K Number
K063787
Date Cleared
2008-03-13

(448 days)

Product Code
Regulation Number
866.5900
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

InPlex™ CF Molecular Test is an in vitro diagnostic device used to simultaneously detect and identify a panel of mutations and variants in the cystic fibrosis transmembrane conductance regulator (CFTR) gene in genomic DNA samples isolated from human peripheral whole blood specimens. The panel includes mutations and variants recommended by the 2004 American College of Medical Genetics (ACMG). The InPlex™ CF Molecular Test is a qualitative genotyping test that provides information intended to be used for cystic fibrosis carrier screening as recommended by ACMG and the 2005 American College of Obstetricians and Gynecologists (ACOG) for adults of reproductive age, as an aid in newborn screening for cystic fibrosis, and in confirmatory diagnostic testing for cystic fibrosis in newborns and children.

The test is not indicated for use in fetal diagnostic or pre-implantation testing. This test is also not indicated for stand-alone diagnostic purposes and results should be used in conjunction with other available laboratory and clinical information.

Device Description

InPlex™ CF Molecular Test amplifies specific regions of the CF7R gene in genomic DNA extracted from human whole peripheral blood. Each amplified DNA sample is subsequently mixed with Cleavase® enzyme and buffer then added to a loading port on an InPiex™ microfluidic card. An InPlex™ card contains eight sample-loading ports, each connected to 48 independent reaction chambers. Twenty-eight of these reaction chambers contain dried assay mixes specific for reporting the 23 ACMG/ACOG recommended CF7R mutations and variants. The remaining chambers consist of a "No Invader" Control", an Independent Quality Control. and several unused chambers.

After an InPlex™ card is loaded; the channels are mechanically sealed using a micro-fluidic card sealer, isolating each individual reaction chamber from all other chambers. The card is then incubated to allow individual Invader® reactions to occur. Following incubation, the card is read in a multi-well fluorometer and the raw signal data are imported into the InPlex™ CF Molecular Test Call Reporting Software for final result analysis.

AI/ML Overview

The InPlex™ CF Molecular Test is a qualitative genotyping test designed to detect and identify a panel of mutations and variants in the CFTR gene for cystic fibrosis carrier screening, newborn screening, and confirmatory diagnostic testing. The acceptance criteria and performance are detailed across several analytical studies rather than a single overarching study with a unified set of criteria and results. The studies consistently aim for high percent agreement with known genotypes, typically emphasizing a 1-sided lower 95% Confidence Limit.

Here's a breakdown of the requested information based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance:

The document presents several analytical studies, each with its own performance and acceptance criterion (implicitly, high agreement with ground truth). The overall accuracy and reproducibility studies are the most central to demonstrating the device's main function.

