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510(k) Data Aggregation
(138 days)
TruAbutment DS is a patient-specific CAD/CAM abutment, which is directly connected to endosseous dental implants and is intended to be used as an aid in prosthetic rehabilitation. It is compatible with the following systems: Astra OsseoSpeed EV (K130999, K120414), Biomet 3i Full OSSEOTITE Tapered Certain (K130949), DIO UF (II) Internal Submerged (K161987, K170608, K173975), Neoss ProActive® (K083561), Osstem TS (K161604), Camlog Screw-Line (K083496), Conelog Screw-Line (K113779), Implant Direct Legacy2 (K192221), BioHorizons Internal Implant System (K093321, K143022, K071638), MegaGen AnyRidge Internal Implant (K140091). All digitally designed abutments and/or copings for use with the TruAbutments are intended to be sent to a TruAbutment-validated milling center for manufacture.
TruBase is a titanium component that is directly connected to endosseous dental implants to provide support for patient-specific prosthetic restorations, such as copings or crowns. It is indicated for a screw-retained single tooth or cement-retained single tooth and bridge restorations. It is compatible with the following systems: Astra OsseoSpeed EV (K130999), Biomet 3i Full OSSEOTITE Tapered Certain (K130949), DIO UF(II) Internal Submerged (K161987, K170608, K173975), Neoss ProActive® (K083561), Camlog Screw-Line (K083496), Conelog Screw-Line (K113779), Implant Direct Legacy2 (K192221). All digitally designed abutments and/or copings for use with the TruAbutment are intended to be sent to a TruAbutment-validated milling center for manufacture.
TruAbutment DS, TruBase and abutment screw are made of Titanium grade Ti-6A1-4V ELI (meets ASTM Standard F136). TruAbutment DS, TruBase are supplied with two identical screws which are used: (1) For fixing the abutment into the endosseous implant. (2) For dental laboratory use during construction of related restoration. TruAbutment DS, TruBase are provided non-sterile. Therefore, it must be sterilized before use. TruAbutment DS, TruBase are devices that can only be sold, distributed, or used upon the order of an authorized healthcare provider, generally referred to as prescription (Rx) devices.
TruAbutment DS system includes patient-specific abutments that are placed into the dental implant to provide support for the prosthetic restoration. The subject abutments are indicated for serew-retained restorations. The design and manufacturing of the patient-specific abutments take into consideration the shape of the final prosthesis based on the patient's intra-oral indications using CAD/CAM system during the manufacturing. All manufacturing processes of TruAbutment DS are conducted at the TruAbutment milling center.
TruBase is a two-piece abutment. The base component is premanufactured and is used to support a cemented CAD/CAM zirconia superstructure. The base and the zirconia superstructure together form the final abutment. CAD/CAM customized superstructure that composes the final abutment is intended to be sent to a TruAbutment-validated milling center to be designed and milled, according to the prosthetic planning and patient clinical situation. The superstructure is cemented to the TruBase in the lab. Use "RelyX Unicem 2Automix" as an adhesive extra orally to connect.
The provided text is a 510(k) summary for the TruAbutment DS and TruBase devices. It primarily focuses on demonstrating substantial equivalence to a predicate device (TruAbutment DS, K203649) and does not detail an acceptance criteria table with reported device performance in the manner of a clinical study. The text describes non-clinical testing performed, but not a study designed to prove the device meets acceptance criteria related to a specific clinical outcome or diagnostic accuracy.
Therefore, many of the requested items (acceptance criteria table, sample size for test/training sets, data provenance, expert ground truth, adjudication, MRMC studies, standalone performance, type of ground truth) are not applicable based on the content of this 510(k) summary, which is a premarket notification for a medical device primarily based on demonstrating substantial equivalence through engineering and mechanical testing, not clinical performance or AI algorithm validation studies.
However, I can extract the information provided regarding non-clinical testing for the devices.
Acceptance Criteria and Study for TruAbutment DS & TruBase
Based on the provided 510(k) summary, the "acceptance criteria" and "study" described are focused on non-clinical mechanical performance testing and demonstration of substantial equivalence to a predicate device, rather than a clinical study proving performance against specific clinical or diagnostic accuracy metrics with human or AI components.
