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510(k) Data Aggregation
(266 days)
Indianapolis, Indiana 46250
Re: K233060
Trade/Device Name: Elecys Folate III Regulation Number: 21 CFR 862.1295
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| Product Codes,
Regulation Numbers | CGN, 21 CFR 862.1295
Binding assay for the in vitro quantitative determination of folate in erythrocytes (red blood cells, RBC). Folate measurements are used in the diagnosis and treatment of anemia. The electrochemiluminescence immunoassay "ECLIA" is intended for use on cobas e immunoassay analyzers.
Elecsys Folate III is a binding assay that makes use of a competitive test principle using a ruthenium labeled folate-binding assay.
Elecsys Folate III is a binding assay for the in vitro quantitative determination of folate in erythrocytes (red blood cells, RBC). Folate measurements are used in the diagnosis and treatment of anemia. The electrochemiluminescence immunoassay "ECLIA" is intended for use on cobas e immunoassay analyzers.
Whole blood treated with anticoagulants (heparin or EDTA) is mixed with ascorbic acid solution and incubated for approximately 90 minutes at 20-25 °C. Lysis of the erythrocytes takes place, with liberation and stabilization of the intracellular folate. The resulting hemolysate sample is then used for subsequent measurement.
Results are determined via a calibration curve, which is instrument-specifically generated by 2point calibration, and a master curve provided via the cobas link.
Here's a summary of the acceptance criteria and study details for the Elecsys Folate III device, based on the provided FDA 510(k) summary:
1. Table of Acceptance Criteria and Reported Device Performance
Performance Metric | Acceptance Criteria (Implied / Stated) | Reported Device Performance |
---|---|---|
Precision | "All predefined acceptance criteria was met for the precision experiments." (Specific numerical criteria not explicitly stated in this document but implied to be within acceptable limits as per CLSI guideline EP05-A3.) | Repeatability (within-run precision) & Intermediate Precision (within-laboratory precision) (cobas e 801 analyzer) |
Sample | Mean (ng/mL) | Repeatability SD (ng/mL) |
--------------- | -------------- | -------------------------- |
Hemolysate 1 | 152 | 5.73 |
Hemolysate 2 | 206 | 6.14 |
Hemolysate 3 | 252 | 6.70 |
Hemolysate 4 | 363 | 8.01 |
Hemolysate 5 | 605 | 10.7 |
Lot-to-lot Reproducibility: "All predefined acceptance criteria was met for the lot-to-lot reproducibility experiment." (Specific data not provided, but confirmed to meet criteria.) | ||
Analytical Sensitivity | Based on CLSI EP17-A2 guidelines for Limit of Blank (LoB), Limit of Detection (LoD), and Limit of Quantitation (LoQ). | LoB: 45 ng/mL |
LoD: 70 ng/mL | ||
LoQ: 120 ng/mL | ||
Linearity | Measurements across the claimed measuring range (120 - 620 ng/mL) must be linear as assessed per CLSI EP06-Ed2. | Linearity confirmed to support the measuring range of 120 - 620 ng/mL. |
Dilution | Data must support instruction for use for samples diluted 1:2. | Data supports instruction for use. |
Endogenous Interferences | "All predefined acceptance criteria were met" for various endogenous substances including Bilirubin, Intralipid, Biotin, Rheumatoid factors, IgG, IgA, IgM, at specified concentrations, confirming no significant interference. (Specific thresholds for non-interference not provided in text, but implied to be within acceptable limits). | No significant interference for: |
Bilirubin: ≤ 29 mg/dL | ||
Intralipid: ≤ 1500 mg/dL | ||
Biotin: ≤ 1200 ng/mL | ||
Rheumatoid factors: ≤ 1000 IU/mL | ||
IgG: ≤ 1.6 g/dL | ||
IgA: ≤ 0.4 g/dL | ||
IgM: ≤ 1 g/dL | ||
Analytical Specificity/Cross-Reactivity | Expected low cross-reactivity with specified compounds. (Specific thresholds for cross-reactivity not provided in text, but implied to be within acceptable limits). | Low cross-reactivity: |
Amethopterin: (750 ng/mL) 1.7% | ||
Aminopterin: (750 ng/mL) 2.0% | ||
Folinic acid: (750 ng/mL) 2.6% | ||
Exogenous Interferences | No interference from 17 commonly used pharmaceuticals and erythropoietin. (Specific thresholds for non-interference not provided in text, but implied to be within acceptable limits). | No interference found from 17 commonly and 1 specially used pharmaceutical (erythropoietin) compounds. |
Sample Matrix Comparison | Results within specification, supporting the use of hemolysate prepared from whole blood treated with Na-heparin or K3-EDTA. | Results were within specification and support the use of hemolysate prepared from whole blood and treated with Na-heparin or K3-EDTA. |
Method Comparison to Predicate | High correlation and agreement with the predicate device (Elecsys Folate RBC). | Number of samples: 119 (concentrations 132-618 ng/mL) |
Passing/Bablok: y = 1.04x - 14.6, τ = 0.913 | ||
Linear regression: y = 1.03x - 11.0, r = 0.991 | ||
Reagent Stability (On-board) | Reagent kits can be stored on-board for up to 16 weeks. | Tested on one cobas e 801 analyzer; Elecsys Folate III reagent kits can be stored on-board for up to 16 weeks. (Note: The product comparison table states "2 weeks" for predicate; this indicates an improvement for the candidate device.) |
Calibration Stability (Lot) | Calibration for a lot is recommended every 12 weeks; during this period, fresh kits of same lot can be used without re-calibration using the day 0 curve. | Tested on one cobas e 801 analyzer. Calibration of an Elecsys Folate III reagent lot is recommended every 12 weeks. |
Calibration Stability (On-board) | Reagent epacks can be stored on-board for up to 28 days without a new calibration. | Tested on one cobas e 801 analyzer. Elecsys Folate III epacks can be stored on board of the analyzers for up to 28 days without a new calibration. |
2. Sample Sizes and Data Provenance
- Precision (Repeatability & Intermediate Precision): Not explicitly stated, but typically involves multiple replicates over several days/runs with multiple instruments. Specific sample types are "Hemolysate 1" to "Hemolysate 5".
- Lot-to-lot Reproducibility: "three reagent lots" were used.
- Analytical Sensitivity (LoB, LoD, LoQ): Not explicitly stated, but determined according to CLSI EP17-A2, which involves specific numbers of blank and low-concentration samples.
- Linearity and Dilution: "At least seven concentrations using hemolysate samples" for linearity. Dilution study used "high concentration hemolysate samples".
- Endogenous Interferences: Not explicitly stated, but "various endogenous substances" were evaluated.
- Analytical Specificity/Cross-Reactivity: Not explicitly stated.
- Exogenous Interferences: "17 commonly and 1 specially used pharmaceutical" compounds.
- Sample Matrix Comparison: "Whole blood samples were drawn into Na-Heparin and K3-EDTA tubes." (Number not specified).
- Method Comparison to Predicate: 119 samples with concentrations between 132 and 618 ng/mL.
- Reagent Stability (On-board), Lot Calibration Stability, On-board Calibration Stability: Tested on "one cobas e 801 analyzer".
Data Provenance: The document states "NON-CLINICAL PERFORMANCE EVALUATION" and refers to CLSI (Clinical and Laboratory Standards Institute) guidelines, which are standard for in-vitro diagnostic device performance studies. The data is internal to Roche Diagnostics, a company with global operations. The specific country of origin for the studies is not stated, but given the submission is to the U.S. FDA, the studies are expected to meet international and U.S. regulatory standards. These are retrospective studies in the context of device development and validation.
3. Number of Experts and Qualifications for Ground Truth (Test Set)
This device is an in-vitro diagnostic (IVD) assay that produces quantitative measurements of folate. It does not involve human interpretation of images or other subjective data. Therefore, the "ground truth" for its performance is established by reference methods, calibrated standards, and accurate measurement principles, rather than human expert consensus. No human experts were used to establish ground truth in the way one would for an AI imaging device.
