The MULTIGENT Creatinine (Enzymatic) assay is a device intended to measure creatinine levels in human serum, plasma, and urine using the ARCHITECT c8000 System and the AEROSET System. Creatinine measurements are used in the diagnosis and treatment of renal diseases, in monitoring renal dialysis, and as a component of various calculations for determination or estimation of creatinine clearance, glomerular filtration rate (GFR) or estimated GFR (eGFR).
Device Story
The MULTIGENT Creatinine (Enzymatic) Assay is a dual-reagent, liquid, ready-to-use kit for use on Abbott ARCHITECT c8000 and AEROSET systems. The assay utilizes enzymatic colorimetry to measure creatinine levels in human serum, plasma, and urine. Reagent 1 contains creatinase, sarcosine oxidase, ascorbate oxidase, and catalase; Reagent 2 contains creatininase and peroxidase. The reaction produces a quinoneimine dye, with absorbance measured at 548 nm. The change in absorbance is proportional to creatinine concentration. The device is intended for clinical laboratory use by trained personnel. Results assist clinicians in diagnosing renal disease, monitoring dialysis, and calculating GFR or creatinine clearance. The assay is traceable to IDMS values via SRM967.
Clinical Evidence
Bench testing only. Performance evaluated per CLSI guidelines (EP5-A, EP6-A, EP17-A, EP9-A2). Precision studies showed total CVs < 2% for serum and < 1.5% for urine. Linearity confirmed for serum (0.1-40 mg/dL) and urine (2.5-400 mg/dL). Method comparison against predicate yielded correlation coefficients of 0.999-1.000. Interference testing identified alpha-methyldopa as an interferent in serum; EDTA is not recommended as an anticoagulant due to -9.1% bias.
Technological Characteristics
Enzymatic colorimetric assay. Reagents: creatininase, creatinase, sarcosine oxidase, peroxidase, 4-aminoantipyrine, ESPMT. Sensing: spectrophotometric absorbance at 548 nm. Platform: AEROSET and ARCHITECT c8000 automated clinical chemistry analyzers. Calibration: traceable to IDMS.
Indications for Use
Indicated for the quantitative measurement of creatinine in human serum, plasma, and urine to aid in the diagnosis and treatment of renal diseases and monitoring of renal dialysis in adult populations.
Regulatory Classification
Identification
A creatinine test system is a device intended to measure creatinine levels in plasma and urine. Creatinine measurements are used in the diagnosis and treatment of renal diseases, in monitoring renal dialysis, and as a calculation basis for measuring other urine analytes.
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k073634
B. Purpose for Submission:
New Device
C. Measurand:
Creatinine
D. Type of Test:
Enzymatic, quantitative
E. Applicant:
Sentinel CH. SpA
F. Proprietary and Established Names:
MULTIGENT Creatinine (Enzymatic) Assay
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JFY | Class II | 21 CFR§ 862.1225
Creatinine test system | 75 - Clinical Chemistry |
H. Intended Use:
1. Intended use(s):
See indications for use below.
2. Indication(s) for use:
The MULTIGENT Creatinine (Enzymatic) assay is a device intended to measure
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creatinine levels in human serum, plasma, and urine using the ARCHITECT c8000 System and the AEROSET System. Creatinine measurements are used in the diagnosis and treatment of renal diseases, in monitoring renal dialysis, and as a component of various calculations for determination or estimation of creatinine clearance, glomerular filtration rate (GFR) or estimated GFR (eGFR).
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
Abbot ARCHITECT c8000 and AEROSET systems
I. Device Description:
The MULTIGENT Creatinine (Enzymatic) Assay is a dual reagent kit. Reagent one contains Good's buffer, creatinase, sarcosine oxidase, ascorbate oxidase, catalase and ESPMT (N-ethyl-N-sulfopropyl-M-toluidine). Reagent 2 contains Good's buffer, creatininase, peroxidase and 4-Aminoantipyrine.
