(456 days)
Milex Wide-Seal Silicone Diaphragms, in conjunction with an approved spermicidal gel or cream are indicated for the prevention of pregnancy in women who elect to use diaphragms as a method of contraception.
The Milex Wide-Seal contraceptive diaphragm is a shallow cup with a flexing rim. The diaphragm is composed of silicone. The diaphragm is placed over the cervix and coated with spermicidal cream or gel to prevent pregnancy. The diagrams are offered in the following sizes: 60mm, 65mm, 70mm, 75mm, 80mm, 85mm, 90mm, 95mm. The diaphragms are offered in two styles: Omniflex (Flat or Coil Style that folds in one place only) and Arcing (Folds in any place to form an arc or bow for insertion).
Here's an analysis of the provided text regarding the acceptance criteria and study for the CooperSurgical Milex Wide-Seal Diaphragms:
Based on the provided 510(k) summary, the device is a contraceptive diaphragm. The submission asserts substantial equivalence to a predicate device, the Ortho McNeil Diaphragm.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria Category | Specific Criteria | Reported Device Performance | Comments |
|---|---|---|---|
| Substantial Equivalence | Comparison to Predicate Device (Ortho McNeil Diaphragm) in terms of intended use, technological characteristics, safety, and effectiveness. | The main difference is the material composition: the subject device uses silicone, while the predicate uses natural rubber. CooperSurgical believes the differences are minor and that the subject device is "as safe and effective as the predicate device." | This is a claim of equivalence rather than a direct measurement against a predefined numerical acceptance threshold for efficacy or safety. |
| Biocompatibility | General biocompatibility standards for medical devices. | "Subject device has been subjected to and passed a variety of biocompatibility tests." | No specific biological criteria or results are provided. |
| Cleaning Validation | Standards for ensuring adequate cleaning of a reusable device (if applicable) or ensuring manufacturing cleanliness. | "Subject device has been subjected to and passed... cleaning validation." | No specific cleaning validation criteria or results are provided. |
| Functional/Mechanical Testing | Relevant functional and mechanical properties for a contraceptive diaphragm (e.g., flexibility, durability, rim integrity, sizing accuracy). | "Subject device has been subjected to and passed... functional / mechanical testing." | No specific functional/mechanical criteria or results are provided. |
| Clinical Efficacy (Indirect) | Prevention of pregnancy "in conjunction with an approved spermicidal gel or cream." | The document implies efficacy by stating the device's intended use is pregnancy prevention and claiming substantial equivalence to a predicate device that has been on the market for a long time. It also mentions "Over 500,000 Milex silicone Diaphragms have been distributed since the device was introduced in 1962," suggesting real-world usage. | No specific clinical trial data or performance metrics (e.g., Pearl Index, typical use effectiveness) are presented in this 510(k) summary. The approval hinges on substantial equivalence to a pre-amendment device. |
2. Sample Size Used for the Test Set and Data Provenance
The provided 510(k) summary does not contain information about a specific test set or clinical study conducted for this submission with a defined sample size for efficacy or safety. The device's approval is based on substantial equivalence to a predicate device (Ortho McNeil Diaphragm) which was pre-amendment (meaning it was on the market prior to May 28, 1976, and did not undergo the same regulatory scrutiny as new devices). The document broadly mentions "Over 500,000 Milex silicone Diaphragms have been distributed since the device was introduced in 1962," but this refers to historical distribution rather than a controlled study's test set.
3. Number of Experts Used to Establish Ground Truth and Qualifications
Not Applicable. The submission does not describe a study involving human experts establishing ground truth for a test set.
4. Adjudication Method
Not Applicable. There is no described study or test set requiring an adjudication method.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not Applicable. This type of study is for evaluating observer performance (e.g., radiologists interpreting images) with and without AI assistance. The device in question is a physical contraceptive diaphragm, not an AI software.
6. Standalone (Algorithm Only) Performance Study
Not Applicable. This device is a physical product, not an algorithm.
7. Type of Ground Truth Used
The "ground truth" for the current 510(k) submission is historical market performance and regulatory status of the predicate device (Ortho McNeil Diaphragm), coupled with the assumption that the new device, due to its similar design and intended use (despite material changes), would perform equivalently. The predicate's long-standing use (since 1962) implicitly served as evidence of its general safety and effectiveness.
8. Sample Size for the Training Set
Not Applicable. As this is a physical medical device and not an AI/algorithmic device, there is no concept of a "training set" in the context of this 510(k) submission.
9. How Ground Truth for the Training Set Was Established
Not Applicable. (See #8)
Summary of the Study that Proves the Device Meets Acceptance Criteria:
The provided 510(k) summary does not describe a specific clinical study with a defined methodology, sample size, or measured performance endpoints for the Milex Wide-Seal Diaphragm to prove it meets acceptance criteria in the conventional sense.
Instead, the "study" that proves the device meets acceptance criteria is fundamentally a comparison to a legally marketed predicate device (Ortho McNeil Diaphragm) through the 510(k) substantial equivalence pathway.
The core argument for the device meeting the implicit acceptance criteria (safety and effectiveness) is:
- Substantial Equivalence: The subject device has the same intended use, similar technological characteristics, and (according to the manufacturer) is as safe and effective as the predicate device. The primary difference is material composition (silicone vs. natural rubber).
- Performance Data (Non-Clinical):
- Biocompatibility testing.
- Cleaning validation.
- Functional/mechanical testing.
- All these tests were "passed." (No specific results or criteria are provided in this summary).
