K Number
K992296
Device Name
PASCO MIC AND MIC/ID PANELS, VANCOMYCIN
Date Cleared
1999-09-21

(76 days)

Product Code
Regulation Number
866.1640
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Pasco MIC and MIC/ID panels are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement of category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms. This 510(k) notification is for the addition Vancomycin to Pasco panels at concentrations of 0.03 to 2 mcg/ml for use in determining the susceptibility of S. pneumoniae and non-pneumococcal streptococci.
Device Description
Varying concentrations of antimicrobial agents (usually in two-fold dilutions) are dispensed into the Pasco panels and the panels are then frozen. Panels are thawed prior to use, inoculated with the test organisms, incubated the traditional 16-24 hours and panels are then observed for visible growth or color changes as described in the package insert. The lowest concentration of each antimicrobial agent with no apparent visible growth of the test organism is recorded as the minimum inhibitory concentration (MIC). Changes in pH and production of specific metabolites from growth in biochemical substrates are interpreted as described in the package insert for conventional tubed media.
More Information

Not Found

No
The device description and performance studies focus on traditional microbiological methods (visible growth, color changes, pH changes) and do not mention any AI/ML components or algorithms for interpretation or analysis.

No

This device is designed for in vitro diagnostic purposes, specifically for determining the susceptibility of bacteria to antimicrobial agents and their biochemical identification. It provides information to guide treatment rather than directly providing therapy.

Yes

The device is explicitly stated to be used for "quantitatively measuring ... the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms," which directly relates to diagnosing bacterial infections and guiding treatment decisions.

No

The device description clearly outlines a physical panel with dispensed antimicrobial agents that are inoculated and incubated, requiring visual observation for interpretation. This is a hardware-based diagnostic device, not software-only.

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

Here's why:

  • Intended Use: The intended use explicitly states that the panels are used for "quantitatively measuring... the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms." This is a classic definition of an in vitro diagnostic test, as it involves analyzing biological samples (bacterial pathogens) outside of the body to provide information for diagnosis or treatment.
  • Device Description: The description details how the panels are used to test bacterial growth in the presence of antimicrobial agents and interpret biochemical reactions. This process is performed in vitro (in a lab setting).
  • Performance Studies: The performance studies describe testing the device against bacterial strains to determine its accuracy in measuring susceptibility and agreement with a reference method. This type of testing is characteristic of IVD devices to demonstrate their clinical validity.

The information provided clearly indicates that this device is designed to be used in a laboratory setting to perform tests on biological samples for diagnostic purposes, which aligns with the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

PASCO MIC AND MIC/ID PANELS are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement or category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms. This 510(k) notification is for the addition Vancomycin to Pasco panels at concentrations of 0.03 to 2 mcg/ml for use in determining the susceptibility of S. pneumoniae and non-pneumococcal streptococci.

Product codes

JWY

Device Description

Varying concentrations of antimicrobial agents (usually in two-fold dilutions) are dispensed into the Pasco panels and the panels are then frozen. Panels are thawed prior to use, inoculated with the test organisms, incubated the traditional 16-24 hours and panels are then observed for visible growth or color changes as described in the package insert. The lowest concentration of each antimicrobial agent with no apparent visible growth of the test organism is recorded as the minimum inhibitory concentration (MIC). Changes in pH and production of specific metabolites from growth in biochemical substrates are interpreted as described in the package insert for conventional tubed media.

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

Not Found

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

Not Found

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

Comparative testing of the Pasco test panel to a reference panel was performed at two sites using CDC challenge strains and clinical isolates. Test results of the 101 S. pneumoniae strains demonstrated acceptable Essential Agreement (EA) of 98.1% upon initial testing and an EA of 98.7% on retesting. No major (M), very major (VM) or minor errors were observed. Category agreement (CA) was 100% with no additional random minor errors noted. Test results of the 130 non-pneumococcal strains demonstrated acceptable Essential Agreement (EA) of 100% on initial testing with a Category Agreement (CA) of 100%.

Summary of Performance Studies

STUDY TYPE: Comparative testing, Reproducibility testing, QC performance testing.
SAMPLE SIZE: 101 S. pneumoniae strains, 130 non-pneumococcal strains, 12 organisms for reproducibility.
KEY RESULTS: Test results of the 101 S. pneumoniae strains demonstrated acceptable Essential Agreement (EA) of 98.1% upon initial testing and an EA of 98.7% on retesting. No major (M), very major (VM) or minor errors were observed. Category agreement (CA) was 100% with no additional random minor errors noted. Test results of the 130 non-pneumococcal strains demonstrated acceptable Essential Agreement (EA) of 100% on initial testing with a Category Agreement (CA) of 100%. QC endpoints for the QC organism S. pneumoniae ATCC 49619 from both the reference and Pasco panels throughout testing were within the recommended NCCLS acceptable range. Overall reproducibility data demonstrated 100% within the acceptable plus or minus 1 dilution.

Key Metrics

Essential Agreement (EA) of 98.1% (S. pneumoniae, initial), EA of 98.7% (S. pneumoniae, retesting), Category Agreement (CA) of 100% (S. pneumoniae and non-pneumococcal), Essential Agreement (EA) of 100% (non-pneumococcal).

Predicate Device(s)

K982235, K982156, K980955, K974362, K973317, K973695, K972567, K971951, K946126

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 866.1640 Antimicrobial susceptibility test powder.

