K Number
K173857
Manufacturer
Date Cleared
2018-11-06

(321 days)

Product Code
Regulation Number
862.1678
Reference & Predicate Devices
N/A
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Immunoassay for the in vitro quantitative determination of tacrolimus in EDTA human whole blood. The assay is used as an aid in the management of liver and kidney transplant patients receiving tacrolimus therapy.

The electrochemiluminescence immunoassay "ECLIA" is intended for use on cobas e immunoassay analyzers.

Device Description

The Elecsys Tacrolimus immunoassay uses the principle of electrochemiluminescence for detection and measurement. Before testing with the Elecsys Tacrolimus assay, the specimen, calibrators and controls are pretreated with the Elecsys ISD Pretreatment Reagent. The reagent lyses the cells, extracts Tacrolimus and precipitates virtually all of the blood proteins. The pretreated samples are centrifuged, and an aliquot of the resulting supernatant containing Tacrolimus is then assayed using the Elecsys Tacrolimus assay.

Results are determined via a calibration curve which is instrument-specifically generated by 2-point calibration and a master curve provided via the reagent barcode.

AI/ML Overview

This document describes the Elecsys Tacrolimus immunoassay, an in vitro quantitative determination of tacrolimus in EDTA human whole blood. The assay is used as an aid in the management of liver and kidney transplant patients receiving tacrolimus therapy. It is intended for use on Elecsys and cobas e immunoassay analyzers.

Here's a breakdown of the acceptance criteria and study information:

1. Table of Acceptance Criteria and Reported Device Performance

Performance CharacteristicAcceptance CriteriaReported Device Performance
PrecisionRepeatability:cobas e 411 (Intermediate precision):
(cobas e 411)LoQ – 3.5 ng/mL: SD ≤ 0.25 ng/mLHSP 1 (1.28 ng/mL): SD=0.182, CV=14.2% (for reference, this is an intermediate precision pool)
> 3.5 – 12 ng/mL: CV ≤ 5 %HSP 2 (9.14 ng/mL): SD=0.513, CV=5.6%
> 12 – 30 ng/mL: CV ≤ 6 %HSP 3 (18.5 ng/mL): SD=0.600, CV=3.3%
Intermediate Precision:HSP 4 (27.07 ng/mL): SD=0.882, CV=3.3%
LoQ – 3.5 ng/mL: SD ≤ 0.35 ng/mLPC ISD1 (2.49 ng/mL): SD=0.213, CV=8.6%
> 3.5 – 12 ng/mL: CV ≤ 6 %PC ISD2 (10.2 ng/mL): SD=0.383, CV=3.7%
> 12 – 30 ng/mL: CV ≤ 7 %PC ISD 3 (19.6 ng/mL): SD=0.571, CV=2.9%
Clinical Reproducibility:All results met pre-defined acceptance criteria for repeatability and intermediate precision.
UCL of SD (1-sided 95%) and % CV values are provided across different components (repeatability, between day, between lot, between site, system reproducibility) for various sample pools and controls. Specific criteria not explicitly stated in one place but values are provided.See Table 2 on page 19 for detailed reproducibility results.
Analytical Sensitivity:Limit of Blank (LoB): ≤ 0.3 ng/mLLoB: 0.3 ng/mL
Limit of Detection (LoD): ≤ 0.5 ng/mLLoD: 0.5 ng/mL
Limit of Quantitation (LoQ): 25% total error at LoQ ≤ 0.75 ng/mLLoQ: 0.75 ng/mL
Recovery (Accuracy)≤ ± 0.3 ng/mL for samples LoQ to 3 ng/mLRecovery (accuracy) meets the specifications.
± 10 % for samples > 3 ng/mL
Linearity< ± 0.2 ng/mL for samples LoQ to 2 ng/mLConfirmed in the range from 0.75 to 30 ng/mL.
± 10 % for samples > 2 ng/mL
Analytical SpecificityNot explicitly stated but implied by cross-reactivity testing.Provides cross-reactivity percentages for various metabolites (M I-M VIII). See Table on page 9.
Endogenous InterferencesLoQ to < 3.0 ng/mL must be < ± 0.3 ng/mL absolute deviationNot explicitly stated as "met" but effects of various substances are described.
> 3 to 30 ng/mL must be ≤ ± 10 % recovery to the reference
Exogenous Interferences (Drugs)Recovery within ± 10 % of initial value.All drugs met the criterion except Itraconazole at 10 ug/mL (114% recovery).
Biotin Interference≤ 10% bias in results for biotin concentrations up to 100 ng/mLAt 100 ng/mL biotin, bias was +5.1% (for 2.28 ng/mL tacrolimus) and +1.8% (for 18.1 ng/mL tacrolimus). Higher concentrations showed significantly higher bias.
Reagent StabilityShelf Life Stability:All results met acceptance criteria.
PreciControl ISD 1: 75 – 125% recovery of reference value
PreciControl ISD 2 and 3: 80 – 120% recovery of reference value
Sample StabilityPercent recovery calculated based on reference T0 (fresh sample) values.Data collected in-house supported short stability claims. Literature supported 1-month stability claim.
Method Comparisonvs. Abbott ARCHITECT Tacrolimus: Combined slope (95% CI) and correlation (r) provided.Combined: Slope = 0.99 (0.98, 1.01), Intercept = 0.06 (-0.07, 0.18), r = 0.99
vs. LC-MS/MS: Combined slope (95% CI) and correlation (r) provided.Combined: Slope = 0.92 (0.90, 0.95), Intercept = -0.01(-0.16, 0.14), r = 0.96