4. Adjudication Method (Test Set)
Not applicable, as this is an IVD device producing quantitative results, not an AI imaging device requiring expert adjudication.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
Not applicable. This is an in-vitro diagnostic device, not an AI device assisting human readers with interpreting cases.
6. Standalone (Algorithm Only) Performance
Yes, the studies described are standalone performance evaluations of the Elecsys Folate III assay (the "algorithm" in a broad sense for an IVD) without human intervention in the measurement process. The device performs the quantitative determination of folate using its defined binding assay and electrochemiluminescence immunoassay (ECLIA) method.
7. Type of Ground Truth Used
The ground truth for evaluating the Elecsys Folate III's performance is established through:
- Reference materials/standards: For analytical sensitivity (LoB, LoD, LoQ) and linearity, where known concentrations are used.
- Performance against a predicate method: For method comparison, the results are compared to a previously cleared, established method (Elecsys Folate RBC).
- CLSI guidelines: Adherence to established scientific and statistical methodologies for validating assay performance, implying well-defined benchmarks for accuracy, precision, and interference.
8. Sample Size for the Training Set
Not explicitly stated. For an IVD like the Elecsys Folate III, a traditional "training set" as understood in machine learning is not directly applicable. The "training" for such a system would involve the development and optimization of the reagent formulations, assay parameters, and calibration curve algorithms, using various samples and experiments during the research and development phase. However, a specific training set size with corresponding ground truths is not documented in the same way as an AI algorithm.
9. How the Ground Truth for the Training Set was Established
As above, a formal "training set ground truth" isn't directly applicable in the machine learning sense. The "ground truth" during the development and optimization (analogous to training) would have been established through:
- Known concentrations: Using purified folate standards or spiked samples.
- Reference methods: Comparing early-stage assay performance against established, often more labor-intensive or gold-standard methods for folate determination.
- Clinical correlation: (Though "clinical testing" is marked Not Applicable for this 510(k), early development might involve correlation with clinical status or outcomes).
- Statistical optimization: Adjusting reagent ratios, incubation times, and instrument settings to achieve optimal analytical performance characteristics (sensitivity, specificity, precision, linearity) based on these known values and reference method comparisons.
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(265 days)
Chaska, Minnesota 55318
Re: K223590
Trade/Device Name: Access Folate Assay Regulation Number: 21 CFR 862.1295
: Access Folate Assay Classification Name: Folic acid test system Classification Requlation: 21 CFR 862.1295
The Access Folate assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of folic acid levels in human serum, lithium heparin plasma, and red blood cells using the Access Immunoassay Systems. Folic acid measurements are used in the diagnosis and treatment of megaloblastic anemia.
Folate levels in serum, lithium heparin plasma, and red blood cells are used to assess folate status. The serum folate levels is an indicator of recent folate intake. A low RBC folate value can indicate a prolonged folate deficiency.
The Access Folate assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of folic acid levels in human serum and lithium heparin plasma or red blood cells using the Access Immunoassay Systems.
The provided text describes the Beckman Coulter Access Folate Assay, a chemiluminescent immunoassay for the quantitative determination of folic acid levels. The submission is a 510(k) premarket notification for demonstrating substantial equivalence to a predicate device.
Here's an analysis of the acceptance criteria and supporting studies based on the provided document:
1. Table of Acceptance Criteria and Reported Device Performance
Study Type | Acceptance Criteria | Reported Device Performance |
---|---|---|
Method Comparison | R² ≥ 0.90 and slope 1.00 ± 0.12. Estimated bias at concentration corresponding to reference limits suggestive that values have not changed appreciably. | R² = 0.99, Slope = 1.04 (95% CI: 1.01 - 1.07), Intercept = 0.081 (95% CI: -0.074 - 0.19). The study met the acceptance criteria. The estimated bias at concentration corresponding to reference limits defined on the predicate system suggest that such values have not changed appreciably on the DxI 9000 analyzer. |
Linearity | Linear throughout the analytical measuring interval (2.0 - 24.8 ng/mL). | The study met the acceptance criterion, indicating linearity on the DxI 9000 Immunoassay Analyzer throughout the analytical measuring interval (2.0 - 24.8 ng/mL). |
Serum Imprecision | Not explicitly stated as acceptance criteria, but based on typical standards for imprecision: Expected low %CV for higher concentrations and low SD for lower concentrations. | Within-laboratory (total) % CV: between 2.2% and 4.4% for Folate concentrations > 2.0 ng/mL. Within-laboratory (total) SD: between 0.10 - 0.21 for Folate concentrations ≤ 2.0 ng/mL. Repeatability (within-run) % CV: between 1.6% and 2.7% for Folate concentrations > 2.0 ng/mL. Repeatability (within-run) SD: between 0.08 - 0.09 for Folate concentrations ≤ 2.0 ng/mL. |
RBC Imprecision | Not explicitly stated as acceptance criteria, but based on typical standards for imprecision: Expected low %CV. | Within-laboratory (total) % CV: ranged from 1.9% to 4.9%. |
Limit of Blank (LoB) | Claimed LoB of 0.80 ng/mL (1.81 nmol/L). | The assay is designed to meet the claimed LoB of 0.80 ng/mL. |
Limit of Detection (LoD) | Claimed LoD of 1.0 ng/mL (2.27 nmol/L). | The assay is designed to meet the claimed LoD of 1.0 ng/mL. |
Limit of Quantitation (LoQ) | Claimed LoQ of |
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(230 days)
Stillwater, MN 55082-0285
Re: K192586
Trade/Device Name: Liaison® Folate Regulation Number: 21 CFR 862.1295
Classification Name: Folic acid test system Trade Name: LIAISON® Folate Common Name: Folate Regulation: 21 CFR 862.1295
The DiaSorin LIAISON® Folate assay uses chemiluminescent immunoassay (CLIA) technology for the quantitative determination of Folic acid in human serum. Folic acid measurements are used in the diagnosis and treatment of anemias. Assay results should be used in conjunction with other clinical or laboratory data to assist the clinician in making individual patient management decisions.
The assay must be performed on the LIAISON® XL Analyzer.
The LIAISON® Folate assay is a competitive chemiluminescence immunoassay (CLIA) for quantitative determination of Folic acid in serum. During the first incubation, Folic acid is dissociated from its binding protein. After five (5) minutes, a high pH buffer is added to prevent re-association to the binding protein. After five (5) minutes, Folic acid binds to a Folate Binding Protein on the solid phase, which competes with a Folic acid linked to an isoluminol derivative. After a third incubation, the unbound material is removed with a wash cycle. Subsequently, the starter reagents are added to initiate a flash chemiluminescent reaction. The light signal is measured by a photomultiplier as relative light units (RLU) and is inversely proportional to the concentration of Folic acid present in calibrators, controls, or samples.
Here's an analysis of the acceptance criteria and study that proves the device meets them, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance:
The document doesn't explicitly state "acceptance criteria" for each performance characteristic in a pass/fail format. Instead, it presents study results which implicitly demonstrate the device's acceptable performance. For clarity, I've inferred common acceptance standards for such in vitro diagnostic assays where explicit criteria aren't given and formatted the reported performance against these.
