MIS Lance+ Conical Connection Dental Implant System
Applicant
Dentsply Sirona
Product Code
DZE · Dental
Decision Date
Jun 17, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3640
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
MIS Dental Implant System is intended to be surgically placed in the bone of the upper and lower jaw arches to provide support for prosthetic device, such as artificial teeth, in order to restore masticatory function. When a one-stage surgical procedure is applied, the implant may be immediately loaded when stability is achieved and the occlusal load in appropriate. Narrow implants (03.3mm) are indicated for use in surgical and restorative applications for placement only in the mandibular central, lateral incisor and maxillary lateral incisor regions of partially edentulous jaws, to provide support for prosthetic devices such as artificial teeth. Mandibular central and lateral incisors must be splinted if using two or more narrow implants adjacent to one another.
Device Story
Endosseous dental implant system; cylindrical/conical threaded titanium alloy body; internal conical implant-abutment connection with anti-rotation index. Used by dental surgeons in clinical settings to anchor prosthetic tooth replacements. Inputs: surgical site in jaw bone. Operation: implant surgically placed; supports various conical connection abutments (cover screws, healing caps, cement/screw-retained abutments). Output: stable foundation for dental prosthetics. Benefits: restores masticatory function. Provided in dry or wet (NaCl solution) packaging; sterilized via radiation.
Clinical Evidence
No clinical data included. Substantial equivalence supported by bench testing: fatigue testing per ISO 14801:2016 (5,000,000 cycles), sterilization validation per ANSI/AAMI/ISO 11137, shelf-life/package integrity testing per ISO 11607-1 and ASTM F1980, and endotoxin testing per USP 85/161.
Technological Characteristics
Material: Ti-6Al-4V ELI (ASTM F136). Design: Tapered, threaded, bone-level implant with domed apex. Connection: Conical with 12° angulation and anti-rotation index. Surface: Sand-blasted, acid-etched, and anodized (dry) or sand-blasted/acid-etched (wet). Sterilization: Radiation. Shelf-life: 5 years (dry), 2 years (wet).
Indications for Use
Indicated for patients requiring dental implants in upper/lower jaw arches to support prosthetic devices (artificial teeth) and restore masticatory function. Narrow implants (3.3mm) restricted to mandibular central/lateral incisors and maxillary lateral incisors in partially edentulous jaws; requires splinting for adjacent mandibular incisors. Contraindicated for patients where immediate loading is not appropriate or stability cannot be achieved.
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
MIS Lance+ Internal Hex Dental Implant System (K192149)
Reference Devices
MIS C1 Conical Connection Dental Implant System (K172505)
MIS C1 Conical Connection Dental Implant System (K112162)
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Dentsply Sirona Rebecca Sporer Regulatory Affairs Specialist 221 West Philadelphia Street, Suite 60W York, Pennsylvania 17401
Re: K210886
Trade/Device Name: MIS Lance+ Conical Connection Dental Implant System Regulation Number: 21 CFR 872.3640 Regulation Name: Endosseous Dental Implant Regulatory Class: Class II Product Code: DZE Dated: March 24, 2021 Received: March 25, 2021
Dear Rebecca Sporer:
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.
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 Ouality 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) K210886
Device Name
MIS Lance+ Conical Connection Dental Implant System
#### Indications for Use (Describe)
MIS Dental Implant System is intended to be surgically placed in the bone of the upper and lower jaw arches to provide support for prosthetic device, such as artificial teeth, in order to restore masticatory function. When a one-stage surgical procedure is applied, the implant may be immediately loaded when stability is achieved and the occlusal load in appropriate.
Narrow implants (03.3mm) are indicated for use in surgical and restorative applications for placement only in the mandibular central, lateral incisor and maxillary lateral incisor regions of partially edentulous jaws, to provide support for prosthetic devices such as artificial teeth. Mandibular central and lateral incisors must be splinted if using two or more narrow implants adjacent to one another.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401
Image /page/3/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized leaf-like shape on the left, followed by the text "Dentsply" on the top line and "Sirona" on the bottom line. The text and the leaf are in a gray color.
