K Number
K080125
Device Name
APOLOWAKO T-CHO, HDL-C, TG AND ANALYZER, MODELS 993-23501, 999-23601, 995-23701 AND 993-25201
Date Cleared
2008-07-18

(183 days)

Product Code
Regulation Number
862.1475
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The APOLOWAKO T-CHO is for the quantitative determination on the APOLOWAKO analyzer of total cholesterol in whole blood. The APOLOWAKO HDL-C is for the quantitative determination on the APOLOWAKO analyzer of HDL cholesterol in whole blood. The APOLOWAKO TG is for the quantitative determination on the APOLOWAKO analyzer of triglycerides in whole blood. In conjunction with the above values, the APOLOWAKO analyzer also calculates LDL cholesterol for triglyceride values up to 400 mg/dL and T-CHO/HDL-C ratio. APOLOWAKO Analyzer is a discrete photometric chemistry analyzer for clinical use in both central laboratories and in point of care sites. The device is intended to duplicate manual analytical procedures by automatically performing various steps such as pipetting, mixing and measuring color intensity. This device is intended for use in conjunction with certain materials to measure a variety of analytes of clinical interest in whole blood samples. The measurements of total cholesterol, HDL cholesterol, triglycerides, and LDL cholesterol (by calculation for triglyceride values up to 400 mg/dL) when used in conjunction with other biochemical markers and coronary risk factors, is useful in the prediction of CHD/CVD risk and the assessment of CHD/CVD severity.
Device Description
The APOLOWAKO analyzer is a fully-integrated POC test system that can perform up to six analytical tests per individual sample. The analyzer automatically separates plasma from whole blood for testing. Once the plasma has been separated, it is transferred to a cell on a measurement disk where the chemical reactions take place. The analyzer uses liquid reagents which are packaged into kits. Each kit contains 2 reagent units. Each unit is composed of two enzyme color reagents and a lyophilized calibrator. All of the reagents have a reagent information tag applied to the back of each bottle which controls the reagent parameters and conditions such as, calibration, reagent quantity, shelf-life, and lot number. The instrument contains an automated liquid dispenser, temperature controlled reagent carrousel, analysis compartment, and sample holder. The instrument is designed to automatically and constantly monitor the reagents, dispensing system, measurement disk, and measurement process to ensure that no erroneous results are shown. The APOLOWAKO's lipid panel will include, total cholesterol, HDL cholesterol, LDL cholesterol (by calculation), and triglycerides in tubed venous whole blood. The test system is designed for professional use and consists of a small table top instrument (31 cm wide x 47.5 cm high x 56 cm deep, weight: 25 kg).
More Information

Not Found

No
The description focuses on automated photometric analysis and standard chemical reaction measurements, with no mention of AI or ML algorithms for data processing or interpretation.

No
This device is an in vitro diagnostic (IVD) device used for quantitative determination of cholesterol and triglycerides in whole blood, which helps in predicting and assessing CHD/CVD risk. It is not designed to directly treat or prevent a disease, but rather to provide diagnostic information.

Yes

The device quantitatively measures cholesterol and triglyceride levels in whole blood, which are used in the prediction and assessment of cardiovascular disease risk and severity. This indicates its role in providing information for diagnosis.

No

The device description clearly outlines a physical instrument (analyzer) with automated components, liquid reagents, and a measurement disk, indicating it is a hardware device, not software-only.

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

Here's why:

  • Intended Use: The intended use explicitly states the quantitative determination of analytes (total cholesterol, HDL cholesterol, triglycerides) in whole blood. This is a classic definition of an in vitro diagnostic test, as it involves analyzing a biological sample outside of the body to provide information about a patient's health.
  • Device Description: The description details a system that performs chemical reactions on a biological sample (plasma separated from whole blood) using reagents to measure analytes. This process is characteristic of an IVD.
  • Clinical Use: The device is intended for clinical use in both central laboratories and point-of-care sites, further indicating its role in diagnosing or monitoring health conditions.
  • Performance Studies: The document describes performance studies evaluating imprecision, linearity, interfering substances, and method comparison to FDA cleared comparison methods. These are standard evaluations for IVD devices to demonstrate their accuracy and reliability for clinical use.
  • Predicate Devices: The mention of predicate devices (CHOLESTECH LDX) which are known IVD devices, strongly suggests that the APOLOWAKO system is also an IVD.

