K Number
K200986
Device Name
OPTI® B-Lac Cassette
Date Cleared
2021-08-02

(474 days)

Product Code
Regulation Number
862.1120
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The OPTI® B-Lac cassette is intended to be used for the in vitro measurement of pH, PO2, total hemoglobin (tHb), and % Saturated O2 in sodium heparinized venous blood samples on the OPTI CCA-TS and OPTI CCA-TS2 platform in a clinical laboratory location. · Measurements of blood gases (pCO2, pO2) and blood pH are used in the diagnosis and treatment of life-threatening acid-base disturbances. - · Total hemoglobin (tHb) measurement is used to determine the hemoglobin content of human blood. · Oxygen saturation (SO2) measurement is used to determine the oxygen capacity of the hemoglobin.
Device Description
The OPTI CCA-TS/TS2 are portable devices, microprocessor-based instrument using optical fluorescence for the measurement blood gases, electrolytes and enzymes. The OPTI CCA-TS/TS2 utilize a color, graphical touch screen user interface. A disposable, single-use cassette contains all of the elements needed for calibration, sample measurement, and waste containment. Specific calibration from the cassette is scanned into the analyzer by holding the cassette package in front of the bar code scanner. The cassette is then placed into the measurement chamber. The analyzer warms the cassette to 37.0±0.1°C and performs a calibration verification. When calibration is verified, the analyzer aspirates the blood sample into the cassette and across the optode sensors. Fluorescence emission is then measured after equilibrating with the blood sample. After a single measurement, the cassette containing the blood sample is removed from the analyzer and discarded. The analyzer contains no reagents, blood, or waste. The B-Lac cassette is a disposable, single use cassette that contains four (4) sensors for in vitro quantitative measurements of PO2, PCO2, pH. There is an additional laser based measurement of total hemoglobin (tHb) and SO2. The B-Lac cassette is sealed in a foil pouch along with a desiccant and is marked with a barcode label that includes a lot identification number, calibration information, and expiration date.
More Information

No
The description focuses on optical fluorescence and laser-based measurements with a microprocessor. There is no mention of AI or ML algorithms for data processing or interpretation.

No
The device is an in vitro diagnostic (IVD) device used for measuring specific analytes in blood samples to aid in diagnosis and treatment, rather than directly treating a condition.

Yes

The device measures pH, PO2, tHb, and % Saturated O2, and the "Intended Use / Indications for Use" section explicitly states that "Measurements of blood gases (pCO2, pO2) and blood pH are used in the diagnosis and treatment of life-threatening acid-base disturbances." This indicates its role in diagnosing medical conditions.

No

The device description clearly outlines a hardware instrument (OPTI CCA-TS/TS2) and a disposable hardware component (OPTI® B-Lac cassette) that perform the measurements. The software is part of the overall system but not the sole component.

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 OPTI® B-Lac cassette is intended for "in vitro measurement" of various analytes in "sodium heparinized venous blood samples." This directly aligns with the definition of an in vitro diagnostic device, which is used to examine specimens derived from the human body to provide information for diagnostic purposes.
  • Device Description: The description details a "disposable, single-use cassette" that contains "sensors for in vitro quantitative measurements" of blood gases, pH, total hemoglobin, and oxygen saturation. This further confirms its use in analyzing biological samples outside of the body.
  • Performance Studies: The "Summary of Performance Studies" describes testing performed on "whole blood samples" and "aqueous quality control solution," which are typical samples used with IVD devices.

The device is designed to analyze biological samples (blood) outside of the body to provide diagnostic information, which is the core function of an IVD.

N/A

Intended Use / Indications for Use

The OPTI O B-Lac cassette is intended to be used for the in vitro measurement of pH, PO2, total hemoglobin (tHb), and % Saturated O2 in sodium heparinized venous blood samples on the OPTI CCA-TS and OPTI CCA-TS2 platform in a clinical laboratory location.

  • Measurements of blood gases (pCO2, pO2) and blood pH are used in the diagnosis and treatment of life-threatening acid-base disturbances.
  • Total hemoglobin (tHb) measurement is used to determine the hemoglobin content of human blood.
  • Oxygen saturation (SO2) measurement is used to determine the oxygen capacity of the hemoglobin.

