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510(k) Data Aggregation

    K Number
    K190686
    Date Cleared
    2019-05-28

    (71 days)

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

    K110035

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

    The Optilite IgM CSF Kit is intended for the quantitative in vitro measurement of IgM in cerebrospinal fluid (CSF) samples using the Optilite analyser.

    Device Description

    The Optilite IgM CSF Kit comprises the following reagents:
    Latex Reagent: Supplied in stabilised liquid form. Preservatives: 0.025% sodium azide, 0.1% E-amino-n-caproic acid (EACA) and 0.01% benzamidine, 0.05% ProClin.
    Calibrator and Controls: Pooled human serum, supplied in stabilised liquid form. Containing 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

    The provided text describes the 510(k) submission for the Optilite IgM CSF Kit, an in vitro diagnostic device, not an AI/ML-based device. Therefore, the questions related to AI/ML specific criteria, such as expert adjudication, MRMC studies, standalone algorithm performance, and training set details, are not applicable to this submission.

    The acceptance criteria and device performance evaluation for this diagnostic kit are centered on analytical performance characteristics, which are standard for laboratory assays.

    Here's a breakdown of the applicable information from the provided text:

    1. Table of acceptance criteria and the reported device performance:

    Performance CharacteristicAcceptance Criteria (from CLSI Guidelines and Internal Standards)Reported Device Performance
    Precision
    Total Precision (%CV)<10%Level 1: 7.2%Level 2: 5.9%Level 3: 3.6%Level 4: 4.2%
    Within-run Precision (%CV)<5%Level 1: 3.9%Level 2: 2.8%Level 3: 2.2%Level 4: 2.3%
    Between-run Precision (%CV)<8%Level 1: 1.5%Level 2: 2.5%Level 3: 2.6%Level 4: 2.9%
    Between-day Precision (%CV)<8%Level 1: 5.9%Level 2: 4.6%Level 3: 1.3%Level 4: 2.0%
    Linearity/Assay Reportable RangeDeviation from linearity <10% over the measuring rangeConfirmed over 0.07 - 4.55 mg/L with deviation from linearity <10%
    Detection Limit (LoQ)Not explicitly stated as a numerical criterion, but defined as the bottom of the measuring range.0.11 mg/L (bottom of measuring range)
    Analytical Specificity (Interference)Mean results from spiked samples within 10% of control samples.Not affected by Acetaminophen (1324µmol/L), Acetylsalicylic Acid (3.62mmol/L), Bilirubin (80mg/L), Haemoglobin (1g/L)
    Method Comparison (Regression Analysis)Not explicitly stated as a numerical criterion for slope/intercept, but implied to show substantial equivalence.N=155 samples, Slope: 1.02, 95% CI: 1.00 to 1.04; Intercept: 0.07, 95% CI: 0.03 to 0.09; Pearson's r: 0.997

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

    • Precision Study: 4 sample preparations tested (details on the specific number of aliquots or patient samples composing these preparations are not given). The study design involved 2 runs per day (each in duplicate) over 5 days using 3 analyzers.
    • Linearity Study: A serially diluted sample was used. Specific N is not provided.
    • Detection Limit (LoQ) Study: The study was based on CLSI EP17-A2. Specific N is not provided.
    • Analytical Specificity (Interference) Study: Samples at different IgM concentrations were spiked with interfering substances and tested. Specific N is not provided.
    • Method Comparison Study: A total of 239 samples were initially tested, including 219 native CSF samples and 20 patient samples spiked with purified IgM. 155 of these samples were within the measuring range and used for regression analysis.
    • Provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective). However, the samples would be human CSF.

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

    This is a quantitative immunodiagnostic assay, not an imaging device requiring expert interpretation for ground truth. The "ground truth" for this device's performance is established by reference methods, international standards (ERM-DA470k/IFCC), and the inherent accuracy and precision of the measurements themselves validated against established statistical methodologies (CLSI guidelines).

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

    Not applicable, as this is a quantitative diagnostic assay, not a subjective interpretation task that requires 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:

    Not applicable, as this is not an AI/ML-based device that assists human readers.

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

    The device is an automated turbidimetric analyzer (Optilite) performing a quantitative assay. Its performance is inherently "standalone" in the sense that the instrument provides a numerical result without human interpretation being part of the result generation. The performance metrics presented (precision, linearity, detection limit, method comparison) are its standalone performance.

