K Number
K211559
Device Name
EasyStat 300
Manufacturer
Date Cleared
2023-01-27

(617 days)

Product Code
Regulation Number
862.1120
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The EasyStat 300 is designed for clinical laboratory use, making quantitative measurements of pO2 (partial pressure of oxygen), pCO2 (partial pressure of carbon dioxide), and pH (hydrogen ion activity) in whole blood (arterial/venous) samples from Li-Heparinized Syringes or Capillary Tubes. This Analyzer should only be used by trained technicians in clinical laboratories to aid in the diagnosis and treatment of patients with blood gas and/or acid-base disturbances. Blood gases (p02, pCO2) and pH measurements in blood are used in the diagnosis and treatment of life-threatening acidbase disturbances.
Device Description
The EasyStat 300 is a system for use by health care professionals to rapidly analyze whole blood samples. The analyzer incorporates a Reagent Module containing the "calibrating" solutions A2, B2, and a "conditioning" solution C2, which is also use a calibrant for the Oxygen sensor. Calibrations are performed automatically or on-demand by the user to establish the "slope" of each sensor used in the calculation of the patient sample. The EasyStat 300 uses 175μL of whole blood in the "Syringe" mode and 100μL of whole blood in the "Capillary" mode to analyze patient samples. The EasyStat 300 reports results for blood Gases (PCO2, PO2), and pH. Additionally, it provides a number of calculated parameters based on the reported results and a number of input parameters as described in the Operator's Manual. The EasyStat 300 is a microprocessor-controlled device with a touch sensitive screen that guides the operator through the different menu options and proper operation. It also incorporates a thermal printer to record all reported results and patient information as described in the Operator's Manual. The device software has incorporated routines to assist the end-user with maintenance, cleaning, and troubleshooting activities also outlined in the manual. The incorporated USB port may be used to download data and also to update the software version based on detailed instructions by Medica Corporation. The blood gas and pH sensors require calibration and cleaning after a predefined number of samples are analyzed as described in the Operator's Manual. The pH and PCO2 sensors are based on potentiometric sensor design, generating a small voltage that is dependent on the concentrations of these analytes in the patient sample. The PO2 sensor is based on amperometric sensor design that generates a small current that is dependent on the concentration of oxygen in the patient sample. Medica's EasyQC materials are specifically formulated for the EasyStat 300. The EasyStat 300 may be equipped with a Medica provided barcode scanner via a USB port to automatically enter patient sample and EasyQC material info. To maintain the performance of the analyzer Medica provides a cleaning solution and a troubleshooting kit.
More Information

Not Found

No
The summary describes a standard blood gas analyzer with microprocessor control and automated calibration, but there is no mention of AI or ML in the device description, intended use, or performance studies. The focus is on traditional analytical methods and statistical performance metrics.

No
The device is an in vitro diagnostic (IVD) device used to measure physiological parameters in blood samples (pO2, pCO2, and pH) to aid in diagnosis and treatment, rather than directly providing therapy.

Yes

The "Intended Use / Indications for Use" section explicitly states that the device is "to aid in the diagnosis and treatment of patients with blood gas and/or acid-base disturbances." This directly indicates its role as a diagnostic tool.

No

The device description clearly indicates it is a physical analyzer with hardware components such as sensors, a microprocessor, a touch screen, a thermal printer, and a USB port, in addition to software.

Based on the provided information, the EasyStat 300 is indeed an IVD (In Vitro Diagnostic) device. Here's why:

  • Intended Use: The device is designed for "clinical laboratory use, making quantitative measurements of pO2, pCO2, and pH in whole blood... to aid in the diagnosis and treatment of patients with blood gas and/or acid-base disturbances." This clearly indicates its use in a laboratory setting to analyze biological samples for diagnostic purposes.
  • Sample Type: It analyzes "whole blood," which is a biological specimen.
  • Measurements: It measures specific analytes (pO2, pCO2, pH) in the blood sample.
  • Purpose: The results are used "to aid in the diagnosis and treatment of patients." This is a core function of IVD devices.
  • Device Description: The description details the components and functionality for analyzing blood samples and reporting results, consistent with an IVD.
  • Performance Studies: The document includes detailed performance studies (Precision, Linearity, Method Comparison, Sensitivity, Selectivity) which are standard requirements for demonstrating the analytical performance of an IVD device.
  • Predicate Device: The mention of a predicate device (K021515; EasyStat Blood Gas Analyzer) further supports its classification as an IVD, as predicate devices are used for comparison in regulatory submissions for new IVDs.

