This guidance was written prior to the February 27, 1997 implementation of FDA’s Good Guidance Practices, GGP’s. It does not create or confer rights for or on any person and does not operate to bind FDA or the public. An alternative approach may be used if such approach satisfies the requirements of the applicable statute, regulations, or both. This guidance will be updated in the next revision to include the standard elements of GGP’s.
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DRAFT GUIDANCE FOR PREPARATION OF PMA APPLICATIONS FOR PENILE INFLATABLE IMPLANTS |
Urology and Lithotripsy Devices Branch Division of Reproductive, Abdominal, Ear, Nose and Throat and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health March, 1993 TABLE OF CONTENTS I. PREFACE 1 II. DEVICE DESCRIPTION 1 III. BACKGROUND 1 IV. GENERAL.REQUIREMENTS OF PREMARKET APPROVAL (PMA) APPLICATIONS FOR PENILE INFLATABLE IMPLANTS 2 1. Manufacturing Data: 2 1.1 Chemical Characterization of Device Components 2 1.1.1 Process tree 3 1.1.2 Master List 3 1.1.3 Chemical characterization of Polymer Precursors 3 1.2 Sterilization processes. 4 1.3 Quality Assurance/control. 5 2. Preclinical Data 5 2.1 Finished product chemistry 6 2.1.1 Chemical characterization 6 2.1.2 Leachable Chemicals 6 2.1.3 Surface Composition 8 2.2 Toxicological Evaluation 8 2.2.1 Pharmacokinetics Studies 9 2.2.2 Mutagenicity Testing 9 2.2.3 Acute, subchronic, and chronic toxicity,carcinogenicity,teratogenicity, and immunotoxicity. 10 2.3 Physical, Mechanical and Reliability testing 10 2.3.1 General Requirements 10 2.3.2 Physical Material Characterization 12 2.3.3 Device/Component/Subassembly Performance Testing 15 3. Clinical data 22 4. Labeling. 28 5. References (Risks and benefits associated with penile implants) 31 Appendix I Extraction Guidelines for Polymers 38 Appendix II Selected bibliography of analytical methods 43 DRAFT GUIDANCE FOR PREPARATION OF PMA APPLICATIONS FOR PENILE INFLATABLE IMPLANTS Urology and Lithotripsy Devices Branch Division of Reproductive, Abdominal, Ear, Nose and Throat and Radiological Devices I. PREFACE This guidance document addresses the preparation of premarket approval (PMA)applications for penile inflatable implants for the treatment of erectile dysfunction. It may also be useful for the preparation of Investigational Device Exemptions (IDE) applications, reclassification petitions, and master files. Development of this document is based upon scientific review and analysis by the FDA and by published and unpublished studies. II. DEVICE DESCRIPTION A penile inflatable implant is a device that consists of two inflatable cylinders implanted in the penis, connected to a reservoir filled with radiopaque fluid implanted in the abdomen, and a subcutaneous manual pump implanted in the scrotum. These devices have been constructed from silicone or polyurethane elastomers and some models also contain silicone gel. Also included within this device classification are those models of the penile inflatable implant that have the reservoir and the pump combined into one component that is implanted within the scrotum, or that have a reservoir and pump combined within each of the two cylinders. When the cylinders are inflated, they provide rigidity to the penis. These devices are used in the treatment of erectile dysfunction. III. BACKGROUND In the FEDERAL REGISTER of November 23, 1983 (48 FR 53023), FDA issued a final rule classifying the penile inflatable implant into class III (21 CFR 876.3350). In the FEDERAL REGISTER of January 6, 1989, (54 FR 550), FDA published a notice of intent to initiate proceedings to require premarket approval of 31 preamendments Class III devices. Although the penile inflatable implant was not included in this list of 31 devices, the agency has received more than 6,500 Medical Device Reports (MDRs) for this device since 1984. Therefore, FDA has determined that the penile inflatable implant identified in 21 CFR 876.3350 has a high priority for initiating a proceeding to require premarket approval. In the FEDERAL REGISTER of ____________________, FDA issued a proposed rule requiring a PMA for these devices. These proceedings were enacted on {_____________________}, requiring a PMA for these devices be filed with the agency within 90 days. IV. GENERAL REQUIREMENTS OF PREMARKET APPROVAL (PMA) APPLICATIONS FOR PENILE INFLATABLE IMPLANTS A PMA must be submitted by all distributors of penile inflatable implants. Any PMA submitted must meet the content requirements contained in Section 515(c)(1) of the Federal Food, Drug and Cosmetic Act (the act) and 21 CFR 814.20. A PMA must also include a detailed discussion, with results of preclinical and clinical studies, of the safety and effectiveness of the device. In particular, the PMA shall include all known or otherwise available data and other information regarding: (1) any risks known to the applicant that have not been identified in this document, and (2) the effectiveness of the specific penile inflatable implant that is the subject of the application. Valid scientific evidence, as defined in 21 CFR 860.7, addressing the safety and effectiveness of the device should be presented, evaluated and summarized in a section or sections of the PMA separate from known or otherwise available safety and effectiveness information that does not constitute valid scientific evidence (e.g., isolated case reports, random experiences, etc.). This must include but not be limited to: 1. Manufacturing Data Complete manufacturing information must be submitted in accordance with the "Guidance for the Preparation of PMA Manufacturing Information". This guidance is available upon request from the Division of Small Manufacturing Assistance (HFZ-220), Center for Devices and Radiological Health, Food and Drug Administration, 5600 Fishers Lane, Rockville, MD 20857. In addition, the following specific chemical processing, sterilization and quality assurance information is required to assess the safety and effectiveness of penile inflatable implants. 1.1 Chemical Characterization of Device Components Manufacturing and process tree information show how the components of a device are made from starting materials. This identifies potentially leachable chemicals and immediate precursors of crosslinked polymers. Only a limited amount of chemical characterization can be done on highly crosslinked polymers. For such polymers, it is important to characterize the immediate precursors to assure the quality of the base polymers and crosslinking agents. The viscosity and molecular weight distribution are very basic characteristics of all polymers that greatly influence the mechanical and physical properties of the device. Determination of volatile content, extent of chemical crosslinking, and the sol fraction of components characterizes the curing processes that are used. These determinations should be done on 10 or more lots to establish that control of the chemical processing exists. 1.1.1 Process tree Chemical formulation and manufacturing information, presented in a step-by-step process, from the starting materials to composites to the final products, including, but not limited to, all nonreactants and reactants (including catalysts, curing agents, and intermediate precursors) must be provided for all device components, including all adhesives, colorants and filling agents (e.g., gel, saline contrast medium, etc.). On this tree, any substance or material identified by some sort of company name or code must also be identified by a corresponding common chemical name. 1.1.2 Master List A complete master list of common chemical names and alternate names (company, trade and code) for all nonreactants, reactants (including intermediate precursors), additives, catalysts, adjuvants, and products should be provided. The same name for each specific compound must be utilized throughout the document. 1.1.3 Chemical characterization of Polymer Precursors Chemical characterization of the elastomer intermediates (i.e., network precursors) of the various components of the device sufficient to demonstrate control of chemical processing of the device materials should be provided. This should be based on lot- to-lot comparisons (minimum of 10 consecutive lots) of the following information: a. the molecular weight distribution, expressed as weight average molecular weight (Mw), number average molecular weight (Mn), and polydispersity (MWD) of these precursors. b. analyses for volatile and nonvolatile (if applicable) compounds, such as cyclic oligomers, to establish the upper limit of these compounds and to show that they are being controlled. c. if copolymers are being used, data to show that the composition of these copolymers is under control and that a consistant product is being made. Usually, such data would consist of analyses of the group content of the copolymer, for example, phenyl, fluoro, vinyl, hydroxyl number, acid number, peroxide, etc. as appropriate. d. when viscosity is used as the variable that is measured for production control, a comparison of viscosity, Mn, and volatile content should be given on a lot-by-lot basis to show that viscosity monitoring is sufficient to control the chemical processing. e. if composites or filled or reinforced polymers are being used, the fillers should be characterized. The particle size or surface area of any reinforcing and nonreinforcing filler should be given. If silica is being used, the percent crystallinity should be provided. 1.2 Sterilization processes Standard operating procedures for sterilizing and qualifying the sterilization process must be provided. Provided information should include the method of sterilization; the detailed sterilization validation protocol/results; the sterility assurance level; the type of packaging; the packaging validation protocol/results; residual levels of ethylene oxide, ethylene glycol, and ethylene chlorhydrin remaining on the device after the sterilization quarantine period, if applicable; and the radiation dose, if applicable. 1.3 Quality Assurance/control A QA/QC plan that demonstrates how raw materials, components, subassemblies, and any filling agents will be received, stored, and handled in a manner designed to prevent damage, mixup, contamination, and other adverse effects must be provided. This plan shall specifically include, but not necessarily be limited to, a record of raw material, component, subassembly, and filling agent acceptance and rejection, visual examination for damage, and inspection, sampling and testing for conformance to specifications. Written procedures for finished device inspection to assure that device specifications are met must be provided. These procedures shall include, but are not limited to, that each production run, lot or batch be evaluated and, where necessary, tested for conformance with device specifications prior to release for distribution. A representative number of samples shall be selected from a production run, lot or batch and tested under simulated use conditions and to any extremes to which the device may be exposed. Furthermore, the QA/QC procedures should include appropriate visual testing of the packaging, packaging seal, and product. Sampling plans for checking, testing, and release of the device shall be based on an acceptable statistical rationale (21 CFR 820.80 and 820.160). 2. Preclinical Data All physical and chemical properties of the device must be completely characterized. Each item must be supported by complete reports (i.e., protocols with a full description of test methods and raw data). These reports must be from the testing of an adequate number of samples obtained from sterilized devices produced by the standard manufacturing procedures. Laboratory test methods and animal experiments used in the characterization of the physical, chemical (other than exhaustive extraction) and mechanical properties of the device should be applicable to the intended use of the device in humans. 