CLEARCORRECT SYSTEM

K113618 · Clearcorrect, Inc. · NXC · Mar 19, 2012 · Dental

Device Facts

• Record ID: K113618
• Device Name: CLEARCORRECT SYSTEM
• Applicant: Clearcorrect, Inc.
• Product Code: NXC · Dental
• Decision Date: Mar 19, 2012
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 872.5470
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The ClearCorrect System is indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e. all second molars). The ClearCorrect System positions teeth by way of continuous gentle force.

Device Story

ClearCorrect System consists of sequential, clear, thin thermoformed polyurethane plastic trays; designed to progressively reposition teeth via continuous gentle force. Dental professional assesses patient, takes molds, and submits prescription; ClearCorrect uses standard dental software to design tray series; physician reviews/approves model scheme. Trays are manufactured, then provided to patient by dental professional; patient wears trays sequentially (typically 2-4 weeks per tray) to move teeth. Trays are removable by patient. System used in dental clinic setting; monitored by orthodontist or dentist. Benefits include gradual tooth realignment for malocclusion correction.

Clinical Evidence

No clinical testing was required. Substantial equivalence was supported by non-clinical bench testing, including visual performance, mechanical performance, device processing performance, and biocompatibility (cytotoxicity, intracutaneous reactivity, oral mucosa irritation, and delayed-type hypersensitivity).

Technological Characteristics

Sequential thermoformed polyurethane plastic aligners. Principle of operation: continuous gentle force via sequential tray changes. Biocompatibility: USP Class VI, ISO 10993-5 (cytotoxicity), ISO 10993-10 (reactivity/irritation/hypersensitivity). Software: standard dental alignment design software used for tray fabrication.

Indications for Use

Indicated for treatment of tooth malocclusion in patients with permanent dentition (all second molars).

Regulatory Classification

Identification

An orthodontic plastic bracket is a plastic device intended to be bonded to a tooth to apply pressure to a tooth from a flexible orthodontic wire to alter its position.

Predicate Devices

• ClearCorrect System (K082556)
• FS Aligner System (K093821)

Submission Summary (Full Text)

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K1136/8

# Section 5 - 510(k) Summary for ClearCorrect System

#### 1. Submission Sponsor

ClearCorrect LLC 15151 Sommermeyer St. Houston, Texas 77041 United States Phone: [phone] x 11 e-mail: [e-mail] Contact: Pedro Garcia, VP of QA/RA ClearCorrect LLC

#### 2. Submission Correspondent

Emergo Group 611 West 5th Street, Third Floor Austin, TX 78701 Cell Phone: Office Phone: [phone] Fax: [phone] Contact: Cheryl Fisher, Sr. QA/RA Consultant Email: [e-mail]

- 3. Date Prepared
10/31/2011

#### 4. Device Name

Trade/Proprietary Name: ClearCorrect System Common/Usual Name: Invisible braces Classification Name: Sequential Aligner Classification Regulation: 872.5470 Classification Panel: 872 Dental Product Code: NXC Device Class:2

FDA Establishment Registration #: 3007130440-

#### Predicate Devices 5.

ClearCorrect System, ClearCorrect LLC K082556 FS Aligner System, Sybron Dental Specialties K093821

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## ClearCorrectLLC Traditional 510(k) Premarket Submission ClearCorrect System

#### 6. Device Description

The ClearCorrect device is fabricated of clear thin thermoformed polyeurathane plastic in a sequential series to progressively reposition the teeth. Corrective force to straighten the teeth is delivered via minor changes into a position in each subsequent aligner.

## 7. Intended Use

The ClearCorrect System is indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e. all second molars). The ClearCorrect System positions will
earting and of of continuous gentle force.

## 8. Summary of Usage

A dental health care professional (e.g. orthodontists or dentists), prescribes the ClearCorrect system based on an assessment of the patient's teeth, determines a course of treatment with the system, takes molds of the patient's teeth and completes a prescription form. The molds and prescription are sent to ClearCorrect. Utilizing standard dental software used for tooth alignment, ClearCorrect designs a series of plastic trays intended to gradually realign the patient's teat briefd.
the physicing's provincial and since and the patient's teeth in accordance with the physician's prescription. The prescribing physician reviews and approves the model scheme before the molds are produced. Once approved, ClearCorrect the model schefne
of cloar, thin thermator worked, ClearCorrect produces the trays, which are formed of clear, thin thermoformed polyeurathaneplastic. The trays are sent back to the dental health care professional, who then provides them to the patient, confirming fit and design. Over a period of months, additional trays are provided sequentially to the patient by the dental health care professional to gradually move the target teeth to the desired position. The dental care professional monitors treatment from the moment the first aligner is delivered to when treatment is completed. The trays are held in place by pressure and can be removed by the patient at any time. This technology is essentially identical to that used by a number of sequential alignment systems, including the predicates referenced below.

