(62 days)
The pHoenix Electrolyte Calibrator Set for the Medica EasyLyte Calcium Analyzer is intended for use as The procedes to calibrate Nat, K+, Ca* and pH for the Medica EasyLyte Calcium Analyzer.
Phoenix Electrolyte Calibration Set for Medica Easylyte Analyzer consists of two standards A and B for use in calibrating Nat, Kt, Cat+ and pH electrodes. The Medica Easylyte Calcium Analyzer measures Na , K , Ca + , and pH using ion selective electrode technology. pHoenix calibration set is intended to serve as direct replacement to similar calibrator manufactured by Medica Corporation. pHoenix uses similar composition, description and packaging design as that used by Medica Corporation in its calibration set.
The provided text describes the pHoenix Electrolyte Calibration Set for Medica Easylyte Calcium Analyzer. This submission focuses on establishing substantial equivalence to a predicate device, rather than providing detailed acceptance criteria and performance data in a typical study format for a diagnostic device. As such, some of the requested information cannot be fully extracted.
Here's the information that can be derived and a note on what is not available:
1. Table of Acceptance Criteria and Reported Device Performance
Note: The document describes "performance equivalence" through "method comparison" and "precision study" but does not provide specific numerical acceptance criteria (e.g., within X% of predicate) nor the detailed results of these studies. The table below represents the areas of comparison rather than quantitative performance.
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Equivalent intended use as predicate device | Similar: Calibration of Na, K, Ca, and pH electrodes |
| Equivalent target population (Medica EasyLyte Calcium Analyzer) | Similar: Medica EasyLyte Calcium Analyzer |
| Equivalent design and material (composition) | Similar: Contains Sodium, Potassium, Calcium, and buffers in an aqueous base |
| Equivalent overall performance as predicate device (implicitly via method comparison and precision) | Similar: Demonstrated through method comparison and precision study (specific results not provided) |
| Equivalent sterility | Similar: No Growth |
| Equivalent biocompatibility | Similar: Not Applicable |
| Equivalent mechanical safety | Similar: Not Applicable |
| Equivalent chemical safety (no hazardous chemicals) | Similar: Both contain no hazardous chemicals |
| Equivalent human factors | Similar: Not Applicable |
| Equivalent energy used | Similar: Not Applicable |
| Equivalent compatibility with environment and other devices | Similar: Not Applicable |
| Equivalent where used (laboratories) | Similar: Laboratories |
| Equivalent standards (if any) | Similar: No known standards |
| Equivalent electrical, thermal, and radiation safety | Similar: Not Applicable |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: Not explicitly stated. The document mentions a "method comparison" and "precision study" but does not provide the number of samples or runs performed.
- Data Provenance: Not explicitly stated. It's safe to assume the data would have been generated in a controlled laboratory setting for the purpose of this submission, likely in the US, but the document does not specify "country of origin" or if it was retrospective/prospective.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications
Not Applicable. This is a calibration set for an analyzer, not a diagnostic device requiring expert interpretation of results. The "ground truth" would be established by the reference methods/readings of the predicate device and internal quality control standards.
4. Adjudication Method for the Test Set
Not Applicable. This is not a study requiring adjudication of expert opinions.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done
No. This is a calibration set, not a device for interpretation by human readers.
6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Was Done
Not Applicable / Partially applicable. The device itself is a calibrator, which performs its function standalone by interacting with the analyzer. Its "performance" is its ability to correctly calibrate the analyzer, which is then measured by its analytical accuracy and precision in comparison to a predicate, not in an interpretive sense.
7. The Type of Ground Truth Used
The "ground truth" for evaluating the pHoenix Electrolyte Calibration Set is based on its performance relative to the predicate Medica Electrolyte Calibration Set. This is established through:
* Method Comparison: Comparing the results obtained when using the pHoenix calibrator versus the Medica calibrator on the Medica EasyLyte Calcium Analyzer.
* Precision Study: Assessing the consistency and variability of results when using the pHoenix calibrator.
* Implicitly, the "ground truth" for the actual analyte values within the calibrator would be established by the manufacturer through traceable reference materials and methods.
8. The Sample Size for the Training Set
Not Applicable. This is a physical calibration solution, not an AI/ML algorithm that requires a "training set" of data.
9. How the Ground Truth for the Training Set Was Established
Not Applicable. (As explained in point 8).
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tics, Inc
· NATICK, MA 01760 · TEL: 508-655-8310 · FAX: 508-655-8273
510 K SUMMARY
- Ram Nunna 1. Submitter: Address: pHoenix Diagnostics Inc. 8 Tech Circle Natick. MA 01760 208-655-8310 Phone: 508-655-8273 Fax: Contact Person: Ram Nunna
Date of Summary: 11/01/01
NOV 0 7 2001
2. Device Name and Associated Information:
Device Name: Electrolyte Calibration Set for Medica Easylyte Calcium Analyzer.
