Boston SIMPLUS Multi-Action Solution is indicated for use in cleaning, removing protein, rinsing, disinfecting, conditioning, storing and cushioning fluoro silicone acrylate and silicone acrylate rigid gas permeable contact lenses.
Device Story
Boston SIMPLUS Multi-Action Solution is a sterile, aqueous, buffered chemical solution for rigid gas permeable (RGP) contact lens care. It contains surfactants (poloxamine), chelating/cleaning agents (hydroxyalkylphosphonate), buffers (boric acid, sodium borate), tonicity agents (sodium chloride), and lubricants (hydroxypropylmethyl cellulose, Glucam), preserved with chlorhexidine gluconate and polyaminopropyl biguanide. The solution is used by patients at home to clean, disinfect, and condition lenses. The user applies the solution to the lens surface to remove protein and lipid deposits, disinfect, and store the lenses. The solution acts as a chemical cleaner and disinfectant, ensuring lens surface cleanliness and physiological compatibility for the wearer. It replaces multi-step regimens with a single-solution process, simplifying maintenance for RGP lens wearers and improving compliance.
Clinical Evidence
Multi-site randomized, controlled clinical study comparing Boston SIMPLUS to Boston Simplicity. Patients used lenses on a daily wear basis. Endpoints included visual acuity, lens surface characteristics, and physiological response. Safety endpoint: no statistically significant difference in Grade 2 or greater slit lamp findings. Efficacy endpoint: statistical equivalence in proportion of visual acuities 20/40 or better. Results demonstrated clinically acceptable lens cleanliness and safety equivalent to the predicate.
Technological Characteristics
Sterile, aqueous, buffered solution. Ingredients: poloxamine, hydroxyalkylphosphonate, boric acid, sodium borate, sodium chloride, hydroxypropylmethyl cellulose, Glucam. Preservatives: chlorhexidine gluconate (0.003%), polyaminopropyl biguanide (0.0005%). Packaging: plastic bottles. Testing performed per ISO 10993-5 (cytotoxicity) and ISO 10993-10 (irritation/sensitization).
Indications for Use
Indicated for cleaning, protein removal, rinsing, disinfecting, conditioning, storing, and cushioning of fluoro silicone acrylate and silicone acrylate rigid gas permeable contact lenses for daily wear users.
Regulatory Classification
Identification
A rigid gas permeable contact lens care product is a device intended for use in the cleaning, conditioning, rinsing, lubricating/rewetting, or storing of a rigid gas permeable contact lens. This includes all solutions and tablets used together with rigid gas permeable contact lenses.
Special Controls
*Classification.* Class II (Special Controls) Guidance Document: “Guidance for Industry Premarket Notification (510(k)) Guidance Document for Contact Lens Care Products.”
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K024289
# 510 (k) SUMMARY SUMMARY OF SAFETY AND EFFECTIVENESS
## FOR
## Boston SIMPLUS Multi-Action Solution
#### Submitter Information 1.
Polymer Technology A Bausch & Lomb company 1400 North Goodman Street Rochester, New York 14609
| Contact Person: | Jennifer B. Murray |
|-----------------|---------------------------|
| | Global Regulatory Affairs |
Telephone Number: 585-338-8460
#### 2. Device Name
Classification Name: Rigid Gas Permeable Contact Lens Care Product
Proprietary Name: Boston® SIMPLUS Multi-Action Solution
#### 3. Predicate Devices
Boston Simplicity® Multi-Action Solution, Bausch & Lomb ReNu MultiPlus® Multi-Purpose Solution and Alcon Unique pH were selected as the predicate devices for Boston SIMPLUS Multi-Action Solution.
#### 4. Description of the Device
Boston SIMPLUS Multi-Action Solution is a sterile, aqueous, buffered solution that contains poloxamine, hydroxyalkylphosphonate, boric acid, sodium borate, sodium chloride, hydroxypropylmethyl cellulose, Glucam and preserved with chlorhexidine gluconate (0.003%), polyaminopropyl biguanide (0.0005%).
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#### ર્ડ Indications for Use
Boston SIMPLUS Multi-Action Solution is for cleaning, removing protein, rinsing, disinfecting, conditioning, storing and cushioning fluoro silicone acrylate and silicone acrylate rigid gas permeable contact lenses.
#### Description of Safety and Substantial Equivalence 6.
A series of preclinical and clinical studies were completed on Boston SIMPLUS Multi-Action Solution. The results indicate that this product is safe, efficacious, and substantially equivalent to the predicate devices identified in Section 3 of this summary.
Toxicology
A series of in-vitro biological reactivity test were performed to determine the toxicity of Boston SIMPLUS Multi-Action Solution.
ISO Agarose Overlay Tests of Boston SIMPLUS Multi-Action Solution, Fluoro Silicone Acrylate Lenses Cycled in Boston SIMPLUS Multi-Action Solution and Silicone Acrylate Lenses Cycled in Boston SIMPLUS Multi-Action Solution were conducted in accordance with the requirements of ISO 10993-5. The negative and positive controls performed as anticipated. The test articles demonstrated no evidence of cell lysis. All test requirements were met.
