K Number
K050590
Date Cleared
2006-08-10

(520 days)

Product Code
Regulation Number
866.3830
Reference & Predicate Devices
N/A
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

ENZY-WELL SYPHILIS IgG is an immunoenzymatic method for the qualitative detection of IgG antibodies to Treponema pallidum in human serum by a manual technique. The test may be used in conjunction with non-treponemal testing to provide serological evidence of infection with T. pallidum. For in vitro diagnostic use only.

Device Description

ENZY-WELL SYPHILIS IgG is an immunoenzymatic method for the qualitative detection of IgG antibodies to Treponema pallidum in human serum/ plasma. The test may be used in conjunction with non-treponemal testing to provide serological evidence of infection with T. pallidum. The ENZY-WELL SYPHILIS IgG test is based on the ELISA technique (Enzyme-linked immunosorbent assay). Diluted patient sample is incubated in microplate wells coated with T. pallidum. During this incubation specific immunoglobulins, if present, bind to the antigen on the well. After washing, to eliminate unbound proteins, a second incubation is performed with the conjugate, composed of human IgG monoclonal antibodies labeled with peroxidase. After washing to remove unbound conjugate from the wells, the substrate is added, which will react to produce color in the presence of the peroxidase. An acidic solution is added to stop the reaction and the absorbance of the developed color is read at 450 nm

AI/ML Overview

Here's a summary of the acceptance criteria and the study details for the ENZY-WELL SYPHILIS IgG device, based on the provided document:


Acceptance Criteria and Device Performance

Acceptance Criteria CategorySpecific MetricAcceptance CriteriaReported Device Performance (ENZY-WELL SYPHILIS IgG)
Clinical PerformanceSensitivityNot explicitly stated as a numerical threshold, but implied to be high based on predicate comparison.100% agreement positive with CAPTIA Syphilis - G (for syphilitic sera), Clinical Sensitivity with FTA: 96.7% (Lab A).
SpecificityNot explicitly stated as a numerical threshold, but implied to be high based on predicate comparison.99.6% agreement negative with CAPTIA Syphilis - G (for negative sera), Analytical Specificity: 100% (Cross-reactivity study). Clinical Specificity with FTA: 88.4% (Lab A).
PrecisionWithin-run CV%CV lower than 15%Generally well within 15%, with a few exceptions (e.g., Neg serum2 on Day 2 Run 2, and some values for C and D in Lab A & B intra-run).
Between-run CV%Not explicitly stated as a numerical threshold, but implied to be low for consistency.Ranges from 2.5% to 21% (for positives) and up to NA for negatives (due to very low O.D.).
Interlaboratory CV%Not explicitly stated as a numerical threshold, but implied to be low for consistency.Ranges from 19% to 27% (for positives), and up to NA for negatives.
Cross-ReactivityInterferenceNo interferencesNo interferences shown, 100% analytical specificity. One HCV positive sample was reactive but confirmed positive by TPHA.

Study Details

  1. Sample sizes used for the test set and data provenance:

    • Clinical Sample Correlation (Primary Study):
      • First group (syphilitic sera): 125 samples (pediatric and adult, male and female patients). Data provenance not explicitly stated (e.g., country), but implied to be clinical. Retrospective/prospective not specified.
      • Second group (negative sera): 300 samples (150 from clinical sources/blood donors, 150 from normal donors). Data provenance not explicitly stated, but implied to be clinical. Retrospective/prospective not specified.
      • Third group (different pathologies): 100 samples (no known history/serological evidence of syphilis, suspected for other infective/clinical pathology). Data provenance not explicitly stated. Retrospective/prospective not specified.
    • Clinical Studies (Independent Labs): 387 specimens across two independent clinical laboratories (Lab B and Lab C).
    • Cross-Reactivity & Interference Studies: 332 sera with known diseases collected from a "seroteque" (implying retrospective sourcing).
    • Precision Studies: Various control and serum samples (number not detailed for each type beyond "3 replicates" for specific samples in each run/day experiment).
  2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

