ACCU-CHEK AVIVA PLUS BLOOD GLUCOSE MONITORING SYSTEM
Applicant
Roche Diagnostics
Product Code
LFR · Clinical Chemistry
Decision Date
Sep 21, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Indications for Use
The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, or palm. The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended to be used by a single person and should not be shared. The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended for self testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System should not be used for the diagnosis of or screening of diabetes or for neonatal use. Alternative site testing should be done only during steady - state times (when glucose is not changing rapidly). The ACCU-CHEK Aviva Plus Test Strips are for use with the ACCU-CHEK Aviva Blood Glucose Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, or palm.
Device Story
System measures capillary whole blood glucose; utilizes ACCU-CHEK Aviva meter and Aviva Plus test strips with modified GDH-PQQ enzyme. User applies 0.6 μL blood sample to strip; meter applies AC voltages at four frequencies to assess sample/environment, followed by DC voltage to measure glucose-proportional current. System provides hematocrit and temperature-compensated results. Intended for single-patient home use; operated by patient. Output displayed on meter; aids in diabetes management. Includes code key for calibration; supports data transmission to external devices.
Clinical Evidence
Clinical performance evaluated via user study with 195 subjects (fingertip) and 314 (palm), 155 (forearm), 156 (upper arm). Accuracy compared to hexokinase reference method. Results showed high correlation (r=0.989 for fingertip). System accuracy for glucose ≥75 mg/dL met 99.2% within ±20% for fingertip samples. Bench testing included precision, linearity, interference, hematocrit (10-65%), and altitude (up to 10,000 ft) studies.
Technological Characteristics
Disposable dry reagent test strip; electrochemical sensing; Mut. Q-GDH enzyme; PQQ coenzyme; electrochemical mediator; meter-based display; single-patient use design.
Indications for Use
Indicated for people with diabetes for self-testing of capillary whole blood glucose from fingertips, forearm, upper arm, or palm to monitor diabetes control. Contraindicated for neonates, diagnosis/screening of diabetes, and patients who are dehydrated, hypotensive, in shock, critically ill, or in a hyperosmolar state.
Regulatory Classification
Identification
A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
Special Controls
*Classification.* Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.
{0}
1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k101299
B. Purpose for Submission:
New blood glucose monitoring system (new Aviva Plus glucose test strips with a modified GDH-PQQ methodology are intended to be used with the cleared ACCU-CHECK Aviva meter)
C. Measurand:
Capillary whole blood Glucose
D. Type of Test:
Quantitative amperometric assay, glucose dehydrogenase (mutant GDH- PQQ)
E. Applicant:
Roche Diagnostics
F. Proprietary and Established Names:
ACCU-CHEK Aviva Plus Blood Glucose Monitoring System
G. Regulatory Information:
1. Regulation section:
21 CFR §862.1345, Glucose Test System
2. Classification:
Class II
3. Product code:
NBW (System, Test, Blood Glucose, Over The Counter)
LFR (glucose dehydrogenase, glucose)
{1}
4. Panel:
Clinical Chemistry (75)
H. Intended Use:
1. Intended use(s):
See Indications for Use below.
2. Indication(s) for use:
The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, or palm. The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended to be used by a single person and should not be shared.
The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended for self testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System should not be used for the diagnosis of or screening of diabetes or for neonatal use. Alternative site testing should be done only during steady - state times (when glucose is not changing rapidly).
The ACCU-CHEK Aviva Plus Test Strips are for use with the ACCU-CHEK Aviva Blood Glucose Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, or palm.
