K073091 · bioMerieux, Inc. · NBC · Feb 29, 2008 · Clinical Chemistry
Device Facts
Record ID
K073091
Device Name
VIDAS NT-PROBNP ASSAY, MODEL: 30 449
Applicant
bioMerieux, Inc.
Product Code
NBC · Clinical Chemistry
Decision Date
Feb 29, 2008
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1117
Device Class
Class 2
Indications for Use
VIDAS® NT-proBNP assay is an automated quantitative test for use on the VIDAS instruments for the determination of N-terminal fragment of B-type natriuretic peptide in human serum or plasma (lithium heparin) using the ELFA (Enzyme-Linked Fluorescent Assay) technique. The VIDAS® NT-proBNP test is used as an aid in the diagnosis of suspected congestive heart failure.
Device Story
VIDAS NT-proBNP is an automated, quantitative, sandwich enzyme-linked fluorescent immunoassay (ELFA) for use on bioMerieux VIDAS or miniVIDAS instruments. The device utilizes a disposable Solid Phase Receptacle (SPR) coated with sheep polyclonal NT-proBNP antibody. Input is human serum or lithium heparin plasma. The instrument cycles the sample and alkaline phosphatase-labeled conjugate through the SPR; unbound material is washed away. Fluorescent substrate (4-Methyl-umbelliferyl phosphate) is added; the enzyme catalyzes the production of a fluorescent product (4-methylumbelliferone). Fluorescence is measured at 450 nm; intensity is directly proportional to NT-proBNP concentration. The system provides quantitative results to clinicians to aid in the diagnosis of suspected congestive heart failure. The device is intended for prescription use in clinical laboratory settings.
Clinical Evidence
Clinical performance was evaluated across 3 sites (2 European, 1 US) using 407 samples with confirmed congestive heart failure (CHF) and 411 control samples. The overall AUC was 0.965. Sensitivity and specificity were calculated by age and gender; overall sensitivity ranged from 84.87% to 94.96% and specificity from 81.31% to 97.39% across sites. Method comparison with the predicate (n=713) showed a correlation of r=0.989, with a slope of 0.905 and intercept of -14.599.
Technological Characteristics
ELFA immunoassay; uses alkaline phosphatase-labeled sheep polyclonal NT-proBNP antibody; fluorescent substrate 4-Methyl-umbelliferyl phosphate; measurement at 450 nm. Kit includes SPRs, reagent strips, calibrators, and controls. Compatible with VIDAS/miniVIDAS instruments. Traceable to Roche purified synthetic NT-proBNP. Measurement range: 20-25,000 pg/mL. LoD: 6.7 pg/mL. LoQ: 21.9 pg/mL.
Indications for Use
Indicated for use as an aid in the diagnosis of suspected congestive heart failure in patients requiring quantitative determination of NT-proBNP in human serum or plasma.
Regulatory Classification
Identification
The B-type natriuretic peptide (BNP) test system is an in vitro diagnostic device intended to measure BNP in whole blood and plasma. Measurements of BNP are used as an aid in the diagnosis of patients with congestive heart failure.
Special Controls
*Classification.* Class II (special controls). The special control is “Class II Special Control Guidance Document for B-Type Natriuretic Peptide Premarket Notifications; Final Guidance for Industry and FDA Reviewers.”
Predicate Devices
Roche Elecsys pro-BNP Immunoassay (k022516)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k073091
B. Purpose for Submission:
Addition of NT-proBNP to bioMerieux VIDAS instruments
C. Measurand:
N-terminal pro-B type Natriuretic Peptide
D. Type of Test:
Quantitative, enzyme-linked fluorescent assay (ELFA)
E. Applicant:
bioMerieux, Inc
F. Proprietary and Established Names:
VIDAS® NT-proBNP
G. Regulatory Information:
1. Regulation section:
21 CFR § 862.1117 B-type natriuretic peptide test system
2. Classification:
Class II (special controls)
3. Product code:
NBC
4. Panel:
Clinical Chemistry (75)
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H. Intended Use:
1. Intended use(s):
See Indications for use below.
