The ACE Alera Clinical Chemistry System is an automated, discrete, bench-top, random access analyzer that is intended for in vitro diagnostic use in the quantitative measurement of general chemistry assays, such as glucose, sodium, potassium, and chloride, for clinical use in physician office laboratories or clinical laboratories. 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. Sodium measurements are used in the diagnosis and treatment of diseases involving electrolyte imbalance. Potassium measurements are used to monitor electrolyte balance in the diagnosis and treatment of disease conditions characterized by low or high blood potassium levels. Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders such as cystic fibrosis and diabetic acidosis. ACE Glucose Reagent is intended for the quantitative determination of glucose in serum and lithium heparin plasma using the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems. 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. This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only. The ACE Ion Selective Electrode (ISE) module on the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems is used to measure concentrations of sodium, potassium, and chloride in undiluted serum and lithium heparin plasma. Sodium measurements are used in the diagnosis and treatment of diseases involving electrolyte imbalance. Potassium measurements are used to monitor electrolyte balance in the diagnosis and treatment of disease conditions characterized by low or high blood potassium levels. Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders such as cystic fibrosis and diabetic acidosis. This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only.
Device Story
Automated, discrete, bench-top, random access clinical chemistry analyzer; includes internal computer, single pipettor, temperature-controlled reagent compartment, reaction wheel, and holographic diffraction grating spectrophotometer. Inputs: serum or lithium heparin plasma samples. Glucose assay: hexokinase/G6PDH enzymatic reaction; NADH production measured bichromatically (340/378 nm). ISE module: potentiometric measurement of Na, K, Cl using ion-specific electrodes and two-point calibration. Used in clinical/physician office labs by laboratory personnel. Output: quantitative concentration values for analytes. Results assist clinicians in diagnosing/monitoring metabolic and electrolyte disorders.
Clinical Evidence
Bench testing only. Precision/reproducibility studies (n=88 per level) and method comparison studies (n=41-46 per analyte) conducted at in-house and physician office laboratory (POL) sites. Linearity confirmed (r2 > 0.999). Matrix comparison (serum vs. lithium heparin plasma) showed high correlation (r > 0.98). Interference testing performed per CLSI EP-7A.
Technological Characteristics
Bench-top analyzer; photometric (holographic diffraction grating) and potentiometric (ISE) sensing. ISE membranes: crown ether (Na), valinomycin (K), quaternary ammonium salts polymer (Cl). Connectivity: on-board computer/monitor. Reagents: liquid-stable in plastic bottles with dot code identification. Automated sample dilution for glucose. Sterilization: not applicable.
Indications for Use
Indicated for quantitative measurement of glucose, sodium, potassium, and chloride in serum and lithium heparin plasma for diagnosis and treatment of metabolic and electrolyte disorders (e.g., diabetes, hypoglycemia, cystic fibrosis, acidosis) in clinical and physician office laboratories.
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:
k123018
B. Purpose for Submission:
New instrument (ACE Alera) and addition of lithium heparin plasma sample to already cleared reagents (ISE and glucose assays on the ACE and ACE Axcel instruments)
C. Measurand:
Glucose, Sodium, Potassium, Chloride
D. Type of Test:
Quantitative, photometric and ion selective electrodes
E. Applicant:
Alfa Wassermann Diagnostic Technologies, LLC.
F. Proprietary and Established Names:
ACE Alera Clinical Chemistry System
ACE Glucose Reagent
ACE Ion Selective Electrode (ISE) Module
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JJE | I, exempt | 862.2160 Discrete photometric chemistry analyzer for clinical use | 75-Chemistry |
| CFR | II | 862.1345, Glucose test system | 75-Chemistry |
| JGS | II | 21 CFR 862.1665 Sodium test system | 75-Chemistry |
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| CEM | II | 21 CFR 862.1600
Potassium test system | 75-Chemistry |
| --- | --- | --- | --- |
| CGZ | II | 21 CFR 862.1170
Chloride test system | 75-Chemistry |
H. Intended Use:
1. Intended use(s):
See Indications for use below.
2. Indication(s) for use:
ACE Alera Clinical Chemistry System
The ACE Alera Clinical Chemistry System is an automated, discrete, bench-top, random access analyzer that is intended for in vitro diagnostic in the quantitative measurement of general chemistry assays, such as glucose, sodium, potassium, and chloride, for clinical use in physician office laboratories or clinical laboratories.
- 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.
- Sodium measurements are used in the diagnosis and treatment of diseases involving electrolyte imbalance.