3. Special conditions for use statement(s):
- For in vitro diagnostic use only
- Device is for over-the-counter (single patient use) only and should not be shared
- Not intended for use on neonates
- Not for the diagnosis of or screening for diabetes mellitus
- Not to be used for patients who are dehydrated, hypotensive, in shock, critically ill or in a hyperosmolar state
4. Special instrument requirements:
ACCU-CHEK Aviva Blood Glucose Meter
I. Device Description:
The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System consists of:
{2}
- ACCU-CHEK Aviva Blood Glucose Meter (cleared under k060620)
- ACCU-CHEK Aviva Plus test strips with modified GDH – PQQ technology
- Code key
- ACCU-CHEK MultiClix Lancing Device with 12 Lancets
ACCU-CHEK Aviva Control solution is required but sold separately
## J. Substantial Equivalence Information:
1. Predicate device name(s):
ACCU-CHEK Aviva
2. Predicate 510(k) number(s):
k060620
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Indications for Use | Same | For the quantitative measurement of glucose in fresh capillary whole blood |
| Measuring Range | 20 – 600 mg/dL | 10 – 600 mg/dL |
| Hematocrit Range | 10 – 65% | 10 – 70% |
| Detection Method | Same | Amperometry |
| Measuring Time | Same | 5 seconds |
| Sample Volume | Same | 0.6 μL |
| Capillary Sample Sites | Fingertip, forearm, upper arm, palm | Fingertip, forearm, upper arm, palm thigh, calf |
| Coding | Same | Code Key |
| Memory | Same | 500 stored results |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Enzyme | Modified Glucose dehydrogenase pyrroloquinoline quinone (GDH-PQQ) | Glucose dehydrogenase pyrroloquinoline quinone (GDH-PQQ) |
| Intended Users | Single patient use | Single patient and healthcare professional |
| Sample Type | Capillary blood only | Rx use: capillary, venous, arterial, and neonatal blood
OTC use: capillary blood only |
{3}
K. Standard/Guidance Document Referenced (if applicable):
- CLSI EP7 - Interference Testing in Clinical Chemistry
- CLSI EP5 – Evaluation of Precision Performance of Quantitative Measurement Methods
- ISO15197:2003 - In vitro diagnostic test systems – Requirements for blood-glucose monitoring systems for self-testing in managing diabetes mellitus.
L. Test Principle:
When an ACCU-CHEK® Aviva Plus test strip is inserted into the ACCU-CHEK® Aviva meter, a small alternating current (AC) is applied until the application of blood causes a spike in the conductivity to be observed at the measurement and sample - sufficiency electrodes. Both are used to assure an adequate sample has been applied. The meter then applies a series of AC voltages at four frequencies and reads the AC responses. These carry information about the sample type and environmental temperature; they also allow the system to perform various internal quality checks. After the AC measures are completed, a small (DC) voltage is applied and current is observed which is proportionate to the glucose. The AC and DC information are then combined to provide a hematocrit and temperature compensated glucose result.
The enzyme on the test strip, a variant of glucose dehydrogenase, converts the glucose in the blood sample to gluconolactone. This reaction creates a harmless DC electrical current that the meter interprets for the blood glucose result. The sample and environmental conditions are also evaluated using a small AC signal.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Repeatability Precision (Within Vial)
A total of 50 individual strip vials per each of three strip lots were used for data collection. These vials were separated into 5 sets of 10 vials each and assigned to 1 of 5 venous blood samples at varying concentrations.
Ten runs were performed on each sample, with an n = 10 replicates collected per vial/strip lot. This resulted in a total of 100 replicates collected for each strip lot and glucose level tested. Results are summarized in the table below.
{4}
| Level | 1 | | | 2 | | | 3 | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Lot 1 | Lot 2 | Lot 3 | Lot 1 | Lot 2 | Lot 3 | Lot 1 | Lot 2 | Lot 3 |
| Mean | 42.7 | 42.5 | 40.9 | 90.0 | 90.7 | 87.1 | 121.9 | 121.2 | 120.4 |
| SD | 2.1 | 1.5 | 1.5 | 2.9 | 3.9 | 2.8 | 4.1 | 5.5 | 4.0 |
| CV(%) | 4.8 | 3.4 | 3.6 | 3.3 | 4.3 | 3.3 | 3.3 | 4.6 | 3.3 |
| n | 100 | 100 | 100 | 100 | 100 | 100 | 100 | 100 | 100 |
| Level | 4 | | | 5 | | |
| --- | --- | --- | --- | --- | --- | --- |
| | Lot 1 | Lot 2 | Lot 3 | Lot 1 | Lot 2 | Lot 3 |
| Mean | 185.9 | 182.4 | 183.1 | 312.8 | 306.5 | 309.7 |
| SD | 6.3 | 6.6 | 5.4 | 10.7 | 12.9 | 10.2 |
| CV(%) | 3.4 | 3.6 | 3.0 | 3.4 | 4.2 | 3.3 |
| n | 100 | 100 | 100 | 100 | 100 | 100 |
Intermediate Precision (Day-to-Day)
Intermediate precision was assessed by analyzing three levels of commercial linearity controls. Results were collected over 10 consecutive days by two operators using three strip lots. Results are summarized in the table below.
