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510(k) Data Aggregation

    K Number
    K240468
    Date Cleared
    2024-10-16

    (239 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Irving, Texas 75038

    Re: K240468

    Trade/Device Name: Alkaline Phosphatase Regulation Number: 21 CFR 862.1050
    Name: Nitropheny|phosphate, Alkaline Phosphatase Or Isoenzymes Governing Regulation Number: 21 CFR §862.1050

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

    The Alkaline Phosphatase assay is used for the quantitation of alkaline phosphatase in human serum or plasma.

    Measurements of alkaline phosphatase or its isoenzymes are to be used as an aid in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases.

    Device Description

    The Alkaline Phosphatase assay is an automated clinical chemistry assay.

    Alkaline phosphatase in the sample catalyzes the hydrolysis of colorless p-nitrophenyl phosphate (p-NPP) to give p-nitrophenol and inorganic phosphate. At the pH of the assay (alkaline), the p-nitrophenol is in the yellow phenoxide form. The rate of absorbance increase at 404 nm is directly proportional to the alkaline phosphatase activity in the sample. Optimized concentrations of zinc and magnesium ions are present to activate the alkaline phosphatase in the sample.

    AI/ML Overview

    The FDA document provided is a 510(k) premarket notification for an in vitro diagnostic device, the Alkaline Phosphatase assay. This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving safety and effectiveness de novo. Therefore, the information provided relates to testing done to establish equivalence for a pre-existing device with modifications, not a new device.

    The study proves that the modified device meets acceptance criteria, primarily by demonstrating that it performs equivalently to the predicate device and that incremental changes do not adversely affect its performance.

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

    Acceptance Criteria and Reported Device Performance

    The document provides a general statement that the device "met the pre-defined product requirements for all characteristics evaluated in the verification studies." It doesn't present a specific table of acceptance criteria vs. performance in the typical format of a clinical study, but rather a comparison of characteristics to a predicate device and a statement about the results of verification studies.

    The key acceptance criterion discussed is substantial equivalence to the predicate device (K023807), particularly regarding:

    • Intended Use and Indications for Use: The subject device is intended for the same use as the predicate: "quantitation of alkaline phosphatase in human serum or plasma," as an aid in diagnosis and treatment of various diseases.
    • Methodology and Assay Principle: Both use para-nitrophenyl phosphate and a kinetic measurement method.
    • Performance (specifically after IFCC calibration factor change): The 6.5% increase in reported results due to the optional IFCC calibration factor is deemed acceptable because it falls within the acceptable assay bias specifications (up to +/-10%) and the customer would be aware of this change.
    • Risk Mitigation: The comprehensive risk-based assessment for all changes ensured that "the accumulated modifications did not impact the performance of the device."

    Since this is an in vitro diagnostic device for measuring a specific analyte (Alkaline Phosphatase), the "performance" here refers to analytical performance characteristics rather than clinical diagnostic accuracy in the way a medical imaging AI would.

    Here's a table summarizing the implicit acceptance criteria and the reported performance as derived from the document:

    Acceptance Criteria CategorySpecific Acceptance Criterion (Implicit)Reported Device Performance and Conclusion
    Intended UseMatch predicate's intended use."The Alkaline Phosphatase assay is used for the quantitation of alkaline phosphatase in human serum or plasma." and "Measurements of alkaline phosphatase or its isoenzymes are to be used as an aid in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases." - Matches predicate.
    Methodology / Assay PrincipleMatch predicate's core analytical method (para-nitrophenyl phosphate)."Para-nitrophenyl phosphate" methodology and "Same" assay principle as predicate. - Matches predicate.
    Specimen TypeMatch predicate's accepted specimen types."Human serum or plasma" - Matches predicate. Minor differences in specific tube types cited, but overall specimen type is equivalent.
    Performance (Post-Modification)All "pre-defined product requirements" regarding characteristics evaluated in verification studies must be met. Specifically, for the IFCC calibration factor: results shift must be within acceptable assay bias specifications (up to +/-10%) and not cause incorrect results, with awareness to the user. Overall, modifications should not impact device performance negatively."The Alkaline Phosphatase assay, evaluated using the optional calibration factor of 2290 on the ARCHITECT c System, met the pre-defined product requirements for all characteristics evaluated in the verification studies." The 6.5% increase in reported results due to the IFCC calibration factor "is within the acceptable assay bias specifications (up to +/-10%) and thus does not have a potential to cause incorrect results." The comprehensive risk-based assessment concluded that "the accumulated modifications did not impact the performance of the device." - Criteria Met.
    Risk AssessmentComprehensive risk-based assessment conducted for all changes, including risk control measures and verification/validation activities. The aim is to demonstrate that modifications do not impact performance and support substantial equivalence."Abbott performed a comprehensive risk-based assessment for each of the changes listed... The assessment includes all risks associated with each device modification, risk control measures to mitigate each identified risk, and the verification and/or validation activities required... The risk control measures show that the accumulated modifications did not impact the performance of the device." - Criteria Met.

    Study Details (based on the provided text, which is an FDA clearance letter for an IVD, not a detailed study report for AI/imaging device)

    The document relates to modifications made to an existing in vitro diagnostic (IVD) device, not a new AI-powered diagnostic for imaging. Therefore, many of the typical questions for an AI/imaging device (e.g., sample size for test set, expert readers, MRMC study, ground truth for imaging) are not directly applicable or detailed in this type of FDA letter.

    However, based on the information provided, we can infer some details relevant to an IVD device:

    1. Sample Size used for the test set and the data provenance:

      • Sample Size: Not explicitly stated. The document refers to "verification studies" which typically involve testing samples across the measurement range, parallelism, interference, precision, etc. for an IVD. The exact number of samples (patients or analytical runs) isn't specified in this summary.
      • Data Provenance: Not specified regarding country of origin. The studies are described as "verification studies" and "comprehensive risk-based assessment." For IVDs, these are typically prospective laboratory studies conducted by the manufacturer to validate performance characteristics. It's safe to assume they were laboratory-controlled, likely prospective.
    2. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • This question is not applicable in the context of this IVD device. "Ground truth" for an IVD like Alkaline Phosphatase is established by the analytical measurement itself, often compared to reference methods or known concentrations, or through internal validation against established performance claims. It does not involve human expert interpretation of an image or signal.
    3. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • This question is not applicable for this IVD. Adjudication methods like 2+1 or 3+1 are used in AI/imaging studies where multiple human readers interpret data that then needs to be reconciled to establish a "ground truth" for comparison with AI. For an IVD, there isn't subjective interpretation of this kind. The measurement process itself generates the result.
    4. 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 type of study is not applicable to this IVD. MRMC studies are specific to AI-assisted imaging diagnostics, evaluating the impact of AI on human reader performance. This device provides a quantitative biochemical measurement, not an image for human interpretation.
    5. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • In a sense, yes, the fundamental performance of the IVD is "standalone" in that the automated analyzer (ARCHITECT c System) quantitatively measures alkaline phosphatase activity. The "algorithm" here is the chemical reaction and photometric measurement, and its output is a numerical value (U/L). The verification studies would assess this standalone analytical performance (e.g., precision, accuracy, linearity, detection limits) against pre-defined specifications. The IFCC factor is a mathematical change to this standalone output.
    6. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For an IVD like this, "ground truth" is typically established through:
        • Reference Methods: Comparison of results to established, highly accurate reference methods for alkaline phosphatase.
        • Known Concentrations: Testing samples with precisely known concentrations of alkaline phosphatase.
        • Clinical Correlation: Demonstrating that the assay measures the analyte in patient samples consistently and reliably across relevant patient populations, although the primary ground truth is analytical.
      • The document implies that the "pre-defined product requirements" and "acceptable assay bias specifications" served as the benchmarks for determining if the device performed acceptably. The 6.5% shift from the IFCC factor was evaluated against these analytical specifications.
    7. The sample size for the training set:

      • This question is not directly applicable in the context of a traditional IVD chemical assay development, as there isn't an "AI model" that requires a training set in the typical sense. The "training" for such a system would be the chemical formulation and instrument calibration based on extensive R&D and optimization, not a data-driven machine learning process. The "validation" of the final product involves the verification studies mentioned.
    8. How the ground truth for the training set was established:

      • As above, not directly applicable. The IVD operates on established biochemical principles. Its "ground truth" for development and optimization would be based on fundamental chemistry, enzyme kinetics, and metrological traceability to international standards (e.g., IFCC reference methods for calibrator values).
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    K Number
    K232904
    Device Name
    Access Ostase
    Manufacturer
    Date Cleared
    2024-04-15

    (210 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Drive Chaska, Minnesota 55318

    Re: K232904

    Trade/Device Name: Access Ostase Regulation Number: 21 CFR 862.1050
    Classification Regulation: [21 CFR 862.1050] Product Code: CIN

    Predicate Device Device Name: Access

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

    The Access Ostase assay is a paramagnetic particle, chemiluminescent immunoassay for use with the Access Immunoassay Systems for the quantitative measurement of bone alkaline phosphatase (BAP), an indicator of osteoblastic activity, in human serum and plasma. This device is intended to be used as an aid in the management of postmenopausal osteoporosis and Paget's disease.

    Device Description

    The Access Ostase assay is a one-step sandwich immunoenzymatic assay. The Access Ostase assay consists of the reagent pack, calibrators and QCs. Other items needed to run the assay include substrate and wash buffer. The Access Ostase assay reagent pack, Access Ostase assay calibrators, Access Ostase QCs, along with the UniCel Dxl Wash Buffer II are designed for use with the Dxl 9000 Access Immunoassay Analyzer in a clinical laboratory setting.

