K Number
K021698
Device Name
MY ALLERGY TEST
Date Cleared
2002-09-19

(120 days)

Product Code
Regulation Number
862.1675
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The MyAllergyTest™ is for the collection and transport of a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing. The MyAllergyTest™ is intended for use with the MyAllergyTest™ System. The MyAllergyTest™ is intended for home use by the lay consumer (Over-the-Counter).
Device Description
MyAllergyTest™ is a Sample Collection Kit containing the materials necessary to collect and mail a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing.
More Information

No
The 510(k) summary describes a sample collection kit and its associated system for transporting blood samples for laboratory testing. There is no mention of AI, ML, or any computational analysis of the sample or results within the device itself. The studies described focus on sample stability, mailing, and consumer usability of the collection kit.

No
The device is described as a sample collection kit for diagnostic testing, not for treating any condition.

Yes
The device is described as being for "collection and transport of a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing," which is a diagnostic purpose. While the device itself is a collection kit, its intended use is fundamentally tied to obtaining a diagnostic result.

No

The device description explicitly states it is a "Sample Collection Kit containing the materials necessary to collect and mail a capillary blood sample," indicating it is a physical kit with hardware components, not software only.

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

Here's why:

  • Intended Use: The intended use explicitly states it's for the "collection and transport of a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing." This testing is performed in vitro (outside the body) on a biological sample to provide information about a person's health status (in this case, their allergic profile).
  • Device Description: The device is described as a "Sample Collection Kit containing the materials necessary to collect and mail a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing." This further reinforces its role in the process of in vitro diagnostic testing.
  • Predicate Device: The predicate device listed (K993787; Appraise-Cardio Sample Collection Kit) is also a sample collection kit intended for use with a laboratory test, which is a common type of IVD.

While the device itself is a sample collection kit and not the analytical instrument that performs the IgE testing, it is an essential component of the overall in vitro diagnostic process. The collection and transport of the sample are critical steps that directly impact the accuracy and reliability of the subsequent in vitro test results. Therefore, the sample collection kit is considered an IVD device.

N/A

Intended Use / Indications for Use

The MyAllergyTest™ is for the collection and transport of a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing. The MyAllergyTest™ is intended for use with the MyAllergyTest™ System (K020387). The MyAllergyTest™ is intended for home use by the lay consumer.

Product codes

JKA

Device Description

MyAllergyTest™ is a Sample Collection Kit containing the materials necessary to collect and mail a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing.

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 use by the lay consumer

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)

Stability Studies were performed to obtain assurance that the whole blood sample would still provide an accurate assessment of allergen specific IgE for the entire transport time indicated in the labeling (seven days). The results from these studies confirmed that the samples would be stable for the entire seven days.

Mailing Studies were performed to obtain assurance that the whole blood samples would still provide an accurate assessment of allergen specific IgE if sent by US Mail. The results from these studies confirmed that the samples would be stable when shipped using US Mail.

Consumer Studies were performed to obtain assurance that the general public would be able to obtain a blood sample by following the MyAllergyTest™ package insert. The results from these studies confirmed that the general public would be able to obtain a blood sample by following the MyAllergyTest™ package insert.

Consumer Comprehension Studies were performed to obtain assurance that the general public would be able to read and understand the MyAllergyTest™ package insert. The results from these studies confirmed that the general public would be able to read and understand the MyAllergyTest™ package insert.

Readability Studies were performed to assurance that the MyAllergyTest™ package was written at a 70 grade reading level. The results from the SMOG Readability Formula (NCCLS GP 14-A Labeling of Home-Use In Vitro Testing Products) confirmed that the MyAllergyTest™ package was written at a 7th grade reading level.

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

Not Found

Predicate Device(s)

K993787

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 862.1675 Blood specimen collection device.

(a)
Identification. A blood specimen collection device is a device intended for medical purposes to collect and to handle blood specimens and to separate serum from nonserum (cellular) components prior to further testing. This generic type device may include blood collection tubes, vials, systems, serum separators, blood collection trays, or vacuum sample tubes.(b)
Classification. Class II.