Study CategoryAcceptance Criteria (Implicit/Explicit)Reported Device Performance
DNA Extraction Equivalency100% agreement with DNA sequencing based genotyping for all extraction methods (with a 1-sided lower 95% CL)100% agreement (99.5%, 1-sided lower 95% Confidence Limit) across 644 calls (28 positive, 616 normal).
Fluorometer Equivalency100% agreement with DNA sequencing genotype results (with a 1-sided lower 95% CL) regardless of fluorometer used.100% agreement (99.8% 1-sided lower 95% Confidence Limit) across a minimum of 1,656 data points.
Incubator EquivalencyHigh percent agreement to known genotypes (with a 1-sided lower 95% CL).99.88% agreement (99.74%, 1-sided 95% Confidence Limit) to known genotypes across 1,656 data points.
Interfering Substances100% agreement with bidirectional sequencing (with a 1-sided lower 95% CL) for samples with interfering substances.100% agreement (99.7%, 1-sided lower 95% Confidence Limit) between genotypes of samples with interfering substances and bidirectional sequencing, across 1,104 data points.
Limit of Detection≥ 99% concordance with DNA sequencing at the lowest DNA concentration.Lower limit of detection: 5ng/μL DNA concentration (25ng input) showed 100% agreement (98.4%, 1-sided lower 95% Confidence Limit). Performance at other concentrations (10, 20, 50, 100 ng/µL) also showed 100% agreement. At 150ng/uL, 99.5% agreement (98.6%, 1-sided lower 95% Confidence Limit) was obtained.
Lot-to-Lot Equivalency100% agreement to pre-characterized gDNA genotypes for each lot tested (with a 1-sided lower 95% CL).100% agreement (99.4% 1-sided lower 95% Confidence Limit) to pre-characterized gDNA genotypes for each of 3 lots, with 529 calls per lot.
Accuracy and Repeat RateHigh overall, positive, and negative agreement with bi-directional DNA sequence analysis; low repeat rate.Overall agreement: 99.96% (2951/2952) (99.9%, 1-sided lower 95% Confidence Limit). Positive agreement: 100% (144/144) (97.9%, 1-sided lower 95% Confidence Limit). Negative agreement: 99.96% (2807/2808) (99.9%, 1-sided lower 95% Confidence Limit). Repeat rate: 0.8% (1 "Invalid" call out of 123 tests). Some initial miscalls (4 samples) were identified and later corrected to 100% agreement upon retesting and root cause investigation.
Freeze-Thaw Tolerance100% overall percent agreement with DNA sequencing for all freeze-thaw cycles tested (with a 1-sided lower 95% CL).100% overall agreement (99.92%, 1-sided lower 95% Confidence Limit) compared to DNA sequencing, across 3,703 data points (up to 12 cycles). Recommended: 8 or fewer freeze-thaw cycles.
Real-Time Stability100% observed percent agreement for each lot at each storage condition and time point (with a 1-sided lower 95% CL).100% observed percent agreement (99.1%, 1-sided lower 95% Confidence Limit) across 3 lots, 3 storage conditions, and 1-month time point, for 345 calls per lot/condition.
Reproducibility StudyHigh overall accuracy rate (with a 1-sided lower 95% CL).Overall accuracy rate: 99.994% (31,738/31,740) (99.986%, 1-sided lower 95% Confidence Limit). Percent agreement ranged from 99.962% to 100% at each of the three sites and 99.987% to 99.994% across all sites.

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • DNA Extraction Equivalency: 7 CF positive genomic DNA samples from human whole peripheral blood.
  • Fluorometer Equivalency: 8 genomic DNA (gDNA) samples (some CFTR mutation positive, some normal).
  • Incubator Equivalency: 8 gDNA samples.
  • Interfering Substances: 8 CF positive genomic DNA samples from human whole peripheral blood.
  • Limit of Detection: 8 gDNA samples.
  • Lot-to-Lot Equivalency: 23 CFTR gDNA samples.
  • Accuracy and Repeat Rate: 123 unique genomic DNA samples from peripheral whole blood and cell lines.
  • Freeze-Thaw Tolerance: 23 CFTR gDNA samples.
  • Real-Time Stability: A panel of seven CFTR gDNA samples and a panel of eight control samples.
  • Reproducibility Study (Proficiency Phase): 8 pre-characterized gDNA samples.
  • Reproducibility Study (Performance Phase): 23 samples containing mutations representing the ACMG recommended panel.

Data Provenance: The document does not explicitly state the country of origin for the samples or whether they were retrospective or prospective. It consistently refers to "genomic DNA samples isolated from human peripheral whole blood" and "cell lines," implying human biological samples. The use of "pre-characterized commercially available reference materials" in the Reproducibility Study suggests some samples might be from commercial sources. Without further information, the provenance is unknown.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

The ground truth for most studies was established by DNA sequencing (bidirectional DNA sequencing). In the context of genetic testing, DNA sequencing itself is the "gold standard" and is not typically "read" by human experts in the same way an image would be. The results from sequencing are analyzed by bioinformatics tools and specialists in molecular genetics. The document does not specify the number or qualifications of individuals interpreting the sequencing data; it's assumed to be standard laboratory practice for DNA sequencing result analysis.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

There is no mention of an adjudication method involving multiple human readers for discrepancies. The comparison is directly between the InPlex™ CF Molecular Test results and the DNA sequencing results. The "root cause" investigation described after the initial miscalls in the "Accuracy and Repeat Rate" study implies a process of technical investigation rather than expert adjudication of conflicting interpretations.