- Potassium measurements are used to monitor electrolyte balance in the diagnosis and treatment of disease conditions characterized by low or high blood potassium levels.
- Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders such as cystic fibrosis and diabetic acidosis.
ACE Glucose Reagent
ACE Glucose Reagent is intended for the quantitative determination of glucose in serum or lithium heparin plasma using the ACE, ACE Alera, or ACE Axcel Clinical Chemistry Systems. 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. This test is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only.
ACE Ion Selective Electrode (ISE) Module
The ACE Ion Selective Electrode (ISE) module on the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems is used to measure concentrations of sodium, potassium, and chloride in undiluted serum and lithium heparin plasma.
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- Sodium measurements are used in the diagnosis and treatment of diseases involving electrolyte imbalance.
- Potassium measurements are used to monitor electrolyte balance in the diagnosis and treatment of disease conditions characterized by low or high blood potassium levels.
- Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders such as cystic fibrosis and diabetic acidosis.
This test is intended for use in clinical laboratories and physician office laboratories. For in vitro diagnostic use only.
3. Special conditions for use statement(s):
For prescription and point-of-care use.
4. Special instrument requirements:
ACE Alera Clinical Chemistry System
I. Device Description:
ACE Alera Clinical Chemistry System
The ACE Alera Clinical Chemistry System is an automated, discrete, random access wet chemistry system, intended for use in clinical laboratories or physician office laboratories. They are intended for in vitro diagnostic use. They consist of a bench-top analyzer and a computer. The bench-top analyzer includes a single pipettor (syringe module/fluid arm/probe), a temperature-controlled reagent compartment, a reaction wheel, and a holographic diffraction grating spectrophotometer. During analysis, samples and reagents are pipetted into disposable cuvettes contained in the reaction wheel. The ACE Alera has an on-board computer, keyboard and monitor, with an ion selective electrode (ISE) module for simultaneous (to the photometer) potentiometric measurements of sodium, potassium and chloride.
The ACE reagent kits used with the ACE Axcel Clinical Chemistry System consist of natural or brown plastic bottles containing liquid-stable reagents. The reagents have a dot code label applied to the bottom of the bottle to identify each bottle to the ACE Axcel system. Reagent kits typically have either one reagent (R1) or sometimes a second reagent (R2) and an Evap-Cap.
ACE Glucose Reagent
Glucose reagent kit contains Nicotinamide adenine dinucleotide (NAD) 2 mmol/L, Adenosine 5'-triphosphate (ATP) 4 mmol/L, Magnesium 2 mmol/L, Hexokinase (Yeast) >2000 U/L, Glucose-6-phosphate dehydrogenase (G-6-PD) (Leuconostoc mesenteroides) >4000 U/L and buffer, stabilizers and preservatives.
ACE Ion Selective Electrode (ISE) Module
The Ion-Selective Electrode (ISE) module includes a sodium electrode, a potassium electrode, a chloride electrode, a reference electrode, a cleaning solution and two calibrators (level 1 and 2).
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The sodium electrode membrane is a crown ether liquid-membrane. The potassium electrode membrane is a valinomycin liquid-membrane. The chloride electrode membrane is a quaternary ammonium salts polymer membrane.
The ISE calibrator 1 and 2 which is included contains the following chemicals: sodium, potassium, chloride. ISE calibrators have been previously cleared in k933862.