2. Indication(s) for use:
VIDAS® NT-proBNP assay is an automated quantitative test for use on the VIDAS instruments for the determination of N-terminal fragment of B-type natriuretic peptide in human serum or plasma (lithium heparin) using the ELFA (Enzyme-Linked Fluorescent Assay) technique. The VIDAS® NT-proBNP test is used as an aid in the diagnosis of suspected congestive heart failure.
3. Special conditions for use statement(s):
For prescription use
4. Special instrument requirements:
bioMerieux VIDAS and miniVIDAS instruments
I. Device Description:
Each VIDAS® NT-proBNP (PBNP) kit contains 60 tests. The kit is comprised of: 60 PBNP Reagent Strips, 60 Solid Phase Receptacles (SPR), PBNP controls (C1 and C2), PBNP calibrators (S1 and S2), Sample Diluent, and one Master Lot Entry (MLE) Card.
The PBNP Reagent Strips consist of 10 wells covered with a labeled foil seal. Five of the wells contain either conjugate (alkaline phosphatase-labeled polyclonal sheep anti-NT-proBNP antibody and preservative), wash buffer, or a cuvette with substrate (4-Methyl-umberlliferyl phosphate, dietholamine, and preservative). One well is designated for the sample and the remaining wells are empty.
The interior of the Solid Phase Receptacles (SPR) are coated with sheep polyclonal NT-proBNP antibody.
The PBNP controls (C1 and C2) are supplied with the kit as four, 2 mL vials of lyophilized human serum, NT-proBNP, and preservative; 2 vials of C1 and 2 vials of C2.
The PBNP calibrators (S1 and S2) are supplied with the kit as four, 2 mL vials of lyophilized human serum, NT-proBNP, and preservative; 2 vials of C1 and 2 vials of C2.
The PBNP diluent is ready-to-use as one 2 mL vial and contains human serum with
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preservatives.
Human source material was tested and found negative for HIV-1/2, HBsAg, and HCV by FDA or European Union approved methods.
# J. Substantial Equivalence Information:
1. Predicate device name(s):
Roche Elecsys pro-BNP Immunoassay
2. Predicate K number(s):
k022516
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Intended Use | Quantitative determination of N-terminal fragment of B-type natriuretic peptide in human serum or lithium heparin plasma. The VIDAS NT-proBNP test is used as an aid in the diagnosis of suspected congestive heart failure | Same as initial claim by Roche (k022516) |
| Antibody | Sheep NT-proBNP antibody | Same |
| Cut-off | 125 pg/mL for patients < 75 years old450 pg/mL for patients ≥ 75 years old | Same |
| Specimen Type | Serum and plasma | Same |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Assay Principle | Enzyme-Linked Fluorescent Assay (ELFA) | Electrochemiluminescence |
| Sample Volume | 200 mcL | 20 mcL |
| Hook Effect | No hook effect found up to 500,000 pg/mL | No hook effect found up to 300,000 pg/mL |
| Measurement range | 20-25,000 pg/mL | 5-35,000 pg/mL |
| Traceability | Roche NT-proBNP | Purified synthetic NTG-proBNP (1-76) in human serum matrix |
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K. Standard/Guidance Document Referenced (if applicable):
CLSI EP5-A2: Evaluation of Precision Performance of Quantitative Measurement Methods
CLSI EP17-A: Protocols for Determination of Limits of Detection and Limits of Quantitation
CLSI EP9-A2: Method Comparison and Bias Estimation Using Patient Samples
CLSI EP6-A: Evaluation of Linearity of Quantitative Measurement Procedures: A Statistical Approach
Class II Special Control Guidance Document for B-Type Natriuretetic Peptide Premarket Notifications: Final Guidance for Industry and FDA Reviewers (Nov. 30, 2000)
Guidance on Informed Consent for In Vitro Diagnostic Device Studies Using Leftover Human Specimens that are Not Individually Identifiable- Guidance for Sponsors, Institutional Review Boards, Clinical Investigators and FDA Staff (April 25, 2006)
L. Test Principle:
The VIDAS® NT-proBNP Assay is one-step, sandwich enzyme-linked fluorescent immunoassay (ELFA) performed with an automated VIDAS or a miniVIDAS instrument. A pipette tip-like disposable device, the Solid Phase Receptacle (SPR), serves as the solid phase as well as a pipettor for the assay. Reagents for the assay are pre-dispensed in the sealed PBNP Reagent Strips.
