K Number
K231290
Device Name
Optilite® Freelite® Kappa Free Kit, Optilite® Freelite® Lambda Free Kit
Date Cleared
2024-01-24

(265 days)

Product Code
Regulation Number
866.5550
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Optilite Freelite Kappa Free Kit is intended for the quantitative in vitro measurement of Kappa free light chains in serum using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings. The Optilite Freelite Lambda Free Kit is intended for the quantitative in vitro measurement of Lambda in serum using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenstrom's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings.
Device Description
The determination of soluble antigen concentration by turbidimetric methods involves the reaction with specific antiserum to form insoluble complexes. When light is passed through the suspension formed a portion of the light is transmitted and focused onto a photodiode by an optical lens system. The amount of transmitted light is indirectly proportional to the specific protein concentration in the test sample. Concentrations are automatically calculated by reference to a calibration curve stored within the instrument.
More Information

No
The summary describes a turbidimetric assay and an analyzer that calculates concentrations based on a stored calibration curve. There is no mention of AI, ML, or related concepts in the device description or performance studies.

No
The device is an in vitro diagnostic (IVD) test used for quantitative measurement of proteins in serum to aid in diagnosis and monitoring of various diseases, not for therapy or treatment.

Yes

The device is intended for the quantitative measurement of substances that aid in the diagnosis and monitoring of various diseases, explicitly stating its role in diagnosis.

No

The device description explicitly states it involves a physical analyser (Optilite analyser) that uses an optical lens system and photodiode to measure transmitted light, indicating it is a hardware-based device with associated software for calculation and calibration.

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 kits are intended for "quantitative in vitro measurement" of Kappa and Lambda free light chains in serum. This directly aligns with the definition of an in vitro diagnostic device, which is used to examine specimens derived from the human body to provide information for the diagnosis, prevention, or treatment of a disease or condition.
  • Measurement of Biomarkers: The device measures specific biomarkers (Kappa and Lambda free light chains) in a biological sample (serum).
  • Diagnostic and Monitoring Aid: The intended use clearly states that the measurement "aids in the diagnosis and monitoring" of various diseases and conditions.
  • Use with an Analyzer: The kits are designed to be used with a specific analyzer (Binding Site Optilite analyser), which is a common characteristic of IVD systems.
  • Clinical Performance Studies: The document includes details of clinical performance studies (Sensitivity and Specificity, Evaluation of MGUS progression) which are required for the regulatory approval of IVD devices.
  • Predicate Devices: The mention of predicate devices (K070900) further indicates that this device is being compared to other legally marketed IVDs.

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

N/A

Intended Use / Indications for Use

The Optilite Freelite Kappa Free Kit is intended for the quantitative in vitro measurement of Kappa free light chains in serum using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings.

The Optilite Freelite Lambda Free Kit is intended for the quantitative in vitro measurement of Lambda in serum using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenstrom's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings.

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

DFH, DEH

Device Description

No modification is made to the principle of operation for the Optilite® Freelite® Kappa and Lambda Free Kits cleared in K150658.

The determination of soluble antigen concentration by turbidimetric methods involves the reaction with specific antiserum to form insoluble complexes. When light is passed through the suspension formed a portion of the light is transmitted and focused onto a photodiode by an optical lens system. The amount of transmitted light is indirectly proportional to the specific protein concentration in the test sample. Concentrations are automatically calculated by reference to a calibration curve stored within the instrument.

Materials provided in the Optilite Freelite Kappa Free kit:

  • Optilite Kappa Free Reagent
  • Optilite Kappa Free Calibrator ●
  • Optilite Kappa Free High Control ●
  • Optilite Kappa Free Low Control ●

Materials provided in the Optilite Freelite Lambda Free kit:

  • Optilite Lambda Free Reagent
  • Optilite Lambda Free Calibrator
  • Optilite Lambda Free High Control ●
  • Optilite Lambda Free Low Control

Reagents composition:

