mesostructure (SageMaxx Zirconia) bonded with cement (Ivoclar Vivadent Multilink Hybrid cement). The dental laboratory is to fabricate the mesostructure restoration by CAD/CAM technique out of zirconia. The TIB abutment base then serves as the interface between the endosseous implant and the Zirconia restoration. The TIB Abutment Base is designed to support the restoration on an endosseous implant in order to restore chewing function for the patient. The mesostructured restoration is a CAD/CAM designed prosthesis milled out of Zirconia (SageMaxx Zirconia), which is designed to fit the abutment base in order to restore chewing function for the patient. Each restoration is custom designed using 3Shape Abutment Designer Software in order to meet the requirements of each patient on a case-by-case basis. Limitations have been put in place in 3Shape Abutment Designer in order to prevent malfunctioning of the restoration and a maximum allowable angulation of 20° for the mesostructured component.
All Provata implants are manufactured from unalloyed titanium conforming to ASTM F67, with a smooth machined collar (0.6mm or extended machined surface of 2 or 3 mm). The remainder of the entire endosseous threaded surface) is grit-blasted. The subject device implant material and surface is identical to the implants cleared in K163634 and K180465. The Cover Screw and Healing Abutments are manufactured from unalloyed titanium conforming to ASTM F67. The remaining Abutments are manufactured from titanium alloy conforming to ASTM F136. The PEEK Abutments are manufactured from medical grade white Polyetheretherketone. The abutment screws are manufactured from titanium alloy conforming to ASTM F136. All subject device components are manufactured in the same facilities using the same materials and manufacturing processes as used for the Southern Implants devices previously cleared in K163634, K180465, K193084 and K191250.
The provided text is a 510(k) summary for the Provata Implant System, which describes various dental implants and abutments. It focuses on demonstrating substantial equivalence to predicate devices and does not contain information about acceptance criteria or a study proving the device meets specific performance criteria beyond the general statement of "demonstrated fatigue performance of the subject device that exceeds its indication" based on ISO 14801 testing.
Therefore, most of the requested information cannot be extracted from the given text.
However, I can extract information related to performance testing and mention the lack of specific acceptance criteria and performance reports.
-
A table of acceptance criteria and the reported device performance
This information is not explicitly provided in the document. The document states that "Dynamic testing was performed on worst-case subject device constructs. The results from the testing demonstrated fatigue performance of the subject device that exceeds its indication." However, no specific acceptance criteria or quantitative performance results are reported. -
Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not specified. The document only mentions "worst-case subject device constructs" were used for dynamic compression-bending testing.
- Data Provenance: Not specified.
-
Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. The reported testing is non-clinical (mechanical fatigue testing), not related to clinical ground truth established by experts. -
Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. This is not a clinical study involving adjudication. -
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, a multi-reader multi-case comparative effectiveness study was not done. This submission is for dental implants and abutments, and the non-clinical performance data focuses on mechanical and biological characteristics, not AI-assisted human reading. -
If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is not an AI algorithm. -
The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. The performance data is based on non-clinical mechanical testing and material equivalence. -
The sample size for the training set
Not applicable. This is not an AI/machine learning device requiring a training set. -
How the ground truth for the training set was established
Not applicable. This is not an AI/machine learning device.
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(96 days)
MIS Ti-base abutment is a titanium base placed onto MIS dental implants to provide support for customized cement-retained or screw retained single or multiple-unit restorations. It is used with a digitally designed mesostructure. MIS Ti-base and the mesostructure make up a two- piece abutment used in conjunction with MIS dental implants, to be placed in the upper or lower jaw arches, in order to restore masticatory function.
Narrow platform Ti-bases are indicated for use only in the mandibular central, lateral incisor and maxillary lateral incisor regions of partially edentulous jaws.
MIS short implants are to be used only with straight abutments. Mesostructures for use with the MIS Tibase abutment are to be made from inCoris ZI, IPS e.max® CAD Abutment or VITA ENAMIC® (IS), designed and manufactured using Sirona CEREC SW version 4.6.1 software.
MIS Ti-base abutments are intended for use with the following MIS implants:
- C1 conical connection implant system
- V3 conical connection implant system
- SEVEN internal hex implant system
- M4 internal hex implant system
- Lance+ internal hex implant system
The subject MIS Ti-base abutments are endosseous dental implant abutments intended to be connected to MIS dental implants and used to support CAD/CAM customized cement-retained or screw retained single or multiple-unit restorations.
