K Number
K190784
Device Name
BUHLMANN fCAL turbo
Date Cleared
2019-06-25

(90 days)

Product Code
Regulation Number
866.5180
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The BÜHLMANN fCAL turbo is an in vitro diagnostic assay intended for the quantitative measurement of fecal calprotectin, a neutrophilic protein that is a marker of intestinal mucosal inflammation, in human stool. The BÜHLMANN fCAL turbo aids in the diagnosis of inflammatory bowel disease (IBD), specifically Crohn's disease (CD) and ulcerative colitis (UC) and aids in the differentiation of IBD from irritable bowel syndrome (IBS) in conjunction with other laboratory and clinical findings.
Device Description
The BÜHLMANN fCAL® turbo, a particle-enhanced turbidimetric immunoassay (PETIA), is performed using patient stool extracts collected without preservatives. Calprotectin within the sample extract mediates immunoparticle agglutination; sample turbidity is proportional to calprotectin concentration. The detected light absorbance allows quantification of calprotectin concentration via interpolation of an established calibration curve. The assay is validated for use on clinical chemistry analyzers such as the Roche cobas® c501/c502 platforms. The BÜHLMANN fCAL® turbo Reagent Kit is to be used in conjunction with the BÜHLMANN fCAL® turbo Calibrator Kit and BÜHLMANN fCAL® turbo Control Kit, which are available separately.
More Information

Not Found

No
The device description and performance studies focus on a turbidimetric immunoassay and standard statistical analysis of results, with no mention of AI or ML.

No
This device is an in vitro diagnostic assay used to measure fecal calprotectin, which aids in the diagnosis and differentiation of certain conditions. It does not directly provide therapy or treatment to a patient.

Yes

The "Intended Use / Indications for Use" section explicitly states that the device is an "in vitro diagnostic assay" intended to "aid in the diagnosis of inflammatory bowel disease (IBD)".

No

The device is an in vitro diagnostic assay that involves physical reagents and is performed on clinical chemistry analyzers, indicating it is a hardware-dependent system, not software-only.

Yes, this device is an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The "Intended Use / Indications for Use" section explicitly states that the device is an "in vitro diagnostic assay intended for the quantitative measurement of fecal calprotectin... in human stool." This directly aligns with the definition of an IVD, which are tests performed on samples taken from the human body to detect diseases, conditions, or infections.
  • Device Description: The description details a laboratory test (particle-enhanced turbidimetric immunoassay) performed on patient samples (stool extracts). This is characteristic of an IVD.
  • Performance Studies: The document describes various performance studies (Precision, Linearity, Accuracy, Method Comparison, Clinical Sensitivity/Specificity) which are standard requirements for demonstrating the analytical and clinical performance of an IVD.
  • Predicate Device: The mention of a "Predicate Device" (BÜHLMANN fCAL® ELISA) with a K number (K181012) indicates that this device is being compared to a previously cleared IVD by a regulatory body (likely the FDA in the US, given the K number format).

All of these points strongly support the classification of this device as an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The BÜHLMANN fCAL turbo is an in vitro diagnostic assay intended for the quantitative measurement of fecal calprotectin, a neutrophilic protein that is a marker of intestinal mucosal inflammation, in human stool. The BÜHLMANN fCAL turbo aids in the diagnosis of inflammatory bowel disease (IBD), specifically Crohn's disease (CD) and ulcerative colitis (UC) and aids in the differentiation of IBD from irritable bowel syndrome (IBS) in conjunction with other laboratory and clinical findings.

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

NXO

Device Description

The BÜHLMANN fCAL® turbo, a particle-enhanced turbidimetric immunoassay (PETIA), is performed using patient stool extracts collected without preservatives. Calprotectin within the sample extract mediates immunoparticle agglutination; sample turbidity is proportional to calprotectin concentration. The detected light absorbance allows quantification of calprotectin concentration via interpolation of an established calibration curve. The assay is validated for use on clinical chemistry analyzers such as the Roche cobas® c501/c502 platforms.