Therefore, the EasyStat 300 fits the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The EasyStat 300 is designed for clinical laboratory use, making quantitative measurements of pO2 (partial pressure of oxygen), pCO2 (partial pressure of carbon dioxide), and pH (hydrogen ion activity) in whole blood (arterial/venous) samples from Li-Heparinized Syringes or Capillary Tubes. This Analyzer should only be used by trained technicians in clinical laboratories to aid in the diagnosis and treatment of patients with blood gas and/or acid-base disturbances.

Blood gases (p02, pCO2) and pH measurements in blood are used in the diagnosis and treatment of life-threatening acid-base disturbances.

Product codes

CHL

Device Description

The EasyStat 300 is a system for use by health care professionals to rapidly analyze whole blood samples. Good Laboratory Practices (GLPs) are strongly advised when using the EasyStat 300. The analyzer incorporates a Reagent Module containing the "calibrating" solutions A2, B2, and a "conditioning" solution C2, which is also use a calibrant for the Oxygen sensor. Calibrations are performed automatically or on-demand by the user to establish the "slope" of each sensor used in the calculation of the patient sample.

The EasyStat 300 uses 175μL of whole blood in the "Syringe" mode and 100μL of whole blood in the "Capillary" mode to analyze patient samples. Medica provides a capillary tube kit (REF 8303) used for the capillary data collection in this submission. The EasyStat 300 reports results for blood Gases (PCO2, PO2), and pH. Additionally, it provides a number of calculated parameters based on the reported results and a number of input parameters as described in the Operator's Manual.

The EasyStat 300 is a microprocessor-controlled device with a touch sensitive screen that guides the operator through the different menu options and proper operation. It also incorporates a thermal printer to record all reported results and patient information as described in the Operator's Manual. The device software has incorporated routines to assist the end-user with maintenance, cleaning, and troubleshooting activities also outlined in the manual. The incorporated USB port may be used to download data and also to update the software version based on detailed instructions by Medica Corporation.

The blood gas and pH sensors require calibration and cleaning after a predefined number of samples are analyzed as described in the Operator's Manual. The pH and PCO2 sensors are based on potentiometric sensor design, generating a small voltage that is dependent on the concentrations of these analytes in the patient sample. The PO2 sensor is based on amperometric sensor design that generates a small current that is dependent on the concentration of oxygen in the patient sample. The theory and mathematical formulas on which the sensor functionality is based are described in the Operator's Manual.

Medica's EasyQC materials (REF 8315/8316/8317 and 8309) are specifically formulated for the EasyStat 300. Medica requires the use of quality controls everyday patient samples are analyzed and after any troubleshooting is performed, as instructed in the Operator's Manual, to validate the performance of the analyzer. The analyzer stores QC results and provides a statistical analysis of its performance using Levey-Jennings plots for the last 30 consecutive days. The EasyQC materials for the EasyStat 300 have a minimum of three years shelf-life when stored refrigerated (20-80C).

The Reagent Module (REF 8101) has a twelve-month shelf-life when stored at 4º-25ºC. Use-life depends on the number of samples analyzed and the overall performance of the sensors. The analyzer monitors the consumption of calibrant solution A2 and warns the operator when the reagent module is about to expire. A typical Use-life for an average user is expected to be 15 days and/or 350 samples whichever comes first. This feature is the one provided with the predicate EasyStat analyzer.

The sensors have one-year shelf-life when stored at 4º 25ºC for blood gases (PCO2, PO2), pH. Use-Life of the sensors is determined from their calibration profiles and from the reported results during the EasyQC analysis. Sensors are replaced by the operator as described in the Operator's Manual. An automatic calibration is performed after installation to qualify the new sensor(s) and the operator is instructed to use the EasyQC multi-level QC materials to validate the EasyStat 300 performance.

The EasyStat 300 may be equipped with a Medica provided barcode scanner (REF 8420) via a USB port to automatically enter patient sample and EasyQC material info. Details are provided in the operator's Manual.

To maintain the performance of the analyzer Medica provides a cleaning solution (REF 8305) and a troubleshooting kit (REF 8250). Their proper uses are described also in the operator's Manual.

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

trained technicians in clinical laboratories

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

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Summary of Performance Studies

Precision Studies:
Repeatability 20-Day Precision Study (Syringe & Capillary Modes) – Aqueous Controls: Medica used the EasyStat 300 tri-level aqueous EasyQC material. Each of the quality control levels were analyzed in three EasyStat 300 analyzers for twenty days taking duplicate readings in the morning (AM) and afternoon (PM). All results were within specification.
Reproducibility (5-Day) Precision Study - Syringe & Capillary Modes: This study was performed as a substitute to the typical single run with twenty whole blood replicates. Five replicates of whole blood were run for five days. All results were within specification.
Conclusion of Precision Studies: Medica's Total precision and Within-Run precision studies demonstrate that the EasyStat 300 is precise and true to Medica's performance specifications and comparable to the predicate device.

