The BS-400/CLC 720 Chemistry Analyzers are designed for clinical laboratory use, making direct quantitative measurements of Na+ (sodium), K+ (potassium), Cl- (chloride) in serum, plasma and urine samples and Glucose in serum samples plasma and urine samples. Additionally, other various chemistry assays may be adaptable to the analyzer depending on the reagent used to induce a photometric reaction. Sodium measurements are used in the diagnosis and treatment diseases involving electrolyte imbalance. Potassium measurements monitor electrolyte balance and in the diagnosis and treatment of diseases conditions characterized by low or high blood potassium levels. Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders. 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.
Device Story
Automated clinical chemistry analyzer for in vitro diagnostic use in clinical laboratories. Inputs: serum, plasma, urine, or CSF samples. Operation: utilizes absorbance photometry for kinetic/endpoint assays and optional Ion-Selective Electrode (ISE) module for electrolyte (Na+, K+, Cl-) measurement. Principle: determines analyte concentration from standard curves generated with known concentrations. Output: quantitative clinical chemistry results. Operated by laboratory personnel. Healthcare providers use results to diagnose and monitor electrolyte imbalances, metabolic disorders, and carbohydrate metabolism conditions like diabetes.
Clinical Evidence
Bench testing only. Precision/reproducibility evaluated per CLSI EP05-A2; linearity per EP06-A; interference per EP07-A2; LoB/LoD/LoQ per EP17-A. Method comparison studies performed against Beckman Synchron CX7 (glucose) and BS-200 (ISE) using 110-218 patient samples. Glucose correlation r²=0.999-1.000; ISE correlation r²=0.994-0.999. No clinical studies required.
Technological Characteristics
Automated clinical chemistry analyzer. Sensing: absorbance photometry and Ion-Selective Electrodes (ISE). Connectivity: standalone. Software: automated analysis of photometric and ISE signals. Materials: standard laboratory analyzer components. Sterilization: N/A (in vitro diagnostic device).
Indications for Use
Indicated for clinical laboratory use to perform quantitative measurements of Na+, K+, Cl- in serum, plasma, and urine, and Glucose in serum, plasma, and urine. Used for diagnosis and treatment of electrolyte imbalances, metabolic disorders, and carbohydrate metabolism disorders (e.g., diabetes mellitus, neonatal/idiopathic hypoglycemia, pancreatic islet cell carcinoma).
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.
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k112377
B. Purpose for Submission:
New submission for the BS-400/CLC 720 using previously cleared Glucose Reagent (k971467) and the same ISE module cleared under Mindray’s BS-200 Chemistry Analyzer (k072018)
C. Measurand:
Glucose, Sodium, Potassium, Chloride
D. Type of Test:
Quantitative, Photometric and Ion Selective Electrode
E. Applicant:
Shenzhen Mindray Bio-Medical Electronics Co., Ltd
F. Proprietary and Established Names:
BS-400/CLC 720
G. Regulatory Information:
1. Regulation section:
21CFR Sec.-862.1345 Glucose test system
21CFR Sec.-862.1665 Sodium test system
21CFR Sec.-862.1600 Potassium test system
21CFR Sec.-862.1170 Chloride test system
21CFR Sec.-862.2160-Discrete photometric chemistry analyzer for clinical use
2. Classification:
Class II for assays
Class I for analyzer (reviewed as part of Class II test systems)
3. Product code:
CFR - hexokinase, glucose
JGS - electrode, ion specific, sodium
CEM - electrode, ion specific, potassium
CGZ - electrode, ion-specific, chloride
JJE - analyzer, chemistry (photometric, discrete), for clinical use
4. Panel:
Chemistry (75)
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H. Intended Use:
1. Intended use(s):
See indications for use below
2. Indication(s) for use:
The BS-400/CLC 720 Chemistry Analyzers are designed for clinical laboratory use, making direct quantitative measurements of Na+ (sodium), K+ (potassium), Cl- (chloride) in serum, plasma and urine samples and Glucose in serum samples plasma and urine samples. Additionally, other various chemistry assays may be adaptable to the analyzer depending on the reagent used to induce a photometric reaction.
