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510(k) Data Aggregation

    K Number
    K220972
    Date Cleared
    2023-09-15

    (529 days)

    Product Code
    Regulation Number
    866.6010
    Reference & Predicate Devices
    Predicate For
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Access Thyroglobulin assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of thyroglobulin levels in human serum using the Access Immunoassay Systems. This device is aid in monitoring for the presence of persistent or recurrent/metastatic disease in patients who have differentiated thyroid cancer (DTC) and have had thyroid surgery (with or without ablative therapy), and who lack serum thyroglobulin antibodies.

    Device Description

    Access Thyroqlobulin assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of thyroglobulin levels in human serum using the Access Immunoassay Systems. This device is intended to aid in monitoring for the presence of persistent or recurrent /metastatic disease in patients who have differentiated thyroid cancer (DTC) and have had thyroid surgery (with or without ablative therapy), and who lack serum thvroglobulin antibodies.

    The Access Tg assay consists of the reagent pack and calibrators. Other items needed to run the assay include the Access Tg sample diluent substrate and wash buffer. The Access Tg assay along with the Access wash buffer and substrate are designed for use with the Access Immunoassay Systems in a clinical laboratory setting.

    The device modification described in this submission impacts the Access Thyroqlobulin reagent pack only; the change does not impact or change the other components that are used with this reagent pack. The modification does not affect the intended use or indications of the device or alter the fundamental scientific technology of the device.

    A description of the reagent pack is provided below.

    WellIngredients
    R1a:Dynabeads* paramagnetic particles coated with streptavidinand coupled to biotinylated mouse monoclonalantithyroglobulin antibodies, suspended in a TRIS buffer withprotein (bovine), < 0.1% sodium azide, and 0.1% ProClin**300.
    R1b:Mouse monoclonal anti-thyroglobulin-alkaline phosphatase(bovine) conjugate in a TRIS buffer with protein (bovine,murine), < 0.1% sodium azide, and 0.1% ProClin 300.
    R1c:HEPES buffer with protein (bovine and mouse), < 0.1% sodiumazide, and 0.5% ProClin 300.
    AI/ML Overview

    The provided text describes the Beckman Coulter Access Thyroglobulin assay, a chemiluminescent immunoassay for the quantitative determination of thyroglobulin levels in human serum. This device is intended to aid in monitoring for persistent or recurrent/metastatic differentiated thyroid cancer (DTC) in patients who have undergone thyroid surgery and lack serum thyroglobulin antibodies.

    Here's a breakdown of the acceptance criteria and the studies that prove the device meets these criteria:

    1. A table of acceptance criteria and the reported device performance

    The document does not explicitly present a table of acceptance criteria alongside reported performance for all aspects. Instead, acceptance criteria are generally mentioned within the description of each study. Below is a compilation of the criteria and reported performance for key studies.

    Acceptance Criteria CategorySpecific Acceptance CriteriaReported Device Performance
    Method ComparisonR ≥ 0.90 and slope 1.00 ± 0.09Met (R and slope not explicitly provided but stated as met)
    High-dose Hook EffectNo high-dose hook effectNo high-dose hook effect at concentrations up to at least 40,000 ng/mL
    Reference RangeLinear across the range of the assayLinear across the range of the assay (0.1 to approximately 500 ng/mL)
    Limit of Blank (LoB)≤ 0.03 ng/mL0.02 ng/mL
    Limit of Detection (LoD)≤ 0.05 ng/mL0.05 ng/mL
    Limit of Quantitation (LoQ)≤ 0.1 ng/mL0.05 ng/mL
    Analytical Specificity (Cross-reactivity)Change in concentration between diluent control and test samples within ± 10%No significant cross-reactivity for T3, T4, TBG, TSH
    Analytical Specificity (Interference)Change in concentration between diluent control and test samples within <± 10%No significant interference observed, including with biotin at 3510 ng/mL

    Note: For Imprecision and Reproducibility, specific acceptance criteria (e.g., maximum allowable %CV) are not explicitly stated. The tables provide the observed performance metrics (SD, %CV) and imply that these are acceptable.

