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510(k) Data Aggregation
(15 days)
The use of this reagent is indicated for the measurement of CO2 levels in serum or plasma on manual or automated systems. The measurement of serum or plasma CO2 content is useful in the assessment of disturbance of acid base balance in respiratory or metabolic acidosis and alkalosis
This reagent is intended for the quantitative in vitro enzymatic determination of CO2 in serum or plasma on manual or automated systems. The method used in the present procedure is based on the following reactions. Carbon dioxide, in the form of bicarbonate ions, reacts with phosphoenolpyruvate (PEP) to form oxaloacetate and phosphate. This reaction is catalyzed by the enzyme phosphoenolpyruvate carboxylase (PEPC). PEP + HCO3- - PERC > oxaloacetate + H2PO4 This reaction is coupled with a second enzymatic reaction. Oxaloacetate, in the presence of malate dehydrogenase (MDH), is converted to malate, by reduced nicotinamide adenine dinucleotide (NADH). In this reaction one molecule of NADH is oxidized for each molecule of oxaloacetate present. oxaloacetate + NADH + H - MDH > malate + NAD The decrease in absorbance resulting from the oxidation of NADH is proportional to the original concentration of CO2 in the sample. Raichem wishes to market an extended stability formulation modification of the predicate device. Slight variations in the concentrations of ingredients were made to achieve an extended reconstituted stability of one year at 2 to 8 °C. The assay procedure and timing of the assay is the same as that of the predicate device.
The provided document is a 510(k) submission for a medical device called "CO2 XL Reagent". This document focuses on demonstrating substantial equivalence to a predicate device and does not describe a study in the context of typical AI/ML device evaluations. Therefore, many of the requested categories are not applicable.
Here's an attempt to extract relevant information, with a strong emphasis on what is not present in the document.
Acceptance Criteria and Device Performance (as much as can be inferred from a 510(k) for a reagent):
The acceptance criteria for this type of device (a chemical reagent for in vitro diagnostic use) are typically centered around analytical performance parameters such as precision, accuracy (often demonstrated through comparison with a predicate device), and interference. The "device performance" reported is essentially the results of these analytical studies.
Acceptance Criteria Category | Specific Criteria (Inferred/Typical for Reagents) | Reported Device Performance (CO2 XL Reagent) |
---|---|---|
Precision | Coefficient of Variation (CV%) should be low, indicating reproducibility. | Manual Assay: |
Within Run: | ||
@ 15.7 mmol/L: CV = 4.3% | ||
@ 23.2 mmol/L: CV = 1.8% | ||
Total: | ||
@ 15.3 mmol/L: CV = 5.7% | ||
@ 23.2 mmol/L: CV = 2.3% | ||
Hitachi 717 Automated Assay: (Table headers are garbled, but implies precision studies were performed over 26 days following NCCLS EP5-T2, suggesting similar parameters would be evaluated and found acceptable.) | ||
Accuracy / Comparison to Predicate | Strong correlation (high R, close to 1) and linear regression equation close to y = x, demonstrating agreement with the predicate device. | Comparison with Raichem CO2 Reagent (Manual Assay): |
Number of sample pairs: 65 | ||
Range: 4 - 40 mmol/L | ||
Correlation Coefficient: 0.993 | ||
Regression Equation: y = 0.988x + 0.43 | ||
Automated Method (Hitachi 717) Comparison: | ||
Number of sample pairs: 107 | ||
Range: 7 - 46 mmol/L | ||
Correlation Coefficient: 0.998 | ||
Regression Equation: y = 0.976x + 0.487 | ||
Interference | No significant interference from common endogenous substances at physiologically relevant concentrations. | Bilirubin: No significant interference up to 20 mg/dL. |
Hemolysis (Hemoglobin): No significant interference up to 500 mg/dL. | ||
Lipemia (Triglycerides): No significant interference up to 3000 mg/dL. | ||
Stability | Extended reconstituted stability of one year at 2 to 8 °C (This is the primary modification). | Implied to be met, as the modification goal was "extended reconstituted stability of one year at 2 to 8 °C." The document states "The product performance has been evaluated... The results of the comparative studies support the claim that the Raichem CO2 XL Reagent (modified device) is substantially equivalent..." thus implying this stability was successfully achieved and demonstrated. |
Detailed Study Information (as requested, with noted applicability to this document):
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Sample size used for the test set and the data provenance:
- Precision Studies:
- Manual Assay: N=10 for each "Within Run" mean, N=20 for each "Total" mean. These are likely replicates of controls or patient samples tested multiple times.
- Hitachi 717: Not explicitly stated, but "52 runs over a period of 26 days" implies a substantial number of measurements.
- Comparison Testing:
- Manual Assay: 65 sample pairs.
- Automated Method (Hitachi 717): 107 sample pairs.
- Interfering Substances: Not explicitly stated, but implied to be sufficient for testing the specified concentrations of bilirubin, hemoglobin, and triglycerides.
- Data Provenance: Not specified, but generally for such studies supporting a 510(k), the data would be generated in a laboratory setting (likely within the manufacturer's R&D or QA facilities) in the country of origin (USA, based on the address). The studies are prospective in the sense that they were designed and executed to evaluate the performance of the new reagent formulation.
- Precision Studies:
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not Applicable. This is a chemical reagent. The "ground truth" for the performance studies is the quantitative value obtained from testing samples, either against a known standard, or via the predicate device. Expert interpretation of images or clinical data is not involved.
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Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not Applicable. As above, no human interpretation requiring adjudication.
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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 is an in vitro diagnostic reagent, not an AI/ML diagnostic aid for human readers.
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not Applicable. This is a chemical reagent, not an algorithm or AI system. Its performance is inherent to the chemical reactions and measurement system.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- The "ground truth" in this context refers to the reference method or values against which the modified device's performance is compared.
- For precision, the ground truth is the expected statistical distribution around a true mean value for a given sample or control.
- For comparison studies, the "ground truth" for each sample is the measurement obtained using the predicate device. This establishes equivalence.
- For interference studies, the ground truth is the expected result of a sample without the interfering substance, and the acceptance criteria define the allowable shift in result when the interfering substance is present.
- The "ground truth" in this context refers to the reference method or values against which the modified device's performance is compared.
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The sample size for the training set:
- Not Applicable. This is a chemical reagent. There is no concept of a "training set" in the AI/ML sense. The formulation development process would involve extensive R&D and optimization, but this isn't analogous to training data for an algorithm.
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How the ground truth for the training set was established:
- Not Applicable. Similar to the above, there is no "training set" or corresponding ground truth in the AI/ML context. The formulation (the "device") itself is the result of chemical and biochemical engineering principles, not machine learning from a dataset.
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