Therefore, based on the provided information, the APOLOWAKO T-CHO, HDL-C, TG, and the APOLOWAKO Analyzer system are clearly intended and function as In Vitro Diagnostic devices.

N/A

Intended Use / Indications for Use

The APOLOWAKO T-CHO is for the quantitative determination on the APOLOWAKO analyzer of total cholesterol in whole blood. The APOLOWAKO HDL-C is for the quantitative determination on the APOLOWAKO analyzer of HDL cholesterol in whole blood. The APOLOWAKO TG is for the quantitative determination on the APOLOWAKO analyzer of triglycerides in whole blood. In conjunction with the above values, the APOLOWAKO analyzer also calculates LDL cholesterol for triglyceride values up to 400 mg/dL and T-CHO/HDL-C ratio.

APOLOWAKO Analyzer is a discrete photometric chemistry analyzer for clinical use in both central laboratories and in point of care sites. The device is intended to duplicate manual analytical procedures by automatically performing various steps such as pipetting, mixing and measuring color intensity. This device is intended for use in conjunction with certain materials to measure a variety of analytes of clinical interest in whole blood samples.

The measurements of total cholesterol, HDL cholesterol, triglycerides, and LDL cholesterol (by calculation for triglyceride values up to 400 mg/dL) when used in conjunction with other biochemical markers and coronary risk factors, is useful in the prediction of CHD/CVD risk and the assessment of CHD/CVD severity.

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

CGO, CDT, LBS, JJE

Device Description

The APOLOWAKO analyzer is a fully-integrated POC test system that can perform up to six analytical tests per individual sample. The analyzer automatically separates plasma from whole blood for testing. Once the plasma has been separated, it is transferred to a cell on a measurement disk where the chemical reactions take place. The analyzer uses liquid reagents which are packaged into kits. Each kit contains 2 reagent units. Each unit is composed of two enzyme color reagents and a lyophilized calibrator. All of the reagents have a reagent information tag applied to the back of each bottle which controls the reagent parameters and conditions such as, calibration, reagent quantity, shelf-life, and lot number. The instrument contains an automated liquid dispenser, temperature controlled reagent carrousel, analysis compartment, and sample holder. The instrument is designed to automatically and constantly monitor the reagents, dispensing system, measurement disk, and measurement process to ensure that no erroneous results are shown. The APOLOWAKO's lipid panel will include, total cholesterol, HDL cholesterol, LDL cholesterol (by calculation), and triglycerides in tubed venous whole blood. The test system is designed for professional use and consists of a small table top instrument (31 cm wide x 47.5 cm high x 56 cm deep, weight: 25 kg).

Mentions image processing

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Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

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Intended User / Care Setting

Professional use, point-of-care, clinical use in both central laboratories and in point of care sites.

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

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

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

Non-clinical Data: Evaluations were performed for within-day imprecision, between-day imprecision, linearity, and interfering substances.
Triglyceride: Within-day imprecision (low- 45 mg/dL, intermediate- 139 mg/dL, and high- 1209 mg/dL) ranged from 0.5 % CV to 2.9 % CV. Between-day imprecision (in duplicate over 10 days) ranged 0.9 % CV to 1.8 % CV. Results from linearity studies demonstrated that the triglyceride is linear throughout the reportable range. Interference testing showed triglyceride assay is not affected by high levels of hemoglobin, bilirubin (conjugated or unconjugated) or free glycerol.
Total Cholesterol: Within-day imprecision (low- 122 mg/dL, intermediate- 187 mg/dL, and high- 764 mg/dL) ranged from 0.5 % CV to 1.2 % CV. Between-day imprecision (in duplicate over 10 days) ranged 0.6 % CV to 1.7 % CV. Results from linearity studies demonstrated that the total cholesterol is linear throughout the reportable range. Interference testing showed that the total cholesterol is not affected by high levels of hemoglobin, bilirubin (conjugated or unconjugated), triglycerides, ascorbic acid, EDAT-2Na, or heparin sodium.
HDL-C: Within-day imprecision (low-30.8 mg/dL, intermediate- 51.1 mg/dL, and high- 95.2 mg/dL) ranged from 0.5 % CV to 1.6 % CV. Between assay imprecision (in duplicate over 10 days) ranged 0.5 % CV to 1.6 % CV. Results from linearity studies demonstrated that the HDL-C assay is linear throughout the reportable range. Interference testing showed that the HDL-C is not affected by high levels of hemoglobin, bilirubin (conjugated or unconjugated), triglycerides, ascorbic acid, EDAT-2Na, or heparin sodium.

