K Number
K971006
Device Name
LYME DISEASE B. BURGDORFERI GENOGROUP 1 WESTERN BLOT IGG (WB0400G)
Manufacturer
Date Cleared
1998-06-01

(439 days)

Product Code
Regulation Number
866.3830
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
MRL Diagnostics' Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is intended for the qualitative detection of IgG class antibodies, in human serum, to the genogroup 1 (Borrelia burgdorferi sensu stricto) of B. burgdorferi sensu lato. The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG test is intended to provide supportive evidence of infection with B. burgdorferi, the causative agent of Lyme disease as an aid in the diagnosis of Lyme disease, using serum samples which have been found positive or equivocal by a B. burgdorferi screening method (e.g., IFA or ELISA). The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG can be used at any time following onset of symptoms provided the IFA or ELISA is positive or equivocal. Also, it should be used for follow up when: 1) only IgM antibodies were originally detected, 2) IgG antibodies were detected, but were not considered significant by Western blot, or 3) previously seronegative patients subsequently test positive by IFA or ELISA.
Device Description
MRL Diagnostics separates B. burgdorferi proteins by polyacrylamide gel electrophoresis and electrophoretically transfers the fractionated proteins from the gel to a nitrocellulose membrane. The nitrocellulose membrane is dried and cut into strips. The antigen strips are numbered and packaged. The MRL Diagnostics Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is a two stage procedure. In the first stage, the patient sera is diluted and incubated with individual antigen strips. If antibodies to B. burgdorferi are present in the sera, they will bind to the Borrelia antigens immobilized on the nitrocellulose membranes. In the second stage, visualization of the bound antibodies is accomplished by incubating the blots with alkaline phosphatase-conjugated goat anti-human IgG, (Fc fragment specific) followed by the addition of substrate (BCIP/NBT) which forms a colored precipitate at each site (antigen band) where the anti-human conjugate has bound. The resulting pattern of band reactivity is then interpreted.
More Information

Not Found

No
The description details a traditional Western Blot assay with manual interpretation of band reactivity. There is no mention of automated analysis, image processing, or any computational methods that would suggest the use of AI/ML.

No
The device is described as a diagnostic test for Lyme disease, intended to detect antibodies and provide supportive evidence of infection, not to treat or directly manage a patient's condition.

Yes

Explanation: The "Intended Use / Indications for Use" section explicitly states that the device is "intended to provide supportive evidence of infection with B. burgdorferi, the causative agent of Lyme disease as an aid in the diagnosis of Lyme disease." This directly indicates its diagnostic purpose.

No

The device description clearly outlines a laboratory test involving physical components like nitrocellulose membranes, gels, and chemical reagents, which are used to detect antibodies in human serum. This is a hardware-based in vitro diagnostic device, not a software-only device.

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

Here's why:

  • Intended Use: The intended use explicitly states that the test is for the "qualitative detection of IgG class antibodies, in human serum," and is intended to "provide supportive evidence of infection with B. burgdorferi... as an aid in the diagnosis of Lyme disease." This clearly indicates the device is used to examine specimens derived from the human body (serum) to provide information for diagnostic purposes.
  • Device Description: The description details a laboratory procedure involving the analysis of patient serum samples to detect antibodies. This is a typical characteristic of an in vitro diagnostic test.
  • Performance Studies: The document describes performance studies conducted on human serum samples from different populations (Lyme Disease, Normal, Cross-reactivity) to evaluate the test's sensitivity and specificity. This is a requirement for demonstrating the performance of an IVD.
  • Predicate Device: The mention of a predicate device (MRL Diagnostics Lyme Disease IFA IgG kit) which is also an IVD further supports the classification of this device as an IVD.

The device is designed to be used in vitro (outside the body) to analyze a human specimen (serum) to aid in the diagnosis of a disease (Lyme disease). This aligns perfectly with the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

MRL Diagnostics' Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is intended for the qualitative detection of IgG class antibodies, in human serum, to the genogroup 1 (Borrelia burgdorferi sensu stricto) of B. burgdorferi sensu lato. The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG test is intended to provide supportive evidence of infection with B. burgdorferi, the causative agent of Lyme disease as an aid in the diagnosis of Lyme disease, using serum samples which have been found positive or equivocal by a B. burgdorferi screening method (e.g., IFA or ELISA). The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG can be used at any time following onset of symptoms provided the IFA or ELISA is positive or equivocal. Also, it should be used for follow up when: 1) only IgM antibodies were originally detected, 2) IgG antibodies were detected, but were not considered significant by Western blot, or 3) previously seronegative patients subsequently test positive by IFA or ELISA.