Sodium measurements are used in the diagnosis and treatment diseases involving electrolyte imbalance.
Potassium measurements monitor electrolyte balance and in the diagnosis and treatment of diseases conditions characterized by low or high blood potassium levels.
Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders.
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.
3. Special conditions for use statement(s):
Prescription use
4. Special instrument requirements:
BS-400/CLC 720 Chemistry Analyzers
I. Device Description:
The BS-400/CLC 720 are automated chemistry analyzers for in vitro diagnostic use in clinical laboratories and designed for in vitro quantitative determination of clinical chemistries in serum, plasma and urine samples. The device is composed of a photometric module and an Ion Selective Electrode module.
The Glucose reagent is ready to use and the composition is Liquid Glucose (Hexokinase) Reagent: Hexokinase (yeast) 2000U/L, G6PDH (Leuconostoc mesenteroides) 4000U/L, ATP 1.1 mmol/L, NAD 2.7mmol/L, magnesium 2mmol/L, preservative and stabilizers. The reagent is manufactured by Carolina Liquid Chemistries for use on the BS-400/CLC 720 Chemistry Analyzers.
The ISE module is the same module as the one cleared on the BS- 200 analyzer and consists of ion selective electrodes for sodium, potassium, and chloride, a reference electrode and accessory reagents.
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J. Substantial Equivalence Information:
1. Predicate device name(s): BS-200 Chemistry Analyzer
2. Predicate 510(k) number(s): k072018
3. Comparison with predicate:
BS-400 and BS-200
| Feature | BS-400 | BS-200 |
| --- | --- | --- |
| Indications | The BS-400/CLC 720 Chemistry Analyzers are designed for clinical laboratory use, making direct quantitative measurements of Na+ (sodium), K+ (potassium), Cl- (chloride) in serum, plasma and urine samples and Glucose in serum samples plasma and urine samples. Additionally, other various chemistry assays may be adaptable to the analyzer depending on the reagent used to induce a photometric reaction. | Same |
| System Function | | |
| System Control | Automatic, computer controlled | same |
| LIS external connectivity capability | Yes | same |
| Calibration/QC | Automatic and Manual calibration/QC | same |
| Barcode | Yes | same |
| Throughput (Max) | | |
| | 400 photometric tests per hour | 200 photometric tests per hour |
| Configuration | | |
| | Analytical unit, Operational Unit | same |
| Principle of Analysis | | |
| Mode of detection | Photometric | same |
| Analytical methods | Endpoint Fixed-time Kinetic | same |
| Calibration methods | Linear calibration and nonlinear calibration | same |
| Optical Measurement Unit | | |
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| Feature | BS-400 | BS-200 |
| --- | --- | --- |
| Measurement Modes | Absorbance | same |
| Optical Modes | Monochromatic, Bichromatic | same |
| Photometer | Multi-wavelength diffraction grating spectrophotometer | same |
| Wavelength | 340nm, 380nm, 412nm, 450nm, 505nm, 546nm, 570nm, 605nm, 660nm, 700nm, 740nm and 800nm | 340nm, 405nm, 450nm,410nm, 546nm, 578nm, 630nm, 670nm |
| Linear absorbance range | 0-3.0 absorbance | 0-4.0 absorbance |
| Light Source | Tungsten halogen lamp | same |
| Detector | Photodiode | same |
| Reaction Unit | | |
