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510(k) Data Aggregation

    K Number
    K222636
    Manufacturer
    Date Cleared
    2023-04-28

    (240 days)

    Product Code
    Regulation Number
    872.3630
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The ET Abutment System are indicated for use with ET Dental Implants to provide support to prosthetic restoration such as crowns, bridges and overdentures in partially or fully edentulous patients.

    Device Description

    The ET Abutment System are indicated for use with ET dental implants to provide support to prosthetic restoration such as crowns, bridges and overdentures in partially or fully edentulous patients. Manufactured from medical grade titanium alloy and delivered non-sterilized. The ET Abutments are available in various lengths and diameters; configurations are listed in the table below.

    AI/ML Overview

    This document describes a 510(k) premarket notification for a medical device called the "ET Abutment System," which is an endosseous dental implant abutment. The primary purpose of a 510(k) submission is to demonstrate substantial equivalence to a legally marketed predicate device, rather than proving safety and effectiveness through de novo clinical trials.

    Therefore, the submission does not contain information about specific "acceptance criteria" for an AI algorithm's performance, nor does it detail a study proving such a device meets these criteria in the typical sense of AI/ML performance evaluation. The "studies" referenced are non-clinical bench tests demonstrating the physical and material properties of the dental abutments are comparable to existing, legally marketed devices.

    Based on the provided text, here's an analysis of the "acceptance criteria" and "proof" in the context of this 510(k) submission:

    The acceptance criteria and proof fundamentally revolve around demonstrating substantial equivalence to predicate devices, not performance against a specific clinical metric for an AI algorithm.

    Missing Information:

    The document concerns a physical dental device (abutment system), not an AI/ML powered device. As such, the concept of "acceptance criteria" for AI performance, clinical study design for AI (sample size for test/training sets, data provenance, expert ground truth, adjudication, MRMC studies, standalone performance, etc.) are not applicable to this submission. The FDA letter confirms the device type: "Endosseous Dental Implant Abutment."

    However, to address the prompt's implied need for "acceptance criteria" and "studies" as they relate to this specific device (dental abutment), I will interpret the request within the context of a 510(k) submission for a non-AI medical device.


    1. Table of Acceptance Criteria and Reported Device Performance (as interpreted for a Dental Abutment System)

    In a 510(k) submission for a dental abutment, "acceptance criteria" are typically defined by demonstrating that the proposed device has the same technological characteristics and similar performance to legally marketed predicate devices, or that differences do not raise new questions of safety and effectiveness. The "reported device performance" comes from non-clinical bench testing.

    Acceptance Criterion (for Substantial Equivalence to Predicate)Reported Device Performance (from Non-Clinical Testing)
    Intended Use Equivalence: The device has the same intended use as the predicate.The ET Abutment System is "indicated for use with ET Dental Implants to provide support to prosthetic restoration such as crowns, bridges and overdentures in partially or fully edentulous patients." This matches the intended use of the primary predicate and reference devices, e.g., "Osstem Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures."
    Technological Characteristics Equivalence: The device has comparable design, dimensions, materials, surface, sterilization, and packaging as the predicate.- Design: "The ET Abutment System has the same design...as the predicate." (Explicitly stated) - Dimensions (Diameter, Length, Height, G/H): Various tables (pages 4, 5, 8, 9, 10, 11, 12, 13) compare proposed device dimensions to predicate/reference devices, showing direct matches or ranges that encompass them. E.g., ET Angled: Diameters 4.0 ~ 6.0 mm (Proposed) vs. 4.0 ~ 6.0 mm (Predicate). Heights 8.0 mm (Proposed) vs. 8.0 mm (Predicate). - Material: Primarily "Titanium alloy Ti-6Al-4V (ASTM F136)" or "Titanium CP Grade 3," and other specified materials (Nylon, Acrylonitrile & Butadiene Polymer (NBR), PolyCarbonate Polymer, Polyoxymethylene (POM), Gold alloy) are identical to those of the predicate devices. (Explicitly stated and documented in tables). - Surface: "Machine surface" across the board, matching predicates. (Explicitly stated and documented in tables). - Sterilization: "Delivered non-sterilized, Steam sterilized by user," matching predicates. "Validation was done following ISO 17665-1 [2006]... not necessary to re-test validation." - Packaging: "Housed in Tyvek-lidded blister tray; Placed in a tamper-evident outer package," matching predicates. Some also "Secured in plastic ampule."
    Performance Equivalence (Non-Clinical): Device performance is similar, and any differences do not raise new questions of safety or effectiveness.- Biocompatibility: "Contract manufactured by the predicate device manufacturer using the same manufacturing process and same well known and well-established material as the predicate device; therefore, we reason it was not necessary to re-test biocompatibility." - Shelf Life: "Do not have a stated shelf life" and "use the same exact packaging materials, manufactured from medical grade titanium alloy which are non-mechanical, non-active materials therefore, degradation in performance characteristics is not likely." - Surface Treatment Characterization Testing: "Contractured by the predicate device manufacturer, with surfaces using the same manufacturing process, material and surface finishing as the predicate devices... No additional character testing was necessary." - Mechanical Properties (Fatigue Testing): "Fatique testing of the worst case scenario was conducted per Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Abutments." Proposed devices "were fatigue tested in accordance with ISO 14801 Dentistry - Fatique Test for Endosseous Dental Implants." This implies the proposed device met the fatigue resistance established for the predicate under this standard. - MRI Compatibility: "K221684 has cleared the contract manufacturer's support for the MRI compatibility of the ET Abutment System." A non-clinical review evaluated components in the MRI environment using scientific rationale and published literature, addressing force and torque per FDA guidance.
    No New or Increased Risk: The device does not introduce new or increased risks compared to the predicate."The propose devices do not pose any new or increased risk as compared to both the legally marketed predicate and reference devices." This is the ultimate conclusion sought by demonstrating equivalence in all the above categories.

