With its "Polywave" LED with broadband spectrum, Bluephase PowerCure is suitable for the polymerization of all lightcuring dental materials curing in the wavelength range of 385-515 nm. These materials include restoratives, bonding agents/adhesives, bases, liners, fissure sealants, temporaries, as well as luting materials for brackets and indirect restorations, such as ceramic inlays.
Device Story
Bluephase PowerCure is a pen-shaped, battery-powered LED curing light used by dentists or dental assistants in clinical settings. It utilizes a 'Polywave' LED to emit broadband blue light (385-515 nm) to polymerize dental materials. The device features four operational modes (3s Cure, Turbo, High Power, PreCure) with irradiance up to 3,050 mW/cm². The operator selects the program and time; the device automatically terminates the cycle upon completion. It is intended for use in dental practices or hospitals to harden restorative materials, adhesives, and luting agents directly in the oral cavity. The device benefits patients by enabling rapid polymerization of dental materials, potentially reducing chair time.
Clinical Evidence
No clinical data. Bench testing only. Device performance validated through electrical safety testing (IEC 60601-1:2012, IEC 60601-1-2:2007) and sterilization validation per ISO 14937.
Technological Characteristics
Handheld pen-style LED curing light; Polywave LED source; Li-ion battery power; 4 curing modes; irradiance up to 3,050 mW/cm²; wavelength 385-515 nm. Tested to IEC 60601-1:2012 and IEC 60601-1-2:2007. Non-sterile; light probe requires sterilization per ISO 14937.
Indications for Use
Indicated for polymerization of light-curing dental materials (restoratives, adhesives, bases, liners, sealants, temporaries, luting materials) in the 385-515 nm wavelength range for dental patients.
Regulatory Classification
Identification
An ultraviolet activator for polymerization is a device that produces ultraviolet radiation intended to polymerize (set) resinous dental pit and fissure sealants or restorative materials by transmission of light through a rod.
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. Underneath the square are the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.
July 3, 2019
Ivoclar Vivadent, AG % Lori Aleshin Director of Quality & Regulatory Affairs Ivoclar Vivadent, Inc. 175 Pineview Drive Amherst. New York 14228
Re: K190272
Trade/Device Name: Bluephase PowerCure Regulation Number: 21 CFR 872.6070 Regulation Name: Ultraviolet Activator For Polymerization Regulatory Class: Class II Product Code: EBZ Dated: June 11, 2019 Received: June 13, 2019
Dear Lori Aleshin:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 of medical device-related adverse events) (21 CFR 803) for
devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Srinivas Nandkumar, Ph.D. Acting Assistant Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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### Indications for Use
510(k) Number (if known)
K190272
Device Name Bluephase® PowerCure
Indications for Use (Describe)
With its "Polywave" LED with broadband spectrum, Bluephase PowerCure is suitable for the polymerization of all lightcuring dental materials curing in the wavelength range of 385-515 nm. These materials include restoratives, bonding agents/adhesives, bases, liners, fissure sealants, temporaries, as well as luting materials for brackets and indirect restorations, such as ceramic inlays.
Type of Use (Select one or both, as applicable)
| <span style="font-family: Arial;"> <input checked="true" type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D) </span> |
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| <span style="font-family: Arial;"> <input type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C) </span> |
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## 510(K) SUMMARY
Image /page/3/Picture/1 description: The image shows the logo for Ivoclar Vivadent, a dental company. The logo features the company name in a stylized font, with "Ivoclar" in green and "Vivadent" in blue. Below the name is the tagline "passion vision innovation" in a smaller font. Above the company name is a series of green and blue dots and squares.
