(156 days)
Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses, when used as directed, cleans and removes protein deposits from fluorosilicone acrylate rigid gas permeable contact lenses.
Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses is the mixture of two sterile solutions, Progent A (active ingredient, sodium hypochlorite) and Progent B (active ingredient, potassium bromide). Progent A and B are mixed in a Menicon SP Vial. Allow lenses to soak in the Progent solution mixture for 30 minutes. Soaking for longer than 30 minutes is not recommended. The Progent treatment is recommended every two weeks. The frequency may vary according to the condition of your lens. Follow your eye care professional's directions (to a maximum of every 5 days).
The provided 510(k) summary for K122273 describes the Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses. This submission focuses on the equivalence of an alternative rinsing solution (sterile normal saline) to a previously cleared one (sterile purified water) and an alternative manufacturing site. Therefore, the study described is a non-clinical equivalence study rather than a study typically seen for novel diagnostic devices.
Here's an analysis based on the information provided:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Rinsing effectiveness of sterile normal saline (based on active chlorine concentrations and pH values) is equivalent to sterile purified water. | "A comparison of the two sets of data was completed and based on active chlorine concentrations and pH values it was confirmed that the rinsing efficacy of sterile normal saline was equal to the rinsing efficacy of the sterile purified water." |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size: The document does not explicitly state the numerical sample size (e.g., number of lenses or test runs) used for the "Residual Progent Testing." It only mentions that the test was "repeated with sterile normal saline."
- Data Provenance: The study was conducted by Menicon Co., Ltd. (Japan) as part of their 510(k) application. It is a non-clinical, bench-top study rather than a study involving human subjects or real-world data.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
This type of study does not involve human experts establishing ground truth in the traditional sense of medical image analysis or diagnostic studies. The "ground truth" here is objective chemical measurement in vitro.
4. Adjudication Method for the Test Set
Not applicable. This was a non-clinical, objective measurement study, not one requiring adjudication by human observers.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. This was a non-clinical bench study comparing rinsing efficacy of two solutions, not a study involving human readers or comparative effectiveness in a clinical setting.
6. If a Standalone Performance Study Was Done
Yes, in a sense. The "Residual Progent Testing" was done to evaluate the performance of the rinsing solutions in a controlled environment, independently measuring residual active chlorine concentration and pH. However, it's not a "standalone algorithm performance" in the context of AI/diagnostic devices, but rather a standalone test of a specific device function. The purpose was to show equivalence to a previously cleared product, so the performance was evaluated relative to the predicate.
7. The Type of Ground Truth Used
The ground truth was established by objective chemical measurements of active chlorine concentration and pH values in the rinsing solutions. This is an in vitro measurement, not expert consensus, pathology, or outcomes data.
8. The Sample Size for the Training Set
Not applicable. This is a non-clinical, bench-top study comparing two rinsing solutions. There is no machine learning component and therefore no "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable, as there is no training set mentioned or implied.
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510(k) Summary For K122273 MENICON PROGENT PROTEIN REMOVER FOR RIGID GAS PERMEABLE CONTACT LENSES
JAN 0 2 2013
:
November 30, 2012
1. Applicant Information
| Menicon Co., Ltd. | |
|---|---|
| 3-21-19, Aoi, | |
| Naka-ku, Nagoya 460-0006 | |
| JAPAN | |
| Contact Person: | Takahiro Ochi |
| Telephone No .: | +81-52-935-1676 |
| Fax No.: | +81-52-935-1633 |
| E-mail: | t-ochi@menicon-net.co.jp |
| Summary prepared on: | November 30, 2012 |
2. Device Information
| Classification name: | Rigid gas permeable contact lens care products |
|---|---|
| Device classification: | Class II |
| Regulation number: | 21 CFR 886.5918 |
| Product code: | MRC |
| Proprietary name: | Menicon Progent Protein Remover forRigid Gas Permeable Contact Lenses |
3. Predicate Devices
Menicon claims substantial equivalence to Menicon Progent Protein Remover for Rigid Gas Permeable Contact (RGP) Lenses previously cleared under K002140 and K082855.