Product codes

LSR

Device Description

MRL Diagnostics separates B. burgdorferi proteins by polyacrylamide gel electrophoresis and electrophoretically transfers the fractionated proteins from the gel to a nitrocellulose membrane. The nitrocellulose membrane is dried and cut into strips. The antigen strips are numbered and packaged.
The MRL Diagnostics Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is a two stage procedure. In the first stage, the patient sera is diluted and incubated with individual antigen strips. If antibodies to B. burgdorferi are present in the sera, they will bind to the Borrelia antigens immobilized on the nitrocellulose membranes. In the second stage, visualization of the bound antibodies is accomplished by incubating the blots with alkaline phosphatase-conjugated goat anti-human IgG, (Fc fragment specific) followed by the addition of substrate (BCIP/NBT) which forms a colored precipitate at each site (antigen band) where the anti-human conjugate has bound. The resulting pattern of band reactivity is then interpreted.

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

Not Found

Intended User / Care Setting

Prescription Use

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

Three investigational sites (2 independent off-site investigators and 1 on-site investigator) studied the following 3 distinct populations:

    1. a Lyme Disease population (n=183) consisting of serum samples from patients with EM, a late stage symptom per the CDC case definition and B. burgdorferi seropositive, or B. burgdorferi culture positive;
    1. a Normal population (n=326) consisting of serum samples from donors with no known history or symptoms of Lyme Disease (including persons from Lyme disease endemic and non-endemic areas), and;
    1. a Cross-reactivity population (n=282) consisting of serum samples from patients with potentially cross-reactive conditions or infections.

Summary of Performance Studies

Sensitivity Study:
Two independent off-site investigations (Investigational Sites 1 and 2) and one on-site investigational Site 3), assayed well characterized Lyme disease positive patient sera (n=184) from patients (n=158) with EM, a late stage symptom per the CDC case definition and B. burgdorferi seropositive, or B. burgdorferi culture positive. Investigational Sites 1 and 2 used retrospective serum samples from their own well-characterized serum banks, and Investigational Site 3 used a retrospective well characterized serum panel supplied by the CDC.

  • CDC panel: Overall Sensitivity 43% (17/40) (95% CI: 27 to 59%).
  • All three sites combined: Overall Sensitivity 46% (83/179) (95% CI: 39 to 54%).
  • Multiple draws patients:
    • Initial Draw Sensitivity: 12% (2/17)
    • Subsequent Draw Sensitivity:

§ 866.3830

Treponema pallidum treponemal test reagents.(a)
Identification. Treponema pallidum treponemal test reagents are devices that consist of the antigens, antisera and all control reagents (standardized reagents with which test results are compared) which are derived from treponemal sources and that are used in the fluorescent treponemal antibody absorption test (FTA-ABS), theTreponema pallidum immobilization test (T.P.I.), and other treponemal tests used to identify antibodies toTreponema pallidum directly from infecting treponemal organisms in serum. The identification aids in the diagnosis of syphilis caused by bacteria belonging to the genusTreponema and provides epidemiological information on syphilis.(b)
Classification. Class II (performance standards).

0

100000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000 JUN

DIAGNOSTICS

K971006

510(k) Safety and Effectiveness Summary ______________________________________________________________________________________________________________________________________ (Page 1 of 6)

Applicant:MRL Diagnostics
10703 Progress Way
Cypress, California 90630

2023365 Establishment Registration No:

  • Michael J. Wagner Contact Person:
    (714) 220-1900 Phone:

(714) 220-1182 Telefax:

mwagner@mrlinfo.com E-mail:

May 20, 1998 Summary Date:

Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG Device Name:

  • Lyme Disease Borrelia burgdorferi Serological Reagents Classification: 21 CFR §866.3830 Class II
    MRL Diagnostics Lyme Disease IFA IgG kit (K883487) Predicate Device:

1

Image /page/1/Picture/0 description: The image shows the logo for MRL Diagnostics. The letters "MRL" are stacked on top of the word "DIAGNOSTICS". There is a thick black line between the two words. The text is in a bold, sans-serif font.