Linearity Study:
This study followed the CLSI EP06-A protocol. The linearity performance on the EasyStat 300 was evaluated using nine (9) to eleven (11) spiked and diluted whole blood specimens to cover the reportable range for each analyte. The pre-assayed whole blood samples were finally tested in triplicate on three EasyStat 300 analyzers. All results met device specifications.
Conclusion of Linearity Study: Data demonstrate that all analytes (pH, pCO2, pO2) reported by the EasyStat 300 are linear within the advertised reportable range.

Method Comparison Study:
This study followed the CLSI EP9-A2 protocol. Whole blood from more than 200 donors plus six modified whole blood samples (spiked and diluted) were used. All blood samples were tested on the predicate devices twice and on three EasyStat 300 analyzers. Some samples were modified to achieve analyte levels covering the reportable range using tonometry. The "Capillary" mode on the EasyStat 300 was evaluated against the "Capillary" mode on the predicate EasyStat analyzer using the same whole blood samples collected with the same capillary tubes.
Conclusion of the Method Comparison Study: Data demonstrate that all analytes (pH, pCO2, pO2) reported by the EasyStat 300 are favorably correlated to the predicate/reference device and were within specifications.

Sensitivity Study:
The sensitivity study followed the guidelines from CLSI EP17-A. It was performed on three ES 300 analyzers covering the pH and blood gas sensors. The study established the Limit of Blank (LoB), Limit of Detection (LoD), and Limit of Quantitation (LoQ).
Conclusion of the Sensitivity Study: The lowest reportable limit for each assay on the EasyStat 300 was based on the LoQ result calculated or experimentally determined in this sensitivity studies indicate that the following values may be used as the lowest limit of the reportable range of each assay available on the EasyStat 300: p02: 5 mmHg, pCO2: 5.0 mmHg, pH: 6.800 units.

Selectivity Study (Interference):
The selectivity (interference) study followed in principle the guidelines from CLSI EP07-A. The level chosen is the typical normal value for a particular analyte in whole blood. All collected data are from spiked whole blood samples collected from healthy donors. The study concluded "No Interference" for all tested interfering substances if the change was less than 10%.

Key Metrics

Accuracy/Correlation: Linear regression slope, coefficient of variation, and calculated predicted bias were within specifications for Method Comparison Study.
Repeatability/Precision: All results for within-run and total precision were within specification.
Linearity: All analytes passed linearity within advertised reportable range.
Sensitivity: LoB, LoD, and LoQ were determined and the lowest reportable limits were identified (p02: 5 mmHg, pCO2: 5.0 mmHg, pH: 6.800 units).
Selectivity/Interference: "No Interference" found for all tested substances if the change was

§ 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.

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: on the left, there is a seal with an abstract design, and on the right, there is the text "FDA U.S. FOOD & DRUG ADMINISTRATION" in blue. The text is arranged in three lines, with "FDA" being the largest and boldest, followed by "U.S. FOOD & DRUG" and then "ADMINISTRATION".

January 27, 2023

Medica Corporation Photios Makris VP Regulatory Affairs 5 Oak Park Drive Bedford, MA 01730

Re: K211559

Trade/Device Name: EasyStat 300 Regulation Number: 21 CFR 862.1120 Regulation Name: Blood Gases (PCO2, PO2) and Blood pH Test System Regulatory Class: Class II Product Code: CHL Dated: September 30, 2022 Received: October 3, 2022

Dear Photios Makris:

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

1

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 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 (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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/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,

Digitally signed by Paula Paula Caposino -S Caposino -S Date: 2023.01.27
12:07:22 -05'00' Paula V. Caposino, Ph.D. Acting Deputy Director

Division of Chemistry and Toxicology Devices OHT7: Office of In Vitro Diagnostics Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K211559

Device Name EasyStat 300

Indications for Use (Describe)

The EasyStat 300 is designed for clinical laboratory use, making quantitative measurements of pO2 (partial pressure of oxygen), pCO2 (partial pressure of carbon dioxide), and pH (hydrogen ion activity) in whole blood (arterial/venous) samples from Li-Heparinized Syringes or Capillary Tubes. This Analyzer should only be used by trained technicians in clinical laboratories to aid in the diagnosis and treatment of patients with blood gas and/or acid-base disturbances.

Blood gases (p02, pCO2) and pH measurements in blood are used in the diagnosis and treatment of life-threatening acidbase disturbances.