    AI/ML Overview

    The provided text describes the performance of the Beckman Coulter Access Ostase assay on the Dxl 9000 Access Immunoassay Analyzer, comparing it to the predicate device (Access Ostase on Access 2 Immunoassay System).

    Here's an analysis of the acceptance criteria and the studies performed, structured as requested:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't explicitly state "acceptance criteria" for each performance characteristic in a separate, clear table format. However, it does outline the assay's design goals for imprecision and then presents the results. For other parameters like linearity and detection limits, it states the claimed values or that linearity was demonstrated. I will infer the acceptance criteria for imprecision from the "designed to have" statement and present the reported performance.

    ParameterAcceptance CriteriaReported Device Performance (Access Ostase on Dxl 9000)
    Method ComparisonImplicit: Close statistical agreement (slope near 1, intercept near 0, high correlation) with the predicate device (Access Ostase on Access 2 Immunoassay System). While not explicitly stated as an "acceptance criteria," the results indicate substantial equivalence.N: 163 samples
    Concentration Range: 0.34 - 108 µg/L
    Slope: 0.95 (95% CI: 0.93 - 0.98)
    Intercept: 0.53 (95% CI: 0.32 - 0.75)
    Correlation Coefficient (R): 1.00
    Imprecision≤ 0.2 µg/L SD at concentrations ≤ 3 µg/L
    ≤ 7.0% CV at concentrations > 3 µg/L (within-laboratory imprecision)Sample 1 (Mean 1.8 µg/L): SD 0.1, %CV 4.7
    Sample 2 (Mean 9.1 µg/L): SD 0.4, %CV 4.1
    Sample 3 (Mean 25 µg/L): SD 1.1, %CV 4.4
    Sample 4 (Mean 38 µg/L): SD 1.6, %CV 4.3
    Sample 5 (Mean 98 µg/L): SD 4.1, %CV 4.2
    All reported within-laboratory %CVs are ≤ 7.0% and the SD for Sample 1 (1.8 µg/L) is 0.1 µg/L, meeting the criteria.
    LinearityImplicit: Demonstrate linearity across the measuring interval.Demonstrated linearity across the measuring interval.
    Limit of Blank (LoB)Claimed LoB of 0.1 µg/L.Claimed LoB for Access Ostase assay is 0.1 µg/L on Dxl 9000 Access Immunoassay Analyzer.
    Limit of Detection (LoD)Claimed LoD of 0.1 µg/L.Claimed LoD for Access Ostase assay is 0.1 µg/L on Dxl 9000 Access Immunoassay Analyzer.
    Limit of Quantitation (LoQ)Claimed LoQ of 0.3 µg/L.Claimed LoQ for Access Ostase assay is 0.3 µg/L on Dxl 9000 Access Immunoassay Analyzer.

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

    • Method Comparison Test Set:

      • Sample Size: 163
      • Data Provenance: Not explicitly stated (e.g., country of origin, retrospective/prospective). However, the study involved comparing results from two different immunoassay systems (Access 2 and Dxl 9000) using patient samples, implying real-world or simulated clinical samples.
    • Imprecision Test Set:

      • Sample Size: 80 for each of the 5 samples tested (total of 400 individual measurements of samples).
      • Data Provenance: Not explicitly stated. The study involved testing "multiple samples in duplicate in 2 runs per day for a minimum of 20 days," which suggests a controlled laboratory setting.
    • Linearity, LoB, LoD, LoQ: The sample sizes for these studies are not explicitly mentioned, nor is their specific provenance beyond being performed "on the Dxl 9000 Access Immunoassay Analyzer."

    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 an in vitro diagnostic (IVD) assay that measures quantitative analytes like bone alkaline phosphatase. The "ground truth" for such devices is typically established through reference methods, certified reference materials, or statistical comparison to a legally marketed predicate device (as done here). There are no "experts" in the human perception or diagnostic interpretation sense used to establish ground truth for this type of test.

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

    Not applicable. Adjudication methods like 2+1 or 3+1 are typically used in studies involving human interpretation (e.g., radiology reads) where discrepancies between experts need to be resolved to establish ground truth. This is a quantitative immunoassay.

    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. This device is an in vitro diagnostic immunoassay, not an AI-assisted diagnostic tool for human readers. No MRMC study was performed.

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

    This device is an automated immunoassay system that provides quantitative results. The performance studies described (Method Comparison, Imprecision, Linearity, LoB/LoD/LoQ) inherently represent the standalone performance of the device (including its reagents and analyzer software) in generating these quantitative results. It operates without direct human-in-the-loop interpretation of the primary measurement signal for the reported value. A human reviews the final numerical result, but the device itself generates that result primarily through an automated process.

    7. The type of ground truth used:

    • Method Comparison: The ground truth was established by comparison to the predicate device (Access Ostase on Access 2 Immunoassay System). This assumes the predicate device's measurements represent a valid "truth" for substantial equivalence purposes. Patient samples were used, and their values from one system were compared to the other.
    • Imprecision: The ground truth for evaluating imprecision is the inherent variability of the measurement process itself, determined by repeated measurements of samples with known (or established) concentrations.
    • Linearity, LoB, LoD, LoQ: These are determined using samples of known concentrations (dilutions, blank samples, low-concentration samples) and statistical methods based on CLSI guidelines.

    8. The sample size for the training set:

    Not applicable. This device is a quantitative immunoassay system, not a machine learning or AI model that requires a "training set" in the conventional sense. The development of such assays involves extensive research, development, and optimization of reagents and protocols, but this is distinct from "training data" for an algorithm.

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

    Not applicable, as there is no "training set" in the context of an AI/ML algorithm.

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    K Number
    K223317
    Date Cleared
    2023-07-21

    (266 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    N/A
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Ireland

    Re: K223317

    Trade/Device Name: Alkaline Phosphatase2 Regulation Number: 21 CFR 862.1050 Regulation
    Classification Name: Alkaline phosphatase or isoenzymes test system Governing Regulation Number: 21 CFR §862.1050

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

    The Alkaline Phosphatase2 assay is used for the quantitation of alkaline phosphatase in human serum or plasma on the ARCHITECT c System.

    Measurements of alkaline phosphatase or its isoenzymes are to be used as an aid in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases.

    Device Description

    The Alkaline Phosphatase2 assay is an automated clinical chemistry assay for the quantitation of alkaline phosphatase in human serum or plasma on the ARCHITECT c System. Alkaline Phosphatase in a sample catalyzes the hydrolysis of colorless para-nitrophenyl phosphate (p-NPP) to give para-nitrophenol (yellow phenoxide form at alkaline pH) and inorganic phosphate. The rate of absorbance increase at 404 nm is directly proportional to the alkaline phosphatase activity in the sample. Optimized concentrations of zinc and magnesium ions are present to activate the alkaline phosphatase in the sample.

    AI/ML Overview

    The provided document is a 510(k) Premarket Notification for a clinical chemistry assay (Alkaline Phosphatase2) and does not describe an AI medical device. Therefore, the questions related to AI-specific acceptance criteria, ground truth establishment by experts, adjudication methods, multi-reader multi-case studies, and human-in-the-loop performance are not applicable.

    The document focuses on the analytical performance of the Alkaline Phosphatase2 assay, demonstrating its substantial equivalence to a legally marketed predicate device. The information details various non-clinical performance studies to establish the device's reliability and accuracy for quantitating alkaline phosphatase in human serum or plasma.

    Here's a breakdown of the relevant information from the document, tailored to the context of a diagnostic assay's performance evaluation, substituting the AI-specific questions with applicable details:


    Acceptance Criteria and Device Performance for Alkaline Phosphatase2 Assay

    This submission (K223317) is for a clinical chemistry assay, not an AI medical device. The acceptance criteria and performance studies are focused on the analytical performance of the assay to demonstrate its intended use for quantitative measurement of alkaline phosphatase.

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly present a "table of acceptance criteria" for regulatory review, but it details various performance studies with implicit acceptance ranges. The reported device performance metrics are presented instead.

    Performance Metrics of Alkaline Phosphatase2 Assay (Representative Values)

    Performance MetricAcceptance Criteria (Implied by Study Design & Clinical Standards)Reported Device Performance (Example Values)
    Analytical Measuring Interval (AMI)Defined range for acceptable linearity, imprecision, and bias.4-4522 U/L
    Reportable IntervalExtends from LoD to upper limit of AMI.3-4522 U/L
    Precision (Within-Laboratory - %CV)(Example target from CLSI EP05-A3 guidelines)Range from 0.3% to 11.5%
    * Low-End Control (~115 U/L)*(e.g.,
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    K Number
    K200475
    Date Cleared
    2020-09-30

    (217 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    9PD United Kingdom

    Re: K200475

    Trade/Device Name: IDS-iSYS Ostase® BAP Regulation Number: 21 CFR 862.1050

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

    The IDS-iSYS Ostase® BAP assay is an in vitro diagnostic device intended for the quantitative determination of bone-specific alkaline phosphatase (BAP), an indicator of osteoblastic activity, in human serum on the IDS system. Results are to be used in conjunction with other clinical and laboratory data to aid the clinician in the management of postmenopausal osteoporosis and Paget's disease.

    Device Description

    The IDS-iSYS Ostase® BAP assay consists of one reagent cartridge and one set of calibrators (CAL A & CAL B).

    The reagent cartridge contains multiple reagents:

    • MPM1 (Magnetic particles coated with streptavidin in a phosphate buffer with sodium azide as preservative);
    • Ab-BIOT Monoclonal anti-BAP labelled with biotin, in buffer containing horse serum with bovine and mouse proteins and sodium azide as a preservative (
    AI/ML Overview

    The provided document is a 510(k) Premarket Notification from the FDA for a medical device called "IDS-iSYS Ostase® BAP." This document is primarily concerned with demonstrating the substantial equivalence of the new device to a predicate device, rather than focusing on the acceptance criteria and study proving performance for an AI/ML-based medical device.

