K163194 · Jjgc Industria E Comercio DE Materiais Dentarios S.A. · DZE · Jul 14, 2017 · Dental
Device Facts
Record ID
K163194
Device Name
Neodent Implant System - GM Line
Applicant
Jjgc Industria E Comercio DE Materiais Dentarios S.A.
Product Code
DZE · Dental
Decision Date
Jul 14, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3640
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Indications for Use for GM implants and conventional abutments: The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices such as artificial teeth, to restore chewing function. It may be used with single-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading. Indications for Use for GM Titanium Base abutments: Titanium Base Abutment is a titanium base placed onto Neodent dental implants to provide support for customized prosthetic restorations. It is used with a coping and crown, or crown alone, and is indicated for cement-retained single or multi-unit restorations, or screw-retained single restorations. All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center. Indications for Use for GM Pro Peek Abutments: The Pro PEEK Abutments are indicated to be used on Neodent implants to provide temporary support for prosthesis structure for up to 6 months. They can be used in one or two stage procedures and also immediate load when there is good primary stability.
Device Story
Neodent Implant System - GM Line comprises endosseous dental implants, conventional abutments, and CAD/CAM abutments. Implants are surgically placed in the jawbone to support prosthetic restorations. System utilizes a Morse taper implant-to-abutment interface with an internal hexagonal index. CAD/CAM abutments (Titanium Bases) require digital design via DWOS or 3Shape software, with manufacturing performed at a validated milling center. Devices are used in dental clinics by trained professionals. Output is a stable foundation for prosthetic teeth, restoring chewing function. Benefits include improved oral function and aesthetics. System includes temporary components (Pro PEEK abutments, cover screws, healing abutments) for soft tissue management during osseointegration. Performance is supported by dynamic fatigue testing (ISO 14801) and biocompatibility assessments.
Clinical Evidence
Bench testing only. No clinical data provided. Performance supported by dynamic fatigue testing per ISO 14801, biocompatibility testing (cytotoxicity, chemical characterization), and sterilization validation (ISO 11137, ISO 11135, ISO 17665). Shelf life validated via accelerated and real-time aging (ASTM F1980).
Technological Characteristics
Implants: Grade 4 titanium (ASTM F67). Abutments: Ti-6Al-4V ELI titanium alloy (ASTM F136) or PEEK. Interface: 16° Morse taper with internal hexagonal index. Surface treatments: NeoPoros (abrasive jet/acid etch) and Acqua (hydrophilic). Sterilization: Gamma irradiation (implants) or Ethylene Oxide (abutments). CAD/CAM integration: DWOS or 3Shape software.
Indications for Use
Indicated for patients requiring dental implants in the upper or lower jaw to support prosthetic devices (artificial teeth) for chewing restoration. Suitable for single or multiple unit restorations, single or two-stage procedures, and immediate loading if primary stability is achieved. Titanium Base abutments indicated for cement-retained single/multi-unit or screw-retained single restorations. Pro PEEK abutments indicated for temporary support (up to 6 months).
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.
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features the department's name in a circular arrangement around a symbol. The symbol consists of three stylized human profiles facing to the right, with flowing lines connecting them, representing health and well-being.
Public Health Service Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
July 14, 2017
JJGC Industria e Comercio de Materiais Dentarios SA c/o Jennifer Jackson Director, Regulatory Affairs & Quality Management Straumann USA, LLC 60 Minuteman Road Andover, Massachusetts 01810
Re: K163194
Trade/Device Name: Neodent Implant System - GM Line Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: Class II Product Code: DZE, NHA Dated: June 13, 2017 Received: June 15, 2017
Dear Jennifer 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.
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
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### Page 2 - Jennifer Jackson
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 (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.
# Mary S. Runner -A
Lori A. Wiggins, MPT, CLT Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
# Indications for Use
510(k) Number (if known)
K163194
Device Name
Neodent Implant System - GM Line
Indications for Use (Describe)
Indications for Use for GM implants and conventional abutments:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices such as artificial teeth, to restore chewing function. It may be used with single-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
Indications for Use for GM Titanium Base abutments:
Titanium Base Abutment is a titanium base placed onto Neodent dental implants to provide support for customized prosthetic restorations. It is used with a coping and crown, or crown alone, and is indicated for cement-retained single or multi-unit restorations, or screw-retained single restorations.
All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
Indications for Use for GM Pro Peek Abutments:
The Pro PEEK Abutments are indicated to be used on Neodent implants to provide temporary support for prosthesis structure for up to 6 months. They can be used in one or two stage procedures and also immediate load when there is good primary stability.