The BÜHLMANN fCAL® turbo Reagent Kit is to be used in conjunction with the BÜHLMANN fCAL® turbo Calibrator Kit and BÜHLMANN fCAL® turbo Control Kit, which are available separately.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Intestinal mucosal (via human stool sample)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

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

Precision (Single-Site Repeatability Study Results):

  • Sample size: 80 for each of 8 samples (S01-S08)
  • Key results:
    • S01 (Mean 42.9 µg/g): Within-run %CV 8.3%, Within-laboratory %CV 9.1%
    • S08 (Mean 5405.6 µg/g): Within-run %CV 0.7%, Within-laboratory %CV 1.4%

Precision (Multi-Site Reproducibility Study Results):

  • Sample size: 75 for each of 8 samples (S01-S08)
  • Key results:
    • S01 (Mean 47.2 µg/g): Within-run %CV 7.6%, Total Precision %CV 9.1%
    • S08 (Mean 5475.6 µg/g): Within-run %CV 1.3%, Total Precision %CV 3.2%

Precision (Lot-to-Lot Precision Study Results):

  • Sample size: 75 for each of 8 samples (S1-S8)
  • Key results:
    • S1 (Mean 45.2 µg/g): Within-Run %CV 7.1%, Total Precision %CV 11.3%
    • S8 (Mean 5303.1 µg/g): Within-Run %CV 1.8%, Total Precision %CV 3.6%

Extraction Reproducibility Study Results:

  • Sample size: 80 for each of 10 samples (S1-S10)
  • Key results:
    • S1 (Mean 47.7 µg/g): Within-Run %CV 2.4%, Total Precision (Between-operator) %CV 7.2%
    • S10 (Mean 3330.4 µg/g): Within-Run %CV 2.8%, Total Precision (Between-operator) %CV 4.5%

Linearity Study:

  • Study procedures: Two dilution series, each using a stool specimen extract with concentration above and below the anticipated analytical measuring range, combined in various mixing ratios. Each dilution tested in 4 replicates.
  • Key results:
    • Linear regression for Run 1 (37.6 – 12,216.0 µg/g): R2 = 0.9983
    • Linear regression for Run 2 (33.5 – 13,339.5 µg/g): R2 = 0.9984
  • Supports claimed direct measuring range: 30 - 2000 ug/g
  • Supports claimed measuring range with automatic dilution: 30 - 10,000 ug/g

High Dose Hook Effect:

  • Key results: No high dose hook effect at theoretical concentrations up to 45,715 ug/g.

Accuracy/Recovery:

  • Sample size: 7 samples
  • Key results: Total recovery ranged from 93.6% to 102.0%.

Analytical Sensitivity:

  • Key results:
    • LoB = 16.7 µg/g
    • LoD = 23.7 µg/g
    • LoQ = 30 µg/g

Interfering Substances:

  • Study procedures: Stool specimen extracts with calprotectin concentrations of 30 µg/g, 100 µg/g, 300 µg/g, and 550 µg/g.
  • Key results: Various analytes, pharmaceuticals, nutritional supplements, and enteropathological microorganisms (E. coli, Salmonella, Klebsiella, Citrobacter, Shigella, Yersinia) did not interfere.

Method Comparison:

  • Sample size: 248 clinical study samples tested, 220 had valid results within the linear measuring range for both assays.
  • Comparison: BÜHLMANN fCAL® turbo vs. predicate device (BÜHLMANN fCAL® ELISA assay).
  • Analysis: Passing-Bablok regression analysis.
  • Key results:
    • Slope (95% CI): 1.025 (0.990, 1.058)
    • Intercept (µg/g) (95% CI): -4.5 (-8.7, 0.3)
    • Correlation r: 0.972

Clinical Sensitivity/Specificity (IBD vs. IBS):

  • Sample size: 265
  • Borderline values considered Positive:
    • Sensitivity = 91.1%; 95% C.I. (85.0%, 95.3%)
    • Specificity = 76.2%; 95% C.I. (67.9%, 83.2%)
    • PPV = 79.9%; 95% C.I. (72.7%, 85.9%)
    • NPV = 89.2%; 95% C.I. (81.9%, 94.3%)
  • Borderline values considered Negative:
    • Sensitivity = 80.0%; 95% C.I. (72.3%, 86.4%)
    • Specificity = 87.7%; 95% C.I. (80.8%, 92.8%)
    • PPV = 87.1%; 95% C.I. (79.9%, 92.4%)
    • NPV = 80.9%; 95% C.I. (73.4%, 87.0%)

Clinical Sensitivity/Specificity (IBD vs. non-IBD):

  • Sample size: 337
  • Borderline values considered Positive:
    • Sensitivity = 91.1%; 95% C.I. (85.0%, 95.3%)
    • Specificity = 74.3%; 95% C.I. (67.7%, 80.1%)
    • PPV = 70.3%; 95% C.I. (62.9%, 76.9%)
    • NPV = 92.6%; 95% C.I. (87.4%, 96.1%)
  • Borderline values considered Negative:
    • Sensitivity = 80.0%; 95% C.I. (72.3%, 86.4%)
    • Specificity = 85.1%; 95% C.I. (79.5%, 89.8%)
    • PPV = 78.3%; 95% C.I. (70.4%, 84.8%)
    • NPV = 86.4%; 95% C.I. (80.9%, 90.9%)