## J. Substantial Equivalence Information:
1. Predicate device name(s) and 510(k) numbers:
ACE Axcel Chemistry System: k113253
ACE Clinical Chemistry System – With ISE: k933862
ACE Glucose Reagent: k930104
2. Device comparison with predicate:
## ACE Alera Clinical Chemistry System
Comparison of similarities and differences:
| | Candidate Device | Predicate Device K113253 (ACE Axcel) |
| --- | --- | --- |
| Intended Use | Clinical chemistry analyzer intended for the quantitative measurements of general chemistry assays. For use in clinical laboratories or physician office laboratories. | Same |
| Instrument Platform | ACE Alera Clinical Chemistry System | ACE Axcel Clinical Chemistry System |
| Method of measurements | Potentiometric (ISE) and photometric chemistries | Same |
| Calibration | same | Automatic |
| Calibration Stability | same | 3 hrs. STAT READY, as required after 3 hrs. STANDBY. When solution lot numbers are changed, new electrodes are installed, major service is performed or a control shift warrants |
| Sample Volume | same | 156 μL |
| ISE Type | same | Direct (undiluted) |
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# ACE Ion Selective Electrode (ISE) Module
Comparison of similarities and differences:
| | Candidate device | Predicate device ACE Clinical Chemistry System – With ISE (k933862) |
| --- | --- | --- |
| Intended Use | For the quantitative measurements of sodium, potassium, and chloride in human serum | Same |
| Method | Potentiometric: Ion-selective electrode | Same |
| Sample Type | Serum and lithium heparin plasma | Serum |
| Expected Values | Na: 136-145 mmol/L
K: 3.5-5.1 mmol/L
Cl: 98-107 mmol/L | Same |
| Measuring range | Na 40-205 mmol/L
K 1.5-15 mmol/L
Cl 50-200 mmol/L | Same |
# ACE Glucose Reagent
Comparison of similarities and differences:
| | Candidate Device | Predicate Device k930104 (ACE glucose reagent) |
| --- | --- | --- |
| Intended Use | For the quantitative measurement of glucose in human serum | Same |
| Method | Photometric | Same |
| Sample Type | Serum and lithium heparin plasma | Serum |
| Expected value | 70-105 mg/dL | Same |
| Measuring range | 4-750 mg/dL | 3-750 mg/dL |
# K. Standard/Guidance Document Referenced:
CLSI Guideline EP05-A2: Evaluation of Precision Performance of Quantitative Measurement Methods
CLSI Guideline EP06-A: Evaluation of the Linearity of Qualitative Measurement Methods
CLSI Guideline EP07-A2: Interference Testing in Clinical Chemistry
CLSI Guideline EP09-A2: Method Comparison and Bias Estimation Using Patient Samples
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CLSI Guideline EP10-A3: Preliminary Evaluation of Quantitative Clinical Laboratory Measurement Procedures
CLSI Guideline EP17-A: Protocols for Determination of Limits of Detection and Limits of Quantitation
## L. Test Principle:
### ACE Glucose Reagent
Glucose in serum reacts with adenosine triphosphate (ATP) in the presence of hexokinase (HK) and magnesium with the formation of glucose-6-phosphate (G-6-P) and adenosine diphosphate (ADP). Glucose-6-phosphate dehydrogenase (G-6-PD) catalyzes the oxidation of glucose-6-phosphate with $\mathrm{NAD}_+$ to form 6-phosphogluconate and NADH. NADH absorbs strongly at $340~\mathrm{nm}$ , whereas $\mathrm{NAD}_+$ does not. The total amount of NADH formed is proportional to the initial amount of glucose present. The rate of increase in absorbance, monitored bichromatically at $340~\mathrm{nm} / 450~\mathrm{nm}$ , is directly proportional to the glucose concentration in the sample.
### ACE Ion Selective Electrode (ISE) Module
The sodium, potassium and chloride are measured using ion-selective electrodes. Each electrode uses ion-specific membrane to measure the difference in ionic concentration between an inner electrolyte solution and the sample. The difference causes an electro-chemical potential to form on the membrane of the active electrode. The measured voltage difference of the sample and CAL A are used to determine the ion concentration in the sample. Two solutions contained in the ISE reagent pack CAL A and CAL B are used to perform a two-point calibration of the ion selective electrodes (ISE)
## M. Performance Characteristics:
### 1. Analytical performance:
#### a. Precision/Reproducibility:
In-house precision studies were conducted on the ACE Alera Clinical Chemistry System following CLSI guidance document EP05-A2. Three levels of human serum samples were run 2 times per run, 2 runs per day, for a total of 22 days ( $n = 88$ measurements/sample level). Results are summarized below.
| Precision (SD, %CV) | | | |
| --- | --- | --- | --- |
| Glucose | Mean (mg/dL) | Within-Run | Total |
| | | | |
| Serum Low | 62 | 0.6, 0.9% | 0.8, 1.3% |
| Serum Mid | 121 | 1.2, 1.0% | 1.5, 1.3% |
| Serum High | 366 | 6.4, 1.8% | 6.9, 1.9% |
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| | | | |
| --- | --- | --- | --- |
| Sodium | Mean (mmol/L) | Within-Run | Total |
| | | | |
| Serum Low | 111.2 | 0.59, 0.5% | 0.93, 0.8% |
| Serum Mid | 139.0 | 0.80, 0.6% | 0.87, 0.6% |
| Serum High | 159.9 | 0.38, 0.2% | 0.90, 0.6% |
| | | | |
| Potassium | Mean (mmol/L) | Within-Run | Total |
| | | | |
| Serum Low | 2.2 | 0.04, 1.6% | 0.05, 2.4% |
| Serum Mid | 4.0 | 0.07, 1.8% | 0.07, 1.8% |
| Serum High | 7.9 | 0.07, 0.9% | 0.11, 1.4% |
| | | | |
| Chloride | Mean (mmol/L) | Within-Run | Total |
| | | | |
| Serum Low | 75.0 | 0.80, 1.1% | 1.50, 2.0% |
| Serum Mid | 99.3 | 0.75, 0.8% | 0.87, 0.9% |
| Serum High | 119.3 | 0.45, 0.4% | 1.10, 0.9% |
Additional precision studies were conducted at 3 Physician Office Laboratories (POL) with trained operators typically found in these settings, following CLSI guidance document EP5-A2. Three samples each of low, mid and high analyte serum were run on the ACE Alera Clinical Chemistry Systems in duplicate, for 5 days at 2 runs per day, both in-house and at 3 POL sites (Per site, $N = 40$ ; 20 replicates per decision level per instrument system).