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

CHL, GKR, GLY

Device Description

The OPTI CCA-TS/TS2 are portable devices, microprocessor-based instrument using optical fluorescence for the measurement blood gases, electrolytes and enzymes. The OPTI CCA-TS/TS2utilize a color, graphical touch screen user interface.

A disposable, single-use cassette contains all of the elements needed for calibration, sample measurement, and waste containment. Specific calibration from the cassette is scanned into the analyzer by holding the cassette package in front of the bar code scanner. The cassette is then placed into the measurement chamber.

The analyzer warms the cassette to 37.0±0.1°C and performs a calibration verification. When calibration is verified, the analyzer aspirates the blood sample into the cassette and across the optode sensors. Fluorescence emission is then measured after equilibrating with the blood sample. After a single measurement, the cassette containing the blood sample is removed from the analyzer and discarded. The analyzer contains no reagents, blood, or waste.

No changes to the OPTI CCA-TS/TS2analyzer's hardware have been made to accommodate the addition of the parameters associated with the B-Lac cassette, thus the electromagnetic compatibility remains unchanged from prior claims of the OPTI CCA-TS. The software driving the analyzer has been updated according to internal design control and verification procedures of the Quality System at OPTI Medical Systems, Inc. to accommodate the addition of the B-Lac cassette.

The B-Lac cassette is a disposable, single use cassette that contains four (4) sensors for in vitro quantitative measurements of PO2, PCO2, pH. There is an additional laser based measurement of total hemoglobin (tHb) and SO2. The B-Lac cassette is sealed in a foil pouch along with a desiccant and is marked with a barcode label that includes a lot identification number, calibration information, and expiration date.

The B-Lac cassette uses fluorescence optodes to measure the intensity of light emitted from fluorescent dyes exposed to specific analytes. The concentration of the analyte is determined by the calculation of the difference in fluorescence measured at a defined calibration point and that measured with the unknown concentration of analyte. The principles of measurement of PO2, PCO2 and pH for the B-Lac cassette are similar to those used with existing cassette styles that are used on the OPTI CCA-TS/TS2.

Each lot of B-Lac cassettes is calibrated during the manufacturing process. The process utilizes multi-levels of high precision standard solutions spanning the operating range for pH. For O2 and CO2 the calibration parameters are determined using specially targeted calibration standards focusing on the clinically critical ranges. Every cassette package has a bar code label containing this calibration information as well as its lot number and expiration date. A onepoint calibration is performed each time a cassette is used. The B-Lac cassette uses a proprietary dry-calibration for the pH sensor. For the Blood Gas sensors PO2 and PCO2, a precision gas mixture similar to that used by conventional blood analyzers is used. The calibration for the tHb and SO2 measurements is factory set for each analyzer.

During the calibration and measurement processes, diagnostic tests are automatically performed to assure correct operation of the instrument and measurement of the cassette. These tests include automatic checks of the cassette for packaging integrity, proper cassette temperature control, and proper equilibration behavior of the sensors during calibration and measurement, automatic detection of bubbles and short sample during aspiration, and automatic detection of dirty optics.

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 location.

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)

20-Day Precision (in-house)

  • Study type: Precision study
  • Sample size: Not specified
  • Data source: Paired samples run twice daily over 20 days on three lots of B-Lac cassettes run on OPTI CCA-TS/TS2 analyzers using three levels of aqueous quality control solution.
  • Annotation protocol: Not specified
  • Key results: The precision performance for the redesigned B-Lac cassette was determined to meet the performance claims made in the original B-Lac cassette submission (K093280) for all analytes.

Within Run Precision (in-house)

  • Study type: Precision study
  • Sample size: Not specified
  • Data source: Multiple repeats on three lots of B-Lac cassettes run on OPTI CCA-TS/TS2 analyzers using three levels of aqueous quality controls and whole blood manipulated to 3 different levels.
  • Annotation protocol: Not specified
  • Key results: The precision performance for the redesigned B-Lac cassette was determined to meet the performance claims made in original B-Lac cassette submission (K093280) for all analytes.

