K Number
K173225
Device Name
Interlude and private label Unscented 3-piece compact applicator tampon
Manufacturer
Date Cleared
2018-06-15

(255 days)

Product Code
Regulation Number
884.5470
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Interlude and private label Unscented 3-piece applicator tampons are inserted into the vagina and used to absorb menstrual or other vaginal discharge.
Device Description
Interlude and private label Unscented 3-piece compact applicator tampons are menstrual tampons used to absorb menstrual fluid. These tampons are provided in 2 absorbencies, regular and super. These tampons are made from rayon fibers and polymeric overwrap. The withdrawal cord is made of cotton and polyester. The applicator tubes are made of polyethylene (PE) and include a cylindrical barrel with a finger grip and a two-piece plunger. The assembled tampon with applicator is wrapped in a printed PE wrapper.
More Information

Not Found

No
The device description and performance studies focus on the physical properties, absorbency, and biocompatibility of a menstrual tampon, with no mention of AI or ML.

No
Explanation: This device is clearly described as being used to absorb menstrual or other vaginal discharge, which is a supportive and not a therapeutic function.

No

Explanation: The device, a menstrual tampon, is described as absorbing menstrual or other vaginal discharge. Its intended use is for fluid absorption, not for detecting, monitoring, or diagnosing any medical condition.

No

The device description clearly states it is a physical product (tampons with applicators) made of materials like rayon, cotton, polyester, and polyethylene, and the performance studies focus on physical and biological characteristics, not software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is to absorb menstrual or other vaginal discharge by being inserted into the vagina. This is a physical function within the body, not a test performed on a sample taken from the body to diagnose a condition.
  • Device Description: The description details the physical components of a tampon and applicator, designed for absorption.
  • Lack of Diagnostic Function: There is no mention of the device being used to detect, measure, or analyze any substance or characteristic to provide diagnostic information.
  • Performance Studies: The performance studies focus on physical characteristics (absorbency, strength, integrity), biocompatibility, and microbial effects, all related to the device's function as an absorbent product used internally. There are no studies related to diagnostic accuracy or performance.

IVD devices are used to examine specimens (like blood, urine, tissue) outside of the body to provide information about a person's health or condition. This tampon does not fit that description.

N/A

Intended Use / Indications for Use

Interlude and private label Unscented 3-piece applicator tampons are inserted into the vagina and used to absorb menstrual or other vaginal discharge.

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

HEB

Device Description

Interlude and private label Unscented 3-piece compact applicator tampons are menstrual tampons used to absorb menstrual fluid. These tampons are provided in 2 absorbencies, regular and super. These tampons are made from rayon fibers and polymeric overwrap. The withdrawal cord is made of cotton and polyester. The applicator tubes are made of polyethylene (PE) and include a cylindrical barrel with a finger grip and a two-piece plunger. The assembled tampon with applicator is wrapped in a printed PE wrapper.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

vagina

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Over-The-Counter Use

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 were performed in accordance with the 2016 FDA guidance document Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1: Evaluation and testing within a risk management process" and ISO 10993-1:2009. All tests were performed on the tampon and applicator separately. The results of this testing demonstrated that the subject device is non-cytotoxic, non-irritating, non-sensitizing, and non-systemically toxic.

Performance characteristics assessed in accordance with the 2005 FDA guidance document Menstrual Tampons and Pads: Information for Premarket Notification Submissions (510(k)s) – Guidance for Industry and FDA Staff:

  • Dimensional information
  • Absorbency range
  • Chemical residues
  • Withdrawal cord strength
  • Fiber shedding
  • Tampon integrity

Microbial Testing per the 2005 FDA guidance document Menstrual Tampons and Pads: Information for Premarket Notification Submissions (510(k)s) – Guidance for Industry and FDA Staff:

  • Zone of inhibition assay assessing the effects of the subject device on the representative microorganisms considered as normal microflora and/or microflora from the infected genitourinary tract
  • Evaluation of the tampon's effect on Staphylococcus aureus growth and Toxic Shock Syndrome Toxin-1 production using the tampon-sac/device-sac method

The tests performed met the recommendations of the 2005 FDA guidance document.

