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IA #86-07, REVISION 11/18/99 - IMPORT ALERT #86-07, "DETENTION WITHOUT
           PHYSICAL EXAMINATION AND GUIDANCE OF NON-PRESCRIPTION SUNGLASSES"

NOTE:     This revision changes the name of the alert and updates the alert to the
          current format and terminology. In addition, this revision creates an
          attachment which lists firms whose sunglasses are subject to detention
          without physical examination.


TYPE OF ALERT: Detention without Physical Examination and Guidance

Note:     This import alert represents the Agency's current guidance to FDA
          field personnel regarding the manufacturer(s)and/or product(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.

PRODUCTS: Sunglasses, Non-prescription (Including photosensitive)

PRODUCT CODE:   86HQY

PROBLEM:  Failure to have impact resistant lenses
          (OASIS charge code = NOT IMPACT)

          Failure to provide impact resistant certification
          (OASIS charge code = LENS CERT)

PAF:           PER (Performance)
          LBL (Labeling)

PAC:      82008

COUNTRY:  Guidance  - All (999)
          Detention without Physical Examination - see Attachment

MANUFACTURER/
SHIPPER:  Guidance - All
          Detention without Physical Examination - see Attachment


CHARGE:   For Detention without Physical Examination and for products for
          which testing has confirmed the certification is invalid:

          "The article is subject to refusal of admission pursuant to
          Section 801(a)(3) in that it appears to fail to comply with
          21CFR801.410 [Adulteration, Section 501]"

          For products that lack certification: "The article is subject to
          refusal of admission pursuant to Section 801(a)(3) in that it
          appears to not have been tested for impact resistance as required
          by 21CFR801.410 [Misbranding, Section 502]"

RECOMMENDING
OFFICE:   SAN-DO (HFR-PA152) and CDRH (HFZ-330)

REASON FOR
ALERT:    Sunglasses imported into the United States must comply with the
          Impact Resistant Lens Regulation, 21CFR801.410. A certificate to
          comply with 21CFR801.410(g) must accompany each entry of
          sunglasses showing that they have been sampled and tested using a
          method which employs a statistically significant number of units
          such as ANSI/ASQC ZI.4, which has replaced MIL-STD 105E, and that
          they meet an AQL of 6.5 when when tested by the drop ball test or
          an equal or superior test.

          It has been reported that certificates from foreign manufacturers
          may not be valid. Tests by one U.S. distributor revealed 40-70%
          breakage which differed significantly from the manufacturer's
          certificate.

          Because of apparent certificate irregularities SAN-DO recently
          collected a sample of childrens sunglasses. The manufacturer's
          certificate indicated that no lenses broke during testing. WEAC
          testing of the sample found that nearly every lens broke
          completely.

GUIDANCE: Districts may detain without physical examination all non-
          prescription sunglasses from the manufacturer's listed in the
          attachment to this alert.

          Districts may detain all shipments of non-prescription sunglasses
          not accompanied by a certificate showing the lenses meet an AQL of
          6.5 when tested by the drop ball test or an equal or superior
          test.

          If certificate irregularities are noted sample collection may be
          warranted. Prior to collecting samples, districts should contact
          WEAC to determine they can handle the samples on a timely basis.
          Products that fail FDA testing should be referred to DIOP for DWPE
          consideration.

          For questions or issues concerning science, science policy, sample
          collection, analysis, preparation, or analytical methodology,
          contact the Division of Field Science at (301)443-3320 or 3007.

FOI:      No purging is required.

KEYWORDS: Sunglasses, Impact Resistant

PREPARED BY:   Doug Randes, DIOP, 301-443-6553.

                                 Attachment to Import Alert #86-07   Firms subject to detention without
physical examination - 4/21/05



FIRM NAME AND ADDRESS              PRODUCT

Hang Chow Industrial Co., LTD.     Non-prescription Sunglasses
          aka
Shye I Glasses Enterprises Co., Ltd.
9f, 253 Chungsiao E. Rd. Sec. 3
Taipei, Taiwan
FEI# 3002427048