  • . Latex Reagent: Consisting of polyclonal monospecific antibody coated onto polystyrene latex. Supplied in stabilised liquid form. Preservatives: 0.1% E-amino-n-caproic acid (EACA) and 0.01% benzamidine, 0.05% ProClin.
  • . Calibrator and Controls: Pooled human serum, supplied in stabilised liquid form. Containing 0.099% sodium azide, 0.1% EACA and 0.01% benzamidine as preservatives.
  • Reaction Buffer: Containing 0.099% sodium azide as a preservative. ●

Note: In Optilite Freelite kits, the latex reagent and reaction buffer are supplied in a single wedge with a chamber for each fluid. They are therefore labelled as a single component Optilite Kappa Free Reagent or Optilite Lambda Free Reagent.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

This assay has not been established for use with the paediatric population.

Intended User / Care Setting

Prescription Use (Part 21 CFR 801 Subpart D)

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

For Study 1 (Sensitivity and Specificity):
Sensitivity
A retrospective study was performed using a total of 234 MGUS samples from patients with clinically confirmed MGUS. The clinical diagnostic criteria that the clinicians used to establish the clinical truth of all samples included in the study as 'MGUS positive' was confirmed with each site. The diagnostic criteria and classification for MGUS and related plasma-cell disorders, as practiced clinically, fulfilled, but was not limited to, the criteria outlined by the 'International Myeloma Working Group (IMWG)' consensus. The diagnostic criteria in the clinical study are aligned with actual clinical practices widely accepted and used in the U.S. for the target patient population. Samples were tested for free light chain (FLC) kappa and lambda levels with the Optilite Freelite Kappa and Lambda Free kits on the Optilite Analyser. The kappa:lambda ratios were calculated for each sample. The result of the device was compared to the clinical diagnosis for each sample.

Specificity
A retrospective study was performed using a total of 140 samples. These samples were from patients with polyclonal hypergammaglobulinemia confirmed by study testing (total IgG/IgA/IgM and serum IFE), with supporting clinical information for example, diagnosis of hepatitis, systemic lupus erythematosus. Samples were tested for free light chain (FLC) kappa and lambda levels with the Optilite Freelite Kappa and Lambda Free kits on the Optilite Analyser. The kappa:lambda ratios were calculated for each sample. The result of the device was compared to the clinical truth for each sample.

For Study 2 (Evaluation of MGUS progression):
Another retrospective study was performed using a total of 185 samples from 49 MGUS patients with clinically determined stable or progressive status. Up to 4 individual sample draws, taken at various time intervals, were tested from each patient for the stable cohort and up to 6 for the progressive MGUS cohort. All samples were tested for free light chain (FLC) kappa and lambda levels with the Optilite Freelite Kappa and Lambda Free kits on the Optilite analyser. The kappa:lambda ratios were calculated for each sample. The result of the device was compared to the clinical diagnosis for each sample. The study population consisted of 45 patients with clinically stable MGUS diagnosis (stable cohort) and 4 patients that demonstrated a progressive clinical status by converting from MGUS to MM (progressive cohort).

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

Study 1: Clinical Performance: Sensitivity and Specificity

  • Sensitivity (Freelite Kappa:Lambda Ratio Sensitivity in MGUS)
    • Study type: Retrospective study.
    • Sample size: 234 MGUS samples from patients with clinically confirmed MGUS.
    • Key Results:
      • Obtained Sensitivity: 59.4% [95% CI: 53.0 - 65.5] for all MGUS positive.
      • Light chain MGUS (N=12): 100.0% [95% CI: 75.8 - 100].
      • Non-light chain only MGUS (N=222): 57.2% [95% CI: 50.6 - 63.5].
      • Pre-defined acceptance criterion for sensitivity (at least 30%) was met.
      • MGUS isotype specific sensitivity shown in Table 3 (e.g., IgG κ: 70.3% >1.65, 30.6%

§ 866.5550 Immunoglobulin (light chain specific) immunological test system.

