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510(k) Data Aggregation
(282 days)
The Roche Acetaminophen assay is an in vitro test for the quantitative determination of toxic levels of acetaminophen in serum and plasma on Roche COBAS Integra, Roche/ Hitachi and cobas c system analyzers.
The Roche Diagnostics Acetaminophen assays under consideration in this submission are the same assays as were cleared on the COBAS Integra in K991598, Hitachi 917 in K013757 and cobas c501 in K060373 for the quantitative determination of toxic levels of Acetaminophen in human serum and plasma on automated clinical chemistry analyzers. The same reagents are used on all three systems. Acetaminophen is hydrolyzed by an arylacylamidase to yield p-aminophenol and acetate. Subsequently, the p-aminophenol is converted to an indophenol in the presence of o-cresol and a periodate catalyst. The production of indophenol is followed colorimetrically. The change in absorbance is directly proportional to the quantitative drug concentration in the sample.
The acceptance criteria for the Roche Acetaminophen assay are based on demonstrating substantial equivalence to previously cleared predicate devices: Roche COBAS Integra Acetaminophen assay (K991598), Roche/Hitachi Acetaminophen assay (K013757), and cobas c501 Acetaminophen assay (K060373). The study performed by Roche Diagnostics focused on validating the performance of the new Roche Acetaminophen assays on the cobas 8000 Modular Analyzer Series, specifically on the cobas c501 and Hitachi 917 platforms, and confirming similar performance on the COBAS Integra platform.
The study did not explicitly state "acceptance criteria" in terms of numerical thresholds for performance metrics. Instead, it demonstrated equivalence by comparing the analytical characteristics of the new assays with those of the predicate devices. The key performance aspects compared include:
1. Table of Acceptance Criteria (Implied) and Reported Device Performance:
Feature | Implied Acceptance Criteria (Equivalent to Predicate) | Reported Device Performance (Roche Acetaminophen assay) |
---|---|---|
Indications for Use | Quantitative determination of toxic levels of acetaminophen in serum and plasma. | Same as predicate (stated as "Same" in tables). |
Technology | Enzymatic-end point assay. | Same as predicate (stated as "Same" in tables). |
Sample types | Serum and plasma. | Same as predicate (stated as "Same" in tables). |
Calibrators | COBAS Integra calibrators. | Same as predicate (stated as "Same" in tables). |
Reagents | R1: Sodium periodate 3.75 mmol/L, R2: Arylacylamidase (microbial) ≥7000U/L; o-cresol 3.75 mmol/L (order varies on Integra). | Same as predicate (stated as "Same" in tables). |
Analytical Sensitivity (LoB) | cobas c501/Hitachi 917: 1.2 µg/ml; COBAS Integra: 0.7 µg/ml (LDL). | cobas c501/Hitachi 917/COBAS Integra: 1.2 µg/ml. |
Analytical Sensitivity (LoD) | Not explicitly stated for predicate in this K. | cobas c501/Hitachi 917/COBAS Integra: 2.4 µg/ml. |
Analytical Sensitivity (LoQ) | Not explicitly stated for predicate in this K. | cobas c501/Hitachi 917/COBAS Integra: 15 µg/ml. |
Measuring range | cobas c501: 1.2-500 µg/ml; Hitachi 917: 1.2-600 µg/ml; COBAS Integra: 0.7-300 µg/ml. | cobas c501/Hitachi 917: 15-500 µg/ml; COBAS Integra: 15-300 µg/ml. |
Interferences (Bilirubin) | Bilirubin interference at Acetaminophen level of 50 µg/ml. | Bilirubin interference at Acetaminophen level of 15, 30 and 50 µg/ml. |
Important Note on Measuring Range and Sensitivity: While the new device's LoB is 1.2 µg/ml for all platforms, the "Measuring range" starts at 15 µg/ml. This is a key difference from the predicate devices which had measuring ranges starting at their respective LDLs (1.2 µg/ml or 0.7 µg/ml). The LoQ (Limit of Quantitation) of 15 µg/ml seems to define the lower end of the measuring range for the new device. Additionally, the new assays performed more extensive bilirubin interference testing (at 15, 30, and 50 µg/ml) compared to the predicates (only at 50 µg/ml).
2. Sample size used for the test set and the data provenance:
- The document does not explicitly state the sample sizes used for the analytical performance studies (e.g., for LoB, LoD, LoQ, measuring range, specificity, or interference testing).
- The document does not specify the data provenance (e.g., country of origin, retrospective or prospective).
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 submission. This is a 510(k) for an in vitro diagnostic (IVD) assay based on chemical/enzymatic reactions. The "ground truth" for an IVD assay's analytical performance (e.g., concentration of acetaminophen) is established through reference methods, certified reference materials, and robust analytical chemistry techniques, not through expert consensus on images or clinical outcomes.
4. Adjudication method for the test set:
- This information is not applicable as it pertains to expert reviews of data, which is not how analytical performance of IVD assays is typically established.
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, an MRMC comparative effectiveness study was not done. This is an IVD device, not an AI-powered diagnostic system that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done:
- Yes, the performance described is the standalone performance of the analytical assay (the "algorithm" here is the chemical reaction and measurement system). There is no "human-in-the-loop" performance being evaluated in the context of this device's function.
7. The type of ground truth used:
- The "ground truth" for the analytical performance of this assay would be established using reference methods (e.g., gas chromatography-mass spectrometry (GC-MS) or high-performance liquid chromatography (HPLC) for acetaminophen quantification) and certified reference materials with known concentrations of acetaminophen. The document doesn't explicitly detail the reference methods used but implies the use of quantitative standards for calibration and evaluation.
8. The sample size for the training set:
- This information is not explicitly stated as it's an analytical assay and not a machine learning algorithm that typically requires a distinct "training set." The development of such assays involves extensive R&D, method optimization, and analytical validation which uses various samples and experiments, but these are not typically referred to as a "training set" in the context of AI/ML.
9. How the ground truth for the training set was established:
- As above, the concept of a "training set" with established ground truth in the AI/ML sense is not applicable here. The analytical accuracy and precision are established through internal validation studies using known concentrations of analytes and comparison to reference methods, not through human-adjudicated ground truth.
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