    2. Sample Size Used for the Test Set and Data Provenance

    Since this is a physical medical device submission and not an AI/ML algorithm:

    • Sample Size for Test Set: Not applicable in the context of an AI test set. For physical device testing, the sample sizes would be determined by the relevant ISO standards (e.g., ISO 14801 for fatigue testing). These specific numbers are not detailed in the summary but are typically part of detailed test reports that support the conclusion of substantial equivalence.
    • Data Provenance: The data comes from non-clinical testing (bench tests) performed to standard specifications (e.g., ISO 14801). The "ET Abutment System are contract manufactured by the predicate device manufacturer," implying the manufacturing process and potentially some historical performance data are shared or directly comparable.
      • Country of Origin: Not specified for the non-clinical test data itself, but the applicant (Hiossen Inc.) is in Fairless Hills, Pennsylvania, USA. The predicate manufacturer (Osstem Implant Co., Ltd.) is generally based in South Korea, suggesting potential international collaboration or shared manufacturing data.
      • Retrospective or Prospective: Not applicable in the context of patient data. The non-clinical tests would be conducted prospectively on newly manufactured devices.

    3. Number of Experts Used to Establish Ground Truth and Qualifications of Experts

    • This concept is not applicable as this is not an AI/ML diagnostic or image analysis device that requires expert labeling or interpretation for "ground truth." The "ground truth" here is the adherence to material specifications, dimensional tolerances, and performance under specific mechanical and biological test conditions as defined by international standards.

    4. Adjudication Method for the Test Set

    • This concept is not applicable as there is no "test set" in the sense of clinical cases requiring interpretation or adjudication by multiple readers/experts. Performance is based on mechanical, material, and sterilization testing against predefined standards.

    5. Multi Reader Multi Case (MRMC) Comparative Effectiveness Study

    • Not applicable. This type of study is for evaluating human performance with or without AI assistance, typically in image interpretation or diagnosis. This submission is for a physical dental implant component. The document explicitly states: "No clinical performance report(s) is being submitted."

    6. Standalone (i.e., algorithm only without human-in-the-loop performance) Study

    • Not applicable. This pertains to AI algorithm performance.

    7. Type of Ground Truth Used

    • The "ground truth" for this device's acceptance is based on engineering standards, material specifications, and performance data from validated non-clinical bench tests. This includes:
      • ASTM (American Society for Testing and Materials) standards for materials (e.g., ASTM F136 for titanium alloy).
      • ISO (International Organization for Standardization) standards for testing medical devices (e.g., ISO 14801 for fatigue testing of dental implants, ISO 17665-1 for moist heat sterilization).
      • FDA guidance documents (e.g., "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Abutments," "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment").
      • Direct comparison to the established characteristics and performance of the legally marketed predicate devices.

    8. Sample Size for the Training Set

    • Not applicable. This concept relates to AI/ML model development. There is no "training set" for a physical dental abutment. The device's design and manufacturing rely on established engineering principles and prior knowledge from the predicate device.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable. Again, this refers to AI/ML model training. The "ground truth" for developing a physical device is derived from engineering design principles, material science, and the performance history of similar devices.
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    K Number
    K210039
    Manufacturer
    Date Cleared
    2022-01-07

    (366 days)

    Product Code
    Regulation Number
    872.3640
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    CORE1 Implant System is indicated for use in partially or fully edentulous mandibles and maxillae, in support of single or multiple unit restorations including; cemented retained, and terminal or intermediate abutment support for fixed bridgework. This system is dedicated for one and two stage surgical procedures. This system is intended for delayed loading.

    CORE1 Implant System 3.3mm diameter implants may be used as an artificial root structure for single tooth replacement of mandibular central and lateral incisors and maxillary lateral incisors.

    Device Description

    CORE1 Fixture is a thread type implant made of CP Titanium Gr.4 according to ASTM F67 which will be placed in the alveolar bone to replace the function of missing tooth. This device has connection between the upper prosthesis and the internal hex. Fixture's surface is treated with SLA (Sandblasted with Large-grit and Acid-etching). It is only part to be implanted into bone, and to provide connection of prosthetic device or other components of a dental implant set with human body (mandibular or maxillary bone). Fixtures are provided after gamma sterilization as a set package including a cover screw or as a single fixture.

    CORE1 Abutment intended for Single Unit restorations is a superstructure of a dental implant system and connecting elements between the dental implant and the crown. It is to made of Ti-6A1-4V ELI (ASTM F136), and intended to be placed on the fixture allows single prosthetic restorations to restore a patient's chewing function. Abutment Screw made of Ti-6AI-ELI (ASTM F136) is used to connect and fix the abutment to the fixture. The contained various abutments and accessories in the system are Solid Abutment, Cement Abutment, Angled Abutment, Milling Abutment, Temporary Abutment, Solid Protect Cap, Cover Screw, Healing Abutment, Healing Abutment (Scan). Angled Abutment can select 15° and 25° angles for prosthetics, and Milling Abutment is up to 20° for hand milling only.

    CORE1 Abutment intended for Multi-Unit restorations is a superstructure of a dental implant system and connecting elements between the dental implant and the bridge. It is to made of Ti-6A1-4V ELI (ASTM F136), and intended to be placed on the fixture allows multi prosthetic restorations to restore a patient's chewing function. Universal Plastic Cylinder is a burn-out device only used in the lab for casting and is not part of the final restoration. Abutment Screw made of Ti-6A1-ELI (ASTM F136) is used to connect and fix the abutment to the fixture. The contained various abutments and accessories in the system are Universal Abutment, Universal Angled Abutment, Universal Ti Cylinder, Universal Temporary Cylinder, Universal Healing Cap. Universal Angled Abutment has angles of 17%30°.

