K Number
K993829
Device Name
ACCU-CHEK SIMPLICITY SYSTEM
Date Cleared
1999-12-09

(27 days)

Product Code
Regulation Number
862.1345
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The test strips are to be used with the Accu-Chek Simplicity meter. The Accu-Chek Simplicity system is designed for testing glucose in whole blood by persons with diabetes or by health care professionals in the home or in health care facilities.
Device Description
Instrument Operating Principle -- photometric Reagent Test Principle -- glucose deoxy reductase
More Information

Not Found

No
The summary describes a standard photometric glucose meter and test strips, with no mention of AI, ML, or related concepts.

No
The device, Accu-Chek Simplicity, is designed for testing glucose levels, which is a diagnostic function rather than a therapeutic one. It measures a condition but does not treat or alleviate it.

Yes
The device is described as a "glucose in whole blood" testing system, which is used for monitoring and managing diabetes, a diagnostic purpose.

No

The device description explicitly mentions "Instrument Operating Principle -- photometric" and "Reagent Test Principle -- glucose deoxy reductase," indicating the use of hardware components (meter and test strips) for measurement, not just software.

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

Here's why:

  • Intended Use: The intended use explicitly states that the system is "designed for testing glucose in whole blood". This is a diagnostic test performed on a biological sample (whole blood) outside of the body (in vitro).
  • Device Description: The description mentions a "Reagent Test Principle" (glucose deoxy reductase) and an "Instrument Operating Principle" (photometric). These are components and principles used in in vitro diagnostic testing.
  • Anatomical Site: The test is performed on "whole blood", which is a biological specimen.
  • Intended User / Care Setting: The device is intended for use by "persons with diabetes or by health care professionals in the home or in health care facilities", indicating a diagnostic purpose for managing a medical condition.

All of these points align with the definition of an In Vitro Diagnostic device, which is used to examine specimens taken from the human body to provide information for diagnostic, monitoring, or screening purposes.

N/A

Intended Use / Indications for Use

The test strips are to be used with the Accu-Chek Simplicity meter. The Accu-Chek Simplicity system is designed for testing glucose in whole blood by persons with diabetes or by health care professionals in the home or in health care facilities.

Product codes

LFR

Device Description

Instrument Operating Principle -- photometric
Reagent Test Principle -- glucose deoxy reductase

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

persons with diabetes or by health care professionals in the home or in health care facilities.

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)

Performance Characteristics Method Comparison
Capillary blood study: N = 297, y = 1.02x - 5.2, r = 0.977, range = 57 to 515 mg/dL
Consumer study: N = 230, y = 1.05x - 7.0, r = 0.982, range = 57 to 515 mg/dL

Precision
Control Level 1:
• Mean (mg/dL): 52
• Standard Deviation (SD) (mg/dL): 1.6
Control Level 2:
• Mean (mg/dL): 167
• Standard Deviation (SD) (mg/dL): 4.7
• CV: 2.8
Venous Blood Level 1:
• Mean (mg/dL): 53
• Standard Deviation (SD) (mg/dL): 1.7
Venous Blood Level 2:
• Mean (mg/dL): 153
• Standard Deviation (SD) (mg/dL): 6.3
• CV: 4.1
Venous Blood Level 3:
• Mean (mg/dL): 499
• Standard Deviation (SD) (mg/dL): 16.3
• CV: 3.3

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

Not Found

Predicate Device(s)

K971876

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 862.1345 Glucose test system.

(a)
Identification. A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.(b)
Classification. Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.