J. Substantial Equivalence Information:
1. Predicate device name(s):
Roche Creatinine Plus Assay
2. Predicate K number(s):
k003261
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Form | Liquid, ready to use | Same |
| Test Method | Enzymatic colorimetry | Same |
| Sample | Serum, plasma, urine | Same |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Measuring Range | Serum: 0.10-40 mg/dl | Serum:0.03-30 mg/dl |
| | Plasma: 0.10-40 mg/dl | Plasma: 0.03-30 mg/dl |
| | Urine: 2.5-400 mg/dl | Urine: 0.3-400 mg/dl |
| Instruments | Abbott Aeroset and Architect systems | Roche Hitachi 911 system |
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K. Standard/Guidance Document Referenced (if applicable):
CLSI EP5-A, CLSI EP-6A, CLSI EP17A, and CLSI EP9-A2
L. Test Principle:
Creatininase (in reagent 1) hydrolyzes creatinine in a sample to creatine. Creatine is hydrolyzed by creatinase to sarcosine and urea. Sarcosine from this reaction is oxidized by sarcosine oxidase to glycine and formaldehyde and hydrogen peroxide. The hydrogen peroxide reacts with 4-aminoantipyrine and ESPMT in the presence of peroxidase to yield a quinoneimine dye. The resulting change in absorbance at 548 nm is proportional to the creatinine concentration in the sample.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
i.) Precision studies for serum samples were evaluated using CLSI EP5-A as a guideline. For within-run (intra-assay) and total precision studies, testing was performed on both Architect c8000 and Aeroset systems. For within-run precision, 3 serum controls were run in singlet for one day. For total precision, 3 serum controls were tested twice daily, in duplicate, for over 20 days. Results of the precision studies were shown below:
| MULTIGENT Creatinine (Enzymatic)
ARCHITECT Serum Precision | | | | |
| --- | --- | --- | --- | --- |
| Intra-Assay Precision | | | | |
| Control | | Level 1 | Level 2 | Level 3 |
| N | | 20 | 20 | 20 |
| Mean (mg/dL) | | 0.623 | 0.958 | 3.752 |
| Intra-assay | SD | 0.0055 | 0.0052 | 0.0089 |
| | %CV | 0.88 | 0.55 | 0.24 |
Total Precision
| N | | 80 | 80 | 80 |
| --- | --- | --- | --- | --- |
| Mean (mg/dL) | | 0.654 | 1.827 | 6.604 |
| Within Run | SD | 0.0042 | 0.0061 | 0.0199 |
| | %CV | 0.64 | 0.33 | 0.30 |
| Between Day | SD | 0.0173 | 0.0265 | 0.0300 |
| | %CV | 2.65 | 1.45 | 0.45 |
| Between Run | SD | 0.0100 | 0.0173 | 0.0520 |
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| MULTIGENT Creatinine (Enzymatic)
AEROSET Serum Precision | | | | |
| --- | --- | --- | --- | --- |
| Intra-Assay Precision | | | | |
| Control | | Level 1 | Level 2 | Level 3 |
| N | | 20 | 20 | 20 |
| Mean (mg/dL) | | 0.624 | 0.973 | 3.746 |
| Intra-assay | SD | 0.0059 | 0.0080 | 0.0190 |
| | %CV | 0.94 | 0.82 | 0.51 |
Total Precision
| N | | 80 | 80 | 80 |
| --- | --- | --- | --- | --- |
| Mean (mg/dL) | | 0.647 | 1.826 | 6.606 |
| Within Run | SD | 0.0077 | 0.0077 | 0.0165 |
| | %CV | 1.19 | 0.42 | 0.25 |
| Between Day | SD | 0.0100 | 0.0224 | 0.0374 |
| | %CV | 1.55 | 1.23 | 0.57 |
| Between Run | SD | 0.0000 | 0.0000 | 0.0245 |
| | %CV | 0.00 | 0.00 | 0.37 |
| Total | SD | 0.0126 | 0.0237 | 0.0475 |
| | %CV | 1.95 | 1.30 | 0.72 |
ii.) Precision studies for urine samples were evaluated according to the CLSI EP5-A guideline. For total precision studies, two urine controls were tested twice daily, in duplicate, for over 20 days and were assayed on both the Architect c8000 and the Aeroset system. Urine controls were diluted x 10 with 0.9% saline before testing. Results of the total precision studies were shown below:
| MULTIGENT Creatinine (Enzymatic)
ARCHITECT Urine Precision
Total precision Data Summary | | |
| --- | --- | --- |
| Control | Level 1 | Level 2 |
| N | 80 | 80 |
| Mean (mg/dL) | 69.940 | 124.724 |
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| MULTIGENT Creatinine (Enzymatic) AEROSET Urine Precision Total precision Data Summary | | | |
| --- | --- | --- | --- |
| Control | | Level 1 | Level 2 |
| N | | 80 | 80 |
| Mean (mg/dL) | | 68.769 | 121.937 |
| Within Run | SD | 0.8699 | 1.4059 |
| | %CV | 1.26 | 1.15 |
| Between Day | SD | 0.3317 | 0.2387 |
| | %CV | 0.48 | 0.20 |
| Between Run | SD | 0.4136 | 0.5834 |
| | %CV | 0.60 | 0.48 |
| Total | SD | 0.9023 | 1.5033 |
| | %CV | 1.31 | 1.23 |
# b. Linearity/assay reportable range:
Linearity study was assessed according to CLSI EP-6A.
