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EUA-COVID-19-genesig-Real-Time-PCR-assay-Primerdesign-Letter March 20, 2020
Navin Nauth-Misir, Group RA QA Director Primerdesign Ltd. Unit 1, Watchmoor Point, Watchmoor Road, Camberley, GU15 3AD, UK
Device: Company: Indication:
Authorized Laboratories:
Dear Mr. Nauth-Misir:
Primerdesign Ltd COVID-19 genesig Real-Time PCR assay.
Primerdesign Ltd.
Qualitative detection of nucleic acid from SARS-CoV-2 in oropharyngeal swab specimens from patients suspected of COVID19 by their healthcare provider. Emergency use of this test is limited to authorized laboratories.
Laboratories certified under the Clinical Laboratory Improvement Amendments of 1988 (CLIA), 42 U.S.C. §263a, to perform high complexity tests.
This letter is in response to your1 request that the Food and Drug Administration (FDA) issue an Emergency Use Authorization (EUA) for emergency use of your product,2 pursuant to
Section 564 of the Federal Food, Drug, and Cosmetic Act (the Act) (21 U.S.C. §360bbb-3).
On February 4, 2020, pursuant to Section 564(b)(1)(C) of the Act, the Secretary of the Department of Health and Human Services (HHS) determined that there is a public health emergency that has a significant potential to affect national security or the health and security of United States citizens living abroad, and that involves the virus that causes COVID-19.3 Pursuant to Section 564 of the Act, and on the basis of such determination, the Secretary of HHS then declared that circumstances exist justifying the authorization of emergency use of in vitro diagnostics for detection and/or diagnosis of the virus that causes COVID-19 subject to the terms of any authorization issued under Section 564(a) of the Act.4
1 For ease of reference, this letter will use the term "you" and related terms to refer to the Primerdesign Ltd. 2 For ease of reference, this letter will use the term "your product" to refer to the Primerdesign Ltd COVID-19 genesig Real-Time PCR assay used for the indication identified above. 3 On February 11, 2020, the virus tentatively named 2019-nCoV was formally designated as Severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). Also on February 11, 2020, the disease caused by SARS-CoV-2 was formally designated as Coronavirus Disease 2019 (COVID-19). This document uses the updated names. 4 U.S. Department of Health and Human Services, Determination of a Public Health Emergency and Declaration that Circumstances Exist Justifying Authorizations Pursuant to Section 564(b) of the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. § 360bbb-3. February 4, 2020.
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Having concluded that the criteria for issuance of this authorization under Section 564(c) of the Act are met, I am authorizing the emergency use of your product, described in the scope Section of this letter (Section II), subject to the terms of this authorization.
I. Criteria for Issuance of Authorization
I have concluded that the emergency use of your product meets the criteria for issuance of an authorization under Section 564(c) of the Act, because I have concluded that:
1. The SARS-CoV-2 can cause a serious or life-threatening disease or condition, including severe respiratory illness, to humans infected by this virus;
2. Based on the totality of scientific evidence available to FDA, it is reasonable to believe that your product may be effective in diagnosing COVID-19, and that the known and potential benefits of your product when used for diagnosing COVID-19, outweigh the known and potential risks of your product; and
3. There is no adequate, approved, and available alternative to the emergency use of your product. 5
II. Scope of Authorization
I have concluded, pursuant to Section 564(d)(1) of the Act, that the scope of this authorization is limited to the indication above.
Authorized Product Details
Your product is for the qualitative detection of nucleic acid from SARS-CoV-2 in oropharyngeal swab specimens from patients suspected of COVID-19 by their healthcare provider. The SARSCoV-2 is generally detectable in oropharyngeal swab specimens during the acute phase of infection. Positive results are indicative of the presence of SARS-CoV-2 RNA; clinical correlation with patient history and other diagnostic information is necessary to determine patient infection status. Positive results do not rule out bacterial infection or co-infection with other viruses.
