K Number
K073489
Date Cleared
2008-02-11

(61 days)

Product Code
Regulation Number
866.5510
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

System reagent for the quantitative determination of IgA immunoglobulins in human serum and plasma on OLYMPUS analyzers.
For in vitro diagnostic use.

Device Description

In this Olympus procedure:
When a sample is mixed with R1 buffer and R2 antiserum solution, human IgA reacts specifically with anti-human IgA antibodies to yield insoluble aggregates.
Immune complexes formed in solution scatter light in proportion to their size, shape and concentration.
Turbidimeters measure the reduction of incidence light due to reflection, absorption or scatter.
In the Olympus procedure, the decrease in intensity of light transmitted (increase in absorbance) through particles suspended in solution is as a result of complexes formed during the antigen-antibody reaction.

AI/ML Overview

Here's an analysis of the provided text regarding the acceptance criteria and study for the Olympus IgA Reagent (OSR6X171):

Acceptance Criteria and Device Performance

1. Table of Acceptance Criteria and Reported Device Performance

Performance CharacteristicAcceptance Criteria (Implied by Predicate)Reported Device Performance (Olympus IgA (OSR6X171) reagent)
Precision (Total CV%)
AU400/400e Sample 1As good as or better than 1.53%2.43%
AU400/400e Sample 2As good as or better than 1.63%2.52%
AU400/400e Sample 3As good as or better than 1.26%2.95%
AU600/640/640e Sample 1As good as or better than 1.38%3.39%
AU600/640/640e Sample 2As good as or better than 1.08%3.85%
AU600/640/640e Sample 3As good as or better than 1.81%4.01%
AU2700/5400 Sample 1As good as or better than 2.64%1.50%
AU2700/5400 Sample 2As good as or better than 2.05%1.91%
AU2700/5400 Sample 3As good as or better than 3.29%1.83%
Assay Range10 to 700 mg/dL10 to 700 mg/dL
LoQNot specified (or comparable to predicate)10 mg/dL
Method Comparison (Linear Regression)
InterceptComparable to 1.3 mg/dL15.1 mg/dL
SlopeComparable to 0.9570.923
R^2Comparable to 0.990.999
NComparable to 94111
RangeComparable to 54-660 mg/dL38-672 mg/dL
Interfering Substances
Bilirubin (AU400/400e)Interference < 2% up to 40 mg/dLInterference < 2% up to 40 mg/dL
Hemolysate (AU400/400e)Interference < 2% up to 500 mg/dLInterference < 1% up to 500 mg/dL
Lipemia (AU400/400e)Interference < 10% up to 600 mg/dLInterference < 10% up to 1000 mg/dL
RF (AU400/400e)Not specifiedInterference < 8% up to 600 IU/mL
Bilirubin (AU600/640/640e)Interference < 5% up to 40 mg/dLInterference < 3% up to 40 mg/dL
Hemolysate (AU600/640/640e)Interference < 2% up to 500 mg/dLInterference < 5% up to 500 mg/dL
Lipemia (AU600/640/640e)Interference < 7% up to 1000 mg/dLInterference < 6% up to 1000 mg/dL
RF (AU600/640/640e)Not specifiedInterference < 8% up to 600 IU/mL
Bilirubin (AU2700/5400)Interference < 5% up to 40 mg/dLInterference < 3% up to 40 mg/dL
Hemolysate (AU2700/5400)Interference < 3% up to 500 mg/dLInterference < 4% up to 500 mg/dL
Lipemia (AU2700/5400)Interference < 10% up to 1000 mg/dLInterference < 4% up to 1000 mg/dL
RF (AU2700/5400)Not specifiedInterference < 4% up to 600 IU/mL
Ascorbic AcidInterference < 2-3% up to 20 mg/dLNot tested
Prozone CapacityNo high dose effect up to 3,200 mg/dLNo high dose effect up to 10,000 mg/dL

Note: Acceptance criteria are inferred based on the performance of the predicate device, as the document states "The following Tables compare the new Olympus IgA (OSR6X171) reagent with the predicate devices..." implying that comparable performance to the predicate is the acceptance standard for substantial equivalence.

2. Sample Size Used for the Test Set and Data Provenance

  • Precision: The sample sizes for the precision studies are not explicitly stated, but "Sample 1," "Sample 2," and "Sample 3" for each instrument suggest multiple measurements were taken for each of these samples. The number of replicates per sample and the total number of samples tested are not provided.
  • Method Comparison (Linear Regression): N = 111 samples were used for the method comparison study.
  • Interfering Substances: The sample sizes for interference studies are not provided.
  • Prozone Capacity: The sample sizes for prozone capacity testing are not provided.
  • Data Provenance: The document does not explicitly state the country of origin of the data or whether it was retrospective or prospective. Given it's a 510(k) submission, it is typically based on prospective studies conducted in controlled laboratory settings for device validation.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

This document describes an in vitro diagnostic (IVD) reagent, not an AI/CADe device that uses expert-established ground truth from medical images. Therefore, this information is not applicable. For IVDs, the "ground truth" is typically established through reference methods or highly accurate comparative assays. In this case, the predicate device (Olympus IgA (OSR6X44) Reagent) served as the comparator for method comparison, and the "calibration traceability" to the International Reference Preparation CRM 470 (US designation RPPHS lot 91/0619) provides the ultimate "ground truth" for the quantitative measurements.