(a)
Identification. An immunoglobulin (light chain specific) immunological test system is a device that consists of the reagents used to measure by immunochemical techniques both kappa and lambda types of light chain portions of immunoglobulin molecules in serum, other body fluids, and tissues. In some disease states, an excess of light chains are produced by the antibody-forming cells. These free light chains, unassociated with gamma globulin molecules, can be found in a patient's body fluids and tissues. Measurement of the various amounts of the different types of light chains aids in the diagnosis of multiple myeloma (cancer of antibody-forming cells), lymphocytic neoplasms (cancer of lymphoid tissue), Waldenstrom's macroglobulinemia (increased production of large immunoglobulins), and connective tissue diseases such as rheumatoid arthritis or systemic lupus erythematosus.(b)
Classification. Class II (performance standards).

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January 24, 2024

The Binding Site Ltd. Jolanta Wolff Regulatory Affairs Project Manager 8 Calthorpe Road Birmingham, Edgbaston B15 1QT United Kingdom

Re: K231290

Trade/Device Name: Optilite Freelite Kappa Free Kit Optilite Freelite Lambda Free Kit Regulation Number: 21 CFR 866.5550 Regulation Name: Immunoglobulin (light chain specific) immunological test system Regulatory Class: Class II Product Code: DFH, DEH Dated: December 21, 2023 Received: December 22, 2023

Dear Jolanta Wolff:

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

1

2

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 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,

Ying Mao -S

Ying Mao, Ph.D. Branch Chief Division of Immunology and Hematology Devices OHT7: Office of In Vitro Diagnostics Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K231290

Device Name Optilite Freelite Kappa Free Kit Optilite Freelite Lambda Free Kit

Indications for Use (Describe)

The Optilite Freelite Kappa Free Kit is intended for the quantitative in vitro measurement of Kappa free light chains in serum using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings.

The Optilite Freelite Lambda Free Kit is intended for the quantitative in vitro measurement of Lambda in serum using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenstrom's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted 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 (as per 21 CFR 807.92)

This 510(k) Summary of Safety and Effectiveness information is being submitted in accordance with the requirements of the Safe Medical Device Act 1990 and 21 CFR 807.92.

510(k) Number:K231290
Type of 510(k):Original, Traditional 510(k)
Purpose of Submission:Modification to a previously cleared device
Date of Preparation:26 April 2023, revised on 23rd January 2024

1 SUBMITTER/APPLICANT:

The Binding Site Ltd 8 Calthorpe Road, Edgbaston, Birmingham, B15 1QT, GB

Correspondent/ Contact:Jolanta Wolff, MBA
Regulatory Affairs Project Manager
Phone:+44 121 456 9500

2 DEVICE INFORMATION:

| Proprietary Name: | Optilite® Freelite® Kappa Free Kit
Optilite® Freelite® Lambda Free Kit |
|-------------------|---------------------------------------------------------------------------|
| Measurand: | Kappa (κ) free light chains (FLC)
Lambda (λ) free light chains (FLC) |
| Type of Test: | Quantitative, immunoturbidimetry |

Regulatory information:

| Regulation section: | 21 CFR 866.5550, Immunoglobulin (light chain specific)
immunological test system |
|---------------------|-------------------------------------------------------------------------------------|
| Classification: | Class II |
| Product Code(s): | DFH - Kappa antigen, antiserum, control
DEH - Lambda antigen, antiserum, control |
| Review Panel: | IM - Immunology (82) |

4

3 PREDICATE DEVICES AND 510(k) NUMBERS

Freelite Human Kappa Free Kit for use on Roche Cobas Integra 400/400 plus - K070900 Freelite Human Lambda Free Kit for use on Roche Cobas Integra 400/400 plus - K070900

ব DEVICE DESCRIPTION

Test Principle 4.1

No modification is made to the principle of operation for the Optilite® Freelite® Kappa and Lambda Free Kits cleared in K150658.

The determination of soluble antigen concentration by turbidimetric methods involves the reaction with specific antiserum to form insoluble complexes. When light is passed through the suspension formed a portion of the light is transmitted and focused onto a photodiode by an optical lens system. The amount of transmitted light is indirectly proportional to the specific protein concentration in the test sample. Concentrations are automatically calculated by reference to a calibration curve stored within the instrument.