To use your product, SARS-CoV-2 nucleic acid is first extracted, isolated and purified from oropharyngeal swabs. The purified nucleic acid is then reverse transcribed into cDNA followed by PCR amplification and detection with an authorized RT-PCR Master Mix on authorized RealTime PCR instrument(s). The Primerdesign Ltd COVID-19 genesig Real-Time PCR assay includes the following materials or other authorized materials: oasig OneStep 2X RT-qPCR Master Mix, COVID-19 Primers & Probe Mix, Oasig resuspension buffer, Template preparation buffer, Water RNase/DNase free, Genesig COVID-19 Positive control template and Genesig Easy RNA Internal extraction control (IEC).
Your product requires the following control materials, or other authorized control materials, that
5 No other criteria of issuance have been prescribed by regulation under Section 564(c)(4) of the Act.
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are processed in the same way as the patient samples and are to be run as outlined in the Instructions for Use for your product:
· Genesig Easy RNA Internal extraction control (IEC) - added prior to nucleic acid extraction to measure RNA extraction purity, detect PCR inhibition and confirm the integrity of the PCR run.
· Genesig COVID-19 Positive control template - contains synthetic DNA representing the SARS-CoV-2 genomic region of interest. The positive control is used to monitor for failures of primer/probe reagents and reaction conditions.
· Negative Extraction Control (NEC) RNase/DNase free water, run each time RNA is extracted from a clinical specimen or sample.
· No Template (Negative) Control - DNase/RNase free water used to monitor nonspecific amplification, cross-contamination during experimental setup, and nucleic acid contamination of reagents.
Your product also requires the use of additional authorized materials and authorized ancillary reagents that are not included with your product and are described in the Instructions for Use.
The above described product, when labeled consistently with the labeling authorized by FDA, entitled "Primerdesign Ltd COVID-19 genesig Real-Time PCR assay Instructions for Use" (available at https://www.fda.gov/medical-devices/emergency-situations-medicaldevices/emergency-use-authorizations), which may be revised in consultation with, and with concurrence of, the Division of Microbiology Devices (DMD)/Office of Health Technology 7 Office of In Vitro Diagnostics and Radiological Health (OHT7-OIR)/Office of Product Evaluation and Quality (OPEQ)/Center for Devices and Radiological Health (CDRH), is authorized to be distributed to and used by authorized laboratories under this EUA, despite the fact that it does not meet certain requirements otherwise required by applicable federal law.
Your product is authorized to be accompanied by the following product-specific information pertaining to the emergency use, which is required to be made available to healthcare providers and patients:
· Fact Sheet for Healthcare Providers: Primerdesign Ltd COVID-19 genesig RealTime PCR assay
· Fact Sheet for Patients: Primerdesign Ltd COVID-19 genesig Real-Time PCR assay
I have concluded, pursuant to Section 564(d)(2) of the Act, that it is reasonable to believe that the known and potential benefits of your authorized product, when used for the qualitative detection of SARS-CoV-2 and used consistently with the Scope of Authorization of this letter (Section II), outweigh the known and potential risks of your product.
I have concluded, pursuant to Section 564(d)(3) of the Act, based on the totality of scientific evidence available to FDA, that it is reasonable to believe that your product may be effective for the indication above, when used consistently with the Scope of Authorization of this letter (Section II), pursuant to Section 564(c)(2)(A) of the Act.
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FDA has reviewed the scientific information available to FDA, including the information supporting the conclusions described in Section I above, and concludes that your product (as described in the Scope of Authorization of this letter (Section II)) meets the criteria set forth in Section 564(c) of the Act concerning safety and potential effectiveness.
The emergency use of your product under this EUA must be consistent with, and may not exceed, the terms of this letter, including the Scope of Authorization (Section II) and the Conditions of Authorization (Section IV). Subject to the terms of this EUA and under the circumstances set forth in the Secretary of HHS's determination under Section 564(b)(1)(C) described above and the Secretary of HHS's corresponding declaration under Section 564(b)(1), your product is authorized for the indication above.
