DAKO MOUSE ANTI HUMAN CYTOKERATIN, HIGH MOLECULAR WEIGHT, CLONE 34BE12, MONOCLONAL ANTIBODY FOR IMMUNOENZYMATIC STAINING
K971905 · Dako Corp. · DEH · Dec 12, 1997 · Immunology
Device Facts
Record ID
K971905
Device Name
DAKO MOUSE ANTI HUMAN CYTOKERATIN, HIGH MOLECULAR WEIGHT, CLONE 34BE12, MONOCLONAL ANTIBODY FOR IMMUNOENZYMATIC STAINING
Applicant
Dako Corp.
Product Code
DEH · Immunology
Decision Date
Dec 12, 1997
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 866.5550
Device Class
Class 2
Indications for Use
Monoclonal mouse anti-human Cytokeratin, High Molecular Weight, clone 34βE12 (34βE12) is intended for laboratory use to qualitatively identify by light microscopy the 66, 57, 51 and 49kD proteins corresponding to cytokeratins 1, 5, 10 and 14 of the Moll catalog in acetone or methanol fixed, frozen and formalin, methacarn or Carnoy's fixed, paraffin embedded tissues. 34BE12 specifically binds to antigens located in the cytoplasm of normal squamous and ductal epithelial cells. Positive results aid in the classification of normal and abnormal cells and tissues and serve as an adjunct to conventional histopathology. The clinical interpretation of any positive staining or its absence should be complemented by morphological and histological studies with proper controls. Evaluations should be made within the context of the patient's clinical history and other diagnostic tests by a qualified individual.
Device Story
Immunohistochemical staining reagent; utilizes monoclonal mouse anti-human antibody (clone 34βE12) to target high molecular weight cytokeratins (66, 57, 51, 49kD). Input: tissue sections (formalin, methacarn, or Carnoy's fixed, paraffin-embedded or frozen). Process: antibody binds to cytoplasmic antigens in squamous and ductal epithelial cells; visualized via light microscopy using immunoenzymatic staining (e.g., DAKO LSAB®2 Peroxidase kit). Output: qualitative visual staining pattern. Used in clinical pathology laboratories by pathologists/technicians. Results serve as an adjunct to conventional histopathology; aid in differential diagnosis of anaplastic tumors and prostate lesions. Benefits: assists in identifying epithelial nature of cells and distinguishing specific tumor types, improving diagnostic accuracy for complex histological cases.
Clinical Evidence
Bench testing only. Reproducibility established via intra-run and inter-run testing on serial sections of formalin-fixed, paraffin-embedded normal skin. Performance validated against a panel of normal tissues (positive in breast, cervix, esophagus, prostate, salivary gland, skin, thymus, tonsil; negative in others). Clinical utility supported by 15 published articles characterizing immunoreactivity in various normal and neoplastic tissues, including prostate small-acinar lesions and differential diagnosis of anaplastic tumors.
Technological Characteristics
Monoclonal mouse antibody (clone 34βE12) in Tris-HCl buffer with fetal calf serum and 15mM sodium azide. Formulated as concentrated or ready-to-use reagent. Principle: immunoenzymatic staining for light microscopy. Requires standard laboratory equipment for tissue fixation, embedding, and staining (e.g., LSAB®2 Peroxidase kit).
Indications for Use
Indicated for use as part of an antibody panel to aid in the differential diagnosis of anaplastic cells of undetermined origin. Aids in differentiating carcinomas from non-epithelial tumors (e.g., gliomas, lymphomas, melanomas, sarcomas, seminomas) when used with simple epithelium markers. Aids in subclassification of carcinomas and differential diagnosis of small-acinar lesions of the prostate gland by staining basal cells.
Regulatory Classification
Identification
An immunoglobulin (light chain specific) immunological test system is a device that consists of the reagents used to measure by immunochemical techniques both kappa and lambda types of light chain portions of immunoglobulin molecules in serum, other body fluids, and tissues. In some disease states, an excess of light chains are produced by the antibody-forming cells. These free light chains, unassociated with gamma globulin molecules, can be found in a patient's body fluids and tissues. Measurement of the various amounts of the different types of light chains aids in the diagnosis of multiple myeloma (cancer of antibody-forming cells), lymphocytic neoplasms (cancer of lymphoid tissue), Waldenstrom's macroglobulinemia (increased production of large immunoglobulins), and connective tissue diseases such as rheumatoid arthritis or systemic lupus erythematosus.