Type of Use (*Select one or both, as applicable*)
| <span style="font-size: 10pt;"> <span style="font-family: Wingdings;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D)</span> |
|------------------------------------------------------------------------------------------------------------------------------------|
| <span>☐ Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
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# 510(k) Summary
| Submitter | Straumann USA, LLC<br>60 Minuteman Road<br>Andover, MA 01810<br>Registration No.: 1222315<br>Owner/Operator No.: 9005052 |
|------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | on behalf of:<br>JJGC Indústria e Comércio de Materiais Dentários SA<br>Av. Juscelino Kubitschek de Olivera, 3291<br>Curtiba, Parana, BRAZIL 81270-200<br>Registration No.: 3008261720<br>Owner/Operator No.: 10031702 |
| Contact Person | Jennifer M. Jackson, MS<br>Director, Regulatory Affairs & Quality, Straumann USA<br>E-Mail: jennifer.jackson@straumann.com<br>Telephone (978) 747-2509 |
| Date Prepared | 14/Jul/2017 |
| Prepared by | Ana Carolina Martins Vianna<br>RA & Compliance Manager, Institut Straumann AG<br>ana.vianna@straumann.com |
| Product Code<br>Device Class<br>Classification Panel | DZE (21 CFR 872.3640) / NHA<br>II<br>Dental |
| Classification Name | Root-form endosseous dental implant (21 CFR 872.3640) |
| Common Name | Root-form endosseous dental implant |
| Proprietary name | Neodent Implant System - GM Line |
| Primary Predicate | K101945 - Neodent Implant System, JJGC Indústria e Comércio de<br>Materiais Dentários SA |
| Reference Predicate<br>Devices | K150182 - Neodent Implant System - CM Drive line extension,<br>JJGC Indústria e Comércio de Materiais Dentários SA<br>K153624 - Neodent Implant System, JJGC Indústria e Comércio de<br>Materiais Dentários SA<br>K093027 – Straumann RC Temporary Abutments, Institut<br>Straumann AG<br>K151455 – 3Shape Abutment Designer Software, 3Shape A/S<br>K130808 - Straumann Healing Abutments, Healing Caps and<br>Closure Screws, Institute Straumann AG<br>K061804 - Zerion Alpha, Zerion Beta, ETKON International, Gmbh |
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#### 5.1 Device Description
The GM Line of the Neodent Implant System (GM Line) consists in an expansion of the Neodent Implant System previously cleared under K101945, K150182 and K153624, presenting a new design of Morse taper implant-to-abutment interface trade named GM line.
The GM line comprises a range of endosseous dental implants as well as conventional and CAD/CAM abutments described as follows:
The GM Line dental implants are threaded, self-tapping, root form with a Morse taper implantto-abutment interface with an internal hexagonal index exclusive to the GM line. They are made of titanium grade 4 conforming to ASTM F67. They are available in two types of surface treatment:
NeoPoros: rough surface created using an abrasive particle jet concept with controlled grain oxides, followed by acid etching creating uniform cavities in the implant surface.
- Acqua: hydrophilic surface created from Neoporos rough surface that undergoes additional processing that renders hydrophilic surface.
# GM Titamax implants
The GM Titamax implants have cylindrical shape with double threads of pyramidal profile, rounded apex and are available in diameters of 3.5, 3.75 and 4.0 mm with lengths of 7, 8, 9, 11, 13, 15 and 17 mm, and in 5.0 mm diameter with lengths of 7, 8, 9, 11 and 13 mm. They are recommended for surgical intraoral installation in bone of type I or II.
### GM Helix implants
The GM Helix implants have a conical shape, double threads with trapezoidal profile, a rounded apex and are available in diameters of 3.5, 3.75, 4.0, 4.3 and 5.0 mm with lengths of 8, 10, 11.5, 13, 16 and 18 mm. They are recommended for surgical intraoral installation in bones types III or IV, or in bone of type I and II when using conical drills.
### GM Drive implants
The GM Drive implants have conical shape with double and progressive threads, cutting chambers in the counterclockwise direction, blade-shaped apical thread, rounded apex and are available in diameters of 3.5, 4.3 and 5.0 mm with lengths of 8, 10, 11.5, 13, 16 and 18 mm. They are recommended for surgical intraoral installation in bone of type III or IV.