Performance Characteristic | Acceptance Criteria (Inferred for IVDs) | Reported Device Performance |
---|---|---|
Method Comparison | Good agreement with a legally marketed predicate device (e.g., R-value > 0.9, acceptable bias at medical decision levels). | Passing & Bablok regression: LIAISON® Folate = (y = 0.96x - 0.61); R = 0.948. |
Bias at 4.41 ng/mL medical decision level: -0.772 ng/mL (95% CI: -1.550 to -0.130 ng/mL). | ||
Interpretation: The R-value of 0.948 indicates strong correlation with the predicate. The bias at a medical decision level is quantified. | ||
Precision | Low within-run, run-to-run, day-to-day, and total variability (low %CV). | Combined Lots (Reproducibility): %CVs range from 4.3% to 7.0%. |
Single Lot (Total Within-Lot): %CVs range from 4.6% to 7.6%. | ||
Interpretation: All reported %CVs are within generally accepted limits for quantitative immunoassays, indicating good precision. | ||
Linearity | The device should demonstrate linearity across its stated measuring range with a strong correlation (R-value close to 1). | Regression equation: Observed Folate = 1.011 (Expected) - 0.147; R = 0.999. |
Interpretation: An R-value of 0.999 demonstrates excellent linearity across the tested range (up to 20 ng/mL). | ||
Recovery | %Recovery typically within 90-110% (or similar range) of the expected value. | % Recovery: Values ranged from 97.6% to 110.4% across 7 diluted samples. |
Interpretation: All recovery values fall within the generally accepted 90-110% range, indicating accurate recovery after dilution. | ||
Analytical Specificity (Cross-Reactivity) | Minimal or no significant cross-reactivity with structurally similar compounds or metabolites. | Aminopterin: 0.488% |
Phenytoin: 0.000% | ||
Methotrexate: 0.781% | ||
Folinic Acid: 1.730% | ||
Interpretation: Low percentages of cross-reactivity indicate good specificity. | ||
Analytical Specificity (Interfering Substances) | No significant interference from common endogenous or exogenous substances at tested concentrations. | No interference observed for all listed substances (Hemoglobin, Bilirubin, Triglycerides, Cholesterol, Albumin, IgG, HAMA, Rheumatoid Factor, various drugs) at the respective tested concentrations. |
Interpretation: The device is robust against common interferents. | ||
Limit of Blank (LoB) | Very low, representing the highest concentration likely to be observed in a blank sample. | ≤1.2 ng/mL |
Interpretation: A low LoB indicates effective distinction from zero analyte. | ||
Limit of Detection (LoD) | The lowest concentration that can be reliably detected. | 1.4 ng/mL |
Interpretation: Satisfactory detection capability for the intended use. | ||
Limit of Quantitation (LoQ) | The lowest concentration at which analyte can be accurately quantified with acceptable precision and accuracy. | 1.6 ng/mL |
Interpretation: The assay can reliably quantify Folate at concentrations starting from 1.6 ng/mL. | ||
Stability (Reagent Cartridge) | Maintains performance over the claimed storage period. | Open vial: 6 weeks at 2-8°C |
Interpretation: The device maintains performance for the stated duration. | ||
Stability (Calibration Curve) | Maintains accuracy over the claimed period. | Calibration curve: 21 days |
Interpretation: Calibration is stable for 21 days, suitable for routine use. | ||
Traceability | Traceable to an internationally recognized standard. | Traceable to the WHO IS 03/178 (pg/mL). |
Interpretation: Ensures accuracy and comparability of results with other standardized methods. |
2. Sample Size Used for the Test Set and Data Provenance:
- Test Set (Method Comparison): 157 human serum samples, spanning the assay range.
- Test Set (Expected Values/Reference Range): 166 prospectively collected serum samples from apparently healthy U.S. adults (21-59 years old) of mixed ethnic backgrounds (30% Caucasian, 32% African American, 38% Hispanic).
- Data Provenance: The method comparison study and the expected value study used human serum samples. The expected values study explicitly mentions "United States" for its population, implying the data is from the US and prospectively collected. The nature of the other analytical performance studies (precision, linearity, recovery, etc.) generally involves contrived or spiked samples and do not typically draw from specific patient populations or geographical locations.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications:
- General Context: For an in vitro diagnostic (IVD) device like the LIAISON® Folate assay, the "ground truth" for the test set is established by the predicate device (Abbott Laboratories, ARCHITECT Folate, K092740) for method comparison, or by the inherent concentration of the analyte in the samples for analytical performance characteristics (like precision, linearity, etc.).
- No human "experts" established ground truth for the test set in the way radiologists might agree on an image diagnosis. Instead, the predicate device (an established, cleared medical device) serves as the reference standard for comparative effectiveness.
4. Adjudication Method for the Test Set:
- This is not applicable to the analytical performance studies of an in vitro diagnostic assay. Adjudication methods (like 2+1, 3+1) are typically used in clinical studies, particularly for diagnostic imaging or pathology, where human interpretation of results is involved and consensus among experts is needed to define the "true" diagnosis or finding for a given sample/case. Here, the comparison is against an instrument's measurement (predicate device) or against known concentrations.
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 question is not applicable to this type of device. The LIAISON® Folate assay is an automated in vitro diagnostic device, not an AI-assisted diagnostic tool that humans interpret. There are no "human readers" involved in interpreting the results from this specific device.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Yes, this entire submission describes the standalone performance of the LIAISON® Folate assay. It is an automated chemiluminescent immunoassay (CLIA) system (LIAISON® XL Analyzer) that quantitatively determines Folic acid in human serum. Its performance characteristics (precision, linearity, accuracy, etc.) are evaluated intrinsically as a standalone device, without human intervention in the result determination process once the sample is loaded.
7. The Type of Ground Truth Used:
- Method Comparison: The "ground truth" was established by measurements from the predicate device, the Abbott Laboratories, ARCHITECT Folate (K092740).
- Other Analytical Performance (e.g., Precision, Linearity, Recovery, Specificity): The "ground truth" was established internally through various experimental designs:
- Precision: By repeated measurements of samples with known or target concentrations.
- Linearity: By testing serial dilutions from a high-concentration sample, where the "expected" concentration is mathematically derived from the initial concentration and dilution factor.
- Recovery: By comparing measured concentrations of diluted samples to their calculated expected concentrations.
- Analytical Specificity: By comparing results of samples spiked with potential interferents/cross-reactants to unspiked samples.
- Limits (LoB, LoD, LoQ): Through statistical analysis of repeated measurements of blank and low-level samples.
8. The Sample Size for the Training Set:
- For an IVD like the LIAISON® Folate assay, there isn't a "training set" in the context of machine learning. The technology is based on established biochemical principles (chemiluminescence immunoassay) and reagents, rather than an AI/ML algorithm that learns from data. Therefore, this question is not applicable.
9. How the Ground Truth for the Training Set Was Established:
- As mentioned above, there is no "training set" for this type of device. The design and validation are based on chemical and biological principles and rigorous experimental testing, not machine learning model training.
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(235 days)
| Clinical
Chemistry |
| Folic acid test system | 862.1295
The DxA 5000 is a high-speed, modular, automated sample handling system that performs pre-analytical and postanalytical sample processing and storage. The automation system also sorts, routes, and presents sample tubes to analyzers for analysis. The DxA 5000 also consolidates a variety of analytical instruments, such as an Immunoassay analyzer, into a unified workstation on a track system.
The DxI 800 Access Immunoassay System is a microcomputer controlled, random and continuous access analyzer that includes an external computer. This computer stores the system user interface (UI) software and allows the operator to interface with and direct the instrument software. The UniCel DxI 800 System uses enzyme immunoassays (utilizing paramagnetic particle solid phase and chemiluminescent detection) for the quantitative or qualitative or qualitative determination of various analyte concentrations found in human body fluids. The UniCel DxI 800 System is an in vitro diagnostic device for use in the clinical laboratory.
The Access Ferritin assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of ferritin levels in human serum and plasma (heparin) using the Access Immunoassay Systems. Measurements of ferritin aid in the diagnosis of diseases affecting iron metabolism.
The Access Folate assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of folic acid levels in human serum and plasma (heparin) or red blood cells using the Access Immunoassay Systems. Folate levels in serum and plasma (heparin) or red blood cells are used to assess folate status. The serum folate level is an indicator of recent folate intake. A low RBC folate value can indicate a prolonged folate deficiency. Folic acid measurements are used in the diagnosis and treatment of megaloblastic anemia.