(a)
Identification. An antimicrobial susceptibility test powder is a device that consists of an antimicrobial drug powder packaged in vials in specified amounts and intended for use in clinical laboratories for determining in vitro susceptibility of bacterial pathogens to these therapeutic agents. Test results are used to determine the antimicrobial agent of choice in the treatment of bacterial diseases.(b)
Classification. Class II (performance standards).

0

K992296

SEP 2 1 1999

510(k) SUMMARY (page 1 of 2)

DATE:June 24, 1999
CONTACT PERSON:Linda K. Dillon
Chuck Lakel
TRADE NAME OF DEVICE:Pasco MIC and MIC/ID Panels
COMMON NAME:Antimicrobial Susceptibility Test
CLASSIFICATION NAME:Class II Antimicrobial Susceptibility Test Microbiology Panel
#83

SUBSTANTIAL EQUIVALENCE:

In review of previous 510(k) notifications for the Pasco MIC and MIC/ID panels (most recently: K982235, July 30, 1998 RE: Minocycline; K982156, July 29, 1998 RE: Cefdinir; K980955 May 18. 1998 RE: Trovafloxacin: K974362. February 12, 1998 RE: Cefepime; K973317, November 14, 1997 RE: Cefpodoxime: K973695, November 5, 1997 RE: Meropenem; K972567, August 20,1997 RE: Sparfloxacin: K971951. August 15. 1997 RE: Levofloxacin: and K946126, January 17, 1995 RE: Detection of resistant pneumococci), the FDA has determined the Pasco panels to be substantially equivalent to devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments.

The term "substantial equivalence" as used in this 510(k) notification is limited to the definition of substantial equivalence as found in the Federal Food, Drug, and Cosmetic Act, as amended and as applied under 21 CFR 807, Subpart E under which a device can be marketed without pre-market approval or reclassification. A determination of substantial equivalency under this notification is not intended to have any bearing whatsoever on the resolution of patent infringement suits or any other patent matters. No statements related to, or in support of substantial equivalence herein shall be construed as an admission against interest under the US Patent Laws or their application by the courts.

DESCRIPTION OF THE DEVICE:

Varying concentrations of antimicrobial agents (usually in two-fold dilutions) are dispensed into the Pasco panels and the panels are then frozen. Panels are thawed prior to use, inoculated with the test organisms, incubated the traditional 16-24 hours and panels are then observed for visible growth or color changes as described in the package insert.

1

The lowest concentration of each antimicrobial agent with no apparent visible growth of the test organism is recorded as the minimum inhibitory concentration (MIC). Changes in pH and production of specific metabolites from growth in biochemical substrates are interpreted as described in the package insert for conventional tubed media.

INTENDED USE FOR THE PASCO MIC AND MIC/ID PANELS:

PASCO MIC AND MIC/ID PANELS are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement or category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms.

SUMMARY/CONCLUSION OF SUBSTANTIAL EQUIVALENCE TESTING:

Test panels containing Vancomycin at concentrations ranging from 2-0.03 mcg/ml were prepared in-house at Pasco using routine manufacturing procedures. Comparative testing of the Pasco test panel to a reference panel was performed at two sites using CDC challenge strains and clinical isolates.

Test results of the 101 S. pneumoniae strains demonstrated acceptable Essential Agreement (EA) of 98.1% upon initial testing and an EA of 98.7% on retesting. No major (M), very major (VM) or minor errors were observed. Category agreement (CA) was 100% with no additional random minor errors noted. Test results of the 130 non-pneumococcal strains demonstrated acceptable Essential Agreement (EA) of 100% on initial testing with a Category Agreement (CA) of 100%.

QC endpoints for the QC organism S. pneumoniae ATCC 49619 from both the reference and Pasco panels throughout testing were within the recommended NCCLS acceptable range.

Reproducibility testing of 12 organisms at each site provided 12 organisms with on-scale endpoints. Overall reproducibility data demonstrated 100% within the acceptable plus or minus 1 dilution.

The results of the clinical testing, reproducibility testing and OC performance testing supports Substantial Equivalence as outlined in the FDA draft document "Review Criteria For Assessment Of Antimicrobial Susceptibility Devices" (May 1991).

2

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three curved lines representing its body and wings. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the eagle.

SEP 2 1 1999

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

Ms. Linda K. Dillon Technical Manager Pasco Laboratories, Inc. 12750 West Forty-Second Avenue Wheat Ridge, Colorado 80033

K992296 Re:

Trade Name: Pasco MIC and MIC/ID Panels (Vancomycin) Regulatory Class: II Product Code: JWY Dated: June 24, 1999 Received: July 7, 1999

Dear Ms. Dillon:

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 Eederal 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.

3

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 vours.

Steven Putman

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

4

K 992296

Device Name:

PASCO MIC and MIC/ID Panels; Inclusion of Vancomycin

A

Indication For Use:

Pasco MIC and MIC/ID panels are used for quantitatively measuring (with the exception of the Breakpoint/ID panel which provides qualitative measurement of category results) the susceptibility of rapidly growing aerobic and facultative anaerobic bacterial pathogens to a battery of antimicrobial agents and determining the biochemical identification of those organisms.

This 510(k) notification is for the addition Vancomycin to Pasco panels at concentrations of 0.03 to 2 mcg/ml for use in determining the susceptibility of S. pneumoniae and non-pneumococcal streptococci.

the. Peete Acting for DR. Dubois, Ph.D.

(Division Sign-Off) Division of Clinical Laboratory Devices 510(k) Number.

Prescription Use (Per 21 CFR 801.109) OR

Over-The Counter Use

(Optional Format 1-2-96)