K Number
K171861
Manufacturer
Date Cleared
2018-02-07

(230 days)

Product Code
Regulation Number
862.1373
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The CAPILLARYS Hb A1c kit is intended for separation and quantification of the HbA1c glycated fraction of hemoglobin (in IFCC unit (mmol/mol) and NGSP unit (%)) in venous whole human blood, by capillary electrophoresis in alkaline buffer with the CAPILLARYS 2 FLEX-PIERCING instrument of hemoglobin A1c is used as an aid in diagnosis of diabetes, as an aid to identify patients who may be at risk for developing diabetes mellitus, and for the monitoring of long-term blood glucose control in individuals with diabetes mellitus. The CAPILLARYS Hb A 1c kit is intended for in vitro Diagnostic Use Only.

Device Description

The CAPILLARYS 2 FLEX-PIERCING instrument uses the principle of capillary electrophoresis in free solution. With this technique, charged molecules are separated by their electrophoretic mobility in an alkaline buffer with a specific pH. Separation occurs according to the electrolyte pH and electroosmotic flow.

The CAPILLARYS 2 FLEX-PIERCING instrument has silica capillaries functioning in parallel allowing 8 simultaneous analyses of HbA1c quantification in a whole blood sample. A sample dilution with hemolysing solution is prepared and injected by aspiration at the anodic end of the capillary. A high voltage protein separation is then performed and direct detection of the hemoglobins is made at the cathodic end of the capillary at 415 nm, which is the absorbance wave length specific to hemoglobins. Before each run, the capillaries are washed with a wash solution and prepared for the next analysis with buffer.

Direct detection provides accurate relative quantification of individual hemoglobin A1c fraction. In addition, the high resolution of CAPILLLARYS Hb A1c procedure allows the quantification of HbA1c even in the presence of labile HbA1c, carbamylated and acetylated hemoglobins, and major hemoglobin variants.

By using an alkaline pH buffer, normal and abnormal (or variant) hemoglobins are detected in the following order, from cathode to anode: A2/C, E, S/D, F, A0, other Hb (including minor Hb A1) and then A1c.

The HbA1c concentrations are standardized and indicated in %HbA1c (DCCT/NGSP) and in mmol/mol (IFCC) units.

AI/ML Overview

The provided text describes the performance data for the CAPILLARYS Hb A1c device, which is an in vitro diagnostic test for measuring HbA1c. The acceptance criteria and the study proving adherence to these criteria are detailed, primarily focusing on precision, linearity, and interference.

Here's the breakdown of the requested information:

1. Table of Acceptance Criteria and Reported Device Performance

Acceptance Criteria (Stated Requirements)Reported Device Performance
Device must have initial and annual standardization verification by certifying glycohemoglobin standardization organization deemed acceptable by FDA.The CAPILLARYS Hb A1c test standardization is traceable to the International Federation of Clinical Chemistry (IFCC) reference calibrators. The CAPILLARYS Hb A1c assay is NGSP certified. The NGSP certification expires in one year. (http://www.ngsp.org)
Performance testing of device precision must, at a minimum, use blood samples with concentrations near 5.0%, 6.5%, 8.0%, and 12% hemoglobin A1c. Testing must evaluate precision over a minimum of 20 days using at least 3 lots of the device and instruments, as applicable.Precision was evaluated using the CLSI EP5A3 guideline. Four whole blood samples with targeted HbA1c concentrations of ~5%, ~6.5%, ~8%, and ~12% were used. Eight different samples (4 human blood, 2 controls, 2 calibrators) were run in duplicate on two capillaries per run, two runs per day over 20 days per lot, using three lots (total 1440 results per sample over 60 days). The full precision results are provided in extensive tables for both mmol/mol and %HbA1c. The total reproducibility CVs for %HbA1c ranged from 1.2% to 2.0% across the different samples and instruments.
Performance testing of accuracy must include a minimum of 120 blood samples that span the measuring interval of the new device and compare results of the new device to results of the standardized method. Results must demonstrate little or no bias versus the standardized method.A method comparison study included 150 variant-free whole blood samples covering the measuring range (4.4% to 16.6% HbA1c). Results were compared to an NGSP reference laboratory using the cleared HPLC HbA1c method (Tosoh Automated Glycohemoglobin Analyzer HLC-712G8). The correlation coefficient (r) was 0.999. Average bias for all samples was -0.07% (-0.08 to -0.05). Bias at the normal range (6.5%) was -0.09% (-0.11 to -0.07). These values indicate very low bias.
Total error of the new device must be evaluated using single measurements by the new device compared to the results of the standardized test method, and this evaluation must demonstrate a total error of less than or equal to 6%.Total Error (TE) was calculated for 4 concentrations (5.1%, 6.4%, 8.2%, and 12.2% HbA1c) using %Bias and %CV from the precision study. The reported TE% values were 5.9%, 4.1%, 2.8%, and 3.1% respectively, all of which are ≤ 6.0%.
Performance testing must demonstrate that there is little to no interference from common hemoglobin variants, including Hemoglobin C, Hemoglobin D, Hemoglobin E, Hemoglobin A2, and Hemoglobin S.No interference was observed for HbA1c quantification due to the presence of major abnormal hemoglobins: Hb S (≤ 40.8%), Hb C (≤ 37.2%), Hb D (≤ 41.3%), and Hb E (≤ 37.0%). Levels of Hb A2 up to 7.7% did not interfere. Mean relative % Bias for these variants was very low.
When assay interference from Hemoglobin F or interference with other hemoglobin variants with low frequency in the population is observed, a warning statement must be placed in a black box and must appear in all the labeling material for these devices describing the interference and any affected population.Levels of Hb F up to 23% in the blood sample do not interfere. If Hb F levels are higher than 23%, a warning message "Atypical profile – Possible quantitative interference if Hb F or variant > 23 %" is displayed, recommending further analysis. (This criterion is marked "NA" in the table, implying it might be covered by a general warning, rather than a specific black box for this device for this interference).