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K971905
0
# 510(k) Summary
| Submitter: | DAKO Corporation<br>6392 Via Real<br>Carpinteria, CA 93013<br>805-566-6655 |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Gretchen M. Murray, Ph.D. |
| Date Summary<br>Prepared: | December 4, 1997<br>DEC 12 1997 |
| Device Name: | 1) DAKO® Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone<br>34βE12. Monoclonal Antibody for Immunoenzymatic Staining (Product Code No.<br>M0630) |
| | 2) DAKO® Ready-to-Use Mouse Anti-Human Cytokeratin, High Molecular<br>Weight, Clone 34βE12, Monoclonal Antibody and Negative Control Reagent for<br>Immunoenzymatic Staining (Product Code No. N1553) |
| Device<br>Classification: | Class I or II has been proposed for immunohistochemical staining reagents. |
| Panel: | The proposed device classification is under the Hematology and Pathology<br>devices panel, Division of Clinical Laboratory Devices. |
| Predicate Device: | Becton Dickinson Anti-Human Cytokeratin, CAM5.2 (FDA K864893). |
| Device<br>Description: | 1) Monoclonal Mouse Anti-Human Cytokeratin, High Molecular Weight,<br>clone 34βE12 (Product Code No. M0630) is a mouse anti-human antibody<br>produced as a tissue culture supernatant. The antibody is supplied in 0.05M Tris-<br>HCl buffer, pH 7.2, containing fetal calf serum and 15mM sodium azide. (1mL<br>total volume). |
| | 2) Ready-to-Use Monoclonal Mouse Anti-Human Cytokeratin, High Molecular<br>Weight, clone 34βE12 Antibody and Negative Control (Product Code No. N1553)<br>consists of a mouse anti-human monoclonal antibody produced as a tissue culture<br>supernatant and pre-diluted in 0.05M Tris-HCl buffer, pH 7.6, containing fetal<br>calf serum and 15mM sodium azide (7mL total volume). The primary antibody is<br>packaged with a negative control reagent consisting of fetal calf serum in 0.05M<br>Tris-HCl buffer, pH 7.6 and 15mM sodium azide (5mL total volume). |
| Intended Use: | For In Vitro Diagnostic Use |
| | Monoclonal mouse anti-human Cytokeratin, High Molecular Weight, clone<br>34βE12 (34βE12) is intended for laboratory use to qualitatively identify by light<br>microscopy the 66, 57, 51 and 49kD3 proteins corresponding to cytokeratins 1, 5,<br>10 and 14 of the Moll catalog in acetone or methanol fixed, frozen and formalin, |
{1}------------------------------------------------
methacarn or Carnoy's fixed, paraffin embedded tissues. 34BE12 specifically binds to antigens located in the cytoplasm of normal squamous and ductal epithelial cells. Positive results aid in the classification of normal and abnormal cells and tissues and serve as an adjunct to conventional histopathology. The clinical interpretation of any positive staining or its absence should be complemented by morphological and histological studies with proper controls. Evaluations should be made within the context of the patient's clinical history and other diagnostic tests by a qualified individual.
- Anti-Human Cytokeratin. High Molecular Weight, Clone 34BE12 Antibody may Indicated Use: be used as one member of a panel of antibodies to aid in the differential diagnosis of anaplastic cells of undetermined origin. When used with markers of simple epithelium, it can aid in the differentiation of carcinomas from non epithelial tumors, e.g., gliomas, lymphomas, melanomas, sarcomas or seminomas. Because it does not react with all carcinomas, it may be used also as an aid in the subclassification of carcinomas. It is also useful in the differential diagnosis of small-acinar lesions of the prostate gland because it stains basal cells which are absent in the disease.
Normal Tissue Testing:
The required panel of normal tissues was tested with this antibody as specified in the 3/28/95 draft of Guidance for Submissions of Immunohistochemistry applications to the FDA. All tissues were formalin fixed and paraffin embedded. Staining was performed using the DAKO LSAB®2 Peroxidase kit system (Code No. K0677).