Method Comparison - (in-house)

  • Study type: Method comparison study
  • Sample size: Not specified
  • Data source: Whole blood samples tonometered to different levels using different O2/CO2 gas mixtures to generate test levels for pH, PCO2, PO2, and SO2 and samples were manipulated to obtain test levels for tHb. The results were compared to the gravimetric target for PCO2 and PO2 based on the gas concentration and to the predicate device ABL90 Flex for pH, PCO2, PO2, and tHb and the E series cassettes on the OPTI CCA-TS/TS2 for SO2.
  • Annotation protocol: Not specified
  • Key results: The performance of the redesigned B-Lac cassette was determined to meet the performance claims included in the previous 510(K) submission K093280 for all analytes.

Method Comparison - Altitude

  • Study type: Method comparison study
  • Sample size: Not specified
  • Data source: Whole blood and ampuled aqueous control materials at various altitudes (Westbrook, Maine, USA, 75 feet; Roswell, Georgia, USA, 1080 feet; Beech Mountain, North Carolina, USA, 5560 feet; Leadville, Colorado, USA, 10151 feet). Whole blood samples were tonometered to obtain samples that span the range for PCO2, PO2, and pH, and spiked or diluted for tHb at both 1180 ft. and 10,151 ft. Aqueous solutions were measured for PCO2, pH, tHb and Saturate O2 at all sites and the results compared to the reference site in Roswell, Georgia.
  • Annotation protocol: Not specified
  • Key results: The performance of the B-Lac cassette with redesigned PCO2 sensors was demonstrated to meet the performance claims included in the previous 510(K) submission K093280 when tested with whole blood samples at 1180 feet and 10151 feet (PCO2, PO2, pH, tHb) and aqueous samples at all altitudes tested (PCO2, PO2, pH, tHb, and SO2).

Interference (in-house)

  • Study type: Interference testing
  • Sample size: Not specified
  • Data source: 16 interferents were tested for PCO2, PCO2, ph, tHb, and SO2.
  • Annotation protocol: Not specified
  • Key results: Several interferents were found for tHb and SO2, no interferents for PCO2, and only one interferent for PO2 and pH.

Stability (in-house)

  • Study type: Stability testing
  • Sample size: Three Lots of B-Lac cassettes
  • Data source: One Lot was subjected to two cycles of elevated and frozen temperatures. Aqueous control data.
  • Annotation protocol: Not specified
  • Key results: Performance of the B-Lac cassette has been demonstrated to meet the performance claims for up to 6 months shelf life. Real time testing will continue for 13 months to demonstrate that the shelf life for the new cassette is equivalent to the shelf life (12 mos.) for the B-Lac cassette included in the previous 510(K) submission K093280.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

Instrumentation Laboratory GEM Premier 4000

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Radiometer ABL90 Flex (K092686), OPTI CCA TS2 E-Series Cassettes (K131126)

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 862.1120 Blood gases (P

CO2 , PO2 ) and blood pH test system.(a)
Identification. A blood gases (PCO2 , PO2 ) and blood pH test system is a device intended to measure certain gases in blood, serum, plasma or pH of blood, serum, and plasma. Measurements of blood gases (PCO2 , PO2 ) and blood pH are used in the diagnosis and treatment of life-threatening acid-base disturbances.(b)
Classification. Class II.

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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 seal of the Department of Health & Human Services. 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 are the words "U.S. FOOD & DRUG" in blue, with the word "ADMINISTRATION" below it.

August 2, 2021

OPTI Medical Systems, Inc. Theron Gober Director, Quality and Regulatory 235 Hembree Park Drive Roswell, Georgia 30114

Re: K200986

Trade/Device Name: OPTI® B-Lac Cassette Regulation Number: 21 CFR 862.1120 Regulation Name: Blood Gases (pCO2, pO2) And Blood pH Test System Regulatory Class: Class II Product Code: CHL, GKR, GLY Dated: March 3, 2021 Received: March 4, 2021

Dear Theron Gober:

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.