    AI/ML Overview

    The provided document is a 510(k) summary for the CORE1 Implant System, demonstrating its substantial equivalence to predicate devices. It focuses on physical and material characteristics and performance testing based on industry standards, rather than clinical study results involving human or expert evaluation for diagnostic accuracy.

    Therefore, many of the requested details, such as those related to "acceptance criteria" for diagnostic accuracy, "sample size for the test set," "number of experts," "adjudication method," "MRMC study," "standalone performance," "type of ground truth," and "training set details" are not applicable or extractable from this document as it pertains to a dental implant system, not an AI/diagnostic device.

    However, I can extract information related to the device's performance through non-clinical testing.

    Here's a breakdown of the relevant information provided:

    1. A table of acceptance criteria and the reported device performance:

    The document doesn't define specific numerical "acceptance criteria" in a table format for diagnostic performance, as it's a dental implant. Instead, it describes performance through non-clinical testing against established ISO standards and FDA guidance for dental implants. The "acceptance" is demonstrated by meeting the requirements of these standards.

    Test PerformedAcceptance CriteriaReported Device Performance
    Bacterial Endotoxin TestAccording to USP and ANSI/AAMI ST72:2011. Testing limit of 20 EU/device for blood contacting and implanted device.Confirmed that the endotoxin test reagent (PTS cartridge) and laboratory environment were suitable, meeting endotoxin standards and established criteria. Implies performance within the accepted limit.
    Fatigue TestingAccording to ISO 14801:2016 and FDA guidance document "Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments". Objective: Confirm permanent restoration of the implant without failure.Performed on the subject device and reference device K190837 to confirm covering permanent restoration of the implant without failure. The language "to confirm covering permanent restoration of the implant without failure" implies successful completion meeting the standard.
    Surface AnalysisNot explicitly stated as a separate acceptance criterion but is part of material characterization.SEM & EDS analysis showed surface roughness leading to a macroroughness and no other impurity on the surface of the final product. This indicates the desired surface characteristics were achieved.
    Gamma SterilizationAccording to ISO 11137-1:2006/Amd.1:2013, ISO 11137-2:2013, and ISO 11137-3:2006. Objective: Acceptable range of densities of other product in carrier and confirm process stability.Evaluation showed an acceptable range of densities of other products in the carrier and confirmed process stability. Concluded that the packaging with gamma sterilization of the subject device is equivalent to predicate/reference devices, with a shelf life of 5 years.
    End User SterilizationAccording to ISO 17665-1:2006, ISO 17665-2:2009, and ANSI/AAMI ST79:2010/A4:2013.Performed according to the stated standards. The implicit result is that it meets the requirements for end-user sterilization.
    Biocompatibility TestingAccording to ISO 10993-1:2018 and FDA Guidance Document "Use of International Standard ISO 10993-1...", and ISO 10993-5:2009.Performed for each subject device. The non-clinical testing results demonstrate that the subject device is substantially equivalent to the predicate devices, which includes assurance of biocompatibility.

    2. Sample size used for the test set and the data provenance:

    • Sample size: Not explicitly stated as a number of devices. The testing is based on performing the required tests as per relevant ISO standards. For fatigue testing, it states it was performed on "subject device and reference device K190837," implying at least one of each for the test, but typically these tests involve multiple samples to establish robustness and statistical significance as required by the standards.
    • Data provenance: Not specified in terms of country of origin or whether it was retrospective/prospective. As this is non-clinical bench testing, the data is generated in a laboratory setting. The manufacturer, Cybermed Inc., is from the Republic of Korea.

    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 device is a dental implant, not a diagnostic device requiring expert review for "ground truth" establishment of medical conditions. The "ground truth" for performance is based on established engineering and materials science standards for dental implants.

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

    Not applicable, as this is non-clinical bench testing against established 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:

    Not applicable. This is a dental implant, not an AI/diagnostic device.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    Not applicable. This is a dental implant, not an AI/diagnostic device.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    The "ground truth" for this device's performance is derived from compliance with international and national standards for medical device safety and performance, specifically for dental implants (e.g., ISO 14801 for fatigue, ISO 10993 for biocompatibility, ISO 11137 for sterilization, USP for endotoxins).

    8. The sample size for the training set:

    Not applicable. This document does not describe a machine learning or AI algorithm, so there is no "training set."

    9. How the ground truth for the training set was established:

    Not applicable, as there is no "training set."

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    K Number
    K203360
    Manufacturer
    Date Cleared
    2022-01-07

    (417 days)

    Product Code
    Regulation Number
    872.3640
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K151626, K153332, K182091, K161689, K140507, K110308

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The EK Dental Implants are indicated for use in partially or fully edentulous mandibles and maxillae, in support of single or multiple-unit restorations including; cemented, screw or overdenture restorations, and final or temporary abutment support for fixed bridgework. It is indicated for delayed loading. Ultra wide versions are indicated for use in the molar region only.

    The EK Dental Implants (Ø3.5mm) are made of titanium alloy (Ti 6Al 4V) for Fixtures and Simple Mount and pure titanium for Cover Screw. The EK Dental Implants (Ø3.5mm) are indicated for use in mandibular and maxillary lateral and central incisor, in support of single or multiple-unit restorations including; cemented retained, screw retained, or overdenture restorations, and final or temporary abutment support for fixed bridgework. It is intended for delayed loading.

    The EK Dental Abutments are indicated for use with EK Dental Implants to provide support to prosthetic restoration such as crowns, bridges and overdentures in partially or fully edentulous patients.

