K100539 · Preventive Technologies, Inc. · EJR · Jun 17, 2010 · Dental
Device Facts
Record ID
K100539
Device Name
PREVENTECH PROPHYLAXIS PASTE WITH FLUORIDE
Applicant
Preventive Technologies, Inc.
Product Code
EJR · Dental
Decision Date
Jun 17, 2010
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.6030
Device Class
Class 1
Indications for Use
PREVENTECH Prophylaxis Paste with Fluoride is intended to be used for cleaning and polishing procedures as part of a professionally administered prophylaxis treatment. (218 CFR 872.6030),
Device Story
PREVENTECH Prophylaxis Paste with Fluoride is an oral cavity abrasive polishing agent; contains sodium fluoride, pumice, humectants, and sweeteners. Applied by dental professionals during routine hygiene procedures using a low-speed dental handpiece and prophylaxis cup at <5000 RPM. Used for cleaning, polishing, and removal of stain and plaque. Benefits include professional dental hygiene maintenance. Packaged in 2-gram individual use cups.
Clinical Evidence
Bench testing only. Relative Enamel Abrasion (REA) study (REA09-284) compared enamel abrasion performance of subject device against predicate (ENAMEL PRO).
Technological Characteristics
Oral cavity abrasive polishing agent. Composition: 1.23% fluoride ion (sodium fluoride), pumice abrasive, glycerin/polyol humectants, Xylitol/sodium saccharin sweeteners, flavoring, and color agents. Form factor: paste in 2g individual use cups. Application: low-speed dental handpiece (<5000 RPM) with prophylaxis cup.
Indications for Use
Indicated for cleaning and polishing teeth during professionally administered prophylaxis treatment.
Regulatory Classification
Identification
An oral cavity abrasive polishing agent is a device in paste or powder form that contains an abrasive material, such as silica pumice, intended to remove debris from the teeth. The abrasive polish is applied to the teeth by a handpiece attachment (prophylaxis cup).
Predicate Devices
ENAMEL PRO™ Professional Prophylaxis Paste with ACP (Amorphous A. Calcium Phosphate), Premier Dental (K062166)
NUPRO® (Satin) Prophylaxis Paste with Fluoride, Dentsply International (K912945)
Submission Summary (Full Text)
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K100539
## 510(k) SUMMARY
(21 C.F.R.§ 807.87(a), 807.92)
JUN 1 7 2010
- Applicants Information/Address: 1. Preventive Technologies, Inc 4330 Matthews-Indian Trail Road Indian Trail, North Carolina 28079
- 2. Establishment Registration Number: 1061053
- 3. Contact Person/Telephone: Kenneth S. Peterson 704-849-2416 (Phone) 704-849-2417 (Fax)
- 4. Date Summary was Prepared: February 18, 2010
#### ડ. Device Identification:
- A. Panel: DENTAL
- B. Proprietary Name: PREVENTECH Prophylaxis Paste with Fluoride
- C. Common Name: Dental Prophylaxis Paste
- D. Classification Name: Oral Cavity Abrasive Polishing Agent (215 CFR 872.6030)
- E. Classification: Class I
- F. Product Code: EJR
#### Legally Marketed Predicate Device(s): 6.
- ENAMEL PRO™ Professional Prophylaxis Paste with ACP (Amorphous A. Calcium Phosphate), Premier Dental (K062166)
- B. NUPRO® (Satin) Prophylaxis Paste with Fluoride, Dentsply International,
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### (K912945)
Proposed Labeling Sufficient to Describe the Device, Its Intended Use, and the Directions for Its Use: (807.87(e)), (continued);
#### 7. Description of the Device:
PREVENTECH Prophylaxis Paste with Fluoride is an oral cavity abrasive polishing agent containing sodium fluoride in a blend of enamel polishing and cleaning abrasive agents in a paste form designed for professional application to the teeth during the course of standard dental hygiene procedures. PREVENTECH Prophylaxis Paste with Fluoride is sweetened with Xylitol® and offered in various grit levels and various flavors.
The standard mode of application for PREVENTECH Prophylaxis Paste with Fluoride is by use of a low speed Dental Handpiece and accessories, (21 § CFR 872.4200) and a Prophylaxis Cup, (21§ CFR 872.6290).
#### 8. Statement of Intended Use:
PREVENTECH Prophylaxis Paste with Fluoride is intended to be used for cleaning and polishing procedures as part of a professionally administered prophylaxis treatment. (218 CFR 872.6030),
#### 9. Technological Characteristics and Comparison of Devices
- A. The technological characteristics of the Proposed device. PREVENTECH Prophylaxis Paste with Fluoride is substantially equivalent to the Predicate devices, ENAMEL PRO Professional Prophylaxis Paste with ACP. (K062166) and NUPRO (Satin) Prophylaxis Paste with Fluoride, (K912945) in:
- i.) Intended Use: The Proposed device, PREVENTECH Prophylaxis Paste with Fluoride and Predicate devices, ENAMEL PRO Professional Prophylaxis Paste with ACP, (K062166) and NUPRO (Satin) Prophylaxis Paste with Fluoride, (K912945) have the same Intended Use;
- For cleaning and polishing procedures as part of a professionally ટ્વ. administered prophylaxis treatment (218 872.6030).
