K Number
K993547
Device Name
BECKMAN COULTER IMMAGE IMMUNOCHEMISTRY SYSTEM LOW CONCENTRATION IMMUNOGLOBULIN M (IGMLC) REAGENT, BECKMAN COULTER CEREB
Date Cleared
2000-02-01

(105 days)

Product Code
Regulation Number
866.5510
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent, when used in conjunction with Beckman Coulter's IMMAGE® Immunochemistry Systems and Cerebrospinal Fluid Protein Calibrator, is intended for the quantitative determination of human immunoglobulin M in serum and cerebrospinal fluid by rate nephelometry.
Device Description
The IMMAGE® Low Concentration Immunoglobulin M (IGMLC) Reagent and Cerebrospinal Fluid Calibrator are designed for optimal performance on the IMMAGE® Immunochemistry Systems. It is intended for the quantitative determination of immunoglobulin M in serum and cerebrospinal fluid.
More Information

Not Found

No
The summary describes a reagent and calibrator for a standard immunochemistry system using rate nephelometry, a well-established analytical technique. There is no mention of AI, ML, image processing, or any data analysis methods beyond standard statistical calculations for performance evaluation.

No.
The device is an in vitro diagnostic (IVD) reagent intended for quantitative determination of immunoglobulin M, which is used for diagnostic purposes, not for treating or preventing a disease.

Yes

The device is intended for the "quantitative determination of human immunoglobulin M in serum and cerebrospinal fluid," which is a measurement used for diagnostic purposes.

No

The device is a reagent and calibrator intended for use with a specific immunochemistry system, indicating it is a physical component of a larger diagnostic system, not software only.

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

Here's why:

  • Intended Use: The intended use explicitly states "intended for the quantitative determination of human immunoglobulin M in serum and cerebrospinal fluid by rate nephelometry." This describes a test performed on samples taken from the human body (serum and CSF) to provide information about a person's health status (immunoglobulin M levels).
  • Device Description: The description reinforces this by stating it's for the "quantitative determination of immunoglobulin M in serum and cerebrospinal fluid."
  • Performance Studies: The performance studies involve testing the device with human samples (serum and CSF) and comparing the results to a predicate device, which is typical for IVD submissions.
  • Predicate Device: The predicate devices listed are also IVD reagents used for similar diagnostic purposes.

The core function of the device is to analyze biological samples in vitro (outside the body) to provide diagnostic information, which is the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent, when used in coniunction with Beckman Coulter's IMMAGE® Immunochemistry Systems and Cerebrospinal Fluid Protein Calibrator, is intended for the quantitative determination of human immunoglobulin M in serum and cerebrospinal fluid by rate nephelometry.

Product codes

CFN

Device Description

The IMMAGE® Low Concentration Immunoglobulin M (IGMLC) Reagent and Cerebrospinal Fluid Calibrator are designed for optimal performance on the IMMAGE® Immunochemistry Systems. It is intended for the quantitative determination of immunoglobulin M in serum and cerebrospinal fluid.

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

Not Found

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

The data in the Premarket Notification on safety and effectiveness supports a finding of substantial equivalence to chemistry test systems already in commercial distribution. Equivalence is demonstrated through method comparison and imprecision experiments.

Serum Study Results: N=55, Slope=0.977, Intercept=9.12, Mean (IGMLC) mg/L=1039, Mean (predicate) mg/L=1054, Correlation Coefficient=0.988

CSF Study Results: N=51 (Test Positive), 51 (Test Negative), Test Positive=45, Test Negative=6, False Positives=0, False Negative=0, Sensitivity%=100%, Specificity%=100%

Estimated IMMAGE System IGMLC Reagent Imprecision (Serum):
Within-Run: Low: N=80, Mean=173 mg/L, SD=5.4 mg/L, %CV=3.2; Mid: N=80, Mean=869 mg/L, SD=14.6 mg/L, %CV=1.7; High: N=80, Mean=1779 mg/L, SD=31.8 mg/L, %CV=1.8
Total: Low: N=80, Mean=173 mg/L, SD=6.1 mg/L, %CV=3.5; Mid: N=80, Mean=869 mg/L, SD=21.8 mg/L, %CV=2.5; High: N=80, Mean=1779 mg/L, SD=35.5 mg/L, %CV=2.0

Estimated IMMAGE System IGALC Reagent Imprecision (CSF):
Within-Run: Low: N=80, Mean=0.536 mg/L, SD=0.0279 mg/L, %CV=5.2; Mid: N=80, Mean=4.77 mg/L, SD=0.096 mg/L, %CV=2.0; High: N=80, Mean=8.61 mg/L, SD=0.182 mg/L, %CV=2.1
Total: Low: N=80, Mean=0.536 mg/L, SD=0.0320 mg/L, %CV=6.0; Mid: N=80, Mean=4.77 mg/L, SD=0.197 mg/L, %CV=4.1; High: N=80, Mean=8.61 mg/L, SD=0.299 mg/L, %CV=3.5

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Serum Study Results: Slope=0.977, Intercept=9.12, Correlation Coefficient=0.988
CSF Study Results: Sensitivity%=100, Specificity%=100

Predicate Device(s)

K963868, K823884

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 866.5510 Immunoglobulins A, G, M, D, and E immunological test system.