    • The document primarily relies on "comparative testing methods" and "confirmatory tests" (FTA-ABS, TPHA, VDRL) rather than direct expert consensus on raw data.
    • For the 'First group' of 125 syphilitic sera, it states "no disagreement between two comparative testing methods." This suggests at least two methods or interpretations were used, but not necessarily by human experts on individual cases.
    • For discordant results in the negative and pathological groups, confirmatory tests like FTA-ABS, TPHA, and VDRL were used. The interpretation of these confirmatory tests would likely be performed by qualified laboratory personnel, but the number and specific qualifications of such "experts" are not detailed.
  3. Adjudication method for the test set:

    • For the primary clinical sample correlation, disputes between the ENZY-WELL SYPHILIS IgG and the predicate device (CAPTIA Syphilis - G) were resolved using confirmatory tests like FTA-ABS, TPHA, and VDRL.
    • For the 10 discordant samples in the independent clinical study, a "third commercially available test" (referee test) was used, and it agreed with the Diesse test for 8 out of 10 samples.
  4. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:

    • No, this device is an immunoassay (laboratory test kit), not an AI-assisted diagnostic device. Therefore, an MRMC study related to human readers improving with AI assistance is not applicable and was not performed.
  5. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:

    • Yes, the performance data presented is for the standalone performance of the ENZY-WELL SYPHILIS IgG immunoassay kit. It measures the qualitative detection of IgG antibodies directly from human serum/plasma. There is no "human-in-the-loop" component in the interpretive function of the device itself, although human laboratory technicians perform the assay.
  6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

    • Clinical Status: Ground truth was established based on clinical diagnosis of syphilis ("patients with syphilis") or confirmed negative status ("negative to Syphilis").
    • Confirmatory Tests: For validation and adjudication of discordant results, established laboratory confirmatory tests were used:
      • FTA-ABS (Fluorescent Treponemal Antibody Absorption)
      • TPHA (Treponema Pallidum Hemagglutination Assay)
      • VDRL (Venereal Disease Research Laboratory)
  7. The sample size for the training set:

    • This is an immunoassay kit, not a machine learning or AI model. Therefore, there isn't a traditional "training set" in the computational sense. The "development" of the assay involves optimizing reagents and conditions using internal samples, but these are not typically referred to as a "training set" in the context of device validation. The provided data focuses on the validation of the finalized kit.
  8. How the ground truth for the training set was established:

    • As noted above, there is no explicit "training set" for an AI or machine learning model. The ground truth for the performance evaluation (test set) samples was established based on clinical diagnosis, serological history, and confirmatory laboratory tests (FTA-ABS, TPHA, VDRL).

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K050590

Attachment no.5 to the December 9,2005 Letter

AUG 1 0 2006

Page 119

Appendix C

510(k) Summary of Safety and Effectiveness

NameDIESSE Diagnostica Senese SpA
AddressVia delle Rose 10, 53035 MonteriggioniSITel. 39-0577-587111Fax 39-0577-318690
Contact PersonDr. Francesco Cocola
Phone Number39-0577-587143
Fax Number39-0577-318379

The Following section is included as required by the Safe Medical Device Act (SMDA) 1990. 510(k) Summary of Safety and Effectiveness

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92. The Assigned 510(k) Number is: K050590 Applicant

DatePreparedFebruary 4, 2004
NameDIESSE Diagnostica Senese SpA
AddressVia delle Rose 10, 53035 Monteriggioni SI, ItalyTel. 011-39-0577- 587111Fax 011-39-0577-318690
ContactPersonDr. Francesco Cocola
PhoneNumber39-0577-587143
Fax Number39-0577-318379

Device information

Trade NameENZY-WELL SYPHILIS IgG
ClassificationNameEnzyme linked immunosorbent assay, Treponema pallidum
Equivalent Device

Equivalent Device

Trinity Biotech CAPTIA Syphilis-G Elisa Test Kit

Device Description

ENZY-WELL SYPHILIS IgG is an immunoenzymatic method for the qualitative detection of IgG antibodies to Treponema pallidum in human serum/ plasma. The test may be used in conjunction with non-treponemal testing to provide serological evidence of infection with T. pallidum.