5. 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, a multi-reader multi-case (MRMC) comparative effectiveness study was not conducted. This device is a molecular diagnostic test, not an imaging device typically involving human readers for interpretation. The "reproducibility study" involved multiple technicians at different sites, but this was to assess the assay's consistency across operators and sites, not to compare human reader performance with and without AI (or this assay's) assistance.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Yes, the studies described are essentially standalone performance studies of the InPlex™ CF Molecular Test. The device, including its Call Reporting Software, provides final result analysis. The performance data (e.g., percent agreement with DNA sequencing) reflects the algorithm's ability to accurately detect mutations without human interpretation being part of the primary outcome measure for accuracy. Human involvement would be in operating the device and performing the laboratory procedures, but the "call" itself is algorithm-generated.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

The primary ground truth used across all analytical studies is DNA sequencing (specifically, bidirectional DNA sequencing). This is considered the gold standard for genetic mutation detection. In some instances, samples were "pre-characterized gDNA genotypes," implying their mutation status was already known from previous (likely sequencing-based) analysis.

8. The sample size for the training set

The document does not explicitly mention a separate "training set" for the InPlex™ CF Molecular Test. As a molecular diagnostic test, such devices are typically developed and optimized using various samples during their R&D phase, but the rigorous performance studies presented (like accuracy, LoD, etc.) constitute the test set performance verification. The document describes analytical validation studies, not an AI model requiring distinct training and test sets in the conventional machine learning sense. The "samples" referred to throughout the document are for validation of the fully developed device.

9. How the ground truth for the training set was established

Since a distinct "training set" is not described, the method for establishing ground truth for development/optimization samples (if any) is not specified. However, given the nature of the device and the ground truth used for validation, it is highly probable that DNA sequencing would also have been the method used to establish ground truth for any samples used during the development and optimization phases.

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K063787

510(k) SUMMARY

TRADE NAME:

MAR 1 3 2008

InPlex™ CF Molecular Test

COMMON NAME:

CFTR Gene Mutation Detection System

CLASSIFICATION NAME:

Class II, 21 CFR 866.5900: Cystic Fibrosis Transmembrane Conductance Regulator (CFTR) Gene Mutation Detection System

PREDICATE DEVICE:

Tag-It™ Cystic Fibrosis Kit, K043011

DEVICE DESCRIPTION:

InPlex™ CF Molecular Test amplifies specific regions of the CF7R gene in genomic DNA extracted from human whole peripheral blood. Each amplified DNA sample is subsequently mixed with Cleavase® enzyme and buffer then added to a loading port on an InPiex™ microfluidic card. An InPlex™ card contains eight sample-loading ports, each connected to 48 independent reaction chambers. Twenty-eight of these reaction chambers contain dried assay mixes specific for reporting the 23 ACMG/ACOG recommended CF7R mutations and variants. The remaining chambers consist of a "No Invader" Control", an Independent Quality Control. and several unused chambers.

After an InPlex™ card is loaded; the channels are mechanically sealed using a micro-fluidic card sealer, isolating each individual reaction chamber from all other chambers. The card is then incubated to allow individual Invader® reactions to occur. Following incubation, the card is read in a multi-well fluorometer and the raw signal data are imported into the InPlex™ CF Molecular Test Call Reporting Software for final result analysis.