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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3

510(k) Summary

Submitted By:

Medica Corporation 5 Oak Park Drive Bedford, MA 01730

Contact Person:

Photios Makris, VP. Regulatory Affairs Phone: 781-541-7443 Fax: 781-275-2731 pmakris@medicacorp.com E-mail:

Summary Prepared:

January 25th, 2023

Trade Name:EasyStat 300
Common Name:Blood Gas Analyzer
Classification Name:Blood Gases and Blood pH Test System

Regulatory Information:

EasyStat 300 Analyzer

DescriptionRegulation No.Device ClassProduct Code
Blood Gas and blood pH862.1120IICHL

EasyQC BGEM Material for EasyStat

DescriptionRegulation No.Device ClassProduct Code
Quality control Material862.1660Class IJJY

Predicate devices:

Description510(k)Regulation No.Device ClassProduct Code
EasyStat Blood Gas AnalyzerK021515862.1120IICHL

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Device Description and Indications for Use:

The EasyStat 300 is a system for use by health care professionals to rapidly analyze whole blood samples. Good Laboratory Practices (GLPs) are strongly advised when using the EasyStat 300. The analyzer incorporates a Reagent Module containing the "calibrating" solutions A2, B2, and a "conditioning" solution C2, which is also use a calibrant for the Oxygen sensor. Calibrations are performed automatically or on-demand by the user to establish the "slope" of each sensor used in the calculation of the patient sample.

The EasyStat 300 uses 175μL of whole blood in the "Syringe" mode and 100μL of whole blood in the "Capillary" mode to analyze patient samples. Medica provides a capillary tube kit (REF 8303) used for the capillary data collection in this submission. The EasyStat 300 reports results for blood Gases (PCO2, PO2), and pH. Additionally, it provides a number of calculated parameters based on the reported results and a number of input parameters as described in the Operator's Manual.

The EasyStat 300 is a microprocessor-controlled device with a touch sensitive screen that guides the operator through the different menu options and proper operation. It also incorporates a thermal printer to record all reported results and patient information as described in the Operator's Manual. The device software has incorporated routines to assist the end-user with maintenance, cleaning, and troubleshooting activities also outlined in the manual. The incorporated USB port may be used to download data and also to update the software version based on detailed instructions by Medica Corporation.

The blood gas and pH sensors require calibration and cleaning after a predefined number of samples are analyzed as described in the Operator's Manual. The pH and PCO2 sensors are based on potentiometric sensor design, generating a small voltage that is dependent on the concentrations of these analytes in the patient sample. The PO2 sensor is based on amperometric sensor design that generates a small current that is dependent on the concentration of oxygen in the patient sample. The theory and mathematical formulas on which the sensor functionality is based are described in the Operator's Manual.

Medica's EasyQC materials (REF 8315/8316/8317 and 8309) are specifically formulated for the EasyStat 300. Medica requires the use of quality controls everyday patient samples are analyzed and after any troubleshooting is performed, as instructed in the Operator's Manual, to validate the performance of the analyzer. The analyzer stores QC results and provides a statistical analysis of its performance using Levey-Jennings plots for the last 30 consecutive days. The EasyQC materials for the EasyStat 300 have a minimum of three years shelf-life when stored refrigerated (20-80C).

The Reagent Module (REF 8101) has a twelve-month shelf-life when stored at 4º-25ºC. Use-life depends on the number of samples analyzed and the overall performance of the sensors. The analyzer monitors the consumption of calibrant solution A2 and warns the operator when the reagent module is about to expire. A typical Use-life for an average user is expected to be 15

5

days and/or 350 samples whichever comes first. This feature is the one provided with the predicate EasyStat analyzer.

The sensors have one-year shelf-life when stored at 4º 25ºC for blood gases (PCO2, PO2), pH. Use-Life of the sensors is determined from their calibration profiles and from the reported results during the EasyQC analysis. Sensors are replaced by the operator as described in the Operator's Manual. An automatic calibration is performed after installation to qualify the new sensor(s) and the operator is instructed to use the EasyQC multi-level QC materials to validate the EasyStat 300 performance.

The EasyStat 300 may be equipped with a Medica provided barcode scanner (REF 8420) via a USB port to automatically enter patient sample and EasyQC material info. Details are provided in the operator's Manual.

To maintain the performance of the analyzer Medica provides a cleaning solution (REF 8305) and a troubleshooting kit (REF 8250). Their proper uses are described also in the operator's Manual.

Intended use and Indications for use of the analytes measured by the EasyStat 300 are:

The EasyStat 300 provides quantitative measurements of pH (hydrogen ion activity), pCO2 (partial pressure of carbon dioxide), and pO2 (partial pressure of oxygen) in Li-heparinized whole blood (arterial/venous) samples from Syringes or Capillary Tubes. This Analyzer should only be used by trained technicians in clinical laboratories to aid in the diagnosis and treatment of patients with blood gas and/or acid-base disturbances.

pCO2, PO2 (blood gases) and pH measurements in blood are used in the diagnosis and treatment of lifethreatening acid-base disturbances.