Normal tissues exhibiting positive staining with 348E12 included the following: breast, cervix, esophagus, prostate, salivary gland, skin, thymus and tonsil. Normal tissues that did not stain with 34BE12 include adrenal, bone marrow. brain (cerebellum and cerebrum), colon. heart. kidnev, liver, lung, mesothelial cells, ovary, pancreas, parathyroid, pericardium, peripheral nerve, pituitary, skeletal muscle, small intestine. spleen, stomach, testis, thyroid and uterus.
### Reproducibility Testing:
Eight serial sections from each of three different formalin-fixed, paraffin embedded blocks of normal skin were collected for testing. Testing was performed as follows:
Intra-run reproducibility: Following the standard DAKO LSAB®2 Peroxidase Kit protocol (Code No. K0677). three slides from each tissue block were stained with Ready-to-Use DAKO® Mouse Anti-Human Cytokeratin clone 34BE12 (Code No. N1553). Concurrently, one slide from each block was stained with the supplied negative control reagent.
Inter-run reproducibility: Staining one slide from each tissue block, the above procedure was repeated on two additional days. Concurrently, one slide from each block was stained with the supplied negative control reagent.
{2}------------------------------------------------
Reproducibility experiments with 34BE12 yielded consistent results with intra- and inter-run testing. Consistent test conditions were maintained throughout the study and reagents were stored at 2-8° C. between test runs (See Section 3 for the Report of the Results of the Reproducibility Testing)
Published Immunoreactivity:
Fifteen articles published on the characterization or clinical use of high molecular weight cytokeratin were used in the submission. Eleven of those articles reported on studies using 348E12. Following is a brief summary of the compiled information.
Cytokeratins are intermediate filament cvtoskeletal proteins essential to development and differentiation of epithelial cells. Approximately twenty different cvtokeratins have been identified and are classified and numbered according to molecular weight and isoelectric points. In general, most low molecular weight cvtokeratins (40kD-54kD) are distributed in nonsquamous epithelium, Moll's Catalog numbers 7-8 and/or 17-20.2 High molecular weight cytokeratins (48kD-67kD) are found in the upper portions of the epidermis and squamous epithelium, Moll's Catalog numbers 1-6 and/or 9-16.2 The DAKO® Mouse Anti-Human Cytokeraun. High Molecular Weight, clone 34BE12 antibody has been shown to react with the 66, 57, 51 and 49kD proteins corresponding to cytokeratins 1, 5, 10 and 14 of the Moll Catalog. 134 Positive immunoreactivity with the 66. 57, 51 and 49kD antigen appears as diffuse cvtoplasmic staining and indicates cells of epithelial nature, specifically squamous or ductal epithelium.3
34BE12 reacts with a variety of normal epithelial tissue including: squamous epithelium and sweat ducts in skin. all epithelial lavers including luminal and basal epithelium and ductal cells in breast, some pneumocvtes, mesothelium and bronchial epithelium in lung, collecting duct epithelia in kidnev and ductal cells in the pancreas, bile ducts in the liver, and mesothelium and a portion of epithelium (cells with a more basal location ) of the gastrointestinal tract. Hepatocytes, pancreatic acinar cells, proximal renal tubules, and nonepithelial normal tissues are not labeled by 34BE12 4
Monoclonal antibodies to intermediate filaments can be used as an aid in the histologic subclassification of human neoplasms. The cvtoskeletal phenotype of most tumors resembles that of their normal cellular counterpart regardless of the degree of differentiation. Thus, they can be used as an aid in the differential diagnosis of anaplastic tumors of unknown origin.
It has been reported 55 that the 348E12 antibody reacted positively with high molecular weight cytokeratins present in squamous cell and ductal or transitional cell carcinomas including: squamous cell carcinoma of the skin, lung and nasopharynx, ductal carcinoma of the breast, bile duct and salivary gland as well as transitional cell carcinomas of the bladder and nasopharynx and thymomas. 348E12-negative epithelial turnors are either "acinar" type adenomas (e.g., pituitary) or adenocarcinomas of simple epithelia (e.g., endometrial carcinomas, renal and hepatocellular carcinomas) or neuroendocrine tumors.4-37 34BE12 stained epithelial mesotheliomas, but failed to react with sarcomatoid or desmoplastic mesotheliomas " Thus, 34BE12 may be used as an aid in the subclassification of carcinomas.