2.1 Finished product chemistry 2.1.1 Chemical characterization If fabrication of the device involves curing of polymeric components by chemical crosslinking, then data establishing the extent and reproducibility of the crosslinking should be provided. This may be done by a various methods, for example; a. Measurement of Young's modulus at low strain, as this is approximately proportional to crosslink density. b. Measurement of equilibrium swelling of the polymeric component by a good solvent. c. Measurement of the soluble (sol fraction) content of a gel. Determination of total extractables using a good solvent could accomplish this. d. Determination of the amount of unreacted crosslinker from its concentration in the total extractables. 2.1.2 Leachable Chemicals Determination of the extractable or releasable chemicals in an implant device are necessary for assessment of the safety of the device. Chemical identification and quantification of releasable chemicals is necessary to facilitate the determination of safe levels by dose-response toxicological methods. Migration rates of the releasable chemicals from various components of the device may also be evaluated when providing toxicology data. Knowledge of the levels of volatiles and residues in the device provides an upper limit to the amount of releasable chemicals from the various components as they are found in the final sterilized device. This is necessary to relate amounts of releasable chemicals back to device characteristics as these are factors that should and can be controlled in the manufacturing process. Complete identification and quantification of all chemicals, such as: a. residual monomers, cyclics, and oligomers; b. known toxic residues such as polychlorinated biphenyls (PCBs) if dichlorobenzoyl peroxides are used, heavy metals, aromatic amines if polyurethanes are used, and residues of transition metal catalysts; c. residues of ethylene oxide if that is used for sterilization; d. additives and adjuvants used in the manufacture of the device, such as plasticizers, antioxidants, etc.; below a molecular weight of 1500, exhaustively extracted from each of the individual structural components as they are found in the final sterilized device should be reported. The solvents used for extraction should have varying polarities and should include, but not be limited to dichloromethane and ethanol/saline (1:9). Other, more contemporary extraction techniques such as supercritical fluid extraction, may also be useful - at least for exhaustive extraction of the silicone materials. Experimental evidence must be provided to show that exhaustive extraction has been achieved with one of the solvents, and the percent recovery, especially for the more volatile components, be reported. Extracts that may contain oligomeric or polymeric species must have the molecular weight distribution provided, along with the number and weight average molecular weights and the polydispersity. Guidelines for extraction and a selected bibliography of analytical methodologies are included as Appendix I and II respectively. All experimental methodology must be described, and raw data (including instrument reports) provided along with all chromatograms, spectrograms, etc. The practical quantitation limit (PQL) (see "Compilation of EPA's sampling and analysis methods, Lewis publishers 1992) must be provided when the analyte of interest is not detected. 2.1.3 Surface Composition Infrared measurements of the surface of device components as they occur in the final sterilized product should be provided. This establishes the major chemical characteristics of the surface which may differ from the bulk. This information will provide baseline characterization for comparison with explants. 2.2 Toxicological Evaluation The synthetic polymeric materials used in the penile inflatable implant should not present any toxic risks upon long-term intimate contact with the body. The high molecular weight polymeric material used in silicone penile prostheses contains low molecular weight components, such as monomers, oligomers, and catalysts which can leach out into the body. Therefore, one important requirement of the preclinical toxicology testing of the device is to determine the potential toxicity testing of these releasable chemicals as they appear in the final sterilized device. These tests should reveal the potential for local as well as systemic toxicity (including genotoxicity, carcinogenicity, adverse reproductive effects, teratogenicity, and immunotoxicity) of any leachable substance. Thus, the chemicals recovered by extraction of the final sterilized implant device, when appropriate, should be used as the test article in animal studies after they are separated, quantified and identified. In addition, the primary concern for any implanted device is its potential to cause cancer. This potential may arise not only from chemical leachables and degradation products from the device, but also from physical effects of the device at the implanted site. Therefore, adequate long-term studies with implantation of device materials should be conducted to evaluate the carcinogenic potential of penile prostheses. The Tripartite Biocompatability Guidance for Medical Devices (September 1986) lists suggested short-term (irritation tests, sensitization assay, cytotoxicity, acute systemic toxicity, hemocompatibility/hemolysis, pyrogenicity (material-mediated), implantation tests, pharmacokinetics studies, mutagenicity (genotoxicity)) and long-term (subchronic toxicity, chronic toxicity, carcinogenesis bioassay, reproductive and developmental toxicity) biological tests that might be applied to evaluating the safety of medical devices. The guidance may also be used in selecting appropriate tests for the evaluation of penile inflatable implants. 2.2.1 Pharmacokinetics Studies Pharmacokinetic/biodegradation studies of all materials contained in the finished sterilized device must be reported. Of special concern are questions regarding the ultimate fate, quantities, sites/organs of deposition, routes of excretion, and potential clinical significance of silicone shedding, retention, and migration. For designs using polyurethane elastomers, FDA believes that in vivo implant studies must be performed to identify and determine the polyurethane elastomers (as well as their degradation products) in experimental animals. It is also important to identify and determine the mechanism and rate of degradation, as well as the quantity of degradation products generated by the breakdown of polyurethane elastomers after prolonged exposure under physiological conditions in animals. The agency suggests that these studies on polyurethane elastomers be conducted as a separate subset of penile inflatable implant safety studies. 2.2.2 Mutagenicity Testing Complete reports from the mutagenicity testing of chemicals extracted from the finished, sterilized components of the device must be provided. The testing must, at minimum, consist of bacterial mutagenicity, mammalian mutagenicity, DNA damage, and cell transformation assays. 2.2.3 Acute, Subchronic and Chronic Toxicity, Carcinogenicity, Teratogenicity, and Immunotoxicity Acute, subchronic, and chronic toxicity, carcinogenicity*, reproductive and teratological effects*, and immunotoxicity* studies should be conducted on the final sterilized product, using either device materials and/or appropriate extracts of the device materials. In particular, studies should assess compounds extracted from the materials of the final sterilized device for estrogen-like antigonadotropic activity in an appropriate animal model using scientifically valid methods. Complete reports from acute and subchronic toxicity testing of extractable chemicals contained in the final sterilized device should include gross and histopathological studies in appropriate tissues both surrounding and remote from the implanted site. * For specific and detailed guidance on these studies, please contact the Urology and Lithotripsy Devices Branch at (301) 427- 1194. 2.3 Physical, Mechanical and Reliability Testing 2.3.1 General Requirements Physical, mechanical and reliability tests should be conducted on components, subassemblies, and finished devices of each device model proposed for marketing, as appropriate, and must examine all aspects of device design, construction, and operation. All tests should be performed on components and devices fabricated by representative manufacturing processes and subjected to the final validated sterilization procedures intended for the device. A statistically valid number of samples of each model should be tested. If sample devices of each available size are not tested, it must be clearly indicated which device sizes were used for each test. The absence of testing on each size must be justified by an analysis demonstrating that the results from the tested devices will accurately predict results for the untested device sizes. Copies of typical original data sheets from all tests should be included. For all tests that result in device failure, the failure mode must be completely described. The significance of all tests that result in failure of a device, component, or subassembly to meet specification must be rationalized. If the conditions under which the failed device, component, or subassembly was tested (loads, environments, etc.) are likely to occur in vivo, corrective actions taken to eliminate or minimize further occurance must be identified and modified samples retested. The performance specifications for all components, subassembles, and finished devices, and test conditions and acceptance criteria for all tests should be completely explained and justified by comparison to expected in vivo conditions. All tests should be performed in an environment simulating the possible range of anticipated in vivo conditions (temperatures, pressures, forces, stresses, etc.), including capsular formation, where possible. All methods used to determine the condition of the device after testing, e.g., visual examination, electrical continuity, electron microscope examination, functional testing, etc., should be discussed and justified. If accelerated aging is used to demonstrate device durability and reliability, all processes used should be completely described, and the calculations validating the expected aging should be provided. All data, collected from in vitro and animal testing, regarding the useful lifetime or long term reliability of the device, must be compared to data from clinical studies (prospective and/or retrospective) where the useful lifetime of the device has been determined. This comparison must validate the ability of the in vitro and animal tests to accurately predict the useful lifetime of an implanted device. A failure mode and effects analysis (FMEA) should be conducted and provided. Testing should demonstrate how the proposed device design and manufacturing processes are consistent with the FMEA. Additionally, the effects of implantation, including the stresses of the biological environment, on device function and integrity should be determined by appropriate animal testing. Complete material, chemical and physical characterization and device/ component performance testing should be performed on devices explanted from animals after an appropriate implantation duration. Of special concern is the integrity of the cylinders, reservoir, pump, tubing, joints, etc. Results on tests of explants should be compared to results on unimplanted devices and conclusions about degradation of materials or components drawn. The results of this testing should also be compared to failure rates determined in in vitro tests and clinical studies, in order to demonstrate that the animal model and study duration are appropriate. 