    Device Description

    The EK Dental Implants are intended to be surgically placed in the bone of the upper or lower jaw arches, providing support to prosthetic devices to restore normal chewing functions. There are two types: SA and NH, both are bone level implants with the exact same internal hex, tapered body, use the same EK Dental Abutments, are manufactured from the same medical grade titanium materials and sterilized via gamma radiation. They only difference is the surface; SA is sand blasted and acid etched and NH which is SA + Dglucose + NaCI.

    The EK Dental Abutments are indicated for use with EK Dental Implants to provide support to prosthetic restoration such as crowns, bridges and overdentures in partially or fully edentulous patients. Manufactured from medical grade titanium alloy and delivered non-sterilized.

    The EK Dental Implants and Abutments are available in various lengths and diameters; configurations are listed in the table below.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for dental implants and abutments. It focuses on demonstrating substantial equivalence to previously cleared devices, rather than proving the device meets specific acceptance criteria through a clinical or performance study with a test set, ground truth, or expert readers as typically seen for novel AI/ML medical devices.

    Therefore, the requested information regarding acceptance criteria, device performance, sample sizes, expert involvement, adjudication methods, MRMC studies, standalone performance, and ground truth establishment is not directly applicable to this type of submission.

    Instead, the document demonstrates substantial equivalence by comparing the proposed EK Dental Implants and Abutments to predicate and reference devices across several key characteristics:

    • Intended Use: The proposed devices have the same intended use as the predicate devices (supporting single or multiple-unit restorations in edentulous mandibles and maxillae, for delayed loading).
    • Design/Structure: The proposed implants have an internal hex connection, are submerged fixtures, and have a tapered body shape, similar to the predicate devices. The abutments are also comparable in design to their reference devices.
    • Material: The implants use Pure Titanium Grade 4 (ASTM F67) and Titanium alloy Ti-6Al-4V (ASTM F136), which are standard materials also used in the predicate devices. Abutments use similar materials (Ti-6Al-4V, Co-Cr-Mo Alloy, Gold alloy as per the reference devices).
    • Surface Treatment: The implants employ SA (Sandblasted and Acid etched) and NH (SA + D-glucose + NaCl) surfaces, which are consistent with the predicate and reference devices.
    • Sterilization: Implants are gamma irradiated, and abutments are provided non-sterile for steam sterilization by the user, matching the predicate/reference devices.
    • Packaging: Similar packaging methods are used as the predicate devices.
    • Performance Characteristics (Non-Clinical):
      • Biocompatibility: Not re-tested, as the materials and manufacturing processes are the same as predicate/reference devices.
      • Sterilization Validation: Not re-tested for implants (same process as predicate) or for abutments (provided non-sterile like reference devices, with user steam sterilization).
      • Shelf Life: Not re-validated for implants (same as predicate's 8-year validated shelf life and packaging) or for abutments (non-sterile, non-mechanical, no stated shelf life, similar to reference devices).
      • Surface Treatment Characterization: Not re-tested, as surfaces are manufactured using the same process and materials as predicate/reference devices.
      • Fatigue Testing: Conducted in accordance with ISO 14801. The worst-case implant and abutment configurations withstood 5,000,000 cycles without failure at a substantially equivalent load to the primary predicate.
    • Clinical Performance Testing: No clinical performance report(s) were submitted, indicating that substantial equivalence was demonstrated through non-clinical data and comparison to predicates.

    In a 510(k) substantial equivalence submission for a traditional medical device like a dental implant, the "acceptance criteria" are effectively the demonstration of sufficient similarity in technological characteristics and performance (often non-clinical) to a legally marketed predicate device. The "study" proving this device meets the "acceptance criteria" is the comprehensive comparison outlined above, coupled with relevant non-clinical testing (like fatigue testing).

    Therefore, I cannot populate the table or answer the specific questions in the format requested, as they pertain to a different type of validation study (e.g., for an AI/ML diagnostic algorithm, which would involve a test set, ground truth established by experts, and statistical performance metrics).

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    K Number
    K200817
    Manufacturer
    Date Cleared
    2020-10-07

    (191 days)

    Product Code
    Regulation Number
    872.3640
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    URIS OMNI Narrow System is indicated for use in the treatment of missing maxillary lateral incisors or the mandbular central and lateral incisors, in support of single or multiple-unit restorations including: cemented retained, or overdenture restorations, and final or temporary abutment support for fixed bridgework. It is intended for delayed loading.

    The URIS OMNI Prosthetic abutments are intended for use with URIS OMNI dental implants to provide support for prosthetic restorations such as crowns, bridges, or over-dentures.

    All digitally designed abutments and/or coping for use with URIS OMNI Prosthetic abutments are intended to be sent to a TruAbutment-validated milling center for manufacture.

    Device Description

    URIS OMNI Narrow System fixtures are dental implants made of Unalloyed Titanium, grade 4 (ASTM F67) intended for use in the treatment of missing maxillary lateral incisors or the mandibular central and lateral incisors. The surface is SLA (Sandblasted, Large grit and Acid etched) treated and is provided sterile. It consists of two implant lines, the OMNI Straight and the OMNI Tapered, with corresponding cover screws, healing abutments and prosthetic abutments. The OMNI Tapered implant has a tapered wall with a single thread design. The OMNI Straight implant has straight wall with smaller threading at the coronal end, and bigger threading at the apical end. Both implant lines have Narrow (Ø 3.15 mm) platform sizes. Both implant lines share the following diameters and lengths.