All assay steps and assay temperatures are controlled by the instrument. The sample is transferred into the wells containing the conjugate (alkaline phosphatase-labeled sheep polyclonal NT-proBNP antibody). The sample and conjugate mixture is cycled in and out of the SPR several times. Unbound sample is removed from the SPR during the wash step. During the detection step, the fluorescent substrate (4-Methyl-umberlliferyl phosphate) is cycled in and out of the SPR. The conjugate enzyme remaining in the SPR catalyzes the hydrolysis of the substrate into a fluorescent product 4-methylumbellferone. Fluorescence is measured at 450 nm wavelength by the optical scanner in the instrument. The intensity of the fluorescence is directly proportional to the concentration of analyte present in the sample.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
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# a. Precision/Reproducibility:
The precision study was performed over 10 days using five samples covering the measurement range (116.58, 508.55, 1407.06, 7,126.53, 14,528.62) assayed in duplicate in 40 different runs (2 runs per day) with two reagent lots using the same VIDAS instrument at three different sites—2 European and 1 US. Each site performed modified randomized precision studies following CLSI EP5-A2 Guidelines. 80 values per sample were generated per site $(n = 240$ values for each sample). The results presented below were evaluated for the following: repeatability, between-run within-day precision, between-day within-site precision, between-site within-lot precision, and lot-to-lot precision.
| Source of Variation | Statistics Mean (pg/mL) | C001 116.85 | C002 513.47 | C003 1066.82 | C004 7143.73 | C005 14528.62 |
| --- | --- | --- | --- | --- | --- | --- |
| Repeatability or within-run | SD (pg/mL) | 2.84 | 8.29 | 16.38 | 179.03 | 408.49 |
| | CV (%) | 2.43 | 1.61 | 1.54 | 2.51 | 2.81 |
| Run-to-run or between-run | SD (pg/mL) | 4.32 | 13.26 | 22.60 | 230.71 | 543.08 |
| | CV (%) | 3.69 | 2.58 | 2.12 | 3.23 | 3.74 |
| Day-to-day or between-day | SD (pg/mL) | 4.48 | 14.52 | 26.05 | 242.09 | 602.08 |
| | CV (%) | 3.84 | 2.83 | 2.44 | 3.39 | 4.14 |
| Inter-site or site-to-site or between site | SD (pg/mL) | 5.13 | 18.84 | 35.71 | 278.39 | 743.47 |
| | CV (%) | 4.39 | 3.67 | 3.35 | 3.90 | 5.12 |
| Inter-lot or lot-to-lot Or between-lot | SD (pg/mL) | 6.32 | 21.43 | 37.79 | 599.82 | 1083.20 |
| | CV (%) | 5.41 | 4.17 | 3.54 | 8.40 | 7.46 |
# b. Linearity/assay reportable range:
The reportable range is 20-25,000 pg/mL. 2 samples were tested for linearity. One sample was a high pool (28,459 pg/mL) and the other was a lower pool (1583 pg/mL). Each pool was diluted 13 times using the reagent kit diluent, and a pool of human samples mixed with other samples in variable proportions to cover the measurement range down to 30 pg/mL. Samples were assayed in duplicate. 30 pg/mL was the lowest concentration obtainable because the diluent is composed of human serum pool with preservatives so there is always some NT-proBNP present. The percent deviation from linearity was $10\%$ .