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Principle of the assay

The ENZY-WELL SYPHILIS IgG test is based on the ELISA technique (Enzyme-linked immunosorbent assay). Diluted patient sample is incubated in microplate wells coated with T. pallidum. During this incubation specific immunoglobulins, if present, bind to the antigen on the well. After washing, to eliminate unbound proteins, a second incubation is performed with the conjugate, composed of human IgG monoclonal antibodies labeled with peroxidase. After washing to remove unbound conjugate from the wells, the substrate is added, which will react to produce color in the presence of the peroxidase. An acidic solution is added to stop the reaction and the absorbance of the developed color is read at 450 nm

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Performance Characteristic

Comparison studies, precision studies, interference and specificity studies, expected values were performed. Performance was evaluated at Azienda Ospedaliera Umberto I (Ancona).

CLINICAL SAMPLE CORRELATION

A total of 525 samples were collected and tested to study the performance of the ENZY-WELL SYPHILIS laG kit.

FIRST group: 125 serum samples from both pediatric and adult male and female patients with syphilis.

SECOND group: 300 negative sera; 150 of these serum samples came from clinical sources and/or from a blood donor facility and 150 samples from normal donors.

THIRD group: 100 samples from subjects with no known history or serological evidence of syphilis and suspected for different kinds of infective or clinical pathology.

In the first group of the 125 syphilitic sera there was no disagreement between two comparative testing methods; therefore the reference method FTA-ABS was not used. In the second group of the 300 syphilis-negative sera there was one sample not in agreement. It was equivocal with the ENZY-WELL SYPHILIS IgG test and negative with the CAPTIA Syphilis - G test. The confirmatory FTA-ABS test was negative (it was also negative with TPHA and VDRL test).

Table n°1

Results obtained with ENZYWELL vs. Captia Syphills-G, testing 127(First Group ) Syphilitic sera:

CAPTIA Syphilis - G
NegativeEquivocalPositive
ENZY-WELSYPHILIS IgGNegative000
Equivocal000
Positive00125

Results:

Percent agreement positive = 100 %. 95% CI: 100% <Se <100%

Table n°2

Results obtained testing 300 sera( Second Group): 150 sera from clinical source and 150 sera from normal donor, both groups were negative to Syphilis

CAPTIA Syphilis -G
NegativeEquivocalPositive
ENZY-WELLNegative29900
Equivocal000
Positive1*00

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  • The test gave a positive result even after repeat testing. Both the confirmatory tests (FTA-ABS and TPHA) gave negative results.

Percent agreement negative = 99.6 %.

95% Cl: 99%<Sp<100%

In the third group of 100 sera with different pathological diseases, two sera gave equivocal results with both methods, also after repeating the test. The confirmatory test gave a positive result with a titer of 1280; the FTA-ABS test also gave positive results.

The Percent agreement negative of ENZY-WELL SYPHILIS IgG kit in this group is 100%

In addition, clinical studies performed at two independent clinical laboratories with a total of three hundred and eighty-seven specimens, comparing the Diesse Enzy-well Syphilis IgG test with two other commercially available tests.

DiesseClinical Sensitivityand Specificity
FTAPosEqvNeg%95 % C.I.
Reactive293196.790.2 to 100
Non-Reactive517588.490.3 to 99.0
94.590.3 to 98.8

Lab B

Lab C

EIA% Agreement (Pos.or Neg.)
EnzyWELIPosEqvNeg%95 % C.I.
Positive72277.850.6 to 100
Equivocal010
Negative2225799.298.2 to 100
98.597.1 to 99.9

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23

8

6

10

370

801

101

୧୫

6.3

1.1

8.6

10.0

Excluding equivocal results, a total of 10 samples gave discordant results. When these samples were tested by a third commercially available test, the referee test agreed with the Diesse test for 8 of the 10 discordant samples tested.

PRECISION

All samples (Cut-Off Control, Positive Control and Negative Control) were tested in triplicate in two separate runs on three different days. CV lower than 15% are accepted. Within run Precision

