K Number
K232092
Date Cleared
2023-11-14

(124 days)

Product Code
Regulation Number
866.3130
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Great Basin Toxigenic C. difficile Direct Test, performed on the Great Basin PA500 Analyzer, is a qualitative in vitro diagnostic test for the detection of toxigenic Clostridioides difficile in unformed (liquid or soft) stool samples collected from patients suspected of having C. difficile infection (CDI). The automated assay utilizes polymerase chain reaction (PCR) to detect a conserved region of the toxin gene (tcdB) associated with toxin-producing C. difficile.

The Toxigenic C. difficile Direct Test is intended for use as an aid in the diagnosis of CDI in conjunction with clinical and epidemiological risk factors.

Device Description

The Great Basin Toxigenic C. difficile Direct Test (CDF2) performed on the PA500 Analyzer utilizes automated, hot-start PCR amplification technology to amplify specific nucleic acid sequences that are then detected using hybridization probes immobilized on a modified silicon chip surface, in a single-use, self-contained test cartridge.

A swab volume of the specimen (raw stool) is first processed using the Sample Preparation Device (SPD). During processing through the SPD the specimen is infused with a synthetic bacterial sample processing control (SPC). An aliquot (250 µL) of the eluate obtained from the SPD, containing diluted specimen mixed with SPC, is loaded into the sample port of the CDF2 Test Cartridge.

Genomic DNA is extracted from microbial cells and diluted to reduce potential inhibitors of PCR. During the PCR process, biotin-labeled primers direct the amplification of specific nucleic acid sequences within a conserved region of the C. difficile Toxin B (tcdB) gene.

Following PCR, biotin-labeled, amplified target DNA sequences are hybridized to sequence specific probes immobilized on the silicon chip surface and incubated with antibody conjugated to the horseradish peroxidase enzyme (HRP). The unbound conjugate is washed away, and then tetramethylbenzidine (TMB) is added to produce a colored precipitate at the location of the probe/target sequence complex.

The resulting signal is detected by the automated PA500 Optical Reader within the PA500 Analyzer System. The SPC undergoes the same extraction, and detection steps as the sample in order to monitor for inhibitory substances, as well as process inefficiency due to instrument or reagent failure. No operator intervention is required once the sample is loaded into the sample port and the Toxigenic C. difficile Direct Test cartridge is loaded into the PA500 Analyzer.

The Great Basin System is a fully automated in vitro diagnostic system that includes: the PA500 Analyzer, single-use SPDs, single-use Toxigenic C. difficile Direct Test Cartridges, and the PA500 Data Analysis Software Program. The PA500 Analyzer is designed to perform automated sample preparation, target amplification via PCR, chip-based (optical) target detection, and integrated data analysis in less than two hours.

AI/ML Overview

The Great Basin Toxigenic C. difficile Direct Test (CDF2) is a qualitative in vitro diagnostic test designed to detect toxigenic Clostridioides difficile in unformed stool samples from patients suspected of CDI. The device utilizes PCR to detect a conserved region of the toxin B gene (tcdB).

The study that proves the device meets the acceptance criteria is a prospective multi-center method comparison study (section H. Performance Data - Clinical Studies, page 12).

Here's a breakdown of the requested information:

1. Table of Acceptance Criteria and Reported Device Performance

The acceptance criteria are not explicitly stated as numerical targets in the provided text. However, the study aims to demonstrate "acceptable performance" and states that the "information submitted...supports substantial equivalence." Based on the clinical performance, the implicit acceptance criteria would involve high positive and negative percent agreements with an FDA-cleared molecular reference.

MetricAcceptance Criteria (Implicit)Reported Device Performance (All Sites Combined)
Positive Percent Agreement (PPA)High agreement with reference95.8% (91.2% - 98.5% CI)
Negative Percent Agreement (NPA)High agreement with reference98.5% (97.3% - 99.3% CI)

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

  • Sample Size (Clinical Test Set): A total of 829 specimens were included in the final dataset (page 12).
  • Data Provenance: The study was conducted at three geographically diverse U.S. clinical study sites (Midwest, West). The data is prospective, as specimens were collected from symptomatic individuals suspected of CDI between June 2022 and February 2023 (page 12). The specimens were "excess remnants of unpreserved stool specimens...processed according to routine standard of care testing, and would have otherwise been discarded" (page 12).

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

The ground truth for the clinical test set was established using an FDA-cleared molecular reference (page 12), not human experts. Discrepant results were investigated by testing on a third molecular test (page 14). Therefore, no human experts were directly involved in establishing the primary ground truth for the clinical samples.

4. Adjudication Method for the Test Set

The adjudication method for discrepant results was comparison to a third FDA-cleared molecular C. difficile test (page 14). If the CDF2 test result differed from the initial molecular comparator, the specimen was re-tested using a third molecular test to resolve the discrepancy.

5. If a Multi Reader Multi Case (MRMC) Comparative Effectiveness Study was done

No, an MRMC comparative effectiveness study was not done. The study compares the device performance against a molecular reference, not human readers.

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

Yes, this was a standalone study. The device is an automated in vitro diagnostic test where "No operator intervention is required once the sample is loaded into the sample port and the Toxigenic C. difficile Direct Test cartridge is loaded into the PA500 Analyzer" (page 4). The performance metrics (PPA, NPA) directly reflect the device's accuracy against a molecular comparator without human interpretation of the results.

7. The Type of Ground Truth Used

The primary ground truth for the clinical study was an FDA-cleared molecular reference (page 12). For discrepant samples, a third FDA-cleared molecular C. difficile test was used for resolution (page 14).