i.) Serum samples: Serum linearity was assessed on three different ranges of human sera: whole analytical measuring range (2.3 to $53\mathrm{mg / dL}$ ), pathologic analytical measuring range (pre dialysis range of 0.39 to $9.7\mathrm{mg / dL}$ ) and low analytical measuring range (0.04 to $2.2\mathrm{mg / dL}$ ). The spiked pools were serially diluted to obtain a set of at least 10 samples with proportionally decreased concentrations of creatinine. Serum sample pools were assayed in triplicates. The sponsor's acceptance criterion was a bias of $5\%$ between the expected values and the observed values. The study supported the sponsor's linearity claim range of 0.1 to $40.0\mathrm{mg / dL}$ .
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ii.) Urine samples: Urine linearity was assessed on a pool of human urine that was spiked with a concentrated solution to obtain a final analyte concentration exceeding the targeted high linearity and was serially diluted to obtain a set of at least 12 samples with proportionally decreased concentrations of creatinine. The study covered the entire analytical measuring range (22.9 to 476.6 mg/dL) and the low analytical measuring range (2.39 to 52.45 mg/dL). Urine sample pools were run in triplicates and the sponsor's acceptance criterion was a bias of 5% between the expected values and the observed values. The study supported the sponsor's linearity claim range of 2.5 to 400 mg/dL.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The assay is traceable to IDMS values through SRM967.
This device does not include the calibrator materials. The sponsor's labeling recommends using the MULTIGENT Clin Chem Calibrators (cleared in k070971). The sponsor states that the recommended calibrators are stable for 60 days when stored on-board and is required for each new lot of reagent.
The sponsor conducted open on-board, closed stability (reagent) and calibration stability of reagents 1 and 2 on both the ARCHITECT c8000 and AEROSET systems. On-board stability of the assay reagents was conducted with new calibrators, two control materials and a prepared human serum sample and calibrator were analyzed over 98 days- every 3 to 4 days. Shelf-life stability was determined using an accelerated stability study. The sponsor's on-board/open stability for the MULTIGENT Creatinine (Enzymatic) Assay reagents is stable up to 60 days at 2-10° C and has a shelf life stability of 120 days when stored at 2-8° C.
d. Detection limit:
i.) A detection limits study was performed according to the CLSI EP17A guideline for the serum samples. The serum LOB was determined by assaying saline and human control serum in replicates of 20 for 3 different runs on the Aeroset and Architect instruments. The serum LOD was determined by assaying a human control serum mixed with a pool of human sera (for a concentration 4 to 6 times higher than the found LOB) assayed in 20 replicates for 3 different runs on the Aeroset and Architect instruments. The serum LOQ was determined with a pool of human sera with concentrations around the clinical decision level (1.00 mg/dL). The sera pool was serially diluted with a commercially available analyte free human serum material. Each sample was tested on the Aeroset and the Architect in replicates of 10. The sponsor's acceptance criterion was a total error no greater than 15% (defined by the sponsor as %bias + 2X %CV). The detection limits study supported the sponsor's measuring range claims of 0.1-40.0
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mg/dL for serum samples.