2. Sample sizes used for the test set and the data provenance

  • Precision Study:
    • Sample Size: Four human blood samples, two controls, and two calibrators were used. Each of these 8 distinct samples was analyzed in duplicate on two capillaries per run, two runs per day over 20 days per lot, using three lots. This results in 1440 results per sample (8 samples * 2 replicates * 2 capillaries * 2 runs * 20 days * 3 lots, though the 1440 figure suggests a different multiplication, it's stated as 1440 results per sample meaning 8 * 1440 total measurements).
    • Data Provenance: Not explicitly stated regarding country of origin. The study was based on CLSI (USA) guidelines. It's a prospective study as specified by the testing methodology (over 20 days, 3 lots, etc.).
  • Accuracy (Comparison) Study:
    • Sample Size: 150 variant-free whole blood samples.
    • Data Provenance: Not explicitly stated regarding country of origin. This dataset was collected for the purpose of the comparison study, implying a prospective design for comparing to a reference method. The samples spanned the measuring range and were distributed around clinical decision points.
  • Interference Study:
    • Sample Size: For endogenous factors and drugs, two different whole blood samples were used (one near cut-off, one elevated HbA1c). Ten replicates were analyzed. For hemoglobin variants, specific numbers of samples were used for each variant: 20 for Hb A2, 20 for Hb F, 20 for Hb S, 20 for Hb C, 21 for Hb D, and 22 for Hb E.
    • Data Provenance: Not explicitly stated. Assumed to be prospective.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

The ground truth for this device (a quantitative diagnostic test) is established by reference methods and certified reference materials, not expert consensus.

  • Precision: No "ground truth" experts in the conventional sense. The "ground truth" for the mean values (target concentrations) of the blood samples, controls, and calibrators would be established through highly standardized and traceable processes by the manufacturer or a reference lab according to CLSI guidelines.
  • Accuracy (Comparison): The comparison was against a "cleared HPLC HbA1c method (Automated Glycohemoglobin Analyzer HLC-712G8) performed at a NGSP reference laboratory." An NGSP (National Glycohemoglobin Standardization Program) reference laboratory adheres to stringent guidelines for HbA1c measurement and provides traceability to the DCCT (Diabetes Control and Complications Trial) reference method and IFCC (International Federation of Clinical Chemistry and Laboratory Medicine). The "ground truth" here is the result from this highly standardized and certified reference method, not an individual expert's reading.
  • Interference: "Ground truth" for interference studies is typically based on the known concentration of the interfering substance and the measured value using a validated method. For hemoglobin variants, it was also compared against an NGSP laboratory's reference method.

Therefore, the concept of "experts" in the traditional sense of medical image interpretation (like radiologists) doesn't directly apply here. The "expertise" is embedded in the scientific rigor of the reference methods and standardization programs.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable. This is a quantitative chemical assay, not a qualitative assessment like image interpretation that requires adjudication among human readers. The "ground truth" from the reference method is considered definitive.

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

Not applicable. This is a medical device for an automated quantitative laboratory test and does not involve human readers, AI assistance, or MRMC studies.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done

Yes, the CAPILLARYS Hb A1c device is an automated in vitro diagnostic instrument. The performance data presented (precision, linearity, accuracy, interference) are all standalone performance characteristics of the algorithm and instrument system without human intervention influencing the measurement result itself once the sample is loaded.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

The ground truth used for performance evaluation was:

  • Reference methods from NGSP certified laboratories: For accuracy (comparison) and hemoglobin variant interference studies, the device's results were compared to those obtained from an NGSP reference laboratory using a cleared HPLC HbA1c method. NGSP certification ensures traceability to the primary international reference methods (DCCT/IFCC).
  • Gravimetric/Volumetric preparation and known concentrations: For linearity and interference studies with endogenous substances and drugs, samples were likely prepared to specific, known concentrations, serving as the ground truth.
  • Certified calibrators and controls: For precision studies, the 'true' values of the controls and calibrators are established through rigorous certification processes, making them the ground truth for evaluating reproducibility.

8. The sample size for the training set

This document describes premarket notification for a traditional IVD device, not an AI/ML-based device that typically undergoes "training" and "testing" phases in the same way. The instrument and its reagents are designed based on established chemical and electrophoretic principles. Therefore, there isn't a "training set" in the machine learning sense. The development of the assay and the robust validation typically leverage extensive historical data and scientific understanding, but it's not "training data" for a machine learning algorithm.

9. How the ground truth for the training set was established

As there isn't a "training set" in the AI/ML context, this question is not applicable. The performance is validated against rigorous clinical laboratory standards and reference methods as described above.

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February 7, 2018

Sebia Karen Anderson Director of Technical and Regulatory 1705 Corporate Drive Suite 400 Norcross, GA 30093

Re: K171861

Trade/Device Name: CAPILLARYS Hb A1c Regulation Number: 21 CFR 862.1373 Regulation Name: Hemoglobin A1c test system Regulatory Class: Class II Product Code: PDJ Dated: December 14, 2017 Received: December 20, 2017

Dear Karen Anderson:

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 Part 801 and Part 809); medical device 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

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Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Kellie B. Ke

for Courtney H. Lias, Ph.D. Director Division of Chemistry and Toxicology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K171861

Device Name CAPILLARYS Hb A1c

Indications for Use (Describe)

The CAPILLARYS Hb A1c kit is intended for separation and quantification of the HbA1c glycated fraction of hemoglobin (in IFCC unit (mmol/mol) and NGSP unit (%)) in venous whole human blood, by capillary electrophoresis in alkaline buffer with the CAPILLARYS 2 FLEX-PIERCING instrument of hemoglobin A1c is used as an aid in diagnosis of diabetes, as an aid to identify patients who may be at risk for developing diabetes mellitus, and for the monitoring of long-term blood glucose control in individuals with diabetes mellitus. The CAPILLARYS Hb A 1c kit is intended for in vitro Diagnostic Use Only.