    Therefore, the requested information regarding AI/ML-specific acceptance criteria and validation studies (like sample size for test set, data provenance, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, training set details) is not present in this document because it describes an in vitro diagnostic (IVD) test for quantitative determination of bone-specific alkaline phosphatase, not an AI/ML-driven imaging or diagnostic algorithm.

    However, I can extract the relevant performance characteristics that are analogous to "acceptance criteria" for this type of IVD device and the study data proving it meets those.


    Device Description

    The IDS-iSYS Ostase® BAP assay is an in vitro diagnostic device intended for the quantitative determination of bone-specific alkaline phosphatase (BAP), an indicator of osteoblastic activity, in human serum on the IDS system. Results are to be used in conjunction with other clinical and laboratory data to aid the clinician in the management of postmenopausal osteoporosis and Paget's disease.


    1. Table of Acceptance Criteria (Performance Characteristics) and Reported Device Performance

    For an in vitro diagnostic device, "acceptance criteria" are typically defined by various analytical performance characteristics that demonstrate the device's accuracy, precision, and reliability for its intended use. While explicit acceptance ranges are not always presented as a separate "criteria" table in a 510(k), the studies conducted implicitly aim to demonstrate performance within acceptable ranges for IVDs. The comparison to the predicate device and adherence to CLSI guidelines are key for demonstrating substantial equivalence.

    Here's a table summarizing the analytical performance characteristics and the reported device performance, which serve as the "proof" that the device meets the implied acceptance criteria for an IVD:

    Performance CharacteristicAcceptance Criteria (Implied / Comparator)Reported Device Performance (IDS-iSYS Ostase® BAP)
    PrecisionTypically aims for low %CV (Coefficient of Variation) within and between runs, indicating reproducibility. Compared to predicate:
    • Predicate Within Run: 2.6% to 6.5% (7.4 to 79.5 μg/L)
    • Predicate Between Run: 2% to 6.4% (8.4 to 81.1 µg/L) | Repeatability (Within Run):
      From 1.7% to 2.8% in the concentration range 6.2 to 59.8 µg/L (N=80 data points for each sample, for one representative lot).
      From 1.7% to 2.8% for combined 3 lots across samples 1-10 (6.2-59.8 μg/L).
      Within Laboratory (Between Run/Total Precision):
      From 3.0% to 7.6% in the concentration range 6.2 to 59.8 µg/L (N=80 data points for each sample, for one representative lot).
      From 3.0% to 7.2% for combined 3 lots across samples 1-10 (6.2-59.8 μg/L).
      Overall, shows robust precision comparable or improved relative to the predicate. |
      | Linearity / Reportable Range | The assay should demonstrate linearity across its claimed measuring range. Expected a high correlation coefficient (R²) close to 1.0.
    • Predicate Range: 0.7 – 90 µg/L. | Linear Range: 0.9 to 78.5 µg/L.
      Measuring (Reportable) Range: 3 to 70 µg/L.
      Regression: Observed = 0.98 x (Expected) - 0.9 ng/mL.
      Regression coefficient R²: 1.00.
      The high R² demonstrates excellent linearity across the range. |
      | Detection Limits (LoB, LoD, LoQ) | Low values for LoB (Limit of Blank), LoD (Limit of Detection), and LoQ (Limit of Quantitation) are desirable to demonstrate the ability to detect very low concentrations of the analyte.
    • Predicate: LoD 0.7 µg/L. Other values N/A. | LoB (Limit of Blank): 0.3 µg/L
      LoD (Limit of Detection): 0.4 µg/L
      LoQ (Limit of Quantitation): 0.5 µg/L
      Demonstrates improved or comparable sensitivity to the predicate. |
      | Analytical Specificity (Interference) | Bias due to common interfering substances should be non-significant, typically defined as
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    K Number
    K191245
    Manufacturer
    Date Cleared
    2019-08-30

    (113 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Re: K191245

    Trade/Device Name: Yumizen C1200 ALP, Yumizen C1200 Albumin Regulation Number: 21 CFR 862.1050
    | Class II / 510(k) required |
    | Classification Name: | §862.1050

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

    Yumizen C1200 ALP reagent is intended for the quantitative in vitro diagnostic determination of alkaline phosphatase in human serum and plasma based on a kinetic photometric test using p-Nitropherylphosphate. Measurements of alkaline phosphatase or its isoenzymes are used in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases.

    Yumizen C1200 Albumin reagent is intended for the quantitative in vitro diagnostic determination of albumin in human serum and plasma by colorimetry. Albumin measurements are used in the diagnosis and treatment of numerous diseases involving primarily the liver or kidneys.

    Device Description

    Not Found

    AI/ML Overview

    The provided text describes analytical performance characteristics and comparison studies for two in vitro diagnostic reagents, Yumizen C1200 ALP and Yumizen C1200 Albumin, intended for use on the Yumizen C1200 clinical chemistry analyzer. The document is a 510(k) summary, demonstrating substantial equivalence to predicate devices.

    Here's an analysis of the acceptance criteria and the studies performed, structured according to your request:

    Acceptance Criteria and Reported Device Performance

    For both assays, the acceptance criteria are implicitly defined by the successful demonstration of performance characteristics within established guidelines (CLSI) and comparison to their respective predicate devices. The "Results are within predefined acceptance criteria" statements affirm that the tested parameters met the company's internal benchmarks, which are aligned with industry standards for analytical performance.

    Here's a table summarizing the reported device performance for key analytical characteristics:

    Acceptance Criteria CategoryYumizen C1200 ALP Reported PerformanceYumizen C1200 Albumin Reported Performance
    Measuring RangeLoD = 1.40 U/L, LoQ = 5.85 U/L, Linearity 0-1620 U/L. Measuring Range: 6 to 1200 U/L (up to 4800 U/L with post-dilution)LoD = 0.57 g/L, LoQ = 3.34 g/L, Linearity 0-60.2 g/L. Measuring Range: 4.6 to 56 g/L (up to 112 g/L with post-dilution)
    Precision (Within-Run CV)Single Site: Low: 3.3%, Mid: 1.0%, High: 0.5% (Sample 1, 3, 5)Single Site: Low: 0.7%, Mid: 0.4%, High: 0.4% (Sample L, M, H)
    Multi Site: Low: 2.7%, Mid: 1.3%, High: 2.0% (Sample 1, 3, 5 - listed as Within-Day)Multi Site: Low: 2.2%, Mid: 1.4%, High: 0.6% (Sample 1, 2, 3 - listed as Within-Day)
    Precision (Total CV)Single Site: Low: 7.2%, Mid: 6.8%, High: 2.5% (Sample 1, 3, 5)Single Site: Low: 3.3%, Mid: 2.3%, High: 2.1% (Sample L, M, H)
    Multi Site: Low: 3.9%, Mid: 2.5%, High: 3.6% (Sample 1, 3, 5)Multi Site: Low: 3.4%, Mid: 1.8%, High: 0.8% (Sample 1, 2, 3)
    Interferences (Analyte values not showing >10% interference)Hemoglobin: 500 mg/dL, Triglycerides: 504.88 mg/dL, Total Bilirubin: 28.84 mg/dL, Direct Bilirubin: 26.36 mg/dL, Acetylsalicylic Acid: 65.16 mg/dL, Ascorbic Acid: 5.98 mg/dL, Ibuprofen: 50.10 mg/dL, Acetaminophen: 20 mg/dLHemoglobin: 375 mg/dL, Triglycerides: 463.75 mg/dL, Total Bilirubin: 31.39 mg/dL, Direct Bilirubin: 26.27 mg/dL, Acetylsalicylic Acid: 65.16 mg/dL, Ascorbic Acid: 5.98 mg/dL, Ibuprofen: 50.10 mg/dL, Acetaminophen: 20 mg/dL
    Method Comparison (with predicate device)N=165 serum samples. Intercept: +3.907, Slope: 0.940, Correlation R²: 0.993 (against COBAS INTEGRA systems ALP IFCC Gen.2)N=111 serum samples. Intercept: +0.421, Slope: 0.963, Correlation R²: 0.990 (against ABX Pentra 400 ABX Pentra Albumin CP)
    Matrix Comparison (Plasma vs. Serum)N=40 lithium-heparin plasma samples. Intercept: 0.3709, Slope: +1.013, Correlation: 0.993 (against Cobas800 with c502 module)N=70 lithium-heparin plasma samples. Intercept: 0.769, Slope: +1.009, Correlation: 0.988 (against Pentra C400)
    Reagent StabilityClosed: 15 months (2-8°C). On-board: 1 weekClosed: 24 months (2-8°C). On-board: 6 weeks
    Reference RangeVerified against literature and limited study. Adults (Men: 40-129 U/L, Women: 35-104 U/L). Children data from literature.Verified against literature and limited study. Adults: 35-52 g/L. Children data from literature.

