Random fresh clinical urine samples from point-of-care (POC) sites
The sponsor conducted a method comparison study using 351 clinical urine samples collected at three POC sites to demonstrate substantial equivalence to the predicate device.
Random fresh urine samples; Sample Size: 351; Number of Sites: 3
Siemens Clinitek Status Analyzer and Clinitek Microalbumin 2 Reagent Strips
Agreement between URiSCAN Optima and predicate device for Albumin, Creatinine, and ACR
Indications for Use
The URiSCAN Optima urine chemistry test system consists of URiSCAN Optima Urine analyzer and URiSCAN 2ACR Urine strips. The intended use of the URiSCAN Optima Urine analyzer is to read the color change on the test pads found on the URiSCAN 2ACR Urine strips and to display and print the results. The intended use of the URiSCAN 2ACR Urine test strips is for the in vitro semi-quantitative measurement of the following parameters: Albumin Creatinine ACR (Albumin Creatinine Ratio) These measurements are useful in the evaluation of renal, urinary and metabolic disorders. URiSCAN Optima urine chemistry test system is intended for prescription use only, in clinical laboratory and in point-of-care setting.
Device Story
System consists of URiSCAN Optima analyzer and URiSCAN 2ACR test strips; used in clinical labs and point-of-care settings. Device reads color changes on test pads via optical system; displays results on LCD; prints via internal printer; transfers data to host computer. Analyzer performs self-test and calibration using internal white plastic bar before each run. Healthcare providers use results to evaluate renal, urinary, and metabolic disorders. Benefits include early disease detection.
Clinical Evidence
Bench testing only. Precision/reproducibility tested at three sites using commercial controls. Method comparison study (n=351) against predicate device showed 95.7% agreement for microalbumin, 96.6% for creatinine, and 98% for ACR. Interference testing performed per CLSI EP7-A. Stability studies support 24-month shelf-life and 3-month open-vial stability.
Technological Characteristics
Plastic test strips with colorimetric pads; CCD-based optical reflectance analyzer. Albumin: sulfonephthalein dye binding. Creatinine: copper-creatinine complex peroxidase-like activity. Connectivity: printer/computer output. Calibration: automatic via internal white check bar. Standards: CLSI EP5-A2, EP7-A, EP9A. Traceability: Albumin to IFCC CRM 475; Creatinine to NIST SRM 914a.
Indications for Use
Indicated for prescription use in clinical laboratory and point-of-care settings for the semi-quantitative measurement of albumin, creatinine, and albumin-creatinine ratio (ACR) in urine to evaluate renal, urinary, and metabolic disorders.
Regulatory Classification
Identification
An automated urinalysis system is a device intended to measure certain of the physical properties and chemical constituents of urine by procedures that duplicate manual urinalysis systems. This device is used in conjunction with certain materials to measure a variety of urinary analytes.
Predicate Devices
Siemens Clinitek Status (k091216)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION MEMORANDUM ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k141874
B. Purpose for Submission:
New device
C. Measurand:
Urine Creatinine and Albumin
D. Type of Test:
Semi-quantitative colorimetric urinalysis
E. Applicant:
YD Diagnostics Corp.
F. Proprietary and Established Names:
URiSCAN 2ACR Urine strips
URiSCAN Optima Urine Analyzer
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JFY | Class II | 21 CFR 862.1225
Creatinine test system. | Chemistry (75) |
| JIR | Class I | 21 CFR 862.1645
Urinary protein or albumin (nonquantitative) test system | Chemistry (75) |
| KQO | Class I | 21 CFR 862.2900
Automated urinalysis system | Chemistry (75) |
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H. Intended Use:
1. Intended use(s):
Refer to Indications for use below.
2. Indication(s) for use:
The URiSCAN Optima urine chemistry test system consists of URiSCAN Optima Urine analyzer and URiSCAN 2ACR Urine strips. The intended use of the URiSCAN Optima Urine analyzer is to read the color change on the test pads found on the URiSCAN 2ACR Urine strips and to display and print the results.
The intended use of the URiSCAN 2ACR Urine test strips is for the in vitro semi-quantitative measurement of the following parameters:
Albumin
Creatinine
ACR (Albumin Creatinine Ratio)
These measurements are useful in the evaluation of renal, urinary and metabolic disorders. URiSCAN Optima urine chemistry test system is intended for prescription use only, in clinical laboratory and in point-of-care setting.
