K Number
K014167
Device Name
LIBERTY BLOOD GLUCOSE MONITORING SYSTEM
Date Cleared
2002-02-19

(62 days)

Product Code
Regulation Number
862.1345
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Liberty™ Blood Glucose System is intended for the quantitative measurement of glucose in fresh capillary whole blood. Testing is done outside the body (in vitro diagnostic use). It is indicated for use in the home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.
Device Description
The Liberty™ Blood Glucose Monitoring System consists of the following elements: test strips; a battery operated, portable, compact meter; and a control solution. Instrument Operating Principle: photometric Reagent Test Principle: glucose oxydase The Liberty™ System is based on photometric biosensor technology. The test strip is first inserted into the meter and the meter is switched on by pressing the "ON" button. A code number will appear on the display that should match the code on the vial of strips. An icon showing a flashing drop near the end of a test strip will appear on the display to prompt the user to apply a drop of blood. When a drop of blood is applied to the top of the strip at the mesh-filled target area, it flows into the membrane and starts the measurement. This is indicated on the display by a moving bar. After approximately 30 seconds, a glucose reading is displayed on the meter. The reading is stored in the meter memory with a date and time. The Liberty™ System uses a photometric test strip that includes glucose oxidase to generate a color reaction that is proportional to the concentration of glucose in the sample.
More Information

Not Found

No
The description details a standard photometric blood glucose meter using glucose oxidase, with no mention of AI or ML in its operating principle or performance studies.

No.
The device is intended for measurement and monitoring, not for treating any condition.

Yes
The device is intended for the quantitative measurement of glucose in fresh capillary whole blood, which is a diagnostic measurement used to monitor the effectiveness of diabetes control.

No

The device description explicitly lists hardware components: test strips, a battery-operated meter, and control solution. It describes a physical process involving applying blood to a strip inserted into a meter.

Yes, this device is an IVD (In Vitro Diagnostic).

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section explicitly states: "Testing is done outside the body (in vitro diagnostic use)."
  • Definition of IVD: An in vitro diagnostic device is a medical device intended for use in vitro for the examination of specimens, including blood and tissue samples, derived from the human body, in order to provide information for diagnostic, monitoring or compatibility purposes. This device fits this definition as it tests blood outside the body to monitor glucose levels.
  • Device Description: The description details a system that analyzes a biological sample (blood) using reagents and a meter to provide a quantitative measurement of a substance (glucose) within that sample. This is characteristic of an IVD.

N/A

Intended Use / Indications for Use

The Liberty™ Blood Glucose System is intended for the quantitative measurement of glucose in fresh capillary whole blood. Testing is done outside the body (in vitro diagnostic use). It is indicated for use in the home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.

Liberty™ Blood Glucose Meter is intended for use with Liberty™ Blood Glucose Strips for the quantitative measurement of glucose in fresh capillary whole blood. Testing is done outside the body (in vitro diagnostic use). It is indicated for use at home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.

Liberty™ Blood Glucose Strips are intended for the quantitative measurement of glucose in fresh capillary whole blood when used with the Liberty™ Blood Glucose Meter. Testing is done outside the body (in vitro diagnostic use). It is indicated for use at home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.

Liberty™ Control Solution is an aqueous glucose solution for use with the Liberty™ Blood Glucose System. It is used as a quality control check to verify the accuracy of the blood glucose test result. The Liberty™ Control Solution is intended for use in the validation of the performance of the Blood Glucose System by providing a test solution with a known range of glucose. A control test that falls within the acceptable range indicates the user's technique is appropriate and the test strip and meter are functioning properly.