| Level | 1 | 2 | 3 |
| --- | --- | --- | --- |
| mean | 45.1 | 118.7 | 307.4 |
| SD | 1.4 | 3.0 | 7.7 |
| CV (%) | 3.1 | 2.5 | 2.5 |
| n | 300 | 300 | 300 |
b. Linearity/assay reportable range:
Linearity was evaluated using 8 spiked whole blood samples with glucose concentrations ranging from 18 to $632\mathrm{mg / dL}$ (18, 38, 63, 81, 153, 314, 470, and $632\mathrm{mg / dL}$ ) as measured by the reference method. Per lot, each sample was measured 4 times out of 8 strip vials for a total of 32 replicates per level.
Results are summarized in the table below:
| Strip Lot | Slope | Intercept | Corr Coeff (r) | Range of recoveries |
| --- | --- | --- | --- | --- |
| 1 | 0.992 | -0.649 | 1.000 | 98 – 105% |
| 2 | 0.977 | -0.842 | 1.000 | 96 – 103% |
| 3 | 1.011 | -0.415 | 1.000 | 98 – 107% |
The claimed range of measurement for this device is 20 to $600\mathrm{mg / dL}$ glucose.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
{5}
The Aviva Plus system is calibrated to a hexokinase method on a laboratory analyzer. A method comparison was performed using this method as the comparative method. See Comparison studies in 2a below.
The controls recommended for the ACCU-CHEK Aviva Plus Blood Glucose Monitoring System were cleared under k043474.
The sponsor provided a protocol and acceptance criteria to verify the closed-vial stability (shelf life) and open vial stability of the test strips. The stability protocols and acceptance criteria were reviewed and found to be acceptable. The sponsor claims a closed-vial (shelf life) and open-vial stability of 18 months when stored at 36 – 86° F (2 – 30° C)
d. Detection limit:
The claimed reportable range for the system is 20 – 600 mg/dL. This range was verified by the linearity study (M.1.b) above.
e. Analytical specificity:
To assess potential interference, whole blood samples were spiked with glucose at concentrations of approximately 25, 55, 120, 350, and 500 mg/dL and split into a control sample and a test sample. Various endogenous and exogenous substances were then added to the test sample only. Concentrations tested were at least three times the upper therapeutic level (for drugs) or three times the highest expected concentration (for endogenous substances). Concentrations listed in CLSI EP7-A2 were used when available. For substances not listed in CLSI EP7-A2, other published references were consulted. Each combination of glucose concentration and interferent concentration was analyzed 16 times per strip lot using three strip lots for a total of 48 measurements per each combination of glucose and interferent. The % difference between the test sample and the control sample was calculated. The sponsor defines no significant interference as ≤ 10%.
Three compounds were found to cause significant interference:
| Compound Name | Concentration at Which Significant Interference Criteria was Seen (mg/dL) |
| --- | --- |
| Triglycerides | >1800 |
| Galactose | >15 |
| Ascorbic Acid | >3 |
{6}
The sponsor includes the following in the limitations section of the labeling:
- Lipemic samples (triglycerides) in excess of 1800 mg/dL may produce elevated results.
- Blood concentrations of galactose >15 mg/dL will cause overestimation of blood glucose results.
- Intravenous administration of ascorbic acid which results in blood concentrations of ascorbic acid >3 mg/dL will cause overestimation of blood glucose results.