| Glucose | | ACE Alera SD (mg/dL) or %CV | | |
| --- | --- | --- | --- | --- |
| Lab | Sample | Mean (mg/dL) | Within-Run | Total |
| In-House | 1 | 62.5 | 1.2 SD | 1.3 SD |
| | | | 1.9% | 2.1% |
| POL 1 | 1 | 64.3 | 1.1 SD | 1.5 SD |
| | | | 1.7% | 2.3% |
| POL 2 | 1 | 65.3 | 0.6 SD | 0.9 SD |
| | | | 0.9% | 1.3% |
| POL 3 | 1 | | 0.5 SD | 1.0 SD |
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| Sodium | | ACE Alera SD (mmol/L) or %CV | | |
| --- | --- | --- | --- | --- |
| Lab | Sample | Mean (mmol/L) | Within-Run | Total |
| In-House | 1 | 107.5 | 0.80 SD | 1.50 SD |
| | | | 0.7% | 1.4% |
| POL 1 | 1 | 108.4 | 0.93 SD | 1.44 SD |
| | | | 0.9% | 1.3% |
| POL 2 | 1 | 108.1 | 0.94 SD | 1.16 SD |
| | | | 0.9% | 1.1% |
| POL 3 | 1 | 107.0 | 0.56 SD | 0.98 SD |
| | | | 0.5% | 0.9% |
| | | | | |
| In-House | 2 | 149.2 | 0.60 SD | 0.70 SD |
| | | | 0.4% | 0.5% |
| POL 1 | 2 | 148.7 | 1.41 SD | 1.72 SD |
| | | | 0.9% | 1.2% |
| POL 2 | 2 | 146.1 | 0.56 SD | 0.80 SD |
| | | | 0.4% | 0.5% |
| POL 3 | 2 | 147.6 | 0.95 SD | 0.95 SD |
| | | | 0.6% | 0.6% |
| | | | | |
| In-House | 3 | 197.1 | 1.80 SD | 2.10 SD |
| | | | 0.9% | 1.1% |
| POL 1 | 3 | 193.7 | 1.33 SD | 2.74 SD |
| | | | | |
| POL 2 | 3 | 197.0 | 1.33 SD | 1.92 SD |
| | | | 0.9% | 1.1% |
| POL 3 | 3 | 196.7 | 1.13 SD | 1.53 SD |
| | | | 0.7% | 1.3% |
| | | | | |
| In-House | 4 | 200.0 | 0.80 SD | 0.90 SD |
| | | | 0.7% | 0.9% |
| POL 1 | 4 | 200.0 | 0.80 SD | 0.90 SD |
| | | | 0.7% | 0.9% |
| POL 2 | 4 | 200.0 | 0.90 SD | 0.90 SD |
| | | | 0.7% | 0.9% |
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| Potassium | | ACE Alera
SD (mmol/L) or %CV | | |
| --- | --- | --- | --- | --- |
| Lab | Sample | Mean (mmol/L) | Within-Run | Total |
| In-House | 1 | 3.70 | 0.06 SD | 0.06 SD |
| | | | 1.6% | 1.7% |
| POL 1 | 1 | 3.73 | 0.07 SD | 0.08 SD |
| | | | 1.8% | 2.2% |
| POL 2 | 1 | 3.77 | 0.06 SD | 0.07 SD |
| | | | 1.7% | 1.8% |
| POL 3 | 1 | 3.73 | 0.05 SD | 0.06 SD |
| | | | 1.3% | 1.6% |
| | | | | |
| In-House | 2 | 6.56 | 0.13 SD | 0.14 SD |
| | | | 2.0% | 2.1% |
| POL 1 | 2 | 6.89 | 0.13 SD | 0.16 SD |
| | | | 1.8% | 2.4% |
| POL 2 | 2 | 6.70 | 0.08 SD | 0.09 SD |
| | | | 1.2% | 1.3% |
| POL 3 | 2 | 6.67 | 0.05 SD | 0.10 SD |
| | | | 0.8% | 1.4% |
| | | | | |
| In-House | 3 | 9.73 | 0.09 SD | 0.19 SD |
| | | | 0.9% | 2.0% |
| POL 1 | 3 | 10.36 | 0.08 SD | 0.19 SD |
| | | | 0.8% | 1.8% |
| POL 2 | 3 | 10.04 | 0.04 SD | 0.19 SD |
| | | | 0.4% | 1.9% |
| POL 3 | 3 | 9.92 | 0.15 SD | 0.22 SD |
| | | | 1.5% | 2.2% |
| Chloride | | ACE Alera
SD (mmol/L) or %CV | | |
| --- | --- | --- | --- | --- |
| Lab | Sample | Mean (mmol/L) | Within-Run | Total |
| In-House | 1 | 77.3 | 0.50 SD | 1.20 SD |
| | | | 0.6% | 1.6% |
| POL 1 | 1 | 78.1 | 0.76 SD | 1.30 SD |
| | | | 1.0% | 1.7% |
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Another precision study was performed in-house using 3 different lithium heparin plasma samples over a period of 5 days. All samples were tested twice a day in duplicate on the ACE, ACE Alera, and ACE Axcel Clinical Chemistry Systems. The within-run and total precision results are summarized in the tables below.
