K Number
K213822
Device Name
cobas Influenza A/B & RSV nucleic acid test for use on the cobas Liat System
Date Cleared
2022-07-06

(210 days)

Product Code
Regulation Number
866.3980
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The cobas® Influenza A/B & RSV Nucleic acid test for use on the cobas® Liat® System (cobas® Influenza A/B & RSV) is an automated multiplex real-time RT-PCR assay for the rapid in vitro qualitative detection and discrimination of Influenza A virus, Influenza B virus and respiratory syncytial virus (RSV) RNA in nasopharyngeal swab specimens from patients with signs and symptoms of respiratory infection in conjunction with clinical and epidemiological risk factors. The test is intended for use as an aid in the differential diagnosis of Influenza A, Influenza B, and RSV in humans and is not intended to detect Influenza C. Negative results do not preclude Influenza virus or RSV infection and should not be used as the sole basis for treatment or other patient management decisions. Conversely, positive results do not rule out bacterial infection or co-infection with other viruses. The agent detected may not be the definite cause of disease. Performance characteristics for Influenza A were established during the 2013-2014 and the 2014-2015 influenza seasons when Influenza A/H3 and A/H1N1 pandemic were the predominant Influenza A viruses in circulation. When other Influenza A viruses are emerging, performance characteristics may vary. If infection with a novel Influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent Influenza viruses and sent to state or local health department for testing. Viral culture should not be attempted in these cases unless a BSL3+ facility is available to receive and culture specimens.
Device Description
The cobas® Liat® Influenza A/B & RSV Nucleic Acid Test for use on the cobas® Liat® System (cobas® Influenza A/B & RSV) is an automated in vitro diagnostic test for the qualitative detection of Influenza A, Influenza B, and RSV RNA in nasopharyngeal swab (NPS) specimens. The sample-to-result time is ~20 minutes. The assay is performed on the Analyzer which automates and integrates sample purification, nucleic acid amplification, and detection of the target sequence in biological samples using realtime RT-PCR assays. The assay targets a well-conserved region of the matrix gene of Influenza A (Inf A target), the non-structure protein gene of Influenza B (Inf B target), and the matrix gene of RSV (RSV target). An Internal Process Control (IPC) is also included. The IPC is present to control for adequate processing of the target virus through all steps of the assay process and to monitor the presence of inhibitors in the RT-PCR reactions. The System consists of an instrument and preloaded software for running tests and viewing the results. The system requires the use of a single-use disposable cobas® Influenza A/B & RSV assay tube that holds the nucleic acid purification and RT-PCR reagents, and hosts the sample preparation and RT-PCR processes. The detection module monitors the reaction in real-time, while an on-board computer analyzes the collected data and outputs an interpreted result. The latter is displayed in the assay report on the integrated LCD touch screen of the cobas® Liat® Analyzer and in an electronic file. The report can be printed directly through a USB or network-connected printer. The results can also be exported to an external server, middleware or data management system, or to a Laboratory Information System (LIS).
More Information

Not Found

No
The description details a standard real-time RT-PCR assay with automated sample processing and data analysis, but there is no mention of AI or ML algorithms being used for interpretation or any other function. The analysis is based on detecting specific genetic targets and an internal control.

No

Explanation: This device is an in vitro diagnostic test for the qualitative detection and discrimination of viruses, intended to aid in diagnosis, not to provide therapy.

Yes

The "Intended Use / Indications for Use" section explicitly states that "The test is intended for use as an aid in the differential diagnosis of Influenza A, Influenza B, and RSV in humans." The "Device Description" also mentions it is an "automated in vitro diagnostic test."

No

The device description explicitly states that the system consists of an instrument (the cobas® Liat® Analyzer) and a single-use disposable assay tube, in addition to the software. This indicates the device is a hardware and software system, not software-only.

