ACE DIRECT TOTALIRON-BINDING CAPACITY (TIBC) REAGENT, ACE SERUM IRON REAGENT, ACE LIPASE REAGENT
K113438 · Alfa Wassermann Diagnostic Technologies, Inc. · JMO · Jun 1, 2012 · Clinical Chemistry
Device Facts
Record ID
K113438
Device Name
ACE DIRECT TOTALIRON-BINDING CAPACITY (TIBC) REAGENT, ACE SERUM IRON REAGENT, ACE LIPASE REAGENT
Applicant
Alfa Wassermann Diagnostic Technologies, Inc.
Product Code
JMO · Clinical Chemistry
Decision Date
Jun 1, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1415
Device Class
Class 1
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K113438 · Jun 1, 2012
ACE DIRECT TOTALIRON-BINDING CAPACITY (TIBC) REAGENT, ACE SERUM IRON REAGENT, ACE LIPASE REAGENT
Alfa Wassermann Diagnostic Technologies, Inc.
Physician Office Laboratory (POL) patient samples
Patient correlation studies were performed at three independent POL sites to demonstrate the accuracy and performance of the ACE Axcel Clinical Chemistry System reagents compared to the predicate ACE Clinical Chemistry System using routine clinical patient samples.
POL correlation study; Accuracy; Clinical performance
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
POL Patient Correlation Studies; Retrospective/Prospective clinical correlation study; Follow-up/Duration: 5 days
Clinical patient samples; Sample Size: Not specified (multiple samples across 3 sites); Number of Sites: 3
Alfa Wassermann ACE Clinical Chemistry System
Correlation coefficient, standard error estimate, slope, and intercept
Indications for Use
The ACE Axcel Clinical Chemistry System is an automated, discrete, bench-top, random access analyzer that is intended for in vitro diagnostic use in the quantitative determination of constituents in blood and other fluids. The ACE TIBC Reagent is intended for the quantitative determination of total iron-binding capacity in serum using the ACE Axcel Clinical Chemistry System. Iron-binding capacity measurements are used in the diagnosis and treatment of anemia. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only. The ACE Serum Iron Reagent is intended for the quantitative determination of iron concentration in serum using the ACE Axcel Clinical Chemistry System. Iron (non-heme) measurements are used in the diagnosis and treatment of diseases such as iron deficiency anemia, hemochromatosis (a disease associated with widespread deposit in the tissues of two iron-containing pigments, hemosiderin and hemofuscin, and characterized by pigmentation of the skin), and chronic renal disease. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only. The ACE Lipase Reagent is intended for the quantitative determination of lipase activity in serum using the ACE Axcel Clinical Chemistry System. Lipase measurements are used in diagnosis and treatment of diseases of the pancreas such as acute pancreatitis and obstruction of the pancreatic duct. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only.
Device Story
Device consists of three colorimetric reagent assays (TIBC, Serum Iron, Lipase) for use on ACE Axcel Clinical Chemistry System. Reagents are two-part liquid formulations. TIBC assay uses chromazurol B/cetrimide/ferric chloride; Serum Iron uses ferrozine; Lipase uses 1,2-diglyceride substrate with redox-coupled enzymatic reaction. System measures absorbance changes (bichromatic or monochromatic) to determine analyte concentration or activity. Used in clinical/physician office labs by trained personnel. Output is quantitative concentration/activity value. Results assist clinicians in diagnosing anemia, iron-related disorders, and pancreatic conditions.
Clinical Evidence
Bench testing only. Precision evaluated per CLSI EP5-A2 and EP10-A3 across multiple sites. Linearity confirmed for TIBC (42-700 μg/dL), Iron (12-600 μg/dL), and Lipase (15-700 U/L). Method comparison against predicate (k931786) using Deming regression showed high correlation (R² > 0.99) for all assays. Interference testing performed for bilirubin, hemolysis, lipemia, and ascorbic acid.
