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DRAFT GUIDANCE FOR PREPARATION OF PMA APPLICATIONS FOR PENILE INFLATABLE IMPLANTS

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                  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.  

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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.  

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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.  

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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). National Technical Information Service (NTIS), Springfield, VA, 1982; NBSIR 81-2436. Krause, A., Lange, A., Erzin, M. Plastics Analysis Guide: Chemical and Instrumental Methods; Hanser: New York, 1983. Crompton, T.R. The Analysis of Plastics; Pergamon Series in Analytical Chemistry, Pergamon Press: New York, 1984; Vol. 8. Vargo, J.D., Olson, K.L., "Characterization of Additives in Plastics by Liquid Chromatography-Mass Spectrometry", J. Chromatogr., 353, 215-224, (1986). Gibbons, J.J., "An Evaluation of Plasticizers by Fourier Transform Infrared Spectroscopy", American Laboratory, November, 78-85, 1987. Middleditch, B.S., Zlatkis, A., "Artifacts in Chromatography: An Overview", J. Chromatogr. Sci., 25, 547-551, (1987). Hopkins, J.L., Cohen, K.A., Hatch, F.W., Pitner, T.P., Stevenson, J.M., Hess, F.K., "Pharmaceuticals: Tracking Down an Unidentified Trace Level Constituent", Anal. Chem., 59(11), 784-790, (1987). McGorrin, R.J., Pofahl, T.R., Croasmun, W.R., "Identification of the Musty Component From an Off-Odor Packaging Film", Anal. Chem., 59(18), 1109-1112, (1987). Del Rios, J.K., "Polymer Characterization Using the Photodiode Array Detector", American Laboratory, January, 1988. Multidimensional Chromatography; Cortes, H.J., Ed.; Chromatographic Science Series 50; Dekker, New York, 1990. The Analytical Chemistry of Silicones, Smith, A. Lee, Ed.; Chemical Analysis: A Series of Monographs on Analytical Chemistry and Its Applications 112; Wiley-Interscience, New York, 1991. Braybrook, J.H., Mackay, G.A., "Supercritical Fluid Extraction of Polymer Additives for Use in Biocompatibility Testing", Polym. Int., 27, 157-164 (1992). Erickson, M.D., Analytical Chemistry of PCBs;Lewis:Boca Raton,1992. POLYOLEFINS Spell, R.L., Eddy, R.D., "Determination of Additives in Polyethylene by Absorption Spectroscopy", Anal. Chem., 32(13), 1811-1814, (1960). Crompton, T.R., "Identification of Additives in Polyolefins and Polystyrenes", Eur. Polym. J., 4, 473-496, (1968). Howard, J.M., "Gel Permeation Chromatography and Polymer Additive Systems", J. Chromatogr., 55, 15-24, (1971). Couper, J., Pokorny, S., Protivova, J., Holcik, J., Karvas, M., Pospisil, J., "Antioxidants and Stabilizers. XXXIII. Analysis of Stabilizers of Isotactic Polypropylene: Application of Gel Permeation Chromatography", J. Chromatogr., 65, 279-286, (1972). Wims, A.M., Swarin, S., "Determination of Antioxidants in Polypropylene by Liquid Chromatography", J. Appl. Polym. Sci., 19, 1243-1256, (1975). Lichenthaler, R.G., Ranfelt, F., "Determination of Antioxidants and their Transformation Products in Polyethylene by High-Performance Liquid Chromatography", J. Chromatogr., 149, 553-560, (1978). Schabron, J.F., Fenska, L.E., "Determination of BHT, Irganox 1076, and Irganox 1010 Antioxidant Additives in Polyethylene by High Performance Liquid Chromatography", Anal. 