K Number
K161533
Manufacturer
Date Cleared
2017-06-16

(379 days)

Product Code
Regulation Number
864.7470
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

A1C EZ Glycohemoglobin Analysis System is an in vitro diagnostic test used to quantitatively measure the percent glycohemoglobin Alc or glycohemoglobin A1c fraction mmol/mol in venous whole blood samples. This system is intended for multiple patient use to monitor long term glycemic control in individuals previously diagnosed with diabetes. This test is not to be used for screening or diagnosis of diabetes or for neonatal use. The A1C EZ Glycohemoglobin Analysis System is intended for professional use in clinical laboratories only.

Device Description

This product is used to quantitatively measure the percent glycohemoglobin A1c or glycohemoglobin A1c fraction mmol/mol in human whole blood sample.

AI/ML Overview

Here is an organized overview of the acceptance criteria and study details for the A1C EZ Glycohemoglobin Analysis System:

1. A table of acceptance criteria and the reported device performance

The document does not explicitly present a table of acceptance criteria. However, it details various performance characteristics and compares them to a predicate device. I've extracted the key performance metrics from the non-clinical testing section and the "Substantial Equivalence Comparison" table, treating them as implicitly accepted performance criteria for substantial equivalence.

Performance MetricAcceptance Criteria (Implied / Predicate Device)Reported Device Performance (A1C EZ Glycohemoglobin Analysis System)
Measuring Range4%-13% HbA1c (Predicate: A1CNow+)4%-14% HbA1c
MethodologyImmunoassay (Predicate: A1CNow+)Boronate Affinity
Precision (Internal - Total CV)3.00% CV (low) / 4.02% CV (high) (Predicate: A1CNow+)3.3% CV (low, HbA1c 5.8%) / 2.8% CV (high, HbA1c 12.2%) (NGSP)
Precision (External - Total CV)Not explicitly stated as acceptance criteria, but provided for predicate comparison.Level 1 (5.09%): 3.1% (NGSP), 5.3% (IFCC)Level 2 (7.37%): 2.7% (NGSP), 3.8% (IFCC)Level 3 (11.54%): 2.3% (NGSP), 2.8% (IFCC)
Accuracy (Slope vs. Tosoh G8)1.02 (Predicate: A1CNow+ vs. Tosoh A1c 2.2 Plus)Lot1: 0.973, Lot2: 0.979, Lot3: 0.989 (NGSP);Lot1: 0.975, Lot2: 0.979, Lot3: 0.989 (IFCC)
Accuracy (Intercept vs. Tosoh G8)-0.23 (Predicate: A1CNow+ vs. Tosoh A1c 2.2 Plus)Lot1: 0.188, Lot2: 0.162, Lot3: 0.111 (NGSP);Lot1: 1.326, Lot2: 1.266, Lot3: 0.957 (IFCC)
Analytical Specificity (Interference: Bilirubin)20 mg/dL (Predicate: A1CNow+)60 mg/dL (No interference up to this conc.)
Analytical Specificity (Interference: Triglyceride)3000 mg/dL (Predicate: A1CNow+)900 mg/dL (No interference up to this conc.)
Analytical Specificity (Interference: Hemoglobin)500 mg/dL (Predicate: A1CNow+)500 mg/dL (No interference up to this conc.)
Analytical Specificity (Interference: Acetaminophen)80 µg/mL (Predicate: A1CNow+)200 µg/mL (No interference up to this conc.)
Analytical Specificity (Interference: Ascorbic acid)5 mg/dL (Predicate: A1CNow+)30 mg/dL (No interference up to this conc.)
Hemoglobin Variant InterferenceNot specified for predicateNo significant interference for Hb C (≤ 44.7%), Hb D (≤ 41.7%), Hb E (≤ 32.6%), Hb S (≤ 37.8%), and Hb F (≤ 14.7%)
Test Strip Stability (Room Temp.)15 months (Predicate: A1CNow+)18 months
Linearity (R-square)Not explicitly stated as acceptance criteria0.9989 (NGSP), 0.9990 (IFCC)
Reportable Range4%-13% HbA1c (Predicate: A1CNow+)4%-14% NGSP or 20-130 mmol/mol IFCC
Operating ConditionsNot explicitly stated as acceptance criteria50~104°F (10°C-40°C) and RH 30% to 75%
Sample VolumeNot explicitly stated as acceptance criteria2.5-4.5 µL