3. Special conditions for use statement(s):
This product is for in vitro diagnostic use only.
Not for visual read.
4. Special instrument requirements:
URiSCAN Optima Urine analyzer
I. Device Description:
The URiSCAN 2ACR Urine strip is a plastic strip with color blocks that can semi-quantitatively measure albumin and creatinine simultaneously using chemical reactions. The Albumin – Creatinine Ratio (ACR) results are based on the color changes obtained on the measurements of albumin and creatinine.
The URiSCAN Optima Urine analyzer is a semi-quantitative urine analyzer used to determine the amounts of components in urine including albumin, creatinine and ACR (albumin creatinine ratio), represent the figures on a liquid crystal display and through a printer and transfer them to a computer.
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J. Substantial Equivalence Information:
1. Predicate device name(s):
Siemens Clinitek Status
2. Predicate 510(k) number(s):
k091216
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | URiSCAN 2ACR Urine strips and URiSCAN Optima Urine Analyzer (Candidate Device) | Clinitek Status (Predicate Device K971216) |
| Intended Use | Intended for the semi-quantitative urine measurement of the following parameters: albumin, creatinine and ACR (albumin creatinine ratio). | Same |
| Measuring Range | 10-150mg/L albumin
10-300 mg/dL creatinine | Same |
| Sample Type | Urine | Same |
| Format | Strips | Same |
| Differences | | |
| --- | --- | --- |
| Item | URiSCAN 2ACR Urine strips and URiSCAN Optima Urine Analyzer (Candidate Device) | Clinitek Stratus (Predicate Device K972706) |
| Analytes | Albumin, Creatinine | Albumin, Creatinine, Glucose, Blood (Occult), human Chorionic Gonadotropin (hCG), Creatinine, Albumin, Protein, Bilirubin, Ketone, Leukocytes, Nitrite, pH, Specific Gravity, and Urobilinogen |
| Throughput | 36 tests/hour | 50 tests/hour |
| Measuring Cycle | 100sec | 70sec |
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4
K. Standard/Guidance Document Referenced (if applicable):
CLSI EP5-A2 Evaluation of Precision Performance of Quantitative Measurement Methods" Approved Guideline – Second Edition.
CLSI EP7-A Interference testing in clinical chemistry; Approved Guideline.
CLSI EP9A Method Comparison and Bias Estimation Using Patient Samples; Approved Guideline (2002).
L. Test Principle:
The urine will be absorbed into each test portion of the strip and the subsequent chemical and enzymatic reactions will change the color of the test paper in proportion to the amount of analyte present in the sample. The reaction for the albumin test is based on dye binding using a sulfonephthalein dye. At a constant pH, albumin binds sulfonephthalein dye. The resulting color on the test pad ranges from pale green to aqua blue.
The reaction for the creatinine test is based on the peroxidase-like activity of a copper creatinine complex that catalyzes the reaction of cummen hydroperoxide and 3,3',5,5'-tetramethylbenzidine. The resulting color on the test pad ranges from yellow through green to blue.
The analyzer, a charge coupled device, will measure and analyzes the ratios of the composition of the primary colors of light, and reads out the extent of change in the color of the test paper.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Within-run precision:
Two within run studies were performed; one using 2 levels of controls for each analyte and one using urine samples for each analyte. The studies were performed at 3 different clinical sites using 3 lots of URiSCAN 2 ACR strips and 10 replicates for a total of 90 reps per level for each analyte. Three different URiSCAN Optima analyzers were also used. The control concentrations used are as follows: albumin control level 1 (≤ 10mg/L) and control level 2 (80 - ≥150mg/L); creatinine control level 1 (10 -50mg/dL) and control level 2 (100 - ≥300mg/dL) were used for the studies. The urine samples were spiked at 4 levels of albumin as follows: -(0mg/L), +(30mg/L), 2+(80mg/L), 3+(150mg/L) and at the following 5 levels of creatinine: ±(10mg/dL), + (50mg/dL), 2+ (100 mg/dL), 3+(200mg/dL) and 4+(300mg/dL).