8. The Sample Size for the Training Set

The document does not explicitly state a separate training set or its size for the algorithm itself. The studies described are primarily analytical (LoD, inclusivity, exclusivity, interference, reproducibility) and a clinical validation study. These types of in vitro diagnostic device submissions typically focus on analytical and clinical performance rather than a distinct "training set" for an AI algorithm in the same sense as image recognition or similar machine learning applications. The device's "automated data analysis software program" (page 4) is part of its design, and its performance is evaluated through the described analytical and clinical studies.

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

As no specific "training set" is described for an AI algorithm, the method for establishing its ground truth is not detailed. However, the performance is established through rigorous analytical studies using characterized microbial strains and spiked samples (e.g., cell cultures with known CFU/mL) and clinical specimens compared to a molecular reference.

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

November 14, 2023

Vela Operations USA Larry Rea Chief Operating Officer 2441 South 3850 West Salt Lake City, Utah 84120

Re: K232092

Trade/Device Name: Great Basin Toxigenic C. difficile Direct Test (CDF2) Regulation Number: 21 CFR 866.3130 Regulation Name: Clostridium Difficile Toxin Gene Amplification Assay Regulatory Class: Class II Product Code: OZN Dated: July 5, 2023 Received: July 13, 2023

Dear Larry Rea:

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 (the 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 available at https://www.accessdata.fda.gov/scripts/cdrb/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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

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Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safetyreporting-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 mediation-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.

Natasha Griffin -S

0.B.O. Ribhi Shawar, Ph.D. (ABMM) Branch Chief General Bacteriology and Antimicrobial Susceptibility Branch Division of Microbiology Devices OHT7: Office of In Vitro Diagnostics 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) K232092

Device Name

Great Basin Toxigenic C. difficile Direct Test (CDF2)

Indications for Use (Describe)

The Great Basin Toxigenic C. difficile Direct Test, performed on the Great Basin PA500 Analyzer, is a qualitative in vitro diagnostic test for the detection of toxigenic Clostridioides difficile in unformed (liquid or soft) stool samples collected from patients suspected of having C. difficile infection (CDI). The automated assay utilizes polymerase chain reaction (PCR) to detect a conserved region of the toxin gene (tcdB) associated with toxin-producing C. difficile.

The Toxigenic C. difficile Direct Test is intended for use as an aid in the diagnosis of CDI in conjunction with clinical and epidemiological risk factors

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 - TOXIGENIC C. DIFFICILE DIRECT TEST

A. Submitted By

Vela Operations USA 2441 South 3850 West Salt Lake City, Utah 84120

Contact Information

Larry Rea Chief Operating Officer Vela Operations USA (DBA Great Basin Scientific)

B. Name of Device

Proprietary Name: Great Basin Toxigenic C. difficile Direct Test Common or Usual Names: Toxigenic C. difficile Direct Test CDF2

C. Requlatory Information:

  • a. Requlation: 21 CFR 866.3130 - Clostridium difficile toxin gene amplification assay
  • b. Classification: Class II (Toxigenic C. difficile Direct Test; non-exempt) Class II (PA500 Analyzer System)
  • Microbiology (83) c. Panel:
  • OZN C. difficile Toxin Gene Amplification Assay Product Code: ರ

D. Intended use(s)/Indications for Use

The Great Basin Toxigenic C. difficile Direct Test, performed on the Great Basin PA500 Analyzer, is a qualitative in vitro diagnostic test for the detection of toxigenic Clostridioides difficile in unformed (liguid or soft) stool samples collected from patients suspected of having C. difficile infection (CDI). The automated assay utilizes polymerase chain reaction (PCR) to detect a conserved region of the toxin gene (tcdB) associated with toxin producing C. difficile.

The Toxigenic C. difficile Direct Test is intended for use as an aid in the diagnosis of CDI in conjunction with clinical and epidemiological risk factors.

E. Device Description

Test Principle:

The Great Basin Toxigenic C. difficile Direct Test (CDF2) performed on the PA500 Analyzer utilizes automated, hot-start PCR amplification technology to amplify specific nucleic acid sequences that are then detected using hybridization probes immobilized on a modified silicon chip surface, in a single-use, self-contained test cartridge.

A swab volume of the specimen (raw stool) is first processed using the Sample Preparation Device (SPD). During processing through the SPD the specimen is infused with a synthetic bacterial sample processing control (SPC). An aliquot (250 µL) of the eluate obtained from the SPD, containing diluted specimen mixed with SPC, is loaded into the sample port of the CDF2 Test Cartridge.

Genomic DNA is extracted from microbial cells and diluted to reduce potential inhibitors of PCR. During the PCR process, biotin-labeled primers direct the amplification of specific nucleic acid sequences within a conserved region of the C. difficile Toxin B (tcdB) gene.

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Following PCR, biotin-labeled, amplified target DNA sequences are hybridized to sequence specific probes immobilized on the silicon chip surface and incubated with antibody conjugated to the horseradish peroxidase enzyme (HRP). The unbound conjugate is washed away, and then tetramethylbenzidine (TMB) is added to produce a colored precipitate at the location of the probe/target sequence complex.

The resulting signal is detected by the automated PA500 Optical Reader within the PA500 Analyzer System. The SPC undergoes the same extraction, and detection steps as the sample in order to monitor for inhibitory substances, as well as process inefficiency due to instrument or reagent failure. No operator intervention is required once the sample is loaded into the sample port and the Toxigenic C. difficile Direct Test cartridge is loaded into the PA500 Analyzer.

