(35 days)
The Glucose assay is used for the quantitation of glucose in human serum, plasma, urine, or cerebrospinal fluid (CSF) on the ALCYON 300/300i Analyzer. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
Glucose is an in vitro diagnostic assay for the quantitative determination of glucose in human serum, plasma, urine, or cerebrospinal fluid (CSF). The Glucose assay is a clinical chemistry assay in which glucose is phosphorylated by hexokinase (HK) in the presence of adenosine triphosphate (ATP) and magnesium ions to produce glucose-6-phosphate (G-6-P) and adenosine diphosphate (ADP). Glucose-6-phosphate dehydrogenase (G-6-PD) specifically oxidizes G-6-P to 6-phosphogluconate with the concurrent reduction of nicotinamide adenine dinucleotide (NAD) to nicotinamide adenine dinucleotide reduced (NADH). One micromole of NADH is produced for each micromole of glucose consumed. The NADH produced absorbs light at 340 nm and can be detected spectrophotometrically as an increased absorbance.
The provided document describes a 510(k) submission for the Abbott Laboratories Glucose assay. This assay is an in vitro diagnostic (IVD) test, not a medical device in the typical sense of imaging or interventional tools, and as such, the acceptance criteria and study design will differ significantly from what would be expected for a device like an AI-powered diagnostic image analysis system.
The document does not contain acceptance criteria or study details in the format requested for a typical AI/medical device study. Instead, it focuses on demonstrating substantial equivalence to existing predicate devices.
Here's a breakdown based on the information available and what is not present:
Missing Information:
The document does not provide specific numerical acceptance criteria (e.g., sensitivity, specificity, AUC) or detailed study designs with sample sizes, expert qualifications, or ground truth establishment methods for a de novo performance study. This is because the submission's goal is to show equivalence.
Based on the provided K981185 510(k) Summary:
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria (Expected/Implied) | Reported Device Performance |
|---|---|
| Clinical Results: Similar to predicate devices | "Both assays yield similar clinical results." (compared to Roche) |
| "Both assays yield similar clinical results." (compared to Boehringer Mannheim) | |
| Methodology: In vitro clinical chemistry method | "Both assays are in vitro clinical chemistry methods." (compared to Roche and Boehringer Mannheim) |
| Intended Use: Quantitative determination of glucose | "Both assays can be used for the quantitative determination of glucose." (compared to Roche and Boehringer Mannheim) |
| Assay Range: Comparable to predicate devices | "There is a minor difference between the assay range." (compared to Roche and Boehringer Mannheim) |
Explanation: For an IVD assay seeking substantial equivalence, the "acceptance criteria" are implicitly met if the new device performs "similarly" to a legally marketed predicate device across key performance characteristics and intended use. The document states that the new Glucose assay yields "similar clinical results" and utilizes "similar clinical chemistry methods" to its predicates. The "minor difference between the assay range" is acknowledged but not presented as a significant deviation from equivalence.
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: Not explicitly stated. The document describes a general comparison to predicate devices, but no specific sample size for a "test set" from a performance study is provided.
- Data Provenance: Not explicitly stated. This would typically involve details on study populations (e.g., patient demographics, disease prevalence) and whether the data was collected retrospectively or prospectively. Given it's a 1998 submission for an assay, it's highly likely internal validation data was used, but the specifics are absent.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts:
- Not applicable / Not provided. For an IVD assay like this, "ground truth" is typically established by reference methods or clinical diagnosis, not by experts adjudicating visual data as in an AI imaging study. No information on experts or their qualifications is present.
4. Adjudication Method for the Test Set:
- Not applicable / Not provided. Adjudication methods (like 2+1, 3+1) are common in AI imaging studies where human disagreement needs resolution. For a quantitative IVD assay, ground truth is usually a measured value, and adjudication in this sense is not relevant.
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 study is for a standalone in vitro diagnostic assay, not an AI-assisted diagnostic tool that would be used by human readers. Therefore, an MRMC study comparing human readers with and without AI assistance was not performed.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done:
- Yes, implicitly. The device is a standalone assay. Its performance is evaluated independently as a chemical reaction observed spectrophotometrically. The "algorithm" here is the chemical reaction and spectrophotometric measurement, not a software algorithm in the AI sense. Its performance is "standalone" in that it directly measures glucose levels.
7. The Type of Ground Truth Used:
- Clinical results compared to predicate assays. The document states "Both assays yield similar clinical results" when compared to the Roche Cobas Mira Plus Glucose assay and the Boehringer Mannheim Glucose/HK assay. For an IVD, the ground truth would typically be established by a well-accepted reference method or another clinically validated method that is considered a gold standard for glucose measurement. While not explicitly stated, the implication is that the predicate assays served as the comparative "truth" for demonstrating similar performance, likely against a broader clinical context of diagnosed conditions.