Even though clone 34BE12 was negative with most non epithelial turnors e.g., gliomas, lymphomas, melanomas , sarcomas or seminomas, 459 it cannot be used as the sole epithelial marker in the differential diagnosis of carcinomas from non epithelial turnors. Because it does not react with all carcinomas, another marker for simple epithelium must be incorporated into a panel of antibodies with 340E12 to aid in the differential diagnosis of anaplastic tumors of unknown origin. Epitheloid sarcomas and synovial sarcomas. however, have shown to exhibit positive staining with various cytokeratin antibodies including 34BE12.500
{3}------------------------------------------------
It has been suggested also that 34BE12 is useful in the differential diagnosis of small acunar lesions of the It was proposed that its diagnostic value lies in the identification of basal cells. O`Malley, et. al. saw positive staining of basal cells in 47 examples of benign prostatic lesions including atypical adenomatous hyperplasia (13), basal cell hyperplasia (11), atrophy (16), post-sclerotic hyperplasia (5) and fibroepithelial nodule (2), while 21 cases of small-acinar adenocarcinomas showed no reactivity
4)
with the antibody. This was explained as loss of basal cells in this condition. It was stressed that loss of basal cell layer is not uniform in all prostatic adenocarcinomas. Basal cells are lost only in small-acunar adenocarcinomas. It was recommended that complete absence of staining of prostate lesions with 34BE12 should be regarded as very suggestive, but not diagnostic of malignancy.
Shah et. al., 2 suggested clinical usefulness of 34BE12 as an aid in the differentiation of Paget s disease and Bowen's disease (carcinoma in situ) from Pagetoid superficial spreading melanoma. 348E12 positivity was reported in Paget's disease of the breast (5/5) and Bowen's disease (10/10). However only 1/4 of Paget s disease of the vulva stained. None of 6 of the Pagetoid superficial spreading melanomas stained.
Bibliography:
prostate gland. "
- Moll R. Franke WW. Schiller DL. The Catalog of Human Cvtokeratins: Patterns of Expression in l . Normal Epithelia, Tumors and Cultured Cells. Cell 1982;31:11
- 2. Miettinen M. Keratin Inmunohistochemistry: Update of Applications and Pitfalls. Pathology Annuals 1993;28:113
- Gown AM and Vogel AM. Monoclonal Antibodies to Intermediate Filament Proteins of Human 3. Unique and Cross-reacting Antibodies. The Journal of Cell Biology 1982;95;414 Cells:
- 4. Gown AM and Vogel AM. Monoclonal Antibodies to Human Intermediate Filament Proteins II. Distribution of Filaments in Normal Human Tissues. Am J Pathol 1984:114:309
- 5. Gown AM and Vogel AM. Monoclonal Antibodies to Human Intermediate Filament Proteins III. Analysis of Tumors. Am J Clin Pathol 1985:84:413
- Dairkee SH, Puett L, Hackett AJ. Expression of Basal and Luminal Epithelium-Specific Keratins 6. in Normal, Benign and Malignant Breast Tissue. J Nat Can Inst 1988:80:691
- 7. Hurlimann J and Gardiol D. Immunohistochemistry in the Differential Diagnosis of Liver Carcinomas. Am J Surg Pathol 1991:15:280
- 8 . Bolen JW, Hammar SP, McNutt MA. Reactive and Neoplastic Serosal Tissue: A Light-Microscopic, Ultrastructural, and Immunocytochemical Study. Am J Surg Pathol 1986; 10:34
- 9. Bacchi CA, Zarbo RJ, Jiang JJ, Gown AM. Do Glioma Cells Express Cytokeratin? App Immunohisto 1995:3:45
- 10. Swanson PE, Dehner LP, Sirgi KE, Wick MR. Cytokeratin Immunoreactivity in Malignant Tumors of Bone and Soft Tissue. Appl Immunohistochem 1994;2;103
- 】 . O'Malley FP, Grignon DJ, Shum DT. Usefulness of Immunoperoxidase Staining with High-Molecular-Weight Cytok ratin in the Differential Diagnosis of Small-Acinar Lesions of the Prostate Gland. Virchows Archiv A Pathol Anat 1990;417:191
- 12. Shah KD, Tabibzadeh SS, Gerger MA. Immunohistochemical Distinction of Paget's Disease from Bowen's Disease and Superficial Spreading Melanoma with the Use of Monoclonal Cvtokeratin Antibodies. Am J Clin Pathol 1987;88:689
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#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/2 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird-like figure, with its wings spread upward. The image is in black and white.
