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510(k) Data Aggregation
(205 days)
hCG Urine Test Strip, hCG Urine Test Cassette, hCG Urine Test Midstream
The hCG Urine Test Strip is a rapid one step assay designed for qualitative detection of human chorionic gonadotropin (hCG) in urine for early detection of pregnancy.
The hCG Urine Test Cassette is a rapid one step assay designed for qualitative detection of human chorionic gonadotropin (hCG) in urine for early detection of pregnancy.
The hCG Urine Test Midstream is a rapid one step assay designed for qualitative detection of human chorionic gonadotropin (hCG) in urine for early detection of pregnancy.
The hCG Urine Test will be sold in three formats: cassette, test strip, and midstream. The test strip and midstream kits consist of one test device and a package insert. The cassette kit consists of one test device and a disposable plastic dropper, and a package insert. Each test device contains mouse monoclonal anti-βhCG antibody coated membrane and a pad containing mouse monoclonal anti-α-hCG antibody colloidal gold conjugate. The control antibodies are goat anti-rabbit IgG.
The provided document is an FDA 510(k) summary for a set of hCG Urine Test devices. This document focuses on demonstrating analytical performance and user comprehension/accuracy for an In-Vitro Diagnostic (IVD) device, specifically a pregnancy test, not an AI-powered medical device. Therefore, many of the requested criteria related to AI/MRMC studies, expert ground truth, and training sets are not applicable to this type of device and submission.
However, I can extract the relevant information regarding the acceptance criteria and study proving the device meets these for an IVD device.
Acceptance Criteria and Device Performance for hCG Urine Test Strip, Cassette, and Midstream
This submission primarily focuses on analytical performance characteristics and comparison studies to demonstrate substantial equivalence to a predicate device.
1. Table of Acceptance Criteria and Reported Device Performance
Performance Characteristic | Acceptance Criteria (Implicit from Study Design/FDA Guidance) | Reported Device Performance |
---|---|---|
Analytical Sensitivity (Detection Limit) | Must accurately detect hCG at 25 mIU/mL (claimed sensitivity, matches predicate). | 100% positive detection for samples at 25 mIU/mL, 50 mIU/mL, and 100 mIU/mL across all formats and lots. |
Analytical Precision/Reproducibility | Consistent results (positive/negative) across different lots, operators, and days for given hCG concentrations. | 100% agreement (positive/negative) for all tested concentrations (0 mIU/mL, 12.5 mIU/mL, 18.75 mIU/mL, 25 mIU/mL, 50 mIU/mL, 100 mIU/mL) across 3 lots, 3 operators, over 10 days for all three formats (strip, cassette, midstream via dip and simulated midstream). |
Analytical Specificity (Cross-reactivity) | No interference from closely related hormones (LH, FSH, TSH) at specified concentrations. | No cross-reaction observed with LH at 500 mIU/mL, FSH at 1000 mIU/mL, and TSH at 1000 μIU/mL. |
Analytical Specificity (Interfering Substances) | No interference from common exogenous compounds or endogenous substances at specified concentrations. | No interference observed from 14 listed substances (e.g., Acetaminophen, Aspirin, Glucose, Albumin, Bilirubin, etc.) at their specified challenge concentrations for both 0 mIU/mL and 25 mIU/mL hCG samples. |
Analytical Specificity (hCG β-core fragment) | No interference from hCG β-core fragment at likely physiological levels. | No interference observed at β-core fragment concentrations up to 1,000,000 pmol/mL. |
Analytical Specificity (pH) | Performance not affected by varying urine pH within a physiological range. | No interference observed for urine pH range of 3 to 9. |
Analytical Specificity (Specific Gravity) | Performance not affected by varying urine specific gravity within a physiological range. | No interference observed for specific gravity between 1.001-1.039. |
High Dose Hook Effect | Device should accurately detect high concentrations of hCG without false negatives (hook effect). | Positive results obtained for HCG concentrations ranging from 5,000 to 850,000 mIU/ml. |
Comparison (Professional Use) | High agreement with the predicate device when interpreted by professionals. | 100% agreement (53 positive, 67 negative) with the predicate device for all three formats using urine samples from 120 women. |
Comparison (Lay User Comprehension/Accuracy) | High agreement between lay user interpretation and professional interpretation (ground truth). | 100% conformity between lay user interpretation and professional interpretation for all three formats (strip, cassette, midstream dip, midstream actual) across 360 women. |
OTC User Suitability | Untrained users can accurately use and interpret the test. | 100% agreement between lay user results and professional laboratory results for masked spiked samples (30 positive at 31.25 mIU/mL, 30 negative at 18.75 mIU/mL) for all formats. Participants rated the test as "very easy" or "easy" to read and interpret. |
Shelf-life Stability | Maintain performance characteristics over the claimed shelf life. | Data supports a 30-month shelf life when stored at 4-30℃. |
2. Sample Sizes and Data Provenance
- Analytical Performance Studies (Precision, Specificity, Hook Effect, pH, Specific Gravity):
- Sample Size: Varies by test. For precision, it's 3 lots x 3 runs/day x 10 days x 6 concentrations = 540 tests per format per operator x 3 operators (though total tests are reported per concentration per lot, e.g., 30 results). For other analytical tests, specific numbers are not always given but imply multiple runs with spiked samples.