Expected Values/Reference Range:

  • Sample size: 141 apparently healthy normal adults (> 21 years of age) with no symptoms or signs of gastrointestinal disease.
  • Key results:
    • 160 µg/g: 17 subjects (12.1%)

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

Clinical Sensitivity/Specificity (IBD vs. IBS) - Borderline Values Considered Positive:

  • Sensitivity = 91.1%; 95% C.I. (85.0%, 95.3%)
  • Specificity = 76.2%; 95% C.I. (67.9%, 83.2%)
  • PPV = 79.9%; 95% C.I. (72.7%, 85.9%)
  • NPV = 89.2%; 95% C.I. (81.9%, 94.3%)

Clinical Sensitivity/Specificity (IBD vs. IBS) - Borderline Values Considered Negative:

  • Sensitivity = 80.0%; 95% C.I. (72.3%, 86.4%)
  • Specificity = 87.7%; 95% C.I. (80.8%, 92.8%)
  • PPV = 87.1%; 95% C.I. (79.9%, 92.4%)
  • NPV = 80.9%; 95% C.I. (73.4%, 87.0%)

Clinical Sensitivity/Specificity (IBD vs. non-IBD) - Borderline Values Considered Positive:

  • Sensitivity = 91.1%; 95% C.I. (85.0%, 95.3%)
  • Specificity = 74.3%; 95% C.I. (67.7%, 80.1%)
  • PPV = 70.3%; 95% C.I. (62.9%, 76.9%)
  • NPV = 92.6%; 95% C.I. (87.4%, 96.1%)

Clinical Sensitivity/Specificity (IBD vs. non-IBD) - Borderline Values Considered Negative:

  • Sensitivity = 80.0%; 95% C.I. (72.3%, 86.4%)
  • Specificity = 85.1%; 95% C.I. (79.5%, 89.8%)
  • PPV = 78.3%; 95% C.I. (70.4%, 84.8%)
  • NPV = 86.4%; 95% C.I. (80.9%, 90.9%)

Predicate Device(s)

BÜHLMANN fCAL® ELISA, K181012

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 866.5180 Fecal calprotectin immunological test system.

(a)
Identification. A fecal calprotectin immunological test system is anin vitro diagnostic device that consists of reagents used to quantitatively measure, by immunochemical techniques, fecal calprotectin in human stool specimens. The device is intended forin vitro diagnostic use as an aid in the diagnosis of inflammatory bowel diseases (IBD), specifically Crohn's disease and ulcerative colitis, and as an aid in differentiation of IBD from irritable bowel syndrome.(b)
Classification. Class II (special controls). The special control for these devices is FDA's guidance document entitled “Class II Special Controls Guidance Document: Fecal Calprotectin Immunological Test Systems.” For the availability of this guidance document, see § 866.1(e).

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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.

June 25, 2019

Roshana Ahmed President Quaras. LLC 2101 Camino Rey Fullerton, California 92833

Re: K190784

Trade/Device Name: BUHLMANN fCAL turbo Regulation Number: 21 CFR 866.5180 Regulation Name: Fecal calprotectin immunological test system Regulatory Class: Class II Product Code: NXO Dated: March 25, 2019 Received: March 27, 2019

Dear Roshana Ahmed:

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. Although this letter refers to your product as a device, please be aware 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 requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Doug Jeffery, Ph.D. Acting Deputy Division Director Division of Immunology and Hematology Devices OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K190784

Device Name BÜHLMANN fCAL turbo

Indications for Use (Describe)

The BÜHLMANN fCAL turbo is an in vitro diagnostic assay intended for the quantitative measurement of fecal calprotectin, a neutrophilic protein that is a marker of intestinal mucosal inflammation, in human stool. The BÜHLMANN fCAL turbo aids in the diagnosis of inflammatory bowel disease (IBD), specifically Crohn's disease (CD) and ulcerative colitis (UC) and aids in the differentiation of IBD from irritable bowel syndrome (IBS) in conjunction with other laboratory and clinical findings.

