K Number
K173345
Date Cleared
2018-05-04

(192 days)

Product Code
Regulation Number
862.1435
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The TD-4140 Smart Dongle Blood Glucose plus [-ketone Monitoring System consists of the Smart Dongle blood glucose test strips, Smart Dongle {}-ketone test strips, and the Procheck mobile application as the display component of the system. This system is intended to be used for the quantitative measurement of glucose (sugar) and fketone in fresh capillary whole blood from the finger.

This system is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. This system should not be used for the diagnosis of or screening for diabetes, nor for use on neonates.

Device Description

The TD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System consists of the Smart Dongle meter, Smart Dongle blood glucose test strips, Smart Dongle 0-ketone test strips, and the Procheck mobile application as the display component of the system.

This system is compatible to iPhone series, including iPhone 4/4s, 5/5s, 6/6 plus, and iPod touch 5. These products have been designed, tested, and proven to work together as a system to produce accurate test results. The Smart Dongle meter should only be used with the Smart Dongle Blood Glucose test strips and the Smart Dongle ß-ketone test strips.

AI/ML Overview

The provided text describes the TD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System, but only offers limited information on specific acceptance criteria for blood glucose and ß-ketone measurements. It reports accuracy and precision performance. The study described is a submission for 510(k) clearance, which typically involves demonstrating substantial equivalence to a predicate device through various performance characteristics, not necessarily a comparative effectiveness study with human readers.

Here's a breakdown of the available information:

1. Table of Acceptance Criteria and Reported Device Performance

Note: The document does not explicitly state "acceptance criteria" but rather presents performance results against implicit standards for glucose and ß-ketone meters. The ranges below are derived from the reported accuracy tables for blood glucose and ß-ketone.

Measurement ParameterAcceptance Criteria (Implied from Performance Tables)Reported Device Performance
Blood Glucose
Accuracy:For glucose < 75 mg/dL: - Within 5 mg/dL (target of 100%) - Within 10 mg/dL (target of 100%) - Within 15 mg/dL (target of 100%)Glucose < 75 mg/dL (N=78): - Within 5 mg/dL: 57 (73.1%) - Within 10 mg/dL: 78 (100%) - Within 15 mg/dL: 78 (100%) Glucose ≥ 75 mg/dL (N=402): - Within 5%: 272 (67.7%) - Within 10%: 386 (96.0%) - Within 15%: 402 (100%) - Within 20%: 402 (100%) (This implies stricter criteria are being met fully)
For glucose ≥ 75 mg/dL: - Within 5% (target of 100%) - Within 10% (target of 100%) - Within 15% (target of 100%) - Within 20% (target of 100%)Intermediate Precision (Blood Glucose): - Level 1 (49.6 mg/dL): CV 4.38%- Level 2 (139.4 mg/dL): CV 3.13%- Level 3 (335.4 mg/dL): CV 3.01%Repeatability (Blood Samples - Glucose): - Level 1 (49.7 mg/dL): CV 4.39%- Level 2 (91.2 mg/dL): CV 3.23%- Level 3 (128.3 mg/dL): CV 3.16%- Level 4 (227.8 mg/dL): CV 3.15%- Level 5 (390.2 mg/dL): CV 3.09%
Precision (CV%)(Generally, CV% < 5% for glucose measurements is considered good, but specific criteria are not stated)
ß-ketone
Accuracy:For ketone < 2 mmol/L: - Within ±0.3 mmol/L (target of 100%) - Within ±0.5 mmol/L (target of 100%)Ketone < 2 mmol/L (N=89): - Within ±0.3 mmol/L: 84 (94.4%) - Within ±0.5 mmol/L: 89 (100%) Ketone ≥ 2 mmol/L (N=31): - Within 5%: 14 (45.2%) - Within 10%: 26 (83.9%) - Within 15%: 29 (93.5%) - Within 20%: 31 (100%) - Within 25%: 31 (100%) (This implies stricter criteria are being met fully)
For ketone ≥ 2 mmol/L: - Within 5% (target of 100%) - Within 10% (target of 100%) - Within 15% (target of 100%) - Within 20% (target of 100%) - Within 25% (target of 100%)Repeatability Precision (ß-ketone - Venous Blood): - Level 1 (0.520 mmol/L): CV 10.59%- Level 2 (2.887 mmol/L): CV 3.12%- Level 3 (5.030 mmol/L): CV 3.05%Intermediate Precision (ß-ketone - Control Solution): - Level 1 (0.593 mmol/L): CV 6.15%- Level 2 (2.583 mmol/L): CV 2.71%
Precision (CV%)(Generally, CV% < 10% for ketone measurements is often a benchmark, but specific criteria are not stated)