Indicated for quantitative determination of total iron-binding capacity, serum iron, and lipase activity in serum for patients requiring diagnosis or treatment of anemia, iron deficiency, hemochromatosis, chronic renal disease, or pancreatic diseases (e.g., pancreatitis, duct obstruction). Intended for use in clinical or physician office laboratories.
Regulatory Classification
Identification
An iron-binding capacity test system is a device intended to measure iron-binding capacity in serum. Iron-binding capacity measurements are used in the diagnosis and treatment of anemia.
Predicate Devices
Alfa Wassermann ACE Clinical Chemistry System (K931786)
{0}
1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k113438
B. Purpose for Submission:
New Device
C. Measurand:
Total iron-binding capacity
Iron
Lipase
D. Type of Test:
Quantitative, colorimetric assay
E. Applicant:
Alfa Wassermann Diagnostic Technologies, LLC
F. Proprietary and Established Names:
ACE Direct Total Iron-Binding capacity (TIBC) Reagent
ACE Serum Iron Reagent
ACE Lipase Reagent
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JMO | Class I, reserved | 21 C.F.R. §862.1415
Iron-Binding Capacity Test | Clinical Chemistry (75) |
| JIY | Class I, reserved | 21 C.F.R. §862.1410
Iron (non-heme) Test System | Clinical Chemistry (75) |
| CHI | Class I (meets the limitations of exemptions in 21 CFR 862.9(c)(9)) | 21 C.F.R. §862.1465
Lipase Test System | Clinical Chemistry (75) |
{1}
H. Intended Use:
1. Intended use(s):
Please see indication use below.
2. Indication(s) for use:
ACE TIBC Reagent is intended for the quantitative determination of total iron-binding capacity in serum using the ACE Axcel Clinical Chemistry System. Iron-binding capacity measurements are used in the diagnosis and treatment of anemia. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only.
The ACE Serum Iron Reagent is intended for the quantitative determination of iron concentration in serum using the ACE Axcel Clinical Chemistry System. Iron (non-heme) measurements are used in the diagnosis and treatment of diseases such as iron deficiency anemia, hemochromatosis (a disease associated with widespread deposit in the tissues of two iron-containing pigments, hemosiderin and hemofusion, and characterized by pigmentation of the skin), and chronic renal disease. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only.
The ACE Lipase Reagent is intended for the quantitative determination of lipase activity in serum using the ACE Axcel Clinical Chemistry System. Lipase measurements are used in diagnosis and treatment of diseases of the pancreas such as acute pancreatitis and obstruction of the pancreatic duct. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only.
3. Special conditions for use statement(s):
For prescription Use.
4. Special instrument requirements:
ACE Axcel Clinical Chemistry System
I. Device Description:
ACE Direct Total Iron-Binding capacity (TIBC) Reagent assay consists of the Direct TIBC Color Reagent (R1) and the Direct TIBC Buffer (R2). The Direct TIBC Color Reagent contains chromazurol B, cetrimide, ferric chloride and acetate buffer. The Direct TIBC Buffer contains sodium bicarbonate buffer. Both reagents are added to the serum sample.
ACE Serum Iron Reagent is composed of two reagent bottles, Buffer (R1) and Color Reagent (R2). The Buffer contains hydroxylamine hydrochloride, acetate buffer (pH 4.5) and surfactant. The Color Reagent contains ferrozine and hydroxylamine hydrochloride.
ACE Lipase Reagent is composed of two reagents, the Lipase Reagent (R1) and the Lipase Activator Reagent (R2). The Lipase Reagent contains 1, 2dyclicicide, monoglyceride lipase, glycerol kinase, glycerol-3-phosphate oxidase, N-ethyl-N-(2-hydroxy-3-sulfopropyl)-m-
{2}
toluidine, ATP, peroxidase and cholic acid. The Lipase Activator Reagent contains deoxycholate and 4-Aminoantipyrene.
