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IA #75-02, 7/14/05, IMPORT ALERT #75-02 "DETENTION WITHOUT PHYSICAL EXAMINATION AND
INCREASED SURVEILLANCE OF BLOOD GLUCOSE TEST STRIPS"


TYPE OF ALERT: Detention Without Physical Examination, Increased Surveillance

               (Note: This import alert represents the Agency's current guidance
               to FDA field personnel regarding the manufacturer(s) and/or
               products(s) at issue.  It does not create or confer any rights for
               or on any person, and does not operate to bind FDA or the public).

PRODUCT:       OneTouch  Basic, OneTouch Profile, and OneTouch II blood glucose
               test strips, manufactured by Lifescan, Inc., that are calibrated
               to be "plasma equivalent.";

                                  and

               Accu-Chek blood glucose test strips, manufactured by Roche
               Diagnostics Corporation, that are calibrated to be "whole blood
               equivalent."

PRODUCT
CODE:               75CGA and 75LFR

PROBLEM:       Adulterated and Misbranded

PAF:           AAP  Lack of an approved PMA; and
               REG- Lack of a Premarket Notification, 510(k)

PAC FOR
COLLECTION:         82008

COUNTRY:       All countries

MANUFACTURERS: ^

                                                                    ^

DISTRIBUTORS:  Numerous

CHARGE:        "These articles are subject to refusal of admission pursuant to
               Section 801(a)(3) in that they are class III devices which do not
               have an approved application for premarket approval in effect
               pursuant to section 515(a) or an approved application for an
               investigational device exemption under section 520(g).
               [Adulterated, section 501(f)(1)(B)]"

                                  and

               "These articles are subject to refusal of admission pursuant to
               section 801(a)(3) in that it appears that a notice or other
               information respecting the devices was not provided to FDA, as
               required by section 510(k), and the devices were not found to be
               substantially equivalent to a predicate device.  [Misbranded,
               section 502(o)]"

OASIS CHARGE
CODE:               LACK OF AN APPROVED APPLICATION FOR PREMARKET APPROVAL (PMA)
               LACK OF A PREMARKET NOTIFICATION [510(k)]

RECOMMENDING
OFFICE:        Center for Devices and Radiological Health (CDRH), Office of In
               Vitro Diagnostic Device Evaluation and Safety (HFZ-440) and the
               Office of Compliance (HFZ-320)

REASON FOR
ALERT:         Lifescan manufactures, for export only, certain blood glucose test
               strips that are calibrated to be "plasma equivalent."  These
               strips do not have FDA premarket clearance or approval.  FDA
               investigations revealed, however, that these test strips are being
               imported into the United States by other companies.

               Roche Diagnostics manufactures, for export only, certain blood
               glucose test strips that are calibrated to be "whole blood
               equivalent." These strips do not have FDA premarket clearance or
               approval.  FDA investigations revealed, however, that these test
               strips are being imported into the United States by other
               companies.

GUIDANCE:      Districts may detain the following blood glucose test strips:

               OneTouch Basic, OneTouch Profile, and OneTouch II strips,
               manufactured by Lifescan that are calibrated to be plasma
               equivalent. The outer carton packaging for these products ^

               ^.  Plasma equivalent calibration may be confirmed in the
               package inserts for the products.  These products may also be
               labeled as "not for sale in the United States" or with a similar
               statement indicating that they are for export only and not to be
               sold in the United States.  In some cases, stickers may have been
               placed over this designation.

               Accu-Chek test strips, manufactured by Roche Diagnostics  that are
               calibrated to be whole blood equivalent.  It is our understanding
               that the outer carton packaging for these products ^
                                                    ^.  Whole blood equivalent
               calibration may be confirmed in the package inserts for the
               products.  These products may also be labeled as "not for sale in
               the United States" or with a similar statement indicating that
               they are for export only and not to be sold in the United States.
               In some cases, stickers may have been placed over this
               designation.
               Continued surveillance of blood glucose test strips from all
               foreign shippers appears to be warranted.

               Consult DIOP and the Center for Devices and Radiological Health
               (HFZ-440), Tonya Wilbon at (240)276-0496 for questions concerning
               whether detention is warranted.

               For questions or issues concerning science, science policy, sample
               collection, analysis, preparation, or analytical methodology,
               contact Division of Field Science at (301)276-0496.

PRIORITIZATION
GUIDANCE:      N/A

FOI:           Purging is required between ^      ^

KEYWORDS:      Lifescan, Roche, blood glucose, test strips, plasma, whole blood

PREPARED BY:   Tonya Wilbon, CDRH, OIVD (HFZ-440)
               Anthony W. Lee, DIOP (HFC-170)

DATE LOADED
INTO FIARS:         July 14, 2005

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