2.3.2 Physical Material Characterization Physical tests should include, but are not necessarily limited to, the following, as appropriate. Suggested methodologies are listed where available: tensile strength and ultimate elongation of material specimens taken from cylinders, pumps, reservoirs, and tubing of the finished, sterilized product (ASTM D412). The device materials must possess some minimum level of mechanical strength in order to withstand ruptures from stresses and deformations applied to the components of the device. Tensile strength and ultimate elongation represent respectively the largest sustainable stress and stretching deformation on a test specimen before rupture occurs. energy to rupture, i.e., strain energy to failure, for material specimens taken from each of the above listed device components of the finished, sterilized device. Energy to rupture, determined from the total area under a generated stress-strain curve, represents the total trauma, in units of energy, that a test specimen can endure before rupturing. tear resistance for material specimens taken from each of the above listed device components of the finished, sterilized device (ASTM D624). The device materials must possess some minimum level of protection against the catastrophic propagation of a puncture or small tear. Tear resistance is a measure of this capability. integrity of fused or adhered joints. ASTM F703 contains a methodology, including geometries of test specimens. Unlike ASTM F703, however, the testing should be conducted to and results reported for the failure points of the specimens. The breaking force at failure, normalized to the joint thickness, should be reported for the test specimens. Failure of a fused or adhered joint represents a potential source for leakage of gel-fill and/or liquid-fill from the device. This testing provides a measure of the resistance of the device to such failures. cohesivity and/or penetration testing of gel in devices containing gel. A methodology for gel cohesivity testing is given in ASTM F703. Reported results for gel testing should include the actual measurements of gel slump in gel cohesivity testing and/or measurements of penetrometer fall in gel penetration testing. The chosen test method(s) should be adequately sensitive to detect significant variances in gel cohesivity and/or stiffness. Gel cohesivity testing is designed to measure both the flow properties and integrity, or connectivity, of the gel. In the event of rupture of a gel-containing device component, it is important that the gel maintain some degree of consistency and cohesiveness in order to facilitate surgical removal. Gel cohesivity can, in many respects, be predicted from detailed chemical characterization of the gel product. Knowledge of information such as molecular weight averages of gel components, percentages of cross-linked and uncross-linked components, and average degrees of functionality for precursors of cross-linked components, is important in predicting the degree of cohesion in a gel, as well as its relative tendency to bleed liquid components of the gel. This information should be provided as well. abrasion resistance and analysis of abraded surfaces of silicone and polyurethane device components taken from the final sterilized device. Some elastomeric components (particularly silicone ones) of penile inflatable implants can be relatively soft and prone to abrasive degradation at their surfaces. While being placed in a patient, the prosthesis is rubbed against tissue. When the patient moves, tissue or other anatomic structures move over the prosthesis. Folds or hernias in device components could conceivably cause device component surfaces to rub against one another. Rubbing actions such as these can abrade the surface of the device. Abrasion can lead to weakening of the device component surface making it more prone to mechanically induced trauma. Abrasion can also release small particles of silicone or other elastomers into the body, leading to the formation of granulomas. In addition, abrasion of a silicone elastomer can expose the particles of silica added to reinforce the elastomer. Crystalline silica is recognized as a sclerogen, i.e., an agent which produces hard or sclerotic tissue, capable of causing adverse reactions when placed in the body. Amorphous fumed, rather than crystalline, silica is typically used to reinforce the silicone elastomers of these devices. However, there are still concerns over the presence of minute crystalline silica impurities in the reinforcer and whether there is any significant in vivo conversion of amorphous silica into crystalline silica. The abrasion resistance of the surfaces of elastomeric components and the content and particle size distribution of the material abraded from the elastomeric components must be known in order to determine whether the implant is safe and effective. Reports on abrasion resistance testing of elastomeric components of penile inflatable implants should contain relevant information on the equipment and abrader used, identification and dimensions of specimens, and detailed protocols. In particular, a standard abrasion test machine, or equivalent specialized equipment, should be used to conduct the testing. A description of the test apparatus used, including the number of specimens that can be tested simultaneously, the dimensions (width and length) of both the maximum sample size and the maximum abrading area, and the manner in which specimens are held, should also be provided. The material used to abrade specimens should be identified, and a rationale for choosing this material should be provided as well. Properties of the abrading medium including hardness, roughness, etc., that are pertinent to the abrasion process, also should be identified. As usual, test specimens should be obtained from components of finished sterilized devices. Significant weight losses in abraded material should be induced, and the total number of passes (by the abrasive medium) required to induce this observed weight loss should be reported. Averages, standard deviations, detailed protocols, cycling rates, and raw data should be reported. Examinations for exposed silica (particularly crystalline silica) of both the abraded surfaces and abraded particles from test specimens should be conducted and reported. Percentages of crystalline silica and the total content of crystalline silica in these abraded particles should be analyzed for and reported. Particle size distributions of abraded particles should be reported. The results of these tests must be compared to the energy, stresses, etc., that the device will encounter in vivo. 2.3.3 Device/Component/Subassembly Performance Testing General Device/component/subassembly testing should demonstrate the ability of the device to withstand the demands of use while maintaining operational characteristics sufficient for intercourse throughout the expected operational lifetime of the penile inflatable implant, as stated in the physician and patient labeling. Since in vivo loading histories are somewhat sporadic, a discussion comparing the effects of the rate of cycling in each in vitro test to actual usage conditions and to the expected longevity of the implant should be included. Life tests should be interrupted at appropriate intervals and devices/components/ subassemblies evaluated for relevant performance characteristics and conformance to design specifications. Material characteristics indicative of material degradation that could induce device malfunction should be completely evaluated. Cyclical testing beyond the expected longevity of the implant and recording of failure mode should be included as part of the life tests. Complete Device testing Testing to demonstrate the operational characteristics of the device should include but not necessarily be limited to: amount of pressure generated in the penile cylinder during inflation; rate of pressure rise during inflation and pressure drop during deflation; range of time and number of strokes required for full inflation; ability to maintain the cylinder in a functional inflated condition for the specified duration (valve leakage); symmetry of geometry between cylinder pairs while inflated; time to fully deflate cylinder from fully inflated pressure; all bonds within the device and between components should undergo appropriate testing to include but not be limited to measurement of bond shear and tensile strength. Bond strength should exceed the loads expected during device handling and after implantation; cyclic inflation/deflation tests to demonstrate appropriate functional durability. Filling Agent Permeability The permeability of the filling agent through the reservoir and body of the device must be evaluated to demonstrate that fluid loss due to osmosis will be acceptable over the expected life of the penile inflatable implant. Component Specific Testing Proper component operation, conformance to predetermined operational specifications, and reliability over the expected life of the device must be demonstrated. Resistance of each component to tears, crazing, fracture, material fatigue (including wear between mating components), change of position (e.g., valve seats), and permanent deformation also must be demonstrated. Component characterization and testing should include but not be limited to: Pumps Pump characterization and testing should include but not necessarily be limited to: minimum force required to affect fluid displacement; range of volumes displaced per stroke; squeeze force vs. fluid displacement (volume); inflation effort, defined as pump force times number of strokes required for full inflation; objective confirmation of uniform pump discharge to both penile cylinders. Valves Valve characterization and testing should include but not necessarily be limited to: pump output pressure required to affect valve opening for inflation; tactile pressure/force required to affect valve opening, against fully inflated cylinders, for deflation; back pressure required for valve failure; maximum pressure differential across closed valve at full inflation and leakage rate at this pressure; prevention of spontaneous inflation and deflation under movements and loads simulating those expected to be sustained by the implanted device in both inflated and deflated states; potential for valve failure which could result in an inability to deflate cylinders. Cylinders Cylinder characterization and testing should include but not necessarily be limited to: maximum expansion capability (length and girth); stiffness or rigidity, including resistance to buckling at maximum inflation pressure; resistance to aneurysms; confirmation of concentricity; wear characteristics if a fold in the cylinder develops; burst strength of the cylinder, including all joints and seams, or proof testing demonstrating an adequate margin of safety relative to the maximum inflation pressure; durability tests demonstrating adequate resistance to fatigue caused by cyclic external compression applied radially to the inflated cylinder; durability tests demonstrating adequate resistance to fatigue caused by cyclic oscillation (bending and/or axial buckling) of both inflated and deflated cylinders; applied force at the rate of 1 Hertz versus number of cycles to rupture (AF/N) curve, constructed on the basis of cyclical externally applied radial compression on a fully inflated cylinder. The resultant data points used to construct each curve must be sufficient to plot the asymptotic endurance, or "fatigue force" limit, of the device and to approximately determine the "elbow point", i.e., the location of the maximum change in curvature of the AF/N plot, if any exists. Each curve must also contain an average value for failure of the device due to a single blow, i.e., a single stroke of loading. Horizontal and vertical motions of inflated and deflated devices over the expected operational lifetime of the device must also be evaluated. Reservoirs Reservoir characterization and testing should include but not necessarily