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

I. Submitter

BÜHLMANN Laboratories AG Baselstrasse 55 Schönenbuch CH-4124 Switzerland Phone: +41 61 487 12 50

Contact Person: Laura Zurbrügg Date Prepared: June 20, 2019

II. Device

Device Proprietary Name:BUHLMANN fCAL® turbo
Common or Usual Name:Fecal calprotectin immunological test system
Classification Name:Calprotectin, Fecal
Regulation Number:21 CFR 866.5180
Product Code:NXO
Device Classification:II

III. Predicate Device

Substantial equivalence is claimed to the following device:

  • BÜHLMANN fCAL® ELISA, K181012, BÜHLMANN Laboratories AG

IV. Device Description

The BÜHLMANN fCAL® turbo, a particle-enhanced turbidimetric immunoassay (PETIA), is performed using patient stool extracts collected without preservatives. Calprotectin within the sample extract mediates immunoparticle agglutination; sample turbidity is proportional to calprotectin concentration. The detected light absorbance allows quantification of calprotectin concentration via interpolation of an established calibration curve. The assay is validated for use on clinical chemistry analyzers such as the Roche cobas® c501/c502 platforms.

The BÜHLMANN fCAL® turbo Reagent Kit is to be used in conjunction with the BÜHLMANN fCAL® turbo Calibrator Kit and BÜHLMANN fCAL® turbo Control Kit, which are available separately.

4

V. Indications for Use

The BÜHLMANN fCAL® turbo is an in vitro diagnostic assay intended for the quantitative measurement of fecal calprotectin, a neutrophilic protein that is a marker of intestinal mucosal inflammation, in human stool. The BÜHLMANN fCAL® turbo aids in the diagnosis of inflammatory bowel disease (IBD), specifically Crohn's disease (CD) and ulcerative colitis (UC) and aids in the differentiation of IBD from irritable bowel syndrome (IBS) in conjunction with other laboratory and clinical findings.

VI. Comparison of Technological Characteristics

The BÜHLMANN fCAL® turbo and the predicate device share the following characteristics:

  • measurement of human fecal calprotectin in human stool;
  • use of a quantitative platform;
  • use of manual weighing extraction method for stool samples; and ●
  • clinical decision thresholds. ●

The BÜHLMANN fCAL® turbo is technologically different from the predicate device as follows:

  • assay method;
  • use of an alternate, automated, detection method;
  • use of polyclonal antibodies; and ●
  • broader measuring range. ●

The tables below compare key technological features between the subject and predicate device.

Technological comparison

Comparison of Assay

Similarities
BÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
(K181012)
AnalyteHuman fecal calprotectin
(MRP8/14)Human fecal calprotectin
(MRP8/14)
Assay formatQuantitativeQuantitative
Specimen typeHuman stoolHuman stool
Extraction
MethodManual Weighing (1:50 dilution in
Extraction Buffer)Manual Weighing (1:50 dilution in
Extraction Buffer)
Clinical Decision
ThresholdsNormal: 160 µg/gNormal: 160 µg/g

5

Differences
BÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
(K181012)
MethodPETIAELISA
AutomationAutomatedNot automated
Solid phasePolystyrene nanoparticles (beads)96-well polystyrene microtiter plate
Detection methodAutomated clinical chemistry
analyzer read at 546 nmMicrotiter plate reader read at
450 nm
Analyte-specific
antibody
componentsPolyclonal antibodies against
human calprotectin coated on
polystyrene beadsCapture antibodies: monoclonal
antibodies against human
calprotectin coated on microtiter
plates
Detection antibodies: monoclonal
antibodies against human
calprotectin conjugated to HRP
Measuring rangeDirect measuring range:
30 – 2000 µg/g
Measuring range with automatic
dilution: 30 – 10,000 µg/g30 – 1800 µg/g

Comparison of Calibrators

BÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
Indications for
UseThe BÜHLMANN fCAL® turbo
Calibrator Kit is intended for use
with the BÜHLMANN fCAL®
turbo Reagent Kit for the
determination of fecal calprotectin
levels in extracted stool samples.
Comprised of six (6) calibrators,
each calibrator establishes a point
of reference for the working curve
that is used to calculate test results
from patient samples.N/A
MethodBÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
AnalyteNative human calprotectin
Source: human granulocyte extractNative human calprotectin
Source: human serum
Calibrators6 levels:
Target values: 0, 50, 200, 500,
1000, 2000 µg/g5 levels:
4, 12, 40, 120, and 240 ng/mL
Conversion factorN/A7.5
Value assignment:Calibrator values assigned using a
value transfer protocol for each
calibrator lot. Values are indicated
in the QC datasheet.Nominal values:
30 µg/g, 90 µg/g, 300 µg/g, 900
µg/g, 1800 µg/g

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BÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
ConfigurationAvailable as a separate
BÜHLMANN fCAL® turbo
Calibrator Kit.Included within the BÜHLMANN
fCAL® ELISA kit.