MIS Ti-base abutments consist of a titanium base and a prosthetic screw, both made of TI-6AI-4V ELI complying with ASTM F136. The prosthetic screw tightens the finished CAD/CAM abutment to the dental implant.
MIS Ti-base abutments are the bottom-half/base of a two-piece custom ceramic-titanium abutment consisting of a ceramic coping/mesostructure and a titanium base.
The top-half custom ceramic coping/mesostructure or crown is intended to be fabricated from Sirona inCoris ZI zirconium oxide ceramic block, IPS e.max® CAD ceramic block, or from IPS e.max® CAD ceramic block or VITA ENAMIC® (IS) ceramic block and designed and milled using Sirona chairside Dental CAD/CAM System, with software version: CEREC SW version 4.6.1. The mesostructure design will be subject to the Sirona system controls, such as: A maximum angulation of 20° and minimum wall thickness of 0.5mm for inCoris ZI and e.max materials and 0.8mm for VITA ENAMIC material.
It is not permitted to reduce the Ti-base's diameter, shorten the Ti-base or modify its implant-abutment connection and emergence profile in any way.
The subject, pre-fabricated titanium base abutment is designed with interface compatibility to specific MIS dental implant systems. The subject MIS Ti-base abutments are MIS connection and internal hex connection Ti-base abutments, and their connection is compatible with MIS conical connection C1 and V3 implants, and MIS SEVEN, M4 and Lance+ internal hex implants, which are not subject to this submission and were previously cleared.
This document describes a 510(k) premarket notification for the MIS Ti-base abutment. This is an FDA submission for devices that are "substantially equivalent" to predicate devices, meaning they have the same intended use and similar technological characteristics. Therefore, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are typically demonstrating this substantial equivalence through non-clinical performance data, rather than a clinical trial with specific performance metrics like sensitivity or specificity for an AI algorithm.
Here's the breakdown based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Since this is a substantial equivalence submission for a physical medical device (dental abutment) and not an AI algorithm, the "acceptance criteria" are related to demonstrating that the device performs as safely and effectively as a legally marketed predicate device. The performance is assessed through non-clinical testing against established standards.
Acceptance Criteria (Demonstration of Substantial Equivalence) | Reported Device Performance (Summary of Non-clinical Testing) |
---|---|
Biocompatibility | The subject device is manufactured using identical methods, facility, and raw material as the predicate (K191152). Patient contact duration and type are the same. IPS e.max® and VITA ENAMIC® (IS) mesostructure materials are cleared under K191382 and K153645 respectively, and no modifications to these materials are included. No new biocompatibility testing was required. |
Fatigue Testing (Mechanical Performance) | Withstand 2,000,000 cycles without failure at a substantially equivalent load to the cited predicates, as per ISO 14801:2016. Worst-case abutments (narrowest, 20° mesostructure, various materials) were tested. |
Sterilization Testing | Validated steam sterilization parameters (gravity displacement and pre-vacuum) for inCoris ZI mesostructure according to ANSI/AAMI/ISO 17665-1:2006 and ANSI/AAMI/ISO 17665-2:2009. For IPS e.max and VITA ENAMIC (IS) mesostructures, recommended parameters are based on predicate clearances K191382 and K153645. |
Software Verification and Validation (CAD/CAM Integration) | Software verification and validation testing for the abutment design library demonstrated that restrictions prevent design of the mesostructure component outside of design limitations. The encrypted design library was validated to ensure established limitations are locked and cannot be modified. (For CEREC SW version 4.6.1). |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The document does not specify a "test set" in the context of clinical data for AI. For the non-clinical fatigue testing, "worst case abutments" were chosen. The exact number of samples tested for each worst-case configuration (e.g., number of narrowest abutments, number of specific mesostructures) is not explicitly stated but implied to be sufficient for ISO 14801:2016 compliance.
- Data Provenance: Not applicable in the context of clinical or retrospective data for an AI algorithm. The performance data comes from laboratory non-clinical tests.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- This is not applicable as this is a non-clinical device submission for a physical component, not an AI algorithm requiring expert ground truth for interpretation.
4. Adjudication Method for the Test Set
- Not applicable for a non-clinical device submission.
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 is not an AI-assisted diagnostic device.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This device is a physical dental abutment. The software mentioned (CEREC SW version 4.6.1) is for design and milling, not a standalone AI diagnostic algorithm.
7. The Type of Ground Truth Used
- For fatigue testing, the "ground truth" is defined by the mechanical strength and durability requirements of the ISO 14801:2016 standard, ensuring the device can withstand chewing forces.