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.

K090071

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

§ 884.5470 Unscented menstrual tampon.

(a)
Identification. An unscented menstrual tampon is a device that is a plug made of cellulosic or synthetic material that is inserted into the vagina and used to absorb menstrual or other vaginal discharge. This generic type of device does not include menstrual tampons treated with scent (i.e., fragrance materials) or those with added antimicrobial agents or other drugs.(b)
Classification. Class II (performance standards).

0

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June 15, 2018

ALBAAD fem % Robert Staab Official Correspondent Regulatory Technical Associates 30 Neck Road Old Lyme, Connecticut 06371

Re: K173225

Trade/Device Name: Interlude and private label Unscented 3-piece compact applicator tampon Regulation Number: 21 CFR 884.5470 Regulation Name: Unscented Menstrual Tampon Regulatory Class: Class II Product Code: HEB Dated: May 14, 2018 Received: May 14, 2018

Dear Robert Staab:

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 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);

1

and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Michael T. Bailey -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

2

Indications for Use

510(k) Number (if known) K173225

Device Name

Interlude and private label Unscented 3-piece compact applicator tampon

Indications for Use (Describe)

Interlude and private label Unscented 3-piece applicator tampons are inserted into the vagina and used to absorb menstrual or other vaginal discharge.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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K173225 510(k) SUMMARY

| ALBAAD fem
1.0

Submitter:
---------------------------------

Name: Shlomo Helvits Address: 1, Alon Hatavor St. Caesarea Ind. Park 3800900 Israel

FDA Est Reg#: 9613295 Phone No: +972-4-6223860 Fax No: +972-4-6277022

Date 510(k) Summary was prepared: 06/14/2018

  • 2.0 Submission Correspondent:
Name:Robert J. Staab
Address:30 Neck Road
Old Lyme, CT 06371
Phone No:+1 (860) 434-5872
Fax No:+1 (860) 434-5892
Email:rta1ali1@aol.com

3.0 Name of the device:

Trade Name:Interlude and private label Unscented 3-piece compact applicator tampon
Device Name:Unscented 3-piece compact applicator tampon
Common Name:Unscented menstrual tampon
Device Class:Class II
Regulation Name:Unscented menstrual tampon
Regulation Number:21 CFR 884.5470
Product Code:HEB (tampon, menstrual, unscented)

4.0 Predicate Device Information:

The predicate device is K090071, Rostam Fragranced and Unfragranced Compact Applicator Tampons, Rostam Limited

The predicate device has not been subject to a design-related recall

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  • 5.0 Description of the Device:
    • A. Device Description and Dimensions

Interlude and private label Unscented 3-piece compact applicator tampons are menstrual tampons used to absorb menstrual fluid. These tampons are provided in 2 absorbencies, regular and super.

These tampons are made from rayon fibers and polymeric overwrap. The withdrawal cord is made of cotton and polyester. The applicator tubes are made of polyethylene (PE) and include a cylindrical barrel with a finger grip and a two-piece plunger. The assembled tampon with applicator is wrapped in a printed PE wrapper.

  • B. Physical Properties and Weight
    • a. Dimensions and Weight

Regular size length = 114.4 mm Regular size diameter = 14 mm Regular size weight = 2.25 g

Super size length = 114.4 mm Super size diameter = 16 mm Super size weight = 2.4 g

  • b. Absorbency
    Regular size absorbency = 6-9 grams Super size absorbency = 9-12 grams

  • C. Device Materials

    • The pledget absorbing fibers are made of rayon. The finishing a. agent for the rayon fibers is a polyglycol ester and fatty alcohol mixture. Leomin or glycerol.
    • b. The non-woven over-wrap is a bi-component thermoplastic nonwoven.
    • The withdrawal cord is made from polyester and cotton, and c. includes an antiwicking agent consisting of a paraffin wax emulsion.
    • d. The applicator is made from high density polyethylene (HDPE), low density polyethylene (LDPE) and polypropylene

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  • 6.0 Indications for Use
    Interlude and private label Unscented 3-piece applicator tampons are inserted into the vagina and used to absorb menstrual or other vaginal discharge.