2. Sample Size Used for the Test Set and Data Provenance

  • Precision (Non-clinical):
    • Seven-member panel (four pooled patient and single donor spiked human whole blood samples, three controls).
    • Measured in single determination in four separate aliquots (divided in two runs per day) for 21 operating days. The number of samples for the test set is not explicitly stated as a single number but implies repeated measurements over time.
    • Data provenance: Not explicitly stated, but "pooled patient and single donor spiked human whole blood samples" suggests human biological samples.
  • Limit of Blank (LoB):
    • Five analyte-free whole blood samples.
    • 30 measuring points collected per instrument, for a total of 60 measured values (across two instruments).
  • Limit of Detection (LoD):
    • Five spiked human whole blood samples with low analyte.
    • 30 measuring points collected per instrument, for a total of 60 measured values (across two instruments).
  • Limit of Quantitation (LoQ):
    • 14 spiked human whole blood samples each diluted to concentrations covering the range between LoB and 2x LoQ.
    • 84 measuring points collected per instrument, for a total of 168 measured values per lot (across two instruments and three reagent lots).
  • Recovery (Accuracy):
    • ISD-free human blood spiked with tacrolimus.
    • Patient derived samples (from patients taking Tacrolimus) divided into at least four aliquots and spiked. The exact number of patient samples is not specified.
  • Linearity:
    • Three dilution series prepared from three different spiked human whole blood samples.
    • Each dilution series included 22 dilutions.
  • Dilution:
    • Three ISD-free human whole blood samples spiked separately.
    • Dilution series of nine respective dilutions.
  • Analytical Specificity (Cross-reactivity):
    • Each cross-reactant compound spiked into two human whole blood samples (analyte-free and slightly elevated analyte level). Sample size for each cross-reactant is therefore 2 samples per compound.
  • Endogenous Interferences:
    • Three spiked human whole blood samples (one low and one high concentration).
    • Dilution series of 10 dilutions.
  • Exogenous Interferences (Drugs):
    • 16 common and 25 additional pharmaceutical compounds spiked into two spiked human tacrolimus containing human whole blood samples (single donor samples spiked with 3 ng/mL and 10 ng/mL tacrolimus). So, 2 samples per drug.
  • Reagent Stability:
    • Study 1 & 2: Five human whole blood samples (pooled patient samples and single donor samples spiked with tacrolimus) and three controls.
    • Study 3: PreciControl ISD 1, 2, and 3.
  • Sample Stability:
    • Not explicitly stated, but the studies mention "human EDTA blood" and "reference T0 (fresh sample) values."
  • Reproducibility (Clinical):
    • Human sample pools (HSP 01-06) and PreciControl materials (PC ISD L1-L3).
    • N=90 for each sample type. Data provenance: Human samples.
  • Method Comparison (Clinical):
    • Abbott ARCHITECT Tacrolimus vs. Elecsys Tacrolimus: Combined 553 samples (346 Kidney, 207 Liver).
    • Elecsys Tacrolimus vs. LC-MS/MS: Combined 554 samples (344 Kidney, 210 Liver).
    • Data provenance: Clinical test results for enrolled subjects. No country of origin is specified.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

This document describes the validation of an in vitro diagnostic assay for quantitative determination of tacrolimus. There is no mention of human experts (e.g., radiologists) establishing ground truth. The ground truth is established by reference methods or gravimetric preparation of known concentrations.

4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

Not applicable, as this is an in vitro diagnostic device and not a diagnostic imaging device requiring expert adjudication.

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

Not applicable. This is an in vitro diagnostic immunoassay, not an AI-driven imaging analysis system involving human readers.

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

The entire performance evaluation described is for the standalone device (Elecsys Tacrolimus immunoassay) without human-in-the-loop performance influencing the assay results. The device quantifies tacrolimus levels; human intervention is for sample preparation, loading, and interpretation of the quantitative result in a clinical context.

7. The Type of Ground Truth Used

The ground truth for the performance studies is established using:

  • Gravimetrically prepared reference material: For spiking studies (recovery, linearity, dilution, exogenous/endogenous interferences).
  • Reference Methods:
    • Abbott ARCHITECT Tacrolimus (a legally marketed predicate device) for method comparison studies.
    • LC-MS/MS (Liquid Chromatography-Mass Spectrometry/Mass Spectrometry) for method comparison studies, which is considered a gold standard for tacrolimus quantification.
  • Assigned values for controls: For stability and reproducibility studies (e.g., PreciControl ISD).
  • Analyte-free whole blood samples: For LoB determination.

8. The Sample Size for the Training Set

This document describes a premarket notification for an in vitro diagnostic device, not a machine learning or AI algorithm. Therefore, the concept of a "training set" in the context of AI models does not apply here. The document details studies designed to validate the assay's performance characteristics.

9. How the Ground Truth for the Training Set was Established

Not applicable, as there is no "training set" in the context of an AI algorithm for this in vitro diagnostic device.