| Reaction cuvettes | Plastic or Glass 90 non-disposable | Plastics, 80 disposable |
| Reaction volume | 150~360μL | 180~500uL |
| Path length | 5mm | same |
| Reaction temperature | 37°C | same |
| Sample and Reagent System | | |
| Sample disk | 90 positions. 30 positions respectively for inner, middle and outer circles. | 40 sample tube positions on the outer circle |
| Reagent disk | 80 positions. 40 positions respectively for inner and outer circles | 40 reagent bottle positions on the inner circle of the sample disk |
| Pipettor System | Positive displacement stepper motor driven | same |
| Refrigerator temperature | 2-10°C | 4-15°C |
| Sample Dispense | 2μL -45μL | 3μl -45μl |
| Reagent Dispense | 20μL-350μL | 30μl-450μl |
| POWER | | |
| Input | 110/115V~, 60Hz | 100-130V ,50/60±1 Hz |
| Operating environmental conditions | | |
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| Feature | BS-400 | BS-200 |
| --- | --- | --- |
| Temperature | 15°C to 30°C | same |
| Humidity | 35% to 80%, non-condensing | Same |
| | ISE (ion selective electrode technology) | same |
| Sample Type | | |
| | Serum, plasma, or diluted urine | same |
| Test | | |
| | Na+, K+, Cl | same |
| Sample Size | | |
| | 70 μL Serum, plasma mode; 140 μL Urine mode | same |
| ISE Calibration | | |
| | Two-point and single-point calibrations | same |
# K. Standard/Guidance Document Referenced (if applicable):
CLSI - Evaluation of Precision Performance of Clinical Chemistry Devices - EP05-A2
CLSI - Evaluation of the Linearity of Quantitative Analytical Methods - EP06-A
CLSI - Interference Testing in Clinical Chemistry - EP07-A2
CLSI - Method Comparison and Bias Estimation Using Patient Samples - EP09-A2
CLSI - Protocols for Determination of Limits of Detection and Limits of Quantitation - EP17-A
# L. Test Principle:
Glucose is phosphorylated with adenosine triphosphate (ATP) in the reaction catalyzed by hexokinase (HK). The product, glucose-6-phosphate (G6P) is then oxidized with the concomitant reduction of nicotinamide adenine dinucleotide (NAD) to NADH in the reaction catalyzed by glucose-6-phosphate-dehydrogenase (G6PDH). The formation of NADH causes an increase in absorbance at $340\mathrm{nm}$ . The increase is directly proportional to the amount of glucose in the sample.
The ion selective electrodes develop a voltage that varies with the concentration of the ion $(\mathrm{Na}^{+},\mathrm{K}^{+},\mathrm{Cl}^{-})$ to which they are specific. The relationship between the voltage developed and the concentration of the sensed ion is logarithmic and calculated by the Nernst equation.
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M. Performance Characteristics (if/when applicable):
These studies are intended to verify use of photometric and ISE technology on the analyzer.
1. Analytical performance:
a. Precision/Reproducibility:
Repeatability and within device imprecision for both serum/control and urine specimens are shown through the replicate assay of specimen pools and control materials over twenty days as described in CLSI document EP5-A2
Imprecision statistics are summarized below.
Imprecision of Glucose Measurements (in mg/dL)
| | | | | Repeatability | | Within Device Imprecision | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Specimen | Sample | n | mean | SD | %CV | SD | %CV |
| Serum | | | | | | | |
| | Control pool 1 | 120 | 56.3 | 0.57 | 1.0% | 0.88 | 1.6% |