Food and Drug Administration Gretchen M. Murray, Ph.D. 2098 Gaither Road Assistant Manager, Regulatory Affairs Rockville MD 20850 DAKO Corporation 6392 Via Real Carpinteria, California 93013 DEC 1 2 1997 Re : K971905/S1 Trade Name: 1.) DAKO® Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone 34BE12, Monoclonal Antibody for Immunoenzymatic Staining (Product Code No. M0630).
2.) DAKO® Ready-to-Use Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone 34BE12, Monoclonal Antibody and Negative Control Reagent for Immunoenzymatic Staining (Product Code No. N1553) Requlatory Class: II Product Code: DEH
Dated: September 10, 1997 Received: September 15, 1997
Dear Dr. Murray:
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 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 requirement, as set forth in the Quality System Requlation (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 requlation 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 Requlations.
{5}------------------------------------------------
Page 2
Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity categorization. To determine if it does, you should contact the Centers for Disease Control and Prevention (CDC) at (770)488-7655.
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 leqally 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" (21 CFR 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 at (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/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 Radioloqical Health
Enclosure
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K971905
0
# 510(k) Summary
| Submitter: | DAKO Corporation<br>6392 Via Real<br>Carpinteria, CA 93013<br>805-566-6655 |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Contact: | Gretchen M. Murray, Ph.D. |
| Date Summary<br>Prepared: | December 4, 1997<br>DEC 12 1997 |
| Device Name: | 1) DAKO® Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone<br>34βE12. Monoclonal Antibody for Immunoenzymatic Staining (Product Code No.<br>M0630) |
| | 2) DAKO® Ready-to-Use Mouse Anti-Human Cytokeratin, High Molecular<br>Weight, Clone 34βE12, Monoclonal Antibody and Negative Control Reagent for<br>Immunoenzymatic Staining (Product Code No. N1553) |
| Device<br>Classification: | Class I or II has been proposed for immunohistochemical staining reagents. |
| Panel: | The proposed device classification is under the Hematology and Pathology<br>devices panel, Division of Clinical Laboratory Devices. |
| Predicate Device: | Becton Dickinson Anti-Human Cytokeratin, CAM5.2 (FDA K864893). |
| Device<br>Description: | 1) Monoclonal Mouse Anti-Human Cytokeratin, High Molecular Weight,<br>clone 34βE12 (Product Code No. M0630) is a mouse anti-human antibody<br>produced as a tissue culture supernatant. The antibody is supplied in 0.05M Tris-<br>HCl buffer, pH 7.2, containing fetal calf serum and 15mM sodium azide. (1mL<br>total volume). |
| | 2) Ready-to-Use Monoclonal Mouse Anti-Human Cytokeratin, High Molecular<br>Weight, clone 34βE12 Antibody and Negative Control (Product Code No. N1553)<br>consists of a mouse anti-human monoclonal antibody produced as a tissue culture<br>supernatant and pre-diluted in 0.05M Tris-HCl buffer, pH 7.6, containing fetal<br>calf serum and 15mM sodium azide (7mL total volume). The primary antibody is<br>packaged with a negative control reagent consisting of fetal calf serum in 0.05M<br>Tris-HCl buffer, pH 7.6 and 15mM sodium azide (5mL total volume). |
| Intended Use: | For In Vitro Diagnostic Use |
| | Monoclonal mouse anti-human Cytokeratin, High Molecular Weight, clone<br>34βE12 (34βE12) is intended for laboratory use to qualitatively identify by light<br>microscopy the 66, 57, 51 and 49kD3 proteins corresponding to cytokeratins 1, 5,<br>10 and 14 of the Moll catalog in acetone or methanol fixed, frozen and formalin, |
{7}------------------------------------------------
methacarn or Carnoy's fixed, paraffin embedded tissues. 34BE12 specifically binds to antigens located in the cytoplasm of normal squamous and ductal epithelial cells. Positive results aid in the classification of normal and abnormal cells and tissues and serve as an adjunct to conventional histopathology. The clinical interpretation of any positive staining or its absence should be complemented by morphological and histological studies with proper controls. Evaluations should be made within the context of the patient's clinical history and other diagnostic tests by a qualified individual.
