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CPG Sec. 345.300 Menstrual Sponges

FinalCenter for Devices and Radiological Health Office of Regulatory Affairs03/01/1995
Stability studies

Description

Natural sea sponges have been promoted as "menstrual sponges," "hygienic sponges," and "sanitary sponges" for use as menstrual tampons. Public interest in these products has grown since the publicity associating toxic shock syndrome with the use of menstrual tampons.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

4
Dura Substitute Devices

Subject of the guidance document; Information about the product structure is critical in determining equivalence

Medical Devices

Medical devices intended for human use; Approved or cleared medical devices

Class II Device

Devices subject to section 522 postmarket surveillance orders; devices subject to postmarket surveillance orders

dura substitutes

Information about the product structure is critical in determining equivalence

Stakeholders

1
Division of Small Manufacturers Assistance

Entity providing guidance documents upon request

Regulatory Context

Regulatory Activities

2
510(k)

Premarket notification submission type

multicenter clinical trial

clinical data for dura substitutes composed of material not previously used

Document Types

5
Master File

Documentation artifact related to NDI notifications

intended use statement

Document element that should include specific indications and target populations

Certificate of Analysis

Document indicating analytical results of testing; record relied on to control L. monocytogenes in ingredients; document provided for a food prior to or upon receipt of the food; COA documentation

Materials Safety Data Sheet

Information on material components

case report forms

MDS-specific information should be documented and collected on the case report forms

Attributes

2
Substantial Equivalence

Standard for 510(k) clearance

expiration date

Required label element for outsourcing facilities

Technical Details

Substances

6
Lyophilized Human Dura Mater

Regulated as medical devices, distinct from synthetic dura substitutes.

Bovine Pericardium

Alternative material to human dura

Silicone

primary material of menstrual cups

Synthetic Bioabsorbable Polymer Sheets

Alternative material to human dura

Synthetic Cellulose

Alternative material to human dura

Ethylene Oxide

sterilization facilities that use a gas called ethylene oxide (EtO) to sterilize medical devices; Common method of terminal sterilization of medical devices; sterilization facility change involving EtO; Sterilant used in the manufacturing process

Testing Methods

6
Intracranial Implantation

Used to assess irritation for EtO sterilized devices

Pyrogenicity testing

Used to protect patients from febrile reactions

scanning electron microscopy

used to evaluate surface structure

cytotoxicity

subsequent assessment is not necessary for cytotoxicity

genotoxicity

includes bacterial reverse mutation assay

carcinogenicity studies

rodent carcinogenicity studies

Processes

2
Sterilization

Required for contaminated equipment and media before disposal

implantation studies

The device should be evaluated by conducting implantation studies at the intended anatomic site

Clinical Concepts

3
adverse events

Safety events that must be tracked for different updates

target populations

Specific patient groups to be identified in labeling

indications for use

Specific clinical uses to be included in the intended use statement

Identified Hazards

Hazards

2
BSE

hazard associated with animal food facilities

Viral Safety

Addressed in ICH Q5A (R2)

Standards & References

External Standards

3
AAMI TIR-19

Standard for ethylene oxide sterilization residuals

USP

United States Pharmacopeia standards for compendial drug substances; confirming conformance to the application-approved specification and USP

ASTM

International standards development organization cited for scientific standards

Specifications

2
Sterility Assurance Level

Sterility Assurance Level (SAL) stated

final product release specifications

Examples include device thickness, pore size, and residual levels of manufacturing reagents

ICH References (1)

ICH Q5A

Viral Safety Evaluation of Biotechnology Products Derived From Cell Lines of Human or Animal Origin

Related CFR Sections (2)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Misbranding under Section 502(c) for Failure to Have Compliant Labeling
1
Misbranding under Section 502(t)(2) for Failure to Submit Required Information to GUDID
1

Related Warning Letters (1)

See Also (8)