Zaga Zygomatic System

K222497 · Southern Implants (Pty), Ltd. · DZE · Nov 9, 2022 · Dental

Device Facts

• Record ID: K222497
• Device Name: Zaga Zygomatic System
• Applicant: Southern Implants (Pty), Ltd.
• Product Code: DZE · Dental
• Decision Date: Nov 9, 2022
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 872.3640
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

Southern Implants ZAGA Zygomatic System implants are intended to be implanted in the upper jaw arch to provide support for fixed dental prostheses in patients with partially or fully edentulous maxillae. All implants are appropriate for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

Device Story

ZAGA Zygomatic System consists of partially threaded root-form dental implants designed for placement into the zygoma to support fixed dental prostheses in edentulous or partially edentulous maxillae. Implants feature an external hexagonal abutment interface angled at 55°. Available in 'Round' and 'Flat' designs with varying lengths. Implants are placed by dental surgeons in a clinical setting. The device provides a stable anchor for prosthetic rehabilitation, potentially improving patient quality of life and satisfaction. The system is provided sterile for single-patient, single-use.

Clinical Evidence

Clinical evidence includes a case report and two published studies. Parel et al. (2001) reported on 59 zygomatic implants (25-60mm) for maxillary defect rehabilitation. Fernández-Ruiz et al. (2021) conducted a prospective randomized clinical study of 40 zygomatic cases (35-60mm) comparing patient quality of life and satisfaction against conventional All-on-Four implants.

Technological Characteristics

Unalloyed titanium (ASTM F67, Grade 4, UTS ≥ 900MPa). Partially threaded root-form design with grit-blasted endosseous surface. External hex interface with 55° head angulation. Sterilized via gamma irradiation. Complies with ISO 14801 for dynamic fatigue testing.

Indications for Use

Indicated for patients with partially or fully edentulous maxillae requiring support for fixed dental prostheses via implantation in the upper jaw arch. Appropriate for immediate loading given good primary stability and appropriate occlusal loading.

Regulatory Classification

Identification

An endosseous dental implant is a prescription device made of a material such as titanium or titanium alloy that is intended to be surgically placed in the bone of the upper or lower jaw arches to provide support for prosthetic devices, such as artificial teeth, in order to restore a patient's chewing function.

Special Controls

*Classification.* (1) Class II (special controls). The device is classified as class II if it is a root-form endosseous dental implant. The root-form endosseous dental implant is characterized by four geometrically distinct types: Basket, screw, solid cylinder, and hollow cylinder. The guidance document entitled “Class II Special Controls Guidance Document: Root-Form Endosseous Dental Implants and Endosseous Dental Implant Abutments” will serve as the special control. (See § 872.1(e) for the availability of this guidance document.)(2) *Classification.* Class II (special controls). The device is classified as class II if it is a blade-form endosseous dental implant. The special controls for this device are:(i) The design characteristics of the device must ensure that the geometry and material composition are consistent with the intended use; (ii) Mechanical performance (fatigue) testing under simulated physiological conditions to demonstrate maximum load (endurance limit) when the device is subjected to compressive and shear loads; (iii) Corrosion testing under simulated physiological conditions to demonstrate corrosion potential of each metal or alloy, couple potential for an assembled dissimilar metal implant system, and corrosion rate for an assembled dissimilar metal implant system; (iv) The device must be demonstrated to be biocompatible; (v) Sterility testing must demonstrate the sterility of the device; (vi) Performance testing to evaluate the compatibility of the device in a magnetic resonance (MR) environment; (vii) Labeling must include a clear description of the technological features, how the device should be used in patients, detailed surgical protocol and restoration procedures, relevant precautions and warnings based on the clinical use of the device, and qualifications and training requirements for device users including technicians and clinicians; (viii) Patient labeling must contain a description of how the device works, how the device is placed, how the patient needs to care for the implant, possible adverse events and how to report any complications; and (ix) Documented clinical experience must demonstrate safe and effective use and capture any adverse events observed during clinical use.