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Test Sets for Precision:
    • Internal Precision: "Sample from normal patient (Level 1, HbA1c% = 5.8%) and diabetic patient (Level 2, HbA1c% = 12.2%)" were used. The study involved running samples over 20 consecutive days. The exact number of individual patient samples (N) is not explicitly stated, but rather referred to as "Level 1" and "Level 2" control samples.
    • External Precision: "3 levels of K2-EDTA anticoagulated venous blood samples (level 1- 5.1%, level 2- 7.3%, level 3- 11.7%)" were used. For each sample level, 360 tests were performed across all sites, operators, meters, and test strip lots (N=360 for each level).
  • Test Sets for Accuracy: The "internal comparison study" does not specify the number of individual patient samples. It mentions comparison with a reference device (Tosoh HLC-723 G8) and the predicate device (A1CNow+), implying a set of samples with known values.
  • Test Sets for Linearity: Not specified.
  • Test Sets for Analytical Specificity: Not specified, but involved testing various interferent substances at specified concentrations.
  • Data Provenance: The document does not explicitly state the country of origin for the patient samples or if the data was retrospective or prospective. Given the applicant is from China, it is plausible the studies were conducted in China.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

This device is an in vitro diagnostic (IVD) quantitative measurement system, not an imaging device requiring expert interpretation. Therefore, the concept of "experts" to establish ground truth in the traditional sense (e.g., radiologists, pathologists) is not applicable here.

Instead, the ground truth for performance evaluation (accuracy) was established by comparison to a recognized reference method:

  • Reference Method: Tosoh HLC-723 G8, which is an HPLC device certified by the National Glycohemoglobin Standardization Program (NGSP) and International Federation of Clinical Chemistry and Laboratory Medicine (IFCC). This method is considered the "gold standard" for HbA1c measurement.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable. As an IVD device measuring a quantitative biomarker, adjudication by multiple human readers is not a part of the evaluation process. The accuracy is assessed by comparing the device's numerical output to a highly accurate reference method.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

Not applicable. This is an IVD device for quantitative measurement, not an AI-assisted diagnostic tool that involves human readers interpreting cases.

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

Yes, the studies described are for the standalone performance of the A1C EZ Glycohemoglobin Analysis System. It's an automated system that provides a quantitative measurement, inherently operating without human-in-the-loop performance influencing the measurement itself. Users operate the device, but their interpretation skills are not part of the device's core performance evaluation here; rather, the device's ability to accurately measure HbA1c is what's being assessed.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The ground truth for the device's accuracy was established by comparison to a reference method – the Tosoh HLC-723 G8 HPLC device. This method is internationally recognized and certified (NGSP and IFCC), serving as the de facto "truth" for HbA1c concentration.

8. The sample size for the training set

This document does not describe a "training set" in the context of machine learning (AI). This is a traditional IVD device, and the listed studies are for its analytical performance validation rather than AI model training. Therefore, a training set as understood in AI/ML is not applicable.

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

As there is no "training set" in the AI/ML sense for this device, this question is not applicable. The device's underlying chemistry and photometric measurement principles are based on established scientific methods for HbA1c detection, not statistical learning from a labeled training dataset.

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002 June16, 2017

BIOHERMES CO., LTD C/O FIELD FU, SHENZHEN JOY ANTECH CONSULTING CO., LTD. ROOM 2032, INTERNATIONAL MAYORS COMMUNICATION CENTRE, NO. 55 SHIZHOU MIDDLE ROAD, NANSHAN DISTRICT SHENZHEN, GD755 CHINA

Re: K161533

Trade/Device Name: A1C EZ Glycohemoglobin Analysis System Regulation Number: 21 CFR 864.7470 Regulation Name: Glycosylated hemoglobin assay Regulatory Class: II Product Code: LCP. JJE Dated: May 3, 2017 Received: May 8, 2017

Dear Field Fu:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and 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) that do not require approval of a premarket approval application (PMA). 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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Parts 801 and 809); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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If you desire specific advice for your device on our labeling regulations (21 CFR Parts 801 and 809), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Kellie B. Kelm -S

for Courtney H. Lias, Ph.D. Director Division of Chemistry and Toxicology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K161533

Device Name

A1C EZ Glycohemoglobin Analysis System

Indications for Use (Describe)

A1C EZ Glycohemoglobin Analysis System is an in vitro diagnostic test used to quantitatively measure the percent glycohemoglobin Alc or glycohemoglobin A1c fraction mmol/mol in venous whole blood samples. This system is intended for multiple patient use to monitor long term glycemic control in individuals previously diagnosed with diabetes. This test is not to be used for screening or diagnosis of diabetes or for neonatal use. The A1C EZ Glycohemoglobin Analysis System is intended for professional use in clinical laboratories only.

