K180428 · Nova Biomedical Corporation · JGS · Aug 15, 2018 · Clinical Chemistry
Device Facts
Record ID
K180428
Device Name
Stat Profile Prime Plus Analyzer System
Applicant
Nova Biomedical Corporation
Product Code
JGS · Clinical Chemistry
Decision Date
Aug 15, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1665
Device Class
Class 2
Indications for Use
The Stat Profile® Prime Plus Analyzer System is intended for use by healthcare professionals in clinical laboratory settings for the quantitative determination of sodium, potassium, chloride, ionized calcium, and ionized magnesium in heparinized arterial and venous whole blood. Sodium measurements are used in the diagnosis and treatment of aldosteronism, diabetes insipidus, adrenal hypertension, Addison’s disease, dehydration, or diseases involving electrolyte imbalance. Potassium measurements are used in the diagnosis and treatment of disease conditions characterized by low or high potassium levels. Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders such as cystic fibrosis and diabetic acidosis. Ionized calcium measurements are used in the diagnosis and treatment of parathyroid disease, a variety of bone diseases, chronic renal disease and tetany (intermittent muscular contractions or spasms). Ionized magnesium measurements are used in the diagnosis and treatment of hypomagnesemia (abnormally low levels of magnesium) and hypermagnesemia (abnormally high levels of magnesium).
Device Story
Stat Profile Prime Plus Analyzer System; clinical laboratory use; quantitative electrolyte analysis. Inputs: heparinized arterial/venous whole blood (135 μL). Principle: ion-selective electrode (ISE) potentiometry; potential proportional to logarithm of ionic activity (Nernst equation). Output: concentration values for Na, K, Cl, iCa, iMg (plus optional CO-Oximeter parameters depending on sensor card). Operation: barcode scan or manual touchscreen entry; automated processing via sensor cartridges/calibrator packs. Healthcare providers use output for diagnosis/treatment of electrolyte/metabolic disorders. Benefits: rapid, accurate electrolyte monitoring in clinical settings.
Clinical Evidence
Bench testing only. Precision/reproducibility evaluated using QC materials and whole blood (n=20 replicates; 20-day run-to-run studies). Linearity confirmed across claimed ranges (r > 0.99). Analytical specificity tested against common interferents; interference thresholds defined. Method comparison against predicate (n=214-222 samples) showed high correlation (slopes 0.997-1.015; r=0.975-0.999).
Technological Characteristics
Ion-selective electrode (ISE) sensing; potentiometric measurement. 10.1" WXGA 1280x800 color touch screen. Analyte ranges: Na (80-200 mmol/L), K (1.0-20.0 mmol/L), Cl (50-200 mmol/L), iCa (0.1-2.7 mmol/L), iMg (0.1-1.5 mmol/L). Traceable to NIST SRM standards. Complies with IEC 61010-1 and IEC 61010-2-101.
Indications for Use
Indicated for healthcare professionals in clinical laboratory settings for quantitative measurement of sodium, potassium, chloride, ionized calcium, and ionized magnesium in heparinized arterial and venous whole blood.
Regulatory Classification
Identification
A sodium test system is a device intended to measure sodium in serum, plasma, and urine. Measurements obtained by this device are used in the diagnosis and treatment of aldosteronism (excessive secretion of the hormone aldosterone), diabetes insipidus (chronic excretion of large amounts of dilute urine, accompanied by extreme thirst), adrenal hypertension, Addison's disease (caused by destruction of the adrenal glands), dehydration, inappropriate antidiuretic hormone secretion, or other diseases involving electrolyte imbalance.
