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510(k) Data Aggregation

    K Number
    K192116
    Date Cleared
    2019-09-04

    (29 days)

    Product Code
    Regulation Number
    866.5510
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K103824

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

    This kit is intended for the quantitative in vitro determination of human IgA in serum, lithium heparin or EDTA plasma, using the Binding Site SPAPLUS turbidimetric analyser. Measurement of IgA aids in the diagnosis of abnormal protein metabolism and the body's lack of ability to resist infectious agents. The test results are to be used in conjunction with other clinical and laboratory findings.

    Device Description

    Human IqA liquid reagent kit for use on SPAPLUS® comprises the following reagents:

    Antiserum: Monospecific goat anti IgA supplied in stabilised liquid form. lt contains 0.099% sodium azide, 0.1% E-amino-n-caproic acid (EACA), 0.5% BSA and 0.01% benzamidine as preservatives.

    Calibrator and Controls: These consist of pooled human serum and are supplied in stabilised liquid form. The concentration of IgA given on the quality control certificate has been obtained by comparison with European Reference Material ERM-DA470k. They contain 0.099% sodium azide, 0.1% EACA and 0.01% benzamidine as preservatives.

    Reaction Buffer: Containing 0.099% sodium azide as a preservative.

    AI/ML Overview

    The provided document describes the "Human IgA liquid reagent kit for use on SPAPLUS" by The Binding Site Group Ltd. This device is intended for the quantitative in vitro determination of human IgA in serum, lithium heparin, or EDTA plasma using the Binding Site SPAPLUS turbidimetric analyzer. The submission is a special 510(k) for a modification to an existing device (K103824), specifically a change in the source of the detection antibody from sheep to goat.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them:

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

    The document does not explicitly present acceptance criteria in a dedicated table format with corresponding reported device performance for all aspects. Instead, acceptance criteria are described within the context of each study and then a conclusion about meeting those criteria is stated. I will extract and present this information in a table format where possible.

    Test Parameter / CharacteristicAcceptance Criteria (Implicit/Explicit)Reported Device PerformanceConclusion on Meeting Criteria
    Precision (Repeatability & Within Lab)No explicit numerical acceptance criteria given, but the expectation is "no change in performance compared to the device cleared in K103824".CV% ranges from 1.7% to 7.1%.Do not indicate any change in performance compared to K103824.
    Precision (Between Instrument)No explicit numerical acceptance criteria given, but the expectation is "no change in performance compared to the device cleared in K103824".CV% ranges from 0.0% to 1.8%.Do not indicate any change in performance compared to K103824.
    Precision (Between Lot)No explicit numerical acceptance criteria given, but the expectation is "no change in performance compared to the device cleared in K103824".CV% ranges from 0.0% to 3.2%.Do not indicate any change in performance compared to K103824.
    Linearity/Assay Reportable RangeNo explicit numerical acceptance criteria given, but the expectation is "comparable to those currently presented in the product insert" and "no change in performance compared to K103824".Linear regression equation: y=0.993x - 0.230 g/L with an R value of 0.996.Comparable to product insert, do not indicate any change in performance compared to K103824.
    Accelerated Kit StabilityMaximum allowable difference of ±15% to verify the stability claim of 18 months.All controls, internal reference, and samples for two batches (455406 and 455407) passed, achieving an equivalent stability of 561 days at 4ºC, which exceeds the required 395 days (18 months).Pass for all tested parameters and batches.
    On-Board StabilityNo explicit numerical acceptance criteria given, but the expectation is "no difference in the cleared on-board stability claim".Studies showed no difference in the cleared on-board stability claim.No difference observed.
    Limit of Quantitation (LoQ)Allowable CV of 8%.LoQ claim was validated by all samples reporting within the acceptance criteria.LoQ claim validated.
    Limit of Detection (LoD) & Limit of Blank (LoB)No explicit numerical acceptance criteria given, but the expectation is "no change in performance compared to the device cleared in K103824".LoD estimated as 0.003 g/L, LoB as 0.001 g/L. No change in performance observed after antisera change.Do not indicate any change in performance compared to K103824.
    Method Comparison with Predicate Device (Bland Altman)No explicit numerical acceptance criteria given, but the expectation is "no change in performance compared to K103824".Mean Bias: -2.18%, 95% Limits of Agreement: 0.55% to 3.17%.Do not indicate any change in performance compared to K103824.
    Method Comparison with Predicate Device (Passing Bablok)No explicit numerical acceptance criteria given, but the expectation is "no change in performance compared to K103824".Equation: y=1.017x + 0.002, Slope 95% CI: 1.004 to 1.029, Intercept 95% CI: -0.029 to 0.026. Correlation coefficient: 0.998.Do not indicate any change in performance compared to K103824.
    Expected Values/Reference Range Transfer≤2 samples falling outside of the limits of the reference interval to be transferred.All 20 samples tested gave results within the reference interval (1.553 to 4.840 g/L).Meets acceptance criteria, reference interval can be transferred.

