(66 days)
Not Found
No
The device description details a traditional, manual method of observing visible growth or color changes to determine MIC and interpret biochemical substrates. There is no mention of automated analysis, image processing, or any computational methods that would suggest the use of AI/ML. The performance studies focus on agreement with reference methods and reproducibility, not on the performance of an AI/ML algorithm.
No.
This device is for in vitro diagnostic (IVD) use to evaluate the susceptibility of bacteria to antimicrobial agents and identify the organisms, not to directly treat a disease or condition.
Yes
The "Intended Use / Indications for Use" section explicitly states that the device is "used for quantitatively measuring...the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms." This describes a diagnostic function, as it helps identify specific characteristics of pathogens that are relevant for diagnosis and treatment. The device also determines Minimum Inhibitory Concentration (MIC) which is a key diagnostic output for guiding antimicrobial therapy.
No
The device description clearly states that the device is a physical panel containing antimicrobial agents and biochemical substrates, which are inoculated with test organisms and observed for visible growth or color changes. This involves physical components and biological processes, not solely software.
Yes, this device is an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use explicitly states that the device is used for "quantitatively measuring... the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms." This is a classic description of an in vitro diagnostic test performed on biological samples (bacterial pathogens).
- Device Description: The description details how the panels are used to test bacterial growth in the presence of antimicrobial agents and observe color changes from biochemical substrates. This process is performed outside of the body (in vitro) to diagnose or provide information about a patient's condition (in this case, the susceptibility of an infection to antibiotics and the identification of the causative organism).
- Performance Studies: The document describes clinical testing, reproducibility testing, and QC performance testing using bacterial isolates. These are typical studies conducted for IVD devices to demonstrate their accuracy and reliability.
- Predicate Devices: The list of predicate devices are all "Pasco MIC and MIC/ID panel," which are known IVD devices used for antimicrobial susceptibility testing and identification.
The core function of the device is to analyze biological samples (bacterial cultures) outside of the body to provide information relevant to the diagnosis and treatment of infectious diseases. This aligns perfectly with the definition of an In Vitro Diagnostic device.
N/A
Intended Use / Indications for Use
PASCO MIC AND MIC/ID PANELS are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement or category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms.
This 510(k) notification is for the antimicrobial Ertapenem at concentrations of 0.03 - 32 mcg/ml to Pasco Panels. Ertapenem has been shown to be active in vitro against most strains of microorganisms listed below, as described in the FDA-approved package insert for this antimicrobic.
Active In Vitro and in Clinical Infectious Against:
Aerobic Gram-positive microorganisms Staphylococcus aureus (methicillin-susceptible strains only)
Aerobic Gram-negative microorganisms Escherichia coli Klebsiella pneumoniae
Active In Vitro but their clinical significance is unknown
Aerobic Gram-negative microorganisms
Citrobacter freundii Citrobacter koseri Enterobacter aerogenes Enterobacter cloacae Klebsiella oxytoca (excluding ESBL producing strains) Morganella morganii Proteus mirabilis Proteus vulgaris Serratia marcescens
Product codes
JWY
Device Description
Pasco Panels are used for quantitatively measuring the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms. Varving concentrations of antimicrobial agents (usually in two-fold dilutions) are dispensed into the Pasco microdilution panels and the panels are then frozen. Panels are thawed prior to use, inoculated with the test organisms, incubated the traditional 16-24 hours and panels are then observed for visible growth or color changes as described in the package insert.
The lowest concentration of each antimicrobial agent with no apparent visible growth of the test organism is recorded as the minimum inhibitory concentration (MIC). Changes in pH and production of specific metabolites from growth in biochemical substrates are interpreted as described in the package insert for conventional tubed media.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Not Found
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Not Found
Description of the training set, sample size, data source, and annotation protocol
Not Found
Description of the test set, sample size, data source, and annotation protocol
Challenge strains, fresh clinical isolates, stock clinical isolates and QC strains were tested concurrently using both Pasco methodology and reference methodology in panels contained Ertapenem at concentrations ranging from 0.03 - 32 mcg/ml. Testing was conducted at three test sites.
Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)
Challenge strains, fresh clinical isolates, stock clinical isolates and QC strains were tested concurrently using both Pasco methodology and reference methodology in panels contained Ertapenem at concentrations ranging from 0.03 - 32 mcg/ml. Testing was conducted at three test sites.
Test results from 410 challenge and clinical Staphylococci spp. demonstrated an Essential Agreement (EA) of 98.3%. For the methicillin-susceptible Staphylococci spp., the Category agreement (CA) was 100% with no very major or minor errors noted.
Test results of 574 challenge and clinical Enterobacteriaceae demonstrated an Essential Agreement (EA) of 99.6%. No major (M) or very major (VM) errors were observed. Category Agreement (CA) was acceptable at 99.4% with 5 random minor discrepancies, all of which were within EA.