The GM Line dental abutments are made of titanium alloy conforming to ASTM F136 and have a machined surface. The abutments are intended to be placed directly onto implants and are recommended according to the available interocclusal space, gingival height, and threedimensional position of the implant. They can be used in immediate or conventional rehabilitation procedures on the maxilla or mandible.
### GM Cover Screws
The GM Cover Screws are devices for temporary use during the implant healing phase. They are available in two different heights: at the level of the platform (for use on implants placed at the
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bone level) and with a gingival height of 2 mm (for use on implants placed up to 2 mm infraosseous). The GM Cover Screws are indicated for use during the osseointegration phase, on Neodent implants to be rehabilitated using the late loading technique. Cover Screws should remain intramucosal, impeding tissue grown over the platform of the implant. Cover Screws are placed out of occlusion.
# GM Healings
The GM Healing Abutments are devices for temporary use. They are available in diameters of 3.3 and 4.5 mm and the following gingival heights: 0.8, 1.5, 2.5, 3.5, 4.5, 5.5 mm. They are indicated for maintenance of the soft tissue during the osseointegration phase of Neodent implant to be rehabilitated using the late loading technique. They can be used on the insertion of the Implant or re-opening surgery (second surgical phase). Healing Abutments are placed out of occlusion.
### GM Micro Abutments / GM Mini Conical Abutment / GM Exact Mini Conical Abutment
They are intermediary prosthetic components to be installed onto GM implants to support the final prosthesis. They are provided in a rotational shape for the coupling with the prosthesis and in different gingival heights to match the variations in mucosal thickness. The GM Exact Mini Conical abutment is provided angled. They are indicated for screw-retained multiple-unit prostheses onto implants. The GM Micro Abutment, when used with the anti-rotational coping, is also indicated for single-tooth prosthesis.
# GM Exact Abutments
GM Exact abutments are intermediary prosthetic components to be installed onto GM implants to support the final prosthesis. They are provided in an anti-rotational shape for the coupling with the prosthesis and are available in 3.5 and 4.8 mm of diameter and the following gingival heights: 0.8, 1.5, 2.5, 3.5, 4.5, 5.5 mm. They are indicated for screw-retained single-tooth prostheses onto implants.
# GM Exact Click Universal Abutments (straight and angled)
GM Exact Click Universal abutments are intermediary prosthetic components to be installed onto GM implants to support the final prosthesis. They provided in an anti-rotational shape for the coupling with the prosthesis and in various angulation, prosthetic and gingival heights to match the variation in mucosal thickness. They are indicated for cemented-retained single-tooth prostheses onto implants.
# GM Exact Titanium Base abutments
The Titanium Bases are intermediary prosthetic components to be installed onto GM implants to support the final prosthesis; the Titanium Base two-piece abutments used as a base when fabricating a CAD/CAM customized restoration. They are provided in an anti-rotational shape for the coupling with the prosthesis and are available in diameters of 3.5 and 4.5 mm and the following gingival heights: 0.8, 1.5, 2.5, 3.5, 4.5, 5.5 mm. The planning and milling of the customized superstructures must be made using the validated Dental Wings Operating System (DWOS) or 3Shape software. All digitally designed copings and/or crowns for use with the Titanium Bases are intended to be manufactured at a validated milling center. The limits for customization are stated in product IFU. The superstructure produced through CAD/CAM System will compose the second part of the two-piece abutment; the assembly becomes a
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finished medical device after cementation on Titanium Base. They are indicated cementedretained single-tooth prostheses onto implants.
#### GM Pro PEEK Abutment
GM Pro PEEK abutments are temporary intermediary prosthetic components to be installed onto the Implants to support the provisional prosthesis up to 6 months. They are composed of a customizable cylindrical body made of PEEK and a non-customizable base made of titanium alloy for an anti-rotational implant connection to GM implants. They are available in 4.5 and 6.0 mm of diameter and the following gingival heights: 0.8, 1.5, 2.5, 3.5, 4.5, 5.5 mm. Pro PEEK Abutments can be used before the installation of the final prosthesis to maintain, stabilize and shape the soft tissue (gum) during the healing phase. Pro PEEK Abutment must not be placed in occlusion when assembled with small diameter implants (≤3.75 mm).
#### Protection Cylinders
The Protection Cylinders are prosthetic components with a tapered shape intended to be placed on abutments to protect them during the fabrication of the prosthesis and/or healing of the peri-implant tissues. They are available in models for attachment to abutments, mini conical abutments or micro abutments.