Type of Use (Select one or both, as applicable)

☑ Prescription Use (Part 21 CFR 801 Subpart D)☐ Over-The-Counter Use (21 CFR 801 Subpart C)
-----------------------------------------------------------------------------------------------

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Contact Details

Product: A1C EZ Glycohemoglobin Analysis System

Version: A/4

K161533

1.1 Applicant information Applicant Name BioHermes Co., Ltd 2F, 3F, No. 136 Mashan Meiliang Road, Binhu District, Wuxi, China Address Phone No. +86-510-85991708 +86-510-85995258 Fax No. Contact person Rao Qiangying Contact person's e-mail raoqiangying@biohermes.com.cn Date Prepared March 28, 2016 Website www.biohermes.com

510(k) Summary

1.2 Submission Correspondent

Shenzhen Joyantech Consulting Co., LtdRoom 2032, International Mayors Communication Centre, NO. 55Shizhou middle road, Nanshan District, Shenzhen
卓远天成
Phone No.+86-755-86069197
Contact personChristy Young; Field Fu;
Contact person's e-mailchristy@cefda.com; cefda13485@163.com;
Websitehttp://www.cefda.com

Device information 2.

Trade nameA1C EZ Glycohemoglobin Analysis System
Common namePercent Hemoglobin A1c (percent glycosylated hemoglobin)
Model/
ClassificationII; I
Classification nameAssay, Glycosylated Hemoglobin; Analyzer, Chemistry (Photometric, Discrete), For Clinical Use
Product codeLCP; JJE
Regulation No.864.7470;862.2160

3. Legally Marketed Predicate Device

Trade NameA1CNow+ (Professional Use)
510(k) NumberK090413
Product CodeLCP
ManufacturerBayer HealthCare Diabetes Care

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4. Device Description

This product is used to quantitatively measure the percent glycohemoglobin A1c or glycohemoglobin A1c fraction mmol/mol in human whole blood sample.

5. Intended Use/Indication for Use

Product: A1C EZ Glycohemoglobin Analysis System

A1C EZ Glycohemoglobin Analysis System is an in vitro diagnostic test used to quantitatively measure the percent glycohemoglobin A1c or glycohemoglobin A1c fraction mmol/mol in venous whole blood samples. This system is intended for multiple patient use to monitor long term glycemic control in individuals previously diagnosed with diabetes. This test is not, to be used for screening or diagnosis of diabetes or for neonatal use. The A1C EZ Glycohemoglobin Analysis System is intended for professional use in clinical laboratories only.

Proposed Device:Predicate Device:
ItemA1C EZ Glycohemoglobin Analysis SystemA1CNow+ (Professional Use)(K090413)
Product CodeLCP,JJELCP
Intended UseA1C EZ Glycohemoglobin Analysis Systemis an in vitro diagnostic test used toquantitatively measure the percentglycohemoglobin A1c or glycohemoglobinA1c fraction mmol/mol in venous whole bloodsamples. This system is intended for multiplepatient use to monitor long term glycemiccontrol in individuals previously diagnosedwith diabetes. This test is not to be used forscreening or diagnosis of diabetes or forneonatal use. The A1C EZ GlycohemoglobinAnalysis System is intended for professionaluse in clinical laboratories only.The A1CNow multi-use test providesquantitative measurement of the percent ofglycated hemoglobin (%HbAlc, %A1C)levels in whole blood samples. The test isfor professional use for monitoring glycemiccontrol in people with diabetes.
Sample TypesWhole blood sampleWhole blood samples
CalibrationAutomatic, not required by end-userNot required by end-user; each unit isfactory calibrated
TestingEnvironmentProfessional UseProfessional Use
RoomTemperatureStability18 months room temperature15 months room temperature
MethodologyBoronate AffinityImmunoassay
MeasuringRange4%-14% HbA1c4%-13% HbA1c

