K Number
K200239
Manufacturer
Date Cleared
2020-11-13

(287 days)

Product Code
Regulation Number
884.5300
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Astroglide® Organix® Gel is a personal lubricant 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. The product is not compatible with polyurethane condoms.

Device Description

Astroglide® Organix ® Gel is non-sterile, translucent, colorless to slight yellow, water-based personal lubricant intended for penile and vaginal application 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 and is not compatible with polyurethane condoms. This product is for over-the-counter (OTC) use. Astroglide® Organix ® Gel's formulation consists of water, glycerine, xanthan gum, gellan gum, aloe barbabensis powder, chamomilla recutita (matricaria) flower extract, calendula officinalis flower extract, vaccinium macrocarpon (cranberry) fruit extract, passiflora incarnata flower extract, sodium benzoate, potassium sorbate, and citric acid. It is packaged in white LDPE tube with a screw on flip top cap comprised of polypropylene. This product is also provided in 2.5 ml foil packs.

AI/ML Overview

This document is a 510(k) Premarket Notification from the FDA regarding a personal lubricant, Astroglide® Organix® Gel. It is a not a study of an AI/ML medical device. Therefore, I cannot extract the information required using the provided text.

The request asks for specific details related to the validation of an AI/ML medical device, such as acceptance criteria based on AI performance metrics (e.g., sensitivity, specificity), details about test sets (sample size, provenance, ground truth establishment, expert qualifications, adjudication methods), information on multi-reader multi-case (MRMC) studies, and details about training sets. These concepts are entirely absent from the provided document, which focuses on the chemical, physical, and biocompatibility testing of a personal lubricant to demonstrate its substantial equivalence to a predicate device.

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November 13, 2020

BioFilm Inc. Richard Hines Regulatory Affairs Manager 3225 Executive Ridge Vista, CA 92081

Re: K200239 Trade/Device Name: Astroglide® Organix® Gel Regulation Number: 21 CFR 884.5300 Regulation Name: Condom Regulatory Class: II Product Code: NUC Dated: October 2, 2020 Received: October 14, 2020

Dear Richard Hines:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.

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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance)and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Monica D. Garcia, Ph.D. Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K200239

Device Name Astroglide® Organix® Gel

Indications for Use (Describe)

Astroglide® Organix® Gel is a personal lubricant 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. The product is not compatible with polyurethane condoms.

Type of Use (Select one or both, as applicable)
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Prescription Use (Part 21 CFR 801 Subpart D)

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

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510(K) Summary - K200239 Astroglide® Organix ® Gel

i. Submitter Information

Applicant:BioFilm, Inc.
Address:3225 Executive RidgeVista, CA 92081 USA
Telephone:760-727-9030
Fax:760-727-8080
Contact Person:Richard Hines
Contact Title:Regulatory Affairs Manager
Email:richard@biofilm.com
Date Prepared:November 12, 2020

Device Information ii.

Trade Name:Astroglide® Organix ® Gel
Common Name:Personal Lubricant
Regulation Number:21 CFR 884.5300
Regulation Name:Condom
Product Code:NUC (Lubricant, Personal)
Regulatory Class:II

iii. Predicate Device

Predicate Device510(k) Number
Astroglide NaturalK141581
Original Applicant: BioFilm Inc.

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

Description of Device iv.

Astroglide® Organix ® Gel is non-sterile, translucent, colorless to slight yellow, water-based personal lubricant intended for penile and vaginal application 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 and is not compatible with polyurethane condoms. This product is for over-the-counter (OTC) use.

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Astroglide® Organix ® Gel's formulation consists of water, glycerine, xanthan gum, gellan gum, aloe barbabensis powder, chamomilla recutita (matricaria) flower extract, calendula officinalis flower extract, vaccinium macrocarpon (cranberry) fruit extract, passiflora incarnata flower extract, sodium benzoate, potassium sorbate, and citric acid. It is packaged in white LDPE tube with a screw on flip top cap comprised of polypropylene. This product is also provided in 2.5 ml foil packs.

Device specifications are listed in the table below.

ParameterSpecification (Test Method)
ColorColorless to slight yellow
ClarityHazy liquid
OdorOdorless
Osmolality500-1000 mOsm/kg (1:5 dilution)
pH3.5-5.5
Viscosity200,000-300,000 cP
Total yeast/mold count<10 cfu/mL (USP <61>)
Total aerobic microbial count<100 cfu/mL (USP <61>)
Staphylococcus aureus, Pseudomonas aeruginosa, and Candida albicansAbsent (USP <62>)
Antimicrobial effectiveness (per USP <51>)Category 2, bacteria should show not less than 2.0 log reduction at 14 days and no increase from 14-day count at the 28-day count. Yeast and molds should show no increase from the initial calculated count at 14 and 28 days

Indications for Use v.

Astroglide® Organix ® Gel is a personal lubricant 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.