Serum results:
| Analytical Item | Instrument | Sample | N | mg/dL |
| --- | --- | --- | --- | --- |
| LoB | Aeroset | Saline | 60 | 0.0097 |
| LoB | Aeroset | Negative serum | 60 | 0.0154 |
| LOD | Aeroset | Low Serum | 60 | 0.0589 |
| LOQ | Aeroset | Serum | 10 | 0.092 |
| | | | | |
| LoB | C8000 | Saline | 60 | 0.0076 |
| LoB | C8000 | Negative serum | 60 | 0.0086 |
| LOD | C8000 | Low serum | 60 | 0.0523 |
| LOQ | C8000 | Serum | 10 | 0.092 |
ii.) A detection limit study was performed according to the CLSI EP17A guideline for the urine samples. The urine LOB was determined by assaying saline in replicates of 20 for 3 different runs on the Aeroset and Architect instruments. The urine LOD was determined by assaying human urine that was diluted with saline (for a creatine concentration around 5 to 6 times higher than the found LOB) and run in 20 replicates in 3 different runs on the Aeroset and Architect instruments. The urine LOQ was determined with two human urine samples with a concentration about 40 mg/dL. The samples were serially diluted with saline to obtain two set of samples with decreased concentrations of creatinine and run in replicated of 10 on the Aeroset and Architect instruments. The detection limits study supported the sponsor's measuring range claims of 2.5-400.0 mg/dL for the urine samples.
Urine results:
| Analytical Item | Instrument | Sample | N | mg/dL |
| --- | --- | --- | --- | --- |
| LoB | Aeroset | Saline | 60 | 0.097 |
| LOD | Aeroset | Diluted urine | 60 | 0.676 |
| LOQ | Aeroset | Urine | 10 | 2.02 |
| | | | | |
| LoB | C8000 | Saline | 60 | 0.061 |
| LOD | C8000 | Diluted urine | 60 | 0.671 |
| LOQ | C8000 | Urine | 10 | 1.74 |
e. Analytical specificity:
The MULTIGENT Creatinine (Enzymatic) Assay was evaluated for
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interferences caused by bilirubin (conjugated and unconjugated), hemoglobin, triglyceride (intralipid), creatine, ascorbic acid, and glucose in serum samples. The MULTIGENT Creatinine (Enzymatic) Assay was also evaluated for interferences caused by ascorbic acid, glucose, hemoglobin, conjugated bilirubin, protein (albumin) and pH in urine samples. The following substances demonstrated no significant bias as defined by the sponsor as $+/-$ $8\%$ difference between the interferent result and the unspiked result.
MULTIGENT Creatinine (Enzymatic)
Serum - Endogenous Interferent Summary
| Interfering Substance | Interfering Substance Concentration | Target (mg/dL) | Observed (mg/dL) | % Recovery | % Interference at 1 mg/dL |
| --- | --- | --- | --- | --- | --- |
| Bilirubin (conjugated) | 39.6 mg/dL | 1.09 | 1.01 | 92.6% | -8.0% |
| Bilirubin (unconjugated) | 46.2 mg/dL | 0.99 | 0.94 | 94.9% | -5.0% |
| Hemoglobin | 1000 mg/dL | 1.044 | 0.97 | 92.9% | -7.4% |
| Triglyceride* | 2,000 mg/dL | 0.981 | 0.94 | 95.8% | -4.1% |
| Creatine | 100 mg/dL | 1.16 | 1.21 | 104.3% | +5.0% |
| Ascorbic Acid | 120 mg/dL | 1.16 | 1.09 | 94.0% | -7.0% |
| Glucose | 6,000 mg/dL | 1.15 | 1.10 | 95.7% | -5.0% |
MULTIGENT Creatinine (Enzymatic)
Urine - Endogenous Interferent Summary
| Interfering Substance | Maximum Interfering Substance Concentration | Target (mg/dL) | Observed (mg/dL) | % Recovery |
| --- | --- | --- | --- | --- |
| Ascorbic Acid | 250 mg/dL | 78.86 | 79.29 | 100.5% |
| Glucose | 3,000 mg/dL | 81.71 | 78.98 | 96.7% |
| Hemoglobin | 1,000 mg/dL | 80.90 | 83.85 | 103.6% |
| Conjugated Bilirubin | 400 mg/dL | 81.42 | 76.00 | 93.4% |
| Proteins (albumin) | 300 mg/dL | 78.41 | 80.93 | 103.1% |
The sponsor conducted a urine preservative study to determine compatibility of different preservatives that may be used for urine sample collection with the device. The sponsor determined that the following seven preservatives at the stated concentrations caused no interferences.