Product codes (comma separated list FDA assigned to the subject device)

NBW; CGA; JJX

Device Description

The Liberty™ Blood Glucose Monitoring System consists of the following elements: test strips; a battery operated, portable, compact meter; and a control solution.
Instrument Operating Principle: photometric
Reagent Test Principle: glucose oxydase
The Liberty™ System is based on photometric biosensor technology. The test strip is first inserted into the meter and the meter is switched on by pressing the "ON" button. A code number will appear on the display that should match the code on the vial of strips. An icon showing a flashing drop near the end of a test strip will appear on the display to prompt the user to apply a drop of blood. When a drop of blood is applied to the top of the strip at the mesh-filled target area, it flows into the membrane and starts the measurement. This is indicated on the display by a moving bar. After approximately 30 seconds, a glucose reading is displayed on the meter. The reading is stored in the meter memory with a date and time.
The Liberty™ System uses a photometric test strip that includes glucose oxidase to generate a color reaction that is proportional to the concentration of glucose in the sample.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

home by persons with diabetes

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

The non-clinical and clinical studies carried out on the Liberty™ System and the predicate device (Accu-Chek Simplicity) demonstrate that the system is substantially equivalent to the predicate device and is safe and effective for its intended use.
Capillary blood study: N = 116 patients, Linear regression: Y = 0.930, Correlation coefficient = 0.941, Range = 35 - 470 mg/dL
Consumer study: N = 116 different patients, linear regression results: y = 0.872, Correlation coefficient = 0.921, Range = 28 to 390 mg/dL
Precision (Within-run precision, N=20 per level):
Control solution: Medium Mean 163 mg/dl, sd 11,3, CV 99 % of the 2 lots are in "A" region

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Correlation coefficient, Mean, Standard Deviation, CV

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K993829

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 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.

0

K014167

2017 - 12:42 PM IST - 12:00 PM IST - 12:00 PM IST - 12:00 PM - 12:00 PM IST - 12:00 PM - 12:00 PM - 12:00 PM - 12:00 PM - 12:00 PM - 12:00 PM - 12:00 PM - 12:00 PM - 12:00 PM

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FEB 1 9 2002K0141
E.510(k) SUMMARY
IntroductionAccording to the requirements of 21 CFR 807.92, the following information provides
sufficient detail to understand the basis for a determination of substantial equivalence
Submitter
name, address,
contactPolymedica Corporation
11 State Street
Woburn, MA 01801, USA
(781)-933-2020

Contact Person: Patricia Collins | |
| Device name | Date prepared: 12/04/01
Proprietary name: Liberty™ Blood Glucose Monitoring System
Common name: whole blood glucose test system
Classification name: Glucose Test System (21 CFR 862.1345) | |
| Predicate device | We claim substantial equivalence to the Accu-check Simplicity System marketed by
Roche Diagnostics, 510(k) # K993829 | |
| Device
description | The Liberty™ Blood Glucose Monitoring System consists of the following elements:
test strips; a battery operated, portable, compact meter; and a control solution. | |
| | Instrument Operating Principle: photometric
Reagent Test Principle: glucose oxydase | |
| | The Liberty™ System is based on photometric biosensor technology. The test strip is
first inserted into the meter and the meter is switched on by pressing the "ON"
button. A code number will appear on the display that should match the code on the
vial of strips. An icon showing a flashing drop near the end of a test strip will appear
on the display to prompt the user to apply a drop of blood. When a drop of blood is
applied to the top of the strip at the mesh-filled target area, it flows into the
membrane and starts the measurement. This is indicated on the display by a moving
bar. After approximately 30 seconds, a glucose reading is displayed on the meter. The
reading is stored in the meter memory with a date and time. | |
| | The Liberty™ System uses a photometric test strip that includes glucose oxidase to
generate a color reaction that is proportional to the concentration of glucose in the
sample. | |
| Intended use | The Liberty™ Blood Glucose System is intended for the quantitative measurement of
glucose in fresh capillary whole blood. Testing is done outside the body ( in vitro
diagnostic use). It is indicated for use in the home by persons with diabetes as an aid
to monitor the effectiveness of diabetes control. | |
| Comparison to
Predicate Device | The Liberty™ Blood Glucose System is substantially equivalent to the Accu-chek
Simplicity System marketed by Roche Diagnostics, 510(k) K993829 | |

