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510(k) Data Aggregation

    K Number
    K221315
    Date Cleared
    2023-10-25

    (537 days)

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

    K031055, K200586, K213599, K172640, K161416, K052823

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

    The UNIdental Symphony 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, or overdenture restorations, and terminal or intermediate abutment support for fixed bridgework. The UNIdental Symphony Implant System is for single and two stage surgical procedures. It is intended for delayed loading.

    Device Description

    The UNIdental Symphony Implant System is a dental implant system made of Titanium 6AL 4V ELI alloy and CP Ti Grade 4 intended to be surgically placed in the bone of the upper or lower jaw arches for loading after a conventional healing period. The implants may be used to replace one or more missing teeth. The systems are similar to other commercially available products based on the intended use, the technology used, the claims, the material composition employed and performance characteristics. Symphony 1 Fixture is Bone level, and Symphony 2 Fixture is Tissue level.

    Symphony 1 Fixture is a taper shape that gradually decreases the outer diameter of the lower part from the upper part.

    And It is a taper shape that gradually decreases the outer diameter of the lower part from the upper part. It is a structure that can perform a tapping function at the same time without a separate tap. It couples up with the abutment and its hexagon shape.

    Symphony 2 Fixture is a structure with a round shape at the end. It couples up with the abutment and its octagon shape. The area that touches the patient's gums is pure titanium surface.

    The upper structure of the abutments support prosthetics such as artificial teeth to restore patient's total mouth function.

    AI/ML Overview

    The provided text details the 510(k) summary for the UNIdental Symphony Implant System, focusing on its substantial equivalence to predicate devices rather than directly presenting acceptance criteria and performance data in the traditional sense of a clinical study for an AI/CADe device.

    This document describes a dental implant system, which is a physical medical device, not a software or AI-driven diagnostic device. Therefore, the questions related to "AI vs without AI assistance," "standalone algorithm performance," "number of experts for ground truth," "adjudication methods," and "training/test set size and provenance" are not applicable to this type of medical device submission.

    The "acceptance criteria" for a dental implant system of this nature typically revolve around meeting established engineering standards and demonstrating comparable performance (e.g., mechanical strength, biocompatibility, sterilization efficacy) to already cleared predicate devices. The "study that proves the device meets the acceptance criteria" refers to the non-clinical testing performed to demonstrate substantial equivalence.

    Here's an interpretation of the provided information based on the typical requirements for a physical medical device:

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

    The document doesn't explicitly list "acceptance criteria" in a numerical table format for each performance metric, as one might see for an AI device's sensitivity/specificity. Instead, the acceptance is implicitly demonstrated by showing substantial equivalence to existing predicate devices through various non-clinical tests and material comparisons. The "performance" is implicitly deemed acceptable if it meets the established standards that the predicates have also met.

    Acceptance Criteria (Implied)Reported Device Performance (Demonstrated by Substantial Equivalence and Non-Clinical Testing)
    Intended Use EquivalenceMatches the intended use of predicate devices (partially or fully edentulous mandibles and maxillae, supporting single/multi-unit restorations).
    Technological Characteristics EquivalenceUses similar designs, operating principles, materials (Titanium 6AL 4V ELI alloy and CP Ti Grade 4), and sterilization methods (Gamma, Steam).
    BiocompatibilityBiocompatibility tests performed per ISO 10993-3, 5, 6, 10, and 11, indicating device is biocompatible.
    Sterilization EfficacySterilization validating testing performed per ISO 11137 (gamma) and ISO 17665-1/17665-2 (steam), demonstrating effective sterilization.
    Mechanical Strength/FatigueCompressive load and fatigue tests performed in accordance with ISO 14801, demonstrating mechanical integrity comparable to predicate devices. The text explicitly states, "We have conducted a fatigue test and the subject device is substantially equivalent to the predicate device."
    Shelf-life StabilityShelf-life testing performed in accordance with ASTM F1980, ISO 11607, ASTM F88, ASTM F1140, ASTM F1929, ASTM F2096, and ISO 11737-2, indicating stable performance over time.
    Surface CharacteristicsSEM and EDS performed to evaluate fixture surface characteristics after SLA treatment. (Implied acceptability of surface given no issues raised).
    Bacterial Endotoxin Levels (LAL)LAL tests performed in accordance with USP 85. (Implied acceptable levels given no issues raised).
    MRI SafetyNon-clinical worst-case MRI review performed based on existing literature (e.g., Kim et al. 2019, Woods et al. 2019) and alignment with FDA guidance, concluding safety in MRI environment due to material properties.