# J. Substantial Equivalence Information:
1. Predicate device name(s):
ACE Clinical Chemistry System, ACE TIBC Reagent
ACE Clinical Chemistry System, ACE Serum Iron Reagent
ACE Clinical Chemistry System, ACE Lipase Reagent
2. Predicate $510(\mathrm{k})$ number(s):
k931786
3. Comparison with predicate:
| Attribute | ACE Direct Total Iron-Binding Capacity (TIBC) Reagent (Candidate Device – k113438) | ACE Clinical Chemistry System, ACE TIBC Reagent (Predicate – k931786) |
| --- | --- | --- |
| Indication for use / Intended Use | It is intended for the quantitative determination of Total Iron Binding Capacity in serum | Same |
| Instrument | ACE Axcel Clinical Chemistry System | ACE and ACE Alera® Clinical Chemistry Systems |
| Sample | Serum | Same |
| Reagent type | Two part liquid | Same |
| Reaction Type/Test Methodology | Delta/ Measurement of the capacity of serum protein to bind to iron using a dye. | Same |
| Measuring range | 42 - 700 μg/dL | Same |
| Storage Temperature after opening | 10-14°C for 8 hrs per day / capped and refrigerated at 2-8 °C when not in use | Same |
| Onboard Stability Claim | 30 days | Same |
| Shelf life | Stable until expiration date on box when stored at 2-8°C | Same |
| Attribute | ACE Serum Iron Reagent (Candidate Device – k113438) | ACE Clinical Chemistry System, ACE Serum Iron Reagent (Predicate – k931786) |
| --- | --- | --- |
| Indication for use / Intended Use | It is intended for the quantitative determination of Iron in serum | Same |
| Instrument | ACE Axcel Clinical Chemistry System | ACE and ACE Alera and NExCT Clinical Chemistry Systems |
{3}
| Sample | serum | Same |
| --- | --- | --- |
| Reagent type | Two part liquid | Same |
| Reaction Type/Test Methodology | Endpoint/Ferrachrome/Ferrozine without protein removal | Same |
| Linearity range | 12 - 600μg/dL | Same |
| Storage Temperature after opening | 10-14°C | Same |
| Onboard Stability Claim | 30 days | Same |
| Shelf life | Stable until expiration date on box when stored at 2-8°C | Same |
| Attribute | ACE Lipase Reagent (Candidate Device - k113438) | ACE Clinical Chemistry System, ACE Lipase Reagent (Predicate - k931786) |
| --- | --- | --- |
| Indication for use / Intended Use | The ACE Lipase Reagent is intended for the quantitative determination of lipase activity in serum | Same |
| Instrument | ACE Axcel Clinical Chemistry System | ACE and ACE Alera® Clinical Chemistry Systems |
| Sample | Serum | Same |
| Reagent type | Two part liquid | Same |
| Reaction Type/Test Methodology | Delta / Colorimetric method | Same |
| Linearity range | 15 – 700U/L | 11 – 700U/L |
| Storage Temperature after opening (onboard) | 10-14°C | 1 week @ 25°C 3 weeks @ 2-8°C |
| Onboard Stability Claim | 20 days | 20 days |
| Shelf life | Stable until expiration date on box when stored at 2-8°C | Same |
# K. Standard/Guidance Document Referenced (if applicable):
Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline (CLSI EP6-A)
Interference Testing in Clinical Chemistry; Approved Guidelines- Second edition (CLSI EP7-A2)
{4}
Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline- Second Edition (CLSI EP5-A2)
Preliminary Evaluation of Quantitative Clinical Laboratory Measurement Procedures – Third Edition (CLSI EP10 –A3)
Method Comparison and Bias Estimation Using Patient Samples; Approved Guideline- Second Edition (CLSI EP9-A2-IR)
Protocols for Determination of Limits of Detection; Approved Guideline (CLSI EP17-A)
## L. Test Principle:
**ACE Direct Total Iron-Binding capacity (TIBC) Reagent**
The Direct TIBC Color reagent releases iron from transferrin, forming a color complex with the dye. Then the Direct TIBC Buffer is added, shifting the pH and resulting in a large affinity of transferrin for iron. The serum transferrin rapidly binds the iron by abstracting the iron from the dye-iron complex. The decrease in absorbance is directly proportional to the total iron binding capacity of the serum sample. The absorbance is measured at 647 nm.
