OsteosScaf™ bone grafting material is indicated for filling and/or augmenting intraoral/maxillofacial osseous defects, such as intrabony periodontal osseous defects, furcation defects, augmentation of bony defects of the alveolar ridge, filling of tooth extraction sites, and sinus elevation grafting.
Device Story
OsteoScaf™ is a synthetic, osteoconductive, bioresorbable bone grafting material used in dental and maxillofacial surgery. Composed of a 3-phase composite (PLGA, calcium phosphate, and hydroxyapatite), it is provided as particulates, cylinders, or blocks. The device is implanted by a clinician into osseous defects to serve as a scaffold. Its trabecular structure mimics human cancellous bone, facilitating osteoconduction; as the material undergoes hydrolytic and cell-mediated degradation, it is replaced by native bone tissue. The device provides dimensional integrity during handling and placement. It benefits patients by promoting bone regeneration in surgical sites, such as extraction sockets or sinus elevations, aiding in the restoration of bony architecture.
Clinical Evidence
No human clinical data. Evidence consists of bench testing and animal studies. Bench testing verified chemical composition, impurity levels (ASTM 1185), density, porosity (>80%), particle size, morphology, and mechanical strength. Animal studies (rat calvaria model) demonstrated that OsteoScaf™ is osteoconductive and bioresorbable, showing increased new bone formation compared to coagulum control and faster resorption/bone replacement compared to predicate devices.
Technological Characteristics
3-phase composite scaffold: 22% PLGA, 66% calcium phosphates, 12% hydroxyapatite. Highly interconnected macroporous structure (0.25-1.2 mm pore size, >80% porosity). Form factors: particulate, cylinder, block. Sterilization: irradiation. Complies with ASTM 1185 for impurities.
Indications for Use
Indicated for filling and/or augmenting intraoral/maxillofacial osseous defects in patients requiring bone grafting for periodontal defects, furcation defects, alveolar ridge augmentation, tooth extraction sites, and sinus elevation.
Regulatory Classification
Identification
Bone grafting material is a material such as hydroxyapatite, tricalcium phosphate, polylactic and polyglycolic acids, or collagen, that is intended to fill, augment, or reconstruct periodontal or bony defects of the oral and maxillofacial region.
Special Controls
*Classification.* (1) Class II (special controls) for bone grafting materials that do not contain a drug that is a therapeutic biologic. The special control is FDA's “Class II Special Controls Guidance Document: Dental Bone Grafting Material Devices.” (See § 872.1(e) for the availability of this guidance document.)(2) Class III (premarket approval) for bone grafting materials that contain a drug that is a therapeutic biologic. Bone grafting materials that contain a drug that is a therapeutic biologic, such as biological response modifiers, require premarket approval.
(c)
*Date premarket approval application (PMA) or notice of product development protocol (PDP) is required.* Devices described in paragraph (b)(2) of this section shall have an approved PMA or a declared completed PDP in effect before being placed in commercial distribution.
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K101827
K081432
## Section 5
APR 2 0 2011
# 510(k) Summary
| Applicant Name<br>and Address | Texas Innovative Medical Devices (DBA)<br>Skeletal Regeneration, Ltd.<br>14785 Omicron Dr<br>Building 100, Suite 101<br>San Antonio, Texas 78245 | |
|-------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------|---------|
| Contact Person: | Jerry Chang<br>Senior Director of Quality Assurance/Regulatory Affairs<br>(210) 696-7616 | |
| Date of Summary: | January 18, 2011 (edits made) Original Submission made<br>June 30, 2010 | |
| Name of Device: | OsteoScaf™ | |
| Trade/Proprietary Name: | OsteoScaf™ | |
| Common Name: | Bone Grafting Materials, Synthetic | |
| Establishment Name: | OsteoScaf™ | |
| Establishment Number: | 21 CFR 872.3930 | |
| Proposed Classification: | Class II | |
| Product Code: | LYC | |
| Panel: | Dental | |
| Predicate Devices: | | |
| ReOSS™ | Intra-Lock International, Inc | K082419 |
| Bio-OSS™ | Geistlich Biomaterials, Inc | K033815 |
| Norian PDC™ | Norian Corp | K983104 |
| Vitoss™ | Orthovita, Inc | K083033 |
Depuy Spine, Inc
HEALOS™
{1}------------------------------------------------
#### Intended Use:
OsteosScaf™ bone grafting material is indicated for filling and/or augmenting intraoral/maxillofacial osseous defects, such as intrabony periodontal osseous defects, furcation defects, augmentation of bony defects of the alveolar ridge, filling of tooth extraction sites, and sinus elevation grafting.
#### Device Description:
OsteoScaf™ is a synthetic osteoconductive and bioresorbable bone grafting material composed of 3-phase biodegradable polymer and calcium phosphate composite, intended to fill and/or augment intraoral/maxillofacial osseous defects. It functions in the same manner as the predicate devices. The product is available as a particulate, cylinder, or block and is provided in sterile packaging in various dosage volumes.