- Boric acid to $1000\mathrm{mg / dL}$
Hydrochloric acid (6N) to $5\mathrm{mL} / \mathrm{dL}$
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- Acetic acid (8.5N) to 10 mL/dL
- Nitric acid (6N) to 6 mL/dL
- Sodium Carbonate to 1.5 g/dL
- Sodium Oxalate to 70 mg/dL
- Sodium Fluoride to 500 mg/dL
The sponsor conducted a drug interferent study with the MULTIGENT Creatinine (Enzymatic) Assay. The following drugs, when spiked into serum or urine samples were tested at a low and high level and the only one that interfered was alpha-methyldopa in serum. This is noted in the package insert.
Summary of Drug Interference Results – Serum
| Drug Name | Drug Units | Low Drug Conc. | Maximum %Bias | Pass Fail | High Drug Conc. | Maximum% Bias | Pass Fail |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Acetaminophen | μmol/L | 132.4 | -1.2% | Pass | See Note 1 below. | | |
| Acetazolamide | μmol/L | 270 | 0.6% | Pass | 400 | 0.6% | Pass |
| Acetylsalicylic acid | mmol/L | 3.62 | -1.7% | Pass | 5 | -0.8% | Pass |
| Ascorbic acid | μmol/L | 342 | 0.8% | Pass | 500 | 0.8% | Pass |
| Cefazolin | μmol/L | 2643 | -0.8% | Pass | 4000 | -2.5% | Pass |
| Chlorothiazide | μmol/L | 67.6 | 2.5% | Pass | 100 | 2.5% | Pass |
| Cimetidine | μmol/L | 252 | 1.7% | Pass | 500 | 0.0% | Pass |
| Digoxin | nmol/L | 7.8 | -0.8% | Pass | 10 | -0.8% | Pass |
| Furosemide | μmol/L | 181 | -0.8% | Pass | 250 | -0.8% | Pass |
| Gliclazide | μmol/L | 100 | 2.5% | Pass | 200 | 1.6% | Pass |
| Ibuprofen | μmol/L | 2425 | -1.7% | Pass | 5000 | -1.7% | Pass |
| Phenidione | μmol/L | 75 | 2.5% | Pass | 150 | 1.6% | Pass |
| Ranitidine | μmol/L | 19.1 | 0.8% | Pass | 30 | -0.8% | Pass |
| Spironolactone | μmol/L | 1.44 | -0.8% | Pass | 3 | -0.8% | Pass |
| Triamterene | μmol/L | 35 | -0.8% | Pass | 50 | -0.8% | Pass |
| Alpha-methyldopa | μmol/L | 71 | -20.8% | Fail | 100 | -25.8% | Fail |
| Dexamethasone | μmol/L | 1.53 | -1.7% | Pass | 3 | -0.8% | Pass |
| Nitrofurantoin | μmol/L | 16.8 | -0.8% | Pass | 30 | -0.8% | Pass |
Note 1: Due to the low solubility of acetaminophen in water, only one concentration was tested.