2. Sample Sizes Used for the Test Set and Data Provenance

  • Blood Glucose Accuracy:
    • For glucose < 75 mg/dL: N = 78
    • For glucose ≥ 75 mg/dL: N = 402
    • Total N for glucose accuracy: 480
  • ß-ketone Accuracy: N = 120 (capillary blood sampling subjects)
    • Ketone < 2 mmol/L: N = 89
    • Ketone ≥ 2 mmol/L: N = 31
  • Precision Tests (Glucose & ß-ketone): The document doesn't specify the exact number of samples or subjects for precision tests, only the "levels" of control solutions/blood samples tested.
  • Data Provenance: Not specified. The document states the applicant company is in Taiwan, but it does not specify the country of origin for the clinical study data or whether it was retrospective or prospective.

3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

Not specified. The document describes electrochemical biosensor technology being used, and the "ground truth" for glucose and ß-ketone measurements would typically be established by a reference laboratory method (e.g., YSI for glucose, or a high-performance liquid chromatography (HPLC) method for ketones), not by human experts for this type of quantitative measurement.

4. Adjudication Method

Not applicable. For quantitative measurements by a device, ground truth is typically established by laboratory reference methods, not by expert adjudication.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

No. This document does not mention an MRMC comparative effectiveness study. This type of study is more common for diagnostic imaging or interpretation tasks, not for quantitative blood glucose and ß-ketone monitoring systems. The study presented focuses on the device's standalone analytical performance and substantially equivalence to a predicate device.

6. Standalone Performance

Yes, the studies reported are standalone performance studies of the algorithm/device. The tables provided show the accuracy and precision of the TD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System relative to reference measurements, without human intervention in the measurement process. The mobile application acts as a display component, but the core measurement and algorithmic analysis for glucose and ß-ketone are intrinsic to the dongle and test strips.

7. Type of Ground Truth Used

The ground truth for both glucose and ß-ketone measurements is implied to be based on laboratory reference methods. The document states, "The test strip is calibrated to display the equivalent of plasma glucose values to allow comparison of results with laboratory methods," strongly suggesting that such methods were used as the gold standard for comparison in accuracy studies.

8. Sample Size for the Training Set

Not specified. The document focuses on performance studies for regulatory submission (510(k)) and does not detail the internal development and training of any algorithms within the device. For electrochemical biosensors, "training" might refer to the calibration of the strips and meter rather than machine learning algorithm training.

9. How the Ground Truth for the Training Set Was Established

Not specified. As mentioned above, the concept of a "training set" and "ground truth establishment" in the context of machine learning is not explicitly addressed in this document. If algorithmic calibration was involved, it would likely use well-characterized reference solutions and laboratory methods, similar to the ground truth used for validation.

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May 4, 2018

TaiDoc Technology Corporation Anne Kuo Regulatory Affairs Specialist B1-7F, No. 127, Wugong 2nd Rd., Wugu District New Taipei City, 24888 Taiwan

Re: K173345

Trade/Device Name: TD-4140 Smart Dongle Blood Glucose plus B-ketone Monitoring System Regulation Number: 21 CFR 862.1435 Regulation Name: Ketones (nonquantitative) test system Regulatory Class: Class I, meets the limitation of exemptions 21 CFR 862.9(c)(5) Product Code: JIN Dated: March 31, 2018 Received: April 4, 2018

Dear Anne Kuo:

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 medical devices and radiation-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. Kelm -S

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) K173345

Device Name

TD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System

Indications for Use (Describe)

The TD-4140 Smart Dongle Blood Glucose plus [-ketone Monitoring System consists of the Smart Dongle blood glucose test strips, Smart Dongle {}-ketone test strips, and the Procheck mobile application as the display component of the system. This system is intended to be used for the quantitative measurement of glucose (sugar) and fketone in fresh capillary whole blood from the finger.