Comparison of Controls

BÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
Indications for
UseThe BÜHLMANN fCAL® turbo
Control Kit, comprised of a high
and low control, is intended for use
with the BÜHLMANN fCAL®
turbo Reagent Kit, for quality
control, in the determination of
fecal calprotectin levels in extracted
stool samples.N/A
MethodBÜHLMANN fCAL® turboBÜHLMANN fCAL® ELISA
AnalyteNative human calprotectin
Source: human granulocyte extractNative human calprotectin
Source: human serum
Levels2 (low and high)2 (low and high)
Physio-chemical
characteristicsReady to useReady to use
ConfigurationAvailable as a separate
BÜHLMANN fCAL® turbo Control
KitIncluded within the BÜHLMANN
fCAL® ELISA kit

Discussion

As seen above, differences between the subject and predicate device include the assay and detection methods, antibodies, and reportable measuring range. These technological differences do not create new questions of safety and effectiveness and the differences are addressed by the performance studies identified below.

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VII. Performance Data

A. Clinical Thresholds

Calprotectin ConcentrationInterpretationFollow-Up
160 µg/gElevatedRetest as appropriate

B. Precision

Single-Site Repeatability Study Results:

| ID | Mean
[µg/g] | n | Within-run
(Repeatability) | | Between-
run | | Between-
day | | Within-
laboratory | |
|-----|----------------|----|-------------------------------|------|-----------------|------|-----------------|------|-----------------------|------|
| | | | SD | %CV | SD | %CV | SD | %CV | SD | %CV |
| S01 | 42.9 | 80 | 3.6 | 8.3% | 1.2 | 2.7% | 1.1 | 2.5% | 3.9 | 9.1% |
| S02 | 98.4 | 80 | 2.5 | 2.6% | 1.8 | 1.8% | 2.2 | 2.2% | 3.7 | 3.8% |
| S03 | 166.5 | 80 | 4.3 | 2.6% | 0.8 | 0.5% | 1.9 | 1.2% | 4.8 | 2.9% |
| S04 | 267.6 | 80 | 3.9 | 1.4% | 2.5 | 0.9% | 1.8 | 0.7% | 5.0 | 1.9% |
| S05 | 642.0 | 80 | 20.1 | 3.1% | 14.9 | 2.3% | 0.0 | 0.0% | 25.1 | 3.9% |
| S06 | 1414.2 | 80 | 19.6 | 1.4% | 11.1 | 0.8% | 3.5 | 0.2% | 22.8 | 1.6% |
| S07 | 3251.4 | 80 | 40.8 | 1.3% | 21.4 | 0.7% | 19.7 | 0.6% | 50.1 | 1.5% |
| S08 | 5405.6 | 80 | 40.2 | 0.7% | 56.6 | 1.0% | 34.5 | 0.6% | 77.5 | 1.4% |

Multi-Site Reproducibility Study Results:

| ID | Mean
[µg/g] | n | Within-run
(Repeatability) | | Between-
day | | Between-
site | | Total
Precision | |
|-----|----------------|----|-------------------------------|-----|-----------------|-----|------------------|-----|--------------------|-----|
| | | | SD | %CV | SD | %CV | SD | %CV | SD | %CV |
| S01 | 47.2 | 75 | 3.6 | 7.6 | 2.4 | 5.0 | 0.0 | 0.0 | 4.3 | 9.1 |
| S02 | 91.1 | 75 | 3.5 | 3.8 | 3.5 | 3.8 | 2.8 | 3.1 | 5.7 | 6.2 |
| S03 | 185.4 | 75 | 5.1 | 2.7 | 2.7 | 1.4 | 5.5 | 3.0 | 7.9 | 4.3 |
| S04 | 276.9 | 75 | 6.4 | 2.3 | 4.5 | 1.6 | 9.7 | 3.5 | 12.5 | 4.5 |
| S05 | 674.5 | 75 | 12.9 | 1.9 | 1.2 | 0.2 | 22.8 | 3.4 | 26.3 | 3.9 |
| S06 | 1519.6 | 75 | 25.3 | 1.7 | 17.8 | 1.2 | 62.3 | 4.1 | 69.6 | 4.6 |
| S07 | 3343.8 | 75 | 54.6 | 1.6 | 35.6 | 1.1 | 100.0 | 3.0 | 119.4 | 3.6 |
| S08 | 5475.6 | 75 | 72.1 | 1.3 | 35.8 | 0.7 | 154.2 | 2.8 | 173.9 | 3.2 |