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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

November 6, 2018

Roche Diagnostics Khoa Tran Regulatory Affairs Principal 9115 Hague Road Indianapolis, IN 46250

Re: K173857

Trade/Device Name: Elecsys Tacrolimus Regulation Number: 21 CFR 862.1678 Regulation Name: Tacrolimus test system Regulatory Class: Class II Product Code: MLM Dated: October 23, 2018 Received: October 24, 2018

Dear Khoa Tran:

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 mav, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be avare that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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

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requirements, including, but not limited to: registration and listing (21 CFR Part 801 and Part 809); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.htm); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Kellie B. Kelm -S

for Courtney H. Lias, Ph.D. Director Division of Chemistry and Toxicology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K173857

Device Name Elecsys Tacrolimus

Indications for Use (Describe)

Immunoassay for the in vitro quantitative determination of tacrolimus in EDTA human whole blood. The assay is used as an aid in the management of liver and kidney transplant patients receiving tacrolimus therapy.

The electrochemiluminescence immunoassay "ECLIA" is intended for use on cobas e immunoassay analyzers.

Type of Use (Select one or both, as applicable)
☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

K173857

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92.

Submitter NameRoche Diagnostics
Address9115 Hague RoadIndianapolis, IN, 46250
ContactKhoa TranPhone: (317) -521-3409FAX: (317) 521-2324Email: khoa.tran@roche.com
Date PreparedNovember 5th, 2018
Proprietary NameElecsys Tacrolimus
Common NameTacrolimus assay
Classification NameTacrolimus Test System
Product CodesMLM, 21 CFR 862.1678
Predicate DevicesAbbott ARCHITECT Tacrolimus Assay K070820
Establishment RegistrationRoche Diagnostics GmbH in Mannheim, Germany, is 9610126
Roche Diagnostics GmbH in Penzberg, Germany, is 9610529
Roche Diagnostics in the United States is 1823260

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1. DEVICE DESCRIPTION

The Elecsys Tacrolimus immunoassay uses the principle of electrochemiluminescence for detection and measurement. Before testing with the Elecsys Tacrolimus assay, the specimen, calibrators and controls are pretreated with the Elecsys ISD Pretreatment Reagent. The reagent lyses the cells, extracts Tacrolimus and precipitates virtually all of the blood proteins. The pretreated samples are centrifuged, and an aliquot of the resulting supernatant containing Tacrolimus is then assayed using the Elecsys Tacrolimus assay.

Results are determined via a calibration curve which is instrument-specifically generated by 2-point calibration and a master curve provided via the reagent barcode.

1.1. Reagents

The reagent working solution includes:

  • M Streptavidin-coated microparticles (transparent cap), 1 bottle, 6.5 mL: . Streptavidin-coated microparticles 0.72 mg/mL; preservative
  • R1 Anti-Tacrolimus-S-Ab~biotin (gray cap), 1 bottle, 10 mL: . Biotinylated monoclonal anti-tacrolimus-antibody (sheep) 15 ug/L: phosphate buffer 100 mmo1/L, pH 7.8; preservative
  • R2 Tacrolimus~Ru(bpy) (black cap), 1 bottle, 8 mL: Tacrolimus-derivative labeled . with ruthenium complex 4 µg /L; citrate buffer 10 mmol/L, pH 3.3; preservative

ISD Sample Pretreatment reagent 1.2.

ISD Sample Pretreatment is labeled as ISD Sample PT and it includes:

  • . 1 bottle containing 30 mL
    Contents: zinc sulfate solution in methanol and ethylene glycol

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2. INDICATIONS FOR USE

Immunoassay for the in vitro quantitative determination of tacrolimus in EDTA human whole blood. The assay is used as an aid in the management of liver and kidney transplant patients receiving tacrolimus therapy.

The electrochemiluminescence immunoassay “ECLIA” is intended for use on Elecsys and cobas e immunoassay analyzers.

TECHNOLOGICAL CHARACTERISTICS 3.

Assay Comparison
FeaturePredicate Device:Abbott ARCHITECT Tacrolimus (K070820)Candidate Device:Elecsys Tacrolimus
General Assay Features
Intended Use/Indications forUseThe ARCHITECT Tacrolimus assay is achemiluminescent microparticle immunoassay(CMIA) for the quantitative determination oftacrolimus in human whole blood on theARCHITECT i System. The ARCHITECTTacrolimus assay is to be used as an aid in themanagement of liver and kidney allograft patientsreceiving tacrolimus therapyImmunoassay for the in vitro quantitativedetermination of tacrolimus in human wholeblood. The assay is used as an aid in themanagement of liver and kidney transplantpatients receiving tacrolimus therapy.The electrochemiluminescence immunoassay"ECLIA" is intended for use on Elecsys andcobas e immunoassay analyzers.
Test PrincipleThe ARCHITECT Tacrolimus assay is a delayedone-step immunoassay for the quantitativedetermination of tacrolimus in human wholeblood using CMIA technology with flexible assayprotocols, referred to as Chemiflex. Prior to theinitiation of the automated ARCHITECTsequence, a manual pretreatment step isperformed in which the whole blood sample isextracted with a precipitation reagent andcentrifuged. The supernatant is decanted into aTransplant Pretreatment Tube, which is placedonto the ARCHITECT System Sample, assaydiluent, and anti-tacrolimus coated paramagneticmicroparticles are combined to create a reactionmixture. Tacrolimus present in the sample bindsto the anti-tacrolimus coated microparticles. Aftera delay, tacrolimus acridinium-labeled conjugateis added to the reaction mixture. The tacrolimuson the acridinium-labeled conjugate competes forthe available binding sites on the microparticles.Following incubation, the microparticles areThe Elecsys Tacrolimus immunoassay uses theprinciple of electrochemiluminescence fordetection and measurement. Before testing withthe Elecsys Tacrolimus assay, the specimen,calibrators and controls are pretreated with theElecsys ISD Pretreatment Reagent. The reagentlyses the cells, extracts Tacrolimus andprecipitates most of the blood proteins. Thepretreated samples are centrifuged, and an aliquotof the resulting supernatant containingTacrolimus is then assayed using the ElecsysTacrolimus reagent.Competition principle. Total duration of assay:18 minutes.1st incubation: 35 $ μ $ L of pretreated sample isincubated with a Tacrolimus-specificbiotinylated antibody and a rutheniumcomplex (Tris(2,2'-bipyridyl)ruthenium(II)-complex (Ru(bpy) ) labeled Tacrolimus-derivative. Depending on the concentrationof the analyte in the sample and the