INDICATIONS FOR USE / INTENDED USE:

InPlex™ CF Molecular Test is an in vitro diagnostic device used to simultaneously detect and identify a panel of mutations and variants in the cystic fibrosis transmembrane conductance regulator (CFTR) gene in genomic DNA samples isolated from human peripheral whole blood specimens. The panel includes mutations and variants recommended by the 2004 American College of Medical Genetics (ACMG). The InPlex™ CF Molecular Test is a qualitative

InPlex™ CF Molecular Test 510(k) Submission

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genotyping test that provides information intended to be used for cystic fibrosis carrier screening as recommended by ACMG and the 2005 American College of Obstetricians and Gynecologists (ACOG) for adults of reproductive age, as an aid in newborn screening for cystic fibrosis, and in confirmatory diagnostic testing for cystic fibrosis in newborns and children.

The test is not indicated for use in fetal diagnostic or pre-implantation testing. This test is also not indicated for stand-alone diagnostic purposes and results should be used in conjunction with other available laboratory and clinical information.

CharacteristicsTag-It™ Cystic Fibrosis KitInPlex™ CF Molecular Test
Intended UseThe Tag-It™ Cystic Fibrosis Kit is adevice used to simultaneously detect andidentify a panel of mutations and variantsin the cystic fibrosis transmembraneconductance regulator (CFTR) gene inhuman blood specimens. The panelincludes mutations and variants currentlyrecommended by the American Collegeof Medical Genetics and AmericanCollege of Obstetricians andGynecologists (ACMG/ACOG), plussome of the worlds most common andNorth American-prevalent mutations.The Tag-It™ Cystic Fibrosis Kit is aqualitative genotyping test whichprovides information intended to be usedfor carrier testing in adults ofreproductive age, as an aid in newbornscreening, and in confirmatory diagnostictesting in newborns and children.The kit is not indicated for use in fetaldiagnostic or pre-implantation testing.This kit is also not indicated for stand-alone diagnostic purposes.Same as the predicate devicefor the ACMG/ACOG panel,but with no further mutationsbeyond the ACMG/ACOGpanel.
Gene mutation andvariant screeningThe Tag-It™ Cystic Fibrosis Kitsimultaneously screens for the 23 cysticfibrosis transmembrane conductanceregulator (CFTR) gene mutations, plus16 other mutations and 4 variants(polymorphisms) recommended by theAmerican College of Medical Genetics(ACMG) and American College ofObstetricians and Gynecologists (ACOG)The InPlex™ CF MolecularTest simultaneously screensfor the 23 cystic fibrosistransmembrane conductanceregulator (CFTR) genemutations and IVS8 variants(polymorphisms)recommended by theAmerican College of MedicalGenetics (ACMG) andAmerican College ofObstetricians andGynecologists (ACOG)

SUMMARY OF TECHNOLOGICAL CHARACTERISTICS:

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CharacteristicsTag-It™ Cystic Fibrosis KitInPlex™ CF Molecular Test
Technology:Genomic DNAsample preparationGenomic DNA Sample Preparation fromwhole bloodSame as the predicate device
Technology: Assayreactions(1)Multiplex PCR(2) Multiplex Allele Specific PrimerExtension (ASPE)(3) PCR samples are treated withenzymes (Alkaline Phosphatase(SAP) to inactivate any remainingnucleotides (especially dCTP), andwith Exonuclease I (EXO) to degradeany primers left over from the PCRreaction)(4) Multiplex allele-specific primerextension (ASPE) for genotyping(5)Hybridization using 5 $ μ $ L ASPE with45 $ μ $ L bead(1)Multiplex PCR(2)Amplified samples aremixed with enzyme(Cleavase®) and bufferand added to micro-fluidiccards(3)Invader® reactions occurwhereby twooligonucleotides (adiscriminatory PrimaryProbe and an Invader®oligonucleotide) hybridizein tandem to the targetDNA to form anoverlapping structure thatis subsequently cleaved byan enzyme (Cleavase®).
Data AnalysisAssay result data is analyzed by asoftware program which provides a finalgenotypeSame as the predicate device

PERFORMANCE DATA:

ANALYTICAL STUDIES

DNA Extraction Equivalency

Equivalency between four different DNA purification methodologies and their subsequent performance using the InPlex™ CF Molecular Test was evaluated using 7 CF positive genomic DNA samples isolated from whole peripheral blood. Internal processing involved the purification of the same 7 samples using four commonly used, commercially available DNA extraction kits. These samples were also genotyped by DNA sequencing to confirm results.