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Results were consistent between lots. A representative lot results are presented in the tables below:
Control Samples:
| Within-run test (n=10) | Level 1 | | | Level 2 | | |
| --- | --- | --- | --- | --- | --- | --- |
| | ALB | CRE | ACR | ALB | CRE | ACR |
| Target Value | - | ± | <30mg/g | 3+ | 4+ | >300 mg/g |
| Agreement within same grade (%) | 100% (10/10) | 100% (10/10) | 100% (10/10) | 100% (10/10) | 100% (10/10) | 100% (10/10) |
Albumin Urine Samples:
| Within-run N=50 | ALB | ALB | ALB | ALB |
| --- | --- | --- | --- | --- |
| Target Value | - | + | 2+ | 3+ |
| Agreement within same grade (%) | 100% (50/50) | 100% (50/50) | 100% (50/50) | 100% (50/50) |
Creatinine Urine Samples:
| Within-run N=50 | CRE | CRE | CRE | CRE | CRE |
| --- | --- | --- | --- | --- | --- |
| Target value | ± | + | 2+ | 3+ | 4+ |
| Agreement within same grade (%) | 100% (50/50) | 100% (50/50) | 100% (50/50) | 100% (50/50) | 100% (50/50) |
Albumin Creatinine Ratio (ACR) Urine Samples:
| Within-run N=50 | ACR | ACR | ACR | ACR | ACR |
| --- | --- | --- | --- | --- | --- |
| Target value | <30mg/g | 30-300 mg/g | 30-300 mg/g | 30-300 mg/g | <30 mg/g |
| Agreement within same grade (%) | 100% (50/50) | 100% (50/50) | 100% (50/50) | 100% (50/50) | 100% (50/50) |
Intermediate precision:
Within day precision studies were performed using 2 levels of controls for each analyte and urine samples for each analyte. Each of the studies used three different URiSCAN Optima analyzers and three different lots of URiSCAN 2 ACR strips for 10 days. The test was performed at three different point-of-care (POC) sites by trained medical technicians. The control concentrations used are as follows: albumin control level 1 ( $\leq 10\mathrm{mg/L}$ ) and control level 2 ( $80 - \geq 150\mathrm{mg/L}$ ); creatinine control level 1 (10
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- $50\mathrm{mg / dL}$ and control level 2 $(100 - \geq 300\mathrm{mg / dL})$ were used for the studies. The urine samples were spiked at 4 levels of albumin as follows: $-(0\mathrm{mg / L}), + (30\mathrm{mg / L}), 2 + (80\mathrm{mg / L}), 3 + (150\mathrm{mg / L})$ and at the flowing 5 levels of creatinine: $\pm (10\mathrm{mg / dL}), + (50\mathrm{mg / dL}), 2 + (100\mathrm{mg / dL}), 3 + (200\mathrm{mg / dL})$ and $4 + (300\mathrm{mg / dL})$ . Results were consistent between lots. A representative lot results are presented in the tables below:
Controls:
| Intermediate precision (n=10) | Level 1 | | | Level 2 | | |
| --- | --- | --- | --- | --- | --- | --- |
| | ALB | CRE | ACR | ALB | CRE | ACR |
| Target Value | - | ± | <30mg/g | 3+ | 4+ | >300 mg/g |
| Agreement within same grade (%) | 100% | 100% | 100% | 100% | 100% | 100% |
Urine samples:
Albumin:
| Intermediate precision N=50 | ALB | ALB | ALB | ALB |
| --- | --- | --- | --- | --- |
| Target value | - | + | 2+ | 3+ |
| Agreement within same grade (%) | 100% | 100% | 100% | 100% |
Creatinine:
| Within-run N=50 | CRE | CRE | CRE | CRE | CRE |
| --- | --- | --- | --- | --- | --- |
| Target value | ± | + | 2+ | 3+ | 4+ |
| Agreement within same grade (%) | 100% | 100% | 100% | 100% | 100% |
Albumin - Creatinine Ratio (ACR)
| Within-run N=50 | ACR | ACR | ACR | ACR | ACR |
| --- | --- | --- | --- | --- | --- |
| Target value | <30mg/g | 30-300mg/g | 30-300mg/g | 30-300mg/g | <30mg/g |
| Agreement within same grade (%) | 100% | 100% | 100% | 100% | 100% |
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b. Linearity/assay reportable range:
This assay reports color block outputs of 0mg/L (Negative), 30 mg/L, 80 mg/L, 150 mg/L for albumin, and 10 mg/dL, 50 mg/dL, 100 mg/dL, 200 mg/dL, 300 mg/dL for creatinine.
