Non-interventional post-market study; Clinical literature review
The sponsor used data from a non-interventional post-market study and a literature review to support updating the Instructions for Use (IFU). Specifically, the data supported moving metabolic bone disease from a contraindication to a precaution and allowing the use of Ø3.3 mm implants in the molar region.
Post-market study; Literature review; Labeling change; Dental implants
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Non-Interventional Study (Post-market); Non-interventional, observational; Follow-up/Duration: Up to 2 years
Subjects requiring dental implant therapy and restoration with Roxolid Ø3.3 mm implants
Not applicable for this study
Implant success and survival rates, change in bone level, treatment characteristics
Clinical literature review; Literature review
Patients with metabolic bone diseases receiving dental implants
Patients free of metabolic bone disease
Implant performance
Indications for Use
Straumann® Dental implants are indicated for oral endosteal implantation in the upper and lower jaw arches for the functional and aesthetic oral rehabilitation of edentulous and partially dentate patients. Straumann® Dental implants are also indicated for immediate or early implantation following extraction or loss of natural teeth. Implants can be placed with immediate function on single-tooth and/or multiple tooth applications when good primary stability is achieved and with appropriate occlusal loading to restore chewing function. The prosthetic restorations used are single crowns, bridges and partial or full dentures, which are connected to the implants through the corresponding components (abutments). In cases of fully edentulous patients, 4 or more implants must be used in immediately loaded cases.
Device Story
Endosseous dental implants; root-form design; used for oral rehabilitation of edentulous/partially dentate patients. Implants surgically placed in jaw arches; support prosthetic restorations (crowns, bridges, dentures) via abutments. Enables immediate/early loading post-extraction if primary stability achieved. Used in clinical settings by dental professionals. Labeling change only; physical device identical to predicates. Clinical data supports use in patients with pharmacologically controlled metabolic bone disease and use of small diameter (Ø3.3 mm) implants in molar regions, moving previous contraindications/restrictions to precautions.
Clinical Evidence
Non-interventional post-market study of Roxolid Ø3.3 mm implants in molar regions (n=not specified). Primary endpoints: success/survival rates at 1 year. Secondary: bone level changes, success/survival at 2-3 years, clinician satisfaction. Results: 2-year follow-up showed minimal failures (2 in molar region) and adverse events (inflammation, resorption) which resolved. Literature review supported safety in patients with controlled metabolic bone disease. Evidence supports equivalence to implants placed in other mouth regions.
Technological Characteristics
Endosseous root-form dental implants. Materials, surface treatments (SLA, SLActive), and design are identical to predicate devices. No changes to energy source, dimensions, or sterilization. Standalone mechanical devices; no software or electronic components.
Indications for Use
Indicated for edentulous and partially dentate patients requiring oral endosteal implantation in upper/lower jaw arches for functional/aesthetic rehabilitation. Suitable for immediate/early implantation post-extraction/tooth loss. Supports single-tooth or multiple-tooth applications with immediate function if primary stability is achieved. Requires 4+ implants for fully edentulous immediate loading.
Regulatory Classification
Identification
An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.
Special Controls
*Classification.* (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)(2)
*Classification.* Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use;
(ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads;
(iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system;
(iv) The device must be demonstrated to be biocompatible;
(v) Sterility testing must demonstrate the sterility of the device;
(vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment;
(vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians;
(viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and
(ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.
Narrow Neck CrossFit (NNC) Ø3.3 mm Dental Implant System (K111357)
Straumann Bone Level Ø4.1 mm and Ø4.8 mm Regular Connection (RC) Roxolid Dental Implants (K121131)
Straumann Tissue Level Ø4.1 mm and Ø4.8 mm Roxolid Dental Implants (K122855)
Submission Summary (Full Text)
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## 510(k) Summary - K123784
## Submitter's Contact Information:
Straumann USA, LLC (on behalf of Institut Straumann AG)
60 Minuteman Road
Andover, MA 01810
Phone Number: 1-978-747-2509
Fax Number: 1-978-747-0023
Contact Person: Jennifer M. Jackson, MS
Date of Submission: 07-Dec-2012
## Name of the Device:
| Trade Name: | Straumann® Dental Implant System |
|-------------|-----------------------------------------------|
| | SLA®, SLActive® and Roxolid® Product Families |
Common Name: Dental Implants
Classification Name: Implant, Endosseous, Root-form
Regulation Number: §872.3640
#### Predicate Device(s):
K983742, ITI Dental Implants
K012757, ITI® Dental Implant System
K033922, Modification to ITI Dental Implant System
K033984, ITI Dental Implant System
K053088, SLActive Implants
K062129, P.004 Implants
K081419, Modified Dental Implant
K083550, Modified Dental Implant
K111357, Narrow Neck CrossFit (NNC) Ø3.3 mm Dental Implant System
K121131, Straumann Bone Level Ø4.1 mm and Ø4.8 mm Regular Connection (RC) Roxolid Dental Implants
K122855, Straumann Tissue Level Ø4.1 mm and Ø4.8 mm Roxolid Dental Implants
#### Traditional 510(k) Straumann Dental Implant System
6-1
## APR 1 0 2013
{1}------------------------------------------------
## Device Description:
This premarket notification serves to affect a labeling change applicable to all endosseous dental implants of the Straumann® Dental. Implant System. The subject devices are physically identical to the listed predicate device descriptions are identical to those presented in the referenced predicate submissions.