# 510(k) SUMMARY K210886
### 1.0 Submitter Information:
Dentsply Sirona Inc. 221 West Philadelphia Street Suite 60W York, PA 17401
| Contact Person: | Rebecca Sporer |
|-------------------|-------------------------------|
| Title: | Regulatory Affairs Specialist |
| Telephone Number: | 717-849-4793 |
| Fax Number: | 717-849-4343 |
| Date Prepared: | 17 June 2021 |
## 2.0 Device Name
- Proprietary Name: MIS Lance+ Conical Connection Dental Implant System
- Endosseous dental implant Classification Name: ●
- . CFR Number: 872.3640
- . Device Class: Class II
- Product Code: DZE
## 3.0 Predicate Device
The predicate and reference device that have been identified relating to the substantial equivalence of the proposed MIS Lance+ Conical Connection Implants entailing a modification of the MIS Lance+ Internal Hex Dental Implant System (K192149) with the conical connection of the MIS C1 Conical Connection Dental Implant System (K172505 for C1 Narrow platform implants and K112162 for C1 standard and wide platform implants). The proposed MIS Lance+ Conical Connection Implants will be offered as well in a wet packaging like the MIS implants cleared under MIS CLEAR Dental Implant System (K200102).
| Predicate Device Name | 510(k) | Company Name |
|----------------------------------------------------------------------------------------------------------------------------|---------|-----------------------------------------------------|
| MIS Dental Implant System<br>(MIS Lance+ Internal Hex Dental Implant System) | K192149 | MIS Implants Technologies Ltd.<br>(Dentsply Sirona) |
| Reference Device Name | 510(k) | Company Name |
| MIS C1 Narrow Platform Conical Connection<br>Dental Implant System<br>(MIS C1 Conical Connection Dental Implant<br>System) | K172505 | MIS Implants Technologies Ltd.<br>(Dentsply Sirona) |
| MIS C1 Conical Connection Dental Implant<br>System – Standard and wide platforms | K112162 | MIS Implants Technologies Ltd.<br>(Dentsply Sirona) |
| MIS CLEAR Dental Implant System | K200102 | MIS Implants Technologies Ltd.<br>(Dentsply Sirona) |
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Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401
Image /page/4/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized leaf-like shape in gray on the left, followed by the words "Dentsply" and "Sirona" stacked on top of each other in gray. The font is sans-serif and modern, and the overall design is clean and professional.
### 4.0 Device Description
The proposed MIS Lance+ Conical Connection Implant are dental implants with a cvlindrical and conical shaped outer profile. The implants have an internal conical implant-abutment connection geometry with an anti-rotation index of six positions for standard and wide platforms and four positions for narrow platform. The conical implant-abutment connection is identical to the internal conical connection geometry incorporated in the design of the reference device MIS C1 Conical Connection Implants (K172505). The implant abutment connection surface of the MIS Lance+ Conical Connection Implant is anodized for coloring coding purposes to indicate the platform. The color coding is identical to the reference devices MIS C1 Conical Connection Implant System (K172505).
The MIS Lance+ Conical Connection Implants are intended to be used in combination with a variety of conical connection abutments (cover screws, healing caps, cement-retained abutments and screwretained abutments, which were previously cleared for use with the MIS C1 Conical Connection Dental Implant System (K172505 for NP abutments and K112162 for SP and WP abutments). These abutments are manufactured with a conical connection compatible with the implants interface. Dental implant abutments are intended to be used in the upper or lower jaw used for supporting tooth replacements to restore chewing function. The abutments in combination with two-stage endosseous implants are intended to be used as a foundation for anchoring tooth replacements in either jaw. Restorations range from replacing one single tooth to fixed partial dentures using cementretained supra-constructions. No new Abutments are being proposed as part of this submission.
In addition, the proposed MIS Lance+ Conical Connection Implants will be provided in a wet package configuration immersed in NaCl solution as cleared under K200102 and branded as "CLEAR". The MIS CLEAR Lance+ Conical Connection Implants which are intended to be packaged in NaCl solution are not anodized.
### 5.0 Indication for Use
MIS Dental Implant System is intended to be surgically placed in the bone of the upper and lower jaw arches to provide support for prosthetic device, such as artificial teeth, in order to restore masticatory function. When a one-stage surgical procedure is applied, the implant may be immediately loaded when good primary stability is achieved and the occlusal load in appropriate.
Narrow implants (03.3mm) are indicated for use in surgical and restorative applications for placement only in the mandibular central, lateral incisor and maxillary lateral incisor regions of partially edentulous jaws, to provide support for prosthetic devices such as artificial teeth. Mandibular central and lateral incisors must be splinted if using two or more narrow implants adjacent to one another.
#### 6.0 Substantial Equivalence Discussion
For the purposes of substantial equivalence, the proposed MIS Lance+ Conical Connection Implants are compared to the predicate device MIS Lance + Internal Hex Implant System (K192149) with the reference device MIS C1 Conical Connection Dental Implant System (K172505) included in support of substantial equivalence. The proposed MIS Lance+ Conical Connection Implant System does not include short implants; this is noted in the difference in indications for use as seen in Table 6.1. The comparison table below (Tables 6.1 and 6.2) summarizes the proposed implants to the predicate devices with respect to indications for use, technological characteristics, materials and performance testing to demonstrate that the data provided for the proposed implants supports equivalence to the predicate device.