6. Substantial Equivalence Comparison

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BioHermes Co., Ltd

SEC 005:001 510K Summary

Version: A/4

Product: A1C EZ Glycohemoglobin Analysis System

PrecisionThe overall imprecision (including within-run, between-run, and between-day) was 3.3% CV at the low level and 2.8% CV at the high level.The overall imprecision (including within-day and between day) was 3.00% CV at the low level and 4.02% CV at the high level.
AccuracyLinear regression analysis of comparison study between A1c EZ 2.0 and Tosoh G8 Slop Intercept Lot1 0.973 0.188 Lot2 0.979 0.162 Lot3 0.989 0.111Linear regression analysis of comparison study between A1CNow+ and Tosoh A1c 2.2 Plus Slop Intercept 1.02 -0.23
AnalyticalSpecificityINTERFERENTBilirubinTESTCONCENTRATION60mg/dl
Triglyceride900mg/dl
Hemoglobin500 mg/dL
Acetaminophen200 µg/mL
Ascorbic acid30mg/dl
INTERFERENTBilirubinTESTCONCENTRATION20 mg/dL
Triglyceride3000 mg/dL
Hemoglobin500 mg/dL
Acetaminophen80 µg/mL
Ascorbic acid5 mg/dL

lssue 1: Even though the Room Temperature Stability is different, but the performances between the proposed device within the stable period and the predicate device within the stable period are the same.

Issue 2: The A1c EZ 2.0 glycohemoglobin analysis system utilizes the boronate affinity lateral chromatography method to quantitatively measure the percentage of glycohemoglobinA1c (HbA1c) in total hemoglobin. A solid phase separation matrix in membrane contains both negatively charged groups and boronate groups. When buffer A which is acidic flows through the matrix membrane, positively charged hemoglobin (including glycohemoglobin and non-glycohemoglobin) bind to the negatively charged groups. When buffer B flows through and the pH turns basic, hemoglobin loses its positive charge and is released from the matrix. However, cis-diols of glycohemoglobin can bind with the boronate group and stays in the matrix. The device uses a photometer to measure the reflectance and calculate the ratio of the glycohemoglobin to the total hemoglobin.

A1cNow+'s work mechanism is immunoassay, which utilizes the specific recognition of antibodies to glycohemoglobin and non-glycohemoglobin respectively. Detection and quantification of HbA1c and normal hemoglobin are also achieved by measurement of reflectance by photometer. Although the test method of A1c Ez 2.0 and A1cNow+ differs, both of the devices use photochemistry and reflectance measure to quantify the percentage of glycohemoglobin. According to the comparison study, their accuracy is similar to each other.

7. Non-clinical Testing

  • 7.1 Test strip stability test
    The test strip's stability was tested and the test results showed that A1c Ez 2.0 HbA1c test kit can keep stable in room temperature for at least eighteen months.

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7.2 Traceability

The A1C EZ Glycohemoglobin Analysis System is certified with the National Glycohemoglobin Standardization Program (NGSP) and International Federation of Clinical Chemistry and laboratory medicine (IFCC).

7.3 Performance test-bench (Analysis Performance)

a) Precision and reproducibility

Internal precision

Precision studies in internal laboratory were performed according to CLSI EP5-A2. Sample from normal patient (Level 1, HbA1c% = 5.8%, all labeled value of blood sample used in this performance test were determined by Tosoh G8) and diabetic patient (Level 2, HbA1c% = 12.2%) were run in the precision study. The precision study was performed on 1 instrument over 20 consecutive days by using 3 lots of the test kits.

CV %Lot 1Lot 2Lot 3All lots combined
Level 1Level 2Level 1Level 2Level 1Level 2Level 1Level 2
Within-run3.0%2.7%3.4%2.9%3.3%2.9%3.2%2.8%
Between-run0.8%0.5%0.0%0.0%1.3%0.0%0.9%0.0%
Between-day2.1%1.6%1.1%0.9%0.0%1.0%0.0%0.3%
Total3.8%3.1%3.5%3.0%3.5%3.1%3.3%2.8%

Results of internal precision tests (HbA1c % NGSP)