The remaining compounds tested were found to not cause significant interference, as follows:
| Compound Name | Concentration at Which No Significant Interference Criteria was Seen (mg/dL) |
| --- | --- |
| β - Carotene | 0.6 |
| 5-Fluorocytosine | 30 |
| Acarbose | 60 |
| Acetaminophen | 20 |
| Acetazolamide | 6 |
| Acetone | 60 |
| Acetylprocainamide | 15 |
| Acetylsalicylic Acid | 60 |
| Acyclovir | 5 |
| Albumin | 5000 |
| Albuterol | 25 |
| Allopurinol | 5 |
| Aminocaproic Acid | 0.08 |
| Amiodarone HCI | 5 |
| Amitriptyline HCI | 1 |
| Amoxapine | 0.1 |
| Amoxicillin | 600 |
| Ampicillin | 5.3 |
| Astemizole | 1 |
| Atropine | 1 |
| Bile Acids | 1.5 |
| Buspirone HCI | 1 |
| Caffeine | 10 |
| Compound Name | Concentration at Which No Significant Interference Criteria was Seen (mg/dL) |
| --- | --- |
| Captopril | 0.5 |
| Carbamazepine | 3 |
| Cefaclor | 200 |
| Cefadroxil | 10.5 |
| Cephalexin | 32 |
| Cephalothin Sodium | 200 |
| Cetirizin Dihydrochloride | 1 |
| Chenodeoxycholic Acid | 3 |
| Chlorothiazide | 2 |
| Chlorpropamide | 80 |
| Cholesterol | 500 |
| Cholic Acid | 2.4 |
| Cimetidine | 10 |
| Citric Acid | 30 |
| Clindamycin | 4.5 |
| Clonidine HCI | 2 |
| Conjugated Bilirubin | 15 |
| Creatinine | 30 |
| Cyclophosphamide | 37.5 |
| Desipramine HCI | 0.1 |
| Dexamethasone | 0.09 |
| Dextromethorphan HBr | 1 |
| Diclofenac | 5 |
| Dicumarol | 20 |
| Digoxin | 1 |
{7}
| Diltiazem | 20 |
| --- | --- |
| Diphenhydramine HCI | 1 |
| Dipyrone | 11 |
| Disopyramide | 5 |
| DL Dopa | 2.8 |
| DL-Tyrosine | 24 |
| DL-β-Hydroxybutyric Acid | 100 |
| D-Mannitol | 600 |
| D-Mannose | 10 |
| D-Norpropoxyphene Maleate | 1 |
| Dopamine HCI | 1.5 |
| Doxazosin Mesylate | 1 |
| Doxycycline Hyclate | 3 |
| D-Penicillamine | 2.4 |
| D-Sorbitol | 70 |
| EDTA Calcium Disodium Salt | 180 |
| Enalapril | 8 |
| Ephedrine | 1 |
| Equilin | 15 |
| Erythromycin | 60 |
| Estradiol | 0.1 |
| Estrone | 1 |
| Ethanol | 350 |
| Ethosuximide | 25 |
| Ethyl Acetoacetate | 20 |
| Ethylene Glycol | 5 |
| Famotidine | 0.6 |
| Felodipine | 5 |
| Fenofibrate | 5 |
| Fenoprofen | 20 |
| Flecainide Acetate | 1 |
| Fluoxetine HCI | 12 |
| Flurbiprofen | 5 |
| Fructose | 250 |
| Furosemide | 6 |
| Galactose-1-phosphate | 5 |
| Gamma Globulins | 3000 |
| Gemfibrozil | 15 |
| Gentamicin Sulfate | 3.6 |
| Gentisic Acid | 50 |
| Glimepiride | 1 |
| Glipizide | 8 |
| Glucosamine | 450 |
| Glybenclamide | 1.5 |
| --- | --- |
| Glycerol | 10 |
| Hemoglobin | 500 |
| Heparin Lithium | 8000 U/dL |
| Heparin Sodium | 8000 U/dL |
| Humulin N | 20 U/dL |
| Humulin R | 20 U/dL |
| Hydrochlorothiazide | 0.61 |
| Hydrocortisone | 1 |
| Hydroxychloroquine Sulfate | 4 |
| Ibandronic Acid | 0.5 |
| Ibuprofen | 40 |