**ACE Serum Iron Reagent**
The transferring-bound iron in serum is released at a pH and reduced from ferric to ferrous iron. These ions react with ferrozine to form a violet color complex, which is measured bichromatically at 554 nm/692 nm. The intensity of color produced is directly proportional to the serum iron concentration.
**ACE Lipase Reagent**
Serum lipase acts on a natural substrate, 1, 2-diglyceride, to liberate 2-monoglyceride. A series of redox reactions take place leading to the formation of a quinine dye. The rate of formation of the dye, determined bichromatically at an absorbance of 573 nm/692 nm, is proportional to the lipase activity in the sample.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
**In house: ACE Direct Total Iron-Binding capacity (TIBC) Reagent**
Within-Run and Total precision evaluations were determined following CLSI EP5-A2. Four levels, three serum based pool and one normal human serum sample, were tested on the ACE Axcel Clinical Chemistry System analyzer in two runs per day, with two replicates of each level per run for 22 days.
5
{5}
| Sample 1 Mean 176.3 μg/dL TIBC | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 3.9 | 1.7 | 4.1 | 5.9 |
| Coefficient of Variation | 2.2% | 1.0% | 2.3% | 3.3% |
| Sample 2 Mean 342.8 μg/dL TIBC | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 3.5 | 2.5 | 5.2 | 6.8 |
| Coefficient of Variation | 1.0% | 0.7% | 1.5% | 2.0% |
| Sample 3 Mean 444.9 μg/dL TIBC | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 7.4 | 0.0 | 7.4 | 10.5 |
| Coefficient of Variation | 1.7% | 0.0% | 1.7% | 2.4% |
| Sample 4 Mean 320.3 μg/dL TIBC | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 2.9 | 3.9 | 4.5 | 6.7 |
| Coefficient of Variation | 0.9% | 1.2% | 1.4% | 2.1% |
Point of Care Laboratory: ACE Direct Total Iron-Binding capacity (TIBC) Reagent Point of care precision evaluations were determined following CLSI EP10-A3. Three serum based pools were tested on the ACE Axcel Clinical Chemistry System analyzer in one run per day, with three replicates of each level per run for 5 days.
| TIBC | | | Within Run | | Total | |
| --- | --- | --- | --- | --- | --- | --- |
| Lab | Sample | Mean μg/dL | SD | %CV | SD | %CV |
| POL 1 | 1 | 177.3 | 2.3 | 1.3 | 3.2 | 1.8 |
| POL 2 | 1 | 175.2 | 5.6 | 3.2 | 6.7 | 3.8 |
| POL 3 | 1 | 180.1 | 6.1 | 3.4 | 7.4 | 4.1 |
| | | | | | | |
| POL 1 | 2 | 340.2 | 2.2 | 0.6 | 3.1 | 0.9 |
| POL 2 | 2 | 334.2 | 4.1 | 1.2 | 9.7 | 2.9 |
| POL 3 | 2 | 338.6 | 3.3 | 1.0 | 9.2 | 2.7 |
| | | | | | | |
| POL 1 | 3 | 439.7 | 6.9 | 1.6 | 8.2 | 1.9 |
| POL 2 | 3 | 422.9 | 6.7 | 1.6 | 11.6 | 2.8 |
| POL 3 | 3 | 433.6 | 8.9 | 2.1 | 12.0 | 2.8 |
{6}
In house: ACE Serum Iron Reagent
Within-Run and Total precision evaluations were determined following CLSI EP5-A2. Four levels, three serum based pool and one normal human serum sample were tested on one ACE Axcel Clinical Chemistry System analyzer in two runs per day, with two replicates of each level per run for 22 days.
