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510(k) Data Aggregation

    K Number
    K250390
    Date Cleared
    2025-05-19

    (97 days)

    Product Code
    Regulation Number
    N/A
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K163029

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

    Relieves the symptom and discomfort of dry mouth, refreshes, moisturizes/hydrates, and lubricates oral dryness.

    Device Description

    CloSYS® Dry Mouth Sensitive Mouth Rinse is an oral rinse designed to alleviate the symptoms of dry mouth for home use. The formulation includes water, humectants/ moisturizers, flavors, sweeteners, as well as ingredients with lubricating, soothing, and refreshing properties. The product is a ready-to-use, non-sterile, semi-viscous clear liquid, packaged in 16.0 FL OZ white High-Density Polyethylene (HDPE) bottles within a carton. Accelerated stability testing of the finished product supports a shelf life of 2 years. The rinse is formulated to have similar properties as predicate product Biotene Dry Mouth Oral Rinse Fresh Mint, which is a medical device 510(k) Number K123731 and the reference device Hydris™ Oral Rinse cleared under K163029. CloSYS® Dry Mouth Sensitive Mouth Rinse will be available in 16 fl oz (473 mL) PET bottles in a carton.

    AI/ML Overview

    The provided FDA 510(k) clearance letter and summary for the CloSYS® Dry Mouth Sensitive Mouth Rinse focuses on establishing substantial equivalence to predicate devices, primarily through technological characteristics and non-clinical testing. This type of submission generally does not include extensive clinical studies or acceptance criteria tables related to device performance as you might find for novel drug or high-risk medical device approvals.

    Therefore, many of the requested points regarding acceptance criteria, study details, sample sizes, expert ground truth, adjudication, MRMC studies, and standalone performance for an AI/software device are not applicable to this particular 510(k) summary for a dry mouth rinse.

    Here's an analysis based on the provided document:

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

    The document does not present a formal table of acceptance criteria for specific performance metrics (like efficacy percentages, reduction in dry mouth symptoms, etc.). For this type of device, substantial equivalence is primarily evaluated based on similar indications for use, technological characteristics (ingredients, presentation, function), and safety (biocompatibility, stability).

    The "performance" reported is related to safety and stability, rather than clinical efficacy against a specific quantitative target.

    Acceptance Criteria CategoryReported Device Performance (from "Discussion and Conclusions from the Nonclinical and Clinical Tests")
    Safety- Biocompatibility: Demonstrated to be safe through standard biocompatibility testing (Sensitization, Mucosal Irritation, Cytotoxicity) in accordance with ISO 10993.
    • Results: Assays demonstrated an acceptable biocompatibility profile consistent with the predicate. |
      | Stability | - Stability Studies: Stability of the finished product is monitored at room temperature and under accelerated conditions.
    • Results: Accelerated stability testing supports a shelf life of 2 years. |
      | Technological Equivalence| - Same Intended Use: Relieves symptom and discomfort of dry mouth, refreshes, moisturizes/hydrates, lubricates oral dryness.
    • Same Technology: Ready-to-use liquid, similar ingredients/solvents/moisturizers/sweeteners/thickeners. |

    2. Sample sizes used for the test set and the data provenance

    Not applicable in the context of this 510(k) for a dry mouth rinse. The non-clinical studies mentioned (biocompatibility, stability) would have their own sample sizes (e.g., number of cell cultures, animal subjects, or product batches tested), but these are not specified in this summary. There is no "test set" here in the sense of a clinical trial cohort or an AI model's validation dataset.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. There is no "ground truth" derived from expert consensus for clinical performance in this submission. Safety assessments (biocompatibility) would be evaluated by toxicologists/biocompatibility specialists, and stability by analytical chemists, but these are not clinical "experts" establishing a disease-related ground truth in the manner implied by the question.

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

    Not applicable. No clinical test set or adjudication method is described in this 510(k) summary.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    Not applicable. This device is a mouth rinse, not an AI or imaging device that would involve human readers or MRMC studies.

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

    Not applicable. This device is a medical product, not an algorithm.

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

    For the safety studies, the "ground truth" is based on established scientific methods and ISO standards for biocompatibility (e.g., cell viability, irritation scores, sensitization reactions). For stability, it's based on analytical measurements over time compared to pre-defined specifications. There is no clinical "ground truth" (like pathology results for a diagnostic device) mentioned for this type of product in this summary.

    8. The sample size for the training set

    Not applicable. There is no "training set" for this kind of medical device approval. This concept applies to machine learning models, not physical products like a mouth rinse.

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

    Not applicable. As there is no training set, there is no ground truth established for it.

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    K Number
    K181194
    Date Cleared
    2019-02-15

    (287 days)

    Product Code
    Regulation Number
    N/A
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K163029

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

    Provides relief of the symptoms and discomfort of dry mouth; refreshes, moisturizes, cleans, soothes oral irritation and lubricates oral dryness. Freshens breath.