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

1

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 postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Marianela Perez-Torres, Ph.D. Deputy Director Division of Chemistry and Toxicology Devices OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K200986

Device Name OPTI® B-Lac Cassette

Indications for Use (Describe)

The OPTI® B-Lac cassette is intended to be used for the in vitro measurement of pH, PO2, total hemoglobin (tHb), and % Saturated O2 in sodium heparinized venous blood samples on the OPTI CCA-TS and OPTI CCA-TS2 platform in a clinical laboratory location.

· Measurements of blood gases (pCO2, pO2) and blood pH are used in the diagnosis and treatment of life-threatening acid-base disturbances.

  • · Total hemoglobin (tHb) measurement is used to determine the hemoglobin content of human blood.
    · Oxygen saturation (SO2) measurement is used to determine the oxygen capacity of the hemoglobin.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

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

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OPTI® Medical Systems B-Lac Cassette 510(k) Summary

| Submitted by: | OPTI Medical Systems, Inc.
Phone Number: (770) 510-4444
Fax Number: (770) 510-4447 |
|-----------------------|--------------------------------------------------------------------------------------------------------|
| Contact: | Theron Gober |
| Date of Preparation: | April 6, 2020 |
| Current 510(k): | K200986 |
| Device Trade Name: | OPTI® B-Lac Cassette |
| Common Name: | Blood gas Analyzer |
| Type of Test: | Measurement of pH, PO2, PCO2, total hemoglobin (tHb) and SO2 |
| Classification Names: | Blood gas and pH test system
Automated hemoglobin test system
Whole blood hemoglobin test system |
| Regulations: | 862.1120
864.5620
864.7500
862.1450 |
| Product codes: | CHL
GKR
GLY |
| Panel: | Cliinical Chemistry, Hematology |
| Predicate Devices: | Instrumentation Laboratory GEM Premier 4000 |

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1. REASON FOR SUBMISSION

The purpose of this submission is to provide data to demonstrate that the new B-Lac cassette design meets the performance claims included in the previous submission referenced above and that it is substantially equivalent to the referenced predicate device. This submission includes changes to the PCO2 sensor as well as the new algorithms utilized to calculate concentrations for these sensors. No changes have been made to the pH or PQ2 sensors or the measurement of tHb or SO2(Saturated Oxygen). In addition, changes to the software that were made to the OPTI CCA-TS (K984299) and CCA-TS2 (K131126), referred to as OPTI CCA-TS/TS2, to implement the algorithms for the PCO2, sensors are documented.

2. DEVICE DESCRIPTION

2.1. OPTI CCA-TS and OPTI CCA-TS2 Instruments

The OPTI CCA-TS/TS2 are portable devices, microprocessor-based instrument using optical fluorescence for the measurement blood gases, electrolytes and enzymes. The OPTI CCA-TS/TS2utilize a color, graphical touch screen user interface.

A disposable, single-use cassette contains all of the elements needed for calibration, sample measurement, and waste containment. Specific calibration from the cassette is scanned into the analyzer by holding the cassette package in front of the bar code scanner. The cassette is then placed into the measurement chamber.

The analyzer warms the cassette to 37.0±0.1°C and performs a calibration verification. When calibration is verified, the analyzer aspirates the blood sample into the cassette and across the optode sensors. Fluorescence emission is then measured after equilibrating with the blood sample. After a single measurement, the cassette containing the blood sample is removed from the analyzer and discarded. The analyzer contains no reagents, blood, or waste.

No changes to the OPTI CCA-TS/TS2analyzer's hardware have been made to accommodate the addition of the parameters associated with the B-Lac cassette, thus the electromagnetic compatibility remains unchanged from prior claims of the OPTI CCA-TS. The software driving the analyzer has been updated according to internal design control and verification procedures

5

of the Quality System at OPTI Medical Systems, Inc. to accommodate the addition of the B-Lac cassette.

2.2. OPTI B-LAC Cassette

The B-Lac cassette is a disposable, single use cassette that contains four (4) sensors for in vitro quantitative measurements of PO2, PCO2, pH. There is an additional laser based measurement of total hemoglobin (tHb) and SO2. The B-Lac cassette is sealed in a foil pouch along with a desiccant and is marked with a barcode label that includes a lot identification number, calibration information, and expiration date.