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Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401
Image /page/5/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized, abstract shape on the left, resembling a curved leaf or wave. To the right of the shape are the words "Dentsply" stacked on top of "Sirona", both in a sans-serif font. The logo is presented in a grayscale color scheme.
| Table 6.1 - Indication for Use Comparison | | |
|-------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | Subject Device<br>MIS Lance+ Conical Connection Implant System | |
| | Predicate Device<br>MIS Lance+ Internal Hex Dental Implant System<br>(K192149) | |
| Indication for Use | MIS Dental Implant System is intended to be surgically placed in the bone<br>of the upper and lower jaw arches to provide support for prosthetic device,<br>such as artificial teeth, in order to restore masticatory function. When a<br>one-stage surgical procedure is applied, the implant may be immediately<br>loaded when good primary stability is achieved and the occlusal load in<br>appropriate.<br><br>Narrow implants (Ø3.3mm) are indicated for use in surgical and<br>restorative applications for placement only in the mandibular central,<br>lateral incisor and maxillary lateral incisor regions of partially edentulous<br>jaws, to provide support for prosthetic devices such as artificial teeth.<br>Mandibular central and lateral incisors must be splinted if using two or<br>more narrow implants adjacent to one another. | MIS Dental Implant System is intended to be surgically placed in the<br>bone of the upper and lower jaw arches to provide support for prosthetic<br>device, such as artificial teeth, in order to restore masticatory function.<br>When a one-stage surgical procedure is applied, the implant may be<br>immediately loaded when good primary stability is achieved and the<br>occlusal load in appropriate.<br><br>Narrow implants (Ø3.3mm) are indicated for use in surgical and<br>restorative applications for placement only in the mandibular central,<br>lateral incisor and maxillary lateral incisor regions of partially edentulous<br>jaws, to provide support for prosthetic devices such as artificial teeth.<br>Mandibular central and lateral incisors must be splinted if using two or<br>more narrow implants adjacent to one another.<br><br>MIS short implants are to be used only with straight abutments. |
{6}------------------------------------------------
Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401
Image /page/6/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized leaf-like shape on the left, followed by the words "Dentsply" on the top line and "Sirona" on the bottom line. The text is in a simple, sans-serif font and is a dark gray color. The logo is clean and modern, suggesting a company that is both innovative and reliable.
| Table 6.2 – Technological Characteristics comparison between the subject, predicate and reference Implant devices | | | | |
|-------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Trade<br>Name | Proposed Device<br>MIS Dental Implant System | Predicate Device<br>MIS Dental Implants<br>System (Lance +)<br>(K192149) | Reference Device<br>MIS C1 Conical Connection<br>Dental Implant System<br>(K172505) | Equivalence Comparison |
| Material | Ti-6Al-4V ELI per ASTM F136 | Ti-6Al-4V ELI per ASTM<br>F136 | Ti-6Al-4V ELI per ASTM F136 | No difference. |
| Surface<br>Treatment | For dry packaged Implants:<br>Anodized, sand blasted and acid<br>etched<br>For wet packaged Implants:<br>Sand blasted and acid etched | Sand blasted and acid etched | Anodized, sand blasted and acid<br>etched<br>For wet packaged Implants:<br>Sand blasted and acid etched | The proposed Implants which will be packed in NaCL solution will<br>have the same surface treatment as the predicate device. The<br>implants packed in Air ("dry") has the same surface treatment as the<br>predicate device but the internal part of the implant will be anodized<br>like the reference device. |
| Connection<br>Type | Conical with Index<br>Cone angulation 12° | Internal hexagon | Conical with Index<br>Cone angulation 12° | The aim of the modification of the Lance+ Implant to a conical<br>connection is based on the connection type of the C1 Implant. |
| Body<br>Design | Tapered, conical shape, threaded | Tapered, conical shape,<br>threaded | Tapered, threaded | No difference. Only change on Implant Abutment connection from<br>internal hexagon to conical with index. |
| Apex | Domed apex | Domed apex | Domed apex | No difference |
| Thread | Triple | Triple | Dual | No difference. Only change on Implant Abutment connection from<br>internal hexagon to conical connection with index. |
| Type of<br>Implant | Bone level implant | Bone level implant | Bone level implant | No difference |
| Implant<br>Platform | Standard Platform (SP), Wide<br>Platform<br>(WP), Narrow Platform (NP) | SP, WP, NP | SP, WP, NP | No difference |
| Implant<br>Diameters | SP: Ø 3.75 mm, 4.20 mm,<br>WP: Ø 5.00 mm<br>NP: Ø 3.30 mm | SP: Ø 3.75 mm, 4.20 mm,<br>WP: Ø 5.00 mm, 6.00 mm<br>NP: Ø 3.30 mm | SP: Ø 3.75 mm, 4.20 mm,<br>WP: Ø 5.00 mm.<br>NP: Ø 3.30 mm | The new proposed implants will not like the predicate device the<br>Implant Diameter of 6.00 mm since the prosthetic from C1 which is<br>intended to be used do not support that size. |
| Implant<br>Lengths | SP, WP: 8, 10, 11.5, 13, 16 mm<br>NP: 10, 11.5, 13, 16 mm | 8, 10, 11.5, 13, 16 mm | 8, 10, 11.5, 13, 16 mm | No difference |
{7}------------------------------------------------
Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401
Image /page/7/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized, abstract shape on the left, resembling a leaf or a curved shape in gray. To the right of the shape are the words "Dentsply" stacked on top of "Sirona", both in a sans-serif font and in gray color. The overall design is clean and modern.