Clinical Data: The method comparison study shows substantial equivalence to FDA cleared comparison methods for total cholesterol, triglycerides and HDL-cholesterol. For each analyte, 388 (384 for HDL-cholesterol; 4 samples out of the detectable range) broadly distributed samples showed statistically significant correlation with the reference method with slopes approaching 1.0 and y-intercepts approaching zero. APOLOWAKO results were collected under rigorous conditions sufficient to meet the requirements for CLIA Waiver. The results show correlation coefficients of 0.945 or better for each assay.

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

Not Found

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.

K954778, K946067

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

§ 862.1475 Lipoprotein test system.

(a)
Identification. A lipoprotein test system is a device intended to measure lipoprotein in serum and plasma. Lipoprotein measurements are used in the diagnosis and treatment of lipid disorders (such as diabetes mellitus), atherosclerosis, and various liver and renal diseases.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 862.9.

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KOS012>

Wako Wako Diagnostics

JUL 1 8 2008

SECTION 9

510(k) SUMMARY

This summary of 510(k) safety and effectiveness information is bcing submitted in accordance with the requirements of SMDA 1990 and 21 CFR 807.92.

The assigned 510(k) number is K080125.

Wako Diagnostics 807.92 (a)(1): Name:

Address: 665 Clyde Avenue, Suite B Mountain Vicw, CA 94043 Phone: (650) 210-9153 FAX: (650) 210-9170 Contact: Peter Panfili, Ph.D.

807.92 (a)(2): Device name- trade name and common name, and classification

Trade Name:

APOLOWAKO Lipid Panel*, composed of; APOLOWAKO T-CHO APOLOWAKO HDL-C APOLOWAKO TG APOLOWAKO Analyzer and accessories

  • APOLOWAKO Lipid Panel is a generic name for the above three reagents for lipids determination in whole

Common Name:

Test system for individual reporting of:

  • total cholesterol
  • HDL cholesterol -
  • triglyccrides -
  • LDL cholesterol (by Friedewald calculation) -
  • -Discrete photometric chemistry analyzer for clinical use

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Image /page/1/Picture/0 description: The image shows the logo for Wako Diagnostics. The word "Wako" appears twice, once in a black box on the left and again in black text on a white background to the right. The word "Diagnostics" appears to the right of the second "Wako".

Classification:

Total cholesterol: §21.862.1175 HDL cholesterol: §21.862.1475 Triglycerides: $21.862.1705 LDL cholesterol: §21.862.1475 (by calculation) Discrete photometric chemistry analyzer for clinical use: 821.862.2160

807.92 (a)(3): Identification of the legally marketed predicate device

CHOLESTECH LDX, Cholestech Corporation, Hayward, CA cleared under K954778 and K946067 for lipids.

807.92 (a)(4): Device Description

The APOLOWAKO analyzer is a fully-integrated POC test system that can perform up to six analytical tests per individual sample. The analyzer automatically separates plasma from whole blood for testing. Once the plasma has been separated, it is transferred to a cell on a measurement disk where the chemical reactions take place. The analyzer uses liquid reagents which are packaged into kits. Each kit contains 2 reagent units. Each unit is composed of two enzyme color reagents and a lyophilized calibrator. All of the reagents have a reagent information tag applied to the back of each bottle which controls the reagent parameters and conditions such as, calibration, reagent quantity, shelf-life, and lot number. The instrument contains an automated liquid dispenser, temperature controlled reagent carrousel, analysis compartment, and sample holder. The instrument is designed to automatically and constantly monitor the reagents, dispensing system, measurement disk, and measurement process to ensure that no erroneous results are shown. The APOLOWAKO's lipid panel will include, total cholesterol, HDL cholesterol, LDL cholesterol (by calculation), and triglycerides in tubed venous whole blood. The test system is designed for professional use and consists of a small table top instrument (31 cm wide x 47.5 cm high x 56 cm deep, weight: 25 kg).

807.92 (a)(5): Intended Use

The APOLOWAKO Lipid Panel is for the quantitative determination of total cholesterol. HDL cholesterol and triglycerides in whole blood and also calculates and gives results for LDL cholesterol and the T-CHO/HDL-C ratio.

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Image /page/2/Picture/0 description: The image shows the logo for Wako Diagnostics. The word "Wako" is written in white on a black rectangle on the left side of the image. To the right of the rectangle, the words "Wako Diagnostics" are written in black.