9.0 Predicate Device Comparison

The table below shows similarities and differences between the predicate device and the subject device.

CharacteristicsPredicate DeviceSubject Device
Device NameRostam Scented and
Unscented plastic
COMPACT applicator
TamponsInterlude and private label
Unscented 3-piece compact
applicator tampon
ManufacturerRostam LimitedALBAAD fem
510(k)K090071K173225
Indications for UseThe Rostam Fragranced and
Unfragranced Compact
Applicator Tampons
are inserted into the vagina
and used to absorb
menstrual or other vaginal
dischargeInterlude and private label
Unscented 3-piece
applicator tampons are
inserted into the vagina and
used to absorb menstrual or
other vaginal discharge.
Device DesignCompact applicator with
cylindrical barrel and one-
piece plunger. W folded
tampon with round
mushroom tipCompact style applicator
with cylindrical barrel with
finger grip and two-piece
plunger. Tampon with
round tip and straight
grooves.
Overwrap
compositionPolyethylene/Polypropylene
NonwovenPolyethylene/Polyethylene
Terephthalate Nonwoven
Withdrawal cord
compositionCottonPolyester and Cotton
Pledget compositionViscose RayonViscose Rayon
Plastic ApplicatorPolyethyleneHDPE, LDPE,
polypropylene
Primary Packaging
(i.e. wrapper)Printed PolypropylenePrinted Polyethylene

The Interlude and private label Unscented 3-piece compact applicator tampon is a modification of the Rostam Scented and Unscented plastic COMPACT applicator Tampons. The modifications include material and physical design changes, including differences in the overwrap composition, applicator composition, packaging, and minor dimensional differences in the applicator and pledget.

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These differences do not raise different questions of safety and effectiveness. The intended use of the subject and predicate device are identical, to absorb menstrual or other vaginal discharge

10.0 Summary of Performance Testing:

Biocompatibility

Biocompatibility studies were performed in accordance with the 2016 FDA guidance document Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1: Evaluation and testing within a risk management process" and ISO 10993-1:2009 as follows:

  • Cytotoxicity (ISO 10993-5:2009) ●
  • Sensitization (ISO 10993-10:2010) ●
  • Irritation (ISO 10993-10:2010)
  • Acute Systemic Toxicity (ISO 10993-11:2006) .

All tests were performed on the tampon and applicator separately. The results of this testing demonstrated that the subject device is non-cytotoxic, non-irritating, non-sensitizing, and non-systemically toxic.

Performance Characteristics

The following performance characteristics were assessed in accordance with the 2005 FDA guidance document Menstrual Tampons and Pads: Information for Premarket Notification Submissions (510(k)s) – Guidance for Industry and FDA Staff:

  • Dimensional information ●
  • . Absorbency range
  • Chemical residues ●
  • Withdrawal cord strength
  • Fiber shedding ●
  • Tampon integrity ●

Microbial Testing

Per the 2005 FDA guidance document Menstrual Tampons and Pads: Information for Premarket Notification Submissions (510(k)s) – Guidance for Industry and FDA Staff, tampon manufacturers should demonstrate that the subject device in its final, finished form does not:

  • enhance the growth of Staphylococcus aureus
  • increase the production of Toxic Shock Syndrome Toxin-1 (TSST-1)
  • alter the growth of normal vaginal microflora ●

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To assess these parameters, the following tests were performed:

  • Zone of inhibition assay assessing the effects of the subject device on the . representative microorganisms considered as normal microflora and/or microflora from the infected genitourinary tract
  • Evaluation of the tampon's effect on Staphylococcus aureus growth and . Toxic Shock Syndrome Toxin-1 production using the tampon-sac/devicesac method

The tests performed met the recommendations of the 2005 FDA guidance document.

11.0 Conclusion:

The results of the performance testing described above demonstrate that the Interlude and private label Unscented 3-piece compact applicator tampon is as safe and effective as the predicate device and supports a determination of substantial equivalence.