K222323 · Elevate Oral Care, LLC · PHR · Jun 23, 2023 · Dental
Device Facts
Record ID
K222323
Device Name
Black Diamond
Applicant
Elevate Oral Care, LLC
Product Code
PHR · Dental
Decision Date
Jun 23, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3260
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Black Diamond is intended as Treatment of Dental Hypersensitivity. For use in adults over the age of 21.
Device Story
Black Diamond is a two-part liquid system for treating dentin hypersensitivity in adults. The device consists of two dropper bottles containing an aqueous silver fluoride solution and a stannous fluoride reducing agent. A clinician applies the liquids sequentially to the tooth surface using a standard flock tip applicator. The mechanism involves the deposition of silver into open dentinal tubules, which occludes the tubules, reduces hydraulic conductance, and alleviates sensitivity. The device is used in a dental office setting by a dentist or dental professional. It does not require light curing. The clinical benefit is the reduction of dentin hypersensitivity.
Clinical Evidence
Bench testing only. Evidence includes hydraulic conductance testing demonstrating efficacy in dentinal tubule occlusion compared to the predicate device. Scanning Electron Microscopy (SEM) images were provided to visualize tubule occlusion on treated dentin surfaces. Biocompatibility and ion elution testing were conducted per ISO 10993-1.
Technological Characteristics
Two-part liquid system; aqueous silver fluoride solution and stannous fluoride reducing agent. Mechanism: silver deposition for dentinal tubule occlusion. No light curing required. Biocompatibility assessed per ISO 10993-1; risk management per ISO 14971.
Indications for Use
Indicated for treatment of dental hypersensitivity in adults over age 21.
Regulatory Classification
Identification
Cavity varnish is a device that consists of a compound intended to coat a prepared cavity of a tooth before insertion of restorative materials. The device is intended to prevent penetration of restorative materials, such as amalgam, into the dentinal tissue.
Special Controls
*Classification.* Class II (special controls). The device, when it is an external cleaning solution, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 872.9.
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June 23, 2023
Elevate Oral Care, LLC % Steve Pardue Elevate Oral Care 346 Pike Road Suite 5 West Palm Beach, Florida 33411
Re: K222323
Trade/Device Name: Black Diamond Regulation Number: 21 CFR 872.3260 Regulation Name: Cavity Varnish Regulatory Class: Class II Product Code: PHR Dated: June 8, 2023 Received: June 8, 2023
Dear Steve Pardue:
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.
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
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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 mediation-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,
# Bobak Shirmohammadi -S
For Michael E. Adjodha, M. ChE., CQIA 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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### Indications for Use
510(k) Number (if known) K222323
Device Name Black Diamond
Indications for Use (Describe)
Black Diamond is intended as Treatment of Dental Hypersensitivity. For use in adults over the age of 21.
Type of Use (Select one or both, as applicable)
X Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for Elevate Oral Care. The logo consists of a blue globe-like icon on the left, followed by the word "elevate" in blue, and the words "ORAL CARE" in a smaller font size below it. The logo is simple and clean, with a focus on the company name and its connection to oral health.
### 510(k) Summary
#### Submitter:
346 Pike Road, Suite 5 · Vest Palm Beach, FL 33411 Phone: 877-866-9113 · Fax: 561-244-1927 www.elevateoralcare.com
## K22323
| Company: | Elevate Oral Care |
|------------------------|---------------------------------|
| Street: | 346 Pike Road, Suite 5 |
| City, State Zip: | West Palm Beach, FL 33411 |
| Country: | USA |
| Estab. Registration #: | 3009603151 |
| Correspondent: | Steve Pardue<br>Managing Member |
| Phone: | 877-866-9113 |
| Fax: | 561-244-1927 |
| Email: | spardue@elevateoralcare.com |
| Date: | October 26, 2022 |
#### Name of Device
| Proprietary Name: | Black Diamond™ |
|----------------------|------------------------------------------------------------------------------------------------------------|
| Classification Name: | Silver Fluoride Dental Hypersensitivity Varnish<br>21 CFR 872.3260 as Class II device<br>Product Code: PHR |
| Common Name: | Silver Fluoride Dental Hypersensitivity Varnish & Device |
#### Predicate Devices
| Primary Predicate Device | 510(k) |
|--------------------------|---------|
| Silver Dental Arrest | K102973 |
| | |
| Reference Device | |
| Riva Star | K172047 |
#### Description
Black Diamond is a two-part liquid intended as a treatment for dentin hypersensitivity, for use in adults over the age of 21. The product does not need light cured and will provide occlusion of dentinal tubules preventing or reducing dentin hypersensitivity.
The formula has two liquid steps, each provided in an individual dropper bottle. A drop of each product is placed in a mixing well/dappen dish and applied sequentially to the tooth using a standard flock tip applicator bush such as a microbrush. The mixing pad, and applicator may or
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may not be included in the product package. These are standard items in dental offices and numerous types of each will work.
#### Indications for Use
- . Black Diamond is a two-part liquid intended as a treatment for dentin hypersensitivity, for use in patients over the age of 21.
#### Comparison of the Intended Use of Black Diamond to the Predicate Device
| Black Diamond Indication for Use | Silver Dental Arrest |
|--------------------------------------------------------------------------------|--------------------------------------------------------------------------------|
| Treatment of Dental Hypersensitivity. For use<br>in adults over the age of 21. | Treatment of Dental Hypersensitivity. For use<br>in adults over the age of 21. |
#### Comparison of the Intended Use of Black Diamond to the Reference Device
| Black Diamond<br>Indication for Use | Riva Star |
|--------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------|
| Treatment of Dental<br>Hypersensitivity. For<br>use in adults over the<br>age of 21. | Treatment of Dental<br>Hypersensitivity.<br>For use in adults<br>over the age of 21. |
#### Technological Characteristics
Black Diamond has similar composition and claims as the predicate device Silver Dental Arrest and reference product Riva Star (product codes PHR). All three devices contain silver and fluoride as the main functioning ingredient.
Black Diamond uses an aqueous solution of silver fluoride, followed by a second solution of Stannous Fluoride, a reducing agent, that causes the deposition of silver into open dentinal tubules which in turns reduces sensitivity and hydraulic conductance. This same silver deposition process is used by the predicate device as well as the reference device, both in product code PHR.
Black Diamond has been commercially available in various countries for many years with a significant safe history of use as well as a published body of literature.
Application of Black Diamond is similar to both other products in product code PHR.
#### Summary of Physical Tests
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A hydraulic conductance test was completed showing the efficacy of Black Diamond in occlusion of dentinal tubules in comparison to the predicate device. Additionally, SEM images were taken of untreated dentin treated with the predicate and subject device to show dentin tubule occlusion, and no other effect on healthy dentin.
It was concluded that Black Diamond is substantially equivalent to the predicate device, and reference device, and is a two-part liquid intended as a treatment for dentin hypersensitivity for use in patients over the age of 21.
#### Description of Safety and Substantial Equivalence
The chemical components in Black Diamond have been used extensively in dental devices and have significant toxicological profiles and safety history. Biocompatibility and Risk assessments have been completed on the product, ingredients, and combination of ingredients. Ion elution tests have been successfully completed. These facts support the compatibility of Black Diamond, and the safety of the applicant device is substantially equivalent to the predicate devices in properties, intended use and composition.
Information provided in this submission confirms the substantial equivalence to the predicate devices with common indications, and indication from the reference predicate devices. The data provided in this 510(k) submission also shows that the composition is safe for its intended use based on the biocompatibility assessment and risk assessment conducted according to ISO 10993-1 and ISO 14971.
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.