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K12273 2/3
4. Description of device
Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses is the mixture of two sterile solutions, Progent A (active ingredient, sodium hypochlorite) and Progent B (active ingredient, potassium bromide). Progent A and B are mixed in a Menicon SP Vial. Allow lenses to soak in the Progent solution mixture for 30 minutes. Soaking for longer than 30 minutes is not recommended. The Progent treatment is recommended every two weeks. The frequency may vary according to the condition of your lens. Follow your eye care professional's directions (to a maximum of every 5 days).
5. Indications for use
Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses, when used as directed, cleans and removes protein deposits from fluorosilicone acrylate RGP contact lenses.
6. Substantial equivalence
The claim of substantial equivalence to the previously cleared Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses is based on the fact that the active components of the protein remover system (Progent Solution A and Progent Solution B) are the same formulation as the predicate devices. The only change is the addition of an alternative rinsing solution, sterile normal saline, versus sterile purified water cleared in 510(k) K082855..
In support of this application, nonclinical testing (Residual Progent Testing) was done to prove that the rinsing effectiveness of the new rinsing solution, sterile normal saline, was equivalent to the rinsing solution used in the previously cleared 510(k) K0828 55, sterile purified water.
Residual Progent Testing was performed to determine the amount of residual Progent Solution that remains following the lens rinsing process. Rinsing solutions were collected and measure to determine the remaining active chlorine concentration and pH of the rinsing solutions.
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6. Substantial equivalence (continued)
This test was originally performed in 2009 with the sterile purified water used as a rinsing solution in K082855. In support of this application the test was repeated with sterile normal saline as a rinsing solution. A comparison of the two sets of data was completed and based on active chlorine concentrations and pH values it was confirmed that the rinsing efficacy of sterile normal saline was equal to the rinsing efficacy of the sterile purified water.
Based on these results the Menicon Progent Protein Remover for RGP Contact Lenses with sterile saline rinse is substantially equivalent to the Menicon Progent Protein Remover for RGP Contact Lenses with sterile purified water rinse.
In addition the Progent solutions may be manufactured at an alternate manufacturing site, Gujo Factory, Menicon Nect, Co., Ltd.
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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 circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol resembling an eagle or bird in flight, composed of three stylized lines.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
JAN 0 2 2013
Menicon Co., Ltd. % Ms. Ellen M. Beucler Foresight Regulatory Strategies, Inc. 187 Ballardvale Street. Suite 180 Wilmington, MA 01887
Re: K122273
Trade/Device Name: Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses
Regulation Number: 21 CFR 886.5918
Regulation Name: Rigid gas permeable contact lens care products Regulatory Class: Class II Product Code: MRC Dated: November 30, 2012 Received: December 6, 2012
Dear Ms. Beucler:
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
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Page 2 - Ms. Ellen Beucler
device-related adverse events) (21 CFR 803); 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.
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 vours.
Deborah L. Falls
Malvina B. Eydelman, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): ___ K 122273_
Device Name: Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses
Indications for Use:
Menicon Progent Protein Remover for Rigid Gas Permeable Contact Lenses, when used as directed, cleans and removes protein deposits from fluorosilicone acrylate rigid gas permeable contact lenses.
Prescription Use (Part 21 CFR 801 Subpart D)
AND/OR
Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE OF NEEDED)
10 mm ------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Concurrence of CDRH, Office of Device Evaluation (ODE)
ia Ngg
(Division Sign-Off) (Division of Ophthalmic, Neurological and Ear, Nose and Throat Devices
K 122273 510(k) Number_
§ 886.5918 Rigid gas permeable contact lens care products.
(a)
Identification. A rigid gas permeable contact lens care product is a device intended for use in the cleaning, conditioning, rinsing, lubricating/rewetting, or storing of a rigid gas permeable contact lens. This includes all solutions and tablets used together with rigid gas permeable contact lenses.(b)
Classification. Class II (Special Controls) Guidance Document: “Guidance for Industry Premarket Notification (510(k)) Guidance Document for Contact Lens Care Products.”