Predicate Devices
Stat Profile pHOx Ultra Analyzer System (k110648)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k180428
B. Purpose for Submission:
New device
C. Measurands:
Sodium (Na), Potassium (K), Chloride (Cl), Ionized Calcium (iCa) and Ionized Magnesium (iMg)
D. Type of Test:
Quantitative, potentiometric, ion selective electrode
E. Applicant:
Nova Biomedical Corporation
F. Proprietary and Established Names:
Stat Profile® Prime Plus Analyzer System
G. Regulatory Information:
| Regulation section | Classification | Product code | Panel |
| --- | --- | --- | --- |
| 21 CFR § 862.1665 (Sodium test system) | Class II | JGS | Chemistry (75) |
| 21 CFR § 862.1600 (Potassium test system) | Class II | CEM | |
| 21 CFR § 862.1170 (Chloride test system) | Class II | CGZ | |
| 21 CFR § 862.1145 (Calcium test system) | Class II | JFP | |
| 21 CFR § 862.1495 (Magnesium test system) | Class I, reserved | CFA | |
H. Intended Use:
1. Intended use(s):
See Indication(s) for Use below
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2. Indication(s) for use:
The Stat Profile® Prime Plus Analyzer System is intended for use by healthcare professionals in clinical laboratory settings for the quantitative determination of sodium, potassium, chloride, ionized calcium, and ionized magnesium in heparinized arterial and venous whole blood.
Sodium measurements are used in the diagnosis and treatment of aldosteronism, diabetes insipidus, adrenal hypertension, Addison’s disease, dehydration, or diseases involving electrolyte imbalance.
Potassium measurements are used in the diagnosis and treatment of disease conditions characterized by low or high potassium levels.
Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders such as cystic fibrosis and diabetic acidosis.
Ionized calcium measurements are used in the diagnosis and treatment of parathyroid disease, a variety of bone diseases, chronic renal disease and tetany (intermittent muscular contractions or spasms).
Ionized magnesium measurements are used in the diagnosis and treatment of hypomagnesemia (abnormally low levels of magnesium) and hypermagnesemia (abnormally high levels of magnesium).
3. Special conditions for use statement(s):
Not for point of care use.
4. Special instrument requirements:
Stat Profile® Prime Plus Analyzer System
I. Device Description:
The Stat Profile® Prime Plus Analyzer System is designed to be used in a clinical laboratory setting. It consists of the analyzer, sensor cartridges, calibrator packs, auto-cartridge quality control packs (internal controls), ampiled quality control materials (external controls) and thermal paper for an onboard printer. Specimens are identified by scanning a barcode or by manually entering the information via the touchscreen.
The Stat Profile® Prime Plus Analyzer has slots to accommodate two sensor cartridges (primary and auxiliary). The analyzer will determine the configuration of the system by detecting which sensor cards are installed. The reporting of CO-Oximeter parameters (or not reporting them) will also be determined by the selection of the Sensor Cards, for which there are two options:
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- Primary Sensor Card 1 reports the following analytes: $\mathrm{pO}_2$ , $\mathrm{pCO}_2$ , pH, Hct, tHb, Na, Cl, K, iCa, iMg, Glu, $\mathrm{SO}_2$ , $\mathrm{O}_2\mathrm{Hb}$ , COHb, MetHb, HHb, tBil, and HbF
- Primary Sensor Card 2 reports the following analytes: $\mathrm{pO}_2$ , $\mathrm{pCO}_2$ , pH, Hct, tHb, Na, Cl, K, iCa, iMg, Glu, SO₂
# J. Substantial Equivalence Information:
1. Predicate device name(s):
Stat Profile pHOx Ultra Analyzer System
2. Predicate 510(k) number(s):
k110648
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Candidate Device - Stat Profile® Prime Plus Analyzer (k180428) | Predicate Device - Stat Profile pHOx Ultra Analyzer (k110648) |
| Intended Use | For the quantitative determination of sodium, potassium, chloride, ionized calcium, and ionized magnesium in heparinized arterial and venous whole blood. | Same |
| Measuring range – Na | 80 - 200 mmol/L | Same |
| Measuring range – K | 1.0 - 20.0 mmol/L | Same |
| Measuring range – Cl | 50 - 200 mmol/L | Same |
| Measuring range – iCa | 0.1 - 2.7 mmol/L | Same |
| Measuring range – iMg | 0.1 - 1.5 mmol/L | Same |
| Measurement Principle | Ion selective electrode | Same |
| Differences | | |
| --- | --- | --- |
| Item | Candidate Device - Stat Profile® Prime Plus Analyzer (k180428) | Predicate Device - Stat Profile pHOx Ultra Analyzer (k110648) |
| Matrices | Lithium heparin whole blood | Sodium or lithium heparinized whole blood, serum, or plasma |
| Sample Volume | 135 μL | 60 – 200 μL |
| Touch Screen | 10.1” WXGA 1280 x 800 color touch screen | 12.1” LCD, 1024x768 pixel, Resistive Touch |
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K. Standard/Guidance Document Referenced (if applicable):
- IEC 61010-1:2010 Safety requirements for electrical equipment for measurement, control, and laboratory use - Part 1: general requirements
- IEC 61010-2-101:2015 - Particular requirements for in vitro diagnostic (IVD) medical equipment
L. Test Principle:
The sodium, potassium, chloride, ionized calcium and ionized magnesium parameters are measured by an ion-selective electrode (ISE) that selectively measures the activity of ionic species. When the ISE is contacted with a sample, a potential is developed. The potential is proportional to the logarithm of the ionic activity and is measured versus a reference electrode, as described by the Nernst equation.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Within-run and between-analyzer precision was evaluated by analyzing quality control (QC) materials and whole blood samples in replicates of 20 on each of three analyzers.