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

Here's why:

  • Intended Use/Indications for Use: The description explicitly states it is for "rapid in vitro qualitative detection and discrimination of Influenza A virus, Influenza B virus and respiratory syncytial virus (RSV) RNA in nasopharyngeal swab specimens". The term "in vitro" is a key indicator of an IVD. It also states it is "intended for use as an aid in the differential diagnosis".
  • Device Description: The description refers to it as an "automated in vitro diagnostic test".
  • Function: The device analyzes biological samples (nasopharyngeal swabs) to detect specific nucleic acids (RNA) for diagnostic purposes. This is the core function of an IVD.

N/A

Intended Use / Indications for Use

The cobas® Influenza A/B & RSV Nucleic acid test for use on the cobas® Liat® System (cobas® Influenza A/B & RSV) is an automated multiplex real-time RT-PCR assay for the rapid in vitro qualitative detection and discrimination of Influenza A virus, Influenza B virus and respiratory syncytial virus (RSV) RNA in nasopharyngeal swab specimens from patients with signs and symptoms of respiratory infection in conjunction with clinical and epidemiological risk factors. The test is intended for use as an aid in the differential diagnosis of Influenza B, and RSV in humans and is not intended to detect Influenza C.

Negative results do not preclude Influenza virus or RSV infection and should not be used as the sole basis for treatment or other patient management decisions. Conversely, positive results do not rule-out bacterial infection with other viruses. The agent detected may not be the definite cause of disease.

Performance characteristics for Influenza A were established during the 2013-2014 and the 2014-2015 Influenza seasons when Influenza A/H3 and A/H/N1 pandemic were the predominant Influenza A viruses in circulation. When other Influenza A viruses are emerging, performance characteristics may vary.

If infection with a novel Influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent Influenza viruses and sent to state or local health department for testing. Viral culture should not be attempted in these cases unless a BSL3+ facility is available to receive and culture specimens.

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

OCC, OOI

Device Description

The cobas® Liat® Influenza A/B & RSV Nucleic Acid Test for use on the cobas® Liat® System (cobas® Influenza A/B & RSV) is an automated in vitro diagnostic test for the qualitative detection of Influenza A, Influenza B, and RSV RNA in nasopharyngeal swab (NPS) specimens. The sample-to-result time is ~20 minutes.

The assay is performed on the Analyzer which automates and integrates sample purification, nucleic acid amplification, and detection of the target sequence in biological samples using realtime RT-PCR assays. The assay targets a well-conserved region of the matrix gene of Influenza A (Inf A target), the non-structure protein gene of Influenza B (Inf B target), and the matrix gene of RSV (RSV target). An Internal Process Control (IPC) is also included. The IPC is present to control for adequate processing of the target virus through all steps of the assay process and to monitor the presence of inhibitors in the RT-PCR reactions.

The System consists of an instrument and preloaded software for running tests and viewing the results. The system requires the use of a single-use disposable cobas® Influenza A/B & RSV assay tube that holds the nucleic acid purification and RT-PCR reagents, and hosts the sample preparation and RT-PCR processes.

The detection module monitors the reaction in real-time, while an on-board computer analyzes the collected data and outputs an interpreted result. The latter is displayed in the assay report on the integrated LCD touch screen of the cobas® Liat® Analyzer and in an electronic file. The report can be printed directly through a USB or network-connected printer. The results can also be exported to an external server, middleware or data management system, or to a Laboratory Information System (LIS).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

nasopharyngeal swab specimens

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)

Performance of the cobas® Influenza A/B & RSV assay when used with NEG BUF as a negative control and positive control diluent was assessed. It was determined that the overall cobas® Influenza A/B & RSV assay performance claims were not impacted by the changed control material when compared to the current commercially available version of the assay and quality control kit. The change is limited to the control processing and does not affect clinical specimen testing.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K210234

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 866.3980 Respiratory viral panel multiplex nucleic acid assay.