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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). Brynda, E., Stol, M., Chytry, V., Cifkova, I., "The Removal of Residuals and Oligomers from Poly(2-hydroxyethylmethacrylate)", J. Biomed. Mater. Res., 19, 1169-1179, (1985). Huribut, J.A., Cummins, J.D., "Analysis of 2-Hydroxyethyl Methacrylate in Soft Contact Lenses by High Performance Liquid Chromatography with UV Detection", LC GC, 8(6), 478-479, (1990). POLYURETHANES Spagnolo, F., "Quantitative Determination of Small Amounts of Toluene Diisocyanate Monomer in Urethane Adhesives by Gel Permeation Chromatography", J. Chromatogr. Sci., 14, 52-56, (1976). McFadyen, P., "Determination of Free Toluene Diisocyanate in Polyurethane Prepolymers by High-Performance Liquid Chromatography", J. Chromatogr., 123, 468-473, (1976). Guthrie, J.L. and McKinney, R.W., "Determination of 2,4- and 2,6- Diaminotoluene in Flexible Urethane Foams", Anal. Chem., 49(12), 1676-1680, (1977). Bagon, D.A., Hardy, H.L., "Determination of Free Monomeric Toluene Diisocyanate (TDI) and 4,4'-diisocyanatodiphenylmethane (MDI) in TDI and MDI Prepolymers, Respectively, by High-Performance Liquid Chromatography", J. Chromatogr., 152, 560-564, (1978). Unger, P.D., Friedman, M.A., "High-Performance Liquid Chromatography of 2,6- and 2,4-Diaminotoluene, and its Application to the Determination of 2,4-Diaminotoluene in Urine and Plasma", J. Chromatogr., 174, 379-384, (1979). Snyder, R.C., Breder, C.V., "High-Performance Liquid Chromatographic Determination of 2,4- and 2,6-Toluenediamine in Aqueous Extracts", J. Chromatogr., 236, 429-440, (1982). Lattimer, R.P., Welch, K.R., "Direct Analysis of Polymer Chemical Mixtures by Field Desorption Mass Spectroscopy", Rubber Chem. Technol., 53, 151-159, (19**). Hepburn, C., Polyurethane Elastomers, Applied Sci. Publ.: New York, 1982, Chapter 11. Owen, D.R., Zone, R., Armer, T., Kilpatrick, C., "Analytical Methods for the Determination of Biologically Derived Absorbed Species in Biomedical Elastomers", In Biomaterials: Interfacial Phenomena and Applications; Cooper, S.L., Peppas, N.A., Eds.; Advances in Chemistry 199; American Chemical Society: Washington, DC, 1982; pp 395-411. Guise, G.B., Smith, G.C., "Liquid Chromatography of Some Polurethane Polyols", J. Chromatogr., 247, 369-373, (1982). Kuo, C., Provder, T., Kah, A.F., "Application of HPGPC and HPLC to Characterise Oligomers and Small Molecules used in Enviromentally Acceptable Coatings Systems", Paint & Resin, 53(2), 26-33, (1983). Ernes, D.A., Hanshumaker, D.T., "Determination of Extractable Methylene (aniline) in Polyurethane Films by Liquid Chromatography", Anal. Chem., 55, 408-409, (1983). Ratner, B.D., "ESCA Studies of Extracted Polyurethanes and Polyurethane Extracts: Biomedical Implications", In Physicochemical Aspects of Polymer Surfaces, Mittal, K.L., Ed.; Plenum: New York, 1983; pp 969-983. Mazzu, A.L., Smith, C.P., "Determination of Extractable Methylene Dianiline in Thermoplastic Polyurethanes by HPLC", J. Biomed. Mater. Res., 18, 961- 968, (1984). O'Mara, M.M., Ernes, D.A., Hanshumaker, D.T., "Determination of Extractable Methylenebis(aniline) in Polyurethane Films by Liquid Chromatography", In Polyurethanes in Biomedical Engineering, H. Planck, G. Egbers, I. Syr , Eds.;Elsevier:Amsterdam,1984;pp. 83-92. Ward, C.J.P., Radzik, D.M., Kissinger, P.T., "Detection of Toxic Compounds in Polyurethane Food Bags by Liquid Chromatography/Electrochemistry", J. Liq. Chromatogr., 8(4), 677-690, (1985). Rosenberg, C., Ainen, H.S., "Detection of Urinary Metabolites in Toluene Diisocyanate Exposed Rats", J. Chromatogr., 323, 429-433, (1985). Hirayama, T., Ono, M., Uchiyama, K., Nohara, M., J. Assoc. Off. Anal. Chem., 68(4), 746-748, (1985). Vimalasiri, P.A.D.T., Burford, R.P., Haken, J.K., "Chromatographic Analysis of Elastomeric Polyurethanes", Rubber Chem. Tech., 60, 555-577, (1987). Richards, J.M., McClennen, W.H., Meuzelaar, H.L.C., Shockcor, J.P., Lattimer, R.P., "Determination of the Structure and Composition of Clinically Important Polyurethanes by Mass Spectrometric Techniques", J. Appl. Polym. Sci., 34, 1967-1975, (1987). Noel, D., VanGheluwe, "High-Performance Liquid Chromatography of Industrial Polyurethane Polyols", J. Chromatogr. Sci., 25, 