1. For ACE system:
| Assay | Sample | Mean | With-run SD | Within-run CV | Total SD | Total CV |
| --- | --- | --- | --- | --- | --- | --- |
| Sodium (mmol/L) | 1 | 140.8 | 0.56 | 0.4% | 0.62 | 0.4% |
| | 2 | 166.9 | 0.74 | 0.4% | 0.98 | 0.6% |
| | 3 | 193.4 | 0.47 | 0.2% | 1.29 | 0.7% |
| Potassium (mmol/L) | 1 | 3.35 | 0.03 | 0.9% | 0.05 | 1.5% |
| | 2 | 6.42 | 0.08 | 1.2% | 0.08 | 1.2% |
| | 3 | 9.57 | 0.05 | 0.5% | 0.14 | 1.4% |
| Chloride (mmol/L) | 1 | 116.3 | 0.46 | 0.4% | 0.73 | 0.6% |
| | 2 | 146.1 | 0.74 | 0.5% | 1.25 | 0.9% |
| | 3 | 175.2 | 0.45 | 0.3% | 1.45 | 0.8% |
| Glucose (mg/dL) | 1 | 78 | 1.3 | 1.7% | 1.5 | 2.0% |
| | 2 | 362 | 1.9 | 0.5% | 3.6 | 1.0% |
| | 3 | 632 | 8.9 | 1.4% | 10.7 | 1.7% |
2. For ACE Alera system:
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| Assay | Sample | Mean | With-run SD | Within-run CV | Total SD | Total CV |
| --- | --- | --- | --- | --- | --- | --- |
| Sodium (mmol/L) | 1 | 141.1 | 0.95 | 0.7% | 0.97 | 0.7% |
| | 2 | 166.6 | 0.89 | 0.5% | 1.12 | 0.7% |
| | 3 | 192.8 | 0.46 | 0.2% | 1.54 | 0.8% |
| Potassium (mmol/L) | 1 | 3.36 | 0.03 | 0.9% | 0.04 | 1.2% |
| | 2 | 6.4 | 0.08 | 1.3% | 0.08 | 1.3% |
| | 3 | 9.52 | 0.04 | 0.4% | 0.17 | 1.8% |
| Chloride (mmol/L) | 1 | 116.5 | 0.68 | 0.6% | 0.76 | 0.6% |
| | 2 | 145.1 | 0.79 | 0.5% | 1.69 | 1.2% |
| | 3 | 173.0 | 0.47 | 0.3% | 2.84 | 1.6% |
| Glucose (mg/dL) | 1 | 78 | 1.6 | 2.0% | 1.6 | 2.1% |
| | 2 | 358 | 2.3 | 0.7% | 2.8 | 0.8% |
| | 3 | 625 | 5.1 | 0.8% | 8.5 | 1.4% |
# 3. For ACE Axcel system:
| Assay | Sample | Mean | With-run SD | Within-run CV | Total SD | Total CV |
| --- | --- | --- | --- | --- | --- | --- |
| Sodium (mmol/L) | 1 | 140.1 | 0.38 | 0.3% | 0.62 | 0.4% |
| | 2 | 166.6 | 0.82 | 0.5% | 1.36 | 0.8% |
| | 3 | 193.3 | 0.5 | 0.3% | 2.26 | 1.2% |
| Potassium (mmol/L) | 1 | 3.31 | 0.02 | 0.7% | 0.04 | 1.3% |
| | 2 | 6.4 | 0.07 | 1.1% | 0.09 | 1.3% |
| | 3 | 9.56 | 0.04 | 0.4% | 0.17 | 1.8% |
| Chloride (mmol/L) | 1 | 115.9 | 0.48 | 0.4% | 0.57 | 0.5% |
| | 2 | 145.5 | 0.76 | 0.5% | 1.38 | 0.9% |
| | 3 | 174.3 | 0.42 | 0.2% | 2.43 | 1.4% |
| Glucose (mg/dL) | 1 | 79 | 0.4 | 1.5% | 0.5 | 0.6% |
| | 2 | 363 | 1.9 | 0.5% | 2.0 | 0.5% |
| | 3 | 638 | 2.3 | 0.4% | 3.7 | 0.6% |
# b. Linearity/assay reportable range:
Linearity was confirmed for ISE and Glucose assays on the ACE Alera Clinical Chemistry System by spiking serum samples with a high concentration of analyte, then diluting the spiked sample with saline or water to obtain at least 7 levels that span the measuring range of each assay. The assigned value of the highest sample was set to its mean value. The assigned values of the other levels were calculated by multiplying the mean value by the dilution ratios obtained from the manufacturer. Each level was tested in triplicate. The linear regression correlation between the expected values and the measured values is summarized below:
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| Analyte tested | Linear regression | r2 |
| --- | --- | --- |
| Glucose (mg/dL) | y = 0.979x - 0.51 | 0.9999 |
| Na (mmol/L) | y = 1.017x - 2.95 | 0.9990 |
| K (mmol/L) | y = 1.035x - 0.60 | 0.9992 |
| Cl (mmol/L) | y = 1.013x - 1.35 | 0.9994 |
The linearity data provided by the sponsor support the following reportable range claims:
| Analyte tested | Assay range |
| --- | --- |
| Glucose (mg/dL) | 4 - 750 |
| Na (mmol/L) | 40 – 205 |
| K (mmol/L) | 1.5 – 15 |
| Cl (mmol/L) | 50 - 200 |
# Automatic dilution study:
The ACE Alera Clinical Chemistry System can perform automatic 1:3 dilutions of samples that exceed the upper limit of the glucose assay. To examine the accuracy of the auto-dilution function for the ACE Glucose Reagent, serum samples were spiked with high concentrations of glucose and were then either run directly on each of the ACE systems or they were manually diluted 1:3 using system diluent (3 samples per instrument system in triplicate). The results from the auto-dilution and the manually diluted samples, run on the same ACE systems, were compared. All samples recovered within $10\%$ recovery. The auto-dilution function is not available for ISE analytes.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability and stability: The ISE calibrator material was previously cleared under k933862 and the glucose calibrator was previously cleared under k930104.
# d. Detection limit:
The sponsor performed a detection limit study for glucose on the ACE Alera Clinical Chemistry System, based on a modified protocol according to the CLSI EP17-A. For Na, K and Cl detection limits, please refer to their linearity studies, as the sponsor determined that the limits of detection are defined by the linear range studies for these assays on the ACE Alera Clinical Chemistry System.
Limit of Blank (LoB) determination was based on 60 replicate glucose measurements of 5 blank samples (human serum albumin) on 2 ACE Alera Clinical Chemistry Systems, and 1 lot of assay reagents. The limit of blank, as determined by the upper 95th percentile was 0.80 mg/dL for the ACE Alera Clinical Chemistry System.
Limit of Detection (LoD) determination was based on 60 replicate glucose measurements of 5 low human serum-based samples on 2 ACE Alera Clinical Chemistry System, and 1 lot of assay reagents. The limits of detection were calculated using the determined LoB value and pooled SD values from LoD samples. The sponsor claimed that the LoD for serum samples
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on ACE Alera Clinical Chemistry System was $1.18\mathrm{mg / dL}$
Limit of Quantitation (LoQ) determination was based on inter-assay precision of $20\%$ for 40 replicate measurements of 5 low serum samples, per day for 5 days, on 1 ACE Alera Clinical Chemistry System. The LoQ was determined to be $2.88 \mathrm{mg} / \mathrm{dL}$ for the ACE Alera system.