    2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Precision Studies:
      • Repeatability and Within Laboratory: 4 different samples, 80 data points for each level (total 320 data points).
      • Between Instrument: 4 different samples, 24 data points for each level (total 96 data points).
      • Between Lot: 4 different samples, 24 data points for each level (total 96 data points).
    • Linearity Study: A high pool (8.19g/L) and a low pool (0.12 g/L) were used to create a dilution series. Each diluted sample was tested in 3 replicates.
    • Accelerated Stability: 6 replicates of controls, internal reference, and 3 different samples were tested.
    • Limit of Quantitation (LoQ) Validation: 4 samples were tested using two reagent lots.
    • Method Comparison with Predicate Device: 102 serum samples and 42 plasma samples (total 144 samples).
    • Expected Values/Reference Range Transfer: 20 samples from "apparently healthy US donors".

    Data Provenance:

    • For the Expected Values/Reference Range Transfer study, samples were from "apparently healthy US donors".
    • For other studies, the country of origin or whether the data was retrospective or prospective is not explicitly stated. The studies were carried out by The Binding Site Group Ltd., which is based in the UK, so it's likely testing was conducted there unless otherwise specified.

    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)

    This product is an in vitro diagnostic (IVD) reagent kit for quantitative Immunoglobulin A (IgA) determination. The "ground truth" in this context refers to the accurate measurement of IgA concentration. The document mentions traceability to European Reference Material ERM-DA470k/IFCC for calibration. This implies that the standard itself serves as the "ground truth" reference, rather than independent expert consensus on clinical interpretation. There are no mentions of experts establishing ground truth in the sense of clinical diagnosis or image interpretation.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    Adjudication methods like 2+1 or 3+1 are typically used in studies involving subjective interpretation by multiple human readers (e.g., in radiology studies) to resolve discrepancies and establish a consensus "ground truth." Since this device is a quantitative IVD assay and its performance is validated against analytical standards, reference materials, and comparative measurements, such adjudication methods are not applicable and therefore not used.

    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

    No, a multi-reader multi-case (MRMC) comparative effectiveness study was not done. This type of study is relevant for AI-powered diagnostic tools where human readers (e.g., radiologists) use AI assistance to improve their diagnostic accuracy. This device is a standalone quantitative laboratory test kit, not an AI or imaging diagnostic aid, so an MRMC study is not applicable.

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

    Yes, the performance studies described are for the standalone device (reagent kit on the SPAPLUS analyzer) without human-in-the-loop performance influencing the measurement part of the device's function. The analytical performance, stability, and comparison studies evaluate the kit's ability to accurately measure IgA concentrations. The device's output is a quantitative value, not an interpretation of data that requires human feedback for performance assessment.

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

    The ground truth for this quantitative assay is primarily based on:

    • Reference Materials: Calibration traceability to ERM-DA470k/IFCC. This is the international standard for immunoglobulin measurements.
    • Reference Methods: The predicate device itself (K103824) serves as a comparative "ground truth" for method comparison studies, demonstrating substantial equivalence.
    • Defined Concentrations: For linearity and precision studies, samples with known or precisely diluted concentrations are used.
    • Clinical Reference Intervals: The ability to transfer established reference intervals (based on a healthy population) is also part of the "ground truth" for clinical usability.

    8. The sample size for the training set

    This document describes a special 510(k) submission for a modification to an existing device, which mostly involves re-validation studies to ensure the modification (change in antibody source from sheep to goat) does not alter performance compared to the cleared predicate. It does not describe the development of a novel algorithm or AI model that requires a distinct "training set." The studies performed are validation studies, not training. Therefore, a "training set" in the context of machine learning is not applicable here.

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

    As there is no "training set" in the machine learning sense for this device submission, this question is not applicable. The device's underlying principles (immunoturbidimetry) are well-established, and its performance is validated against analytical standards rather than learned from a dataset.

