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510(k) Data Aggregation

    K Number
    K203818
    Date Cleared
    2021-06-11

    (164 days)

    Product Code
    Regulation Number
    884.5300
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Replens Long-Lasting Vaginal Moisturizer

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Replens Long-Lasting Vaginal Moisturizer is a personal lubricant for vaginal application, intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and to 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

    Replens Long-Lasting Vaginal Moisturizer is a personal lubricant that is non-sterile, water-based, and provides lubrication during intimate sexual activity. It is a smooth, white, homogenous vaginal gel packaged with a reusable applicator. This device is compatible with natural rubber latex and polyisoprene condoms and is not compatible with polyurethane condoms. Its formulation consists of Water, Glycerin, Mineral Oil, Polycarbophil, Carbomer Homopolymer Type B, Hydrogenated Palm Oil Glyceride, Sorbic Acid, Benzyl Alcohol, Ethylhexylglycerin, tocopherol, and Sodium Hydroxide. Replens Long-Lasting Vaginal Moisturizer is packaged in a 35g aluminum tube (14 applications), with a reusable two-piece, blue translucent, polyethylene applicator designed to dispense 2.5g of lubricant.

    The reusable applicator is packaged with an over-wrap in clear, biaxially oriented polypropylene film. The subject device and applicator are packaged together in a carton with a consumer leaflet.

    AI/ML Overview

    The provided document is a 510(k) Pre-market Notification from the FDA regarding a medical device, the Replens Long-Lasting Vaginal Moisturizer. This document focuses on demonstrating substantial equivalence to a previously cleared predicate device, rather than proving that the device meets specific acceptance criteria through a clinical study with a test set, expert ground truth, or MRMC studies.

    Therefore, many of the requested details about acceptance criteria, study design, and performance metrics (like sensitivity, specificity, or reader improvement) are not applicable to this type of regulatory submission. The goal here is to show that the new device is as safe and effective as the predicate device, primarily through non-clinical performance testing and comparison of technological characteristics.

    However, I can extract information related to what is presented as "acceptance criteria" in the context of this submission, which are primarily product specifications and performance testing results.

    Here's a breakdown of the requested information based on the provided document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document presents product specifications as the "acceptance criteria" for the device itself, rather than acceptance criteria for a diagnostic algorithm's performance. The "reported device performance" is essentially that the device meets these specifications.

    PropertyAcceptance Criteria (Specification)Reported Device Performance (Implied by "demonstrated that the device can maintain its specifications")
    AppearanceWhite to off-white smooth homogenous gelMet
    OdorOdorlessMet
    Viscosity30,000 - 130,000 cPsMet
    pH2.5 - 3.5Met
    Osmolality1200 - 2000 mOsm/KgMet
    Total Aerobic Microbial Count (TAMC)
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    K Number
    K101241
    Date Cleared
    2010-08-17

    (105 days)

    Product Code
    Regulation Number
    884.5300
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    REPLENS LONG-LASTING VAGINAL MOISTURIZER (PRE-FILLED APPLICATOR)

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Replens is a personal lubricant for 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 condoms and synthetic (polyurethane and polyisoprene) condoms.

    Device Description

    Replens Vaginal Moisturizer is a non-sterile, water-based, white to off-white, non-irritating, non-greasy, non-staining vaginal gel delivered in single-use, pre-filled applicators as a long-lasting moisturizer for vaginal dryness. The use of prefilled applicators provides less mess in application. Replens Vaginal Moisturizer is intended for ongoing use, not exclusively for use during intimate sexual activity.

    AI/ML Overview

    The provided document is a 510(k) Summary for Replens Long-Lasting Vaginal Moisturizer (in pre-filled applicators). It primarily focuses on demonstrating substantial equivalence to a predicate device for regulatory clearance rather than establishing a new device's performance against explicit acceptance criteria in a typical clinical study format for novel devices.

    Therefore, the requested information, particularly regarding specific acceptance criteria, comprehensive effect sizes, and detailed ground truth establishment methods for a standalone AI algorithm, is largely not applicable or not explicitly stated in this type of regulatory submission. The document outlines safety and performance data in relation to its intended use and comparison to a predicate device.

