K Number
K124044
Device Name
ALOE CADABRA LUBRICANT, ALOE CADABRA FLAVORED/SCENTED LUBRICANTS
Date Cleared
2013-08-30

(242 days)

Product Code
Regulation Number
884.5300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are personal lubricants, for penile and/or vaginal application, intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with natural rubber latex and polyisoprene condoms. This product is not compatible with polyurethane condoms.
Device Description
Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are non-sterile, aloe-based vaginal lubricants designed to supplement the body's own natural lubrication fluids, and to enhance the ease and comfort of intimate sexual activity. Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are specifically formulated with 95% organic aloe. The remaining five percent of ingredients are in all cases food grade and in many cases certified organic. This device is not a contraceptive or spermicide, nor does it contain any such component. All ingredients in Aloe Cadabra Flavored/Scented Lubricants are GRAS (Generally Recognized as Safe by FDA). The specifications for the Aloe Cadabra Lubricants include appearance, odor, pH, viscosity, osmolality, total microbial count, fungal/yeast/mold limits, and absence of pathogenic organisms (straphylococcus aureus, pseudomonas aeruginosa, escheria coli, salmonella, bile tolerant gram negative bacteria, c. albicans and clostridia). The product is bottled in an HDPE opaque white plastic bottle with a white flip top cap. The bottle is packaged into a carton for sale to consumers. The product comes in five varieties of scents and flavors including Natural Aloe, Pina Colada, Tahitian Vanilla, French Lavender, and Peppermint.
More Information

Not Found

No
The device description and performance studies focus on the physical and chemical properties of a personal lubricant, with no mention of any computational or analytical functions that would utilize AI/ML.

No
The device is described as a personal lubricant intended to enhance comfort during intimate sexual activity, not to treat or prevent a medical condition.

No

Explanation: The "Intended Use / Indications for Use" section states that the device is a personal lubricant intended to moisturize and lubricate to enhance comfort during sexual activity. It does not mention any diagnostic purpose or function.

No

The device description clearly indicates that the device is a physical product (lubricant) bottled in a plastic container, not a software program.

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

Here's why:

  • Intended Use: The intended use is clearly stated as a personal lubricant for penile and/or vaginal application to enhance intimate sexual activity and supplement natural lubrication. This is a topical application for physical comfort and ease, not for diagnosing, monitoring, or treating a medical condition through in vitro examination of specimens.
  • Device Description: The description focuses on the composition (aloe-based), physical properties (pH, viscosity, etc.), and packaging. It explicitly states it is not a contraceptive or spermicide.
  • Performance Studies: The performance studies described are biocompatibility tests (toxicity, irritation, sensitization) and condom compatibility. These are relevant to the safety and functionality of a topical lubricant, not to the performance of an in vitro diagnostic test.
  • Lack of IVD Characteristics: There is no mention of analyzing biological specimens (blood, urine, tissue, etc.) outside the body, which is the defining characteristic of an in vitro diagnostic device.

In summary, the device is a personal lubricant intended for direct application to the body, not for performing diagnostic tests on specimens.

N/A

Intended Use / Indications for Use

Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are personal lubricants, for penile and/or vaginal application, intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with natural rubber latex and polyisoprene condoms. This product is not compatible with polyurethane condoms.

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

NUC

Device Description

Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are non-sterile, aloe-based vaginal lubricants designed to supplement the body's own natural lubrication fluids, and to enhance the ease and comfort of intimate sexual activity. Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are specifically formulated with 95% organic aloe. The remaining five percent of ingredients are in all cases food grade and in many cases certified organic. This device is not a contraceptive or spermicide, nor does it contain any such component. All ingredients in Aloe Cadabra Flavored/Scented Lubricants are GRAS (Generally Recognized as Safe by FDA). The specifications for the Aloe Cadabra Lubricants include appearance, odor, pH, viscosity, osmolality, total microbial count, fungal/yeast/mold limits, and absence of pathogenic organisms (straphylococcus aureus, pseudomonas aeruginosa, escheria coli, salmonella, bile tolerant gram negative bacteria, c. albicans and clostridia).

The product is bottled in an HDPE opaque white plastic bottle with a white flip top cap. The bottle is packaged into a carton for sale to consumers. The product comes in five varieties of scents and flavors including Natural Aloe, Pina Colada, Tahitian Vanilla, French Lavender, and Peppermint.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

penile and/or vaginal

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)