807.92 (a)(6): Technological Similarities and Differences to the Predicate

Predicate Device (Cholestech LDX)
CHARACTERISTICAPOLOWAKO AnalyzerCholestech LDX System
Intended UseThe APOLOWAKO Lipid
Panel is used for the in vitro
quantitative determination of
total cholesterol, HDL
cholesterol, LDL cholesterol
(by calculation), triglycerides
in whole blood and the T-
CHO/HDL-C ratio.The Cholestech LDX System
is used for the quantitative
determination of total
cholesterol, HDL (high-
density lipoprotein)
cholesterol and triglycerides
glucose in whole blood. A
TC/HDL (total
cholesterol/HDL cholesterol
ratio and estimated values for
LDL (low density
lipoprotein) and non-HDL
cholesterol are calculated by
the Cholestech LDX.
Indications for UseThe measurement of total
cholesterol, HDL cholesterol,
LDL cholesterol, and
triglycerides when used in
conjunction with other
biochemical markers and
coronary risk factors, is
useful in the prediction of
CHD/CVD risk and the
assessment of CHD/CVD
severity.Lipoprotein measurements
are used in the diagnosis and
treatment of lipid disorders
such as diabetes mellitus,
atherosclerosis, and various
liver and renal diseases.
SampleWhole bloodWhole blood
Sample PreparationVenous whole blood sampleFinger stick or venous whole
blood sample
CalibrationCalibration is required at the
time the reagent is opened
and lasts for 28 days or until
expiration date.No calibration is performed
by the user.
MethodologyColorimetric, enzyme-basedColorimetric
Reagent FormatLiquidDry
Testing EnvironmentProfessional use, point-of-
careProfessional use, point-of-
care
Reportable
rangeT-CHO: 25-330 mg/dL
HDL-C: 8.0-100 mg/dL
TG: 30-625 mg/dL
LDL-C by calculationT-CHO: 100 to 500 mg/dL
HDL-C: 15-100 mg/dL
TG: 45-650 mg/dL
LDL-C by calculation
PrecisionT-CHO: Total imprecision less than 2.0% CV across a range of 133 mg/dL to 788 mg/dL (mean values)
HDL-C: Total imprecision less than 2.0% CV across a range of 38.8 mg/dL to 100.3 mg/dL (mean values)
TG: Total imprecision less than 2.0% across a range of 90 mg/dL to 1178 mg/dL (mean values)T-CHO: Total imprecision less than 4.0% across a range of 161 mg/dL to 244 mg/dL (mean values)
HDL-C: Total imprecision less than 6.5% CV across a range of 29 mg/dL to 46 mg/dL (mean values)
TG: Total imprecision less than 3.2% across a range of 121 mg/dL to 276 mg/dL (mean values)
LinearityAssay linear throughout reportable rangeAssay linear throughout reportable range
Interfering
SubstancesNo interference from high levels of bilirubin (conjugated and unconjugated), hemoglobin, EDTA-2Na, heparin sodium and ascorbic acid.
No interference from triglycerides on T-CHO and HDL-C measurements.There are 23 substances including hemoglobin, bilirubin and uric acid that did not interfere with the assay. Free glycerol does affect Cholestech TG test but it does not affect APOLOWAKO TG.

Similarities / Differences between the APOLOWAKO Lipid Panel and Established Predicate Device (Cholestech LDX)

3

807.92 (b)(1): Brief Description of Non-clinical Data

Evaluations were performed for within-day imprecision, between-day imprecision, linearity, and interfering substances. Those resulting data are summarized below.

Triglyceride

Within-day imprecision, when evaluated at three levels of triglyceride (low- 45 mg/dL, intermediate- 139 mg/dL, and high- 1209 mg/dL), ranged from 0.5 % CV to 2.9 % CV. Between-day imprecision, when evaluated in duplicate over 10 days, ranged 0.9 % CV to 1.8 % CV.

Results from linearity studies demonstrated that the triglyceride is linear throughout the reportable range.

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Wako Diagnostics Wako

Results from an interference testing showed triglyceride assay is not affected by high levels of hemoglobin, bilirubin (conjugated or unconjugated) or free glycerol.

Total Cholestcrol

Within-day imprecision, when evaluated at three levels of total cholesterol (low- 122 mg/dL, intermediate- 187 mg/dL, and high- 764 mg/dL), ranged from 0.5 % CV to 1.2 % CV. Between-day imprecision, when evaluated in duplicate over 10 days, ranged 0.6 % CV to 1.7 % CV.

