K Number
K102164
Device Name
HEMOSIL PROTEIN S ACTIVITY ASSAY
Date Cleared
2011-03-17

(227 days)

Product Code
Regulation Number
864.7290
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on ACL TOP Family members.
Device Description
The HemosIL Protein S Activity assay determines the functional activity of free Protein S by measuring the degree of prolongation of prothrombin time in the presence of the human recombinant factor, phospholipids, calcium ions, and activated Protein C. The protein S activity is correlated with the prolongation of the clotting time of a Protein S deficient plasma to which a diluted sample has been added.
More Information

Not Found

No
The description focuses on a functional assay measuring clotting time and does not mention any AI/ML components or algorithms.

No
The device is an in vitro diagnostic (IVD) assay designed to aid in the diagnosis of a condition by quantitatively measuring a substance in plasma, rather than directly treating or preventing a disease.

Yes
The "Intended Use / Indications for Use" states that the device is "an aid in the diagnosis of hereditary and acquired Protein S deficiency". This explicitly indicates its diagnostic purpose.

No

The device is a laboratory assay that measures the functional activity of Protein S in plasma. It is used on specific laboratory instruments (ACL TOP Family members) and involves chemical reactions and measurement of clotting time. This is a reagent-based assay, not a software-only device.

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

Here's why:

  • Intended Use: The intended use explicitly states it's for the "quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency". This involves testing a sample taken from the human body (in vitro) to provide information for diagnosis.
  • Device Description: The description details how the assay works by measuring the prolongation of prothrombin time in the presence of various reagents and a diluted sample of plasma. This is a laboratory-based test performed on a biological sample.
  • Sample Type: The assay uses "human citrated plasma," which is a biological sample taken from a human.

These characteristics clearly align with the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on ACL TOP Family members.

Product codes

GGP

Device Description

The HemosIL Protein S Activity assay determines the functional activity of free Protein S by measuring the degree of prolongation of prothrombin time in the presence of the human recombinant factor, phospholipids, calcium ions, and activated Protein C. The protein S activity is correlated with the prolongation of the clotting time of a Protein S deficient plasma to which a diluted sample has been added.

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

Not Found

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

Precision Performance characteristics were assessed utilizing 3 lots of reagent on 3 representative members of the ACL TOP Family (ACL TOP, ACL TOP 500 CTS and ACL TOP 700). Precision was evaluated in accordance with CLSI EP05-A2-, for 20 days, with 2 runs per day and 2 replicates per run, for each sample level (n=80/ instrument/ lot).
Method Comparison - In-House: An in-house comparison study was performed in accordance with CLSI EPO9-A2; Method Comparison and Bias Estimation, 200 Edition, 2002, to compare the performance of HemoslL Protein S Activity versus the predicate device (HemoslL ProS) on representative ACL TOP Family members.
Method Comparison – Field Sites: Two field site studies were performed to compare the performance of the HemosIL Protein S Activity assay versus the predicate device (HemosIL ProS) on the ACL TOP.
Key Results: The test results demonstrate that the changes in kit composition and tissue factor type do not adversely affect the product's performance.

Key Metrics

ACL TOP Precision (Data from a representative lot):
Normal Control: Mean (% PS) 94.2, CV% (Within run) 2.5, CV% (Total) 4.9
Low Abnormal Control: Mean (% PS) 33.6, CV% (Within run) 3.8, CV% (Total) 7.1
High Abnormal Control: Mean (% PS) 19.3, CV% (Within run) 1.19 (SD), CV% (Total) 2.23 (SD)
Internal Control 1: Mean (% PS) 44.5, CV% (Within run) 2.9, CV% (Total) 6.2
Internal Control 2: Mean (% PS) 67.2, CV% (Within run) 1.7, CV% (Total) 4.7
High Plasma Sample: Mean (% PS) 128, CV% (Within run) 1.6, CV% (Total) 4.2

Predicate Device(s)

K053499

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

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Image /page/0/Picture/1 description: The image shows three logos side by side. The first logo is a circular design with horizontal lines, accompanied by the text "Werfen Group" underneath. The second logo is a geometric shape resembling a cube, and the third logo reads "Instrumental Laboratory" in a stacked format.