Predicate Devices

• ZAGA Zygomatic System (K192651)

Submission Summary (Full Text)

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Southern Implants (Pty) Ltd Leith Cumming Acting Head of Regulatory Affairs and Quality 1 Albert Road Irene, Gauteng 0062 SOUTH AFRICA

Re: K222497

Trade/Device Name: Zaga Zygomatic System Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: Class II Product Code: DZE Dated: August 17, 2022 Received: August 18, 2022

# Dear Leith Cumming:

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 ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely.

# Andrew I. Steen -S

Andrew I. Steen Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality 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)

K222497

Device Name

ZAGA Zygomatic System

Indications for Use (Describe)

Southern Implants ZAGA Zygomatic System implants are intended to be implanted in the upper jaw arch to provide support for fixed dental prostheses in patially or fully edentulous maxillae. All implants are appropriate for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

| Type of Use ( <i>Select one or both, as applicable</i> ) | <span> <span style="padding-right: 5px;"> <span style="font-size: 16px;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> <span> <span style="font-size: 16px;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </span> |
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### 510(k) Summary

## ZAGA Zygomatic System

#### Southern Implants (Pty) Ltd

#### K222497

#### November 9, 2022

#### ADMINISTRATIVE INFORMATION

| Manufacturer Name | Southern Implants (Pty) Ltd<br>1 Albert Road<br>Irene, Gauteng, 0062 South Africa |
|-------------------|----------------------------------------------------------------------------------------------------------|
| | Telephone: [phone]<br>Fax: [phone] |
| Official Contact | Leith C. Cumming<br>Acting Head of Regulatory Affairs and Quality<br>Email: [e-mail] |

#### DEVICE NAME AND CLASSIFICATION

| Trade/Proprietary Name | ZAGA Zygomatic System |
|---------------------------|---------------------------|
| Common Name | Dental implant |
| Classification Name | Endosseous dental implant |
| Classification Regulation | 21 CFR 872.3640, Class II |
| Product Code | DZE |
| Classification Panel | Dental Products Panel |
| Reviewing Branch | Dental Devices Branch |

#### PREDICATE DEVICE INFORMATION The primary predicate device is K192651.

#### INDICATIONS FOR USE STATEMENT

Southern Implants ZAGA Zygomatic System implants are intended to be implanted in the upper jaw arch to provide support for fixed dental prostheses in patients with partially or fully edentulous maxillae. All implants are appropriate for immediate loading when good primary stability is achieved and with appropriate occlusal loading.

#### SUBJECT DEVICE DESCRIPTION

The ZAGA zygomatic implants are partially threaded root-form dental implants with an external hexagonal abutment interface angled 55° at the head of the implant, and are threaded internally for attachment of mating abutments. The ZAGA zygomatic implants are provided in two designs: the ZAGA Round zygomatic implant (previously named the ZAGA Regular), coronally and apically threaded, diameter 4.3 mm (coronal) tapering to 3.4 mm (apical), in overall lengths ranging of 30 mm and the ZAGA Flat zygomatic implant (previously named the ZAGA Advanced), apically threaded, diameter 4.3 mm (coronal) tapering to 3.4 mm (apical), in overall lengths ranging from 30 mm, with a flat cut into the buccal-facing side of the implant body. Only the length 30, 32.5, 57.5 and 60 mm ZAGA Round zygomatic implants and length 55, 57.5 and 60 mm ZAGA Flat zygomatic implants are a subject of this submission.

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All ZAGA zygomatic implants are manufactured from unalloyed titanium conforming to ASTM F67. The apically threaded portions of the implants have the identical aluminum oxide grit-blasted surface as the implants cleared in K192651. The subject device implants are manufactured in the same facilities using the same manufacturing processes as used for the Southern Implants predicate device previously cleared in K192651.