Genotype calls as generated by the InPlex™ CF Molecular Test were compared to DNA sequencing based genotyping for all extraction methods.

The seven CF positive genomic DNA samples extracted from human peripheral whole blood using four different DNA extraction kits generated a total of 644 calls with 28 positive and 616 normal (negative) calls. Each extraction method provided 161 data points. All calls were concordant with the DNA sequencing based genotyping, providing an overall agreement of 100% (99.5%, 1-sided lower 95% Confidence Limit).

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Fluorometer Equivalency

Equivalency between three multi-well fluorometers meeting indicated specifications in generating signal data from the InPlex™ CF Molecular Test micro-fluidic card was determined using a panel of eight genomic DNA (gDNA) samples. The genomic DNA samples were either positive for a subset of the CFTR mutations listed as part of the ACMG recommended panel or normal. The eight samples were tested in triplicate providing a minimum of 1,656 data points (8 samples x 23 assays x 3 replicates x 3 plate reader data).

All InPlex™ CF Molecular Test genotype results for the characterized gDNA samples described were concordant with DNA sequencing genotype results and in 100% (99.8% 1-sided lower 95% Confidence Limit) agreement regardless of the fluorometer used.

Incubator Equivalency

Three thermal incubators were evaluated for equivalency in generating concordant genotype data using the InPlex™ CF Molecular Test. A panel of eight gDNA samples was tested in triplicate using each incubator. A total of 1,656 data points (8 samples x 23 assays x 3 replicates x 3 incubators - 552 data points per incubator) were generated in this study. The percent agreement to known genotypes was 99.88% (99.74%, 1-sided 95% Confidence Limit).

Interfering Substances

The performance of the InPlex™ CF Molecular Test was evaluated using eight, CF positive, genomic DNA samples isolated from whole peripheral blood in the absence (untreated) and presence (treated) of potential interfering substances included compounds that are endogenous to the blood sample matrix, compounds associated with blood collection and those that may result from sample preparation solutions. Depending on the nature of the substance, compounds were added either directly to the blood sample or to purified genomic DNA. Compounds added to the blood sample included bilirubin, triglycerides, and potassium EDTA (blood collection anti-coagulant). Compounds added to the purified genomic DNA sample included Qiagen® Buffer AW2 and hemoglobin. Following DNA extraction, eight whole peripheral blood samples were each tested as treated and untreated samples. The number of samples provided 1,104 data points (8 blood samples x 23 assays x 6 treatments).

The InPlex™ CF Molecular Test detected a total of 23 CFTR mutations. The genotype calls for the DNA samples containing an interfering substance were compared to the untreated samples for calculation of percent agreement. The results of this study showed that the InPlex™ CF Molecular Test achieved a 100% agreement (99.7%, 1-sided lower 95% Confidence Limit)

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between the genotypes of the samples containing potential interfering substances and bidirectional sequencing.

Limit of Detection

An input genomic DNA concentration range was evaluated with the InPlex™ CF Molecular Test. A panel of eight gDNA samples were prepared and tested at eight concentrations ranging from 1ng/uL to 150ng/uL (total input DNA range of 5-750ng / reaction). The number of samples analyzed provided 1,472 data points (8 samples x 8 concentrations x 23 assays). One hundred and eighty four genotype calls were generated per DNA concentration tested (8 samples x 1 concentration x 23 assays).

Genotype call results for all eight characterized samples were assessed for percent agreement at each concentration. The lower limit of detection was defined as the lowest DNA concentration in which a 99% or greater concordance with DNA sequencing was observed.