The EasyStat 300 has the same technical characteristics with the predicate device. Sensor technology, Reagent module calibrating solutions, principles of operation, and parameters measured are practically the same. User device display may differ due to the new touch sensitive screen, user menu preferences, and more friendly user interface. None of these differences affect the performance when compared to the predicate EasyStat analyzer. The following sections provide a brief discussion of the performance characteristics of the EasyStat 300 based on the studies submitted to determine substantial equivalency.

All tests on the following sections are non-clinical bench tests except for Method Comparison, which was performed on a clinical laboratory using actual venous and arterial blood. The non-clinical tests also used contrived venous blood of aqueous QC materials that are part of the EasyStat 300 system.

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EasyStat 300EasyStat Ca++
510(k) NumberNew IVD DeviceK021515
ManufacturerMedica Corp.Medica Corp.
Address5 Oak Park Dr. Bedford, MA 017305 Oak Park Dr. Bedford, MA 01730
Intended UseClinical LaboratoriesClinical Laboratories
Indications for UseSame with predicate devicesSame with submitted device
Operating PrinciplePotentiometricPotentiometric
pHPotentiometricPotentiometric
PCO2PotentiometricPotentiometric
PO2AmperometricAmperometric
Calibrant BaseAqueousAqueous
Measured ParameterspH, pCO2, pO2pH, PCO2, PO2
Sample TypeWhole BloodWhole Blood
Sample Volume175µL Syringe, 100 µL Capillary120µL Syringe, 95 µL Capillary
Analysis Time110 seconds120 seconds
Measured Range
pH6.800 to 8.000 units6.500 to 8.000 units
pCO25.0 – 150.0 mmHg5.0 – 150.0 mmHg
pO25-700 mHg5-700 mmHg
DisplayTFT LCD, Touch screenLCD
PrinterThermalThermal
Communication PortsUSB (5), 1 for Barcode readerNone
Ethernet (1)None
RS232 Serial (1)RS232 Serial (1)
SD card port (1)None
N/ABarcode Reader
Calculated ParametersPatient Temp. Correction, pH, PCO2, PO2Patient Temp. Correction, pH, PCO2, O2
Total HemoglobinTotal Hemoglobin
Hematocrit, measuredHematocrit, measured
Total CO2 (TCO2)Total CO2 (TCO2)
Bicarbonate (HCO3-)Bicarbonate (HCO3-)
Base excess of blood (BEb)Base excess of blood (BEb)
Base excess of Extracellular fluid (BEecf)Base excess of Extracellular fluid (BEecf)
Standard Bicarbonate (SBC)Standard Bicarbonate (SBC)
Oxygen Saturation calculated at P50 (%SO2c)Oxygen Saturation calculated at P50 (%SO2c)
Total Oxygen Content (ctO2)Total Oxygen Content (ctO2)
Alveolar-Arterial O2 Gradient (A-aDO2)Alveolar-Arterial O2 Gradient (A-aDO2)
Respiratory Index (RI)Respiratory Index (RI)
Safety ComplianceEN61010EN61010
EMC ComplianceEN55011EN55011
UL TestedUL3101UL3101
CSA TestedC22.2C22.2
Dimensions14.5"WX13"HX7"D14.25"W X 12.5"H X 7"D
Voltage Requirements110/115VAC, 50-60Hz, 220VAC, 50-60Hz110/115VAC, 50-60Hz, 220VAC, 50-60Hz

Substantial Equivalency Between EasyStat 300 and predicate EasyStat

7

All tests on the following sections are non-clinical bench tests except for Method Comparison, which was performed on a clinical laboratory using actual venous and arterial blood. The non-clinical tests also used contrived venous blood of aqueous QC materials that are part of the EasyStat 300 system.

8

Performance Summaries:

Precision Studies:

Repeatability 20-Day Precision Study (Syringe & Capillary Modes) – Aqueous Controls

Medica used the EasyStat 300 tri-level aqueous EasyQC material to establish the Total and Within-Run precision of all analytes reported by the EasyStat 300. Each of the quality control levels were analyzed in three EasyStat 300 analyzers for twenty days taking duplicate readings in the morning (AM) and afternoon (PM). All results were within specification.