$971006

510(k) Safety and Effectiveness Summary

(Page 2 of 6)

MRL Diagnostics separates B. burgdorferi proteins by polyacrylamide gel electrophoresis Device and electrophoretically transfers the fractionated proteins from the gel to a nitrocellulose Description: membrane. The nitrocellulose membrane is dried and cut into strips. The antigen strips are numbered and packaged.

The MRL Diagnostics Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is a two stage procedure. In the first stage, the patient sera is diluted and incubated with individual antigen strips. If antibodies to B. burgdorferi are present in the sera, they will bind to the Borrelia antigens immobilized on the nitrocellulose membranes. In the second stage, visualization of the bound antibodies is accomplished by incubating the blots with alkaline phosphatase-conjugated goat anti-human IgG, (Fc fragment specific) followed by the addition of substrate (BCIP/NBT) which forms a colored precipitate at each site (antigen band) where the anti-human conjugate has bound. The resulting pattern of band reactivity is then interpreted.

MRL Diagnostics' Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is Intended Use: intended for the qualitative detection of IgG class antibodies, in human serum, to the genogroup 1 (Borrelia burgdorferi sensu stricto) of B. burgdorferi sensu lato. The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG test is intended to provide supportive evidence of infection with B. burgdorferi, the causative agent of Lyme disease as an aid in the diagnosis of Lyme disease, using serum samples which have been found positive or equivocal by a B. burgdorferi screening method (e.g., IFA or ELISA). The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG can be used at any time following onset of symptoms provided the IFA or ELISA is positive or equivocal. Also, it should be used for follow up when: 1) only IgM antibodies were originally detected, 2) IgG antibodies were detected, but were not considered significant by Western blot, or 3) previously seronegative patients subsequently test positive by IFA or ELISA.

2

K971006

510(k) Safety and Effectiveness Summary_______________________________________________________________________________________________________________________________________ (Page 3 of 6)

Expected

Values:

Three investigational sites (2 independent off-site investigators and 1 on-site investigator) studied the following 3 distinct populations:

    1. a Lyme Disease population (n=183) consisting of serum samples from patients with EM, a late stage symptom per the CDC case definition and B. burgdorferi seropositive, or B. burgdorferi culture positive;
    1. a Normal population (n=326) consisting of serum samples from donors with no known history or symptoms of Lyme Disease (including persons from Lyme disease endemic and non-endemic areas), and;
    1. a Cross-reactivity population (n=282) consisting of serum samples from patients with potentially cross-reactive conditions or infections.

The frequency of criteria bands observed in the three populations are described in the following table:

Disease Staten%PosAny Band21232830394145586693
Lyme Disease (By Disease Stage) (n=183)
Lyme I7221%96%17%39%7%14%54%93%7%24%22%11%
Lyme II4137%95%32%27%24%49%73%95%39%41%24%34%
Lyme III7071%97%59%54%54%64%86%94%33%73%59%61%
Lyme Disease (By Months Post Infection Onset) (n=183)
12 months5463%98%50%50%44%54%81%96%30%65%54%54%
Normal Population (n=326)
Endemic820%49%0%0%0%1%7%32%0%9%2%0%
Non-Endemic2440%61%0%1%0%2%8%48%3%4%6%1%
Possible Cross-reactives (n=281)
Spirochetal1040%85%0%4%3%5%16%66%11%5%10%3%
Auto-Immune220%77%0%0%0%5%0%55%0%5%9%5%
Tick Borne210%43%0%0%0%5%14%38%14%5%14%0%
Musc. Skeletal336%88%9%9%6%12%15%79%21%9%6%9%
Neurologic274%78%4%0%0%7%11%59%4%22%15%4%
Viral320%66%0%3%3%6%0%44%9%6%0%0%
Symptomology150%93%7%0%0%13%7%73%7%7%7%0%
Misc. Disease290%93%0%0%0%7%21%72%10%17%3%0%

3

K971006

mwagner(@mr)into.com

510(k) Safety and Effectiveness Summary (Page 4 of 6)