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)

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K171861

510K SUMMARY (Summary of Safety and Effectiveness)

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

Submitter NameSebia, Inc.
Address1705 Corporate Drive Suite 400Norcross, Georgia 30093, USA
ContactKaren Anderson, Dir of Technical and QAPhone: 1-800-835-6497Fax: 770-446-8511Email: karen.anderson@sebia-usa.com
Date PreparedFebruary 6, 2018
ManufacturingSebiaParc Technologique Léonard de VinciRue Léonard de Vinci,CP 8010 LISSES, 91008 EVRY CedexFRANCEPhone: (33) 1 69 89 80 80Fax: (33) 1 69 89 78 78
Product NameCAPILLARYS Hb A1c
Common NameWhole blood hemoglobin A1c (HbA1c) by capillaryelectrophoresis
Product Regulation No.21 CFR 862.1373
Product CodesPDJ
Device classification and Panel ClassificationClass II , Clinical Chemistry(75)
Establishment Registration No.8023024

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1. DEVICE DESCRIPTION

The CAPILLARYS 2 FLEX-PIERCING instrument uses the principle of capillary electrophoresis in free solution. With this technique, charged molecules are separated by their electrophoretic mobility in an alkaline buffer with a specific pH. Separation occurs according to the electrolyte pH and electroosmotic flow.

The CAPILLARYS 2 FLEX-PIERCING instrument has silica capillaries functioning in parallel allowing 8 simultaneous analyses of HbA1c quantification in a whole blood sample. A sample dilution with hemolysing solution is prepared and injected by aspiration at the anodic end of the capillary. A high voltage protein separation is then performed and direct detection of the hemoglobins is made at the cathodic end of the capillary at 415 nm, which is the absorbance wave length specific to hemoglobins. Before each run, the capillaries are washed with a wash solution and prepared for the next analysis with buffer.

Direct detection provides accurate relative quantification of individual hemoglobin A1c fraction. In addition, the high resolution of CAPILLLARYS Hb A1c procedure allows the quantification of HbA1c even in the presence of labile HbA1c, carbamylated and acetylated hemoglobins, and major hemoglobin variants.

By using an alkaline pH buffer, normal and abnormal (or variant) hemoglobins are detected in the following order, from cathode to anode: A2/C, E, S/D, F, A0, other Hb (including minor Hb A1) and then A1c.

The HbA1c concentrations are standardized and indicated in %HbA1c (DCCT/NGSP) and in mmol/mol (IFCC) units.

Reagents:

CAPILLARYS HbA1c KIT

ITEMSPN 2015
Buffer (ready to use)2 vials, 700 mL each
Hemolysing solution (ready to use)1 vial, 700 mL
Wash solution (stock solution)1 vial, 75 mL
Green dilution segments1 pack of 90
Filters4 filters

Additional reagents not included in the CAPILLARYS Hb A1c KIT

ITEMSPNCOMPONENTS
CAPICLEAN20581 vial, 25 mL

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CAPILLARYS WASH SOLUTION20522 vial, 75mL
TUBES AND CAPS FOR CONTROLS9202920520 units500 units
Wedge adapters920310 per box
PHORESIS software1110
CAPILLARYS 2 FLEX-PIERCINGINSTRUMENT1227
Hb A1c CAPILLARY CALIBRATORS475547561 SET5 SETS
MULTI-SYSTEM Hb A1cCAPILLARY CONTROLS4767476810 SETS1 SET

2. INDICATIONS FOR USE

CAPILLARYS Hb A1c kit:

The CAPILLARYS Hb A1c kit is intended for separation and quantification of the HbA1c glycated fraction of hemoglobin (in IFCC unit (mmol/mol) and NGSP unit (%)) in venous whole human blood, by capillary electrophoresis in alkaline buffer with the CAPILLARYS 2 FLEXPIERCING instrument. Measurement of hemoglobin A1c is used as an aid in diagnosis of diabetes, as an aid to identify patients who may be at risk for developing diabetes mellitus, and for the monitoring of long-term blood glucose control in individuals with diabetes mellitus. The CAPILLARYS Hb A1c kit is intended for in vitro Diagnostic Use Only

3. SUBSTANTIAL EQUIVALENCE INFORMATION:

Predicate Device NamePredicate Device Product Code Regulation No.510(k) number
Tosho AutomatedGlycohemoglobin Analyzer HLC-723G-8K131580PDJ862.1373

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Similarities between the candidate device (CAPILLARYS Hb A1c) and the predicate device (Tosoh HLC-723G8, K131580 (Table A).

Similarities
Table ASebia CAPILLARYS Candidate Device Hb A1cTosoh HLC-723G8 Predicate Device (K131580)
Intended useThe CAPILLARYS Hb A1c kit is intended for separation and quantification of the HbA1c glycated fraction of hemoglobin (in IFCC unit (mmol/mol) and NGSP unit (%)) in venous whole human blood, by capillary electrophoresis in alkaline buffer with the CAPILLARYS 2 FLEX-PIERCING instrument. Measurement of hemoglobin A1c is used as an aid in diagnosis of diabetes, as an aid to identify patients who may be at risk for developing diabetes mellitus, and for the monitoring of long-term blood glucose control in individuals with diabetes mellitus. The CAPILLARYS Hb A1c kit is intended for in vitro Diagnostic Use OnlyThe Tosoh Automated Glycohemoglobin Analyzer HLC723G8 is intended for the in vitro diagnostic use for the measurement of % hemoglobin A1c (HbA1c) (DCCT/NGSP) and mmol/mol hemoglobin A1c (IFCC) in whole blood specimens. This test is to be used as an aid in diagnosis of diabetes and identifying patients who may be at risk of developing diabetes.
Specimen TypeHuman Whole BloodHuman Whole Blood
StandardizationTraceable to the Diabetes Contraol and Complications Trial (DCCT) reference method and IFCC. Certified via the National Glycohemoglobin Standardization Program ( NGSP)Same
LinearityMeasuring Range4.4 – 16.6% (NGSP)24 – 158 mmol/mol ( IFCC)4.0 – 16.9 %
TotalErrorallowable bias6%Concentration5.16.48.212.2Concentration5.06.58.012.0
TE%5.94.12.83.1TE%5.82.83.03.1
HemoglobinVariantInterferencesHbA2, HbS, HbC, HbD, does not interfere with this assayHbA2, HbF, HbS, HbC, HbD, does not interfere with this assay

Table B. Differences between the predicate device (CAPILLARYS Hb A1c) and the candidate device (Tosoh HLC-723G8, K131580) in (Table B).

