(56 days)
The Varelisa® ReCombi ANA Screen EIA kit is designed for the qualitative determination of eight antinuclear antibodies in human serum or plasma to aid in the diagnosis of systemic rheumatic diseases such as SLE (Systemic Lupus Erythematosus), Scleroderma (Progressive Systemic Sclerosis), MCTD (Mixed Connective Tissue Disease), SS (Sjögren's Syndrome) and Polymyositis/ Dermatomyositis. The Varelisa ReCombi ANA Screen detects antibodies against dsDNA, RNP(68kDa, A, C), Sm(B,B',D) SS-A/Ro(52kDa, 60kDa), SS-B/La, Scl-70, Centromere and Jo-1 in a single microwell.
The Varelisa ReCombi ANA Screen is an enzyme immunoassay for the qualitative determination of antinuclear antibodies in serum or plasma. Designed as a screen assay, it detects 8 antinuclear antibodies in a single microwell. The determination of antinuclear antibodies (ANA) is of central importance for the clinical diagnosis of rheumatic diseases. The presence of ANA suggests the possibility of rheumatic autoimmune diseases. These diseases include Systemic Lupus Erythematosus, Polymyositis/ Dermatomyositis, Scleroderma, Sjögren's Syndrome and Mixed Connective Tissue Diseases.
Varelisa ReCombi ANA Screen is an indirect noncompetitive enzyme immunoassay. The wells of a microplate are coated with human recombinant, native affinity purified nuclear antigens and dsDNA. Antibodies specific for the nuclear antigens present in a patient sample bind to these antigens.
In a second step the enzyme labeled second antibody (Conjugate) binds to the antigenantibody complex which leads to the formation of an enzyme labeled antigen-antibody sandwich complex.
The enzyme labeled antigen-antibody complex converts the added substrate to form a colored solution. The rate of color formation from the chromogen is a function of the amount of Conjugate complexed with the bound antibody and thus is proportional to the initial concentration of the respective antibodies in the patient sample.
1. Acceptance criteria and reported device performance:
| Acceptance Criteria (Implicit) | Reported Device Performance |
|---|---|
| Substantial equivalence to the predicate device (Varelisa® ANA-8-Screen Assay). | The Varelisa® ReCombi ANA Screen showed a 97.5% agreement with the predicate device (Varelisa® ANA-8-Screen) when 7 dsDNA positive samples (not detectable by the predicate) were excluded. |
| Ability to detect antibodies against dsDNA, in addition to the analytes detected by the predicate device. | The Varelisa® ReCombi ANA Screen demonstrably detects antibodies against dsDNA, which the predicate device does not. This was confirmed by the exclusion of 7 dsDNA positive samples that tested positive with the new device and negative with the predicate. |
| High correlation between the new device and the predicate device for shared analytes. | A linear regression analysis of the data (comparing the new device to the predicate) resulted in the equation y = 0.91x + 0.05 with an R² value of 0.93, indicating an excellent correlation. |
| Minimal discordance, especially concerning samples near the equivocal zone, between the new device and the predicate for shared analytes. | For the 3 discordant samples, they were borderline near the upper or lower limit of the equivocal zone and differed by a maximum of 0.3 Ratio, suggesting good agreement even for borderline cases. |
| Qualitative determination of eight antinuclear antibodies in human serum or plasma to aid in the diagnosis of systemic rheumatic diseases. | The device's intended use statement and the correlation study results demonstrate its capability for qualitative determination of the specified antibodies, performing comparably (and with added functionality for dsDNA) to a previously cleared device for aiding in the diagnosis of systemic rheumatic diseases. |
Note: The acceptance criteria are largely implied by the nature of a 510(k) submission, which focuses on demonstrating substantial equivalence to a predicate device. The primary performance metric presented is the agreement rate and correlation with the predicate device.
2. Sample size used for the test set and data provenance:
- Sample Size for the Test Set: 129 samples.
- Data Provenance: The document does not specify the country of origin. It is a retrospective study comparing a new device to an existing predicate device using collected samples.
3. Number of experts used to establish the ground truth for the test set and their qualifications:
This information is not provided in the summary. The study is a comparison between two devices, not an evaluation against an independent gold standard established by experts.
4. Adjudication method for the test set:
This information is not provided in the summary. Given it's a direct comparison between two assays, an adjudication method for reconciling differences between human readers or separate ground truth methodologies isn't applicable in the same way it would be for image-based or interpretation-heavy diagnostic studies. The "adjudication" in this context involved the exclusion of 7 dsDNA positive samples due to the known difference in detectable analytes between the new device and the predicate.