be limited to: capacity (volume); pressures experienced over the inflation/deflation cycle; rate of maximum fluid outflow and inflow; wear characteristics if a fold in the reservoir envelope occurs; durability tests demonstrating adequate resistance to fatigue caused by cyclic external compression applied radially to inflated reservoir. Tubing Tubing characterization and testing should include but not necessarily be limited to: tensile characteristics (with and without tubing connectors, if any); tear or rupture resistance; kink resistance; wear characteristics if a fold in the tubing develops. Accessory Components Other components of the penile inflatable implant or accessories such as tubing connectors, extension adapters, and specialized tools used during the insertion procedure should be evaluated appropriately. Testing of these components or accessories should reflect the anticipated conditions of use. For example, extension adapters and tubing connectors should be demonstrated to be able to maintain connection to the device for the expected life of the device. Gel Bleed Testing Silicone bleed permeation, which is the seepage of silicone fluid components of any gel used in a penile prosthesis, is one means by which the device can release silicone into the human body. The body is essentially a fluid receptacle for the liquid silicone released by the device. As the liquid silicone emerges from the component, it can dissipate into the body by at least two mechanisms. The silicone bleed product can be transported away from the device by simple diffusion, that is, liquid flow in the extracellular fluid as this fluid perfuses the region adjacent to the surface of the prosthesis. The bleed product can also be taken up by white blood cells, primarily macrophages in the tissues, and carried to lymph nodes or other organs. Because the liquid silicone is constantly removed from the region of the prosthesis, the bleed process cannot come to a halt. This results in the body acting as an "infinite sink" for the liquid silicone. Steady-state diffusion coefficients for silicone bleed permeation rates from penile prostheses must be determined so that sound estimates can be made of long-term accumulations of silicone into a patient's body. These steady-state diffusion coefficients must be determined for individual components of the silicone bleed as well. Silicone molecules in gel bleed product have a range of molecular weights, which cannot be assumed to be representative of the range of molecular weights found for molecules of silicone fluid in the gel inside the device. In fact, it is likely that silicone molecules of smaller molecular weight possess higher permeability rates through intact penile prostheses than do silicone molecules of higher molecular weight. Thus, the composition of the bleed product is likely, at any given time, to be skewed toward lower molecular weight components in comparison to the composition of the fluid components of the gel inside the device. These lower molecular weight silicone molecules are also more likely to stimulate biological activity. Therefore, accurate assessments of the likelihood of long-term toxicological responses to an implanted prosthesis (that remains intact) require accurate dose rates of individual liquid silicone components in the bleed, especially those of the lowest molecular weights. Various methodologies for performing liquid silicone bleed permeation testing have been used or proposed. Measured coefficients for diffusion of components of liquid silicone through a prosthesis are largely dependent upon the receptacle medium used to collect the bleed. It is possible to conduct the experiment using either a solid-state medium or a liquid-state medium. While, in general, solid-state receptacles are easier to use, there are major drawbacks associated with them. The major drawback to using a solid-state medium is the potential for significant loss of volatile silicones of low molecular weight. Unlike a liquid receptacle diffusion cell, the placement of a penile prosthesis on a disk or a filter is an experimental system open to air or vacuum. Substantial amounts of volatile silicones may be lost (during the bleed experiment and/or during subsequent extraction of the disk or filter) and thus excluded from compositional analysis of the bleed product. Yet, as explained earlier, it is vital that accurate short-term and long- term dose rates of these low molecular weight, volatile silicones be established. Therefore, a liquid-state receptacle medium must be used to conduct liquid silicone bleed experiments in order to adequately assess the potential risks attributable to liquid silicone bleed from penile prostheses. A stirred receptacle medium of physiological saline is the best means of emulating actual in vivo bleed rates. Stirring of the saline medium is necessary to more accurately account for the "infinite sink" conditions which, as discussed earlier, exist in the body. Stirring of the saline medium transports a portion of the poorly soluble silicones from the membrane surface such that a concentration gradient in the vicinity of the surface is maintained. In summary, bleed permeation experiments must be conducted as following: A standard liquid diffusion cell, maintained at a temperature simulating physiologic conditions must be employed. The upper compartment must consist of gel obtained from a sterilized, finished, and manufactured penile prosthesis. The membrane must consist of component materials obtained from the same sterilized, finished, and manufactured device from which the gel sample was obtained. The bottom compartment must consist of the receptacle medium for the liquid silicone bleed product. Each variety of gel-containing component varying significantly in thickness or design must be tested separately. Each variation in gel must be tested separately. Control cells must also be employed to correct measurements for background levels of silicone. Stirred physiological saline should be used as a receptacle medium. While CDRH believes that useful information (as to a "worst possible case" scenario) can still be obtained from a bleed experiment into a hydrocarbon solvent, the priority for testing into stirred saline is much greater. In any case, if a manufacturer believes that a different solvent is more suitable to the bleed experiment, full justification must be provided to CDRH as to the choice of solvent. Sufficient amounts of liquid silicone bleed must be collected and analyzed on a time-course basis such that both short-term accumulation amounts and long-term, i.e., steady-state, diffusion coefficients of both total bleed and individual components of liquid silicone bleed can be estimated. Analyses of bleed permeation data indicate that limiting steady-state coefficients can be obtained from properly conducted experiments provided sufficient time is allowed to establish equilibrium bleed rates. The intervals at which bleed product is analyzed for chemical identity and molecular weight shall be determined by the manufacturer, but must be such that steady-state diffusion coefficients, particularly of low molecular weight silicones, can be determined with sufficient accuracy. It is not sufficient for a manufacturer to simply measure the total weight of liquid silicone bleed as a function of time. The bleed product must be adequately analyzed and resolved in order to determine accurate dose rates of smaller linear and cyclical silicones of, e.g., molecular weights of 1500 or less. All extraction procedures for these low molecular weight silicones must be validated for percent recovery. Additional parameters needed to estimate long-term in vivo accumulation rates of liquid silicone components must also be provided. These parameters include the normalized cross-sectional area of each and every membrane tested, the average thickness of each and every membrane tested, estimates of the total surface area (for the intact device) of each gel-containing component tested, and estimates of the minimum and maximum surface areas for the size range of each type of gel-containing component tested. As with all other physical and chemical testing reports, detailed protocols, calculation methods, all raw data (on a time-course basis), and calculated averages with standard deviations must be provided. 3. Clinical data Valid scientific evidence, as defined in 21 CFR 860.7, should include information from well-controlled, prospective, clinical studies, with statistically justified sample size and detailed long-term follow-up, in order to provide reasonable assurance of the safety and effectiveness of the penile inflatable implant. A detailed protocol for the clinical trial with explicit patient inclusion/exclusion criteria, clear study objectives, and a well-defined follow-up schedule should be specified. FDA believes that 5-year follow-up data are necessary in order to characterize the safety and effectiveness of the device over its expected lifetime; however, appropriately justified alternate follow-up schedules will be considered. Any deviations from the protocol should be stated and justified. Time course presentations of patient/partner satisfaction with and psychological benefit from the implantation of this device as well as information on the anatomical and physiological effects of the penile inflatable implant (including all adverse events) should be provided. Full patient accounting should be reported, including: (1) theoretical follow- up (the number of patients that would have been examined if all patients were examined according to their follow-up schedules); (2) patients lost to follow-up, including the measures taken to minimize such events (with all information obtained on patients lost to follow-up); (3) time course of revisions, including all explant and repair data; and (4) time course of deaths (stating the cause of death, including the reports from any postmortem examinations). As part of this, each clinical report should clearly state the date that the database was closed to the addition of new information. Detailed patient demographic analyses and characterizations should be presented, and should show that the patients enrolled in the study are representative of the population for whom the device is intended. A statistical demonstration, based on the number of patients who complete the required study period, should show that the sample size of the clinical study is adequate to provide accurate measures of the safety and effectiveness of this device. The statistical demonstration should identify the effect criteria, reasonable levels for Type I (alpha) and Type II (beta) errors, and anticipated variances of the response variables and provide any assumptions or statistical formulas with copies of any references used and all calculations used. A complete description of any patient randomization technique used, and how these techniques were employed to exclude potential sources of bias, should be provided. Statistical justifications for pooling across several variables such as the etiology and duration of impotence, anatomical abnormalities of the genitalia, the number and type of treatments (if any) attempted to restore potency prior to device implantation, device usage (initial implantation versus revision), the frequency of device use post-implantation, degree of manual dexterity, investigational site, surgeon experience and technique, and incision site should be provided. The data collected and reported should include all possible relevant variables in order to permit stratification and analysis of the study data. This is necessary in order to evaluate the risk/benefit ratio for each unique subpopulation of patients. Appropriate control/comparison groups should be included and justified and, if not, their absence must be justified. All hypotheses to be tested must be clearly stated. Appropriate statistical techniques must be employed