K Number
K170864
Device Name
VALIDATE D-Dimer Calibration Verification / Linearity Test Kit
Date Cleared
2017-06-21

(90 days)

Product Code
Regulation Number
864.5425
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit solutions are assayed quality control materials intended for in vitro diagnostic use in the quantitative determination verification verification and verification of reportable range for the following analyte: D-Dimer in a clinical laboratory personnel. The product is intended for use with quantitative assays on the indicated analyzers specified in the labeling.
Device Description
Each VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit contains one analyte set of D-Dimer in a human plasma base matrix. The kit includes a set containing five liquid levels, 3.0 mL each. The set is provided to establish the relationship between theoretical and actual performance of the included analyte D-Dimer. Material of human origin used in the manufacture of this test kit was tested at the donor level using FDA approved methods and was found to be non-reactive for HBsAG and to antibodies to HCV and HIV-1/2.
More Information

No
The summary describes a calibration verification and linearity test kit for D-Dimer, a standard in vitro diagnostic product. There is no mention of AI, ML, image processing, or any other technology typically associated with AI/ML applications in medical devices. The performance studies focus on standard analytical validation metrics like precision and reproducibility.

No.
This device is an in vitro diagnostic quality control material used to verify assays for D-Dimer, not to treat or diagnose patients.

No

This device is a calibration verification/linearity test kit ("quality control materials"), not a diagnostic device. It is used to verify the performance of quantitative assays for D-Dimer, which are themselves used for diagnostic purposes.

No

The device description clearly states the kit contains liquid levels in a human plasma base matrix, indicating it is a physical product, not software.

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

Here's why:

  • Intended Use: The "Intended Use / Indications for Use" section explicitly states that the VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit solutions are "intended for in vitro diagnostic use".
  • Device Description: The device is a "quality control material" used for "quantitative determination verification" of an analyte (D-Dimer) in a "human plasma base matrix". This is a typical description of a material used in laboratory testing of biological samples.
  • Intended User / Care Setting: The intended users are "clinical laboratory personnel", and the product is for use with "quantitative assays on the indicated analyzers". This indicates use in a clinical laboratory setting for diagnostic purposes.

The purpose of this device is to verify the performance of quantitative D-Dimer assays, which are used in the diagnosis and management of various medical conditions. This aligns directly with the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit solutions are assayed quality control materials intended for in vitro diagnostic use in the quantitative determination of linearity, calibration verification and verification of reportable range for the following analyte: D-Dimer in a clinical laboratory setting by laboratory personnel. The product is intended for use with quantitative assays on the indicated analyzers specified in the labeling.

Product codes

GGN

Device Description

Each VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit contains one analyte set of D-Dimer in a human plasma base matrix. The kit includes a set containing five liquid levels, 3.0 mL each. The set is provided to establish the relationship between theoretical and actual performance of the included analyte D-Dimer. Material of human origin used in the manufacture of this test kit was tested at the donor level using FDA approved methods and was found to be non-reactive for HBsAG and to antibodies to HCV and HIV-1/2.

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

clinical laboratory personnel

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

The performance of the new VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit was compared to the predicate device K152961, VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit.

Precision/Reproducibility: Precision was evaluated on the Siemens Sysmex CS-2500 instrument system with the VALIDATE® D-Dimer product following the product package insert instructions. Three lots of VALIDATE® D-Dimer product were tested with one lot of Siemens Innovance® D-Dimer reagent and quality controls on the Siemens CS-2500 instrument system over 20 days, 2 runs per day, 2 replicates per run for Level 1 through Level 5 with a minimum of two operators to obtain a total of eighty (80) replicates per kit Level. All levels of the VALIDATE® D-Dimer kit met the CV% acceptance criteria on the Siemens CS-2500 instrument system. Reproducibility was evaluated on the Siemens Sysmex CS-2500 instrument system with the VALIDATE® D-Dimer kit containing 5 levels following the product package insert instructions. One lot of VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit was tested with one lot of Siemens Innovance® D-Dimer reagent and quality controls on three instruments, multi-site, over 5 days, with 1 run per day of Levels 1-5, 5 replicates per run and a minimum of three operators to obtain seventy-five (75) replicates per kit level. All levels of the VALIDATE® D-Dimer kit met the CV% acceptance criteria on the Siemens CS-2500 instrument system.