Internal Quality Control within-run results:
All three analyzers yielded similar results. The results of one representative analyzer are summarized in the table below.
| Parameter | n = 20 | Internal Control Level 1 | Internal Control Level 2 |
| --- | --- | --- | --- |
| Na+ (mmol/L) | Mean | 141.9 | 116.2 |
| | SD | 0.2 | 0.2 |
| | CV% | 0.2 | 0.1 |
| K+ (mmol/L) | Mean | 4.02 | 6.22 |
| | SD | 0.01 | 0.01 |
| | CV% | 0.2 | 0.2 |
| Cl- (mmol/L) | Mean | 127.0 | 98.1 |
| | SD | 0.3 | 0.1 |
| | CV% | 0.2 | 0.1 |
| iCa²⁺ (mmol/L) | Mean | 0.97 | 1.39 |
| | SD | 0.00 | 0.00 |
| | CV% | 0.3 | 0.2 |
| iMg²⁺ (mmol/L) | Mean | 0.64 | 1.17 |
| | SD | 0.00 | 0.01 |
| | CV% | 0.5 | 0.5 |
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# External Quality Control within-run results:
All three analyzers yielded similar results. The results of one representative analyzer are summarized in the table below.
| Parameter | n = 20 | External Control Level 1 | External Control Level 2 |
| --- | --- | --- | --- |
| Na+ (mmol/L) | Mean | 137.9 | 111.7 |
| | SD | 0.2 | 0.3 |
| | CV% | 0.2 | 0.2 |
| K+ (mmol/L) | Mean | 3.91 | 6.10 |
| | SD | 0.14 | 0.02 |
| | CV% | 3.7 | 0.3 |
| Cl- (mmol/L) | Mean | 127.0 | 97.5 |
| | SD | 0.0 | 0.6 |
| | CV% | 0.0 | 0.6 |
| iCa2+ (mmol/L) | Mean | 0.99 | 1.64 |
| | SD | 0.01 | 0.01 |
| | CV% | 0.9 | 0.6 |
| iMg2+ (mmol/L) | Mean | 0.66 | 1.06 |
| | SD | 0.02 | 0.03 |
| | CV% | 2.4 | 2.6 |
# Within-run precision using whole blood:
All three analyzers yielded similar results. The results from one representative analyzer are summarized in the tables below. Note: the samples below were selected to evaluate a specific parameter over a specific range, so all parameters were not evaluated on all samples.
