K Number
K182593
Device Name
KET-1 Blood Ketone Monitoring System
Date Cleared
2018-12-18

(89 days)

Product Code
Regulation Number
862.1435
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
KET-1 System: The KET-1 Blood Ketone Monitoring System is intended to quantitatively measure $\beta$ -hydroxybutyrate ( $\beta$ -ketone) in fresh capillary whole blood from fingertips. It should only be used by a single patient and it should not be shared. Testing is done outside the body (In Vitro diagnostic use). It is intended for self-testing by people with diabetes at home as an aid to monitoring the effectiveness of diabetes control programs. It is not to be used for diagnosis or screening of diabetes, or for neonatal use. The KET-1 Blood Ketone Monitoring System is comprised of the KET-1 Blood Ketone Meter and KET-1 Blood Ketone Test Strip.
Device Description
The KET-1 Blood Ketone Monitoring System consists of the KET-1 Blood Ketone Meter, KET-1 Blood Ketone Test Strips, and KET-1 Ketone Control Solutions (Level 1 and Level 2). The system is for self-testing of blood ketone. The KET-1 Blood Ketone Test Strips and KET-1 Ketone Control Solutions are purchased separately.
More Information

Not Found

No
The summary describes a standard blood ketone monitoring system using a meter and test strips, with no mention of AI or ML in the device description, intended use, or performance studies.

No

Explanation: The device is an in vitro diagnostic (IVD) device used to monitor blood ketone levels, not to treat or alleviate a medical condition.

No

The "Intended Use / Indications for Use" explicitly states: "It is not to be used for diagnosis or screening of diabetes, or for neonatal use."

No

The device description explicitly states the system consists of a "KET-1 Blood Ketone Meter" and "KET-1 Blood Ketone Test Strips," which are hardware components.

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

The "Intended Use / Indications for Use" section explicitly states: "Testing is done outside the body (In Vitro diagnostic use)."

N/A

Intended Use / Indications for Use

The KET-1 Blood Ketone Monitoring System is intended to quantitatively measure beta-hydroxybutyrate (beta-ketone) in fresh capillary whole blood from fingertips. It should only be used by a single patient and it should not be shared. Testing is done outside the body (In Vitro diagnostic use). It is intended for self-testing by people with diabetes at home as an aid to monitoring the effectiveness of diabetes control programs. It is not to be used for diagnosis or screening of diabetes, or for neonatal use.
The KET-1 Blood Ketone Monitoring System is comprised of the KET-1 Blood Ketone Meter and KET-1 Blood Ketone Test Strip.

Product codes

JIN

Device Description

The KET-1 Blood Ketone Monitoring System consists of the KET-1 Blood Ketone Meter, KET-1 Blood Ketone Test Strips, and KET-1 Ketone Control Solutions (Level 1 and Level 2). The system is for self-testing of blood ketone. The KET-1 Blood Ketone Test Strips and KET-1 Ketone Control Solutions are purchased separately.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Fingertips (capillary whole blood)

Indicated Patient Age Range

Not Found (explicitly states "not to be used for ... neonatal use.")

Intended User / Care Setting

self-testing by people with diabetes at home

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-Clinical Testing:
Testing was conducted as follows: EMC and Electrical Safety, disinfection performance (robustness of meter to multiple cleanings and disinfections), software verification and validation, linearity testing with validation of Lo/Hi detection, temperature and humidity testing, sample volume verification, precision testing, repeatability testing, interferences testing, altitude testing, qualification of control solutions, hematocrit performance testing, results demonstrate substantial equivalence to the predicate system.

Clinical Testing:
An accuracy study was conducted with home users using finger capillary whole blood. Results demonstrate substantial equivalence to the predicate system.

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

Not Found

Predicate Device(s)

Nova Max Plus Blood Glucose and beta-ketone Monitor System (K091547)

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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.