Test Device:

The Great Basin System is a fully automated in vitro diagnostic system that includes: the PA500 Analyzer, single-use SPDs, single-use Toxigenic C. difficile Direct Test Cartridges, and the PA500 Data Analysis Software Program. The PA500 Analyzer is designed to perform automated sample preparation, target amplification via PCR, chip-based (optical) target detection, and integrated data analysis in less than two hours. The PA500 Analyzer has been granted 510(k) clearance for the Portrait Toxigenic C. difficile Assay (DEN120013/K113358), Portrait GBS Assay (K143312), Staph ID/R Blood Culture Panel (K152470), Shiga Toxin Direct Test (K152955), Stool Bacterial Pathogens Panel (K163571), and the Bordetella Direct Test (K170284).

F. Substantial Equivalence Information

A comparison of the Toxigenic C. difficile Direct Test (CDF2) and the predicate device, Meridian Bioscience® GenePOC® CDiff Assay (K172569), is provided in Table 1.

Similarities
Features/CharacteristicsGreat Basin Toxigenic C. difficileDirect Test (CDF2)Predicate DeviceGenePOC® CDiff Assay (K172569)
ManufacturerVela Operations USAMeridian Bioscience
Trade NameGreat Basin Toxigenic C. difficile DirectTestGenePOC® CDiff Assay
510(k) NumberK232092K172569
ClassificationIIII
Product CodeOZNOZN
Intended Use/Indications for UseThe Great Basin Toxigenic C. difficileDirect Test, performed on the GreatBasin PA500 Analyzer, is a qualitative invitro diagnostic test for the detection oftoxigenic Clostridioides difficile inunformed (liquid or soft) stool samplescollected from patients suspected ofhaving C. difficile infection (CDI). Theautomated assay utilizes polymerasechain reaction (PCR) to detect aconserved region of the toxin gene( tcdB ) associated with toxin-producingC. difficile .The Toxigenic C. difficile Direct Test isintended for use as an aid in thediagnosis of CDI in conjunction withclinical and epidemiological risk factors.The GenePOC CDiff assay performedon the revogene instrument is aqualitative in vitro diagnostic test thatutilizes automated sample processingand real-time polymerase chain reaction(PCR) to detect the toxin B ( tcdB ) geneof toxigenic Clostridium difficile ( C.difficile ) in unformed (liquid or soft) stoolspecimens obtained from patientssuspected of having C. difficile infection(CDI). The GenePOC CDiff assay isintended to aid in thediagnosis of CDI.
Qualitative/QuantitativeQualitativeQualitative

Table 1. Predicate Comparison

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InstrumentPA500 Analyzerrevogene®
Specimen TypeUnformed (liquid or soft) stoolspecimensSame
Assay Targettoxin B gene (tcdB)Same
Sample Lysis andDNA ExtractionAutomated sample lysis and DNAextraction in a self-contained cartridgeSame
AmplificationTechnologyMultiplex polymerase chain reaction(PCR)Same
ResultInterpretationAutomatedSame
Test PrincipleAutomated and integrated samplepreparation, nucleic acid amplification,and detection of the target sequence ina single-use, disposable test cartridgeSame
ControlsIntegrated Sample Processing Control(SPC) to control for adequateprocessing of the target bacteria andmonitor the PCR amplification reactionfor the presence of inhibitors as well asmicrofluidic cartridge, instrument orreagent failure.Fiducial and Hybridization Controls (HC) to control for cartridge selection,cartridge integrity, and to verifydetection chemistryIntegrated Processing Control(PrC) to verify sample processing andamplification steps. The PrC allows forthe verification of potentialinhibitor substances as well asmicrofluidic, instrument or reagentfailure.
Differences
Features/CharacteristicsGreat Basin Toxigenic C. difficileDirect Test (CDF2)Predicate DeviceGenePOC® CDiff Assay (K172569)
Detection ProbesHybridization probesTaqMan probes
DetectionTechnologyColorimetric target specific hybridizationto probe on a chip surface, opticalreader, automated software with built-inresult interpretation.Real-time PCR (fluorescent signals) andembedded detection algorithm
Sample Input1 Swab Volume1 Disposable Transfer Loop Volume(5 uL)
Samples per Run1Up to 8
Time to Result~2 hours~70 min

G. Performance Summary - Analytical Studies

a. Specimen Stability

A room temperature and refrigerated Specimen Stability study was conducted to determine the allowable time and temperature storage conditions for clinical specimens. The study was conducted using fresh, never frozen C. difficile ATCC 43255 cells spiked into a pooled, clinical negative stool matrix at a concentration of approximately 2.5X LoD. A true negative sample was also evaluated. Stability samples were tested in triplicate in a time course study. The Specimen Stability Study demonstrated that the C. difficile target remains stable up to and beyond 72 hours when specimens are stored refrigerated (2° - 8°C). The results also demonstrate that the CDF2 test performance is consistent and stable for low positive samples stored up to 24 hours at room temperature (18° - 22°C).

b. Analytical Sensitivity

The limit of detection (LoD) of the Toxigenic C. difficile Direct Test was measured for two (2) toxigenic Clostridioides difficile (tcdB+) strains: Clostridioides difficile ATCC 43255 (Toxinotype

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  1. tcdA+, tcdB+) and Clostridioides difficile ATCC BAA-1805 (Toxinotype IIIb, NAP1/027, tcdA+, tcdB+).

For limit of detection (LoD) assessment, C. difficile strains were freshly cultured in liquid medium, serially diluted, and plated on agar to determine the cell concentration (i.e., CFU/mL). Enriched broths were then diluted into a pooled clinical negative stool to create a dilution series that was utilized for preliminary range finding on the CDF2 test. Results of the preliminary range finding were analyzed via Probit analysis to calculate the theoretical LoD at 95% agreement. The Probit estimated LoD was then confirmed with an additional round of testing from frozen cultures. The LoD for each strain tested is provided in Table 2.