#### PERFORMANCE DATA

Non-clinical data submitted, referenced, or relied upon to demonstrate substantial equivalence include: biocompatibility (referenced from K192651); comparison and features; sterilization validation according to ISO 11137-1, ISO 11137-2, ISO 17665-1, ISO TS 17665-2; bacterial endotoxin according to USP 39-NF34; sterile barrier shelf life (referenced from K192651); MR safety evaluation and MR Conditional labeling as per the recommendations of the FDA Guidance Document "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment''; and static and dynamic compression-bending according to ISO 14801 Dentistry - Implants - Dynamic fatigue test for endosseous dental implants (referenced from K192651 as the surgical protocol of the implants did not warrant the additional subject device lengths as a new worst-case for fatigue testing).

Non-clinical worst-case MRI review was performed to evaluate the metallic Straumann® ZAGA Zygomatic Implant System devices in the MRI environment using scientific rationale and published literature (e.g., Woods, Terry O., Jana G. Delfino, and Sunder Rajan. "Assessment of Magnetically Induced Displacement Force and Torque on Metal Alloys Used in Medical Devices." Journal of Testing and Evaluation 49.2 (2019): 783-795; and Oriso, Kenta, Takuya Kobayashi, Makoto Sasaki, Ikuko Uwano, Hidemichi Kihara, and Hisatomo Kondo. "Impact of the static and radiofrequency magnetic fields produced by a 7T MR imager on metallic dental materials." Magnetic Resonance in Medical Sciences 15, no. 1 (2016): 26-33), based on the entire system including all variations (all compatible implant bodies, dental abutments, and fixation screws) and material composition. Rationale addressed parameters per the FDA guidance "Testing and Labeling Medical Devices for Safety in the Magnetic Resonance (MR) Environment," including magnetically induced displacement force and torque.

Clinical data submitted, referenced or relied upon to demonstrate substantial equivalence include: a clinical case report demonstrating the use of 60mm length zygomatic implants in a patient, and two published articles utilizing, among other implants, 60mm length zygomatic implants for patient rehabilitation. These articles are summarized below:

- Parel et al. (Remote implant anchorage for the rehabilitation of maxillary defects. The Journal of . prosthetic dentistry 86.4 (2001): 377-381) presented a rationale for the use of remote bone sites and zygomatic implants for rehabilitating patients with maxillary defects. Parel et al. provide clinical data on the use of 59 zygomatic implants in lengths ranging from 25 to 60mm.
- Fernández-Ruiz et al. (Evaluation of quality of life and satisfaction in patients with fixed prostheses on . zygomatic implants compared with the all-on-four concept: a prospective randomized clinical study. International Journal of Environmental Research and Public Health 18.7 (2021): 3426) present a prospective randomized clinical study comparing patient quality of life and satisfaction with their prosthesis on zygomatic implants versus the All-on-Four with conventional implants. This study reported 40 zygomatic cases in which zygomatic implants of lengths 35 - 60mm were used.

#### EQUIVALENCE TO MARKETED DEVICE

Southern Implants (Pty) Ltd submits the information in this Premarket Notification to demonstrate that, for the purposes of FDA's regulation of medical device is substantially equivalent in indications and design principles to the following legally marketed predicate devices:

#### K192651, ZAGA Zygomatic System, Southern Implants (Pty) Ltd.

A comparison of the technological characteristics of the subject devices and the primary predicate devices is provided in the following table.