4.2 Special conditions for use statement(s):

Prescription use only.

The kappa free light chain results for a given specimen determined with assays from different manufacturers or on different systems can vary due to differences in assay methods and reagent specificity. The results reported by the laboratory to the physician must include the identity of the kappa free light chain assay used. Values obtained with different assays or systems cannot be used interchangeably. If, in the course of serially monitoring a patient, the assay or system used for determining kappa free light chain levels is changed, additional sequential testing should be carried out. Prior to changing assay or system, the laboratory MUST confirm baseline values for patients being serially monitored.

Interpretation of results:

Guidelines and consensus recommendations for the diagnosis and monitoring of multiple myeloma and AL amyloidosis have been published by the International Myeloma Working Group (IMWG) and National Cancer Comprehensive Network (NCCN). Evaluation of patients with MGUS is also included in guidelines published by IWMWG and NCCN. These include FLC testing, with the reference values for FLC based on Freelite® assay results. Guidelines are included in the product IFU bibliography; however, clinicians should refer to the most current versions available as they may be updated.

Limitations:

· Turbidimetric assays are not suitable for measurement of highly lipaemic or haemolyzed samples or samples containing high levels of circulating immune complexes (CICs) due to the unpredictable degree of non-specific scatter these sample types may generate. Unexpected results should be confirmed using an alternative assay method.

5

· Diagnosis cannot be made and treatment must not be given on the basis of kappa free light chain measurements alone. Clinical history and other laboratory findings must be taken into account.

· This assay has not been established for use with the paediatric population.

4.3 Special Instrument requirements

Optilite® Analyser

4.4 Kit Reagents and composition

The devices in this submission have not materially changed since originally cleared under K150658.

Materials provided in the Optilite Freelite Kappa Free kit:

  • Optilite Kappa Free Reagent
  • Optilite Kappa Free Calibrator ●
  • Optilite Kappa Free High Control ●
  • Optilite Kappa Free Low Control ●

Materials provided in the Optilite Freelite Lambda Free kit:

  • Optilite Lambda Free Reagent
  • Optilite Lambda Free Calibrator
  • Optilite Lambda Free High Control ●
  • Optilite Lambda Free Low Control

Reagents composition:

  • . Latex Reagent: Consisting of polyclonal monospecific antibody coated onto polystyrene latex. Supplied in stabilised liquid form. Preservatives: 0.1% E-amino-n-caproic acid (EACA) and 0.01% benzamidine, 0.05% ProClin.
  • . Calibrator and Controls: Pooled human serum, supplied in stabilised liquid form. Containing 0.099% sodium azide, 0.1% EACA and 0.01% benzamidine as preservatives.
  • Reaction Buffer: Containing 0.099% sodium azide as a preservative. ●

Note: In Optilite Freelite kits, the latex reagent and reaction buffer are supplied in a single wedge with a chamber for each fluid. They are therefore labelled as a single component Optilite Kappa Free Reagent or Optilite Lambda Free Reagent.

5 INTENDED USE/ INDICATIONS FOR USE:

5.1 Intended use:

Same as Same as indications for use.

6

5.2 Indications for use:

The Optilite® Freelite® Kappa Free Kit is intended for the quantitative in vitro measurement of Kappa free light chains in serum using the Binding Site Optilite® analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings.

The Optilite® Freelite® Lambda Free Kit is intended for the quantitative in vitro measurement of Lambda free light chains in serum using the Binding Site Optilite® analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE), and aids in the evaluation of monoclonal gammopathy of undetermined significance (MGUS). Results of the free light chain measurements should always be interpreted in conjunction with other laboratory and clinical findings.