- Anti-Human Cytokeratin. High Molecular Weight, Clone 34BE12 Antibody may Indicated Use: be used as one member of a panel of antibodies to aid in the differential diagnosis of anaplastic cells of undetermined origin. When used with markers of simple epithelium, it can aid in the differentiation of carcinomas from non epithelial tumors, e.g., gliomas, lymphomas, melanomas, sarcomas or seminomas. Because it does not react with all carcinomas, it may be used also as an aid in the subclassification of carcinomas. It is also useful in the differential diagnosis of small-acinar lesions of the prostate gland because it stains basal cells which are absent in the disease.
Normal Tissue Testing:
The required panel of normal tissues was tested with this antibody as specified in the 3/28/95 draft of Guidance for Submissions of Immunohistochemistry applications to the FDA. All tissues were formalin fixed and paraffin embedded. Staining was performed using the DAKO LSAB®2 Peroxidase kit system (Code No. K0677).
Normal tissues exhibiting positive staining with 348E12 included the following: breast, cervix, esophagus, prostate, salivary gland, skin, thymus and tonsil. Normal tissues that did not stain with 34BE12 include adrenal, bone marrow. brain (cerebellum and cerebrum), colon. heart. kidnev, liver, lung, mesothelial cells, ovary, pancreas, parathyroid, pericardium, peripheral nerve, pituitary, skeletal muscle, small intestine. spleen, stomach, testis, thyroid and uterus.
### Reproducibility Testing:
Eight serial sections from each of three different formalin-fixed, paraffin embedded blocks of normal skin were collected for testing. Testing was performed as follows:
Intra-run reproducibility: Following the standard DAKO LSAB®2 Peroxidase Kit protocol (Code No. K0677). three slides from each tissue block were stained with Ready-to-Use DAKO® Mouse Anti-Human Cytokeratin clone 34BE12 (Code No. N1553). Concurrently, one slide from each block was stained with the supplied negative control reagent.
Inter-run reproducibility: Staining one slide from each tissue block, the above procedure was repeated on two additional days. Concurrently, one slide from each block was stained with the supplied negative control reagent.
{8}------------------------------------------------
Reproducibility experiments with 34BE12 yielded consistent results with intra- and inter-run testing. Consistent test conditions were maintained throughout the study and reagents were stored at 2-8° C. between test runs (See Section 3 for the Report of the Results of the Reproducibility Testing)
Published Immunoreactivity:
Fifteen articles published on the characterization or clinical use of high molecular weight cytokeratin were used in the submission. Eleven of those articles reported on studies using 348E12. Following is a brief summary of the compiled information.
Cytokeratins are intermediate filament cvtoskeletal proteins essential to development and differentiation of epithelial cells. Approximately twenty different cvtokeratins have been identified and are classified and numbered according to molecular weight and isoelectric points. In general, most low molecular weight cvtokeratins (40kD-54kD) are distributed in nonsquamous epithelium, Moll's Catalog numbers 7-8 and/or 17-20.2 High molecular weight cytokeratins (48kD-67kD) are found in the upper portions of the epidermis and squamous epithelium, Moll's Catalog numbers 1-6 and/or 9-16.2 The DAKO® Mouse Anti-Human Cytokeraun. High Molecular Weight, clone 34BE12 antibody has been shown to react with the 66, 57, 51 and 49kD proteins corresponding to cytokeratins 1, 5, 10 and 14 of the Moll Catalog. 134 Positive immunoreactivity with the 66. 57, 51 and 49kD antigen appears as diffuse cvtoplasmic staining and indicates cells of epithelial nature, specifically squamous or ductal epithelium.3
34BE12 reacts with a variety of normal epithelial tissue including: squamous epithelium and sweat ducts in skin. all epithelial lavers including luminal and basal epithelium and ductal cells in breast, some pneumocvtes, mesothelium and bronchial epithelium in lung, collecting duct epithelia in kidnev and ductal cells in the pancreas, bile ducts in the liver, and mesothelium and a portion of epithelium (cells with a more basal location ) of the gastrointestinal tract. Hepatocytes, pancreatic acinar cells, proximal renal tubules, and nonepithelial normal tissues are not labeled by 34BE12 4
Monoclonal antibodies to intermediate filaments can be used as an aid in the histologic subclassification of human neoplasms. The cvtoskeletal phenotype of most tumors resembles that of their normal cellular counterpart regardless of the degree of differentiation. Thus, they can be used as an aid in the differential diagnosis of anaplastic tumors of unknown origin.