5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance:
No, an MRMC comparative effectiveness study was not done. This study is for an in vitro diagnostic (IVD) immunoassay, not an AI-powered diagnostic imaging device that involves human reader interpretation. Therefore, the concept of human readers improving with AI assistance is not applicable here.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Assuming "standalone" refers to the device's inherent performance without human interpretation influencing the measurement, yes, a standalone performance study was done in the sense that the Varelisa ReCombi ANA Screen (and the predicate device) are automated or semi-automated laboratory assays that quantitatively or qualitatively measure analytes in a sample. The results are generated by the device itself based on the reaction, rather than requiring human interpretation of complex outputs in the way an imaging AI might. The study directly compares the results from the new device to the predicate device.
7. The type of ground truth used:
The "ground truth" for this study was essentially the results obtained from the predicate device, Varelisa® ANA-8-Screen Assay, for the analytes it detects. For the dsDNA specificity, the ground truth was the known characteristic of the new device to detect dsDNA, which the predicate did not. This is a comparative study, not one establishing absolute diagnostic accuracy against a clinical outcome or pathology.
8. The sample size for the training set:
This information is not provided in the summary. This appears to be a clinical validation study for a finished device, not a development or training phase for a machine learning model.
9. How the ground truth for the training set was established:
This information is not provided in the summary, as there is no mention of a training set or a machine learning component for this device.
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510(K) SUMMARY OF SAFETY AND EFFECTIVENESS 9.
This summary of safety and effectiveness information is being submitted in accordance with the requirements of The Safety Medical Devices Act of 1990 (SMDA 1990) and 21 CFR Part 807.92.
| Assigned 510(k) Number: | K993108 |
|---|---|
| Date of Summary Preparation: | September 8, 1999 |
| Distributor: | Pharmacia & UpjohnDiagnostics Division, US Operation7425-248-17000 Portage RoadKalamazoo, MI 49001 |
| Manufacturer: | Pharmacia & Upjohn Diagnostics GmbH Co. KGMunzingerstrasse 7D-79111 Freiburg, Germany |
| Company Contact Person: | Karen E.MatisManager, Regulatory Affairs and QualityManagementDiagnostics DivisionUS Operation7000 Portage Road7425-248-01Kalamazoo, MI 49001(614) 794-3324 (Phone)(614) 794-0266 (Fax) |
| Device Name: | Varelisa® ReCombi ANA Screen |
| Common Name: | Antinuclear antibody immunological test |
Classification:
| Product Name | Product Code | Class | CFR |
|---|---|---|---|
| Varelisa® ReCombi ANA Screen | 82LJM | II | 866.5100 |
00 00078RAS9v5.doc
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Substantial Equivalence to:
Varelisa® ANA-8-ScreenAssay
Intended Use Statement:
The Varelisa® ReCombi ANA Screen EIA kit is designed for the qualitative determination of eight antinuclear antibodies in human serum or plasma to aid in the diagnosis of systemic rheumatic diseases such as SLE (Systemic Lupus Erythematosus), Scleroderma (Progressive Systemic Sclerosis), MCTD (Mixed Connective Tissue Disease), SS (Sjögren's Syndrome) and Polymyositis/ Dermatomyositis. The Varelisa ReCombi ANA Screen detects antibodies against dsDNA, RNP(68kDa, A, C), Sm(B,B',D) SS-A/Ro(52kDa, 60kDa), SS-B/La, Scl-70, Centromere and Jo-1 in a single microwell.
General Description of the Device
The Varelisa ReCombi ANA Screen is an enzyme immunoassay for the qualitative determination of antinuclear antibodies in serum or plasma. Designed as a screen assay, it detects 8 antinuclear antibodies in a single microwell. The determination of antinuclear antibodies (ANA) is of central importance for the clinical diagnosis of rheumatic diseases. The presence of ANA suggests the possibility of rheumatic autoimmune diseases. These diseases include Systemic Lupus Erythematosus, Polymyositis/ Dermatomyositis, Scleroderma, Sjögren's Syndrome and Mixed Connective Tissue Diseases.
Varelisa® ReCombi ANA Screen, Test Principle
Varelisa ReCombi ANA Screen is an indirect noncompetitive enzyme immunoassay. The wells of a microplate are coated with human recombinant, native affinity purified nuclear antigens and dsDNA. Antibodies specific for the nuclear antigens present in a patient sample bind to these antigens.
In a second step the enzyme labeled second antibody (Conjugate) binds to the antigenantibody complex which leads to the formation of an enzyme labeled antigen-antibody sandwich complex.