| | Serum Pool | 120 | 117.0 | 0.83 | 0.7% | 1.74 | 1.5% |
| | Control pool 2 | 120 | 561.6 | 3.42 | 0.6% | 6.84 | 1.2% |
| Urine | | | | | | | |
| | Urine pool 1 | 117 | 14.9 | 0.26 | 1.7% | 0.32 | 2.1% |
| | Urine pool 2 | 117 | 194.3 | 1.08 | 0.6% | 1.91 | 1.0% |
| | Urine pool 3 | 120 | 330.0 | 1.80 | 0.5% | 2.95 | 0.9% |
ISE within-run precision
| Item | Level I | | | Level II | | |
| --- | --- | --- | --- | --- | --- | --- |
| | Mean | SD | CV% | Mean | SD | CV% |
| Serum K+ (mmol/L) | 3.49 | 0.02 | 0.54% | 6.21 | 0.03 | 0.43% |
| Serum Na+ (mmol/L) | 128.1 | 0.63 | 0.49% | 150.8 | 0.50 | 0.33% |
| Serum Cl- (mmol/L) | 84.8 | 0.95 | 1.12% | 117.9 | 0.51 | 0.44% |
| | Urine Level I | | | Urine Level II | | |
| Urine K+ (mmol/L) | 21 | 0.51 | 2.48% | 44 | 0.00 | 0.00% |
| Urine Na+ (mmol/L) | 65 | 1.60 | 2.46% | 124 | 1.81 | 1.47% |
| Urine CL- (mmol/L) | 53 | 1.08 | 2.03% | 106 | 1.15 | 1.08% |
ISE Total precision
| Item | Level I | | | Level II | | |
| --- | --- | --- | --- | --- | --- | --- |
| | Mean | SD | CV% | Mean | SD | CV% |
| Serum K+ (mmol/L) | 3.48 | 0.03 | 0.78 | 6.17 | 0.04 | 0.64 |
| Serum Na+ (mmol/L) | 129.1 | 1.00 | 0.78 | 150.4 | 0.89 | 0.59 |
| Serum Cl- (mmol/L) | 85.1 | 1.10 | 1.29 | 117.1 | 0.96 | 0.82 |
| | Urine Level I | | | Urine Level II | | |
| Urine K+ (mmol/L) | 21 | 0.47 | 2.23 | 44 | 0.24 | 0.56 |
| Urine Na+ (mmol/L) | 67 | 3.19 | 4.75 | 126 | 3.45 | 2.74 |
| Urine CL- (mmol/L) | 56 | 2.13 | 3.83 | 108 | 2.02 | 1.87 |
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b. Linearity/assay reportable range:
Linearity claims for both the serum and urine applications are validated using procedures based on CLSI document EP06-A
## Glucose
A first set of 0, 5, 25, 50, 100, 200, 300, 400, 500, 600 and 700 mg/dL glucose (NIST SRM 917c) in a matrix of 7 g/dL BSA, 0.85% sodium chloride, and an inert preservative for the serum/plasma application.
A second, analogous set of standards was similarly prepared in an aqueous matrix without BSA for the urine application.
## ISE
Linearity samples were prepared by using low and high samples with serial dilution schemes to cover 11 points in the test range.
| Measuring Range | | |
| --- | --- | --- |
| Glucose mg/dL Serum/Plasma Based on LOQ and Linearity y = 0.999x + 0.777 R² = 1 | 5 | 700 |
| Glucose Urine mg/dL Based on LOQ and Linearity y = 1.002x + 0.610 R² = 1 | 2 | 700 |
| ISE Based on Linearity and supported by LOQ | | |
| K (mmol/L) serum(ISE) y = 1.0007x - 0.0051 R² = 0.9998 | 0.94 | 8.2 |
| Na (mmol/L) serum(ISE) y = 1.0001x - 0.0038 R² = 0.9998 | 71 | 232.3 |
| CL (mmol/L) serum(ISE) y = 1.0001x - 0.015 R² = 0.9999 | 50 | 198 |
| K (mmol/L) Urine(ISE) y = 0.9998x + 0.0203 R² = 0.9987 | 3.5 | 209.3 |
| Na (mmol/L) Urine(ISE) y = 1.0000x - 0.0024 R² = 0.9999 | 9.25 | 725.5 |
| CL (mmol/L) Urine(ISE) y = 0.9999x + 0.0129 R² = 0.9986 | 7.25 | 693.3 |
c. Traceability, Stability, Expected values (controls, calibrators, or methods): Cleared under Point Multi-Analyte Chemistry Calibrator (k070207) Cleared under Medica EasyElectroLyte/RapidLyte Na/K/Cl Analyzer (k000926)
d. Detection limit:
The limits of blank (LoB) and detection (LoD) are listed below with the number of determinations they are based on. These limits were determined consistent with the guidelines of CLSI protocol EP17-A with proportions of false positives less than 5% and false negatives less than 5%.