    Ø 3.15 x 10, 11.5, 13, 14.5mm (L)

    URIS Prosthetic System is made of titanium alloy (Ti-6Al-4V ELI) intended for use as an aid in prosthetic restoration. It consists of Ball Abutment, Retainer, T LOC Straight Abutment, T Loc Titanium Cap, Multi-Unit Straight Abutment, Multi-Unit Angled Abutment, Multi-Unit Healing Cap, Multi-Unit Ti Cylinder, Multi-unit temporary cylinder, Multi-Unit Cylinder screw, URIS DS, URIS Base. No additional angulation is to be included in the when using a coping or cylinder (i.e., Multi-unit Ti Cylinder, Multi-unit Temporary Cylinder, Multi-unit Base) with any of the Multi-unit Abutments.

    URIS Base consists of a two-piece abutment, where the titanium base is a pre-manufactured abutment that will be used to support a CAD/CAM designed superstructure (the second part of the two-piece abutment) that composes the final abutment. URIS Base is made of titanium alloy conforming to ASTM F136 Standard Specification for Wrought Titanium-4Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications.

    URIS DS abutment as a patient matched titanium abutment compatible with both URIS OMNI System (K172100) and URIS OMNI Narrow System (subject).

    AI/ML Overview

    The provided document is a 510(k) Summary for a dental implant system. It discusses the substantial equivalence of the "URIS OMNI Narrow System & Prosthetic" to predicate devices based on non-clinical testing. The document does not contain information about acceptance criteria or a study proving the device meets acceptance criteria in the context of human reader performance or a standalone algorithm performance for AI/ML-driven devices.

    The document states: "No clinical data were included in this submission." and focuses on demonstrating substantial equivalence through comparisons of technological characteristics and non-clinical test data.

    Therefore, I cannot provide the requested information for an AI/ML device related to acceptance criteria, detailed study design, sample sizes, expert ground truth, adjudication methods, or MRMC comparative effectiveness studies, as these types of studies are not discussed in this 510(k) summary for this device.

    The "acceptance criteria" presented in this document are primarily related to the successful completion and results of non-clinical tests to demonstrate equivalence to predicate devices. These are not performance metrics for an AI/ML algorithm.

    Here's an analysis of what is provided regarding acceptance criteria in the context of this traditional medical device:

    1. A table of acceptance criteria and the reported device performance:

    The document implicitly defines acceptance criteria by listing the standards to which tests were performed and stating that "the results have met the criteria of the standards." The "reported device performance" is that it successfully met these standards, thereby demonstrating substantial equivalence.

    Acceptance Criteria (Standards Met)Reported Device Performance
    USP and USP for Bacterial EndotoxinMet the criteria of the standards
    ISO 10993-1 for BiocompatibilityMet the criteria of the standards
    ISO 11137-1,-2,-3 and ISO 11737-1,-2 for SterilizationMet the criteria of the standards
    ISO 17665-1,-2 for End user sterilizationMet the criteria of the standards
    ISO 11607-1,-2 / ASTM F1980-07, ASTM F88, ASTM F1140, ASTM F1929, ASTM F2096 and sterility testing for Shelf LifeMet the criteria of the standards
    ISO 14801:2016 and FDA Guidance for Fatigue TestingMet the criteria of the standards ("worst-case scenario")
    SEM and EDS analysisPerformed (implied acceptable by equivalence conclusion)

    2. Sample size used for the test set and the data provenance:
    Not applicable for this type of non-clinical, non-AI device study. The document refers to testing on the device itself (e.g., fatigue testing, sterilization testing, biocompatibility).

    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. Ground truth as typically understood for AI/ML performance is not relevant here. The "ground truth" for these tests would be the accepted parameters and methods defined by the referenced ISO/ASTM standards and FDA guidance.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
    Not applicable. This is not a human reader or AI performance study.

    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. This is not an AI/ML device.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
    No. This is not an AI/ML device.

    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc):
    Not applicable in the context of AI/ML device performance. For the described non-clinical tests, the "ground truth" is defined by the specific parameters and requirements of the referenced ISO/ASTM standards. For example, for biocompatibility, the ground truth is whether the materials meet the criteria specified in ISO 10993-1.

    8. The sample size for the training set:
    Not applicable. This is not an AI/ML device.

    9. How the ground truth for the training set was established:
    Not applicable. This is not an AI/ML device.

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    K Number
    K182091
    Date Cleared
    2019-07-12

    (343 days)

    Product Code
    Regulation Number
    872.3630
    Why did this record match?
    Reference Devices :

    K160670, K160519, K150295, K140507, K132067, K120847

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Osstem Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures.
    • Link Abutment for CEREC
    The Link Abutment for CEREC is titanium alloy abutments placed onto OSSTEM dental implants to provide support for customized prosthetic restorations. Link Abutment for CEREC is indicated for screw-retained single tooth or cement-retained single tooth and bridge restorations. All digitally designed copings and/or crowns for use with the Link abutment for CEREC is to be scanned using Sirona CEREC AC or CEREC AF or CEREC AI, designed using Sirona inLab software (Version 3.65) or Sirona CEREC Software (Version 4.2) and manufactured using a Sirona CEREC or inLab MC X or MC XL milling unit. CAD/CAM manufacturing/milling occurs at dental laboratories per the design limitations of the Sirona CEREC.

    Device Description

    Osstem Abutment System is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures.
    Osstem Abutment System is similar to other commercially available products based on the intended use, technology used, claims, material composition employed and performance characteristics.
    Osstem Abutment System is substantially equivalent in design, function and intended use to the predicate devices as above.
    The document then lists various components of the system including Transfer Abutment, Angled Abutment, Link Abutment for Cerec, Temporary Abutment, Multi Angled Abutment, Multi NP-Cast Cylinder, Multi Combination Cylinder, Convertible Angled Cylinder, Stud Abutment, O-ring, O-ring Retainer Cap, Port Abutment, Port Angled Abutment, Port Angled Abutment Head, Port Male, Port Extended Male, Port Male Cap, Port Male Kit, Abutment Screw, Cylinder Screw, Esthetic-low Temporary Cylinder, and Temporary Cap (Narrow Ridge), along with their descriptions, materials, and dimensions.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for the Osstem Abutment System. It outlines how the device is considered substantially equivalent to already marketed predicate devices, rather than providing a performance study against specific acceptance criteria for a new AI/software device.