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5/14//2002
MyAllergy Test™
510(k) Premarket Submission
Page 11

7. 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS

This summary of safety and effectiveness is being submitted in accordance with the requirements of The Safety Medical Device Act of 1990 and 21 CFR Part 807.92

510(k) Number:K021698
SEP 1 9 2002
Date of Summary Preparation:May 14, 2002
Submitter:ImmuneTech Corporation
Contact Person:Vivianne Noetzel
Address:P.O. Box 9433
17394 Via Del Bravo
Rancho Santa Fe, CA 92067
Phone:858-756-8483
FAX:858-759-7492
Manufacturing Site:ImmuneTech Corporation
Address:888 Oak Grove, Suite 4
Menlo Park, CA 94025
Phone:650-470-7420
FAX:650-470-7423
Device Trade Name:MyAllergyTest™
Device Common Name:Blood Sample Collection Kit
Device Classification:Class II (21 CFR 862.1675)
Device Product Code:JKA
Performance Standards:None established (as a medical device) under Section 514.
Device Description:MyAllergyTest™ is a Sample Collection Kit containing the
materials necessary to collect and mail a capillary blood
sample to a clinical laboratory for allergen specific IgE
profile testing.
Intended UseThe MyAllergyTest™ is for the collection and transport of
a capillary blood sample to a clinical laboratory for
allergen specific IgE profile testing. The MyAllergyTest™
is intended for use with the MyAllergyTest™ System
(K020387). The MyAllergyTest™ is intended for home use
by the lay consumer.
Indication for UseThe MyAllergyTest™ is for the collection and transport of
a capillary blood sample to a clinical laboratory for
allergen specific IgE profile testing. The MyAllergyTest™
is intended for use with the MyAllergyTest™ System. The

1

MyAllergyTest™ is intended for home use by the lay conusmer.

Substantial Equivalence Claim to:

Appraise-Cardio Sample Collection Kit K993787.

Summary of Device Testing:

Stability Studies were performed to obtain assurance that the whole blood sample would still provide an accurate assessment of allergen specific IgE for the entire transport time indicated in the labeling (seven days). The results from these studies confirmed that the samples would be stable for the entire seven days.

Mailing Studies were performed to obtain assurance that the whole blood samples would still provide an accurate assessment of allergen specific IgE if sent by US Mail. The results from these studies confirmed that the samples would be stable when shipped using US Mail.

Consumer Studies were performed to obtain assurance that the general public would be able to obtain a blood sample by following the MyAllergyTest™ package insert. The results from these studies confirmed that the general public would be able to obtain a blood sample by following the MyAllergyTest™ package insert.

Consumer Comprehension Studies were performed to obtain assurance that the general public would be able to read and understand the MyAllergyTest™ package insert. The results from these studies confirmed that the general public would be able to read and understand the MyAllergyTest™ package insert.

Readability Studies were performed to assurance that the MyAllergyTest™ package was written at a 70 grade reading level. The results from the SMOG Readability Formula (NCCLS GP 14-A Labeling of Home-Use In Vitro Testing Products) confirmed that the MyAllergyTest™ package was written at a 7th grade reading level.

Conclusion:

These studies demonstrate the substantial equivalence of the MyAllergyTest™ to a currently marketed device that has been reviewed and cleared through the 510(k) notification process.

2

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around it. Inside the circle is a stylized image of an eagle with three human profiles incorporated into its design.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

SEP 1 9 2002

Ms. Vivianne Noetzel ImmuneTech Corporation P.O. Box 9433 Rancho Santa Fe, CA 92067

Re: K021698

Trade/Device Name: My Allergy Test™ Regulation Number: 21 CFR 862.1675 Regulation Name: Blood Specimen Collection Device Regulatory Class: Class II Product Code: JKA Dated: July 8, 2002 Received: August 23, 2002

Dear Ms. Noetzel:

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 (OS) 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 v 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 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

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5/14//2002

6. INDICATIONS FOR USE STATEMENT

K02 / 698 510(k) Number:

MyAllergyTest™ Device Name:

Indications for Use: The MyAllergyTest™ is for the collection and transport of a capillary blood sample to a clinical laboratory for allergen specific IgE profile testing. The MyAllergyTest™ is intended for use with the MyAllergyTest™ System. The MyAllergyTest™ is intended for home use by the lay consumer (Over-the-Counter).

Soushn S. Altare

(Division Sign-Off) Division of Clinical Laboratory Devices 510(k) Number_

(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)

Concurrence of CDHR, office of Device Evaluation (ODE)

Prescription Use

OR

Over-The-Counter Use