    Study Details:

    1. Sample Size Used for the Test Set and Data Provenance:

      • Yumizen C1200 ALP:
        • Measuring Range/Linearity: Data not explicitly stated for individual samples, but the study showed linearity from 0 to 1620 U/L.
        • Precision: "Single site: 20x2x2" and "Multi site: 3x5x2x3". This notation often refers to runs x replicates x instrument/lots, but the exact number of unique "samples" (control and general) for precision is stated as N=240 for single site, and N=90 for multi-site across various levels (control and patient samples). The provenance of these samples is not specified (e.g., country of origin) but they are "control" or "patient" samples. It's an analytical performance study, not a clinical study on specific patient populations.
        • Interferences: Specific sample numbers for this study are not provided, but the tested interferent concentrations are listed.
        • Method Comparison: 165 native serum samples.
        • Matrix Comparison: 40 lithium-heparin plasma samples (individual donors).
      • Yumizen C1200 Albumin:
        • Measuring Range/Linearity: Data not explicitly stated for individual samples, but the study showed linearity from 0 to 60.2 g/L.
        • Precision: "Single site: 20x2x2" and "Multi site: 3x5x2x3". Again, N=240 for single site and N=90 for multi-site across various levels.
        • Interferences: Specific sample numbers for this study are not provided.
        • Method Comparison: 111 native serum samples.
        • Matrix Comparison: 70 lithium-heparin plasma samples (individual donors).
      • Data Provenance: The document does not specify the country of origin for the samples. The studies are described as analytical performance validations, which are typically retrospective using banked/collected samples. The term "native serum samples" and "individual donors" implies real patient samples.
    2. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts:

      • This is an in vitro diagnostic device (measurement of lab analytes), not an imaging AI or diagnostic AI device where human experts establish "ground truth" in the typical sense of clinical interpretation.
      • The ground truth for the test set is established by the predicate devices (Roche Diagnostics ALP IFCC Gen2 on COBAS INTEGRA systems, and HORIBA ABX SAS ABX Pentra Albumin CP on ABX Pentra 400/Pentra C400) or by established analytical methods for measuring concentrations (e.g., gravimetric for linearity, standard additions for LoD/LoQ).
      • The "experts" involved are likely laboratory professionals, biochemists, and statisticians who design and execute these analytical validation studies according to CLSI (Clinical and Laboratory Standards Institute) guidelines. Their specific qualifications (e.g., MD, PhD) or number are not explicitly stated in this document but are assumed to be standard for medical device development.
    3. Adjudication Method for the Test Set:

      • Not applicable in the context of analytical performance studies of laboratory reagents. Adjudication (e.g., 2+1, 3+1 consensus) is typical for clinical studies involving subjective interpretations (e.g., radiology reads). For a quantitative IVD, the "truth" is the measured value from a reference method or known concentration.
    4. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:

      • No, an MRMC study was not done. This type of study is relevant for diagnostic imaging interpretation or other scenarios where human readers make subjective judgments, and AI provides assistance. This document is for quantitative lab reagents, where the assessment is about the accuracy and precision of the measurement itself.
    5. If a Standalone Performance Study Was Done:

      • Yes, the entire document describes standalone performance of the Yumizen C1200 ALP and Albumin reagents on the Yumizen C1200 analyzer. This is not an "algorithm only without human-in-the-loop" performance as the device itself is an integrated system of reagent, instrument, and software. "Standalone" in this context means the performance of the new device/reagent system as a complete unit, not in comparison to human interpretation.
    6. The Type of Ground Truth Used:

      • External Reference Measurement: For method comparison studies, the "ground truth" is the result obtained from the legally marketed predicate device (Roche Diagnostics ALP IFCC Gen2 for ALP, and HORIBA ABX SAS ABX Pentra Albumin CP for Albumin).
      • Known Concentrations/Standards: For linearity, limit of detection/quantitation, and interference studies, the ground truth is established by preparing samples with known concentrations of analytes and/or interferents.
      • Consensus/Literature: For reference ranges, the ground truth is based on established bibliographic references and a verification study using "normal samples" from a blood bank.
    7. The Sample Size for the Training Set:

      • This document describes the validation/test phase for regulatory submission (510(k)). It does not detail the training set used for the development of the reagents or the analyzer's measurement algorithms. For IVDs, the "training" analogous to machine learning often involves extensive R&D, chemical optimization, and instrument calibration development using a variety of samples, but these are not explicitly quantified in terms of a "training set" size in this regulatory summary.
    8. How the Ground Truth for the Training Set Was Established:

      • As above, details about the "training set" are not provided. However, for the development of quantitative IVD assays, ground truth for initial development/training would typically be established through:
        • Primary Reference Methods: Highly accurate and precise methods (e.g., isotope-dilution mass spectrometry) for specific analytes, often used for calibrator assignment.
        • Certified Reference Materials: Materials with an assigned value and uncertainty for an analyte, traceable to recognized metrological standards.
        • Large Sample Cohorts: A diverse range of clinical samples (with values determined by established methods) to ensure robustness across different patient populations and disease states.
        • Experimental Design: Controlled experiments to characterize reagent stability, reaction kinetics, and potential interferents.
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    510k Summary Text (Full-text Search) :

    skyla Clinical Chemistry Analyzer Minicare C300 Clinical Chemistry Analyzer Regulation Number: 21 CFR 862.1050
    I |
    | Alkaline phosphatase or isoenzymes test system | CJE | 862.1050

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

    The Comprehensive Metabolic Panel is intended to be used for the quantitative determination of Alkaline Phosphate (ALP), Alanine Aminotransferase (ALP/GPT), Aspartate Aminotransferase (AST/GOT), Blood Urea Nitrogen (BUN) and Creatinine (CREA) in concentrations in lithium-heparinized venous whole blood, heparinized plasma, or serum in a clinical laboratory setting or point-of-care location.

    • Alkaline phosphatase or its isoenzymes measurements are used in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases.

    • Alanine aminotransferase measurements are used in the diagnosis and treatment of certain liver diseases (e.g., viral hepatitis and cirrhosis) and heart diseases.

    • Aspartate aminotransferase measurements are used in the diagnosis and treatment of certain types of liver and heart disease.

    • Blood urea nitrogen measurements are used in the diagnosis and treatment of certain types of renal and metabolic diseases.

    • Creatinine measurements are used in the diagnosis and treatment of renal dialysis, and as a calculation basis for measuring other urine analytes.

    The skyla Clinical Chemistry Analyzer is an in-vitro diagnostic device for the quantitative determination of clinical chemistry analytes in lithium-heparinized venous whole blood, heparinized plasma, or serum. It is for clinical laboratory and point-of-care use.

    The Minicare C300 Clinical Analyzer is an in-vitro diagnostic devices for the quantitative determination of clinical chemistry analytes in lithium-heparinized venous whole blood, heparinized plasma, or serum. It is for clinical laboratory and point-of-care use.

    Device Description

    The skyla Clinical Chemistry Analyzer, Minicare C300 Clinical Chemistry Analyzer (private label) and Comprehensive Metabolic Panel is an automatic chemistry system intended for use in clinical laboratories or point-of-care locations. The system consists of a portable analyzer and single-use disposable reagent panel discs.

    The analyzer utilizes precision photometric measurement technology, combined with the use of specific reagent panel disc, to measure the amount of substance in blood. The analyzer measures absorbance change of each reaction well in reagent panel disc and covert it to a concentration value for each analyte included on the panel.

    The skyla and Minicare Comprehensive Metabolic Panel reagent disc (which contains the Alkaline Phosphatase, Alanine Aminotransferase, Aspartate Aminotransferase, Blood Urea Nitrogen and Creatinine test systems) is designed to separate a heparinized venous whole blood sample into plasma and blood cells. The disc meters the required quantity of plasma and diluent, mixes the plasma with diluent, and delivers the mixture to the reaction cuvettes along the disc perimeter. The diluted plasma mixes with the reagent beads, initiating the chemical reactions that are then monitored by the analyzer.

    AI/ML Overview

    The Lite-On Technology Corp.'s Comprehensive Metabolic Panel, skyla Clinical Chemistry Analyzer, and Minicare C300 Clinical Chemistry Analyzer (K171971) were evaluated for substantial equivalence. The acceptance criteria and performance data are primarily based on precision, matrix comparison, detection limits, linearity, and interference testing.

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally implied by the predicate device's performance and the established clinical laboratory standards (e.g., CLSI guidelines, recovery within 90-110% for interference). The reported device performance aligns with these expectations.

    Performance CharacteristicAcceptance Criteria (Implied / Stated)Device Performance (Reported)
    Internal Precision / Reproducibility (CV%)Less than 10%ALP: 1.7 - 4.3%
    ALT: 3.0 - 6.8%
    AST: 2.2 - 9.7%
    BUN: 3.0 - 3.8%
    CREA: 2.4 - 8.5%
    (All results within 10% CV)
    Matrix Comparison (Correlation Coefficient)High correlation (e.g., >0.99) with predicate/reference method for Serum vs. Plasma, Plasma vs. WB, WB vs. SerumALP: 0.9997 - 0.9998
    ALT: 0.9997 - 0.9998
    AST: 0.9987 - 0.9990
    BUN: 0.9988 - 0.9990
    CREA: 0.9964 - 0.9971
    (All show strong correlation)
    Detection Limit (LoD/LoQ)LoD/LoQ should meet requirements for total error for each analyte.ALP: LoD/LoQ: 4.405 U/L
    ALT: LoD/LoQ: 5.228 U/L
    AST: LoD/LoQ: 11.690 (LoQ) / 12.089 (LoD) U/L
    BUN: LoD/LoQ: 1.526 mg/dL
    CREA: LoD/LoQ: 0.262 mg/dL
    (All LoD/LoQ met requirements for total error)
    Linearity (R2 )High linearity (e.g., >0.99) across the claimed measuring range.ALP: 0.9967 (range 30-2083 U/L vs. claimed 41-1500 U/L)
    ALT: 0.9999 (range 17-535 U/L vs. claimed 20-500 U/L)
    AST: 0.9984 (range 16-1021.3 U/L vs. claimed 20-1000 U/L)
    BUN: 0.9979 (range 1.8-126.9 mg/dL vs. claimed 2-120 mg/dL)
    CREA: 0.9993 (range 0.48-21.48 mg/dL vs. claimed 0.6-20 mg/dL)
    (All show strong linearity within and beyond claimed ranges)
    Endogenous InterferenceRecoveries between 90% and 110% of the neat value.No significant effect (>10% effect) from Hemolysis (60-66 mg/dL), Icterus (13-32 mg/dL), Lipemia (189-1032 mg/dL) for any tested analyte.
    Exogenous InterferenceNo significant interference (>10% shift)Most substances showed no significant interference. Ibuprofen showed 11.8% Inc. for CREA, Salicylic acid showed 16.3% Dec. for ALT, and Theophylline showed 14.4% Dec. for ALP.
    POC Method Comparison (Correlation Coefficient)High correlation (e.g., >0.99) with a comparative clinical analyzer.ALP: 0.9987 (WB), 0.9986 (Serum)
    ALT: 0.9980 (WB), 0.9983 (Serum)
    AST: 0.9988 (WB), 0.9986 (Serum)
    BUN: 0.9981 (WB), 0.9977 (Serum)
    CREA: 0.9975 (WB), 0.9975 (Serum)
    (All show strong correlation)
    POC Precision (CV%)Less than 10% between operators.All analytes across three concentration levels at three POC sites showed CVs less than 10%.
    Electrical Safety and EMCCompliance with IEC 60601-1-2.Passed tests according to IEC 60601-1-2.