#### Summary of Technological Characteristics:
The OsteoScaf™ bone grafting material is comprised of a 3-phase composite scaffold comprising poly (lactide-co-glycolide) (PLGA) and 2 osteoclast-resorbable calcium phosphate (CaP) phases that provide the same physical characteristics as the listed predicate devices. The latter are particulates synthesized at physiological temperature and blended with the PLGA phase, and a thin layer of hydroxyapatite surface coating generated in a simulated body fluid at physiological temperature. The Device is configured as a particulate, cvlinder or in a block shape and is packaged in a tray and a chevron type peel pouch for easy use. The product is irradiated to ensure sterility. The Device has a trabecular structure that is the same as the predicate devices and mimics the multidirectional interconnected porosity of human cancellous bone. The Device resorbs and is replaced with natural bone, which remodels during the healing process in the same fashion as that of the predicate devices.
#### Summary of Performance Testing:
Bench and animal studies were conducted to ensure that OsteoScaf™ bone grafting material met the predetermined design specifications. OsteoScaf™ has been tested for a number of chemical and physical characteristics: chemical composition, phase composition, trace of impurities, density and porosity, particle size, morphology, compressive strength and elastic modulus. All these characteristics are equivalent to those of the predicate device. OsteoScaf™ is osteoconductive and bioresorbable based on in vivo studies. When OsteoScaf™ is placed in direct contact with viable bone, new bone forms in apposition to the OsteoScaf™ surfaces and within the interstices of the implant. As the material resorbs, bone tissue grows into the space previously occupied by the implant. The testing performed included the following:
{2}------------------------------------------------
| Test Items | Summarized Results |
|----------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Chemical composition | 3-phase composite of 22% (wt) PLGA, 66% Calcium phosphates<br>and 12% hydroxyapatite. |
| Impurity | Testing demonstrates compliance with ASTM 1185 requirements. |
| Pore structure | Highly interconnected macroporous structure of larger than 80%<br>porosity and 0.25~1.2 mm pore size similar to human cancellous<br>bone. |
| Mechanical strength | The devices provides adequate handling properties and strength to<br>ensure dimensional integrity when handled by the surgeon and<br>delivered to bony application sites. |
| Degradation | All three phases of the composite can be resorbed over time through<br>hydrolytic and/or cell-mediated degradation. |
| Animal studies | 1) OsteoScaf™ was used to reconstruct the critical-sized defect in a<br>rat calveria model. The result demonstrated that more new bone<br>formed with OsteoScaf™, compared to coagulum control, after 4<br>weeks.<br>2) OsteoScaf™ gave rise to more new bone formation and faster<br>resorption of the material than the predicate in a rat model.<br>3) The biomechanical testing in rat model demonstrates that<br>OsteoScaf™<br>bone grafting material facilitates replacement with<br>native bone. |
#### Conclusion:
The Company Device (OsteoScaf™) is substantially equivalent to the predicate devices for filling and/or augmenting intraoral/maxillofacial osseous defects, such as intrabony periodontal osseous defects, furcation defects, augmentation of bony defects of the alveolar ridge, filling of tooth extraction sites, and sinus elevation grafting. The Device is also substantially equivalent to the predicate devices in terms of material composition, geometry, and technological characteristics. The material is at least as safe and effective as predicate devices.
{3}------------------------------------------------
#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a stylized eagle with three stripes forming its body and wings. The eagle is facing to the right. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the eagle.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Mr. Jerry Chang Senior Director of Quality Assurance and Regulatory Affairs Texas Innovative Medical Devices (DBA) Skeletal 4808 Research Drive San Antonio, Texas 78240
Re: K101827
Trade/Device Name: OsteoScafTM Regulation Number: 21 CFR 872.3930 Regulation Name: Bone Grafting Material Regulatory Class: II Product Code: LYC Dated: March 31, 2011 Received: April 1, 2011
APR 2 0 2011
Dear Mr. Chang:
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 mav, 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. Chang
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/ucm 115809.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 yours,
Nh 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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## Section 4 Indications for Use
510(k) Number (if known): K101827
Device Name: OsteoScaf™
Indications for Use:
OsteoScaf™ bone grafting material is indicated for filling and/or augmenting intraoral/maxillofacial osseous defects, such as intrabony periodontal osseous defects, furcation defects, augmentation of bony defects of the alveolar ridge, filling of tooth extraction sites, and sinus elevation grafting.
Prescription Use X (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use __ (21 CFR 801 Subpart C)
### · (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
K. Alberons for Dr. Susan Runner
Division Sign-Off
ivision Sign-K
Office of Device Evaluation (ODE)
510(k) K101827
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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.
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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?
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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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.
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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.