To determine assay Sensitivity, two independent off-site investigations (Investigational Sites Sensitivity: 1 and 2) and one on-site investigational Site 3), assayed well characterized Lyme disease positive patient sera (n=184) from patients (n=158) with EM, a late stage symptom per the CDC case definition and B. burgdorferi seropositive, or B. burgdorferi culture positive. Investigational Sites 1 and 2 used retrospective serum samples from their own well-characterized serum banks, and Investigational Site 3 used a retrospective well characterized serum panel supplied by the CDC. The CDC panel results are presented as a means to convey further information on the performance of this assay with a masked, characterized serum panel. This does not imply an endorsement of the assay by the CDC. For the CDC panel, sensitivity results are provided in the following table for 1) the IgG Western Blot, and 2) the number of samples which were IgG negative but IgM positive by MRL Diagnostics' B. burgdorferi Western Blots ("IgG Negative & IgM Positive"):

| Months Post
Infection Onset | IgG
Sensitivity | IgG
95% CI | IgG Negative &
IgM Positive |
|--------------------------------|--------------------|---------------|--------------------------------|
| 6 | 82% (9/11) | 48 to 98% | 1 |
| Overall
Sensitivity | 43% (17/40) | 27 to 59% | 19 |

For all three sites, sensitivity results are provided in the following table for 1) the IgG Western Blot and 2) the number of samples which were IgG negative but IgM positive by MRL Diagnostics' B. burgdorferi Western Blots ("IgG Negative & IgM Positive"):

| Months Post
Infection Onset | IgG
Sensitivity | IgG
95% CI | IgG Negative &
IgM Positive |
|--------------------------------|--------------------|---------------|--------------------------------|
| 6 | 65% (47/72) | 53 to 76% | 5 |
| Unspecified | 100% (1/1) | | |
| Overall
Sensitivity | 46% (83/179) | 39 to 54% | 55 |

Eighteen patients were drawn more than once, i.e., three patients were drawn three times and the other patients twice. One of those patients was drawn at 99 and 105 months post onset, and both draws were found IgG positive IgM negative. The other seventeen patients were initially drawn less than one month post onset, and the results for those multiple draws are summarized in the following table:

Initial DrawSubsequent Draw Sensitivity
SensitivityFor persons with no known history of Lyme disease (Normals), and those with potentially cross-reactive diseases (Potential Cross-reactives),specificity results are provided in the following table for 1) the IgG Western Blot and 2) the number of samples which were IgG negative but IgM positive by MRL Diagnostics' B. burgdorferi Western Blots ("IgG Negative & IgM Positive"):

| Condition | IgG Positivity | IgG Negative &
IgM Positive |
|----------------------------------------|------------------------|--------------------------------|
| Normal Population (n=326) | | |
| Endemic Normals | 0% (0/82) | 0 |
| Non-Endemic Normals | 0% (0/244) | 5 |
| Condition | IgG
Crossreactivity | IgG Negative &
IgM Positive |
| Spirochetal Disease Population (n=103) | | |
| Syphilis | 0% (0/73) | 1 |
| Periodontal | 0% (0/20) | 2 |
| Leptospirosis | 0% (0/10) | 0 |
| Auto Immune Disease Population (n=22) | | |
| RF | 0% (0/10) | 2 |
| ANA | 0% (0/11) | 2 |
| SLE (Lupus) | 0% (0/1) | 0 |
| Tickborne Disease Population (n=21) | | |
| Rickettsia | 0% (0/9) | 0 |
| E. chaffeensis | 0% (0/8) | 5 |
| HGE | 0% (0/3) | 0 |
| Tickborn Relapsing | 0% (0/1) | 0 |
| Muscular Skeletal Disease (n=33) | | |
| Arthritis | 7% (1/15) | 0 |
| Arthralgia | 9% (1/11) | 1 |
| JRA | 0% (0/4) | 0 |
| Misc. Muscular | 0% (0/3) | 0 |
| Misc. Neurologic Disease (n=27) | 4% (1/27) | 1 |
| Viral Disease Population (n=36*) | | |
| EBV* | 0% (0/13) | 0 |
| CMV* | 0% (0/11) | 0 |
| HSV-1/2* | 0% (0/2) | 0 |
| HIV | 0% (0/10) | 0 |
| Misc. Disease/Similar Symptoms (n=44) | | |
| Fatigue | 0% (0/15) | 0 |
| Misc. | 0% (0/29) | 1 |

