K102164 · Instrumentation Laboratory CO · GGP · Mar 17, 2011 · Hematology
Device Facts
Record ID
K102164
Device Name
HEMOSIL PROTEIN S ACTIVITY ASSAY
Applicant
Instrumentation Laboratory CO
Product Code
GGP · Hematology
Decision Date
Mar 17, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 864.7290
Device Class
Class 2
Indications for Use
Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on the ACL TOP® Family of analyzers.
Device Story
The HemosIL Protein S Activity assay is an automated coagulation functional assay used on ACL TOP Family analyzers. It measures the functional activity of free Protein S by determining the prolongation of prothrombin time in the presence of recombinant human tissue factor, synthetic phospholipids, calcium ions, and activated protein C. The assay correlates Protein S activity with the prolongation of clotting time in Protein S-deficient plasma to which a patient sample has been added. The device is used in clinical laboratory settings by trained personnel. Results assist clinicians in diagnosing hereditary and acquired Protein S deficiency. The assay utilizes a lyophilized reagent containing human tissue factor and a separate calcium reagent to improve shelf life.
Clinical Evidence
Bench testing only. Precision evaluated per CLSI EP05-A2 over 20 days (n=80/instrument/lot) across three ACL TOP systems, showing total CVs ranging from 2.2% to 7.1%. Method comparison studies (in-house and field sites) performed per CLSI EP09-A2 against the predicate device demonstrated comparable performance.
Technological Characteristics
Quantitative coagulation assay. Reagents: lyophilized recombinant human tissue factor, synthetic phospholipids, activated protein C, Polybrene, buffer, stabilizers, preservatives; separate liquid calcium reagent. Analyzers: ACL TOP Family (ACL TOP, 700, 500 CTS, 700 CTS, 700 LAS). Principle: Clotting time prolongation assay. Stability: 2-year shelf life at 2-8°C. Standards: CLSI EP5-A2, EP6-A, EP7-A2, EP9-A2, EP17-A, EP25-A, C28-A3.
Indications for Use
Indicated for the quantitative determination of free Protein S in human citrated plasma to aid in the diagnosis of hereditary and acquired Protein S deficiency in patients.
Predicate Devices
HemosIL® ProS (k053499)
Submission Summary (Full Text)
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
A. 510(k) Number:
k102164
B. Purpose for Submission:
Clearance of a new device
C. Measurand:
Free Protein S Activity
D. Type of Test:
Quantitative
E. Applicant:
Instrumentation Laboratory Co.
F. Proprietary and Established Names:
HemosIL® Protein S Activity
G. Regulatory Information:
1. Regulation section:
21 CFR 864.7290, Factor Deficiency Test
2. Classification:
Class II
3. Product code:
GGP, Test Qualitative and Quantitative Factor Deficiency
4. Panel:
81 (Hematology)
H. Intended Use:
1. Intended use(s):
Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on the ACL TOP® Family of analyzers.
2. Indication(s) for use:
Same as intended use(s)
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
ACL TOP® Family of analyzers - ACL TOP, ACL TOP 700, ACL TOP 500 CTS, ACL TOP 700 CTS, and ACL TOP 700 LAS.
I. Device Description:
The HemosIL Protein S Activity Kit consists of the following:
- Protein S reagent: 3 x 2 mL vials of a lyophilized preparation containing recombinant human tissue factor, synthetic phospholipids, activated protein C, polybrene, buffer, stabilizers and preservatives.
- Calcium reagent: 3 x 6 mL vials of a liquid preparation containing calcium.
- Protein S deficient plasma: 3 x 2 mL vials of a lyophilized human plasma which has been artificially depleted of Protein S.