| Indomethacin | 5 |
| Isoniazid | 5 |
| Kanamycin | 6 |
| Lactic Acid | 100 |
| Lactose | 10 |
| L-Cysteine | 5 |
| L-Cystine | 50 |
| Lecithin | 500 |
| L-Glutathione, oxidized | 183.9 |
| L-Glutathione, reduced | 12.3 |
| Lidocaine | 1.2 |
| Lisinopril | 1 |
| lodoacetate | 35 |
| Loratadine | 1 |
| Lovastatin | 0.4 |
| L-Phenylalanine | 50 |
| L-Thyroxine | 5 |
| Magnesium Sulfate | 26 |
| Metaproterenol | 1.81 |
| Metformin | 50 |
| Methyl Dopa | 2.5 |
| Methylhydroxy progesterone | 50 |
| Metoclopramide HCI | 0.13 |
| Metoprolol Tartrate | 0.7 |
| Mexiletine HCI | 1 |
| Misoprostol | 0.8 |
| Nadolol | 2 |
| Naproxen | 100 |
| Neostigmine Bromide | 0.2 |
| Neostigmine Methyl Sulfate | 0.2 |
{8}
| Nicotine | 2 |
| --- | --- |
| Nifedipine | 40 |
| Nitrofurantoin | 4 |
| Nordoxepin HCI | 5 |
| Normethyl-(±)-verapamil HCI | 1 |
| Nortriptyline HCI | 0.3 |
| Oleic Acid | 35 |
| Omeprazole | 0.52 |
| Oxalic Acid | 20 |
| Palmitic Acid | 150 |
| Penicillin G | 15 |
| Phenelzine Sulfate | 0.5 |
| Phenytoin | 10 |
| Pindolol | 0.5 |
| Pioglitazone | 5 |
| Piroxicam | 10 |
| Polysorbate 80 | 24 |
| Potassium Chloride | 50 |
| Pralidoxime Iodide (PAM) | 25 |
| Primidone | 5 |
| Probenecid | 60 |
| Procainamide HCI | 10 |
| Propranolol HCI | 1 |
| Pseudoephedrine | 1 |
| Pyridoxine HCI (Vitamin B6 HCl) | 3 |
| Pyruvic acid | 4 |
| Quinine Sulfate | 4.8 |
| Ramipril | 3.58 |
| Ranitidine HCI | 20 |
| Repaglinide | 5 |
| Rifampicin | 8 |
| Rosiglitazone | 5 |
| Salicylic Acid | 60 |
| Sodium Bicarbonate | 336 |
| Stearic Acid | 15 |
| Streptomycin Sulfate | 15 |
| Sucrose | 500 |
| Terfenadine | 25 |
| Tetracycline HCI | 10 |
| Theophylline | 25 |
| Thioridazine HCI | 4 |
| Tobramycin | 3.6 |
| Tolazamide | 200 |
| Tolbutamide | 100 |
| --- | --- |
| Trazodone HCI | 2 |
| Triamterene | 6 |
| Trimethoprim | 6 |
| Unconjugated Bilirubin | 40 |
| Urea | 600 |
| Uric Acid | 40 |
| Valproic Acid | 50 |
| Vancomycin HCI | 20 |
| Verapamil HCI | 1 |
| Vitamin B12 | 1 |
| Vitamin E | 20 |
| Voluven | 800 |
| Warfarin | 10 |
| Xylitol | 200 |
| Xylose | 100 |
| Zenapax (Daclizumab) | 10 |
{9}
10
# Hematocrit study:
The effect of different hematocrit levels was evaluated using venous whole blood samples with hematocrit levels of 10 – 65% (10,15, 20, 25, 30, 43, 50, 55, 60, and 65%) spiked with glucose to achieve target concentrations of 25, 55, 120, 350, and 500 mg/dL. Three strip lots were evaluated, and there were 30 measurements for each combination of strip lot, glucose concentration, and hematocrit level tested. The results demonstrated that the ACCU-CHEK Aviva Plus Blood Glucose Monitoring System produces accurate results over the claimed hematocrit range of 10 – 65%.
f. Assay cut-off:
Not applicable.