#### Coping Screws
The Coping Screws are prosthetic devices intended for coping fixation on the corresponding GM (screw-retained) abutment. They are available in two different models: one for fitting in GM Exact Abutments and another for fitting in GM Mini and Micro Abutments.
#### 5.2 Indications for Use
Indications for Use for GM implants and conventional abutments:
The Neodent Implant System is intended to be surgically placed in the bone of the upper or lower jaw to provide support for prosthetic devices such as artificial teeth, to restore chewing function. It may be used with single-stage or two-stage procedures, for single or multiple unit restorations, and may be loaded immediately when good primary stability is achieved and with appropriate occlusal loading.
Indications for Use for GM Titanium Base abutments:
Titanium Base Abutment is a titanium base placed onto Neodent dental implants to provide support for customized prosthetic restorations. It is used with a coping and crown, or crown alone, and is indicated for cement-retained single or multi-unit restorations, or screw-retained single restorations.
All digitally designed copings and/or crowns for use with the Neodent Titanium Base Abutment System are intended to be sent to Straumann for manufacture at a validated milling center.
#### Indications for Use for GM Pro Peek Abutments:
The Pro PEEK Abutments are indicated to be used on Neodent implants to provide temporary support for prosthesis structure for up to 6 months. They can be used in one or two stage procedures and also immediate load when there is good primary stability.
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#### 5.3 Technological Characteristics
The subject and the predicate devices have a range of dental implants and abutments with the same indication of providing solutions for teeth replacement, restoring chewing function.
The subject and predicate devices are based on the following same technological elements:
- -Root-form implants intended to replace natural tooth root;
- -Endosseous dental abutments to provide support for temporary or permanent restorations;
- -Possibility of use in single or two-stage procedures, for single or multiple-unit restorations;
- -Implants and conventional and CAD/CAM abutments made of the same material;
- -Same sterilization methods and packaging for implants, conventional and CAD/CAM abutments.
The following technological differences exist between the subject and predicate devices:
- A new design of Morse taper implant-to-abutment interface is presented; -
- -A new design of implant thread was developed to fit in all types of bone quality;
- -The subject temporary abutment is provided sterile by EO exposition whereas its predicate device is provided non-sterile for end-user sterilization.
In the end of this Section, a comparison between the features of subject device and its predicate devices is shown in a tabular format. The assessment of the differences is also included.
#### 5.4 Performance data
The following performance data supports the substantial equivalence determination:
### Biocompatibility testing
The implants are made of unalloyed titanium, Grade 4, conforming to ASTM F67 Standard Specification for Unalloyed Titanium for Surgical Implant Applications (UNS R50250, UNS R50400, UNS R50550, UNS R50700). The conventional and CAD/CAM abutments are made of titanium ASTM F136 Standard Specification alloy conforming conforming to for Wrought Titanium-6Aluminum-4Vanadium ELI (Extra Low Interstitial) Alloy for Surgical Implant Applications (UNS R56401). The types of titanium are the same to that used for fabrication of the predicate devices cleared under K101945, K150182 and K153624. The subject devices undergo to the same manufacturing processes to the cited predicate devices.
The temporary abutments are made of PEEK. A chemical characterization of this material has been performed to identify leachable inorganic substances and extractable organic substances. Additionally, cytotoxicity analysis also has been performed.
The superstructures for titanium bases are made of zirconia, IPS e.max, Co-Cr and Lava Plus. Zirconia is conforming to ISO 13356 - Implants for surgery - Ceramic materials based on yttriastabilized tetragonal zirconia (Y-TZP), IPS e.max CAD (lithium disilicate) is conforming to ISO
JJGC Indústria e Comércio de Materiais Dentários S.A.
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6872 - Dentistry - Ceramic Materials and Co-Cr is conforming to ISO 22674 - Dentistry - Metallic materials for fixed and removable restorations and appliances. These raw materials are the same already cleared for the reference predicate devices under K153624. Lava Plus is an yttrium stabilized zirconium oxide (Y-TZP) and complies with the requirements of ISO 6872 Dentistry -Ceramic Materials. Cytotoxicity testing was performed for this raw material and showed no proliferation inhibition. Also, Lava Plus has been cleared by FDA per K072055 for manufacturing of dental restorations through CAD/CAM technique.
### Mechanical testing
The strength of the system is demonstrated through fatigue testing performed according to ISO 14801 - Dentistry - Implants - Dynamic fatique test for endosseous dental implants and FDA document Guidance for Industry and FDA Staff - Class II Special Controls Guidance Document: Root-form Endosseous Dental Implants and Endosseous Dental Abutments. The tested subject devices exhibit a level of performance equivalent to that reviewed for the predicate devices.