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Glucose
| Specimen | n | LoB | LoD | LOQ |
| --- | --- | --- | --- | --- |
| Serum | 80 | 2.2 | 2.6 | 5.0 mg/dL |
| Urine | 60 | 0.6 | 0.9 | 1.0 mg/dL |
ISE
| Item | n | LoB | LoD | LoQ |
| --- | --- | --- | --- | --- |
| Serum | | | | |
| K (mmol/L) | 60 | 0.06 | 0.08 | 0.48 |
| Na (mmol/L) | 60 | 0.92 | 1.41 | 3.27 |
| CL (mmol/L) | 60 | 1.12 | 1.94 | 5.04 |
| Urine | | | | |
| K (mmol/L) | 60 | 1.50 | 1.76 | 3.01 |
| Na (mmol/L) | 60 | 3.50 | 6.88 | 11.22 |
| CL (mmol/L) | 60 | 1.00 | 2.96 | 5.55 |
e. Analytical specificity:
Glucose
Effects of potentially interfering substances are shown by spiking serum pools with increasing amounts of interferent and measuring the effect of the additions on results. Bilirubin, hemoglobin, and Intralipid® 20% Emulsion are used to estimate icterus, hemolysis, and lipemia interference.
| Interferent | Glucose Concentration | Interferent Concentration | Change in Glucose Result |
| --- | --- | --- | --- |
| Ascorbic acid | 76 mg/dL | 30 mg/L† | -0.1 mg/dL* |
| | 140 mg/dL | 30 mg/L† | -0.8 mg/dL* |
| Bilirubin | 78 mg/dL | 4.8 mg/dL | -2.6 mg/dL |
| | | 8.0 mg/dL | -4.0 mg/dL |
| | 138 mg/dL | 8.0 mg/dL | -3.3 mg/dL |
| | | 16.0 mg/dL | -6.9 mg/dL |
| Hemoglobin | 74 mg/dL | 400 mg/dL† | -2.0 mg/dL |
| | 134 mg/dL | 400 mg/dL† | -3.8 mg/dL |
| Triglycerides (non-turbid) | 69 mg/dL | 728 mg/dL | +2.3 mg/dL |
| | | 910 mg/dL | +3.0 mg/dL |
| | 115 mg/dL | 742 mg/dL | +2.2 mg/dL |
| | | 927 mg/dL† | +2.7 mg/dL |
| Metronidazole | 75 mg/dL | 24 mg/L | +2.6 mg/dL |
| | | 48 mg/L | +5.6 mg/dL |
| | 137 mg/dL | 24 mg/L | +3.1 mg/dL |
| | | 48 mg/L | +5.1 mg/dL |
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| Tetracycline | 76 mg/dL | 15 mg/L† | -1.5 mg/dL |
| --- | --- | --- | --- |
| | 140 mg/dL | 15 mg/L† | -1.5 mg/dL |
| EDTA | 76 mg/dL | 8 mg/mL† | +0.2 mg/dL* |
| | 145 mg/dL | 8 mg/mL† | -0.1 mg/dL* |
| Potassium oxalate | 76 mg/dL | 8 mg/dL† | +0.0 mg/dL* |
| | 146 mg/dL | 8 mg/dL† | -0.8 mg/dL* |
| Sodium citrate | 76 mg/dL | 140 mg/dL† | -1.1 mg/dL |
| | 145 mg/dL | 140 mg/dL† | -2.8 mg/dL |
| Sodium fluoride | 77 mg/dL | 10 mg/dL† | +0.1 mg/dL* |
| | 145 mg/dL | 10 mg/dL† | +0.9 mg/dL* |
* Result is statistically insignificant at p=0.05.
† Highest level tested.
Serum pools containing 73 mg/dL and 121 mg/dL glucose and respectively spiked with 50 mg/dL and 60 mg/dL Intralipid® give lipemia index values of 47.1 and 54.9. Both pools appear moderately lipemic.
Visibly lipemic specimens with lipemic index values greater than 47 may produce elevated results. Assay these specimens using the Glucose (Blanked) Application.