2. Comparison studies:
a. Method comparison with predicate device:
# System Accuracy:
To assess system accuracy, the ACCU-CHEK Aviva Plus Blood Glucose Monitoring System was compared to a hexokinase – based reference method. All of the samples were capillary fingersticks collected by a trained technician. Additional blood from the same fingerstick was collected for the reference measurement.
If native samples could not be collected for glucose concentrations <50 mg/dL or >400 mg/dL, then samples could be collected into a Lithium heparin anticoagulant tube and allowed to age in order to achieve a glucose concentration <50 mg/dL or spiked with glucose to achieve a glucose concentration >400 mg/dL.
Five samples were allowed to glycolyze to achieve a concentration less than 50 mg/dL and four samples were spiked to achieve a concentration greater than 400 mg/dL.
Linear regression based on single glucose measurements produced the following:
| Lot | n | Range of values mg/dL | Slope | Slope 95% CI | Intercept | Intercept 95% CI | r | Std. Error |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | 10
0 | 20-529 | 1.026 | (1.001, 1.051) | -3.1 | (-8.4, 2.2) | 0.992 | 14.6 |
| 2 | 10
0 | 22-511 | 1.042 | (1.017, 1.067) | -3.7 | (-8.8, 1.4) | 0.993 | 14 |
| 3 | 10
0 | 19-542 | 1.018 | (0.993, 1.043) | -2.4 | (-7.6, 2.8) | 0.992 | 14.6 |
{10}
System accuracy results for glucose concentration $< 75\mathrm{mg / dL}$
| Strip Lot | Within ±5 mg/dL | Within ± 10mg/dL | Within ± 15mg/dL |
| --- | --- | --- | --- |
| 1 | 15/16 (93.8%) | 16/16 (100%) | 16/16 (100%) |
| 2 | 14/16 (87.5%) | 16/16 (100%) | 16/16 (100%) |
| 3 | 12/16 (75%) | 16/16 (100%) | 16/16 (100%) |
| Combined | 41/48 (85.4%) | 48/48 (100%) | 48/48 (100%) |
System accuracy results for glucose concentration $\geq 75\mathrm{mg / dL}$
| Strip Lot | Within ±5% | Within ± 10% | Within ± 15% | Within ±20 % |
| --- | --- | --- | --- | --- |
| 1 | 53/84 (63.1%) | 74/84 (88.1%) | 82/84 (97.6%) | 84/84 (100%) |
| 2 | 44/84 (52.4%) | 73/84 (86.9%) | 81/84 (96.4%) | 83/84 (98.8%) |
| 3 | 50/84 (59.5%) | 75/84 (89.3%) | 83/84 (98.8%) | 83/84 (98.8%) |
| Combined | 147/252 (58.3%) | 222/252 (88.1%) | 246/252 (97.6%) | 250/252 (99.2%) |
b. Matrix comparison:
Not applicable. Fresh capillary whole blood is the only acceptable matrix.
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):
User results with capillary blood from the fingertip
A user performance study was performed to compare the lay user self-test results to the hexokinase reference method. The study was performed in 2 clinical sites with samples from 195 subjects using three lots of test strips. Each subject was asked to read the English version of the First Time Guide and Owner's Booklet, which will be provided to users when the device is marketed. Subjects were not allowed to practice testing with controls or blood prior to performing their own fingerstick blood glucose test.