| | Precision
Estimate | Level | Target | Performance
Specs | | System 1_P21 | | | System 2_P22 | | | System 3_P23 | | |
|------|------------------------------|-------|--------|----------------------|------|--------------|-------|-----|--------------|-------|-----|--------------|-------|-----|
| | | | | SD | CV | Mean | SD | CV | Mean | SD | CV | Mean | SD | CV |
| PO2 | Within-
Device
(Total) | 1 | 36 | 2.5 | | 36 | 1.39 | | 35 | 1.33 | | 37 | 1.18 | |
| | | 2 | 98 | 2.5 | | 99 | 1.61 | | 98 | 2.23 | | 99 | 1.56 | |
| | | 3 | 136 | | 2.5% | 137 | | 1.4 | 137 | | 1.4 | 138 | | 1.5 |
| PCO2 | Within-
Device
(Total) | 1 | 69.0 | | 5.0% | 68.9 | | 0.9 | 68.1 | | 0.9 | 68.3 | | 0.8 |
| | | 2 | 45.0 | | 4.0% | 45.4 | | 1.2 | 45.2 | | 1.0 | 45.2 | | 0.9 |
| | | 3 | 21.0 | 2.0 | | 21.2 | 0.28 | | 21.4 | 1.13 | | 21.1 | 0.23 | |
| pH | Within-
Device
(Total) | 1 | 7.186 | 0.020 | | 7.183 | 0.002 | | 7.182 | 0.002 | | 7.185 | 0.001 | |
| | | 2 | 7.411 | 0.015 | | 7.410 | 0.002 | | 7.410 | 0.003 | | 7.408 | 0.002 | |
| | | 3 | 7.621 | 0.020 | | 7.622 | 0.004 | | 7.623 | 0.002 | | 7.618 | 0.002 | |

Typical Repeatability Precision Study (Syringe Mode) – Aqueous Controls

Typical Repeatability Precision Study (Capillary Mode) – Aqueous Controls

20 Day QC Precision (Capillary Mode)
AnalytePrecision
EstimateLevelTargetPerformance
SpecsUnit 1Unit 2Unit 3
SDCVMeanSDCVMeanSDCVMeanSDCV
PO2Repeatability
(Within-Run)1363532.705.1531.703.2522.414.6
29831071.511.41081.841.71081.991.8
31363.0%1401.851.31401.521.11412.501.8
PO2Within-Device
(Total)1364533.677.0532.815.3524.007.7
29841072.492.31082.372.21082.252.1
31364.0%1402.301.61403.172.31412.721.9
PCO2Repeatability
(Within-Run)169.05.0%63.40.961.563.00.931.563.20.681.1245.04.0%41.40.451.141.10.501.241.20.421.0321.01.521.20.190.921.40.211.021.20.231.1PCO2Within-Device
(Total)169.05.0%63.41.141.863.01.151.863.21.001.6245.04.0%41.40.521.341.10.551.341.20.461.1321.02.021.20.231.121.40.271.321.20.251.2pHRepeatability
(Within-Run)17.1860.0207.2090.0040.067.1920.0060.087.1970.0070.0927.4110.0157.4330.0030.047.4210.0030.047.4230.0020.0337.6210.0207.6190.0040.057.6120.0030.037.6090.0030.04pHWithin-Device
(Total)17.1860.0207.2090.0110.167.1920.0080.107.1970.0110.1627.4110.0157.4330.0090.127.4210.0030.047.4230.0050.0637.6210.0207.6190.0070.107.6120.0040.057.6090.0040.06
PCO2Repeatability
(Within-Run)169.05.0%63.40.961.563.00.931.563.20.681.1
245.04.0%41.40.451.141.10.501.241.20.421.0321.01.521.20.190.921.40.211.021.20.231.1PCO2Within-Device
(Total)169.05.0%63.41.141.863.01.151.863.21.001.6245.04.0%41.40.521.341.10.551.341.20.461.1321.02.021.20.231.121.40.271.321.20.251.2pHRepeatability
(Within-Run)17.1860.0207.2090.0040.067.1920.0060.087.1970.0070.0927.4110.0157.4330.0030.047.4210.0030.047.4230.0020.0337.6210.0207.6190.0040.057.6120.0030.037.6090.0030.04pHWithin-Device
(Total)17.1860.0207.2090.0110.167.1920.0080.107.1970.0110.1627.4110.0157.4330.0090.127.4210.0030.047.4230.0050.0637.6210.0207.6190.0070.107.6120.0040.057.6090.0040.06
245.04.0%41.40.451.141.10.501.241.20.421.0
321.01.521.20.190.921.40.211.021.20.231.1
PCO2Within-Device
(Total)169.05.0%63.41.141.863.01.151.863.21.001.6245.04.0%41.40.521.341.10.551.341.20.461.1321.02.021.20.231.121.40.271.321.20.251.2pHRepeatability
(Within-Run)17.1860.0207.2090.0040.067.1920.0060.087.1970.0070.0927.4110.0157.4330.0030.047.4210.0030.047.4230.0020.0337.6210.0207.6190.0040.057.6120.0030.037.6090.0030.04pHWithin-Device
(Total)17.1860.0207.2090.0110.167.1920.0080.107.1970.0110.1627.4110.0157.4330.0090.127.4210.0030.047.4230.0050.0637.6210.0207.6190.0070.107.6120.0040.057.6090.0040.06
PCO2Within-Device
(Total)169.05.0%63.41.141.863.01.151.863.21.001.6
245.04.0%41.40.521.341.10.551.341.20.461.1
321.02.021.20.231.121.40.271.321.20.251.2
pHRepeatability
(Within-Run)17.1860.0207.2090.0040.067.1920.0060.087.1970.0070.0927.4110.0157.4330.0030.047.4210.0030.047.4230.0020.0337.6210.0207.6190.0040.057.6120.0030.037.6090.0030.04pHWithin-Device
(Total)17.1860.0207.2090.0110.167.1920.0080.107.1970.0110.1627.4110.0157.4330.0090.127.4210.0030.047.4230.0050.0637.6210.0207.6190.0070.107.6120.0040.057.6090.0040.06
pHRepeatability
(Within-Run)17.1860.0207.2090.0040.067.1920.0060.087.1970.0070.09
27.4110.0157.4330.0030.047.4210.0030.047.4230.0020.03
37.6210.0207.6190.0040.057.6120.0030.037.6090.0030.04
pHWithin-Device
(Total)17.1860.0207.2090.0110.167.1920.0080.107.1970.0110.1627.4110.0157.4330.0090.127.4210.0030.047.4230.0050.0637.6210.0207.6190.0070.107.6120.0040.057.6090.0040.06
pHWithin-Device
(Total)17.1860.0207.2090.0110.167.1920.0080.107.1970.0110.16
27.4110.0157.4330.0090.127.4210.0030.047.4230.0050.06
37.6210.0207.6190.0070.107.6120.0040.057.6090.0040.06