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

    • Sample Size for Test Set: Not explicitly stated as a "test set" in the context of an AI model. For the non-clinical physical testing (fatigue, biocompatibility, sterilization, etc.), the sample sizes would be determined by the specific ISO/ASTM standards referenced. These standards usually specify the number of samples required for robust statistical analysis to demonstrate compliance. This is not a "data provenance" like for AI models, but rather the laboratory conditions under which the physical tests were conducted. The document doesn't specify the country of origin for the non-clinical testing data, but the submitter is UNIdental Co., Ltd. in Korea. This is inherently a prospective testing process for the device being submitted.

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

    • Not Applicable. This is a physical dental implant, not a diagnostic AI device requiring expert consensus for ground truth.

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

    • Not Applicable. See point 3.

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

    • Not Applicable. This is a physical dental implant, not an AI-assisted diagnostic device.

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

    • Not Applicable. This is a physical dental implant, not an algorithm.

    7. The type of ground truth used:

    • For physical devices, "ground truth" is established through adherence to recognized national and international consensus standards (e.g., ISO, ASTM) for material properties testing, mechanical performance, biocompatibility, and sterilization. For example, the "ground truth" for fatigue resistance is meeting the load cycles and fracture limits defined by ISO 14801. Biocompatibility "ground truth" is meeting the criteria of ISO 10993 series.

    8. The sample size for the training set:

    • Not Applicable. This is a physical device submission; there is no "training set" in the context of an AI model.

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

    • Not Applicable. See point 8.
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    K Number
    K192436
    Manufacturer
    Date Cleared
    2020-01-23

    (139 days)

    Product Code
    Regulation Number
    872.3630
    Panel
    Dental
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K041368, K112045, K141457, K153268, K172640

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

    Dentium Prosthetics are intended for use as an aid in prosthetic rehabilitation.

    Device Description

    The purpose of this submission is to change the sterilization method of Healing Abutments and Cover Screws. These devices which have been provided non-sterilized by gamma radiation.

    Healing Abutments are used provisionally as an accessory to endosseous dental implant during healing period to prepare gingival tissue for acceptance of a final abutment. Healing Abutments are designed to aid in soft tissue contouring during the healing period after implant placement, creating an emergence profile for the final abutment. Cover Screws are used provisionally as an accessory to protect the inner features of the implant.

    The Healing Abutments and Cover Screws are prefabricated and made of Ti-6Al-4V ELI (ASTM F136). These devices are sterilized using gamma radiation method and intended for single use only.

    AI/ML Overview

    The provided document is a 510(k) premarket notification for "Healing Abutments and Cover Screws." This type of submission focuses on demonstrating substantial equivalence to a predicate device, rather than proving a device meets specific performance acceptance criteria through the kind of rigorous, large-scale studies typically associated with AI/ML-based medical devices or novel technologies.

    Therefore, many of the requested details, such as sample size for test sets, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, and training set details, are not applicable to this specific submission. This document describes a change in the sterilization method for existing devices, not a new device with performance metrics that require extensive clinical validation studies beyond sterilization and biocompatibility.

    Here's an analysis based on the information available in the document:


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

    For a 510(k) submission concerning a change in sterilization method for mechanical components like healing abutments and cover screws, the "acceptance criteria" revolve around demonstrating that the new sterilization method achieves the required sterility assurance level and does not adversely affect the device's material properties or function, maintaining its substantial equivalence to the predicate.