Reproducibility testing of 10 organisms at each site on three separate days in triplicate demonstrated inter-site reproducibility of MIC results of 100%. Intra-site reproducibility of MIC results was also 100% for all sites.
The results of the clinical testing, reproducibility testing and QC performance testing supports Substantial Equivalence as outlined in the FDA document "Class II Special Controls Guidance Document: Antimicrobial Susceptibility Test (AST) Systems; Guidance for Industry and FDA.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Essential Agreement (EA) of 98.3% (Staphylococci spp.)
Category agreement (CA) was 100% (methicillin-susceptible Staphylococci spp.)
Essential Agreement (EA) of 99.6% (Enterobacteriaceae)
Category Agreement (CA) was 99.4% (Enterobacteriaceae)
Inter-site reproducibility of MIC results of 100%
Intra-site reproducibility of MIC results was also 100% for all sites.
Predicate Device(s)
K011116, K010508, K020331, K001953, K001887, K001721, K001612, K001516, K992853, K992726, K992717, K992646, K992647, K992593, K992562, K992568, K992507, K992546, K992420, K992296, K992297, K992143, K992108, K992076, K992059, K992077, K991925, K946126
Reference Device(s)
Not Found
Predetermined Change Control Plan (PCCP) - All Relevant Information
Not Found
§ 866.1640 Antimicrobial susceptibility test powder.
(a)
Identification. An antimicrobial susceptibility test powder is a device that consists of an antimicrobial drug powder packaged in vials in specified amounts and intended for use in clinical laboratories for determining in vitro susceptibility of bacterial pathogens to these therapeutic agents. Test results are used to determine the antimicrobial agent of choice in the treatment of bacterial diseases.(b)
Classification. Class II (performance standards).
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JUN 1 2 2003
2
510(k) SUMMARY
(page 1 of 3)
| DATE: | April 4, 2003 |
|---|---|
| CONTACT PERSON: | Linda K. Dillon |
| Chuck Lakel | |
| Pasco Laboratories | |
| 12750 West 42nd Avenue | |
| Wheat Ridge, Co 80033 | |
| 303-423-9504 | |
| TRADE NAME OF DEVICE: | Pasco MIC and MIC/ID Panels |
| COMMON NAME: | Antimicrobial Susceptibility Test |
| CLASSIFICATION NAME: | Class II Antimicrobial Susceptibility Test |
| Microbiology Panel #83 |
SUBSTANTIAL EQUIVALENCE:
In review of previous 510(k) notifications for the Pasco MIC and MIC/ID panel: K011116, April 24, 2001 RE: ESBL Confirmatory Test; K010508, April 23, 2001 RE: ESBL Screen Test; K020331, March 20, 2002 RE: Ertapenem; K001953, August 10, 2000 RE: Amoxicillin; K001887, August 9, 2000 RE: Ampicillin; K001721, August 4, 2000 RE: Clarithromycin: K001612, July 18, 2000 RE: Linezolid: K001516, July 12, 2000 RE: Moxifloxacin: K992853, November 4, 1999 RE: Cefdinir: K992726, November 3, 1999 RE: Synercid (non-fastidious); K992717, November 2, 1999 RE: Synercid: K992646, October 19, 1999 RE: Penicillin; K992647, October 19, 1999 RE: Erythromycin; K992593, October 14, 1999 RE: Chloramphenicol; K992562, October 13, 1999 RE: Ceftriaxone; K992568, October 14, 1999 RE: Cefotaxime; K992507. October 18, 1999 RE: Trovafloxacin; K992546, October 12, 1999 RE: Meropenem; K992420, September 27, 1999 RE: Sparfloxacin; K992296, September 21, 1999 RE: Vancomycin: K992297, September 3, 1999 RE: Levofloxacin; K992143, September 16, 1999 RE: Clindamycin; K992108, September 3, 1999 RE: Cefepime; K992076, August 30, 1999 RE: Cefuroxime; K992059, August 30, 1999 RE: Imipenem; K992077, September 3, 1999 RE: Ofloxacin; K991925, August 20, 1999 RE: Amoxicillin/Clavulanic Acid; and K946126, January 17, 1995 RE: Detection of resistant pneumococci), the FDA has determined the Pasco panels to be substantially equivalent to devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments.
The term "substantial equivalence" as used in this 510(k) notification is limited to the definition of substantial equivalence as found in the Federal Food, Drug, and Cosmetic Act, as amended and as applied under 21 CFR 807, Subpart E under which a device can be marketed without pre-market approval or reclassification. A determination of
1
substantial equivalency under this notification is not intended to have any bearing whatsoever on the resolution of patent infringement suits or any other patent matters. No statements related to, or in support of, substantial equivalence herein shall be construed as an admission against interest under the US Patent Laws or their application by the courts.