Differences
Table BSebia CAPILLARYS Hb A1cCandidate DeviceTosoh HLC-723G8Predicate Device (K131580)
Assay PrincipleCapillary electrophoresisIon-exchange HPLC

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HemoglobinVariantInterferencesHb E no interferenceHb E has known interference, a HbEflag is displayed and no Hb A1c isreported.
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  1. Performance Data:

a. Precision / Reproducibility:-

Precision

The precision of the CAPILLARYS Hb A1c procedure using the CAPILLARYS 2 FLEX-PIERCING was evaluated in a study based on the Clinical Laboratory Standards Institute (CLSI - USA) EP5A3 guideline "Evaluation of Precision of Quantitative Measurements Procedures; Approved Guideline - Third Edition".

The means, standard deviations (SD) and coefficients of variation (CV %) were calculated for HbA1c concentration (mmol/mol) and percentage (%) for each sample.

Evaluation of Precision of Quantitative Measurement Procedures. Four whole blood samples at the following targeted HbA1c concentration of ~ 5%. ~ 6.5%. ~ 8%, and ~12% were used in the study

Eight (8) different samples were run using the CAPILLARYS Hb A1c procedure on the CAPILLARYS 2 FLEX-PIERCING instrument. The analyzed samples included 4 human blood samples (blood No. 1 to 4), 2 controls and 2 calibrators. Each sample was analyzed in duplicate on two capillaries per run, two runs per day over 20 days per lot of CAPILLARYS Hb A1c kit, using three lots yielding a total of 1440 results per sample over 60 days.

The reproducibility between instruments is summarized in the following tables including withincapillary, between-capillary, between-run, between-lot, between-instrument and total reproducibility precision estimates (SD and %CV) for the HbAre percentages.

Mean(mmol/mol)Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotBetween-instrumentTotal reproducibility (*)
SampleSDCVSDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 1320,601,9%0,672,1%0,000,0%0,260,8%0,351,1%0,000,0%0,993,1%
Blood No. 2460,761,7%0,400,9%0,000,0%0,270,6%0,380,8%0,000,0%0,982,1%
Blood No. 3660,781,2%0,580,9%0,000,0%0,320,5%0,360,6%0,000,0%1,091,6%
Blood No. 41090,890,8%0,880,8%0,000,0%0,510,5%1,181,1%0,000,0%1,791,6%
Control 1330,642,0%0,571,8%0,000,0%0,361,1%0,571,8%0,030,1%1,103,4%
Control 2630,731,2%0,991,6%0,000,0%0,791,2%0,170,3%0,911,4%1,732,7%
Calibrator 1370,762,0%0,411,1%0,000,0%0,320,8%0,441,2%0,000,0%1,022,7%
Calibrator 2870,941,1%0,670,8%0,000,0%0,230,3%0,620,7%0,000,0%1,331,5%

(*) Total reproducibility includes: within-capillary, between-capillary, between-run, between-day, between-lot and between-instrument.

SampleMean(%)Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotBetween-instrumentTotal reproducibility (*)
SDCVSDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 15,10,061,1%0,061,2%0,000,0%0,030,6%0,030,5%0,000,0%0,091,8%
Blood No. 26,40,071,1%0,040,6%0,000,0%0,030,4%0,040,6%0,000,0%0,091,4%
Blood No. 38,20,070,9%0,050,7%0,000,0%0,030,3%0,030,4%0,000,0%0,101,2%
Blood No. 412,20,080,7%0,080,6%0,000,0%0,040,4%0,100,9%0,000,0%0,161,3%
Control 15,10,061,1%0,051,1%0,000,0%0,030,7%0,051,0%0,010,3%0,102,0%
Control 28,00,070,9%0,091,1%0,000,0%0,070,9%0,010,2%0,081,1%0,162,0%
Calibrator 15,60,071,3%0,040,7%0,000,0%0,030,5%0,050,9%0,000,0%0,101,8%
Calibrator 210,10,080,8%0,060,6%0,000,0%0,020,2%0,070,7%0,000,0%0,131,3%

(") Total reproducibility includes : within-capillary, between-run, between-day, between-day, between-lot and betwee

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The reproducibility within the same instrument is summarized in the following tables :

including within-capillary, between-capillary, between-day, between-day, between-lot and total reproducibility precision estimates (SD and %CV) for the HbA% concentrations (in mmol/mol) and percentages for each instrument.

including the within-lot precision estimates (SD and %CV) for the HbA1ം concentrations (in mmol/mol) and percentages for each lot on each instrument.