9

Reproducibility (5-Day) Precision Study - Syringe & Capillary Modes

This study was performed as a substitute to the typical single run with twenty whole blood replicates. We chose to use the option allowed in the CLSI EP05-A3 protocol to run five replicates of whole blood for five days. All results were within specification.

Within-Run, 5-day w. Blood Study
AnalyteMetricLevel 1Level 2Level 3
Avg (mmHg)3978223
PO2SD (mmHg)0.61.73.3
CV(%)1.52.11.5
specification2.5mmHg2.5mmHg3.0%
Avg (mmHg)36.967.4132.6
PCO2SD (mmHg)0.51.32.7
CV(%)1.31.92.1
specification2.0%3.0%3.0%
Avg (pH units)7.4107.2167.588
pHSD (pH units)0.0070.0100.007
CV(%)0.10.10.1
specification0.015 units0.015 units0.015 units

Typical Repeatability Performance of the EasyStat 300 operating in "Syringe" mode

Typical Reproducibility Performance of the EasyStat 300 operating in "Capillary" mode

Within-Run, 5-day w. Blood Study
AnalyteMetricLevel 1Level 2Level 3
PO2Avg (mmHg)39.780.8225.2
SD (mmHg)0.91.12.2
CV(%)2.31.41
specification2.4mmHg3.0%3.0%
PCO2Avg (mmHg)36.065.9131.1
SD (mmHg)0.911.912.62
CV(%)2.52.92
specification4.0%5.0%5.0%
pHAvg (pH units)7.4097.2187.561
SD (pH units)0.0080.0110.006
CV(%)0.10.10.1
specification0.015 units0.015 units0.015 units

Conclusion of Precision Studies

Medica's Total precision and Within-Run precision studies, demonstrate that the EasyStat 300 Blood-Gas/Electrolyte/metabolite analyzer is precise and true to Medica's performance specifications and comparable to the predicate device in this submission.

10

Linearity Study

This study followed the CLSI EP06-A protocol officially recognized by the FDA. The linearity performance on the EasyStat 300 was evaluated using nine (9) to eleven (11) spiked and diluted whole blood specimens to cover the reportable range for each analyte. The pre-assayed whole blood samples were finally tested in triplicate on three EasyStat 300 analyzers to establish the linearity performance for each analyte. The table below shows a summary of the obtained results that met all device specifications.

Linearity Summary for one of the three EasyStat 300 analyzers operating in the "Syringe" mode
AnalyteDatePredicateES300Syringe
Sensor 1Sensor 2
LinearitySlopeR2LinearitySlopeR2
PO212/26/19ES_4P7PASS1.0160.999
P8PASS1.0270.998
P17PASS1.0130.999
PCO212/26/19ES_3P7PASS1.0660.999
P8PASS0.9840.998
P17PASS0.9830.996
pH01/22/20ES_4P7PASS1.0080.996PASS1.0110.996
P8PASS1.0220.997PASS0.9810.997
P17PASS1.0270.997PASS1.0610.997

Conclusion of Linearity Study

Data from the linearity study on three EasyStat 300 analyzers performed according to CLSI EP6-A demonstrate that all analytes (pH, pCO2, pO2) reported by the EasyStat 300 are linear within the advertised reportable range.