Based on these results, a 5ng/μL DNA concentration (input DNA of 25ng) provided a percent agreement of 100% (98.4%, 1-sided lower 95% Confidence Limit) with DNA sequencing qualifying it as the lower limit of detection. At the highest DNA concentration tested, 150ng/uL (input DNA of 750ng), a 99.5% percent agreement was obtained (98.6%, 1 sided lower 95% Confidence Limit). The remaining DNA concentrations tested, 10, 20, 50, and 100ng/ul (input DNA of 50, 100, 250 and 500ng) all obtained a 100 percent agreement (98.4%, 1-sided lower 95% Confidence Limit) with expected results (see Table 3).

Table 3. Percent Agreement for Each DNA Concentration
DNAConcentration(ng/µL)# ofConcordantCalls# of LowSignalCalls# ofEquivocalCallsTotal #of CallsPercentAgreement1 sided lower95% CI
114827918480.40%75.6%
21784218496.80%94.6%
518400184100.00%98.4%
1018400184100.00%98.4%
2018400184100.00%98.4%
5018400184100.00%98.4%
10018400184100.00%98.4%
1501830118499.50%98.6%

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Lot-to-Lot Equivalency

Equivalency between three lots of InPlex™ CF Molecular Test kits was evaluated. A panel of 23 CFTR gDNA samples was tested in singlicate with each lot. Five hundred twenty-nine (529) genotype calls were generated for each lot tested (23 samples x 23 assays). All genotype calls were in 100% (99.4% 1-sided lower 95% Confidence Limit) agreement to pre-characterized gDNA genotypes for each lot tested.

Accuracy and Repeat Rate

Accuracy and repeat rate of the InPlex™ CF Molecular Test was determined by comparing InPlex™ CF Molecular Test genotyping results from of a panel of unique genomic DNA samples to bi-directional DNA sequence analysis. The sample panel tested consisted of genomic DNA samples isolated from peripheral whole blood and cell lines. A total of 23 CFTR mutations (as well as the IVS8-5T/7T/9T variants) were tested in this study. Genotype calls were compared between the DNA sequencing results and the InPlex™ CF Molecular Test results for the calculation of overall agreement. In addition, positive and negative agreement for each mutation was calculated. The repeat rate was determined by the number of samples that generated an invalid genotype call for one or more mutations with the InPlex™ CF Molecular Test on the first attempt.

This study was performed on a total of 123 unique samples containing 144 positive CFTR calls and 2808 normal (negative) CFTR calls.

The results of this study showed that the InPlex™ CF Molecular Test achieved 99.96% (2951/2952) overall agreement (99.9%, 1-sided lower 95% Confidence Limit), 100% (144/144) positive agreement (97.9%, 1-sided lower 95% Confidence Limit), and 99.96% (2807/2808) negative agreement (99.9%, 1-sided lower 95% Confidence Limit). There was one "Invalid" call out of 123 tests, resulting in a repeat rate of 0.8%. This overall agreement of 99.96% is derived without repeat testing. No repeat testing was done to support this study.

Of the 123 unique samples in the initial study, four (4) samples (negative for R117H) were confirmed by sequencing as 77/9T, but miscalled as 7T/7T by the InPlex™ CF Molecular Test. The four miscalled samples were tested in a reproducibility study once a day for 5 days in conjunction with two 7T/7T and two 7T/9T samples, which were called correctly in the initial study. Upon retesting all four (4) miscalled samples gave the correct 7T/9T result on each of the five consecutive days. The root cause of the miscalls was determined to potentially be due to the InPlex cards failing to be rotated during incubation resulting in temperature inconsistencies

InPlex™ CF Molecular Test 510(k) Submission .

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(e.g., hot spots) near the heat source causing the 9T/7T ratio to fall below the cut-off for the 9T/7T call. The 7T/7T miscall was reproduced in one of the four samples experimentally.

Freeze-Thaw Tolerance

A study was performed to establish the tolerance of the InPlex™ CF Molecular Test to various freeze-thaw cycles. The InPlex™ CF Molecular Test kit were subjected to 2, 4, 6, 8, 10 and 12 freeze-thaw cycles (test points) followed by functional testing of the product with control samples. Each freeze-thaw cycle consisted of freezing at -20°C±3°C for at least 24 hours and thawing at room temperature for 30 minutes. For the multiple freeze-thaw cycles the cards were returned to -20°C±3 °C storage after 30 minutes at room temperature.