8. The Sample Size for the Training Set:
- Not applicable / Not provided. This is an IVD assay based on a pre-defined chemical reaction, not a machine learning algorithm that requires a "training set" in the AI sense. The assay is "trained" by its chemical formulation and calibration, not by data.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable / Not provided. As mentioned above, there isn't a "training set" or "ground truth for a training set" in the context of this chemical assay. The assay's performance characteristics (e.g., linearity, precision, accuracy) would have been established through standard IVD validation procedures using calibrated materials and patient samples, but these are not equivalent to AI training data.
Summary of Limitations based on the provided document:
The provided document is a 510(k) summary focused on establishing substantial equivalence for an in vitro diagnostic assay. It is not a detailed clinical study report for an AI-powered medical device. Therefore, many of the requested categories (e.g., sample size for test set/training set, expert qualifications, MRMC study, ground truth for training set) are either not applicable or not explicitly detailed within the scope of this specific type of regulatory submission. The "study" described is a comparison of performance characteristics and intended use to existing, legally marketed predicate devices, rather than a de novo clinical trial with specific performance endpoints.
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CONFIDENTIAL
MAY 7 1998
510(k) Summary
Submitter's Name/Address Abbott Laboratories 1920 Hurd Drive Irving, Texas 75038
Contact Person Mark Littlefield Section Manager MS 1-8 Regulatory Affairs (972) 518-7861 Fax (972) 753-3367
| Date of Preparation of this Summary: | March 31, 1998 |
|---|---|
| Device Trade or Proprietary Name: | Glu |
| Device Common/Usual Name or Classification Name: | Glucose |
| Classification Number/Class: | 75CFR/Class II |
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.
The assigned 510(k) number is:
Test Description:
Glucose is an in vitro diagnostic assay for the quantitative determination of glucose in human serum, plasma, urine, or cerebrospinal fluid (CSF). The Glucose assay is a clinical chemistry assay in which glucose is phosphorylated by hexokinase (HK) in the presence of adenosine triphosphate (ATP) and magnesium ions to produce glucose-6-phosphate (G-6-P) and adenosine diphosphate (ADP). Glucose-6-phosphate dehydrogenase (G-6-PD) specifically oxidizes G-6-P to 6-phosphogluconate with the concurrent reduction of nicotinamide adenine dinucleotide (NAD) to nicotinamide adenine dinucleotide reduced (NADH). One micromole of NADI-Is produced for each micromole of glucose consumed. The NADH produced absorbs light at 340 nm and can be detected spectrophotometrically as an increased absorbance.
Section II Page I
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Substantial Equivalence:
The Glucose assay is substantially equivalent to the following devices:
- Roche® Cobas Mira® Plus Automated Chemistry System Glucose assay (K953847) . for the serum application
- Boehringer Mannheim® Glucose/HK assay on the Hitachi® 717 Analyzer . (K812303) for the urine and CSF applications
These assays yield similar Performance Characteristics.
Similarities to Roche:
- Both assays are in vitro clinical chemistry methods. .
- Both assays can be used for the quantitative determination of glucose. .
- Both assays yield similar clinical results. .
Differences to Roche:
-
There is a minor difference between the assay range. .
Similarities to Boehringer Mannheim: -
Both assays are in vitro clinical chemistry methods. .
-
Both assays can be used for the quantitative determination of glucose. .
-
. Both assays yield similar clinical results.
Differences to Boehringer Mannheim:
- · There is a minor difference between the assay range.
Intended Use:
The Glucose assay is used for the quantitation of glucose in human serum, plasma, urine, or cerebrospinal fluid (CSF) on the ALCYON 300/300i Analyzer.
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DEPARTMENT OF
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
7 1998 MAY
Mark Littlefield . Section Manager, Regulatory Affairs Abbott Laboratories 1920 Hurd Drive 75038 Irving, Texas
Re : K981185 Glucose Requlatory Class: II Product Code: CFR March 31, 1998 Dated: Received: April 2, 1998
Dear Mr. Littlefield:
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 The general controls provisions of the Act of the Act. include requirements for annual registration, listing of devices, qood 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 requlations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or requlations.
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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 qeneral 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 (301) 443-6597 or at its internet address "http://www.fda.qov/cdrh/dsmamain.html".
Sincerely yours,
Steven Litman
Steven I. Gutman, M.D., M.B.A. Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Number (if known): ____________________________________________________________________________________________________________________________________________________
Device Name: _________________________________________________________________________________________________________________________________________________________________
Indications For Use:
The Glucose assay is used for the quantitation of glucose in human serum, plasma, urine, or cerebrospinal fluid (CSF) on the ALCYON 300/300i Analyzer. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
(Division Sign-Off)
Division of Clinical Laboratory Devices
510(k) Number. k 181185
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------Concurrence of CDRH, Office of Device Evaluation (ODE) Over-The-Counter Use__________________________________________________________________________________________________________________________________________________________ Prescription Use_ OR (Per 21 CFR 801.109)
(Optional Format 1-2-96)
§ 862.1345 Glucose test system.
(a)
Identification. A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.(b)
Classification. Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.