K151984 · Thommen Medical AG · NHA · Mar 10, 2016 · Dental
Device Facts
Record ID
K151984
Device Name
Thommen Milling Abutment for CAD/CAM
Applicant
Thommen Medical AG
Product Code
NHA · Dental
Decision Date
Mar 10, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3630
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Thommen Milling abutments for CAD/CAM are intended to be used in conjunction with Thommen System dental implants in the maxillary and /or mandibular arch to provide support for crowns, bridges and overdentures. All digitally designed abutments for use with Thommen Milling abutments for CAD/CAM are intended to be sent to a Thommen validated milling center for manufacture.
Device Story
Milling Abutment for CAD/CAM is a titanium dental abutment blank used by dental laboratories to fabricate patient-specific abutments. Clinicians prescribe the custom design; laboratories use the 3Shape CAD/CAM system to design the abutment based on patient anatomy. Designs are sent to a Thommen-validated milling center for manufacturing. The final custom abutment is then sterilized and placed by a clinician to support crowns, bridges, or overdentures on Thommen System implants. The device facilitates functional and aesthetic dental restoration by providing a patient-specific interface between the implant and the prosthetic superstructure.
Clinical Evidence
No clinical data were included in this submission. Evidence consists of bench testing: sterilization validation (ISO 17665-1/2), biocompatibility evaluation (ISO 10993-1), input/output validation for the Thommen Medical library, and static/dynamic compression-bending fatigue testing (ISO 14801).
Technological Characteristics
Titanium abutment blanks; diameters 3.5mm–6.0mm; heights 12mm–15mm; max angulation 20°; min wall thickness 0.4mm. Compatible with Thommen ELEMENT and CONTACT implants. Sterilization via moist heat. CAD/CAM design workflow.
Indications for Use
Indicated for patients requiring dental prosthetic support (crowns, bridges, overdentures) in the maxillary or mandibular arch using Thommen System dental implants.
Regulatory Classification
Identification
An endosseous dental implant abutment is a premanufactured prosthetic component directly connected to the endosseous dental implant and is intended for use as an aid in prosthetic rehabilitation.
Special Controls
*Classification.* Class II (special controls). 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.)
Predicate Devices
CORE 3D Abutment System for Digital Prosthetic Solutions (K122295)
{0}------------------------------------------------
Image /page/0/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" written around it. Inside the circle is an emblem featuring three stylized human profiles facing to the right, with flowing lines suggesting movement or connection.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
March 10, 2016
Thommen Medical AG c/o Ms. Linda K. Schulz Regulatory Affairs PaxMed International, LLC 12264 El Camino Real, Suite 400 San Diego, California 92130
Re: K151984
Trade/Device Name: Milling Abutment for CAD/CAM Regulation Number: 21 CFR 872.3630 Regulation Name: Endosseous Dental Implant Abutment Regulatory Class: Class II Product Code: NHA Dated: February 10, 2016 Received: February 11, 2016
Dear Ms. Schulz:
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.
{1}------------------------------------------------
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 (OS) 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 (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely yours,
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
Enclosure
{2}------------------------------------------------
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
### Indications for Use
510(k) Number (if known)
K151984
Device Name
Milling Abutment for CAD/CAM
Indications for Use (Describe)
Thommen Milling abutments for CAD/CAM are intended to be used in conjunction with Thommen System dental implants in the maxillary and /or mandibular arch to provide support for crowns, bridges and overdentures.
All digitally designed abutments for use with Thommen Milling abutments for CAD/CAM are intended to be sent to a Thommen validated milling center for manufacture.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
## 510(k) Summary
## Thommen Medical AG
# Milling Abutment for CAD/CAM K151984
March 7, 2016
#### ADMINISTRATIVE INFORMATION
| Manufacturer Name | Thommen Medical AG | |
|---------------------------|---------------------------------|------------------------------------------|
| | Neckarsulmstrasse 28 | |
| | 2540 Grenchen, Solothurn | |
| | Switzerland | |
| | Telephone: | +41 61 965 90 20 |
| | Fax: | +41 61 965 90 21 |
| Official Contact | Daniel Snetivy | |
| | Chief Technology Officer | |
| Representative/Consultant | Linda Schulz, BSDH, RDH | |
| | Floyd G. Larson | |
| | PaxMed International, LLC | |
| | 12264 El Camino Real, Suite 400 | |
| | San Diego, CA 92130 | |
| | Telephone: | +1 (858) 792-1235 |
| | Fax: | +1 (858) 792-1236 |
| | Email: | lschulz@paxmed.com<br>flarson@paxmed.com |
#### DEVICE NAME AND CLASSIFICATION
| Trade/Proprietary Name: | Milling Abutment for CAD/CAM |
|----------------------------|------------------------------------|
| Common Name: | Dental implant abutment |
| Classification Name: | Endosseous dental implant abutment |
| Classification Regulation: | 21 CFR 872.3630, Class II |
| Product Code: | NHA |
| Classification Panel: | Dental Products Panel |
| Reviewing Branch: | Dental Devices Branch |
{4}------------------------------------------------
#### INDICATIONS FOR USE
Thommen Milling abutments for CAD/CAM are intended to be used in conjunction with Thommen System dental implants in the maxillary and /or mandibular arch to provide support for crowns, bridges and overdentures.