ISE
Interference: Interference studies were performed based on CLSI document EP7-A2, the test results are showing below with no interference up to the amounts tested.
| Item | Interference materials | | |
| --- | --- | --- | --- |
| | Hemoglobin | Bilirubin | Lipemia Intralipids® |
| K (mmol/L) | 500 mg/dL | 40 mg/dL | 1000 mg/dL |
| Na (mmol/L) | 500 mg/dL | 40 mg/dL | 1000 mg/dL |
| CL (mmol/L) | 500 mg/dL | 40 mg/dL | 1000 mg/dL |
Note: Hemolysis: Hemoglobin had no interference to serum K⁺ due to Hemoglobin used not having K⁺, but Hemolysis will interfere with K⁺ due to the high K⁺ concentration in erythrocytes.
f. Assay cut-off: Not Applicable
2. Comparison studies:
a. Method comparison with predicate device:
Method comparison using 110 serum and 108 plasma samples (vs. Beckman
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Synchron CX7)
| Item | Specimen | N | r2 | Slope | Intercept | Range |
| --- | --- | --- | --- | --- | --- | --- |
| GLU (mg/dL) | Serum + Plasma | 218 | 0.999 | 0.989 | 1.31 | 38 – 672 |
| GLU (mg/dL) | Serum | 110 | 1.000 | 0.992 | 1.40 | 38 – 672 |
| GLU (mg/dL) | Plasma | 108 | 0.999 | 0.986 | 1.22 | 42 – 672 |
Method comparison using urine samples (vs. Beckman Synchron CX7)
| Item | N | r2 | Slope | Intercept | Range |
| --- | --- | --- | --- | --- | --- |
| GLU (mg/dL) | 108 | 1.000 | 1.001 | 1.36 | 2 – 660 |
ISE analysis (vs. BS-200 Chemistry Analyzer)
| Item (mmol/L) | Regression Slope | Regression Intercept | Correlation coefficient square R2 | Analyze Range of BS-400 (mmol/L) | Sample numbers |
| --- | --- | --- | --- | --- | --- |
| Serum K+ | 1.0097 | 0.0591 | 0.997 | 0.93~8.18 | 40 |
| Serum Na+ | 1.0092 | -0.7885 | 0.9975 | 70.7~232.3 | 40 |
| Serum Cl- (mmol/L) | 0.9763 | 1.3848 | 0.9946 | 49.5~198.0 | 40 |
| Urine K+ | 0.9718 | 1.7022 | 0.9996 | 4~210 | 40 |
| Urine Na+ | 1.0249 | -13.487 | 0.9994 | 12~725 | 40 |
| Urine Cl- | 0.9984 | 2.1591 | 0.9996 | 7~690 | 40 |
b. Matrix comparison:
See 2.a method comparison above for glucose plasma and urine and ISE urine claim. The plasma claim for the ISE electrodes was previously cleared under the Medica EasyElectroLyte/RapidLyte Na/K/Cl Analyzer (k000926).
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:
Glucose
Sample Conventional Units SI Units
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Serum/Plasma 74 to 100 mg/dL 4.1 to 5.1 mmol/L
Urine, Random 1 to 15 mg/dL 0.1 to 0.8 mmol/L
Urine, 24 hour < 0.5 g/day < 2.87 mmol/day
Tietz Textbook of Clinical Chemistry and Molecular Diagnostics. Elsevier Inc., St. Louis, MO, 2006.
Sodium – serum: 136-145 mmol/L, 24 hour urine: 40-220 mmol/L
Potassium – serum: 3.5-5.1 mmol/L, 24 hour urine: 25-125 mmol/L
Chloride – serum: 98-107 mmol/L, 24 hour urine: 110-250 mmol/L
Tietz, N.W., Clinical Guide to Laboratory Tests, Philadelphia, W.B. Saunders, 1990
## N. Instrument Name:
BS-400/CLC 720 Chemistry Analyzer
## O. System Descriptions:
1. Modes of Operation:
Random access instrument with ISE module
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 ☐ or No ☐ X
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:
Sample bar code option
4. Specimen Sampling and Handling:
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Random access and stat mode operation Samples are loaded on sample disk
5. Calibration:
Linear calibration and nonlinear calibration
6. Quality Control:
Includes quality control program
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
None
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.
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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.