- For biocompatibility, the "ground truth" is adherence to ISO 10993-1 and prior clearances of materials used.
- For sterilization, the "ground truth" is effective sterilization as demonstrated by ANSI/AAMI/ISO 17665 standards.
- For software verification, the "ground truth" is the established design limitations and the software's ability to enforce them.
8. The Sample Size for the Training Set
- Not applicable. This is not an AI algorithm that requires a training set. The software mentioned (CEREC SW) is a CAD/CAM design software, not a machine learning model developed with a training set.
9. How the Ground Truth for the Training Set was Established
- Not applicable as there is no training set for an AI algorithm.
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The Elos Accurate® Hybrid Base™ is intended for attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations. The Hybrid Base™ is used as an interface between a dental implant and a zirconia superstructure and will be attached to the implant using a prosthetic screw and attached to the zirconia superstructure by cementing.
The Elos Accurate® Hybrid Base™ is compatible with the implant systems listed in table 1:
Implant Platform compatibility | Platform diameter [mm] | Implant Body diameter [mm] |
---|---|---|
Nobel Replace NP | 3.5 | 3.5 |
Nobel Replace RP | 4.3 | 4.3 |
Nobel Replace WP | 5 | 5 |
Nobel Replace 6.0 | 6 | 6 |
Nobel OC 3.0 | 3 | 3 |
Nobel CC NP | 3.5 | 3.5 & 3.75 |
Nobel OC RP | 3.9 | 4.3 & 5 |
Nobel CC WP | 5.1 | 5.5 |
Straumann Bone Level NC | 3.3 | 3.3 |
Straumann Bone Level RC | 4.1 & 4.8 | 4.1 & 4.8 |
Astra Tech 3.0 | 3 | 3 |
Astra Tech 3.5/4.0 | 3.5 & 4 | 3.5 & 4 |
Astra Tech 4.5/5.0 | 4.5 & 5 | 4.5 & 5 |
Astra Tech EV 3.0 | 3 | 3 |
Astra Tech EV 3.6 | 3.6 | 3.6 |
Astra Tech EV 4.2 | 4.2 | 3.6 & 4.2 |
Astra Tech EV 4.8 | 4.8 | 4.2 & 4.8 |
Astra Tech EV 5.4 | 5.4 | 5.4 |
Brånemark NP | 3.5 | 3.3 |
Brånemark RP | 4.1 | 3.75, 4 & 5 |
Brånemark WP | 5.1 | 5 & 6 |
The zirconia superstructures for use with the Elos Accurate® Hybrid Base™ are only intended to be designed and manufactured according to digital dentistry workflow system integrates multiple components of the digital dentistry workflow: scan files from Intra-Oral Scanners, CAD software, CAM software, ceramic material, milling machine and associated tooling and accessories.
The Elos Accurate® Hybrid Base™ is intended for attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations. The Hybrid Base™ is used as an interface between a dental implant and a zirconia superstructure and will be attached to the implant using the included prosthetic screw and attached to the zirconia superstructure by cementing. The Elos Accurate® Hybrid Base™ is a two-piece abutment composed of the Hybrid Base as the bottom-half and the zirconia superstructure as the top-half.
The Elos Accurate® Hybrid Base™ consists of a pre-manufactured prosthetic component in Titanium alloy per ASTM F136, as well as supporting digital library file for 510(k) cleared design software (i.e. 3Shape Abutment Designer Software, K151455) which facilitates the design of a patient specific zirconia superstructure by the laboratory/clinician. The Elos Accurate® Hybrid Base™ fits directly to an endosseous dental implant. The laboratory designed superstructure is manufactured from 510(k) cleared Zirconia (Lava Plus, K011394) according to digital dentistry workflow. For all Elos Accurate® Hybrid Base™ models the zirconia superstructure must be designed according to following limits:
- Minimum wall thickness 0.5 mm
- Minimum post height 4.0 mm (for single unit restorations)
- Maximum gingival height 5.0 mm
- Maximum angulation 20°
The laboratory designed superstructure is attached to the Elos Accurate® Hybrid Base by use of 510(k) cleared cement (Multilink Hybrid Abutment, K130436) and the final prosthetic restoration is attached to the implant using a Prosthetic screw. The Elos Accurate® Hybrid Base™ is delivered non-sterile and the final restoration and corresponding screw is intended to be sterilized at the dental clinic before it is placed in the patient.