(a)
Identification. A respiratory viral panel multiplex nucleic acid assay is a qualitative in vitro diagnostic device intended to simultaneously detect and identify multiple viral nucleic acids extracted from human respiratory specimens or viral culture. The detection and identification of a specific viral nucleic acid from individuals exhibiting signs and symptoms of respiratory infection aids in the diagnosis of respiratory viral infection when used in conjunction with other clinical and laboratory findings. The device is intended for detection and identification of a combination of the following viruses:(1) Influenza A and Influenza B;
(2) Influenza A subtype H1 and Influenza A subtype H3;
(3) Respiratory Syncytial Virus subtype A and Respiratory Syncytial Virus subtype B;
(4) Parainfluenza 1, Parainfluenza 2, and Parainfluenza 3 virus;
(5) Human Metapneumovirus;
(6) Rhinovirus; and
(7) Adenovirus.
(b)
Classification. Class II (special controls). The special controls are:(1) FDA's guidance document entitled “Class II Special Controls Guidance Document: Respiratory Viral Panel Multiplex Nucleic Acid Assay;”
(2) For a device that detects and identifies Human Metapneumovirus, FDA's guidance document entitled “Class II Special Controls Guidance Document: Testing for Human Metapneumovirus (hMPV) Using Nucleic Acid Assays;” and
(3) For a device that detects and differentiates Influenza A subtype H1 and subtype H3, FDA's guidance document entitled “Class II Special Controls Guidance Document: Testing for Detection and Differentiation of Influenza A Virus Subtypes Using Multiplex Nucleic Acid Assays.” See § 866.1(e) for the availability of these guidance documents.

0

Date: July 6, 2022

Image /page/0/Picture/1 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.

Roche Molecular Systems, Inc. Khushvanreep Singh Official Correspondent 4300 Hacienda Drive Pleasanton, California 94588-2722

Re: K213822

Trade/Device Name: cobas Influenza A/B & RSV nucleic acid test for use on the cobas Liat System Regulation Number: 21 CFR 866.3980 Regulation Name: Respiratory Viral Panel Multiplex Nucleic Acid Assay Regulatory Class: Class II Product Code: OCC, OOI Dated: December 7, 2021 Received: December 8, 2021

Dear Khushvanreep Singh:

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 801 and Part 809); medical device reporting of medical device-related adverse events) (21 CFR

1

  1. 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-reporting-

combination-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.

for Himani Bisht, Ph.D. Assistant Director Viral Respiratory and HPV Branch Division of Microbiology 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) K213822

Device Name

cobas Influenza A/B & RSV nucleic acid test for use on the cobas Liat System

Indications for Use (Describe)

The cobas Influenza A/B & RSV Nucleic acid test for use on the cobas Influenza A/B & RSV) is an automated multiplex real-time RT-PCR assay for the rapid in vitro qualitative detection and discrimination of Influenza A virus, Influenza B virus and respiratory syncytial virus (RSV) RNA in nasopharyngeal swab specimens from patients with signs and symptoms of respiratory infection in conjunction with clinical and epidemiological risk factors. The test is intended for use as an aid in the differential diagnosis of Influenza B, and RSV in humans and is not intended to detect Influenza C.

Negative results do not preclude Influenza virus or RSV infection and should not be used as the sole basis for treatment or other patient management decisions. Conversely, positive results do not rule-out bacterial infection with other viruses. The agent detected may not be the definite cause of disease.

Performance characteristics for Influenza A were established during the 2013-2014 and the 2014-2015 Influenza seasons when Influenza A/H3 and A/H/N1 pandemic were the predominant Influenza A viruses in circulation. When other Influenza A viruses are emerging, performance characteristics may vary.

If infection with a novel Influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent Influenza viruses and sent to state or local health department for testing. Viral culture should not be attempted in these cases unless a BSL3+ facility is available to receive and culture specimens.