- ii.) Composition: The Proposed device, PREVENTECH Prophylaxis Paste with Fluoride and Predicate devices. ENAMEL PRO Professional Prophylaxis Paste with ACP, (K062166) and NUPRO (Satin) Prophylaxis Paste with Fluoride, (K912945) are similar in components used;
- Sodium fluoride, 1.23% Fluoride ion, a.
- Pumice as the abrasive agents at various grit levels for cleaning. b. polishing, stain and plaque removal,
- c. Glycerin and/or other humectants polyols for moisture control. viscosity and lubrication during use,
- d. Xylitol® or sodium saccharin as sweetening agents,
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- Flavoring and color agents. e.
Proposed Labeling Sufficient to Describe the Device, Its Intended Use, and the Directions for Its Use: (807.87(e)), (continued);
- iii.) Shelflife/Expiration Dating: The Proposed device, PREVENTECH Prophylaxis Paste with Fluoride will be labeled with an expiration date of two (2) years from date of manufacture. This statements is similar to the Predicate devices, ENAMEL PRO Professional Prophylaxis Paste with ACP, (K062166) and NUPRO (Satin) Prophylaxis Paste with Fluoride, (K912945).
- iv.) Method of application; Prophylaxis Paste is applied to teeth during a routine dental hygiene procedure via the use of a low speed Dental Handpiece and accessories, (21§ 872.4200) and a Prophylaxis Cup, 218872.6290) at RPM of less than 5000.
- Primary Package; The Proposed device, PREVENTECH Prophylaxis Paste v.) with Fluoride and Predicate devices, ENAMEL PRO Professional Prophylaxis Paste with ACP. (K062166) and NUPRO (Satin) Prophylaxis Paste with Fluoride, (K912945) are packaged into 2 gram Individual Use cups,
- vi.) Relative Enamel Abrasion (REA); The Proposed device, PREVENTECH Prophylaxis Paste with Fluoride and Predicate device, ENAMEL PRO Professional Prophylaxis Paste with ACP, (K062166) demonstrate similar performance for enamel abrasion. The Proposed device, PREVENTECH Prophylaxis Paste with Fluoride is identified as Prophy Paste C and Predicate device, ENAMEL PRO Professional Prophylaxis Paste with ACP, (K062166) is identified as Prophy Paste B as referenced in Final Report, Relative Enamel Abrasion (REA) Study, REA09-284.
#### 10. Substantial Equivalence (SE) Summary Statement
In summary, we believe the Proposed device, PREVENTECH Prophylaxis Paste with Fluoride is substantially equivalent in composition and performance to the Predicate devices ENAMEL PRO Professional Prophylaxis Paste with ACP, (K062166) and NUPRO (Satin) Prophylaxis Paste with Fluoride, (K912945) as referenced in this submission. The components used in the Proposed device, PREVENTECH Prophylaxis Paste with Fluoride are similar to those components used in the Predicate devices described within this submission as well as other dental prophylaxis products.
CONFIDENTIAL
3
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized depiction of an eagle or bird-like figure with three wing-like strokes. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular fashion around the bird symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Mr. Kenneth S. Peterson Vice President, Research and Development Preventitive Technologies, Incorporated 4330 Mathews-Indian Trail Road Indian Trail, North Carolina 28079
JUN 1 7 2010
Re: K100539
Trade/Device Name: PREVENTECH Prophylaxis Paste with Flouride Regulation Number: 21 CFR 872.6030 Regulation Name: Oral Cavity Abrasive Polishing Agent Regulatory Class: 1 Product Code: EJR Dated: May 27, 2010 Received: June 4, 2010
Dear Mr. Peterson:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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. Peterson
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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to
http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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 (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely vours,
for
Anthony D. Watson, B.S., M.S., M.B.A. 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 STATEMENT
(21 CFR §§ 807.87(h), 807.92) .
510(K) Number (if known):
Device Name: PREVENTECH Prophylaxis Paste with Fluoride.
Indications for Use:
For cleaning and polishing procedures as part of a professionally administered prophylaxis treatment.
Prescription Use AND/OR (21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C
# Concurrence of CDRH, Office of Device Evaluation (ODE)
Kein Muly for MSN
(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices
510(k) Number: K100539
8
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.