to test these hypotheses and support claims of safety and effectiveness. For each relevant subgroup, a sufficient number of patients needs to be followed for a sufficient length of time to adequately support all claims (explicit and implied) in any PMA submission. To evaluate the risks to the patient from the penile inflatable implant, such studies should include time course presentations of clinical data demonstrating the presence or absence of device leakage, tubing bending/kinking or disconnection, cylinder aneurysm or rupture, valve failure, spontaneous inflation/deflation, component migration, extrusion, skin erosion, infection, iatrogenic injury, hematoma, excessive fibrous capsular growth, pain, sensory loss, patient dissatisfaction leading to surgical removal, or any other device malfunction or adverse health event, including any effects on the immune system (both local to the device and systemic) and the reproductive system, without regard to the device relatedness of the event. The diagnostic criteria for each type of immunological and allergic phenomenon should be defined at the beginning of the study, and all cases should be well documented utilizing these criteria. Patients must be regularly monitored for the occurrence of such adverse events for a minimum of 5 years post-implantation. FDA recognizes that the primary benefit of the penile inflatable implant is the restoration of penile erectile function. The effectiveness of the device can probably be measured by assessing (1) the ability of the device in vivo to provide adequate rigidity (as well as length/girth enhancement, if such claims are made) to the penis to permit coitus; (2) the degree of maintenance or enhancement of a male's psychological well- being post-implantation; (3) partner satisfaction with the device; and (4) the enhancement of the male's ability to conceive naturally, as a result of the improved intromission provided by the implant (provided that the patient's semen quality was sufficient for conception prior to implantation); all of which can be balanced against any illness or injury from the use of the device. FDA understands that evaluation of the degree of benefit, in part, involves an assessment of patient satisfaction and psychological well- being, particularly in light of the function of the device. Such evaluation includes subjective factors, relates to patient expectations, and may be transient in nature. Device effectiveness is also dependent upon the degree of partner satisfaction with the implant's performance, since this can directly relate to the patient's own perception of self image. Assessments of enhanced fertility and penile rigidity, length, and girth post-implantation, on the other hand, should provide some objective measure of device effectiveness. The evaluation parameters for this portion of the clinical study should be structured for an objective and standardized recording/measurement of: (1) the psychological benefit of the device to the implant recipient (as well as to his sexual partner), including any improvement in quality of life; (2) the quality of the erection provided by the implant; and (3) an increase in the rate of conception (in those patients interested in future fertility). The primary requirements for an acceptable scientific documentation of psychological benefits of the device (to both the implant recipient and his partner) are the use of (1) prospective research designs, including pre- and post-surgical repeated measures; (2) appropriate control/comparison groups; and (3) standardized test questions rather than informal, yet-validated questionnaires. Any questionnaire utilized in the documentation of the psychological consequences of penile inflatable implants must be shown to provide a scientifically valid measure of the psychological effects of impotency upon males and their partners. Documentation of these psychological consequences shall include (1) pre-surgical baseline assessment of psychological status, including measures of the perceived loss that these subjects experience and their expectations for improvement with the device; (2) regular post-surgical follow-up of any changes in psychological status for at least 5 years; (3) statistical comparison of post-surgical psychological test scores versus pre-surgical test scores within the group of treated patients; (4) statistical comparison of psychological test scores of treated patients versus untreated control patients at all pre- surgical and post-surgical assessment intervals; and (5) correlation of the psychological data with the physical outcomes of the implant procedure. Documentation of the anatomical and physiologic outcomes of implantation of a penile inflatable implant shall include: (1) regular post-surgical evaluations of the inflation, dimensional, rigidity/stiffness, and deflation characteristics provided by the device for at least 5 years post-implantation; and (2) patient/partner assessments of the mechanical function of the implant (such as ease of inflation, quality of the erection, ability of the device to operate and function reliably, etc.) during this follow-up period (which may be influenced by the manual dexterity of the patient and/or partner). Documentation of the effect of the penile inflatable implant upon the fertility of the male shall include: (1) an assessment of the conception rate among those implant recipients who are interested in future fertility; and (2) comparison of this rate to either the conception rate of this patient cohort prior to receiving the implant, or the rate of conception in an appropriate control population. Any PMA for the penile inflatable implant should separately analyze the degree of device safety and efficacy by the following variables: (1) etiology and duration of erectile dysfunction; (2) anatomical abnormalities of the genitalia; (3) the number and type of treatments (if any) attempted to restore potency prior to device implantation; (4) device usage (initial implantation versus revision); (5) frequency of device usage post- implantation; (6) degree of manual dexterity; (7) investigational site; (8) surgeon experience and technique; (9) incision site; and (10) degree of sexual therapy provided to the subject postoperatively. Furthermore, for each explantation procedure performed on the study subjects, the following information must be provided: (1) the mode of failure of the removed device; (2) whether or not the explanted device was replaced with a new device; and (3) either the manufacturer, type, and model of the new device (if another penile implant was implanted), or the type of treatment (if any) that the patient received for his impotence (if revision surgery was not performed). Additionally, the effect of the presence of these implants upon future medical diagnoses/treatments to the lower pelvic region in recipients of penile inflatable implants must be analyzed. Furthermore, any accessories that are sold with the penile inflatable implant (such as corporal dilators, suturing tools, etc.) must be shown to have been effectively used in implant procedures without adverse effects. Lastly, each clinical investigation should validate the physician and patient instructions for use (labeling) that were utilized. For the polyurethane elastomer covered implants, the following information needs to be presented: (1) the kinetics of the end products generated from the degradation of the polyurethane elastomer (in vivo); (2) the frequency and incidence of infection and complication of retrieval of the implant by surgeons using both polyurethane and non-polyurethane covered implants in a retrospective cohort study; and (3) the neoplasticity of the material as well as its general toxicity, including neurological, physiological, biochemical, and hematological effects, as well as pathology following prolonged and repeated exposure to polyurethane elastomer penile inflatable implants. Any epidemiological studies that are submitted should contain enough subjects to detect a small but significant increase in one or more connective tissue diseases (especially scleroderma) that may be associated with the use of the device. The agency believes that insufficient time has elapsed to permit a direct evaluation of the risks of cancer and immune related connective tissue disorders posed by the presence of silicone in the human body and that sufficient epidemiological data or experimental animal data is not available to make a reasonable and fair judgement. Therefore, the agency will require long-term postapproval follow-up for any penile inflatable implant permitted to continue in commercial distribution. Well-designed clinical prospective studies with long-term follow-up together with experimental animal studies will be considered as essential in the determination of safety and effectiveness of the device. Further, these clinical studies must collect long-term data on the reproductive/teratogenic effects of the device as well as the later effects on offspring. The risk/benefit assessment (as with the entire PMA) must rely on valid scientific evidence as defined in 21 CFR 860.7(c)(2) from well- controlled studies as described in 21 CFR 860.7(f) in order to provide reasonable assurance of the safety and effectiveness of the penile inflatable implant in the treatment of erectile dysfunction in the male. 4. Labeling Copies of all proposed labeling for the device, including any information, literature, or advertising that constitutes labeling under Section 201(m) of the act, should be provided. The general labeling requirements for medical devices are contained in 21 CFR Part 801. These regulations specify the minimum requirements for all devices. Additional guidance regarding device labeling can be obtained from FDA's publication "Labeling: Regulatory Requirements for Medical Devices," and from the Office of Device Evaluation's "Device Labeling Guidance"; both documents are available upon request from the Division of Small Manufacturers Assistance (HFZ-220), Center for Devices and Radiological Health, Food and Drug Administration, 5600 Fishers Lane, Rockville, MD 20857. Highlighted below is additional guidance for some of the specific labeling requirements for penile inflatable implants. The intended use statement should include the specific indications for use and identification of the target populations. Specific indications and target populations must be completely supported by the clinical data described above; for example, it may be necessary to restrict the intended use to patients who have failed prior less invasive therapies and/or to patients with specific etiologies of impotence in whom safety and effectiveness have been demonstrated. The directions for use should contain comprehensive instructions regarding the preoperative, perioperative and postoperative procedures to be followed. This information includes but is not necessarily limited to, (1) a description of any pre-implant training necessary for the surgical team; (2) a description of how to prepare the patient (e.g., prophylactic antibiotics), operating room (e.g., what supplies must be on hand), and penile inflatable implant (e.g., handling instructions, resterilization instructions) for device implantation; (3) instructions for implantation, including surgical approach, sizing, fluid adjustment (including what filling solutions may be used and how they must be prepared), device handling, and intraoperative test procedures to ensure implant functionality and proper placement; (4) and instructions for follow-up, including whether patient antibiotic prophylaxis is recommended during the post-implant period and during any subsequent dental or other surgical procedures, how to determine when patients are ready to attempt intercourse and begin periodic activation, and how to evaluate proper functionality and placement, and how often. The directions should instruct caregivers to specifically question