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

    • Internal Precision/Reproducibility: 80 runs per level (quadruplicate testing a day for 20 working days) for each of the three serum levels for all 5 analytes. Data provenance is not specified (e.g., country of origin) but refers to "patient serum samples." Implied prospective collection for the study.
    • Matrix Comparison: 40 human samples. Data provenance not specified. Implied prospective collection for the study.
    • Detection Limit: LoB: 60 measurements of a near-zero sample over 10 days. LoD/LoQ: serum samples containing very low concentrations, tested in triplicate using 2 lots of reagent discs for 10 days. Data provenance not specified. Implied prospective collection.
    • Linearity: 9 intermediate dilutions created from high and low human serum pool samples, plus spiked samples. Data provenance not specified. Implied prospective collection.
    • Endogenous Interferences: Not explicitly stated, but implies multiple samples to test two different concentrations (normal and abnormal) of analytes against specified interference levels. Data provenance not specified. Implied prospective collection.
    • Exogenous Substances: Two concentrations (low and high level) of samples for each of the 10 potential interferents. Data provenance not specified. Implied prospective collection.
    • Point-of-Care (POC) Method Comparison: Over 120 heparinized venous whole blood and serum samples for each analyte. Data provenance not specified; likely collected from the three POC sites, implying prospective collection.
    • Point-of-Care (POC) Precision Studies: Three levels of human serum samples from POC sites, assayed in quadruplicate twice a day for 20 days. Data provenance not specified. Implied prospective collection.
    • Point-of-Care (POC) Whole Blood Precision: Not explicitly stated, but tabular data suggests multiple analyses (mean, SD, CV) for low, medium, and high samples across 3 POC sites and multiple operators (OP1, OP2, OP3).

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

    This type of submission (510k for a clinical chemistry analyzer) does not typically involve human experts establishing a "ground truth" for the test set in the same way an image analysis or diagnostic AI device would. Instead, the ground truth is established by:

    • Reference Methods/Materials: Traceability to established reference methods (e.g., IFCC reference method for ALT/ALP/AST, CDC reference method for BUN, IDMS Reference Method for CREA) and reference materials (NIST SRM967).
    • Comparative Clinical Analyzers: For method comparison studies, the Beckman Coulter AU2700 clinical analyzer served as the comparative (reference) method.

    Therefore, the "experts" in this context are the established, validated, and traceable laboratory methods and instruments, rather than individual human practitioners.

    4. Adjudication Method for the Test Set

    Not applicable. Diagnostic test performance for clinical chemistry analyzers is typically evaluated by statistical comparison to a reference method or established clinical ranges, not by an adjudication process as seen in clinical trial settings for diagnostic imaging.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    No, an MRMC comparative effectiveness study was not done. This type of study is relevant for diagnostic imaging devices where multiple human readers interpret cases with and without AI assistance. This submission is for a clinical chemistry analyzer.

    However, the "POC Precision studies" did evaluate performance across multiple operators (9 operators) at three POC sites. This demonstrates inter-operator variability, which is a related concept to multi-reader studies in a laboratory context, but it does not measure an "improvement with AI vs. without AI assistance" since the device itself is the primary measurement tool, not an AI assistant to a human reader.

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

    Yes, the studies presented are generally "standalone" performance evaluations of the device (skyla/Minicare Clinical Chemistry Analyzer with Comprehensive Metabolic Panel) itself. The device automatically measures analytes and displays results; there isn't an "algorithm only" component separate from the integrated device performance. All performance data (precision, linearity, detection limits, interference) are solely based on the device's output.

    7. The Type of Ground Truth Used

    The ground truth for the device's performance is established through:

    • Traceability to Reference Methods/Materials: For calibration and analytical accuracy (e.g., IFCC, CDC, IDMS reference methods, NIST reference materials).
    • Comparative Clinical Analyzers: The Beckman Coulter AU2700 served as the comparative method for method comparison studies, essentially acting as the "ground truth" or reference for evaluating the test device's performance on patient samples.
    • Known Concentrations: For studies like linearity, detection limits, and interference, samples with known or spiked concentrations are used.

    8. The Sample Size for the Training Set

    This document does not specify a separate "training set" in the context of machine learning or AI. This device is a traditional in-vitro diagnostic (IVD) clinical chemistry analyzer. Its development would involve internal validation and optimization processes by the manufacturer, which might loosely be considered "training," but it's not described as an AI model training set with a specific size or provenance.

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

    As this is a traditional IVD device, the concept of a "training set" for an AI model's ground truth is not applicable in the way it would be for AI-powered diagnostic software. The "ground truth" for the development and internal validation of such a device is established through:

    • Chemical Principles and Reactions: The underlying scientific principles of colorimetry and specific reagent reactions form the fundamental 'ground truth' for measurement.
    • Calibration Standards: The device is calibrated using standards whose concentrations are traceable to recognized reference methods and materials, ensuring accurate quantitative measurements.
    • Quality Control Materials: Known quality control materials are used to ensure the device performs within expected ranges over time.

    These elements collectively serve as the basis for ensuring the device's accuracy and reliability during its design, development, and manufacturing phases.

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    K Number
    K171080
    Device Name
    ALP IFCC Gen.2
    Date Cleared
    2017-05-10

    (29 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    ROAD INDIANAPOLIS IN 46250

    Re: K171080

    Trade/Device Name: ALP IFCC Gen.2 Regulation Number: 21 CFR 862.1050

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

    ALP IFCC Gen.2 is an in vitro test intended for the quantitative determination of the catalytic activity of alkaline phosphatase in human serum and plasma on COBAS INTEGRA systems. Measurements of alkaline phosphatase or its isoenzymes are used in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases.

    Device Description

    The Roche ALP IFCC Gen.2 assay provides quantitative measurement of the catalytic activity of alkaline phosphatase in human serum and plasma in accordance with a standardized method.. The reagents are packaged in a cassette with two bottles labeled with their instrument positioning, R1 (position B) and SR (position C).

    In the presence of magnesium and zinc ions, p-nitrophenyl phosphate is cleaved by phosphatases into phosphate and p-nitrophenol. The p-nitrophenol released is directly proportional to the catalytic ALP activity. It is determined by measuring the increase in absorbance.

    AI/ML Overview

    Here's an analysis of the provided text regarding the acceptance criteria and study information:

    This document is a 510(k) summary for a diagnostic assay, not an AI/ML device. Therefore, many of the typical questions for AI/ML studies (like MRMC studies, reader performance, training set details, etc.) are not applicable here. The acceptance criteria and performance are for an in vitro diagnostic (IVD) reagent and its analytical performance.


    1. Table of Acceptance Criteria and Reported Device Performance

    The document describes modifications to an existing device (ALP IFCC Gen.2). The acceptance criteria are implicit in the "Pass/Fail criteria" for the verification and validation tests performed. The "reported device performance" refers to the characteristics of the modified device and the confirmation that it met these criteria.

    Performance CharacteristicAcceptance Criterion (Implicit)Reported Device Performance (Modified ALP IFCC Gen.2)
    Measuring Range3.0 - 1200 U/L (consistent with predicate/intended use)3.0 - 1200 U/L
    Lower Detection Limit (LDL)3.0 U/L (consistent with predicate/intended use)3.0 U/L
    Precision"See predicate method sheet" (implies performance is comparable)"Same" as predicate (meaning performance met the established precision specifications for the predicate)
    Method Comparison"See predicate method sheet" (implies performance is comparable)"Same" as predicate (meaning the method comparison with established methods yielded comparable results to the predicate, likely within established statistical agreement limits)
    Interference: HemolysisNo significant interference up to 0.16 mmol/L (2.5 g/L) hemoglobinNo significant interference up to hemoglobin level of 0.16 mmol/L (2.5 g/L).
    Interference: IcterusNo significant interference up to specified I index levelsNo significant interference up to an I index of 42 for conjugated bilirubin and 60 for unconjugated bilirubin. (This is an improvement/addition to the predicate which simply stated "No significant interference.")
    Interference: LipemiaNo significant interference up to specified L index levelsNo significant interference up to an L index of 2000. (This is an improvement/addition to the predicate which simply stated "No significant interference.")
    Traceability/StandardizationStandardized against the IFCC (2011) reference procedureStandardized against the IFCC (2011) procedure. (This is the primary change and was successfully implemented.)
    Recovery in ControlsMet pre-determined Pass/Fail criteria for accuracyPassed all tests based on pre-determined Pass/Fail criteria (specific values not provided, but implies recovery was within acceptable limits for various control levels across the measuring range).
    LinearityMet pre-determined Pass/Fail criteria for linearity across rangePassed all tests based on pre-determined Pass/Fail criteria (specific values not provided, but implies the assay demonstrated linear response across its measuring range within acceptable deviations).