| Na+ (mmol/L) (n=20) | | | |
| --- | --- | --- | --- |
| Sample | Mean | SD | %CV |
| Sample A | 141.7 | 0.3 | 0.2 |
| Sample B | 142.4 | 0.4 | 0.3 |
| Sample 1 | 160.3 | 0.7 | 0.4 |
| Sample 2 | 120.3 | 0.4 | 0.4 |
| K+ (mmol/L) (n=20) | | | |
| --- | --- | --- | --- |
| Sample | Mean | SD | %CV |
| Sample A | 4.18 | 0.01 | 0.3 |
| Sample B | 3.86 | 0.03 | 0.8 |
| Sample 1 | 6.50 | 0.07 | 1.0 |
| Sample 6 | 2.58 | 0.04 | 1.5 |
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| Cl- (mmol/L) (n=20) | | | |
| --- | --- | --- | --- |
| Sample | Mean | SD | %CV |
| Sample A | 103.3 | 0.2 | 0.2 |
| Sample B | 107.3 | 0.8 | 0.7 |
| Sample 3 | 145.7 | 1.3 | 0.9 |
| Sample 4 | 74.8 | 0.7 | 1.0 |
| iCa2+ (mmol/L) (n=20) | | | |
| --- | --- | --- | --- |
| Sample | Mean | SD | %CV |
| Sample A | 1.18 | 0.01 | 0.6 |
| Sample B | 1.13 | 0.01 | 0.5 |
| Sample 1 | 1.66 | 0.01 | 0.9 |
| Sample 5 | 0.75 | 0.01 | 1.1 |
| iMg2+ (mmol/L) (n=20) | | | |
| --- | --- | --- | --- |
| Sample | Mean | SD | %CV |
| Sample A | 0.64 | 0.00 | 0.7 |
| Sample B | 0.65 | 0.01 | 1.0 |
| Sample 1 | 1.13 | 0.02 | 1.7 |
| Sample 7 | 0.24 | 0.01 | 3.6 |
# Run-to-run precision using QC material
Run-to-run precision was assessed by analyzing two levels of QC materials and whole blood in duplicate on each of three analyzers, with two runs per day over 20 days for a total of forty runs.
| Sodium | | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| Sample | Pooled Mean | N | Within run SD (Sr) | Within run % CV | Total imprecision SD (St) | Total Imprecision % CV |
| QC Level 4 | 141.7 | 240 | 0.2 | 0.2 | 0.3 | 0.2 |
| QC Level 5 | 116.5 | 240 | 0.2 | 0.2 | 0.3 | 0.3 |
| Potassium | | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| Sample | Pooled Mean | N | Within run SD (Sr) | Within run % CV | Total imprecision SD (St) | Total Imprecision % CV |
| QC Level 4 | 4.02 | 240 | 0.01 | 0.2 | 0.01 | 0.2 |
| QC Level 5 | 6.23 | 240 | 0.02 | 0.3 | 0.04 | 0.6 |
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| Chloride | | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| Sample | Pooled Mean | N | Within run SD (Sr) | Within run % CV | Total imprecision SD (St) | Total Imprecision % CV |
| QC Level 4 | 126.4 | 240 | 0.4 | 0.3 | 1.3 | 1.0 |
| QC Level 5 | 99.3 | 240 | 0.4 | 0.4 | 1.3 | 1.3 |
| ionized Calcium | | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| Sample | Pooled Mean | N | Within run SD (Sr) | Within run % CV | Total imprecision SD (St) | Total Imprecision % CV |
| QC Level 4 | 0.97 | 240 | 0.00 | 0.4 | 0.00 | 0.0 |
| QC Level 5 | 1.4 | 240 | 0.01 | 0.7 | 0.01 | 0.7 |
| ionized Magnesium | | | | | | |
| --- | --- | --- | --- | --- | --- | --- |
| Sample | Pooled Mean | N | Within run SD (Sr) | Within run % CV | Total imprecision SD (St) | Total Imprecision % CV |
| QC Level 4 | 0.61 | 240 | 0.01 | 1.6 | 0.02 | 3.3 |
| QC Level 5 | 1.14 | 240 | 0.01 | 0.9 | 0.03 | 2.6 |
# Run-to-run precision using whole blood
Estimates of the run-to-run precision were determined for the Stat Profile® Prime Plus analyzers for whole bloods that were sampled from a syringe. A ten day study was simulated by running samples followed by running a calibration and repeating the process ten times. All three analyzers yielded similar results. The results from one representative analyzer are summarized in the tables below. Note: the samples below were selected to evaluate a specific parameter over a specific range, so all parameters were not evaluated on all samples.
