K Number
K980839
Device Name
AVOCET PT
Date Cleared
1998-09-30

(210 days)

Product Code
Regulation Number
864.5425
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The AvocetpT is an in vitro diagnostic system that provides a quantitative prothrombin time result, expressed as an International Normalized Ratio (INR). It is intended for use by health care professionals in monitoring patients who are on warfarin-type (coumarin) anticoagulation therapy.
Device Description
The Avocetpr is a membrane-based, dry-reagent system for use with fresh capillary or venous whole blood, and citrated venous whole blood or citrated plasma. The system uses an membrane to separate plasma from red cells. The membrane contains calcium and thromboplastin, and permits the reactions of the complete extrinsic pathway to occur with minimal distortion from membrane surface interactions. Thrombin generation is monitored optically using a rhodamine-110-based fluorescent thrombin substrate. Fluorescence kinetics are analyzed to produce a prothrombin-time-equivalent parameter that is converted to an international normalized ratio (INR) value.
More Information

Not Found

Not Found

No
The description focuses on the biochemical and optical detection methods, and there is no mention of AI or ML in the device description, intended use, or performance studies.

No
The device is an in vitro diagnostic system used for monitoring patient anticoagulation therapy, not for directly treating a condition or restoring a function.

Yes
Explanation: The "Intended Use / Indications for Use" section explicitly states, "The AvocetpT is an in vitro diagnostic system..." This directly identifies the device as diagnostic.

No

The device description clearly outlines a hardware system involving a membrane, dry reagents, optical monitoring, and fluorescence kinetics analysis. This is not a software-only device.

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 AvocetpT is an "in vitro diagnostic system".
  • Device Description: The description details how the device analyzes a biological sample (blood or plasma) outside of the body to provide a diagnostic result (prothrombin time/INR). This is the core function of an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The Avocetor is an in vitro diagnostic system that provides a quantitative prothrombin time result, expressed as an International Normalized Ratio (INR). It is intended for use by health care professionals in monitoring patients who are on warfarin-type (coumarin) anticoagulation therapy. The Avocetor is an in vitro diagnostic system that provides a quantitative prothrombin time result, expressed as an International Normalized Ratio (INR). It uses fresh capillary whole blood, citrated venous whole blood or citrated venous plasma samples. It is intended for use by health care professionals in monitoring patients who are on warfarin-type (coumarin) anticoagulation therapy.

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

JPA

Device Description

The Avocetpr is a membrane-based, dry-reagent system for use with fresh capillary or venous whole blood, and citrated venous whole blood or citrated plasma. The system uses an membrane to separate plasma from red cells. The membrane contains calcium and thromboplastin, and permits the reactions of the complete extrinsic pathway to occur with minimal distortion from membrane surface interactions. Thrombin generation is monitored optically using a rhodamine-110-based fluorescent thrombin substrate. Fluorescence kinetics are analyzed to produce a prothrombin-time-equivalent parameter that is converted to an international normalized ratio (INR) value.

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

health care professionals

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)

The accuracy of the Avocetor was compared to the CoaguChek and a reference method in field studies and found to be equivalent (r>0.95). Precision and linearity evaluations were done on the Avocetor and found to be acceptable. Additional testing of interfering substances, hematocrit, RBC abnormalities and factor deficiencies were performed and the results are reflected in the product labeling.

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.

The Boehringer Mannheim Coaguchek™ System

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.

Not Found

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

§ 864.5425 Multipurpose system for in vitro coagulation studies.

(a)
Identification. A multipurpose system for in vitro coagulation studies is a device consisting of one automated or semiautomated instrument and its associated reagents and controls. The system is used to perform a series of coagulation studies and coagulation factor assays.(b)
Classification. Class II (special controls). A control intended for use with a multipurpose system for in vitro coagulation studies is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 864.9.

0

SEP 3 0 1998

Image /page/0/Picture/2 description: The image shows the logo for AOCET Medical Incorporated. The logo features a stylized "A" connected to the letters "OCET" in a sans-serif font. Below the letters is the text "MEDICAL INCORPORATED" in a smaller font size. The logo is black and white.

1696 Dell Ave., Campbell, CA 95008 · 408/374-7262 · Fax 408/374-7822

Avocet Medical, Inc. Avocetpr System 510(k) Premarket Notification

510(k) Summary

Introduction:

According to the requirements of 21 CFR 807.92, the following information provides sufficient detail to understand the basis for a determination of substantial equivalence.

