David,
We are just completing a round of 510(k) questions on a personal lubricant. You can definitely submit accelerated testing (while retaining samples for real time testing). The accelerated testing length should support, of course, what you want to label your product regarding expiration dating. However, I strongly encourage you to follow the USP series of standards to design your testing. These standards for non sterile formulations would include 51, 61, 62, and 1111. Hope this helps.
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Barry Sands
RQMIS Inc.
Newburyport MA
United States
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Original Message:
Sent: 06-18-2015 08:26
From: David Lucking
Subject: Stability data for 510(k) for personal lubricant
How much stability data is required at filing for a 510(k) for a personal lubricant? I have seen companies file with 6 months accelerated following ICH guidelines or with 3 months following Consumer Health Products Association (CHPA) guidelines in order to get a 24 month shelf life. Thank you.
Regards,
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David Lucking FL
United States
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