    Summary of the Study:

    The document describes a Special 510(k) Premarket Notification for modifications to an existing in vitro diagnostic device, ALP IFCC Gen.2. The core purpose was to change the traceability standard of the assay and add specific interference claims. The "study" refers to the verification, validation, and testing activities conducted to confirm that these modifications did not adversely affect the device's performance and that the new claims were supported.

    Breakdown of Information Request:

    1. Table of acceptance criteria and reported device performance: See table above.

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

      • Sample Size: Not explicitly stated. The document mentions "verification, validation and testing activities" including "recovery in controls, linearity, method comparison, within run precision and interference characteristics." For these types of analytical studies, samples typically include:
        • Controls: Multiple replicates, often 2-3 levels, run over several days/runs for precision and recovery.
        • Linearity samples: A series of diluted or spiked samples across the measuring range.
        • Method Comparison samples: A set of patient samples (often 40-100+) covering the assay range, compared against a reference method or the predicate device.
        • Interference samples: Patient samples or spiked samples tested with various concentrations of interferents (hemoglobin, bilirubin, lipids).
      • Data Provenance: Not explicitly stated, but standard practice for Roche Diagnostics (a global company with manufacturing in Germany and operations in the US) would be internal lab testing, likely at their R&D facilities in Germany or the US. It would be prospective testing of the modified device.
    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 question is not applicable in the context of an IVD reagent analytical performance study. "Ground truth" for an IVD assay's performance would be established by:
        • Highly accurate reference measurement procedures (e.g., the IFCC (2011) reference method cited for traceability).
        • Certified reference materials.
        • Comparison against a legally marketed predicate device or a clinical laboratory's established, validated method.
      • No "experts" in the sense of clinical reviewers are typically used to establish ground truth for analytical performance, but rather highly skilled laboratory scientists and metrologists ensure the accuracy of the reference methods and measurements.
    4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:

      • This question is not applicable. Adjudication methods like "2+1" or "3+1" are characteristic of clinical studies involving human interpretation (e.g., image reading), where disagreements among reviewers need resolution. This document describes analytical performance testing of a reagent where results are quantitative and objective.
    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 is not applicable. An MRMC study assesses the performance of human readers, often with and without AI assistance, on a set of cases. This document is about the analytical performance of an in vitro diagnostic reagent, not an AI/ML device or human reader performance.
    6. If a standalone (i.e., algorithm only without human-in-the-loop performance) was done:

      • This is not applicable. The device is an in vitro diagnostic reagent executed on an automated instrument (COBAS INTEGRA systems). Its performance is inherently "standalone" in functionality (it performs the assay automatically), but it's not an algorithm in the AI/ML sense that would have an "algorithm only" performance study. Its performance is the instrument's performance running the reagent.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • For this type of analytical IVD study, the "ground truth" for method comparison and traceability would be:
        • Reference Measurement Procedures: Specifically, the modified IFCC (2011) reference method for ALP activity.
        • Certified Reference Materials/Calibrators: These provide established, highly accurate values.
        • Comparison to Predicate Device: The performance of the modified device was compared to the legally marketed predicate, which itself would have been validated against established clinical laboratory methods or reference methods.
    8. The sample size for the training set:

      • This is not applicable. This is an IVD reagent, not an AI/ML algorithm that requires a "training set." The reagent's formulation and associated analytical procedures are developed through biochemical and analytical chemistry principles, not machine learning training.
    9. How the ground truth for the training set was established:

      • This is not applicable for the same reason as point 8.
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    K Number
    K162275
    Date Cleared
    2017-04-21

    (252 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    K162275

    Trade/Device Name: Randox RX Daytona Plus Alkaline Phosphatase (ALP) Regulation Number: 21 CFR 862.1050
    CJE | Alkaline
    Phosphatase or
    isoenzymes test
    system. | II | 21 CFR 862.1050

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

    The Randox RX Daytona Plus Alkaline Phosphatase (ALP) test system is intended for the quantitative in vitro determination of Alkaline Phosphatase (ALP) activity in serum and lithium heparinized plasma. Measurements of alkaline phosphatase are used in the diagnosis, treatment and investigation of hepatobiliary disease and in bone disease.

    Device Description

    The Randox RX Daytona Plus Alkaline Phosphatase (ALP) assay consists of ready to use reagent solutions.

    AI/ML Overview

    Here's a breakdown of the acceptance criteria and study information for the Randox RX Daytona Plus Alkaline Phosphatase (ALP) device, based on the provided text:

    Acceptance Criteria and Device Performance

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    Linearity/Reportable RangeLoQ / L1 pool: ≤ 20% deviation to targetMet (linear regression r = 1.000, claimed range 8 – 918 U/L)
    L2 to L11: 0.95Met (r = 1.000)
    Analytical SpecificityControl pool within 10% of decision level targetMet (Interferents did not demonstrate significant interference up to tested concentrations)
    Control and test pools recover within 10% of each otherMet (Interferents did not demonstrate significant interference up to tested concentrations)

    Study Details

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

    • Precision/Reproducibility: Not explicitly stated for specific test sets, but 80 determinations per sample (QC or serum) were performed for each of the two reagent lots. Human serum samples (altered and unaltered, some spiked or diluted) were used. Data provenance is not explicitly stated beyond "human serum samples."
    • Linearity/Reportable Range: 11 levels of samples were prepared. Each level was run in replicates of five. Provenance of these samples is not specified.
    • Detection Limit: Not explicitly stated for a separate "test set" size, but the LoD was based on 240 determinations using 4 low-level samples. Provenance not specified.
    • Analytical Specificity: Not explicitly stated for a separate "test set" size for each interferent, but the study implies testing at ALP concentrations of 80 U/I and 240 U/I. Provenance not specified.
    • Method Comparison with Predicate Device: 106 serum patient samples. Data provenance is not explicitly stated but implies patient samples from the UK, given the manufacturer's location. The study was retrospective, comparing the new device results against an existing predicate device using collected samples.
    • Matrix Comparison: 46 matched patient sample pairs (serum and lithium heparin plasma). Provenance not explicitly stated.
    • Expected Values/Reference Range Verification: Human serum from 30 normal donors. Provenance not explicitly stated.

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

    • Not Applicable. This document describes the analytical performance of an in vitro diagnostic device (a laboratory test for Alkaline Phosphatase activity). The "ground truth" for such devices is typically established through reference methods, certified standards, or consensus values from established quality control materials, rather than expert interpretation of images or patient data. The document does not mention the use of experts to establish ground truth for the analytical performance studies.
      • For the precision study, control materials and altered/unaltered human serum samples were used.
      • For linearity, pooled samples with known concentrations were used.
      • For method comparison, the predicate device (Siemens Alkaline Phosphatase (ALPAMP) Assay, K991576) served as the reference for comparison.

    4. Adjudication Method for the Test Set:

    • Not Applicable. As noted above, this study evaluates the analytical performance of an in vitro diagnostic device, not interpretive performance requiring adjudication.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, What was the Effect Size of How Much Human Readers Improve with AI vs Without AI Assistance:

    • Not Applicable. This is an evaluation of an in vitro diagnostic device for quantitative chemical analysis, not an AI-powered diagnostic imaging system requiring human reader studies.

    6. If a Standalone (i.e., Algorithm Only Without Human-in-the-loop Performance) Was Done:

    • Yes, a standalone study was done. The entire submission details the performance of the Randox RX Daytona Plus Alkaline Phosphatase (ALP) system itself, comprising reagents and the RX Daytona Plus analyzer. This is the inherent nature of an in vitro diagnostic test; its performance is measured independently of human interpretation of the result, though human operators perform the test and interpret the clinical significance of the result. The performance metrics (precision, linearity, detection limits, accuracy/method comparison) are all measures of the device's standalone analytical capabilities.

    7. The Type of Ground Truth Used:

    • Reference Methods/Comparative Devices and Spiked/Diluted Samples:
      • Precision and Linearity: Values derived from known concentrations in quality control materials, spiked samples, or diluted samples where the true value is calculable.
      • Method Comparison: The predicate device (Siemens Alkaline Phosphatase (ALPAMP) Assay, K991576) served as the comparative "ground truth" to establish substantial equivalence.
      • Detection Limits: Determined statistically using defined protocols (CLSI guideline EP17-A2).
      • Analytical Specificity: Known concentrations of interferents added to known ALP concentrations.

    8. The Sample Size for the Training Set:

    • Not Applicable. The document describes a traditional analytical performance study for an in vitro diagnostic assay, not an AI/machine learning model that requires a training set. The device is a chemical reagent and analyzer system.

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

    • Not Applicable. See point 8.
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    510k Summary Text (Full-text Search) :

    . § 862.1050)
    Product Code CJE |
    | | Trade Name:
    Alkaline Phosphatase Reagent ACE Amylase Reagent ACE ALT Reagent ACE AST Reagent Regulation Number: 21 CFR 862.1050

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

    The ACE Alkaline Phosphatase Reagent is intended for the quantitative determination of alkaline phosphatase activity in serum and lithium heparin plasma using the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems. Measurements of alkaline phosphatase are used in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases. This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only.

    The ACE Amylase Reagent is intended for the quantitative determination of α-amylase activity in serum and lithium heparin plasma using the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems. Amylase measurements are used primarily for the diagnosis and treatment of pancreatitis (inflammation of the pancreas). This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only.

    The ACE ALT Reagent is intended for the quantitative determination of alanine aminotransferase activity in serum and lithium heparin plasma using the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems. Alanine aminotransferase measurements are used in the diagnosis and treatment of certain liver diseases (e.g., viral hepatitis and cirrhosis) and heart diseases. This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only.