2.2.1. Principle of Measurement

The B-Lac cassette uses fluorescence optodes to measure the intensity of light emitted from fluorescent dyes exposed to specific analytes. The concentration of the analyte is determined by the calculation of the difference in fluorescence measured at a defined calibration point and that measured with the unknown concentration of analyte. The principles of measurement of PO2, PCO2 and pH for the B-Lac cassette are similar to those used with existing cassette styles that are used on the OPTI CCA-TS/TS2.

2.2.2. Calibration

Each lot of B-Lac cassettes is calibrated during the manufacturing process. The process utilizes multi-levels of high precision standard solutions spanning the operating range for pH_. For O2 and CO2 the calibration parameters are determined using specially targeted calibration standards focusing on the clinically critical ranges. Every cassette package has a bar code label containing this calibration information as well as its lot number and expiration date. A onepoint calibration is performed each time a cassette is used. The B-Lac cassette uses a proprietary dry-calibration for the pH sensor. For the Blood Gas sensors PO2 and PCO2, a precision gas mixture similar to that used by conventional blood analyzers is used. The calibration for the tHb and SO2 measurements is factory set for each analyzer.

During the calibration and measurement processes, diagnostic tests are automatically performed to assure correct operation of the instrument and measurement of the cassette. These tests include automatic checks of the cassette for packaging integrity, proper cassette

6

temperature control, and proper equilibration behavior of the sensors during calibration and measurement, automatic detection of bubbles and short sample during aspiration, and automatic detection of dirty optics.

Three levels of standard control solutions (OPTI Check Level 1, 2 and 3) are supplied by Bionostics Inc., of Acton Massachusetts. Each level of control solution contains a different concentration of PO2, PCO2, pH, K, Na, Ca, Cl.

3. INDICATIONS FOR USE

The OPTI® B-Lac cassette is intended to be used for the in vitro measurement of pH, PO2, PCO2, , total hemoglobin (tHb), and % Saturated O2 in sodium heparinized venous blood samples on the OPTI CCA-TS and OPTI CCA-TS2 platform in a clinical laboratory location.

  • Measurements of blood gases (pCO2, pO2) and blood pH are used in the diagnosis and ● treatment of life-threatening acid-base disturbances.
  • Total hemoglobin (tHb) measurement is used to determine the hemoglobin content of human blood.
  • Oxygen saturation (SO2) measurement is used to determine the oxygen capacity of the hemoglobin.

4. TECHNOLOGICAL CHARACTERISTICS

The primary technological characteristics and intended use of the OPTI® B-Lac Cassette used with the OPTI CCA-TS/TS2 Analyzers are substantially equivalent to other legally marketed devices used for the quantitative measurement of blood gases, pH, and metabolites (lactate).

As indicated in Table 1 the OPTI B-Lac Cassette is substantially equivalent to significant characteristics of the identified predicate device, the Radiometer ABL90 Flex (K092686) and the OPTI CCA TS2 E-Series Cassettes (K131126).

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Table 1: Comparison of the OPTI® B-Lac Cassette with the predicate device