    Therefore, many of the requested details, such as those related to AI/algorithm performance (e.g., test set sample size, expert ground truth establishment, MRMC studies, standalone performance), are not applicable to this type of submission. The document focuses on material properties, design, indications for use, and a comparison to predicate devices to establish substantial equivalence.

    Based on the provided text, here's what can be extracted and what cannot:

    1. A table of acceptance criteria and the reported device performance

    The document does not present explicit acceptance criteria in the typical sense of performance metrics for an AI/software device (e.g., accuracy, sensitivity, specificity). Instead, substantial equivalence is claimed based on similarities in:

    • Intended Use
    • Technology (design principles)
    • Material Composition
    • Performance Characteristics (mechanical properties, biocompatibility, sterilization)

    The performance is "reported" by demonstrating that the device is equivalent to known predicate devices through non-clinical testing (biocompatibility, sterilization validation, mechanical properties, specifically fatigue testing and retention testing). The document states: "Non-clinical testing data are submitted, referenced, or relied upon to demonstrate substantial equivalence."

    Acceptance Criteria (Demonstration of Substantial Equivalence to Predicates)Reported Device Performance (as described in the 510(k))
    BiocompatibilityEvaluted following FDA Guidance Document ISO 10993-1 and ISO 10993 suite of standards. (Implies compliance, but no specific numerical results or pass/fail thresholds are provided in this summary.)
    Sterilization ValidationConsidered according to ISO 17665-1 (for non-sterile delivery). (Implies validation, but no specific numerical results or pass/fail thresholds are provided. Products are provided non-sterile, so this refers to validation of sterilization methods for the end-user.)
    Mechanical Properties (Fatigue Testing)Considered according to FDA Guidance Document "Guidance for Industry and FDA Staff Class II Special Controls Guidance Document Root-form Endosseous Dental Implants and Endosseous Dental Abutment" and ISO 14801 standard with worst-case scenario. (Implies testing was performed and passed, but no specific numerical results or pass/fail thresholds are provided.)
    Mechanical Properties (Retention Testing for Dental Attachments)Conducted. (Implies testing was performed and passed, but no specific numerical results or pass/fail thresholds are provided.)
    Indications for Use"Identical, with the exception of the addition to the Subject Indications for Use Statements language regarding the Link Abutment for CEREC. This language is identical to the Indications for Use Statement of the Reference Device being used for the Substantial Equivalence comparison for the Link Abutment for CEREC." (Demonstrated through comparison tables in Section 6).
    Material Composition"Identical" or "Within the range of the predicates" for most components. (Demonstrated through comparison tables in Section 6).
    Design/Dimensions"Identical" or "Similar" or "Within the range of the predicates" with explanations for minor differences and why they don't affect safety/effectiveness. (Demonstrated through comparison tables in Section 6).

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    This information is not applicable and not provided. The submission relies on non-clinical (laboratory) testing for mechanical properties and biocompatibility, as well as comparison to predicate devices, not on a clinical test set with patient data.

    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. No clinical test set or human expert review of "truth" data for diagnostic performance is described.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Not applicable.

    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/software device that assists human readers.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    Not applicable.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    For mechanical testing, the "ground truth" would be established by the physical and mechanical properties of the materials and designs as measured in laboratory tests, and compared against established industry standards (ISO 14801) and FDA guidance for dental abutments. For biocompatibility, it's adherence to ISO 10993 standards. No clinical ground truth from patients is established or used for this 510(k) submission.

    8. The sample size for the training set

    Not applicable. There is no concept of a "training set" for this type of device submission.

    9. How the ground truth for the training set was established

    Not applicable.

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    K Number
    K161689
    Date Cleared
    2017-05-22

    (336 days)

    Product Code
    Regulation Number
    872.3630
    Why did this record match?
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The OSSTEM Implant System - Abutment is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures.

    Device Description

    The OSSTEM Implant System - Abutment is intended for use as an aid in prosthetic restoration. It consists of Abutments, components and Abutment Screws.

    AI/ML Overview

    This document is a 510(k) Premarket Notification of the OSSTEM Implant System - Abutment, indicating it is a dental device and not an AI/ML medical device. Therefore, the information requested in the prompt, which pertains to the acceptance criteria and study proving an AI/ML device meets those criteria, cannot be fully provided from this document.

    The document discusses the substantial equivalence of the OSSTEM Implant System - Abutment to predicate devices. This typically involves demonstrating that the new device is as safe and effective as a legally marketed predicate device, often through material comparisons, design comparisons, and performance testing for mechanical properties and biocompatibility, rather than clinical studies or performance against defined efficacy metrics tied to patient outcomes.

    However, I can extract information related to the device and the type of testing performed that is relevant to its acceptance for market.

    Here's a breakdown based on the provided text, addressing the points of your prompt where applicable, and highlighting what's not present due to the nature of the device:

    Device Description: The OSSTEM Implant System - Abutment is intended for use with a dental implant to provide support for prosthetic restorations such as crowns, bridges, or overdentures. It consists of Abutments, components, and Abutment Screws.

    Acceptance Criteria and Device Performance (General):
    For this type of device, "acceptance criteria" revolve around demonstrating substantial equivalence to existing, legally marketed predicate devices. This means proving the new device is as safe and effective as the predicate. The performance is assessed through:

    • Material composition: Comparing the materials used (e.g., Titanium Alloy, Zirconia, PEEK, PC, POM).
    • Design and dimensions: Comparing the shapes, diameters, and lengths.
    • Intended use: Confirming the device serves the same purpose.
    • Technological characteristics: Ensuring the fundamental mechanism of action is similar.
    • Nonclinical testing: Biocompatibility, sterilization validation, and mechanical properties.