Biocompatibility studies including Acute System Toxicity, Vaginal Irritation Testing, Cytotoxicity, and Skin Sensitization were performed according to ISO 10993 standards.
Acute Systemic Toxicity: This test evaluated systemic responses in mice after injection of Aloe Cadabra® Lubricant. The test was conducted according to ISO 10993-11: 2006 standards. All test group animals survived the test period and none of the test group animals exhibited any biological reactivity at any of the tested time points.
Vaginal Irritation Testing: The potential of Aloe Cadabra® Lubricant to produce irritation of the vaginal mucosal tissue was assessed according to ISO 10993-10: 2010 standards. Results of the testing show that Aloe Cadabra® Lubricant was considered non-irritating to the vaginal mucosa in female New Zealand White Rabbits.
Cyotoxicity: Aloe Cadabra® Lubricant was not considered to have a cytotoxic effect according to the qualitative evaluation of cells exposed to Aloe Cadabra® Lubricant based on grading criteria in ANSI/AAMI/ISO 10993-5: 2009.
Skin Sensitization: Maximization testing for delayed hypersensitivity was performed to determine to what extent Aloe Cadabrao Lubricant has the potential to act as a contact sensitizer in guinea pigs. This test was completed according to methods detailed in ISO 10-993-10: 2010. According to methods detailed in ISO 10-993-10: 2010, Aloe Cadabra® Lubricant did not elicit sensitization reactions in the animals used in the study.
Shelf Life: The Aloe Cadabra® Lubricants have a two-year shelf life based on the results of a real time aging study.
Condom Compatibility: The compatibility of the Aloe Cadabra® Lubricants was evaluated with natural rubber latex, polyisoprene, and polyurethane condoms per ASTM D7661-10. The condom compatibility testing was performed on all 5 versions of the lubricants. The testing showed that the lubricants are compatible with natural rubber latex and polyisoprene condoms and are not compatible with polyurethane condoms.
Conclusions drawn from Testing Performed: The non-clinical performance testing conducted demonstrates that the Aloe Cadabra Personal Lubricants are substantially equivalent to the proposed predicate device.

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.

K061466

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

§ 884.5300 Condom.

(a)
Identification. A condom is a sheath which completely covers the penis with a closely fitting membrane. The condom is used for contraceptive and for prophylactic purposes (preventing transmission of sexually transmitted infections). The device may also be used to collect semen to aid in the diagnosis of infertility.(b)
Classification. (1) Class II (special controls) for condoms made of materials other than natural rubber latex, including natural membrane (skin) or synthetic.(2) Class II (special controls) for natural rubber latex condoms. The guidance document entitled “Class II Special Controls Guidance Document: Labeling for Natural Rubber Latex Condoms Classified Under 21 CFR 884.5300” will serve as the special control. See § 884.1(e) for the availability of this guidance document.

0

510(k) Summary

In accordance with 21 CFR 807.87(h) and (21 CFR 807.92) the 510(k) Summary for the Aloe Cadabra Lubricant and Aloe Cadabra Flavored/Scented Lubricants is provided below.

Device Common Name:Personal Lubricant
Device Proprietary Name:Aloe Cadabra® Personal Lubricant - Natural Aloe
Aloe Cadabra® Personal Lubricant - Pina Colada
Aloe Cadabra® Personal Lubricant - Tahitian Vanilla
Aloe Cadabra® Personal Lubricant - French Lavender
Aloe Cadabra® Personal Lubricant - Peppermint
Submitter:Seven Oaks Ranch, Inc.
2658 Channel Drive
Ventura, CA 93003
Contact:Calley Herzog, consultant
Biologics Consulting Group, Inc.
Phone: 720-883-3633
Fax: 720-293-0014
Email: cherzog@bcg-usa.com
AUG 3 0 2013
Date Prepared:July 12, 2013
Classification
Regulation:884.5300
Classification Name:Condom
Panel:Obstetrics/Gynecology
Product Code:NUC
Predicate Device:K061466 - INTIMOL™ Liquid Personal Lubricant (DLC
Laboratories, Inc.)

Indication for Use:

Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are personal lubricants, for penile and/or vaginal application, intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with natural rubber latex and polyisoprene condoms. This product is not compatible with polyurethane condoms.

Device Description:

Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are non-sterile, aloe-based vaginal lubricants designed to supplement the body's own natural lubrication fluids,

1

and to enhance the ease and comfort of intimate sexual activity. Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are specifically formulated with 95% organic aloe. The remaining five percent of ingredients are in all cases food grade and in many cases certified organic. This device is not a contraceptive or spermicide, nor does it contain any such component. All ingredients in Aloe Cadabra Flavored/Scented Lubricants are GRAS (Generally Recognized as Safe by FDA). The specifications for the Aloe Cadabra Lubricants include appearance, odor, pH, viscosity, osmolality, total microbial count, fungal/yeast/mold limits, and absence of pathogenic organisms (straphylococcus aureus, pseudomonas aeruginosa, escheria coli, salmonella, bile tolerant gram negative bacteria, c. albicans and clostridia).

The product is bottled in an HDPE opaque white plastic bottle with a white flip top cap. The bottle is packaged into a carton for sale to consumers. The product comes in five varieties of scents and flavors including Natural Aloe, Pina Colada, Tahitian Vanilla, French Lavender, and Peppermint.

Performance Data:

Biocompatibility studies including Acute System Toxicity, Vaginal Irritation Testing, Cytotoxicity, and Skin Sensitization were performed according to ISO 10993 standards.

Acute Systemic Toxicity: This test evaluated systemic responses in mice after injection of Aloe Cadabra® Lubricant. The test was conducted according to ISO 10993-11: 2006 standards. All test group animals survived the test period and none of the test group animals exhibited any biological reactivity at any of the tested time points.

