HARDYDISK ERYTHROMYCIN, 15MCG

K994135 · Hardy Diagnostics · JTN · Feb 16, 2000 · Microbiology

Device Facts

• Record ID: K994135
• Device Name: HARDYDISK ERYTHROMYCIN, 15MCG
• Applicant: Hardy Diagnostics
• Product Code: JTN · Microbiology
• Decision Date: Feb 16, 2000
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 866.1620
• Device Class: Class 2

Intended Use

HardyDisk™ Antimicrobial Seasitivity Disks are used for semi-quantitative in vitro susceptibility testing by the agar diffusion test proccdure (Kirby-Bauer) of rapidly growing and certain fastidious bacterial vathogens. Standardized methods for agar diffusion testing have been described for Euterobacteriaccas, Staphylococcus spp., Pseudomonas spn., Acinetobacter spp., Listerta monocytogenes, Enterococcus spp., other streptococci and, hy modified procedures, Haemophilus influenzae, Neisseria gonorrhoeae and Streptococcus pneumoniae. Hardy Disk™ Erythromycin is indicated for in vitro activity against Staphylococcus spp., and Streptococcus spp. including S. pneumoniae.

Device Story

HardyDisk™ Erythromycin 15mcg is an antimicrobial susceptibility test disk used in clinical microbiology laboratories. The device consists of a paper disk impregnated with a specific concentration of erythromycin. It is used in the Kirby-Bauer agar diffusion procedure to determine the susceptibility of rapidly growing and certain fastidious bacterial pathogens. The laboratory technician places the disk onto an inoculated agar plate; the antibiotic diffuses into the medium, creating a zone of inhibition around the disk. The size of this zone is measured and compared to standardized interpretive criteria to classify the bacteria as susceptible, intermediate, or resistant. This information assists clinicians in selecting appropriate antibiotic therapy for patients with bacterial infections.

Clinical Evidence

No clinical data. The device relies on established standardized in vitro susceptibility testing methods (Kirby-Bauer) for antimicrobial disks.

Technological Characteristics

Paper disk impregnated with 15mcg of Erythromycin. Operates via passive diffusion in agar medium. Used for semi-quantitative in vitro susceptibility testing. No electronic components, software, or energy source.

Indications for Use

Indicated for in vitro susceptibility testing of Staphylococcus spp. and Streptococcus spp. (including S. pneumoniae) using the Kirby-Bauer agar diffusion method.

Regulatory Classification

Identification

An antimicrobial susceptibility test disc is a device that consists of antimicrobic-impregnated paper discs used to measure by a disc-agar diffusion technique or a disc-broth elution technique the in vitro susceptibility of most clinically important bacterial pathogens to antimicrobial agents. In the disc-agar diffusion technique, bacterial susceptibility is ascertained by directly measuring the magnitude of a zone of bacterial inhibition around the disc on an agar surface. The disc-broth elution technique is associated with an automated rapid susceptibility test system and employs a fluid medium in which susceptibility is ascertained by photometrically measuring changes in bacterial growth resulting when antimicrobial material is eluted from the disc into the fluid medium. Test results are used to determine the antimicrobial agent of choice in the treatment of bacterial diseases.

Submission Summary (Full Text)

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Food and Drug Administration 2098 Gaither Road Rockville MD 20850

FEB 1 6 2000

Ms. Melissa M. Traylor, RAC Director of Technical Services Regulatory Affairs Hardy Diagnostics 1430 West McCoy Lane Santa Maria, California 93455

K994135 Re:

Trade Name: HardyDisk™ Erythromycin 15mcg Regulatory Class: II Product Code: JTN Dated: December 7, 1999 Received: December 7, 1999

Dear Ms. Traylor:

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.

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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 [phone]. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at [phone]. 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 [phone] or [phone] or at its internet address "http://www.fda.gov/cdrh/dsma/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

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Phoenix Arizona from Ave., \$105 tesa, A7 A5710 Try: [phone] Fex. 10021464-9520

## Indications for Use Statement-HardyDisk™ Erythromycin, 15mcg

HardyDisk™ Antimicrobial Seasitivity Disks are used for semi-quantitative in vitro susceptibility testing by the agar diffusion test proccdure (Kirby-Bauer) of rapidly growing and certain fastidious bacterial vathogens. Standardized methods for agar diffusion testing have been described for Euterobacteriaccas, Staphylococcus spp., Pseudomonas spn., Acinetobacter spp., Listerta monocytogenes, Enterococcus spp., other streptococci and, hy modified procedures, Haemophilus influenzae, Neisseria gonorrhoeae and Streptococcus pneumoniae.

Hardy Disk™ Erythromycin is indicated for in vitro activity against Staphylococcus spp., and Streptococcus spp. including S. pneumoniae.

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Concurrence of CDRH-ODE

Woody Dubose

atory Devices ivision of Clinic 510(k) Number

Prescription Use (per 21 CFR 801.109)

OR

Over-the Counter-Use ((.)ptional format 1-2-96)

Scring the laboratorian since 1980