SampleMean(mmol/mol)Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotTotal reproducibility (*)
SDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 1320,601,9%0,491,5%0,000,0%0,220,7%0,421,3%0,912,8%
Blood No. 2460,801,7%0,370,8%0,000,0%0,220,5%0,380,8%0,992,1%
Blood No. 3660,771,2%0,500,8%0,000,0%0,440,7%0,360,6%1,081,6%
Blood No. 41090,900,8%0,790,7%0,000,0%0,530,5%1,111,0%1,721,6%
Control 1330,642,0%0,491,5%0,000,0%0,401,2%0,511,6%1,043,2%
Control 2630,751,2%1.362,2%0,000,0%0,400,6%0,290,5%1,632,6%
Calibrator 1370,802,1%0,290,8%0,000,0%0,401,1%0,320,8%0,992,7%
Calibrator 2870,911,1%0,770,9%0,000,0%0,130,2%0,650,7%1,361,6%
(*) Total reproducibility includes : within-capillary, between-capillary, between-run, between-day and between-lot

Instrument No. 1

withi Within-lot (*)

SampleMean(mmol/mol)Lot No. 1Lot No. 2Lot No. 3
SDCVSDCVSDCV
Blood No. 1320,882,7%0,672,1%0,872,7%
Blood No. 2460,912,0%0,962,1%0,891,9%
Blood No. 3660,871,3%1,081,6%1,101,7%
Blood No. 41091,331,2%1,361,2%1,241,1%
Control 1330,812,5%0,993,1%0,892,7%
Control 2631,252,0%1,592,5%1,913,0%
Calibrator 1370,872,3%0,992,7%1,022,7%
Calibrator 2870,951,1%1,401,6%1,251,4%

(*) Within lot reproducibility includes : within-capillary, between-capillary, between-run and between-day

MeanWithin-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotTotal reproducibility (*)
Sample(%)SDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 15,10,061,3%0,040,7%0,000,0%0,030,5%0,030,7%0,091,7%
Blood No. 26,40,071,1%0,040,5%0,000,0%0,030,4%0,030,5%0,091,4%
Blood No. 38,20,080,9%0,050,6%0,000,0%0,040,4%0,040,5%0,101,3%
Blood No. 412,20,080,7%0,080,6%0,000,0%0,050,4%0,100,8%0,161,3%
Control 15,10,061,2%0,040,7%0,000,0%0,040,7%0,040,8%0,091,8%
Control 28,00,070,9%0,121,5%0,000,0%0,030,4%0,020,3%0,141,8%
Calibrator 15,60,071,2%0,040,7%0,000,0%0,040,7%0,040,7%0,101,7%
Calibrator 210,10,090,9%0,070,7%0,000,0%0,020,2%0,070,7%0,141,3%
(*) Total reproducibility includes : within-capillary, between-capillary, between-run, between-day and between-lot.
SampleMean (%)Within-lot (*)

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Lot No. 1Lot No. 2Lot No. 3
SDCVSDCVSDCV
Blood No. 15,10,071,5%0,071,4%0,091,8%
Blood No. 26,40,071,1%0,081,3%0,091,4%
Blood No. 38,20,081,0%0,101,2%0,101,2%
Blood No. 412,20,131,1%0,121,0%0,120,9%
Control 15,10,071,4%0,091,7%0,081,6%
Control 28,00,111,4%0,131,6%0,172,2%
Calibrator 15,60,071,3%0,091,7%0,101,7%
Calibrator 210,10,090,9%0,141,3%0,111,1%

(1) Within-lot reproducibility includes : within-capillary, between-run and between-run and between-day.
Instrument No. 2

SampleMean(mmol/mol)Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotTotal reproducibility (*)
SDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 1320,601,9%0,250,8%0,000,0%0,230,7%0,230,7%0,732,3%
Blood No. 2460,681,5%0,360,8%0,000,0%0,350,8%0,481,0%0,972,1%
Blood No. 3660,721,1%0,320,5%0,210,3%0,260,4%0,520,8%1,001,5%
Blood No. 41090,850.8%0,720,7%0,000,0%0,440,4%1,401,3%1,841,7%
Control 1330,621,9%0,481,4%0,000,0%0,260,8%0,631,9%1,043,2%
Control 2630,600,9%0,921,4%0,000,0%0,631,0%0,250,4%1,302,0%
Calibrator 1370,691,8%0,310,8%0,000,0%0,280,7%0,551,5%0,972,6%
Calibrator 2870,891,0%0,460,5%0,300,3%0,320,4%0,740,9%1,321,5%
(*) Total reproducibility includes : within-capillary, between-capillary, between-run, between-day and between-lot.
SampleMean(mmol/mol)Lot No. 1Lot No. 2Lot No. 3
SDCVSDCVSDCV
Blood No. 1320,672,0%0,632,0%0,812,5%
Blood No. 2460,831,8%0,891,9%0,851,8%
Blood No. 3660,821,2%0,851,3%0,911,4%
Blood No. 41091,081,0%1,191,1%1,301,2%
Control 1330,882,6%0,792,4%0,812,4%
Control 2631,392,2%1,041,6%1,362,1%
Calibrator 1370,872,3%0,772,1%0,812,2%
Calibrator 2870,921,1%1,141,3%1,181,4%
(*) Within lot reproducibility includes : within-capillary, between-capillary, between-run and between-day.
SampleMean(%)Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotTotal reproducibility (*)
SDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 15,10,051,0%0,020,4%0,000,0%0,020,5%0,010,2%0,061,2%
Blood No. 26,40,071,1%0,040,6%0,000,0%0,030,4%0,050,8%0,101,5%
Blood No. 38,20,070,8%0,020,3%0,020,2%0,030,3%0,050,6%0,091,1%
Blood No. 412,20,080,7%0,060,5%0,000,0%0,030,3%0,121,0%0,161,3%
Control 15,10,051,1%0,051,0%0,000,0%0,030,5%0,061,1%0,101,9%
Control 28,00,050,7%0,091,1%0,000,0%0,060,7%0,020,3%0,121,5%
Calibrator 15,60,071,3%0,030,6%0,000,0%0,020,4%0,061,1%0,101,8%
Calibrator 210,10,080,8%0,050,5%0,030,3%0,020,2%0,080,7%0,121,2%

(*) Total reproducibility includes : within-capillary, between-run, between-run, between-day and between-lot.