{11}
Linear regression analysis results based on single glucose measurements are summarized below:
| n | Range of values mg/dL | Slope | Slope 95% CI | Intercept | Intercept 95% CI | r | Std. Error |
| --- | --- | --- | --- | --- | --- | --- | --- |
| 195 | 41-472 | 0.969 | (.949, .989) | 2.3 | (-1.3, 5.9) | 0.989 | 11.6 |
System accuracy results for glucose concentration $< 75\mathrm{mg / dL}$
| Within ±5 mg/dL | Within ±10mg/dL | Within ±15mg/dL |
| --- | --- | --- |
| 23/29 (79.3%) | 29/29 (100%) | 29/29 (100%) |
System accuracy results for glucose concentration $>75\mathrm{mg / dL}$
| Within ±5% | Within ±10% | Within ±15% | Within ±20% |
| --- | --- | --- | --- |
| 94/166 (56.6%) | 152/166 (91.6%) | 164/166 (98.8%) | 165/166 (99.4%) |
User results with capillary blood from alternate sites
A user performance study was performed to compare the lay user self-test results to the hexokinase reference method. The study was performed in 2 clinical sites. For samples collected from the palm, 153 subjects collected capillary blood from the thenar site and 161 subjects collected blood from the hypothenar site. No significant difference was seen between the thenar and hypothenar sites, and they were combined for a total of 314 measurements from the palm. Forearm samples were collected by 155 subjects and upper arm samples were collected by 156 subjects. Each subject was asked to read the English version of the First Time Guide and Owner's Booklet, which will be provided to users when the device is marketed. Subjects were not allowed to practice testing with controls or blood prior to performing their own fingerstick blood glucose test.
Linear regression analysis based on single glucose measurements are summarized below:
| Alternate Site | n | Range of values mg/dL | Slope | Slope 95% CI | Intercept | Intercept 95% CI | r | Std. Error |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Palm | 314 | 60-439 | 0.983 | (0.963, 1.003) | 0.1 | (-2.9, 3.1) | 0.984 | 11.6 |
| Forearm | 155 | 61-381 | 1.004 | (0.967, 1.041) | -1.9 | (-8.1, 4.3) | 0.975 | 16.3 |
| Upper Arm | 156 | 61-381 | 0.929 | (0.896, 0.962) | 8.4 | (2.8, 14) | 0.976 | 14.8 |
{12}
System accuracy results for glucose concentration $< 75\mathrm{mg / dL}$
| Alternative Site | Within ±5 mg/dL | Within ± 10mg/dL | Within ±15mg/dL |
| --- | --- | --- | --- |
| Palm | 8/11 (73%) | 11/11 (100%) | 11/11 (100%) |
| Forearm | 3/6 (50%) | 5/6 (83%) | 6/6 (100%) |
| Upper Arm | 4/6 (67%) | 5/6 (83%) | 6/6 (100%) |
System accuracy results for glucose concentration $\geq 75\mathrm{mg / dL}$
| Alternate Site | Within ±5% | Within ± 10% | Within ± 15% | Within ± 20% |
| --- | --- | --- | --- | --- |
| Palm | 158/303 (52%) | 242/303 (80%) | 280/303 (92%) | 299/303 (99%) |
| Forearm | 64/149 (43%) | 104/149 (70%) | 136/149 (91%) | 147/149 (99%) |
| Upper Arm | 66/150 (44%) | 109/150 (73%) | 135/150 (90%) | 146/150 (97%) |
# 4. Clinical cut-off:
Not applicable.
# 5. Expected values/Reference range:
The sponsor states the following in their labeling:
# Expected Values
The normal fasting glucose level for an adult without diabetes is below $100\mathrm{mg / dl}^{1,2}$ . Two hours after meals, the normal blood glucose level for a non-diabetic adult is less than $140\mathrm{mg / dl}^2$ . For people with diabetes: please consult your healthcare professional for the blood glucose level appropriate for you. You should treat your low or high blood glucose as recommended by your healthcare professional.