    Device Description

    SmartMouth® DryMouth Oral Rinse is a specially formulated water soluble artificial saliva with for use at home in the oral cavity. It is formulated with water, humectants/moisturizers, including two moisture-rich humectants that are plant based, thickeners/binders, buffers, sweeteners, flavor, and colorant that collectively have moisturizing, soothing, and refreshing properties. The device is provided ready to use as a non-sterile, two-part semi-viscous green colored liquid packaged in white polyethylene terephthalate (PET) bottles with a clear polypropylene cap that present the liquid out of the polypropylene spout.

    AI/ML Overview

    The provided document is a 510(k) summary for the SmartMouth® DryMouth Oral Rinse. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving a device meets specific performance criteria through extensive clinical studies like those for novel high-risk devices.

    Therefore, the sections of your request regarding acceptance criteria, study details, expert involvement, and ground truth are not applicable to this document, as it describes a clearance process for a low-risk, unclassified device based on substantial equivalence.

    Here's a breakdown based on the information available:

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

    • Acceptance Criteria: For this 510(k) submission, the primary "acceptance criteria" is demonstrating substantial equivalence to the predicate devices (Biotene Dry Mouth Oral Rinse K123731 and Hydris Oral Rinse K163029) in terms of Indications for Use, technological characteristics, safety, and effectiveness.
    • Reported Device Performance:
      • Indications for Use: The device provides relief of symptoms and discomfort of dry mouth; refreshes, moisturizes, rehydrates, cleans, soothes oral irritation and lubricates oral dryness. It also freshens breath. These are largely identical to the predicate devices, with "freshens breath" being an additional claim.
      • Technological Characteristics: The device is a "formulation of water, humectants or moisturizers, thickening/binding agents, buffering agents, sweeteners, flavor, and colorant" for at-home oral cavity use.
      • Shelf-life: 36 months, same as the primary predicate device.
      • Physical Properties: Demonstrated substantial equivalence to predicate devices in Appearance, Color, Odor, pH, Viscosity, Specific Gravity, and Water Content through comparative physical property data.
      • Biocompatibility: Assessed in accordance with ISO 10993-1, demonstrating safety for use as directed.

    The document provides a comparison table of the proposed device against the predicate devices (see page 5 and 6 of the original document). This table effectively serves as the "performance against criteria" for this type of submission.

    Table of Performance Comparison (Derived from the document):

    Feature/CriteriaPrimary Predicate Device (Biotene Dry Mouth Oral Rinse K123731)Reference Device (Hydris Oral Rinse K163029)Proposed Device (SmartMouth® DryMouth Oral Rinse K181194)Equivalence/Meeting Criteria
    Indications for UseRelieves symptoms of dry mouth, refresh, moisturize, clean, soothe oral irritation, lubricate oral dryness.Relieves symptoms and discomfort of dry mouth, refresh, moisturize/hydrate, clean, soothe oral irritation, lubricate oral dryness.Provides relief of symptoms and discomfort of dry mouth; refreshes, moisturizes, rehydrates, cleans, soothes oral irritation, lubricates oral dryness. Freshens breath.Substantially Equivalent (with additional 'freshens breath' claim, deemed an extension of 'refreshes')
    Technological BasisFormulation of water, humectants/moisturizers, thickeners/binders, buffers, sweeteners, flavor, surfactants and preservatives.Formulation of water, humectants/moisturizers, thickeners/binders, buffers, sweeteners, and flavor.Formulation of water, humectants/moisturizers (plant-based), thickeners/binders, buffers, sweeteners, flavor, and colorant.Substantially Equivalent
    Shelf-life Stability36 months(Not explicitly stated in comparison, assumed to be robust)36 monthsEquivalent
    Physical Properties(Standard for oral rinses)(Standard for oral rinses)Appearance, Color, Odor, pH, Viscosity, Specific Gravity, Water Content demonstrated substantial equivalence.Substantially Equivalent
    Biocompatibility(Assumed to be safe)(Assumed to be safe)Assessed per ISO 10993-1; deemed safe for use.Sufficient

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

    • Not Applicable. This submission did not involve a test set for clinical performance evaluation. Non-clinical tests were conducted on the device itself (e.g., shelf-life, physical properties, biocompatibility).

    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" establishment by experts was part of this 510(k) submission.

    4. Adjudication method for the test set

    • Not Applicable. No clinical test set requiring adjudication was part of this 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 a medical device (oral rinse), not an AI-assisted diagnostic tool. No MRMC studies were performed.

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

    • Not Applicable. This is a medical device (oral rinse), not an algorithm.

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

    • Not Applicable. For the non-clinical tests conducted, the "ground truth" was based on established scientific methods for measuring physical properties, stability, and biocompatibility standards (e.g., pH meters for pH, viscometers for viscosity, ISO 10993-1 for biocompatibility). There was no "ground truth" in the clinical sense with patient outcomes or expert consensus.

    8. The sample size for the training set

    • Not Applicable. This product is an oral rinse, not a machine learning model. There was no training set.

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

    • Not Applicable. This product is an oral rinse, not a machine learning model. There was no training set or ground truth for it.
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