patients prior to surgery for any history of allergic reaction to any of the device materials or filling agents. Troubleshooting procedures should be completely described. The directions for use should incorporate the clinical experience with the implant, and should be consistent with those provided in other company-provided labeling. The labeling should include both implant and explant forms to allow the sponsor to adequately monitor device experience. The explant form should allow collection of all relevant data, including the reason for the explant, any complications experienced and their resolution, and any action planned (e.g., replacement with another implant). Patient labeling must be provided which includes the information needed to give prospective patients realistic expectations of the benefits and risks of device implantation. Such information should be written and formatted so as to be easily read and understood by most patients and should be provided to patients prior to scheduling implantation, so that each patient has sufficient time to review the information and discuss it with his physician(s) and sexual partner. Technical terms should be kept to a minimum and should be defined if they must be used. Patient information labeling should not exceed the seventh grade reading comprehension level. The patient labeling should provide the patient with the following information. (1) The indications for use and relevant contraindications, warnings, precautions and adverse effects/ complications should be described using terminology well known and understood by the average layman. (2) The anticipated benefits and risks associated with the device must be provided to give patients realistic expectations of device performance and potential complications. The known, suspected and potential risks of device implantation should be identified and the consequences, including possible methods of resolution, should be described. The patient should be advised that penile length and/or width reductions may occur, and that any latent erectile capability will be impaired by implantation of a penile inflatable implant. (3) Alternatives available to the use of the device, including less invasive treatments, should be identified, along with a description of the associated benefits and risks of each. The patient should be advised to contact his physician for more information on which of these alternatives might be appropriate given his specific condition. (4) Instructions for how to use the device must be provided to the patient. This information should include the expected length of recovery from surgery and when to resume intercourse following implantation, whether and how often the device should be periodically inflated (if applicable), warnings against certain actions (e.g., repeated flexing) that could damage the device, how to identify conditions that require physician intervention, who to contact if questions arise, and other relevant information. (5) The fact that the implant should not be considered a "lifetime" implant must be emphasized. Where possible, provide information on the approximate number of revisions necessary in the average patient, and indicate the average longevity of each implant so patients are fully aware that additional surgery for device modification, replacement, or removal may be necessary. This information must be supported by the clinical experience (i.e., not merely bench studies) with the implant or by published reports of experience with similar devices. The physician's labeling should instruct the urologist or implanting surgeon to provide the implant candidate with the patient labeling prior to surgery to allow each patient sufficient time to review and discuss this information with his physician(s) and sexual partner. The adequacy and appropriateness of the instructions for use provided to physicians and patients should be verified as part of the clinical investigations. Applicants should submit any PMA in accordance with FDA's "Premarket Approval (PMA) Manual." The guidance is available upon request from the Division of Small Manufacturers Assistance (HFZ-220), Center for Devices and Radiological Health, Food and Drug Administration, 5600 Fishers Lane, Rockville, MD. 20857. 5. References (Risks and Benefits Associated with Penile Implants) 1. Carson, C.C., "Infections in Genitourinary Prostheses," Urologic Clinics of North America, 16(1): 139-147, 1989. 2. Fishman, I.J., "Complicated Implantations of Inflatable Penile Prostheses," Urologic Clinics of North America, 14(1): 217-239, 1987. 3. Kabalin, J.N., and R. Kessler, "Infectious Complications of Penile Prosthesis Surgery," The Journal of Urology, 139(5): 953-955, 1988. 4. Merrill, D.C., "Clinical Experience with the Mentor Inflatable Penile Prosthesis in 301 Patients," The Journal of Urology, 140(6): 1424- 1427, 1988. 5. Merrill, D.C., "Mentor Inflatable Penile Prostheses," Urologic Clinics of North America, 16(1): 51-66, 1989. 6. Walters, F.P., D.E. Neal, Jr., A.B. Rege, W.J. George, M.J. Ricci, and W.J.G. Hellstrom, "Cavernous Tissue Antibiotic Levels in Penile Prosthesis Surgery," The Journal of Urology, 147(5): 1282-1284, 1992. 7. Wilson, S.K., G.E. Wahman, and J.L. Lange, "Eleven Years of Experience with the Inflatable Penile Prosthesis," The Journal of Urology, 139(5): 951-952, 1988. 8. Parulkar, B.G., and D.M. Barrett, "Combined Implantation of Artificial Sphincter and Penile Prostheses," The Journal of Urology, 142(3): 732-735, 1989. 9. McClellan, D.S., and B.K. Masih, "Gangrene of the Penis as a Complication of Penile Prosthesis," The Journal of Urology, 133(5): 862- 863, 1985. 10. Thomas, C.L. (ed.), "Taber'sR Cyclopedic Medical Dictionary," 15th Edition, F.A. Davis Company, Philadelphia, pp. 569, 591 and 1052, 1985. 11. Carson, C.C., "Genitourinary Prostheses," in S.D. Graham, Jr. (ed.), Urologic Oncology, New York, Raven Press, pp. 459-470, 1986. 12. Dupont, M.C., and H.I. Hochman, "Erosion of an Inflatable Penile Prosthesis Reservoir into the Bladder, Presenting as Bladder Calculi," The Journal of Urology, 139(2): 367-368, 1988. 13. Fein, R.L., "Clinical Evaluation of Inflatable Penile Prosthesis with Combined Pump-Reservoir," Urology, 32(4): 311-314, 1988. 14. Gasser, T.C., E.H. Larsen and R.G. Bruskewitz, "Penile Prosthesis Reimplantation," The Journal of Urology, 137(1): 46-47, 1987. 15. Godiwalla, S.Y., J. Beres, and S.C. Jacobs, "Erosion of an Inflatable Penile Prosthesis Reservoir into an Ileal Conduit," The Journal of Urology, 137(2): 297-298, 1987. 16. Mulcahy, J.J., "A Technique of Maintaining Penile Prosthesis Position to Prevent Proximal Migration," The Journal of Urology, 137(2): 294-296, 1987. 17. Brooks, M.B., "42 Months of Experience with the Mentor Inflatable Penile Prosthesis," The Journal of Urology, 139(1): 48-49, 1988. 18. Fein, R.L., "Cylinder Problems with AMS 700 Inflatable Penile Prosthesis," Urology, 31(4): 305-307, 1988. 19. Fein, R.L., "The G. F. S. Mark II Inflatable Penile Prosthesis," The Journal of Urology, 147(1): 66-68, 1992. 20. Kabalin, J.N., and R. Kessler, "Penile Prosthesis Surgery: Review of Ten-Year Experience and Examination of Reoperations," Urology, 33(1): 17-19, 1989. 21. Moul, J.W., and D.G. McLeod, "Negative Pressure Devices in the Explanted Penile Prosthesis Population," The Journal of Urology, 142(3): 729-731, 1989. 22. Furlow, W.L., and B. Goldwasser, "Salvage of the Eroded Inflatable Penile Prosthesis: A New Concept," The Journal of Urology, 138(2): 312-314, 1987. 23. Steidle, C.P., and J.J. Mulcahy, "Erosion of Penile Prostheses: A Complication of Urethral Catheterization," The Journal of Urology, 142(3): 736-739, 1989. 24. Furlow, W.L., and R.C. Motley, "The Inflatable Penile Prosthesis: Clinical Experience with a New Controlled Expansion Cylinder," The Journal of Urology, 139(5): 945-946, 1988. 25. Knoll, L.D., W.L. Furlow, and R.C. Motley, "Clinical Experience Implanting an Inflatable Penile Prosthesis with Controlled-Expansion Cylinder," Urology, 36(6): 502-504, 1990. 26. Weese, D.L., and P.E. Zimmern, "Corporeal Perforation or Undersized Prosthesis? The Role of Corpus Cavernosum Endoscopy," The Journal of Urology, 144(3): 714-716, 1990. 27. Sender, M.B., M.A. Koyle, and J. Rajfer, "Complications of Scrotal Surgery," in R.B. Smith and R.M. Ehrlich (eds.), Complications of Urologic Surgery: Prevention and Management, Philadelphia, Harcourt Brace Jovanovich, Inc., pp. 528-529, 1990. 28. Barrett, D.M., D.C. O'Sullivan, A.A. Malizia, H.M. Reiman, and P.C. Abell-Aleff, "Particle Shedding and Migration from Silicone Genitourinary Prosthetic Devices," The Journal of Urology, 146(2): 319-322, 1991. 29. Bertram, R.A., C.C. Carson, III, and L.F. Altaffer, "Sever Penile Curvature after Implantation of an Inflatable Penile Prosthesis," The Journal of Urology, 139(4): 743-745, 1988. 30. Fitch, III, W.P., and T. Roddy, "Erosion of Inflatable Penile Prosthesis Reservoir into Bladder," The Journal of Urology, 136(5): 1080, 1986. 31. Montague, D.K., "Penile Prostheses: An Overview," Urologic Clinics of North America, 16(1): 7-12, 1989. 32. Kaufman, J.J., A. Linder, and S. Raz, "Complications of Penile Prosthesis Surgery for Impotence," The Journal of Urology, 128(6): 1192- 1194, 1982. 33. Fallen, M.J., and R.W. Lewis, "Experience with a Two-Piece Inflatable Penile Prosthesis," Abstract, The Journal of Urology, 143(4): 409A, 1990. 34. McLaren, R.H., and R.W. Lewis, "Analysis of Reoperation in the Patient with Inflatable Penile Prosthesis," Abstract, The Journal of Urology, 143(4): 408A, 1990. 35. Montague, D.K., "Experience with Semirigid Rod and Inflatable Penile Prostheses," The Journal of Urology, 129(5): 967-968, 1983. 36. Joseph, D.B., R.C. Bruskewitz, and R.C. Benson, "Long-Term Evaluation of the Inflatable Penile Prosthesis," The Journal of Urology, 131(4): 670-673, 1984. 37. Malloy, T.R., A.J. Wein, and V.L. Carpiniello, "Reliability of AMS M700 Inflatable Penile Prosthesis," Urology, 28(5): 385-387, 1986. 38. Merrill, D.C., "Clinical Experience with Mentor Inflatable Penile Prosthesis in 206 Patients," Urology, 28(3): 185-189, 1986. 39. Stanisic, T.H., and J.C. Dean, "The Flexi-Flate and Flexi-Flate II Penile Prostheses," Urologic Clinics of North America, 16(1): 39-49, 1989. 40. Fallon, B., and W.L. Gerber, "New Complication of Inflatable Penile Prosthesis," Urology, 18(4): 405, 1981. 41. Goulding, F.J., "Fracture of Hydroflex Penile Implant," Urology, 30(5): 490-491, 1987. 42. Furlow, W.L., B. Goldwasser, and J.C. Gundian, "Implantation of Model AMS 700 Penile Prosthesis: Long-Term Results," The Journal of Urology, 139(4): 741-742, 1988. 43. Mulcahy, J.J., "The Hydroflex Penile Prosthesis," Urologic Clinics of North America, 16(1): 33-38, 1989. 44. Mulcahy, J.J., "The Hydroflex Self-Contained Inflatable Penile Prosthesis: Experience with 100 Patients," The Journal of Urology, 140(6): 1422-1423, 1988. 45. Gregory, J.G., and M.H. Purcell, "Scott's Inflatable Penile Prosthesis: Evaluation of Mechanical Survival in the Series 700 Model," The Journal of Urology, 137(4): 676-677, 1987. 46. Beaser, R.S., C. Van der Hoek, A.M. Jacobson, T.M. Flood, and R.E. Desautels, "Experience with Penile Prostheses in the Treatment of Impotence in Diabetic Men," Journal of the American Medical Association, 248(8): 943-948, 1982. 47. Diokno, A.C., "Asymmetric Inflation of the Penile Cylinders: Etiology and Management," The Journal of Urology, 129(6): 1127-1130, 1983. 48. Earle, C.M., G.R. Watters, A.G.S. Tulloch, Z.S. Wisniewski, D.J. Lord, and E.J. Keogh, "Complications Associated with Penile Implants Used to Treat Impotence," Australia and New Zealand Journal of Surgery, 59: 959- 962, 1989. 49. Casey, W.C., "Tubing Kinks in Inflatable Penile Prosthesis: A Cause and Prevention," Urology, 20(5): 542, 1982. 50. Engel, R.M.E., and R.L. Fein, "Mentor GFS Inflatable Prostheses," Urology, 35(5): 405-406, 1990. 