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510(k) Data Aggregation

    K Number
    K102643
    Date Cleared
    2011-07-15

    (304 days)

    Product Code
    Regulation Number
    862.1315
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The SPOTCHECK Neonatal GALT Microplate Reagent Kit is for the quantitative determination of galactose-1-phosphate uridyltransferase, EC 2.7.7.12 (GALT), activity in whole blood saturated filter paper disks, using a microplate absorbance reader. Measurements of GALT enzyme activity are used primarily in the diagnosis and treatment of the hereditary disease galactosemia. This method is intended for in vitro diagnostic use as an aid in neonatal screening for decreased levels of GALT enzyme activity, and not for monitoring purposes.

    The SPOTCHECK Pro is used for automated sample processing in the application of in vitro diagnostic assays. Specimens containing patient bodily substances are introduced and analyzed in microtiter plates using qualitative/quantitative determination through absorbance measurements.

    These devices are intended for use by trained, qualified laboratory personnel.

    Device Description

    SPOTCHECK Neonatal GALT Microplate Reagent Kit - 60 Plate: Four enzyme mediated reactions are employed in the determination of GALT activity. GALT activity is determined by measuring the colored formazan produced by the addition of the color reagent to the incubated blood/substrate mixture. Patient samples of whole blood collected on standardized filter paper are placed into the wells of a standard 96 well microplate. A buffered enzyme mixture is added to each well and the plate is incubated at 37 °C for 120 minutes on a plate shaker/incubator. Following incubation, an aliquot of the mixture from each well is transferred to the corresponding wells on a clean 96 well microplate. Color reagent is added to each well, the color is developed over the course of 10 minutes, and the absorbance of each sample is determined on the plate reader. A blank absorbance reading is made prior to the addition of the color reagent to correct for endogenous sample color. The color developed is proportional (1:1) to the GALT activity in the sample. A standard curve prepared from a stock NADH solution is used to quantitate the results. Results are expressed as units of GALT enzyme activity per gram of hemoglobin or U/g Hb.

    SPOTCHECK Pro: INSTRUMENT COMPONENTS: Tecan Freedom EVO and accessories necessary for assay.

    AI/ML Overview

    This is a 510(k) premarket notification for a medical device, not an AI/ML device, therefore, some of the requested information (e.g., number of experts, adjudication method, MRMC study, sample size for training set) is not applicable or cannot be extracted from the provided text. The document describes the device's technical characteristics, performance studies performed to demonstrate substantial equivalence to a predicate device, and its intended use.

    Here's an analysis of the provided information, tailored to what is available in the regulatory submission format:

    1. Table of Acceptance Criteria (Performance Goals) and Reported Device Performance

    The acceptance criteria are generally implied by the comparative studies to the predicate device and established CLSI guidelines for analytical performance. The studies aim to show the SPOTCHECK Kit performs comparably or better than the predicate device across various metrics.

