K Number
K093320
Device Name
DRYODINE CADEXOMER-IODINE GEL
Date Cleared
2010-06-18

(238 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Dryodine™ Antibacterial Gel is indicated for use in the management/cleaning of wet ulcers and wounds such as venous stasis ulcers, pressure sores, diabetic foot ulcers, and traumatic and surgical wounds. Dryodine™ Antibacterial Gel assists to keep lesions soft and pliable.
Device Description
Dryodine™ Antibacterial Gel consists of 0.1mm diameter biodegradable hydrophilic beads of cadexomer dispersed in a hydrophilic gel comprised of polyethylene glycol and poloxamer and contains 0.9% by weight iodine. The device is presented as a prescription product that requiring a physician to diagnosis the disease state and prescribe the product.
More Information

Not Found

No
The device description and intended use are for a topical antibacterial gel, with no mention of AI or ML technology.

Yes
The device is intended for use in the management/cleaning of ulcers and wounds, which are therapeutic applications. It also assists in keeping lesions soft and pliable, contributing to the healing process.

No

Explanation: The device is an antibacterial gel for wound management, not for diagnosing disease states. The text explicitly states it's a "prescription product that requiring a physician to diagnosis the disease state and prescribe the product," indicating it's a treatment, not a diagnostic tool.

No

The device description clearly states it is a gel comprised of physical components (beads, gel, iodine), indicating it is a physical medical device, not software.

Based on the provided information, Dryodine™ Antibacterial Gel is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the management and cleaning of wounds and ulcers on the human body. This is a therapeutic application, not a diagnostic one.
  • Device Description: The description details a gel with antibacterial properties applied topically to wounds. It does not describe a test or assay performed on a sample taken from the body (like blood, urine, or tissue) to diagnose a condition.
  • Performance Studies: The performance studies mentioned are "in vitro effectiveness tests," which likely refer to testing the antibacterial properties of the gel against microorganisms in a lab setting, not diagnostic performance on patient samples.
  • Lack of Diagnostic Elements: There is no mention of analyzing biological samples, detecting biomarkers, or providing information for diagnosis.

IVDs are devices used to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. Dryodine™ Antibacterial Gel's function is to treat and manage existing wounds, not to diagnose a condition.

N/A

Intended Use / Indications for Use

Dryodine™ Antibacterial Gel is indicated for use in the management/cleaning of wet ulcers and wounds such as venous stasis ulcers, pressure sores, diabetic foot ulcers, and traumatic and surgical wounds. Dryodine™ Antibacterial Gel assists to keep lesions soft and pliable.

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

FRO

Device Description

Dryodine™ Antibacterial Gel consists of 0.1mm diameter biodegradable hydrophilic beads of cadexomer dispersed in a hydrophilic gel comprised of polyethylene glycol and poloxamer and contains 0.9% by weight iodine. The device is presented as a prescription product that requiring a physician to diagnosis the disease state and prescribe the product.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

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)

In vitro effectiveness tests were conducted on Dryodine™ Antibacterial Gel.

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.

K905069, K051452

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

510 (k) Premarket Notification CONFIDENTIAL

JUN 1 8 2010

SECTION 9

ﺍﻟﺘﻮ

SUBSECTION 9.5

APPENDICES

510(k) Summary of Safety and Effectiveness

તે જે રે 510(k) Summary of Safety and Effectiveness

Collegium Pharmaceutical, Incorporated Dryodine™ Antibacterial Gel October 22, 2009

9.5.1 Sponsor Name

Collegium Pharmaceutical, Incorporated 400 Highland Corporate Drive Cumberland, RI 02864

Contact Individual: Mark W. Trumbore, Ph.D. Director, Product Research & Development Collegium Pharmaceutical, Inc. 401-762-2000 X17 401-762-2043 (fax) mtrumbore@collegiumpharma.com

9.5.2 Device Name

Proprietary Name: Dryodine™ Antibacterial Gel Common/Usual Name: Wound Dressing

Identification of Predicate or Legally Marketed Device 9.5.3

Dryodine™ Antibacterial Gel is substantially equivalent to the following predicate devices:

  • Iodosorb Gel cleared under 510(k) K905069, from Perstorp Pharma. o
  • Triosyn T40 Antimicrobial Dressing under 510(k) K051452, from Triosyn O Corporation

9.5.4 Device Description

Dryodine™ Antibacterial Gel consists of 0.1mm diameter biodegradable hydrophilic beads of cadexomer dispersed in a hydrophilic gel comprised of polyethylene glycol and poloxamer and contains 0.9% by weight iodine. The device is presented as a prescription product that requiring a physician to diagnosis the disease state and prescribe the product.


1

09 3320
page 2 of 2

Dryodine™ Antibacterial Gel

510 (k) Premarket Notification CONFIDENTIAL

SECTION 9

SUBSECTION 9.6

APPENDICES

510(k) Summary of Safety and Effectiveness

9.5.5 Intended Use

Dryodine™ Antibacterial Gel is indicated for use in the management/cleaning of wet Dryounds - Innouvids such as venous stasis ulcers, pressure sores, diabetic foot ulcers, and traumatic and surgical wounds. Dryodine™ Antibacterial Gel assists to keep lesions soft and pliable.

Comparison of Technological Characteristics 9.5.6

Both the proposed Dryodine™ Antibacterial Gel and the predicate device Iodosorb Gel Donsist of 0.1mm diameter biodegradable hydrophilic beads of cadexomer dispersed in a bydrophilic Gel comprised of polyethylene glycol and poloxamer and contain 0.9% by weight iodine. Both the proposed and predicate devices are designed to be highly absorbent while providing a moist wound healing environment.

Performance Testing 9.5.7

In vitro effectiveness tests were conducted on Dryodine™ Antibacterial Gel.

9.5.8 Statement of Equivalency

Dryodine™ Antibacterial Gel is substantially equivalent in design, materials, construction and intended use to that of the predicate devices. The principal of operation of Dryodine™ Antibacterial Gel and the predicate devices is exactly the same. Since of Dryodine™ Antibacterial Gel has the same intended use and technological characteristics Di yound - Antouvererial Gel mas Antibacterial Gel does not raise any new safety and efficacy concerns when compared to the similar legally marketed devices. Testing and labeling demonstrate that Dryodine™ Antibacterial Gel is substantially equivalent to the predicate devices and is capable of safely and accurately performing the stated intended use.

2

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle with three stripes forming its wing, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circle around the eagle. The text is in all caps and appears to be in a sans-serif font. The logo is black and white.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -W066-G609 Silver Spring, MD 20993-0002

JUN 1 8 2010

Collegium Pharmaceutical Inc. % Mark W. Trumbore, Ph.D. Director, Product Research & Development 400 Highland Corporate Drive ... Cumberland, Rhode Island 02864

Re: K093320

Trade/Device Name: Dryodine™ Antibacterial Gel Regulatory Class: Unclassified Product Code: FRO Dated: May 14, 2010 Received: May 17, 2010

Dear Dr. Trumbore:

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. 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.

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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set

3

Page 2 - Mark W. Trumbore, Ph.D.

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.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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 (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Mark N. Melkerson

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

Enclosure

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Page 1 of 1

Dryodine™ Antibacterial Gel

510 (k) Premarket Notification CONFIDENTIAL

SECTION 1

SUBSECTION 1.8

GENERAL INFORMATION

Statement of Indications for Use

1.7 Statement of Indications for Use

510(k) Number (if known): K093320

Device Name: Dryodine™ Antibacterial Gel

Indications For Use:

Dryodine™ Antibacterial Gel is indicated for use in the management/cleaning of wet ulcers and wounds such as venous stasis ulcers, pressure sores, diabetic foot ulcers, and traumatic and surgical wounds. Dryodine™ Antibacterial Gel assists to keep lesions soft and pliable.

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)

Daniel Krenz for MXM
(Division Sign-Off)

Division of Surgical, Orthopedic, and Restorative Devices

510(k) Number K093320