B-Lac on OPTI CCA TS & TS2ABL90 FLEX
510(k) #K200986K092686Comparison
ItemSubject of this submissionPredicate
Intended useThe OPTI Medical B-Lac cassette is intended to be used
for the in vitro measurement of pH, PO2, PCO2, total
hemoglobin (tHb), and % Saturated O2 in sodium
heparinized venous blood samples on the OPTI CCA-TS
and OPTI CCA-TS2 platform in a clinical laboratory
location.
• Measurements of blood gases (pCO2, pO2) and blood
pH are used in the diagnosis and treatment of life-
threatening acid-base disturbances.
• Total hemoglobin (tHb) measurement is used to
determine the hemoglobin content of human blood.
• Oxygen saturation (SO2) measurement is used to
determine the oxygen capacity of the hemoglobin.The ABL90 FLEX analyzer is a portable,
automated analyzer that measures pH, blood
gases, electrolytes, glucose, lactate, bilirubin
and oximetry in whole blood. It is intended
for use in a laboratory environment, near
patient or point-of-care setting.ABL90 FLEX: Similar
Where usedHospital (Laboratory Environment)Laboratory environmentABL90 FLEX: Similar
Measured
ParameterpH, PCO2, PO2, tHb (total hemoglobin) and SO2 (oxygen
saturation).pH, PCO2, PO2, tHb (total hemoglobin) and
SO2 (oxygen saturation).ABL90 FLEX: Similar
Sample TypeWhole blood (sodium heparinized, venous)Whole blood samplesABL90 FLEX: Same
Reportable
rangespH: 6.818 to 7.8
PO2: 10 to 700 mmHg
PCO2: 10 to 200 mmHg
tHb: 5.0 to 24 g/dLpH: 6.818 to 7.797
PO2: 30.1 to 488 mmHg
PCO2: 15.4 to 98.3 mmHg
tHb: 0.1 to 24 g/dLABL90 FLEX: Similar
B-Lac on OPTI CCA TS & TS2ABL90 FLEX
510(k) #K200986K092686Comparison
ItemSubject of this submissionPredicate
Sample
Volume125 μL65 -150 μLABL90 FLEX: Similar
Test
consumableSingle use cassette with optical fluorescence multi-
sensor array
Port for sample introduction
Fluid waste chamberSensor cassette and solution packABL90 FLEX: Similar
Test
consumable
storageRefrigerated storage (2 - 8°C) until expiry date
including max 28 days at room temperature.Sensor Pack: 2 - 8°C storage until expiry
date.
Fluid Pack: 2 - 25°C storage until expiry dateABL90 FLEX: Similar
Measuremen
t sequenceCalibrate cassette
Introduce sample - Measure
Display ResultsIntroduce sample
Measure
Display resultsABL90 FLEX: similar
Measuremen
t time180 sec from sample introduction35 secABL90 FLEX: Similar
Measuremen
t
Temperature37°C37°CABL90 FLEX: Same
Error
detectionQC system to detect user errors
QC system for reader self-check
QC system to detect cassette non-conformanceQC system to detect user errors
QC system for reader self-check
QC system to detect test cartridge non-
conformanceABL90 FLEX: similar
Measuremen
t PrinciplepH: fluorescence
PO2: fluorescence
PCO2: fluorescence
tHb- Optical reflectance measurement.pH, pCO2, K+, Na+, Ca2+, Cl-, Glu:
electrochemistry
PO2: optical
ctHb, sO2, FO2Hb, FCOHb, FHHb, FMetHb,
FHbF and ctBil: SpectrophotometryABL90 FLEX: Similar

