BRAND NAME *1-STEP PREGNANCY

K973352 · Armkel, LLC · LCX · Oct 27, 1997 · Clinical Chemistry

Device Facts

• Record ID: K973352
• Device Name: BRAND NAME *1-STEP PREGNANCY
• Applicant: Armkel, LLC
• Product Code: LCX · Clinical Chemistry
• Decision Date: Oct 27, 1997
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 862.1155
• Device Class: Class 2

Intended Use

The Brand Name 1-Step Pregnancy Test is a simple-to-use at-home pregnancy test marketed over-the-counter (OTC) to lay consumers. The test device product is intended for the detection of human chorionic gonadotropin (hCG) in urine as an aid in the detection of pregnancy.

Device Story

At-home, OTC pregnancy test; detects hCG in urine. Device consists of plastic stick with absorbent tip; collects urine via midstream or dip method. Principle of operation: double antibody immunochromatographic assay; colloidal gold label; biotin-streptavidin complexing reaction. User observes test window for color change: two pink lines indicate pregnancy (hCG present); one pink line indicates no pregnancy. Used by lay consumers at home. Provides rapid visual result to aid in early pregnancy diagnosis.

Clinical Evidence

Three laboratory studies conducted: two compared accuracy against predicate device; one confirmed sensitivity. Consumer studies evaluated ability of lay users to perform and interpret results using both midstream and dip methods.

Technological Characteristics

In vitro diagnostic; double antibody immunochromatographic assay. Materials: plastic stick, absorbent tip, chromatographic strip. Detection: colloidal gold agglutination (pink/purple color) and biotin-streptavidin complexing. Form factor: handheld test stick. No electronic components or software.

Indications for Use

Indicated for lay consumers for the early diagnosis of pregnancy by detecting hCG in urine. Can be used at any time of day as early as the first day of missed menses.

Regulatory Classification

Identification

A human chorionic gonadotropin (HCG) test system is a device intended for the early detection of pregnancy is intended to measure HCG, a placental hormone, in plasma or urine. A human chorionic goadotropin (HCG) test system is a device intended for any uses other than early detection of pregnancy (such as an aid in the diagnosis, prognosis, and management of treatment of persons with certain tumors or carcinomas) is intended to measure HCG, a placental hormone, in plasma or urine.

Predicate Devices

• First Response® 1-Step Pregnancy Test

Submission Summary (Full Text)

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#### 510(k) SUMMARY II.

OCT 2 7 1997 Carter-Wallace Submitted By: Carter Products Division P.O. Box 1001, Half Acre Road Cranbury, New Jersey 08512-0181 [phone] Contact Person: Theresa Sines September 4, 1997 Date Prepared: Brand Name* 1-Step Pregnancy Proprietary Name: *May be marketed under brand names yet to be determined, including ANSWER®, ANSWER QUICK & SIMPLE®, FIRST RESPONSE®, or others. At-Home Pregnancy Test Common Name: Human chorionic gonadotropin (hCG) test system Classification Name: Predicate Device: First Response® 1-Step Pregnancy Test

Description of the Device: The Brand Name 1-Step Pregnancy Test is a Class II in vitro diagnostic medical device product that functions by way of a double antibody immunochromatographic assay in detecting the presence of hCG in the urine as an aid in the early diagnosis of pregnancy. It consists of a plastic stick, which contains an absorbent tip that protrudes from the end of the device and collects and delivers urine to reagents on a chromatographic strip contained within the device. The test is performed by placing the absorbent tip of the device in the urine stream for 5 seconds or by immersing the absorbent tip into a container of urine for 5 seconds. The absorbent section of the strip allows the urine sample to move chromatographically along the reagent strip reconstituting the diffusible reagents placed strategically along the strip and delivering them to the appropriate capture zones for visualization of the test results. The detection of hCG (pregnant) in the urine sample is indicated by the appearance of two pink lines in the test window. If there is no hCG (not-pregnant) in the urine, one pink line will appear.

The Brand Name 1-Step Pregnancy test is substantially equivalent to the First Response® 1-Step Pregnancy Test distributed by Carter Products.

Intended Use of the Device: The Brand Name 1-Step Pregnancy Test is a simple-to-use at-home pregnancy test marketed over-the-counter (OTC) to lay consumers. The test device product is intended for the detection of human chorionic gonadotropin (hCG) in urine as an aid in the detection of pregnancy.

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## 510(k) SUMMARY (cont'd) II.

Technological Characteristics: The Brand Name 1-Step Pregnancy Test has the same technological characteristics as the predicate device. It differs from the predicate device by utilizing a plastic stick with an absorbent tip which protrudes from the end of the device and collects and delivers the urine to reagents on the chromatographic strip contained within the device. The First Response 1-Step Pregnancy Test utilizes a plastic stick which encloses the absorbent pad and exposes a urine collection area on the underside of the stick. Both test products detect hCG, the hormone produced during pregnancy, by utilizing a double antibody immunochromatographic assay. Both tests use a direct label to visualize the immunoreaction indicating the presence of hCG. Both tests use colloidal gold which upon agglutination produces a pink/purple color. Both tests also utilize a third complexing reaction (between biotin and streptavidin) to produce an easy-to-read test result. These technological characteristics raise no new issues regarding safety or effectiveness.

The performance studies conducted included the evaluation of the laboratory accuracy of the Brand Name 1-Step Pregnancy Test and the ability of lay consumers to perform the test and interpret the result. Two laboratory studies were conducted to determine the performance of the Brand Name 1-Step Pregnancy Test in comparison to the predicate device, First Response® 1-Step Pregnancy Test. A third laboratory study was performed to evaluate and confirm the sensitivity of the Brand Name 1-Step Pregnancy Test. In three separate studies, the ability of consumers to perform and interpret the Brand Name 1-Step Pregnancy Test using both the midstream and dip methods was evaluated.

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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus, a symbol often associated with medicine and healthcare. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the caduceus. The logo is black and white.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

OCT 2 7 1997

Stephen C. Kolakowsky · Director, Requlatory Affairs Carter-Wallace, Inc. Half Acre Road P.O. Box 1001 Cranbury, New Jersey 08512-0181

K973352 Re : Brand Name 1-Step Pregnancy Test Requlatory Class: II Product Code: LCX Dated: September 4, 1997 Received: September 5, 1997

Dear Mr. Kolakowsky:

We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to 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). 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 (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. ಗೆ substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does

not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or requlations.

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Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity categorization. To determine if it does, you should contact the Centers for Disease Control and Prevention (CDC) at [phone].

This letter will allow you to begin marketing your device as described in your 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 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at [phone]. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at [phone]. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number [phone] or [phone] or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".

Sincerely yours,
Steven Sitman

Steven I. Gutman, M.D., M.B.A. Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## INDICATIONS FOR USE STATEMENT VI.

510(k) Number (if known):

Brand Name 1-Step Pregnancy Test Device Name:

The Brand Name 1-Step Pregnancy Test is an at-home Indications For Use: pregnancy test marketed over-the-counter (OTC) to lay consumers. The Brand Name 1-Step Pregnancy Test detects the presence of hCG in the urine as an aid in the early diagnosis of pregnancy. The test, which can be used anytime of the day, can detect hCG as early as the first day of the missed menses.

# (PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED) Concurrence of CDRH, Office of Device Evaluation (ODE)

(Division:
Division:
510(k) Number: K973352

Over-The-Counter Use √

Prescription Use_ (Per 21 CFR 801.109)

OR