(50 days)
The BD Phoenix™ Automated Microbiology System is intended for the rapid identification and in vitro antimicrobial susceptibility testing of isolates from pure culture of most aerobic and facultative anaerobic Gram-negative and Gram-positive bacteria of human origin.
The BD Phoenix™ Automated Microbiology System is intended for in vitro quantitative determination of antimicrobial susceptibility by minimal inhibitory concentration (MIC) of most Gram-negative aerobic and facultative anaerobic bacteria isolates from pure culture for Enterobacteriaceae and Non-Enterobacteriaceae and most Gram-positive bacteria isolates from pure culture belonging to the genera Staphylococcus, Enterococcus, and Streptococcus.
This premarket notification is for additional organism groups and BD Phoenix™ Automated Microbiology System with cefepime (0.5-64 µg/mL) and ceftriaxone (0.5-64 µg/mL) on Gramnegative ID/AST or AST only Phoenix panels.
The BD Phoenix Automated Microbiology System (Phoenix System) is an automated system for the rapid identification (ID) and antimicrobial susceptibility testing (AST) of clinically relevant bacterial isolates. The system includes the following components:
- . BD Phoenix instrument and software.
- BD Phoenix panels containing biochemicals for organism ID testing and antimicrobial agents . for AST determinations.
- BD Phoenix ID Broth used for performing ID tests and preparing AST Broth inoculum. .
- . BD Phoenix AST Broth used for performing AST tests only.
- BD Phoenix AST Indicator solution added to the AST Broth to aid in bacterial growth . determination.
The Phoenix AST method is a broth based microdilution test. The Phoenix System utilizes a redox indicator for the detection of organism growth in the presence of an antimicrobial agent. Measurements of changes to the indicator as well as bacterial turbidity are used in the determination of bacterial growth. Each AST panel configuration contains several antimicrobial agents with a wide range of two-fold doubling dilution concentrations.
The Phoenix panel is a sealed and self-inoculating molded polystyrene tray with 136 micro-wells containing dried reagents. Organisms for susceptibility testing must be a pure culture and preliminarily identified as a Gram-negative or Gram-positive isolate. Phoenix panels are inoculated with a specified organism density and placed into the instrument.
The instrument houses the panels where they are continuously incubated at a nominal temperature of 35℃. The instrument takes readings of the panels every 20 minutes. The readings are interpreted to give an identification of the isolate, minimum inhibitory concentration (MIC) values and category interpretations, S, I, or R (sensitive, intermediate, or resistant).
1. Acceptance Criteria and Reported Device Performance
| Antimicrobial | Acceptance Criteria (FDA Guidance 2003) | Device Performance (Essential Agreement, EA%) | Device Performance (Category Agreement, CA%) |
|---|---|---|---|
| Cefepime | N/A (Guidance sets thresholds) | 95.2% | 92.9% |
| Ceftriaxone | N/A (Guidance sets thresholds) | 95.8% | 90.9% |
Note: The document references the "Class II Special Controls Guidance Document: Antimicrobial Susceptibility Test (AST) Systems: Guidance for Industry and FDA," February 5, 2003. While specific numerical acceptance criteria for EA and CA are not explicitly stated in the provided text, such guidance documents typically define thresholds for these metrics to demonstrate substantial equivalence. The reported performance metrics are then compared against these implied or explicit thresholds.
2. Sample Size Used for the Test Set and Data Provenance
The exact sample size for the test set is not explicitly stated as a single number. Instead, the number of isolates for which Essential Agreement (EA) and Category Agreement (CA) were calculated for each antimicrobial agent are provided.
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Cefepime: 1789 isolates for EA and CA.
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Ceftriaxone: 1872 isolates for EA and CA.
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Data Provenance: Clinical, stock, and challenge isolates were tested from "multiple geographically diverse sites across the United States." This indicates a prospective collection of data from diverse US locations.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
The document does not specify the number of experts or their qualifications used to establish the ground truth. It states that Phoenix System results for clinical isolates were compared to results obtained from the CLSI reference broth microdilution method. While this method is a well-established standard, it doesn't explicitly involve a panel of human experts for ground truth establishment in the same way, for instance, a radiological image interpretation study would.
