Jade 37% Phosphoric Acid Etchant Gel

K150696 · Dharma Research, Inc. · KLE · Jun 23, 2015 · Dental

Device Facts

• Record ID: K150696
• Device Name: Jade 37% Phosphoric Acid Etchant Gel
• Applicant: Dharma Research, Inc.
• Product Code: KLE · Dental
• Decision Date: Jun 23, 2015
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 872.3200
• Device Class: Class 2

Intended Use

A thixotropic 37% phosphoric acid dental etchant gel for etching enamel, dentin, and glass ionomer cements to produce the necessary micro-retentive surface for successful bonding of restorations.

Device Story

Jade 37% Phosphoric Acid Etchant Gel is a thixotropic dental etchant used by dentists to prepare tooth surfaces for bonding. The device consists of 37% phosphoric acid in a thick gel vehicle, supplied in pre-filled syringes with 23-gauge or 25-gauge bent applicators. The clinician applies the gel to enamel, dentin, or glass ionomer cements; the acid etches the surface to create micro-retentive patterns necessary for the adhesion of restorative materials. The gel's thixotropic properties ensure it remains in place during application. The device is used in a clinical dental setting. By facilitating a strong bond between the tooth structure and the restoration, the device helps ensure the longevity and success of dental restorative procedures.

Clinical Evidence

Bench testing only. Comparative testing between Jade and the predicate device evaluated percent phosphoric acid, pH, viscosity, consistency, color, and odor. Results demonstrated equivalence in material properties and performance.

Technological Characteristics

Thixotropic gel containing 37% phosphoric acid; utilizes thickeners and emulsifiers for delivery vehicle. Supplied in pre-filled syringes (1.2 ml, 12 g, 50 ml) with 23 ga or 25 ga bent applicators. pH 1.52; viscosity 60,000 cps. Color: blue or green.

Indications for Use

Indicated for dental patients requiring etching of enamel, dentin, or glass ionomer cements to facilitate bonding of dental restorations.

Regulatory Classification

Identification

A resin tooth bonding agent is a device material, such as methylmethacrylate, intended to be painted on the interior of a prepared cavity of a tooth to improve retention of a restoration, such as a filling.

Predicate Devices

• Seity 37% Phosphoric Acid Etching Gel (K112597)

Submission Summary (Full Text)

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

June 23, 2015

Dharma Research Inc. Mr. Ricardo Carles President 5220 NW 72nd Avenue #15 Miami, FL 33166

Re: K150696

Trade/Device Name: Jade 37% Phosphoric Acid Etchant Gel Regulation Number: 21 CFR 872.3200 Regulation Name: Resin Tooth Bonding Agent Regulatory Class: II Product Code: KLE Dated: February 3, 2015 Received: March 25, 2015

Dear Mr. Carles:

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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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 contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] 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 Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely vours.

Tina
Kiang -S

for Erin I. Keith, M.S. Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

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Image /page/2/Picture/0 description: The image shows the logo for Dharma Research. The logo consists of a circular graphic on the left and the text "DHARMA RESEARCH" on the right. The circular graphic is made up of three overlapping shapes in shades of orange. The text "DHARMA" is in a large, sans-serif font, and the text "RESEARCH" is in a smaller font below the word "DHARMA".

### Section 5 – Form FDA-3881 Indications for Use

| DEPARTMENT OF HEALTH AND HUMAN SERVICES<br>Food and Drug Administration | Form Approved: OMB No. 0910-0120<br>Expiration Date: January 31, 2017<br>See PRA Statement below. |
|-------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|
|-------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|

**Indications for Use**

| 510(k) Number (if known) | K150696 |
|-------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | Jade 37% Phosphoric Acid Etchant Gel |
| Indications for Use (Describe) | A thixotropic 37% phosphoric acid dental etchant gel for etching enamel, dentin, and glass ionomer cements to produce the necessary micro-retentive surface for successful bonding of restorations. |
| Type of Use (Select one or both, as applicable) | <div> <span> <input checked="true" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) </span> <span> <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |

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FORM FDA 3881 (8/14)

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Image /page/3/Picture/0 description: The image shows the logo for Dharma Research. The logo consists of an orange circular icon on the left and the words "DHARMA RESEARCH" on the right. The word "DHARMA" is in a larger, bolder font than the word "RESEARCH", which is located underneath the word "DHARMA".