| Parameter | n = 30 | Venous Blood 1 | Venous Blood 2 | Venous Blood 3 | Venous Blood 4 |
| --- | --- | --- | --- | --- | --- |
| Na + (mmol/L) | Mean | 146.4 | 157.3 | 119.7 | n/a |
| | SD | 0.8 | 0.6 | 0.7 | |
| | CV% | 0.6 | 0.4 | 0.6 | |
| K + (mmol/L) | Mean | 3.49 | 4.85 | n/a | 2.53 |
| | SD | 0.08 | 0.05 | | 0.03 |
| | CV% | 2.26 | 1.0 | | 1.4 |
| Cl - (mmol/L) | Mean | 103.5 | 120.5 | 90.3 | n/a |
| | SD | 0.3 | 0.7 | 0.4 | |
| | CV% | 0.3 | 0.6 | 0.5 | |
| iCa2+ (mmol/L) | Mean | 1.19 | 1.60 | n/a | 0.96 |
| | SD | 0.01 | 0.01 | | 0.01 |
| | CV% | 0.51 | 0.6 | | 0.6 |
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| Parameter | n = 30 | Venous Blood 1 | Venous Blood 2 | Venous Blood 3 | Venous Blood 4 |
| --- | --- | --- | --- | --- | --- |
| iMg 2+ (mmol/L) | Mean | 0.64 | 0.87 | n/a | 0.42 |
| | SD | 0.00 | 0.01 | | 0.01 |
| | CV% | 0.6 | 1.6 | | 1.2 |
# b. Linearity/assay reportable range:
The sponsor performed a linearity study to evaluate the claimed analytical measurement range (AMR) for the sodium, potassium, chloride, ionized calcium, and ionized magnesium assays on the Stat Profile Prime® Plus Analyzer. The evaluation of the linear range included lower and upper limits of the AMR and various medical decision limits.
Low and high concentration pools were prepared from the whole bloods for each parameter. Nine to eleven different concentrations spanning the analytical range were made per analyte from these pools using serial dilutions. Each blood level was analyzed in triplicate in random order on three test analyzers and on the pHOx Ultra reference analyzer. The pHOx Ultra analyzers were used to establish the target value of each blood level for each parameter. All three analyzers yielded similar results. The results of the least squares linear regression analysis from one representative analyzer are summarized below.
| Analyte | Claimed measurement range | Concentration range tested | Slope | Intercept | r |
| --- | --- | --- | --- | --- | --- |
| Na+ mmol/L | 80 - 200 | 77.6 - 213.5 | 1.0076 | -1.1382 | 0.9998 |
| K+ mmol/L | 1.0 - 20.0 | 0.57 - 21.7 | 1.0199 | -0.2714 | 0.9993 |
| Cl- mmol/L | 50 - 200 | 45.6 - 225 | 0.9681 | 2.8399 | 0.9992 |
| iCa mmol/L | 0.1 - 2.7 | 0.06 - 2.76 | 1.0003 | 0.0015 | 0.9996 |
| iMg mmol/L | 0.1 - 1.5 | 0.12 - 1.56 | 0.9887 | 0.0356 | 0.9964 |
The results of the linearity study support the sponsor's claimed measuring ranges (as described in the table above).
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c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The sodium standards and reagents are traceable to NIST SRM 2201.
The potassium standards and reagents are traceable to NIST SRM 2202.
The chloride standards and reagents are traceable to NIST SRM 2201.
The ionized calcium standards and reagents are traceable to NIST SRM 91Sa.
The ionized magnesium standards and reagents are traceable to NIST SRM 929a.
d. Detection limit:
The sponsor performed a study to evaluate the limit of blank (LoB), limit of detection (LoD) and limit of quantification for ionized calcium and ionized magnesium using altered whole blood samples. Study samples were prepared from heparinized venous whole blood samples. Varying amounts of sodium citrate were added to some samples to bind the iCa and iMg and create blank samples and low level samples. All prepared samples were analyzed on the reference analyzer to obtain the target values.