### K190272
| Contact: | Lori Aleshin, Director of Quality and Regulatory Affairs<br>Ivoclar Vivadent, Inc.<br>175 Pineview Drive<br>Amherst, New York 14228<br>716-264-2045<br>lori.aleshin@ivoclarvivadent.com |
|----------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Company: | Ivoclar Vivadent, AG<br>Bendererstrasse 2, Schaan, FL-9494, Liechtenstein<br>+423-235-3535 |
| Date Prepared: | June 6, 2019 |
| Proprietary Name: | Bluephase® PowerCure |
| Classification Name: | Activator, Ultraviolet, For Polymerization (872.6070)<br>(Classification Code EBZ) |
| Predicate Device: | Bluephase Style 20i (K163613) by Ivoclar Vivadent, AG |
Bluephase® PowerCure is an LED curing light that produces blue Device Description: light. It is used for the polymerization of light-curing dental materials immediately in the oral cavity of patients. The intended place of application is in the dental practice, medical practice or in the hospital by the dentist or dental assistant. The curing light must only be operated by trained dental personnel.
- The handpiece has the shape of a pen
- Operational notes: 4 programs (3s, Turbo, High, PreCure)
- Light source: Polywave LED ●
- . Power Source: Li-lons batterv
Indications for Use: With its "Polywave" LED with broadband spectrum, Bluephase PowerCure is suitable for the polymerization of all light-curing dental materials curing in the wavelength range of 385 - 515 nm. These materials include restoratives, bonding agents/adhesives, bases, liners, materials include restoratives, bonding agents/adhesives, bases, liners, fissure sealants, temporaries, as well as luting materials for brackets and indirect restorations, such as ceramic inlays.
Comparison to Predicate: The primary predicate devices to which Bluephase® PowerCure has been compared is Ivoclar Vivadent, AG Bluephase Style 20i (K163613). The new device Bluephase PowerCure composite materials can be cured within 3 seconds, the new device is able to emit light with an irradiance of 3.050 mW/cm² in contrast to the predicate and has 4 curing modes in contrast to 2 programs of the predicate. To enable the higher light irradiance the power supply has a higher output.
Reference Device: VALO Grand Corded manufactured by Ultradent Products Inc. (K190627)
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# 510(K) SUMMARY
Image /page/4/Picture/1 description: The image shows the logo for Ivoclar Vivadent, a dental company. The logo is blue and green, and it features the company's name in a stylized font. Below the name is the company's slogan, "passion vision innovation." The number 2 is in the upper right corner of the image.
| Device | Ivoclar Vivadent AG: Bluephase Style 20i<br>(K163613) | Ivoclar Vivadent: Bluephase®<br>PowerCure |
|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | With its "Polywave" broadband<br>spectrum, Bluephase Style 20i is<br>suitable for the polymerization of all light<br>curing dental materials curing in the<br>wavelength range of 385-515 nm.<br>These materials include restoratives,<br>bonding agents/adhesives, bases,<br>liners, fissure sealants, temporaries, as<br>well as luting materials for brackets and<br>indirect restorations, such as ceramic<br>inlays. | With its "Polywave" LED with<br>broadband spectrum, Bluephase<br>PowerCure is suitable for the<br>polymerization of all light-curing dental<br>materials curing in the wavelength<br>range of 385 – 515 nm. These<br>materials include restoratives, bonding<br>agents/adhesives, bases, liners,<br>fissure sealants, temporaries, as well<br>as luting materials for brackets and<br>indirect restorations, such as ceramic<br>inlays. |
| Summary of Indications | The indications are the same as for the predicate therefore both devices are<br>substantially equivalent. | |
| Principles of operation | Step-by-step:<br>1. Disinfect contaminated surfaces of<br>the curing light as well as light probes<br>and anti-glare cones before<br>each use.<br>2. Make sure that the stipulated light<br>irradiance permits adequate<br>polymerization. For that purpose, check<br>the light probe for contamination and<br>damage, as well as the light irradiance<br>at regular intervals.<br>3. Select curing program and time<br>4. Start: Once the selected curing time<br>has elapsed,the curing program is<br>automatically terminated. | Step-by-step:<br>1. Disinfect contaminated surfaces of<br>the curing light as well as light guides<br>and anti-glare cones before each use.<br>2. Make sure that the stipulated light<br>irradiance permits adequate<br>polymerization. For that purpose,<br>check the light probe for contamination<br>and damage, as well as the light<br>irradiance at regular intervals.<br>3. Select curing program and time<br>4. Start: Once the selected curing time<br>has elapsed, the curing program is<br>automatically terminated. |