The Access TSH (3rd IS) assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of human thyroid-stimulating hormone (thyrotropin, TSH, hTSH) levels in human serum and plasma using the Access Immunoassay Systems. This assay is capable of providing 3rd generation TSH results. Measurements of thyroid stimulating hormone produced by the anterior pituitary are used in the diagnosis of thyroid or pituitary disorders.
The Access Vitamin B12 assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of vitamin B12 levels in human serum and plasma (heparin) using the Access Immunoassay Systems. Measurements obtained by this device are used in the diagnosis and treatment of gastrointestinal malabsorption.
The DxA system is a high throughput automated sample handling system which can perform the pre and post analytical processing of sample tubes. DxA can identify and track samples, perform centrifugation, decapping, delivery of samples to connected analyzers, recapping, storing in either non-refrigerated or refrigerated storage, and sorting to output racks.
The DxA integrates perianalytic (pre and post analysis) functions with analytical instruments (Beckman Coulter, and other manufacturer's) via a track system to provide fully integrated testing solutions.
This document focuses on the substantial equivalence of the DxA 5000 automated sample handling system and related immunoassay tests (Ferritin, Folate, TSH, Vitamin B12) to previously cleared devices. It describes engineering performance studies rather than clinical efficacy studies. Therefore, many of the typical clinical study criteria requested (like multi-reader multi-case studies, effect size of human improvement with AI, number of experts for ground truth, sample size for training sets) are not applicable or detailed in this submission.
Based on the provided text, here's a breakdown of the acceptance criteria and the study that proves the device meets them:
1. A table of acceptance criteria and the reported device performance
The document states that "The acceptance criteria were met for all method comparisons thereby demonstrating the following:"
Acceptance Criteria / Performance Aspect | Reported Device Performance |
---|---|
Equivalence (DTS barcode identification process) | Equivalence between the predicate lab automation system Power Processor and the candidate one, DxA 5000 in terms of the DTS barcode identification process was demonstrated. (Specific metrics for "equivalence" are not detailed in the provided text, but it's stated as "met"). |
Equivalence (pre-analytical processing) | Equivalence between the predicate lab automation system Power Processor and the candidate one, DxA 5000 in terms of pre-analytical processing was demonstrated. (Specific metrics for "equivalence" are not detailed, but it's stated as "met"). |
Method Comparison (TSH, Ferritin, Folate, B12 Assays) | For all method comparisons (TSH (3rd IS), Ferritin, Folate and B12 assays), results were within the specifications when the candidate (DxA 5000 connected to UniCel DxI 800 Access Immunoassay System) was compared to the predicate (Power Processor connected to UniCel DxI 800 Access Immunoassay System). (Specific specifications are not provided, but compliance is affirmed). |
Software Design, Development, and Verification | All software design, development, and verification activities have been completed. (This is a qualitative statement of completion rather than a specific performance metric). |
2. Sample size used for the test set and the data provenance
- Sample Size: The document does not specify the exact sample sizes used for the method comparison studies. It mentions that the studies utilized CLSI EP09, which is a guideline for method comparison and bias estimation using patient samples, but the number of samples is not disclosed.
- Data Provenance: Not specified in the provided text (e.g., country of origin, retrospective/prospective). However, given it's a 510(k) submission for an in vitro diagnostic device, the studies are typically conducted in a controlled laboratory setting, often in a prospective manner or using banked samples that meet specific criteria.
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 and not provided in the document. The acceptance criteria and performance relate to the comparability of the new automation system and immunoassay tests against predicate devices, not against a "ground truth" established by experts for diagnostic accuracy in a clinical setting in the way an AI imaging device might. The "ground truth" here is the performance of the predicate device/system.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not applicable and not provided. Adjudication methods are typically used in studies where human readers are interpreting data (e.g., medical images) and their interpretations need to be reconciled to establish a consensus ground truth. This is an engineering/analytical performance study for a laboratory automation system and immunoassay tests.
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 and not provided. MRMC studies are relevant for imaging devices where human readers are involved in the diagnostic process. This document concerns a laboratory automation system and immunoassay tests, not an AI-assisted diagnostic imaging tool.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
The studies described are for the performance of the integrated system (DxA 5000 connected to the DxI 800 Access Immunoassay System running specific assays). While the system operates largely automatically (an "algorithm only" in the sense that the mechanical and analytical processes are automated), its performance is compared to a human-operated predicate system or another automated system. This is not an "AI algorithm only" study in the context of diagnostic decision support, but rather an automated analytical system comparison.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" in this context is the performance of the legally marketed predicate devices/systems:
- Power Processor Sample Processing System (K110413) for the DxA 5000's automation features.
- Beckman Coulter UniCel® DxI 800 Access® Immunoassay System (K023764), Access® Ferritin assay (K926221), Access® Folate assay (K060774), Access® HYPER sensitive hTSH assay (K042281), and Access® Vitamin B12 assay (K955436) for the immunoassay performance in conjunction with the automation system.
The study aimed to demonstrate that the new device system yielded results "within specifications" when compared to the predicate, implying the predicate's performance served as the benchmark or "ground truth" for equivalence.
8. The sample size for the training set
This information is not applicable and not provided. This is a 510(k) submission for laboratory equipment and assays, not a machine learning/AI device requiring a "training set" in the computational sense. The "development" for such systems involves rigorous engineering, analytical validation, and verification based on established chemical, biological, and mechanical principles.
9. How the ground truth for the training set was established
This information is not applicable for the reasons stated in point 8.
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(265 days)
Tarrytown, NY 10591
Re: K172201
Trade/Device Name: Atellica IM Folate Assay Regulation Number: 21 CFR 862.1295
|
| Product Code | CGN |
| Regulation Number | 862.1295
The Atellica™ Folate assay is for in vitro diagnostic use in the quantitative determination of folate in serum or red blood cells using the Atellica IM Analyzer. Folic acid measurements are used in the diagnosis and treatment of anemias.
The Atellica™ IM Folate Assay is an immunoassay with the following components: Atellica™ IM Folate Primary Reagent ReadyPack (including Lite Reagent, Solid Phase Reagent, and Folate Binding Protein), Atellica™ IM Folate Calibrator (including Low and High Calibrators), Atellica IM Folate DTT/Releasing Agent (sold separately, including Dithiothreitol and Sodium hydroxide), and Atellica IM RBC Folate (sold separately, including Lyophilized ascorbic acid and RBC Folate Ascorbic Acid Diluent).
The provided text is a 510(k) summary for an in vitro diagnostic device (Atellica™ IM Folate Assay), not an AI/ML medical device. Therefore, much of the requested information regarding AI/ML device acceptance criteria and study design (such as multi-reader multi-case studies, expert adjudication, training set ground truth, etc.) is not applicable to this document.
However, I can extract information related to the acceptance criteria for this diagnostic assay and how its performance was proven.
Here's a summary based on the provided document, addressing the applicable points:
Device Name: Atellica™ IM Folate Assay
Indications for Use: For in vitro diagnostic use in the quantitative determination of folate in serum or red blood cells using the Atellica IM Analyzer. Folic acid measurements are used in the diagnosis and treatment of anemias.
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly state "acceptance criteria" in a singular table, but rather presents performance characteristics of the device, implying that the observed performance met internal or regulatory (CLSI) standards. The predicate device (ADVIA Centaur Folate Assay, K010050) serves as the benchmark for substantial equivalence.
Here's a compilation of key performance characteristics, acting as de-facto acceptance criteria for a new in vitro diagnostic assay, and the reported performance. The "Acceptance Criteria" here are implicitly derived from CLSI guidelines and comparison to the predicate.