All digitally designed abutments for use with Thommen Milling abutments for CAD/CAM are intended to be sent to a Thommen validated milling center for manufacture.
| K122295 | CORE 3D Abutment System for<br>Digital Prosthetic Solutions | CORE 3D Protech, S.L. | Primary Predicate |
|------------------------------------------|-------------------------------------------------------------|-----------------------|-------------------|
| K073713 | Blue Sky Bio Dental Implant | Blue Sky Bio, LLC | Reference |
| | System | | Predicate |
| K031747<br>SPI® Dental Implant Abutments | | Thommen Medical, AG | Reference |
| | | | Predicate |
| K090154 | SPI® Dental Implant, INICELL® | Thommen Medical, AG | Reference |
| | | | Predicate |
### PREDICATE INFORMATION
#### DEVICE DESCRIPTION
The Milling Abutment for CAD/CAM is an abutment used by a dental laboratory equipped with the 3Shape CAD/CAM System to fabricate a customized abutment made of titanium. Each patient-specific abutment is individually prescribed by the clinician. Minimum wall thickness allowed for the final abutment is 0.4 mm, maximum angulation is 20°, maximum gingival height is 7.0 mm, and total height of the abutment is no greater than 15 mm and no shorter than 4.5 mm. All digitally designed abutments for use with Thommen Milling abutments for CAD/CAM are intended to be sent to a Thommen validated milling center for manufacture. Final abutments are to be sterilized prior to intraoral placement.
Milling Abutment for CAD/CAM is available in five diameters (3,5 mm, 4,0 mm, 5,0 mm, 6,0 mm) and two heights (12 mm and 15 mm). The Ø3.5 mm abutment is provided in the 12 mm height. All other diameters are provided in the 15 mm height. Each abutment is supplied with a corresponding screw. Milling Abutment for CAD/CAM is compatible with the Thommen Implant System ELEMENT and CONTACT implants.
#### PERFORMANCE DATA
Non-clinical testing data submitted, referenced, or relied upon to demonstrate substantial equivalence included the following: sterilization according to ISO 17665-1 Sterilization of health care products – Moist heat – Part 1: Requirements for the development, validation, and routine control of a sterilization process for medical devices and ISO 17665-2 Sterilization of health care products – Moist heat - Part 2: Guidance on the application of ISO 17665-1; Biocompatibility evaluation according to ISO 10993-1 Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process which determined that no further biocompatibility testing is required because all
{5}------------------------------------------------
510(k) Summary Page 3 of 4
materials and processing are identical to the abutments cleared in K031747: Input/output validation for the Thommen Medical library performed to ensure accuracy and conformance to the parameters outlined for the Thommen Milling Abutment for CAD/CAM. Validation confirmed that accuracy was consistent and parameter limits were maintained in final device manufacturing. Static and dynamic compression -bending testing were performed according to ISO 14801 Dentistry - Implants - Dynamic fatigue test for endosseous dental implants.
No clinical data were included in this submission.
#### EQUIVALENCE TO MARKETED DEVICE
The subject device is substantially equivalent in indications and design principles predicate devices shown above. Below are summary tables showing technical comparison between the subject device and the primary predicate devices.
| Subject Device | Primary Predicate Device |
|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Thommen Medical AG | CORE 3D Protech, S.L. |
| Milling Abutment for<br>CAD/CAM | Core 3D Abutment System for Digital Prosthetic Solutions |
| K151984 | K122295 |
| Indications for use | |
| Thommen Milling abutments for<br>CAD/CAM are intended to be<br>used in conjunction with | The CORE 3D abutment system for digital prosthetic solutions are dental abutments<br>placed into a dental implant to provide support for dental prosthetic restorations. The<br>abutments include: |
| Thommen System dental<br>implants in the maxillary and /or<br>mandibular arch to provide<br>support for crowns, bridges and<br>overdentures. | • Titanium Bases to be attached to the underlying implant and upon which a CAD/CAM<br>designed superstructure may be fitted to complete a two-piece dental abutment;<br>• Titanium Abutment Blanks with a pre-machined implant connection where the upper<br>portion may be custom-milled in accordance with a patient-specific design using<br>CAD/CAM techniques |
| All digitally designed<br>abutments for use with<br>Thommen Milling abutments<br>for CAD/CAM are intended<br>to be sent to a Thommen<br>validated milling center for<br>manufacture. | • Abutment Screws to permanently fix the abutments to the underlying implant. Core 3D<br>abutments are intended for use to support single-tooth (unit) and multiple-tooth (bridges<br>and bars) prostheses, in the mandible or maxilla for functional and aesthetic restorations.<br>Core 3D abutments designed using CAD/CAM techniques must fulfill the Core 3D<br>allowable range of design specifications and be provided as straight abutments only.<br>Core 3D abutments and are compatible for use with the following dental Implants:<br>• Nobel Biocare Brånemark System (K022582, K934825)<br>• Zimmer Tapered Screwvent (K013227, K061410, K072589) |
| Design | |
| CAD/CAM Blank | CAD/CAM Blank,<br>Titanium Base |
| Cement-retained | Cement-retained |
| Single-unit,<br>Multi-unit | Single-unit,<br>Multi-unit |
| 3.5 - 6.0 | 3.5 - 5.7 |
| Internal Hex | Internal Hex,<br>External Hex |
The subject device and primary predicate have slightly different Indications for Use language. However, the difference in language does not change the intended use of abutments. Both abutments are being used in conjunction with dental implants for the purpose of supporting dental prostheses and are CAD/CAM custom abutments fabricated at a milling center.
{6}------------------------------------------------
CONCLUSION
The subject device and the predicate devices have intended use, have similar technological characteristics, and are made of similar materials. The subject device and predicate devices encompass the same range of physical dimensions, including diameter and length of the implants, and diameter, gingival height, and angle of the abutments. The subject and predicate devices are packaged in similar materials and to be sterilized using similar methods.
The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.
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.