    Table of Acceptance Criteria and Reported Device Performance (as inferred from a 510(k) for a non-AI/ML device):

    Acceptance Criteria CategorySpecific Criteria (Inferred for a Dental Abutment)Reported Device Performance (as demonstrated by comparison to predicates)
    Intended UseMust be for use with dental implants to support prosthetic restorations.Identical to predicate devices for all components. (e.g., page 7: "Indication for use of subject device is slight differences in phrase with predicate but fundamental Indication is same")
    MaterialsMust use materials with established biocompatibility and mechanical properties for dental implants.Identical to predicate devices (e.g., Titanium Alloy (Ti-6Al-4V), Zirconia, PEEK, PC, POM), or demonstrating equivalence if slight variations exist. (e.g., page 7: "Material: Zirconia, Identical"; page 8: "Material: Titanium Alloy PEEK, Identical")
    Design/DimensionsMust be geometrically compatible with specified implant systems and suitable for intended restorations.Substantially Equivalent or Identical designs and dimensions. Some new dimensions are added but fall within accepted ranges, or minor cosmetic/functional modifications are made that do not raise new safety/effectiveness questions. (e.g., page 7 "Connection structure is different (Hex and Non-Hex) but Design is Substantial Equivalence"; page 8 "Diameter 4.0mm is added"; page 9 "Design is Substantial Equivalence With highlighted predicate with red Box")
    Technological CharacteristicsMust function physically in a manner similar to predicate dental abutments (e.g., cement-retained, screw-retained).Identical to predicate devices (e.g., page 7 "Use for making general cement-type prosthesis. Identical"; page 8 "Cement retained restoration. Capable of altering/removing shape of plastic material. Two piece (Abutment + Screw) Identical")
    BiocompatibilityMust be biocompatible, as per ISO 10993 standards.Relying on identical materials and manufacturing processes as previously cleared predicate devices. "Therefore, no additional testing is necessary." (page 11)
    SterilizationMust be able to be sterilized to an appropriate Sterility Assurance Level (SAL).For Custom Healing Abutment, leveraged data from predicate device (ISO 11137-1, -2, -3 and shelf life testing). For other non-sterile devices, steam sterilization validation conducted per ISO 17665-1 and -2. (page 11)
    Mechanical PerformanceMust withstand normal forces and maintain integrity in the oral cavity. Generally, this would be mechanical testing.The document does not explicitly detail the mechanical performance results in a table format, but states that the device is "substantially equivalent in design, function and intended use" to predicates. This implies mechanical performance is considered equivalent due to material and design similarity, and potentially prior testing on the predicate devices. The listed nonclinical tests (like "tensile test (ASTM F882), seal peel test (ASTM F88/EN868-5), burst test (ASTM F1140), dye penetration (ASTM F1929), bubble test (ASTM F2096)") mentioned under sterilization validation are related to packaging and sterility, not the inherent mechanical strength of the abutment itself, which would be covered by separate mechanical testing for dental implants if required for initial approval. For this 510(k), they rely on the substantial equivalence premise.

    Here's how the remaining points of your prompt are addressed:

    1. Sample sized used for the test set and the data provenance:

      • Test set sample size: Not applicable in the context of an AI/ML algorithm's test set. The "testing" here refers to nonclinical lab tests and comparison to predicates.
      • Data provenance: Not directly applicable. The "data" are internal company reports demonstrating compliance with standards or comparisons to their own previously cleared devices. The manufacturer is OSSTEM Implant Co., Ltd. and their correspondent is HIOSSEN Inc., based in Republic of Korea and Pennsylvania, USA, respectively. The data are typically generated in a prospective manner for regulatory submission (i.e., tests are performed specifically for the submission).
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • Not applicable as this is a physical medical device, not an AI/ML algorithm requiring ground truth from experts for image interpretation or diagnosis.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • Not applicable. This concept pertains to consolidating expert opinions for ground truth in AI/ML performance studies.
    4. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

      • No MRMC study was done, as this is not an AI/ML device. The document explicitly states: "No clinical studies are submitted." (page 12)
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Not applicable, as this is not an AI/ML device.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • Not applicable. For this device, "ground truth" is embodied by established engineering specifications, material properties, and performance benchmarks for dental implants, which are verified through nonclinical laboratory testing against international standards (e.g., ISO, ASTM) and comparison to predicate device characteristics.
    7. The sample size for the training set:

      • Not applicable. There is no concept of a "training set" for this type of conventional physical device.
    8. How the ground truth for the training set was established:

      • Not applicable. (See #7).

    Summary of Acceptance:

    The device's acceptance (clearance) by the FDA is based on demonstrating substantial equivalence to existing predicate devices (listed in section 3 and 6) in terms of:

    • Indications for Use: Identical.
    • Technological Characteristics: Very similar, with minor differences in design/dimensions that do not raise new safety/effectiveness concerns.
    • Materials: Identical.
    • Performance (Nonclinical): Biocompatibility is leveraged from predicate devices; sterilization validated according to relevant ISO standards.

    The document explicitly states: "No clinical studies are submitted." This reinforces that the acceptance was based on nonclinical testing and comparison to predicates, as is common for many Class II medical devices in the 510(k) pathway.

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    K Number
    K153350
    Date Cleared
    2016-05-09

    (171 days)

    Product Code
    Regulation Number
    872.3640
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K140507, K123755, K111120

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The IBS Implant System is intended to replace missing teeth to restore chewing function. The IBS Implant can be placed in support of single or multiple-unit restorations including; cement retained, screw retained, or overdenture restorations, and terminal or immediate abutment support for fixed bridgework. This system is for one or two stage surgical procedures. This system is intended for delayed loading.