0

DEC - 9 1999

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
name, address,
contact | Roche Diagnostics Corporation
9115 Hague Rd.
Indianapolis, IN 46250
(317) 845-2000 |
| | Contact Person: Mike Flis |
| | Date Prepared: November 09, 1999 |
| 2) Device name | Proprietary name: Accu-Chek Simplicity™ System
Common name: whole blood glucose test system
Classification name: Glucose dehydrogenase, glucose |
| 3) Predicate
device | We claim substantial equivalence to the current legally marketed version of
the same device. |
| 4) Device
Description | Instrument Operating Principle -- photometric
Reagent Test Principle -- glucose deoxy reductase |
| 5) Intended use | The test strips are to be used with the Accu-Chek Simplicity meter. The
Accu-Chek Simplicity system is designed for testing glucose in whole blood
by persons with diabetes or by health care professionals in the home or in
health care facilities. |
| 6) Comparison
to predicate
device | The Roche Diagnostics Accu-Chek Simplicity System is substantially
equivalent to the current legally marketed version of the same device. |

1

Comparison to Predicate Device - .

Similarities

Feature/ClaimDetail
Intended useThe test strips are to be used with the Accu-Chek Simplicity meter.
The Accu-Chek Simplicity system is designed for testing glucose
in whole blood by persons with diabetes or by health care
professionals in the home or in health care facilities.
Test principleGlucose dehydrogenase chemical reaction. The instrument
measures the chemical reaction by detecting photometric changes.
Monitor coding
procedureCode chip is provided with each carton of test strips.
Minimum sample
volume3 µL
Test strip storage
conditionsStore the strips at room temperature between +36° F and +86° F.
Do not freeze.
Test strip operating
conditionsUse at temperatures between 50° and 104° F and less than 85%
humidity.
Quality control
procedureTests should be run with liquid quality control materials whenever
a new vial of test strips is opened or an unusual blood test result is
obtained.
Labeling instructions
regarding expected
resultsThe normal fasting adult blood glucose range for a non-diabetic is
70-105 mg/dL. One to two hours after meals, normal blood
glucose levels should be less than 140 mg/dL. Doctors will
determine the range that is appropriate for the patients.
Labeling instructions
regarding response to
unusual resultsRun a quality control test, if the result is outside the acceptable QC
recovery range contact Roche Diagnostics's Accu-Chek Customer
Care center; if result is within the acceptable range, review proper
testing procedure and repeat blood glucose test with a new test
strip.
Hematocrit range30 to 57%
Reportable range10-600 mg/dL
Warnings and
precautionsFor in vitro diagnostic use only.
Reagent stability18 months

Continued on next page

2

Comparison to Predicate Device, Continued

Similarities, Contd.

Reagent compositionCopied from test strip carton label (qty/cm2):
Glucose-dye-oxidoreductase
Bis-(2-hydroxyethyl)-(4-hydroxminocyclohexa-2,5-dienylidene)-
ammonium chloride
2,18-Phosphomolybdic acid
Stabilizer
Nonreactive substances.
Minimum at time of manufacture.

Differences

| Feature | Accu-Chek Simplicity
Test Strip
(modified) | Accu-Chek Simplicity
Test Strip
(predicate) |
|-------------------------|--------------------------------------------------------------------------|------------------------------------------------------------------------|
| Values equivalent to... | plasma lab method | whole blood method |
| Maximum altitude | Tested acceptably at
elevations up to 10,150
feet above sea level1 | Tested acceptably at
elevations up to 9500
feet above sea level. |
| Acceptable sample type | Fresh capillary whole
blood only2 | Fresh capillary and
heparinized venous
whole blood samples |

    1. The effect of altitude was examined at a different clinical investigation site than K971876. The site selected for the most recent examination was higher than the prior site. The results of the 1999 study confirm the device performs acceptably at 10,150 feet.
    1. The proposed modification does not adversely effect the product's performance with heparinized whole blood samples. The removal of the venous sample claim from the product's labeling is triggered by our desire to position this device as a test best suited for consumer testing. The draft labeling only includes references to capillary fingerstick testing procedures and summaries of results obtained in capillary blood clinical studies.

