K081583 · Kuraray Medical, Inc. · EMA · Jul 28, 2008 · Dental
Device Facts
Record ID
K081583
Device Name
CLEARFIL SA CEMENT
Applicant
Kuraray Medical, Inc.
Product Code
EMA · Dental
Decision Date
Jul 28, 2008
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3275
Device Class
Class 2
Indications for Use
Cementation of crowns, bridges, inlays and onlays made of conventional porcelain, ceramic, hybrid ceramics, composite resin or metal. Cementation of metal cores, resin cores, metal posts or glass-fiber posts.
Device Story
CLEARFIL SA CEMENT is a dual-cure (light- and/or self-curing) dental resin cement. Used by dental professionals for luting/cementing restorations including crowns, bridges, inlays, onlays, and posts (metal, resin, glass-fiber). Composed of materials other than zinc oxide-eugenol. Applied by clinicians in a dental office setting to secure prosthetic restorations to prepared tooth structures. The dual-cure mechanism allows for polymerization via external light energy or self-curing chemical reaction, ensuring fixation of the restoration. Benefits include stable, durable bonding of various restorative materials.
Clinical Evidence
Bench testing only. Device performance verified against ISO 4049:2000 standards for polymer-based luting materials. No clinical data presented.
Technological Characteristics
Dual-cure (light/self-cure) resin cement. Classified as Class 3 material per ISO 4049:2000. Composition includes various dental resin materials. No specific dimensions or connectivity features described.
Indications for Use
Indicated for the cementation of crowns, bridges, inlays, onlays, metal cores, resin cores, metal posts, or glass-fiber posts in patients requiring dental restorations using porcelain, ceramic, hybrid ceramic, composite resin, or metal materials.
Regulatory Classification
Identification
Zinc oxide-eugenol is a device composed of zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp. Dental cement other than zinc oxide-eugenol is a device composed of various materials other than zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.
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### 510(k) Summary
## JUL 2 8 2008
#### 3-1. 510(k) owner (submitter)
1) Name
2) Address
3) Contact person
4) Contact person in U.S.
KURARAY MEDICAL INC.
1621 Sakazu, Kurashiki, Okayama 710-0801, Japan
Michio Takigawa Quality Assurance Department
CLEARFIL SA CEMENT
Dental adhesive resin cement
Dental cement
510(k) Number:
21 CFR Section:
Product Code:
Applicant:
Koji Nishida KURARAY AMERICA INC. 600 Lexington Avenue, 26th Floor New York, NY 10022 Tel: (212)-986-2230 (Ext. 115) or (800)-879-1676 Fax: (212)-867-3543
(21 CFR section 872.3275. Product code: EMA)
K032455
872.3275
EMA
#### 3-2. Name of Device
1) Trade / Proprietary name
2) Classification name
3) Common name
3-3. Predicate device
3) MAXCEM
1) PANAVIA F 2.0
### Applicant: 2) CLEARFIL ESTHETIC CEMENT & DC BOND
510(k) Number: K062410 Product Code: EMA
21 CFR Section: 872. 3275 KURARAY MEDICAL INC.
KURARAY MEDICAL INC.
510(k) Number: Product Code: 21 CFR Section: Applicant:
K041474 EMA 872. 3275 SYBRON DENTAL SPECIALTIES INC.
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#### 3-4. Device Description
- 1) CLEARFIL SA CEMENT is a dual-cure (light-and/or self-adhesive resin cement for conventional porcclain, ceramic, hybrid ceramics (e.g. ESTENIA C&B), composite resin and metal restorations.
- 2) It is classified into dental cement (21 CFR section 872.3275, Product code: EMA ) according to 21 CFR § 872 since it is composed of various materials other than zinc oxide-eugenol.
- 3) According to the applicable FDA recognized consensus standard, ISO 4049: 2000 "Dentistry - Polymer-based filling, restorative and luting materials", this device is classified into the following:
- Class 3: materials that are cured by the application of external energy and also have a self-curing mechanism present
#### 3-5. Substantial Equivalence Discussion
#### 1) Intended uses
-
It is intended to be used for the indications listed in the left hand column of the table of "Section 5: Executive Summary, Table 5" that are equivalent to the predicate devices, PANAVIA F2.0 and CLEARFIL ESTHETIC CEMENT & DC BOND.
#### 2) Chemical ingredients / Safety
All the chemical ingredients of CLEARFIL SA CEMENT, the subject device, have been used in the predicate devices, PANAVIA F2.0 and CLEARFIL ESTHETIC CEMENT & DC BOND. It indicates that the safety of the applicant device is substantially equivalent to that of the predicate devices.
#### 3) Effectiveness / Performance
CLEARFIL SA CEMENT, the subject device, has been verified to comply with the requirements of the applicable FDA recognized consensus standard, ISO 4049: 2000 "Dentistry - Polymer-based filling, restorative and luting materials". As to comparison with the predicate device, MAXCEM, according to ISO 4049; 2000, it was proved that both the subject one and the predicate one complied with ISO 4049: 2000 and the subject one should be effective as well as the predicate one,
### 3-6. Biocompatibility
All the chemical ingredients of CLEARFIL SA CEMENT, the subject device, have been used in the predicate devices as shown on the tables of "Section 7: Substantial Equivalence Discussion, Table: 7-2, 7-3, 7-4" where all the chemical ingredients of the subject device are listed in the left hand column and the abbreviated names of the predicate devices which contain the chemical component are listed in the right hand. From those tables, it can be said that the safety of the subject device is substantially equivalent to the predicate devices.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized eagle emblem, depicted with flowing lines to represent its wings and body. The eagle faces to the right.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
JUL 2 8 2008
Kuraray Medical, Incorporated C/O Mr. Koji Nishida General Manager Kuraray America, Incorporated 600 Lexington Avenuc, 26th Floor New York, New York 10022
Re: K081583
Trade/Device Name: CLEARFIL™ SA CEMENT Regulation Number: 872.3275 Regulation Name: Dental Cement Regulatory Class: II Product Code: EMA, KLE Dated: June 3, 2008 Received: June 12, 2008
Dear Mr. Nishida:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
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Page 2 - Mr. Nishida
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Chiu Lin, Ph.D. Director Division of Anesthesiology, General Hospital, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
K 68158 3 510(k) Number (if known):
Device Name: _CLEARFIL SA CEMENT
Indications for Use:
- 1) Cementation of crowns, bridges, inlays and onlays made of conventional porcelain, ceramic, hybrid ceramics, composite resin or metal
- 2) Cementation of metal cores, resin cores, metal posts or glass-fiber posts
Prescription Use __ (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use __ N/A . (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Susan Reaser
Division Sign-Off) Jivision of Anesthesiology, General Hospital nfection Control, Dental Devices
10(k) Number:
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.