Here's the relevant information extracted and presented based on the document:
1. A table of acceptance criteria and the reported device performance
The document does not provide a table with specific quantitative acceptance criteria alongside actual reported numerical performance results for the new devices in the context of a comparative study proving their performance against such criteria. Instead, it states that "The results of the above tests have met the criteria of the standard and demonstrated substantial equivalence with the reference devices." This implies a qualitative "met standard" outcome rather than specific numerical performance data.
The tables provided describe the design limits of the devices and compare them to the predicate device, not performance data from a test:
TruAbutment DS Design Parameters (Acceptance Criteria are implied by meeting these limits)
Design Parameter | Subject Device (TruAbutment DS) Design Limit | Primary Predicate Device (K203649) Design Limit | Reported Device Performance (Implied) |
---|---|---|---|
Minimum and Maximum abutment angle (°) | 0 ~ 25 | 0 ~ 25 | Met specified range |
Minimum and Maximum cuff height (mm) | 0.5 ~ 6.0 | 0.5 ~ 6.0 | Met specified range |
Minimum and Maximum diameter at abutment/implant interface (Ø, mm) | 3.3 ~ 8.0 | 3.3 ~ 8.0 | Met specified range |
Minimum and Maximum length of the abutment (mm) | 6 ~ 11 | 6 ~ 11 | Met specified range |
Minimum wall thickness at abutment/implant interface (mm) | 0.4 | 0.4 ~ 0.9 | Met specified range |
Minimum and Maximum length of abutment post (length above the abutment collar / gingival height) (mm) | 4.0 ~ 7.0 | 4.0 ~ 7.0 | Met specified range |
TruBase Design Parameters (Acceptance Criteria are implied by meeting these limits)
Design Parameter | Subject Device (TruBase) Design Limit | Primary Predicate Device (K203649) Design Limit | Reported Device Performance (Implied) |
---|---|---|---|
Minimum and Maximum angulation (°) | 0 ~ 15 | 0 ~ 15 | Met specified range |
Minimum and Maximum gingival (cuff) height (mm) | 0.5 ~ 5.0 | 0.5 ~ 5.0 | Met specified range |
Minimum and Maximum diameter at abutment/implant interface (Ø, mm) | 5.0 ~ 8.0 | 5.0 ~ 8.0 | Met specified range |
Minimum thickness (mm) | 0.4 | 0.4 | Met specified value |
Minimum and Maximum length of abutment post (length above the abutment collar / gingival height) (mm) | 4.0 ~ 6.0 | 4.0 ~ 6.0 | Met specified range |
For mechanical performance, the document states:
"Mechanical performance testing was performed according to ISO 14801. For compatible OEM implant line, worst-case constructs were subjected to static compression and compression fatigue testing. The fatigue limit data for all other implant lines demonstrated the construct strengths to be sufficient for their intended use."
This confirms that the acceptance criteria for mechanical performance were "sufficient for their intended use" as defined by ISO 14801 and worst-case testing, but quantitative results are not provided.
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 for Test Set: The document mentions "worst-case constructs" were tested for mechanical performance, and "the entire system including all variations (all compatible implant bodies, dental abutments, and fixation screws)" was evaluated for MRI environment conditions. However, specific numerical sample sizes for these tests are not provided.
- Data Provenance: The data comes from non-clinical laboratory testing following international standards (ISO 14801, ISO 17665-1/2, ISO 10993 series). The country of origin and retrospective/prospective nature are not applicable as it's not a clinical data study.
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)
- This is not applicable. The "ground truth" for this type of device (dental abutments) is established through adherence to engineering design specifications, material standards (ASTM F136), and performance under mechanical stress tests (ISO 14801), as well as compliance with sterilization and biocompatibility standards. It does not involve expert interpretation of images or clinical outcomes in the same way an AI diagnostic device would.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- This is not applicable as there is no human interpretation or subjective assessment of data requiring adjudication. Testing is based on objective measurements against engineering standards.