Summary of Intended Use and Technological Characteristics of the Subject Device vi. in Comparison to the Predicate Device

The following table compares the Indications for Use and technological characteristics of the subject and predicate device:

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Characteristic /FeatureAstroglide® Organix ®Gel (subject device)Astroglide ® Natural(predicate device) -K141581Comparison
Indication foruseAstroglide® Organix Gel is apersonal lubricant for penileand/or vaginal application,intended to moisturize andlubricate, to enhance the easeand comfort of intimatesexual activity andsupplement the body'snatural lubrication. Thisproduct is compatible withnatural rubber latex andpolyisoprene condoms. Thisproduct is not compatiblewith polyurethane condoms.Astroglide® Natural is apersonal lubricant for penileand/or vaginal application,intended to moisturize andlubricate, to enhance theease and comfort ofintimate sexual activity andsupplement the body'snatural lubrication.This product is compatiblewith natural rubber latexand polyisoprene condoms.This product is notcompatible withpolyurethane condoms.Same: The subject andpredicate devices have thesame indication for use withthe exception that the it is notcompatible with polyurethanecondoms. Therefore, thesubject and predicate deviceshave the same intended use(provides lubrication duringintimate sexual activity).
Water-BasedLubricantYesYesSame
Over theYesYesSame
OdorlessYesYesSame
Non-sterileYesYesSame
PrimaryIngredientsPurified Water, Glycerin*,Xanthan Gum, Gellan Gum,Aloe Barbadensis Powder*,Chamomilla Recutita(Matricaria) Flower Extract*,Calendula Officinalis FlowerExtract*, VacciniumMacrocarpon (Cranberry)Fruit Extract*, PassifloraIncarnata Flower Extract*,Sodium Benzoate, PotassiumSorbate, Citric Acid*Indicates OrganicWater, Xylitol,Hydroxyethylcellulose,Phenoxyethanol, AloeBarbadensis Leaf Juice Extract,Chamomilla Recutita(Matricaria) Flower Extract,Pectin, Potassium AscorbylTocopheryl Phosphate, LacticAcidDifferent: The ingredients of thepredicate device are different;however, differences in deviceingredients do not raise differentquestions of Safety &Effectiveness (S & E).
MicrobialLimits• Total mold/yeast count<10 cfu/mL• Total aerobic microbialcount <100 cfu/mL• Absence of pathogens(Candida albicans,Pseudomonas aeruginosa,• Total mold/yeast count<10 cfu/mL• Total aerobic microbialcount <100 cfu/mL• Absence of pathogens(Candida albicans,Pseudomonas aeruginosa,Same
Viscosity200,000-300,000 centipoise2200-3400 centipoiseDifferent: the viscosity of thesubjective device is higher. Thisdifference does not raisedifferent questions of S & E.
pH3.5-5.54.0-7.0Different: The subjectdevice has a lower pHthan the predicate. Thisdifference does not raisedifferent questions ofS& E.
Osmolality500-1000 mOsm/kg (1:5dilution)769 mOsm/kgDifferent: Theosmolality specificationfor the subject device isdifferent than thepredicate device.Difference in osmolalityspecifications do notraise different questionsof S&E.
PackagingLDPE tube and foilPETE BottleDifferent: The subjectdevice is packaged in aLDPE tube and thepredicate is packaged inPETE bottles. Thesubject device in alsopackaged a foil pack.These differences donot raise differentquestions of S &E.
Shelf-lifeBottle: 6 monthsFoil: 3monthsThree yearsDifferent: The subjectdevices have a shortershelf-life than thepredicate device. Thisdifference does not raisedifferent questions of S&E.

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The subject and predicate device indications for use are not identical, as the predicate device indications for use does not specifically state that it is not compatible with polyurethane condoms. However, the intended use of the subject and predicate devices is the same (i.e., provides lubrication during intimate sexual activity).

In addition, the subject and predicate devices have different technological characteristics as shown in the table above. The differences in technological characteristics between the subject and predicate devices do not raise different questions of safety and effectiveness.

Summary of Non-Clinical Performance Testing vii.

Biocompatibility

Astroglide® Organix® Gel has undergone biocompatibility testing in accordance with the 2020 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." Testing included:

  • Cytotoxicity per ISO 10993-5: 2009 ●
  • Sensitization and Irritation testing using the human repeat insult patch testing, an ● alternative test method to ISO 10993-10:2010
  • Acute systemic toxicity testing per ISO 10993-11:2017.

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The testing demonstrated that Astroglide® Organix® Gel is non-cytotoxic, nonsensitizing, non-irritating, and not acutely-systemically toxic. Condom Compatibility

Astroglide® Organix® Gel was tested in accordance with ASTM D7661-10 "Standard Test Method for Determining Compatibility of Personal Lubricants with Natural Rubber Latex Condoms." Results showed that Astroglide® Organix® Liquid is compatible with natural rubber latex and polyisoprene condoms. Astroglide® Organix® Liquid is not compatible with polyurethane condoms.

Shelf life

Astroglide® Organix® Gel has a shelf-life of 6 months in 3 oz. LDPE tubes and 3 months in foils packs. Results from testing demonstrated that the device can maintain its specifications (as shown in Section IV) over the duration of its shelf-life in both packaging forms.

viii. Conclusion

The results of the testing described above provide reasonable assurance that the Astroglide® Organix Gel Personal Lubricant is as safe and effective as the predicate device and supports a determination of substantial equivalence.

§ 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.