K120751 · Church & Dwight Co., Inc. · NUC · Oct 3, 2012 · Obstetrics/Gynecology
Device Facts
Record ID
K120751
Device Name
NIRVANA B PERSONAL LUBRICANT
Applicant
Church & Dwight Co., Inc.
Product Code
NUC · Obstetrics/Gynecology
Decision Date
Oct 3, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 884.5300
Device Class
Class 2
Indications for Use
is as personal lubricant, for penile and/or vaginal application, intended to lubricate and moisturize, 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. Not compatible with polyurethane or other condoms.
Device Story
Aqueous, non-sterile personal lubricants designed for penile and/or vaginal application to supplement natural lubrication and enhance comfort during sexual activity. Available in two formulations: 'Continuous Silkiness' and 'Continuous Silkiness - Warm & Tingling' (containing menthol and vanillyl butyl ether). Applied topically by the user. Compatible with natural rubber latex and polyisoprene condoms. Packaged in PET bottles with polypropylene flip-top closures. Provides physical lubrication to reduce friction during intimate activity.
Clinical Evidence
Bench testing only. Biocompatibility testing performed per ISO 10993:2009, including cytotoxicity, rabbit vaginal/penile irritation, acute systemic toxicity, guinea pig maximization, and primary rabbit skin irritation; all results indicated non-irritating and non-sensitizing profiles. Condom compatibility testing performed per modified ASTM D7761-10 using natural rubber latex and polyisoprene condoms confirmed compatibility. Shelf-life established via accelerated aging studies.
Technological Characteristics
Aqueous, non-sterile personal lubricant. Ingredients: propylene glycol, water, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, propylparaben; 'Warm & Tingling' version adds menthol and vanillyl butyl ether. Packaging: PET bottle with polypropylene closure. Tested per ISO 10993 and ASTM D7761-10.
Indications for Use
Indicated for individuals requiring personal lubrication for penile and/or vaginal application to enhance comfort during sexual activity. Compatible with natural rubber latex and polyisoprene condoms; contraindicated for use with polyurethane or other condom types.
Regulatory Classification
Identification
A condom is a sheath which completely covers the penis with a closely fitting membrane. The condom is used for contraceptive and for prophylactic purposes (preventing transmission of sexually transmitted infections). The device may also be used to collect semen to aid in the diagnosis of infertility.
Special Controls
*Classification.* (1) Class II (special controls) for condoms made of materials other than natural rubber latex, including natural membrane (skin) or synthetic.(2) Class II (special controls) for natural rubber latex condoms. The guidance document entitled “Class II Special Controls Guidance Document: Labeling for Natural Rubber Latex Condoms Classified Under 21 CFR 884.5300” will serve as the special control. See § 884.1(e) for the availability of this guidance document.
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K12075)
Confidential
(revised)
October 2, 2012
510(k) Premarket Notification Church & Dwight Co., Inc. Troian Nirvana B Personal Lubricant
II. 510(k) Summary
OCT Э 2012 Church & Dwight Co., Inc. Submitter Name: 469 North Harrison Street Submitter Address: Princeton, NJ 08543 Emily Perez Contact Person: Regulatory Affairs Specialist Church & Dwight Co., Inc. 469 North Harrison Street Princeton, NJ 08543 Tel: (609) 688-5347 Fax: (609) 497-7179 October 2, 2012 Date Prepared: TROJAN™ LUBRICANTS Continuous Silkiness - Warm & Device Trade Name: Tingling Personal Lubricant TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant Personal Lubricant Device Common Name: NUC - Condom (21 C.F.R. § 884.5300) Product Code: Class II Classification: TROJANTM Crystal Clear Liquid (K013614) Predicate Device: [Continuous Silkiness - Warm & Tingling] [Continuous Silkiness] Intended Use: is as personal lubricant, for penile and/or vaginal application, intended to lubricate and moisturize, 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. Not compatible with polyurethane or other condoms.
(continued)
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Device Description:
The device will be available in two forms - as the TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling Personal Lubricant and as the TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant - each an aqueous, non-sterile, clear personal lubricant compatible with natural rubber latex and polyisoprene condoms. TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling Personal Lubricant consists of low levels of sensory ingredients.
TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant is composed of propylene glycol, water, dimethicone, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, and propy|paraben, TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling Personal Lubricant is composed of propylene glycol, water, dimethicone, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, menthol, propylparaben, and vanillyl butyl ether. Each product is not a spermicide or a contraceptive and is packaged in a polyethylene terephthalate (PET) bottle with a screw-on, flip top polypropylene (PP) closure constituting the device's primary packaging. One bottle is packaged into a cardboard carton, which constitutes the device outer packaging.
#### Technological Characteristics:
There is no difference in the fundamental technological characteristics of the TROJAN™ LUBRICANTS [Continuous Silkiness- Warm & Tingling] [Continuous Silkiness] and the predicate TROJANTM Crystal Clear Liquid Personal Lubricant. TROJANTM LUBRICANTS Continuous Silkiness- Warm & Tingling is composed of propylene glycol, water, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, menthol, propylparaben, and vanilly! butyl ether and TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant is composed of propylene glycol, water, dimethicone, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, and propylparaben. The proposed lubricant is substantially equivalent to the predicate Trojan™ Crystal Clear Liquid Personal Lubricant cleared under 510(k) # K013614.