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Within-lot (*)
SampleMean(%)Lot No. 1Lot No. 2Lot No. 3
SDCVSDCVSDCV
Blood No. 15,10,051,1%0,061,2%0,071,3%
Blood No. 26,40,081,2%0,081,3%0,081,3%
Blood No. 38,20,070,9%0,080,9%0,081,0%
Blood No. 412,20,090,7%0,110,9%0,121,0%
Control 15,10,081,6%0,091,7%0,081,5%
Control 28,00,131,6%0,101,3%0,121,4%
Calibrator 15,60,081,4%0,081,4%0,091,6%
Calibrator 210,10,080,8%0,111,1%0,101,0%

(*) Within-lot reproducibility includes : within-capillary, between-run and between-run and between-day.
Instrument No. 3

SampleMean(mmol/mol)Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotTotal reproducibility (*)
SDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 1320,601,9%1,013,2%0,000,0%0,311,0%0,361,1%1,273,9%
Blood No. 2460,811,7%0,451,0%0,140,3%0,210,5%0,240,5%0,992,1%
Blood No. 3660,851,3%0,821,2%0,000,0%0,220,3%0,000,0%1,201,8%
Blood No. 41090,920,8%1,081,0%0,000,0%0,540,5%0,980,9%1,811,7%
Control 1330,662,1%0,722,2%0,000,0%0,411,3%0,561,7%1,203,7%
Control 2630,831,3%0,490,8%0,000,0%1,131,8%0,000,0%1,492,4%
Calibrator 1370,782,1%0,571,5%0,000,0%0,250,7%0,411,1%1,082,9%
Calibrator 2871,021,2%0,730,8%0,000,0%0,190,2%0,430,5%1,341,5%

(*) Total reproducibility includes : within-capillary, between-run, between-day and between-lot. .

SampleMean (mmol/mol)Within-lot (*)
Lot No. 1Lot No. 2Lot No. 3
SDCVSDCVSDCV
Blood No. 1320,902,8%1,243,9%1,444,4%
Blood No. 2460,761,6%0,942,0%1,162,5%
Blood No. 3661,191,8%1,121,7%1,392,1%
Blood No. 41091,451,3%1,261,1%1,801,7%
Control 1330,922,8%0,993,1%1,253,8%
Control 2631,502,4%1,422,3%1,532,4%
Calibrator 1371,102,9%0,912,5%1,092,9%
Calibrator 2871,181,4%1,211,4%1,421,6%

------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------. (*) Within lot reproducibility includes : within-capillary, between-capillary, between-run and betwe en-day.

Within-capillaryBetween-capillaryBetween-runBetween-dayBetween-lotTotal reproducibility (*)
SampleMean(%)SDCVSDCVSDCVSDCVSDCVSDCV
Blood No. 15,10,061,1%0,101,9%0,000,0%0,040,7%0,030,6%0,122,4%
Blood No. 26,40,071,2%0,040,6%0,000,0%0,020,3%0,020,3%0,091,4%
Blood No. 38,20,080,9%0,080,9%0,000,0%0,020,2%0,000,0%0,111,3%
Blood No. 412,20,080,7%0,090,8%0,000,0%0,050,4%0,090,7%0,161,3%
Control 15,10,061,2%0,071,3%0,000,0%0,040,7%0,051,0%0,112,1%
Control 28,00,081,0%0,050,6%0,000,0%0,101,3%0,000,0%0,131,7%
Calibrator 15,60,081,4%0,050,9%0,000,0%0,030,5%0,050,9%0,111,9%
Calibrator 210,10,090,9%0,070,7%0,000,0%0,020,2%0,050,5%0,131,2%

(*) Total reproducibility includes : within-capillary, between-run, between-run, between-day and between-lot.

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Within-lot (*)
SampleMean(%)Lot No. 1Lot No. 2Lot No. 3
SDCVSDCVSDCV
Blood No. 15,10,091,8%0,122,3%0,142,7%
Blood No. 26,40,071,1%0,091,4%0,101,6%
Blood No. 38,20,101,3%0,101,2%0,131,6%
Blood No. 412,20,121,0%0,110,9%0,161,3%
Control 15,10,091,7%0,091,8%0,112,2%
Control 28,00,131,7%0,121,6%0,141,8%
Calibrator 15,60,101,8%0,091,6%0,112,0%
Calibrator 210,10,111,1%0,121,1%0,121,2%

b. Linearity / assay reportable range

A linearity study was performed per CLSI EP06-A: Evaluation of Quantitative Measuring Procedures; A Statistical Approach. Linearity across the reportable range was performed using low 4.4% Hb A1c (24 mmol/mol) and high 16.7% (159 mmol/mol).

Mixture of 2 different blood samples:

This linearity study of the CAPILLARYS Hb A1c procedure was evaluated in a study based on the Clinical Laboratory Standards Institute (CLSI - USA) EP6-A guideline "Evaluation of the Linearity of Quantitative Measurement Procedures: A statistical Approach: Approved Guideline". The results for HbA . concentration (mmol/mol) and percentage (%) were analyzed using statistical tools recommended by CLSI.

2 characteristic blood samples, including a normal sample and an elevated HbAre level sample were mixed within different proportions and the mixtures were electrophoresed with the CAPILLARYS Hb A1c procedure. For each mixture, samples were analyzed in triplicate. The tests were determined to be linear within the entire range studied for HbAit hemoglobin fraction. The stated measuring range is 24 mmol/mol to 158 mmol/mol HbAre (4.4 % to 16.6 % HbA«¿).

c. Traceability, Stability (controls, calibrators, or methods)

The CAPILLARYS Hb A1c test standardization is traceable to the International Federation of Clinical Chemistry (IFCC) reference calibrators.

The CAPILLARYS Hb A1c assay is NGSP certified. The NGSP certification expires in one year. See the NGSP website for current certification at http://www.ngsp.org

Hb A1c results are provided in two different units: NGSP equivalent units (%) and IFCC equivalent units (mmol/mol).

{12}------------------------------------------------

d. Calibrators and Controls

The Hb A1c CAPILLARY CALIBRATORS are required for use with this device. Value assignment and stability protocol and acceptance criteria were previously reviewed and cleared in K122101.