| Summary Principles of<br>operation | No difference. | |
| Delivery form content | 1 Charging base with power cord and<br>power pack<br>1 Handpiece<br>1 Light probe 10>8 mm, black<br>1 Anti-glare shield<br>3 Anti-glare cones<br>1 Pack of sleeves<br>1 Instructions for use | 1 Charging base with power cord and<br>power pack<br>1 Handpiece<br>1 Handpiece support<br>1 Light guide 10>9 mm<br>1 Anti-glare shield<br>3 Anti-glare cones<br>1 Instructions for Use |
| Summary of Delivery<br>form content | The US delivery form currently does not contain sleeves. Customers are<br>recommended to use an alternative product which is locally available in the US.<br>The handpiece support is an accessory so that the dentist can lie the device down<br>without putting it on the charging base or the working surface.<br>The differences in the light guide diameter is non-significant.<br>Therefore, delivery forms are basically the same for both devices. | |
| Electrical Safety | This product has been tested to IEC<br>60601-1:2005 and IEC 60601-1-2:2007 | The new device has been tested to<br>IEC 60601-1:2012 and IEC 60601-1-<br>2:2007 |
| Summary of Electrical<br>Safety | Bluephase PowerCure conforms to the current version of the same standards as<br>the predicate device. | |
| Operational modes | 2 programs:<br>- Turbo (2,000 mW/cm²)<br>- High Power Program (1,200 mW/cm²) | 4 programs:<br>- 3s Cure Program (3,050 mW/cm²)<br>- Turbo program (2,100 mW/cm²)<br>- High power Program (1,200 mW/cm²)<br>- PreCure (preset to 2s)(950 mW/cm²) |
| Summary Operational<br>modes | The innovation of the new device Bluephase PowerCure is that it is able to emit<br>light with 3,050mW/cm² in combination with a shorter curing time. | |
| Storage Conditions | Temperature: -20 °C to + 60 °C /+4 °F<br>to +140 °F<br>Relative humidity: 10% to 75% | Temperature: -20 °C to + 60 °C /+4 °F<br>to +140 °F<br>Relative humidity: 10% to 75% |
| Summary of Storage<br>Conditions | No difference. | |
| Device Specification<br>Summary | The higher irradiance of Bluephase PowerCure (3,050mW/cm²) is comparable to the Xtra<br>Power Mode (3,200 mW/cm²) | |
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## 510(K) SUMMARY
Image /page/5/Picture/1 description: The image shows the Ivoclar Vivadent logo. The logo is composed of the company name in blue, with the words "passion vision innovation" underneath. Above the company name, there is a series of green and blue dots and squares arranged in a semi-circular pattern. The number 3 is in the upper right corner of the image.
### Infection Control:
The device is sold in a non-sterile condition. Prior to use and after use sterilization of the light probe is recommended. The sterilization cycle recommended in the Instructions for Use have been validated according to ISO 14937 Sterilization of health care products- General requirements for characterization of a sterilization agent and the development, validation and routine control of a sterilization process for medical devices.
### Biocompatibility:
Direct contact with tissue is not intended. Therefore ISO 10993-1 is not applicable. A Toxicological statement of the LED Unit Bluephase PowerCure has been included in this submission.
### Software Validation:
Bluephase PowerCure software/firmware has been fully validated and the device software meets its Design Specifications. FDA Guidance Document Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices has been followed in connection with the design of the device.
### Summary of Safety Testing:
The product has been tested to IEC 60601-1:2012 and IEC 60601-1-2:2007 and meets the requirements for Electrical Safety, including US National Deviations, and Electromagnetic Compatibility. The test reports are included in this submission.
### Conclusion:
Bluephase PowerCure is an LED polymerization light, which is used for the polymerization of light-curing dental materials. This is achieved by using the same operating principle and performance criteria as for Bluephase Style 20i.
Therefore, Bluephase PowerCure is substantially equivalent to its predicate device, Bluephase Style 20i.
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.