11 11 11 11

1

SE Comparison Table, Technological CharacteristicsLiberty™ SystemAccu-Chek Simplicity
CHARACTERISTICPre-market NotificationK014167K993829
CHARACTERISTICMarketed byPolymedica CorporationRoche Diagnostics
CHARACTERISTICType of MeterPortable, battery operated, blood glucose metersame
CHARACTERISTICGlucose Measurement Technology (test strip)Glucose oxidase chemistry; colorimetric, reflectance detection technologysame
CHARACTERISTICIntended UseQuantitative determination of glucose in blood
home use, self test blood glucose monitoring by diabeticssame
CHARACTERISTICReferenceWhole blood referencedPlasma calibrated
CHARACTERISTICSample TypeCapillary whole bloodsame
CHARACTERISTICSample ApplicationApply blood to test stripsame
CHARACTERISTICHematocrit range35%-55%30%-60%
CHARACTERISTICControl Solution(s)Normal control solution, aqueous-based polymer emulsionNormal control solution, aqueous buffered solution
CHARACTERISTICOperating temperature range59 - 95F (15 - 35C)50 - 104F (10 to 40C)
CHARACTERISTICOperating humidity rangeLess than 80%same
CHARACTERISTICDimensions9.8 cm x 5 cm x 1.9 cm10 cm x 5.5c m x 1.7 cm
CHARACTERISTICWeight2.1 ounces with battery2.03 ounces without battery
CHARACTERISTICDisplayLiquid Crystal displaysame
CHARACTERISTICResults PresentationLiquid Crystal displaysame
CHARACTERISTICMemory Capabilities250 tests with time and date30 test results with time and date
CHARACTERISTICTest StartTurn on meter, insert strip, then application of blood samplesame
CHARACTERISTICLiberty™ SystemAccu-Chek Simplicity
Test Time20-30 seconds25 to 30 seconds
Power SourceSingle 3-volt lithium battery2 lithium batteries Duracell
D11/3N or
4 button batteries Varta: V13G
Ucar: A76 Panasonic LR44,
Toshiba G13
Battery Life1 year of routine usagesame
Meter coding procedureEnter lot-specific code number
from test strip bottle into meterCode chip provided with each
carton of test strips
Measurement Range30-500 mg/dL (1.6 - 27 mmol/L)10-600 mg/dL
Qualified Test StripDevice-specific test stripsame
Qualified Control SolutionOne glucose control solutionsame
Accuracy Check DeviceMeter automatically self-
calibrates when new strip is
insertedsame
Test strip storage conditions15-30C (59-86F)36 to 86F (2 to 30C)
Quality control procedureTests should be run with control
solutions whenever new vial of
test strips is opened or an
unusual blood test result is
obtainedsame
Labeling instructions regarding
response to unusual resultsRun a quality control test, if the
result is outside the acceptable
QC range, contact customer
service. If results are within the
acceptable range, review proper
testing procedure and repeat
blood glucose test with a new
test stripsame
Labeling instructions regarding
expected resultsThe normal fasting adult blood
glucose range for a non-diabetic
is 70 - 105 mg/dL. One to two
hours after meals, normal blood
glucose levels should be less
than 140 mg/dL. Physician will
determine range that is
appropriate for the patientssame
Warnings and precautionsFor in vitro diagnostic usesame
Reagent stability16 months24 months
Liberty™ SystemAccu-Chek Simplicity
CHARACTERISTIC
Reagent compositionTest strips:Test strips:
min at time of
manufacture
0.016 mg Chromogen
2.3 IU Glucose oxidase,
1.0 IU Peroxidaseqty/cm2
(minimum at time of manufacture)
Glucose-dye-
0.4 IU
oxidoreductase
Bis-(2-hydroxyethyl)-
(4-hydroxaminocyclohexa-
2,5-dienylidene)-
ammonium chloride
19.3 ug
2,18-Phospho-
328 ug
molybdic acid
0.3 l mg
Stabilizer
4.4 mg
Nonreactive substances
Control Solution:Control solution:
0.2% sodium benzoate
10% hydrophilic synthotic
polymer
0.1% Ponceau red
0.1% glucoseGlucose
Oxypyrion
Germall
Phosphate Buffer Solution