DESCRIPTION OF THE DEVICE:
Pasco Panels are used for quantitatively measuring the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms. Varving concentrations of antimicrobial agents (usually in two-fold dilutions) are dispensed into the Pasco microdilution panels and the panels are then frozen. Panels are thawed prior to use, inoculated with the test organisms, incubated the traditional 16-24 hours and panels are then observed for visible growth or color changes as described in the package insert.
The lowest concentration of each antimicrobial agent with no apparent visible growth of the test organism is recorded as the minimum inhibitory concentration (MIC). Changes in pH and production of specific metabolites from growth in biochemical substrates are interpreted as described in the package insert for conventional tubed media.
INTENDED USE FOR THE PASCO MIC AND MIC/ID PANELS:
PASCO MIC AND MIC/ID PANELS are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement or category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms.
SUMMARY/CONCLUSION OF SUBSTANTIAL EQUIVALENCE TESTING: Challenge strains, fresh clinical isolates, stock clinical isolates and QC strains were tested concurrently using both Pasco methodology and reference methodology in panels contained Ertapenem at concentrations ranging from 0.03 - 32 mcg/ml. Testing was conducted at three test sites.
Test results from 410 challenge and clinical Staphylococci spp. demonstrated an Essential Agreement (EA) of 98.3%. For the methicillin-susceptible Staphylococci spp., the Category agreement (CA) was 100% with no very major or minor errors noted.
Test results of 574 challenge and clinical Enterobacteriaceae demonstrated an Essential Agreement (EA) of 99.6%. No major (M) or very major (VM) errors were observed. Category Agreement (CA) was acceptable at 99.4% with 5 random minor discrepancies, all of which were within EA.
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510(k) SUMMARY (page 3 of 3)
QC endpoints for the NCCLS recommended QC organisms (S. aureus ATCC 29213, E. faecalis ATCC 29212, E. coli ATCC 25922 and P. aeruginosa ATCC 27853) from panels using both the reference and test methodology were acceptable.
Reproducibility testing of 10 organisms at each site on three separate days in triplicate demonstrated inter-site reproducibility of MIC results of 100%. Intra-site reproducibility of MIC results was also 100% for all sites.
The results of the clinical testing, reproducibility testing and QC performance testing supports Substantial Equivalence as outlined in the FDA document "Class II Special Controls Guidance Document: Antimicrobial Susceptibility Test (AST) Systems; Guidance for Industry and FDA.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the text "Public Health Service". The text is in a simple, sans-serif font and is left-aligned. The words are stacked on a single line. The text is likely part of a document or sign.
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JUN 1 2 2003
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
Ms. Linda K. Dillon R&D Manager BD Diagnostics Systems Pasco Laboratories 12750 W. 42nd Avenue Wheat Ridge, CO 80033-2440
K031103 Re:
Trade/Device Name: PASCO MIC and MIC/ID Panels Ertapenem, 0.03-32 µg/ml Regulation Number: 21 CFR 866.1640 Regulation Name: Antimicrobial Susceptibility Test Regulatory Class: Class II Product Code: JWY Dated: April 4, 2003 Received: May 14, 2003
Dear Ms. Dillon:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Parts 801 and 809); and good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820).
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Page 2 -
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific information about the application of labeling requirements to your device, or questions on the promotion and advertising of your device, please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 594-3084. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.
Sincerely yours,
Steven Sutman
Steven I. Gutman, M.D., M.B.A. Director Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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Page 1 of 1
510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________
Device Name: PASCO MIC and MIC/ID Panels
Indications For Use: Inclusion of Ertapenem
Pasco MIC and MIC/ID panels are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement of category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms.
This 510(k) notification is for the antimicrobial Ertapenem at concentrations of 0.03 - 32 mcg/ml to Pasco Panels. Ertapenem has been shown to be active in vitro against most strains of microorganisms listed below, as described in the FDA-approved package insert for this antimicrobic.
Active In Vitro and in Clinical Infectious Against:
Aerobic Gram-positive microorganisms Staphylococcus aureus (methicillin-susceptible strains only)
Aerobic Gram-negative microorganisms Escherichia coli Klebsiella pneumoniae
Active In Vitro but their clinical significance is unknown
Aerobic Gram-negative microorganisms
Citrobacter freundii Citrobacter koseri Enterobacter aerogenes Enterobacter cloacae Klebsiella oxytoca (excluding ESBL producing strains) Morganella morganii Proteus mirabilis Proteus vulgaris Serratia marcescens
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) al additional la F-Padle
Division Sign-Off
Concurrence of CDRH, Office of Device Evaluation (ODE)
Office of In Vitro Diagnostic Device
Evaluation and Safety
| Prescription Use (Per 21 CRF 801.109) | 510(k) |
|---|---|
| OR | |
| Over The Counter Use (Optional Format 1-2-96) |