    Performance MetricAcceptance Criteria (Implied/Standard)Reported Device Performance (SPOTCHECK Neonatal GALT Microplate Reagent Kit)
    LinearityAdherence to CLSI EP6-A; 2nd order regression from 0 to 15 U/g Hb.Non-linear (2nd order regression) in the range of 0.25 to 15 U/g Hb. Confirmed by adherence to CLSI EP6-A. Calibration curve (NADH standards) conforms to a 2nd order regression from 0 to 15 U/g Hb. Results > 15 U/g Hb are reported as such.
    Analytical Sensitivity (LoD)Consistent with CLSI EP17-A; α < 0.3%, β < 0.3%Limit of Detection (LoD) = 0.2 U/g Hb. Determined consistent with CLSI EP17-A protocol, with α < 0.3% and β < 0.3%, based on 300 measurements (60 blank, 240 low-level samples); LoB = 0.08 U/g Hb. Total error (3xSD) < 0.2 U/g Hb. LoD = LoQ.
    Analytical Sensitivity (LoQ)< 20% total imprecision at LoQ (functional LoQ).Functional LoQ = 0.3 U/g Hb. Established using a criterion of < 20% total imprecision at the LoQ. Neonatal specimens < 0.3 U/g Hb reported as such (presumed positive for galactosemia).
    Automated vs. Manual PerformanceManual and automated processing should provide similar results. Screening equivalence should be confirmed if manual is backup.Linear Regression (Automated vs. Manual): - Multiple R: 0.946- R²: 0.896- Adjusted R²: 0.895- Standard Error: 0.804- Observations: 204- Intercept: 0.393 (SE 0.168, 95% CI 0.063-0.724)- X Variable: 0.963 (SE 0.023, 95% CI 0.917-1.01)Study confirms similar results can be expected.
    Clinical Classification (Automated)Screening results should correlate to the predicate device.Comparison to Predicate Device (Automated):- Total N = 1752- Positive agreement: (57/58) = 98.3% (calculated from table)- Negative agreement: (1746/1747) = 99.9% (calculated from table)- Overall agreement: (57+1746)/1752 = 99.8% (calculated from table)(Note: There are conflicting tables for automated classification, using one where SPOTCHECK Positive/Negative vs Predicate Positive/Negative sum to 1752 cases (the "57" table)).
    Clinical Classification (Manual)High degree of correlation to predicate device classification. Correct classification of known deficient samples.Comparison to Predicate Device (Manual):- Total N = 292- Positive agreement: (58/62) = 93.5%- Negative agreement: (214/230) = 93.0%- 10 known GALT deficient samples correctly classified.
    PrecisionComparable to predicate device; adherence to CLSI EP5-A2.Within-Run Precision (Manual, n=80):- Deficient (0.45 U/g Hb): CV 8.1%- Partial (1.3 U/g Hb): CV 6.5%- Near cutoff (2.4 U/g Hb): CV 8.3%- Normal (6.7 U/g Hb): CV 8.2%Within-Run Precision (Automated, n=80):- Deficient (0.60 U/g Hb): CV 7.8%- Partial (1.3 U/g Hb): CV 6.2%- Near cutoff (2.4 U/g Hb): CV 6.7%- Normal (6.1 U/g Hb): CV 6.6%Total Precision (Manual, n=80):- Deficient (0.45 U/g Hb): CV 11%- Partial (1.3 U/g Hb): CV 9.2%- Near cutoff (2.4 U/g Hb): CV 9.2%- Normal (6.7 U/g Hb): CV 9.7%Total Precision (Automated, n=80):- Deficient (0.60 U/g Hb): CV 11%- Partial (1.3 U/g Hb): CV 7.3%- Near cutoff (2.4 U/g Hb): CV 7.1%- Normal (6.1 U/g Hb): CV 6.7%Demonstrates comparable precision to predicate device.
    Analytical Specificity (Interference)No statistically or clinically significant interference from common substances. Adherence to CLSI EP7-A2.γ globulin (6000 mg/dL): No significant interference. Minor GALT increases near cutoff, but not enough to misclassify deficient. (Predicate: no interference up to 2500 mg/dL).Albumin (6000 mg/dL): No significant interference or misclassification. (Predicate: not evaluated).Bilirubin, conjugated (28.8 mg/dL): No significant interference. (Predicate: no interference up to 40 mg/dL).Bilirubin, unconjugated (20 mg/dL): No significant interference. (Predicate: no interference up to 40 mg/dL).Hemoglobin (200 mg/dL): Statistically significant decrease in GALT activity, could lead to false positive near cutoff. (Predicate: not evaluated).Triglycerides (3270 mg/dL): No significant interference. (Predicate: no interference up to 1000 mg/dL).Sulfamethoxazole (400 ug/mL): No significant interference. (Predicate: not evaluated).Trimethoprim (40 ug/mL): No significant interference. (Predicate: not evaluated).
    Contributions from HematocritVarying hematocrit should not lead to false negatives.45% Hct: Deficient 0.43 U/g Hb, Near Cutoff 2.4 U/g Hb, Normal 5.4 U/g Hb55% Hct: Deficient 0.55 U/g Hb, Near Cutoff 2.7 U/g Hb, Normal 6.9 U/g Hb65% Hct: Deficient 0.72 U/g Hb, Near Cutoff 3.3 U/g Hb, Normal 8.3 U/g HbDifferences in hematocrit had a statistically significant effect on samples with low GALT activity, but no indication of misclassifying a deficient sample as normal (false negative).