J. Substantial Equivalence Information:
1. Predicate device name(s):
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HemosIL® ProS
2. Predicate K number(s):
k053499
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | HemosIL® Protein S Activity | HemosIL® ProS (predicate) |
| Intended Use | Automated coagulation functional assay for the quantitative determination of free Protein S in human citrated plasma as an aid in the diagnosis of hereditary and acquired Protein S deficiency, on the ACL TOP® Family of analyzers. | Same |
| Reagent Shelf Life | 2 years (when stored at 2 - 8°C) | Same |
| Differences | | |
| --- | --- | --- |
| Item | HemosIL® Protein S Activity | HemosIL® ProS (predicate) |
| Reagent Kit Composition | Protein S reagent: Lyophilized preparation containing recombinant human tissue factor, synthetic phospholipids, activated protein C, Polybrene, buffer, stabilizers, and preservatives.
Calcium reagent: included in a separate vial
Protein S deficient plasma: lyophilized human plasma which has been artificially depleted of protein S, vial size 2 mL.
Protein S Control Plasma: not sold with this product | Protein S reagent: Lyophilized preparation containing recombinant rabbit tissue factor, calcium ions, synthetic phospholipids, activated protein C, Polybrene, buffer, stabilizers, preservatives,
Calcium reagent: included within Protein S reagent (separate calcium reagent vial absent).
Protein S deficient plasma: lyophilized human plasma which has been artificially depleted of protein S, vial size 1 mL.
Protein S Control Plasma: Lyophilized human plasma containing a low level of protein S. |
| Open vial stability- after reconstitution (if applicable) | Protein S reagent: 24 hours at 2-8°C, 8 hours at 15°C on-board.
Calcium reagent: 24 hours at 2-8°C, 8 hours on-board.
Protein S deficient plasma: 6 hours at 15°C on-board. | Protein S reagent: 2 days at 2-8°C, 2 days at 15°C on- board.
Calcium reagent: included within Protein S reagent
Protein S deficient plasma: 4 hours at 15-25°C. |
K. Standard/Guidance Document Referenced (if applicable):
CLSI, Evaluation of Precision of Quantitative Measurement Methods; Approved Guidelines-Second Edition (EP5-A2).
CLSI, Evaluation of the Linearity of Quantitative Measurement Procedures: A statistical Approach (EP6-A).
CLSI, Interference Testing in Clinical Chemistry (EP7-A2).
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CLSI, Method Comparison and Bias Estimation Using Patient Samples (EP9-A2).
CLSI, Protocols for the Limit of Detection and Limits of Quantitation (EP17-A).
CLSI, Evaluation of Stability of In Vitro Diagnostic Reagents (EP25-A).
CLSI, Reference Range Data: Defining, Establishing and Verifying Reference Intervals in the Clinical Laboratory (C28-A3).
## L. Test Principle:
The test is based on the ability of endogenous protein S as a cofactor of activated protein C to prolong the clotting time. Protein S levels in patient plasma are measured automatically on the ACL TOP® Family of analyzers. The test determines the functional activity of free Protein S by measuring the degree of prolongation of a prothrombin time in the presence of the recombinant tissue factor, phospholipids, calcium ions, and activated protein C. The Protein S activity is correlated with the prolongation of the clotting time of a Protein S deficient plasma to which diluted sample has been added.
## M. Performance Characteristics:
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Within-run, between-run and total reproducibility: A precision study was performed with three lots of HemosIL Protein S Activity on an ACL TOP, ACL TOP 700 and ACL TOP 500 CTS analyzers, for 20 days, with 2 runs a day and 2 replicates each run for each sample level (N=80 per level for each instrument). Test samples consisted of High Abnormal Control (HAC), Normal Control (NC), and High Normal Donor (HND). The acceptance criteria were as follows for the within-run study: HAC, standard deviation (SD) ≤ 2.5; NC, coefficient of variation (CV) ≤ 6%; HND, CV ≤ 6%. The acceptance criteria were as follows for between-run study: HAC, SD ≤ 3.0; NC, CV ≤ 8%; HND, CV ≤ 8%. Acceptance criteria for total reproducibility were as follows: HAC, SD ≤ 3.0; NC, CV ≤ 8%; HND, CV ≤ 8%. The acceptance criteria for all samples within each study were achieved.
