K Number
K032518
Device Name
PASCO MIC AND MIC/ID PANELS, GEMIFLOXACIN (STREP)
Date Cleared
2003-09-15

(32 days)

Product Code
Regulation Number
866.1640
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
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 addition of the antimicrobial Gemifloxacin at concentrations of 0.015 - 4 mcg/ml to Pasco Panels for use in testing Streptococcus pneumoniae and Streptococcus spp. other than S. pneumoniae. Gemifloxacin 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 Streptococcus pneumoniae (including penicillin-resistant strains) Active In Vitro but their clinical significance is unknown Aerobic Gram-positive microorganisms Streptococcus pvogenes
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. Varying 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.
More Information

Not Found

No
The device description details a traditional microdilution method based on visible growth and color changes, with no mention of automated interpretation or algorithmic analysis. The "Mentions AI, DNN, or ML" section is explicitly marked as "Not Found".

No
This device is for in vitro diagnostic use, specifically for quantitatively measuring the susceptibility of bacteria to antimicrobial agents and determining their biochemical identification. It does not directly treat or alleviate a disease, but rather provides information to aid in diagnosis and treatment selection.

Yes

The device "Pasco MIC and MIC/ID panels" 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 process identifies specific characteristics of pathogens that can inform treatment decisions, qualifying it as a diagnostic device.

No

The device description explicitly states that the Pasco Panels are physical microdilution panels containing antimicrobial agents, 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 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." This is a classic description of an in vitro diagnostic test, as it involves analyzing biological samples (bacterial pathogens) outside of the body to provide information for diagnosis and treatment decisions.
  • Device Description: The description details how the panels are used to determine the minimum inhibitory concentration (MIC) of antimicrobial agents and interpret biochemical changes. This process is performed in vitro (in a laboratory setting) using the provided panels and reagents.
  • Performance Studies: The performance studies involve testing bacterial strains using the Pasco methodology and comparing the results to a reference methodology. This type of testing is conducted to demonstrate the accuracy and reliability of an IVD device.

The device is designed to be used in a laboratory setting to test biological samples (bacterial cultures) and provide information about their characteristics (susceptibility to antibiotics and biochemical identification). This aligns directly 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 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 addition of the antimicrobial Gemifloxacin at concentrations of 0.015 - 4 mcg/ml to Pasco Panels for use in testing Streptococcus pneumoniae and Streptococcus spp. other than S. pneumoniae. Gemifloxacin 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.

Product codes (comma separated list FDA assigned to the subject device)

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. Varying 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

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Challenge strains, fresh clinical isolates, stock clinical isolates and OC strains were tested concurrently using both Pasco methodology and reference methodology in panels that contained Gemifloxacin at concentrations ranging from 0.015 - 4 mcg/ml. Testing was conducted at three test sites.

Test results of 570 challenge and clinical Streptococcus pneumoniae and Streptococcus spp. other than S. pneumoniae demonstrated an Essential Agreement (EA) of 99.7%. No major (M) or very major (VM) errors were observed. Category Agreement (CA) was acceptable at 99.0% with 7 random minor discrepancies, all of which were within EA with the exception of one.

OC endpoints for the NCCLS recommended QC organisms (S. pneumoniae ATCC 49619) 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 100% for all three sites.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Essential Agreement (EA) of 99.7%. Category Agreement (CA) was acceptable at 99.0%. Inter-site reproducibility of MIC results of 100%. Intra-site reproducibility of MIC results was 100%.

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K031727, K031205, K031103, K030933, K030620, 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): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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).

0

SEP 1 5 2003

KO32518

Image /page/0/Picture/2 description: The image contains a circled number 2. The number 2 is written in a simple, slightly slanted font. The circle around the number is complete and appears to have been drawn with a pen or marker.

510(k) SUMMARY

(page1 of 3)
----------------
DATE:August 8, 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 EOUIVALENCE:

In review of previous 510(k) notifications for the Pasco MIC and MIC/ID panel: K031727. July 30. 2003 RE Gemifloxacin: K031205. June 13, 2003 RE: Linezolid; K031103, June 12, 2003 RE: Ertapenem; K030933, May 1, 2003 RE: Moxifloxacin; K030620, April 14, 2003 RE: Gatifloxacin; 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 (nonfastidious): 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

510(k) SUMMARY (page 2 of 3)

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. Varying 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 OC strains were tested concurrently using both Pasco methodology and reference methodology in panels that contained Gemifloxacin at concentrations ranging from 0.015 - 4 mcg/ml. Testing was conducted at three test sites.

Test results of 570 challenge and clinical Streptococcus pneumoniae and Streptococcus spp. other than S. pneumoniae demonstrated an Essential Agreement (EA) of 99.7%. No major (M) or very major (VM) errors were observed. Category Agreement (CA) was acceptable at 99.0% with 7 random minor discrepancies, all of which were within EA with the exception of one.

2

510(k) SUMMARY (page 3 of 3)

OC endpoints for the NCCLS recommended QC organisms (S. pneumoniae ATCC 49619) 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 100% for all three 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.

3

Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services. The logo consists of a stylized caduceus symbol, which is a staff with two snakes coiled around it, often associated with medicine and healthcare. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES (USA)" are arranged in a circular fashion around the caduceus symbol.

Public Health Service

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

SEP 1 5 2003

Ms. Linda K. Dillon R&D Manager BD Diagnostic Systems Pasco Laboratories 12750 W. 42nd Avenue Wheat Ridge, CO 80033-2440

Re: K032518

Trade/Device Name: PASCO MIC and MIC/ID Panels Gemifloxacin, 0.015-4 ug/ml Regulation Number: 21 CFR 866.1640 Regulation Name: Antimicrobial Susceptibility Test Regulatory Class: Class II Product Code: JWY Dated: August 8, 2003 Received: August 16, 2003

Dear Ms. Dillon:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have deternined 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 (QS) regulation (21 CFR Part 820).

4

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

5

Page 1 of 1

6

510(k) Number (if known): الك 32 32 ك

Device Name: PASCO MIC and MIC/ID Panels

Indications For Use: Inclusion of Gemifloxacin

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 addition of the antimicrobial Gemifloxacin at concentrations of 0.015 - 4 mcg/ml to Pasco Panels for use in testing Streptococcus pneumoniae and Streptococcus spp. other than S. pneumoniae. Gemifloxacin 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

Streptococcus pneumoniae (including penicillin-resistant strains)

Active In Vitro but their clinical significance is unknown

Aerobic Gram-positive microorganisms

1000 States of the same of the states of the same of the states of the states of the states of the states of the states of the states of the states of the states of the state

Streptococcus pvogenes

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

| Prescription Use
(Per 21 CRF 801.109) | ✓ | OR | Over-The-Counter Use
(Optional Format 1-2-96) |

---------------------------------------------------------------------------------------------------
Division Sign-OffSam ctgf 9/11/03
-------------------------------------

Office of In Vitro Diagnostic

Evaluation and Safety

510(k) K032518