Sebia MULTI-SYSTEM Hb A1c CAPILLARYS CONTROLS are required for use with this device and cleared in submission K162281.

e. Comparison Studies

A method comparison study of 150 variant-free whole blood samples covering the measuring range were evaluated using the CAPILLARYS Hb A1c kit and the CAPILLARYS 2 FLEXPIERCING instrument. The results were compared to the testing performed at a NGSP reference laboratory using the cleared HPLC HbA1c method (Automated Glycohemoglobin Analyzer HLC-712G8).

To support the diagnostic claim for HbA1c the samples spanned around the decision points as follows:

HbA1c levelNumber of samples% of samples
HbA1c ≤ 5,0 %75
5,0 % < HbA1c ≤ 6,0 %1913
6,0 % < HbA1c ≤ 6,5 %3523
6,5 % < HbA1c ≤ 7,0 %3624
7,0 % < HbA1c ≤ 8,0 %2315
8,0 % < HbA1c ≤ 9,0 %139
HbA1c > 9,0 %1711
Total150100

Samples distribution

{13}------------------------------------------------

HbA1c results given as a NGSP unit (%)

FractionRegression AnalysisCorrelation coefficienty-interceptSlopeRange of HbA1c % value CAPILLARYS Hb A1c
HbA1cOrdinary linear fit0.999-0.2651.0274.4 - 16.6

150 samples

HbA1c results given as a NGSP unit (%)

Regression Analysis (HbA1c fraction)
Ordinary linear fitWeighed DemingPassing Bablok
95 % Confidence Intervals are shown in parentheses
Points (Plotted/Total)150/150
Results Ranges4,4 to 16,6
Normal range< 6.5
Correlation coefficient (r)0,999
Slope1,027 (1,019 to 1,035)1,023 (1,012 to 1,034)1,000 (1,000 to 1,026)
vintercept-0,265 (-0,325 to -0,204)-0,235 (-0,312 to -0,158)-0,100 (-0,248 to -0,039)
Average bias (all samples)-0,07 (-0,08 to -0,05)
Bias at normal range (6,5 %)-0.09 (-0.11 to -0.07)-0,09 (-0,10 to -0,07)-0,10 (-0,10 to -0,04)

The unit of the bias is the same of the result provided (%)

f. Total Error Calculations

Total error (TE) is calculated for 4 concentrations, corresponding to the concentrations of the samples used in the reproducibility study, (5.1 %, 6.4 %, 8.2 % and 12.2 %) using the results of bias estimation (%Bias) and coefficients of variation (CV).

Total Error is calculated as follows: Total Error is calculated as follows: %TE= (%Bias)+ 1.96 x %CV×(1+%Bias/100)

The results are presented in the following table for the CAPILLARYS Hb A1c using the CAPILLARYS 2 FLEX-PIERCING instrument:

HbA1c results given as a NGSP unit (%)

Linear equationregressionTarget (%)y from linearequationDeviation fromtarget%BiasCV (%)TE (%)Specification
y = 1,027 x -0,2655,15,0-0,1-2,471,85,9≤ 6,0%
6,46,3-0,1-1,421,44,1
8,28,20,0-0,511,22,8
12,212,30,10,551,33,1

Total Error is calculated as follows: %TE= 1%Bias + 1.96 x %CV×(1+%Bias/100)

g. Interferences

Interference studies were performed per CLSI EP07-A2, Interference Testing in Clinical Chemistry. Each study was performed using 2 different whole blood samples: a blood sample close to the cut-off value and a blood sample with elevated HbA1c level. Ten replicates were analyzed using the CAPILLARYS Hb A1c on the CAPILLARYS 2 FLEX-PIERCING testing system.

{14}------------------------------------------------

No interference with the CAPILLARYS Hb A1c procedure was detected due to the blood sample's high concentration of the following interfering factors tested at levels equal to the concentrations listed below:

Endogenous interferingfactorConcentration
Conjugated bilirubin60 mg/dL
Unconjugated bilirubin60 mg/dL
D-glucose1000 mg/dL (55 mM)
Rheumatoid factor1076 IU/mL
Total Protein149,5 g/L
Triglycerides2,89 g/dL (33,1 mM)
Urea265 mg/dL (44,2 mM)
DrugConcentration
Acetaminophen200 mg/L (1325 μΜ)
Acetylcysteine200 mg/dL (12,3 mM)
Acetylsalicilyc acid1000 mg/dL (55,56 mM)
Ampicillin-Na1000 mg/dL (28653 μΜ)
Ascorbic acid300 mg/dL (17045 μΜ)
Cefoxitin2500 mg/dL (58548 μΜ)
Cyclosporine5 mg/L
Doxycycline50 mg/dL (1123,6 μΜ)
Glybenclamide3 mg/dL
Heparin5000 U/L
Ibuprofen500 mg/L (2427 μΜ)
Levodopa40 mg/dL
Metformin5 mg/dL (387 μΜ)
Methyldopa40 mg/dL (1896 μΜ)
Metronidazole200 mg/dL (11696 μΜ)
Phenylbutazone400 mg/L
Rifampicin70 mg/L (85,1 μΜ)
Theophylline100 mg/L (556 μΜ)
Hemoglobin Derivatives andcross reactantsConcentrations
Carbamylated Hemoglobin≤ 8.1 mg/mL
HbA1a+b≤ 0.20 mg/mL
Labile HbA1c≤ 19.7 mg/mL
Acetylated hemoglobin≤ 4.2 mg/mL

{15}------------------------------------------------

Glycated Albumin≤ 2.2 mg/mL
-------------------------------

Hemoglobin Variant Study was performed using specific samples known to contain hemoglobin variants S. C. E. D. A2 and F. The samples were analyzed with a reference method performed in a NGSP laboratory (reference) and with CAPILLARYS Hb A1c procedure on CAPILLARYS 2 FLEX-PIERCING instrument (test): percentages of HbA1c fraction. The relative deviation (%) between the reference procedure and the test procedure has been calculated for each sample (see the following tables).