5.3 Summary and Explanation:

Immunoglobulin molecules consist of two identical heavy chains (α, μ, γ, δ οι ε) which define the immunoglobulin class and two identical light chains (к ог λ). Each light chain is covalently linked to a heavy chain and the two heavy chains are linked covalently at the hinge region. In healthy individuals, the majority of light chain in serum exists in this form, bound to heavy chain. However, low levels of free light chain (FLC) are found in serum of normal individuals due to the over-production and secretion of FLC by the plasma cells. Whilst the molecular weight of both light chains is ≈22.5kD, in serum κ free light chain

(к-FLC) exists predominantly as monomer and λ free light chain (λ-FLC) as a covalently linked dimer with a molecular weight of ≈45kD. This will lead to a differential glomerular filtration rate for к-FLC and λ-FLC and may explain the observed ratio of к-FLC to λ-FLC of 0.625 in serum compared to the ratio of bound κ to λ of 2.0.

Elevated serum levels of monoclonal FLC are associated with malignant plasma cell proliferation (e.g. multiple myeloma), AL amyloidosis and, light chain deposition disease and MGUS. Raised serum levels of polyclonal FLC may be associated with autoimmune diseases such as SLE.

6 TECHNOLOGICAL CHARACTERISTICS:

Both the subject and predicate devices contain the same intended use with respect to the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE). The purpose of this submission is to extend these claims to add an aid in evaluation of Monoclonal Gammopathy of Undetermined Significance (MGUS) to the intended use of the Optilite® Freelite® Kappa and Lambda Free Kits. Although, the predicate devices cited in this submission do not contain the evaluation of

7

MGUS claim in their instructions for use, such is supported by the body of peer revied literature as relevant extension to the clinical application of the Freelite assays; and it is considered appropriate to support the determination of substantial equivalence with an assessment of clinical performance study. Refer to section 6.3 for the summary of the clinical performance study pertinent to the MGUS extension of the extension of the clinical claims for the Optilite® Freelite® Kappa and Lambda Free Kits does not affect the safety and effectiveness of the devices relative to the predicate.

Similarities and Differences to the Predicate: 6.1

A comparison of the similarities and differences between the proposed Optilite Freelite Kappa and Lambda Free Kits and the predicate Freelite Human Kappa and Lambda Free Diagnostic test Kits for use on Roche Cobas Integra 400/400 plus, provided in Table 1 as follows:

Similarities
Item(Proposed Device)
Optilite Freelite Kappa and Lambda Free Kits
(K150658)(Predicate Device)
Freelite Human Kappa and Lambda
Free Kits for use on Roche Cobas
Integra 400/400 plus
(K070900)
Assay typeQuantitativesame
Test methodTurbidimetrysame
Detection antibodyKappa:
Polyclonal sheep anti-human Kappa antibody
coated onto latex particles
Lambda:
Polyclonal sheep anti-human Lambda antibody
coated onto latex particlessame
Open Vial Stability3 monthssame
Adult Reference
IntervalKappa: 3.30 - 19.40mg/L
Lambda: 5.71-26.30mg/L
Ratio: 0.26 - 1.65mg/Lsame
Specimen TypeSerumsame
Calibrator
TraceabilityInternal Reference Master Calibratorsame
Sample dilutions
(Kappa)1+1, 1+9, 1+99, 1+999, 1+4999same
(First 4 dilutions only)
Sample dilutions
(Lambda)1+1, 1+7, 1+79, 1+799, 1+7999same
Measuring range
(Kappa)0.6 - 25.3mg/L (1+1)
2.9 - 127mg/L (1+9)
29 - 1270mg/L (1+99)
290 - 12700mg/L (1+999)
1450 - 63500mg/L (1+4999)same
(First 4 dilutions only)
Measuring range
(Lambda)1.3 - 34.7mg/L (1+1)
5.2 - 139mg/L (1+7)
52 - 1390mg/L (1+79)
520 - 13900mg/L (1+799)
5200 - 139000mg/L (1+7999)same

Table 1. Technological similarities and differences.