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

December 18, 2018

Apex Biotechnology Corp. Lisa Liu Manager of Quality Assurance Division No. 7, Li-Hsin Road V, Hsinchu Science Park Hsinchu. 30078 Taiwan

Re: K182593

Trade/Device Name: KET-1 Blood Ketone Monitoring System Regulation Number: 21 CFR 862.1435 Regulation Name: Ketones (nonquantitative) test system Regulatory Class: Class I, meets the limitation of exemption 21 CFR 862.9(c)(5) Product Code: JIN Dated: September 13, 2018 Received: September 20, 2018

Dear Lisa Liu:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.

1

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) for devices or post marketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 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. k

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

2

| Food and Drug Administration
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|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------|
| 510(k) Number (if known
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| KET-1 Blood Ketone Monitoring System
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9 510(k) Summary

510(k) numberK182593
Submitter:Apex Biotechnology Corp.
No. 7, Li-Hsin Road V, Hsinchu Science Park
Hsinchu, 30078
CHINA (TAIWAN)
Contact Person:Lisa Liu
Manager of Quality Assurance Division
Apex Biotechnology Corp.
No. 7, Li-Hsin Road V, Hsinchu Science Park
Hsinchu, 30078
CHINA (TAIWAN)
email: lisaliu@apexbio.com
Phone: 011-886-3-5641952
FAX: 011-886-3-5678021
Date Prepared:December 05, 2018
Trade Names:KET-1 Blood Ketone Monitoring System
Classification:Ketones (nonquantitative) test system, 21 CFR 862.1435, Class I, meets
limitation of exemptions 21 CFR 862.9(c)(5)
Product Codes:JIN
Predicate Devices:Nova Max Plus Blood Glucose and β-ketone Monitor System (K091547)
Device Description:The KET-1 Blood Ketone Monitoring System consists of the KET-1
Blood Ketone Meter, KET-1 Blood Ketone Test Strips, and KET-1
Ketone Control Solutions (Level 1 and Level 2). The system is for
self-testing of blood ketone. The KET-1 Blood Ketone Test Strips and
KET-1 Ketone Control Solutions are purchased separately.
Intended Use:KET-1 System: The KET-1 Blood Ketone Monitoring System is intended
to quantitatively measure $\beta$ -hydroxybutyrate ( $\beta$ -ketone) in fresh capillary
whole blood from fingertips. It should only be used by a single patient and it
should not be shared. Testing is done outside the body (In Vitro diagnostic
use). It is intended for self-testing by people with diabetes at home as an aid to
monitoring the effectiveness of diabetes control programs. It is not to be used
for diagnosis or screening of diabetes, or for neonatal use.
The KET-1 Blood Ketone Monitoring System is comprised of the KET-1
Blood Ketone Meter and KET-1 Blood Ketone Test Strip.
Comparison of
Technological
Characteristics:The $\beta$ -ketone ( $\beta$ -Hydroxybutyrate) measurement is based on amperometric
biosensor technology using the enzyme $\beta$ -hydroxybutyrate dehydrogenase. The
enzyme reacts with $\beta$ -Hydroxybutyrate in blood and produces electrical current
that the magnitude of electrical current resulting from this enzymatic reaction is
proportional to the amount of $\beta$ -hydroxybutyrate. The meter measures the
electrical current and displays the concentration of $\beta$ -Hydroxybutyrate in blood.

The technological characteristics of KET-1 Blood Ketone Monitoring
System are substantially equivalent to the predicate system (K091547). |
| Non-Clinical
Testing: | Testing was conducted as follows: EMC and Electrical Safety, disinfection
performance (robustness of meter to multiple cleanings and disinfections),
software verification and validation, linearity testing with validation of Lo/Hi
detection, temperature and humidity testing, sample volume verification,
precision testing, repeatability testing, interferences testing, altitude testing,
qualification of control solutions, hematocrit performance testing, results
demonstrate substantial equivalence to the predicate system. |
| Clinical Testing | An accuracy study was conducted with home users using finger capillary
whole blood. Results demonstrate substantial equivalence to the predicate
system. |
| Conclusion: | Clinical and non-clinical testing demonstrated that the KET-1 Blood Ketone
Monitoring Systems perform in a substantially equivalent manner to that of
the predicate. We conclude that the KET-1 Blood Ketone Monitoring
Systems is substantially equivalent to the predicate system |

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510(k) Summary (Continued)