Results of internal precision tests (HbA1c mmol/mol IFCC)
-------------------------------------------------------------
CV %Lot 1Lot 2Lot 3All lots combined
Level 1Level 2Level 1Level 2Level 1Level 2Level 1Level 2
Within-run4.8%3.2%5.4%3.5%5.2%3.6%5.3%3.4%
Between-run1.3%0.7%0.0%0.0%2.1%0.0%1.4%0.0%
Between-day3.4%1.9%1.7%1.1%0.0%1.2%0.0%0.5%
Total6.0%3.8%5.6%3.6%5.6%3.8%5.8%4.4%

External precision

In this study, repeatability and reproducibility of A1C EZ 2.0 test strips have been evaluated at 3 external clinical sites. 10 sets of A1C EZ 2.0 analyzers, 3 lots of test strips and 3 levels of K2-EDTA anticoagulated venous blood samples (level 1- 5.1%, level 2- 7.3%, level 3- 11.7%) were used. For each sample, every operator performed the tests in 2 run per day, tests at each site were finished in two days) by 10 sets of A1C EZ 2.0 analyzers with 3 different lots of test strips. Totally 120 tests were performed at each site for each sample. The precision represented as CV and mean value by percentage are given as below:

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Version: A/4

Level123
N360360360
% NGSPMEAN5.097.3711.54
CV3.1%2.7%2.3%
mmol/molIFCCMEAN32.257.1102.6
CV5.3%3.8%2.8%

Table: Total CV includes all sites, operators, meters and test strip lots

Table: CV calculated for test strip lots

Strip Lot123
Level123123123
N120120120120120120120120120
% NGSPMEAN5.097.3711.575.107.3511.475.097.4111.58
CV3.2%2.8%2.1%3.1%2.6%2.3%3.0%2.6%2.4%
mmol/molIFCCMEAN32.157.0102.932.356.8101.932.257.5103.0
CV5.5%4.0%2.5%5.3%3.7%2.9%5.2%3.6%2.9%

Table: CV calculated for sites

Site 1Site 2Site 3
Level123123123
N120120120120120120120120120
% NGSPMEAN5.047.2911.495.067.4311.575.117.4011.56
CV3.0%2.7%2.5%2.7%2.5%2.1%2.9%2.5%2.2%
mmol/mol IFCCMEAN31.656.2102.032.957.7103.032.057.3102.8
CV5.2%3.8%3.0%5.0%3.6%2.6%4.9%3.5%2.7%

Table: CV calculated for operators

Operator123
Level123123123
N606060606060606060
% NGSPMEAN5.047.2811.455.057.3011.525.187.4711.56
CV3.0%3.0%2.4%3.0%2.3%2.5%2.8%2.5%2.1%
mmol/mol IFCCMEAN31.556.1101.631.656.2102.433.058.1102.8
CV5.2%4.2%3.0%5.2%3.3%3.1%4.9%3.5%2.6%
Operator456
Level123123123
N606060606060606060

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BioHermes Co., Ltd

SEC_005:001_510K Summary

% NGSPMEAN5.157.4011.595.107.4411.555.097.3511.57
CV3.0%2.5%2.2%3.1%2.7%2.2%3.0%2.1%2.4%
mmol/molMEAN32.857.4103.231.757.8102.732.356.8102.9
IFCCCV5.2%3.6%2.7%4.8%3.8%2.5%5.0%3.0%2.9%

Product: A1C EZ Glycohemoglobin Analysis System

Version: A/4

b) Linearity and reportable range/detection limit

Linearity was evaluated according to CLSI EP06-A. The test results and linear regression analysis are given in Table 5.

Table 5: Linear regression analysis of linearity test

SlopeInterceptRR2
A1C EZ 2.0(HbA1c % NGSP)1.0334-0.16280.99950.9989
A1C EZ 2.0(HbA1c mmol/mol IFCC)1.0377-1.47950.99950.9990

The reportable range / detection limit of A1C EZ 2.0 is 4%~14% NGSP or 20-130 mmol/mol IFCC

c) Analytical specificity

Anticoagulants:

The results show that K2-EDTA, Heparin Sodium fluoride have no significant interference on HbA1c determination by A1c EZ 2.0 HbA1c Test System. Lithium Heparin,Sodium Fluoride or K2-EDTA venous whole blood are suitable to be used with the device.