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

    The ground truth or reference for this quantitative assay is:

    • Traceability: Established through calibration traceable to the ERM-DA470k/IFCC international reference material.
    • Method Comparison: Comparison against a legally marketed predicate device (Human IgM CSF Kit for use on SPAPLUS K120750) using patient samples. The predicate device itself serves as a reference point for substantial equivalence.
    • Statistical Methodologies: Adherence to CLSI (Clinical and Laboratory Standards Institute) guidelines for evaluating precision, linearity, detection capability, and interference.

    8. The sample size for the training set:

    Not applicable, as this is not an AI/ML device that requires a "training set."

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

    Not applicable, as this is not an AI/ML device.

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    K Number
    K173732
    Date Cleared
    2018-08-23

    (260 days)

    Product Code
    Regulation Number
    866.5550
    Reference & Predicate Devices
    Predicate For
    N/A
    Why did this record match?
    Reference Devices :

    K110035

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

    The Optilite Freelite Mx Kappa Free Kit is intended for the quantitative in vitro measurement of Kappa free light chains in serum and urine using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE) in conjunction with other laboratory and clinical findings.

    The Optilite Freelite Mx Lambda Free Kit is intended for the quantitative in vitro measurement of Lambda free light chains in serum and urine using the Binding Site Optilite analyser. Measurement of free light chains aids in the diagnosis and monitoring of multiple myeloma, lymphocytic neoplasms, Waldenström's macroglobulinaemia, AL amyloidosis, light chain deposition disease and connective tissue diseases such as systemic lupus erythematosus (SLE) in conjunction with other laboratory and clinical findings.

    Device Description

    The Optilite Freelite Mx Kappa Free Kit is comprised of the following reagents: Latex Reagent: Sheep anti-Human Kappa (polyclonal monospecific) antibody (F(ab')2 fragment) bound to 200nm polystyrene latex particles. In 0.033M Glycine buffered saline pH8 (containing Sodium Azide (0.033%), Proclin (0.05%), Benzamidine (0.01%) and EACA (0.1%) as preservative plus BSA (0.033%)). Calibrator and Controls: Pooled human serum, supplied in stabilised liquid form. Containing 0.099% sodium azide, 0.1% EACA and 0.01% benzamidine as preservatives. Reaction Buffer: Containing 0.099% sodium azide as a preservative.

    The Optilite Freelite Mx Lambda Free Kit is comprised of the following reagents: Latex Reagent: Sheep anti-Human Lambda (polyclonal monospecific) Free antibody (F(ab')2 fragment) bound to 200nm polystyrene latex particles. In 0.033M Glycine buffered saline pH8 (containing Sodium Azide (0.033%), Proclin (0.05%), Benzamidine (0.01%) and EACA (0.1%) as preservatives plus BSA (0.1665%)). Calibrator and Controls: Pooled human serum, supplied in stabilised liquid form. Containing 0.099% sodium azide, 0.1% EACA and 0.01% benzamidine as preservatives. Reaction Buffer: Containing 0.099% sodium azide as a preservative.

    Note - In Optilite Freelite kits, the latex reagent and reaction buffer are supplied in a single wedge with a chamber for each fluid. They are therefore labelled as a single component Optilite Kappa Free Mx Reagent or Optilite Lambda Free Mx Reagent.

    AI/ML Overview

    The provided text describes the performance characteristics of the Optilite Freelite Mx Kappa Free Kit and Optilite Freelite Mx Lambda Free Kit, which are devices for the quantitative measurement of Kappa and Lambda free light chains in serum and urine.

    Here's an analysis of the acceptance criteria and the study that proves the device meets these criteria, based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    Since this is a submission for an in-vitro diagnostic device, the "acceptance criteria" are typically inferred from the performance targets set by the manufacturer and assessed against relevant CLSI (Clinical and Laboratory Standards Institute) guidelines. The reported device performance is directly stated in the tables within the document.