231-236, (1987). Marchant, R.E., Zhao, Q., Anderson, J.M., Hiltner, A., "Degradation of a Poly(ether urethane urea) Elastomer: Infra-red and XPS Studies", Polymer, 28, 2032-2039, (1987). Grasel, T.G., Lee, D.C., Okkema, A.Z., Slowinski, T.J., Cooper, S.L., "Extraction of Polyurethane Block Copolymers: Effects on Bulk and Surface Properties and Biocompatibility", Biomaterials, 9, 383-392, (1988). Hull, C.J., Guthrie, J.L., McKinney, R.W., Taylor, D.C., Mabud, Md.A., Prescott, S.R., "Determination of Toluenediamines in Polyurethane Foams by High-Pressure Liquid Chromatography with Electrochemical Detection", J. Chromatogr., 477, 387-395, (1989). Richards, J.M., Meuzelaar, H.L.C., Bunger, J.A., "Spectrometric and Chromatographic Methods for the Analysis of Polymeric Explant Materials", J. Biomed. Mater. Res., 23, 321-335, (1989). Richards, J.M., McClennen, W.H., Meuzelaar, H.L.C., "Determination of Additives in Biomer and Lycra Spandex by Pyrolysis Tandem Mass Spectrometry and Time Temperature Resolved Pyrolysis Mass Spectrometry", J. Appl. Polym. Sci., 40, 1-12, (1990). Belisle, J., Maier, S.K., Tucker, J.A., "Compositional Analysis of Biomer", J. Biomed. Mater. Res., 24, 1585-1598, (1990). Dillon, J.G., Hughes, M.K., "Determination of Cholesterol and Cortisone Absorption in Polyurethane I. Methodology Using Size-exclusion Chromatography and Dual Detection," J. Chromatogr., 572, 41-49, (1991). Shintani, H., "Solid-Phase Extraction and High-Performance Liquid Chromatographic Analysis of a Toxic Compound from g-irradiated Polyurethane", J. Chromatogr., 600, 93-97, (1992). RUBBERS Protivova, J., Posp sil, J., "XLVII. Behavior of Amine Antioxidants and Antiozonants and Model Compounds in Gel Permeation Chromatography", J. Chromatogr., 88, 99-107, (1974). Protivova, J., Posp sil, J., "XLVIII. Analysis of the Components of Stabilization and Vulcanization Mixtures for Rubbers by Gel Permeation Chromatography and Thin-Layer Chromatographic Methods", J. Chromatogr., 92, 361-370, (1974). Weston, R.J., "Volatile Nitrosamine Levels in Rubber Teats and Pacifiers Available in New Zealand", J. Anal. Toxicol., 9, 95-96, (1985). Zwickenpflug, W., Richter, E., "Rapid Method for the Detection and Quantification of N-Nitrosodibutylamine in Rubber Products", J. Chromatogr. Sci., 25, 506-509, (1987). NYLONS Caldwell, J., Perenich, T., "Recovery and Analysis by HPLC of Benzoyl Peroxide Residues in Nylon Carpet Fibers", Textile Res. J., June, 1987. CELLULOSE ACETATE Floyd, Th.R., "Use of Two-Dimensional Liquid Chromatography in the Analysis of Additives in Cellulose Acetate Polymer", Chromatographia, 25(9), 791- 796, (1988). SILICONES Horner, H.J., Weiler, J.E., Angelotti, "Visible and Infrared Spectroscopic Determination of Trace Amounts of Silicones in Foods and Biological Materials", Anal. Chem., 32(7), 858-861, (1960). Estes, Z.E., Faust, R.M., "A Colorimetric Method for the Determination of Silicon in Biological Materials", Anal. Biochem., 13, 518-522, (1965). Neal, P., "Note on the Atomic Absorption Analysis of Dimethylpolysiloxanes in the Presence of Silicates", J. Assoc. Off. Anal. 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Vessman, J., Hammar, C., Lindeke, B., Stromberg, S., LeVier, R., Robinson, R., Spielvogel, D., Hanneman, L., "Analysis of Some Organosilicone Compounds in Biological Material", In Biochemistry of Silicon and Related Problems; Bendz, G, Lindqvist, I., Eds.; Plenum: New York, 1977; pp 535- 558. Pellenbarg, R., "Enviromental Poly(organosiloxanes) (Silicones)", Environmental Science and Technology, 13(5), 565-569, (1979). Abraham, J.L., Etz, E.S., "Molecular Microanalysis of Pathological Specimens in situ with a Laser-Raman Microprobe", Science, 206, 716-718, (1979). Buch, R.R., Ingebrightson, D.N., "Rearrangement of Poly(dimethylsiloxane) Fluids on Soil", Environmental Science and Technology, 13(6), 676-679, (1979). Doeden, W.G., Kushibab, E.M., Ingala, A.C., "Determination of Dimethylpolysiloxanes in Fats and Oils", J. Amer. Oil Chemists Soc., 57(2), 73-74, (1980). Abe, Y., Butler, G.B., Hogen-Esch, T.E., "Photolytic Oxidative Degradation of Octamethylcyclotetrasiloxane and Related Compounds", J. Macromol. Sci., Chem., A16(2), 461-471, (1981). Leong, A.S.