    Device Description

    An endosseous dental implant is a device made of a material such as Ti-6AL-4V Eli (Conforming to ASTM Standard F-136). The IBS Implant System is consists of dental implants, abutments, and screws for use in one or two-stage dental implant placement and restorations. The implant-abutment connection is tight and precise fitting with internal hex and Morse taper bevel.

    The surface of the system has been treated with RBM (Resorbable Blasted media) to increase junction strength by increasing the area of bone-implant interface.

    There are 2 types of fixtures in this system, NR Fix and Magic FC. The NR Fix has diameters in 3.5mm and lengths in 9, 10, 11, 12, 13, 14 mm. The Magic FC has diameters in 4. 4.5. 5.0. 5.5. 6.0. 6.5mm and lengths in 7. 9. 11, 13. 15 mm.

    The contained various abutments and accessories in the system are Magic Screw retained type Abutment & protect cap, Healing Abutment, Angled Abutment (hexa, non hexa), Pair Abutment (non hexa), Solid Abutment & Solid abutment cap, Magic abutcoping (transfer type, pick up type), Multiunit abutment, UCLA abutment.

    Fixtures and abutments are packaged separately. The Fixtures are supplied sterile and the abutments and accessories are provided non-sterile. The abutments and accessories should be sterilized before use. But healing abutment is supplied sterile.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the IBS Implant System, primarily focusing on demonstrating substantial equivalence to predicate devices rather than providing detailed acceptance criteria and study results for device performance. As such, much of the requested information regarding specific acceptance criteria, detailed study parameters, ground truth establishment, sample sizes, and expert qualifications for performance evaluation (especially for AI/standalone algorithm performance) is not available in this document.

    The document primarily discusses non-clinical data to support substantial equivalence.

    Here's an attempt to extract the available information based on your request, followed by acknowledgments of what is missing:


    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly state acceptance criteria in terms of numerical performance thresholds (e.g., specific accuracy, sensitivity, specificity, or success rates) for the device. Instead, the reported "performance" is demonstrated through compliance with recognized standards and successful non-clinical testing to show substantial equivalence.

    Acceptance Criteria CategorySpecific Criteria (as inferred/stated)Reported Device Performance (as summarized)
    Intended UseReplace missing teeth to restore chewing function; support single or multiple-unit restorations (cement/screw retained, overdentures, fixed bridgework); one or two-stage surgical procedures; delayed loading.Matches the predicate device's intended use, demonstrating substantial equivalence.
    Material CompositionFabricated from Ti-6AL-4V Eli (Conforming to ASTM Standard F-136).Subject device is fabricated from Ti-6AL-4V Eli (Conforming to ASTM Standard F-136), same as predicate.
    SterilizationSterilization validation performed in accordance with ISO 11137-1:2006, ISO 11137-2:2009.Sterilization Validation testing performed in accordance with specified ISO standards. Fixtures are supplied sterile; healing abutments are supplied sterile. Other abutments/accessories are non-sterile and require sterilization before use.
    Surface TreatmentSurface treated with RBM (Resorbable Blasted media) to increase junction strength by increasing bone-implant interface area.Surface treatment analysis used. Similar R.B.M. surface as predicate.
    Fatigue ResistanceFatigue test performed under worst-case scenario in accordance with ISO 14801:2007.Fatigue test performed in accordance with ISO 14801:2007.
    Shelf LifeChanged from 2 years to 5 years.Not explicitly stated as "met" acceptance criteria, but noted as a change in the submission. Implies successful testing to support this change.
    General Device Design/FunctionDesigned, manufactured, and tested in compliance with FDA's "Class II Special Controls Guidance Document: Root-form Endosseous Dental Implant and Endosseous Dental Implant abutments."Device found substantially equivalent, implying compliance with this guidance.

    Missing Information (Not available in the provided text):

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • The document mentions "non-clinical tests" and "fatigue test" but does not detail the sample sizes (e.g., number of implant samples tested) or data provenance (e.g., from which specific test batches or labs). No human or clinical data is mentioned, so no information on retrospective/prospective human data.

    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 as no human-expert-evaluated test set is described. The "ground truth" for the non-clinical tests would be the established performance metrics or compliance standards.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable as no human-expert evaluation/adjudication 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 or AI-assisted study is mentioned. This filing is for a physical dental implant system, not an AI software device.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

    • Not applicable; this is not an AI algorithm.

    7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

    • For the non-clinical tests (sterilization, fatigue, surface analysis), the "ground truth" would be established by the specifications of the relevant ISO and ASTM standards and the results obtained from laboratory testing (e.g., successful biological indicator kill for sterilization, passing cycles for fatigue).

    8. The sample size for the training set

    • Not applicable; this is not an AI algorithm.

    9. How the ground truth for the training set was established

    • Not applicable; this is not an AI algorithm.

    Summary of what the document confirms:

    The IBS Implant System received 510(k) clearance by demonstrating substantial equivalence to existing predicate devices. This was supported by:

    • Matching intended use.
    • Identical material composition (Ti-6AL-4V Eli conforming to ASTM F-136).
    • Compliance with non-clinical testing standards including ISO 11137-1:2006, ISO 11137-2:2009 for sterilization validation, and ISO 14801:2007 for fatigue testing.
    • Similar surface treatment (R.B.M.).
    • A general statement of being "designed, manufactured and tested in compliance with FDA's Class II special controls guidance document root-form endosseous dental implants and endosseous dental implant abutments."

    The review process focused on these points to confirm that the new device does not raise new questions of safety and effectiveness compared to the already marketed predicate devices.

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