    2. Sample size used for the test set and the data provenance

    • Method Comparison: 102 serum samples.
    • Imprecision: Not explicitly stated as a general sample count; involved multiple samples (6 different samples with varying concentrations) run in duplicate over 20 days.
    • Reproducibility:
      • Study 1: 2 samples run in 3 replicates.
      • Study 2: 3 samples run in 5 replicates.
    • High-dose Hook Effect: Not specified how many samples or what types were used, but concentrations up to 40,000 ng/mL were tested.
    • Linearity: Serum samples were used across the assay range.
    • Dilution Recovery: Serum samples were used across and above the assay range.
    • Limit of Blank (LoB), Limit of Detection (LoD), Limit of Quantitation (LoQ): Not explicitly stated how many individual samples were used for these studies, but they were determined based on specific testing procedures.
    • Analytical Specificity (Cross-reactivity): Serum patient samples at two thyroglobulin concentrations (approx. 20 ng/mL and 100 ng/mL) were used. The number of unique patient samples is not specified.
    • Analytical Specificity (Interference): Patient serum samples containing two levels of Thyroglobulin (approx. 25.0 ng/mL and 100.0 ng/mL) were used. The number of unique patient samples is not specified.

    Data Provenance: The document does not specify the country of origin for the data or whether the samples were collected retrospectively or prospectively. It consistently refers to the use of "human serum" or "patient serum samples."

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    This information is not applicable to this type of device (an in-vitro diagnostic immunoassay). The ground truth for such assays is established by the intrinsic biochemical properties and analytical performance of the assay itself (e.g., accuracy against reference methods, precision, detection limits using reference standards or well-characterized samples), rather than expert interpretation of images or clinical cases.

    4. Adjudication method for the test set

    This information is not applicable to this type of device. Adjudication methods like 2+1 or 3+1 are typically used in studies involving expert interpretation (e.g., radiology for AI-assisted diagnosis), where there might be disagreement among experts. For an immunoassay, the results are quantifiable and objective measurements, not subject to subjective adjudication.

    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

    This information is not applicable to this device. An MRMC study is relevant for imaging devices or AI-assisted diagnostic tools where human readers are interpreting cases. The Access Thyroglobulin assay is an automated laboratory test that directly measures a biomarker, without a "human reader" component in the interpretation of the primary data within the context of an MRMC study.

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

    The Access Thyroglobulin assay is a standalone device in the sense that it performs the measurement algorithmically via its chemiluminescent immunoassay system without direct human interpretation of the raw signal output. The "algorithm only" performance is what these analytical studies (imprecision, linearity, LoD, etc.) demonstrate. Human involvement is in sample preparation, loading, and interpretation of the final quantitative result.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)

    The ground truth for this device is based on analytical performance characteristics established through:

    • Reference methods or predicate device comparison (for method comparison study).
    • Use of well-characterized samples or reference materials (e.g., for LoB, LoD, LoQ, linearity).
    • Known concentrations of potential cross-reactants and interferents (for analytical specificity studies).
    • Statistical analysis of repeated measurements (for imprecision and reproducibility).

    8. The sample size for the training set

    This document describes the performance studies for a modificated device that is compared to a previously cleared predicate and is not a new AI/machine learning device that typically involves a distinct "training set." The studies mentioned are validation studies, not training. Therefore, a specific "training set sample size" is not applicable in the context of this submission. The development and optimization of the immunoassay reagents and protocols would have occurred during the assay's development, but this document focuses on its validation.

    9. How the ground truth for the training set was established

    As there is no "training set" in the context of an AI/machine learning model for this immunoassay submission, the question of how its ground truth was established is not applicable. The "ground truth" for the performance studies described in this document is derived from established analytical methods, reference materials, and the comparative performance against the predicate device.

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