Table 1: Assay Comparison

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Assay Comparison
FeaturePredicate Device:Abbott ARCHITECT Tacrolimus (K070820)Candidate Device:Elecsys Tacrolimus
added to the reaction mixture. The resultingchemiluminescent reaction is measured asrelative light units (RLUs). An indirectrelationship exists between the amount oftacrolimus in the sample and the RLUs detectedby the ARCHITECT' System optics.formation of the respective immunecomplex, the labeled antibody binding siteis occupied in part with sample analyte andin part with ruthenylated hapten 2nd incubation: After addition ofstreptavidin-coated microparticles the entirecomplex becomes bound to the solid phasevia interaction of biotin and streptavidin.
Assay Comparison
FeaturePredicate Device:Abbott ARCHITECT Tacrolimus (K070820)Candidate Device:Elecsys Tacrolimus
The reaction mixture is aspirated into themeasuring cell where the microparticles aremagnetically captured onto the surface ofthe electrode. Application of a voltage to theelectrode then induces chemiluminescentemission which is measured by aphotomultiplier.Results are determined via a calibration curvewhich is instrument-specifically generated by2-point calibration and a master curve providedvia the reagent barcode.
Sample MatrixHuman Whole BloodSame
SamplePreparationManual PretreatmentSame
ReagentLiquid Ready-to-Use (Antibody coatimicroparticle reagent, Tacrolimus conjugatereagent, and Assay diluent)Liquid Ready-to-Use (Streptavidin-coatedmicroparticle reagent, biotinylated anti-Tacrolimus antibody reagent, tacrolimusconjugated reagent).
Assay Range2.0 to 30.0 ng/mL0.75 to 30.0 ng/mL
DetectionProtocolChemiluminescent Microparticle immunoassay(CMIA)Electrochemiluminescent Immunoassay (ECLIA)
ApplicationsDid not specified18-minute application
InstrumentPlatformARCHITECT i Systemcobas e 411
Sample TypeHuman Whole BloodSame
ReagentsCompetition principleCompetition principle.Total duration of assay: 18 minutes
CalibrationIntervalOnce an ARCHITECT Tacrolimus calibration isaccepted and stored, all subsequent samples maybe tested without further calibration unless:A reagent kit with a new lot number is used.Controls are out of range.Calibration must be performed once per reagentlot using fresh reagent (i.e. not more than24 hours since the reagent kit was registered onthe analyzer). Renewed calibration isrecommended as follows:After 1 month (28 days) when using thesame reagent lot.After 7 days (when using the same reagentkit on the analyzer).As required: e.g. quality control findingsoutside the defined limits
Traceability /StandardizationThe ARCHITECT Tacrolimus Calibrators aretraceable to an internal reference standardgravimetrically prepared and confirmed viaHPLC. Calibrators' values must be within ±1 %of the reference calibrator value.This method has been standardized againstreference standards traceable to tacrolimusreference material (USP = United StatesPharmacopeia) by weight.

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Assay Comparison
FeaturePredicate Device:Abbott ARCHITECT Tacrolimus (K070820)Candidate Device:Elecsys Tacrolimus
ReagentStabilityUnopened: 2-8°C - Up to the stated expiration date.After Opening at 2-8°C - 30 daysOn the Analyzers – 30 daysUnopened: 2-8°C - Up to the stated expiration date.After Opening at 2-8°C - 84 daysOn the Analyzers – 56 days
MeasuringRange2 -30 ng/mL0.75 - 30 ng/mL
PrecisionWithin-run (results from two instruments)cobas e 411:Within-run (will be labeled Intermediate precision)
Sample Mean (ng/mL) SD CV (%) Level 1Instrument 1 3.0 0.1 3.7 Instrument 2 2.9 0.2 5.8 Level 2Instrument 1 7.8 0.2 2.4 Instrument 2 8.5 0.2 2.7 Level 3Instrument 1 14.5 0.4 2.5 Instrument 2 15.7 0.5 2.9 Panel 1Instrument 1 5.5 0.2 3.6 Instrument 2 5.9 0.2 4.0 Panel 2Instrument 1 14.0 0.5 3.5 Instrument 2 15.3 0.6 4.1 Panel 3Instrument 1 4.8 0.2 4.4 Instrument 2 4.9 0.2 5.0 Panel 4Instrument 1 10.1 0.2 2.4 Instrument 2 11.2 0.5 4.1 Panel 5Instrument 1 21.2 0.7 3.3 Instrument 2 22.4 0.8 3.6Sample Mean (ng/mL) SD CV (%) HSP 1 1.28 0.182 14.2 HSP 2 9.14 0.513 5.6 HSP 3 18.5 0.600 3.3 HPS 4 27.07 0.882 3.3 PC ISD1 2.49 0.213 8.6 PC ISD2 10.2 0.383 3.7 PC ISD 3 19.6 0.571 2.9 HSP = Human Sample PoolPC = PreciControl
Abbott Immunosuppressant-MCC (levels 1, 2 and 3) and five whole blood panels were assayed, using two lots of reagents, on two instruments, in replicates of two at two separate times per day for 20 days.
AnalyticalSensitivityLimit of detection ≤ 1.5 ng/mLLimit of Blank (LoB): = 0.3 ng/mLLimit of Detection (LoD): = 0.5 ng/mLLimit of Quantitation (LoQ): = 0.75 ng/mL

