K Number
K123805
Device Name
E-Z CHEK BLOOD LEAK TEST STRIPS
Date Cleared
2013-03-20

(99 days)

Product Code
Regulation Number
876.5820
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Reprocessing Products Corporation (RPC) E-Z Chek® Blood Leak Test Strips are designed to indicate the presence or absence of blood in dialysate during the hemodialysis procedure. The test strips will measure equal to 0 mg HGB/dL and 0.25 mg HGB/dL in dialysate. The Reprocessing Product Corporation (RPC) E-Z Chek® Blood Leak Test Strips are indicated for detecting the presence or absence of blood in dialysate during hemodialysis treatments.
Device Description
Device is semi-quantitative, reagent test strip comprised of a pad impregnated with chemicals which change color upon contact with blood in dialysate. The pad is attached to a plastic strip for handling.
More Information

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Not Found

No
The device description and performance summary indicate a simple chemical reaction-based test strip with no mention of AI or ML.

No
The device is designed to detect the presence of blood in dialysate during hemodialysis, which is a diagnostic function rather than a therapeutic one. It does not treat or prevent any medical condition.

No

The device is designed to indicate the presence or absence of blood in dialysate, which is a test performed on the equipment (dialysis machine) rather than on a patient. It assesses the performance of the machine's filtering capabilities indirectly, not a patient's medical condition. Therefore, it is not a diagnostic device for a patient.

No

The device description explicitly states it is a "reagent test strip comprised of a pad impregnated with chemicals which change color upon contact with blood in dialysate" and is "attached to a plastic strip for handling." This describes a physical, chemical-based test strip, not a software-only device.

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

Here's why:

  • Intended Use: The intended use explicitly states that the device is "designed to indicate the presence or absence of blood in dialysate during the hemodialysis procedure." This involves testing a sample (dialysate) taken from a patient's treatment process to provide information about the patient's condition (presence of blood leak).
  • Device Description: The device is a "reagent test strip comprised of a pad impregnated with chemicals which change color upon contact with blood in dialysate." This describes a chemical reaction used to detect a substance in a biological sample (or a sample related to a biological process).
  • Performance Studies: The performance studies describe evaluating the device's ability to detect different concentrations of hemoglobin (blood) in dialysate. This is a typical evaluation for an IVD.

The definition of an In Vitro Diagnostic (IVD) device generally includes reagents, instruments, and systems intended for use in the diagnosis of disease or other conditions, including a determination of the state of health, in order to cure, mitigate, treat, or prevent disease or its sequelae. This device fits within this definition as it is used to detect a potential issue (blood leak) during a medical procedure (hemodialysis) which could impact the patient's health.

N/A

Intended Use / Indications for Use

The Reprocessing Products Corporation (RPC) E-Z Chek® Blood Leak Test Strips are designed to indicate the presence or absence of blood in dialysate during the hemodialysis procedure. The test strips will measure equal to 0 mg HGB/dL and 0.25 mg HGB/dL in dialysate.

The Reprocessing Product Corporation (RPC) E-Z Chek® Blood Leak Test Strips are indicated for detecting the presence or absence of blood in dialysate during hemodialysis treatments.

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

FJD

Device Description

Device is semi-quantitative, reagent test strip comprised of a pad impregnated with chemicals which change color upon contact with blood in dialysate. The pad is attached to a plastic strip for handling.

Mentions image processing

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Mentions AI, DNN, or ML

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Input Imaging Modality

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Anatomical Site

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Indicated Patient Age Range

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Intended User / Care Setting

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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)

The data confirm the product consistently generates color change which meets the color block for the reference solution concentration. Reference solutions were used to evaluate performance between 0 mg HGB/dL and 0.25 mg HGB/dL Bicarbonate/Acetate dialysate used for hemodialysis treatment. These data demonstrate appropriate performance for use in hemodialysis dialysate used in treatment.

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

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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.

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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.

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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

§ 876.5820 Hemodialysis system and accessories.

(a)
Identification. A hemodialysis system and accessories is a device that is used as an artificial kidney system for the treatment of patients with renal failure or toxemic conditions and that consists of an extracorporeal blood system, a conventional dialyzer, a dialysate delivery system, and accessories. Blood from a patient flows through the tubing of the extracorporeal blood system and accessories to the blood compartment of the dialyzer, then returns through further tubing of the extracorporeal blood system to the patient. The dialyzer has two compartments that are separated by a semipermeable membrane. While the blood is in the blood compartment, undesirable substances in the blood pass through the semipermeable membrane into the dialysate in the dialysate compartment. The dialysate delivery system controls and monitors the dialysate circulating through the dialysate compartment of the dialyzer.(1) The extracorporeal blood system and accessories consists of tubing, pumps, pressure monitors, air foam or bubble detectors, and alarms to keep blood moving safely from the blood access device and accessories for hemodialysis (§ 876.5540) to the blood compartment of the dialyzer and back to the patient.
(2) The conventional dialyzer allows a transfer of water and solutes between the blood and the dialysate through the semipermeable membrane. The semipermeable membrane of the conventional dialyzer has a sufficiently low permeability to water that an ultrafiltration controller is not required to prevent excessive loss of water from the patient's blood. This conventional dialyzer does not include hemodialyzers with the disposable inserts (Kiil type) (§ 876.5830) or dialyzers of high permeability (§ 876.5860).
(3) The dialysate delivery system consists of mechanisms that monitor and control the temperature, conductivity, flow rate, and pressure of the dialysate and circulates dialysate through the dialysate compartment of the dialyzer. The dialysate delivery system includes the dialysate concentrate for hemodialysis (liquid or powder) and alarms to indicate abnormal dialysate conditions. This dialysate delivery system does not include the sorbent regenerated dialysate delivery system for hemodialysis (§ 876.5600), the dialysate delivery system of the peritoneal dialysis system and accessories (§ 876.5630), or the controlled dialysate delivery system of the high permeability hemodialysis system § 876.5860).
(4) Remote accessories to the hemodialysis system include the unpowered dialysis chair without a scale, the powered dialysis chair without a scale, the dialyzer holder set, dialysis tie gun and ties, and hemodialysis start/stop tray.
(b)
Classification. (1) Class II (performance standards) for hemodialysis systems and all accessories directly associated with the extracorporeal blood system and the dialysate delivery system.(2) Class I for other accessories of the hemodialysis system remote from the extracorporeal blood system and the dialysate delivery system, such as the unpowered dialysis chair, hemodialysis start/stop tray, dialyzer holder set, and dialysis tie gun and ties. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 876.9.