1000 1000

and the comments of the comments of

:

buslazioal Chazaoteristics

:

:

2

:

:

3

4

The non-clinical and clinical studies carried out on the Liberty™ System and the The non-clinical and clinical Simplicity) demonstrate that the system is substantially
predicate device (Accu-Chek Simplicity) demonstrate that the intended use. predicate device (Accu-Chek Simplicity) demonstaller in its intended use.
equivalent to the predicate device and is safe and effective for its intended use.

SE Comparison Table, Performance Characteristics
CHARACTERISTICLiberty™ SystemAccu-Chek Simplicity
Laboratory methodYellow Springs Instrument
(YSI), HemoCueYSI
Capillary blood studyN = 116 patients
Linear regression:
Y = 0.930
Correlation coefficient = 0.941
Range = 35 - 470 mg/dLN = 116 patients
Linear regression:
Y = 1.02
Correlation coefficient = 0.939
Range = 74 - 500 mg/dL
Consumer study:
Studies conducted comparing
patient capillary results with those
of a whole blood glucose
laboratory reference methodN = 116 different patients
linear regression results
y = 0.872
Correlation coefficient = 0.921
Range = 28 to 390 mg/dLN = 116 different patients linear
regression results
y = 1.02
Correlation coefficient = 0.939
Range = 74 to 500 mg/dL
Precision
Within-run precision
(N=20 per level)Control solution

Medium
Mean 163 mg/dl
sd 11,3
CV 99 % of the 2 lots are in "A"
region | Blood
Range 35 to 450 mg/dl
R=0.996

93 % is in "A" region |

Table Performance Characteristics on a

5

Image /page/5/Picture/1 description: The image is a black and white logo for the U.S. Department of Health & Human Services. The logo features a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. Inside the circle is an abstract symbol that resembles an eagle or bird in flight, composed of three stylized lines or strokes.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

FEB 1 9 2002

Ms. Patricia Collins Director, Corporate QA PolyMedica Pharmaceuticals, USA., Inc. 11 State Street Woburn, MA 01801

Re: K014167

K014167
Trade/Device Name: Liberty™ Blood Glucose System, Liberty™ Blood Glucose Meter, Liberty - Diood Glucose Strips, Liberty ™ Control Solution Regulation Number: 21 CFR 862.1345; 21 CFR 862.1660 Regulation Name: Glucose test system; Quality Control Materials Regulatory Class: Class II; Class II.; Class I Product Code: NBW; CGA; JJX Dated: December 12, 2001 Received: December 19, 2001

Dear Ms. Collins:

We have reviewed your Section 510(k) premarket notification of intent to market the device We have reviewed your Section 910(tr) premained in the the indications felerenced above and nave decembers and are and and and one marketed in interstate for use stated in the enclosate) to regarly manatinent from the Medical Device Amendments, or to commerce prior to May 28, 1970, the characted in accordance with the Federal Food, Drug, devices that have been recassified in accordance with a premarket approval application (PMA).
and Cosmetic Act (Act) that do not require approval of a previsions of the Act. and Cosmetic Act (Act) that do not require subject to the general controls provisions of the Act. The You may, therefore, market the device, seeject of the more of registration, listing of general controls provisions of the free labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controlls) or class III (PMA), in If your device is classified (secure) into existing major regulations affecting your device can
may be subject to such additional controls. Existing major may be subject to such addressions, Title 21, Parts 800 to 898. In addition, FDA may be found in the Code of Poderal Regarming your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean Please be advised that FDA s issualled of a built other requirements of the Act
that FDA has made a determination that your device complies with other mast that FDA has made a determination administered by other Federal agencies. You must or any Federal statures and regulations damind.co. by not limited to: registration and listing (21)
comply with all the Act's requirements, including, but not limited to: reg comply with an the Act s requirements, mercessed wantics requirements as set
CFR Part 807); labeling (21 CFR Part 801); good manufacturing plactically, the electronic CFK Part 807), labeling (21 CFR Part 800); good maxam (20); and if applicable, the electronic
forth in the quality systems (QS) regulation (21 CFR Part 81 CFR 1000 1050 form in the quality systems (Sections 531-542 of the Act); 21 CFR 1000-1050.

