Validated Milling Center or Implant Companies not selling new products

brayks

brayks

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This is the laest way companies are obtaining 510(k) clearance for their implants and implant components-and its becoming a huge deal that I believe will only get bigger.

Under new FDA guidelines these companies obtain 510(k) clerance for their products as long as they only sell them in "closed manufacturing systems" where a "recepie" for porduction (which includes scanner, machine, materials, tooling, etc.) is followed. This is considered a PNP or Plug-n-Play scenaio.

The alternative is for the lab they are selling to, though (either directly or through distributor) has been certified by them (the implant company) as to producing quality, accurate abutments AND has in place a QMS (Quality Managemenet System) thereby assuring they are following GMP (Good Manufacturing Practices).

The FDA grants the implant company 510(k) cleaerance for their products under these conditions.

We are currently working with implant companies and labs to work under these conditions allowing sales for the implant companies and labs to be FDA compliant with minimum investment and worry-free (in terms of FDA compliance) fabrication of custom abuments.

We also work with evo820 who helps our clients set-up a QMS that enables compliance as it sets them up to be what the FDA considers a Certified Milling Center for an implant company whereby the can register as such with the FDA, buy the implant components, mill the abutments and sell them to their customers-all (implant company and lab) being FDA compliant.
 
Affinity

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I just bought 2 dess premills yesterday with no problem, nobody checking my 'clearance' .. or validating my equipment. The government operates with a fear factor to get people to do things, they dont have to actually enforce a law, or even have a law, they just have to make you worry that there COULD someday be a law..
 
Contraluz

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I just bought 2 dess premills yesterday with no problem, nobody checking my 'clearance' .. or validating my equipment. The government operates with a fear factor to get people to do things, they dont have to actually enforce a law, or even have a law, they just have to make you worry that there COULD someday be a law..
My understanding is that 'only' new registries are affected. I can get Keystone parts, all day long, except for their most recent products (Keystone is the company that does not sell me parts for their new line of implants/abutments, unless I get registered).
 
Affinity

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So if its a dess part, can you not get it from dess? What does registration involve? Let me guess, buying your equipment from a keystone authorized reseller?
 
Contraluz

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So if its a dess part, can you not get it from dess? What does registration involve? Let me guess, buying your equipment from a keystone authorized reseller?
I am referring to the FDA registration. Keystone is not involved in that, except they won't sell me parts form their new line.

I get my parts from Keystone directly. Client is involved with Keystone and would not use 3rd party parts. Also, Keystone is one of the companies you can not find knock-offs easily.
 
brayks

brayks

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So. Regarding buying keystone from distributors. It's likely (and rightly) they have the new PNP/NHA 510.(K) validation and as such can only sell to a certified band registred milling center which a distributor is not, hence direct sales to end users is the only way to stay right with the FDA.

Regarding registration, you first have to pay a fee then register. This website will provide information: https://userfees.fda.gov/OA_HTML/furls.jsp?legalsel=2&ref=

It's painful to navigate but doable.

Regarding DESS, our Versamill is considered part of the DESS PNP/Nha 510(k) validation. therefore our customers can utilize DESS premills and components, and since we are a distributor of DESS products, purchase them from Axsys Dental Solutions.

This means our users have a pathway to inhouse manufacturing without the FDA's oversight.

Our sales of DESS products is not just limited to Versamill machine owners.

We are also in the process of finalizing pricing and updating our website.

Since
 
brayks

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Update in this never-changing and always mind-boggling topic...
Under the new system, and this is the new beauty of the PNP/NHA system- labs do not need to register with the FDA. According to Tim Torbenson, CEO of FDA consultancy orginazation, evo820, we are returning to the normalcy of 2016, labs completely operating without any FDA oversight. No registrations, no audits, nothing in that regard. Labs can start legally milling Ti custom abutments tomorrow (components purchased through distributors) by using the "recipe" validated by DESS which includes our Versamill machines.
 
Affinity

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I wanted to rip my face off reading over those fda docs.. the initial fee is $7563 per year. They collected $350 million in fees in one year.
 
Contraluz

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Update in this never-changing and always mind-boggling topic...
Under the new system, and this is the new beauty of the PNP/NHA system- labs do not need to register with the FDA. According to Tim Torbenson, CEO of FDA consultancy orginazation, evo820, we are returning to the normalcy of 2016, labs completely operating without any FDA oversight. No registrations, no audits, nothing in that regard. Labs can start legally milling Ti custom abutments tomorrow (components purchased through distributors) by using the "recipe" validated by DESS which includes our Versamill machines.
Interesting...

Do you have a link, or so?

Thanks for the info/follow up!
 
brayks

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I'm not v sure what links you are looking for, detailed links are hard to find. Here are a few:
 
doug

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There was a thread on here awhile ago about all of this and Bennett Napier provided me with information that I posted. it should be on forum somewhere. People, Dess,(Keith),I'm looking at you, were bitching about TruAbutment. They met all the requirement the FDA laid out and it was posted. All of the sudden the room got quiet. Now someone has a problem with WHO?
 
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Update in this never-changing and always mind-boggling topic...
Under the new system, and this is the new beauty of the PNP/NHA system- labs do not need to register with the FDA. According to Tim Torbenson, CEO of FDA consultancy orginazation, evo820, we are returning to the normalcy of 2016, labs completely operating without any FDA oversight. No registrations, no audits, nothing in that regard. Labs can start legally milling Ti custom abutments tomorrow (components purchased through distributors) by using the "recipe" validated by DESS which includes our Versamill machines.

Is there a link to the FDA regulation you can provide?

It’s hard to take Tim on his word when I don’t know the guy…

There it still states that the dental lab needs to be registered with the FDA if working with implants/abutments/guides
 
brayks

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desertfox384

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Imagine that… another “fee” for nothing except just to be able to do business as usual. It seems the feds took all their plays from the bananos playbook.
 
Contraluz

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I'm not v sure what links you are looking for, detailed links are hard to find. Here are a few:
Thank you. I meant links to the FDA ruling, but I see it was followed up above.
 
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