Identification. A BCR-ABL quantitation test is identified as a reverse transcription-quantitative polymerase chain reaction (RT-qPCR) test for the quantitation of BCR-ABL1 expressed on the International Scale (IS) and control transcripts in total RNA from whole blood of diagnosed t(9;22) positive chronic myeloid leukemia (CML) patients during monitoring of treatment with tyrosine kinase inhibitors. This test is not intended for the diagnosis of CML.
Classification. Class II (special controls). The special controls for this device are:
Premarket notification submissions must include the following information:
The indication for use must indicate the variant(s) for which the assay was designed and validated, for example BCR-ABL e13a2 and/or e14a2.
A detailed description of all components in the test, including the following:
A detailed description of the test components, all required reagents, instrumentation and equipment, including illustrations or photographs of non-standard equipment or methods;
Detailed documentation of the device software including, but not limited to, standalone software applications and hardware-based devices that incorporate software;
Methodology and protocols for control procedures for the assay to allow reporting on the International Scale;
A description of the result outputs, analytical sensitivity of the assay, and the range of values that will be reported; and
A description of appropriate internal and external controls that are recommended or provided. The description must identify those control elements that are incorporated into the testing procedure.
Information that demonstrates the performance characteristics of the test, including:
For indications for use based on a threshold established in a predicate device of this generic type, device performance data from either a method comparison study to the predicate device or through a clinical study demonstrating clinical validity using well-characterized prospectively or retrospectively obtained clinical specimens, as appropriate, representative of the intended use population;
For indications for use based on a threshold not established in a predicate device of this generic type, device performance data from a clinical study demonstrating clinical validity using well-characterized prospectively or retrospectively obtained clinical specimens, as appropriate, representative of the intended use population;
Device reproducibility data generated, using a minimum of three sites, of which at least two sites must be external sites, with two operators at each site. Each site must conduct a minimum of three runs per operator over non-consecutive days evaluating a minimum of five different BCR-ABL concentrations that span and are well distributed over the measuring range and include MR3 (0.1 percent IS). Results shall be reported as the standard deviation and percentage coefficient of variation for each level tested. Prespecified acceptance criteria must be provided and followed;
Device precision data using clinical samples to evaluate the within-lot, between-lot, within-run, between run, and total variation;
Device linearity data using a dilution panel created from clinical samples;
Device analytic sensitivity data, including limit of blank, limit of detection, and limit of quantification;
Device specificity data, including interference and cross-contamination; and
Device stability data, including real-time stability of samples under various storage times, temperatures, and freeze-thaw conditions.
Identification of risk mitigation elements used by your device, including a detailed description of all additional procedures, methods, and practices incorporated into the instructions for use that mitigate risks associated with testing using your device.
Your 21 CFR 809.10 compliant labeling must include the following:
The intended use in your 21 CFR 809.10(a)(2) and (b)(2) complaint labeling must include an indication for use statement that reads “This test is not intended for the diagnosis of CML”; and
A detailed description of the performance studies conducted to comply with paragraph (b)(1)(iii) of this section and a summary of the results.
Your device output must include results on the International Scale (IS) and your assay must include multipoint calibration controls traceable to a relevant international reference panel (e.g., the World Health Organization International Genetic Reference Panel for quantitation of BCR-ABL mRNA).