Recovery studies were performed on samples with NT-proBNP concentrations of 70-24,400 pg/mL. Recoveries ranged from $86.9.0\%$ to $112.9\%$ .
# c. Traceability, Stability, Expected values (controls, calibrators, or methods):
# Traceability
The assay is metrologically traceable to Roche purified synthetic NT-proBNP
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using a modification of ISO 17511.

## Stability
The calibrators and controls are lyophilized and are stable for 12 months when stored at 2-8°C. After reconstitution, they are stable for up to 8 hours at 2-8°C or up to the expiration date of the kit when stored at -25±6°C. Calibrators and controls may be frozen and thawed up to 6 times.
The stability protocols and acceptance criteria were reviewed and found to be acceptable.
## d. Detection limit:
Four samples were analyzed over a period of 4 days on one instrument using one lot of reagents. They consisted of 2 standards, a blank containing no NT-proBNP, and a high standard with a concentration of 51.8 pg/mL of NT-proBNP. Two low level samples with values of 13.64 pg/mL and 14.16 pg/mL were also analyzed.
Limit of Blank (LoB) was defined as corresponding to the 95th percentile of blank signal values. 6 replicates were assayed 10 times for n=60. Based on the sponsor's analysis and acceptance criteria, the LoB = 3.4 pg/mL.
Limit of Detection (LoD) was defined as the concentration corresponding to the signals from the two low level samples along a curve drawn between the blank and the high standard, rounded to the upper value. 2 replicates of each sample were assayed 15 times for a total of 30 measurements per sample (n=60). The LoD signal for the two samples was calculated using the formula LoD = LoB signal + cβ SDs where the SDs are the estimated pooled standard deviation of the low level sample signals and cβ is derived from the 95th percentile of the standard Gaussian distribution and corrected for degrees of freedom of the estimated standard deviations. Based on the sponsor's analysis
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and acceptance criteria, the $\mathrm{LoD} = 6.7\mathrm{pg / mL}$ . The sponsor claims a limit of detection of $< 20~\mathrm{pg / mL}$ .
Limit of Quantitation (LoQ) was defined as the lowest concentration that can be measured with an inter-assay CV of $20\%$ . Twelve samples ranging from 10 to $39~\mathrm{pg / mL}$ were tested in duplicate on one instrument for 9 days over a period of 15 days. The value obtained for LoQ was $21.9~\mathrm{pg / mL}$ .
# e. Analytical specificity:
Analytical specificity (cross-reactivity) was evaluated by spiking each cross-reactant into serums containing target concentrations of 0, 255, $1483~\mathrm{pg / mL}$ NT-proBNP. A control for each cross-reactant was prepared by spiking the samples with the same volume of the solvent used for reconstituting the cross-reactant. The cross-reactant test samples and the control samples were measured on the VIDAS and the cross-reactivity was calculated. Acceptance criteria was the percent of cross-reactivity must be $< 0.1\%$ for all samples, interference ratios are within $99.8\%$ confidence interval (CI) for the within lot precision profile. The following compounds do not cross-react.
| Tested compound | Tested concentration | Cross-reactivity % |
| --- | --- | --- |
| Adrenomodullin | 1.0 ng/mL | < 0.1% |
| Aldosterone | 0.6 ng/mL | < 0.1% |
| Angiotensin I | 0.6 ng/mL | < 0.1% |
| Angiotensin II | 0.6 ng/mL | < 0.1% |
| Angiotensin III | 1.0 ng/mL | < 0.1% |
| ANP28, | 3.1 μg/mL | < 0.1% |
| Arg-vasopressin | 1.0 ng/mL | < 0.1% |
| BNP32 | 3.5 μg/mL | < 0.1% |
| CNP22 | 2.2 μg/mL | < 0.1% |
| Endothelin | 20 pg/mL | < 0.1% |
| NT-proANP1-30 | 3.5 μg/mL | < 0.1% |
| NT-proANP31-67 | 1.0 ng/mL | < 0.1% |
| NT-proANP79-98 | 1.0 ng/mL | < 0.1% |
| Renin | 50 ng/mL | < 0.1% |
| Urodilatin | 3.5 μg/mL | < 0.1% |
Interference from endogenous substances were evaluated for hemoglobin, triglycerides, bilirubin, human serum albumin (HSA), human IgG, IgM, rheumatoid factors (RF), anti-alkaline phosphatase (anti-ALP) and dialysis patients.