| Sample 1
Mean 70.2 μg/dL
Total Iron | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 3.7 | 0.0 | 1.0 | 3.8 |
| Coefficient of Variation | 5.2% | 0.0% | 1.5% | 5.4% |
| Sample 2
Mean 269.6 μg/dL
Total Iron | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 6.3 | 0.0 | 1.6 | 6.5 |
| Coefficient of Variation | 2.3% | 0.0% | 0.6% | 2.4% |
| Sample 3
Mean 457.1 μg/dL
Total Iron | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 5.5 | 2.6 | 0.7 | 6.1 |
| Coefficient of Variation | 1.2% | 0.6% | 1.2% | 1.3% |
| Sample 4
Mean 58.8 μg/dL
Total Iron | Within Run | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, μg/dL | 2.7 | 0.0 | 1.5 | 3.1 |
| Coefficient of Variation | 4.7% | 0.0% | 2.5% | 5.3% |
Point of Care Laboratory: ACE Serum Iron Reagent
Point of care precision evaluations were determined following CLSI EP10-A3. Three serum based pools were tested on the ACE Axcel Clinical Chemistry System analyzer in one run per day, with three replicates of each level per run for 5 days.
| Total Iron | | | Within Run | | Total | |
| --- | --- | --- | --- | --- | --- | --- |
| Lab | Sample | Mean μg/dL | SD | %CV | SD | %CV |
| POL 1 | 1 | 71.3 | 2.9 | 4.1 | 2.9 | 4.1 |
| POL 2 | 1 | 72.5 | 2.5 | 3.4 | 2.6 | 3.6 |
| POL 3 | 1 | 79.5 | 2.1 | 2.6 | 3.3 | 4.2 |
| | | | | | | |
| POL 1 | 2 | 269.2 | 4.4 | 1.6 | 4.4 | 1.6 |
{7}
8
| POL 2 | 2 | 272.5 | 4.2 | 1.5 | 4.2 | 1.5 |
| --- | --- | --- | --- | --- | --- | --- |
| POL 3 | 2 | 281.7 | 3.9 | 1.4 | 4.7 | 1.7 |
| | | | | | | |
| POL 1 | 3 | 457.0 | 5.6 | 1.2 | 5.6 | 1.2 |
| POL 2 | 3 | 458.8 | 7.8 | 1.7 | 7.8 | 1.7 |
| POL 3 | 3 | 473.3 | 6.3 | 1.3 | 6.3 | 1.3 |
**In house: ACE Lipase Reagent**
Within-Run and Total precision evaluations were determined following CLSI EP5-A2. Four serum based levels of lipase were tested on the ACE Axcel Clinical Chemistry System analyzer in two runs per day with two replicates of each level per run for 22 days.
| Sample 1
Mean 38.5 U/L Lipase | Within
Run | Between
Run | Between
Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, U/L | 2.5 | 2.8 | 1.7 | 4.1 |
| Coefficient of Variation | 6.5% | 7.3% | 4.4% | 10.7% |
| Sample 2
Mean 248.35 U/L Lipase | Within
Run | Between
Run | Between
Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, U/L | 3.62 | 2.53 | 15.13 | 15.76 |
| Coefficient of Variation | 1.5% | 1.0% | 6.1% | 6.3% |
| Sample 3
Mean 403.27 U/L Lipase | Within
Run | Between
Run | Between
Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, U/L | 4.61 | 3.53 | 24.40 | 25.08 |
| Coefficient of Variation | 1.1% | 0.9% | 6.1% | 6.2% |
| Sample 4
Mean 56.0 U/L Lipase | Within
Run | Between
Run | Between
Day | Total |
| --- | --- | --- | --- | --- |
| Standard Deviation, U/L | 2.6 | 2.7 | 2.6 | 4.5 |
| Coefficient of Variation | 4.6% | 4.8% | 4.6% | 8.1% |
**Point of Care Laboratory: ACE Lipase Reagent**
Point of care precision evaluations were determined following CLSI EP10-A3. Three serum based samples containing varying levels of lipase were tested on the ACE Axcel Clinical Chemistry System analyzer in one run per day with three replicates of each level per run for 5 days.