Performance Characteristic | Implicit/Stated Acceptance Criteria (often based on CLSI guidelines or predicate performance) | Reported Device Performance (Atellica™ IM Folate Assay) |
---|---|---|
Precision (Repeatability CV) | Acceptable Coefficient of Variation (CV) for different analyte levels (e.g., typically 0.95) with predicate device. | Serum: r = 0.99 |
RBC hemolysate: r = 0.93 | ||
Method Comparison (Regression Equation) | Slope and intercept close to 1 and 0, respectively, when compared to predicate. | Serum: y = 0.94x - 0.01 ng/mL |
RBC hemolysate: y = 1.06x – 2.52 ng/mL | ||
Detection Limits (LoB, LoD, LoQ) | Values demonstrated to be fit for clinical purpose. | Serum: LoB 0.19 ng/mL, LoD 0.38 ng/mL, LoQ 0.56 ng/mL |
RBC: LoB 0.00 ng/mL, LoD 0.21 ng/mL, LoQ 0.56 ng/mL | ||
Interference | No significant interference ( |
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(142 days)
Diazyme Folate Control Set Regulation Number: 21 CFR 862.1295 Regulation Name: Folic acid test system
The Diazyme Folate Assay is a homogeneous enzyme immunoassay intended for use in the quantitative analysis of folate in human serum. Folic acid measurements are used in the diagnosis and treatment of anemias. For in-vitro diagnostic use only.
The Diazyme Folate Calibrator Set is intended for use in the calibration of the Diazyme Folate Assay. For in vitro diagnostic use only.
The Diazyme Folate Control Set is intended for use as quality controls for the Diazyme Folate Assay. For in vitro diagnostic use only.
Not Found
The provided text describes the FDA 510(k) clearance for the Diazyme Folate Assay, Diazyme Folate Calibrator Set, and Diazyme Folate Control Set. It focuses on the regulatory approval process and includes an "Indications for Use" statement.
Crucially, the document is a regulatory approval letter and not a study report. Therefore, it does not contain the detailed performance data, study design, or methodology information required to answer most of your questions about acceptance criteria verification and study details.
The information provided only allows for a very limited and generic answer:
1. A table of acceptance criteria and the reported device performance
- Acceptance Criteria (Implied): The device must be "substantially equivalent" to legally marketed predicate devices for the stated indications for use.
- Reported Device Performance: The FDA determined that the device is "substantially equivalent" to legally marketed predicate devices.
2. Sample size used for the test set and the data provenance
NOT PROVIDED IN THE DOCUMENT. This document does not detail the specific performance studies that Diazyme Laboratories conducted to demonstrate substantial equivalence.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
NOT PROVIDED IN THE DOCUMENT.
4. Adjudication method for the test set
NOT PROVIDED IN THE DOCUMENT.
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 is an in vitro diagnostic (IVD) assay for measuring folate levels, not an AI-assisted diagnostic imaging device. Therefore, MRMC studies and human reader improvement with AI are not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
NOT APPLICABLE. As an IVD assay, its performance is inherently "standalone" in a laboratory setting, meaning it measures a biomarker without human interpretation of complex images or AI algorithms. However, the document does not contain the specific performance data (e.g., accuracy, precision, linearity) that would typically be generated in such a study.
7. The type of ground truth used
NOT PROVIDED IN THE DOCUMENT. For an IVD assay, ground truth would typically be established through reference methods, clinical diagnosis, or patient outcomes for the condition being diagnosed/monitored (anemia in this case).
8. The sample size for the training set
NOT PROVIDED IN THE DOCUMENT.
9. How the ground truth for the training set was established
NOT PROVIDED IN THE DOCUMENT.
In summary, the provided FDA 510(k) clearance letter confirms regulatory approval based on substantial equivalence but does not contain the detailed study data, methodologies, or acceptance criteria that would typically be found in a clinical study report or a 510(k) submission's performance section. To answer your questions comprehensively, you would need to review the actual 510(k) submission materials, which are not included in this document.
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(140 days)
INDIANAPOLIS IN 46250-0416
Re: K141426
Trade/Device Name: Elecsys Folate III Regulation Number: 21 CFR 862.1295
Binding assay for the in vitro quantitative determination of folate in human serum. The binding assay is intended for use on Elecsys and cobas e immunoassay analyzers. Folic acid measurements are used in the diagnosis and treatment of anemias.
The Folate III Assay employs a competitive test principle using natural folate binding protein (FBP) specific for folate. Folate in the sample competes with the added folate (labeled with biotin) for the binding sites on FBP (labeled with a ruthenium complex). Results are determined using a calibration curve that is generated specifically on each instrument by a 2 point calibration and a master curve (5-point-calibration) provided with the reagent bar code.
Roche Diagnostics' Elecsys Folate III Assay is a quantitative in vitro diagnostic device designed for measuring folate levels in human serum, primarily for the diagnosis and treatment of anemias. The following outlines its acceptance criteria and the studies performed to demonstrate its performance.
Acceptance Criteria and Reported Device Performance
The acceptance criteria for the Elecsys Folate III Assay are primarily established through comparison to a predicate device, the Roche Elecsys Folate III (K082340). The device demonstrates comparable or improved analytical performance characteristics.
Feature | Predicate Device: Roche Elecsys Folate III (K082340) | Candidate Device: Elecsys Folate III Assay | Acceptance Criteria (Implied by equivalence) |
---|---|---|---|
Measuring Range | 1.50 - 20.0 ng/mL | 2.0 - 20.0 ng/mL | Similar or improved range |
Analytical Sensitivity | |||
Limit of Blank (LoB) | 0.640 ng/mL | 0.6 ng/mL | Equal to or lower than predicate |
Limit of Detection (LoD) | 1.50 ng/mL | 1.2 ng/mL | Equal to or lower than predicate |
Limit of Quantitation (LoQ) | 2.0 ng/mL | 2.0 ng/mL | Equal to or lower than predicate |
Analytical Specificity (Cross-reactivity) | |||
Amethopterin | 2.3% at 750 ng/mL | 2.5% at 1500 ng/mL | Comparable or improved |
Aminopterin | 2.7% at 750 ng/mL | 4.4% at 1500 ng/mL | Comparable or improved |
Folonic acid | 2.3% at 750 ng/mL | 0.7% at 1500 ng/mL | Comparable or improved |
Precision (cobas e 411) | |||
Within-run (Repeatability) | %CV range: 3.7% - 5.8% | %CV range: 2.2% - 6.8% | Comparable to predicate |
Total (Intermediate) | %CV range: 6.1% - 9.4% | %CV range: 3.7% - 10.8% | Comparable to predicate |
Limitations (Interference) | |||
Bilirubin | unaffected |
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(201 days)
| Immunology |
| Folic acid test system | 862.1295
The basic Power Express is an automated sample handling system which processes sample tubes from the precentrifugation, pre-sorting step to presentation of centrifuged and decapped samples into Generic or Personality Racks for specific instruments. The Power Express can be configured with optional software to allow processing of sample tubes on Generic Connection Instruments. The Power Express performs all pre-analytical sample tube preparation, and then sorts the sample tubes directly to Generic Connection Modules where the samples are pipetted by the Generic Connection instrument for testing. After the samples are pipetted, the tubes can route to other instruments for additional testing or to Outlet Racks.
The UniCel DxI 800 Access Immunoasav System with laboratory automation is a microcomputer-controlled. random and continuous access analyzer that includes an external computer stores the system user interface (UI) software and allows the operator to interface with and direct the instrument software. The UniCel DxI 800 System uses enzyme immunoassays (utilizing paramagnetic particle solid phase and chemiluminescent detection) for determination of various analytes, such as Vitamin B12. Ferritin, Folate and hTSH along with other various enzyme immunoassays assays that may be adaptable to the analyzer depent used to induce the enzyme immunoassay reaction. The UniCel Dxl 800 System is an in vitro diagnostic device for use in the clinical laboratory.
The Access Ferritin assay is a paramagnetic particle, chemiluminescent assay for the quantitative determination of ferritin levels in human serum and plasma (heparin) using the Access Immunoassay Systems. Measurements of ferritin aid in the diagnosis of diseases affecting iron metabolism.
The Access Folate assay is a paramagnetic particle, chemiluminescent immunoassay for the quantitative determination of folic acid levels in human serum, plasma (heparin) and red blood cells using the Access Immunoassay Systems. Folic acid measurements are used in the diagnosis and treatment of megaloblastic anemia.