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```markdown
# Hemoglobin, Bilirubin, Triglycerides
Samples containing approximately 24, 325, 3600 and 14,500 pg/mL NT pro-BNP were spiked with the appropriate concentration of the test substance. NT-proBNP recovery of the sample was compared to that of a control sample. Hemoglobin up to 300 micM (485 g/dL), bilirubin up to 510 micM (29 mg/dL), and triglycerides up to 30 g/L did not interfere with the test. As a further precaution, the device labeling recommends that samples appearing hemolyzed, icteric, or lipemic not be used and that, if possible, a new sample be collected.
# HSA, IgG, IgM, rheumatoid factors, anti-ALP and dialysis samples
Recovery studies were performed to determine interference from HSA, IgG, IgM, RF, anti-ALP and dialysis. A NT-proBNP positive sample (1278.6-1585.8 pg/mL) and a NT-proBNP negative sample (<20-39.8 pg/mL) were used for the studies. There was no IgG, or IgM interference at 1.7 g/dL and 0.6 g/dL respectively.
HSA was evaluated at three doses, 10.5 g/dL, 14.5 g/dL and 19.5 g/dL in the negative and positive NT-proBNP samples. The negative NT-proBNP sample showed interference at the 10.5 g/dL dose of HSA. There was no interference in the positive NT-proBNP sample.
Recovery studies were performed for rheumatoid factor-positive samples, dialysis samples and anti-alkaline phosphatase samples using positive and negative NT-proBNP samples. Dialysis and the anti-alkaline phosphatase (anti-ALP) samples were evaluated by spiking them with known concentrations of the positive and negative NT-proBNP samples from above. These were compared to a "reference sample" composed of a mixture of the positive and negative NT-proBNP samples.
| Interferent | Interferent dose range | Recovery range of all samples |
| --- | --- | --- |
| Rheumatoid factor | 40 IU/mL-1,560 IU/mL | 84.6%-101.9% |
| Dialysis | NA | 88.2%-102.1% |
| Anti-ALP | NA | 88.4%-94.4% |
# Drug Interference
The effect of 39 frequently administered drugs was tested in vitro. No interference was observed.
## f. Assay cut-off:
Assay cutoffs were established based on the Roche Elecsys proBNP assay which the VIDAS assay claims traceable to.
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125 pg/mL for < 75 years old
450 pg/mL for > 75 years old
## 2. Comparison studies:
### a. Method comparison with predicate device:
713 clinical samples from 3 sites were analyzed on the VIDAS and the predicate device, Roche Elecsys across the measurement range of 20-25,000 pg/mL. For method comparison against the predicate, 104 samples were included although they had values <20 pg/mL or were beyond the measurement range and had to be diluted. 224 samples were from a biochemical laboratory in Europe (Site 1), 203 samples from a European hospital (Site 2) and 182 samples from a medical center in the USA (Site 3). Slope = 0.905 and intercept = -14.599 for the combined sites met the sponsor's acceptance criteria of 95% confidence interval (slope 0.896-0.915, intercept -19.031 - -12.120). r = 0.989.
Total concordance between the VIDAS and the predicate using the 713 clinical samples at the cutoffs of 125 pg/mL for subjects < 75 years old and 450 pg/mL for subjects > 75 years old are shown in the table below.