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 is not applicable. The device is an endosseous dental implant abutment, not an AI diagnostic tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This is not applicable. The device is a physical dental component, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- The "ground truth" for validating these devices is adherence to engineering specifications, material properties, and performance standards (e.g., passing specific load-bearing and fatigue tests per ISO 14801, meeting biocompatibility requirements, maintaining dimensional accuracy). "Dimensional analysis and reverse engineering" were used to confirm compatibility.
8. The sample size for the training set
- This is not applicable. There is no "training set" as this is a physical medical device, not an AI/machine learning algorithm.
9. How the ground truth for the training set was established
- This is not applicable for the reason above.
Summary of the Study Proving Device Meets Criteria (Based on Provided Text):
The "study" conducted was primarily non-clinical laboratory testing to demonstrate the mechanical performance, sterilization efficacy, and biocompatibility of the TruAbutment DS and TruBase devices. The objective was to show substantial equivalence to an existing legally marketed device (TruAbutment DS, K203649) by proving that the new devices meet established design limits and performance standards relevant to dental implant abutments.
- Mechanical Testing: Performed on "worst-case constructs" according to ISO 14801 for static compression and compression fatigue. The outcome was that "construct strengths [were] sufficient for their intended use."
- Sterilization Testing: Performed per ISO 17665-1:2006, 17665-2:2009 and ANSI/AAMI ST79:2010.
- Biocompatibility Testing: Performed per ISO 10993-1:2009, ISO 10993-5:2009, and ISO 10993-10:2010.
- MRI Environment Evaluation: A non-clinical worst-case MRI review was done using scientific rationale and published literature to assess magnetically induced displacement force and torque.
- Dimensional Analysis and Reverse Engineering: Conducted on the implant-to-abutment connection platform to assess critical design aspects and tolerances, confirming compatibility.
The overall conclusion was that the devices "met the criteria of the standard and demonstrated substantial equivalence with the reference devices," thus indicating they met their implied acceptance criteria for safety and performance as medical devices. Clinical testing was explicitly stated as "not necessary."
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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:
-
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.
-
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.
-
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.
-
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.
-
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.
-
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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(338 days)
The TruAbutment DS is a patient-specific CAD/CAM abutment, directly connected to endosseous dental implants and is intended for use as an aid in prosthetic rehabilitation.
It is compatible with the following systems:
- · Biomet 3i Certain® (K130949) 3.25, 4.0, 5.0, 6.0 mm
- · DIO UF(II) Internal Submerged (K161987, K170608, K173975) 3.3, 3.8, 4.0, 4.5, 5.0, 5.5, 6.0, 6.5, 7.0 mm
- Megagen AnyRidge® (K140091) 3.5, 4.0, 4.5, 5.0, 5.5, 6.0, 6.5, 7.0, 7.5, 8.0 mm
- · Neoss ProActive® (K083561) 3.25, 3.5, 4.0, 4.5, 5.0, 5.5, 6.0 mm
All digitally designed abutments and/or coping for use with the TruAbutments are intended to be sent to a TruAbutment-validated milling center for manufacture.
The TruAbutment DS system includes custom abutments which are placed into the dental implant to provide support for a prosthetic restoration. The subject abutments are indicated for screwretained restorations. The custom abutment and abutment screw are made of Titanium grade Ti-6A1-4V ELI (meets ASTM Standard F-136). Each patient-specific abutment is supplied with two identical screws which are used for:
- (1) For fixing into the endosseous implant
- (2) For dental laboratory use during construction of related restoration.
The abutment is placed over the implant shoulder and mounted into the implant with the provided screw. The design and manufacturing of the custom abutments take into consideration the shape of final prosthesis based on the patient's intra-oral indications using CAD/CAM system during the manufacturing. All manufacturing processes of TruAbutment DS are conducted at the TruAbutment milling center and provided to the authorized end-user as a final patient-specific abutment.
The proposed abutments are available in internal hex connection, and are compatible with Biomet 3i Certain® Implant/DIO UF(II) Internal Submerged Implant/Megagen AnyRidge® Implant/Neoss ProActive® Implant.