    However, I can extract and infer some information based on what is provided:

    1. Table of Acceptance Criteria and Reported Device Performance

    As this is a 510(k) for a personal lubricant, the "acceptance criteria" are generally tied to demonstrating safety, intended use (moisturizing and lubrication), and compatibility with condoms, rather than a quantifiable performance metric (like accuracy or sensitivity) typically seen in AI or diagnostic devices. The acceptance is implied by successfully passing various tests.

    Acceptance Criteria (Inferred from testing)Reported Device Performance
    Biocompatibility:Passed:
    Cytotoxicity-
    Acute Vaginal Irritation-
    Subacute Vaginal Irritation-
    Subacute Vaginal Irritation with Histological Examination-
    Acute Systemic Toxicity-
    Hypersensitivity-
    Acute Oral Toxicity-
    Acute Dermal Toxicity-
    Dermal Irritation-
    Eye Irritation-
    Clinical Efficacy/Safety:Concluded safe and well-tolerated and provided relief of symptoms: (Based on multiple clinical studies; specific metrics not detailed as acceptance criteria)
    Influence on vaginal pHStudies observed influence on vaginal pH, but specific target range for "acceptance" is not defined.
    Influence on vaginal mucosaStudies observed influence on vaginal mucosa.
    Relief of patient's symptoms (e.g., vaginal dryness)Studies reported relief of patient's symptoms.
    Vaginal dryness indexStudies utilized vaginal dryness index.
    Stability (Shelf life)Confirmed: One (1) year shelf life.
    Preservative Effectiveness (against microbial growth)Successfully passed: USP \ Antimicrobial Effectiveness Test requirements.
    Dosing Consistency (applicator delivers required amount)Confirmed: Prefilled applicator delivers the required amount of gel.
    Condom Compatibility (strength/integrity of latex/synthetic condoms)Confirmed: Does not materially affect the strength or integrity of natural rubber latex or synthetic (polyurethane and polyisoprene) condoms.
    Substantial Equivalence to Predicate Device (Intended Use, Formulation, Safety, Technological Characteristics)Concluded as substantially equivalent.

    2. Sample Sizes and Data Provenance for Test Set (Clinical Studies)

    The "test set" in this context refers to the clinical studies used to support the safety and efficacy of the Replens device.

    • Whitehead (1991): 32 patients enrolled (Replens group)
    • Nachtigall (1994): 15 patients enrolled
    • Gelfand and Wendman (1994): 25 patients enrolled
    • Bachmann et al. (1991): 89 patients enrolled (Replens group)
    • Bachmann et al. (1992): 54 patients enrolled
    • Zinny and Lee (1991): 26 patients enrolled
    • Young et al. (1991): 30 patients enrolled
    • Nakamura (1991): 10 patients enrolled

    Data Provenance: The document does not explicitly state the country of origin for each study. However, authors like Bachmann, Nachtigall, Gelfand, and Wendman are typically associated with studies conducted in North America (primarily the US). Retrospective or Prospective: The study designs (double-blind, cross-over, open, parallel) indicate these were prospective clinical trials.

    3. Number of Experts and Qualifications for Ground Truth

    This information is not provided in the summary. For a medical device like Replens, "ground truth" would be established through patient-reported outcomes, clinical assessments (e.g., pH measurements, vaginal dryness index assessment by a clinician), and potentially histological examination (as mentioned for subacute vaginal irritation). The specific number and qualifications of experts involved in these assessments are not detailed.

    4. Adjudication Method for the Test Set

    This information is not provided. Clinical studies typically have methods for assessing patient outcomes and safety events, but a specific "adjudication method" in the context of diagnostic agreement (like for imaging AI) is not relevant or described here.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No, an MRMC comparative effectiveness study was not performed as this device is a personal lubricant, not an AI diagnostic tool. The concept of "human readers improving with AI vs. without AI assistance" is not applicable here.

    6. Standalone Performance Study

    Yes, the clinical studies listed (Bachmann et al., Nachtigall, Gelfand and Wendman, Zinny and Lee, Young et al., Nakamura) represent standalone performance studies for the Replens device. They assess its effects, safety, and patient-reported outcomes without "human-in-the-loop" interaction in the sense of an AI algorithm enhancing human decision-making.