    The ACE AST Reagent is intended for the quantitative determination of aspartate aminotransferase activity in serum and lithium heparin plasma using the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems. Measurements of aspartate aminotransferase are used in the diagnosis and treatment of certain types of liver and heart disease. This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only.

    Device Description

    In the ACE Alkaline Phosphatase Reagent assay, alkaline phosphatase catalyzes the hydrolysis of colorless p-nitrophenyl phosphate to p-nitrophenol and inorganic phosphate. In an alkaline solution (pH 10.5), p-nitrophenol is in the phenoxide form and has a strong absorbance at 408 nm. The rate of increase in absorbance, monitored bichromatically at 408 nm/486 nm, is directly proportional to the alkaline phosphatase activity in the sample.

    In the ACE Amylase Reagent assay, α-amylase hydrolyzes the 2-chloro-p-nitrophenyl-α-D-maltotrioside substrate to release 2-chloro-p-nitrophenol and form 2-chloro-p-nitrophenyl-α-D-maltoside, maltotriose and glucose. The rate of increase in absorbance, monitored bichromatically at 408 nm/ 647 nm, is directly proportional to the α-amylase activity in the sample.

    In the ACE ALT Reagent assay, alanine aminotransferase converts the L-alanine and α-ketoglutarate substrates in the reagent to L-glutamate and pyruvate, respectively. Lactate dehydrogenase (LDH) catalyzes the oxidation of the reduced cofactor to the cofactor. The rate of conversion of the reduced cofactor to the cofactor can be determined by monitoring the decrease in absorbance bichromatically at 340 nm/647 nm. This rate of conversion from the reduced cofactor to the cofactor is a function of the activity of ALT in the sample.

    In the ACE AST Reagent assay, aspartate aminotransferase converts the L-aspartate and α-ketoglutarate in the reagent to oxaloacetate and L-glutamate, respectively. The oxaloacetate undergoes reduction, with concurrent oxidation of NADH to NAD+ in the malate dehydrogenase-catalyzed indicator reaction. NADH absorbs strongly at 340 nm, whereas NAD+ does not. Therefore, the rate of conversion of NADH to NAD+ can be determined by monitoring the decrease in absorbance bichromatically at 340 nm/647 nm. This rate of conversion from NADH to NAD+ is a function of the activity of AST in the sample. Lactate dehydrogenase is added to prevent interference from endogenous pyruvate, which is normally present in blood.

    AI/ML Overview

    Here's an analysis of the provided information regarding the acceptance criteria and study for the ACE reagents:

    Summary of Acceptance Criteria and Reported Device Performance

    The acceptance criteria for these in vitro diagnostic reagents (ALP, Amylase, ALT, AST) appear to be primarily demonstrated through comparisons with predicate devices and comprehensive performance characteristics like precision, linearity, and interference. The documentation focuses on demonstrating that the new devices perform equivalently to the existing predicate devices and meet established performance expectations for clinical chemistry assays.

    1. Table of Acceptance Criteria and Reported Device Performance

    Since this document describes multiple reagents and doesn't explicitly state pass/fail acceptance values for each performance metric, I will summarize the demonstrated performance and what can be inferred as the "acceptance criteria" (i.e., that the results are comparable to established predicate device performance and within acceptable clinical ranges).

    Performance MetricAcceptance Criteria (Inferred)Reported Device Performance
    PrecisionLow total CV% (generally 0.98 or 0.99) with narrow confidence intervals, indicating interchangeability of sample types.ALP: Slopes 0.983-1.017, Intercepts -6.5 to -8.3, Correlations 0.9952-0.9982.
    Amylase: Slopes 0.977-0.994, Intercepts -1.76 to 1.7, Correlations 0.9994-0.9996.
    ALT: Slopes 0.985-1.003, Intercepts -3.35 to -3.6, Correlations 0.9986-0.9994.
    AST: Slopes 0.998-1.006, Intercepts 0.3 to 1.5, Correlations 0.9993-0.9998.
    All indicate a strong agreement between serum and plasma samples.
    Method Comparison (vs. In-House ACE and POL sites)Slopes close to 1.0, intercepts close to 0, and correlation coefficients (R) close to 1.0 (e.g., >0.98 or 0.99) with narrow confidence intervals, indicating consistency across different instruments and sites.In-House ACE vs. POL ACE:
    ALP: Slopes 0.977-0.989, Intercepts -9.5 to -2.8, Correlations 0.9987-0.9997.
    AMY: Slopes 0.970-0.974, Intercepts 1.5-3.9, Correlations 0.9995-0.9998.
    ALT: Slopes 0.982-1.021, Intercepts -4.7 to -2.3, Correlations 0.9978-0.9993.
    AST: Slopes 0.992-1.019, Intercepts -0.6 to 2.4, Correlations 0.9989-0.9994.
    In-House ACE vs. POL Alera:
    ALP: Slopes 0.997-1.029, Intercepts -6.6 to -4.1, Correlations 0.9986-0.9992.
    AMY: Slopes 0.960-1.010, Intercepts 3.0-5.8, Correlations 0.9991-0.9995.
    ALT: Slopes 0.970-1.019, Intercepts -3.5 to 2.4, Correlations 0.9977-0.9986.
    AST: Slopes 1.004-1.040, Intercepts 0.5-1.8, Correlations 0.9992-0.9995.
    All indicate strong agreement between different sites and initial in-house testing, demonstrating substantial equivalence.
    Detection Limits (LoB, LoD, LoQ)Values below the clinical reference ranges and suitable for detecting low levels of analytes.ACE Alera (Approximate):
    ALP: LoB 2.8, LoD 0.9, LoQ 4.8
    Amylase: LoB 0.2, LoD 3.3, LoQ 5.6
    ALT: LoB 1.6, LoD 4.8, LoQ 4.1
    AST: LoB 2.2, LoD 3.1, LoQ 3.3
    LinearityCorrelation coefficient (R^2) close to 1.0 (e.g., >0.99) over the specified measuring range, with slopes near 1 and intercepts near 0 for the regression equation.ACE Alera:
    ALP: Linear to 1400 U/L, R^2 = 0.9993
    Amylase: Linear to 1900 U/L, R^2 = 0.9974
    ALT: Linear to 480 U/L, R^2 = 0.9992
    AST: Linear to 450 U/L, R^2 = 0.9992
    InterferencesNo significant interference at stated concentrations of common interferents (Icterus, Hemolysis, Lipemia, Ascorbic Acid).The document lists the tested concentrations of interferents (e.g., Icterus up to 70.6 mg/dL for ALP, Hemolysis up to 500 mg/dL for ALT, Lipemia up to 1000 mg/dL for ALP/Amylase, Ascorbic Acid 6 mg/dL for all). The implication, by inclusion in the performance data without negative remarks, is that these levels did not cause unacceptable interference.

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

    • Precision (Serum vs. Plasma):
      • In-House: Each dataset (low, mid, high for serum and plasma) involved "n=20" (number of replicates, likely over multiple days, contributing to within-run and total precision calculations).
      • POL Precision (ACE & Alera): For each analyte (ALP, AMY, ALT, AST) and each POL site (POL 1, POL 2, POL 3), there were 2 to 3 sample levels (Low, Mid, High), with a reported "n" for each (e.g., n=24 for ALT/AST in initial in-house, but the POL tables don't explicitly state the 'n' for each specific mean/SD/CV, implying a standard number of replicates as per precision studies).
    • Matrix Comparison (Serum vs. Plasma):
      • ALP: ACE (108 pairs), ACE Alera (108 pairs), ACE Axcel (62 pairs).
      • Amylase: ACE (104 pairs), ACE Alera (101 pairs), ACE Axcel (52 pairs).
      • ALT: ACE (54 pairs), ACE Alera (52 pairs), ACE Axcel (56 pairs).
      • AST: The number of pairs for AST in the serum vs. plasma matrix comparison is not explicitly stated in the provided snippet. However, based on the pattern of other analytes, it would likely be similar (e.g., 50+ pairs).
    • Method Comparison (In-House vs. POL Sites):
      • ALP: 49-50 samples per site.
      • Amylase: 51 samples per site.
      • ALT: 44-49 samples per site.
      • AST: 50 samples per site.
    • Linearity: Not explicitly stated as an "n" for samples, but rather as "low level tested," "upper level tested," and "linear to" values, which typically involve preparing a dilution series from a high concentration sample.
    • Data Provenance: The studies are labeled "In-House" and "POL" (Point of Care). This suggests:
      • Country of Origin: Likely the USA, given the FDA 510(k) submission.
      • Retrospective or Prospective: These types of performance studies for IVDs are typically prospective, with samples analyzed specifically for the study. The method comparison data often uses a mix of native patient samples and spiked samples to cover the measuring range.

    3. Number of Experts Used to Establish Ground Truth and Their Qualifications

    This document describes the performance of IVD reagents on clinical chemistry systems. The "ground truth" here is not subjective, human interpretation (like in imaging AI), but rather the quantitative measurement of analytes.

    • Number of Experts: Not applicable in the context of IVD reagent performance. The "ground truth" is established by the analytical method itself, or by comparison to a recognized reference method or a legally marketed predicate device.
    • Qualifications of Experts: Not applicable. The "experts" would be qualified laboratory professionals operating the instruments and performing the biochemical assays according to established protocols.

    4. Adjudication Method for the Test Set

    Not applicable. As described above, the "truth" for these quantitative measurements is derived directly from the biochemical reactions and instrument readings, not subjective human judgment requiring adjudication. The predicate device's established performance serves as a comparative benchmark.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done

    No. This is a submission for in vitro diagnostic reagents, not an AI-assisted diagnostic device that involves human readers interpreting images or complex data. Therefore, an MRMC study is not relevant.