4. Adjudication Method for the Test Set

Not applicable, as this is an IVD reagent and not an AI/CADe device involving human expert adjudication.

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 is an IVD reagent, not an AI/CADe device, and does not involve human readers interpreting results.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done

The device is an IVD reagent that performs quantitative measurements on Olympus analyzers. Its performance is inherently standalone in the sense that the measurement results are generated by the instrument and reagent system without human interpretation for the determination of the IgA level itself. The physician then interprets these quantitative results in a clinical context. The performance characteristics described (precision, assay range, method comparison, interference, prozone capacity) all reflect the standalone performance of the reagent on the specified analyzers.

7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

For the quantitative determination of IgA, the "ground truth" is implicitly established by:

  • Traceability to an International Reference Preparation: The method is traceable to the International Reference Preparation CRM 470 (US designation RPPHS lot 91/0619). This serves as the primary reference standard for accurate IgA quantification.
  • Comparison to a Legally Marketed Predicate Device: The performance is compared against the previously approved Olympus IgA (OSR6X44) Reagent (K951055), which itself would have been validated against accepted reference methods and standards.

8. The Sample Size for the Training Set

Not applicable. This is an IVD reagent, not a machine learning or AI device that uses a "training set" in the conventional sense. The development of such a reagent involves chemical formulation and analytical validation, not algorithm training.

9. How the Ground Truth for the Training Set Was Established

Not applicable, as there is no "training set" for this type of device. The accuracy of the reagent is validated against established quantitative standards and predicate device performance.

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510(k) Summary

This summary of the 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: KOJ3489

1. Submitter name, address, contactOlympus America Inc.3500 Corporate ParkwayCenter Valley, PA 18034
U.S. Telephone: 469-230-0959U.S. Fax: 972-317-7861
Contact Person: Stephanie G. Donnelly
Date Prepared: December 10, 2007
2. Device nameProprietary Name: Olympus IgA Reagent (OSR6X171)
Common Name: IgA reagent
Classification Name: IgA, Antigen, Antiserum, Control
3. Predicate deviceReagent: Olympus (OSR6X44) IgA ReagentSubmitted K951055
4. Device descriptionIn this Olympus procedure: When a sample is mixed with R1 buffer and R2 antiserum solution, human IgA reacts specifically with anti-human IgA antibodies to yield insoluble aggregates.Immune complexes formed in solution scatter light in proportion to their size, shape and concentration.Turbidimeters measure the reduction of incidence light due to reflection, absorption or scatter.In the Olympus procedure, the decrease in intensity of light transmitted (increase in absorbance) through particles suspended in solution is as a result of complexes formed during the antigen-antibody reaction.
5. Intended useSystem reagent for the quantitative determination of IgA immunoglobulins in human serum and plasma on OLYMPUS analyzers.For in vitro diagnostic use.

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The following Tables compare the new Olympus IgA (OSR6X171)
reagent with the predicate devices outlined in point 3 above.

Similarities
ItemOlympus IgA (OSR6X171) reagentPredicate System
Intended UseSystem reagent for the quantitativedetermination of IgA immunoglobulins inhuman serum and plasma on OlympusanalyzersSystem reagent for the quantitativedetermination of IgA immunoglobulins inhuman serum on Olympus analyzers
MeasurementQuantitativeSame
Instrument RequiredOlympus AU400/400e, 600/640/640e and2700/5400Same
Reagent handlingReady for useSame
AssayMethodology/OperatingPrincipleImmunoturbidimetricSame
Reagent storage formLiquidOn --board storageSame
CalibratorOlympus Serum Protein Mulit-Calibrator(ODR3021)Same
Calibration TraceabilityThis method is traceable to the InternationalReference Preparation CRM 470 (USdesignation RPPHS lot 91/0619)Same
AntibodyGoat Anti-IgA antiserumSame
Expected Values66-433 mg/dLSame
Reagent On Board StabilityOpened reagents are stable for 90 dayswhen stored in the refrigeratedcompartment of the analyzer.Same
Differences
ItemOlympus IgA (OSR6X171) reagentPredicate System
Specimen TypeSerum, EDTA Plasma and Li-HeparinizedPlasmaSerum
Calibration Frequency90 days7 days
Performance Characteristics
ItemOlympus IgA (OSR6X171) reagentPredicate System
PrecisionAU400/400eAU400/400e
SampleTotal CV%SampleTotal CV%
12.4311.53
22.5221.63
32.9531.26
AU600/640/640eAU600
SampleTotal CV%SampleTotal CV%
13.3911.38
23.8521.08
34.0131.81
AU2700/5400AU640/640e
SampleTotal CV%SampleTotal CV%
11.5011.8
21.9121.3
31.83
AU2700/5400
SampleTotal CV%
12.64
22.05
33.29