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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cobas® Influenza A/B & RSV Nucleic Acid Test for Use on the cobas® Liat® System 510(k) Summary

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

Submitter NameRoche Molecular Systems, Inc.
Address4300 Hacienda Drive
Pleasanton, CA 94588-2722
ContactKhushvanreep Singh
Phone: (848) 250-4084
Email: khushvanreep.singh@roche.com
Date PreparedSeptember 24, 2021
Proprietary Namecobas® Influenza A/B & RSV Nucleic acid test for use on the cobas® Liat®
System
Common NameInfluenza A, B, RSV Panel
Classification NameRespiratory viral panel multiplex nucleic acid assay
Real Time Nucleic Acid Amplification System
Product CodesOCC, 21 CFR 866.3980
OOI, 21 CFR 862.2570
Predicate Devicescobas® Influenza A/B & RSV Nucleic Acid Test for use on the cobas® Liat®
System (K210234)
Establishment RegistrationRoche Molecular Systems, Inc. Branchburg, NJ
Establishment Number: 2243471
Roche Molecular Systems, Inc. Pleasanton, CA
Establishment Number: 3004141078

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1. DEVICE DESCRIPTION

The cobas® Liat® Influenza A/B & RSV Nucleic Acid Test for use on the cobas® Liat® System (cobas® Influenza A/B & RSV) is an automated in vitro diagnostic test for the qualitative detection of Influenza A, Influenza B, and RSV RNA in nasopharyngeal swab (NPS) specimens. The sample-to-result time is ~20 minutes.

The assay is performed on the Analyzer which automates and integrates sample purification, nucleic acid amplification, and detection of the target sequence in biological samples using realtime RT-PCR assays. The assay targets a well-conserved region of the matrix gene of Influenza A (Inf A target), the non-structure protein gene of Influenza B (Inf B target), and the matrix gene of RSV (RSV target). An Internal Process Control (IPC) is also included. The IPC is present to control for adequate processing of the target virus through all steps of the assay process and to monitor the presence of inhibitors in the RT-PCR reactions.

The System consists of an instrument and preloaded software for running tests and viewing the results. The system requires the use of a single-use disposable cobas® Influenza A/B & RSV assay tube that holds the nucleic acid purification and RT-PCR reagents, and hosts the sample preparation and RT-PCR processes.

The detection module monitors the reaction in real-time, while an on-board computer analyzes the collected data and outputs an interpreted result. The latter is displayed in the assay report on the integrated LCD touch screen of the cobas® Liat® Analyzer and in an electronic file. The report can be printed directly through a USB or network-connected printer. The results can also be exported to an external server, middleware or data management system, or to a Laboratory Information System (LIS).

Test Workflow 1.1.

Nasopharyngeal swab can be collected following the user institution's standard procedures. For nasopharyngeal swab samples suspended in collection media, a user transfers the sample into cobas® Influenza A/B & RSV assay tube.

A user then scans the assay tube barcode to identify the test and scans the sample barcode to code the sample ID using the cobas® Liat® System. The assay tube is then inserted into the cobas® Liat® Analyzer (Figure 1). The analyzer performs all test steps and outputs interpreted results in approximately 20 minutes. A report of the interpreted results can be viewed in the View Results window, and printed directly through a USB connected printer.

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Figure 1: Illustration of cobas® Liat® Analyzer Assay Testing Process

Image /page/5/Picture/1 description: The image shows three different steps of a medical process. In each step, a gloved hand is interacting with a medical device. The device has a screen and buttons, and in each step, the hand is either inserting a vial or tube into the device or holding it nearby.

2. INTENDED USE

The cobas® Influenza A/B & RSV Nucleic acid test for use on the cobas® Liat® System (cobas® Influenza A/B & RSV) is an automated multiplex real-time RT-PCR assay for the rapid in vitro qualitative detection and discrimination of Influenza A virus, Influenza B virus and respiratory syncytial virus (RSV) RNA in nasopharyngeal swab specimens from patients with signs and symptoms of respiratory infection in conjunction with clinical and epidemiological risk factors. The test is intended for use as an aid in the differential diagnosis of Influenza A, Influenza B, and RSV in humans and is not intended to detect Influenza C.