Table 2. Toxigenic C. difficile Direct Test Limit of Detection

StrainLimit of Detection(LoD)
Clostridioides difficile(ATCC 43255)$2.6 x 10^4$ CFU/mL
Clostridioides difficile(ATCC BAA-1805)$7.1 x 10^4$ CFU/mL

c. Analytical Reactivity (Inclusivity)

The Analytical Reactivity of the Toxiqenic C. difficile Direct Test was evaluated by testing an additional twenty-two (22) toxigenic Clostridioides difficile strains covering six (6) unique toxinotypes. C. difficile strains were grown as described in the LoD studies, diluted into pooled, clinical negative stool to a concentration of 2X LoD (9.7 x 104 CFU/mL) and tested in triplicate. All additional strains tested were detected in CDF2.

The CDF2 test correctly identified every replicate of all 22 strains evaluated, indicating that the test can detect multiple strains and toxinotypes of Clostridioides difficile strains that harbor the tcdB toxin gene. Results of Analytical Reactivity (Inclusivity) testing are provided in Table 3.

Table 3. Clostridioides difficile Strains Tested for Analytical Reactivity (Inclusivity)

Clostridioidesdifficile StrainToxinotype, Toxin
ATCC 9689
ATCC 17857
ATCC 17858
ATCC 43594
ATCC 43596
ATCC 43599
ATCC 43600
ATCC 516950, A+, B+
ATCC 700792
ATCC BAA-1382
ATCC BAA-1804
ATCC BAA-1808
ATCC BAA-1871
ATCC BAA-1872
ATCC BAA-1874
ATCC BAA-2156
ATCC BAA-1803IIIc, NAP1, A+, B+
ATCC BAA-1875V, A+, B+
ATCC 43598VIII, A-, B+
ATCC BAA-1812XII, A+, B+
ATCC BAA-1814XXII, A+, B+
ATCC BAA-2155

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d. Analytical Specificity (Exclusivity)

The potential for cross-reactivity to non-target organisms was evaluated in an Exclusivity Study, by testing microorganisms commonly found in stool, with the CDF2 test. The study included 83 microorganisms phylogenetically related to C. difficile, as well as other bacteria, fungi/yeast, parasites, viruses, and human genomic DNA (69 unique bacterial strains, 1 yeast, 3 parasites, 9 viruses, and human genomic DNA). Genomic DNA was tested in place of whole organism, for those isolates that were classified as Biosafety Level III, or unable to be cultured via standard clinical microbiology techniques.

Contrived samples were formulated for Exclusivity testing by spiking previously frozen, enumerated cell culture stocks, commercially sourced genomic templates, or commercially sourced viruses into pooled, clinical negative stool matrix. Apart from a single strain (Clostridium butyricum ATCC 19398 tested at an input of 1.0 x 108 CFU/mL), all bacterial and yeast strains were tested at concentrations ≥ 1x10° CFU/mL. Genomic templates and viral strains were tested at ≥ 1x10° copies/mL or ≥ 1x106 TCIDs0mL, respectively. Each organism was tested in triplicate.

All Exclusivity organisms (see Table 4) gave the expected 'NEGATIVE, Toxin NOT DETECTED' result indicating no cross-reactivity was observed in CDF2. The one exception was Salmonella enterica ATCC 6962 which was "Detected" in the CDF2 test in a single replicate. Suspecting contamination, the strain was re-grown, and testing was repeated. Upon retesting all replicates of Salmonella enterica ATCC 6962 yielded the expected 'Negative' result.