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Assay Range10 to 700 mg/dL10 to 700 mg/dL
LoQ10 mg/dLNot specified
Method Comparison(Linear Regression)Intercept 15.1 mg/dLSlope 0.923R2 0.999N 111Range 38-672 mg/dLIntercept 1.3 mg/dLSlope 0.957R2 0.99N 94Range 54-660 mg/dL
Interfering SubstancesAU400/400eBilirubin: Interference less than 2% up to40 mg/dL BilirubinHemolysate: Interference less than 1% upto 500 mg/dL HemolysateLipemia: Interference less than 10% up to1000 mg/dL IntralipidRF: Interferences less than 8% up to 600IU/mLNot testedAU400/400eBilirubin: Interference less than 2% up to40 mg/dL BilirubinHemolysate: Interference less than 2%up to 500 mg/dL HemolysateLipemia: Interference less than 10% upto 600 mg/dL IntralipidNot SpecifiedAscorbic Acid: Interferences less than2% up to 20 mg/dL Ascorbate
AU600/640/640eBilirubin: Interference less than 3% up to40 mg/dL BilirubinHemolysate: Interference less than 5% upto 500 mg/dL HemolysateLipemia: Interference less than 6% up to1000 mg/dL IntralipidRF: Interferences less than 8% up to 600IU/mLNot testedAU600/640/640eBilirubin: Interference less than 5% up to40 mg/dL BilirubinHemolysate: Interference less than 2%up to 500 mg/dL HemolysateLipemia: Interference less than 7% up to1000 mg/dL IntralipidNot SpecifiedAscorbic Acid: Interferences less than2% up to 20 mg/dL Ascorbate
AU2700/5400Bilirubin: Interference less than 3% up to40 mg/dL BilirubinHemolysate: Interference less than 4% upto 500 mg/dL HemolysateLipemia: Interference less than 4% up to1000 mg/dL IntralipidRF: Interferences less than 4% up to 600IU/mLNot testedAU2700/5400Bilirubin: Interference less than 5% up to40 mg/dL BilirubinHemolysate: Interference less than 3%up to 500 mg/dL HemolysateLipemia: Interference less than 10% upto 1000 mg/dL IntralipidNot SpecifiedAscorbic Acid: Interferences less than3% up to 20 mg/dL Ascorbate
Prozone CapacityNo high dose effect at IgA concentrationsup to 10, 000 mg/dLNo high dose effect at IgAconcentrations up to 3,200 mg/dL

.


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Image /page/3/Picture/1 description: The image shows the logo for the Department of Health & Human Services (HHS). The logo consists of a stylized graphic of an eagle or bird-like figure with three curved lines representing its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular pattern around the graphic.

Public Health Service

FEB 11 2008

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

Olympus America, Inc. c/o Ms. Stephanie Donnelly Regulatory Affairs/Quality Assurance Manager Olympus Life Science Research Europa GmbH Lismeehan, O. Callaghan's Mills Co. Claire, Ireland.

Re: K073489

Trade/Device Name: Olympus IgA reagent Regulation Number: 21 CFR 866.5510 Regulation Name: Immunoglobulins A, G, M, D, E immunological test systems Regulatory Class: Class II Product Code: CFN Dated: December 11, 2007 Received: December 12, 2007

Dear Ms. Donnelly:

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). This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The

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Page 2 -

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 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) 276-0450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding postmarket surveillance, please contact CDRH's Office of Surveillance and Biometric's (OSB's) Division of Postmarket Surveillance at 240-276-3474. For questions regarding the reporting of device adverse events (Medical Device Reporting (MDR)), please contact the Division of Surveillance Systems at 240-276-3464. You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Robert H. Baker

Robert L. Becker, Jr., M.D., Ph.D. Director Division of Immunology and Hematology Devices Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

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Indication for Use

510(k) Number (if known): K073489

Device Name: The Olympus IgA reagent (OSR6X171).

Indication For Use: System reagent for the quantitative determination of IgA immunoglobulins in human serum and plasma on OLYMPUS analyzers.

The spectrum of abnormalities in serum immunoglobulin concentrations is broad. Abnormal concentrations range from a virtual absence of one or more of the three major classes of immunoglobulin (IgG, IgA, and IgM) to polyclonal increases in one or more immunoglobulins. Measurement of these immunoglobulins aids in the diagnosis of abnormal protein metabolism and the body's lack of ability to resist infectious agents.

For in vitro diagnostic use.

V Prescription Use (21 CFR Part 801 Subpart D) And/Or

Over the Counter Use (21 CFR Part 801 Subpart C)

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

Concurrence of CDRH, Office of In Vitro Diagnostic Device Evaluation and Safety (OIVD)

Maria M Chan

Division Sign-Off Office of In Vitro Diagnostic Device Evaluation and Safety

510(k) K073489

§ 866.5510 Immunoglobulins A, G, M, D, and E immunological test system.

(a)
Identification. An immunoglobulins A, G, M, D, and E immunological test system is a device that consists of the reagents used to measure by immunochemical techniques the immunoglobulins A, G, M, D, an E (serum antibodies) in serum. Measurement of these immunoglobulins aids in the diagnosis of abnormal protein metabolism and the body's lack of ability to resist infectious agents.(b)
Classification. Class II (performance standards).