(126 days)
The STA Satellite™ Automated Multi-Parametric AnalyzerSatellite® Automated Multi-Parametric Analyzer is a fully automatic clinical instrument indicated and intended for the performance of tests on human plasmas, the results of which aid in the diagnosis of coagulation abnormalities or in monitoring anticoagulant therapy.
The STA Satellite® Automated Multi-Parametric Analyzer is designed as a fully automatic bench-top system. Samples and test reagents are loaded into the instrument where sample handling, reagent delivery, analysis, and reporting of results are performed automatically. A central processing unit controls instrument functions such as, management of patient results, quality control, system supervision, support for instrument maintenance, and work load optimization. The STA Satellite® is the bench-top version of the company's STA-R®, legally marketed predicate device.
The instrument utilizes Diagnostica Stago reagents in addition to open adaptation of other currently available reagents. Barcoding of test reagents, calibrators, and controls facilitate their use on the system and permits reagent management simple. Manual entry of reagent information enables the use of non-barcoded reagents.
The instrument performs multiple test methodologies in random access as selected by the user. These include clotting time or clot-based tests (i.e. Chronometricchronometric) measurements and photometric assays (at specific wave lengths) on plasma samples. The principle of the chronometric method consists in measuring the variation of the oscillation amplitude of the ball (in the cuvette). A decrease in oscillation amplitude corresponds to an increase in the viscosity of the media (i.e. ., coagulation). The principle of the photometric measurements on the instrument is based on measured absorbance (also referred to as Optical Density, or OD) of monochromatic light of predetermined wavelength passing through the cuvette as a (clotting) reaction takes place.
The provided text describes a 510(k) summary for the STA Satellite® Automated Multi-Parametric Analyzer, a modified version of the STA-R® device, intended for in vitro coagulation studies.
Here's an analysis of the acceptance criteria and the study that proves the device meets those criteria, based only on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
| Acceptance Criteria Category | Specific Criteria (Implicitly Derived) | Reported Device Performance |
|---|---|---|
| Correlation | Correlation data between STA Satellite® and STA-R® were within acceptance criteria for all assays and all sites. | Achieved for all assays and all sites. |
| Statistical Difference | No significant or clinically significant difference between results from STA Satellite® and STA-R® at different sites. | Achieved. |
| Clinical Equivalence | The device should be as safe and effective as the predicate devices. | Demonstrated by performance data and risk assessment, leading to a finding of substantial equivalence. |
| Safety and Effectiveness | No new questions of safety or effectiveness should be raised by differences in architecture, software, or chronometric viscosity detection. | Differences noted do not raise new questions of safety or effectiveness. |
2. Sample size used for the test set and the data provenance:
- Test Set Sample Size: The document states that "Test samples were analyzed in duplicate on the STA -Satellite and the STA-R." However, the number of test samples or the total number of subjects from which these samples were derived is not specified in the provided text.
- Data Provenance:
- Country of Origin: The validation study was performed at "an internal site and two external sites." The direct country of origin for these sites is not explicitly stated. However, the submitter, Diagnostica Stago, Inc., is based in Parsippany, New Jersey, USA. The predicate device manufacturer, Diagnostica Stago SAS, is likely based in France given the "CE Marked" status of the device and its commercialization in France since September 2004. It's plausible that one or more sites were in the USA, and potentially one in France, but this is an inference, not a direct statement.
- Retrospective or Prospective: The text does not explicitly state whether the study was retrospective or prospective. The phrasing "Test samples were analyzed" suggests a prospective collection and analysis for the validation study.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
This information is not provided in the text. The study focuses on method comparison between two instruments rather than an expert-adjudicated ground truth for patient diagnoses.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
This information is not applicable and therefore not provided, as the study is a method comparison and does not involve adjudication of expert interpretations for a ground truth.
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:
- MRMC Study: No, an MRMC comparative effectiveness study was not done. This device is an automated instrument for performing coagulation tests, not an AI or imaging diagnostic tool that would involve human readers interpreting results with or without AI assistance.
