K Number
K162167
Device Name
Caphosol Artifical Saliva Tablets
Date Cleared
2017-03-31

(240 days)

Product Code
Regulation Number
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Caphosol Dispersible is indicated for dryness of the mouth and throat (hyposalivation, xerostomia), regardless of the cause and regardless of whether the condition is temporary or permanent. Caphosol Dispersible is also indicated as an adjunct to standard oral care in the treatment of the mucositis that may be caused by radiation or high dose chemotherapy. Relief of dryness of the oral mucosa in these conditions is associated with amelioration of pain.
Device Description
Caphosol is a supersaturated calcium phosphate, electrolyte mouth rinse used as artificial saliva, designed in part to replace ionic and pH balance in the oral cavity, and formulated as a tablet to be dissolved in water prior to use.
More Information

Not Found

No
The device description and intended use describe a chemical solution (mouth rinse) and do not mention any computational or algorithmic components, let alone AI/ML. The "Mentions AI, DNN, or ML" section explicitly states "Not Found".

Yes
Caphosol Dispersible is indicated for the treatment of mucositis and the amelioration of pain associated with dryness of the oral mucosa, which are therapeutic claims.

No
The device, Caphosol Dispersible, is a mouth rinse used for dryness of the mouth and throat and as an adjunct to oral care for mucositis. Its purpose is to provide relief and replace ionic/pH balance, not to diagnose any conditions.

No

The device description clearly states it is a tablet to be dissolved in water, indicating 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 treating dryness of the mouth and throat and as an adjunct to oral care for mucositis. These are conditions affecting the patient directly, not for examining specimens from the body to provide diagnostic information.
  • Device Description: Caphosol is described as a mouth rinse used as artificial saliva. This is a therapeutic or supportive device, not a diagnostic one.
  • Lack of Diagnostic Purpose: There is no mention of the device being used to diagnose, monitor, or screen for any disease or condition by analyzing samples from the body.
  • No Mention of Specimen Analysis: The description does not involve the analysis of blood, urine, tissue, or any other biological specimen.

IVD devices are specifically designed to perform tests on samples taken from the human body to provide information for diagnosis, monitoring, or screening. This device does not fit that description.

N/A

Intended Use / Indications for Use

Caphosol Dispersible is indicated for dryness of the mouth and throat (hyposalivation, xerostomia), regardless of the cause and regardless of whether the condition is temporary or permanent. Caphosol Dispersible is also indicated as an adjunct to standard oral care in the treatment of the mucositis that may be caused by radiation or high dose chemotherapy. Relief of dryness of the oral mucosa in these conditions is associated with amelioration of pain.

Product codes

LFD

Device Description

Caphosol is a supersaturated calcium phosphate, electrolyte mouth rinse used as artificial saliva, designed in part to replace ionic and pH balance in the oral cavity, and formulated as a tablet to be dissolved in water prior to use.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Oral cavity.

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

Biocompatibility assessment conducted in accordance with ISO - 10993-1 Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing within a Risk Management Process.

Clinical performance testing was not conducted for the subject device.

A literature search has not shown any clinically significant adverse effects being reported.

Key Metrics

Not Found

Predicate Device(s)

K030802

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

N/A

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

March 31, 2017

Eusa Pharma (UK) Limited % Mr. J. Harvey Knauss Consultant Delphi Consulting Group 11874 South Evelyn Circle Houston, Texas 77071-3404

Re: K162167

Trade/Device Name: Caphosol Artificial Saliva Tablets Regulatory Class: Unclassified Product Code: LFD Dated: March 7, 2017 Received: March 7, 2017

Dear Mr. Knauss:

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 devicerelated 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.

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If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free 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" (21 CFR 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely.

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Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control, and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration

Indications for Use

510(k) Number (if known). K162167

Device Name CAPHOSOL Artificial Saliva

Indications for Use (Describe)

Caphosol Dispersible is indicated for dryness of the mouth and throat (hyposalivation, xerostomia), regardless of the cause and regardless of whether the condition is temporary or permanent. Caphosol Dispersible is also indicated as an adjunct to standard oral care in the treatment of the mucositis that may be caused by radiation or high dose chemotherapy. Relief of dryness of the oral mucosa in these conditions is associated with amelioration of pain.

Type of Use (Select one or both, as applicable)

× Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(k) Summary, K162167, GENERAL INFORMATION:

| Sponsor/Submitter: | EUSA Pharma
Breakspear Park, Breakspear Way
Hemel Hempstead
HP2 4TZ United-Kingdom
011 44 1732 832 317 voice
Registration # 10049906
Mr. Paul Davisson |

----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Common/Usual NameNone
Proprietary NameCaphosol Artificial Saliva
Regulation NumberUnclassified
Product CodeLFD
Predicate DevicesK030802 Primary

Description of the device and its intended application:

Caphosol is a supersaturated calcium phosphate, electrolyte mouth rinse used as artificial saliva, designed in part to replace ionic and pH balance in the oral cavity, and formulated as a tablet to be dissolved in water prior to use.