Trade Name: Same as above.
Common Name: Same as above.
Classification and Associated Information:
Classification: Calibrator, Multianalyte Mixture
Device Classification: II
Panel: Chemistry 75
Product Code: JIX
3. pHoenix Electrolyte Calibration Set is similar in composition and performance to
the following systems calibration set:
-
- Medica Easylyte Electrolyte Analyzer.
-
- Nova Biomedical Electrolyte Analyzer.
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Image /page/1/Picture/0 description: The image shows the logo for pHoenix Diagnostics, Inc. The text is in bold, black font. The word "pHoenix" is in a slightly smaller font than "Diagnostics, Inc."
· NATICK, MA 01760 · TEL: 508-655-8310 · FAX: 508-655-8273
Attachment: Substantial equivalence comparison.
-
- 510 K Summary: Phoenix Electrolyte Calibration Set for Medica Easylyte Analyzer consists of two standards A and B for use in calibrating Nat, Kt, Cat+ and pH electrodes. The Medica Easylyte Calcium Analyzer measures Na , K , Ca + , and pH using ion selective electrode technology. pHoenix calibration set is intended to serve as direct replacement to similar calibrator manufactured by Medica Corporation. pHoenix uses similar composition, description and packaging design as that used by Medica Corporation in its calibration set. pHoenix has shown performance equivalence of its calibration set, to Medica Corporation calibration set, in the following manner:
-
- through a method comparison
- 2, through a precision study
5. Intended use:
pHoenix Electrolyte Calibration Set for Medica Easylyte Calcium analyzer is intended to calibrate Na, K, Ca*, pH electrodes of Medica Easylyte Calcium analyzer.
Date: 11/5/01
Signature:
Ram Nunna
President,
pHoenix Diagnostics Inc.
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Substantial Equivalence Comparison
Standard A and Standard B for Medica EasyLyte Calcium Analyzer Predicate Device Name: K943091 510 (k) Number:
The pHoenix products under application are similar in composition and function to the Medica products as follow I ne products under application as similar in belige and pHoenix products is as follows:
4
| Areas | Comparison ofpHoenix andMedica products | Comments |
|---|---|---|
| Intended use | Similar | Both are intended for the calibration ofNa, K, Ca and pH for the MedicaEasyLyte Calcium Analyzer |
| Target population | Similar | Medica EasyLyte Calcium Analyzer |
| Design and material | Similar | Contains Sodium, Potassium, Calciumand buffers in an aqueous base |
| Performance | Similar | See 510(k) Summary |
| Sterility | Similar | No Growth |
| Biocompatibility | Similar | Not Applicable |
| Mechanical Safety | Similar | Not Applicable |
| Chemical Safety | Similar | Both contains no hazardous chemicals |
| Human Factors | Similar | Not Applicable |
| Energy used | Similar | Not Applicable |
| Compatibility withenvironment and otherdevices | Similar | Not Applicable |
| Where use? | Similar | Laboratories |
| Standards | Similar | No known standards |
| Electrical, thermal andradiation safety | Similar | Not Applicable |
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is an abstract symbol that resembles an eagle or bird in flight, composed of three curved lines.
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
NOV 0 7 2001
Mr. Ram Nunna President pHoenix Diagnostic Inc. 8 Tech Circle Natick, MA 01760
Re: K012987
Trade/Device Name: pHoenix Electrolyte Calibration Set for the Medica EasyLyte Calcium Analyzer Regulation Number: 21 CFR 862.1150 Regulation Name: Calibrator Regulatory Class: Class II Product Code: JIX Dated: September 6, 2001 Received: September 6, 2001
Dear Mr. Nunna:
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.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), 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 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 Part 801); 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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Page 2 -
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 legally 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" (21CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".
Sincerely yours,
Steven Sutman
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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KD12987
NOV 0 7 2001
INDICATIONS FOR USE STATEMENT
510(k) Number (if known): K_O 1 2 9 8 7
Device Name: pHoenix Electrolyte Calibration Set for the Medica EasyLyte Calcium Analyzer
Indications For Use:
Intended Use:
The pHoenix Electrolyte Calibrator Set for the Medica EasyLyte Calcium Analyzer is intended for use as The procedes to calibrate Nat, K+, Ca* and pH for the Medica EasyLyte Calcium Analyzer.
(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) OR
Over-The-Counter Use (Optional Format 1-2-96)
Cooper
(Division Sign-Off)
Division of Cined Labor
510(k) Numbc, KOL2987
§ 862.1150 Calibrator.
(a)
Identification. A calibrator is a device intended for medical purposes for use in a test system to establish points of reference that are used in the determination of values in the measurement of substances in human specimens. (See also § 862.2 in this part.)(b)
Classification. Class II (special controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.