    Precision/Reproducibility

    Performance MetricAcceptance Criteria (Inferred from CLSI Guidelines/Industry Standards for IVDs)Reported Device Performance (Kappa Urine)Reported Device Performance (Lambda Urine)
    Kappa
    Total %CV (Sample 1)Typically < 10% (for low concentrations)7.6%-
    Total %CV (Sample 2)Typically < 10%8.2%-
    Total %CV (Sample 3)Typically < 10%7.1%-
    Total %CV (Sample 4)Typically < 10%8.8%-
    Lambda
    Total %CV (Sample 1)Typically < 10% (for low concentrations)-7.3%
    Total %CV (Sample 2)Typically < 10%-8.7%
    Total %CV (Sample 3)Typically < 10%-8.2%
    Total %CV (Sample 4)Typically < 10%-8.1%
    Total %CV (Sample 5)Typically < 10%-8.6%

    Linearity/Assay Reportable Range

    Performance MetricAcceptance Criteria (Inferred from CLSI EP6-A)Reported Device Performance (Kappa)Reported Device Performance (Lambda)
    Linearity RangeDemonstrated across the intended measuring range with acceptable deviation2.383 - 142.687 mg/L3.87 - 160.02 mg/L
    Deviation from Linearity≤ 10%≤ 10%≤ 10%

    Detection Limit

    Performance MetricAcceptance Criteria (Inferred from CLSI EP17-A)Reported Device Performance (Kappa Serum)Reported Device Performance (Kappa Urine)Reported Device Performance (Lambda Serum)Reported Device Performance (Lambda Urine)
    Limit of Blank (LoB)Accurately determined0.195 mg/L0.210 mg/L0.285 mg/L0.080 mg/L
    Limit of Detection (LoD)Accurately determined0.224 mg/L0.232 mg/L0.393 mg/L0.184 mg/L
    Limit of Quantitation (LoQ)Accurately determined and clinically relevant0.330 mg/L0.330 mg/L0.740 mg/L0.740 mg/L

    Analytical Specificity (Interference)

    Performance MetricAcceptance Criteria (Inferred from CLSI EP7-A2)Reported Device Performance (Kappa)Reported Device Performance (Lambda)
    Interference (% Deviation from Control)≤ 10% for studied interferentsNo significant interference observed for listed substancesNo significant interference observed for listed substances

    Method Comparison with Predicate Device

    Performance MetricAcceptance Criteria (Inferred for Substantial Equivalence)Reported Device Performance (Kappa Free)Reported Device Performance (Lambda Free)
    Correlation Coefficient (r)High correlation (typically > 0.95 or 0.975 for quantitative assays)0.9920.947
    Regression Equation (y=mx+c)Slope (m) close to 1, intercept (c) close to 0y = 1.02x - 0.21y = 1.11x - 0.27

    Clinical Agreement (2x2 Table with Predicate)

    Performance MetricAcceptance Criteria (Inferred for Substantial Equivalence)Reported Device Performance (Kappa)Reported Device Performance (Lambda)
    Positive AgreementHigh, clinically acceptable90.7% (82.7% to 95.2% CI)73.7% (62.8% to 82.3% CI)
    Negative AgreementHigh, clinically acceptable98.8% (93.3% to 99.8% CI)100.0% (96.0% to 100.0% CI)
    Overall AgreementHigh, clinically acceptable94.6% (90.0% to 97.1% CI)88.1% (92.3% to 92.2% CI)

    Notes on Acceptance Criteria: The document does not explicitly state quantitative acceptance criteria or pass/fail thresholds for many of these performance metrics. The criteria listed above are inferred based on typical expectations for in-vitro diagnostic devices undergoing 510(k) clearance, often guided by CLSI guidelines. The FDA's substantial equivalence determination implies that the reported performance is acceptable in comparison to the predicate device and the recognized standards.

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

    • Precision/Reproducibility:

      • Kappa: Four urine sample pools were tested. The testing involved 21 days with two runs per day using one reagent lot on three analyzers.
      • Lambda: Five urine sample pools were tested. The testing involved 23 days with two runs per day using one reagent lot on three analyzers.
      • Provenance: Not explicitly stated, but likely in-house (Binding Site Group Ltd.) and conducted under controlled laboratory conditions, given it's part of analytical performance testing for an IVD.
    • Linearity/Assay Reportable Range:

      • Sample Size: "serially diluted urine samples" were used. The exact number of individual samples or dilutions is not specified.
      • Provenance: Not explicitly stated, but likely in-house.
    • Detection Limit:

      • LoB: 60 determinations of blank samples (analyte depleted serum and urine at a low analyte concentration).
      • LoQ: Five independent samples (serum and urine) tested twelve times over five days.
      • Provenance: Not explicitly stated, but likely in-house.
    • Analytical Specificity (Interference):