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Differences
Item(Proposed Device)
Optilite Freelite Kappa and Lambda Free Kits
(K150658)(Predicate Device)
Freelite Human Kappa and Lambda Free
Kits for use on Roche Cobas Integra
400/400 plus
(K070900)
Intended useKappa:
The Optilite Freelite Kappa Free Kit is intended for
the quantitative in vitro measurement of Kappa free
light chains in serum using the Binding Site Optilite
analyser. Measurement of free light chains aids in
the diagnosis and monitoring of multiple myeloma,
lymphocytic neoplasms, Waldenström's
macroglobulinaemia, AL amyloidosis, light chain
deposition disease and connective tissue diseases
such as systemic lupus erythematosus (SLE), and
aids in the evaluation of monoclonal gammopathy
of undetermined significance (MGUS). Results of
the free light chain measurements should always
be interpreted in conjunction with other laboratory
and clinical findings.
Lambda:Kappa:
This kit is intended for the quantitation of
kappa free light chains in serum on the
Roche Cobas Integra 400, 400plus and
  1. Measurement of free light chains aids
    in the diagnosis and monitoring of multiple
    myeloma, lymphocytic neoplasms,
    Waldenström's macroglobulinemia, AL
    amyloidosis, light chain deposition disease
    and connective tissue diseases such as
    systemic lupus erythematosus in
    conjunction with other laboratory and
    clinical findings.
    Lambda: |
    | | The Optilite Freelite Lambda Free Kit is intended
    for the quantitative in vitro measurement of Lambda
    free light chains in serum using the Binding Site
    Optilite analyser. Measurement of free light chains
    aids in the diagnosis and monitoring of multiple
    myeloma, lymphocytic neoplasms, Waldenström's
    macroglobulinaemia, AL amyloidosis, light chain
    deposition disease and connective tissue diseases
    such as systemic lupus erythematosus (SLE), and
    aids in the evaluation of monoclonal gammopathy
    of undetermined significance (MGUS). Results of
    the free light chain measurements should always
    be interpreted in conjunction with other laboratory
    and clinical findings. | This kit is intended for the quantitation of
    Lambda free light chains in serum on the
    Roche
    Cobas Integra 400 / 400plus and 800.
    Measurement of free light chains aids in the
    diagnosis and monitoring of multiple
    myeloma, lymphocytic neoplasms,
    Waldenström's macroglobulinemia, AL
    amyloidosis, light chain deposition disease
    and connective tissue diseases such as
    systemic lupus erythematosus in
    conjunction with other laboratory and
    clinical findings. |
    | On-board
    stability | 30 days | 3 months |
    | Instrument | Optilite analyser | Roche Cobas Integra |
    | Top
    Dilution
    (Kappa) | 1+4999 | 1+4999 |
    | Measuring
    range (Kappa) | (Top Dilution)
    1450 - 63500mg/L (1+4999) | (Top Dilution)
    2900 - 127000mg/L (1+4999) |

This submission is to add a claim for evaluation of MGUS to the intended use statement. The differences between the predicate and proposed device do not result in a change to the safety and efficacy when used according to the product labeling.

6.2 Performance Data:

Performance characteristics data is provided for the extended indication for evaluation of Monoclonal Gammopathy of Undetermined Significance (MGUS). Refer to submission K150658 for previously documented analytical performance studies:

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  • Precision/Reproducibility
  • Linearity/assay reportable range ●
  • Traceability
  • Stability
  • Detection Limit
  • Analytical Specificity / Interferences
  • Antigen excess/Prozone detection
  • Reference Interval/ Expected values, and clinical cut off ●
  • Method Comparison studies with predicate device which included samples with ● relevant admission diagnosis to the intended use (including multiple myeloma, Waldenström's Macroglobulinemia, lymphocytic neoplasms and systemic lupus erythematosus).

6.3 Performance data for evaluation of Monoclonal Gammopathy of Undetermined Significance (MGUS)

MGUS is a plasma cell dyscrasia characterised by the presence of a monoclonal protein (Mprotein) in the serum of asymptomatic individuals who do not meet the diagnostic criteria for multiple myeloma (MM), AL amyloidosis, Waldenström's macroglobulinaemia (WM), lymphoproliferative disorders, plasmacytoma or related conditions. [1]

The expansion of the claims to add an aid in the evaluation of Monoclonal Gammopathy of Undetermined Significance (MGUS) to the Optilite Freelite Kappa and Lambda Free Kits is supported by the body of peer reviewed literature and investigated in the retrospective clinical performance studies carried out by The Binding Site Ltd.