    1. Submitter's name Avocet Medical, Inc. address, contact 1696 Dell Avenue Campbell, CA 95008 (408) 374-7262 (phone) (408) 374-7822 (fax)
      Contact person: Judith Blunt

Date prepared: June 8, 1998

  • Common or Usual Name: Prothrombin Time Test (INR) 2. Device name
    Classification Name: Prothrombin Time Test

Trade or Proprietary Name: AvocetpT

    1. Predicate device The Boehringer Mannheim Coaguchek™ System: device for testing Prothrombin Time and INR in whole blood.
      The Avocetpr is a membrane-based, dry-reagent system for 4. Device description use with fresh capillary or venous whole blood, and citrated venous whole blood or citrated plasma. The system uses an membrane to separate plasma from red cells. The membrane contains calcium and thromboplastin, and permits the reactions of the complete extrinsic pathway to occur with minimal distortion from membrane surface interactions. Thrombin generation is monitored optically using a rhodamine-110-based fluorescent thrombin substrate. Fluorescence kinetics are analyzed to produce a

1

AOCET
MEDICAL INCORPORATED

1696 Dell Ave., Campbell, CA 95008 · 408/374-7262 · Fax 408/374-7822

Avocet Medical, Inc. Avocetpr System 510(k) Premarket Notification

prothrombin-time-equivalent parameter that is converted to an international normalized ratio (INR) value.

  1. Intended use: The Avocetor is an in vitro diagnostic system that provides a quantitative prothrombin time result, expressed as an International Normalized Ratio (INR). It is intended for use by health care professionals in monitoring patients who are on warfarin-type (coumarin) anticoagulation therapy.

  2. Comparison to The Avocetor is substantially equivalent in materials, design and intended use to other products that measure predicate device Prothrombin Time INR in human blood. Most notably, it is substantially equivalent to the CoaguChek™, manufactured by the Boehringer Mannheim Corporation. Both products are prothrombin time devices, have the same intended use and serve the same professional, point-of-care market. The AvocetpT and the CoaguChek both measure the extrinsic coagulation pathway, expressed as an International Normalized Ratio. Both products measure the elapsed time between the start of the reaction and the formation of thrombin using a dry reagent thromboplastin. While CoaguChek measures this formation as expressed through the conversion of fibrinogen (a thrombin substrate) to fibrin via the motion of magnetic particles, the AvocetpT measures this formation as expressed through the conversion of (Tos-Gly-Pro-Arg)2-Rhodamine 110 (a thrombin substrate) to free Rhodamine via a change in fluorescence.

  3. Summary of The accuracy of the Avocetor was compared to the performance data CoaguChek and a reference method in field studies and found to be equivalent (r>0.95). Precision and linearity evaluations were done on the Avocetor and found to be acceptable. Additional testing of interfering substances, hematocrit, RBC abnormalities and factor deficiencies were performed and the results are reflected in the product labeling.

2

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" around the perimeter. Inside the circle is a stylized symbol that resembles a human figure or a caduceus, rendered in black and white.

Public Health Service

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

SEP 3 0 1998

Ms. Judith Blunt Director of Regulatory Affairs and Quality Assurance Avocet Medical Incorporated 1696 Dell Avenue Campbell, California 95008

Re : K980839/S1 Trade Name: Avocetpr Regulatory Class: II Product Code: JPA Dated: July 2, 1998 Received: July 6, 1998

Dear Ms. Blunt:

We have reviewed your Section 510(k) notification of intent to market the device referenced above and we 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). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual reqistration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.

If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.

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Page 2

This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a leqally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4588. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the requlation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597, or at its internet address "http://www.fda.gov/cdrh/dsma/dsmamain.html".

Sincerely yours,

Steven Butman

Steven I. Gutman, M.D., M.B.A. ..................... Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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March 12, 1998

PREMARKET NOTIFICATION INDICATIONS FOR USE FORM

Page 1 of 1

510(K) Number: Not known

Device Name: AvocetpT System

The Avocetor is an in vitro diagnostic system that provides a quantitative prothrombin time result, expressed as an International Normalized Ratio (INR). It uses fresh capillary whole blood, citrated venous whole blood or citrated venous plasma samples. It is intended for use by health care professionals in monitoring patients who are on warfarin-type (coumarin) anticoagulation therapy.

This does not differ substantially from the intended use of the Boehringer Mannheim Coagu Chek (predicate device).

PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED

Concurrence of CDRH, Office of Device Evaluation/(ODE)

(Division Sign-Off)
Division of Clinical Laboratory Devices
510(k) NumberK980839
Prescription Use✓ OR Over-The-Counter Use ____
(Per 21 CFR 801.109)(Optional Format 1-2-96