4. Adjudication Method for the Test Set
The document does not describe an adjudication method involving multiple readers or a specific consensus process. The comparison is made directly between the BD Phoenix System results and the CLSI reference broth microdilution method.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No, a multi-reader multi-case (MRMC) comparative effectiveness study was not explicitly done or described in the provided text. The study focused on comparing the automated system's performance against a reference method rather than assessing human reader improvement with or without AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Yes, a standalone performance evaluation was done. The study directly assessed the performance of the "BD Phoenix™ Automated Microbiology System" (the device/algorithm) against the CLSI reference broth microdilution method. This represents the algorithm's performance without direct human intervention in the result determination process for the tested isolates.
7. The Type of Ground Truth Used
The ground truth used was the CLSI reference broth microdilution method. This is considered the gold standard for antimicrobial susceptibility testing. For challenge set isolates, the Phoenix System results were compared to "expected results," which would also be derived from established methods or known characteristics of the challenge strains.
8. The Sample Size for the Training Set
The document does not explicitly state the sample size for a "training set." The study described is an evaluation of the system's performance for new antimicrobial agents (Cefepime and Ceftriaxone) and additional organism groups. It's an assessment of the developed system, not a description of its initial development or training.
9. How the Ground Truth for the Training Set Was Established
Since a dedicated training set is not explicitly mentioned or detailed, the method for establishing its ground truth is not provided. Assuming the system was "trained" or developed based on established microbiology principles and possibly internal datasets, those datasets would have likely used the CLSI reference broth microdilution method or similar validated gold standards to establish ground truth during the system's development.
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510(K) SUMMARY
| SUBMITTED BY: | Becton, Dickinson and Company7 Loveton CircleSparks, MD 21152Phone: (410) 316 - 4278Fax: 410-316-4499 |
|---|---|
| CONTACT NAME: | Monica E GiguereRegulatory Affairs Specialist |
| DATE PREPARED: | March 30, 2006 |
| DEVICE TRADE NAME: | BD Phoenix ™ Automated Microbiology System --Cefepime-0.5-64 µg/mL and Ceftriaxone-0.5-64 µg/mL, |
| DEVICE COMMON NAME: | Antimicrobial susceptibility test system-short incubation |
| DEVICE CLASSIFICATION: | Fully Automated Short-Term Incubation Cycle AntimicrobialSusceptibility Device, 21 CFR 866.1645 |
| PREDICATE DEVICES: | VITEK ® System (PMA No. N50510) and BD Phoenix ™Automated Microbiology System with Gatifloxacin (K020321,May 23, 2002), Cefepime-0.5-64 µg/mL (K032675, March 1,2004) and Ceftriaxone -0.5-64 µg/mL (K032655,October 6, 2003) |
| INTENDED USE: | The BD Phoenix ™ Automated Microbiology System isintended for the rapid identification and in vitro antimicrobialsusceptibility testing of isolates from pure culture of mostaerobic and facultative anaerobic Gram-negative and Gram-positive bacteria of human origin. |
DEVICE DESCRIPTION:
The BD Phoenix Automated Microbiology System (Phoenix System) is an automated system for the rapid identification (ID) and antimicrobial susceptibility testing (AST) of clinically relevant bacterial isolates. The system includes the following components:
- . BD Phoenix instrument and software.
- BD Phoenix panels containing biochemicals for organism ID testing and antimicrobial agents . for AST determinations.
- BD Phoenix ID Broth used for performing ID tests and preparing AST Broth inoculum. .
- . BD Phoenix AST Broth used for performing AST tests only.
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- BD Phoenix AST Indicator solution added to the AST Broth to aid in bacterial growth . determination.
The Phoenix AST method is a broth based microdilution test. The Phoenix System utilizes a redox indicator for the detection of organism growth in the presence of an antimicrobial agent. Measurements of changes to the indicator as well as bacterial turbidity are used in the determination of bacterial growth. Each AST panel configuration contains several antimicrobial agents with a wide range of two-fold doubling dilution concentrations.