    2. Sample Size Used for the Test Set and Data Provenance

    • Automated and Manual Performance Comparison:

      • Test Set Sample Size: 128 newborn patient dried blood spot samples, plus dried blood spot controls (manufactured to mimic newborn specimens) and dried specimens of mixed adult blood. A total of 216 samples were analyzed.
      • Data Provenance: Not explicitly stated (e.g., country of origin, specific state). The samples are referred to as "newborn patient dried blood spot samples" and "mixed adult blood," suggesting they are from human subjects, but the geographical origin is not specified. The study was retrospective, as existing dried blood spots were analyzed.
    • Expected Values and Clinical Cutoff Determination (Automated Processing):

      • Test Set Sample Size: 1752 routine samples and 53 known GALT deficient samples (controls, retrospective galactosemic neonates, and galactosemic non-neonates).
      • Data Provenance: From a "state screening laboratory," indicating US origin and retrospective collection.
    • Screening Using Manual Processing:

      • Test Set Sample Size: 247 newborn patient dried blood spot samples, plus dried blood spot controls (with newborn hematocrit) and dried specimens of mixed adult blood. A total of 292 samples were analyzed.
      • Data Provenance: Not explicitly stated, likely similar to the automated comparison study (retrospective human samples, likely US state screening program).

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts

    • Not applicable as this is a chemical reagent kit for GALT activity measurement, not an AI/ML device relying on human expert image interpretation or similar.
    • The "ground truth" for GALT deficiency or normal activity was established by:
      • Analysis using the predicate device.
      • "Known GALT deficient samples" which included "retrospective galactosemic neonates and galactosemic non-neonates," meaning their clinical status was previously established.
      • "Routine neonatal screening by the state DOH classified all but one of these specimens (as well as the specimens classified as negative) to be presumptive negative for galactosemia." For some samples, the reference came from a state Department of Health (DOH) screening classification.

    4. Adjudication Method for the Test Set

    • Not applicable. The "ground truth" was established based on predicate device results and previously classified clinical samples, not through a consensus or adjudication process among multiple human readers for a primary diagnostic task.

    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 is not an AI/ML device, and no human reader study with or without AI assistance was performed.

    6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done

    • This device is a standalone diagnostic kit (the "algorithm" here being the chemical assay and spectrophotometric measurement, interpreted by trained lab personnel). The studies described (linearity, sensitivity, precision, comparison to predicate) are effectively standalone performance evaluations. The SPOTCHECK Pro (instrument) automates the process, meaning the "algorithm" (assay) performs without manual intervention during the assay process itself, aside from initial setup and final interpretation.

    7. The Type of Ground Truth Used

    • Comparative Reference Standard: The primary ground truth for evaluating the SPOTCHECK Kit was the performance of a legally-marketed predicate device (Bio-Rad Quantase Neonatal GALT Test). The studies explicitly compare the SPOTCHECK Kit's results to the predicate device's results.
    • Clinical Diagnosis/Known Status: For validation of clinical classification, "known GALT deficient samples" (retrospective galactosemic neonates and non-neonates) were used. This indicates a form of outcomes data or pre-established clinical diagnosis.
    • State DOH Screening Classification: In some instances, the "routine neonatal screening by the state DOH" provided a classification (presumptive positive/negative) which served as a reference for comparison.

    8. The Sample Size for the Training Set

    • Not applicable in the context of AI/ML. The device is a chemical reagent kit. There wasn't a "training set" in the machine learning sense. The device's calibration curve is established using NADH standards, which are analytical controls, not a training dataset for an algorithm.

    9. How the Ground Truth for the Training Set was Established

    • Not applicable as there is no "training set" in the AI/ML context. The calibration curve is established analytically using NADH standards, which have known concentrations. These standards are foundational to quantifying the GALT activity, not for training a predictive model.
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