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IDMean [µg/g]nWithin-Run (Repeatability)Between-DayBetween-LotTotal Precision
SD%CVSD%CVSD%CVSD%CV
S145.2753.227.1%1.363.0%3.708.2%5.0911.3%
S286.4753.694.3%1.191.4%5.666.6%6.867.9%
S3175.8755.042.9%0.290.2%9.905.6%11.116.3%
S4263.9757.552.9%0.000.0%9.983.8%12.524.7%
S5647.47515.472.4%0.000.0%15.282.4%21.743.4%
S61460.77533.662.3%11.640.8%41.012.8%54.323.7%
S73234.57571.232.2%8.900.3%130.294.0%148.764.6%
S85303.17597.421.8%11.180.2%163.873.1%190.973.6%

Lot-to-Lot Precision Study Results:

Extraction Reproducibility Study Results:

| Sample | n | Mean
(µg/g) | SD
(µg/g) | %CV | Within-Run
(Repeatability) | | Between-
extraction | | Between-
day | | Between-
operator | | Total
Precision | |
|--------|----|----------------|--------------|-----|-------------------------------|------|------------------------|------|-----------------|-----|----------------------|------|--------------------|-----|
| | | | | | SD
(µg/g) | %CV | SD
(µg/g) | %CV | SD
(µg/g) | %CV | SD
(µg/g) | %CV | SD
(µg/g) | %CV |
| S1 | 80 | 47.7 | 2.8 | 5.9 | 1.1 | 2.4 | 0.7 | 1.5 | 1.4 | 2.9 | 3.4 | 7.2 | | |
| S2 | 80 | 72.3 | 3.8 | 5.2 | 3.9 | 5.4 | 4.2 | 5.8 | 0.0 | 0.0 | 6.8 | 9.5 | | |
| S3 | 80 | 96.1 | 3.8 | 3.9 | 2.2 | 2.3 | 1.4 | 1.4 | 0.0 | 0.0 | 4.6 | 4.8 | | |
| S4 | 80 | 170.6 | 4.0 | 2.4 | 2.5 | 1.5 | 8.7 | 5.1 | 0.0 | 0.0 | 9.9 | 5.8 | | |
| S5 | 80 | 277.0 | 3.7 | 1.4 | 27.9 | 10.1 | 10.0 | 3.6 | 11.0 | 4.0 | 31.8 | 11.5 | | |
| S6 | 80 | 421.1 | 9.8 | 2.3 | 5.9 | 1.4 | 15.3 | 3.6 | 0.0 | 0.0 | 19.1 | 4.5 | | |
| S7 | 80 | 573.9 | 5.4 | 0.9 | 39.5 | 6.9 | 0.0 | 0.0 | 0.0 | 0.0 | 39.9 | 6.9 | | |
| S8 | 80 | 1387.4 | 39.1 | 2.8 | 75.1 | 5.4 | 159.9 | 11.5 | 0.0 | 0.0 | 180.9 | 13.0 | | |
| S9 | 80 | 3264.9 | 87.2 | 2.7 | 236.2 | 7.2 | 256.9 | 7.9 | 0.0 | 0.0 | 359.7 | 11.0 | | |
| S10 | 80 | 3330.4 | 89.8 | 2.7 | 92.4 | 2.8 | 75.7 | 2.3 | 0.0 | 0.0 | 149.4 | 4.5 | | |

9

C. Linearity

Study procedures were performed using two dilution series. For each dilution series, a stool specimen extract with concentration above the anticipated upper limit of the analytical measuring range was combined with a stool specimen extract with concentration below the anticipated lower limit of the analytical measuring range, in various mixing ratios covering the range; each dilution was tested in 4 replicates. Results of the linear regression analyses are presented in the table below.

| Best | Measuring
Range [µg/g] | Linear regression parameters | | |
|------|---------------------------|------------------------------|-------------------------|--------|
| | | Intercept
(95% C.I.) | Slope
(95% C.I.) | R2 |
| 1 | 37.6 – 12,216.0 | 5.7
(1.6, 16.9) | 1.057
(1.044, 1.075) | 0.9983 |
| 2 | 33.5 – 13,339.5 | 3.8
(-0.4, 13.3) | 1.031
(1.014, 1.042) | 0.9984 |

The data supports the following claims for analytical measuring range:

Direct analytical measuring range: 30 - 2000 ug/g Measuring range with automatic dilution: 30 - 10,000 ug/g

D. High Dose Hook Effect

No high dose hook effect at theoretical concentrations up to 45,715 ug/g.