Concordance-all sites combined
| | Elecsys pro- BNP | | | |
| --- | --- | --- | --- | --- |
| | | + | - | Total |
| VIDAS | + | 505 | 1 | 506 |
| NT-proBNP | - | 15 | 192 | 207 |
| Total | | 520 | 193 | 713 |
Concordance met the sponsor's acceptance criteria of 95% confidence interval.
Negative Percent Agreement = 97.12% (95.29%-98.38%)
Positive Percent Agreement = 99.48% (97.15%-99.99)
Overall Agreement = 97.76% (96.38%-98.71%)
### b. Matrix comparison:
In order to demonstrate equivalence between serum and plasma, three different tube types, gel separator, EDTA, and lithium heparin, were compared to a plain tube (no anticoagulants or gel). Two manufacturers' products were used. 63 patient samples were collected. Samples were native and spiked to cover the entire measurement range (<20-24,499.2 pg/mL).
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Results were compared to those of the plain tube. Passing and Bablock regression data of lithium heparin plasma and gel separator tubes to the plain tubes had slopes of 0.98 and 1.00, intercepts of -2.2 and 7.2 respectively. The sponsor's acceptance criteria were: slope 0.9-1.1, intercept $< 20~\mathrm{pg / mL}$ , $\mathrm{CV} > 0.95$ . Based on these studies it was determined that the gel separator (serum) or lithium heparin were appropriate preservatives. EDTA showed nonconformity and is not recommended for use in the labeling.
# 3. Clinical studies:
Clinical studies were performed at 3 sites, 2 European and 1 US, which represented 407 samples with confirmed congestive heart failure (CHF). 147 samples were from European Site 1, 139 samples were from European Site 2, and 119 were from the US Site. The reference group consisted of 411 samples from prospective subjects that presented to the Emergency Department or Clinical Investigation Center at a European site with neither a history of CHF nor cardiac nor circulatory diseases. Sensitivities, specificities and positive and negative predictive values are shown with the $95\%$ CI and are broken down by site, age and gender.
# a. Clinical Sensitivity:
European Site 1
| Statistics | All patients | < 75 yrs. | ≥ 75 yrs. |
| --- | --- | --- | --- |
| Sensitivity (%) | 94.63 (89.64-97.29) | 100 (94.81-100) | 89.47 (80.36-94.64) |
| Specificity (%) | 97.39 (93.36-99.00) | 97.27 (92.14-99.09) | 97.67 (87.63-99.6) |
European Site 2
| Statistics | All patients | < 75 yrs. | ≥ 75 yrs. |
| --- | --- | --- | --- |
| Sensitivity (%) | 94.96 (89.84-97.57) | 94.23 (84.08-98.06) | 95.4 (88.58-98.23) |
| Specificity (%) | 96.69 (92.37-98.6) | 96.36 (90.87-98.6) | 97.56 (87.09-99.58) |
US Site
| Statistics | All patients | < 75 yrs. | ≥ 75 yrs. |
| --- | --- | --- | --- |
| Sensitivity (%) | 84.87 (77.18-90.3) | 82.86 (72.14-90.02) | 87.76 (75.46-94.35) |
| Specificity (%) | 81.31 (72.69-87.67) | 81.82 (72.88-88.28) | 75 (40.31-93.02) |
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Males: All sites combined
| Statistics | Males | Males < 75 yrs. | Males ≥ 75 yrs. |
| --- | --- | --- | --- |
| Sensitivity (%) | 92.92 (88.85-95.57) | 94.07 (88.6-97.01) | 91.43 (84.33-95.48) |
| Specificity (%) | 95.67 (92.13-97.66) | 95.31 (91.23-97.55) | 97.44 (86.49-99.56) |
Females: All sites combined
| Statistics | Females | Females < 75 yrs. | Males ≥ 75 yrs. |
| --- | --- | --- | --- |
| Sensitivity (%) | 90.42 (84.87-94.07) | 88.33 (77.56-94.31) | 91.59 (84.61-95.57) |
| Specificity (%) | 89.44 (83.98-93.2) | 87.4 (80.35-92.17) | 94.34 (84.36-98.1) |
# b. Clinical specificity:
See Clinical Sensitivity above.