HemoglobinVariantsNo.ofSamplesRanges in %VariantRange of % HbA1cConcentration
Hb A2204.0-7.74.5-11.0
Hb F201.5-31.44.9-15.1
Hb S2033.0-40.84.9-14.0
Hb C2028.0-37.24.6-13.1
Hb D2135.5-41.35.2-11.8
Hb E2221.3-37.04.8-9.8
Hemoglobin fractionMean relative % Bias (Range of relative % Bias)
~ 6,5 % Hb A1c~ 9,0 % Hb A1c
Hb S0,8 (0,0 to 1,6)0,4 (-3,1 to 3,2)
Hb C0,0 (0,0 to 0,0)3,3 (1,0 to 5,7)
Hb D0,5 (-1,4 to 1,6)-1,9 (-2,4 to -1,2)
Hb E-0,4 (-3,3 to 1,5)-0,3 (-3,7 to 2,1)
Hb A2-3,4 (-4,5 to -1,4)-0,8 (-2,0 to 0,0)
Hb F-3,3 (-4,8 to -1,6)-2,0 (-5,0 to 0,0)
  • Levels of Hb F up to 23 % in the blood sample do not interfere with HbA1c fraction quantification, a result is reported by the software when the Hb F level is higher than 23 % along with a warning message "Atypical profile – Possible quantitative interference if Hb F or variant > 23 %". It is recommended to analyze the sample with CAPILLARYS HEMOGLOBIN(E) procedure to verity the Hb F percentage and to study the patient's clinical data.

  • Levels of Hb A2 up to 7.7 % in the blood sample do not interfere with HbA1c fraction quantification.

  • No interference has been observed with HbA1c fraction quantification due to the presence of major abnormal hemoglobins Hb S (≤ 40.8 %), Hb C (≤ 37.2 %), Hb D (≤ 41.3 %) and Hb E (≤ 37.0 %).

{16}------------------------------------------------

h. Expected Values/ Reference Range

Hemoglobin A1c expected value range was cited from the American Diabetes Association (Standards of Medical Care in Diabetes 2016, 39 (Suppl 1)

The American Diabetes Association's (ADA) most recent Clinical Practice are:

CategoryHbA1c Range (IFCC)HbA1c Range (NGSP/DCCT)
Normal< 39 mmol/mol< 5.7 %
Prediabetes (increased risk fordiabetes)39 mmol/mol - 47 mmol/mol5.7 % - 6.4 %
Diabetes≥ 48 mmol/mol≥ 6.5 %

The expected HbA1c range for non-diabetic adults is 20 - 42 mmol/mol or 4.0 - 6.0 %. However, each laboratory should establish its reference range and HbA1c goal following state and federal regulations and taking into account sex, age, ethnicity and individual patient situation.

YES OR NORequirement
YESDevice must have initial and annual standardization verification bycertifying glycohemoglobin standardization organization deemedacceptable by FDA
YESPerformance testing of device precision must, at a minimum use bloodsamples with concentrations near 5.0%, 6.5%, 8.0% and 12 %hemoglobin A1c. Testing must evaluate precision over a minimum of20 days using at least 3 lots of the device and instruments, asapplicable
YESPerformance testing of accuracy must include a minimum of 120blood samples that span the measuring interval of the new deviceand compare results of the new device to results of the standardizedmethod. Results must demonstrate little or no bias versus thestandardized method.
YESTotal error of the new device must be evaluated using singlemeasurements by the new device compared to the results of thestandardized test method, and this evaluation must demonstrate atotal error of less than or equal to 6%
YESPerformance testing must demonstrate that there is little to nointerference from common hemoglobin variants, includingHemoglobin C, Hemoglobin D, Hemoglobin E, Hemoglobin A2 andHemoglobin S.
NAWhen assay interference from Hemoglobin F or interference with otherhemoglobin variants with low frequency in the population is observed,a warning statement must be placed in a black box and must appearin all the labeling material for these devices describing the interferenceand any affected population.

5. Requirements for Diabetes Diagnosis Claim

{17}------------------------------------------------

6. Conclusion:

The submitted information in this premarket notification is complete and supports a substantial equivalence decision.

§ 862.1373 Hemoglobin A1c test system.

(a)
Identification. A hemoglobin A1c test system is a device used to measure the percentage concentration of hemoglobin A1c in blood. Measurement of hemoglobin A1c is used as an aid in the diagnosis of diabetes mellitus and as an aid in the identification of patients at risk for developing diabetes mellitus.(b)
Classification. Class II (special controls). The special controls for this device are:(1) The device must have initial and annual standardization verification by a certifying glycohemoglobin standardization organization deemed acceptable by FDA.
(2) The premarket notification submission must include performance testing to evaluate precision, accuracy, linearity, and interference, including the following:
(i) Performance testing of device precision must, at a minimum, use blood samples with concentrations near 5.0 percent, 6.5 percent, 8.0 percent, and 12 percent hemoglobin A1c. This testing must evaluate precision over a minimum of 20 days using at least three lots of the device and three instruments, as applicable.
(ii) Performance testing of device accuracy must include a minimum of 120 blood samples that span the measuring interval of the device and compare results of the new device to results of a standardized test method. Results must demonstrate little or no bias versus the standardized method.
(iii) Total error of the new device must be evaluated using single measurements by the new device compared to results of the standardized test method, and this evaluation must demonstrate a total error less than or equal to 6 percent.
(iv) Performance testing must demonstrate that there is little to no interference from common hemoglobin variants, including Hemoglobin C, Hemoglobin D, Hemoglobin E, Hemoglobin A2, and Hemoglobin S.
(3) When assay interference from Hemoglobin F or interference with other hemoglobin variants with low frequency in the population is observed, a warning statement must be placed in a black box and must appear in all labeling material for these devices describing the interference and any affected populations.