# 510(k) Summary

#### Date Prepared: 03 February 2015

K 150696

| Device Common Name | Agent, tooth bonding, resin | Product Name | Jade 37% Phosphoric Acid Etchant Gel | Seity 37% Phosphoric Acid Etching Gel |
|-------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade Name | Jade 37% Phosphoric Acid Etchant Gel | Sponsor | Dharma Research, Inc. | Mycone Dental |
| Classification Name | Tgukp tooth bonding agent | 510(k) | K150696 | K112597 |
| 510(k) Submitter | Dharma Research, Inc.<br>5220 NW 72nd Avenue, Unit 15<br>Miami, Florida 33166 | Indication for Use | A thixotropic 37% phosphoric acid dental etchant gel for etching enamel, dentin, and glass ionomer cements to produce the necessary micro-retentive surface for successful bonding of restorations. | A thixotropic 37% phosphoric acid dental etchant gel for etching enamel, dentin, and glass ionomer cements to produce the necessary micro-retentive surface for successful bonding of restorations. |
| Contact | Ricardo Carles, President<br>Telephone [phone]<br>Facsimile [phone]<br>E-mail: [e-mail] | Phosphoric Acid | 37% | 37% |
| Classification Regulation | 21 CFR §872.3200 | Consistency | Thick gel | Thick gel |
| Device Class | II | Color | Blue or Green | Blue or Green |
| Classification Panel | Dental | Odor | No characteristic | No characteristic |
| Product Code | KLE | Viscosity | 60,000 cps | 40,000 cps |
| Predicate Device | K112597, Seity 37% Phosphoric Acid Etchant Gel | pH | 1.52 | 1.20 |
| Device Description | Thixotropic dental etchant gel with 37% phosphoric acid | Shelf-Life | Proposed 2-years, based on existing shelf-life studies (refer to Section 15) | Appears to be 2-years based on expiry date printed on label example in MISC files. |
| Indications for Use | A thixotropic 37% phosphoric acid dental etchant gel for etching<br>enamel, dentin, and glass ionomer cements to produce the necessary<br>micro-retentive surface for successful bonding of restorations. | How Supplied | Pre-filled syringes with applicators, 1.2 ml, 12 g (10 ml), and 50 ml | Pre-filled syringe, 12 g |
| Technological characteristics | Thixotropic gel with 37% phosphoric acid, which<br>is the same as the predicate device. | Applicator | Standard 23 ga bent<br>Optional 25 ga bent | Not available |
| Bench testing | Both Jade 37% Phosphoric Acid Etchant Gel and<br>the predicate device were tested for the following<br>characteristics:<br>Percent phosphoric acid pH Viscosity Consistency, Color and Odor Each test demonstrates the equivalence of Jade to<br>the predicate device. | | | |

The information in this submission demonstrates that Jade 37% Phosphoric Acid Etchant Gel device is as safe, as effective, and performs as well the predicate device.

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Image /page/4/Picture/0 description: The image contains the logo for Dharma Research. The logo consists of a circular graphic on the left and the text "DHARMA RESEARCH" on the right. The circular graphic is a gradient of orange and red, with three curved shapes that appear to be overlapping. The text "DHARMA" is in a larger, bolder font than the text "RESEARCH", which is located below it.

## Substantial Equivalence

# 510(k) "Substantial Equivalence" Decision Making Process

| Dec. No. | Question | Answer | Comment |
|----------|----------------------------------------------------------------|--------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 1. | Is the predicate device legally marketed? | Yes | K112597 |
| 2. | Do the devices have the same intended use? | Yes | A thixotropic 37% phosphoric acid<br>dental etchant gel for etching enamel,<br>dentin, and glass ionomer cements to<br>produce the necessary micro-retentive<br>surface for successful bonding of<br>restorations. |
| 3. | Do the devices have the same technological<br>characteristics? | Yes | The formula for Jade and the predicate<br>are substantially equivalent, using<br>thickeners and emulsifiers to provide a<br>thick gel vehicle through which to<br>deliver the phosphoric acid. The<br>coloring agents are also substantially<br>equivalent. |

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Image /page/5/Picture/0 description: The image shows the logo for Dharma Research. The logo consists of an orange circular icon on the left and the text "DHARMA RESEARCH" on the right. The word "DHARMA" is in a larger, bolder font than the word "RESEARCH", which is positioned below it.

#### Conclusion

These key similarities and the results of the bench testing comparison demonstrate that Jade is substantially equivalent to the predicate product and raises no new issues of safety or efficacy. The formula for Jade and the predicate are very similar. Dharma Research was the contract manufacturer of the predicate product at the time that K 1 12597 was cleared and for many years thereafter. Even though the chemical compositions are not identical, bench testing has demonstrated that Jade has comparable material properties and performance.