- Data Provenance: Fresh urine samples from normal, non-pregnant females, spiked with HCG or interfering substances. The origin of the samples (e.g., country) is not specified but the manufacturer is in Hangzhou, China. The studies are retrospective in the sense that they are laboratory-controlled experiments designed to test specific analytical characteristics.
- Comparison Studies (Professional Method):
- Sample Size: 120 women's urine samples.
- Data Provenance: Urine samples collected from women at a hospital laboratory. Origin not specified (likely China). Retrospective collection for testing by both devices.
- Comparison Studies (Lay User Method):
- Sample Size: 360 women.
- Data Provenance: Urine samples collected from women at a hospital laboratory. Origin not specified (likely China). Retrospective collection.
- OTC User Performance (Spiked Masked Samples):
- Sample Size: 30 positive samples (31.25 mIU/mL hCG) and 30 negative samples (18.75 mIU/mL hCG) were tested by lay users for each of the four test methods (strip, cassette, midstream dip, midstream simulated). So, 60 samples per format/method, totaling 240 masked spiked samples.
- Data Provenance: Spiked urine samples prepared in a laboratory setting. This is a prospective experimental design for evaluating lay user performance.
3. Number of Experts and Qualifications for Ground Truth (Test Set)
- Analytical Studies: Ground truth for these studies (e.g., specific hCG concentrations, presence/absence of interfering substances) is established by the preparation of the samples themselves in a laboratory setting using traceable reference materials (e.g., WHO 5th IS for hCG). The "experts" here are essentially the laboratory personnel setting up and verifying these conditions. No specific number or qualifications are provided beyond general lab personnel.
- Professional Method Comparison: The "predicate device professional" interpretation serves as a comparator, implying professional users (e.g., lab technicians, medical staff) were involved in interpreting the predicate device results. The document does not specify the number of individuals or their specific qualifications.
- Lay User Method Comparison & OTC User Performance: The "professional interpretation of the hCG Test Strip/cassette/midstream" (Safecare device professional) appears to serve as the ground truth against which lay user interpretation/performance is compared. This implies that trained professionals used the new device to establish the correct result for each sample before the lay users interpreted their results. The number and qualifications of these "professionals" are not specified.
4. Adjudication Method for the Test Set
- For analytical studies, the "ground truth" is defined by the prepared samples (e.g., 25 mIU/mL hCG is positive, 0 mIU/mL is negative). No formal adjudication method is mentioned for reconciling conflicting results, as the expectation is 100% conformity based on the controlled sample preparation.
- For comparison studies (professional and lay user), the document states "the agreement of hCG Test Strip/cassette/midstream with the predicate device was 100%" or "the conformity between the user interpretation of the and the professional interpretation... is 100%." This implies that there were no discrepancies that required adjudication, or if there were, they are not reported. The "professional interpretation" acts as the reference standard.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No, an MRMC study was not done. This type of study is primarily relevant for AI-powered medical imaging devices where the AI assists human readers, and the goal is to show improved diagnostic performance with AI assistance. For a simple in-vitro diagnostic test like a pregnancy strip, this framework does not apply.
- The comparison studies involved both professional and lay users, but it was to compare the new device's performance against a predicate (professional) or a professional's interpretation of the new device (lay user), not to evaluate the effect of AI assistance on human readers.
6. Standalone (Algorithm-Only) Performance
- Yes, in the context of an IVD device, the "standalone" performance is assessed through the analytical performance studies. The device (the test kits) is the "algorithm," and its ability to correctly detect or not detect hCG at various concentrations (sensitivity, specificity, precision, hook effect, etc.) is its standalone performance demonstrated in the "Analytical performance" section. There is no separate digital algorithm being evaluated here.
7. Type of Ground Truth Used
- Analytical Studies: Lab-defined ground truth based on precisely prepared samples using traceable standards (e.g., WHO 5th IS for hCG) at specified concentrations. This is a form of spike-in ground truth.
- Professional Method Comparison: The results from the predicate device served as the comparator/reference.
- Lay User Method Comparison & OTC User Performance: The professional interpretation of the new device's results served as the ground truth.
8. Sample Size for the Training Set
- Not applicable. This document describes the validation of a manufactured in-vitro diagnostic test kit, not an AI/Machine Learning model that requires a training set. The device itself is a chemical-based test.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. (As above, no training set for an AI/ML model here).
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