E. Accuracy/Recovery

Sample No7226722872387236724472347246
Baseline result [µg/g]44.1065.45116.43138.48230.88510.781076.33
Expected post-spike result [µg/g]101.04122.39173.37195.42458.65738.551304.10
Observed post-spike result [µg/g]94.55114.53170.23186.93453.10753.181309.28
Total recovery [%]93.6%93.6%98.2%95.7%98.8%102.0%100.4%

F. Analytical Sensitivity

Results of the analytical sensitivity studies support a claimed direct measuring range of 30 -2000 ug/g and a measuring range of 30 - 10,000 µg/g with automatic dilution.

LoB = 16.7 µg/g LoD = 23.7 µg/g LoQ = 30 µg/g

10

G. Interfering Substances

Study procedures were performed using stool specimen extracts with the following approximate calprotectin concentrations: 30 µg/g, 100 µg/g, 300 µg/g, and 550 µg/g. The following analytes, pharmaceuticals, and nutritional supplements did not interfere with the BÜHLMANN fCAL® turbo:

| Trade name | Active component | Solvent | Concentration
mg/50 mg
stool |
|------------------|-------------------------|---------------------------------|------------------------------------|
| gyno-Tardyferon | Iron (II) sulfate | HCl/NaOH | 0.11 |
| Prednisone | Prednisone | DMSO | 0.31 |
| Imurek | Azathioprine | DMSO | 0.19 |
| Salofalk | Mesalamine; 5-ASA | DMSO | 5.21 |
| Agopton | Lansoprazole | Dimethylformamide | 0.18 |
| Asacol | Mesalamine; 5-ASA | DMSO | 2.50 |
| Vancocin | Vancomycin | H2Odd | 2.00 |
| Sulfamethoxazole | Sulfamethoxazole | DMSO | 1.60 |
| Trimethoprim | Trimethoprim lactate | DMSO/Exbuffer | 0.35 |
| Ciproxine | Ciprofloxacin | solvent from manufacturer/H2Odd | 1.25 |
| Vitamin E | DL-α Tocopherol Acetate | H2O + Tween | 0.30 |
| Bion 3 | Multivitamin | HCl/NaOH | 1.06 |
| Hemoglobin | Hemoglobin | H2Odd | 1.25 |

The following enteropathological microorganisms did not interfere with the BÜHLMANN fCAL® turbo when added to stool extracts at the given cell counts:

| Microorganism | Concentration
(cfu/mL) |
|-----------------------------------------------|---------------------------|
| Escherichia coli | 3.3 x 107 |
| Salmonella enterica subsp. enterica | 9.0 x 107 |
| Klebsiella pneumoniae subsp. pneumonia | 5.3 x 107 |
| Citrobacter freundii | 12.9 x 107 |
| Shigella flexneri | 5.0 x 107 |
| Yersinia enterocolitica subsp. enterocolitica | 9.8 x 107 |

11

H. Method Comparison

A total of 248 clinical study samples were tested using the BÜHLMANN fCAL® turbo and the predicate device (BÜHLMANN fCAL® ELISA assay); valid results within the linear measuring range for both assays were obtained for 220 of these samples. Results were analyzed by Passing-Bablok regression analysis.

| Slope
(95% CI) | Intercept (µg/g)
(95% CI) | Bias at 80 µg/g
(95% CI) | Bias at 160 µg/g
(95% CI) | Correlation
r |
|-------------------|------------------------------|-----------------------------|------------------------------|-------------------------|
| 1.025 | -4.5 | -3.1% | -0.3% | 0.972 |
| (0.990, 1.058) | (-8.7, 0.3) | (-7.2%, 0.5%) | (-2.4%, 2.7%) | |

Frequency counts of BÜHLMANN fCAL® turbo test results and corresponding BÜHLMANN fCAL® ELISA assay results within each of the diagnostic ranges of these tests are provided below.

# in BÜHLMANN fCAL® ELISA assay range (µg/g)
160Total
# in fCAL
turbo range
(µg/g)160079299
Total925898248

Estimates of positive percent agreement (PPA) and negative percent agreement (NPA) between the BÜHLMANN fCAL® turbo results and corresponding BÜHLMANN fCAL® ELISA assay results, using both sets of assay cutoffs, with respect to IBD subjects, other GI subjects, normal subjects, and all subjects combined are shown in the table below.