8

9

B-Lac on OPTI CCA TS & TS2OPTI CCA TS2 E-Series Cassettes
510(k) #K200986K131126 (TS2)Comparison
ItemSubject of this submissionPredicate
Intended useThe OPTI Medical B-Lac cassette is intended to be used
for the in vitro measurement of pH, PO2, PCO2, -total
hemoglobin (tHb), and % Saturated O2 in sodium
heparinized venous blood samples on the OPTI CCA-TS
and OPTI CCA-TS2 platform in a clinical laboratory
location.
• Measurements of blood gases (pCO2, pO2) and blood
pH are used in the diagnosis and treatment of life-
threatening acid-base disturbances.
• Total hemoglobin (tHb) measurement is used to
determine the hemoglobin content of human blood.
• Oxygen saturation (SO2) measurement is used todetermine the oxygen capacity of the hemoglobin.The OPTI CCA-TS & TS2 cassette is intended to be
used for in vitro measurements of pH, PO2, PCO2,
total hemoglobin (tHb), Na+, K+ Ca++ and oxygen
saturation (SO2), in heparinized whole blood,
plasma, and serum samples (either arterial or
venous) on the OPTI CCA-TS & TS2 system, in either
a clinical laboratory setting or point-of-care
locations.OPTI-CCA: Similar
Where usedHospital (Laboratory Environment)Hospital (Laboratory or near patient)OPTI-CCA: Similar
Measured
ParameterSO2 (oxygen saturation).SO2.OPTI-CCA: Similar
Sample TypeWhole blood (sodium heparinized, venous)Whole blood, serum, and plasma (heparinized,
venous or arterial)OPTI-CCA: Similar
Reportable
rangesSO2: 60% to 100%SO2: 60% to 100%OPTI-CCA: Similar
Sample
Volume125 μL125 μLOPTI-CCA: Same
Test
consumableSingle use cassette with optical fluorescence multi-
sensor array
Port for sample introduction
Fluid waste chamberSingle use cassette with optical fluorescence multi-
sensor array
Port for sample introduction
Fluid waste chamberOPTI-CCA: Same
Test
consumable
storageRefrigerated storage (2 - 8°C) until expiry date
including max 28 days at room temperature.Room temperature storage (4 - 30°C) until expiry
dateOPTI-CCAE-Ca: Similar
B-Lac on OPTI CCA TS & TS2OPTI CCA TS2 E-Series Cassettes
510(k) #K200986K131126 (TS2)Comparison
ItemSubject of this submissionPredicate
Measurement
t sequenceCalibrate cassette
Introduce sample – Measure
Display ResultsCalibrate cassette
Introduce sample – Measure
Display ResultsOPTI-CCA-E-Ca: Same
Measurement
t time180 sec from sample introduction180 sec from sample introductionOPTI-CCA-E-Ca: Similar
Measurement
t
Temperature37°C37°COPTI-CCA-E-Ca: Same
Error
detectionQC system to detect user errors
QC system for reader self-check
QC system to detect cassette non-conformanceQC system to detect user errors
QC system for reader self-check
QC system to detect cassette non-conformanceOPTI-CCA-E-Ca: Same
Measurement
t PrincipleSO2 - Optical reflectance measurement.SO2: Optical reflectance measurement.OPTI-CCA-E-Ca: Similar

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Summary of Performance Testing 4.1.

The design verification tests that were performed are listed in Table 2Fable 2.

Table 2: Summary of Performance Testing

VerificationStandard UsedTesting Guidance Used
20-Day Precision (in-house)Claims submitted in K093280
(based on CLIA 1988
specifications)CLSI EP5-A3, volume 34, Number
13
Within Run Precision (in-house)Claims submitted in K093280
(based on CLIA 1988
specifications)CLSI EP5-A3, volume 34, Number
13
Method Comparison - (in-house)Whole blood - Tonometry/ABL90
FlexCLSI EP9-A2, Volume 22, Number
19
Method Comparison - AltitudeWhole blood - Tonometry/ABL90
FlexNone, regression analysis and
bias analysis at critical levels
Interference (in-house)Whole blood samplesCLSI EP7-A2, Volume 25, Number
27
Stability (in-house)OPTI Check Control MaterialBS EN ISO 13640-2002

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4.1.1. OPTI Medical B-Lac – In-House 20-Day Precision Testing

The 20-Day precision study was carried out following the experimental protocol recommended in the CLSI guideline EP05-A3, volume 34, Number 13. Typical Within-Run (Swr) and Total (ST) precision were determined from paired samples run twice daily over 20 days on three lots of B-Lac cassettes run on OPTI CCA-TS/TS2 analyzers using three levels of aqueous quality control solution. The precision performance for the redesigned B-Lac cassette was determined to meet the performance claims made in the original B-Lac cassette submission (K093280) for all analytes.

OPTI Medical B-Lac – In-House Within Run Precision Testing 4.1.2.

Within run precision testing was performed using whole blood and aqueous solutions following the experimental protocol recommended in the CLSI guideline EP05-A3, volume 34, Number 13. Typical within run (Swr) precision was determined from multiple repeats on three lots of B-Lac cassettes run on OPTI CCA-TS/TS2 analyzers using three levels of aqueous quality controls and whole blood manipulated to 3 different levels. The precision performance for the redesigned B-Lac cassette was determined to meet the performance claims made in original B-Lac cassette submission (K093280) for all analytes.