The sponsor claimed the following measuring range:
| Analyte tested | Assay range |
| --- | --- |
| Glucose (mg/dL) | 4 - 750 |
| Na (mmol/L) | 40 – 205 |
| K (mmol/L) | 1.5 – 15 |
| Cl (mmol/L) | 50 - 200 |
# e. Analytical specificity:
Interference studies were performed according to CLSI guidance document EP-7A to determine the effects from potential interferents on the ACE Glucose and ISE assays. Various concentrations of interferents were spiked into serum pools containing glucose, sodium, potassium and chloride at normal and elevated concentrations. All samples were tested in triplicate on the ACE Alera system. Seven levels were tested for each interferent. The sponsor states that interference is considered to be non-significant if the bias between the tested and control samples are within $\pm 10\%$ for each of the analytes.
The analytical specificity study results are summarized as follows:
| No Significant Interference at or below the listed concentration (mg/dL) | | | | |
| --- | --- | --- | --- | --- |
| | Glucose | Sodium | Potassium | Chloride |
| Bilirubin | 26 | 50 | 50 | 50 |
| Ascorbic Acid | 6 | 6 | 6 | 6 |
| Hemoglobin | 1000 | 1000 | 125 | 1000 |
| Intralipid | 104 | 125 | 125 | 125 |
| Triglycerides | 525 | 656 | 420 | 420 |
Since lipemia affects all test results and hemolysis affects K results, the sponsor has the following limitations in the labeling:
"Do not use hemolyzed samples for potassium since significant hemolysis may increase $\mathrm{K}^+$ concentration because of high levels of $\mathrm{K}^+$ in erythrocytes."
"Do not use lipemic samples."
# f. Assay cut-off:
Not applicable.
{13}
14
2. Comparison studies:
a. Method comparison with predicate device:
Method comparison studies were completed at 3 POC sites following CLSI document EP9-A2. Samples were run on the ACE Clinical Chemistry System at Alfa Wassermann and the results were compared against those gathered on ACE Alera Clinical Chemistry Systems at 3 Physician Office Labs. For each test method, at least 41 determinations were made in singlicate for serum samples drawn from the same individuals on each platform. To test across the assay reportable ranges, additional sets of 4 samples and 6 samples were either spiked with analyte or diluted with saline for the Glucose and ISE POL studies, respectively. The following chart summarizes the POL method comparison studies:
| Glucose | ACE (in-house) vs. ACE Alera (POL) | | |
| --- | --- | --- | --- |
| | POL 1 | POL 2 | POL 3 |
| N | 46 | 46 | 46 |
| Range (mg/dL) | 22-625 | 22-625 | 22-625 |
| Slope | 1.015 | 1.005 | 0.988 |
| Intercept | 0.1 | 3.1 | 3.2 |
| Correlation Coefficient | 0.9993 | 0.9995 | 0.9993 |
| Sodium | ACE (in-house) vs. ACE Alera (POL) | | |
| --- | --- | --- | --- |
| | POL 1 | POL 2 | POL 3 |
| N | 42 | 42 | 42 |
| Range (mmol/L) | 51-202 | 51-202 | 51-202 |
| Slope | 1.025 | 1.021 | 1.044 |
| Intercept | -1.74 | -2.92 | -6.27 |
| Correlation Coefficient | 0.9974 | 0.9958 | 0.9979 |
| Potassium | ACE (in-house) vs. ACE Alera (POL) | | |
| --- | --- | --- | --- |
| | POL 1 | POL 2 | POL 3 |
| N | 43 | 43 | 43 |
| Range (mmol/L) | 1.8-13.7 | 1.8-13.7 | 1.8-13.7 |
| Slope | 1.032 | 1.008 | 0.984 |
| Intercept | -0.108 | -0.054 | 0.150 |
| Correlation Coefficient | 0.9983 | 0.9971 | 0.9942 |
| Chloride | ACE (in-house) vs. ACE Alera (POL) | | |
| --- | --- | --- | --- |
| | POL 1 | POL 2 | POL 3 |
| N | 42 | 42 | 42 |
| Range (mmol/L) | 1.0-13.0 | 1.0-13.0 | 1.0-13.0 |
| Slope | 0.999 | 0.999 | 0.999 |
| Intercept | -0.000 | | |
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| N | 41 | 41 | 41 |
| --- | --- | --- | --- |
| Range (mmol/L) | 59-187 | 59-187 | 59-187 |
| Slope | 1.004 | 1.000 | 1.006 |
| Intercept | 0.96 | 0.29 | 0.16 |
| Correlation Coefficient | 0.9972 | 0.9956 | 0.9946 |
# b. Matrix comparison:
Matrix comparison studies were completed following CLSI guidance document EP9-A2. Samples were tested on the ACE, ACE Alera and ACE Axcel Clinical Chemistry Systems. At least 50 determinations were made in singlicate for paired serum and lithium heparin plasma samples drawn from the same individuals. Of these samples, up to 10 were either spiked with analyte or diluted with water to allowing for testing across the assay ranges.