ISO Ocular Irritation Tests of Boston SIMPLUS Multi-Action Solution, extracts of fluoro silicone acrylate lenses cycled in Boston SIMPLUS Multi-Action Solution and extracts of silicone acrylate lenses cycled in Boston SIMPLUS Multi-Action Solution were conducted in accordance with the requirements of ISO 10993; Biological Evaluation of Medical Devices, Part 10: Tests for Irritation and Sensitization. The test solution did not produce significant ocular irritation. All test requirements were met.
The results of these tests demonstrate that the product is not toxic.
## Stability/Sterility
Stability studies were performed to evaluate the effects of various temperatures on the physical, microbiological and chemical properties of various lots of Boston SIMPLUS Multi-Action Solution. These studies are on-going. To date, all data indicates that the test product meets its specifications.
## Cleaning Studies
The cleaning efficacy of Boston SIMPLUS Multi-Action Solution was determined by a series of in-vitro studies. In addition, the returned clinical lenses were evaluated for cleanliness.
The Critical Micelle Concentration of the surfactant in Boston SIMPLUS Multi-Action Solution was evaluated and found acceptable.
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Testing was performed to determine the cleaning ability of Boston SIMPLUS Multi-Action Solution on rigid gas permeable contact lenses. The first model employed a protein and lipid mixture deposition. The results of this model indicate that the test solution cleans equivalently to or better than the positive and negative controls. A second model employed a tenacious deposition of protein. The results of this model indicate that the test solution cleans better than the positive and negative controls.
Lens compatibility studies were performed to determine the average changes observed in the physical lens parameters of rigid gas permeable contact lenses when subjected to repeated cleaning cycles with Boston SIMPLUS Multi-Action Solution. The physical lens parameters tested within the specifications. The cosmetic appearance of both lens materials tested equivalent to their respected controls.
Lenses returned from the clinical study that were used with either the Test (Boston SIMPLUS Multi-Action Solution) or Control (Boston Simplicity Multi-Action Solution) regimens have been examined by Image Analysis for lens cleanliness and found to be substantially equivalent.
### Microbiology Studies
A series of studies as provided in the Premarket Notification (510(k)) Guidance Document for Contact Lens Care Products were completed to demonstrate the microbiological efficacy of Boston SIMPLUS Multi-Action Solution.
Microbiology testing included Preservative Efficacy with Rechallenge. Disinfection Efficacy-Stand Alone, Disinfection Efficacy-Stand Alone with Organic Soil and a Regimen Test. All results are satisfactory and indicate that the product meets FDA/ISO requirements.
### Clinical Studies
A multi-site randomized, controlled clinical study was conducted to evaluate the safery and efficacy of Boston SIMPLUS Multi-Action Solution employing a regimen that requires the user to rub lenses after the disinfection cycle. The Control solution was Boston Simplicity Multi-Action Solution traditional rub and rinse steps.
Patients were instructed to wear their lenses on a daily wear basis with no scheduled replacements and to clean and disinfect them in accordance with the provided directions for use. Evaluations included visual acuity, lens surface characteristics, and physiological response. The safety endpoint of no statistically significant difference in the incidence rate of any Grade 2 or greater slit lamp findings between the Test and Control was satisfied. The efficacy endpoint of statistical equivalence in the proportion of lens visual acuities at the level of 20/40 or better was met.
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Both solutions demonstrated clinically acceptable lens cleanliness. Safety and efficacy were demonstrated. Boston SIMPLUS Multi-Action Solution is substantially equivalent to Boston Simplicity Multi-Action Solution.
## Substantial Equivalence
Boston SIMPLUS Multi-Action Solution for use with rigid gas permeable contact lenses is substantially equivalent to Boston Simplicity Multi-Action Solution, Bausch & Lomb ReNu Multi-Purpose Solution and Alcon Unique pH Solution.
Boston SIMPLUS Multi-Action Solution will be sold in plastic bottles as a sterile solution; each bottle will be marked by a lot number and expiration date.
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Image /page/4/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is an abstract image of an eagle.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
MAY - 2 2003
Bausch & Lomb Incorporated c/o Jennifer B. Murray Associate Manager 1400 N. Goodman Street Rochester, NY 14609
Re: K024289
Trade/Device Name: Boston SIMPLUS Multi-Action Solution Regulation Number: 21 CFR 886.5918 Regulation Name: Rigid gas permeable contact lens care products Regulatory Class: Class II Product Code: MRC Dated: April 21, 2003 Received: April 22, 2003
Dear Ms. Murray:
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. 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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such 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.
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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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### Page 2 - Jennifer B. Murray
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (301) 594-4613. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html
Sincerely yours,
A. helyi kirendbal
A. Ralph Rosenthal, M.D. Director Division of Ophthalmic and Ear, Nose and Throat Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Polymer Technology a Bausch & Lomb company 1400 North Goodman Street Rochester, NY 14609
## Indications for Use Statement
510(k) Number (if known): K024289
Device Name: Boston® SIMPLUS Multi-Action Solution
Indications for Use:
Boston SIMPLUS Multi-Action Solution is indicated for use in cleaning, removing protein, rinsing, disinfecting, conditioning, storing and cushioning fluoro silicone acrylate and silicone acrylate rigid gas permeable contact lenses.
# (PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use __
OR
Over-The-Counter-Use
(Division Sign-Off) Division of Ophthalmic Ear, Nose and Throat Devises
April
510(k) Number K024289
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.