    7. Type of Ground Truth Used

    The ground truth used in the clinical studies for Replens appears to be a combination of:

    • Clinical Assessments: Vaginal pH determination, vaginal mucosa observations, vaginal dryness index.
    • Patient-Reported Outcomes: Relief of patient's symptoms (vaginal dryness), completion of diary cards.
    • Pathology: Histological examination (for subacute vaginal irritation testing).
    • Safety Data: Adverse event reporting and tolerability assessments.

    8. Sample Size for the Training Set

    This information is not applicable. Replens is a medical device (personal lubricant), not an AI algorithm. Therefore, there is no "training set" in the context of machine learning. The clinical studies mentioned serve as the evidence base for its safety and efficacy.

    9. How the Ground Truth for the Training Set Was Established

    This information is not applicable as there is no training set for an AI algorithm.

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    K Number
    K101098
    Date Cleared
    2010-08-17

    (119 days)

    Product Code
    Regulation Number
    884.5300
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    REPLENS LONG-LASTING VAGINAL MOISTURIZER (35G TUBE WITH REUSABLE APPLICATOR) MODEL: 83035

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Replens is a personal lubricant for 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 condoms and synthetic (polyurethane and polyisoprene) condoms.

    Device Description

    Replens Vaqinal Moisturizer is a non-sterile, water-based, white to off-white, non-irritating, non-greasy, non-staining vaginal gel delivered in a tube with a reusable applicator as a long-lasting moisturizer for vaginal dryness. The use of the reusable applicator provides less mess in application. Replens Vaginal Moisturizer is intended for ongoing use, not exclusively for use during intimate sexual activity.

    Replens Vaginal Moisturizer contains ingredients commonly used in other products for vaginal use sold as medical devices and cosmetics. All ingredients are either NF, USP, or are considered "generally recognized as safe for their intended use". The quantitative formulation is considered confidential commercial information.

    AI/ML Overview

    The Replens Vaginal Moisturizer, a personal lubricant for vaginal application, underwent various tests and clinical studies to demonstrate its safety and effectiveness. The acceptance criteria and performance data are summarized below.

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific Test/ParameterAcceptance Criteria (Implicit)Reported Device Performance
    BiocompatibilityCytotoxicityNo significant cytotoxic effects.Biocompatibility testing performed, implying acceptable results (specific results not detailed, but submission indicates compliance).
    Acute Vaginal IrritationNo significant acute irritation.Biocompatibility testing performed, implying acceptable results.
    Subacute Vaginal IrritationNo significant subacute irritation.Biocompatibility testing performed, implying acceptable results.
    Subacute Vaginal Irritation with Histological ExaminationNo significant subacute irritation or adverse histological changes.Biocompatibility testing performed, implying acceptable results.
    Acute Systemic ToxicityNo significant acute systemic toxicity.Biocompatibility testing performed, implying acceptable results.
    HypersensitivityNo significant hypersensitivity reactions.Biocompatibility testing performed, implying acceptable results.
    Acute Oral ToxicityNo significant acute oral toxicity.Biocompatibility testing performed, implying acceptable results.
    Acute Dermal ToxicityNo significant acute dermal toxicity.Biocompatibility testing performed, implying acceptable results.
    Dermal IrritationNo significant dermal irritation.Biocompatibility testing performed, implying acceptable results.
    Eye IrritationNo significant eye irritation.Biocompatibility testing performed, implying acceptable results.
    Clinical Efficacy & SafetyVaginal pHMaintain a healthy vaginal pH or normalize altered pH associated with vaginal dryness.Studies evaluated the influence of Replens on vaginal pH. One study specifically compared effects on vaginal pH in postmenopausal women. The collective conclusion was that Replens was "safe and well-tolerated."
    Vaginal MucosaImprove the condition of the vaginal mucosa.Studies evaluated the influence of Replens on the vaginal mucosa. The collective conclusion was that Replens was "safe and well-tolerated."
    Symptom ReliefProvide relief for symptoms of vaginal dryness.Clinical studies documented "relief of the patient's symptoms" and improvement in the "vaginal dryness index." The collective conclusion was that Replens was "safe and well-tolerated."
    Safety & TolerabilityNo significant adverse events or poor tolerability.All clinical studies concluded that Replens was "safe and well-tolerated."
    Product StabilityShelf LifeMaintain product integrity and effectiveness for the specified shelf life.Real-time stability data confirmed a shelf life of three (3) years.
    Microbial ControlPreservative EffectivenessMeet USP Antimicrobial Effectiveness Test requirements.Successfully passed the requirements of the USP Antimicrobial Effectiveness Test.
    Condom CompatibilityCondom Strength/IntegrityNot materially affect the strength or integrity of natural rubber latex condoms and synthetic (polyurethane and polyisoprene) condoms.Condom compatibility testing confirmed that Replens Long-Lasting Vaginal Moisturizer does not materially affect the strength or integrity of natural rubber latex or synthetic condoms (polyurethane and polyisoprene).