The enzyme labeled antigen-antibody complex converts the added substrate to form a colored solution. The rate of color formation from the chromogen is a function of the amount of Conjugate complexed with the bound antibody and thus is proportional to the initial concentration of the respective antibodies in the patient sample.
00 00079
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Device Comparison:
A correlation study was performed comparing the new device. Varelisa ReCombi ANA Screen Assay, to the predicate device, Varelisa ANA-8-Screen. 129 samples, including 10 ANA Human Reference Sera and 20 apparently healthy blood donors were assayed using both tests.
Seven monospecific sera, equivocal and positive for dsDNA-Ab in the Varelisa ReCombi ANA Screen were excluded from the evaluation of the agreement between the assays. It is an expected result that these 7 sera would test positive with the new device and negative with the predicate device because the new device, Varelisa ReCombi ANA Screen contains antigens for the detection of dsDNA, whereas the predicate device, Varelisa ANA-8-Screen, does not detect the presence of dsDNA antibodies. With the elimination of the 7 dsDNA positive sera, the agreement in this study was 97.5% (119 out of 122 (129-7) samples). Three discordant samples were borderline either to the upper or lower limit of the equivocal zone and differ with a maximum of 0.3 Ratio.
A linear regression analysis of these data gives the following equation:
$$\begin{array}{|c|c|}\hline\hline\mathbf{y}=\mathbf{0.91x}+\mathbf{0.05}&\mathbf{R^2}=\mathbf{0.93}\\hline\hline\end{array}$$
| VarelisaANA-8-Screen | ||||
|---|---|---|---|---|
| n = 122 | positive | equivocal | negative | |
| VARELISA | positive | 77 | 0 | 0 |
| ReCombi | equivocal | 1 | 4 | 2 |
| ANA Screen | negative | 0 | 0 | 38 |
7 dsDNA-Ab positive samples were excluded from the evaluation
The new device Varelisa® ReCombi ANA Screen shows an excellent correlation with the predicate device, Varelisa ANA-8-Screen, and adds the ability to detect antibodies against dsDNA.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. Inside the circle is a stylized symbol that resembles a human figure or a flame, composed of three curved lines.
NOV I 2 1999
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
Ms. Karen E. Matis Manager, Regulatory Affairs and Quality Management Diagnostics Division, US Operations Pharmacia & Upjohn 7000 Portage Road 7425-248-01 Kalamazoo, Michigan 49001-0199
Re: K993108 Trade Name: Varelisa ReCombi ANA Screen EIA Regulatory Class: II Product Code: LJM Dated: September 16, 1999 Received: September 17, 1999
Dear Ms. Matis:
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 (OS) 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.
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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 (301) 443-6597, or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
Steven Sutman
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
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Varelisa® ReCombi ANA Screen 510(k) Submission Section 1. Indications For Use Statement
510(k) Number:
699308
Device Name: Varelisa® ReCombi ANA Screen
The Varelisa® ReCombi ANA Screen EIA kit is designed for the qualitative determination of eight antinuclear antibodies in human serum or plasma to aid in the diagnosis of systemic rheumatic diseases such as SLE (Systemic Lupus Erythematosus), Scleroderma (Progressive Systemic Sclerosis), MCTD (Mixed Connective Tissue Disease), SS (Sjögren's Syndrome) and Polymyositis/ Dermatomyositis. The Varelisa ReCombi ANA Screen detects antibodies against dsDNA, RNP(68kDa, A, C), Sm(B,B',D) SS-A/Ro(52kDa, 60kDa), SS-B/La, Sc1-70, Centromere and Jo-1 in a single microwell.
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 801.109)
OR
Over-The-Counter Use
Utter A. Mackin'
(Division Sign-Off)
Division of Clinical Laboratory Devices K093108
510(k) Number
000.11 00
§ 866.5100 Antinuclear antibody immunological test system.
(a)
Identification. An antinuclear antibody immunological test system is a device that consists of the reagents used to measure by immunochemical techniques the autoimmune antibodies in serum, other body fluids, and tissues that react with cellular nuclear constituents (molecules present in the nucleus of a cell, such as ribonucleic acid, deoxyribonucleic acid, or nuclear proteins). The measurements aid in the diagnosis of systemic lupus erythematosus (a multisystem autoimmune disease in which antibodies attack the victim's own tissues), hepatitis (a liver disease), rheumatoid arthritis, Sjögren's syndrome (arthritis with inflammation of the eye, eyelid, and salivary glands), and systemic sclerosis (chronic hardening and shrinking of many body tissues).(b)
Classification. Class II (performance standards).