The provided text describes the regulatory clearance of a dental device, the "Elos Accurate® Hybrid Base™", through a 510(k) premarket notification. This process is based on demonstrating substantial equivalence to previously marketed predicate devices, rather than proving safety and effectiveness through clinical trials with acceptance criteria traditionally associated with new drug or high-risk device approvals.
Therefore, the document does not contain information on acceptance criteria for device performance in the classical sense (e.g., sensitivity, specificity, accuracy for an AI/diagnostic device), nor does it describe a study to prove the device meets these types of acceptance criteria.
Instead, the "acceptance criteria" here refer to the regulatory requirements for demonstrating substantial equivalence. The "study that proves the device meets the acceptance criteria" refers to the non-clinical testing and analyses performed to support this substantial equivalence claim.
Here's a breakdown of the requested information based on the provided text, highlighting where information is absent or different from a typical AI/diagnostic device performance study:
1. Table of Acceptance Criteria and Reported Device Performance
As noted, the document doesn't define quantitative performance acceptance criteria like sensitivity/specificity for a diagnostic. The "acceptance criteria" for this 510(k) submission are met by demonstrating:
Acceptance Criterion (Regulatory) | Reported "Performance" / Evidence Presented |
---|---|
Intended Use Equivalence | Subject device has the same intended use as predicate: "attaching to dental implants in order to provide basis for single or multiple tooth prosthetic restorations." |
Operating Principle Equivalence | Uses the same operating principle as predicate. |
Basic Design Equivalence | Incorporates the same basic design (two-piece abutment, titanium alloy base, zirconia superstructure). |
Material Equivalence | Incorporates same or very similar materials (Ti-6Al-4V alloy for Hybrid Base and screw, 3M Lava Plus Zirconia for superstructure, specific cement). |
Sterilization Process Equivalence | To be sterilized using the same processes (non-sterile delivery, final restoration sterilized at dental clinic). |
Dimensional and Compatibility Equivalence | Engineering and dimensional analyses of original manufacturers' components (abutments, implants & abutment screws) were made to determine nominal dimensions and tolerances and ensure compatibility with listed implant systems. |
Fatigue Resistance (Mechanical Performance) | Fatigue testing per ISO 14801 was performed according to FDA guidance. |
Biocompatibility | Biocompatibility testing for cytotoxicity according to ISO 10993-5 was performed. Previous 510(k) cleared products sharing identical manufacturing processes and materials also showed non-cytotoxicity. |
Digital Workflow Validation | Validation of the digital dentistry workflow (scanner, design software, milling unit) with the subject product line, ensuring design limits are enforced by the software. |
2. Sample Sized Used for the Test Set and the Data Provenance
- Test Set Sample Size: The document does not specify a "test set" in the context of clinical data for performance evaluation (e.g., a set of medical images). The "testing" refers to mechanical and biocompatibility tests of the device components.
- For fatigue testing (ISO 14801): The sample size for this mechanical test is not explicitly stated in the provided text.
- For biocompatibility (cytotoxicity ISO 10993-5): "a complete restoration produced via the described validated workflow was performed." The exact number of samples tested is not specified.
- For engineering and dimensional analysis: The number of components analyzed is not specified.
- Data Provenance: The document does not mention human subject data or data provenance like country of origin or retrospective/prospective studies. The testing is described as non-clinical (mechanical, material, software validation).
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
- This question is not applicable as the document describes non-clinical testing of a dental implant component, not a diagnostic or AI device requiring expert-established ground truth from patient data.
4. Adjudication Method for the Test Set
- This question is not applicable for the same reasons as 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
- This question is not applicable as the device is not an AI software intended to assist human readers. It is a physical dental implant component.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This question is not applicable as the device is a physical component, not an algorithm.
7. The Type of Ground Truth Used
- For the non-clinical tests:
- Mechanical Integrity (Fatigue): Ground truth is defined by the performance standards of ISO 14801, which sets limits for mechanical failure under specific loading conditions.
- Biocompatibility (Cytotoxicity): Ground truth is defined by the standards of ISO 10993-5, determining if the material elicits a cytotoxic response.
- Dimensional Accuracy/Compatibility: Ground truth is defined by engineering specifications and measurements of existing implant systems and the device itself.
8. The Sample Size for the Training Set
- This question is not applicable as there is no "training set" of data in the context of machine learning for this physical device.
9. How the Ground Truth for the Training Set was Established
- This question is not applicable for the same reasons as point 8.
In summary, the provided text details a regulatory submission for a physical dental device, focusing on demonstrating substantial equivalence through non-clinical testing (mechanical, material, digital workflow validation) rather than complex diagnostic performance studies common for AI or imaging devices.
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