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    K Number
    K191985
    Device Name
    Optilite IgA Kit
    Date Cleared
    2019-08-19

    (25 days)

    Product Code
    Regulation Number
    866.5510
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K103824

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

    The Optilite IgA Kit is intended for the quantitative in vitro measurement of IgA in serum, lithium heparin or EDTA plasma using the Binding Site Optilite analyser. Measurement of IgA aids in the diagnosis of abnormal protein metabolism and the body's lack of ability to resist infectious agents. This test should be used in conjunction with other laboratory and clinical findings.

    Device Description

    The Optilite IgA Kit comprises the following reagents: Antiserum: Goat anti IgA supplied in stabilised liquid form. Preservatives: 0.099% sodium azide, 0.1% E-amino-n-caproic acid (EACA), 0.5% BSA and 0.01% benzamidine. Calibrator and Controls: Pooled human serum, supplied in stabilised liquid form. Contain 0.099% sodium azide, 0.1% EACA and 0.01% benzamidine as preservatives. The concentration given on the quality control certificate has been obtained by comparison with the DA470k international reference material. Reaction Buffer: Containing 0.099% sodium azide as a preservative.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study detailed in the provided document for the Optilite IgA Kit, organized according to your requested information.

    It's important to note that this document is a 510(k) summary for a modification to an existing device (Optilite IgA Kit, K103824). Therefore, the study presented here primarily focuses on confirming that the modified device (with a change from sheep to goat antibody) performs comparably to the predicate device (the original cleared kit) and that the performance characteristics detailed in the original submission still hold true. This is not a study to establish initial performance characteristics, but rather to demonstrate equivalence after a modification.


    Acceptance Criteria and Device Performance Study for Optilite IgA Kit (K191985)

    This study was conducted to demonstrate that the modified Optilite IgA Kit, with a change in the source of the detection antibody from sheep to goat, maintains comparable performance to the predicate device (Optilite IgA Kit, K103824). The acceptance criteria were primarily based on demonstrating no significant change in performance compared to the previously cleared device.

    1. Table of Acceptance Criteria and Reported Device Performance

    Performance CharacteristicAcceptance Criteria (Relative to Predicate Device's Performance Claims)Reported Device Performance (Modified Kit)Conclusion
    PrecisionNo change in performance compared to predicate. Data should support existing precision claims in product insert.Repeatability & Within Lab: Consistent low CV% (1.0-6.3%) across 5 levels. Between Instrument: Low CV% (0.0-2.9%) across 5 levels. Between Lot: Low CV% (0.8-5.2%) across 5 levels.Meets Criteria: The results do not indicate any change in performance compared to the cleared device (K103824).
    Linearity/Assay Reportable RangeNo change in performance compared to predicate. Data should support existing linearity claims in product insert.Linear regression equation: y=1.007x + 0.159 g/L with R value of 0.999.Meets Criteria: Results are comparable to those presented in the original product insert, indicating no change in performance.
    Kit Stability (Accelerated)Verified stability in accordance with ISO 23640:2015, with maximum allowable difference of ±15% compared to baseline. Should support 18-month stability claim.All tested parameters (IR, Controls, Samples 1, 2, 3) passed the accelerated stability criteria, achieving or exceeding the required stability days (e.g., sample 1 achieved 561 equivalent days at 4°C, required 395 days).Meets Criteria: All parameters passed, verifying the stability claim.
    Detection Limit (LoD, LoQ, LoB)No change in performance compared to predicate. Data should support existing claims in product insert.LoQ validated at 0.02 g/L (within 8% CV acceptance criteria). LoD estimated at 0.007 g/L; LoB estimated at 0.005 g/L. No change observed after antisera change.Meets Criteria: No change in performance observed, supporting existing LoB, LoD, and LoQ claims.
    Method Comparison (vs. Predicate)Bland Altman Mean Bias close to 0%, 95% Limits of Agreement indicating good concordance. Passing Bablok slope close to 1, intercept close to 0. High Correlation Coefficient. No indication of change in performance vs. predicate.Bland Altman Mean Bias: 2.38%, 95% Limits of Agreement: -10.6% to 15.37%. Passing Bablok: y=1.012x + 0.011 (Slope 95% CI: 1.001 to 1.027, Intercept 95% CI: -0.006 to 0.044). Correlation coefficient: 0.998.Meets Criteria: Results do not indicate any change in performance compared to the cleared device (K103824).
    Reference Range Transfer≤2 samples falling outside of the limits of the original reference interval from 20 tested samples.19 out of 20 samples gave results within the reference interval (0.947 to 4.043 g/L). One sample was at the lower boundary (
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