The following chart summarizes the matrix comparison studies:
| Reagent | Range | ACE Serum vs. Plasma |
| --- | --- | --- |
| Sodium 53 pairs | 75-202 mmol/L | Slope: 0.979 Intercept: 3.12 Correlation: 0.9850 |
| Potassium 53 pairs | 1.8-13.9 mmol/L | Slope: 0.984 Intercept: 0.133 Correlation: 0.9948 |
| Chloride 55 pairs | 53-183 mmol/L | Slope: 0.984 Intercept: 2.26 Correlation: 0.9902 |
| Glucose 51 pairs | 15-707 mg/dL | Slope: 1.011 Intercept: -2.0 Correlation: 0.9993 |
| Reagent | Range | ACE Alera Serum vs. Plasma |
| --- | --- | --- |
| Sodium 54 pairs | 77-203 mmol/L | Slope: 0.980 Intercept: 3.46 Correlation: 0.9854 |
| Potassium 55 pairs | 1.9-12.5 mmol/L | Slope: 0.969 Intercept: 0.187 Correlation: 0.9949 |
| Chloride 55 pairs | 53-183 mmol/L | Slope: 1.000 Intercept: 0.89 Correlation: 0.9906 |
| Glucose 50 pairs | 15-740 mg/dL | Slope: 0.997 Intercept: 0.8 Correlation: 0.9988 |
{15}
| Reagent | Range | ACE Axcel Serum vs. Plasma |
| --- | --- | --- |
| Sodium 56 pairs | 65-205 mmol/L | Slope: 1.005
Intercept: -2.13
Correlation: 0.9976 |
| Potassium 58 pairs | 1.7-12.3mmol/L | Slope: 1.024
Intercept: -0.096
Correlation: 0.9941 |
| Chloride 56 pairs | 61-175 mmol/L | Slope: 1.000
Intercept: -0.69
Correlation: 0.9960 |
| Glucose 55 pairs | 24-747 mg/dL | Slope: 1.003
Intercept: -6.6
Correlation: 0.9985 |
The sponsor concluded that Lithium heparin plasma is acceptable to be used with the ISE and glucose assays.
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:
Reference values for serum and plasma are provided in the labeling according to literature as follows:
Na⁺: 136 – 145 mM or mEq/L
K⁺: 3.5 – 5.1 mM or mEq/L
Cl⁻: 98 – 107 mM or mEq/L
Glucose: 70 – 105 mg/dL
{16}
Tietz, N. W. (Ed.), Clinical Guide to Laboratory Tests, 3rd Ed., WB Saunders Co., Philadelphia, PA (1995).
Burtis, C. A., Ashwood, E. R. (Eds.) Tietz Fundamentals of Clinical Chemistry, 4th ed., WB Saunders Co., Philadelphia, PA (1996).
## N. Instrument Name:
ACE Alera Clinical Chemistry System
## O. System Descriptions:
1. Modes of Operation:
This instrument is capable of testing several assays via self-contained reagent bottles. The instrument identifies the assay through reading a dot code label on the bottom of each reagent bottle.
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:
Barcoding or manual entry
4. Specimen Sampling and Handling:
Samples are manually placed on the instrument either by sample tube or sample cup. The system can run an individual sample or a batch of samples. Once tested the samples are removed.
5. Calibration:
On demand calibration. It is recommended to perform a calibration measurement after installing a new or fresh bottle of reagent and/or intervals that are defined for a particular test. It is recommended to recalibrate ISEs after installing a new lot of calibration solution. ISE calibration is required every 3 hours or when quality control results fall outside the established range after replacing electrode, and after ISE cleaning maintenance.
6. Quality Control:
Controls are loaded onto the instrument manually by the user into the sample wells and are run automatically by the instrument. Labeling recommends two levels of controls run daily.
17
{17}
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.
18
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.