(a)
Identification. An immunoglobulins A, G, M, D, and E immunological test system is a device that consists of the reagents used to measure by immunochemical techniques the immunoglobulins A, G, M, D, an E (serum antibodies) in serum. Measurement of these immunoglobulins aids in the diagnosis of abnormal protein metabolism and the body's lack of ability to resist infectious agents.(b)
Classification. Class II (performance standards).

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K993547

Image /page/0/Picture/2 description: The image shows the logo for Beckman Coulter. The logo consists of a circular graphic on the left and the company name on the right. The graphic is a stylized image of two curved lines within a circle. The text "BECKMAN COULTER" is written in bold, sans-serif font.

Summary of Safety & Effectiveness Beckman Coulter IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent Beckman Coulter™ Cerebrospinal Fluid Protein Calibrator (CSF CAL)

1.0 Submitted By:

Richard T. Ross Staff Regulatory Specialist, Product Submissions Beckman Coulter, Inc. 200 South Kraemer Blvd., W-104 Brea, California 92822-8000 Telephone: (714) 961-4912 FAX: (714) 961-4123

2.0 Date Submitted: 01 October 1999

3.0 Device Name(s):

3.1 Proprietary Names

Beckman Coulter IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent Beckman Coulter™ Cerebrospinal Fluid Protein Calibrator (CSF CAL)

3.2 Classification Name

Method, Nephelometric, Immunoglobulins (G, A, M) (21 CFR §866.5510)

4.0 Predicate Device(s):

IMMAGE SystemSerum PredicateManufacturerDocket Number
IMMAGE System
Low Concentration
Immunoglobulin M
(IGMLC) Reagent
Cerebrospinal Fluid
Protein CalibratorIMMAGE
Immunochemistry
Systems
Immunoglobulin M
(IGM) ReagentBeckman
Instruments, Inc.K963868
CSF PredicateManufacturerDocket Number
Paragon®
Immunofixation
Electrophoresis ReagentBeckman
Instruments, Inc.K823884

5.0 Description:

The IMMAGE® Low Concentration Immunoglobulin M (IGMLC) Reagent and Cerebrospinal Fluid Calibrator are designed for optimal performance on the IMMAGE® Immunochemistry Systems. It is intended for the quantitative determination of immunoglobulin M in serum and cerebrospinal fluid.

6.0 Intended Use:

The IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent, when used in coniunction with Beckman Coulter's IMMAGE® Immunochemistry Systems and Cerebrospinal Fluid Protein Calibrator, is intended for the quantitative determination of human immunoglobulin M in serum and cerebrospinal fluid by rate nephelometry.

Mailing Address: 200 S. Kraemer Boulevard P.O. Box 8000 Brea, CA 92822-8000

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7.0 Comparison to Predicate(s):

The following tables show similarities and differences between the predicate identified in Section 4.0 of this summary.

SIMILARITIES to the SERUM PREDICATE

IMMAGE SystemAspect/CharacteristicComments
IMMAGE System IGMLC ReagentIntended useSame as
Predicate
device
Rate nephelometry method
Antibody is goat antihuman IgM
Cerebrospinal Fluid Protein CalibratorSingle level calibrator
SIMILARITIES to the CSF PREDICATE
IMMAGE SystemAspect/CharacteristicComments
IMMAGE System IGMLCIntended useSame as predicate device
ReagentSerum and CSF are acceptable sample types
Antibody is goat antihuman IgM
Cerebrospinal Fluid Protein
CalibratorSingle level calibratorN/A
Protein is of human serum origin
added to human urine basePredicate has
no calibrator

DIFFERENCES from the SERUM PREDICATE

IMMAGE SystemAspect/CharacteristicComments
IMMAGE System
IGMLC ReagentSerum or CSF as sample typePredicate cleared for serum only
CSF CALCSF CAL Cerebrospinal Fluid
Calibrator is a single level,
human urine base, azide
preserved liquidPredicate calibrator is a single
level, human serum based, azide
preserved liquid