c. Other clinical supportive data (when a. and b. are not applicable):
# 4. Clinical cut-off:
Assay cutoffs were established based on the Roche Elecsys proBNP assay which the VIDAS assay is traceable to. Recommended clinical thresholds are $125~\mathrm{pg / mL}$ for patients younger than 75 years and $450~\mathrm{pg / mL}$ for patients 75 years and older. Since the incidence of CHF increases with age, age matched Receiver Operator Curves (ROC) were calculated for each stratification: $< 45$ , 45-54, 55-64, 65-75 and $\geq 75$ years old. The optimum cut-off maximizes the area under the curve (AUC) and represents the highest sensitivity and specificity for the assay. The overall area under the curve (AUC) for the VIDAS NT-proBNP assay was 0.965.
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# 5. Expected values/Reference range:
Assay cutoffs were established based on the Roche Elecsys proBNP assay which the VIDAS assay is traceable to.
125 pg/mL for $< 75$ years old
450 pg/mL for $>75$ years old
Results were stratified by age groups and genders. Patients with results $< 20$ pg/mL were not included in the mean and standard deviation calculations.
| Males | < 45 years | 45 – 54 years | 55 – 64 years | 65 – 74 years | < 75 years | ≥ 75 years |
| --- | --- | --- | --- | --- | --- | --- |
| Mean* | 332.6 | 62.2 | 110.9 | 57.9 | 151.2 | 147.0 |
| Standard deviation* | 971.8 | 42.8 | 206.2 | 32.1 | 532.7 | 131.6 |
| Median | < 20 | < 20 | < 20 | 40 | < 20 | 90 |
| 95th percentile | 334.5 | 107.5 | 153.5 | 123 | 131.5 | 438 |
| % < Cut-off | 93.2 | 97.0 | 95.0 | 100.0 | 95.3 | 97.4 |
| N | 74 | 67 | 40 | 11 | 192 | 39 |
| Females | < 45 years | 45 – 54 years** | 55 – 64 years | 65 – 74 years | < 75 years** | ≥ 75 years |
| --- | --- | --- | --- | --- | --- | --- |
| Mean* | 141.5 | 637.7 | 73.3 | 107.7 | 253.7 | 178.6 |
| Standard deviation* | 309.3 | 2208.5 | 29.4 | 42.7 | 1146.3 | 141.1 |
| Median | 20.5 | < 21 | 41 | 92.5 | 25 | 131 |
| 95th percentile | 618.5 | 4909 | 116.5 | 191 | 251.5 | 533 |
| % < Cut-off | 91.4 | 77.8 | 96.0 | 75.0 | 87.4 | 94.3 |
| N | 58 | 36 | 25 | 8 | 127 | 53 |
| Males and Females | < 45 years | 45 – 54 years** | 55 – 64 years | 65 – 74 years | < 75 years** | ≥ 75 years |
| --- | --- | --- | --- | --- | --- | --- |
| Mean* | 213.1 | 334.8 | 93.3 | 79.7 | 204.8 | 165.2 |
| Standard*deviation | 639.8 | 1525.4 | 150.8 | 43.9 | 905.0 | 137.3 |
| Median | < 20 | < 20 | < 20 | 63 | < 20 | 120 |
| 95th percentile | 263 | 173.5 | 123 | 191 | 174 | 469 |
| % < Cut-off | 92.4 | 90.3 | 95.4 | 89.5 | 92.2 | 95.7 |
| N | 132 | 103 | 65 | 19 | 319 | 92 |
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N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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Part 1 — Search, results, and everyday workflows 16 min
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1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.