This system is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. This system should not be used for the diagnosis of or screening for diabetes, nor for use on neonates.

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

Prescription Use (Part 21 CFR 801 Subpart D)

|X | Over-The-Counter Use (21 CFR 801 Subpart C)

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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 21 CFR 807.92.

The Assigned 510(k) number is: K173345

1. Applicant Information

CompanyTaiDoc Technology Corporation
Contact PersonAnne Kuo
TitleRegulatory Affairs Specialist
Address6F, No. 127, Wugong 2nd Rd., Wugu District, New Taipei City 24888, Taiwan
Phone+886-2-6625-8188 #1195
Fax+886-2-6625-0288
E-mail addressra.cert@taidoc.com.tw / anne.kuo@taidoc.com.tw

2. Device name

Proprietary NameTD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System
Common Nameß-Ketone monitoring system
Product CodeJIN, Nitroprusside, Ketones (Urinary, Non-Quant.)
ClassificationClinical chemistry
PanelJIN: Class I
Classification21 CFR §862.1435 Ketones (nonquantitative) test system
Regulation CitationMeets limitations of exemptions 21 CFR 862.9(c)(5)

3. Predicate Device

K161738FORA ADVANCED GD40 Blood Glucose and β-Ketone Monitoring System
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Intended Use 4.

The TD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System consists of the Smart Dongle meter, Smart Dongle blood glucose test strips, Smart Dongle ß-ketone test strips, and the Procheck mobile application as the display component of the system is intended to be used for the quantitative measurement of glucose (sugar) and ß-ketone in fresh capillary whole blood from the finger.

This system is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. This system should not be used for the diagnosis of or screening for diabetes, nor for use on neonates.

Device Description 5.

The TD-4140 Smart Dongle Blood Glucose plus ß-ketone Monitoring System consists of the Smart Dongle meter, Smart Dongle blood glucose test strips, Smart Dongle 0-ketone test strips, and the Procheck mobile application as the display component of the system.

This system is compatible to iPhone series, including iPhone 4/4s, 5/5s, 6/6 plus, and iPod touch 5. These products have been designed, tested, and proven to work together as a system to produce accurate test results. The Smart Dongle meter should only be used with the Smart Dongle Blood Glucose test strips and the Smart Dongle ß-ketone test strips.

ItemPredicate deviceProposed device
510(k) no.K161738-
Proprietary nameFORA ADVANCED GD40 BloodGlucose and β-Ketone MonitoringSystemTD-4140 Smart Dongle BloodGlucose plus β-ketone MonitoringSystem
Intended useQuantitative measurement ofglucose and β-ketone in freshcapillary whole blood from thefinger by people with diabetes athome as an aid to monitor theeffectiveness of diabetes control.Quantitative measurement ofglucose and β-ketone in freshcapillary whole blood from thefinger by people with diabetes athome as an aid to monitor theeffectiveness of diabetes control.
For single person use and should notFor single person use and should not
ItemPredicate deviceProposed device
510(k) no.K161738-
be shared. Not be used for thediagnosis of or screening fordiabetes, nor for use on neonates.be shared. Not be used for thediagnosis of or screening fordiabetes, nor for use on neonates.
Glucose
Glucose assay methodGlucose dehydrogenaseSame as predicate
Glucose measuring range20 ~ 600 mg/dLSame as predicate
Sample typeCapillary finger stickSame as predicate
Sample size0.9 uL1.0 uL
Hematocrit range20% ~ 70%Same as predicate
Analysis time5 secondsSame as predicate
CodingCode CardNo coding
Ketone
Assay methodẞ-hydroxybutyrate dehydrogenaseSame as predicate
Measuring range0.1 ~ 8.0 mmol/LSame as predicate
Sample typeCapillary finger stickSame as predicate
Ketone sample size1.0 uLSame as predicate
Hematocrit range20% ~ 70%Same as predicate
Analysis time10 secondsSame as predicate
CodingCode cardSame as predicate
Operating conditions10 °C -40 °C, 10% - 90% R.H.10 °C -40 °C, 10% - 85% R.H.
Power sourceAAA x 2Powered by mobile platform
LCDDisplayed on mobile platform:
iPhone 4, iPhone 4s, iPhone 5,
DisplayiPhone 5s, iPhone 6, iPhone 6 plus,
iPhone 6s, iPhone 6s plus and iPod
touch 5th generation
Data storage1000 sets1 set (latest result)
All data stored in the mobile device
Data transmissionRS-232 4 PolesHeadphone jack