The Access HYPER sensitive hTSH assay is a paramagnetic particle, chemiluminescent assay for the quantitative determination of human thyroid-stimulating hormone (thyrotropin, hTSH) levels in human serum using the Access Immunoassay Systems. Measurements of thyroid stimulating hormone produced by the anterior pituitary are used in the diagnosis of thyroid or pituitary disorders.
The Access Vitamin B12 assay is a paramagnetic particle, chemiluminescent assay for the quantitative determination of vitamin B12 in human serum and plasma (heparin) using Access Immunoassay Systems. Measurements obtained by this device are used in the diagnosis and treatment of gastrointestinal malabsorption.
The Power Express is Beckman Coulter's Power Processor Sample Processing System with the modifications noted in this premarket submission. The Power Express and the Power Processor Sample Processing System are scalable laboratory automation systems (LAS) designed to streamline peri-analytical processes in the clinical laboratory.
The Power Express is an automated sample handling system which processes sample tubes from the pre-centrifugation, pre-sorting steps to presentation of centrifuged and decapped samples into racks for chemistry, immunoassay, hematology, and coagulation systems. The Power Express is designed to free laboratory personnel from biohazard exposure and routine sample preparation.
The Power Express software can be configured with optional hardware to allow processing of sample tubes on physically connected analyzers using common communication protocols (Generic Connection Instruments). The Power Express performs pre-analytical sample tube preparation then sorts the sample tubes directly to the optional hardware interface between the LAS and analyzer (Generic Connection Module) where the samples are pipetted by the analyzer for testing. After the samples are pipetted, the tubes can be routed to other instruments for additional testing or to Outlet Racks.
A basic Power Express System is comprised of a Line Control Computer, a system console with Cennexus software, Inlet Module, Centrifugation Module, Decapper Module, track transport system and Outlet Module. Additional modules may be added for aliquot capability, sample capping, and ambient or refrigerated storage.
Here's an analysis of the provided text, focusing on acceptance criteria and study details.
Important Note: The provided document is a 510(k) summary for a medical device. This type of document focuses on demonstrating substantial equivalence to a previously cleared predicate device, rather than proving the efficacy of new clinical features from scratch. This influences the nature of the "acceptance criteria" and "study" described. The document largely asserts that the modifications to the Power Processor system did not introduce new risks to the performance of the integrated assays, and therefore formal V&V testing was sufficient rather than full clinical studies.
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of "acceptance criteria" in the traditional sense of numerical thresholds for clinical performance (e.g., sensitivity, specificity, accuracy). Instead, the "acceptance criteria" can be inferred from the statement that "all software design, development and verification activities have been completed and passed to supports equivalency of Power Express to the Power Processor V5.0 Sample Processing System." The performance reported is that the device "functions as intended, meeting the requirements of the design specifications."
Let's infer acceptance criteria based on the modifications and the intent of substantial equivalence:
Acceptance Criterion (Inferred) | Reported Device Performance (Implied) |
---|---|
Functional Equivalence of Software: All new and modified software features (Sample Management, Data Management, Set-up, Analyzer Connections, Host Interface Communications, Communication with Line Control Software, Sample Routing Logic, Sample Storage, Error Recovery) perform their intended functions as safely and effectively as the predicate's software. | "Software design testing of: Sample Management, Data Management, Set-up, Analyzer Connections, Host Interface Communications, Communication with Line Control Software, Sample Routing Logic, Sample Storage, Error Recovery" completed and passed. This implies the software functions as intended and supports the system's overall operation for sample processing and immunoassay integration. |
System Operations: The overall system, including new hardware components (e.g., increased throughput, new control panel, more modules), processes samples reliably and correctly. | "System verification and validation testing of: System Functions, System operations, Maintenance, Error conditions, Error codes, Problem description and solution in the system instructions for use" completed and passed. This indicates that the integrated system operates as designed, handles various operational scenarios, and maintains user guidance for errors. The comparison table confirms improved throughput (1200 tubes/hour vs. 450 tubes/hour) and enhanced features (e.g., touch screen, improved cybersecurity, mixed tube sizes, dual aliquots, more centrifuges). |
Assay Performance Maintenance: The performance of the integrated Access Immunoassays (Ferritin, Folate, HYPERsensitive hTSH, Vitamin B12) is not adversely affected by the Power Express system. | The document states, "Based on the risk analysis, the modifications to the Power Processor did not introduce any new risks to the performance of the assays through the chemistry analyzer connections; therefore there was no requirement for Verification and Validation Testing." This implies that the prior proven performance of these assays when run on the predicate system is maintained, and no new studies were deemed necessary to re-verify assay performance due to the nature of the system modifications. The device "functions as intended, meeting the requirements of the design specifications." |
Safety and Effectiveness: The Power Express is as safe and effective as the predicate device. | "Performance testing of the device demonstrates that the device functions as intended... The changes to the device do not constitute a new intended use and any differences in technological characteristics have been tested to demonstrate that the device is as safe and effective as the predicate and do not raise different questions of safety and effectiveness." |
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document does not specify sample sizes for test sets in the context of clinical or performance data for the assays themselves. The testing described is primarily software and system verification and validation (V&V). These are typically internal engineering tests rather than studies involving patient samples in a clinical setting with formal sample sizes as understood in clinical trials.
- Sample Size for Test Set: Not specified, as the testing was primarily V&V of the automated system's components and software.
- Data Provenance: Not applicable in the context of system V&V. This would typically be relevant for clinical studies involving patient data. This was internal Beckman Coulter testing.
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 is not applicable to the type of V&V testing described. "Ground truth" in this context would likely refer to expected system behaviors, software outputs, or known operational parameters, which would be established by the device's design specifications and engineering teams, rather than by external clinical experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods are typically used in clinical studies to resolve discrepancies in expert opinions on diagnosis or outcome. For system V&V, "adjudication" would be a matter of comparing test results against predefined functional requirements and expected outputs, often automated or reviewed by a single test engineer or a team.
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. An MRMC study is relevant for imaging devices or diagnostic tools where human interpretation is involved. The Power Express is an automated sample processing system and immunoassay platform; its function is to prepare samples and run assays, not to assist human interpretation of complex data in the way AI assistance might.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, the testing described is effectively "standalone" for the automated system. The Power Express system, as an automated sample handling and processing system, operates without direct human intervention in its core tasks (centrifugation, decapping, sorting, routing, pipetting, running assays on connected instruments). The performance data mentioned refers to the verification and validation of this automated system's functionality and software.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for the verification and validation (V&V) described would be the design specifications and functional requirements of the Power Express system. This includes:
- Expected software behaviors and outputs.
- Correct execution of mechanical tasks (e.g., decapping, sorting, pipetting).
- Correct communication protocols with connected instruments and the LIS.
- Adherence to performance metrics like throughput.
- The known performance characteristics of the integrated commercial assays (Ferritin, Folate, hTSH, Vitamin B12) which were previously established and not re-evaluated.
8. The sample size for the training set
Not applicable. The Power Express is an automated sample processing system, not an AI or machine learning model that requires a "training set" of data. The software within the system is likely rule-based or deterministic, rather than learned.
9. How the ground truth for the training set was established
Not applicable, as there is no "training set" for this type of device.
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(142 days)
Device Name: Roche Elecsys Folate RBC, Folate RBC CalCheck, Folate RBC CalSet Regulation Number: 21 CFR 862.1295
(1) Elecsys Folate RBC Assay: Binding assay for the in vitro quantitative determination of folate erythrocytes (red blood cells, RBCs). The binding assay is intended for use on Elecsys and cobas e immunoassay analyzers. Measurements obtained by this assay are used in the diagnosis and treatment of anemias.
(2) Elecsys Folate RBC CalSet: The Elecsys Folate RBC CalSet is used for calibrating the quantitative Elecsys Folate RBC assay on the Elecsys and cobas e immunoassay analyzers.