12

SubgroupMetricEstimate95% C.I.
IBDPPA (lower cutoff)68/70 = 97.1%[90.1%, 99.7%]
NPA (lower cutoff)6/7 = 85.7%[42.1%, 99.6%]
PPA (upper cutoff)52/56 = 92.9%[82.7%, 98.0%]
NPA (upper cutoff)19/21 = 90.5%[69.6%, 98.8%]
IBSPPA (lower cutoff)28/32 = 87.5%[71.0%, 96.5%]
NPA (lower cutoff)31/33 = 93.9%[79.8%, 99.3%]
PPA (upper cutoff)12/13 = 92.3%[64.0%, 99.8%]
NPA (upper cutoff)49/52 = 94.2%[84.1%, 98.8%]
Other GIPPA (lower cutoff)20/21 = 95.2%[76.2%, 99.9%]
NPA (lower cutoff)16/16 = 100%[79.4%, 100%]
PPA (upper cutoff)13/14 = 92.9%[66.1%, 99.8%]
NPA (upper cutoff)23/23 = 100%[85.2%, 100%]
NormalPPA (lower cutoff)30/33 = 90.9%[75.7%, 98.1%]
NPA (lower cutoff)31/36 = 86.1%[70.5%, 95.3%]
PPA (upper cutoff)15/15 = 100%[78.2%, 100%]
NPA (upper cutoff)52/54 = 96.3%[87.3%, 99.5%]
All subjectsPPA (lower cutoff)146/156 = 93.6%[88.5%, 96.9%]
NPA (lower cutoff)84/92 = 91.3%[83.6%, 96.2%]
PPA (upper cutoff)92/98 = 93.9%[87.1%, 97.7%]
NPA (upper cutoff)143/150 = 95.3%[90.6%, 98.1%]

I. Clinical Sensitivity/Specificity

IBD vs. IBS:

| Borderline Values

Considered PositiveClinical DiagnosisTotal
BÜHLMANN
fCAL® turboIBDIBS
BÜHLMANN
fCAL® turboPositive12331154
BÜHLMANN
fCAL® turboNegative1299111
Total135130265
Sensitivity = 91.1%; 95% C.I. (85.0%, 95.3%)
Specificity = 76.2%; 95% C.I. (67.9%, 83.2%)
PPV = 79.9%; 95% C.I. (72.7%, 85.9%)
NPV = 89.2%; 95% C.I. (81.9%, 94.3%)

13

| Borderline Values

Considered NegativeClinical DiagnosisTotal
IBDIBS
BÜHLMANN
fCAL® turboPositive10816124
Negative27114141
Total135130265
Sensitivity = 80.0%; 95% C.I. (72.3%, 86.4%)
Specificity = 87.7%; 95% C.I. (80.8%, 92.8%)
PPV = 87.1%; 95% C.I. (79.9%, 92.4%)
NPV =80.9%; 95% C.I. (73.4%, 87.0%)

IBD vs. non-IBD:

Borderline ValuesClinical DiagnosisTotal
Considered PositiveIBDNon-IBD
BÜHLMANNPositive12352175
fCAL® turboNegative12150162
Total135202337
Sensitivity = 91.1%; 95% C.I. (85.0%, 95.3%)
Specificity = 74.3%; 95% C.I. (67.7%, 80.1%)
PPV = 70.3%; 95% C.I. (62.9%, 76.9%)
NPV = 92.6%; 95% C.I. (87.4%, 96.1%)
Borderline ValuesClinical DiagnosisTotal
Considered NegativeIBDIBS
BÜHLMANNPositive10830138
fCAL® turboNegative27172199
Totalા રેર202337
Sensitivity = 80.0%; 95% C.I. (72.3%, 86.4%)
Specificity = 85.1%; 95% C.I. (79.5%, 89.8%)
PPV = 78.3%; 95% C.I. (70.4%, 84.8%)
NPV =86.4%; 95% C.I. (80.9%, 90.9%)

14

J. Expected Values/Reference Range:

Stool samples were obtained from 141 apparently healthy normal adults (> 21 years of age) with no symptoms or signs of gastrointestinal disease. The test results were categorized by the assay cut-offs below.

Calprotectin level by BÜHLMANN fCAL turbo
160 μg/gTotal
Number of
subjects (%)106 (75.2%)18 (12.8%)17 (12.1%)141 (100%)

VIII. Conclusion

The information provided above supports that the BÜHLMANN fCAL® turbo is as safe and effective as the predicate device. Although differences exist between the subject and predicate device, verification and validation studies support that these differences do not raise any new questions of safety and effectiveness. Therefore, it is concluded that the BÜHLMANN CAL® turbo is substantially equivalent to the predicate device.

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