Intimate Rose Kegel Exercise System
Device Facts
| Record ID | K193364 |
|---|---|
| Device Name | Intimate Rose Kegel Exercise System |
| Applicant | Plus EV Holdings Dba Intimate Rose |
| Product Code | HIR · Obstetrics/Gynecology |
| Decision Date | Aug 24, 2020 |
| Decision | SESE |
| Submission Type | Traditional |
| Regulation | 21 CFR 884.1425 |
| Device Class | Class 2 |
| Attributes | Therapeutic |
Indications for Use
The Intimate Rose Kegel Exercise System is indicated for the strengthening of the perineal pelvic floor muscles by providing resistance to an individual's voluntary contractions of these muscles. It seeks to correct, through exercise, low tone in the pelvic floor, which can cause or contribute to health issues including urinary incontinence and sexual dysfunction.
Device Story
Pelvic floor exercise device; reusable; over-the-counter. Comprised of 6 progressively weighted, color-coded silicone weights. User inserts weight into vagina; holds in place via voluntary pelvic floor muscle contraction. Device provides resistance to muscle contractions; moves upward/inward during correct activation. Body angle during exercise modulates resistance level. Used by patients for pelvic floor strengthening to address incontinence and sexual dysfunction. No electronic components; purely mechanical resistance.
Clinical Evidence
Bench testing only. Biocompatibility testing performed per ISO 10993-5:2009 (cytotoxicity) and ISO 10993-10:2010 (sensitization and vaginal irritation). Mechanical performance testing included joint strength validation. No clinical data provided.
Technological Characteristics
Materials: Silicone and stainless steel. Form factor: Egg-shaped with removal tail; 6 weights (25g, 40g, 60g, 85g, 105g, 125g). Principle: Mechanical resistance via gravity and muscle contraction. Non-sterile. No software or energy source.
Indications for Use
Indicated for strengthening perineal pelvic floor muscles in individuals with low pelvic floor tone, which may contribute to urinary incontinence and sexual dysfunction.
Regulatory Classification
Identification
A perineometer is a device consisting of a fluid-filled sack for intravaginal use that is attached to an external manometer. The devices measure the strength of the perineal muscles by offering resistence to a patient's voluntary contractions of these muscles and is used to diagnose and to correct, through exercise, uninary incontinence or sexual dysfunction.
Predicate Devices
- Feminine Personal Trainer (FPT) (K171896)
Submission Summary (Full Text)
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August 24, 2020
Plus EV Holdings dba Intimate Rose % Elizabeth Proctor Consultant Q-Metrics LLC 860 Lindenwood Lane Medina, OH 44256
Re: K193364
Trade/Device Name: Intimate Rose Kegel Exercise System Regulation Number: 21 CFR§ 884.1425 Regulation Name: Perineometer Regulatory Class: II Product Code: HIR Dated: July 20, 2020 Received: July 23, 2020
Dear Elizabeth Proctor:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.
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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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Monica D. Garcia, Ph.D. Acting Assistant Director DHT3B: Division of Reproductive, Gynecology and Urology Devices OHT3: Office of GastroRenal, ObGyn, General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2020
See PRA Statement below.
510(k) Number (if known)
Device Name
Indications for Use (Describe)
Type of Use (Select one or both, as applicable)
| Prescription Use (Part 21 CFR 801 Subpart D)
[X] Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(k) Summary — K193364
### I. SUBMITTER
| Submitted by: | Plus EV Holdings dba Intimate Rose<br>1700 Iron Street<br>North Kansas City, MO 64116<br>Phone: 816-805-6722 |
|-----------------|--------------------------------------------------------------------------------------------------------------|
| Contact Person: | Aaron Wilt |
| Date Prepared: | August 21, 2020 |
### II. DEVICE
| Device Name: | Intimate Rose Kegel Exercise System |
|---------------------------|-----------------------------------------|
| Common Name: | Kegel Exercise and Pelvic Floor Workout |
| Device Regulation Number: | 21 CFR § 884.1425 |
| Regulation Name: | Perineometer |
| Regulatory Class: | II |
| Product Code: | HIR (Perineometer) |
| Classification Panel: | Obstetrics/Gynecology |
#### III. PREDICATE DEVICE
| 510(k) Number | Trade or Proprietary or<br>Model Name | Manufacturer |
|---------------|---------------------------------------|---------------|
| K171896 | Feminine Personal Trainer<br>(FPT) | Ralston Group |
This predicate device has not been subject to a design-related recall.