The device being discussed is "TruAbutment DS", a patient-specific CAD/CAM abutment for dental implants.
The acceptance criteria for this device are established by demonstrating substantial equivalence to a predicate device (TruAbutment DS K170259) through non-clinical testing, primarily mechanical performance (fatigue) testing, and biocompatibility assessments. The study described focuses on non-clinical testing to meet these acceptance criteria rather than a clinical study.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Set by Standards & Guidance) | Reported Device Performance (as demonstrated by testing) | Equivalence Discussion |
---|---|---|
Mechanical Performance: Meets ISO 14801:2007 (dynamic fatigue with static compression) and FDA Guidance "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Implant Abutments" to demonstrate sufficient strength for intended use. | Comparative fatigue testing conducted according to ISO 14801 and FDA Guidance. Worst-case constructs (smallest diameter with maximum angulation) were subjected to static compression and compression fatigue. The fatigue limit data for all implant lines demonstrated the construct strengths to be sufficient for their intended use. | Equivalent. The testing demonstrated implant to abutment compatibility and established substantial equivalency. |
Material Biocompatibility: Meets ISO 10993-1:2009, ISO 10993-5:2009, and ISO 10993-10:2010. | Biocompatibility tests performed according to ISO 10993 series. Results met the standards. | Equivalent. No concerns regarding material. |
End User Steam Sterilization: Meets ISO 17665-1:2006, 17665-2:2009 and ANSI/AAMI ST79:2010. | End User Steam Sterilization Test performed according to specified ISO and ANSI/AAMI standards. | Equivalent. Confirmed sterility methods for end-user. |
Dimensional Compatibility: Demonstrates compatibility with specified OEM implant systems (Biomet 3i Certain®, DIO UF(II) Internal Submerged, Megagen AnyRidge®, Neoss ProActive®). | Dimensional analysis and reverse engineering of the implant-to-abutment connection platform were performed, assessing maximum/minimum dimensions, tolerances, and cross-sectional images of the submission device and compatible implants. | Equivalent. Demonstrated implant to abutment compatibility. Minor differences in compatible OEM implant lines are mitigated by mechanical testing. |
2. Sample size used for the test set and the data provenance
The document does not explicitly state the exact sample size (number of abutments or implants) used for the non-clinical mechanical and dimensional tests. It mentions "worst-case constructs" for fatigue testing.
Data provenance: The testing was conducted by the manufacturer (TruAbutment Inc.) as part of their 510(k) submission to the FDA, presumably in the USA (where the company is based). The data is retrospective as it was generated specifically for this submission.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable. The "ground truth" for this device's performance is established by meeting recognized international and national standards (ISO, FDA guidance) through non-clinical laboratory testing, not by expert consensus on clinical cases.
4. Adjudication method for the test set
This is not applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies or studies involving human interpretation of medical images. The studies performed for this device were non-clinical laboratory tests.
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 was not done. This device is a physical dental implant abutment, not an AI or imaging diagnostic tool that would involve human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. This device is a physical medical device, not an algorithm. The "standalone" performance is assessed by its mechanical integrity and biocompatibility when used as intended.
7. The type of ground truth used
The "ground truth" used for this device is based on established engineering and materials science principles and validated standards:
- Mechanical Performance: Defined by the specified fatigue limits and static load capabilities as per ISO 14801 and FDA guidance thresholds for dental implant abutments.
- Biocompatibility: Defined by the absence of adverse biological reactions as per ISO 10993 series standards.
- Dimensional Accuracy: Defined by precise measurements confirming compatibility with target implant systems.
8. The sample size for the training set
This is not applicable. This device is not an AI model that requires a training set. The CAD/CAM design process for patient-specific abutments involves individual patient data rather than a large training dataset for device development in the AI sense.
9. How the ground truth for the training set was established
This is not applicable as there is no "training set" in the context of an AI device. The design principles for the TruAbutment DS are based on established dental implantology, engineering design, and manufacturing standards for patient-specific CAD/CAM abutments.
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