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510(k) Data Aggregation
(48 days)
COMPLETE BRAND LUBRICATING AND REWETTING DROPS
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(77 days)
COMPLETE BRAND LUBRICATING AND REWETTING DROPS
COMPLETE® brand Lubricating and Rewetting Drops are indicated to lubricate and rewet soft (hydrophilic) contact lenses during lens wear.
COMPLETE® brand Lubricating and Rewetting Drops are used to lubricate and rewet soft (hydrophilic) contact lenses before application and during lens wear.
COMPLETE® brand Lubricating and Rewetting Drops are a sterile, isotonic, buffered, solution containing hydroxypropyl methylcellulose as a lubricant, preserved with polyhexamethylene biguanide 0.0001%, a phosphate buffer, Poloxamer 237 as a surfactant, edetate disodium as a chelating agent, sodium chloride, potassium chloride, and purified water. COMPLETE® brand Lubricating and Rewetting Drops contain no chlorhexidine or thimerosal and no other mercury containing ingredients. Both current and reformulated products are clear, colorless solutions packaged in plastic bottles with controlled dropper tips.
The provided 510(k) summary for "COMPLETE® brand Lubricating and Rewetting Drops" does not include a detailed table of acceptance criteria with specific quantitative thresholds or a singular study explicitly designed to "prove" the device meets these criteria in the typical sense of a diagnostic device.
Instead, the submission focuses on demonstrating substantial equivalence to a predicate device (the existing formulation of the product and other contact lens multi-purpose, lubricating and rewetting solutions) through a series of non-clinical and limited clinical studies. The "acceptance criteria" are implied by the successful outcomes of these tests, showing the new formulation is as safe and effective as the predicate.
Here's a breakdown of the information based on the provided text, addressing your points where possible:
1. Table of Acceptance Criteria and Reported Device Performance
As noted, a formal table of quantitative acceptance criteria is not present in the provided text. The "acceptance criteria" are implicitly met when the device performs comparably or better than the predicate/controls in various safety and effectiveness tests.
Acceptance Criterion (Implied) | Reported Device Performance |
---|---|
Microbiological Safety: | |
- Preservative Effectiveness (USP Modified criteria) | Meets USP Modified criteria for Preservative Effectiveness. |
- Sterility (USP Sterility test requirements) | Meets USP Sterility test requirements. |
Toxicology/Biocompatibility: | |
- Cytotoxicity (Cell damage assessment) | Neutral Red Retention Assay: New COMPLETE® exhibited better neutral red retention than benzalkonium chloride (BAK) and at least comparable to ReNu MultiPlus. Indicates potentially less damaging to cells than old COMPLETE® after 3 hours. |
CHO Clonal Growth Assay: New COMPLETE® showed significantly better survival rate of Chinese hamster ovary cells than old COMPLETE® and ReNu MultiPlus. Higher relative survival than negative control. Indicates potentially less damaging to eye cells. | |
- Sensitization (Allergic reaction potential) | No dermal reactions observed in test or control groups in a guinea pig maximization test, indicating comparability to the marketed formulation. |
- Acute Oral Toxicity (Systemic toxicity from ingestion) | No treatment-related effects or deaths, and no adverse effects when administered to rats at a single oral dose of 20 mL/kg. |
- Ocular Safety (Irritation, long-term eye health with use) | In a 28-day rabbit study (4X/day instillations, 8 hours/day lens wear): No clinically significant ocular discomfort, conjunctival irritation, changes in corneal thickness, conjunctival/uveal/corneal abnormalities, or apparent ocular changes. Histopathological exams revealed no treatment-related changes. Concluded as "safe for use with hydrophilic contact lenses". |
Clinical Performance (Indirect for Lubricating Drops): | |
- Safety (Adverse events, ocular findings during lens wear) | No adverse device effects reported. No statistically significant differences in clinically significant slit lamp findings. Statistically significant differences in maximum severity grades for injection and tarsal anomaly, with more severe findings in the predicate (COMPLETE® MPS) group than the investigational group. Other safety variables similar. |
- Acceptability (Patient comfort/symptoms) | Statistically significant difference with higher maximum severity score for symptoms of discomfort in the Investigational MPS group. However, overall incidence of symptoms was low and not regimen-related, thus not clinically relevant. No statistically significant difference in the number of examinations with clinically significant ocular symptoms of discomfort. Unremarkable findings for other variables. |
Equivalence to Predicate | The safety, efficacy, and performance of the Investigational product is substantially equivalent to the approved formulation currently on the market. |
Stability (Expiration Date Establishment) | Stability testing using the protocol approved in K981168 will be completed prior to marketing. (This is a future action, not a completed criterion at the time of submission, but indicates a planned acceptance criterion). |
2. Sample Size Used for the Test Set and Data Provenance
- Nonclinical/Toxicology Studies:
- Cytotoxicity: Not specified, but involved comparisons between new COMPLETE®, old COMPLETE®, ReNu MultiPlus, and BAK.