SpeciesStrain IDInput Tested
Bacteria and Fungi
Abiotrophia defectivaATCC 491764.64 x 108 CFU/mL
Acinetobacter baumanniiATCC196061.39 x 108 CFU/mL
Aeromonas hydrophilaATCC 356549.70 x 107 CFU/mL
Alcaligenes faecalisATCC 155546.20 x 107 CFU/mL
Bacillus cereusATCC 145796.10 x 106 CFU/mL
Bacteroides fragilisATCC 237451.16 x 108 CFU/mL
Campylobacter coliATCC 499414.84 x 108 CFU/mL
Campylobacter fetusATCC 259363.30 x 106 CFU/mL
Campylobacter jejuniATCC 499431.50 x 109 CFU/mL
Candida albicansATCC 140531.40 x 106 CFU/mL
Citrobacter freundiiATCC 80907.40 x 107 CFU/mL
Clostridioides difficile (tcdA-, tcdB-)ATCC 435933.00 x 107 CFU/mL
Clostridioides difficile (tcdA-, tcdB-)ATCC 436012.20 x 107 CFU/mL
Clostridium bifermentansATCC 6381.61 x 107 CFU/mL
Clostridium butyricumATCC 193981.00 x 105 CFU/mL
Clostridium novyiATCC 19402≥ 1 x 106 CFU/mL
Clostridium perfringensATCC 131241.10 x 107 CFU/mL
Clostridium scindensATCC 357047.02 x 107 CFU/mL
Clostridium septicumATCC 12464≥ 1 x 106 CFU/mL
Clostridium sporogenesATCC 155795.80 x 106 CFU/mL
Edwardsiella tardaATCC 159471.10 x 108 CFU/mL
Enterobacter aerogenesATCC 150381.20 x 109 CFU/mL
Enterobacter cloacaeATCC 130471.40 x 108 CFU/mL
Enterococcus faecalisATCC 292122.14 x 108 CFU/mL
Enterococcus faecalis (vanB)ATCC 512995.65 x 107 CFU/mL
Enterococcus faeciumATCC 194347.10 x 107 CFU/mL
Escherichia coliATCC 41576.80 x 107 CFU/mL
Escherichia coli (stx1+, stx2+, eae+)ATCC BAA-22214.70 x 107 CFU/mL
Escherichia coli (stx1+, stx2+, O157:H7)ATCC 438958.60 x 106 CFU/mL
Escherichia coli (stx2+)ATCC BAA-23265.90 x 107 CFU/mL
Escherichia fergusoniiATCC 354693.20 x 107 CFU/mL
Escherichia hermaniiATCC 336505.60 x 106 CFU/mL
Flavonifractor plautii (Clostridium orbiscindens)ATCC 495314.00 x 106 CFU/mL
Hathewaya histolytica (Clostridium histolyticum)ATCC 194014.00 x 107 CFU/mL
Helicobacter pyloriATCC 435042.55 x 107 CFU/mL
Klebsiella oxytocaATCC 491311.21 x 108 CFU/mL
Klebsiella pneumoniaeATCC 138836.70 x 107 CFU/mL
Lactobacillus acidophilusATCC 43561.70 x 107 CFU/mL
SpeciesStrain IDInput Tested
Lactobacillus lactisATCC 490323.64 x 108 CFU/mL
Listeria monocytogenesATCC 191151.34 x 108 CFU/mL
Paeniclostridium (Clostridium) sordelliiATCC 97146.40 x 107 CFU/mL
Peptostreptococcus anaerobiusATCC 273371.40 x 107 CFU/mL
Plesiomonas shigelloidesATCC 519038.00 x 106 CFU/mL
Porphyromonas asaccharolyticaATCC 279081.32 x 108 CFU/mL
Prevotella melaninogenicaATCC 7005242.25 x 106 CFU/mL
Proteus mirabilisATCC 259332.14 x 108 CFU/mL
Proteus vulgarisATCC 68964.90 x 107 CFU/mL
Providencia alcalifaciensATCC 98861.25 x 108 CFU/mL
Providencia rettgeriATCC 92501.25 x 108 CFU/mL
Pseudomonas aeruginosaATCC 101459.60 x 107 CFU/mL
Pseudomonas fluorescensATCC 135252.18 x 107 CFU/mL
Salmonella enterica subsp. ArizonaeATCC 133147.98 x 108 CFU/mL
Salmonella enterica subsp. entericaATCC 133121.38 x 108 CFU/mL
Salmonella enterica subsp. entericaATCC 296284.20 x 107 CFU/mL
Salmonella enterica subsp. enterica1.37 x 108 CFU/mL
Salmonella enterica subsp. entericaATCC 69621.40 x 108 CFU/mL
Salmonella enterica subsp. entericaATCC 65392.50 x 106 CFU/mL
Salmonella enterica subsp. entericaATCC 133111.37 x 108 CFU/mL
Serratia liquefaciensATCC 355511.90 x 108 CFU/mL
Serratia marcescensATCC 138801.12 x 108 CFU/mL
Shigella boydiiATCC 299289.00 x 107 CFU/mL
Shigella dysenteriaeATCC 93611.84 x 107 CFU/mL
Shigella flexneriATCC 259297.20 x 107 CFU/mL
Shigella sonneiATCC 259316.00 x 107 CFU/mL
Staphylococcus aureusATCC 433001.20 x 108 CFU/mL
Staphylococcus aureusATCC 125981.76 x 107 CFU/mL
Staphylococcus epidermidisATCC 122285.80 x 107 CFU/mL
Streptococcus agalactiaeATCC 138131.20 x 106 CFU/mL
Streptococcus dysgalactiaeATCC 43078≥ 1 x 106 CFU/mL
Vibrio parahaemolyticusATCC 178021.71 x 107 CFU/mL
Yersinia enterocoliticaATCC 493971.82 x 108 CFU/mL
Viruses and Parasites
Adenovirus type 40ATCC VR-931D1.67 x 1010 copies/mL
Adenovirus type 41ATCC VR-930D1.34 x 1013 copies/mL
Coxsackievirus B2ATCC VR-291.10 x 107 TCID50/mL
Cryptosporidium parvumATCC PRA-67D1.11 x 108 copies/mL
Echovirus 4ATCC VR-1734D4.25 x 109 copies/mL
Entamoeba histolyticaATCC 30459DQ5.70 x 107 copies/mL
Enterovirus 71ATCC VR-1775DQ4.80 x 107 copies/mL
Giardia intestinalisATCC 50803D1.52 x 107 copies/mL
Herpesvirus 5 (Cytomegalovirus)ATCC VR-538D2.64 x 109 copies/mL
Norovirus GIATCC VR-3234SD4.70 x 107 copies/mL
Norovirus GIIATCC VR-3235SD4.80 x 107 copies/mL
Rotavirus AATCC VR-2018DQ5.30 x 107 copies/mL
Human genomic DNAPromega G147A4.99 x 106 copies/mL

Table 4. Analytical Specificity (Exclusivity) Study Results

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e. Microbial Interference (Competitive Inhibition)

The CDF2 test was evaluated for interference from mixed microbial populations using 82 microorqanisms tested in the Exclusivity Study. Potentially interfering microorganisms were pooled into seventeen (17) unique pools, each containing 3-5 non-target organisms (Table 5).

Test samples were contrived for Microbial Interference testing by first spiking previously frozen cultures of each non-target organism into pooled, negative clinical stool matrix. Each non-target organism was spiked into the Microbial Interference pool at the same input concentration tested in the Analytical Specificity (Exclusivity) Study (see Table 4 above). The Microbial Interference pool was then contrived to a final concentration of 2X LoD C. difficile ATCC 43255 (5.2 x 104 CFU/mL) with previously frozen cell stocks and tested in triplicate. Details of the Microbial Interference Study pools are shown in Table 5.