Continued on next page

3

Comparison to Predicate Device, Continued

Performance Characteristics Method Comparison

| Feature | Accu-Chek Simplicity
Test Strip Package
Insert
(modified) | Accu-Chek Simplicity
Test Strip Package
Insert
(predicate) |
|------------------------------------------|--------------------------------------------------------------------------|---------------------------------------------------------------------------|
| Laboratory method | Hitachi glucose plasma | Hitachi glucose hexokinase
whole blood |
| Capillary blood study | N = 297
$y = 1.02x - 5.2$
$r = 0.977$
$range = 57 to 515 mg/dL$ | N = 202
$y = 1.02x + 2.6$
$r = 0.989$
$range = 51 to 490 mg/dL$ |
| Physician's Office
Venous blood study | Not applicable | N = 104
$y = 1.029x + 2.7$
$r = 0.995$
$range = 35 to 483 mg/dL$ |
| Consumer study | N = 230
$y = 1.05x - 7.0$
$r = 0.982$
$range = 57 to 515 mg/dL$ | N = 134
$y = 1.082x - 2.9$
$r = 0.976$
$range = 58 to 357 mg/dL$ |

Continued on next page ﭘﺎ

r

4

Comparison to Predicate Device, Continued

Performance Characteristics,
Contd.

Precision

| Parameter | Accu-Chek
Simplicity
Test Strip
Package Insert
(modified) | Accu-Chek
Simplicity
Test Strip Package
Insert
(predicate) |
|----------------------------------|-----------------------------------------------------------------------|------------------------------------------------------------------------|
| | N = 20/Level | N = 20/Level |
| Control Level 1 | | |
| •Mean (mg/dL) | 52 | 84.0 |
| •Standard Deviation (SD) (mg/dL) | 1.6 | 2.0 |
| Control Level 2 | | |
| •Mean (mg/dL) | 167 | 196.4 |
| •Standard Deviation (SD) (mg/dL) | 4.7 | |
| •CV | 2.8 | 2.5 |
| Venous Blood Level 1 | | |
| •Mean (mg/dL) | 53 | 28.7 |
| •Standard Deviation (SD) (mg/dL) | 1.7 | 1.2 |
| Venous Blood Level 2 | | |
| •Mean (mg/dL) | 153 | 129.4 |
| •Standard Deviation (SD) (mg/dL) | 6.3 | |
| •CV | 4.1 | 3.0 |
| Venous Blood Level 3 | | |
| •Mean (mg/dL) | 499 | 335.0 |
| •Standard Deviation (SD) (mg/dL) | 16.3 | |
| •CV | 3.3 | 3.4 |

5

Image /page/5/Picture/1 description: The image is a black and white logo for the Department of Health & Human Services USA. The logo is circular in shape, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. Inside the circle is a stylized image of an eagle with its wings spread, with three lines representing the wings.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

DEC - 9 1999

Mr. Mike Flis Regulatory Affairs Principal Roche Diagnostics Corporation 9115 Hague Road P.O. Box 50457 Indianapolis, Indiana 46250-0457

Re: K993829

Trade Name: Accu-Chek Simplicity™ System Regulatory Class: II Product Code: LFR Dated: November 10, 1999 Received: November 12, 1999

Dear Mr. Flis:

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 registration, 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 Regulations, 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 (OS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic OS 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.

6

Page 2

Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity categorization. To determine if it does, you should contact the Centers for Disease Control and Prevention (CDC) at (770) 488-7655.

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 legally 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 regulation 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 Putman

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

7

Indications for Use Statement

510(k) Number (if known): Device Name: Accu-Chek Simplicity™ System

Indications for Use:

The test strips are to be used with the Accu-Chek Simplicity meter. The Accu-Chek Simplicity system is designed for testing glucose in whole blood by persons with diabetes or by health care professionals in the home or in health care facilities.

Jean Cooper

(Division Sign-Off)
Division of Clinical Laboratory Devices
510(k) Number K973629

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

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription Use (Per 21 CFR 801.109) OR

Over-The-Counter Use

(Optional Format 1-2-96)