- Sensitization: 25 female Hartley guinea pigs.
- Acute Oral Toxicity: 40 (20 male and 20 female) CD albino rats.
- 28-Day Ocular Safety Study: 12 female New Zealand white rabbits.
- Clinical Study (referenced from K981168, used for multi-purpose solution):
- Total subjects: 124
- Investigational MPS group: 62 (2 disqualified, leaving 60 evaluable)
- Control (COMPLETE® MPS) group: 62 evaluable
- Data Provenance: The animal studies were conducted in rabbits, guinea pigs, and rats. The clinical study was conducted with human subjects. The country of origin is not specified but implicitly in the USA as it's an FDA submission. The clinical study was prospective, as it involved enrolling subjects and following them. The animal studies are also implicitly prospective evaluations.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
There is no mention of "experts" establishing a ground truth in the context of diagnostic performance for this device. This product is a lens care solution, not a diagnostic tool requiring expert interpretation of results. The "ground truth" for safety and performance comes from direct observation (e.g., ocular irritation, cell survival, animal health) and clinical findings by investigators.
4. Adjudication Method for the Test Set
Not applicable. This is not a diagnostic device with ambiguous readings requiring adjudication. Clinical observations and measurements were performed and analyzed statistically.
5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study Was Done, If So, What Was the Effect Size of How Much Human Readers Improve with AI vs Without AI Assistance
Not applicable. This is not a diagnostic device or an AI-assisted interpretation system.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
Not applicable. This is not a software algorithm; it's a physical product (liquid solution).
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
The "ground truth" for the device's performance is based on a combination of:
- Microbiological assays: Meeting established USP modified criteria and test requirements.
- Cell cultures: Direct observation of cell survival and neutral red retention.
- Animal models: Direct observation of dermal reactions, survival rates, detailed ocular examinations (pachometry, slit lamp, ophthalmoscopy), and histopathological evaluations. These are considered direct evidence of physiological response to the product.
- Clinical observations: Direct observation of adverse events, slit lamp findings, and patient-reported symptoms of discomfort by clinical investigators. These are considered outcomes data relevant to the product's safe use and patient acceptability.
8. The Sample Size for the Training Set
Not applicable. This product does not involve machine learning or AI, so there is no "training set."
9. How the Ground Truth for the Training Set Was Established
Not applicable. There is no training set for this device.
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(153 days)
COMPLETE BRAND MULTI-PURPOSE SOLUTION, COMPLETE BRAND LUBRICATING AND REWETTING DROPS
COMPLETE® brand Multi-Purpose Solution is indicated for use in the chemical (NOT HEAT) disinfection, cleaning, rinsing, protein removal and storing of soft (hydrophilic) contact lenses as recommended by your eye care practitioner.
COMPLETE® brand Multi-Purpose Solution is a sterile, isotonic, buffered, preserved solution. This aqueous formulation includes purified water, sodium chloride, hydroxypropyl methylcellulose as a lubricant, preserved with polyhexamethylene biguanide 0.0001%, Poloxamer 237 as a surfactant, a phosphate buffer, and edetate disodium as a chelating agent. This preparation contains no chlorhexidine, no thimerosal and no other mercury containing ingredients. Both current and reformulated products are clear, colorless solutions packaged in plastic bottles with controlled dropper tips.
The provided document is a 510(k) summary for a contact lens solution, not an AI device. Therefore, many of the requested criteria, such as "multi reader multi case (MRMC) comparative effectiveness study," "standalone (i.e. algorithm only) performance," "sample size for the training set," and "number of experts used to establish the ground truth," are not applicable.
However, I can extract the relevant acceptance criteria and study information for the COMPLETE® brand Multi-Purpose Solution (Revised) as presented in the document.
Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Reported Device Performance |
---|---|
Solution Compatibility & Cleaning Effectiveness | Product is compatible with and an effective cleaner for all soft (hydrophilic) contact lenses. |
Critical Micelle Concentration of Poloxamer 237 | Aggregation concentration range reached at a concentration >0.01% (well below product amount). Surface tension ~45 dynes/cm (in range of current and competitor products). |
Passive Protein Cleaning | Both current and proposed COMPLETE® formulation have significantly (2.8 times) better passive protein cleaning ability than the competitive product (compared to a competitive product). |
Microbiological Efficacy (Disinfection) | Meets current FDA requirements for disinfection against bacteria, yeast, and mold. |
Microbiological Efficacy (Preservative Effectiveness) | Meets USP Modified criteria for Preservative Effectiveness Testing. |
Microbiological Efficacy (Sterility) | Meets USP Sterility test requirements. |
Cytotoxicity | New formulation compares favorably with the old formulation. |
Sensitization | No dermal reactions observed in either test or control groups; comparable to marketed formulation. |
Acute Oral Toxicity | Caused no adverse effects when administered to rats at a single oral dose. |
28-Day Ocular Safety Study | All animals remained healthy with no clinically significant ocular discomfort or conjunctival irritation. |
Stability | Accelerated testing predicts stability for at least 24 months. |
Clinical Safety (Adverse Device Effects) | No adverse device effects reported during the study. |
Clinical Safety (Slit Lamp Findings) | No statistically significant differences in the number of examinations with clinically significant slit lamp findings. |
Clinical Safety (Maximum Severity Grades) | Statistically significant differences in maximum severity grades for injection and tarsal anomaly, with more severe findings in the COMPLETE® MPS group than in the Investigational MPS group (Note: This refers to the predicate, not the new investigational product). |
Clinical Safety (Refraction, VA, Keratometry, Mire Distortion) | Incidence of clinically significant changes was similar for both groups, no findings directly attributed to study regimens. |
Clinical Acceptability (Discomfort Symptoms) | Statistically significant difference with higher maximum severity score for discomfort in the Investigational MPS group (Note: this is the new product). However, overall incidence was low, and severe symptoms not regimen related (not clinically relevant). No statistically significant difference in examinations with clinically significant ocular symptoms of discomfort. |
Clinical Acceptability (Average Lens Comfort Scores) | No statistically significant difference between Investigational MPS and COMPLETE® MPS. |
Clinical Acceptability (Lens Wearing Time) | No statistically significant difference between Investigational MPS and COMPLETE® MPS. |
Clinical Acceptability (Lens Cleanliness - Investigator Analysis) | No statistically significant difference between the groups. |
Clinical Acceptability (Lens Discoloration) | Low incidence of discoloration for untinted lenses in both groups; no discoloration of tinted lenses. |
Clinical Acceptability (Lens Fit & Replacement) | Lens fit well-maintained; unscheduled replacement similar between groups. |
Study Details (Non-Clinical and Clinical)
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Non-Clinical Studies: No specific sample sizes for each non-clinical test (e.g., solution compatibility, protein cleaning, microbiological, toxicology) are provided, only the results. The data provenance is not explicitly stated beyond "The product was tested with the same protocol used to test the prior (substantially equivalent) formulation."
- Clinical Study:
- Total Subjects Enrolled: 124 subjects
- Investigational MPS Group: 62 subjects (60 evaluable after disqualifications)
- COMPLETE® MPS Group (Predicate): 62 subjects (all evaluable)
- Data Provenance: Not specified (e.g., country of origin). A clinical study implies prospective data collection.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Non-Clinical: Not applicable in the context of expert consensus for ground truth as these are lab-based tests.
- Clinical: The clinical study involved "Six clinical investigators," but their specific qualifications or their role in establishing "ground truth" (beyond conducting the study and evaluating subjects) are not detailed.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable as this is a clinical trial for a contact lens solution, not an imaging device requiring expert adjudication for ground truth. The "adjudication" in this context would be the assessment of individual investigators.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Not applicable. This is not an AI device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. This is not an AI algorithm. The device itself (contact lens solution) is "standalone" in its function, but this term typically refers to AI performance.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Non-Clinical:
- Solution Compatibility & Cleaning, Protein Cleaning: Lab-based quantitative measurements of cleaning efficacy.
- Microbiological Studies: Adherence to established FDA guidelines (FDA's Premarket Notification [510(k)] Guidance Document for Contact Lens Care Products, USP Modified criteria).
- Toxicology: Observation of biological responses in animal models and in vitro tests (cytotoxicity, sensitization, oral toxicity, ocular safety).
- Stability: Accelerated aging tests to predict shelf-life.
- Clinical:
- Safety Data: Clinical observations and measurements by investigators (slit lamp findings, visual acuity, refraction, keratometry, mire distortion) and reported adverse events.
- Acceptability Data: Clinical observations and measurements by investigators (lens cleanliness, fit, discoloration, wearing time) and subjective symptom reporting by subjects (comfort, discomfort).
8. The sample size for the training set
- Not applicable as this is not an AI algorithm requiring a training set.
9. How the ground truth for the training set was established
- Not applicable as this is not an AI algorithm.
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