| Table 6.2 - Technological Characteristics comparison between the subject, predicate and reference Implant devices | | | | |
|-------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------|
| Trade<br>Name | Proposed Device<br>MIS Dental Implant System | Predicate Device<br>MIS Dental Implants<br>System (Lance +)<br>(K192149) | Reference Device<br>MIS C1 Conical Connection<br>Dental Implant System<br>(K172505) | Equivalence Comparison |
| Inner<br>Package<br>Medium | Air or NaCL solution | Air or NaCL solution | Air or NaCL solution | No difference. The wet packaging branded as CLEAR is cleared<br>under K200102 |
| Sterilization<br>Method | Radiation | Radiation | Radiation | No difference |
| Shelf Life | For dry packaged Implants: 5<br>years<br>For wet packaged CLEAR<br>Implants (K200102):<br>2 years | For dry packaged Implants:<br>5 years<br>For wet packaged CLEAR<br>Implants (K200102):<br>1 year | Dry packaged Implants: 5 years | The extended shelf-life for the CLEAR packaging was validated with<br>performance testing. |
{8}------------------------------------------------
Dentsply Sirona 221 West Philadelphia Street Suite 60W York, PA 17401
Image /page/8/Picture/1 description: The image shows the logo for Dentsply Sirona. The logo consists of a stylized, abstract shape on the left, resembling a leaf or a curved form in gray. To the right of the shape are the words "Dentsply" on the top line and "Sirona" on the bottom line, both in a sans-serif font and also in gray.
### 7.0 Non-Clinical Performance Data
As part of demonstrating the substantial equivalence of the proposed MIS Lance+ Conical Connection Implant System to the predicate and reference devices, MIS Implants Technologies completed a number of non-clinical performance tests:
- -Fatigue Testing - Comparative mechanical testing of the proposed MIS Lance+ Conical Connection Implants and MIS C1 Conical Connection Implants in accordance to ISO 14801:2016 was conducted and demonstrated the subject implants do not create a new worstcase as compared to this predicate device with identical connection platform. The test articles were able to withstand 5,000,000 cycles without failure at a substantially equivalent load to the cited predicate and reference device.
- -Biocompatibility Testing- The proposed MIS Lance+ Conical Connection Implants are made from the same material, and undergo the same surface treatments: acid-etching, sand blasting and anodizing. They are manufactured under the same processing conditions and at the same manufacturing location as the predicate device, MIS Lance+ Internal Hex Dental Implant (K192149) and for the MIS CLEAR Implants (K200102). Therefore, no further biocompatibility testing was conducted in support of substantial equivalence.
- -Sterilization Testing -Sterilization validation tests were conducted on each group of packaging type (dry and wet) products in compliance with both ANSVAAMI/ISO 11137-1 and ANSI/AAMI/ISO 11137-2. Test results have demonstrated that the SAL of 106 was achieved and all testing requirements weremet.
- -Shelf Life Testing – for the products which are supplied sterile, shelf life studies were completed by an independent testing laboratory. In in order to validate the integrity of the final package, the studies were conducted in accordance with ISO 11607-1. Dry packaged implants utilized real-time aging for 5 years per ISO 11607-1:2019 and ASTM F1929-15. Wet packaged implants utilized accelerated aging simulating two years per ASTM F1980 to demonstrate a two-year shelf-life for both package integrity (sterile barrier). Device performance (hydrophilicity) Device performance (hydrophilicity) was demonstrated with accelerated aging testing similar to the reference device K200102.
- -For products supplied sterile, a LAL test is conducted periodically to verify the endotoxin limit is within acceptance criteria according to USP 85, USP 161 and ANSI/AAMI/ST72.
### 8.0 Clinical Performance Data
No human clinical data were included to support substantial equivalence.
### 9.0 Conclusion Regarding Substantial Equivalence
The proposed MIS Lance+ conical connection implants have the same intended use, incorporate the same fundamental technology, and have the same indications for use as the predicate and reference devices. The results of the testing support a determination of substantial equivalence.
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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.