    2. Sample Size Used for the Test Set and Data Provenance

    The document refers to a series of eight clinical studies as the "test set" for Replens Long-Lasting Vaginal Moisturizer.

    • Sample Sizes: The number of patients enrolled in the Replens arm across these studies varied:
      • Bachmann et al (1991): 89 patients
      • Bachmann et al (1992): 54 patients
      • Zinny and Lee (1991): 26 patients
      • Young et al (1991): 30 patients
      • Nakamura (1991): 10 patients
      • Whitehead (1991): 32 patients
      • Nachtigall (1994): 15 patients
      • Gelfand and Wendman (1994): 25 patients
    • Data Provenance: The provenance of the data is not explicitly stated in terms of country of origin but is indicated by the publication of several studies in peer-reviewed journals (e.g., Clinical Practice in Sexuality, Today's Therapeutic Trends, Fertility and Sterility, J. Women's Health). Some studies were "Unpublished." The studies appear to be prospective clinical trials given their design (e.g., double-blind, cross-over, open-label) and specific dosage regimens and durations.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    The concept of "ground truth" established by experts, as typically understood in the context of AI/ML device performance evaluation, is not directly applicable to this submission. This is a 510(k) for a medical device (vaginal moisturizer), not an AI/ML algorithm.

    The "ground truth" for the clinical efficacy and safety was established:

    • Clinically by the direct observation, assessment (e.g., vaginal pH, vaginal dryness index), and reported symptoms of the patients participating in the clinical trials.
    • Statistically by the analysis of these clinical outcomes by the researchers who conducted and published these studies.
    • Biologically through the results of the various biocompatibility tests.

    The "experts" involved would be the clinical investigators (physicians, researchers) who designed and executed these studies, interpreted the data, and published the findings. Their qualifications are not explicitly detailed but are implied by their authorship in scientific papers.

    4. Adjudication Method for the Test Set

    Adjudication methods (like 2+1, 3+1) are typically used in AI/ML studies to resolve discrepancies in expert labeling or diagnoses. This concept is not applicable to this 510(k) submission as it is not for an AI/ML device. The clinical studies followed standard trial protocols for data collection and analysis, which inherently include methods for managing and interpreting patient data and outcomes. For double-blind studies, the blinding helps ensure impartial assessment.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No Multi-Reader Multi-Case (MRMC) comparative effectiveness study was mentioned. This type of study comparing human readers with and without AI assistance is specific to AI/ML devices and is not relevant to this product submission.

    6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

    No standalone (algorithm only) performance study was conducted or is relevant. This device is a topical moisturizer, not an AI algorithm.

    7. Type of Ground Truth Used

    The "ground truth" for this device's performance was based on:

    • Clinical Endpoints: Patient-reported symptoms (e.g., relief of vaginal dryness), objective clinical measurements (e.g., vaginal pH, vaginal dryness index), and physician assessments of the vaginal mucosa.
    • Biocompatibility Standards: Pre-defined safety standards for cytotoxicity, irritation, sensitization, and toxicity.
    • Physical/Chemical Testing: Laboratory assessments for stability, preservative effectiveness, and condom compatibility.

    8. Sample Size for the Training Set

    The concept of a "training set" is specific to AI/ML models. This device is a traditional medical product (vaginal moisturizer), not an AI/ML algorithm. Therefore, there is no training set in the AI/ML sense. The product development and testing relied on chemical formulation, manufacturing best practices, and the clinical and non-clinical studies summarized.

    9. How the Ground Truth for the Training Set Was Established

    As there is no training set for an AI/ML algorithm, this question is not applicable.

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