Comparison to the Predicate 6.

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www.taidoc.com

新北市24888五股區五工二路127號6樓 6F., No.127, Wugong 2nd Rd., Wugu Dist., New Taipei City 24888, Taiwan

7. Test Principle

Glucose measurement is based on electrochemical biosensor technology using the enzyme Glucose Dehydrogenase to catalyze the formation of gluconolactone from the oxidation of glucose whereby two electrons are produced. The electrical current resulting from this enzymatic reaction is measured and correlated to glucose concentration by the meter. The magnitude of the current is proportional to the

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泰博科技股份有限公司 TaiDoc Technology Corp.

concentration of glucose in the sample. The test strip is calibrated to display the equivalent of plasma glucose values to allow comparison of results with laboratory methods.

Using the same technology, B-hydroxybutyrate (β-ketone) is converted by β-hydroxybutyrate dehydrogenase and the magnitude of electrical current resulting from this enzymatic reaction is proportional to the amount of ß-hydroxybutyrate present in the sample.

The measurement result is transmitted to a compatible device via headphone jack. The App within this system is used for analysis and storage of the data for personal healthcare.

Performance Characteristics 8.

Clinical and non-clinical studies were conducted to test, verify and validate with respect to the predicate device to establish the performance of this system. The data demonstrates that this system is substantially equivalent to the predicate device.

Accuracy – blood glucose

Results for glucoseconcentration< 75 mg/dLWithin 5 mg/dLWithin 10 mg/dLWithin 15 mg/dL
57 (73.1%)78 (100%)78 (100%)
Results for glucoseconcentration≥ 75 mg/dLWithin 5%Within 10 %Within 15 %Within 20 %
272 (67.7%)386 (96.0%)402 (100%)402 (100%)

Precision – blood glucose

Intermediate precision

Control solutionsLevel 1Level 2Level 3
Mean (mg/dL)49.6139.4335.4
SD (mg/dL)2.174.3710.10
CV (%)4.38%3.13%3.01%

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新北市24888五股區五工二路127號6樓 6F., No.127, Wugong 2nd Rd., Wugu Dist., New Tainei City 24888. Taiwar

Repeatability

Blood samplesLevel 1Level 2Level 3Level 4Level 5
Mean (mg/dL)49.791.2128.3227.8390.2
SD (mg/dL)2.182.954.067.1812.06
CV (%)4.39%3.23%3.16%3.15%3.09%

Accuracy – β-ketone

Test results of the test device fulfilling specified error limits
(Capillary blood sampling subjects N=120)
nWithin ±0.3 mmol/LWithin ±0.5 mmol/L
At ketone value< 2 mmol/L8984(94.4%)89(100%)
At ketone value≥ 2 mmol/L31nWithin 5%
Within 10%Within 15%
Within 20%Within 25%
14(45.2%)26(83.9%)
29(93.5%)31(100%)
31(100%)

Precision – β-ketone

Repeatability precision: The test was performed with venous blood sample that contained three different levels of ß-ketone.

Ketone LevelOverall Mean (mmol/L)SD (mmol/L)CV (%)
Level 10.5200.05510.59
Level 22.8870.0903.12
Level 35.0300.1533.05

Intermediate precision: The test was performed with two levels of ß-ketone control solution.

Control solutionsOverall Mean (mmol/L)SD (mmol/L)CV (%)
Level 10.5930.0376.15
Level 22.5830.0702.71

The ß-ketone test strip shows acceptable precision and no variation among lots.