  • includes 2 sera with antibody response to EBV, CMV, and HSV-1/2

10703 PROGRESS WAY, CYPRESS CALIFORNIA 90630

800 445-0185

714 220-1900

5

971006

510(k) Safety and Effectiveness Summary_______________________________________________________________________________________________________________________________________

(Page 6 of 6)

Intra-laboratory Reproducibility was assessed by assaying 10 serum samples (of varying Reproducibility reactivity) once per day on 3 days using a single Antigen Strip lot. All 3 runs yielded identical screening interpretations for 9 of 10 selected sera. The remaining discrepant sample (a weakly reactive sample) produced identical interpretations on 8 of the 10 criteria bands. Overall, the 10 criteria bands yielded identical interpretations on 288 of 300 (96%) criteria band readings.

Inter-lot Reproducibility was assessed using 10 serum samples (of varying reactivity) on 3 lots of Antigen Strips. All 3 lots produced identical screening interpretations for 9 of the 10 selected sera. The discrepant sample (a weakly reactive sample) produced identical interpretations on 7 of the 10 criteria bands. Overall, the 10 criteria bands yielded identical interpretations on 284 of 300 (95%) criteria band readings.

Inter-reader Reproducibility was assessed by assaying 18 patient sera with a single lot of strips. The sera were assayed at up to three Investigational Sites (two sera were tested at two sites only), and read by two readers at each site. Overall, interpretation was identical 94% (49/52), and criteria band readings were identical 94% (491/520).

Inter-site Reproducibility was assessed by assaying 18 patient sera with a single lot of strips. The sera were assayed at the three Investigational Sites, and read by two readers at each site. Overall, interpretation was identical 88% (91/104), and criteria band readings were identical 87% (900/1040).

The results indicate that for strongly reactive and negative specimens the assay Weakly reactive (borderline) specimens decrease the kit's reproducibility is high. reproducibility.

summarizes reproducibility by interpretation The following table and band reproducibility.

StudynInterp21232830394145586693
Intra-lab1090%90%90%90%90%100%90%90%100%90%100%
Inter-lot1090%90%90%90%90%100%90%90%90%90%100%
Inter-reader1894%90%92%94%98%98%98%92%96%90%90%
Inter-site1888%88%83%84%80%91%84%73%94%92%97%

6

Image /page/6/Picture/2 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with three heads, representing the department's mission to protect the health of all Americans and provide essential human services. The logo is surrounded by the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" in a circular arrangement.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

1 1998 וחא

Michael J. Wagner Regulatory Affairs Specialist MRL Diagnostics 10703 Progress Way Cypress. CA 90630

Re: K971006

Trade Name: Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG Regulatory Class: II Product Code: LSR Dated: March 23, 1998 Received: March 25, 1998

Dear Mr. Wagner:

We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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). You may, therefore, market the device, subject to the general controls provisions of the Act. 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.

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.

7

Page 2

Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity categorization. To determine if it does, you should contact the Centers for Disease Control and Prevention (CDC) at (770)488-7655.

This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4588. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll free number (800) 638-2041 or at (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html"

Sincerely yours.

Steven Butman

Steven I. Gutman, M.D., M.B.A. Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

8

510(k) Number (if known): K971006

Device Name: Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG

Indications for Use:

MRL Diagnostics' Lyme Disease B. burgdorferi Genogroup 1 Western Blot IgG test is intended for the qualitative detection of IgG class antibodies, in human serum, to the genogroup 1 (Borrelia burgdorferi sensu stricto) of B. burgdorferi sensu lato. The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG test is intended to provide supportive evidence of infection with B. burgdorferi, the causative agent of Lyme disease as an aid in the diagnosis of Lyme disease, using serum samples which have been found positive or equivocal by a B. burgdorferi screening method (e.g., IFA or ELISA). The MRL Diagnostics Lyme Disease B. burgdorferi Western Blot IgG can be used at any time following onset of symptoms provided the IFA or ELISA is positive or equivocal. Also, it should be used for follow up when: 1) only IgM antibodies were originally detected, 2) IgG antibodies were detected, but were not considered significant by Western blot, or 3) previously seronegative patients subsequently test positive by IFA or ELISA.

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDRH, Office of Device Evaluation (ODE)

Woody Dubois

(Division Sigr ical Laboratory Dev K97100 510(k) Number _

Prescription UseX
(Per 21 CFR 801.109

OR

Over-The-Counter Use

(Optional Format 1-2-96)