Results for ionized calcium and ionized magnesium were as follows:
| Analyte | units | LoB | LoD | TE | LoQ | Acceptance Criteria for TE (<=) | Claimed Measurement Range |
| --- | --- | --- | --- | --- | --- | --- | --- |
| iCa | mmol/L | 0.04 | 0.05 | 0.02 | 0.05 | 0.2 | 0.1 - 2.7 |
| iMg | mmol/L | 0.05 | 0.1 | 0.1 | 0.1 | 0.11 | 0.1 - 1.5 |
The performance at the lower end of the measuring range for sodium, potassium, and chloride is supported by the linearity studies in section M.1.b.
e. Analytical specificity:
The sponsor performed a specificity study using whole blood collected in lithium heparin vacutainers. Samples were divided to create two separate pools of blood, one for control samples and the other for test samples. The potential interferents were tested at two analyte concentrations. For all analytes, the sponsor defined interference as $> \pm 10\%$ bias from the test concentration. If interference was identified, a dose response study was performed to determine the concentration where the interfering substance may alter results.
The sponsor determined that the following substances did not cause interference at the concentrations listed below:
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Sodium
| Substance | Highest concentration tested that did not cause significant interference |
| --- | --- |
| Acetoacetate | 2 mmol/L |
| Acetylsalicylic Acid | 3.62 mmol/L |
| Ammonium Chloride | 107 μmol /L |
| Benzalkonium Chloride | 10 mg/L |
| Bilirubin | 342 μmol /L |
| CaCl₂ | 2 mmol/L |
| Dobutamine | 2 mg/dL |
| Hemoglobin | 2 g/L |
| Ibuprofen | 2.4 mmol/L |
| Intralipid | 1.0% |
| Lithium Lactate | 6.6 mmol/L |
| MgCl₂ | 15 mmol/L |
| Salicylic Acid | 4.34 mmol/L |
| ZnCl₂ | 1.3 mg/dL |
Potassium
| Substance | Highest concentration tested that did not cause significant interference |
| --- | --- |
| Acetoacetate | 2 mmol/L |
| Acetylsalicylic Acid | 3.62 mmol/L |
| Ammonium Chloride | 107 μmol /L |
| Benzalkonium Chloride | 10 mg/L |
| Bilirubin | 342 μmol /L |
| CaCl₂ | 2 mmol/L |
| Dobutamine | 2 mg/dL |
| Hemoglobin | 2 g/L |
| Ibuprofen | 2.4 mmol/L |
| Intralipid | 1.00% |
| Lithium Lactate | 6.6 mmol/L |
| NaBr | 37.5 mmol/L |
| Salicylic Acid | 4.34 mmol/L |
| ZnCl₂ | 1.3 mg/dL |
Chloride
| Substance | Highest concentration tested that did not cause significant interference |
| --- | --- |
| Acetoacetate | 2 mmol/L |
| Acetylsalicylic Acid | 3.62 mmol/L |
| Ammonium Chloride | 107 μmol /L |
| Ascorbic Acid | 50 mg/dL |
| Benzalkonium Chloride | 10 mg/L |
| Bilirubin | 342 μmol /L |
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| Substance | Highest concentration tested that did not cause significant interference |
| --- | --- |
| Hemoglobin | 2 g/L |
| Ibuprofen | 2.4 mmol/L |
| Intralipid | 1.00% |
| Lithium Lactate | 6.6 mmol/L |
| Perchlorate | 1 mmol/L |
| Salicylic Acid | 4.34 mmol/L |
| Sodium Citrate | 12 mmol/L |
| Sodium Oxalate | 500 mg/dL |
Ionized Calcium
| Substance | Highest concentration tested that did not cause significant interference |
| --- | --- |
| Acetoacetate | 2 mmol/L |
| Ammonium Chloride | 107 μmol /L |
| Benzalkonium Chloride | 10 mg/L |
| Bilirubin | 342 μmol /L |
| Dobutamine | 2 mg/dL |
| Hemoglobin | 2 g/L |
| Ibuprofen | 2.4 mmol/L |
| Intralipid | 1.00% |
| KCl | 5 mmol/L |
| Lithium Lactate | 6.6 mmol/L |
| NaBr | 37.5 mmol/L |
| NaCl | 10 mmol/L |
| Perchlorate | 1 mmol/L |
| ZnCl2 | 1.3 mg/dL |