#### Sterilization validation
The subject implants are sterilized by Co60 gamma irradiation at a nominal dose of 25 kGy (2.5 Mrad). Sterilization has been validated by the VDmax® method, according to ISO 11137-1 Sterilization of health care products - Radiation - Part 1: Requirements for development, validation and routine control of a sterilization process for medical devices and ISO 11137-2 Sterilization of health care products - Radiation - Part 2: Establishing the sterilization dose.
The subject abutments are sterilized by exposure to ethylene oxide (EO). Sterilization has been validated by the bioburden method, according to ISO 11135 Sterilization of health care products - Ethylene oxide - Requirements for the development, validation, and routine control of a sterilization process for medical devices. EO sterilization residuals have been verified to be less than the maximum allowable limits as defined in ISO 10993-7 Biological Evaluation of Medical Devices - Part 7: Ethylene Oxide Sterilization Residuals.
The subject CAD/CAM superstructures are sterilized by moist heat (steam). The recommended sterilization has been validated 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/TS 17665-2 Sterilization of health care products - Moist heat - Part 2: Guidance on the application of ISO 17665-1.
All methods achieve a Sterility Assurance Level (SAL) of 10 °.
The sterilization methods presented for the subject devices have been previously reviewed under K101945, K150182 and K153624.
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#### Shelf Life Testing
Shelf life testing for the Neodent Implant System was performed for both methods of sterilization, gamma irradiation and ethylene oxide exposure. Shelf life was determined through both accelerated and real time aging protocols according to ASTM F1980 Standard Guide for Accelerated Aging of Sterile Barrier System for Medical Devices.
JJGC Indústria e Comércio de Materiais Dentários S.A.
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| | SUBJECT DEVICES | PRIMARY PREDICATE | | REFERENCE PREDICATE DEVICES | | |
|-----------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Neodent Implant System –<br>GM Line | Neodent Implant System<br>(K101945) | Neodent Implant System<br>(K150182) | Neodent Implant System<br>(K153624) | Straumann RC Temp.<br>Abutment (K093027) | EQUIVALENCE<br>DISCUSSION |
| Indications for<br>Use | for GM implants and conventional<br>abutments:<br>The Neodent Implant System is<br>intended to be surgically placed in<br>the bone of the upper or lower jaw to<br>provide support for prosthetic<br>devices such as artificial teeth, to<br>restore chewing function. It may be<br>used with single-stage or two-stage<br>procedures, for single or multiple unit<br>restorations, and may be loaded<br>immediately when good primary<br>stability is achieved and with<br>appropriate occlusal loading. | The Neodent Implant<br>System is intended to be<br>surgically placed in the<br>bone of the upper or<br>lower jaw to provide<br>support for prosthetic<br>devices such as artificial<br>teeth, to restore chewing<br>function. It may be used<br>with single-stage or two-<br>stage procedures, for<br>single or multiple unit<br>restorations, and may be<br>loaded immediately<br>when good primary<br>stability is achieved and<br>with appropriate occlusal<br>loading. Multiple tooth<br>applications may be<br>rigidly splinted. | The Neodent Implant<br>System is intended to be<br>surgically placed in the<br>bone of the upper or<br>lower jaw to provide<br>support for prosthetic<br>devices such as artificial<br>teeth, to restore chewing<br>function. It may be used<br>with single-stage or two-<br>stage procedures, for<br>single or multiple unit<br>restorations, and may be<br>loaded immediately<br>when good primary<br>stability is achieved and<br>with appropriate occlusal<br>loading. Multiple tooth<br>applications may be<br>rigidly splinted. | Titanium Base Abutment<br>is a titanium base placed<br>onto Neodent dental<br>implants to provide<br>support for customized<br>prosthetic restorations.<br>It is used with a coping<br>and crown, or crown<br>alone, and is indicated<br>for cement-retained<br>single or multi-unit<br>restorations, or screw-<br>retained single<br>restorations.