The Phoenix panel is a sealed and self-inoculating molded polystyrene tray with 136 micro-wells containing dried reagents. Organisms for susceptibility testing must be a pure culture and preliminarily identified as a Gram-negative or Gram-positive isolate. Phoenix panels are inoculated with a specified organism density and placed into the instrument.
The instrument houses the panels where they are continuously incubated at a nominal temperature of 35℃. The instrument takes readings of the panels every 20 minutes. The readings are interpreted to give an identification of the isolate, minimum inhibitory concentration (MIC) values and category interpretations, S, I, or R (sensitive, intermediate, or resistant).
DEVICE COMPARISON:
The BD Phoenix™ Automated Microbiology System demonstrated substantially equivalent performance when compared with the CLSI reference broth microdilution method. This premarket notification provides data for additional organism groups with Cefepime - 0.5-64 ug/mL and Ceftriaxone - 0.5-64 µg/mL and the BD Phoenix™ Automated Microbiology System.
SUMMARY OF SUBSTANTIAL EQUIVALENCE TESTING:
The BD Phoenix™ Automated Microbiology System has demonstrated substantially equivalent performance when compared to the CLSI reference broth microdilution method (AST panels prepared according to NCCLS M7). The system has been evaluated as defined in the FDA Draft guidance document, "Class II Special Controls Guidance Document: Antimicrobial Susceptibility Test (AST) Systems: Guidance for Industry and FDA," February 5, 2003.
Site Reproducibility
Intra- and inter-site reproducibility of this antimicrobial agent in the BD Phoenix System was evaluated at three sites using a panel chosen isolates. Each site tested the isolates in triplicate on three different days using one lot of Phoenix panels containing the antimicrobial agents and associated reagents.
The results of the study demonstrate for each antimicrobial agent there was an overall intra-site reproducibility of greater than 90% and an overall inter-site reproducibility greater than 95% for the isolates tested.
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Clinical Studies
Clinical, stock and challenge isolates were tested across multiple geographically diverse sites across the United States to demonstrate the performance of the Phoenix antimicrobial susceptibility test with the Phoenix panel formats containing antimicrobial agents. Phoenix System results for Challenge set isolates were compared to the expected results. Phoenix System results for clinical isolates were compared to the results obtained from the CLSI reference broth microdilution method.
The performance of the Phoenix System was assessed by calculating Essential Agreement (EA) and Category Agreement (CA) to expected/reference results for all isolates tested. Essential Agreement (EA) occurs when the BD Phoenix™ Automated Microbiology System agrees exactly or within ± one two-fold dilution to the reference result. Category Agreement (CA) occurs when the BD Phoenix™ Automated Microbiology System agrees with the reference method with respect to the FDA categorical interpretive criteria (susceptible, intermediate, and resistant).
Table 1 summarizes the performance for the isolates tested in this study.
Table 1: Performance of BD Phoenix System by Drug
| Antimicrobial | Concentration | EA (n) | EA (%) | CA (n) | CA (%) |
|---|---|---|---|---|---|
| Cefepime | 0.5-64 μg/mL | 1789 | 95.2 | 1789 | 92.9 |
| Ceftriaxone | 0.5-64 μg/mL | 1872 | 95.8 | 1872 | 90.9 |
Conclusions Drawn from Substantial Equivalence Studies
The data collected from the substantial equivalence studies demonstrate that testing on the BD Phoenix™ Automated Microbiology System with this antimicrobial agent is substantially equivalent as outlined in the FDA draft guidance document, "Class II Special Controls Guidance Document: Antimicrobial Susceptibility Test (AST) Systems: Guidance for Industry and FDA." February 5, 2003. Technological characteristics of this system are substantially equivalent to those used in the VITEK® system, which received approval by the FDA under PMA number N50510 and BD Phoenix™ Automated Microbiology System with Gatifloxacin (K020321, May 23, 2002), Cefepime-0.5-64 µg/mL (K032675, March 1, 2004) and Ceftriaxone -0.5-64 µg/mL (K032655, October 6, 2003).