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| | Subject Device | Primary Predicate Device |
|-------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Comparison | Additional lengths of ZAGA Zygomatic Implant System<br>Southern Implants (Pty) Ltd | K192651<br>ZAGA Zygomatic Implant System<br>Southern Implants (Pty) Ltd |
| Implant | | |
| Indications for Use Statement | Straumann® Zygomatic implants are intended to be implanted in the upper jaw arch to provide support for fixed dental prostheses in patients with partially or fully edentulous maxillae.<br>All implants are appropriate for immediate loading when good primary stability is achieved and with appropriate occlusal loading. | Straumann® Zygomatic implants are intended to be implanted in the upper jaw arch to provide support for fixed dental prostheses in patients with partially or fully edentulous maxillae.<br>All implants are appropriate for immediate loading when good primary stability is achieved and with appropriate occlusal loading. |
| Product Code | DZE | DZE |
| Intended Use | Functional and esthetic rehabilitation of the edentulous maxilla. | Functional and esthetic rehabilitation of the edentulous maxilla. |
| Reason for Predicate/Reference | Not applicable | Implant design |
| Implant Design | Partially threaded root-form implants for placement into the zygoma. | Partially threaded root-form implants for placement into the zygoma. |
| Implant Diameter | ZAGA Round: 4.3 mm (coronal) taper to 3.4 mm (apical)<br>ZAGA Flat: 4.3 mm (coronal with 3.35 mm flat) taper to 3.4 mm (apical) | ZAGA Round: 4.3 mm (coronal) taper to 3.4 mm (apical)<br>ZAGA Flat: 4.3 mm (coronal with 3.35 mm flat) taper to 3.4 mm (apical) |
| Implant Length | ZAGA Round: 30, 32.5, 57.5, 60 mm<br>ZAGA Flat: 55, 57.5, 60 mm | ZAGA Round: 35, 37.5, 40, 42.5, 45, 47.5, 50, 52.5, 55 mm<br>ZAGA Flat: 30, 32.5, 35, 37.5, 40, 42.5, 45, 47.5, 50, 52.5 mm |
| Platform Angle, Relative to orthogonal to implant long axis | 55° angulation at head of implant | 55° angulation at head of implant |
| Implant Prosthetic Diameter | 4.07 mm | 4.07 mm |
| Implant Interface | External Hex | External Hex |
| Implant Material | Unalloyed titanium (ASTM F67) Grade 4, and UTS ≥ 900MPa (cold-worked) | Unalloyed titanium (ASTM F67) Grade 4, and UTS ≥ 900MPa (cold-worked) |
| Implant Endosseous Surface | Grit-blasted | Grit-blasted |
| How Provided | | |
| Sterility | Provided sterile | Provided sterile |
| Sterilization | Gamma irradiation | Gamma irradiation |
| Usage | Single-patient, single-use | Single-patient, single-use |

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The Indications for Use Statement for the subject device is identical to the predicate device K192651.

The primary predicate device K192651 is for substantial equivalence of the subject device implant designs. The subject device implants have the same external hex connection, identical implant diameters, prosthetic platform angulation and diameter, material, endosseous surface, sterility status method, usage and compatible prosthetic components. The clinical evidence, in the form of a clinical case report and two publications, is for the substantial equivalence of the subject device implant lengths (see clinical performance data).

Substantial equivalence of the subject device implants in terms of biocompatibility is supported by the fact that materials are identical in formulation, processing, component interactions, and storage conditions to the predicate devices in K192651.

In support of substantial equivalence of the additional lengths of ZAGA zygomatic implants in terms of mechanical performance, dynamic compression-bending testing to ISO 14801 are referenced from K192651. Dynamic testing (referenced from K192651) was performed on worst-case subject device constructs. The additional lengths of the ZAGA zygomatic implants does not influence the results of this fatigue testing and so additional fatigue testing was not warranted for this submission. The results from the testing provided in K192651 are thus valid for the subject devices and demonstrates the fatigue performance of the subject device exceeds its indication.

#### CONCLUSION

The subject device and the predicate device have the same intended use and indications for use, have similar technological characteristics, and are made of the same materials. The subject device and the predicate device encompass a similar range of physical dimensions, including the same diameter of the implants, same prosthetic platform and same compatible abutment range. The differing total lengths of the subject device is supported by clinical data provided. The subject device and the predicate devices are packaged in similar materials and sterilized using the same methods.

The data included in this submission demonstrate substantial equivalence to the predicate devices listed above.