Results from linearity studies demonstrated that the total cholesterol is linear throughout the reportable range.

Results from an interference testing showed that the total cholesterol is not affected by high levels of hemoglobin, bilirubin (conjugated or unconjugated), triglycerides, ascorbic acid, EDAT-2Na, or heparin sodium.

HDL-C

Within-day imprecision, when cvaluated at three levels of HDL-C (low-30.8 mg/dL, intermediate- 51.1 mg/dL, and high- 95.2 mg/dL), ranged from 0.5 % CV to 1.6 % CV. Between assay imprecision, when evaluated in duplicate over 10 days, ranged 0.5 % CV to 1.6 % CV.

Results from linearity studies demonstrated that the HDL-C assay is linear throughout the reportable range.

Results from an interference testing showed that the HDL-C is not affected by high levels of hemoglobin, bilirubin (conjugated or unconjugated), triglycerides, ascorbic acid, EDAT-2Na, or heparin sodium.

807.92 (b)(2): Brief Description of Clinical Data

The method comparison study shows substantial equivalence to FDA cleared comparison methods for total cholesterol, triglycerides and HDLcholesterol. For each analyte. 388 (384 for HDL-cholesterol; 4 samples out of the detectable range) broadly distributed samples showed statistically significant correlation with the reference method with slopes approaching 1.0 and y-intercepts approaching zero. APOLOWAKO results were collected under rigorous conditions sufficient to meet the requirements for CLIA Waiver. The results show correlation coefficients of 0.945 or better for each assay.

807.92 (b)(3): Conclusions from Non-clinical and Clinical Testing

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Image /page/5/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized depiction of an eagle or bird-like figure with three curved lines forming its body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the bird symbol.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

JUL 1 8 2008

Wako Chemicals USA, Inc. c/o Peter Panfili, Ph.D. 665 Clyde Avenue, Suite B Mountain View, CA 94043

K080125 Re:

Trade/Device Name: APOLOWAKO T-CHO, APOLOWAKO HDL-C, APOLOWAKO TG and APOLOWAKO Analyzer and accessories Regulation Number: 21 CFR 862.1175 Regulation Name: Cholesterol (total) test system Regulatory Class: Class I Product Code: CGO, CDT, LBS and JJE Dated: June 24, 2008 Received: June 30, 2008

Dear Dr. Panfili:

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 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 Parts 801 and 809); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820).

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Page 2 -

This letter will allow you to 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.

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) 276-0490. 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 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 at http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Jean M. Cooper, M.S., D.V.M.

Jean M. Cooper, M.S., D.V.M. Director Division of Chemistry and Toxicology Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

Enclosure

7

Indication for Use

510(k) Number (if known): K080125

Device Name:

APOLOWAKO T-CHO APOLOWAKO HDL-C APOLOWAKO TG APOLOWAKO Analyzer and accessories

Intended Use

The APOLOWAKO T-CHO is for the quantitative determination on the APOLOWAKO analyzer of total cholesterol in whole blood. The APOLOWAKO HDL-C is for the quantitative determination on the APOLOWAKO analyzer of HDL cholesterol in whole The APOLOWAKO TG is for the quantitative determination on the blood. APOLOWAKO analyzer of triglycerides in whole blood. In conjunction with the above values, the APOLOWAKO analyzer also calculates LDL cholesterol for triglyceride values up to 400 mg/dL and T-CHO/HDL-C ratio.

APOLOWAKO Analyzer is a discrete photometric chemistry analyzer for clinical use in both central laboratories and in point of care sites. The device is intended to duplicate manual analytical procedures by automatically performing various steps such as pipetting, mixing and measuring color intensity. This device is intended for use in conjunction with certain materials to measure a variety of analytes of clinical interest in whole blood samples.

Indications for Use

The measurements of total cholesterol, HDL cholesterol, triglycerides, and LDL cholesterol (by calculation for triglyceride values up to 400 mg/dL) when used in conjunction with other biochemical markers and coronary risk factors, is useful in the prediction of CHD/CVD risk and the assessment of CHD/CVD severity.

| Prescription Use
(21 CFR Part 801 Subpart D) | X | And/Or | Over the Counter Use
(21 CFR Part 801 Subpart C) |

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(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)

Carol Benson

Division Sign-Off

Office of In Vitro Diagnostic Device

Evaluation and Safety

510(k) K080125