Stability: Stability testing was performed using the Siemens Sysmex CS-2500 instrument system. The study testing time points included date of manufacture (DOM), followed by testing at specific intervals post manufacture. A freeze-thaw vial stability assessment was also conducted in support of the product package insert four (4) freeze-thaw open vial events claim. All product levels tested within the acceptance criteria limits after 6 freeze-thaw vial events. Shelf Life Claim: Stability of the VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit was set at 9 months based on available real-time stability studies. Real time stability studies are ongoing to support an extended stability claim. The recommended storage temperature is -10 to -25°C.

Linearity: Linearity testing was carried out with the new device VALIDATE® D-Dimer Calibration Verification / Linearity Test Kits on the Siemens Sysmex CS-2500 instrument.

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

All levels of the VALIDATE® D-Dimer kit met the CV% acceptance criteria on the Siemens CS-2500 instrument system (for precision and reproducibility). All product levels tested within the acceptance criteria limits after 6 freeze-thaw vial events.

Predicate Device(s)

K152961

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

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Image /page/0/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" around the perimeter. Inside the circle is an abstract symbol that resembles a stylized caduceus, with three human profiles forming the staff and a ribbon-like shape representing the snakes.

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

June 21, 2017

Maine Standards Company LLC James W. Champlin Director, QSHIE 221 US Route 1 Cumberland Foreside, ME 04110

Re: K170864

Trade/Device Name: VALIDATE® D-Dimer Calibration Verification/Linearity Test Kit Regulation Number: 21 CFR 864.5425 Regulation Name: Multipurpose system for in vitro coagulation studies Regulatory Class: Class II Product Code: GGN Dated: March 22, 2017 Received: March 23, 2017

Dear Mr. Champlin:

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. 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); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the

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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 contact the Division of Industry and Consumer Education 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. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely,

Leonthena R. Carrington -S

Lea Carrington, MS, MBA, MT(ASCP) Director Division of Immunology and Hematology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

2

Indications for Use

Form FDA 3881 (1/14) Attached

3

Indications for Use

510(k) Number (if known)

Device Name

VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit.

Indications for Use (Describe)

VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit solutions are assayed quality control materials intended for in vitro diagnostic use in the quantitative determination verification verification and verification of reportable range for the following analyte: D-Dimer in a clinical laboratory personnel. The product is intended for use with quantitative assays on the indicated analyzers specified in the labeling.

Type of Use (Select one or both, as applicable):

Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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510(k) SUMMARY

"This summary of 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: K170864

A. Submitter:

Maine Standards Company LLC 221 US Route 1 Cumberland Foreside, ME 04110 207-892-1300 Telephone: Fax: 207-892-2266

Contact Person: James Champlin Director, QSHIE jim.champlin@lgcgroup.com 207-892-1300 Ext. 29 Telephone:

Date of Summary Preparation: June 16, 2017

B. Device Classification:

Device classification name: Plasma, Coagulation Control Common name: Calibration Verification / Linearity Test Kit VALIDATE® D-Dimer Calibration Verification / Linearity Test Proprietary Name: Kit Review Panel: Hematology (81) 21 CFR 864.5425 Requlation Number: Product Code: GGN Regulatory Class: Class II

C. Predicate Device Identification:

VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit. Maine Standards Company LLC, Cumberland Foreside, ME 04110 K152961

D. Candidate Device description: Each VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit contains one analyte set of D-Dimer in a human plasma base matrix. The kit includes a set containing five liquid levels, 3.0 mL each. The set is provided to establish the relationship between theoretical and actual performance of the included analyte D-Dimer. Material of human origin used in the manufacture of this test kit was tested at the donor level using FDA approved methods and was found to be non-reactive for HBsAG and to antibodies to HCV and HIV-1/2.

E. Intended use:

VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit solutions are assayed quality control materials intended for in vitro diagnostic use in the quantitative determination of linearity, calibration verification and verification of reportable range for the following analyte: D-Dimer in a clinical laboratory setting by laboratory personnel. The product is intended for use with quantitative assays on the indicated analyzers specified in the labeling.

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F. Summary of Performance Data:

The performance of the new VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit was compared to the predicate device K152961, VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit.

Table 1 compares the technical characteristics of the new VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit with those of the predicate.