Ionized Magnesium
| Substance | Highest concentration tested that did not cause significant interference |
| --- | --- |
| Acetoacetate | 2 mmol/L |
| Ammonium Chloride | 107 μmol /L |
| Benzalkonium Chloride | 10 mg/L |
| Bilirubin | 342 μmol /L |
| CaCl2 | 2 mmol/L |
| Dobutamine | 2 mg/dL |
| Hemoglobin | 2 g/L |
| Ibuprofen | 2.4 mmol/L |
| Intralipid | 1.00% |
| KCl | 5 mmol/L |
| Lithium Lactate | 6.6 mmol/L |
| NaBr | 37.5 mmol/L |
| NaCl | 10 mmol/L |
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The sponsor lists the following interferents in the labeling:
| Parameter | Interferent | Interference Observed at Concentrations Above: |
| --- | --- | --- |
| Ionized Calcium | MgCl2 | 3.75 mmol/L |
| Ionized Magnesium | Perchlorate | 0.06 mmol/L |
| | Thiocyanate | 0.4 mmol/L |
| | ZnCl2 | 0.163 mg/dL |
| Chloride | Bromide | 2.5 mmol/L |
| | Thiocyanate | 3.4 mmol/L |
f. Assay cut-off:
Not applicable
# 2. Comparison studies:
a. Method comparison with predicate device:
Method comparison studies were conducted by testing lithium heparinized arterial and venous whole blood specimens in singlet on the three Stat Profile® Prime Plus analyzers and two pHOx Ultra analyzers (predicate device). In order to evaluate the claimed measuring range, some venous whole blood specimens were tonometered, spiked or diluted to achieve the desired concentrations. The singlet result from each test analyzer was compared to the average of the results from each comparative method. Linear regression analysis of one representative analyzer is shown below.
| Analyte | n | Sample concentration range | Slope | Intercept | r |
| --- | --- | --- | --- | --- | --- |
| Sodium (mmol/L) | 217 | 84.8 – 190.6 | 1.002 | -0.275 | 0.9950 |
| Potassium (mmol/L) | 219 | 1.30 – 18.37 | 1.012 | -0.019 | 0.9991 |
| Chloride (mmol/L) | 219 | 69.7 – 181.9 | 1.015 | -0.835 | 0.9967 |
| Ionized Calcium (mmol/L) | 222 | 0.25 – 2.47 | 0.997 | -0.001 | 0.9928 |
| Ionized Magnesium (mmol/L) | 214 | 0.24 – 1.44 | 0.998 | 0.008 | 0.9751 |
b. Matrix comparison:
Not applicable. For use with lithium heparinized whole blood only.
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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 ranges for sodium, potassium, chloride and ionized calcium are cited from the literature:
Sodium: 136 - 146 mmol/L
Potassium: 3.5 - 5.1 mmol/L
Chloride: 98 - 106 mmol/L
Ionized Calcium: 1.09 - 1.30 mmol/L
References:
Statland, Bernard, Clinical Decision Levels for Lab Tests, Medical Economics Books, 1987.
Burtis, Carl A. and Ashwood, Edward R., ed. 1994. Tietz Textbook of Clinical Chemistry, W. B. Saunders Co. Philadelphia, PA.
Tietz, Norbert W., ed. 1983. Clinical Guide to Laboratory Tests, W. B. Saunders Co., Philadelphia, PA.
Kost, G.T., "The Significance of Ionized Calcium in Cardiac and Critical Care," Arch. Pathol. Lab Med. Vol. 117: pp 890-896. 1993.
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Reference range for ionized magnesium was determined from reference ranges established in a dozen or so reporting institutions that have been working with Nova analyzers. The extremes of the reference ranges in these institutions were 0.43 - 0.57 to 0.46 - 0.62, with most being 0.45 - 0.60 mmol/L.
Ionized Magnesium: 0.45 – 0.60 mmol/L
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Parts 801 and 809, as applicable.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.