General interference substance:

The following substances do not interfere with test result:

Interfering Substance StudyTest Concentration
Acetaminophen200 mg/L
Acetylcysteine1,663 mg/L
Acetylsalicylic acid1,000 mg/L
Ampicillin1,000 mg/L
Ascorbic acid300 mg/L
Bilirubin, conjugated600 mg/L
Bilirubin, unconjugated600 mg/L
Cholesterol10,000 mg/L
Cyclosporine A5 mg/L
Doxycycline50 mg/L
Glucose10,000 mg/L
Glyburide2 mg/L
Hemoglobin500 mg/dL
Hemolysis (Hemolysate)5,000 mg/dL
lbuprofen500 mg/L
Levodopa20 mg/L

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Version: A/4

Metformin40 mg/L
Metronidazole200 mg/L
Phenylbutazone400 mg/L
Rifampicin64 mg/L
Salicylic acid599 mg/L
Theophylline100 mg/L
Triglyceride9,000 mg/L
Rheumatoid factor491 IU/mL

Hemoglobin variant interference

The results from the A1C EZ 2.0 Glycohemoglobin Analysis System show that there is no significant interference for Hemoglobin C (≤ 44.7%), Hemoglobin D (≤ 41.7%), Hemoglobin E (≤ 32.6%), Hemoglobin S (≤ 37.8%), and Hemoglobin F (≤ 14.7%)

    1. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
  • 8.1 Sample volume study:

The sponsor performed a study to verify the test strip minimum sample volume requirement and the test strip fill error requirement established for the HbA1c analyzer. Blood samples were tested at five sample volumes (0.5, 1.5, 3, 4 and 5.5μL). Results support the claimed sample volume of 2.5-4.5ul.

  • 8.2 Test System operating conditions:
    Operating conditions were evaluated for temperatures ranging from 50 ~104°F (10°C-40°C) and relative humidity from 10% to 90%. The following temperature and relative humidity (RH) conditions were tested: 22°C and 40% RH, 11°C and 11% RH, 10°C and 90% RH, 38°C and 10% RH, 40°C and 90% RH. Protocol and acceptance criteria were provided and found to be acceptable. The results supported the Sponsor's claimed operating temperature from 50 ~104°F and relative humidity range from 30% to 75%.

  • 8.3 Infection Control Studies:
    Disinfection efficacy studies were performed on the materials comprising the meter by an outside commercial testing laboratory demonstrating complete inactivation of hepatitis B virus (HBV) with the chosen disinfectant, Clorox Healthcare Bleach Germecidal Wipes (EPA Registraiton# 67619-12). Robustness studies were also performed to demonstrate that there was no change in performance or in external materials of the meter after 18250 cleaning and disinfection cycles with Clorox Healthcare Bleach Germecidal Wipes. The robustness studies were designed to simulate 5 years of multiple-patient use.

9. Accuracy

Internal comparison study was performed according to CLSI EP09-A2 to evaluate accuracy of A1c EZ 2.0. The A1c EZ 2.0 was compared with the reference HPLC device Tosoh HLC-723 G8 and the predicate device A1CNow+ in this study. Linear regression analysis results of the accuracy study are

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Version: A/4

given as below:

Linear regression analysis of internal method comparison study (Unit: %NGSP)

VS Tosoh HLC-723 G8VS A1CNow+
Lot 1Lot 2Lot 3Lot 1Lot 2Lot 3
Slop0.9730.9790.9890.9660.9760.989
Intercept0.1880.1620.1110.2030.1520.079
R-square0.9850.9840.9850.9630.9670.971

Linear regression analysis of internal method comparison study (Unit: mmol/IFCC)

VS Tosoh HLC-723 G8VS A1CNow+
Lot 1Lot 2Lot 3Lot 1Lot 2Lot 3
Slop0.9750.9790.9890.9660.9750.988
Intercept1.3261.2660.9571.4311.1270.652
R-square0.9850.9840.9850.9630.9670.971

10. Conclusions

Based on device comparison information and non-clinical bench testing, the proposed device is substantially equivalent to legally marketed predicate devices (K090413).

§ 864.7470 Glycosylated hemoglobin assay.

(a)
Identification. A glycosylated hemoglobin assay is a device used to measure the glycosylated hemoglobins (A1a , A1b , and A1c ) in a patient's blood by a column chromatographic procedure. Measurement of glycosylated hemoglobin is used to assess the level of control of a patient's diabetes and to determine the proper insulin dosage for a patient. Elevated levels of glycosylated hemoglobin indicate uncontrolled diabetes in a patient.(b)
Classification. Class II (performance standards).