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510(k) Data Aggregation

    K Number
    K160445
    Date Cleared
    2016-03-16

    (28 days)

    Product Code
    Regulation Number
    864.7925
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    HemosIL Silica Clotting Time

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HemosIL Silica Clotting Time is intended for the detection of Lupus Anticoagulants in human citrated plasma on the IL Coagulation Systems by the use of screening (SCT Screen) and confirmatory (SCT Confirm) reagents sensitized to phospholipid dependent antibodies. For in vitro diagnostic use.

    Device Description

    The HemoIL SCT assay, consisting of SCT Screen and SCT Confirm, is intended to simplify and standardize the detection of Lupus Anticoagulants (LA) in clinical evaluations. SCT Screen is poor in phospholipid making it sensitive to LA. The additional amount of phospholipid in SCT Confirm neutralizes LA to give shorter clotting times. Silica Clotting Time in the presence of calcium, directly activates the intrinsic pathway of coagulation. SCT Screen and SCT Confirm are therefore unaffected by factor VII deficiencies or inhibitors.

    AI/ML Overview

    This document is not structured as a typical study report, but rather as a 510(k) summary for a Special 510(k) submission. A Special 510(k) is used when a modification is made to a legally marketed device, and the modification does not affect the device's indications for use or its fundamental scientific technology. In this case, the modification is to the device's labeling (specifically, clarifying heparin interference information) based on updated guidance (CLSI Guideline H60-A).

    Therefore, the primary "study" proving the device meets acceptance criteria in this context is the demonstration that the changes are only to the labeling and do not impact the assay's performance compared to the predicate device. This type of submission relies heavily on the predicate's prior clearance and the assertion that the core device technology and performance remain unchanged.

    Given this, I will describe the "acceptance criteria" and "device performance" in terms of substantiating that the change in labeling does not alter the device's substantial equivalence to its predicate.

    Here's the breakdown of information, addressing your points where applicable based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (for Special 510(k) regarding labeling change)Reported Device Performance (as stated in the 510(k) summary)
    No change in indications for use or intended use: The modified device must serve the same clinical purpose as the predicate."No change in indications for use or intended use." The Indications for Use for both predicate and modified device are: "HemosIL Silica Clotting Time is intended for the detection of Lupus Anticoagulants in human citrated plasma on the IL Coagulation Systems by the use of screening (SCT Screen) and confirmatory (SCT Confirm) reagents sensitized to phospholipid dependent antibodies."
    No change in operating principle: The core scientific methodology by which the device functions must remain the same."No change in operating principle." The methodology is described as "Clotting Time in the presence of reagents" for both.
    No change to stability claims or to storage instructions: The shelf life and handling requirements for the reagents must be unaltered."No change to stability claims or to storage instructions."
    No change to reagent preparation: The procedure for preparing the HemosIL SCT reagents (SCT Screen and SCT Confirm) must be the same."No change to reagent preparation."
    No change to specimen collection and preparation: The requirements for patient sample collection and handling must be unchanged."No change to specimen collection and preparation."
    No change to formulation or materials: The chemical composition and components of the reagents must be identical."No change to formulation or materials." The device description for both predicate and modified remains: "The HemoIL SCT assay, consisting of SCT Screen and SCT Confirm, is intended to simplify and standardize the detection of Lupus Anticoagulants (LA) in clinical evaluations. SCT Screen is poor in phospholipid making it sensitive to LA. The additional amount of phospholipid in SCT Confirm neutralizes LA to give shorter clotting times."
    No change to data reduction software: Any software used to process or interpret the results from the device must be the same."No change to data reduction software."
    No change to test parameters: The settings or conditions under which the test is performed must be identical."No change to test parameters."
    No change to calibration: The calibration procedure and standards must remain the same."No change to calibration."
    No change to quality controls: The quality control materials and procedures must be unchanged."No change to quality controls."
    Demonstration that the only changes are to the insert sheet for clarity regarding heparin interference, based on current guidance (CLSI Guideline H60-A), and that these changes do not alter the analytical or clinical performance of the device.The submission explicitly states the changes are to "remove the current Heparin interference references in the Summary and Principle section and the Limitations/ Interfering Substances section based on current guidance H60-A Laboratory Testing for the Lupus Anticoagulant; Approved Guideline (April 2014), with the associated references added to the Bibliography section." The core assertion is: "There is no change to the assay itself."

    2. Sample size used for the test set and the data provenance
    The document describes a Special 510(k) submission. This type of submission is based on the premise that there are no actual changes to the device's performance, but rather to its labeling or minor design aspects.
    Therefore, no new "test set" data from patient samples is typically required or provided for a Special 510(k) for a labeling change. The claim of substantial equivalence rests on the device being unchanged and performing as cleared under its predicate (K050221). The "study" here is the comparison demonstrating no change to the device itself.

    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)
    Not applicable. No new clinical or analytical performance study requiring a ground truth determination from experts on a new test set was conducted for this Special 510(k) submission. The changes are to informational labeling based on a published guideline (CLSI H60-A).

    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set
    Not applicable, as no new test set requiring expert adjudication was utilized for this type of submission.

    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
    Not applicable. This device is an in vitro diagnostic (IVD) reagent for a laboratory test (detection of Lupus Anticoagulants), not an imaging device or an AI-powered diagnostic system designed for human reader assistance.

    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
    Not applicable. This is an IVD reagent, not an algorithm. Its performance is measured directly by clinical laboratory methods.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
    Not applicable to this Special 510(k) based on a labeling change. The original predicate device (K050221) would have established its performance against appropriate reference methods or clinical outcomes during its initial clearance process. For this submission, the "ground truth" is that the device itself has not changed and therefore its previously established performance holds. The update to the labeling regarding heparin interference aligns with an industry-accepted guideline (CLSI Guideline H60-A).