The clinical performance studies included retrospective testing of residual samples from patients with clinically confirmed MGUS and from disease control subjects (non-MGUS patients) with the Optilite® Freelite® Kappa Free Kit, and the Optilite® Freelite® Lambda Free Kit, and assessing the concordance of the test results with the clinical truth of the patient. The testing investigated the clinical/diagnostic performance (sensitivity and specificity) of Freelite test results in MGUS and disease controls (non-MGUS) at single time points (Study 1); and the monitoring performance of Freelite test results measured on serial samples from patients with stable and progressive MGUS (Study 2).

6.3.1 Clinical Performance: Sensitivity and Specificity (Study 1)

6.3.1.1 Sensitivity

Freelite Kappa:Lambda Ratio Sensitivity in MGUS

A retrospective study was performed using a total of 234 MGUS samples from patients with clinically confirmed MGUS. The clinical diagnostic criteria that the clinicians used to establish the clinical truth of all samples included in the study as 'MGUS positive' was confirmed with each site. The diagnostic criteria and classification for MGUS and related plasma-cell disorders, as practiced clinically, fulfilled, but was not limited to, the criteria outlined by the 'International Myeloma Working Group (IMWG)' consensus. The diagnostic criteria in the

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clinical study are aligned with actual clinical practices widely accepted and used in the U.S. for the target patient population. All samples were tested for free light chain (FLC) kappa and lambda levels with the Optilite Freelite Kappa and Lambda Free kits on the Optilite Analyser. The kappa:lambda ratios were calculated for each sample. The result of the device was compared to the clinical diagnosis for each sample.

Results have been categorized as clinical positive based on the clinical diagnosis and evaluated as test positive and negative based on the results of the Freelite testing performed during the study. The test result for MGUS positive or negative were based on the following definitions:

  • · Test positive (Freelite Positive = Abnormal): FLC kappa:lambda ratio was outside the reference interval (0.26-1.65) for intact immunoglobulin MGUS; the FLC kappa:lambda ratio was outside the reference interval (0.26-1.65) and the involved FLC level was above the reference interval (kappa 3.30-19.40 mg/L and lambda 5.71-26.30 mg/L) for LC-MGUS.
  • · Test negative (Freelite Negative = Normal): FLC kappa:lambda ratio was within the reference interval (0.26-1.65).

Light chain MGUS (LC-MGUS), is a subset of MGUS in which the monoclonal protein produced consists of only immunoglobulin free light chains. The published definition of LC-MGUS is "an abnormal FLC ratio with complete lack of IgH expression, plus elevation in the appropriate involved FLC" [2], and was evaluated as part of this study to demonstrate the capability of the Freelite Kappa and Lambda Free assays to detect this subgroup of MGUS patients.

Sensitivity with 95% confidence interval has been summarized in Table 2 below:

| Disease group | N = | Obtained Sensitivity (%) [95%
CI] |
|------------------------------|-----|--------------------------------------|
| All MGUS positive | 234 | 59.4
[53.0 - 65.5] |
| Light chain MGUS | 12 | 100.0
[75.8 - 100] |
| Non-light chain only
MGUS | 222 | 57.2
[50.6 - 63.5] |

Table 2. Summary Table - Freelite kappa:lambda Ratio Sensitivity.

The pre-defined acceptance criterium for sensitivity in MGUS was set to at least 30 % which was met:

  • · The calculated sensitivity for all MGUS samples in the study was 59.4% (95% C1: 53.0 -65.5%). This was the % of all MGUS samples determined as positive based on Optilite Freelite FLC testing, i.e., show a FLC kappa:lambda ratio outside the reference interval (0.26-1.65) for intact immunoglobulin MGUS; or a FLC kappa:lambda ratio outside the reference interval (0.26-1.65) with the involved FLC level above the reference interval

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(kappa 3.30-19.40 mg/L and lambda 5.71-26.30 mg/L) for LC-MGUS.