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Assay Comparison
FeatureAbbott ARCHITECT Tacrolimus (K070820)Predicate Device:Candidate Device:Elecsys Tacrolimus
AnalyticalSpecificityCross reactant(Metabolite)M IAmount Added(ng/mL)10% Cross-reactivity8Cross reactant(Metabolite)MaximumConcentrationof MetaboliteAdded (ng/mL)% Cross-reactivity
(13-O-demethyl)M II1094M I(13-O-demethyl)50l
(31-O-demethyl)M III1045M II(31-O-demethyl)5071
(15-O-demethyl)M IV(12-O-hydroxy)109M III(15-O-demethyl)503
M VN/AN/A*M IV(12-O-hydroxy)50l
M VIN/A*N/A*M V6.652
M VIIN/A*N/A*M VI50l
M IIIN/A*N/A*M VII500
*Not availableM VIII504
Linearity2 to 30 ng/mL0.75-30 ng/mL
LimitationsThe assay is unaffected by:Albumin 12 mg/dL●Bilirubin ≤ 40.0 mg/dL●Cholesterol 500 mg/dLHAMA 215 ng/mL●Triglycerides 800 mg/dLUric Acid 20 mg/dLHematocrit ≤ 25%, ≥ 55 %Rheumatoid Factor 245 IUThe assay is unaffected by:Albumin ≤ 12.0 g/dL●●HASA < 10 µg/mL●Hematocrit 25- 60 %●●Uric acid ≤ 30 mg/dL●observed.and other findings.Bilirubin ≤ 66.0 mg/dLCholesterol ≤ 500 mg/dLHuman IgG ≤ 12 g/dLIntralipid ≤ 2000 mg/dLRheumatoid factors up to 1200 IU/mLIn vitro tests were performed on 16 commonlyused pharmaceuticals and 25 special drugs.No significant interference with the assay wasIn rare cases, interference due to extremely hightiters of antibodies to analyte-specific antibodies,streptavidin or ruthenium can occur. Theseeffects are minimized by suitable test design.For diagnostic purposes, the results shouldalways be assessed in conjunction with thepatient's medical history, clinical examinationFor Itraconazole and biotin interference, seeSections 5.10 and 5.11 respectively.

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Assay Comparison
FeaturePredicate Device:Abbott ARCHITECT Tacrolimus (K070820)Candidate Device:Elecsys Tacrolimus
Labeled Performance Characteristics
MethodComparisonElecsys Tacrolimus vs. Abbott ARCHITECT Tacrolimus
n = 553Weighted Deming Regression
Slope (95% CI)0.99 (0.98, 1.01)
Intercept (95% CI)0.06 (-0.07, 0.18)
r0.99
Elecsys Tacrolimus vs. LC-MS/MS
n = 554Weighted Deming Regression
Slope (95% CI)0.92 (0.90, 0.95)
Intercept (95% CI)-0.01(-0.16, 0.14)
r0.96

4. TECHNOLOGICAL CHARACTERISTICS

The assay employs a competitive principle using electrochemiluminescence technology.

5. NON-CLINICAL PERFORMANCE EVALUATION

5.1. Precision

Non-clinical performance evaluations for the Elecsys Tacrolimus executed with the study briefly summarized.

Precision of the Tacrolimus assay was evaluated on the cobas e 411 analyzer. Within-run precision (repeatability) and total imprecision (intermediate precision) were determined according to the CLSI EP5-A2 precision evaluation experiment.

A seven-member panel consisting of four pooled patient and single donor spiked human whole blood samples and three controls (PreciControl ISD Level 1, 2 and 3) were measured. The protocol consisted of testing the samples in single determination in four separate aliquots (divided in two runs per day) for 21 operating days. The measurements were performed on the

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cobas e 411 with one reagent lot, performing rack pack calibration according to instruction for use.

RepeatabilityIntermediate Precision
LoQ — 3.5 ng/mLSD ≤ 0.25 ng/mLSD ≤ 0.35 ng/mL
> 3.5 – 12 ng/mLCV ≤ 5 %CV ≤ 6 %
> 12 – 30 ng/mLCV ≤ 6 %CV ≤ 7 %

5.1.1. -Specifications

All results met the pre-defined acceptance criteria for repeatability and intermediate precision.

Limit of Blank (LoB) 5.2.

