(48 days)
HemosIL Factor II Deficient Plasma is human plasma immunodepleted of factor II and intended for the in vitro diagnostic quantitative determination of factor II activity in citrated plasma, based on the prothrombin time (PT) assay, on IL Coagulation and ELECTRA Systems.
HemosIL Factor II Deficient Plasma is human plasma immunodepleted of factor II and intended for the in vitro diagnostic quantitative determination of factor II activity in citrated plasma, based on the prothrombin time (PT) assay, on IL Coagulation and ELECTRA Systems.
Abnormalities of the extrinsic pathway factors are determined by performing a modified prothrombin time (PT) test. Patient plasma is diluted and added to a plasma deficient in factor II. Correction of the clotting time of the deficient plasma is proportional to the concentration (% activity) of the factor II in the patient plasma, interpolated from a calibration curve.
The provided 510(k) summary for the HemosIL Factor II Deficient Plasma does not explicitly state acceptance criteria in the form of pre-defined thresholds that the device had to meet. Instead, the study demonstrates that the new device is "substantially equivalent" to predicate devices by showing comparable performance.
However, we can infer performance metrics that were deemed acceptable for substantial equivalence based on the presented data. The study primarily relies on method comparison and precision data.
Here's a breakdown of the information requested, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
As noted, explicit "acceptance criteria" are not given. The study aims to demonstrate substantial equivalence to predicate devices. We can infer that correlation coefficients (r) close to 1.0, slopes close to 1.0, and small intercepts compared to predicate devices, along with acceptable precision (%CV), were considered evidence of substantial equivalence.
| Performance Metric | Implied "Acceptance Range" (for substantial equivalence) | Reported Device Performance (Range Across Systems) |
|---|---|---|
| Method Comparison (vs. Predicate/Reference Device) | ||
| Correlation Coefficient (r) | Close to 1.0 (e.g., typically > 0.95 or 0.98 for strong correlation in equivalent devices) | 0.9855 to 0.9954 |
| Slope | Close to 1.0 (e.g., typically 0.95-1.05) | 1.0357 to 1.0603 |
| Intercept | Close to 0 (e.g., often within a small clinically acceptable range) | -4.6831 to 1.0196 |
| Within Run Precision (%CV) | Typically a low percentage, e.g., < 5% or < 10% depending on analyte and clinical context. | 2.3% to 6.2% |
| Between Run Precision (%CV) | Typically a low percentage, e.g., < 5% or < 10% depending on analyte and clinical context. | 2.0% to 6.4% |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size (Method Comparison): Approximately 60 citrated plasma samples for the in-house method comparison study. A separate clinical study used n=61 samples.
- Data Provenance:
- Country of Origin: Not explicitly stated, but the submission is from Massachusetts, USA. The studies are described as "in-house" and "clinical," suggesting they were conducted by the manufacturer or collaborators, likely within the US, but this is not definitively stated.
- Retrospective or Prospective: Not explicitly stated. The description "evaluating approximately 60 citrated plasma samples" and "clinical study" doesn't specify the collection method. However, for method comparison, samples are often either prospectively collected or selected from an existing bank that represents the intended use population.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Experts
- Ground Truth Establishment: For in-vitro diagnostic (IVD) devices like this, "ground truth" for method comparison and precision is established by the reference method (the predicate device) and by validated control materials, rather than by human expert consensus or pathology review.
- Number and Qualifications of Experts: Not applicable in the traditional sense for this type of IVD performance study. The "truth" is based on the performance of a legally marketed predicate device and well-characterized control materials.
4. Adjudication Method for the Test Set
- Adjudication Method: Not applicable. This is a quantitative IVD method comparison study where results are numerical and compared against a reference method, not a subjective interpretation requiring adjudication among experts.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and Effect Size
- MRMC Study: No, an MRMC comparative effectiveness study was not conducted. This type of study is typically relevant for diagnostic imaging where human readers interpret results. The HemosIL Factor II Deficient Plasma is an in-vitro diagnostic reagent designed for automated analyzers.