4.1.3. OPTI Medical B-Lac Cassette – In-House Method Comparison

In-house method comparison studies following the CLSI guideline EP9-A2, Volume 22, Number 19 (2002) for the B-Lac pH, PCO2 , PO2 sensors and measured tHb and SQ2 were performed on whole blood samples tonometered to different levels using different O₂/CO₂ gas mixtures to generate test levels for pH, PCQ2 , PO2, and SO2 and samples were manipulated to obtain test levels for tHb. The results were compared to the gravimetric target for PCO2 and PO2 based on the gas concentration and to the predicate device ABL90 Flex for pH, PCO2 , PQ2, and tHb and the E series cassettes on the OPTI CCA-TS/TS2 for SO2. The performance of the redesigned B-Lac cassette was determined to meet the performance claims included in the previous 510(K) submission K093280 for all analytes.

4.1.4. OPTI Medical B-Lac – In-House Linearity Testing

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4.1.5. OPTI Medical B-Lac – In-House Interference Testing

Interference testing was performed for the PCO2, PCO2, ph, sensors and measured tHb and SO2 for the B-Lac cassette following the CLSI guideline EP07-A, volume 22, Number 27 (2002). In all 16 interferents were tested for PCO2, PCO2, ph, tHb, and SQ2. There were several interferents found for tHb, and SO2, no interferents for PCO2 and only one interferent for PO2 and pH.

Altitude testing 4.1.6.

To evaluate the performance of the B-Lac cassette PCO2, PO2, pH, sensors at a range of altitudes, method comparison studies were performed on whole blood and ampuled aqueous control materials at the following sites:

  • Westbrook, Maine, USA, 75 feet (Aqueous) .
  • Roswell, Georgia, USA, 1080 feet (Aqueous and Whole Blood) .
  • Beech Mountain, North Caroling, USA, 5560 feet (Aqueous) .
  • Leadville, Colorado, USA, 10151 feet (Aqueous and Whole Blood) .

Testing for the B-Lac cassette was performed on the OPTI CCA TS and OPTI CCA-TS platforms against the predicate device (ABL90 Flex - K092686) for whole blood. Whole blood samples were tonometered to obtain samples that span the range for PCO2, PO2, and pH, and spiked or diluted for tHb at both 1180 ft. and 10,151 ft. Aqueous solutions were measured for PCO2, pH, tHb and Saturate O2 at all sites and the results compared to the reference site in Roswell, Georgia. Analysis of the data for linearity and bias at the critical limits was calculated. The performance of the B-Lac cassette with redesigned PCO2 sensors was demonstrated to meet the performance claims included in the previous 510(K) submission K093280 when tested with whole blood samples at 1180 feet and 10151 feet (PCO2, PO2, pH, tHb) and aqueous samples at all altitudes tested (PCO2, PO2, pH, tHb, and SO2).

4.1.7. OPTI Medical B-Lac – Stability Testing

Stability testing was performed to establish the shelf life for the redesigned B-Lac cassette. The purpose of this test was to collect aqueous control data to evaluate the stability of pH, PO2, PCO2, tHb, and SO2 on the redesigned B-Lac cassette. The redesigned B-Lac cassette includes

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improvements to the PCO2 sensors while keeping the pH, PO2, tHb, and SO2 the same. The study includes an evaluation of cassettes that have been subjected to 2 cycles of simulated shipping temperature extremes prior to refrigeration. Three Lots of B-Lac cassettes were tested with one Lot being subjected to two cycles of elevated and frozen temperatures cycles. Performance of the B-Lac cassette has been demonstrated to meet the performance claims for up to 6 months shelf life. Real time testing will continue for 13 months to demonstrate that the shelf life for the new cassette is equivalent to the shelf life (12 mos.) for the B-Lac cassette included in the previous 510(K) submission K093280.

5. CONCLUSION

Analysis of the data collected during performance testing studies for the OPTI B-Lac Cassette using the OPTI CCA-TS/TS2 analyzers demonstrates that the redesigned B-Lac Cassette performance in venous whole blood in clinical laboratory setting is substantially equivalent for all analytes.