- Effect Size: Therefore, there is no information on the effect size of human reader improvement with AI assistance.
6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
Yes, the study described is a standalone performance study of the instrument itself. The device is an "Automated Multi-Parametric Analyzer," meaning it performs the analysis automatically. The "Performance Data" section describes a comparison of the STA Satellite® instrument's results to those of the STA-R® predicate device, indicating the algorithm/instrument's performance in isolation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
The "ground truth" in this study is the results obtained from the predicate device, STA-R®. The study's objective was to demonstrate substantial equivalence by showing that the STA Satellite® produces statistically similar results to the legally marketed STA-R®. This is a method comparison study, where the established method (predicate device) serves as the reference.
8. The sample size for the training set:
This information is not provided in the text. The document describes a validation study comparing the new device to a predicate, not the internal development or "training" of a machine learning algorithm. If there was any internal development or calibration, the details are not included here.
9. How the ground truth for the training set was established:
This information is not provided as there is no mention of a training set or ground truth in the context of training for this medical device's performance validation. The study focuses on direct comparison to a predicate device's measured results.
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Attachment - 6
510(k) SUMMARY
DEC 1 2 2008
Diagnost
Submitter's Name, Address, Telephone Number, Contact Person and Date Prepared:
Umberto V. Parrotta Diagnostica Stago, Inc. Five Century Drive Parsippany, New Jersey 07054
Phone: (973) -631-1200, x-2044 Facsimile: (973) -695-0095
Contact Person: Umberto V. Parrotta
Date Prepared: August 06, 2008
Name of Modified Device and Name/Address of Sponsor:
STA Satellite®
Diagnostica Stago, Inc. Five Century Drive Parsippany, New Jersey 07054
Common or Usual Name:
- IVD Coagulation Device/Instrument. ●
- . Automated and Semi-Automated Hematology Device.
- Multi-Parametric Analyzer ●
Classification Name:
System, Multipurpose for In Vitro Coagulation Studies
Predicate Devices:
- Diagnostica Stago SAS' STA-R® Automated Multi-Parametric Analyzer . (K983460).
- Sigma Diagnostic Inc.'s AMAX Destiny Coagulation Analyzer (K021162). .
File: DSI-Satellite-Attachment-06v4-510(k)Summary.doc
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CONFIDENTIAL
Attachment - 6
510(k) SUMMARY
Predicate Device Manufacturer:
Diagnostica Stago SAS
Purpose of the Special 510(k) notice:
The STA Satellite® is a modification to the company's own legally marketed device, STA-R®.
Indication/Intended Use:
The STA Satellite™ Automated Multi-Parametric AnalyzerSatellite® Automated Multi-Parametric Analyzer is a fully automatic clinical instrument indicated and intended for the performance of tests on human plasmas, the results of which aid in the diagnosis of coagulation abnormalities or in monitoring anticoagulant therapy.
Technological Characteristics:
The STA Satellite® Automated Multi-Parametric Analyzer is designed as a fully automatic bench-top system. Samples and test reagents are loaded into the instrument where sample handling, reagent delivery, analysis, and reporting of results are performed automatically. A central processing unit controls instrument functions such as, management of patient results, quality control, system supervision, support for instrument maintenance, and work load optimization. The STA Satellite® is the bench-top version of the company's STA-R®, legally marketed predicate device.
The instrument utilizes Diagnostica Stago reagents in addition to open adaptation of other currently available reagents. Barcoding of test reagents, calibrators, and controls facilitate their use on the system and permits reagent management simple. Manual entry of reagent information enables the use of non-barcoded reagents.
