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510(k) Data Aggregation

    K Number
    K994356
    Device Name
    IMMUNOCYT
    Manufacturer
    Date Cleared
    2000-02-23

    (62 days)

    Product Code
    Regulation Number
    864.1860
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    ImmunoCyt is a qualitative direct immunocytofluorescence assay intended for use in conjunction with cytology to increase the overall sensitivity for the detection of tumor cells exfoliated in the urine of patients previously diagnosed with bladder cancer. ImmunoCyt is indicated for use as an aid in the management of bladder cancer in conjunction with urinary cytology and cystoscopy.

    Device Description

    ImmunoCyt is an in vitro diagnostic device that contains a solution of three monoclonal antibodies. Two antibodies are reactive to epitopes selectively detected on a mucin found in bladder cancer cells, and one antibody reacts with a bladder cancer-associated glycosylated form of the carcinoembryonic antigen. The antibodies are coupled with fluorescent markers. This solution is used to detect tumor cells exfoliated in the urine of bladder cancer patients. ImmunoCyt also contains a sample fixative and a blocking solution, as well as positive and negative control cells.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the ImmunoCyt device, based on the provided 510(k) summary:

    Acceptance Criteria and Device Performance

    The 510(k) summary primarily focuses on demonstrating substantial equivalence to predicate devices, rather than explicit pre-defined acceptance criteria for ImmunoCyt's performance. However, the reported sensitivity and specificity values against the predicate devices imply a comparative acceptance.

    Acceptance Criteria (Implied)Reported ImmunoCyt PerformancePredicate Device 1 (Bard BTA stat Test) PerformancePredicate Device 2 (AuraTek FDP) Performance
    Sensitivity94%66%67%
    Specificity50%80%70%

    Note on "Acceptance Criteria": It's crucial to understand that for a 510(k) submission, the primary "acceptance criterion" is often substantial equivalence to a legally marketed predicate device. This means demonstrating that the new device is as safe and effective as the predicate. While ImmunoCyt's stated sensitivity is higher than the predicates, its specificity is lower. The FDA ultimately found it substantially equivalent due to other factors and its intended use in conjunction with cytology.


    Study Details

    2. Sample sizes and data provenance:

    • Test Set for Sensitivity: 87 urine samples from patients with bladder tumor recurrences confirmed by histology.
    • Test Set for Specificity 1 (monitored patients): 154 urine samples from patients with negative cystoscopy (monitored for bladder tumor recurrence).
    • Test Set for Specificity 2 (normal individuals): 170 urine samples from normal individuals (without genitourinary symptoms).
    • Test Set for Specificity 3 (other GU disorders): 100 urine samples from patients with various genitourinary disorders other than bladder cancer, as established by cystoscopy.
    • Data Provenance: Samples were collected retrospectively from 14 hospital centers in Canada.

    3. Number of experts used to establish the ground truth for the test set and their qualifications:

    • The document does not explicitly state the number of experts or their qualifications for establishing the ground truth (histology or cystoscopy results). It only states "confirmed by histology" or "established by cystoscopy." Usually, these are performed and interpreted by pathologists and urologists, respectively, but specific numbers and experience are not provided.

    4. Adjudication method for the test set:

    • The document does not explicitly describe an adjudication method (e.g., 2+1, 3+1). The ground truth appears to be based on clinical and pathological findings (histology, cystoscopy) as standard clinical practice rather than a consensus interpretation of the ImmunoCyt results themselves for ground truth establishment.

    5. If a multi-reader multi-case (MRMC) comparative effectiveness study was done:

    • A formal MRMC comparative effectiveness study in the sense of human readers with and without AI assistance was not conducted.

    • However, a reproducibility study was performed that involved multiple readers and multiple laboratories to assess within-reader, between-reader, and between-laboratory variability of the ImmunoCyt device's interpretation. This is different from a comparative effectiveness study of the device aiding human readers.

      • Within-reader variability: Three readers from three different laboratories, each performing triplicate and blinded readings of one panel of three patient slides and one panel of three mock samples.
      • Between-reader variability: Nine readers from three different laboratories, each performing single and blinded reading of a panel of nine mock samples slides.
      • Between-laboratory variability: Three readers performing single and blinded reading of four patient slides for each level of positivity.
    • Effect size improvement with AI vs without AI assistance: Not applicable, as this type of MRMC study was not performed.

    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

    • The ImmunoCyt device itself is an in vitro diagnostic immunocytofluorescence assay, which implies a laboratory technician/microscopist is reading the stained cells. It's not an "algorithm" in the typical standalone AI sense. The performance reported (sensitivity and specificity) is the standalone performance of the assay as interpreted by human observers, separate from the ground truth.
    • Its intended use is “in conjunction with cytology” which means it's an additive test to a human-interpreted cytology result.

    7. The type of ground truth used:

    • Clinical Ground Truth:
      • For bladder cancer recurrence confirmation: Histology.
      • For absence of bladder cancer in monitored patients: Negative cystoscopy.
      • For normal individuals and other genitourinary disorders: Cystoscopy (to establish presence/absence of cancer or other conditions).

    8. The sample size for the training set:

    • The document does not explicitly mention a training set size. As ImmunoCyt is an antibody-based immunocytochemistry assay, rather than a machine learning algorithm, the concept of a "training set" for model development isn't directly applicable in the same way it would be for an AI device. The manufacturing and QC processes would be more analogous to its "training."

    9. How the ground truth for the training set was established:

    • Not applicable as it's not an AI/ML device with a distinct "training set" in the conventional sense. The "ground truth" for developing and validating the antibodies and assay components would have been established through standard biological and chemical methods during its development.
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