# 9. Technological Characteristics and Substantial Equivalence

The following table compares the ClearCorrect Systemsto the predicate devices, ClearCorrect System unmodified and the FS Aligner System with respect to intended use, technological characteristics and principles of operation, providing more detailed information regarding the basis for the determination of substantial equivalence.

| Feature | FS | ClearCorrect | ClearCorrect<br>modified | Comparison |
|---------------------|------------------------------|------------------|--------------------------|---------------|
| 510 (k)<br>Number | K093821 | K082556 | Not yet assigned | |
| Manufacturer | Sybron Dental<br>Specialties | ClearCorrect LLC | ClearCorrect LLC | |
| Classification<br># | 872-5470 | 872-5470 | 872-5470 | Same |
| Product Code | NXC | NXC | NXC | Same |
| Intended Use | The FS Aligner System | The | The | Comparable in |

## Comparison Table

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ClearCorrectLLC

## Traditional 510(k) Premarket Submission ClearCorrect System

| is intended for minor<br>anterior tooth<br>movement in patients<br>with<br>permanent dentition<br>(second molars). The<br>FS Aligner System<br>positions teeth by way<br>of<br>continuous gentle<br>force. | ClearCorrectSystem<br>is indicated for the<br>treatment of tooth<br>malocclusion in<br>patients with<br>permanent<br>dentition (i.e. all<br>second molars),<br>The ClearCorrect<br>System positions<br>teeth by way of<br>continuous gentle<br>force | ClearCorrectSystem is<br>indicated for the<br>treatment of tooth<br>malocclusion in<br>patients with<br>permanent dentition<br>(i.e. all second<br>molars), The<br>.ClearCorrect System<br>positions teeth by<br>way of continuous<br>gentle force | the FS Aligner<br>and the same<br>in the<br>unmodified<br>ClearCorrect<br>System | |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------|
| Mode of<br>Action | Each appliance is<br>worn by patient as<br>determined by dental<br>practitioner. Generally<br>2-4 weeks prior to<br>using the next<br>sequential aligner | Alignment of teeth<br>by sequential use<br>of preformed<br>plastic trays | Alignment of teeth by<br>sequential use of<br>preformed plastic<br>trays | Comparable in<br>the FS Aligner<br>System and the<br>same in the<br>unmodified<br>ClearCorrect<br>System |
| Material | Thin thermoformed<br>plastic material | Thermoformed<br>polycarbonate | Thermoformed<br>polyeurathane | Comparable<br>over all three<br>systems |
| OTC or Rx | Rx | Rx | Rx | Same |

# 10. Non-Clinical Testing

- 1. Visual Performance
- 2. Mechanical Performance
- 3. Device Processing performance
- 4. Biocompatibility

## Materials

- . USP Class VI
Finished Product Biocompatibility

- ISO 10993-5 Cytotoxicity .
- . ISO 10993-10 Intracutaneus Intradermal reactivity, Oral Mucosa Irritation test, Maximum
test for Delayed Tuna H test for Delayed Type Hypersensitivity

# 11. Clinical Testing

There was no clinical testing required to support the medical device as the indications for use is equivalent to the predicate device. The substantial equivalence of the mulcations for use is

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non-clinical testing. The verification and validation testing of the device biocompatibility and performance testing was found to be acceptable and supports the claims of substantial equivalence.

## 12. Conclusion

By definition, a device is substantially equivalent to a predicate device when the device has the same intended use and the same technological characteristics as the previously cleared predicate device. Or the device has the same intended use and different technological characteristics that can be demonstrated that the device is substantially equivalent to the predicate device, and that the new device does not raise different questions regarding its safety and effectiveness as compared to the predicate device.

lt has been shown in this 510(k) submission that the difference between the ClearCorrect System and the predicate devices do not raise any questions regarding its safety and effectiveness. The ClearCorrect System, as designed and manufactured, is determined to be substantially equivalent to the referencedpredicate devices.

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Image /page/4/Picture/1 description: The image shows the logo for the Department of Health & Human Services USA. The logo consists of a circle with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is an abstract image of an eagle or bird-like figure with outstretched wings. The image is in black and white.

#### Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002

ClearCorrect LLC C/O Ms. Cheryl Fisher Senior OA/RA Consultant Emergo Group 611 W. 5TH Street, Third Floor Austin, TX 78701

Re: K113618

Trade/Device Name: ClearCorrect System Regulation Number: 21 CFR 872.5470 Regulation Name: Orthodontic Plastic Bracket Regulatory Class: II Product Code: NXC Dated: March 1, 2012 Received: March 2, 2012

Dear Ms. Fisher:

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.

MAR 1 9 2012

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## Page 2 - Ms. Fisher

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 [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

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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K 11 3 618

# Indications for Use Statement

510(k) Number (if known): Not Assigned K1136 | 8

Device Name: ClearCorrect System

Indications for Use:

..

The ClearCorrect System is indicated for the treatment of tooth malocclusion in patients with permanent dentition (i.e. all second molars). The ClearCorrect System positions teeth by way of continuous gentle force.

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 IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Susan Ruaper

(Division Sign-Off) Division of Anesthesiology, General Hospital Infection Control, Dental Devices

510(k) Number. K113618