New DevicePredicate (K152961)
VALIDATE® D-Dimer CalibrationVALIDATE® D-Dimer Calibration
Verification / Linearity Test KitVerification / Linearity Test Kit
SimilaritiesSimilarities
Test KitCalibration Verification/Linearity
Test KitSame
Intended UseFor in vitro diagnostic use in the
quantitative determination of
linearity, calibration verification
and verification of reportable
range in automated instrument
systemsSame
AnalytesD-DimerSame
StabilityUntil expiration dateSame
MatrixHuman plasma baseSame
Number of Levels5 levelsSame
PreparationLiquid, ready to useSame
Storage-10 to -25°CSame

Table 1 - Technical Comparison to Predicate

Value Assignment

VALIDATE® D-Dimer Calibration Verification / Linearity Test Kits are manufactured such that an equal relationship exists among Levels 1 through 5; Level 1 being the lowest concentration and Level 5 being the highest. Levels 1 and 5 are prepared independently by the addition of D-Dimer to a human plasma base matrix. Levels 1 through 5 must meet specified D-Dimer target ranges at all stages of testing.

Specific recovery targets for Levels 1 through 5 are determined by the upper and lower detection limits for D-Dimer. Intermediate Levels 2, 3, and 4 are subsequently prepared from Levels 1 and 5 by equal part dilutions following EP6-A guidelines. Typical value ranges are provided in the package insert.

Typical recovery values, presented in Table 2, were established for Level 1 and Level 5 by testing 30 replicates, with values for Mid-Levels 2, 3, and 4 calculated based on an equal distance (delta) between levels.

The product is designed for laboratories to satisfy the requirements for calibration verification and verification of the systems reportable range as specified in the current CLIA regulations section 493.1255.

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Table 2 - Typical Recovery Values

Set
InstrumentAnalyteUnitsLevels
12345
Siemens Sysmex
CS-2500®D-Dimermg/L FEU0.301.192.082.973.86

A linear relationship exists between each level in a kit. The quantitative determination of linearity, calibration verification, and verification of reportable range relies on the known relationship between each of the levels of the product, in this case equal deltas, as outlined in the CLSI EP6-A referenced standard.

This kit is not intended for use as a calibration material.

Precision/Reproducibility

Precision was evaluated on the Siemens Sysmex CS-2500 instrument system with the VALIDATE® D-Dimer product following the product package insert instructions. Three lots of VALIDATE® D-Dimer product were tested with one lot of Siemens Innovance® D-Dimer reagent and quality controls on the Siemens CS-2500 instrument system over 20 days, 2 runs per day, 2 replicates per run for Level 1 through Level 5 with a minimum of two operators to obtain a total of eighty (80) replicates per kit Level. All levels of the VALIDATE® D-Dimer kit met the CV% acceptance criteria on the Siemens CS-2500 instrument system.

Reproducibility was evaluated on the Siemens Sysmex CS-2500 instrument system with the VALIDATE® D-Dimer kit containing 5 levels following the product package insert instructions. One lot of VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit was tested with one lot of Siemens Innovance® D-Dimer reagent and quality controls on three instruments, multi-site, over 5 days, with 1 run per day of Levels 1-5, 5 replicates per run and a minimum of three operators to obtain seventy-five (75) replicates per kit level. All levels of the VALIDATE® D-Dimer kit met the CV% acceptance criteria on the Siemens CS-2500 instrument system.

Traceability

This device is traceable to a reference standard based on the automated instrument. platform it is used on. The traceability of our product will be established per the respective end user automated instrument calibrator traceability reference statement. For the Siemens Sysmex CS-2500 the device is traceable to the Innovance® reagent calibrator curve.

Stability

Stability testing was performed using the Siemens Sysmex CS-2500 instrument system. The study testing time points included date of manufacture (DOM), followed by testing at specific intervals post manufacture.

A freeze-thaw vial stability assessment was also conducted in support of the product package insert four (4) freeze-thaw open vial events claim. All product levels tested within the acceptance criteria limits after 6 freeze-thaw vial events.

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Shelf Life Claim: Stability of the VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit was set at 9 months based on available real-time stability studies. Real time stability studies are ongoing to support an extended stability claim. The recommended storage temperature is -10 to -25°C. All supporting data is retained on file at Maine Standards Company LLC.

Linearity:

Linearity testing was carried out with the new device VALIDATE® D-Dimer Calibration Verification / Linearity Test Kits on the Siemens Sysmex CS-2500 instrument. All supporting data is retained on file at Maine Standards Company LLC.

G. Conclusion:

Based upon the purpose of the device, the descriptions and labeling of the predicate device, the VALIDATE® D-Dimer Calibration Verification / Linearity Test Kit behaves substantially equivalent to the predicate for the quantitative determination of linearity, calibration verification and verification of reportable range for the D-Dimer analyte. The product is substantially equivalent to the predicate device, K152961.