    Acceptance Criteria CategorySpecific Criteria (Implicit/Explicit)Reported Device Performance/Evidence
    Sterilization EfficacyAchieve a Sterility Assurance Level (SAL) of 10^-6, in accordance with recognized standards."Gamma radiation sterilization validation according to ISO 111137-1 and ISO 11137-2, demonstrating a sterility assurance level (SAL) of 10^-6." (Page 4)
    BiocompatibilityThe device material (Ti-6Al-4V ELI (ASTM F136)) must be biocompatible and the sterilization process must not negatively impact biocompatibility."Biocompatibility of Ti-6A1-4V ELI (ASTM F136) demonstrated by the referenced Dentium submission, K041368, using the identical materials and manufacturing processes including sterilization as the subject device." (Page 4)
    Material Integrity/Shelf-lifeThe sterilization process should not degrade the material or product function over its intended shelf-life."Accelerated and real time aging studies according to ASTM F1980 demonstrating a shelf life." (Page 4)
    Functional EquivalenceThe design, materials, and intended use of the device must remain substantially equivalent to previously cleared versions (predicates), despite the change in sterilization. This is demonstrated by comparing technological characteristics like material, form, connection type, dimensions, and indication for use. The only noted difference between the subject device and the primary predicate device for both healing abutments and cover screws is the sterilization method (Pages 7, 9).The document states that the subject devices (Healing Abutments and Cover Screws) have the "same characteristics for the followings compared to the primary predicate device: Indication for use, Material, Connection type, Dimension" (for Healing Abutments, Page 7) and "Indication for use, Material, Dimension" (for Cover Screws, Page 9). Dimensions are extensively compared and shown to match various predicates (Pages 6-7, 9).

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

    • Sample Size: Not explicitly stated as a separate "test set" in the context of clinical performance data typical for AI/ML devices. The "tests" here are primarily engineering and laboratory validations:
      • Sterilization Validation: ISO 11137 standards define the number of units and replicates required for sterility testing (e.g., bioburden determination, dose mapping, sterility testing), which are often small, specific lots. This is standard laboratory validation, not a patient-based test set.
      • Aging Studies: ASTM F1980 dictates sample sizes for accelerated aging, again, laboratory testing of physical samples.
      • Biocompatibility: Relies on a prior submission (K041368) which presumably included its own biocompatibility testing. No new "sample size" for a clinical test set is mentioned for biocompatibility here.
    • Data Provenance: The studies are laboratory-based ("Non-clinical testing data"). The manufacturer is located in the Republic of Korea (Dentium Co., Ltd.). The data would be derived from their internal validation processes. It is neither retrospective nor prospective in the sense of patient studies.

    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 submission does not involve image interpretation or clinical diagnosis where expert ground truth would be established. The "ground truth" for sterilization is a defined SAL, verified by microbiological and physical testing per ISO standards. The "ground truth" for material properties is based on ASTM standards and prior biocompatibility data.

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

    • Not Applicable. As there is no clinical "test set" based on human interpretation or an AI algorithm's output requiring adjudication, this concept does not apply.

    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 traditional medical device (dental implants and accessories), not an AI-assisted diagnostic or therapeutic device. Therefore, no MRMC study, human reader improvement, or AI assistance is relevant.

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

    • Not Applicable. This is a physical medical device, not an algorithm.

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

    • The "ground truth" for this submission is based on:
      • Standardized Sterility Assurance: Achieving a defined SAL of 10^-6, verified through validated sterilization processes and testing compliant with ISO 11137-1 and ISO 11137-2.
      • Material Standards: Biocompatibility established against Ti-6Al-4V ELI (ASTM F136) as per regulations and previous submissions.
      • Engineering Performance: Shelf-life demonstrated through accelerated and real-time aging studies per ASTM F1980.
      • Substantial Equivalence: Demonstrated by comparing engineering specifications and intended use against legally marketed predicate devices.

    8. The sample size for the training set

    • Not Applicable. This involved physical device manufacturing and validation, not machine learning model training.

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

    • Not Applicable. (See point 8)
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