LoB of the Tacrolimus assay has been determined according to CLSI EP17-A2. The Limit of Blank was determined as the 95th percentile of the measurement of blank samples. The distribution of values for five analyte-free whole blood samples was determined with one reagent lot on two cobas e 411 analyzers with six runs distributed over a period of 5 days. The sample was measured in one-fold determination in each run. In summary, 30 measuring points were collected per instrument, for a total of 60 measured values.

Acceptance criterion: LoB ≤ 0.3 ng/mL

Limit of Detection (LoD) 5.3.

LoD of the Tacrolimus assay has been determined according to CLSI EP17-A2. The LoD was determined as the lowest amount of analyte in a sample that can be detected with a 95% probability. The distribution of values for five spiked human whole blood samples with low analyte has been determined with one reagent lot on two cobas e 411 analyzers with six runs distributed over a period of 5 days. Samples were measured in one-fold determination in each run. In summary, 30 measuring points were collected per instrument, for a total of 60 measured values. The sum of standard deviations (SD total) of the five samples was calculated. The LoD was determined according to the following EP17-A2 calculation: LoD = LoB + 1.653 x SDtotal (of low analyte samples).

Acceptance criterion: LoD ≤ 0.5 ng/mL

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Limit of Quantitation (LoQ) 5.4.

LoO of the Tacrolimus assay has been determined according to CLSI EP17-A2. The LoO was determined as the lowest concentration of analyte which can be quantified with a total error of no more than 25%. The distribution of values for 14 spiked human whole blood samples each diluted to concentrations which covered the range between LoB and 2x LoO has been determined with three reagent lot on two cobas e 411 analyzers with six runs distributed over six days. Each run was calibrated separately using a two-point calibration. Samples were extracted separately and measured in one-fold determination in each run. In summary, a total of 84 measuring points were collected per instrument, for a total of 168 measured values per lot. A separate extraction was performed with the ISD Sample Pretreatment reagent for each sample measurement. The total error (TE) was calculated based on the following equation:

$$TE = \sqrt{\mathbf{s}^2 + \mathbf{bias}^2}$$

Since the % CV and % bias are a function of the concentration, LoQ was calculated individually for each member of the Low level sample set.

The LoQ samples are sorted according to the concentration of their measured mean value. LoQ is defined as the mean value of that sample which is the first that fulfills specifications for TErel and for which no sample with lower concentration exists that exceeds this specification.

A graphic is generated that plots the measured mean values of the LoQ samples (x) against the relative total error (TErel) (y).

Acceptance criterion: 25% total error at LoQ ≤ 0.75 ng/mL

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Recovery (Accuracy) 5.5.

The measure of accuracy study included the ISD free and patient samples. ISD-free human blood is spiked with known concentration of tacrolimus (USP or other suitable reference material). Each level will be spiked independently (no dilution series). The patient derived samples (from patients taking Tacrolimus) were measured prior spiking, to evaluate the 'endogenous' concentration. The samples were then divided into at least four aliquots. Each of this aliquot is spiked with a defined concentration of analyte (5 ng/mL, 15 ng/mL and 20 ng/mL ) to obtain at least four different 'spiking' levels for each patient sample. Each level will be spiked independently (no dilution series). The samples were measured on cobas e 411.

Acceptance criterion:

  • $\n\leq \pm 0.3\n$ ng/mL for samples LoQ to 3 ng/mL .
  • $\n\pm 10\n$% for samples > 3 ng/mL .

Based on data, the recovery (accuracy) meets the specifications.

Linearity 5.6.

The linearity of the Tacrolimus assay was assessed on the cobas e 411 immunoassay analyzer; three dilution series were prepared from three different spiked human whole blood samples. Each dilution series included 22 dilutions. Each sample was measured 4-fold within one run and the measured concentrations were plotted against the expected sample concentration. A separate extraction was performed with the ISD Sample Pretreatment reagent for each sample measurement. The linearity data was determined in accordance with CLSI EP6-A. In a first step, a linearity check was performed with a first order (linear) regression and then with higher order models (quadratic and cubic).

Acceptance criterion:

  • < $\n\pm 0.2\n$ ng/mL for samples LoO to 2 ng/mL .
  • $\n\pm 10\n$% for samples > 2 ng/mL .

Linearity was confirmed in the range from 0.75 to 30 ng/mL.

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5.7. Dilution

To demonstrate the Tacrolimus assay dilution study, three ISD-free human whole blood samples were spiked separately with a known concentration of gravimetrically weight tacrolimus. These samples were used to prepare a dilution series of nine respective dilutions. Each sample was measured in duplicates (n=2).

The dilution factor for samples outside the measuring range is 1:3. The samples prepared above were diluted with the Elecsys Diluent Universal prior to the manual pre-treatment procedure.

Testing was performed on two cobas e 411 analyzers. The percent recoveries were calculated between the expected and the measured concentrations.

Analytical Specificity 5.8.

The specificity was determined using the cross-reactant compound. Each cross-reactant compound was spiked into two human whole blood samples (analyte-free and slightly elevated analyte level). Testing was performed with one reagent lot in one run. The spiked samples were evaluated at four dilutions.

Endogenous Interferences 5.9.