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The following table lists the Caphosol components:

| List of components | Function in
Caphosol
Dispersible | Function in Caphosol |
|---------------------------------------------|----------------------------------------|----------------------|
| Sodium phosphate dibasic
anhydrous | Active component | Active component |
| Sodium phosphate
monobasic anhydrous | Active component | Active component |
| Calcium chloride | Active component | Active component |
| Sodium hydrogen carbonate | Effervescent Agent | Stabilizer |
| Sodium carbonate
anhydrous | Effervescent Agent | none |
| Maltodextrin | Diluent | none |
| Granulate Citric acid
anhydrous/sorbitol | Effervescent Agent | none |
| Water | | Active component |

Caphosol Statement of Intended Use:

Caphosol Dispersible is indicated for dryness of the mouth and throat (hyposalivation, xerostomia), regardless of the cause and regardless of whether the condition is temporary or permanent. Caphosol Dispersible is also indicated as an adjunct to standard oral care in the treatment of the mucositis that may be caused by radiation or high dose chemotherapy. Relief of dryness of the oral mucosa in these conditions is associated with amelioration of pain.

Comparison of Device Technology:

| COMPARING | CAPHOSOL® Dispersible
K162167 | CAPHOSOL®
Predicate
K030802 |
|----------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Product Code | LFD | LFD |
| Regulation Number | Unclassified | Unclassified |
| Indication for Use | Caphosol Dispersible is indicated for dryness of the mouth and throat (hyposalivation, xerostomia), regardless of the cause and regardless of whether the condition is temporary or permanent. Caphosol Dispersible is also indicated as an adjunct to standard oral care in the treatment of the mucositis that may be caused by radiation or high dose chemotherapy. Relief of dryness of the oral mucosa in these conditions is associated with amelioration of pain. | Caphosol is indicated for dryness of the mouth or throat (hypo salivation, xerostomia), regardless of the cause and regardless of whether the condition is temporary or permanent. Caphosol is indicated for relief of dryness of the oral mucosa when hypo salivation results from the following: surgery, radiotherapy near the salivary glands, chemotherapy; infection or dysfunction of the salivary glands; inflammation of the mouth or throat; fever, emotional factors such as fear or anxiety; obstruction of the salivary ducts; Sjogren's syndrome; and Bell's Palsy. |
| COMPARING | CAPHOSOL® Dispersible
K162167 | CAPHOSOL®
Predicate
K030802 |
| | | Caphosol is also indicated for
dryness of the oral mucosa due to
drugs such as antihistamines or
atropine or other anticholinergic
agents that suppress salivary
secretion. It may be used as part of
an oral hygiene program for patients
with dry mouth. Caphosol provides
intensive hygiene of the oral cavity,
and may be used to help relieve bad
taste and to relieve offensive nasal
discharge and crusting. |
| Packaging | Tablet solid form, 1.75 MM
diameter.
Image: Tablet | • Two 15 ml solutions plastid (LDPE)
ampules
• Solution A (blue ampule) –
(phosphate solution) |
| | | Solution B (clear ampule) - (calcium
solution)
Image: Ampules |
| Method of use | Ready to use, mix with water. | Mix solutions A & B |
| Area of use | Oral cavity. | Oral cavity. |
| Presentation | Non-Sterile. | Non-Sterile. |
| Interaction with other
medicinal products | There are no known interactions
with medicinal or other products. | There are no known interactions with
medicinal or other products. |

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Indication for Use Differences:

The indication for use statement of the predicate device is more specific than the indication for use statement of the subject device. The differences do not raise concerns as the intended use is the same.

Technology Differences:

The CAPHOSOL® Artificial Saliva Tablets and Caphosol® Liguid Artificial Saliva active chemical components are identical, however the CAPHOSOL® Artificial Saliva Tablets formulation includes a diluent and effervescent agents, and does not contain water. The available physical form of the subject device is a dry tablet, whereas the predicate device is composed of two ampules containing different solutions to be mixed prior to use. The

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excipients in the subject device formulation result in effervescence and complete dissolution of the table to obtain the final solution prepared after dissolution of a tablet or after mixing 2 ampules are identical in quantity of the active ingredients (Calcium and Phosphate).

The CAPHOSOL® Artificial Saliva Tablets is substantially equivalent to the predicate devices with regard to operating principle and function.

Performance Testing:

Biocompatibility assessment conducted in accordance with ISO - 10993-1 Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing within a Risk Management Process.

Non-Clinical and Clinical Studies:

Clinical performance testing was not conducted for the subject device.

A literature search has not shown any clinically significant adverse effects being reported.

Conclusion:

Based on the similarities in intended use, technology, and performance testing, the CAPHOSOL Artificial Saliva Effervescent Tablets is substantially equivalent to the predicate device.