#### b. Linearity/assay reportable range:
Linearity testing was performed using two lots of HemosIL Protein S Activity reagent kits on two ACL TOP instruments. Eleven (11) samples with protein S % activity ranging from 7.5 to 150% were prepared. Each sample was run in 4 replicates using the two reagent lots, and the average activities for the 11 samples were plotted against their assigned values. Acceptance criteria were as follows: slope, 0.9 – 1.1; R² ≥ 0.95. The results of the study fell within acceptable limits. The results support the claimed assay reportable range of 10 to 150% activity.
#### c. Traceability, Stability, Expected values:
Reagent stability
On-board instrument stability at 15°C: This study was performed using 2 different lots of Protein S and calcium reagents with 2 ACL TOP instruments (ACL TOP 700, ACL TOP 500 CTS). Vials of calcium reagent were opened, and vials of Protein S and Protein S Deficient Plasma reagent were reconstituted and maintained at 15°C on-board the instruments. At set intervals, controls were tested in 4 replicates and the results were compared to
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the control values generated at time zero (i.e. baseline mean). Acceptance criteria were as follows: Normal Control, baseline mean ± 15%; Special Test Control Level 2, baseline mean ± 10%; High Abnormal Control, baseline mean ± 10%. The resulting data supported an on-board 15°C stability claim for Protein S and calcium reagents of 8 hours. The Protein S Deficient Plasma was found to have an on-board 15°C stability of 6 hours.
**Reconstituted reagent stability at 2-8°C**: Vials of Calcium reagent were opened and vials of Protein S reagent were reconstituted and tested at time zero. The remaining vials were stored at 2-8°C for the duration of testing. At each time interval the three controls were tested in 4 replicates on an ACL TOP using the stored opened Calcium reagent and reconstituted Protein S Reagent. The results are compared to time zero. Acceptance criteria were as follows: Normal control, baseline mean ± 15; Special test control level 1, baseline mean ± 10; High abnormal control, baseline mean ± 10. The data presented supported the following stability claims: Protein S reagent and Calcium- 24 hours at 2-8°C.
**Accelerated closed vial stability**: Protein S Reagent vials, stored at different temperatures were tested for Protein S Activity assay on ACL TOP instruments. The stability results at 37°C and 50°C were used to predict the estimated shelf-life. Testing was performed using Protein S Reagent vials stored at 50°C for 12, 24, 32, and 48 hours, as well as vials stored at 37°C for 3, 5, 7, 8, 9, 10, 11, 12 and 13 days and compared to vials stored at 4°C as the control for reagents. Reagents were placed at the desired temperatures at different times and then tested along with the reagents stored under normal storage (4°C) conditions. Control samples for each time/temperature point were analyzed in 4 replicates. The acceptance criteria were as follows: Normal Control, baseline mean ± 15%; Special Test Control Level 2, baseline mean ± 10%; High Abnormal Control, baseline mean ± 10%. The results were evaluated and showed a predicted closed vial stability of 16.45 years.
**Real-time closed vial stability**: Real-time stability is on-going with 2 different lots of HemosIL® Protein S Activity kits stored at 2-8°C. At each time interval each control was run in 4 replicates and the mean value was compared to its established baseline value/range. The acceptance criteria were as follows: Normal Control, baseline mean ± 15%; Special Test Control Level 2, baseline mean ± 10%; High Abnormal Control, baseline mean ± 10%. The real time stability has been tested up to the months of 18 and 6 for lots 1 and 2, respectively. All the real time stability tests performed are within the established stability acceptance range.
