THERATEARS CONTACT LENS COMFORT DROPS

K032481 · Advanced Vision Research, Inc. · LPN · Nov 4, 2003 · Ophthalmic

Device Facts

• Record ID: K032481
• Device Name: THERATEARS CONTACT LENS COMFORT DROPS
• Applicant: Advanced Vision Research, Inc.
• Product Code: LPN · Ophthalmic
• Decision Date: Nov 4, 2003
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 886.5928
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

TheraTears Contact Lens Comfort Drops is indicated to lubricate and rewet soft (hydrophilic) and RGP* (rigid gas permeable) contact lenses, to help relieve dryness, discomfort and irritation that may be associated with lens wear and, to cushion lenses and ease insertion. * RGP lenses include silicone acrylate and fluoro silicone acrylate rigid gas permeable lenses. Consult with your eye care practitioner to identify your RGP material.

Device Story

TheraTears Contact Lens Comfort Drops is a sterile, hypotonic, borate-buffered ophthalmic solution; contains carmellose sodium lubricant and essential electrolytes (sodium chloride, potassium chloride, sodium bicarbonate, calcium chloride, magnesium chloride, sodium phosphate). Preserved with sodium perborate stabilized with phosphonic acid; free of chlorhexidine, thimerosal, mercury, and detergents. Used by contact lens wearers to lubricate/rewet lenses, relieve irritation, and ease insertion. Applied topically to the eye/lens by the patient.

Clinical Evidence

One-month clinical study evaluated safety and efficacy. Results showed performance equivalent to Bausch & Lomb ReNu MultiPlus Lubricating and Wetting Drops. Endpoints included slit lamp findings, stability of contact lens and spectacle-corrected visual acuities, incidence/severity of symptoms, and absence of solution-associated complications.

Technological Characteristics

Sterile, hypotonic, borate-buffered aqueous solution. Active ingredient: carmellose sodium. Electrolytes: NaCl, KCl, NaHCO3, CaCl2, MgCl2, Na-phosphate. Preservative: sodium perborate stabilized with phosphonic acid. No chlorhexidine, thimerosal, or detergents.

Indications for Use

Indicated for users of soft (hydrophilic) and RGP (silicone acrylate and fluoro silicone acrylate) contact lenses to lubricate, rewet, relieve dryness/discomfort/irritation, and cushion lenses for insertion.

Regulatory Classification

Identification

A soft (hydrophilic) contact lens care product is a device intended for use in the cleaning, rinsing, disinfecting, lubricating/rewetting, or storing of a soft (hydrophilic) contact lens. This includes all solutions and tablets used together with soft (hydrophilic) contact lenses and heat disinfecting units intended to disinfect a soft (hydrophilic) contact lens by means of heat.

Special Controls

*Classification.* Class II (Special Controls) Guidance Document: “Guidance for Industry Premarket Notification (510(k)) Guidance Document for Contact Lens Care Products.”

Predicate Devices

• Allergan Refresh Contacts (K992928)
• AQuify lens Comfort Drops (K013204)

Reference Devices

• Bausch & Lomb ReNu MultiPlus Lubricating and Wetting Drops

Submission Summary (Full Text)

{0}------------------------------------------------

NOV = 4 2003

Image /page/0/Picture/1 description: The image shows a handwritten string of characters, "K 032481", followed by the text "Page 1 of 2". The characters are written in a simple, clear font, and the text is smaller and positioned below the string of characters. The image appears to be a scan or photograph of a document.

## 510(k) Summary of Safety and Effectiveness

| Applicant's Name and Address: | Advanced Vision Research, Inc.<br>12 Alfred Street, Suite 200<br>Woburn, MA 01801 |
|-------------------------------|-----------------------------------------------------------------------------------|
| Contact Person: | Jeffrey R. Gilbard, M.D. |
| Contact Person: | Jeffrey P. Gilbard, M.D. |
| | Phone [phone] |
| | Fax [phone] |

October, 2003 Summary Prepared

Trade Name:

TheraTears Contact Lens Comfort Drops

Classification Name:

Soft (hydrophilic) contact lens care products (886.5928) Rigid gas permeable contact lens care products (886.5918)

Predicate Device:

Allergan Refresh Contacts™ (K992928) AQuify lens Comfort Drops (K013204)

Device Description:

TheraTears® brand Contact Lens Comfort Drops contains carmellose sodium in purified water as a lubricant. It is a sterile, hypotonic, borate buffered solution containing the following essential electrolytes found in natural tears: sodium chloride, potassium chloride, sodium chloride, sodium bicarbonate, calcium chloride, magnesium chloride, and sodium phosphate. The gentle patented preservative system consists of sodium perborate stabilized with phosphonic acid. This solution contains no chlorhexidine, no thimerosal and no other mercury-containing ingredients, and it contains no detergents.

