K Number
K050158
Device Name
SINCLAIR SEBORRHEA EMULSION
Date Cleared
2006-10-11

(624 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
FOR TOPICAL DERMATOLOGICAL USE ONLY Description Rx Product: Under the supervision of a healthcare professional, Sinclair Skin Emulsion is indicated to manage and relieve the signs and symptoms of seborrhea and seborrheic dermatitis such as itching, erythema, scaling and pain. Sinclair Skin Emulsion helps to relieve dry waxy skin by maintaining a moist wound & skin environment, which is beneficial to the healing process. Description OTC Product: Sinclair Skin Emulsion helps to nourish skin and relieve the burning and itching associated with many common types of skin irritation and wounds.
Device Description
Sinclair Skin Emulsion is a non sterile viscous emulsion / gel formulation, which is presented for both Prescription (requires physician diagnosis of disease state) and over- the-counter (OTC) use.
More Information

Not Found

No
The 510(k) summary describes a topical skin emulsion and does not mention any AI or ML components, image processing, or data training/testing.

Yes
The product is indicated to "manage and relieve the signs and symptoms of seborrhea and seborrheic dermatitis such as itching, erythema, scaling and pain" and "helps to relieve dry waxy skin by maintaining a moist wound & skin environment, which is beneficial to the healing process." These claims indicate a therapeutic purpose.

No

The device description indicates that Sinclair Skin Emulsion is used to manage and relieve symptoms, and it helps nourish skin and relieve irritation. It is a treatment product, not designed to diagnose conditions. The RX product requires a physician's diagnosis, implying the diagnosis occurs prior to the use of this product.

No

The device description clearly states it is a "non sterile viscous emulsion / gel formulation," indicating it is a physical product, not software.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for "TOPICAL DERMATOLOGICAL USE ONLY" to manage and relieve symptoms of skin conditions like seborrhea and seborrheic dermatitis. This is a topical application to the skin, not a test performed on samples taken from the body (like blood, urine, or tissue).
  • Device Description: It's described as a "viscous emulsion / gel formulation" applied to the skin.
  • Lack of Diagnostic Function: The description focuses on symptom relief and maintaining a moist skin environment, not on diagnosing a disease or condition based on in vitro analysis.
  • Anatomical Site: The anatomical site is "Skin," which is an external application site, not an internal sample source for in vitro testing.

IVD devices are used to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. This device does not fit that description.

N/A

Intended Use / Indications for Use

FOR TOPICAL DERMATOLOGICAL USE ONLY
Description Rx Product:
Under the supervision of a healthcare professional, Sinclair Skin Emulsion
is indicated to manage and relieve the signs and symptoms of seborrhea and
seborrheic dermatitis such as itching, erythema, scaling and pain. Sinclair
Skin Emulsion helps to relieve dry waxy skin by maintaining a moist wound
& skin environment, which is beneficial to the healing process.
Directions For Use (Rx and OTC):
Apply Sinclair Skin Emulsion to the affected skin areas 3 times per day (or
as needed), and massage gently into the skin. If the skin is broken, cover
Sinclair Skin Emulsion with a dressing of choice.
Description OTC Product:
Sinclair Skin Emulsion helps to nourish skin and relieve the burning and
itching associated with many common types of skin irritation and wounds.

Product codes (comma separated list FDA assigned to the subject device)

FRO, MGQ

Device Description

Sinclair Skin Emulsion is a non sterile viscous emulsion / gel formulation, which is presented for both Prescription (requires physician diagnosis of disease state) and over-the-counter (OTC) use.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Skin

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Prescriber: healthcare professional
OTC User: Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Functional and performance testing has been conducted to assess the safety and effectiveness of SINCLAIR SKIN EMULSION ™ and all results are satisfactory.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K024367

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

N/A

0

KOSO 128

Attachment 6

CONFIDENTIAL

March 5, 2004OCT 11 2006
1. Submission Applicant & Correspondent:
Name:Sinclair Pharmaceuticals, Ltd.
Address:Borough Road
Godalming
Surrey
GU7 2AB
United Kingdom
Phone No.:1-972-478-4380
Contact Person:Michael Killeen
2. Name of Device:SINCLAIR SKIN EMULSION
Common or Usual Name:Dressing, Wound & Burn, Hydrogel w/Drug or Biologic
Classification Names:Dressing, Wound & Burn, Hydrogel w/Drug or Biologic
3. Devices to Which New Device is Substantially Equivalent:
Sinclair Wound and Skin Emulsion 510(k) K024367
  1. Device Description:

Sinclair Skin Emulsion is a non sterile viscous emulsion / gel formulation, which is
presented for both Prescription (requires physician diagnosis of disease state) and over-
the-counter (OTC) use.

  1. Intended Use of the Device:

The prescription product requires a physician to diagnose the disease state, while the
OTC product is indicated for general symptoms such as burning and itching in minor
skin irritations and minor burns. This formulation, when applied to the burn, injured
tissue or skin, forms a protective barrier that helps to keep the wound moist.

  1. Summary of Technological Characteristics of the Device Compared to the Predicate
    Devices:

Products referenced are non sterile emulsion/gel types that are applied topically to relieve
the symptoms of certain dermatoses.

  1. Tests and Conclusions:

Functional and performance testing has been conducted to assess the safety and
effectiveness of SINCLAIR SKIN EMULSION ™ and all results are satisfactory.

1

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/1/Picture/1 description: The image shows the seal for the Department of Health & Human Services. The seal is circular with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the edge. In the center of the seal is an abstract image of an eagle.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

OCT I 1 2006

Sinclair Pharmaceuticals Limited % Mr. Michael Killeen Executive Vice President North America Borough Road Godalming Surrey GU7 2AB United Kingdom

Re: K050158

Trade/Device Name: SINCLAIR SKIN EMULSION™ Regulatory Class: Unclassified Product Code: FRO, MGQ Dated: July 27, 2006 Received: July 28, 2006

Dear Mr. Killeen:

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 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 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

2

Page 2 - Mr. Michael Killeen

forth in the quality systems (QS) 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 Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). 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/cdrh/industry/support/index.html.

Sincerely yours,

M. 1 N. M. 11

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

3

Attachment 3 - Indications for Use Statement
510(k) Number050158
Device NameSINCLAIR SKIN EMULSION TM
Indications for UseFOR TOPICAL DERMATOLOGICAL USE ONLY
Description Rx Product:
Under the supervision of a healthcare professional, Sinclair Skin Emulsion
is indicated to manage and relieve the signs and symptoms of seborrhea and
seborrheic dermatitis such as itching, erythema, scaling and pain. Sinclair
Skin Emulsion helps to relieve dry waxy skin by maintaining a moist wound
& skin environment, which is beneficial to the healing process.
Directions For Use (Rx and OTC):
Apply Sinclair Skin Emulsion to the affected skin areas 3 times per day (or
as needed), and massage gently into the skin. If the skin is broken, cover
Sinclair Skin Emulsion with a dressing of choice.
Description OTC Product:
Sinclair Skin Emulsion helps to nourish skin and relieve the burning and
itching associated with many common types of skin irritation and wounds.
Prescription Use
(Part 21 CFR 801 Subpart D)✓ AND/OROver-The-Counter Use
(21 CFR 807 Subpart C)
PLEASE DO NOT WRITE BELOW THIS LINE- CONTINUE ON ANOTHER PAGE IF
NEEDED
Concurrence of CDRN, Office of Device Evaluation (ODE)
(Division Sign-Off)
Division of General, Restorative,
and Neurological Devices
510(k) Number14050158

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