{8}
| Lipase | | | Within Run | | Total | |
| --- | --- | --- | --- | --- | --- | --- |
| Lab | Sample | Mean μg/dL | SD | %CV | SD | %CV |
| POL 1 | 1 | 39.13 | 1.97 | 5.0 | 2.70 | 6.9 |
| POL 2 | 1 | 33.96 | 2.49 | 7.3 | 2.49 | 7.3 |
| POL 3 | 1 | 33.20 | 2.14 | 6.4 | 2.14 | 6.4 |
| | | | | | | |
| POL 1 | 2 | 257.75 | 3.56 | 1.4 | 6.14 | 2.4 |
| POL 2 | 2 | 267.93 | 5.31 | 2.0 | 9.62 | 3.6 |
| POL 3 | 2 | 261.65 | 3.85 | 1.5 | 6.64 | 2.5 |
| | | | | | | |
| POL 1 | 3 | 416.27 | 4.96 | 1.2 | 7.89 | 1.9 |
| POL 2 | 3 | 432.68 | 5.97 | 1.4 | 11.97 | 2.8 |
| POL 3 | 3 | 426.92 | 3.14 | 0.7 | 9.73 | 2.3 |
b. Linearity/assay reportable range:
ACE Direct Total Iron-Binding capacity (TIBC) Reagent
Linearity studies were carried out using dilutions of a spiked serum samples. Twelve concentrations were prepared by mixing spiked serum samples in known portions of saline. All samples were measured in triplicate. The sample range tested was 29.7 to 742 μg/dL.
| Claimed Measuring Range | Intercept | Slope | r² |
| --- | --- | --- | --- |
| 42-700 μg/dL | 0.3 | 1.016 | 0.9966 |
Based on the linearity data, the measuring range claimed from 42-700 μg/dL was supported.
ACE Serum Iron Reagent
Linearity studies were carried out using dilutions of a spiked serum samples. Ten concentrations were prepared by mixing spiked serum samples in known portions of saline. All samples were measured in triplicate. The sample range tested was 11.7 to 606.0 μg/dL.
| Claimed Measuring Range | Intercept | Slope | r² |
| --- | --- | --- | --- |
| 12-600μg/dL | 3 | 0.990 | 0.9996 |
{9}
Based on the linearity data, the measuring range claimed from $12 - 600\mu \mathrm{g / dL}$ was supported.
# ACE Lipase Reagent
Linearity studies were carried out using dilutions of a spiked serum samples.
Thirteen samples with increasing lipase concentrations were measured in triplicate.
The sample range tested was 14.5 to $757.7\mathrm{U / L}$
| Claimed Measuring Range | Intercept | Slope | r2 |
| --- | --- | --- | --- |
| 15-700 U/L | 0.294 | 1.000 | 1.000 |
Based on the linearity data, the measuring range claimed from 15-700 U/L was supported.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability
ACE Direct Total Iron-Binding capacity (TIBC) Reagent
Traceable to another commercially available FDA cleared assay by method comparison. The calibrator was previously cleared under k060264.
ACE Serum Iron Reagent
Traceable to NIST SRM 937. The calibrator was previously cleared under k961588.
ACE Lipase Reagent
Traceable to another commercially available FDA cleared assay by method comparison. The calibrator was previously cleared under k897150.
d. Detection limit:
Detection Limits (LoB and LoD) were performed using 60 blank and 60 low serum samples as per the recommendations of CLSI EP 17A protocol. LoB and LoD were calculated to be: TIBC: $\mathrm{LoB} = 35\mu \mathrm{g / dL}$ , $\mathrm{LoD} = 42\mu \mathrm{g / dL}$ ; Total Iron: $\mathrm{LoB} = 2\mu \mathrm{g / dL}$ , $\mathrm{LoD} = 5\mu \mathrm{g / dL}$ ; Lipase: $\mathrm{LoB} = 8.44\mathrm{U / L}$ , $\mathrm{LoD} = 10.63\mathrm{U / L}$ .
e. Analytical specificity:
ACE Direct Total Iron-Binding capacity (TIBC) Reagent
Interference studies were performed by using serum pools containing $258.0~\mu \mathrm{g / dL}$ to $296.6~\mu \mathrm{g / dL}$ and $600~\mu \mathrm{g / dL}$ of TIBC with individual interferents at a range of concentrations. The sera were assayed for TIBC ( $n = 3$ replicates) and the mean result calculated. Interference was considered to be significant by the sponsor if the analyte recovery changed by $> \pm 10\%$ . The results reported were obtained on ACE Axcel Clinical Chemistry System analyzer using fresh ACE Direct Total Iron-Binding capacity (TIBC) Reagent.