The proposed Straumann Implant Instructions for Use (IFU) changes in this premarket notification are to address the following:
- Update the IFU content to reflect the FDA Guidance on Medical Device Patient . Labeling regarding contraindications, general warnings, and precautions
- Clarify the term "poor bone metabolism" under contraindications and move the . condition "osteoporosis" to Precautions in the IFU
- Modify the indications for use statement previously cleared in premarket notifications . K081419 and K083550 to relocate the statement regarding specific indications for small diameter (Ø3.3 mm) implants from the indications for use to the Precautions
#### Intended Use / Indications For Use:
Straumann® Dental implants are indicated for oral endosteal implantation in the upper and lower jaw arches for the functional and aesthetic oral rehabilitation of edentulous and partially dentate patients. Straumann® Dental implants are also indicated for immediate or early implantation following extraction or loss of natural teeth. Implants can be placed with immediate function on single-tooth and/or multiple tooth applications when good primary stability is achieved and with appropriate occlusal loading to restore chewing function. The prosthetic restorations used are single crowns, bridges and partial or full dentures, which are connected to the implants through the corresponding components (abutments). In cases of fully edentulous patients, 4 or more implants must be used in immediately loaded cases.
#### Technological Characteristics:
There are no changes to the materials, surface treatments, design, fundamental operating principles, or sterilization procedures as a result of the proposed IFU changes. No new surgical instruments or secondary components are being introduced as a result of the proposed IFU changes.
#### Performance Testing:
The bench and animal performance testing previously submitted in support of the referenced predicate devices continues to be representative of the subject devices. A non-interventional clinical study was conducted in accordance with applicable national and local regulations and is being submitted as supporting documentation for the proposed IFU changes.
A review and summarization of the clinical literature associated with the use of dental implants in the presence of metabolic bone diseases was presented. The available data indicate that metabolic disease of the bone is not a strict contraindication for the use of dental implants; the evidence supports that performance of dental implants in patients whose metabolic bone disease is pharmacologically under control is equivalent to those in patients free of metabolic bone disease. This supports the relocation of the statement regarding metabolic bone disease from the Contraindications section of the Instructions For Use to the Precautions section to allow the clinician to determine whether a particular patient is a suitable candidate for dental implants.
{2}------------------------------------------------
A subset of data from a Non-Interventional Study (i.e. post-market) in humans was presented. The study as a whole included subjects with the need of dental implant therapy and restoration according to the cleared indications for the Roxolid Ø3.3 mm implant within Germany, United Kingdom, France, Spain, Sweden, the United States, and Canada. The data subset was specific to patients having implants placed in the molar region of the mouth.
The primary study purpose was to determine implant success and survival rates one year after implant placement. Secondary purposes included assessing the change in bone level (to be estimated by the investigator), success and survival rates 2 and 3 years after implant placement and assessment of other treatment characteristics including protocol, implant position, augmentation procedures and clinician satisfaction.
As of the 2-year time point, there were two reports of implant failyre in the molar region (one prior to restoration and one prior to the 1-year time point after final restoration - Table 16). There was no implant failure reported following the 1-year follow-up visit in the molar region. Other reported implant related adverse events in the molar region include two cases of inflammation (one at implant placement and one at 2-years), one case of poor implant stability (at implant placement), and one case of peri-implant resorption (at final restoration). All adverse events are known to have resolved with the exception of the report of inflammation at 2-years.
This clinical data suggest that performance of Roxolid Ø3.3 mm implants placed in the molar region is equivalent to those placed in other parts of the mouth. This supports the relocation of the recommendation against using Ø3.3 mm (small diameter) implants in the molar region from the Specific Indications section of the Instructions For Use to the Precautions section to allow the clinician to determine whether application in the molar region is appropriate for the particular patient.
#### Conclusion:
The subject devices are identical in all respects to the predicate devices identified. This submission only introduces changes to the product labeling. The data and documentation submitted in this premarket notification supports the proposed changes to the Instructions for Use for the Straumann Dental Implant System.
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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is circular and contains the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. In the center of the logo is an abstract symbol that resembles a stylized human figure.
#### Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
#### April 10, 2013
Jennifer M. Jackson, MS Senior Regulatory Affairs Project Manager Straumann USA, Limited Liability Company 60 Minuteman Road ANDOVER MA 01810
Re: K123784
Trade/Device Name: Straumann® Dental Implant System SLA®, SLActive® and Roxolid® Product Families Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: II Product Code: DZE Dated: March 18, 2013 Received: March 19, 2013
Dear Ms. Jackson:
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.
{4}------------------------------------------------
Page 2 - Ms. Jackson
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 devicerelated 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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. 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,
# Kwame O. Ulmer
for
Anthony D. Watson, B.S., M.S., M.B.A. Director
Division of Anesthesiology, General Hospital, Respiratory, Infection Control and
Dental Devices
Office of Device Evaluation
Center for Devices and
Radiological Health
Enclosure
{5}------------------------------------------------
## Indications for Use
#### 510(k) Number (if known): K123784
Device Name:
#### Straumann® Dental Implant System SLA®, SLActive® and Roxolid® Product Families
#### Indications for Use:
Straumann® Dental implants are indicated for oral endosteal implantation in the upper and lower jaw arches for the functional and aesthetic oral rehabilitation of edentulous and partially dentate patients. Straumann® Dental implants are also indicated for immediate or early implantation following extraction or loss of natural teeth. Implants can be placed with immediate function on single-tooth and/or multiple tooth applications when good primary stability is achieved and with appropriate occlusal loading to restore chewing function. The prosthetic restorations used are single crowns, bridges and partial or full dentures, which are connected to the implants through the corresponding components (abutments). In cases of fully edentulous patients, 4 or more implants must be used in immediately loaded cases.
Prescription Use × (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 Runner, DDSMA | Mary S. Runner -S |
|---------------------|-------------------|
| | 2013.04.10 |
| | 10:13:25 -04'00' |
(Division Sign-Off)
Division of Anesthesiology, General Hospital
Infection Control, Dental Devices
510(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.