MAR 1 7 2011

510(k) Summary

(per 21 CFR 807.92)

781-861-4350

781-861-4207

July 28, 2010

jemery@ilww.com

HemosIL® Protein S Activity

l. Applicant Contact Information

Applicant:Instrumentation Laboratory Co.
Address:180 Hartwell Road
Bedford, MA 01730
Contact Person:Jacqueline Emery, BS EE

Phone Number: Fax Number: Email: Preparation Date:

Device Trade Name

II. Device Regulatory Information

Regulatory Section21 CFR 864.7290
ClassificationClass II
Common Name:Protein S Test
Classification Name:Factor Deficiency Test
Product Code:GGP
Panel:81 (hematology)

III. Identification of Legally Marketed Device

K053499

HemosIL® ProS

IV. Device Description

The HemosIL Protein S Activity assay determines the functional activity of free Protein S by measuring the degree of prolongation of prothrombin time in the presence of the human recombinant factor, phospholipids, calcium ions, and activated Protein C. The protein S activity is correlated with the prolongation of the clotting time of a Protein S deficient plasma to which a diluted sample has been added.

V. Device Indications/ Intended Use

Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on ACL TOP Family members.

1

HemosIL® Protein S Activity Assay

VI. Comparison of Technological Characteristics of the Device

Similarities

The HemosIL Protein S Activity Assay is Substantially Equivalent to its predicate, the HemosIL ProS Assay (K053499), in both intended use and performance:

TABLE 1:Table of Similarity and Differences
-----------------------------------------------
ItemPredicate DeviceNew Device
K#K053499TBD
Device NameHemosIL ProSHemosIL Protein S
Activity
ManufacturerInstrumentation Laboratory Co. (self)Same
Indications for UseAutomated coagulation functional assay
for the quantitative determination of
free Protein S in human citrated plasma
as an aid in the diagnosis of hereditary
and acquired Protein S deficiency, on
the ACL TOP® Family of analyzers.Same
Sample Typecitrated plasmaSame
Test PrincipleFunctional Clotting AssaySame
MethodologyThe test is based on the ability of
endogenous protein S as a cofactor of
activated protein C to prolong the
clotting time. Protein S levels in patient
plasma are measured automatically on
the ACL TOP® Family of analyzers.

The test determines the functional
activity of free protein S by measuring
the degree of prolongation of a
prothrombin time in the presence of
the recombinant tissue factor,
phospholipids, calcium ions, and
activated protein C.

The protein S activity is correlated with
the prolongation of the clotting time of
a Protein S deficient plasma to which
diluted sample has been added. | Same |
| Calibration | HemosIL Calibration plasma values are
assigned for Protein S Activity and used
for calibrating the standard curve. | Same |
| Item | Predicate Device | New Device |
| K# | K053499 | TBD |
| Device Name | HemosIL ProS | HemosIL Protein S
Activity |
| Kit Composition | | |
| - Protein S reagent | - Lyophilized preparation
containing recombinant tissue
factor, synthetic phospholipids,
activated protein C, Polybrene,
buffer, stabilizers &
preservatives.

  • Includes calcium ions.
  • Rabbit Tissue Factor | - Lyophilized
    preparation
    containing
    recombinant
    tissue factor,
    synthetic
    phospholipids,
    activated protein
    . C, Polybrene,
    buffer, stabilizers
    & preservatives.
  • Calcium is added
    separately to
    improve shelf life.
  • Human Tissue
    Factor |
    | - Calcium Reagent | - Calcium is included in the Protein
    S reagent vial. | - Calcium is
    included in a
    separate vial. |
    | - Protein S deficient
    plasma | - Lyophilized human plasma which
    has been artificially depleted of
    protein S. | - Same except for
    vial size. |
    | - Protein S control
    plasma | - Lyophilized human plasma
    containing a low level of protein S. | - Not sold with this
    product. |

2

TABLE 2: Table of Similarity and Differences (continued)

Differences

. . .

There are 2 main differences between the 2 products; the HemosIL Protein S Activity Assay, the subject of this submission, and its HemosIL ProS assay predicate: the applicant contains human tissue factor, whereas the predicate utilizes rabbit tissue factor.