Negative results do not preclude Influenza virus or RSV infection and should not be used as the sole basis for treatment or other patient management decisions. Conversely, positive results do not rule out bacterial infection or co-infection with other viruses. The agent detected may not be the definite cause of disease.

Performance characteristics for Influenza A were established during the 2013-2014 and the 2014-2015 influenza seasons when Influenza A/H3 and A/H1N1 pandemic were the predominant Influenza A viruses in circulation. When other Influenza A viruses are emerging, performance characteristics may vary.

If infection with a novel Influenza A virus is suspected based on current clinical and epidemiological screening criteria recommended by public health authorities, specimens should be collected with appropriate infection control precautions for novel virulent Influenza viruses and sent to state or local health department for testing. Viral culture should not be attempted in these cases unless a BSL3+ facility is available to receive and culture specimens.

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TECHNOLOGICAL CHARACTERISTICS 3.

The technological characteristics and intended use of cobas® Influenza A/B & RSV for use on the cobas® Liat® System, when used with cobas® Influenza A/B & RSV Assay Script v1.16 has not changed from the predicate device. Table 1 provides a comparison of the modified device to the predicate device, as cleared through K210234.

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Table 1: Comparison of the cobas® Influenza A/B & RSV Assay with cobas® Influenza A/B & RSV Assay Script to the Predicate Device
Item NameSubmitted Device:
cobas® Influenza A/B & RSV w/ cobas® Influenza A/B & RSVPredicate Device: K210234
cobas® Influenza A/B & RSV w/ cobas® Influenza A/B & RSV
Intended UseSameThe cobas® Influenza A/B & RSV Nucleic acid test for use on the cobas® Liat®
System (cobas® Influenza A/B & RSV) is an automated multiplex real-time RT-PCR
assay for the rapid in vitro qualitative detection and discrimination of Influenza A
virus, Influenza B virus and respiratory syncytial virus (RSV) RNA in nasopharyngeal
swab specimens from patients with signs and symptoms of respiratory infection in
conjunction with clinical and epidemiological risk factors. The test is intended for use
as an aid in the differential diagnosis of Influenza A, Influenza B, and RSV in humans
and is not intended to detect Influenza C.
Negative results do not preclude Influenza virus or RSV infection and should not be
used as the sole basis for treatment or other patient management decisions.
Conversely, positive results do not rule out bacterial infection or co-infection with
other viruses. The agent detected may not be the definite cause of disease.
Performance characteristics for Influenza A were established during the 2013-2014
and the 2014-2015 influenza seasons when Influenza A/H3 and A/H1N1 pandemic
were the predominant Influenza A viruses in circulation. When other Influenza A
viruses are emerging, performance characteristics may vary.
If infection with a novel Influenza A virus is suspected based on current clinical and
epidemiological screening criteria recommended by public health authorities,
specimens should be collected with appropriate infection control precautions for
novel virulent Influenza viruses and sent to state or local health department for
testing. Viral culture should not be attempted in these cases unless a BSL3+ facility is
available to receive and culture specimens.
RegulationSame21 CFR 866.3980
Product CodeSameOCC, OOI
Assay TargetSameInfluenza A, Influenza B, RSV
Sample TypeSameNasopharyngeal Swab
Internal ControlSameYes for sample preparation and RT-PCR performance using encapsulated RNA
Influenza A Viral
TargetSameWell conserved region of the matrix gene
Item NameSubmitted Device:
cobas® Influenza A/B & RSV w/ cobas® Influenza A/B & RSVPredicate Device: K210234
cobas® Influenza A/B & RSV w/ cobas® Influenza A/B & RSV
Influenza B Viral
TargetSameWell conserved region of the non-structural protein (NSP) gene
RSV Viral TargetSameWell conserved region of the matrix (M) gene
Assay InstrumentSamecobas® Liat® Analyzer
CORE SoftwareSamecobas® Liat® Analyzer Core Software 3.3 (K200065)
Assay Script
(FRTA)Same1.16 (K210234)
Self-contained
SystemSameYes, Integrated PC, software, and touch-screen display
All Assay
Reagents
Contained in
DisposableSameYes, no manual reagent addition required
Sample Volume
DetectionSameYes, automatically checks that input sample volume exceeds lower limit
Automated AssaySameYes, sample preparation, amplification and result interpretation
Error Diagnostic
SystemSameYes, monitors and records system parameters for error recover or abort if
unrecoverable
Extraction
MethodSameSilica-magnetic bead-based nucleic acid extraction
Assay MethodSameRT-PCR for detecting the presence/absence of viral RNA in clinical specimens
Detection
TechniqueSameMultiplex assay using different reporter dyes for each target
Result
InterpretationSameAutomated
PCR Curve
Pattern
RecognitionSameYes, ensures abnormal PCR curves are called "Invalid" or "Indeterminate"
Assay ResultSameQualitative
Item NameSubmitted Device:
cobas® Influenza A/B & RSV w/ cobas® Influenza A/B & RSVPredicate Device: K210234
cobas® Influenza A/B & RSV w/ cobas® Influenza A/B & RSV
UserSameCLIA Waived (CW1500018)
Test AvailabilitySameRandom access, on-demand test
Time-to-resultSame~20 minutes
Limit of DetectionSame10-3 – 10-1 TCID50/mL
ReactivitySameReactive against 28 Flu A, 15 Flu B, and 7 RSV strains tested
Cross ReactivitySame35 microorganisms and human genomic DNA tested. No cross reactivity found.
Interfering
MicroorganismsSame35 microorganisms and human genomic DNA tested. No effect on detection found.
Interfering
SubstancesSame10 substances tested. No effect on detection found.
ReproducibilitySame≥99.8% total percent agreement
Negative Control
BufferRoche Negative Buffer (NEG BUF) comprised of Generic Specimen
Diluent (GSD)Dilution Universal Transport Media (UTM)
Positive Control
DiluentRoche Negative Buffer (NEG BUF) comprised of Generic Specimen
Diluent (GSD)Dilution Universal Transport Media (UTM)