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510(k) SUMMARY

MAR 20 2013

Page 1 of 2

Prepared:November 30, 2012
Submitter:Reprocessing Products Corporation (RPC)
Address:1643 W. Modern Court
Tucson, AZ 85705
Phone:520-888-5551
Fax:(Fax) 520-888-5557
Contact:Michael Honstein, Chief Operating Officer
Device Trade Name:E-Z Chek® Blood Leak Test Strips K100-
0114
Common or Usual Name:Blood Leak Test Strips
Device Classification Name:Strip, Dialysate, Hemodialysis Water,
Blood Leak indicator
Product Code:FJD
Class:II
Regulation Number:875.5665, 876.5820
Substantial Equivalence:The Reprocessing Products Corporation
(RPC) E-Z Chek® Blood Leak Test Strips
are substantially equivalent to the Serim®
Blood Leak Test Strips.
Device Description:Device is semi-quantitative, reagent test
strip comprised of a pad impregnated with
chemicals which change color upon contact
with blood in dialysate. The pad is attached
to a plastic strip for handling.
Intended Use:The Reprocessing Products Corporation
(RPC) E-Z Chek® Blood Leak Test Strips
are designed to indicate the presence or
absence of blood in dialysate during the
hemodialysis procedure. The test strips will
measure equal to 0 mg HGB/dL and 0.25
mg HGB/dL in dialysate.
Technological Characteristics:The detection is based on the
pseudoperoxidative activity of hemoglobin
and myoglobin, which catalyze the
oxidation of an indicator by an organic
hydroperoxide producing a color change
consistent with the color blocks provided in
the labeling.
Performance:The data confirm the product consistently
generates color change which meets the
color block for the reference solution
concentration. Reference solutions were
used to evaluate performance between 0
mg HGB/dL and 0.25 mg HGB/dL
Bicarbonate/Acetate dialysate used for
hemodialysis treatment. These data
demonstrate appropriate performance for
use in hemodialysis dialysate used in
treatment.
Conclusion:The Reprocessing Products Corporation
(RPC) E-Z Chek® Blood Leak Test Strips
have the same intended use as the predicate
device. Both test strips are designed to
detect the presence or absence of blood in
dialysate during hemodialysis treatments.
The Reprocessing Products Corporation
(RPC) E-Z Chek® Blood Leak Test Strips
has no characteristics which raise new
types of safety and effectiveness questions.
The Reprocessing Products Corporation
(RPC) E-Z Chek® Blood Leak Test Strips
can be used to detect the presence or
absence of blood in dialysate during
hemodialysis treatment.

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Traditional 510k Premarket Notification E-Z Chek® Blood Leak Test Strips 22805

age

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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized symbol resembling an abstract caduceus or a representation of human services, featuring three overlapping shapes that suggest movement or progress.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

March 20, 2013

Reprocessing Products Corporation % Mr. Ted Williams Quality Assurance/Regulatory Affairs Director P.O. Box 35849 TUCSON AZ 85740

Re: K123805

Trade/Device Name: E-Z Chek® Blood Leak Test Strips (K100-0114) Regulation Number: 21 CFR& 876.5820 Regulation Name: Hemodialysis system and accessories Regulatory Class: II Product Code: FJD Dated: January 29, 2013 Received: February 7, 2013

Dear Mr. Williams:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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.

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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); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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/ReportaProblem/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/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Herbert P.Lerner -S

for Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Traditional 510k Premarket Notification E-Z Chek® Blood Leak Test Strips

Page 1 of 1

Statement of Indications for Use: 4.

510k Number (if known): K123805

E-Z Chek® Blood Leak (K100-0114) Device Name:

Indications for Use: The Reprocessing Product Corporation (RPC) E-Z Chek® Blood Leak Test Strips are indicated for detecting the presence or absence of blood in dialysate during hemodialysis treatments.

Prescription Use X AND/OR Over the Counter Use __________________________________________________________________________________________________________________________________________________ (Part 21 CFR 801 Subpart D) (21CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) . • '

Concurrence of CDRH, Office of Device Evaluation (ODE)

Herbert Lerner -S

dve. Gastro-Renal, and