{1}------------------------------------------------

Indication for Use:

## TheraTears Contact Lens Comfort Drops is indicated

- to lubricate and rewet soft (hydrophilic) and RGP* (rigid gas permeable) contact . lenses.
- to help relieve dryness, discomfort and irritation that may be associated with lens . wear and,
- to cushion lenses and ease insertion. .

* RGP lenses include silicone acrylate and fluoro silicone acrylate rigid gas permeable lenses. Consult with your eye care practitioner to identify your RGP material.

Safety, Performance and Substantial Equivalence

## Non-clinical Testing

The applicant performed stability, compatibility, toxicology and microbiology testing based the requirements of the May 1, 1997 Premarket Notification (510(k)) Guidance Document for Contact Lens Care Products. The results support the claim of substantial equivalence.

#### Clinical Testing

A one month clinical study was conducted to evaluate the safety and efficacy of TheraTears Contact Lens Comfort Drops. The results of the study demonstrate that TheraTears Contact Lens Comfort Drops is equivalent in performance, safety and efficacy to the Bausch & Lomb ReNu MultiPlus® Lubricating and Wetting Drops.

This conclusion is based upon and supported by:

- The relative frequency and severity of positive slit lamp findings .
- The stability of the contact lens visual acuities as well as the stability of the . best spectacle-corrected visual acuities
- The relative incidence and severity of symptoms, problems and complaints .
- . The lack of solution-associated complications

The claim of substantial equivalence to Allergan Refresh Contacts and AQuify lens Comfort Drops is based on the indication for use as a lubricating and rewetting solution for soft (hydrophilic) and RGP contact lenses. TheraTears Contact Lens Comfort Drops contains the same active ingredient as Allergan Refresh Contacts and the same preservative system as AQuify lens Comfort Drops.

{2}------------------------------------------------

DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized symbol resembling three abstract shapes that could be interpreted as human figures or abstract forms. The logo is in black and white.

Public Health Service

Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV = 4 2003

Advanced Vision Research, Inc. c/o Beverley D. Venuti, Ph.D. R.A.C. Foresight Regulatory Strategies 269A Ballardvale Street Wilmington, MA 01887

Re: K032481

Trade/Device Name: TheraTears Contact Lens Comfort Drops Regulation Number: 21 CFR 886.5928; 21 CFR 886.5918 Regulation Name: Soft (hydrophilic) contact lens care products; Rigid gas permeable contact lens care products Regulatory Class: Class II Product Code: LPN; MRC Dated: August 11, 2003 Received: August 12, 2003

Dear Dr. Venuti:

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.

{3}------------------------------------------------

# Page 2 - Beverley D. Venuti, Ph.D. R.A.C.

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 [phone]. 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 [phone] or [phone] or at its Internet address http://www.fda.gov/cdrl/dsma/dsmamain.html

Sincerely vours,

A. Karyi korenthal.

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

{4}------------------------------------------------

# Indications for Use

510(k) Number (if known):

Device Name: TheraTears Contact Lens Comfort Drops

Indications for Use:

TheraTears Contact Lens Comfort Drops is indicated

- to lubricate and rewet soft (hydrophilic) and RGP* (rigid gas permeable) . contact lenses,
- to help relieve dryness, discomfort and irritation that may be associated with . lens wear and,
- . to cushion lenses and ease insertion.

* RGP lenses include silicone acrylate and fluoro silicone acrylate rigid gas permeable lenses. Consult with your eye care practitioner to identify your RGP material.

(Please do not write below this line. Continue on another page if needed.)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Daniel W. C. Brown Ph.D.

Ophthalmic Ear, roat Devises

510(k) Number K032481

OR Over-The-Counter Use

(Optional Format 1-2-96)

Prescription Use (Per 21 CFR 80.109)