DIFFERENCES from the CSF PREDICATE

IMMAGE SystemAspect/CharacteristicComments
IMMAGE System
IGMLC ReagentIMMAGE System IGMLC is
a rate nephelometric reaction
at a controlled 37°CPredicate is a gel immunofixation
electrophoresis at room
temperature
IMMAGE System
IGMLC ReagentIMMAGE System provides
quantitative result based on
calibration curveQualitative result based on visual
comparison to known controls
IMMAGE System
IGMLC ReagentSample may be loaded
and/or run neat without pre-
analysis concentrationSample concentration typically
required prior to IFE analysis
CSF CALSingle level calibratorPredicate has no calibrator

Beckman Coulter, Inc. IMMAGE® Low Concentration Immunoglobulin M (IGMLC) Reagent Filename: igmlcSSE2.doc

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8.0 Summary of Performance Data:

The data in the Premarket Notification on safety and effectiveness supports a finding of substantial equivalence to chemistry test systems already in commercial distribution. Equivalence is demonstrated through method comparison and imprecision experiments.

Serum Study ResultsCSF Study Results
N55N51 51
Slope0.977Test Positive51 45
Intercept9.12Test Negative0 6
Mean (IGMLC) mg/L1039False Positives6 0
Mean (predicate) mg/L1054False Negative0 0
Correlation Coefficient0.988Sensitivity %100 100
Specificity %89.5 100
% sensitivity = (N/(N + false negative))*100
% specificity = (N/(N + false positive))*100

Method Comparisons

Estimated IMMAGE System IGMLC Reagent Imprecision (Serum)

PRECISIONSAMPLENMEAN (mg/L)SD (mg/L)% CV
Within-RunLow801735.43.2
Within-RunMid8086914.61.7
Within-RunHigh80177931.81.8
TotalLow801736.13.5
TotalMid8086921.82.5
TotalHigh80177935.52.0

Estimated IMMAGE System IGALC Reagent Imprecision (CSF)

PRECISIONSAMPLENMEAN (mg/L)SD (mg/L)% CV
Within-RunLow800.5360.02795.2
Within-RunMid804.770.0962.0
Within-RunHigh808.610.1822.1
TotalLow800.5360.03206.0
TotalMid804.770.1974.1
TotalHigh808.610.2993.5

This summary of safety and effectiveness is being submitted in accordance with the requirements of the Safe Medical Device Act of 1990 and the implementing regulation 21 CFR 807.92.

Beckman Coulter, Inc. IMMAGE® Low Concentration Immunoglobulin M (IGMLC) Reagent Filename: igmlcSSE.doc

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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services - USA. The logo is a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing right, with flowing lines representing hair or clothing.

FEB 1 2000 Food and Drug Administration 2098 Gaither Road Rockville MD 20850

Mr. Richard T. Ross Staff Regulatory Specialist Beckman Coulter, Inc. 200 S. Kraemer Boulevard, W-104 P.O. Box 8000 Brea, California 92622-8000

Re: K993547

Trade Name: IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent Beckman Coulter™ Cerebrospinal Fluid Protein Calibrator (CSF CAL) Regulatory Class: II Product Code: CFN Dated: December 20, 1999 Received: December 21, 1999

Dear Mr. Ross:

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 OS 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

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" (21CFR 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 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

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K993547

page _ of _

510(k) Number (if known): Not yot assigned

Device Name:

IMMAGE® Immunochemistry System

Low Concentration Immunoglobulin M (IGMLC) Reagent

Beckman Coulter™ Cerebrospinal Fluid Protein Calibrator (CSF CAL)

Indications for Use:

The IMMAGE® Immunochemistry System Low Concentration Immunoglobulin M (IGMLC) Reagent, when used in conjunction with Beckman Coulter's IMMAGE® Immunochemistry Systems and Cerebrospinal Fluid Protein Calibrator, is intended for the quantitative determination of human immunoglobulin M in serum and cerebrospinal fluid by rate nephelometry.

Clinical Significance:

The concentration ratio of immunoglobulins in CSF and serum detects increased permeability of the blood-CSF barrier and intrathecal synthesis of immunoglobulins.

The permeability of the blood-CSF barrier to plasma increases due to brain tumor, intracerebral hemorrhage, meningitis, encephalitis, and bacterial infections. The intrathecal synthesis of immunoglobulins is important in the diagnosis of diseases of the Central Nervous Systems (CNS).

Method, Nephelometric, Immunoglobulins (G, A, M) (21 CFR §866.5510)

(b) Classification. Class II.

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

Concurrence of CDRH, Office of Device Evaluation (ODE)
signature
(Division Sign-Off)
Division of Clinical Laboratory Devices

510(k) NumberK993547
------------------------
Prescription Use (per 21 CFR 801.109)OROver-the-Counter Use
Optional Format 1-2-96