6

Page 2 -

This letter will allow you to begin marketing your device as described in your 510(k) prematket This letter will anow you to begin marketing your device of your device to a legally marketed notification. The FDA Inding of Substantal equivalities or your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (2) CFR Part 801 and If you desire specific advice for your do rooms. Includes contact the Office of Compliance at additionally 809.10 for in Vido diaguostic as nother promotion and advertising of your device, (301) 594-4588. Additionally, for questions on as pressed on Are, please note the regulation please contact the Office or Compliation at (30 tr / 01 TFR 807.97). Other general entitled, "Misbranding by telefence to premation in the Act may be obtained from the Division of Small
information on your responsibilities under the Act may be obtained on t information on your responsionnes and its toll-free number (800) 638-2041 or
Manufacturers International and Consumer Assistance at its toll-free demanain html" Manufacturers International and Consumer Prostouries and Consumers of the Marial".
(301) 443-6597 or at its internet address "http://www.fda.gov/cdrb/dsma/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 Radiological Health

Enclosure

7

STATEMENT OF INDICATIONS FOR USE D.

Applicant:Polymedica Pharmaceuticals Inc
510(k) Number (if known):K014167
Device Name:Liberty™ Blood Glucose System, Liberty™ Blood Glucose
Meter, Liberty™ Blood Glucose Strips, Liberty™ Control
Solution

Indications For Use:

Liberty™ Blood Glucose System:

Diberty™ Blood Glucose System is intended for the quantitative The Elocty - Diood Classes th capillary whole blood: Testing is done outside the body (in vitro diagnostic use). It is indicated for use at home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.

Liberty™ Blood Glucose Meter:

Liberty™ Blood Glucose Meter is intended for use with Liberty™ Blood The Elberty - Brood quantitative measurement of glucose in fresh capillary whole blood. Testing is done outside the body (in vitro diagnostic use). It is indicated for use at home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.

Jean
Silom Coffe
(Division Sign-Off)
Division of Clinical Laboni De
510(k) Nurnber 17014107

(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)

Over-the-Counter Use OR

(Optional Format 1-2-96)

8

Page 2 of 2

Liberty™ Blood Glucose Strips:

Liberty™ Blood Glucose Strips are intended for the quantitative measurement of glucose in fresh capillary whole blood when used with the Liberty™ Blood Glucose Meter. Testing is done outside the body (in vitro diagnostic use). It is indicated for use at home by persons with diabetes as an aid to monitor the effectiveness of diabetes control.

Liberty™ Control Solution:

Liberty™ Control Solution is an aqueous glucose solution for use with the Liberty™ Blood Glucose System. It is used as a quality control check to verify the accuracy of the blood glucose test result. The Liberty™ Control Solution is intended for use in the validation of the performance of the Blood Glucose System by providing a test solution with a known range of glucose. A control test that falls within the acceptable range indicates the user's technique is appropriate and the test strip and meter are functioning properly.

Image /page/8/Picture/5 description: The image shows a signature above the text "ision Sign-Off", "vision of Clinica", and "510(k) Number". The number "KC14167" is written next to "510(k) Number". The signature appears to be "Han Coope".

(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)

Over-the-Counter Use V OR

(Optional Format 1-2-96)