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

    Yes, in essence, the performance data presented is "standalone" in the context of the device's function. The ACE reagents, when used on the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems, operate as an automated system to quantify the target analytes. The performance metrics (precision, linearity, method comparison, interferences) reflect the intrinsic analytical performance of the regent-analyzer combination without human intervention influencing the measurement itself. Human operators are involved in sample loading, quality control, and result review, but not in directly influencing the quantitative output in a way that would require a human-in-the-loop comparison for algorithm performance.

    7. The Type of Ground Truth Used

    The "ground truth" in this context is established by:

    • Comparison to Predicate Devices: The primary method is demonstrating substantial equivalence to previously cleared devices (K113253, K931786, K930104, K113436, K113382). This means the new reagents provide results that are analytically comparable to those already accepted by the FDA.
    • Expected Analytical Performance: Meeting industry-standard requirements for precision (low CV%), accuracy (linearity, inter-instrument/site agreement via regression analysis), and specificity (minimal interference).
    • Expected Values/Ranges: The devices are expected to produce results that align with established "expected values" for healthy individuals.

    8. The Sample Size for the Training Set

    Not applicable. These are chemical reagents for quantitative diagnostic tests, not machine learning algorithms that require a "training set" in the conventional sense. The "training" for such systems involves analytical validation experiments to define reagent stability, reaction kinetics, and instrument parameters.

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

    Not applicable for the same reason as point 8. The "ground truth" for developing and validating these reagents is based on fundamental principles of analytical chemistry, biochemical reactions, and extensive internal testing to ensure the reagents perform as intended within the specified analytical parameters.

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    K Number
    K130141
    Date Cleared
    2013-03-22

    (59 days)

    Product Code
    Regulation Number
    862.1050
    Reference & Predicate Devices
    Why did this record match?
    510k Summary Text (Full-text Search) :

    Alkaline Phosphatase (ALP)

    Common Name: Routine chemistry analyzer for ALP

    Classifications: 21 CFR § 862.1050
    |
    | Device Class, Regulation Code | Class II, 21 CFR 862.1050
    Trade/Device Name: S TEST Reagent Cartridge Alkaline Phosphatase (ALP) Regulation Number: 21 CFR §862.1050

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

    The S TEST Reagent Cartridge Alkaline Phosphatase (ALP) is intended for the quantitative measurement of alkaline phosphatase activity in serum, lithium heparinized plasma, or sodium citrate plasma using the HITACHI Clinical Analyzer. The S TEST Reagent Cartridge Alkaline Phosphatase (ALP) is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only.

    Measurements of alkaline phosphatase are used in the diagnosis and treatment of liver, bone, parathyroid, and intestinal diseases.

    Device Description

    The Hitachi Clinical Analyzer is an automatic, bench-top, wet chemistry system intended for use in clinical laboratories or physician office laboratories. The instrument consists of a desktop analyzer unit, an operations screen that prompts the user for operation input and displays data, a printer, and a unit cover. The analyzer unit includes a single probe, an incubation rotor, carousels for sample cups and reagent cartridges, and a multi-wavelength photometer. The single-use reagent cartridges may be placed in any configuration on the carousel, allowing the user to develop any test panel where the reagent cartridges are available.

    The S TEST reagent cartridges are made of plastic and include two small reservoirs capable of holding two separate reagents (R1 and R2), separated by a reaction cell/photometric cuvette. The cartridges also include a dot code label that contains all chemistry parameters, calibration factors, and other production-related information, e.g., expiration dating. The dimensions of the reagent cartridges are: 13.5 mm (W) × 28 mm (D) × 20.2 mm (H).

    System operation: After the sample cup is placed into the carousel, the analyzer pipettes the sample, pipettes the reagent, and mixes (stirs) the sample and reagent together. After the sample and reagent react in the incubator bath, the analyzer measures the absorbance of the sample, and based on the absorbance of the reactions, it calculates the concentration of analyte in the sample. The test system can measure analytes in serum or plasma and results are available in approximately 15 minutes per test. This submission is for Reagent Cartridge ALP.

    Chemistry reactions: Alkaline phosphatase (ALP) in the sample reacts with its substrate, pnitrophenyl phosphate (p-NPP), in ethylaminoethanol (EAE) buffer, to release p-nitrophenol (yellow). The ALP activity is determined by measuring the rate of p-nitrophenol production.

    AI/ML Overview

    The provided text describes the performance characteristics and acceptance criteria for the Hitachi S TEST Reagent Cartridge Alkaline Phosphatase (ALP).

    Here's a breakdown of the requested information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document doesn't explicitly state "acceptance criteria" as a separate column for all metrics. However, the performance data provided implies that the reported results met the internal development criteria for each study. Where a specific acceptance range or threshold is mentioned (e.g., for interference testing), it is included.

    Performance CharacteristicAcceptance Criteria (Implied/Stated)Reported Device Performance
    Analytical Sensitivity (Limit of Detection)Not explicitly stated, but lower is better.1.8 U/L
    Linearity RangePerformance within the specified range (predicate: 5 to 1,200 U/L)5 U/L to 1,000 U/L
    Detection LimitMatch predicate (5 U/L)5 U/L
    Precision (%CVs)For in-house, %CVs range from 4.4% to 5.8% (predicate). For external, performance is reported.In-house: 3.1% to 5.3% (Low), 3.8% to 5.8% (Middle), 2.5% to 4.4% (High). External site precision ranged from 3.0% to 9.2%.
    Interference Testing (Recovery)Recoveries between 90% and 110% of the neat value.Hemoglobin: no interference up to 500 mg/dL. Unconjugated bilirubin: no interference up to 50 mg/dL. Lipemia: no interference up to 2,000 mg/dL. Ascorbic acid: no interference up to 50 mg/dL.
    Method Comparison (Correlation coefficient 'r')High correlation, likely >0.90 for good agreement.In-house: 0.996. External sites: 0.99 for all three sites.
    Method Comparison (Slope, in-house)Close to 1.0; 95% CI covering 1.0 or very close.0.926 (95% CI: 0.909 to 0.943)
    Method Comparison (y-intercept, in-house)Close to 0; 95% CI covering 0 or very close.4.8 (95% CI: -0.2 to 9.8)
    Matrices Comparison (Correlation coefficient 'r')High correlation, likely >0.90 for good agreement.Sodium Citrate Plasma: 0.999. Heparinized Plasma: 0.999.
    Matrices Comparison (Slope, plasma types)Close to 1.0; 95% CI covering 1.0 or very close.Sodium Citrate Plasma: 1.03 (1.01 to 1.05). Heparinized Plasma: 1.01 (1.00 to 1.02).
    Matrices Comparison (y-intercept, plasma types)Close to 0; 95% CI covering 0 or very close.Sodium Citrate Plasma: -11.2 (-15.5 to -7.0). Heparinized Plasma: -5.4 (-8.3 to -2.6).

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

    • Analytical Sensitivity (Limits of Detection): Not specified, but likely involved multiple replicates for statistical analysis as per CLSI EP17-A.
    • Linearity: Not specified, but involved samples spanning 5 U/L to 1,000 U/L as per CLSI EP-6A.
    • 20-day In-house Precision: Three levels of samples, each tested in two runs, twice a day, for 20 days. This means 80 data points per level (2 runs/day * 2 times/run * 20 days). Total around 240 data points across 3 levels.
    • Interference Testing: Two serum pools tested.
    • Method Comparison (in-house): 97 clinical specimens. Data provenance: Not explicitly stated, but implied to be in-house or from a domestic source. Retrospective.
    • Matrices Comparisons: 38 matched serum/plasma samples. Data provenance: Not explicitly stated, but implied to be in-house or from a domestic source. Retrospective.
    • External Site Precision: Each site tested three blinded serum samples, six times per day for five days. This means 30 replicates per sample per site. With 3 sites and 3 samples, approximately 270 data points (30 * 3 * 3).
    • External Site Method Comparison: Approximately 70 serum specimens per site, for a total of around 210 specimens (3 sites * ~70 samples/site). Data provenance: Not explicitly stated, but typically from within the country where the study is conducted (likely USA, given the FDA submission). Retrospective.

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

    This information is not applicable as the device is a quantitative chemical analyzer. The "ground truth" for the test sets (samples used in the studies) is established by the reference methods or known concentrations, not by expert interpretation.

    4. Adjudication Method for the Test Set:

    This information is not applicable as the device is a quantitative chemical analyzer. Ground truth is determined objectively through reference methods or known concentrations, not through expert 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. The device is a diagnostic instrument (chemistry analyzer) and not an AI-based imaging or diagnostic aid that involves human readers.

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

    The studies described (precision, linearity, method comparison, interference, matrices comparison) represent the standalone performance of the Hitachi Clinical Analyzer with the S TEST Reagent Cartridge ALP. This is the direct measurement by the instrument, without a human interpretation step.

    7. The Type of Ground Truth Used:

    The ground truth for the performance studies was established using:

    • Reference Methods: For method comparison studies, the Hitachi system was compared against a "standard laboratory system" (predicate device or another established method).
    • Known Concentrations/Values: For linearity, precision, and interference studies, samples with known or carefully characterized concentrations of ALP and potential interferents were used.
    • CLSI Guidelines: Studies followed established Clinical and Laboratory Standards Institute (CLSI) guidelines (e.g., EP17-A for detection limit, EP-6A for linearity, EP5-A2 for precision, EP7-A2 for interference).

    8. The Sample Size for the Training Set:

    This information is not applicable. This device is a traditional chemical analyzer, not an AI/machine learning system that requires a "training set" in the computational sense. The device's parameters are set during its manufacturing and calibration process, not through a data-driven training phase.

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

    This information is not applicable for the reason stated in point 8.

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