6. If a Standalone Study Was Done
- Standalone Study: Yes, the performance data presented is for the algorithm/device (HemosIL Factor II Deficient Plasma) operating on various IL Coagulation and ELECTRA systems. The "method comparison" directly compares the new device's performance against legally marketed predicate devices, demonstrating its standalone functionality in achieving comparable results. The precision studies also show its standalone performance.
7. The Type of Ground Truth Used
- Type of Ground Truth: The "ground truth" for assessment of the new device is based on the performance of the legally marketed predicate devices (Hemoliance Factor II Deficient Plasma and HemosIL Factor II Deficient Plasma predicate versions) and using known normal and abnormal control materials.
8. The Sample Size for the Training Set
- Training Set Sample Size: The document does not describe a "training set" in the context of machine learning or AI models. This device is a diagnostic reagent, and its development typically involves formulation optimization and analytical verification rather than algorithmic training on a dataset. Therefore, this concept is not directly applicable.
9. How the Ground Truth for the Training Set Was Established
- Ground Truth for Training Set: Not applicable, as there is no "training set" in the context of an AI/ML algorithm for this IVD device. The development of such a reagent involves analytical chemistry, reagent formulation, and stability studies, rather than training on a data set with an established ground truth.
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i< 050661
Section 3 HemosIL Factor II Deficient Plasma - 510(k) Summary (Summary of Safety and Effectiveness)
Submitted by:
Instrumentation Laboratory Co. 113 Hartwell Avenue Lexington, MA 02421 Phone: 781-861-4467 Fax: 781-861-4207
Contact Person:
Carol Marble, Regulatory Affairs Director Phone: 781-861-4467 / Fax: 781-861-4207
Summary Prepared:
March 14, 2005
Name of the Device:
HemosIL Factor II Deficient Plasma
Regulatory Information:
| Regulation Section: | Factor Deficiency Test (864.7290) |
|---|---|
| Classification: | Class II |
| Product Code: | GJT |
| Panel: | Hematology |
Identification of Predicate Device(s):
| K900133 | Hemoliance Factor II Deficient Plasma on ELECTRA Series Analyzers |
|---|---|
| K002400 | HemosIL Factor II Deficient Plasma* on ACL Family of Analyzers |
| *NOTE: FDA cleared as part of each ACL instrument 510(k): for | |
| example, the ACL Advance (K002400) |
Description of the Device/Intended Use(s):
HemosIL Factor II Deficient Plasma is human plasma immunodepleted of factor II and intended for the in vitro diagnostic quantitative determination of factor II activity in citrated plasma, based on the prothrombin time (PT) assay, on IL Coagulation and ELECTRA Systems.
Abnormalities of the extrinsic pathway factors are determined by performing a modified prothrombin time (PT) test. Patient plasma is diluted and added to a plasma deficient in factor II. Correction of the clotting time of the deficient plasma is proportional to the concentration (% activity) of the factor II in the patient plasma, interpolated from a calibration curve.
Statement of Technological Characteristics of the Device Compared to Predicate Device:
The new HemosIL Factor II Deficient Plasma is substantially equivalent to Hemoliance Factor II Deficient Plasma (on ELECTRA Series Analyzers) and HemosIL Factor II Deficient Plasma (on ACL Family of Analyzers) in performance, intended use and safety and effectiveness.
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Section 3 (Cont.) HemosIL Factor II Deficient Plasma - 510(k) Summary (Summary of Safety and Effectiveness)
Summary of Performance Data:
Method Comparison
In an in-house method comparison study evaluating approximately 60 citrated plasma samples, the correlation statistics for HemosIL Factor II Deficient Plasma versus the predicate devices are shown below:
| System | slope | intercept | r | Reference method |
|---|---|---|---|---|
| ACL 300 | 1.0357 | 1.0196 | 0.9921 | HemosIL Factor II Deficient Plasma |
| ACL 6000 | 1.0464 | -2.1396 | 0.9954 | HemosIL Factor II Deficient Plasma |
| ACL 9000 | 1.0458 | -1.6123 | 0.9953 | HemosIL Factor II Deficient Plasma |
| ACL TOP | 1.0582 | -4.6831 | 0.9855 | HemosIL Factor II Deficient Plasma |
| E1600C | 1.0603 | -0.2821 | 0.9917 | Hemoliance Factor II Deficient Plasma |
NOTE: HemosIL RecombiPlasTin was used as the PT reagent in testing.