      • Sample Size: "a single urine sample for the Kappa Free assay and the Lambda Free assay". These were prepared with interferents.
      • Provenance: Not explicitly stated, but likely in-house.
    • Method Comparison with Predicate Device:

      • Kappa Free: 165 urine samples (including 86 with analyte levels below the reference limit).
      • Lambda Free: 115 urine samples (including 59 with analyte levels below the reference limit).
      • Provenance: Not explicitly stated, but these are patient samples tested against a predicate device. Given the context of a European manufacturer and the lack of specific geographical mention, they could be from various locations or a specific clinic associated with the manufacturer. Retrospective or prospective is not specified, but typically for method comparison, collected samples are used retrospectively.
    • Clinical Agreement (2x2 Table with Predicate):

      • Kappa: 166 samples (derived from the 2x2 table: 78+1+8+79 = 166, though the sum of listed cells is 166, the total is given as 166, implying a discrepancy in the row/column totals). The method comparison stated 165, so there might be a rounding or slight difference in sample inclusion for the clinical agreement vs. regression.
      • Lambda: 168 samples (derived from the 2x2 table totals). The method comparison stated 115. This suggests different sample sets or criteria for the 2x2 table analysis compared to the regression analysis, especially given the sample sizes below the reference limit quoted for the method comparison.
      • Provenance: Not explicitly stated, but presumed to be from clinical settings for patient samples. These are likely retrospective samples previously analyzed by the predicate.

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

    For an in-vitro diagnostic device like this, "ground truth" and "experts" are typically not established in the same way as for imaging devices requiring expert interpretation.

    • Ground Truth: For this device, the "ground truth" is typically the result obtained from a well-established, often reference, method or the predicate device that the new device is being compared against. In this case, the predicate device (Freelite® Human Kappa/Lambda Free Kit for use on the Siemens BN™II) serves as the comparator, from which the "Assay" results are compared.
    • Experts and Qualifications: There is no mention of external experts being used for establishing ground truth. The evaluation relies on analytical and clinical performance studies comparing the new device against the predicate or established analytical standards.

    4. Adjudication Method (e.g., 2+1, 3+1, none) for the Test Set

    Not applicable for this type of in-vitro diagnostic device performance study. Adjudication methods like 2+1 or 3+1 are common in studies where human readers interpret medical images and their interpretations need to be reconciled to establish a ground truth or a consensus opinion. For IVD devices, the "truth" for comparison is usually defined by the results of a reference method or legally marketed predicate.

    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. MRMC studies, and improvement with AI assistance, are relevant to medical imaging devices where human readers (e.g., radiologists) interpret images. This submission is for an in-vitro diagnostic assay for laboratory measurement of biomarkers, which does not involve human interpretation of complex visual data in the same way.

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

    This device is a standalone diagnostic assay (an "algorithm only" if one considers the assay chemistry and instrument processing as the "algorithm"). It performs quantitative measurements without direct human real-time interpretation influencing the numerical result. The human element is in collecting the sample, running the test, and interpreting the numerical result in a clinical context.

    7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)

    The ground truth for comparative studies and assessment of substantial equivalence is primarily established by:

    • Predicate Device Results: For method comparison and clinical agreement, the results from the legally marketed predicate device (Freelite® Human Kappa/Lambda Free Kit on the Siemens BN™II) are used as the reference ('ground truth') for comparison.
    • CLSI Guidelines: For analytical performance (precision, linearity, detection limits, interference), the "ground truth" is defined by adherence to the methodologies and performance expectations outlined in recognized CLSI guidelines (e.g., EP17-A, EP7-A2, EP6-A, EP5-A2).

    8. The Sample Size for the Training Set

    This document does not specify a separate "training set" sample size in the context of machine learning. For IVD devices, development involves extensive internal testing and optimization (which can be considered analogous to "training"), but the provided document focuses on the validation studies. The studies described are primarily validation studies against regulatory requirements.

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

    Given that this is an IVD kit based on turbidimetry, it doesn't involve a "training set" or "ground truth" in the machine learning sense. The "ground truth" during development (analogous to training) would involve using known concentrations of analytes, reference materials, and established analytical methods to ensure the assay performs as expected.

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