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4. DESCRIPTION OF CHANGE

The negative control buffer and positive control diluent provided in the cobas® Influenza A/B & RSV Quality Control Kit will be changed from Dilution Universal Transport Media (UTM) to Roche Negative Buffer (NEG BUF).

DESIGN AND DEVELOPMENT ACTIVITY SUMMARY 5.

Roche Molecular Diagnostics (RMD), Pleasanton, CA designed and developed the cobas® Influenza A/B & RSV Quality Control Kit as part of cobas® Influenza A/B & RSV nucleic acid test for use on the cobas® Liat® System. RMD in Pleasanton coordinated the development and verification of cobas® Influenza A/B & RSV at the Product Requirements, Technical Requirements and Technical Requirement Specifications (Unit Specifications) level. These activities included risk management, requirements management, configuration management, and verification testing.

ASSAY PERFORMANCE 6.

Performance of the cobas® Influenza A/B & RSV assay when used with NEG BUF as a negative control and positive control diluent was assessed. It was determined that the overall cobas® Influenza A/B & RSV assay performance claims were not impacted by the changed control material when compared to the current commercially available version of the assay and quality control kit. The change is limited to the control processing and does not affect clinical specimen testing.

7. CONCLUSION

Equivalent performance of the modified device and the current commercial device has been demonstrated, and therefore, it was concluded that the analytical and clinical performance of the product has not changed. The modified device is substantially equivalent to the predicate device, as cleared through K210234 and CLIA waived through CW150018.