A study to evaluate the percent recovery was performed on 3 instruments using 3 lots of test strips, 5 test per strip lot on each instrument at 4 levels of albumin: negative, + (30mg/dL), 2+(80mg/dL), 3+(150 mg/dL) and 5 levels of creatinine: Trace (10mg/dL), 1+ (50mg/dL), 2+(100mg/dL), 3+(200 mg/dL) and 4+(300mg/dL). Results are summarized below.
| Analyte | Color block Out-put | Concentration tested | % Match |
| --- | --- | --- | --- |
| Albumin | -(Neg.) | 0 mg/L | 100% (45/45) |
| | + | 30 mg/L | 100% (45/45) |
| | 2+ | 80 mg/L | 100% (45/45) |
| | 3+ | 150 mg/L | 100% (45/45) |
| Creatinine | ± (Trace) | 10mg/dL | 100% (45/45) |
| | + | 50 mg/dL | 100% (45/45) |
| | 2+ | 100 mg/dL | 100% (45/45) |
| | 3+ | 200 mg/dL | 100% (45/45) |
| | 4+ | 300 mg/dL | 100% (45/45) |
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The firm stated that the albumin strips are traceable to the CRM 475 from IFCC and the Creatinine is traceable to SRM 914a from NIST. The strips are prepared from commercial stocks and verified using commercial verifiers. The traceability for albumin and creatinine is then verified by turbidimetric immunoassay using the corresponding standard.
Stability protocol and acceptance criteria were reviewed and found acceptable and support the following stability claims: the strip can be stored at 15-30°C (59-86°F) and relative humidity of 10-60% in the closed package for up to 24 months and after opening for at least 3 months.
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d. Detection limit:
The cutoff of the assay at each color block was validated by spiking or diluting a pooled urine sample with albumin and creatinine to achieve 3 levels of albumin and 4 levels of creatinine. Each level was further adjusted to concentrations below and above the midpoint concentration of each of these levels. Each sample was tested using 3 lots of strips on 3 analyzers. Each level was tested in replicates of 10. The cutoffs for each color block are defined as the lowest and highest concentrations of analyte tested at which over 50% of the results are positive for each color block. Results for each concentration tested at each color block are shown below:
| Analyte | Concentrations tested | Percentage Agreement at Each Color Block | | | |
| --- | --- | --- | --- | --- | --- |
| | | - (0 ml/L) | + (30 ml/L) | 2+ (80 ml/L) | 3+ (150 ml/L) |
| Albumin | 200 ml/L | 0% | 0% | 0% | 100% |
| | 150 ml/L | 0% | 0% | 0% | 100% |
| | 125 ml /L | 0% | 0% | 0% | 100% |
| | 120 ml /L | 0% | 0% | 0% | 100% |
| | 116 ml /L | 0% | 0% | 25.6% | 74.4% |
| | 110 ml /L | 0% | 0% | 70% | 30% |
| | 105 ml /L | 0% | 0% | 100% | 0% |
| | 65 ml /L | 0% | 0% | 100% | 0% |
| | 60 ml /L | 0% | 0% | 100% | 0% |
| | 56 ml /L | 0% | 25.3% | 74.7% | 0% |
| | 50 ml /L | 0% | 60% | 40% | 0% |
| | 45 ml /L | 0% | 100% | 0% | 0% |
| | 30 ml /L | 0% | 100% | 0% | 0% |
| | 25 ml /L | 0% | 100% | 0% | 0% |
| | 20 ml /L | 25.6% | 74.4% | 0% | 0% |
| | 15 ml /L | 70% | 30% | 0% | 0% |
| | 10 ml /L | 100% | 0% | 0% | 0% |