It has been reported 55 that the 348E12 antibody reacted positively with high molecular weight cytokeratins present in squamous cell and ductal or transitional cell carcinomas including: squamous cell carcinoma of the skin, lung and nasopharynx, ductal carcinoma of the breast, bile duct and salivary gland as well as transitional cell carcinomas of the bladder and nasopharynx and thymomas. 348E12-negative epithelial turnors are either "acinar" type adenomas (e.g., pituitary) or adenocarcinomas of simple epithelia (e.g., endometrial carcinomas, renal and hepatocellular carcinomas) or neuroendocrine tumors.4-37 34BE12 stained epithelial mesotheliomas, but failed to react with sarcomatoid or desmoplastic mesotheliomas " Thus, 34BE12 may be used as an aid in the subclassification of carcinomas.
Even though clone 34BE12 was negative with most non epithelial turnors e.g., gliomas, lymphomas, melanomas , sarcomas or seminomas, 459 it cannot be used as the sole epithelial marker in the differential diagnosis of carcinomas from non epithelial turnors. Because it does not react with all carcinomas, another marker for simple epithelium must be incorporated into a panel of antibodies with 340E12 to aid in the differential diagnosis of anaplastic tumors of unknown origin. Epitheloid sarcomas and synovial sarcomas. however, have shown to exhibit positive staining with various cytokeratin antibodies including 34BE12.500
{9}------------------------------------------------
It has been suggested also that 34BE12 is useful in the differential diagnosis of small acunar lesions of the It was proposed that its diagnostic value lies in the identification of basal cells. O`Malley, et. al. saw positive staining of basal cells in 47 examples of benign prostatic lesions including atypical adenomatous hyperplasia (13), basal cell hyperplasia (11), atrophy (16), post-sclerotic hyperplasia (5) and fibroepithelial nodule (2), while 21 cases of small-acinar adenocarcinomas showed no reactivity
4)
with the antibody. This was explained as loss of basal cells in this condition. It was stressed that loss of basal cell layer is not uniform in all prostatic adenocarcinomas. Basal cells are lost only in small-acunar adenocarcinomas. It was recommended that complete absence of staining of prostate lesions with 34BE12 should be regarded as very suggestive, but not diagnostic of malignancy.
Shah et. al., 2 suggested clinical usefulness of 34BE12 as an aid in the differentiation of Paget s disease and Bowen's disease (carcinoma in situ) from Pagetoid superficial spreading melanoma. 348E12 positivity was reported in Paget's disease of the breast (5/5) and Bowen's disease (10/10). However only 1/4 of Paget s disease of the vulva stained. None of 6 of the Pagetoid superficial spreading melanomas stained.