This EUA will cease to be effective when the HHS declaration that circumstances exist to justify the EUA is terminated under Section 564(b)(2) of the Act or when the EUA is revoked under Section 564(g) of the Act.
III. Waiver of Certain Requirements
I am waiving the following requirements for your product during the duration of this EUA:
· Current good manufacturing practice requirements, including the quality system requirements under 21 CFR Part 820 with respect to the design, manufacture, packaging, labeling, storage, and distribution of your product.
IV. Conditions of Authorization
Pursuant to Section 564(e) of the Act, I am establishing the following conditions on this authorization:
Primerdesign Ltd (You) and Authorized Distributor(s)6
A. Your product must comply with the following labeling requirements under FDA regulations: the intended use statement (21 CFR 809.10(a)(2), (b)(2)); adequate directions for use (21 U.S.C. 352(f)), (21 CFR 809.10(b)(5), (7), and (8)); any appropriate limitations on the use of the device including information required under 21 CFR 809.10(a)(4); and any available information regarding performance of the device, including requirements under 21 CFR 809.10(b)(12).
B. You and authorized distributor(s) will make your product available with the authorized labeling to authorized laboratories. You may request changes to the authorized labeling. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
6 "Authorized Distributor(s)" are identified by you, Primerdesign Ltd, in your EUA submission as an entity allowed to distribute your device.
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C. You and authorized distributor(s) will provide to authorized laboratories the Fact Sheet for Healthcare Providers and the authorized Fact Sheet for Patients. You may request changes to the authorized Fact Sheets. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
D. You and authorized distributor(s) will make available on your website(s) the Fact Sheet for Healthcare Providers and the Fact Sheet for Patients.
E. You and authorized distributor(s) will inform authorized laboratories and relevant public health authorities of this EUA, including the terms and conditions herein, and any updates made to your product, authorized labeling and authorized Fact Sheets.
F. Through a process of inventory control, you and authorized distributor(s) will maintain records of the authorized laboratories to which they distribute the test and number of tests they distribute.
G. You and authorized distributor(s) will collect information on the performance of your product. You will report to FDA any suspected occurrence of false positive and false negative results and significant deviations from the established performance characteristics of the product of which you become aware.
H. You and authorized distributor(s) are authorized to make available additional information relating to the emergency use of your product that is consistent with, and does not exceed, the terms of this letter of authorization.
Primerdesign Ltd (You)
I. You will notify FDA of any authorized distributor(s) of your product, including the name, address, and phone number of any authorized distributor(s).
J. You will provide its authorized distributor(s) with a copy of this EUA and communicate to authorized distributor(s) any subsequent amendments that might be made to this EUA and its authorized accompanying materials (e.g., Fact Sheets).
K. You may request changes to the Scope of Authorization (Section II in this letter) of your product. Such requests will be made in consultation with DMD/OHT7OIR/OPEQ/CDRH, and require concurrence of, Office of Counterterrorism and Emerging Threats (OCET)/Office of the Chief Scientist (OCS)/Office of the Commissioner (OC) and DMD/OHT7-OIR/OPEQ/CDRH.
L. You may request the addition of other instruments and associated software for use with your product. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
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M. You may request the addition of other extraction methods for use with your product. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
N. You may request the addition of other specimen types for use with your product. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7OIR/OPEQ/CDRH.
O. You may request the addition and/or substitution of primers or probes for use with your product. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
P. You may request the addition and/or substitution of control materials for use with your product. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
Q. You may request the addition and/or substitution of other ancillary reagents and materials for use with your product. Such requests will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
R. You will evaluate the analytical limit of detection and assess traceability7 of your product with any FDA-recommended reference material(s). After submission to FDA and DMD/OHT7-OIR/CDRH's review of and concurrence with the data, You will update its labeling to reflect the additional testing. Such labeling updates will be made in consultation with, and require concurrence of, DMD/OHT7-OIR/OPEQ/CDRH.