| Analyte | Concentrations tested | Percentage Agreement at Each Color Block | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| | | ± (10ml/dL) | + (50 ml/dL) | 2+ (100 ml/dL) | 3+ (200 ml/dL) | 4+ (300 ml/dL) |
| Creatinine | 350 ml/dL | 0% | 0% | 0% | 0% | 100% |
| | 300 ml/dL | 0% | 0% | 0% | 0% | 100% |
| | 290 ml/dL | 0% | 0% | 0% | 0% | 100% |
| | 285 ml/dL | 0% | 0% | 0% | 0% | 100% |
| | 281 ml/dL | 0% | 0% | 0% | 41.2% | 58.8% |
| | 275 ml/dL | 0% | 0% | 0% | 70% | 30% |
| | 270 ml/dL | 0% | 0% | 0% | 100% | 0% |
| | 190 ml/dL | 0% | 0% | 0% | 100% | 0% |
| | 185 ml/dL | 0% | 0% | 0% | 100% | 0% |
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Summary of the performance at each color block for the tested analyte concentrations:
| Analyte | Block output | Block cut-off value | % positive results |
| --- | --- | --- | --- |
| Albumin | +(30ml/L) | 20ml/L | 74.4% |
| | 2+(80ml/L) | 56 ml/L | 74.7% |
| | 3+(150ml/L) | 116ml/L | 74.4% |
| Creatinine | +(50ml/dL) | 30ml/L | 56.7% |
| | 2+(100ml/dL) | 81ml/L | 56.7% |
| | 3+(200ml/dL) | 181ml/L | 56.7% |
| | 4+(300ml/dL) | 281ml/L | 58.8% |
e. Analytical specificity:
Interference studies were performed to evaluate the effects of potential interferents commonly found in urine on the performance of URiSCAN 2 ACR strips, using CLSI EP7-A2 as a guide. Testing was done with contrived urine samples at 3 levels of albumin (25, 30, 150 mg/L) and 2 levels of creatinine (50, 300 mg/dL) and different concentrations of the listed compounds with 3 lots of strips in 3 analyzers. Interference is defined as a change in output of $\geq \pm 1$ color block between spiked and unspiked control sample. The results are summarized in the table below:
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| Interferences | Highest Concentration tested with no interference mg/dL | |
| --- | --- | --- |
| | Albumin | Creatinine |
| Calcium chloride | 190 | 210 |
| Glycine | 420 | 420 |
| Fructose | 70 | 90 |
| Ascorbic acid | 290 | 310 |
| Citric acid | 60 | 70 |
| Sodium nitrite | 7 | 9 |
| Potassium chloride | 1990 | 1210 |
| Sodium chloride | 4900 | 5100 |
| Sodium bicarbonate | 1300 | 1150 |
| Albumin | N/A | 880 |
| Sodium-2-mercaptoethene | 520 | 500 |
| Phenolphthalein | 1040 | 1060 |
| Theophylline | 80 | 85 |
| Riboflavin | 10 | 20 |
| Sodium acetate | 240 | 260 |
| Acetaminophen | 35 | 45 |
| High pH | 8 | 8 |
| Bilirubin | 3 | 4 |
| Hemoglobin | 4 | 5 |
| Blood | 290 | 290 |
| High specific gravity | 1.045 | 1.045 |
| Ketone bodies | 300 | 300 |
| White blood cells | 600 | 600 |
| Glucose | 500 | 500 |
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f. Assay cut-off:
Not applicable.
## 2. Comparison studies:
a. Method comparison with predicate device:
Comparison studies using a total of 351 random fresh urine samples were performed at three different POC sites. Results obtained on the URiSCAN 2 ACR strips and URiSCAN Optima Urine Analyzer and were compared to the Siemens Clinitek Status Analyzer and Clinitek Microalbumin 2 Reagent Strips. Similar performance was obtained at the three sites.