The effect on quantitation of analyte in the presence of endogenous interfering substances using the Tacrolimus was determined on the cobas e 411 immunoassay analyzer for the following 10 interfering substances Intralipid, Biotin, Bilirubin, Rheumatic Factor, Human Serum Albumin, IgG, Cholesterol, HASA, Uric Acid and Hematocrit using three spiked human whole blood samples (one low and one high concentration) to prepare dilution series of 10 dilutions that were tested with one reagent lot.

For each interfering substance the following protocol was followed:

One low and one high analyte containing sample were divided into two aliquots each. One aliquot was spiked with the interfering substance up to a concentration given in the table below (sample b) while the other was treated without interferent to mimic the dilution effect (sample a).

The recovery for each sample was calculated by comparison to the reference sample.

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For Hemotocrit interfering substance the following protocol was followed:

ISD-free human EDTA blood is split into two equal volume fractions. A sample is taken to measure the initial hematocrit using a hematocrit centrifuge. Cellular constituents of each fraction are separated from the plasma either by centrifugation at approximately 1000 g for about 15 minutes or overnight sedimentation in the fridge. Blood plasma of the two fractions is then blended in a way that hematocrit concentrations of 15 % resp. 65 % are achieved. Afterwards the samples are homogenized for at least 30 min on a roller mixer at room temperature. After homogenization the two sample preparations are spiked with equal amounts of analyte (USP or other suitable reference material) to reach desired concentrations and again homogenized overnight on a roller mixer at 2-8 °C.

Thereafter the two stocks (15% and 65% hematocrit) are blended in a way to obtain 11 hematocrit dilutions ranging from 15% to 65%, roller mixed for at least 30 minutes at room temperature and then measured. The recovery for every single sample was calculated based on the mean result of the respective first 10 replicates. Acceptance criterion:

  • LoO to < 3.0 ng/mL must be < $\n\pm 0.3\n$ ng/mL absolute deviation .
  • 3 to 30 ng/mL must be $\n\leq \pm 10\n$% recovery to the reference .

5.10. Exogenous Interferences — Drugs

The effect on quantitation of analyte in the presence of drugs was determined by using 16 common and 25 additional pharmaceutical compounds were spiked into each two spiked human tacrolimus containing human whole blood samples. The spiked samples (single donor samples spiked with 3 ng/mL and 10 ng/mL tacrolimus) were evaluated at drug concentrations greater than the daily dose and tested for interference by the Elecsys Tacrolimus assay on cobas e 411 immunoassay analyzer. Acceptance criterion is recovery within $\n\pm 10\n$% of initial value. All drugs met the predetermined criterion except for Itraconazole. The Itraconazole (INN international non-proprietary name) recovery was found to interfere at 10 ug/mL (114%) .

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5.11. Biotin interference

Biotin interference was tested up to 1,200 ng/mL in whole blood samples at low and high concentrations of Tacrolimus. Mean concentration of Biotin dilution sample divided by mean corresponding sample without Biotin. The results are summarized in the table below:

% Bias for samples containing various concentrations of biotin
SamplesBiotin Concentration (ng/mL)
(ng/mL)10020025030035040060010001200
2.28+5.1%+11.2%+20.2%+27.4%+30.8%+41.7%+87.8%+165.6%+203.7%
18.1+1.8%+6.1%+8.6%+12.4%+14.7%+17.8%+34.4%+76.5%+93.3%

The labeling states:

Specimens with biotin concentrations up to 100 ng/mL demonstrated $\n\leq 10\n$% bias in results. Biotin concentrations greater than 100 ng/mL led to higher positive bias Tacrolimus results. Some studies have shown that serum concentrations of biotin can reach up to 355 ng/mL within the first hour after biotin ingestion for subjects consuming supplements of 20 mg biotin per day and up to 1160 ng/mL for subjects after a single dose of 300 mg biotin.

Do not test samples from patients who are taking biotin.

Reagent Stability 6.1.

To test reagent stability, the reagent stability was performed in three different studies.

Study 1: Reagent Stability after First Opening (2-8ºC) 6.1.1.

Reagent stability after first opening for the Elecsys Tacrolimus assay was determined on a cobas e 411 immunoassay analyzer by comparing the reagent stability for four kits of the same lot. All reagent kits were opened on day 0. One kit was placed on the analyzer and calibrated and reference values for the samples tested were determined. The other three kits were stored at 2 to 8°C. After 36, 64 and 92 days, one of the stored kits was placed on the analyzer and calibrated, and the original test samples were measured. Samples tested include five human whole blood samples (pooled patient samples and single donor samples spiked with tacrolimus) and three controls. Acceptance criterion for recovery was compared to day 0 value.

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Study 2: On-board Reagent Stability 6.1.2.

On-board reagent stability for the Tacrolimus assay was tested on one cobas e 411 immunoassay analyzer. A fresh kit was placed on the analyzer and calibrated. Reference values for the samples tested were determined. After measurement, the kit was closed and kept at 20°C $\n\pm 3\n$°C for 9 weeks (64 days) to simulate on-board conditions. Measurements were repeated every week for nine weeks (64 days). The kit was placed on the analyzer again utilizing the calibration curve from seven days earlier for determinations of stability, and the original test samples were measured. The recovery was compared to the measurements from day one. Samples were tested with one reagent lot in one run per day on one cobas e 411 analyzer in duplicate. Samples tested included five human whole blood samples (pooled patient samples and single donor samples spiked with tacrolimus) and three controls (PreciControl ISD). Acceptance criterion for recovery was compared to day 1 value.