{10}
11
Interferents Claim
| Interferents | No Significant Interference At or Below |
| --- | --- |
| Unconjugated Bilirubin | 55 mg/dL |
| Hemolysis | 250 mg/dL |
| Lipemia (Intralipid) | 1000 mg/dL |
| Ascorbic Acid | 3 mg/dL |
## ACE Serum Iron Reagent
Interference studies were performed by using two serum pools containing 70μg/dL and 220μg/dL with individual interferents at a range of concentrations. The sera were assayed for Iron (n = 3 replicates) and the mean result calculated. Interference was considered to be significant by the sponsor if the analyte recovery changed by more than ±10%. The results reported were obtained on ACE Axcel Clinical Chemistry System analyzer using fresh ACE Serum Iron Reagent.
Interferents Claim
| Interferents | No Significant Interference At or Below |
| --- | --- |
| Unconjugated Bilirubin | 56 mg/dL |
| Hemolysis | 62.5 mg/dL |
| Triglycerides | 500 mg/dL |
| Ascorbic Acid | 6 mg/dL |
## ACE Lipase Reagent
Interference studies were performed by using two serum pools containing 40U/L and 380U/L lipase with individual interferents at a range of concentrations. The sera were assayed for lipase (n = 3 replicates) and the mean result calculated. Interference was considered to be significant by the sponsor if the analyte recovery changed by more than the least detectable or >10%. The results reported were obtained on ACE Axcel Clinical Chemistry System analyzer using fresh ACE Lipase Reagent.
{11}
12
Interferents Claim
| Interferents | No Significant Interference At or Below |
| --- | --- |
| Unconjugated Bilirubin | 8 mg/dL |
| Hemolysis | 1000 mg/dL |
| Triglycerides | 693 mg/dL |
| Ascorbic Acid | 6 mg/dL |
Because hemolysis interferes with the above assays, therefore, the sponsor put the following limitations in the labeling for TIBC and Iron:
“Do not use hemolyzed sample.”
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
Studies were carried out according to CLSI EP09-A2-IR.
In house: ACE Direct Total Iron-Binding capacity (TIBC) Reagent
ACE Clinical Chemistry System, ACE TIBC Reagent (k931786) was used as the predicate method, using recommended applications and procedures on the ACE Clinical Chemistry System analyzer and calibrating with ACE Direct TIBC Calibrators. One hundred and nine serum samples were assayed in parallel by both the candidate and predicate methods and the results compared by Deming regression. The range tested was 96 to 598 µg/dL. Two samples were altered.
The comparison by Deming regression resulted in a slope of 0.979 (95%CI = 0.961 to 0.9998), an intercept of 2.5 (95%CI = -9.2 to 4.3), correlation coefficient of R2 = 0.9950, and a std. error of 9.1.
Point of Care Laboratory: ACE Direct Total Iron-Binding capacity (TIBC) Reagent
ACE Clinical Chemistry System, ACE Serum Iron Reagent (k931786) was used as the predicate method, using recommended applications and procedures on the ACE Clinical Chemistry System analyzer and calibrating with ACE Serum Iron Calibrators. Results compared by Deming regression. Twenty five samples were altered.
{12}
13
| POL | n | Range μg/dL | Regression Equation | Correlation Coefficient | Standard Error | Confidence Interval Slope | Confidence Interval Intercept |
| --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | 55 | 59 - 659 | y = 0.982x + 4.2 | 0.9987 | 6.2 | 0.968 to 0.996 | -0.8 to 9.3 |
| 2 | 46 | 53 - 621 | y = 0.978x + 9.2 | 0.9980 | 6.1 | 0.960 to 0.997 | 3.1 to 15.2 |
| 3 | 45 | 135 - 615 | y = 0.964x + 5.6 | 0.9902 | 11.2 | 9.923 to 1.006 | -8.2 to 19.4 |
## In house: ACE Serum Iron Reagent
ACE Serum Iron Reagent was used as the predicate method, using recommended applications and procedures on the ACE Clinical Chemistry System analyzer and calibrating with ACE Serum Iron Calibrators. One hundred thirty serum samples were assayed in parallel by both the candidate and predicate methods and the results compared by Deming regression. The range tested was 13 to 550 µg/dL. Nine samples were altered.