| Albumin (n=351) | Predicate device (mg/l) | | | | |
| --- | --- | --- | --- | --- | --- |
| | | 10 | 30 | 80 | 150 |
| URiSCAN Optima (mg/l) | 150 (3+) | | | 7 | 66 |
| | 80 (2+) | | 6 | 87 | 1 |
| | 30 (1+) | | 92 | 1 | |
| | 10 (Neg.) | 91 | | | |
| Total | | 91 | 98 | 95 | 67 |
| Exact agreement (%) | | 100.0 | 93.9 | 91.6 | 98.5 |
| Within One Block (%) | | 100.0 | 100.0 | 100.0 | 100.0 |
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| Creatinine (n=351) | Predicate device (mg/dl) | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| | | 10 | 50 | 100 | 200 | 300 |
| URiSCAN Optima (mg/dl) | 300 (4+) | | | | 2 | 38 |
| | 200 (3+) | | | 1 | 63 | 2 |
| | 100 (2+) | | 1 | 87 | 1 | |
| | 50 (1+) | 3 | 94 | 2 | | |
| | 10 (±) | 57 | | | | |
| Total | | 60 | 95 | 90 | 66 | 40 |
| Exact agreement (%) | | 95.0 | 98.9 | 96.7 | 95.5 | 95.0 |
| Within One Block (%) | | 100.0 | 100.0 | 100.0 | 100.0 | 100.0 |
| ACR (n=351) | Predicate device (mg/g) | | | |
| --- | --- | --- | --- | --- |
| | | <30 | 30-300 | >300 |
| URiSCAN Optima (mg/g) | >300 | | | 57 |
| | 30-300 | 2 | 169 | 1 |
| | <30 | 118 | 4 | |
| Total | | 120 | 173 | 58 |
| Exact agreement (%) | | 98.3 | 97.7 | 98.3 |
| Within One Block (%) | | 100.0 | 100.0 | 100.0 |
Color:
The URiSCAN Optima also determines the color of the urine automatically. The performance of this function was cleared under k050801. The sponsor stated that there has been no modification to the color function.
b. Matrix comparison:
Not applicable. The device is intended for one matrix (urine) only.
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable.
b. Clinical specificity:
Not applicable.
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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:
Albumin: Albumin is normally present in urine at concentrations of less than 20 mg/L. Albuminuria is defined as an albumin excretion rate of 30~299 mg/24 hours. Urinary albumin excretions can be temporarily elevated by exercise, urinary tract infections, and acute illness with fever.²,³,⁴
Creatinine: Creatinine is normally present in urine at concentrations of 10 to 300 mg/dL (0.9~26.5 mmol/L)
Albumin to Creatinine Ratio: Albumin is normally present in urine at concentrations of less than 30 mg albumin/g creatinine (3.4 mg albumin /mmol creatinine). Albuminuria is indicated at a ratio result of 30~300 mg/g (3.4~33.9 mg/mmol) and clinical albuminuria at a ratio result of >300 mg/g (>33.9 mg/mmol).¹
1. Position Statement: Diabetic Nephropathy. Diabetes Care 20: S24-S27; 1997.
2. Burtis, C.A. and Ashwood, E.R.: Tietz Textbook of Clinical Chemistry, 3rd ed. Philadelphia: Saunders; 1999; pp. 483-484.
3. Mangili, R. et al.: Prevalence of Hypertension and Albuminuria in Adult Type 1(Insulin Dependent) Diabetic Patients without Penal Failure in Italy – Validation of Screening.
4. American Diabetes Association, Clinical Practice Recommendations, Diabetes Care, Vol. 31, Suppl. 1, January 2008.
N. Instrument Name:
URiSCAN Optima Urine Analyzer
O. System Descriptions:
1. Modes of Operation:
Single and continuous testing.
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
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Yes ☐ X ☐ or No ☐
3. Specimen Identification:
Each sample’s identification can be entered prior to testing by way of an alpha-numeric keyboard and optional barcode reader.
4. Specimen Sampling and Handling:
Room temperature urine samples should be measured within 2 hours.
5. Calibration:
The URiSCAN Optima analyzer calibrates automatically before each measurement. The analyzer calibrates by reading the white check bar on each test strip at the appropriate wavelengths to ensure accurate test results. The instrument performs a “self-test” and calibration each time it is turned on. Each time a test is run, the analyzer re-calibrates using a white plastic calibration bar located at the bottom of the analyzer optical system. Reflectance measurements from the bar must match the factory set calibration.
6. Quality Control:
The sponsor recommends the use of commercially available controls intended for monitoring urine strip results at two levels (negative/low and positive).
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
Operating conditions of the URiSCAN Optima Urine Analyzer were evaluated and shown to be at a temperature range of 20 °C and 28 °C and relative humidity range between 10% and 70%.
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.
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.