This study used a panel of 23 CFTR gDNA samples to evaluate the 23 CFTR mutations at each freeze thaw cycle. The samples generated 3,703 data points (23 samples x 23 assays x 7 test points). Each Freeze-Thaw cycle generated 529 data points (23 samples x 23 assays).

The InPlex™ CF Molecular Test achieved an overall percent agreement of 100% (99.92%, 1sided lower 95% Confidence Limit) as compared to DNA sequencing for all freeze-thaw cycles tested. See Table 4 below.

Table 4. Percent Agreement for Each Freeze-Thaw Period
Freeze-ThawCycleConcordant CallsTotal # of CallsPercentAgreement1-sided lower95% CI
0529529100%99.4%
2529529100%99.4%
4529529100%99.4%
6529529100%99.4%
8529529100%99.4%
10529529100%99.4%
12529529100%99.4%
Total3,7033,703100%99.92%

Eight or fewer freeze-thaw cycles for the InPlex™ Molecular Test are recommended to ensure the InPlex™ CF Molecular Test maintains the ability to generate accurate genotype calls.

Real-Time Stability

A study was performed with the objective to establish the stability of the InPlex™ CF Molecular Test when stored under pre-defined storage conditions.

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Three lots of the InPlex™ micro-fluidic cards and three lots of InPlex™ reagents were used to create three master lots of the InPlex™ CF Molecular Test used in this study. A panel of seven CFTR gDNA samples and a panel of eight control samples comprised of pooled amplicons that cover the mutations in the InPlex™ CF Molecular Test were used to assess the performance. The samples were tested in duplicate with each lot for each storage condition at each time point.

Three lots of the InPlex™ Reagents are being maintained at the recommended storage temperature of (-20°C +/-3°C). The InPlex™ micro-fluidic cards are stored at the recommended temperature (-20°C +/-3°C), substandard temperature (4°C -- 8°C), and ship-stressed conditions (37°C±1°C for 48 hours, then room temperature (25°C+/-3°C).

A total of 345 calls were evaluated (15 samples x 23 assays) for each lot tested. All lots met the passing criterion for the Real-Time Stability performance evaluation study with an observed percent agreement of 100% (99.1%, 1-sided lower 95% Confidence Limit) (see Table 5).

Table 5: Percent Agreement for Each Lot at Each Storage Condition
TimepointStorage ConditionMaster Lot# ofConcordantCallsTotal # of CallsPercentAgreement1-sidedlower 95%CI
T=0NAC04AC345345100%99.1%
T=0NAC05AA345345100%99.1%
T=0NAC06AA345345100%99.1%
T=1-20°C±3°CC04AC345345100%99.1%
C05AA345345100%99.1%
C06AA345345100%99.1%
T=14-8°CC04AC345345100%99.1%
C05AA345345100%99.1%
C06AA345345100%99.1%
T=137°C±1°C for 48hours,then hold at roomtempC04AC345345100%99.1%
C05AA345345100%99.1%
C06AA345345100%99.1%

This study showed that multiple lots of the InPlex™ CF Molecular Test produce equivalent results after storage for one month under the conditions tested. This is an ongoing study for which the results from future time points will be used to extend shelf-life dating.

Reproducibility Study

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Samples from pre-characterized commercially available reference materials were used to assess the reproducibility of the InPlex™ CF Molecular Test. The study was conducted in two main phases, a proficiency phase, and a performance phase. The purpose of the proficiency phase was to ensure that each site had the required expertise in the fundamental methodologies so that meaningful assay reproducibility measures could be calculated from the data generated during the performance phase. The proficiency phase was carried out in two steps, one for the training on the product methodology, and one for the confirmation of proficiency. Proficiency testing was performed using eight (8) pre-characterized, gDNA samples. Technicians at each of three investigative sites ran the same DNA samples in duplicate. Data generated during this phase of the study was to demonstrate technician proficiency only and not used to demonstrate the clinical performance of the test.