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Linearity/assay reportable range

The linearity of a blood ß-Ketone system is the degree to which its results (y-axis) form a straight line when plotted against the defined concentrations of samples (x-axis). The reportable range of a system may be established by demonstrating the linearity of its results with samples of known ß-Ketone concentration. The system was validated when ß-Ketone concentrations are (<0.1 mmol/L) and (>8.0mmol/L) displaying "Lo" and "Hi" symbol respectively. The system shows a high linearity over a blood ß-Ketone range of 0.1 to 8.0 mmol/L.

Analytical specificity

Seventy-eight potential interfering substances consisting of exogenous substances originating from outside the body such as therapeutic agents or vitamins) of the most commonly used critical care drugs and endogenous substances (substances produced or originating from with the body) were chosen.

SubstanceHighest concentrationtested at which nosignificant interferenceis observed (mg/dL)SubstanceHighest concentrationtested at which nosignificant interference isobserved (mg/dL)
Acetylsalicylic Acid50Lactitol1000
Acetoacetate20Lidocaine6
Acetone70Magnesium5 mM
Acyclovir3.1Maltitol1000
Allopurinol5Maltose1000
Amitriptylline0.27Mannitol1000
Amoxicillin12.5Metaproterenol1.81
Ampicillin5Metformin HCl50
Aspirin(Salicylic Acid)60Metoprolol0.3
Atenolol10Naproxen100
Bicarbonate336 (40 mM)Nifedipine0.17
Bile Acids6Nortriptyline0.15
  • . The following table lists the concentrations of substances at which no significant interference is observed.

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www.taidoc.com

新北市24888五股區五工二路127號6樓 6F., No.127, Wugong 2nd Rd., Wugu Dist., New Taipei City 24888, Taiwan

(Cholic Acid)
Caffeine10Penicillin12
Calcium5 mMPhenytoin10
Chloride140 mMPiroxicam5
Clonidine2Potassium10 mM
Creatinine5Sodium200 mM
Digoxin0.16Sorbitol1000
Diphenhydramine1Sulfamethoxazole120
Enalapril0.15Sulfate5 mM
Erythromycin20Terfenadine0.45
Ephedrine Hcl60Tetracycline4
Erythromycin20Theophylline25
Estrone0.1Tolbutamide64
Famotidine0.13Total Protein(gamma-Globulin)12000
Fluoxetine0.8Urea600
Fructose1000Vancomycin25
Furosemide2Verapamil0.45
Glyburide1.07Vitamin E20
Ibuprofen55Warfarin2
Isomalt1000Xylitol1000
Lactose1000Xylose1000

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泰博科技股份有限公司 TaiDoc Technology Corp.

www.taidoc.com

  • The following table lists the concentrations of substances at which interference was greater than ● ±10%.
SubstanceLowest Concentrationabove whichinterference >10% isobserved (mg/dL)SubstanceLowest Concentrationabove which interference>10% is observed(mg/dL)
Captopril>500Unconjugated bilirubin>20
Ascorbic acid> 4Cholesterol>500
Dopamine> 0.09Triglycerides(Lipemic Sample)>1500
Levo – Dopa> 0.6Galactose>13.87 mmol/L
Gentisic Acid>1.8Methyl-DOPA>59.18
Paracetamol>25Tolazamide> 321
Uric acid>24N-Acetylcysteine>0.038

9. Conclusion

Based on the information provided in this submission, the TD-4140 Smart Dongle Blood Glucose plus β-ketone Monitoring System is substantially equivalent to the predicate device, FORA ADVANCED GD40 Blood Glucose and ß-Ketone Monitoring System (K161738).

§ 862.1435 Ketones (nonquantitative) test system.

(a)
Identification. A ketones (nonquantitative) test system is a device intended to identify ketones in urine and other body fluids. Identification of ketones is used in the diagnosis and treatment of acidosis (a condition characterized by abnormally high acidity of body fluids) or ketosis (a condition characterized by increased production of ketone bodies such as acetone) and for monitoring patients on ketogenic diets and patients with diabetes.(b)
Classification. Class I (general controls). The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to § 862.9.