In addition the HemosiL Protein S Activity assay kit composition has changed as compared to its predicate: the calcium ions required for the reaction, which were previously included in the predicate's Protein S reagent vial, are now offered as a separate component. The test results demonstrate that these changes do not adversely affect the product's performance.

3

VII. Summary of Performance Data

. Precision

Performance characteristics were assessed utilizing 3 lots of reagent on 3 representative members of the ACL TOP Family (ACL TOP, ACL TOP 500 CTS and ACL TOP 700). Precision was evaluated in accordance with CLSI EP05-A2-, for 20 days, with 2 runs per day and 2 replicates per run, for each sample level (n=80/ instrument/ lot). Data from a representative lot is included below:

ACL TOPMean (% PS)CV% (Within run)CV% (Total)
· Normal Control94.22.54.9
Low Abnormal Control33.63.87.1
High Abnormal Control19.31.19(SD)2.23 (SD)
Internal Control 144.52.96.2
Internal Control 267.21.74.7
High Plasma Sample1281.64.2
  • . Method Comparison - In-House
    An in-house comparison study was performed in accordance with CLSI EPO9-A2; Method Comparison and Bias Estimation, 200 Edition, 2002, to compare the performance of HemoslL Protein S Activity versus the predicate device (HemoslL ProS) on representative ACL TOP Family members with the following results:

TABLE 3: METHOD COMPARISON RESULTS IN-HOUSE

|
System | Canada Canada Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara Cara | 1
Slope | E & TE I RE IN MIN LA MINING BANK |
|------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ------------------------------------
| | 1
0.966 | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Achieves and color de control controlled and contraction of the contribution
0 000 |
| CI TOP SOO CTS | | BALL BROOM STATIST A

OAC
A AND A AND A Comen | 1975

44-46-140

CLSI EP5-A2: Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline, 2" edition.

4

Method Comparison – Field Sites .

Two field site studies were performed to compare the performance of the HemosIL Protein S Activity assay versus the predicate device (HemosIL ProS) on the ACL TOP with the following 1 results:

TABLE 4:METHOD COMPARISON RESULTS FIELD SITE
--------------------------------------------------

|
System | | Slope | -
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ |
|---------------|-------------------------------------------------------------------------------------------------------------------------------|-------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| ﻟ
44 1
| A A C
1 | 0000 | Address States
U OCC |
| 11 m
t | A 1999 199
Acres of the comments of the closed on the comments of the contributed to the courses
A ANNUAL AND AND AND A | 1 010 | 1
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ما تي مل هال |

VIII. Conclusion

Based on the device's similarity in intended use, technology characteristics and performance data, it is determined that the IL HemosIL Protein S Activity assay is substantially equivalent to its predicate, the HemosIL ProS assay.

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Food and Drug Administration 10903 New Hampshire Avenue Document Mail Center - WO66-0609 Silver Spring, MD 20993-0002

Instrumentation Laboratory Co. c/o Ms. Jacqueline Emery Regulatory Affairs Manager 180 Hartwell Rd. Bedford, MA 01730

MAR 1 7 2011

Re: K102164 Trade/Device Name: HemosIL® Protein S Activity Regulation Number: 21 CFR 864.7290 Regulation Name: Test Qualitative and Quantitative Factor Deficiency Regulatory Class: Class II Product Code: GGP Dated: March 4, 2011 Received: March 7, 2011

Dear Ms. Emery,

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 class II (Special Controls), 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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); and good manufacturing practice

6

Page 2 - Ms. Jacqueline Emery

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 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 Parts 801 and 809), please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportalProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

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 (301) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours,

Maria M. Khan

Maria M. Chan, 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

7

K102164 - HemosIL® Protein S Activity Assay

09/28/2010 Request for Additional Information-Response

Indications for Use Statement

102164 510(k) Number (if known):

Device Name: HemosIL Protein S Activity

Indications for Use:

Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on the ACL TOP Family of analyzers.

V Prescription Use _ . (Part 21 CFR 801 Subpart D)

AND/OR

Over-The-Counter Use (21 CFR 801 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)

Lenck

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

510(k) K102164

COMPANY CONFIDENTIAL