The reproducibility testing for the performance phase was conducted using 23 samples containing mutations representing the ACMG recommended panel. Each site ran the same samples tested in duplicate by each technician, with tests being run on each of five (5) nonconsecutive days. There were two technicians at each test site.

Percent agreement ranged from 99.962% to 100% at each of the three sites and 99.987% to 99.994% across all sites. Out of 31,740 calls generated (23 [samples] x 23 [assays] x 2 [replicates] x 2 [operators] x 5 [days] x 3 [sites]), the within operator agreement for two calls at one site vielded an equivocal result for both replicates of a single mutation. The overall accuracy rate was 31,738/31,740 = 99.994% (99.986, 1-sided lower 95% Confidence Limit).

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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 consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" around the perimeter. Inside the circle is a stylized image of a human figure embracing a globe, symbolizing the department's mission to protect the health of all Americans and provide essential human services.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

MAR 1 3 2008

Third Wave Technologies, Inc. c/o Andrew A. Lukowiak, Ph.D. Associate Vice President of Product Development 502 S. Rosa Road. Madison, WI 53719-1256

Re: K063787

Trade/Device Name: InPlex™ CF Molecular Test Regulation Number: 21 CFR 866.5900 Regulation Name: Cystic fibrosis transmembrane conductance regulator (CFTR) gene mutation detection system Regulatory Class: Class II Product Code: NUA Dated: March 7, 2008 Received: March 10, 2008

Dear Dr. Lukowiak:

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 the Code of Federal Regulations, Title 21, Parts 800 to 898. 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 Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820). This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The

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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" (21 CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely vours.

Rola Becker

Robert L. Becker, Jr., M.D., Ph.D. Director Division of Immunology and Hematology Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

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INDICATIONS FOR USE STATEMENT

510(k) Number (if known): K063787

Device Name: InPlex™ CF Molecular Test

Indications For Use:

InPlex™ CF Molecular Test is an in vitro diagnostic device used to simultaneously detect and identify a panel of mutations and variants in the cystic fibrosis transmembrane regulator (CFTR) gene in genomic DNA samples isolated from human peripheral whole blood specimens. The panel includes mutations and variants recommended by the 2004 American College of Medical Genetics (ACMG), plus other more common and North American-prevalent mutations. The InPlex™ CF Molecular Test is a qualitative genotyping test that provides information intended to be used for cystic fibrosis carrier screening as recommended by ACMG and the 2005 American College of Obstetricians and Gynecologists (ACOG) for adults of reproductive age, as an aid in newborn screening for cystic fibrosis, and in confirmatory diagnostic testing for cystic fibrosis in newborns and children.

The test is not indicated for use in fetal diagnostic or pre-implantation testing. This test is also not indicated for stand-alone diagnostic purposes and results should be used in conjunction with other available laboratory and clinical information.

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Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use

OR

Over-The-Counter Use

(Per 21 CFR 801.109)

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(Optional Format 1-2-96)

Division Sign-01

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Office of In Vitro Diagn Device Evaluation and

510(k) K063787

§ 866.5900 Cystic fibrosis transmembrane conductance regulator (CFTR) gene mutation detection system.

(a)
Identification. The CFTR gene mutation detection system is a device used to simultaneously detect and identify a panel of mutations and variants in the CFTR gene. It is intended as an aid in confirmatory diagnostic testing of individuals with suspected cystic fibrosis (CF), carrier identification, and newborn screening. This device is not intended for stand-alone diagnostic purposes, prenatal diagnostic, pre-implantation, or population screening.(b)
Classification. Class II (special controls). The special control is FDA's guidance document entitled “Class II Special Controls Guidance Document: CFTR Gene Mutation Detection System.” See § 866.1(e) for the availability of this guidance document.