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo features a stylized depiction of an eagle or bird-like figure with outstretched wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES, USA" is arranged in a circular fashion around the emblem.
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
APR 1 2 2006
Ms. Monica E. Giguere Regulatory Affairs Specialist BD Diagnostic Systems 7 Loveton Circle Sparks. MD 21152
Re: K060444/ S1
Trade/Device Name: BD Phoenix™ Automated Microbiology System Cefepime (0.5-64 ug/mL) and Ceftriaxone (0.5-64 ug/mL) on Gram-negative ID/AST or AST Regulation Number: 21 CFR 866.1645 Regulation Name: Fully Automated Short Term Incubation Cycle Antimicrobial Susceptibility Devices Regulatory Class: Class II Product Code: LON Dated: February 20, 2006 Received: February 21, 2006
Dear Ms. Giguere:
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).
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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)276-0484. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act 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/industry/support/index.html
Sincerely yours,
Sales, a Forg
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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Page 1 of 2
510(k) Number: K060444(S)
Device Name: BD Phoenix™ Automated Microbiology System for use with the antimicrobial agent Cefepime (0.5-64 µg/mL) and Ceftriaxone (0.5-64 µg/mL) on Gram-negative ID/AST or AST only Phoenix panels with additional organism groups
Indications for Use:
The BD Phoenix™ Automated Microbiology System is intended for in vitro quantitative determination of antimicrobial susceptibility by minimal inhibitory concentration (MIC) of most Gram-negative aerobic and facultative anaerobic bacteria isolates from pure culture for Enterobacteriaceae and Non-Enterobacteriaceae and most Gram-positive bacteria isolates from pure culture belonging to the genera Staphylococcus, Enterococcus, and Streptococcus.
This premarket notification is for additional organism groups and BD Phoenix™ Automated Microbiology System with cefepime (0.5-64 µg/mL) and ceftriaxone (0.5-64 µg/mL) on Gramnegative ID/AST or AST only Phoenix panels.
Cefepime 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 antimicrobial agent.
Active In Vitro and in Clinical Infections Against:
Pseudomonas aeruginosa
Enterobacter species Escherichia coli Klebsiella pneumoniae
Active In Vitro Against:
Acinetobacter lwoffi Citrobacter koseri Citrobacter freundii Hafnia alvei Klebsiella oxytoca Morganella morganii Pantoea agglomerans Providencia rettgeri Providencia stuartii Serratia marcescens
Division Sign-Off
Signature illegible for Sally Hojjat
Office of In Vitre Diagnostic Device Evaluation and Safety
-10(k)_
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Ceftriaxone 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 antimicrobial agent.
Active In Vitro and in Clinical Infections Against:
Acinetobacter calcoaceticus Enterobacter aerogenes Enterobacter cloacae Escherichia coli
Klebsiella oxytoca Klebsiella pneumoniae Morganella morganii Proteus mirabilis
Serratia marcescens Pseudomonas aeruginosa
Active In Vitro Against:
Citrobacter koseri (formerly C. diversus) Citrobacter freundii Providencia species (including Providencia rettgeri) Salmonella species Shigella species
Prescription Use (Per 21 CFR 801.109) Over-the-Counter Use
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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Division Sign-Off
Office of In Vitro Diagnostic Device Evaluation and Safety
510(k) K060444/SCC1
§ 866.1645 Fully automated short-term incubation cycle antimicrobial susceptibility system.
(a)
Identification. A fully automated short-term incubation cycle antimicrobial susceptibility system is a device that incorporates concentrations of antimicrobial agents into a system for the purpose of determining in vitro susceptibility of bacterial pathogens isolated from clinical specimens. Test results obtained from short-term (less than 16 hours) incubation are used to determine the antimicrobial agent of choice to treat bacterial diseases.(b)
Classification. Class II (special controls). The special control for this device is FDA's guidance document entitled “Class II Special Controls Guidance Document: Antimicrobial Susceptibility Test (AST) Systems; Guidance for Industry and FDA.”