-Y., Disney, A.P.S., Grove, D.W., "Spallation and Migration of Silicone from Blood-Pump Tubing in Patients on Hemodialysis", N. Engl. J. Med., 306(3), 135-140, (1982). Baker, J.L., LeVier, R.R., Spielvogel, D.E., "Positive Identification of Silicone in Human Mammary Capsular Tissue", Plast. Reconst. Surg., 69(1), 56-60, (1982). Kacprzak, J.L., "Atomic Absorption Spectroscopic Determination of Dimethylpolysiloxane in Juices and Beer", J. Assoc. Off. Anal. Chem., 65(1), 148-150, (1982). Mahone, L.G., Garner, P.J., Buch, R.R., Lane, T.H., Tatera, J.F., Smith, R.C., Frye, C.L., "A Method for the Qualitative and Quantitative Characterization of Waterborne Organosilicon Substances", Environ. Toxicol. Chem., 2, 307-313, (1983). Buch, R.R., Lane, T.H., Annelin, R.B., Frye, C.L., "Photolytic Oxidative Demethylation of Aqueous Dimethylsiloxanols", Environ. Toxicol. Chem., 3, 215-222, (1984). Watanabe, N., Yasuda, Y., Kato, K., Nakamura, T., "Determination of Trace Amounts of Siloxanes in Water, Sediments and Fish Tissues by Inductively Coupled Plasma Emission Spectrometry", The Science of the Total Environment, 34, 169-176, (1984). Bruggeman, W.A., Weber-Fung, D., Opperhuizen, A., Van der Steen, J., Wijbenga, A., Hutzinger, O., "Absorption and Retention of Polydimethylsiloxanes (Silicones) in Fish: Preliminary Experiments", Toxicol. Environ. Chem., 7, 287-296, (1984). McCamey, D.A., Iannelli, D.P., Bryson, L.J., Thorpe, T.M., "Determination of Silicone in Fats and Oils by Electrothermal Atomic Absorption Spectrometry with In-Furnace Air Oxidation", Anal. Chim. Acta., 188, 119- 126, (1986). Anderson, C., Hochgeschwender, K., Weidemann, H., Wilmes, R., "Studies of the Oxidative Photoinduced Degradation of Silicones in the Aquatic Environment", Chemosphere, 16(10-12), 2567-2577, (1987). Watanabe, N., Nagase, H., Ose, Y., "Distribution of Silicones in Water, Sediment and Fish in Japanese Rivers", The Science of the Total Enviroment, 73, 1-9, (1988). Winding, O., Christensen, L., Thomsen, J.L., Nielsen, M., Breiting, V., Brandt, B., "Silicon in Human Breast Tissue Surrounding Silicone Gel Prostheses", Scand. J. Plast. Reconstr. Surg., 22, 127-130, (1988). Annelin, R.B., Frye, C.L., "The Piscine Bioconcentration Characteristics of Cyclic and Linear Oligomeric Permethylsiloxanes", The Science of the Total Environment, 83, 1-11, (1989). Parker, R.D., "Atomic Absorption Spectrophotometric Method for Determination of Polydimethylsiloxane Residues in Pineapple Juice: Collaborative Study", J. Assoc. Off. Anal. Chem., 73(5), 721-723, (1990). Nakamura, K., Refojo, M.F., Crabtree, D.V., "Factors Contributing to the Emulsification of Intraocular Silicone and Fluorosilicone Oils", Invest. Ophth. Vis. Sci., 31(4), 647-656, (1990). Nakamura, K., Refojo, M.F., Crabtree, D.V., Leong, F., "Analysis and Fractionation of Silicone and Fluorosilicone Oils for Intraocular Use", Invest. Ophth. Vis. Sci., 31(10), 2059-2069, (1990). Gaboury, S.R., Urban, M.W., "Spectroscopic Evidence for Si-H Formation During Microwave Plasma Modification of Poly(dimethylsiloxane) Elastomer Surfaces", Polym. Commun., 32(13), 390-392, (1991). Israeli, Y., Philippart, J.-L., Cavezzan, J., Lacoste, J., Lemaire, J., "Photo-oxidation of Polydimethylsiloxane Oils: Part I - Effect of Silicon Hydride Groups", Polym. Degradation. Stab., 36, 179-185, (1992). "Selective Detection of Cyclic Silicon Compounds Extracted from Silicone Breast Implants"; DET Report No. 22, March, 1992; DETector Engineering & Technology, Inc., Walnut Creek, CA.

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