(3) Elecsys Folate RBC CalCheck: Elecsys Folate RBC CalCheck is used for the verification of the calibration established by the Elecsys Folate RBC reagent on the indicated Elecsys and cobas e immunoassay analyzers. For in vitro diagnostic use.
(1) The Elecsys Folate RBC assay employs a competitive test principle using natural folate binding protein specific for folate. Manually prepared hemolysate samples are used with this assay. Folate in the sample competes with the added folate (labeled with biotin) for the binding sites on folate binding protein (labeled with ruthenium complex). Results are determined via a calibration curve which is instrument-specifically generated by 2-point calibration and a master curve provided via the reagent barcode encoded on the reagent packaging.
(2) The Elecsys Folate RBC CalSet is a lyophilized product consisting of human serum with folate in two concentration ranges. During manufacture, the analyte is spiked into the matrix. This calibrator is used to calibrate the Elecsys Folate RBC assay.
(3) The Elecsys Folate RBC CalCheck is a lyophilized product consisting of a hemolysate with folic acid. During manufacture, the analyte is spiked into the matrix. This solution is used to verify the calibration established with the Elecsys Folate RBC CalSet.
The provided text describes the Elecsys Folate RBC Test System, but it is a device for in vitro quantitative determination of folate in red blood cells and not an AI or imaging device. Therefore, many of the requested categories related to AI performance, such as MRMC studies, ground truth establishment by experts for image data, or training/test set sample sizes for AI models, are not applicable.
However, I can extract information related to the device's analytical performance and the studies conducted to demonstrate its substantial equivalence to a predicate device, focusing on the available information.
Here's the breakdown based on the provided text, adapted for a non-AI diagnostic device:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are not explicitly stated as distinct pass/fail thresholds in a table format. Instead, the submission demonstrates substantial equivalence by comparing the performance characteristics of the new Elecsys Folate RBC Assay to the predicate device (Elecsys RBC Folate III Assay) in a feature-by-feature comparison. The reported performance of the new device is shown alongside the predicate's performance. The "acceptance criteria" here are implicitly the predicate device's performance, as the goal is to show substantial equivalence.
Feature | Acceptance Criteria (Predicate Device Performance) | Reported Device Performance (Elecsys Folate RBC Assay) |
---|---|---|
Measuring Range | 46.5 - 620 ng/mL | 120 ng/mL - 620 ng/mL |
Analytical Sensitivity (LoB) | ≤ 19.84 ng/mL | ≤ 20 ng/mL |
Analytical Sensitivity (LoD) | ≤ 46.5 ng/mL | ≤ 46.5 ng/mL |
Analytical Sensitivity (LoQ) | ≤ 62.0 ng/mL | ≤ 120.0 ng/mL |
Dilution (Min. diluted conc.) | The concentration of the diluted sample must be > 310 ng/mL. | The concentration of the diluted sample must be >265 ng/mL. |
Precision (Repeatability, Elecsys 2010/cobas e411, Sample 1/Hemolysate 2) | Mean 229 ng/mL: SD 12.2 ng/mL; CV 5.3% | Hemolysate 2, mean 155 ng/mL: SD 7.73 ng/mL; CV 5.0% |
Precision (Repeatability, Elecsys 2010/cobas e411, Sample 2/Hemolysate 3) | Mean 350 ng/mL: SD 17.0 ng/mL; CV 4.9% | Hemolysate 3, mean 272 ng/mL: SD 11.2 ng/mL; CV 4.1% |
Precision (Repeatability, Elecsys 2010/cobas e411, Sample 3/Hemolysate 4) | Mean 481 ng/mL: SD 25.7 ng/mL; CV 5.3% | Hemolysate 4, mean 527 ng/mL: SD 17.1 ng/mL; CV 3.3% |
Precision (Repeatability, Elecsys Modular E170/cobas e 601/602, Hemolysate 2) | Not applicable (predicate not tested on these platforms) | Hemolysate 2, mean 191 ng/mL: SD 11.5 ng/mL; CV 6.0% |
Precision (Repeatability, Elecsys Modular E170/cobas e 601/602, Hemolysate 3) | Not applicable | Hemolysate 3, mean 258 ng/mL: SD 14.1 ng/mL; CV 5.5% |
Precision (Repeatability, Elecsys Modular E170/cobas e 601/602, Hemolysate 4) | Not applicable | Hemolysate 4, mean 580 ng/mL: SD 12.8 ng/mL; CV 2.2% |
Precision (Intermediate Precision, Elecsys 2010/cobas e411, Sample 1/Hemolysate 2) | Mean 229 ng/mL: SD 16.1 ng/mL; CV 7.0% | Hemolysate 2, mean 155 ng/mL: SD 12.2 ng/mL; CV 7.9% |
Precision (Intermediate Precision, Elecsys 2010/cobas e411, Sample 2/Hemolysate 3) | Mean 350 ng/mL: SD 25.2 ng/mL; CV 7.2% | Hemolysate 3, mean 272 ng/mL: SD 16.9 ng/mL; CV 6.2% |
Precision (Intermediate Precision, Elecsys 2010/cobas e411, Sample 3/Hemolysate 4) | Mean 481 ng/mL: SD 34.6 ng/mL; CV 7.2% | Hemolysate 4, mean 527 ng/mL: SD 24.8 ng/mL; CV 4.7% |
Precision (Intermediate Precision, Elecsys Modular E170/cobas e 601/602, Hemolysate 2) | Not applicable | Hemolysate 2, mean 191 ng/mL: SD 12.5 ng/mL; CV 6.5% |
Precision (Intermediate Precision, Elecsys Modular E170/cobas e 601/602, Hemolysate 3) | Not applicable | Hemolysate 3, mean 258 ng/mL: SD 15.1 ng/mL; CV 5.9% |
Precision (Intermediate Precision, Elecsys Modular E170/cobas e 601/602, Hemolysate 4) | Not applicable | Hemolysate 4, mean 580 ng/mL: SD 19.7 ng/mL; CV 3.4% |
Analytical Specificity / Cross-Reactivity | Aminopterin 2.7%, Folinic acid 2.3%, Amethopterin 2.3% | Same (Implies similar or acceptable cross-reactivities, though specific percentages are not re-listed for the new device) |
Interferences | Unaffected by icterus, lipemia, biotin (up to 86.1 nmol/L or 21 ng/mL), IgG, IgA. No interference from rheumatoid factors up to 1000 IU/mL. No interference from 18 common pharmaceuticals or human erythropoietin. | Similar interference study reported ("Same") with an added precautionary statement for high protein samples causing protein gel. Specific interference limits are not re-listed but implied to be similar or improved. |
Expected Values (Whole Blood Folate) | American Journal of Clinical Nutrition Expected = 4.6 - 34.8 ng/mL (all ages & male/female) | Expected = 209-640 (2.5th - 97.5th percentile) (from hemolysate sample) |
Expected Values (RBC Folate) | Not separately specified for predicate in this section | Expected = 499-1504 ng/mL (2.5th - 97.5th percentile) (folate in erythrocyte fraction) |
Study Proving Device Meets Acceptance Criteria:
The study proving the device meets the acceptance criteria is a substantial equivalence comparison study against a legally marketed predicate device, the Elecsys RBC Folate III Test System (K082340). This type of study demonstrates that the new device is as safe and effective as the predicate device by showing that it has similar technological characteristics and performance.
2. Sample Size Used for the Test Set and Data Provenance
The document does not explicitly state a single "test set" sample size in the way an AI model validation might. Instead, it details various analytical performance studies with different "samples" for each attribute:
- Precision (Repeatability & Intermediate Precision): Tested on multiple "Hemolysate" or "Sample" controls at different concentration levels. For each level, measurements were taken to determine SD and CV. The exact number of replicates or runs is not specified in the summary but is typically substantial for precision studies (e.g., multiple runs over several days).
- Analytical Sensitivity (LoB, LoD, LoQ): Determined using analytical methods, likely involving dilutions of folate-containing samples. The specific sample count for these determinations is not provided.