  • · The sensitivity for the 12 LC-MGUS samples was 100% (95% CI: 75.8 100%).
  • The sensitivity for the 222 non-LC-MGUS samples was 50.6% (95% CI: 50.6 63.5%).

Freelite Kappa:Lambda Ratio sensitivity in MGUS by isotype

The cohort of 234 MGUS samples included: 174 non-IgM MGUS, 24 biclonal,12 light chain MGUS. The distribution of the cohort with confirmed M component isotype in MGUS samples and the number and percentage of test positive samples are summarised in Table 3 as follows:

| MGUS Isotype, number in study and abnormal by Freelite®

MGUS typeNn (n/N%) Freelite positive
Non-IgM MGUS (all)174101 (58.0%)
IgG κ7452 (70.3%) >1.65
19 (30.6%) 1.65
24 (38.7%) total FLC abnormal
IgA κ2115 (71.4%) >1.65
1 (4.8%) 1.65
IgM λ51 (20.0%) 1.65
16 (66.7%) total abnormal
Total234139 (59.4%)

Table 3. MGUS isotype, number in study and abnormal by Freelite®.

  • These samples have been categorized as non-IgM MGUS based on associated IFE and FLC results generated for these samples.

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6.3.1.2 Specificity

Freelite Kappa:Lambda Ratio Specificity in Disease Controls (non-MGUS)

A retrospective study was performed using a total of 140 samples. These samples were from patients with polyclonal hypergammaglobulinemia confirmed by study testing (total IgG/lgA/lgM and serum IFE), with supporting clinical information for example, diagnosis of hepatitis, systemic lupus erythematosus. All samples were tested for free light chain (FLC) kappa and lambda levels with the Optilite Freelite Kappa and Lambda Free kits on the Optilite Analyser. The kappa:lambda ratios were calculated for each sample. The result of the device was compared to the clinical truth for each sample.

A specificity of 86.4% (95% Cl: 79.8 – 91.1) for non-MGUS samples was determined: refer to Table 4 as follows:

Table 4. Freelite kappa:lambda Ratio Specificity.
Disease groupN =Obtained Specificity (%) [95% CI]
Disease Controls
(Non-MGUS)14086.4
[79.8 - 91.1]

The pre-defined acceptance criterium for specificity for non-MGUS study was set to at least 85 % which was met:

  • · The calculated specificity for the disease controls (non-MGUS samples) in the study was 86.4% (95% CI: 79.8 - 91.1%). This was the percentage of disease control samples determined as negative based on Optilite Freelite FLC testing, i.e., demonstrate an FLC kappa:lambda ratio within the reference interval (0.26-1.65).

Evaluation of MGUS progression (Study 2) 6.3.2

Another retrospective study was performed using a total of 185 samples from 49 MGUS patients with clinically determined stable or progressive status. Up to 4 individual sample draws, taken at various time intervals, were tested from each patient for the stable cohort and up to 6 for the progressive MGUS cohort. All samples were tested for free light chain (FLC) kappa and lambda levels with the Optilite Freelite Kappa and Lambda Free kits on the Optilite analyser. The kappa:lambda ratios were calculated for each sample. The result of the device was compared to the clinical diagnosis for each sample. The study population consisted of 45 patients with clinically stable MGUS diagnosis (stable cohort) and 4 patients that demonstrated a progressive clinical status by converting from MGUS to MM (progressive cohort).

Evaluation criteria: There are no published guidelines relating to the interpretation of consecutive FLC results for MGUS patients. Therefore, for the purpose of the device evaluation only, results were evaluated as stable and progressive MGUS based on the clinical diagnosis provided with the samples and Optilite Freelite FLC testing performed during the study, per definitions as follows:

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  • FLC stable: Stable MGUS defined as 1.65 |
    | IgG λ | 14 | 5 (35.7%) 1.65 |
    | IgA λ | 3 | 0 (0%) 1.65 |
    | IgM λ | 2 | 0 (0%) 1.65
    0 (0%)