11

Method Comparison Study

This study followed the CLSI EP9-A2 protocol. For this study we used whole blood from more than 200 donors plus six modified whole blood samples (spiked and diluted). All blood samples were tested on the predicate devices twice and on three EasyStat 300 analyzers. Some samples were modified to achieve analyte levels covering the reportable range using tonometry.

In addition, the "Capillary" mode on The EasyStat 300 was evaluated against the "Capillary" mode on the predicate EasyStat analyzer using the same whole blood samples collected with the same capillary tubes.

Conclusion of the Method Comparison Study

Data from the Method Comparison study on three EasyStat 300 analyzers demonstrate that all analytes (pH, pCO2, pO2) reported by the EasyStat 300 are favorably correlated to the predicate/reference device selected for this study. For all analytes (pH, pCO2, pO2), the linear regression slope, the coefficient of variation, and the calculated predicted bias at the decision levels for each analyte were within specifications.

Typical correlation results for all analytes (pO2, pCO2, pH) are shown below:

12

Image /page/12/Figure/1 description: This image contains four scatter plots comparing PO2 measurements using different methods (Syringe vs. Capillary) and their corresponding absolute differences. The top two plots show linear regressions, while the bottom two display absolute differences between ES300 PO2 and EasyStat PO2. Each method includes a table summarizing statistical parameters such as 'n', slope, intercept, R-squared, standard error, predicted bias, 95% confidence interval, 100% total allowable error, and status for MDL values of 30, 45, and 60. The Syringe method has a sample size of 272, while the Capillary method has a sample size of 224.

pO2 Method Comparison Analysis (Syringe & Capillary Modes)

13

Image /page/13/Figure/1 description: The image shows two scatter plots and a table comparing PCO2 measurement methods using a syringe. The first scatter plot, titled "PCO2 Method Comparison (Syringe), Linear Regression", plots ES300 PCO2 (Rep 1) against EasyStat PCO2 (Avg), with a linear regression line. The second scatter plot, titled "PCO2 Method Comparison (Syringe), Absolute Difference", plots the difference between ES300 PCO2 (Rep 1) and EasyStat PCO2 (Avg) against EasyStat PCO2 (Avg). The table provides statistical data, including n=265, Slope=1.040, Intercept=-1.159, R^2=0.992, and Std Error=1.326, as well as predicted bias, confidence intervals, allowable errors, and status for MDL values of 5.0, 62.5, and 150.0, all of which PASS.

pCO2 Method Comparison Analysis (Syringe & Capillary Modes)

Image /page/13/Figure/3 description: The image contains two scatter plots comparing PCO2 measurement methods using capillary samples. The first plot, titled "PCO2 Method Comparison (Capillary), Linear Regression," shows a linear regression analysis with EasyStat PCO2 (Avg) on the x-axis and ES300 PCO2 (Rep 1) on the y-axis. The second plot, titled "PCO2 Method Comparison (Capillary), Absolute Difference," displays the absolute difference between the two methods against EasyStat PCO2 (Avg). The image also includes a table with statistical parameters such as n=219, Slope=0.943, Intercept=2.624, R^2=0.911, and Std Error=1.946.

Min

7.0

61.3

143.3

2.34

-0.94

-5.93

5.0

62.5

150.0

Max

7.6

61.8

144.8

Min

0.0

57.5

138.0

Max

10.0

67.5

162.0

PASS

PASS

PASS

510(k) Summary, K211559/S001

14

Image /page/14/Figure/1 description: The image shows a pH method comparison between a syringe and a capillary. There are four scatter plots in the image. The top two plots show a linear regression between the two methods, while the bottom two plots show the absolute difference between the two methods. There are also tables that show the slope, intercept, R^2, and standard error for each method, as well as the predicted bias, 95% confidence interval, and 100% total allowable error.

pH Method Comparison Analysis (Syringe & Capillary Modes)

15

Sensitivity

The sensitivity study is used to validate the low end of the Reportable Range for a particular assay on the EasyStat 300. The study first establishes the Limit of Blank (LoB) that is the starting point for determining the Limit of Detection (LoD) and subsequently the Limit of Quantitation (LoQ).

The sensitivity study in this submission followed the guidelines from CLSI EP17-A. It was performed on three ES 300 analyzers covering the pH and blood gas sensors.

The following table lists the measured LoB, LoD, and LoQ for all analytes reported by the EasyStat 300 analyzer.

| Analyte | Type of sample used | LoB | LoD | LoQ | Lowest Detection Limit (LDL) | LoQ