    8. The sample size for the training set
    Not applicable. No training set was used for this Special 510(k) submission.

    9. How the ground truth for the training set was established
    Not applicable. No training set was used for this Special 510(k) submission.

    In summary of the "study":

    The "study" in this Special 510(k) is a comparison study that demonstrates the "modified device" is identical in all functional aspects to the "predicate device," with the only changes being to the instructional labeling regarding heparin interference. The acceptance criterion is that no functional or performance changes were introduced, and therefore the device remains substantially equivalent to the previously cleared predicate (K050221). The proof is in the documentation confirming no changes to formulation, operating principle, indications for use, stability, specimen requirements, software, or test parameters.

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    K Number
    K050221
    Date Cleared
    2005-03-30

    (58 days)

    Product Code
    Regulation Number
    864.7925
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    HEMOSIL SILICA CLOTTING TIME

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    HemosIL Silica Clotting Time is intended for the detection of Lupus Anticoagulants in human citrated plasma on the IL Coagulation Systems by the use of screening (SCT Screen) and confirmatory (SCT Confirm) reagents sensitized to phospholipid dependent antibodies. For in vitro diagnostic use.

    Device Description

    HemosIL Silica Clotting Time is intended for the detection of Lupus Anticoagulants in human citrated plasma on the IL Coagulation Systems by the use of screening (SCT Screen) and confirmatory (SCT Confirm) reagents sensitized to phospholipid dependent antibodies.

    AI/ML Overview

    Here's a summary of the acceptance criteria and study details for the HemosIL Silica Clotting Time device, based on the provided text:

    Acceptance Criteria and Device Performance

    Acceptance Criteria CategorySpecific Acceptance Criteria (Implied by Predicate Equivalence)Reported Device Performance (HemosIL Silica Clotting Time)
    Method CorrelationSubstantially equivalent correlation to predicate devices (HemosIL LAC Screen and HemosIL LAC Confirm)Slope: 1.099
    Intercept: -0.086
    r (correlation coefficient): 0.874
    Clinical Performance (Cut-off ≥ 1.20 for predicate)Substantially equivalent diagnostic accuracy to predicate devicesRelative Sensitivity: 92.4% (95% C.I. = 82.1-97.0)
    Relative Specificity: 100% (95% C.I. = 97.6-100.0)
    Precision (Within Run)Acceptable within-run variabilityNormal Control: 2.47% CV
    Low LA Control: 4.05% CV
    High LA Control: 5.24% CV
    Precision (Total)Acceptable total variabilityNormal Control: 2.95% CV
    Low LA Control: 6.00% CV
    High LA Control: 5.60% CV

    Note: The document explicitly states that the device "is substantially equivalent to the commercially available predicate devices (HemosIL LAC Screen and HemosIL LAC Confirm) in performance and intended use." This implies that the acceptance criteria were based on demonstrating comparable performance to these predicate devices rather than pre-defined absolute thresholds, for the correlation and clinical performance metrics. For precision, the reported %CVs fall within generally acceptable ranges for diagnostic assays.


    Study Details

    1. Sample size used for the test set and the data provenance:

      • Method Comparison Study: 210 citrated plasma samples (120 normals/90 abnormals)
      • Clinical Study: 206 citrated plasma samples (121 normals/85 abnormals)
      • Data Provenance: "in-house study" and "clinical study." The document does not specify the country of origin, but given the manufacturer (Lexington, MA, USA) and the 510(k) submission to the FDA, it is highly probable the studies were conducted within the US or followed US regulatory guidelines. The studies appear to be retrospective as they involved analyzing collected plasma samples.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • The document does not explicitly state the number or qualifications of experts used to establish the ground truth for the test set. The ground truth appears to be based on the results from the predicate devices (HemosIL LAC Screen and HemosIL LAC Confirm) for comparison. The classification of samples as "normals" and "abnormals" for Lupus Anticoagulants would have been based on established clinical diagnostic criteria, likely involving expert interpretation of multiple tests, but this detail is not provided.
    3. Adjudication method for the test set:

      • The document does not describe a specific adjudication method. As the primary comparison is against predicate devices, the "ground truth" for the test set is established by the results of those predicate devices.
    4. 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:

      • No. This device is an in-vitro diagnostic (IVD) assay, not an AI-assisted imaging or diagnostic tool that requires human reader interpretation. Therefore, an MRMC study is not applicable.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • Yes. The reported performance metrics (slope, intercept, r, sensitivity, specificity, precision) are for the HemosIL Silica Clotting Time device running on an IL Coagulation System, indicating a standalone (algorithm/device only) performance evaluation. There is no mention of human-in-the-loop performance.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

      • The ground truth for the test sets (both method comparison and clinical) appears to be established by the results obtained from the predicate devices (HemosIL LAC Screen and HemosIL LAC Confirm). Additionally, for the clinical study, it's mentioned that "All known Lupus Anticoagulant samples (n=48) tested as part of this study gave SCT normalized ratios > 1.24," suggesting that a subset of the abnormal samples had a pre-established clinical diagnosis of Lupus Anticoagulant, likely based on a combination of tests and expert consensus.
    7. The sample size for the training set:

      • The document does not specify a separate "training set" in the context of machine learning. This is an IVD device, and the development process would involve formulation, optimization, and characterization rather than AI model training. The "in-house study" and "clinical study" are performance validation studies.
    8. How the ground truth for the training set was established:

      • Not applicable as there is no mention of a separate training set in the context of an AI/ML model for this IVD device. The development of such a device focuses on reagent formulation and instrument calibration, typically using well-characterized samples and reference methods.
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