In a separate clinical study (n=61), the following correlation statistics were obtained on an ACL Futura using a specific lot of PT reagent (RecombiPlasTin):
| System | slope | intercept | r | Reference method |
|---|---|---|---|---|
| ACL Futura | 1.0602 | -3.6113 | 0.9946 | HemosIL Factor II Deficient Plasma |
Within Run Precision
Within run and between run precision was assessed over multiple runs (n=80) on different instruments using a specific lot of PT reagent (RecombiPlasTin) and both normal and abnormal controls.
| Instrument | Control | Mean% Factor II | Within run%CV | Between Run%CV |
|---|---|---|---|---|
| ACL 9000 | Normal Control | 99.2 | 2.5 | 2.0 |
| Special Test Control Level 2 | 33.8 | 2.5 | 4.5 | |
| ACL Futura | Normal Control | 86.8 | 3.9 | 4.7 |
| Special Test Control Level 2 | 25.9 | 6.2 | 3.1 | |
| ACL TOP | Normal Control | 130.6 | 2.8 | 4.3 |
| Special Test Control Level 2 | 28.6 | 3.3 | 4.8 | |
| ELECTRA | Normal Control | 99.4 | 2.3 | 5.1 |
| 1600C | Special Test Control Level 2 | 33.3 | 2.8 | 6.4 |
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. Inside the circle is an abstract image of an eagle with three stripes representing its wings.
MAY - 2 2005
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
Ms. Carol Marble Regulatory Affairs Director Instrumentation Laboratory Co. 113 Hartwell Avenue Lexington, MA 02421
Re: K050661
Trade/Device Name: HemosIL Factor II Deficient Plasma Regulation Number: 21 CFR § 864.7290 Regulation Name: Factor Deficiency Test Regulatory Class: II Product Code: GJT ﺒﻲ Dated: March 14, 2005 Received: March 15, 2005
Dear Ms. Marble:
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 Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. 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 r read be act not a latermination 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); and good manufacturing practice OFF Part 820), as set forth in the quality systems (QS) regulation (21 CFR Part 820). This letter requirements us o begin marketing your device as described in your Section 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.
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Page 2 -
If you desire specific information about the application of labeling requirements to your device, or questions on the promotion and advertising of your device, please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (240) 276-0484. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Four may other games games garrers, 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/industry/support/index.html
Sincerely yours,
Robert Beckerh
Robert L. Becker, Jr., MD, Pa Director Division of Immunology and Hematology Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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Indications for Use Statement
510(k) Number (if known): Kp5066/
Device Name: HemosIL Factor II Deficient Plasma
Indications for Use:
HemosIL Factor II Deficient Plasma is human plasma immunodepleted of factor II and intended for the in vitro diagnostic quantitative determination of factor II activity in citrated plasma, based on the prothrombin time (PT) assay, on IL Coagulation and ELECTRA Systems.
Prescription Use (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use _ (21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of In Vitro Diagnostic Devices (OIVD)
Josephine Bautista
Division Sign Off
Office of In Vitro Diagnostic Device Evaluation and Safety
510(k) K050661
HemosIL Factor II Deficient Plasma 510(k)
§ 864.7290 Factor deficiency test.
(a)
Identification. A factor deficiency test is a device used to diagnose specific coagulation defects, to monitor certain types of therapy, to detect coagulation inhibitors, and to detect a carrier state (a person carrying both a recessive gene for a coagulation factor deficiency such as hemophilia and the corresponding normal gene).(b)
Classification. Class II (performance standards).