The instrument performs multiple test methodologies in random access as selected by the user. These include clotting time or clot-based tests (i.e. Chronometricchronometric) measurements and photometric assays (at specific wave lengths) on plasma samples. The principle of the chronometric method consists in measuring the variation of the oscillation amplitude of the ball (in the cuvette). A decrease in oscillation amplitude corresponds to an increase in the viscosity of the media (i.e. ., coagulation). The principle of the photometric measurements on the instrument is based on measured absorbance (also referred
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CONFIDENTIAL
Attachment - 6
510(k) SUMMARY
to as Optical Density, or OD) of monochromatic light of predetermined wavelength passing through the cuvette as a (clotting) reaction takes place.
Performance Data:
Comparison of the device and predicate device performance characteristics was conducted during the performance validation study. Validation of the STA -Satellite® with the STA-R® predicate device was performed at an internal site and two external sites.
Test samples were analyzed in duplicate on the STA -Satellite and the STA-R. Results were analyzed by standard statistical methods (mean, standard deviation, 95% confidence intervals, correlation between instruments and comparison to acceptance criteria).
Correlation data between the STA -Satellite and the STA-R were within the acceptance criteria for all assays and all sites (see Table below for assays performed). There was no significant difference or clinically significant difference between the results from the instruments between the sites and instruments.
In addition, the STA Satellite® is CE Marked and has been in commerce in France since September 2004. There have been no adverse performance-related events or analogous complaints resulting in recalls with regards to its design during this time that would raise questions of safety and effectiveness.
In conclusion, performance validation study comparison results between the STA Satellite® and the STA-R device instrument and predicate device indicate statistically similar results. , Analysis of which demonstrates substantial equivalence.
Substantial Equivalence:
The STA Satellite® has the same intended use and similar indications, principles of operation, and technological characteristics as the STA-R® and the AMAX predicate devices. The differences in the external architecture, software, and chronometric viscosity detection do not raise any new questions of safety or effectiveness. Performance data and risk assessment demonstrate that the STA Satellite® is as safe and effective as STA-R@the predicate devices. Thus, the STA Satellite® is substantially equivalent to its predicate devices.
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DEPARTMENT OF HEALTH & HUMAN SERVICES
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Public Health Service
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
Diagnostica Stago, Inc. C/o Umberto V. Parrotta Five Century Drive Parsippany, New Jersey 07054
DEC 1 2 2008
Re: K082248
Trade/Device Name: STA Satellite® Automated Multi-Parametric Analyzer Regulation Number: 21 CFR 864.5425 Regulation Name: Multipurpose System for In Vitro Coagulation Studies Regulatory Class: Class II Product Code: JPA Dated: October 03, 2008 Received: October 06, 2008
Dear Mr. Parrotta:
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. Isting 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 (OS) 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 FDA finding of substantial equivalence of your device to a legally marketed
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Page 2 - Mr. Parrotta
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), 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" (21CFR 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,
Marian Chan, PhD
Acting Division 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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CONFIDENTIAL Attachment - 2A
Indications for Use Form
510(k) Number (if known): KO822248
Device Name:
Satellite™ Automated Multi-Parametric Analyzer
Indications for Use:
The Satellite™ is a fully automatic clinical instrument designed for the performance of tests on human plasmas, the results of which aid in the diagnosis of coagulation abnormalities or in monitoring anticoagulant therapy.
(PLEASE DO NOT WRITE BELOW THIS LINE -- CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Division Sign-Off
Office of In Vitro Diagnostic Device
Office of In Vitro Diamostic Device Evaluation and Safely
Prescription Use (Per 21 C.F.R. 801.109)
510(k) OR K082246 Over-The-Counter Use
(Optional Format 1-2-96)
File: DSI-Satellite-Attachment-2A-IndicationsForUseStatementForm.doc
§ 864.5425 Multipurpose system for in vitro coagulation studies.
(a)
Identification. A multipurpose system for in vitro coagulation studies is a device consisting of one automated or semiautomated instrument and its associated reagents and controls. The system is used to perform a series of coagulation studies and coagulation factor assays.(b)
Classification. Class II (special controls). A control intended for use with a multipurpose system for in vitro coagulation studies is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 864.9.