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510(k) Data Aggregation
(20 days)
CHIRON DIAGNOSTICS ACS:180 TROPONIN I ASSAY (CTNI)
For the quantitative determination of cardiac troponin I in serum or heparinized plasma and as an aid in the diagnosis of acute myocardial infarction using the Chiron Diagnostics ACS: 180® Automated Chemiluminescence Systems.
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The provided documents are an FDA 510(k) clearance letter for the Chiron Diagnostics ACS:180® Troponin I Assay. While they confirm the device's substantial equivalence and provide its intended use, they do not contain detailed information about acceptance criteria, specific study designs, or performance metrics beyond the general statement of substantial equivalence.
Therefore, I cannot fully answer your request based solely on the provided text. The FDA clearance letter typically refers to information submitted by the manufacturer in their 510(k) application, which would contain such details.
However, based on the context of a 510(k) submission for an in-vitro diagnostic (IVD) device like a Troponin I assay, I can infer the types of information that would likely be present in the full submission, and frame a partial answer accordingly:
Based on the provided FDA 510(k) clearance letter (K980528) for the Chiron Diagnostics ACS:180® Troponin I Assay, the following information can be inferred or is directly stated, but detailed specifics on acceptance criteria and study data are not present in these documents.
The letter confirms the device is substantially equivalent to legally marketed predicate devices and is intended for "quantitative determination of cardiac troponin I in serum or heparinized plasma and as an aid in the diagnosis of acute myocardial infarction using the Chiron Diagnostics ACS: 180® Automated Chemiluminescence Systems."
To fully address your request, one would need to review the complete 510(k) submission (e.g., the Special Controls Guidance Document for Cardiac Troponin devices, or the specific studies performed by Chiron Diagnostics).
Here's an outline of what would typically be found in a 510(k) submission for such a device, and why the provided documents don't offer the detailed answers:
1. A table of acceptance criteria and the reported device performance
- Information in provided document: Not present.
- Inferred: For an IVD like this, acceptance criteria would typically include:
- Analytical Sensitivity: Limit of Blank (LoB), Limit of Detection (LoD), Limit of Quantitation (LoQ).
- Analytical Specificity: Interference studies (hemoglobin, triglycerides, bilirubin, common medications), cross-reactivity with other cardiac or skeletal muscle proteins.
- Precision/Reproducibility: Within-run (intra-assay) and between-run (inter-assay) precision (CV%) at various concentrations, often near the medical decision points.
- Linearity/Reportable Range: Demonstration that the assay accurately measures concentrations across its claimed range.
- Accuracy/Method Comparison: Comparison against a legally marketed predicate device or a reference method using patient samples, typically assessed by correlation (regression analysis) and bias (e.g., Bland-Altman plots). This would be key for demonstrating "substantial equivalence."
- Clinical Performance (aid in diagnosis of AMI): This would involve sensitivity and specificity for diagnosing AMI, usually against a clinical endpoint (e.g., WHO criteria for AMI, or consensus diagnosis by clinicians). This would involve establishing cutoff values.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Information in provided document: Not present.
- Inferred: The 510(k) submission would detail:
- Sample Size: Typically hundreds to thousands of patient samples for method comparison and clinical performance studies. Smaller numbers for analytical performance (e.g., precision, linearity).
- Provenance: This would state whether samples were from specific hospitals, regions, or collected to meet specific demographic criteria. They would likely be retrospective, but could include prospective elements for clinical studies. The country of origin would be specified.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
- Information in provided document: Not present.
- Inferred: For the "aid in the diagnosis of acute myocardial infarction" claim:
- Ground Truth for AMI: Typically established by a panel of independent cardiologists or emergency physicians, sometimes alongside a review of patient charts, ECGs, cardiac imaging, and serial cardiac marker results, based on established clinical guidelines (e.g., ESC/ACC/AHA/WHF Universal Definition of Myocardial Infarction). These experts would need to be board-certified with relevant clinical experience. The number would vary, but typically 2-3 independent clinicians would review each case.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Information in provided document: Not present.
- Inferred: If multiple experts were used to establish clinical ground truth for AMI, an adjudication method would be employed. Common methods include:
- Consensus: All experts must agree.
- Majority Rule: E.g., 2 out of 3 agree.
- Adjudicator: If there's disagreement among initial reviewers, a senior expert (the "plus 1") reviews the case and makes the final determination.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- Information in provided document: Not present.
- Inferred: This device is an in-vitro diagnostic assay (blood test), not an imaging AI diagnostic device for "human readers." Therefore, an MRMC study comparing human reader performance with and without AI assistance is not applicable to this type of device. The "AI" is the automated instrument (ACS:180) that performs the assay, not a cognitive aid for a human interpreter of an image.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Information in provided document: Yes, implicitly.
- Answer: The performance metrics for an IVD assay (like sensitivity, specificity, accuracy, precision, etc.) are inherently "standalone" in the sense that they reflect the analytical and clinical performance of the assay system itself, irrespective of human interpretation in real-time. The result is quantitative (a number), and its diagnostic utility is then interpreted by a clinician.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Information in provided document: Not present explicitly in the clearance letter.
- Inferred:
- Analytical Performance: Ground truth for concentration would be established by reference methods, gravimetric dilutions, or certified reference materials.
- Clinical Performance (for AMI diagnosis): The 'ground truth' for the diagnosis of Acute Myocardial Infarction would be established by a combination of:
- Clinical judgment/Expert Consensus: As described in point 3, based on comprehensive patient data (symptoms, ECG changes, imaging, and potentially serial cardiac marker trends from a predicate device or reference method).
- Outcomes Data: Patient follow-up to confirm definitive diagnosis or rule out AMI.
8. The sample size for the training set
- Information in provided document: Not present.
- Inferred: While "training set" is more common for machine learning, for an IVD assay, method development involves extensive testing and optimization. The sample size for validation studies (which are analogous to "test sets" for performance evaluation) is distinct from the samples used during initial research, development, and optimization. The 510(k) would focus on the validation study sample sizes.
9. How the ground truth for the training set was established
- Information in provided document: Not present.
- Inferred: For the development/optimization phase of an IVD, ground truth for calibrators and controls would be established by meticulous analytical chemistry techniques and comparison to established reference standards. For clinical performance optimization, similar methods to those in point 7 would be used, but in an iterative process to refine assay parameters and cutoffs.
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