- Historical Context: The statement that "Over 500,000 Milex silicone Diaphragms have been distributed since the device was introduced in 1962" suggests a history of real-world use for this type of device, which likely supported the safety argument.
In essence, the "proof" is based on non-clinical testing demonstrating the device's physical properties and biocompatibility, combined with the regulatory finding of substantial equivalence to a long-marketed predicate device. There is no mention of a prospective clinical trial, expert review of data, or comparative effectiveness study against specific efficacy metrics within this document.
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CooperSurgical
23
510 (k) Summary
JAN 23 2008
Date Prepared [21 CFR 807.92(a)(1)]
Revised January 18, 2008
Submitter's Information [21 CFR 807.92(a)(1)]
This 510(k) is being submitted by Joseph Azary (Regulatory / Quality Consultant) on behalf of CooperSurgical, Inc.
Contact Information:
Joseph Azary Telephone: (203) 944-9320 Facsimile: (203) 944-9317 543 Long Hill Avenue Shelton, CT 06484
Sponsor / Manufacturer: CooperSurgical, Inc. 95 Corporate Drive Trumbull, CT 06611.
FDA Registration:
CooperSurgical, Inc. is registered with FDA under Establishment Registration# 1216677.
Trade Name, Common Name, Classification [21 CFR 807.92(a)(2)]
Trade name: Wide-Seal Diaphragms including Omniflex Diaphragms and Arcing Diaphragms
Common / Classification Name: Contraceptive Diaphragm
Classification: Classification of this device would fall under the responsibility of the Division of Obstetrics and Gynecology. Class II, Product Code: HDW, 21 CFR 884.5350
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Predicate Device [21 CFR 807.92(a)(3)]
The following predicate device has been identified:
- . Ortho McNeil Diaphragm - Preamendment
The Milex Diaphragm has been on the market since 1962 prior to the FDA Medical Device Amendments. The U.S. Patent for the Milex Diaphragm is dated May 29, 1962.
The subject device is substantially equivalent to the predicate device. The main difference is the material composition. The Milex Wide-Seal Diaphragms are composed of Silicone and the Ortho Diaphragms are composed of Natural Rubber.
Description of the Device [21 CFR 807.92(a)(4)]
Summary of the Device / Operation / Characteristics
The Milex Wide-Seal contraceptive diaphragm is a shallow cup with a flexing rim. The diaphragm is composed of silicone.
The diaphragm is placed over the cervix and coated with spermicidal cream or gel to prevent pregnancy.
The diagrams are offered in the following sizes:
- 60mm .
- 65mm .
- 70mm .
- . 75mm
- . 80mm
- . 85mm
- 90mm .
- . 95mm
The diaphragms are offered in two styles:
- Omniflex (Flat or Coil Style that folds in one place only). ●
- . Arcing (Folds in any place to form an arc or bow for insertion)
Intended Use [21 CFR 807.92(a)(5)]
The subject device is intended to completely cover the cervix and used with spermicide to prevent pregnancy.
Technological Characteristics [21 CFR 807.92(a)(6)]
CooperSurgical Inc. believes that the subject device is substantially equivalent to the predicate device.
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Performance Data [21 CFR 807.92(b)(1)]
The subject device has been subjected to and passed a variety of biocompatibility tests, cleaning validation, and functional / mechanical testing. Over 500,000 Milex silicone Diaphragms have been distributed since the device was introduced in 1962.
Conclusion [21 CFR 807.92(b)(3)]
We believe the differences between the subject device and predicate device are minor and conclude that the subject devices are as safe and effective as the predicate devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular pattern around the symbol. The logo is black and white and appears to be slightly distressed.
Public Health Service
JAN 23 2008
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Mr. Thomas G. Williams Vice President, Regulatory Affairs and Business Assurance CooperSurgical, Inc. 95 Corporate Drive TRUMBULL CT 06611
K063223 Re:
Trade/Device Name: Milex Wide-Seal Contraceptive Diaphragm Regulation Number: 21 CFR §884.5350 Regulation Name: Contraceptive diaphragm and accessories Regulatory Class: II Product Code: HDW Dated: December 28, 2007 Received: January 2, 2008
Dear Mr. Williams:
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. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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 vour 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); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Center for Devices and Radiological Health's (CDRH's) Office of Compliance at one of the following numbers, based on the regulation number at the top of this letter.
| 21 CFR 876.xxxx | (Gastroenterology/Renal/Urology) | 240-276-0115 |
|---|---|---|
| 21 CFR 884.xxxx | (Obstetrics/Gynecology) | 240-276-0115 |
| 21 CFR 892.xxxx | (Radiology) | 240-276-0120 |
| Other | 240-276-0100 |
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrb/industry/support/index.html.
Sincerely vours.
Nancy C. Brogdon
Nancy C. Brogdon Director, Division of Reproductive. Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
KOG3223 510(k) Number (if known):
Device Name: Milex Wide-Seal Contraceptive Diaphragm
Indications For Use:
Milex Wide-Seal Silicone Diaphragms, in conjunction with an approved spermicidal gel or cream are indicated for the prevention of pregnancy in women who elect to use diaphragms as a method of contraception.
Prescription Use X (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Helen Reiner
(Division Sign-Off) Division of Reproductive, Abdominal and Radiological Devi 510(k) Number
Page 1 of 1
§ 884.5350 Contraceptive diaphragm and accessories.
(a)
Identification. A contraceptive diaphragm is a closely fitting membrane placed between the posterior aspect of the pubic bone and the posterior vaginal fornix. The device covers the cervix completely and is used with a spermicide to prevent pregnancy. This generic type of device may include an introducer.(b)
Classification. Class II (performance standards).