All Microbial Interference pool replicates gave the expected 'POSITIVE, Toxin DETECTED' result (100% agreement) indicating no interference or competitive inhibition from non-target microbes was observed.

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A
Potentially Interfering Microbe
SpeciesStrain IDPool
Aeromonas hydrophilaATCC 35654
Bacteroides fragilisATCC 23745
Campylobacter coliATCC 499411
Campylobacter fetusATCC 25936
Campylobacter jejuniATCC 49943
Citrobacter freundiiATCC 8090
Clostridioides difficileATCC 43593
Clostridioides difficileATCC 436012
Clostridium perfringensATCC 13124
Paeniclostridium (Clostridium) sordelliiATCC 9714
Enterobacter cloacaeATCC 13047
Enterococcus faecalisATCC 29212
Enterococcus faeciumATCC 194343
Escherichia coliATCC 4157
Escherichia coli (O157:H7)ATCC 43895
Escherichia fergusoniiATCC 35469
Escherichia hermaniiATCC 33650
Helicobacter pyloriATCC 435044
Klebsiella pneumoniaeATCC 13883
Peptostreptococcus anaerobiusATCC 27337
Salmonella entericaATCC 13312
Salmonella entericaATCC 29628
Salmonella entericaATCC 69625
Salmonella entericaATCC 6539
Salmonella entericaATCC 13311
Serratia liquefaciensATCC 35551
Serratia marcescensATCC 13880
Shigella boydiiATCC 299286
Shigella flexneriATCC 25929
Shigella sonneiATCC 25931
Candida albicansATCC 14053
Staphylococcus aureusATCC 43300
Staphylococcus aureusATCC 125987
Staphylococcus epidermidisATCC 12228
Yersinia enterocoliticaATCC 49397
Klebsiella oxytocaATCC 49131
Proteus mirabilisATCC 25933
Salmonella entericaATCC 133148
Shigella dysenteriaeATCC 9361
Streptococcus agalactiaeATCC 13813
Acinetobacter baumanniiATCC 19606
Bacillus cereusATCC 14579
Edwardsiella tardaATCC 159479
Enterobacter aerogenesATCC 15038
Pseudomonas fluorescensATCC 13525
Abiotrophia defectivaATCC 49176
Alcaligenes faecalisATCC 15554
Clostridium bifermentansATCC 63810
Clostridium butyricumATCC 19398
Clostridium novyiATCC 19402
Hathewaya histolytica (Clostridium histolyticum)ATCC 19401
Lactobacillus lactisATCC 49032
Listeria monocytogenesATCC 1911511
Pseudomonas aeruginosaATCC 10145
Vibrio parahaemolyticusATCC 17802
Clostridium sporogenesATCC 15579
Lactobacillus acidophilusATCC 4356
Plesiomonas shigelloidesATCC 5190312
Proteus vulgarisATCC 6896

Table 5. Microbial Interference (Competitive Inhibition) Study Results

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Flavonifractor plautii (Clostridium orbiscindens)ATCC 49531
Providencia alcalifaciensATCC 9886
Salmonella entericaATCC 696213
Escherichia coliATCC BAA-2221
Escherichia coliATCC BAA-2326
Adenovirus type 40ATCC VR-931D
Enterovirus 71ATCC VR-1775DQ
Norovirus GIATCC VR-3234SD14
Norovirus GIIATCC VR-3235SD
Rotavirus AATCC VR-2018DQ
Clostridium scindensATCC 35704
Clostridium septicumATCC 12464
Enterococcus faecalis (vanB)ATCC 5129915
Porphyromonas asaccharolyticaATCC 27908
Prevotella melaninogenicaATCC 700524
Adenovirus type 41ATCC VR-930D
Coxsackievirus B2ATCC VR-29
Herpesvirus 5 (Cytomegalovirus)ATCC VR-538D16
Echovirus 4ATCC VR-1734D
Giardia intestinalisATCC 50803D
Cryptosporidium parvumATCC PRA-67D
Entamoeba histolyticaATCC 30459DQ17
Human aDNAPromega G147A

Interfering Substances (Chemical Interference) f.

The CDF2 test was evaluated for potential endogenous Chemical Interference against a panel of thirty (30) substances that are common stool contaminants, or likely present in patients with diarrhea. Each substance was tested in the background of 2X LoD contrived positive stools and true negative stool. Two (2) C. difficile strains were evaluated in the Interfering Substances study at 2X LoD, ATCC 43255 (5.2 x 104 CFU/mL) and ATCC BAA-1805 (1.4 x 105 CFU/mL). The same clinical negative (i.e., un-spiked) stool matrix was also tested as a true negative to evaluate potential interference with the internal assay control in the absence of target analyte.

Each substance was tested in triplicate against both C. difficile strains and a negative sample for a total of nine (9) CDF2 tests per substance. During testing if any substance resulted in less than 100% agreement, the input concentration of the potentially interfering substance was reduced by 10-20% and re-tested stepwise until 100% agreement was achieved. The highest, non-inhibitory input is reported. No CDF2 interference was observed for any of the endogenous or exogenous substances at the concentrations listed in Table 6.