## IV. DEVICE DESCRIPTION
The Intimate Rose Kegel Exercise System is a pelvic floor exercise device for use in strengthening the pelvic floor musculature. It is a reusable, over-the-counter device that is comprised of 6 progressively heavier and color-coded silicone weights. An Intimate Rose
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Kegel Exercise System weight is inserted into the vagina and is held in place by contracting the pelvic floor muscles. The weight of the Intimate Rose Kegel Exercise System device provides resistance as it is lifted with each contraction of the pelvic floor muscles. When utilized correctly, the device will move upward and inward when the user contracts her pelvic floor muscles. The body's angle while exercising controls the level of resistance.
## V. INDICATIONS FOR USE
The Intimate Rose Kegel Exercise System is indicated for the strengthening of the perineal pelvic floor muscles by providing resistance to an individual's voluntary contractions of these muscles. It seeks to correct, through exercise, low tone in the pelvic floor, which can cause or contribute to health issues including urinary incontinence and sexual dysfunction.
| | APPLICANT DEVICE | PREDICATE DEVICE |
|--------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Device Name | Intimate Rose Kegel Exercise System | Feminine Personal Trainer (FPT) |
| 510(k) Number | K193364 | K171896 |
| Regulation<br>Number | 21 CFR§ 884.1425 | 21 CFR§ 884.1425 |
| Regulation<br>Name | Perineometer | Perineometer |
| Regulatory Class | II | II |
| Product Code | HIR | HIR |
| Indications for<br>Use | The Intimate Rose Kegel Exercise System is indicated for the strengthening of the perineal pelvic floor muscles by providing resistance to an individual's voluntary contractions of these muscles. It | The Feminine Personal Trainer (FPT) is indicated for the strengthening of the perineal pelvic floor muscles by providing resistance to an individual's voluntary contractions of these |
| | seeks to correct, through exercise,<br>low tone in the pelvic floor, which<br>can cause or contribute to health<br>issues including urinary incontinence<br>and sexual dysfunction. | muscles. It seeks to correct,<br>through exercise, urinary<br>incontinence in women. |
| Over the<br>Counter | Yes | Yes |
| Anatomical Site | Vagina | Vagina |
| Single Patient<br>Device | Yes | Yes |
| Reusable | Yes | Yes |
| Sterile | No | No |
| Device Design | Egg shaped with tail to remove the<br>device | Hourglass-shaped |
| Materials | Silicone, stainless steel | Stainless steel |
| Dimensions | Six varying weights {25g, 40g, 60g,<br>85g, 105g and 125g), each:<br>Main Section of Device - Length: 2.5<br>inches/62mm, Diameter {widest<br>point): 1 inch/23mm<br>Tail Section of Device - Length: 3.15<br>inches/80mm, Diameter: 3mm body<br>of tail, 5mm bulb end of tail | Standard FPT: Large end diameter:<br>1.628 in Small end diameter: 1.248<br>in Length: 3.503 in Weight: 450 g.<br>Small FPT: Large end diameter:<br>1.500 in Small end diameter: 1.125<br>in Length: 3.500 in Weight: 340 g_<br>Petite FPT: Large end diameter:<br>1.250 in Small end diameter: 1.100<br>in Length: 4.564 in Weight: 340 g. |
| Packaging | The Intimate Rose Kegel Exercise<br>System is packed with 6 weights in a<br>cardboard box with protective<br>foam. It includes a detailed<br>instruction guide and travel<br>bag. | The FPT device is packaged in a<br>velveteen bag inside a clear plastic<br>tube with instructions and exercise<br>chart. |
| Color | Shades of white, pink, and purple | Stainless steel |
# VI. COMPARISON OF INTENDED USE AND TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
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The indications for use of the subject device and predicate device are similar. The subject device and the predicate device have the same intended use for strengthening pelvic floor muscles.
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The subject and predicate device have different technological characteristics, including different materials, shapes, dimensions, and weight options. The technological differences between the subject and predicate device do not raise different types of safety and effectiveness questions.
#### VII. SUMMARY OF NON-CLINICAL PERFORMANCE TESTING
The following non-clinical performance information was provided for the subject device
### Biocompatibility
- Cytotoxicity testing per ISO 10993-5:2009 O
- Guinea pig maximization sensitization testing per ISO 10993-10:2010 O
- O Vaginal irritation testing per ISO 10993-10:2010
#### Reprocessing
Information per FDA's 2015 Guidance Document "Reprocessing Medical Devices in Health Care Settings: Validation Methods and Labeling"
#### Mechanical Performance
- Joint strength testing
#### VIII. CONCLUSION
Based on the results of the performance testing described above, the Intimate Rose Kegel Exercise System is as safe and effective as the predicate device and supports a determination of substantial equivalence.
