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Overjet Charting Assist

Overjet, Inc • Radiology • 08/27/2024

510(k)IEC 62304 Class C§524B Cyber Device
FDA Summary PDF

Device Purpose

Overjet Charting Assist is a medical image processing system that aids dental professionals by automatically analyzing 2D radiographs (bitewing, periapical, panoramic) to detect natural tooth structures, numbering, and various restorative treatments for efficient dental charting. The system utilizes image analysis technology, likely machine learning, and uniquely incorporates a Predetermined Change Control Plan (PCCP) enabling iterative performance enhancements by reducing false positives/negatives through model retraining with real-world data, without altering its core intended use.

Summary

Overjet Charting Assist is a Medical Image Management and Processing System (MIMPS) designed to support dental professionals in creating dental charts. It functions by analyzing 2D dental radiographs—specifically bitewing (BW) and periapical (PA) images for patients aged 5 and above with primary and/or permanent teeth, and panoramic (Pano) radiographs for patients with only permanent teeth. The system automatically detects natural dental structures, including tooth anatomy like enamel and pulp, performs tooth numbering, and identifies dental structures from past restorative treatments such as implants, crowns, endodontic treatments, and fillings. The device serves as an assistive tool and is not intended to replace a clinician's comprehensive review or clinical judgment, which should consider all relevant patient information. The core technology relies on image analysis to interpret radiographs and extract relevant dental information. A key feature of this device is the inclusion of a Predetermined Change Control Plan (PCCP). This plan outlines a structured process for implementing modifications aimed at improving performance by reducing false positive and false negative outputs, based on post-market and real-world data which facilitates re-training of its machine learning model. The PCCP ensures modifications are applied manually and uniformly, with algorithms trained, tuned, and locked before release, rather than through continuous field learning. This PCCP is the primary difference from its predicate device (K233590), with other features, indications, and patient populations remaining unchanged, and existing performance data from K233590 considered applicable.

AI Regulatory Concerns

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Jev reads the full FDA letter and returns calibrated concern probabilities per regulatory category. These are AI estimates, not regulatory advice.

Keywords

Dental radiographyImage analysisMedical Image Management and Processing System (MIMPS)Dental chartingTooth anatomyRestorative treatmentsPredetermined Change Control Plan (PCCP)Machine Learning modelFalse positivesFalse negatives

Device Metadata

Submission Number
K241684
Company
Overjet, Inc
Panel
Radiology
Product Code
N/A
Data Type
Images
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. What specific machine learning algorithms are employed by Overjet Charting Assist for dental structure detection, and what were their documented performance metrics (e.g., sensitivity, specificity, accuracy) in the validation studies for the predicate device (K233590)?; How does the Predetermined Change Control Plan (PCCP) specifically define the quantitative thresholds for 'major drop in performance' that would prevent a proposed algorithm modification from being implemented?; What are the specific protocols for collecting, curating, and annotating the 'post-market and real-world data' used for re-training the ML model, particularly concerning data diversity and bias mitigation?; How will the updates to the 'Instructions for Use,' detailing algorithm changes and revised performance characteristics under the PCCP, be communicated to end-users, and what mechanisms are in place to ensure users understand these changes?; Beyond reducing false positives and negatives, does the current PCCP allow for the potential expansion of detectable dental conditions or features, or integration with new types of radiographic imaging modalities in future iterations?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Qualifies as a cyber device under §524B (post-Dec 2023, networked)

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score20/100
SBOM Evidence⚠ Not in summary - likely in full submission per §524B
Cyber Risk Assessment⚠ Not in summary - likely in full submission per §524B
Postmarket Plan✓ Detected in Summary
§524B ApplicableYes

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(machine learning, algorithm, retraining, bias)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials
- Not detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM detected in AI-generated device summary.

• SBOM not mentioned in AI-generated device summary. Under §524B (effective Oct 2023), cyber devices must provide a SBOM.

• Cybersecurity risk assessment not referenced in AI-generated device summary. FDA cybersecurity guidance (2023) expects this for cyber devices.

• Not detected in AI-generated device summary: SBOM, SaaSBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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Overjet Charting Assist - Overjet, Inc | ESL FDA AI Device Intelligence