Table 6. Interfering Substances Study Results

Interfering SubstanceInput TestedC. difficileATCC 432552X LoDC. difficileATCC BAA-18052X LoDNegative
(Brand Evaluated)POSITIVE CDF2 ResultNEGATIVECDF2 Result
Bismuth subsalicylate50% v/v3/33/33/3
Liquid glycerin suppository50% v/v3/33/33/3
Water-based personal lubricant50% v/v3/33/33/3
Silicon-based personal lubricant50% v/v3/33/33/3
Benzalkonium chloride wipe solution50% v/v3/33/33/3
Aloe leaf juice flushable wipes50% v/v3/33/33/3
Nonoxynol-9 condom lubricant40% w/v3/33/33/3
Hemorrhoidal cream20% w/v3/33/33/3
Hydrocortisone cream30% w/v3/33/33/3
Miconazole nitrate anti-fungal cream30% w/v3/33/33/3
Petroleum jelly30% w/v3/33/33/3
Antacid tablet38% w/v3/33/33/3
Loperamide anti-diarrheal50% v/v3/32/33/3
Loperamide anti-diarrheal44% v/vNot Tested3/3Not Tested
Senna glycoside natural laxative17% w/v3/33/33/3
NSAID, Naproxen Sodium10% w/v3/33/33/3

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Interfering Substance(Brand Evaluated)Input TestedC. difficileATCC 432552X LoDC. difficileATCC BAA-18052X LoDNegative
POSITIVE CDF2 ResultNEGATIVECDF2 Result
Mineral oil50% v/v3/33/33/3
Biotin supplement51% w/v3/33/33/3
Barium sulfate25% w/v3/33/33/3
Stearic acid1.1% w/v2/33/33/3
1% w/v3/3Not TestedNot Tested
Palmitic acid1.5% w/v3/33/33/3
Whole Blood40% v/v3/33/33/3
Biotin0.5 w/v3/33/33/3
Nonoxynol-948% v/v3/32/33/3
42% v/vNot Tested3/3Not Tested
Mesalazine2.5% w/v3/33/33/3
Mucin from Porcine Stomach2.5% w/v3/33/33/3
Topical Antibiotic50% w/v3/33/33/3
Nystatin10% w/v3/33/33/3
Metronidazole0.5% w/v3/33/33/3
Erythromycin10% w/v3/33/33/3
5% w/v0/33/33/3
Vancomycin (100 mg/mL in DMSO)0.4% w/v3/3Not TestedNot Tested

g. Reproducibility

A between-site Reproducibility Study was conducted at one (1) internal and two (2) external sites. The study incorporated several variables including multiple operators (n=6) across the three (3) study sites, multiple non-consecutive testing days (n=5), multiple Analyzers (n=24), and cartridge lots (n=2).

The Reproducibility Panel consisted of five (5) panel members. Each panel contained two (2) toxigenic Clostridioides difficile strains: ATCC 43255 (toxinotype 0, ribotype 087) and ATCC BAA-1805 (toxinotype IIIb, NAP1/ribotype 027). Each strain was evaluated at both low positive (1.5X LoD) and moderate positive (3X LoD) concentrations. A single negative sample was also included in the panel. Contrived Reproducibility Panel samples were prepared by spiking previously enumerated and frozen Clostridioides difficile cultures into pooled negative clinical stool matrix. The contrived panels were frozen, shipped to sites frozen, and thawed at the test site prior to testing on the Toxigenic C. difficile Direct Test.

Results of the Reproducibility Study are provided by site in Table 7.

Agreement(Actual/Expected Outcomes)
C. difficile StrainATCC 43255ATCC BAA-1805N/A
Concentration (LoD)1.5X3X1.5X3XNegative
Clinical Site 1100%(30/30)100%(30/30)100%(30/30*)100%(30/30*)100%(30/30)
Clinical Site 293.3%(28/30)100%(30/30)100%(30/30)100%(30/30)96.7%(29/30)
Internal Site100%(30/30)100%(30/30)100%(30/30)100%(30/30)100%(30/30)
Total (All Sites)[95% CI]97.8%(88/90)[92.2-99.7%]100%(90/90)[96-100%]100%(90/90)[96-100%]100%(90/90)[96-100%]98.9%(89/90)[94-100%]

Table 7. Reproducibility Study Results

  • This dataset contained a single (1) 'Invalid' result that was resolved upon retest.

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Analysis of Positive Results: A total of four (4) positive samples were tested in triplicate by each of the 6 operators over 5 days. Therefore, the study contains a total of 60 positive results per operator and 360 total positives.

Two (2) low positive (test concentration = 1.5X LoD) Reproducibility panel samples yielded 'NEGATIVE' results in a single replicate. Both false negative replicates are assumed to be due to assay variability and stochastic sampling of the contrived sample for this analyte at concentrations very near the limit of detection. Although both false negatives occurred at Site 2, there was no commonality between the operator or the test day. Even with these two missed replicates the overall reproducibility for this analyte was still acceptable (≥ 95%).

Analysis of Negative Results: To assess negative results, aliquots of the same pooled negative matrix that was used to contrive the panel were tested. A single (1) neqative sample was included in each panel, tested in triplicate by each of 6 operators over 5 days each, therefore a total of 15 negative results per operator and 90 total negative results in the study.

A single negative Reproducibility panel sample yielded a 'POSITIVE' result in a single replicate. The false positive was most likely caused by unintentional sample contamination by the operator.

Overall agreement for positive and negative Reproducibility panel samples are provided in Table 8. The agreement of positive results for toxigenic C. difficile was 98.9% at low positive concentrations (1.5X LoD) and 100% at moderate positive concentrations (3X LoD). The overall agreement of positive results was 99.4% [Clgs 98.0 - 99.9%]. The overall agreement of negative results was 98.9% [Clgs 94.0 - 100%]. Given the number of variables included in this study (cartridge lots, analyzers, operators, sites, days) the study demonstrated acceptable reproducibility of the Toxigenic C. difficile Direct Test.

AnalyteConcentrationAgreement(Actual/Expected Outcomes)[95% CI]Agreement(Actual/Expected Outcomes)[95% CI]
Clostridioides difficile(tcdB+)1.5X LoD98.9%(178/180)[96-99.9%]99.4%(358/360)[98-99.9%]
Clostridioides difficile(tcdB+)3X LoD100%(180/180)[98-100%]
NegativeN/A98.9%(89/90)[94-100%]98.9%(89/90)[94-100%]

Table 8. Summary of Reproducibility Results

Performance Data - Clinical Studies H.