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# TROJANTM LUBRICANTS Continuous Silkiness Personal Lubricant:
TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant is composed of propylene glycol, water, dimethicone, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, and propylparaben. The following ingredients, water, propylene glycol, methylparaben, and propylparaben are present in the predicate device. The additional ingredients, dimethicone, dimethicone/viny| dimethicone crosspolymer, hydroxyethyl acrylate, and sodium acryloyl dimethyl taurate copolymer, are safe and do not raise new questions of safety or effectiveness.
# TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling:
TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling is composed of propylene glycol, water, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer, methylparaben, menthol, propylparaben, and vanillyl butyl ether. The following ingredients, water, propylene glycol, methylparaben, and propylparaben are present in the predicate device. The additional ingredients, dimethicone, dimethicone/vinyl dimethicone crosspolymer, hydroxyethyl acrylate, sodium acryloyl dimethyl taurate copolymer,menthol and vanillyl butyl ether are safe and do not raise new questions of safety or effectiveness.
## Biocompatibility:
Biocompatibility testing was performed in accordance with ISO 10993, Biological Evaluation of Medical Devices, 2009.
Testing Performed:
| Testing Performed | Results |
|--------------------------------|---------------------------------------------------------------------------|
| Cytotoxicity | Cytotoxicity profile similar to currently<br>marketed personal lubricants |
| Rabbit Vaginal Irritation | Non-irritating |
| Rabbit Penile Irritation | Non-irritating |
| Acute Systemic Toxicity | Non-systemically toxic |
| Guinea Pig Maximization | Non-sensitizing |
| Primary Rabbit Skin Irritation | Non-irritating |
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510(k) Premarket Notification Church & Dwight Co., Inc. Troian Nirvana B Personal Lubricant
Confidential October 2, 2012 (revised)
## Condom Compatibility:
Condom Compatibility Testing was performed using TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling Personal Lubricant and ASTM D7761-10 "Standard Test Method for Determining Compatibility of Personal Lubricants with Natural Rubber Latex Condoms" which was modified to include pre-lubricated and unlubricated dry condoms. Three marketed brands of pre-lubricated and un-lubricated dry natural rubber latex condoms and one brand of polyisoprene condoms were tested.
Both 510(k)- subject formulas consist of the the same base ingredients; therefore the evaluation for condom compatibility was done with TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling because it was considered the most challenging of the two 510(k)-subject formulas due to the inclusion of sensory ingredients vanillyl butyl ether and menthol,
Condom compatibility testing for TROJAN™ LUBRICANTS [Continuous Silkiness-Warm & Tingling] [Continuous Silkiness] Personal Lubricant show that each is compatible with commercially available natural rubber latex condoms and polyisoprene condoms.
### Shelf-life:
TROJAN™ LUBRICANTS [Continuous Silkiness- Warm & Tingling] [Continuous Silkiness] Personal Lubricant each has a two-year shelf-life based on the results of an accelerated aging study.
A Real-time aging study is being performed in order to verify results of the accelerated aging study.
#### Substantial Equivalence:
Based on nonclinical performance data, biocompatibility review and testing, and safety data, the proposed devices are substantially equivalent to Trojan™ Crystal Clear Liquid in technology, intended use, and safety.
#### Conclusion:
The results from laboratory testing and non-clinical evaluations of human use testing show that the proposed devices perform equivalently to the predicate device and are safe for use as a personal lubricant.
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# DEPARTMENT OF HEALTH & HUMAN SERVICES
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
OCT 3 2012
Ms. Emily Perez Regulatory Affairs Specialist Church & Dwight Co., Inc. 469 North Harrison Street PRINCETON NJ 08543
Re: K120751
Trade/Device Name: TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling Personal Lubricant
TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant Regulation Number: 21 CFR§ 884.5300
Regulation Name: Condom Regulatory Class: II Product Code: NUC Dated: August 29, 2012 Received: August 31, 2012
Dear Ms. Perez:
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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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); medical device reporting (reporting of medical
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device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours,
Benjamin R. Ticho
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Premarket Notification Church & Dwight Co., Inc. Troian™ Nirvana B Personal Lubricant
Confidential August 29, 2012
## I. Indications For Use
510(k) Number (if known): K120751
Device Name: TROJAN™ LUBRICANTS Continuous Silkiness- Warm & Tingling Personal Lubricant TROJAN™ LUBRICANTS Continuous Silkiness Personal Lubricant
## INDICATION FOR USE:
[Continuous Silkiness - Warm & Tingling][Continuous Silkiness] is a personal lubricant, for penile and/or vaginal application, intended to lubricate and moisturize, 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. Not compatible with polyurethane or other condoms.
(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 X
(Part 21 C.F.R. 801 Subpart D) (21 C.F.R. 801 Subpart C)
(Division Sign-Off)
Division of Reproductive, Gastro-Renal, and
Urological Devices
510(k) Number K120751
Concurrence of CDRH, Office of Device Evaluation (ODE)
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.