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510(k) Data Aggregation

    K Number
    K152646
    Date Cleared
    2016-03-11

    (177 days)

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

    Sylk Personal Lubricant is intended 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 and polyisoprene condoms and polyurethane condoms.

    Sylk Personal Lubricant is intended 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, polyurethane and polyisoprene condoms.

    Device Description

    Sylk Personal Lubricant is formulated to be a non-sterile, non-greasy, non-sticky, non-staining, viscous liquid. The device is not a contraceptive and does not contain a spermicide. This device is packaged in 3 ounce tubes. The specifications for the Sylk Personal Lubricant include appearance, odor, pH, viscosity, osmolality, antimicrobial effectiveness, total microbial count, total yeast and mold count, and absence of pathogenic organisms.

    AI/ML Overview

    The document provided describes the Sylk Personal Lubricant, a device regulated under 21 CFR 884.5300 as a Class II product with the classification name "Condom" and product code NUC. The device is intended for vaginal application to moisturize and lubricate, enhancing the ease and comfort of intimate sexual activity and supplementing natural lubrication. It is also compatible with natural rubber latex, polyisoprene, and polyurethane condoms.

    The document does not describe an AI/ML-driven device or a study involving human readers or comparative effectiveness for an AI system. It details the performance testing for a personal lubricant to demonstrate its safety and effectiveness, and substantial equivalence to a predicate device (K124044 - Aloe Cadabra® Personal Lubricant). Therefore, many of the requested elements for an AI study (such as MRMC studies, training set details, expert ground truth establishment, etc.) are not applicable to this document.

    However, based on the information provided, here's a breakdown of the acceptance criteria and the studies performed for the Sylk Personal Lubricant:


    1. Table of Acceptance Criteria and Reported Device Performance

    Since this is not an AI/ML device, the "acceptance criteria" here refer to the successful completion of specific biocompatibility and compatibility tests according to established standards. The "reported device performance" refers to the results of these tests confirming the device meets those standards.

    Acceptance Criterion (Standard Met)Reported Device Performance
    Biocompatibility - Cytotoxicity (ISO 10993-5: 2009, MEM Elution Test)All test method acceptance criteria were met. All results passed from full strength to 1:16 dilution. The product did not demonstrate cytotoxicity.
    Biocompatibility - Vaginal Irritation (ISO 10993-10: 2010)None of the control animals had a total score higher than 4 (indicating a valid test). The Irritant Rank Score was 0. Conclusion: Test article classified as a non-irritant.
    Biocompatibility - Acute Systemic Toxicity (ISO 10993-11: 2010)The polar extracts did not induce any toxic reaction in investigated mice within an observation period of 72 hours. The apolar extracts did not induce any toxic reaction in investigated mice within an observation period of 72 hours.
    Biocompatibility - Sensitization (Guinea Pig Maximization Test - GPMT) (ISO 10993-10: 2010)None of the control animals had a total score higher than 4 (indicating a valid test). The Irritant Rank Score was 0. Conclusion: Test article classified as a non-irritant.
    Condom Compatibility (ASTM D7661-10: Determining Compatibility of Personal Lubricants with Natural Rubber Latex Condoms)Results: Sylk Personal Lubricant was found to be compatible with Natural Rubber Latex, Polyisoprene, and Polyurethane condoms. The specific acceptance criteria within ASTM D7661-10 are not detailed, but the affirmative statement of compatibility implies successful adherence to the standard's requirements (e.g., no degradation of condom material beyond specified limits).
    Shelf LifeThe device maintains its specifications over the duration of its shelf life. Reported Shelf Life: 11 months.
    Device Specifications (Appearance, odor, pH, viscosity, osmolality, antimicrobial effectiveness, total microbial count, total yeast and mold count, absence of pathogenic organisms)The document states these specifications include these parameters, and implies they were met, as it concludes the device is safe and effective. However, the specific acceptance ranges/limits and exact performance values for these parameters are not explicitly provided in the summary.

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

    • Cytotoxicity (ISO 10993-5): Not explicitly stated, but typically involves cell monolayers in culture which are tested with extracts.
    • Vaginal Irritation (ISO 10993-10): "Control animals" are mentioned, suggesting an animal model. The exact number is not explicitly stated, but common protocols involve a specific number of animals (e.g., rabbits for irritation tests).
    • Acute Systemic Toxicity (ISO 10993-11): "Investigated mice" are mentioned. The exact number is not stated, but typically involves groups of mice assigned to control and test articles.
    • Guinea Pig Maximization Test (GPMT) (ISO 10993-10): "Control animals" are mentioned, implying a group of guinea pigs. The exact number is not explicitly stated.
    • Condom Compatibility (ASTM D7661-10): This standard typically requires a minimum number of condoms to be tested for various properties (e.g., burst pressure, volume). The exact sample size used is not specified in the document.
    • Shelf Life: "Real time aging studies" were performed. The sample size or exact protocol detail is not provided.
    • Data Provenance: The studies are described as performance data to support a 510(k) submission to the FDA. They were conducted according to ISO (International Organization for Standardization) and ASTM (American Society for Testing and Materials) standards. These are typically prospective studies performed in a controlled laboratory setting. The country of origin for the data is not specified, but given the US FDA submission, it is likely that the testing was performed by accredited labs, potentially in the US or internationally.

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

    Not applicable for this type of device and study. The "ground truth" for these performance tests is established by adhering to standardized international test protocols (ISO, ASTM) and observing physical/biological responses, not through expert consensus on images or diagnostic outcomes.


    4. Adjudication Method for the Test Set

    Not applicable for these types of performance tests. Adjudication methods like 2+1 or 3+1 are used in studies involving human interpretation or clinical endpoints subject to inter-observer variability. The biocompatibility and compatibility tests rely on objective measurements and observations against pre-defined criteria in the standards.


    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No, this was not done. MRMC studies are relevant for imaging diagnostics or other clinical decision-making support systems, typically involving human readers. This document describes the performance testing of a physical product (personal lubricant).


    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done

    Not applicable. This device is not an algorithm or an AI system.


    7. The Type of Ground Truth Used

    The "ground truth" for the device's performance in these studies is based on:

    • Standardized Test Methods and Criteria: Adherence to established ISO (e.g., ISO 10993 for biocompatibility) and ASTM (e.g., ASTM D7661 for condom compatibility) standards.
    • Objective Laboratory Observations and Measurements: Direct observation of cellular responses, animal reactions, or material properties (e.g., lack of cytotoxicity, absence of irritation, no toxic reactions, condom integrity).
    • Real-time Aging Data: For shelf-life, the ground truth is derived from the actual performance of the device over time in controlled conditions.

    8. The Sample Size for the Training Set

    Not applicable. This is not an AI/ML device that requires a training set.


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

    Not applicable. This is not an AI/ML device.

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