A prospective multi-center method comparison study was conducted to compare the performance of the Toxigenic C. difficile Direct Test (CDF2) to an FDA-cleared molecular reference. The study was conducted at three, geographically diverse, U.S. clinical study sites (Midwest, West) from June 2022 - February 2023.

Specimens enrolled in the study were excess remnants of unpreserved stool specimens that were prospectively collected from symptomatic individuals ≥ 2 years of age suspected of C. difficile infection (CDI), processed according to routine standard of care testing, and would have otherwise been discarded. All specimens were enrolled under an Institutional Review Board (IRB) approved protocol and testing was performed by trained laboratory personnel.

A total of 829 specimens met the inclusion criteria and were included in the final dataset included specimens collected from 431 females (52%), 393 males (47.4%), and 5 (0.6%) individuals of undeclared or unknown gender. The age distribution of study participants is shown in Table 9.

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Table 9. Study Population Distribution by Age Group

Age Group(Years)Number ofSpecimens
<2Excluded
2-1237 (4.5%)
13-1832 (3.9%)
19-64442 (53.3%)
65-88299 (36.1%)
≥ 8919 (2.3%)
Total829 (100.0%)

Results of the prospective method comparison study were analyzed for concordance by site and in total using a 2x2 table. The positive percent agreement (PPA), negative percent agreement (NPA), disease prevalence, positive predictive value (PPV), negative predictive value (NPV) along with the 95% confidence intervals (CI) were then calculated. Results of Prospective Specimen testing by site and in total are shown in Table 10.

Table 10. Prospective Study Results
---------------------------------------
Site 1Molecular Comparator
PositiveNegativeTotal
ToxigenicC. difficileDirectTestPositive71778
Negative2320322
Total73327400
Site 2Molecular Comparator
PositiveNegativeTotal
ToxigenicC. difficileDirectTestPositive60262
Negative4318322
Total64320384
PPA = 93.8% (84.8% - 98.3%)
NPA = 99.4% (97.8% - 99.9%)
Prevalence = 16.7%
PPV = 96.8% (88.8% - 99.6%)
NPV = 98.8% (96.9% - 99.7%)

PPA = 100.0% (59.0% - 100.0%) NPA = 97.4% (86.2% - 99.9%)

Prevalence = 15.6%

PPA = 97.3% (90.5% - 99.7%) NPA = 97.9% (95.6% - 99.1%)

PPV = 91.0% (82.4% - 96.3%) NPV = 99.4% (97.8% - 99.9%)

Prevalence = 18.3%

Site 3Molecular Comparator
PositiveNegativeTotal
ToxigenicC. difficileDirectTestPositive718
Negative03737
Total73845
All SitesMolecular Comparator
PositiveNegativeTotal
ToxigenicC. difficileDirectTestPositive13810148
Negative6675681
Total144685829
PPV = 87.5% (47.4% - 99.7%)NPV = 97.8% (88.2% - 99.9%)
PPA = 95.8% (91.2% - 98.5%)NPA = 98.5% (97.3% - 99.3%)
Prevalence = 17.4%
PPV = 93.2% (87.9% - 96.7%)
NPV = 99.1% (98.1% - 99.7%)

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Discrepant results were defined as results obtained from the CDF2 test that were not with the standard of care molecular reference method. Specimens with discrepant results were investigated by testing the specimens on a third molecular test.

As shown in Table 11, five (5) of six (6) false negative specimens also tested negative when evaluated with a second FDA-cleared molecular C. difficile test and are therefore concordant with the CDF2 result. The remaining false negative (1) specimen tested positive on the BD Max and found to be in concordance with the reference test.

All ten (10) CDF2 false positive results tested negative when evaluated with a second FDA-cleared molecular C. difficile test and found to be in concordance with the reference test.

Results of discrepant resolution testing are summarized in Table 11.

Table 11. Prospective Study Discrepant Testing Results

ResolvedFalse NegativesResolvedFalse Positives
5/60/10

Established clinical performance, positive (PPA) and negative (NPA) percent agreement along with 95% Confidence Intervals, of the Toxigenic C. difficile Direct Test is shown in Table 12. Overall, the results from the clinical evaluation demonstrated acceptable performance of the Great Basin Toxigenic C. difficile Direct Test and support the Intended Use of this product.

Table 12. Summary Table - Clinical Performance of the Toxigenic C. difficile Direct Test

nPPA(95% CI)NPA(95% CI)
ToxigenicC. difficile Direct Test(CDF2)82995.8%(91.2 - 98.5)138/14498.5%(97.3 - 99.3)675/685

l. Overall Conclusion

The information submitted in this 510(k) pre-market notification is complete and supports substantial equivalence.

§ 866.3130 Clostridium difficile toxin gene amplification assay.

(a)
Identification. AClostridium difficile toxin gene amplification assay is a device that consists of reagents for the amplification and detection of target sequences inClostridium difficile toxin genes in fecal specimens from patients suspected of havingClostridium difficile infection (CDI). The detection of clostridial toxin genes, in conjunction with other laboratory tests, aids in the clinical laboratory diagnosis of CDI caused byClostridium difficile. (b)
Classification. Class II (special controls). The special controls are set forth in FDA's guideline document entitled: “Class II Special Controls Guideline: Toxin Gene Amplification Assays for the Detection ofClostridium difficile; Guideline for Industry and Food and Drug Administration Staff.” See § 866.1(e) for information on obtaining this document.