# References:
$^{1}$ American Diabetes Association: Diagnosis and Classification of Diabetes Mellitus (Position Statement). Diabetes Care 34 (Supp. 1) S66, 2011
{13}
2Tietz Fundamentals of Clinical Chemistry, 6th Edition, Edited by Burtis CA and Ashwood ED, W. B. Saunders Co., Philadelphia, PA, 2008, p. 849
## N. Instrument Name:
ACCU-CHEK Aviva Blood Glucose Meter
## O. System Descriptions:
1. **Modes of Operation:**
Each test strip is single use and requires a sample volume of 0.6 uL.
Does the applicant’s device contain the ability to transmit data to a computer, webserver, or mobile device?
☑ Yes ☐ X or No
Does the applicant’s device transmit data to a computer, webserver, or mobile device using wireless transmission?
☑ Yes ☐ X or No
2. **Software:**
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
☐ Yes ☐ X or No
3. **Specimen Identification:**
There is no sample identification function with this device. Samples are applied directly to the test strip as they are collected.
4. **Specimen Sampling and Handling:**
This device is intended to be used with capillary whole blood from the finger, palm, forearm, and upper arm only. The whole blood sample is applied directly to the test strip by capillary action.
5. **Calibration:**
The meter is coded by the user by inserting a code key. The labeling instructs the user to leave the code key in the meter until a new box of test strips is opened and to change the
{14}
code key each time a new box of test strips is opened.
6. Quality Control:
Controls are not included in the ACCU-CHEK Aviva Plus Blood Glucose Monitoring System starter kit, but the labeling explains how users can obtain two levels of controls. The labeling also provides recommendations on when to test control materials. The meter can recognize a control solution automatically and control results are not stored in memory. An acceptable range for each control level is printed on the test strip vial label. If the control values fall outside these ranges, the user is referred to a troubleshooting chart which includes information on how to contact the Customer Care Service Center.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
1. Infection Control studies: The ACCU-CHEK Aviva Plus Blood Glucose Monitoring System is intended for single-patient use only. Disinfection efficacy studies were performed on the materials comprising the meter and lancing device by an outside commercial testing facility demonstrating complete inactivation of hepatitis B virus (HBV) with the chosen disinfectant, Super Sani-Wipes (EPA Registration Number 9480-4). Robustness studies were also performed by the sponsor demonstrating that there was no change in performance or external materials for the meter and lancing device after 260 cleanings and 260 disinfection steps with Super Sani-Wipes. The robustness studies were designed to simulate 5 years of single-patient use. Labeling was reviewed for adequate instructions for the validated cleaning and disinfection procedures.
2. A usability study was performed to assess the readability of the labeling by recruiting untrained lay users who were provided with the test kit containing labeling for the US market. These lay users also completed a questionnaire regarding the clarity of the instructions and the ease of use of the device. The majority of the users responded that they understood the instructions and were able to successfully operate the device.
3. Flesch-Kincaid readability assessment was conducted for the meter user's manual and test strip package insert and were found to be 7.5 and 8.2, respectively.
4. The Customer Care Service Center is available 24/7, 365 days a year. The toll free phone number is 1-800-858-8072.
5. The sponsor claims an operating condition range of $14 - 40^{\circ}\mathrm{C}$ and $10 - 80\%$ relative humidity. Combinations of the claimed temperature and humidity operating conditions were evaluated by measuring whole blood samples at target glucose concentrations of 70, 120, and $250~\mathrm{mg/dL}$ and comparing the meter results to a reference method. The results demonstrated that the system produces accurate results over the claimed range of operating conditions.
6. To evaluate the effects of altitude, glycolyzed venous blood samples from three donors were spiked to glucose concentrations of approximately 40, 90, and $400\mathrm{mg/dL}$ and tested
15
{15}
in a glove box chamber set to simulate atmospheric conditions at 10,000 feet. Three lots of glucose strips were tested in six runs with three replicates per run. This resulted in a total of 18 replicates for each combination of strip lot, glucose level, and donor and a total of 54 replicates overall. These studies demonstrated that altitudes up to 10,000 feet have no significant effect on blood glucose measurements
7. Electromagnetic Compatibility (EMC) testing was performed and found to be adequate in k043474. The Aviva meter in this submission is identical to the one reviewed in k043474.
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
16
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.