DAY 1ReplicatesRUN 1RUN 2
SAMPLES3O.D.S.D.CV%O.D.S.D.CV%
CutOff3353226.2324237.1
Pos. control.31171201.71091918.4
Neg. Control34912.34923.5
Pos serum 131687281.715241379.0
Pos serum 232141894.12184502.3
Pos serum 33383133.3329329.8
Pos serum 43838182.1766597.7
Neg serum137534.16757.0
Neg serum23861112.48034.3
DAY 2ReplicatesRUN 1RUN 2
SAMPLES3O.D.S.D.CV%O.D.S.D.CV%
CutOff3386276.9314144.5
Pos control.31235836.71233604.9
Neg. control33712.73500.0
Pos serum 131787824.61706432.5
Pos serum 232408592.42351944.0
Pos serum 33360215.7322247.4
Pos serum 43879849.6775577.4
Neg serum1368912.75235.8
Neg serum238045.4762127.4
DAY 3ReplicatesRUN 1RUN 2
SAMPLES3O.D.S.D.CV%O.D.S.D.CV%
Cut-Off334292.7339144.0
Pos Control.31218262.11204836.9
Neg Control334411.23413.4
Pos serum 131613573.61633402.4
Pos serum 23195822811.720931768.4

5.1 3 365 19 Pos serum 3 3 769 48 6.2 Pos serum 4 5.7 3 Neg serum 1 3 61 7.2 5 Neg serum 2 દર્ભ 3

Between run Precision

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INDEX
SAMPLEO.D AVERAGESDCV%
CUTOFF343185.2
Pos. Control.1192615.1
Neg. Control4013.9
Positive serum 11658654.0
Positive serum 221891165.5
Positive serum 3355226.3
Positive serum 4805465.7
Negative serum 17157.5
Negative serum 276810.9

In addition, the kit positive and negative controls, plus six additional samples, including 2 negatives and four positives, were assayed in triplicate, in three different runs, at three independent laboratories, using automated analyzers.

Within Run Precision

Lab·A

Run 1Run 2Run 3
IDO.D.S.D.CV%O.D.S.D.CV%O.D.S.D.CV%
PC187021111.3210822710.823581144.8
NC52NANA00NA00NA
A5220NA00NA00NA
B556NA00NA00NA
C617447.23986115.2501489.5
D60310517.446310121.85436011.0
E1013383.71004565.51222675.5
F10101009.9890535.91224746.0

Lab B

Run 1Run 2Run 3
IDO.D.S.D.CV%O.D.S.D.CV%O.D.S.D.CV%
PC1802321.81740291.61825170.9
NC142104NA9661NA13692NA
A13817NA9428NA13655NA

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B9647NA6737NA8673NA
C6378112.7597589.7614518.4
D782395.0691172.5770486.3
E12021018.41050605.81177776.6
F1010898.8995949.5981697.0

Lab C

. :

.

Run 1Run 2Run 3
IDO.D.S.D.CV%O.D.S.D.CV%O.D.S.D.CV%
PC2766301.127471164.32850491.7
NC030NA00NA20NA
A130NA149NA148NA
B5710NA596NA542NA
C824101.3887707.9823749.1
D909384.1942192.0937283.0
E1502704.71489422.81567412.6
F1469281.91659633.81470654.4

Between Run Precision

Lab ALab BLab C
ID O.D. S.D. CV% O.D. S.D. CV% O.D. S.D. CV%
PC 2112 271 12.8 1789 452.52788 833.0
INC 2ിച്ചINA12585INA11INA
রে1728INA12343INA14ರಿINA
B1828NA83055INA5717INA
રિવર્સ10621.061661ರಿ ಕಿ845688.1
D53610219.0748567.5ರಿನ ಕಿರಿ ನಿರ್ವಾರಿ ನಿರ್ವಹಿಸಿದ ಮಾರ್ಥಿಕ ಸಿರ್ವಹಿಸಿದ ಮಾರ್ಥಿಕ ಸಿರ್ವಹಿಸಿದ ಮಾರ್ಥಿಕ ಸಾಮಾನ್ಯ ಸಾಮಾನ್ಯವಾಗಿ ಮಾಡಿ ಮಾಡಿದ್ದಾರೆ. ಇದನ್ನು ಕಾರ್ಯಕ್ಕೆ ಮಾರ್ಗ್ ಅವರ ಮಾಡಿ ಮಾಡಿದ್ದಾರೆ. ಇದನ್ನು ಕಾರ್ಯಕ್ಕೆ0434.6
يلا1080 11911.01143 1039.01520 513.3
F1041 16415.7രിക്കും. അവലംബം പ്രശസ്ത പ്രവരിച്ചു. അവലംബം അതിനും പ്രവരിച്ചു. അവലംബം അതിനും പ്രവരിച്ചു. അവലംബം അതിനും അവലംബം അവലംബം അവലംബം അവലംബം അവലംബം അവലംബം അവലംബം അവലംബം അ07817.91533 1137.4