<br>All digitally designed<br>copings and/or crowns<br>for use with the Neodent<br>Titanium Base Abutment<br>System are intended to<br>be sent to Straumann for<br>manufacture at a<br>validated milling center. | The Straumann RC<br>Temporary Abutments<br>are indicated for use in<br>Straumann RC Bone<br>Level Implants for<br>temporary restorations<br>of single crowns and<br>bridges for up to six<br>months | Equivalent<br>Indications for Use for<br>GM implants and<br>conventional abutments:<br>The indications for use of<br>the subject devices is<br>included into the<br>indications of the<br>primary predicate<br>devices.<br>Indications for Use for<br>GM Titanium Base<br>abutments:<br>The indication for use is<br>identical to the predicate<br>K153624.<br>Indications for Use for<br>GM Pro Peek Abutments<br>Both the indications of<br>subject and predicate<br>device (K093027) have<br>the same intention to<br>provide support to<br>temporary restorations. |
| | for GM Titanium Base abutments:<br>Titanium Base Abutment is a titanium<br>base placed onto Neodent dental<br>implants to provide support for<br>customized prosthetic restorations. It<br>is used with a coping and crown, or<br>crown alone, and is indicated for<br>cement-retained single or multi-unit<br>restorations, or screw-retained single<br>restorations.<br>All digitally designed copings and/or<br>crowns for use with the Neodent<br>Titanium Base Abutment System are<br>intended to be sent to Straumann for<br>manufacture at a validated milling<br>center. | | | | | |
| | for GM Pro Peek Abutments:<br>The Pro PEEK Abutments are<br>indicated to be used on Neodent<br>implants to provide temporary<br>support for prosthesis structure for<br>up to 6 months. They can be used in<br>one or two stage procedures and also<br>immediate load when there is good | | | | | |
| | SUBJECT DEVICES | PRIMARY PREDICATE | REFERENCE PREDICATE DEVICES | | | |
| | Neodent Implant System –<br>GM Line | Neodent Implant System<br>(K101945) | Neodent Implant System<br>(K150182) | Neodent Implant System<br>(K153624) | Straumann RC Temp.<br>Abutment (K093027) | EQUIVALENCE<br>DISCUSSION |
| Diameter(s) | Implants:<br>3.5 to 5.0 mm<br>Conventional abutments:<br>3.3 to 4.8 mm<br>CAD/CAM abutments:<br>3.5 and 4.5 mm<br>Temporary abutments:<br>4.5 and 6 mm | Implants:<br>3.5 to 5.0 mm<br>Conventional abutments:<br>3.5 to 4.5 mm | Implants:<br>3.5 to 5.0 mm | CAD/CAM abutments:<br>3.5 and 4.5 mm | Temporary abutments:<br>4.5 mm | Equivalent<br>Subject device diameters<br>are within the range of<br>diameters of the<br>predicate devices or<br>larger. Larger diameters<br>do not represent a worst<br>case in terms of<br>performance. |
| Implants length | 8 to 18 mm | 8 to 19 mm | 18 mm | NA | NA | Equivalent<br>Subject implant lengths<br>are within the range of<br>the predicate devices. |
| Implants types<br>of threads | Titamax<br>Helix<br>Drive | Titamax<br>Alvim | Drive | NA | NA | Equivalent<br>Titamax model remains<br>the same to that<br>presented in K101945.<br>Drive model presents<br>changes when compared<br>to K150182, however the<br>changes do not affect<br>dynamic fatigue<br>performance. Helix<br>model is new, however<br>tests confirm that they<br>have equivalent<br>performances. |
| Gingival<br>Heights<br>(of the<br>abutments<br>subject to<br>masticatory<br>load) | 0.8 to 5.5 mm | 0.8 to 6.5 mm | NA | 0.8 4.5 mm | Unknown | Equivalent<br>Subject device heights<br>are included in the range<br>of the predicate device<br>heights and do not<br>represent a worst case in<br>terms of performance. |
| | SUBJECT DEVICES | PRIMARY PREDICATE | REFERENCE PREDICATE DEVICES | | | |
| | Neodent Implant System – | Neodent Implant System | Neodent Implant System | Neodent Implant System | Straumann RC Temp. Abutment (K093027) | EQUIVALENCE |
| | GM Line | (K101945) | (K150182) | (K153624) | | DISCUSSION |
| Material | Implants: | Implants: | Implants: | CAD/CAM abutments: | Temporary abutments: | Equivalent |
| | Titanium grade 4 | Titanium grade 4 | Titanium grade 4 | Titanium alloy Ti-6Al-4V ELI | Titanium alloy (Ti-6Al- 7Nb, TAN)<br>PEEK<br>(polyetheretherketone) | The subject and the<br>predicate devices are<br>made of the same type<br>of raw material; the<br>adequacy of the system…
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.