Bibliography:
prostate gland. "
- Moll R. Franke WW. Schiller DL. The Catalog of Human Cvtokeratins: Patterns of Expression in l . Normal Epithelia, Tumors and Cultured Cells. Cell 1982;31:11
- 2. Miettinen M. Keratin Inmunohistochemistry: Update of Applications and Pitfalls. Pathology Annuals 1993;28:113
- Gown AM and Vogel AM. Monoclonal Antibodies to Intermediate Filament Proteins of Human 3. Unique and Cross-reacting Antibodies. The Journal of Cell Biology 1982;95;414 Cells:
- 4. Gown AM and Vogel AM. Monoclonal Antibodies to Human Intermediate Filament Proteins II. Distribution of Filaments in Normal Human Tissues. Am J Pathol 1984:114:309
- 5. Gown AM and Vogel AM. Monoclonal Antibodies to Human Intermediate Filament Proteins III. Analysis of Tumors. Am J Clin Pathol 1985:84:413
- Dairkee SH, Puett L, Hackett AJ. Expression of Basal and Luminal Epithelium-Specific Keratins 6. in Normal, Benign and Malignant Breast Tissue. J Nat Can Inst 1988:80:691
- 7. Hurlimann J and Gardiol D. Immunohistochemistry in the Differential Diagnosis of Liver Carcinomas. Am J Surg Pathol 1991:15:280
- 8 . Bolen JW, Hammar SP, McNutt MA. Reactive and Neoplastic Serosal Tissue: A Light-Microscopic, Ultrastructural, and Immunocytochemical Study. Am J Surg Pathol 1986; 10:34
- 9. Bacchi CA, Zarbo RJ, Jiang JJ, Gown AM. Do Glioma Cells Express Cytokeratin? App Immunohisto 1995:3:45
- 10. Swanson PE, Dehner LP, Sirgi KE, Wick MR. Cytokeratin Immunoreactivity in Malignant Tumors of Bone and Soft Tissue. Appl Immunohistochem 1994;2;103
- 】 . O'Malley FP, Grignon DJ, Shum DT. Usefulness of Immunoperoxidase Staining with High-Molecular-Weight Cytok ratin in the Differential Diagnosis of Small-Acinar Lesions of the Prostate Gland. Virchows Archiv A Pathol Anat 1990;417:191
- 12. Shah KD, Tabibzadeh SS, Gerger MA. Immunohistochemical Distinction of Paget's Disease from Bowen's Disease and Superficial Spreading Melanoma with the Use of Monoclonal Cvtokeratin Antibodies. Am J Clin Pathol 1987;88:689
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#### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/10/Picture/2 description: The image shows the logo for the Department of Health & Human Services USA. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird-like figure, with its wings spread upward. The image is in black and white.
Food and Drug Administration Gretchen M. Murray, Ph.D. 2098 Gaither Road Assistant Manager, Regulatory Affairs Rockville MD 20850 DAKO Corporation 6392 Via Real Carpinteria, California 93013 DEC 1 2 1997 Re : K971905/S1 Trade Name: 1.) DAKO® Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone 34BE12, Monoclonal Antibody for Immunoenzymatic Staining (Product Code No. M0630).
2.) DAKO® Ready-to-Use Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone 34BE12, Monoclonal Antibody and Negative Control Reagent for Immunoenzymatic Staining (Product Code No. N1553) Requlatory Class: II Product Code: DEH
Dated: September 10, 1997 Received: September 15, 1997
Dear Dr. Murray:
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 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 requirement, as set forth in the Quality System Requlation (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 requlation 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 Requlations.
{11}------------------------------------------------
Page 2
Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity categorization. To determine if it does, you should contact the Centers for Disease Control and Prevention (CDC) at (770)488-7655.
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 leqally 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" (21 CFR 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 at (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/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 Radioloqical Health
Enclosure
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Page l of
### 510(k) Number (if known): K971905
Device Name: Monoclonal Mouse Anti-Human Cytokeratin, High Molecular Weight, clone 34BE12 Antibody for Immunoenzymatic Staining
> Monoclonal Mouse Anti-Human Cytokeratin, High Molecular Weight, clone 34BE12 Ready-to-Use Antibody and Negative Control for Immunoenzymatic Staining
### Indications For Use:
Monoclonal Mouse Anti-Human Cytokeratin, High Molecular Weight, Clone 34BE12 Antibody may be used as one member of a panel of antibodies to aid in the differential diagnosis of anaplastic cells of undetermined origin. When used with markers of simple epithelium, it can aid in the differentiation of carcinomas from non epithelial tumors, e.g., gliomas, lymphomas, melanomas, sarcomas or seminomas. Because it does not react with all carcinomas, it may be used also as an aid in the subclassification of carcinomas. It is also useful in the differential diagnosis of small-acinar lesions of the prostate gland because it stains basal cells which are absent in this disease.
The clinical interpretation of any positive staining or its absence should be complemented by morphological and histological studies with proper controls. Evaluations should be made within the context of the patient's clinical history and other diagnostic tests by a qualified individual having knowledge of all the potential antibody reactivities.
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use
(Per 21 CFR 801.109)
IVD Use
(Per 21 CFR 801.119)
OR
(Division Sign-Off)
Division of Clinical Laboratory Devices
510(k) Number K971402 Format 1-2-96)
Over-The-Counter Use
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.