Interlaboratory Precision

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IDO.D.S.D.CV%
PC223051023
NC4371NA
A5162NA
B5333NA
C65617326
D73819727
E124823819
F119029825

CROSSREACTIVITY & INTERFERENCE STUDIES

In order to demonstrate Analitycal Specificity and Interferences an internal experimentation was performed using a total of 332 sera with known disease. Experimentation was performed in two times. The first time the following 130 sera, collected from seroteque, were tested. 73 sera from adults females, 57 from adult males. All these were characterized as follows:

CATEGORY OF SPECIMENSn
ALT20
HCV Positives21
HCV Ab Reactive9
Hypergammaglobulinemia19
Pregnant50
Total Bilirubine2
Lipemic2
Mono test (MT)8

In a second day 202 sera were tested. Sera summarized below:

CATEGORY OF SPECIMENSn
HCV Positives46
Pregnant110
HBSAg Vaccinated30
HBSAg Positives15

Obtained Results:

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Attachment no.5 to the December 9,2005 Letter

19.P
11
CATEGORY OF SPECIMENSnENZY-WELLSYPHILIS IgGReactive
HbsAg Vaccinated300
HBsAg Positives150
ALT200
Sera from HBV Vaccines110
HCV Positives641*
HCV Ab Reactive90
Hypergammaglobulinemia190
Pregnant1600
Total Bilirubine20
Lipemic20
Total Specimen332

Note: Confirmed positive with TPHA

Conclusion:

Only one sample that results reactive when tested with

ENZY- WELL Syphilis IgG was confirmed to be positive with TPHA (Confirmatory test)

Analytical specificity= 100%

No interferences are shown.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/9/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle. The logo is black and white.

Public Health Service

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

Mr. Raul Alvarez Consultant Diesse Inc. 1690 W. 38 Place, Unit B 1 Hialeah, Florida 33012

AUG 1 0 2006

K050590 Re: Trade/Device Name: ENZY-WELL Syphilis IgG Regulation Number: 21 CFR § 866.3830 Regulation Name: Treponema pallidum treponemal test reagent Regulatory Class: II Product Code: LIP Dated: May 30, 2006 Received: June 5, 2006

Dear Mr. Alvarez:

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 (QS) regulation (21 CFR Part 820). This letter requirements as 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.

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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 (240)276-0450. 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 vours,

Sally, anton

Sally A. Hojvat, M.Sc., Ph.D. Director Division of Microbiology Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number : K050590

Device Name: ENZY-WELL Syphilis IgG

Indications For Use:

  • For in vitro diagnostic use only. 1.
  • ENZY-WELL SYPHILIS IgG is an immunoenzymatic method for the 2. qualitative detection of IgG antibodies to Treponema pallidum in human serum by a manual technique.
  • The test may be used in conjunction with non-treponemal testing to provide 3. serological evidence of infection with T. pallidum.

Prescription Use __________ AND/OR x (Part 21 CFR 801 Subpart D)

Over-The-Counter Use (21 CFR 807 Subpart C)

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

Concurrence of CDRH, Office of In Vitro Diagnostic Devices (OIVD)

Luddi L. Poole
Division Sign-Off

Division Sign-Off

Page 1 of

Office of In Vitro Diagnostic Device Evaluation and Safety

310(k) KD50590

§ 866.3830

Treponema pallidum treponemal test reagents.(a)
Identification. Treponema pallidum treponemal test reagents are devices that consist of the antigens, antisera and all control reagents (standardized reagents with which test results are compared) which are derived from treponemal sources and that are used in the fluorescent treponemal antibody absorption test (FTA-ABS), theTreponema pallidum immobilization test (T.P.I.), and other treponemal tests used to identify antibodies toTreponema pallidum directly from infecting treponemal organisms in serum. The identification aids in the diagnosis of syphilis caused by bacteria belonging to the genusTreponema and provides epidemiological information on syphilis.(b)
Classification. Class II (performance standards).