S. You will complete the agreed upon bridging study to add at least one addition extraction method(s) to your product within 15 days of the date of this letter. After submission to FDA and DMD/OHT7-OIR/CDRH's review of and concurrence with the data, you will update its labeling to reflect the additional extraction method(s). Such labeling updates will be made in consultation with, and require concurrence of, DMD/OHT7- OIR/OPEQ/CDRH.
T. You will track adverse events, including any occurrence of false results and report to FDA under 21 CFR Part 803.
Authorized Laboratories
U. Authorized laboratories using your product will include with result reports of your product, all authorized Fact Sheets. Under exigent circumstances, other appropriate methods for disseminating these Fact Sheets may be used, which may include mass media.
V. Authorized laboratories using your product will use your product as outlined in the
7 Traceability refers to tracing analytical sensitivity/reactivity back to an FDA-recommended reference material.
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Instructions for Use. Deviations from the authorized procedures, including the authorized instruments, authorized extraction methods, authorized clinical specimen types, authorized control materials, authorized other ancillary reagents and authorized materials required to use your product are not permitted.
W. Authorized laboratories that receive your product will notify the relevant public health authorities of their intent to run your product prior to initiating testing.
X. Authorized laboratories using your product will have a process in place for reporting test results to healthcare providers and relevant public health authorities, as appropriate.
Y. Authorized laboratories will collect information on the performance of your product and report to DMD/OHT7-OIR/OPEQ/CDRH (via email: CDRH-EUAReporting@fda.hhs.gov) and You (support@primerdesign.co.uk) any suspected occurrence of false positive or false negative results and significant deviations from the established performance characteristics of your product of which they become aware.
Z. All laboratory personnel using your product must be appropriately trained in RT-PCR techniques and use appropriate laboratory and personal protective equipment when handling this kit, and use your product in accordance with the authorized labeling.
Primerdesign Ltd (You), Authorized Distributors and Authorized Laboratories
AA.
You, authorized distributors, and authorized laboratories using your product will
ensure that any records associated with this EUA are maintained until otherwise notified
by FDA. Such records will be made available to FDA for inspection upon request.
Conditions Related to Advertising and Promotion
BB.
All advertising and promotional descriptive printed matter relating to the use of
your product shall be consistent with the Fact Sheets and authorized labeling, as well as
the terms set forth in this EUA and the applicable requirements set forth in the Act and
FDA regulations.
CC.
All advertising and promotional descriptive printed matter relating to the use of
your product shall clearly and conspicuously state that:
· This test has not been FDA cleared or approved;
· This test has been authorized by FDA under an EUA for use by authorized laboratories;
· This test has been authorized only for the detection of nucleic acid from SARSCoV-2, not for any other viruses or pathogens; and
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· This test is only authorized for the duration of the declaration that circumstances exist justifying the authorization of emergency use of in vitro diagnostic tests for detection and/or diagnosis of COVID-19 under Section 564(b)(1) of the Act, 21 U.S.C. § 360bbb-3(b)(1), unless the authorization is terminated or revoked sooner.
No advertising or promotional descriptive printed matter relating to the use of your product may represent or suggest that this test is safe or effective for the detection of SARS-CoV-2.
The emergency use of your product as described in this letter of authorization must comply with the conditions and all other terms of this authorization.
V. Duration of Authorization
This EUA will be effective until the declaration that circumstances exist justifying the authorization of the emergency use of in vitro diagnostic tests for detection and/or diagnosis of COVID-19 is terminated under Section 564(b)(2) of the Act or the EUA is revoked under Section 564(g) of the Act.
Enclosures
Sincerely,
____________________________ RADM Denise M. Hinton Chief Scientist Food and Drug Administration
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