6.1.3. Study 3: Shelf Life Stability

In the real-time stability study, the Tacrolimus assay material was stored at 2 to 8°C. The stored assay reagents were tested at time point T=0 and at specified intervals over the shelf life of the device up to the planned shelf life plus one month. Testing was performed using PreciControl ISD 1, 2 and 3 (stored at -20°C). For the production lots 171852, 172226 and 173556 data for the time-points at 0, 8, 10 and 16 months were tested in duplicates.

The average on-test recovery was calculated as percent recovery compared to the reference value (Assigned value for PreciControl ISD 1, 2 and 3).

The acceptance criterion for PreciControl ISD 1 is recovery of 75 – 125% of the reference value.

The acceptance criterion for PreciControl ISD 2 and 3 are recovery of 80 – 120% of the reference value.

6.2. Sample Stability

The sample stability was performed with six different studies and they are:

  • Study 1. Sample stability before pre-treatment at room temperature (15 to 25°C) .
  • Study 2. Sample stability before pre-treatment at 2 to 8°C .

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  • Study 3. Sample stability before pre-treatment at -20°C .
  • Study 4. Stability through freeze/thaw cycles .
  • Study 5. Sample stability after pre-treatment on-board in Hitachi sample cups .
  • Study 6. Sample stability after pre-treatment at room temperature in closed Hitachi . sample cups

The stability claims to be tested are:

  • . 5 days storage at room temperature before pretreatment
  • 7 days storage before pretreatment at 2-8°C .
  • . 1 time freeze/thaw before pretreatment
  • 4 hours storage at room temperature after pretreatment in closed tube .
  • . 30 minutes on the analyzer after pretreatment
  • . 1 month storage before pretreatment at -15°C to -25°C

The percent recovery was calculated based on reference T0 (fresh sample) values.

The data collected in house supported the short stability claims. Literature reference is use to support 1 month stability claim.

CLINICAL PERFORMANCE EVALUATION 7.

Reproducibility 7.1.

Reproducibility was evaluated by testing human sample pools and PreciControl materials with the Elecsys Tacrolimus assay on the e 411 analyzer at three sites. Testing was conducted in accordance with requirements within CLSI EP5-A2 and EP15-A2. Table 3 below provides the summary of the clinical reproducibility study.

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RepeatabilityBetween DayBetween LotBetween SiteSystemReproducibility
SampleNMean(ng/mL)SDUCL of SD1-sided95%% CVSD% CVSD% CVSD% CVSDUCL of SD1-sided95%% CV
HSP 01902.670.190.237.30.186.80.000.00.217.80.340.5312.6
HSP 02906.230.520.618.30.284.40.000.00.254.00.640.7810.2
HSP 039011.380.690.816.10.554.80.000.00.443.90.991.268.7
HSP 049020.660.740.873.60.864.20.000.00.633.01.301.756.3
HSP 059027.761.191.404.32.097.50.000.01.525.52.854.0910.2
HSP 069034.851.271.493.62.196.30.000.01.053.02.743.547.9
PC ISD_L1902.110.120.145.50.157.00.000.00.188.30.260.4512.1
PC ISD_L2909.490.280.333.00.515.40.000.00.373.90.690.997.3
PC ISD_L39015.830.390.462.50.855.30.000.00.191.20.951.186.0

Table 2: Reproducibility

Note: SD of zero due to variance contributed by particular component was below stated significant figure.

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7.2. Method Comparison

Clinical test results for enrolled subjects were obtained using the Elecsys Tacrolimus Immunoassay and two comparative methods: Abbott ARCHITECT Tacrolimus, and LC-MS/MS, in order to validate performance of the Elecsys Tacrolimus Immunoassay. Table 4 below provides the summary of the clinical method comparison study.

Abbott ARCHITECT Tacrolimus vs. Elecsys Tacrolimus
Total # of samplesSlope (95% CI)(Deming)Intercept (95% CI)(Deming)Correlation (r)
Combined 5530.99 (0.98, 1.01)0.06 (-0.07, 0.18)0.99
Kidney 3461.01 (0.98, 1.03)0.04 (-0.17, 0.24)0.99
Liver 2070.97 (0.95, 0.99)0.13 (-0.01, 0.27)0.99
Elecsys Tacrolimus vs. LC-MS/MS
Total # of samplesSlope (95% CI)(Deming)Intercept (95% CI)(Deming)Correlation (r)
Combined 5540.92 (0.90, 0.95)-0.01(-0.16, 0.14)0.96
Kidney 3440.93 (0.90, 0.96)0.04 (-0.19, 0.27)0.97
Liver 2100.91 (0.87, 0.95)-0.05 (-0.25, 0.16)0.95

Summary of Clinical Method Comparison Table 3:

CONCLUSIONS 8.

The information provided in this Premarket Notification [510(k)] will support a determination of substantial equivalence for the Elecsys Tacrolimus Assay.

§ 862.1678 Tacrolimus test system.

(a)
Identification. A tacrolimus test system is a device intended to quantitatively determine tacrolimus concentrations as an aid in the management of transplant patients receiving therapy with this drug. This generic type of device includes immunoassays and chromatographic assays for tacrolimus.(b)
Classification. Class II (special controls). The special control is “Class II Special Controls Guidance Document: Cyclosporine and Tacrolimus Assays; Guidance for Industry and FDA.” See § 862.1(d) for the availability of this guidance document.