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510(k) Data Aggregation
(18 days)
Number: | 21CFR 862.2860 |
1
The ABCA is a continuous flow Gas Isotope Ratio Mass Spectrometer (GIRMS) System intended for use in the measurement of stable isotopes of carbon, nitrogen, and oxygen in gas samples. For this purpose, the system is comprised of a gas sampling module, a gas purification module, and an isotope ratio mass spectrometer which are synchronously coupled by means of an external personal computer which also collects and archives data.
The ABCA is an acronym for a configuration of modules intended for use in analysis ${}^{13}$C and ${}^{18}$O in CO${}_2$ and ${}^{15}$N in N${}_2$ and N${}_2$O gas samples. The ABCA System includes:
- The Europa 20-20 continuous flow IRMS
- A gas purification module (Gas Chromatograph)
- An autosampler
- An IBM (or compatible) personal computer for system control, data analysis and data storage
Here's a breakdown of the acceptance criteria and the study details for the ABCA Gas Isotope Ratio Mass Spectrometer System, based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Performance Metric | Acceptance Criteria (Implied) | Reported Device Performance | Study Reference |
---|---|---|---|
Systematic Difference (Accuracy) | Not explicitly stated | 0.06 DOB | NCCLS EP9-A |
Within-Run Precision | ≤ 0.1% | 0.056% | NCCLS EPS-A |
Linearity Range (Response Function) | Not explicitly stated | -22%o to 232%o | Not specified |
Explanation of Implied Acceptance Criteria:
- Systematic Difference: While no explicit acceptance criterion is given, the reporting of "0.06 DOB" suggests that this value was considered acceptable for demonstrating substantial equivalence. The method of measurement (comparison to predicate device) implies the new device should perform similarly.
- Within-Run Precision: The statement "The claimed imprecision at this level is 0.1%" directly indicates the acceptance criterion for precision. The reported value of 0.056% is well within this claimed (and implicitly accepted) limit.
- Linearity Range: The statement "The ABCA test system response function was determined to be linear throughout the range -22%o to 232%o" implies that linearity across this range was established and considered satisfactory.
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size:
- Systematic Difference: 102 breath samples
- Within-Run Precision: Triplicate analyses of stable gas samples in each of 10 daily sample runs (total of 30 analyses).
- Linearity: Not specified, but likely involved multiple measurements across the specified range.
- Data Provenance: Retrospective, as the systematic difference study used "102 breath samples from the ${}^{13}$C-urea breath test." The origin of these samples (e.g., country) is not specified. The precision study used "stable gas samples," implying controlled lab samples rather than clinical patient data.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Their Qualifications
- Not Applicable. This device is a measurement instrument, not a diagnostic imaging or AI-driven interpretive device that requires human expert review for ground truth in the traditional sense. The "ground truth" for its performance is its physical and chemical measurement capabilities and comparison to a predicate device.
4. Adjudication Method for the Test Set
- Not Applicable. See point 3. The performance is based on direct measurements and comparisons to known reference values or a predicate device.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No. An MRMC study was not conducted as this is a measurement device and does not involve human readers interpreting results in the way an AI diagnostic tool would.
6. Standalone (Algorithm Only) Performance Study
- Yes, effectively. The "Analytical Performance Data" describe the standalone performance of the device itself (the algorithm in the broad sense of its operational principles and calculations), even though it's a physical instrument. The metrics reported (systematic difference, precision, linearity) directly assess the instrument's capability without human intervention in the primary measurement process.
7. Type of Ground Truth Used
- Systematic Difference: Performance of a legally marketed predicate device (ABCA-NT Gas Isotope Ratio Mass Spectrometer System, K974322) on the same samples. Implicitly, the predicate device's performance defined an acceptable "ground" or reference for the comparison.
- Within-Run Precision: Comparison against the device's own measurements over time on stable gas samples. The "ground truth" here is the expected consistency of the measurements.
- Linearity: Comparison against known concentrations/ratios of reference gases across a range, although not explicitly detailed. The "ground truth" is the established linearity of the physical and chemical principles the device relies upon.
8. Sample Size for the Training Set
- Not Applicable/Not Explicitly Stated. This device is a measurement instrument, not an AI model that undergoes a "training" phase with a large dataset. Its "training" or calibration involves using reference gases of known isotopic composition (as mentioned in section 2. Calibration). The sample size for this calibration process is not specified, but it would involve a limited number of analyses with these reference gases.
9. How the Ground Truth for the Training Set Was Established
- Reference Gas of Known Isotopic Composition. As stated in section 2. Calibration, "The system is calibrated with reference gas of known isotopic composition." These reference gases are likely certified standards whose isotopic abundances are precisely determined through highly accurate measurement techniques.
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(29 days)
Number: | 21CFR 862.2860 |
| Class: | Class I |
The ABCA-NT is a continuous flow Gas Isotope Ratio Mass Spectrometer (GIRMS) System intended for use in the measurement of stable isotopes of carbon, nitrogen, and oxygen in gas samples. For this purpose, the system is comprised of a gas sampling module, a gas purification module, and an isotope ratio mass spectrometer which are synchronously coupled by means of an external computer which also collects and archives data.
The ABCA-NT is an acronym for a configuration of modules intended for use in analysis 13C and 18O in CO2 and 15N in N2 and N2O gas samples. The ABCA-NT System includes, as physically separate modules:
- The Europa 20-20 continuous flow IRMS
- The Europa ABCA-G gas purification module (Gas Chromatograph)
- A Gilson (or equivalent) autosampler
- An IBM (or compatible) personal computer for system control, data analysis and data storage
This 510(k) summary does not contain the information required to answer the questions regarding acceptance criteria and the study that proves the device meets the acceptance criteria. The document focuses on establishing substantial equivalence to a predicate device based on technological similarities, rather than presenting a performance study with specific acceptance criteria.
Here's why the requested information cannot be extracted from the provided text:
- Acceptance Criteria and Reported Device Performance: This document states that "The technical specifications of the systems are essentially equivalent" to the predicate device. However, it does not explicitly define any specific numerical acceptance criteria (e.g., accuracy thresholds, precision ranges) for the ABCA-NT device itself, nor does it present a table comparing such criteria to the reported performance of the new device.
- Study Details (Sample Size, Data Provenance, Experts, Adjudication, MRMC, Standalone, Ground Truth, Training Set): The document describes the principle of operation, calibration methods (using reference gas of known isotopic composition), and calculation of results. It discusses how the ABCA-NT is "faster and more convenient" than the predicate due to its triple-collector system and continuous flow. However, it does not describe any clinical or technical study that specifically evaluated the ABCA-NT's performance against predefined acceptance criteria. There is no mention of a test set, training set, ground truth, experts, or any kind of statistical analysis for performance metrics. The comparison is entirely at a conceptual and design level to argue for substantial equivalence.
In summary, the provided 510(k) summary focuses on demonstrating equivalence to an existing, pre-amendment device based on similar technology and principles, without presenting a specific performance study with clearly defined acceptance criteria and results.
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