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Summary of Drug Interference Results - Urine
| Drug Name | Drug Units | Drug Conc. | Maximum %Bias | Pass/Fail | Drug Conc. | Maximum %Bias | Pass/Fail |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Acetaminophen | μmol/L | 132.4 | -3.2% | Pass | See Note 1 below. | | |
| Acetazolamide | μmol/L | 270 | -2.2% | Pass | 400 | -2.1% | Pass |
| Acetylsalicylic acid | mmol/L | 3.62 | 1.2% | Pass | 5 | 0.5% | Pass |
| Ascorbic acid | μmol/L | 342 | 2.5% | Pass | 500 | 2.9% | Pass |
| Cefazolin | μmol/L | 2643 | 3.9% | Pass | 4000 | 1.0% | Pass |
| Chlorothiazide | μmol/L | 67.6 | 2.2% | Pass | 100 | 2.7% | Pass |
| Cimetidine | μmol/L | 252 | 1.7% | Pass | 500 | 1.7% | Pass |
| Digoxin | nmol/L | 7.8 | 2.0% | Pass | 10 | 1.7% | Pass |
| Furosemide | μmol/L | 181 | -0.9% | Pass | 250 | 1.2% | Pass |
| Gliclazide | μmol/L | 100 | -3.2% | Pass | 200 | 0.9% | Pass |
| Ibuprofen | μmol/L | 2425 | 1.5% | Pass | 5000 | 2.9% | Pass |
| Phenidione | μmol/L | 75 | -3.2% | Pass | 150 | -3.0% | Pass |
| Ranitidine | μmol/L | 19.1 | 1.3% | Pass | 30 | 1.2% | Pass |
| Spironolactone | μmol/L | 1.44 | -0.5% | Pass | 3 | -1.5% | Pass |
| Triamterene | μmol/L | 35 | -3.1% | Pass | 50 | 0.9% | Pass |
| Alpha-methyldopa | μmol/L | 71 | 1.0% | Pass | 100 | 1.2% | Pass |
| Dexamethasone | μmol/L | 1.53 | 0.3% | Pass | 3 | 0.9% | Pass |
| Nitrofurantoin | μmol/L | 16.8 | 1.6% | Pass | 30 | -1.8% | Pass |
Note 1: Due to the low solubility of acetaminophen in water, only one concentration was tested.
f. Assay cut-off:
Not applicable.
2. Comparison studies:
a. Method comparison with predicate device:
A comparison study was performed using CLSI EP9-A2 as a guideline and available enzymatic method as a reference on both instruments for serum and urine. The chart below lists the linear equations, ranges, matrix and instruments.
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i.) The serum method comparison contained eighty native samples ranging from 0.320 to $19.700\mathrm{mg / dL}$ and fourteen spiked samples that ranged from 20.91 to $39.15\mathrm{mg / dL}$ . Results of the method comparison study were shown below:
MULTIGENT Creatinine (Enzymatic) - Serum
Method Comparison
| Regression Parameter | AEROSET vs. Hitachi | ARCHITECT vs. Hitachi | ARCHITECT vs. AEROSET |
| --- | --- | --- | --- |
| Slope | 1.00 (0.992 to 1.007) | 1.011 (1.003 to 1.019) | 1.028 (1.003 to 1.018) |
| Y - Intercept | -0.025 (-0.222 to 0.082) | -0.100 (-0.205 to 0.005) | -0.079 (-0.182 to 0.023) |
| Correlation Coefficient | .999 | 0.999 | .999 |
| Range of all samples tested (mg/dL) | 0.32 to 38.58 | 0.32 to 38.58 | 0.31 to 39.24 |
| Std. Error of estimate (Sy/X) | 0.349 | 0.381 | 0.371 |
| Average Bias (mg/dL) | -0.019 (-0.090 to 0.053) | -0.006 (-0.86 to 0.075) | 0.013 (-0.066 to 0.091) |
| N | 94 | 94 | 94 |
ii.) The urine method comparison study contains 60 native samples ranging from 5.98 to $398.26\mathrm{mg / dL}$ collected from volunteers. Samples over $20\mathrm{mg / dL}$ are automatically diluted x10 by the ARCHITECT and AEROSET analyzers.