The comparison by Deming regression resulted in a slope of 1.006 (95%CI = 1.000 to 1.012), an intercept of 1.8 (95%CI = -2.7 to -1.0), correlation coefficient of R2 = 0.9995, and a std. error of 3.3.
## Point of Care Laboratory: ACE Serum Iron Reagent
ACE Clinical Chemistry System, ACE Serum Iron Reagent (k931786) was used as the predicate method, using recommended applications and procedures on the ACE Clinical Chemistry System analyzer and calibrating with ACE Serum Iron Calibrators. Results compared by Deming regression. Thirty two samples were altered.
| POL | n | Range μg/dL | Regression Equation | Correlation Coefficient | Standard Error | Confidence Interval Slope | Confidence Interval Intercept |
| --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | 63 | 31 - 578 | y = 1.002x - 1.8 | 0.9998 | 3.0 | 0.997 to 1.007 | -2.7 to -0.6 |
| 2 | 54 | 12 - 548 | y = 1.007x + 2.0 | 0.9993 | 4.9 | 0.997 to 1.017 | 0.1 to 3.9 |
| 3 | 49 | 33 - 575 | y = 1.028x + 7.2 | 0.9992 | 4.6 | 1.016 to 1.041 | 5.3 to 9.2 |
## In house: ACE Lipase Reagent
ACE Lipase Reagent was used as the predicate method, using recommended applications and procedures on the ACE Clinical Chemistry System analyzer and calibrating with ACE Lipase Calibrators. One hundred eleven serum samples were assayed in parallel by both the test and predicate methods and the results compared by Deming regression. The range tested was 15.6 to 697.5 U/L. Four samples were altered.
{13}
The comparison by Deming regression resulted in a slope of 0.982 (95%CI = 0.970 to 0.994), an intercept of 3.97 (95%CI = 1.97 to 5.97), correlation coefficient of R2 = 0.9980, and a std. error of 9.06.
## Point of Care Laboratory: ACE Lipase Reagent
ACE Clinical Chemistry System, ACE Lipase Reagent (k931786) was used as the predicate method, using recommended applications and procedures on the ACE Clinical Chemistry System analyzer and calibrating with ACE Lipase Calibrators. Results compared by Deming regression. Sixteen samples were altered.
| POL | n | Range U/L | Regression Equation | Correlation Coefficient | Standard Error | Confidence Interval Slope | Confidence Interval Intercept |
| --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | 51 | 15.9-664.7 | y = 1.013x + 1.89 | 0.9997 | 4.44 | 1.006 to 1.020 | 0.36 to 3.41 |
| 2 | 52 | 15.1 - 674.3 | y = 1.013x + 1.98 | 0.9993 | 7.89 | 1.002 to 1.023 | -4.74 to 0.79 |
| 3 | 45 | 16.1 - 684.2 | y = 1.038x + 1.22 | 0.9996 | 4.64 | 1.030 to 1.047 | -2.89 to 0.44 |
b. Matrix comparison: Not Applicable.
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):
4. Clinical cut-off: Not Applicable.
5. Expected values/Reference range: TIBC expected values are 250-450μg/dL¹.
Total Iron expected values are: Male 65-175μg/dL and female 50-170μg/dL¹.
Lipase Reagent expected values are: 21 - 67 International Units (U/L) at 37 °C¹
1. Tietz, N. W. (Ed.), Clinical Guide to Laboratory Tests, 3rd Edition, W.B. Saunders Co., Philadelphia, PA (2005).
{14}
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.
15
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.