**d. Detection limit**:
Limit of Detection (LOD) and Limit of Blank (LOB) were performed using two lots of HemosIL Protein S Activity reagent kits on two ACL TOP instruments. Protein S Deficient plasma was used for determination of LOB and a 5% Activity Protein S plasma was used for LOD. The Protein S Deficient plasma and the 5% Activity Protein S plasma were analyzed each day (n=12 per day) for 5 days (n=60 total) using both lots of the HemosIL Protein S Activity reagents. The data supports the detection limit claim on the
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ACL TOP family of 5%.
e. Analytical specificity:
An interference study was done with one lot of HemosIL Protein S Activity on an ACL TOP analyzer. Two samples, fresh frozen pool plasma and protein S depleted plasma were used to prepare three plasma pools with different protein S% activity. The three sample levels were spiked with multiple levels of the interferent, tested in quadruplicate, and the mean results compared to the unspiked control result. The acceptance criteria included the following: recovery of ± 15% of the unspiked control result. The data support the claims in the package insert for no significant interference at the concentrations noted by unfractionated heparin (UFH), 1.6 IU/mL; low molecular weight heparin (LMWH), 2.1 IU/mL; hemoglobin, 250 mg/dL; bilirubin, 15 mg/dL; and triglyceride, 2360 mg/dL.
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
An in-house method comparison study was conducted using the predicate and the HemosIL® Protein S Activity assay on an ACL TOP and ACL TOP 500 CTS. Results were calculated by comparing the first replicate values. The study included both normal (N=26) and abnormal (N=72) patient samples. A subset of these samples (N=47) was tested on an ACL TOP 500 CTS. The acceptance criteria were as follows: slope 0.9 – 1.1 and correlation coefficient (r) ≥ 0.95. Deming regression analysis for the ACL TOP shows that the slope and correlation coefficient (r) are 0.966 and 0.968, respectively. ACL TOP 500 CTS demonstrates the slope and correlation coefficient (r) are 1.046 and 0.975, respectively.
Two field site exercises were completed to further evaluate the HemosIL® Protein S Activity assay against its predicate. A method comparison was conducted at a cancer center using 72 normal and 71 abnormal samples. The second comparison was produced at a medical center using 78 normal and 62 abnormal samples. The acceptance criteria for both studies were as follows: slope 0.9 – 1.1 and r ≥ 0.95. The Deming regression analysis for the cancer center data performed on the ACL TOP shows that the slope and correlation coefficient (r) are 1.049 and 0.956, respectively. The medical center study performed on the ACL TOP produced a slope and correlation coefficient (r) of 0.984 and 0.965, respectively.
b. Matrix comparison:
Fresh v. Frozen Sample Study - Plasma samples were collected in evacuated glass tubes with 3.2% sodium citrate as an anticoagulant. Testing was performed on ACL TOP, as a representative family member, with the HemosIL® Protein S Activity assay. Fifty three normal donor samples, collected in-house, were used for the method comparison. Five different levels (10-70% of protein S activity) were prepared for each donor. As soon as the testing was completed for the fresh samples, they were stored at ≤ -70°C. The frozen plasma samples (stored for a minimum of 24 hours at ≤ -70°C) were
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then thawed in a 37°C water bath for 3 to 4 minutes. The acceptance criteria are as follows: slope 0.9 – 1.1 and r (correlation coefficient) ≥ 0.95. The study produced a slope = 0.992 and r = 0.99.
Comparison of 3.2% and 3.8% sodium citrate - From each of 28 donors, two blood samples were drawn, one in a 3.2% and the other in a 3.8% sodium citrate sample tube. Two pools, with different sodium citrate concentrations, were prepared using the same volume of citrated plasma from each donor. Protein S was depleted from each pool using a protein S monoclonal antibody resin. The donor samples then were diluted with the corresponding citrated protein S depleted plasma to produce a range of concentrations. The acceptance criteria are as follows: slope 0.9 – 1.1 and r ≥ 0.95. The study yielded a slope of 1.028 and r = 0.993.
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: A reference interval study was performed using one lot of HemosIL Protein S Activity reagent kit on an ACL TOP analyzer. A total of 165 normal samples (76 male, 89 female) were obtained and a normal range of 63.5 – 149.0% Protein S Activity was established statistically.
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.
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.