MULTIGENT Creatinine (Enzymatic) - Urine
Method Comparison
| Regression Parameter | AEROSET vs. Hitachi | ARCHITECT vs. Hitachi | ARCHITECT vs. AEROSET |
| --- | --- | --- | --- |
| Slope | 0.964 (0.955 to 0.973) | 0.986 (0.980 to 0.992) | 1.022 (1.015 to 1.028) |
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| Y - Intercept | 1.027 (-0.205 to 2.258) | 0.488 (-0.302 to 1.278) | -0.487 (-1.371 to 0.397) |
| --- | --- | --- | --- |
| Correlation Coefficient | 0.999 | 1.000 | 1.000 |
| Range of samples tested (mg/dL) | 5.98 to 398.26 | 5.98 to 398.26 | 6.06 to 378.02 |
| Std. Error of estimate (Sy/X) | 2.867 | 1.839 | 2.046 |
| Average Bias (mg/dL) | -2.924 (-3.991 to -1.856) | 1.079 (-1.641 to -0.517) | 1.845 (1.152 to 2.538) |
| N | 60 | 60 | 60 |
# b. Matrix comparison:
A matrix comparison study was conducted to assess the acceptability of 5 different blood collection tube types. Li-heparin plasma (without gel), Li-heparin plasma (with gel barrier), Na-heparin plasma, Serum (with gel barrier), and EDTA plasma were tested against a serum tube (without gel). The creatinine samples (22 native and 49 spiked) ranged from 0.49 to 36.23 mg/dl from 71 subjects were used for the study. The sponsors acceptance criterion is a slope between 0.95 to 1.05 and a correlation coefficient greater than 0.970. The following table supports the usage of lithium heparin (with or without gel barrier), sodium heparin and SST for sample collection for the Multigent Creatinine (enzymatic) assay. However, EDTA returned a bias of - $9.1\%$ and is not a recommended anticoagulant. This is noted in the package insert.
| Y | Li-heparin | Li-heparin (Gel barrier) | Na-heparin | Serum (Gel barrier) |
| --- | --- | --- | --- | --- |
| Slope | 1.002 (0.984 to 1.020) | 0.993 (0.979 to 1.006) | 0.978 (0.964 to 0.992) | 1.000 (0.991 to 1.009) |
| Y-intercept | 0.019 (-0.273 to 0.311) | -0.009 (-0.223 to 0.206) | 0.124 (-0.101 to 0.350) | 0.024 (-0.118 to 0.166) |
| Correlation Coefficient | 0.997 | 0.998 | 0.998 | 0.999 |
| Range (mg/dL) | 0.49 to 36.23 | 0.49 to 36.23 | 0.49 to 36.23 | 0.49 to 36.23 |
| N | 71 | 71 | 71 | 71 |
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3. Clinical studies:
a. Clinical Sensitivity:
Not applicable.
b. Clinical specificity:
Not applicable.
c. Other clinical supportive data (when a. and b. are not applicable):
Not applicable.
4. Clinical cut-off:
Not applicable.
5. Expected values/Reference range:
The sponsor references literature for the expected values as follows:
Serum/Plasma¹
| | Range (mg/dL) | Range (umol/L) |
| --- | --- | --- |
| Male | 0.73 to 1.18 | 64 to 104 |
| Female | 0.55 to 1.02 | 49 to 90 |
Urine¹
| | Adult Male | Adult Female |
| --- | --- | --- |
| 24- Hour Excretion | 11.1 to 27.9 mg/kg/day (98 to 247 umol/kg/day) | 9.8 to 24.7 mg/kg/day (87 to 218 umol/kg/day) |
| | 870 to 2410 mg/day (7.7 to 21.3 mmol/day) | 670 to 1590 mg/day (5.9 to 14.1 mmol/day) |
| Average Concentration * | 58 to 161 mg/dL (5.1 to 14.2 mmol/L) | 45 to 106 mg/dL (3.9 to 9.4 mmol/L) |
| Creatinine Clearance | 61 to 147 mL/min/1.73 m² BSA (1.02 to 2.45 mL/sec/1.73 m² BSA) | 59 to 151 mL/min/1.73 m² BSA (0.98 to 2.52 mL/sec/1.73 m² BSA) |
* Concentration is based on a daily urine output of 1.5L.
Junge W, Wilke B, Halabi A., et al. Determination of reference intervals for serum creatinine, creatinine excretion and creatinine clearance with an enzymatic and a modified Jaffe method. Clin Chim Acta 2004; 344; 137-148.
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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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Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
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.