51. Malloy, T.R., V.L. Carpiniello, and A.J. Wein, "Mechanical Stability AMS M700 CX Inflatable Penile Prosthesis Cylinders," Abstract, The Journal of Urology, 139(4): 329A, 1988. 52. Stanisic, T.H., J.C. Dean, J.M. Donovan, and L.E. Beutler, "Clinical Experience with a Self-Contained Inflatable Penile Implant: The Flexi-Flate," The Journal of Urology, 139(5): 947-950, 1988. 53. McLaren, R.H., and D.M. Barrett, "Patient and Partner Satisfaction with the AMS 700 Penile Prosthesis," The Journal of Urology, 147(1): 62-65, 1992. 54. Whalen, R.K., and D.C. Merrill, "Patient Satisfaction with Mentor Inflatable Penile Prosthesis," Urology, 37(6): 531-539, 1991. 55. Boyd, S.D., and W. M. Schiff, "Inflatable Penile Prostheses in Patients Undergoing Cystoprostatectomy with Urethrectomy," The Journal of Urology, 141(1): 60-62, 1989. 56. Merrill, D.C., "Clinical Experience with Scott Inflatable Penile Prosthesis in 150 Patients," Urology, 22(4): 371-375, 1983. 57. Fallon, B., S. Rosenberg, and D.A. Culp, "Long-Term Follow-up in Patients with an Inflatable Penile Prosthesis," The Journal of Urology, 132(2): 270-271, 1984. 58. Medical Device Reporting (MDR) and Product Problem Reporting (PPR), Device Experience Network (DEN), FDA. 59. Witherington, R., "Mechanical Devices for the Treatment of Erectile Dysfunction," American Family Physician, 43(5): 1611-1620, 1991. 60. Klabalin, J.N., and R. Kessler, "Experience with the Hydroflex Penile Prosthesis," The Journal of Urology, 141(1): 58-59, 1989. 61. Ball, Jr., T.P., "Surgical Repair of Penile 'SST' Deformity," Urology, 15: 603-604, 1980. 62. Engel, R.M.E., J.K. Smolev, and R. Hackler, "Mentor Inflatable Penile Prosthesis," Urology, 29(5): 498-500, 1987. 63. Knoll, L.D., W.L. Furlow, and R.C. Benson, Jr., "Management of Peyronie Disease by Implantation of Inflatable Penile Prosthesis," Urology, 36(5): 406-409, 1990. 64. Walther, P.J., R.T. Andriani, M.I. Maggio, and C.C. Carson, III, "Fournier's Gangrene: A Complication of Penile Prosthetic Implantation in a Renal Transplant Patient," The Journal of Urology, 137(2): 299-300, 1987. 65. Tiefer, L., S. Moss, and A. Melman, "Follow-up of Patients and Partners Experiencing Penile Prosthesis Malfunction and Corrective Surgery," Journal of Sex and Marital Therapy, 17(2): 113-128, 1991. 66. Schover, L.R., "Sex Therapy for the Penile Prosthesis Recipient," Urologic Clinics of North America, 16(1): 91-98, 1989. 67. Nelson, R.P., "Male Sexual Dysfunction: Evaluation and Treatment," Southern Medical Journal, 80(1): 69-74, 1987. 68. Bischoff, F., and G. Bryson, "Carcinogenesis Through Solid State Surfaces," Progress in Experimental Tumor Research, 5: 85-133, 1964. 69. Hueper, W.C., "Cancer Induction by Polyurethane and Polysilicone Plastics," Journal of the National Cancer Institute, 33: 1005-1027, 1964. 70. Hueper, W.C., "Carcinogenic Studies on Water-Soluble and Insoluble Macromolecules," Archives of Pathology and Laboratory Medicine, 67: 589-617, 1959. 71. Maekawa, A., T. Ogiu, H. Onodera, K. Furuta, C. Matsuoka, Y. Ohno, H. Tanigawa, G.S. Salmo, M. Matsuyama, and Y. Hayashi, "Malignant Fibrous Histiocytomas Induced in Rats by Polymers," Cancer Research and Clinical Oncology, 108: 364-365, 1984. 72. Pedley, R.B., G. Meachim, and D.F. Williams, "Tumor Induction by Implant Materials," in "Fundamental Aspects of Biocompatibility," vol. 2, D.F. Williams (ed.), CRC Critical Reviews in Biocompatibility, CRC Press, Boca Raton, FL., pp. 165-202, 1981. 73. Benjamin, E., A. Ahmed, A.T.F. Rashid, and D.H. Wright, "Silicone Lymphadenopathy: A Report of Two Cases, One with Concomitant Malignant Lymphoma," Diagnostic Histopathology, 5: 133-141, 1982. 74. Digby, J.M., and A.L. Wells, "Malignant Lymphoma with Intranodal Refractile Particles After Insertion of a Silicone Prostheses," Lancet, 2: 580, 1981. 75. Morgenstern, L., S.H. Gleischman, S.L. Michel, J.E. Rosenberg, I. Knight, and D. Goodman, "Relation of Free Silicone to Human Breast Carcinoma," Archives of Surgery, 120: 573-577, 1985. 76. Zafiracopoulos, P., and A. Rouskas, "Breast Cancer at Site of Implantation of Pacemaker Generator," letter to the editor, Lancet, p. 1114, June 1, 1974. 77. Le Vier, R.R., and M.E. Jankowiak, "Effects of Oral 2,6-cis- Diphenylhexamethylcyclotetrasiloxane on the Reproductive System of the Male Rat," Toxicology and Applied Pharmacology, 21: 80-88, 1972. 78. Bates, H., R. Filler, and C. Kimmel, "Developmental Toxicity Study of Polydimethylsiloxane Injection in the Rat," Teratology, 31:50A, 1985. 79. Haley, T.J., "Biocompatibility of Monomers," in Systemic Aspects of Biocompatibility, vol. 2, pp. 59-90, Williams, D.F. (ed.), CRC Series in Biocompatibility, Boca Raton, FL., 1981. 80. Kennedy, G.L., M.L. Keplinger, and J.C. Calandra, "Reproductive, Teratologic and Mutagenic Studies with Some Polydimethylsiloxanes," Journal of Toxicology and Environmental Health, 1: 909-920, 1976. 81. Varga, J., H.R. Schumacher, and S.A. Jimenez, "Systemic Sclerosis after Augmentation Mammoplasty with Silicone Implants," Annals of Internal Medicine, 111: 337-383, 1989. 82. Picha, G.J., and J.A. Goldstein, "Analysis of the Soft-Tissue Response to Components Used in the Manufacture of Breast Implants: Rat Animal Model," Plastic and Reconstructive Surgery, 87: 490-500, 1991. 83. Baker, J.L. et al., "Positive Identification of Silicone in Human Mammary Capsular Tissue," Plastic and Reconstructive Surgery, 69: 56, 1982. 84. Barker, D.E., M.I. Retsky, and S. Schultz, "Bleeding of Silicone from Bag-gel Breast Implants, and Its Clinical Relation to Fibrous Capsule Reaction," Plastic and Reconstructive Surgery, 61: 836-841, 1978. 85. Brody, G.S., "Fact and Fiction About Breast Implant 'Bleed'," Plastic and Reconstructive Surgery, 60: 615, 1977. 86. Gayou, R., and R. Rudolph, "Capsular Contraction Around Silicone Mammary Prostheses," Annals of Plastic Surgery, 2(1): 62-71, 1979. 87. Gibbons, D.F., et al., "Wear and Degradation of Retrieved Ultrahigh Molecular Weight Polyethylene and Other Polymeric Implants," in B.C. Syrett and A. Acharya (eds.), "Corrosion and Degradation of Implant Materials," American Society for Testing and Materials (ASTM), Kansas City, MO, Philadelphia ASTM, pp. 20-40, 1979. 88. Hausner, R.J., et al., "Migration of Silicone Gel to Auxiliary Lymph Nodes After Prosthetic Mammoplasty," Archives of Pathology Laboratory Medicine, 195: 371-372, 1981. 89. Jenny, H., and J. Smahel, "Clinicopathologic Correlations in Pseudocapsule Formation After Breast Augmentation," Aesthetic Plastic Surgery, 5: 63-68, 1981. 90. Mandel, M.A., and D.F. Gibbons, "The Presence of Silicone in Breast Capsules," Aesthetic Plastic Surgery, 3: 219-225, 1979. 91. Smahel, J., "Foreign Material in the Capsules Around Breast Prostheses and the Cellular Reaction To It," British Journal of Plastic Surgery, 32: 35-42, 1979. 92. Wickham, M.G., et al., "Silicon Identification in Prosthesis- Associated Fibrous Capsules," Science, 199: 437-439, 1978. 93. "Bioassay of 2,4-Diaminotoulene for Possible Carcinogenicity," Bethesda, Maryland: National Institutes of Health, U.S. Department of Health, Education and Welfare, Publication 79-1718, 1979. 94. "Carcinogenesis Studies of 4,4'-Methylenedianiline Dihydrochloride (CAS No. 13552-44-8) in F334/N Rats and B6C3F1 Mice (Drinking Water Studies)," National Toxicology Program, Technical Report No. 248, 1983. 95. Kessler, R., "Complications of Inflatable Penile Prostheses," Urology, 18(5): 470-472, 1981. 96. Flanagan, M.J., E.B. Krisch, and W.L. Gerber, "Complication of a Penile Prosthesis Reservoir: Venous Compression Masquerading as a Deep Venous Thrombosis," The Journal of Urology, 146(3): 847-848, 1991. 97. Nelson, R.P., and J.C. Gregory, "Gonococcal Infections of Penile Prostheses," Urology, 31(5): 391-394, 1988. 98. Scott, F.B., "Outpatient Implantation of Penile Prostheses Under Local Anesthesia," Urologic Clinics of North America, 14(1): 177-185, 1987. 99. Lief, H.I., "Sex and the Physician," Sexual Problems in Medical Practice, American Medical Association, pp. 3-8, 1981. 100. Masters, W.H., and V.E. Johnson, "Secondary Impotence," Human Sexual Inadequacy, Boston, Little, Brown and Company, pp. 157-192, 1970. 101. Pedersen, B., L. Tiefer, M. Ruiz, and A. Melman, "Evaluation of Patients and Partners 1 to 4 Years After Penile Prosthesis Surgery," The Journal of Urology, 139(5): 956-958, 1988. 102. Tiefer, L., B. Pedersen, and A. Melman, "Psychosocial Follow-up of Penile Prosthesis Implant Patients and Partners," Journal of Sex and Marital Therapy, 14(3): 184-201, 1988. 103. Domanskis, E., and J. Owsley, "Histological Investigations of the Etiology of Capsular Contraction Following Augmentation Mammoplasty," Plastic and Reconstructive Surgery, 58: 689-693, 1976. 104. Vargas, A., "Shedding of Silicone Particles from Inflated Breast Implants," letter to the editor, Plastic and Reconstructive Surgery, 64: 252-253, 1979. Appendix I Extraction Guidelines for Polymers I. Leachables Most polymeric materials contain in addition to the relatively inert, high molecular weight polymer, other components such as residual monomers, oligomers, catalysts, processing aids, etc. These are present at varying levels depending on the raw material sources, the manufacturing processes, and intended function of additives. Also, additional chemical species may be generated during manufacturing processes such as heat sealing, welding, or sterilization of the device. All of these may migrate from the device into the human body and should be the subject of risk assessments. The rate of migration from a device component will very likely be controlled by diffusion processes in the polymer itself unless there is partitioning in the external phase, in most cases, body fluids and tissues. The latter cannot hold if metabolic processes convert the migrant into another chemical species or if it is eliminated. In either case, the situation is equivalent to migration into infinite volume and corresponds to exhaustive extraction. The effect of the external phase is treated in a paper by R. C. Reid, K. R. Sidman, A. D. Schwope and D. E. Till, Ind. Eng. Chem. Prod. Res. Dev., 19(4), 1980, p. 580-587. The rates of migration may be very slow so that the levels of migrants in short term animal studies may not be high enough to elucidate any responses. Toxicological testing of migrants allows for determination of dose response curves and "no adverse effect levels." For device components, initial levels plus migration rates would allow calculation of dose rates. In order to carry out such risk assessments, the identity and levels of the potential migrants must be established. Presently, exhaustive extractive experiments are the best approach for accomplishing this. II. Samples Each of the individual structural components as they are found in the final sterilized device should be subjected to extractions. No additional processing or curing should be performed on these samples. A major fraction of each structural component as it is in the final device should be subjected to extractions. Two approaches are possible; 1. Several replicate samples can be taken from each of the structural components of the finished devices and these samples can be subjected to extractions. 2. Several replicate samples can be taken from the structural components before final assembly, but the components must have undergone all processing, curing and sterilization treatments that the finished device receives. This approach can be used provided that the content and chemical identity of the extracts is the same as (or closely represents) that found using approach 1. Both of these approaches require that the ratio of the sample weight to the device structural component weight be known so that levels of extractants can be referred back to the entire device as implanted. That is, the grams of migrant per grams of the specific structural component is then multiplied by the total weight of the structural component to give the total amount per device. III. Selection of Extracting Solvents Solvents should be chosen that are expected to solubilize the low molecular weight migrants thus facilitating exhaustive extraction. Inasmuch as the chemical nature of all of the migrants is not known, it is advisable to use solvents with different chemical characteristics such as polarity, aromaticity, etc. Both polar and non-polar solvents should be used. Charged or very polar species such as heavy metals, catalyst complexes, and inorganic chemicals may also migrate from the polymers and would not be soluble in non-polar solvents. Initial experiments should use a solvent of mixed polarity such as methylene dichloride. For highly crosslinked polymers that may used, solvents which swell the polymer are desirable as they would enable completion of the experiments sooner. IV. Design of the Extraction Experiment A. Extraction vessel. An extraction cell should be used in which a sample of known weight and known geometric surface area is extracted by a known volume of solvent. An example of such a cell is described in an article by Snyder, R. C. and Breder, C. V., J. Assoc. Off. Anal. Chem., 68(4) 1985, p 770f. Such a cell may work for polymer plates such as cut from the shell. Mild agitation of the solvent is recommended. Although immersion of samples allows for two- sided extraction, calculation should be based on the sample weight or the area of one side when doing exhaustive extractions. Additional considerations and helpful comments are given in the section "Design of the Extraction Experiment, part D.1.a, Extraction Vessel" of the Recommendations for Chemistry Data for Indirect Food Additive Petitions obtainable from the Division of Food Chemistry and Technology, CFSAN, FDA, Harvey W. Wiley Federal Building, Room 1B-018, 5100 Paint Branch Parkway