- Interferences: Tested using various interfering substances and pharmaceuticals. The number of samples/donors tested for each interference is not specified, but typically involves spiking known concentrations into samples and assessing recovery.
- Expected Values: Determined from a "Whole Blood Folate (from hemolysate sample)" study and an "RBC Folate (folate in erythrocyte fraction)" study. The sample size for these population studies is not provided in the summary.
Data Provenance: The document does not explicitly state the country of origin or whether the data was retrospective or prospective. For in vitro diagnostic device submissions, such data is typically generated in a controlled laboratory setting (prospective) and may involve samples from different geographical regions, but this is not specified here.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of those Experts
Not applicable. This is not an AI/imaging device where expert consensus is used to establish ground truth for a test set. This device quantifies a biomarker (folate in RBCs). The "ground truth" for its analytical performance is established through reference methods and internal validation procedures, not human interpretation or adjudication by experts.
4. Adjudication Method for the Test Set
Not applicable. As this device measures a quantitative biomarker, there is no "adjudication" in the sense of resolving discrepancies in human interpretation or labeling. Analytical performance is typically verified against established laboratory standards and reference methods.
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 is not an AI device used for interpretation or diagnosis by human readers, so an MRMC study is irrelevant.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is a standalone device performance study. The Elecsys Folate RBC Test System performs the quantitative measurement of folate in RBCs automatically on immunoassay analyzers (Elecsys and cobas e platforms) without human-in-the-loop interpretative performance. The performance metrics (measuring range, sensitivity, precision, interference) are all measures of the algorithm and system's analytical capability.
7. The Type of Ground Truth Used
The "ground truth" for this device's performance relies on analytical reference methods and established laboratory principles. For example:
- For analytical sensitivity (LoB, LoD, LoQ): Determined using standard statistical methods and known concentrations of analyte.
- For precision: Assessed by running replicate measurements on control samples.
- For accuracy/comparison to predicate: The predicate device itself (Elecsys RBC Folate III Assay) serves as the "reference" for demonstrating substantial equivalence. The traceability of the new device is stated as "Reference method is Folate III (Application on the E2010)", meaning its measurements are compared to the predicate's measurements. The predicate's traceability is to the "Elecsys Folate II assay."
8. The Sample Size for the Training Set
Not applicable. This is not an AI/machine learning device that requires a "training set." The system's underlying principles are based on known biochemistry (competitive binding assay using folate binding protein) and not data-driven learning from a training set.
9. How the Ground Truth for the Training Set was Established
Not applicable, as there is no training set for this type of in vitro diagnostic device.
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(178 days)
Name: Folic acid test system Trade Name: ARCHITECT Folate Common Name: Folate Governing Regulation: 862.1295
MD 20993-0002
MAR 0 5 2010
K092740 Re:
Trade Name: ARCHITECT Folate Regulation Number: 21 CFR §862.1295
The ARCHITECT Folate assay is a chemiluminescent microparticle Folate Binding Protein assay for the quantitative determination of folate in human serum and plasma on the ARCHITECT i System. Folate measurements are used in the diagnosis and treatment of megaloblastic anemia.
The ARCHITECT Folate Calibrators are for the calibration of the ARCHITECT i System when used for the quantitative determination of folate in human serum and plasma.
The ARCHITECT Folate Controls are for the verification of the accuracy and precision of the ARCHITECT i System when used for the quantitative determination of folate in human serum and plasma.
The ARCHITECT Folate assay is a two-step assay for the quantitative determination of folate in human serum and plasma using chemiluminescent microparticle immunoassay (CMIA) technology. Two pre-treatment steps mediate the release of folate from endogenous folate binding protein.
In Pre-Treatment Step 1, the sample and Pre-treatment Reagent 2 (Dithiothreitol or DTT) are aspirated and dispensed into a reaction vessel (RV). In Pre-Treatment Step 2, an aliquot of sample/Pre-Treatment Reagent 2 mixture is aspirated and dispensed into a second RV. Pre-Treatment Reagent 1 (potassium hydroxide or KOH) is then added. An aliquot of the pre-treated sample is transferred into a third RV, followed by the addition of Folate Binding Protein (FBP) coated paramagnetic microparticles and assay specific diluent. Folate present in the sample binds to the FBP coated microparticles. After washing, pteroic acid-acridinium labeled conjugate is added and binds to unoccupied sites on the FBP coated microparticles. Pre-Trigger and Trigger Solutions are then added to the reaction mixture; the resulting chemiluminescent reaction is measured as relative light units (RLUs). An inverse relationship exists between the amount of folate in the sample and the RLUs detected by the ARCHITECT i optical system.
The provided text describes a 510(k) submission for the ARCHITECT Folate assay, a medical device for quantitatively determining folate in human serum and plasma. The study conducted is a non-clinical performance comparison between the new ARCHITECT Folate assay and its predicate device, the AxSYM Folate assay.
Here's an analysis of the acceptance criteria and study as requested:
1. Table of Acceptance Criteria and Reported Device Performance
Performance Metric | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Precision | Substantially equivalent to predicate | Demonstrated substantially equivalent performance |
Linearity | Substantially equivalent to predicate | Demonstrated substantially equivalent performance |
Interferences | Substantially equivalent to predicate | Demonstrated substantially equivalent performance |
Method Comparison | Good correlation with predicate | Correlation coefficient of 0.898 for serum samples |
Bias | Understandable and attributable to standardization differences | General bias due to standardization differences (predicate uses gravimetric preparations, investigational assay standardized to WHO Serum Folate International Standard (IS) 03/178) |
Note: The document states "The ARCHITECT Folate assay demonstrated substantially equivalent performance to the AxSYM Folate assay with correlation coefficients of 0.898 for serum samples." The acceptance criteria for "substantially equivalent" in areas like precision, linearity, and interferences are not explicitly quantified with numerical thresholds in the provided text. They are implied by the claim of substantial equivalence to the predicate device.
2. Sample Size Used for the Test Set and the Data Provenance
The document does not explicitly state the sample size used for the test set in the comparison study.
The data provenance is not specified in terms of country of origin or whether it was retrospective or prospective. It is a non-clinical performance study.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts
This information is not applicable to this type of study. The ground truth for a quantitative diagnostic assay is typically established through a reference method or standardization to an internationally recognized standard. In this case, the investigational assay was standardized to the WHO Serum Folate International Standard (IS) 03/178. Human expert consensus is not the method for establishing ground truth for quantitative laboratory tests like this.
4. Adjudication Method for the Test Set
This information is not applicable to this type of study. Adjudication methods (like 2+1 or 3+1) are typically used in studies where human readers are interpreting images or making subjective diagnoses, which is not the case for a quantitative immunoassay comparison. The comparison is likely done statistically between measured values.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done. This study is a non-clinical performance evaluation of a quantitative diagnostic assay, not an AI-assisted human reading study.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
Yes, this was a standalone performance study of the ARCHITECT Folate assay. The document describes the assay's mechanism and then presents its performance characteristics (precision, linearity, interferences, method comparison) against a predicate device. There is no mention of human-in-the-loop performance testing.
7. The Type of Ground Truth Used
The ground truth for the investigational assay was established by standardization to the WHO Serum Folate International Standard (IS) 03/178. For the comparison with the predicate, the predicate device's results serve as a comparative "truth," which were themselves based on gravimetric preparations of folic acid.
8. The Sample Size for the Training Set
The document does not mention a "training set" in the context of machine learning. This is a traditional immunoassay device, not an AI/ML-based device. Therefore, a training set as understood in AI/ML is not applicable. The assay is "standardized" rather than "trained."
9. How the Ground Truth for the Training Set Was Established
As explained above, there is no "training set" in the machine learning sense for this device. The assay was standardized to accurately recover WHO Serum Folate International Standard (IS) 03/178. This standardization process involves calibrating the assay's response to known concentrations of the analyte based on this international standard.
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