Vaginal Irritation Testing: The potential of Aloe Cadabra® Lubricant to produce irritation of the vaginal mucosal tissue was assessed according to ISO 10993-10: 2010 standards. Results of the testing show that Aloe Cadabra® Lubricant was considered non-irritating to the vaginal mucosa in female New Zealand White Rabbits.

Cyotoxicity: Aloe Cadabra® Lubricant was not considered to have a cytotoxic effect according to the qualitative evaluation of cells exposed to Aloe Cadabra® Lubricant based on grading criteria in ANSI/AAMI/ISO 10993-5: 2009.

Skin Sensitization: Maximization testing for delayed hypersensitivity was performed to determine to what extent Aloe Cadabrao Lubricant has the potential to act as a contact sensitizer in guinea pigs. This test was completed according to methods detailed in ISO 10-993-10: 2010. According to methods detailed in ISO 10-993-10: 2010, Aloe Cadabra® Lubricant did not elicit sensitization reactions in the animals used in the study.

Shelf Life: The Aloe Cadabra® Lubricants have a two-year shelf life based on the results of a real time aging study.

Condom Compatibility: The compatibility of the Aloe Cadabra® Lubricants was evaluated with natural rubber latex, polyisoprene, and polyurethane condoms per ASTM D7661-10. The condom compatibility testing was performed on all 5 versions of the lubricants. The testing showed that the lubricants are compatible with natural rubber latex and polyisoprene condoms and are not compatible with polyurethane condoms.

Conclusions drawn from Testing Performed: The non-clinical performance testing conducted demonstrates that the Aloe Cadabra Personal Lubricants are substantially equivalent to the proposed predicate device.

2

Substantial Equivalence:

Based on similar intended uses, similar technological characteristics and similar testing, the Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants can be found substantially equivalent to the INTIMOL™ Liquid Personal Lubricant (K061466).

K124044K061466
Device NameAloe Cadabra Personal Lubricant
  • Natural Aloe
    Aloe Cadabra Personal Lubricant
  • Pina Colada
    Aloe Cadabra Personal Lubricant
  • Tahitian Vanilla
    Aloe Cadabra Personal Lubricant
  • French Lavender
    Aloe Cadabra Personal Lubricant
  • Peppermint | INTIMOL Liquid Personal Lubricant |
    | Manufacturer | Seven Oaks Ranch, Inc. | DLC Laboratories, Inc. |
    | Classification | 884.5300 | 884.5300 |
    | Product Code | NUC | NUC |
    | Indication | Aloe Cadabra® Lubricant and
    Aloe Cadabra®
    Flavored/Scented Lubricants
    are personal lubricants, for
    penile and/or vaginal
    application, intended to
    moisturize and lubricate, to
    enhance the ease and comfort of
    intimate sexual activity and
    supplement the body's natural
    lubrication. This product is
    compatible with natural rubber
    latex and polyisoprene
    condoms. This product is not
    compatible with polyurethane
    condoms. | INTIMOL™ Liquid Personal Lubricant is
    principally intended as personal lubricant
    to supplement the body's natural
    lubricating fluids, and to enhance the ease
    and comfort of intimate sexual activity
    with or without a latex condom. |
    | Over-the-Counter | Yes | Yes |
    | Contains Aloe | Yes | Yes |
    | Provided Sterile | No | No |
    | Biocompatible | Yes | Yes |

Device Comparison Table

3

Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES-USA" arranged around the circumference. Inside the circle is an abstract symbol resembling an eagle or bird in flight, composed of three curved lines.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

August 30, 2013

Seven Oaks Ranch, Inc. % Calley Herzog Consultant Biologics Consulting Group, Inc. 400 North Washington Street, Suite 100 Alexandria, VA 22314

  • K124044 Re:
    Trade/Device Name: Aloe Cadabra Personal Lubricant - Natural Aloe, Aloe Cadabra Personal Lubricant - Pina Colada, Aloe Cadabra Personal Lubricant - Tahitian Vanilla, Aloe Cadabra Personal Lubricant -French Lavender, Aloe Cadabra Personal Lubricant - Peppermint Regulation Number: 21 CFR 884.5300 Regulation Name: Condom Regulatory Class: Class II Product Code: NUC Dated: July 17, 2013 Received: July 18, 2013

Dear Calley Herzog:

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.

4

Page 2 - Calley Herzog

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 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 contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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.

Herbert P. Lerner -S

for

Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

5

Indications for Use Statement

510(k) Number (if known): K124044

Device Name:

Aloe Cadabra Personal Lubricant - Natural Aloe Aloe Cadabra Personal Lubricant - Pina Colada Aloe Cadabra Personal Lubricant - Tahitian Vanilla Aloe Cadabra Personal Lubricant - French Lavender Aloe Cadabra Personal Lubricant - Peppermint

Indications For Use:

Aloe Cadabra® Lubricant and Aloe Cadabra® Flavored/Scented Lubricants are personal lubricants, for penile and/or vaginal application, intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with natural rubber latex and polyisoprene condoms. This product is not compatible with polyurethane condoms.

Prescription Use (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use__X (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Herbert P. Lerner -S 2013.08.30 10:56:3

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