College Park, MD 20740-3835 B. Extraction Sample General considerations on sampling are given above. Because migration is a diffusive process plate geometry is desirable; the experimental time can be further minimized by using thin samples. The sample geometry, thickness, weight and solvent volume must be reported. The ratio of volume of solvent to the area of the sample is not so important for exhaustive extraction as described below. However, if cloudy solutions or precipitation is noticed during the first time interval, then the solvent volume to sample surface area is too low. C. Temperature and Time of Extractions For the determination of residual levels of low-molecular weight components of polymeric materials, experiments can be accelerated since only the levels are of interest here and not the kinetics. Exhaustive extractions should be carried out as described below in order to determine residue levels. This will also provide the maximum amount of migrants per sample which should be used for further chemical characterization and for toxicological tests. Extractions can be done at 37*C or at elevated temperatures in order to accelerate the experiment. However, the petitioner is advised that elevated temperatures may cause chemical reactions to produce additional extractants. Also, if elevated temperatures are used they should be chosen so that no additional curing or crosslinking of the polymers takes place during the extraction experiment. For exhaustive extractions, the duration of the extraction cannot be prescribed in advance but can be dealt with in the following manner. A series of successive extractions is carried out by exposing the sample to the solvent for a period of time, analyzing the solvent for extractants, replacing with fresh solvent and again exposing the sample for a period of time, analyzing and repeating the process. When the level of the analyte for the ith successive extraction is one-tenth (.1) of the level in the first extraction the extraction may be deemed complete. It is possible that this condition may not occur because of extremely slow migration of the higher molecular weight material. The test can be applied to the contents of the extract with molecular weights below 1500. All the separate analyte levels are added up to give the cumulative value and via the sample/solvent ratio referred back to sample levels and finally back to device levels. In order to minimize experimental time and provide for analysis choosing unequal time periods is desirable. Intervals based on a log or half-log scale generally work out well and minimizes the number of chemical analyses. For shells, this should also allow determination of migration rates by log-log plots of cumulative migration against time. V. Characterization of the Extracts A. Analytical Methodology Specific or non-specific analytical methods may be required depending on the situation. For example, size exclusion chromatography (SEC), high pressure liquid chromatography (HPLC) or some other chromatographic or separation methods may show that the extractants in a given solvent consist of several chemical species. Appropriate methodologies, such as atomic absorption (AA), ion chromatography, etc., should be employed to assess the presence of metallic, inorganic, organometallic, etc., leachables in polar solvents. For the purposes of performing the exhaustive extraction, determination of the total concentration of extractants by gravimetric or some other method would suffice. A bibliography of representative analytical methodologies which may be useful is given in Appendix II. It is necessary for the purposes of toxicological testing to identify the individual components in terms of their molecular composition and to determine the concentration of the individual components of the extract. Following separation and isolation, identification of the individual components in terms of chemical composition can be done by any number of chemical identification methods such as infrared, UV-visible (including diode array), NMR, or mass spectrometries (See Appendix II). Comparison to known structures will be beneficial. Determination of the individual concentrations may require a specific analytical method unless relative concentrations of the components can be determined and used together with the total concentration to give the individual concentrations. B. Description of Analytical Methods All analytical methods must be completely described. Calibration or standard curves should be supplied. The calibration curve should bracket the concentration of the migrant in the extract. All analytical methods should be validated. An excellent discussion of these points is given in the Section D.3 entitled "Analytical Methodology" in the Recommendations for Chemistry Data for Indirect Food Additive Petitions already cited above. Additional information with accompanying references concerning validation procedures can be found in papers by Vanderwielen and Hardwidge (Guidelines for Assay Validation, Pharmaceutical Technology, March 1982, pp 66-76) and by Ficarro and Shah (Validation of High-Performance Liquid Chromatography and Gas Chromatography Assays, Pharmaaceutical Manufacturing, Sept 1984, pp 25-27). We agree with the recommendations given in those Guidelines. (2/18/93) Appendix II Selected bibliography of analytical methods GENERAL REFERENCES Wheeler, D.A., "Determination of Antioxidants in Polymeric Materials", Talanta, 15, 1315-1334, (1968). Majors, R.E., "High Speed Liquid Chromatography of Antioxidants and Plasticizers Using Solid Core Supports", J. Chromatogr. Sci., 8, 338-345, (1970). Schroeder, E., "The Development of Methods for Examining Stabilizers in Polymers and their Conversion Products", Pure Appl. Chem., 36, 233-251, (1973). Pacco, J., Mukherji, A.K., "Determination of Polychlorinated Biphenyls in a Polymer Matrix by Gel Permeation Chromatography using micro-Styragel* Columns", J. Chromatogr., 144, 113-117, (1977). Crompton, T.R. Chemical Analysis of Additives in Plastics; International Series in Analytical Chemistry, Pergamon Press: New York, 1977; Vol. 46. Majors, R.E., Johnson, E.L., "High-Performance Exclusion Chromatography of Low-Molecular-Weight Additives", J. Chromatogr., 167, 17-30, (1978). Thompson, R.M., Howard, C.C., Crowley, J.P. DeRoos, F.L., Leininger, R.I., "Literature Review: Polymeric Material Leachables and their Biological Effects and Toxicology"; final report to Food and Drug Administration, Center for Devices and Radiological Health (formerly Bureau of Medical Devices) on Contract Number 233-77-5038; Battelle - Columbus Laboratories: Columbus, OH, 1979. Walter, R.B., Johnson, J.F., "Analysis of Antioxidants in Polymers by Liquid Chromatography", J. Polym. Sci.: Macromol. Rev., 15, 29-53, (1980). Shepherd, M.J., Gilbert, J., "Analysis of Additives in Plastics by High- Performance Size-Exclusion Chromatography", J. Chromatogr., 218, 703-713, (1981). Squirrell, D.C.M., "Analysis of Additives and Process Residues in Plastics Materials", Analyst, 106, 1042-1056, (1981). Low Molecular Weight Leachables from Medical Grade Polymers; U.S. Department of Commerce, National Institute of Science and Technology (formerly National Bureau of Standards). 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Munteanu, D., Isfan, A., Isfan, C., Tincul, I., "High-Performance Liquid Chromatographic Separation of Polyolefin Antioxidants and Light- Stabilisers", Chromatographia, 23 (1), 7-14, (1987). Padron, A.J.C., Colmenares, M.A., Rubinztain, Z., Albornoz, L.A., "Influence of Additives on Some Physical Properties of High Density Polyethylene - I. Commercial Antioxidants", Eur. Polym. J., 23 (9), 723- 727, (1987). Padron, A.J.C., Rubinztain, Z., Colmenares, M.A., "Influence of Additives on Some Physical Properties of High Density Polyethylene - II. Commercial u.v. Stabilisers", Eur. Polym. J., 23 (9), 729-732, (1987). Raynor, M.W., Bartle, K.D., Davies, I.L., Williams, A., Clifford, A.A., "Polymer Additive Characterization by Capillary Supercritical Fluid Chromatography/Fourier Transform Infrared Microspectrometry", Anal. Chem., 60, 427-433, (1988). "Deformulating Polypropylene by HPLC", Polymer Notes, Waters Chromatography Division, 2(2), 1988. Neilson, R. C., "Extraction and Quantitation of Polyolefin Additives", J. Liquid. Chromatogr., 14 (3), 503-519, (1991). Waters Polymer Update, applications Brief No. RN101, "The Analysis of Additives in Polyolefins by Reverse Phase Gradient Chromatography", date unknown. POLYVINYL CHLORIDE (PVC) Pedersen, H.L., Lyngaae-Jorgensen, J., "Gel Permeation Chromatography Measurements on PVC Resins and Plasticisers", Br. Polym. J., 1, 138-141, (1969). Howard, J.M., "Gel Permeation Chromatography and Polymer Additive Systems", J. Chromatogr., 55, 15-24, (1971). Liao, J.C., Browner, R.F., "Determination of Polynuclear Aromatic Hydrocarbons in Poly(vinyl chloride) Smoke Particulates by High Pressure Liquid Chromatography and Gas Chromatography-Mass Spectrometry", Anal. Chem., 50,(12), 1683-1686, (1978). Shepherd, M.J., Gilbert, "Simple and Inexpensive Application of Steric Exclusion Chromatography for the Isolation of Low-Molecular Weight Additives form Polymer Systems", J. Chromatogr., 435-441, (1979). Perlstein, P., "The Determination of Light Stabilisers in Plastics by High- Performance Liquid Chromatography", Anal. Chim. Acta, 21-27, (1983). Preussler, V., Slais, K., Hanus, J., "The Use of Micro-HPLC with Gradient Elution for the Characterization of Phenol-Formaldehyde Resins", Angew. Makromol. Chem., 150, 179-187, (1987). POLYMETHYLMETHACRYLATE (PMMA) Pasteur, G.A., "Qunatitative Determination of Stabilizers in Tetraethylene Glycol Dimethacrylate by High Pressure Liquid Chromatography", Anal. Chem., 49(3), 363-364, (1977). Brauer, G.M., Termini, D.J., Dickson, G., "Analysis of the Ingredients and Determination of the Residual Components of Acrylic Bone Cements", J. Biomed. Mater. Res., 11, 577-607, (1977). Schoenfeld, C.M., Conard, G.J., "Monomer Release from Methacrylate Bone Cements During Simulated in vivo Polymerization", J. Biomed. Mater. Res., 13, 135-147, (1979). 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