K240455 · Becton, Dickinson and Company · GIM · Oct 31, 2024 · Clinical Chemistry
Device Facts
Record ID
K240455
Device Name
BD Vacutainer® Citrate Blood Collection Tubes
Applicant
Becton, Dickinson and Company
Product Code
GIM · Clinical Chemistry
Decision Date
Oct 31, 2024
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1675
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The BD Vacutainer® Citrate Blood Collection Tube (0.109M buffered sodium citrate) is a sterile, single use tube used for the collection, containment, transport, and centrifugation of venous blood specimens to obtain plasma for in vitro diagnostic testing. It is used in settings where a venous blood sample is collected by a trained healthcare worker. The BD Vacutainer® Citrate Blood Collection Tube is used for clinical laboratory testing in coagulation.
Device Story
BD Vacutainer Citrate Blood Collection Tubes are sterile, single-use evacuated plastic tubes containing 0.109M buffered sodium citrate. Used by trained healthcare workers in clinical settings to collect, contain, transport, and centrifuge venous blood. The additive reversibly binds free calcium to prevent coagulation. Tubes feature a Hemogard closure assembly with a rubber stopper and protective plastic shield to minimize blood splatter and exposure. Following collection, the device provides an anticoagulated plasma specimen for clinical laboratory coagulation assays. The device is compatible with standard BD blood collection needles, sets, and holders. By maintaining vacuum and additive integrity, the tubes ensure specimen quality for downstream diagnostic testing, facilitating accurate clinical decision-making.
Clinical Evidence
Clinical studies evaluated performance for coagulation parameters (PT, aPTT, INR, D-Dimer, Anti-Factor Xa). Studies included clinical equivalence against a comparator tube, within-tube stability, shelf-life performance (EOSL), and repeatability/reproducibility (within-tube, tube-to-tube, and lot-to-lot). Results confirmed clinical equivalence and met non-inferiority criteria for all tested coagulation analytes.
Technological Characteristics
Evacuated plastic (polypropylene/polypropylene terephthalate) tubes; 13x75mm dimensions; 1.8 mL or 2.7 mL draw volumes. Additive: 0.109 M (3.2%) buffered sodium citrate. Closure: Hemogard assembly (rubber stopper/plastic shield). Sterilization: Gamma irradiation (SAL 10^-3). Compliant with CLSI GP34-A, GP39-A6, EP05-A3, EP25, and ISO 11137 standards.
Indications for Use
Indicated for venous blood collection in patients 18 years or older requiring clinical laboratory coagulation testing. Used by trained healthcare workers in clinical settings.
Regulatory Classification
Identification
A blood specimen collection device is a device intended for medical purposes to collect and to handle blood specimens and to separate serum from nonserum (cellular) components prior to further testing. This generic type device may include blood collection tubes, vials, systems, serum separators, blood collection trays, or vacuum sample tubes.
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FDA
U.S. FOOD & DRUG
ADMINISTRATION
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
ASSAY ONLY
## I Background Information:
A 510(k) Number
K240455
B Applicant
Becton Dickinson and Company
C Proprietary and Established Names
BD Vacutainer Citrate Blood Collection Tubes
D Regulatory Information
| Product Code(s) | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| GIM | Class II | 21 CFR 862.1675 - Blood Specimen Collection Device | CH - Clinical Chemistry |
## II Submission/Device Overview:
A Purpose for Submission:
Modifications to existing blood collection tubes
B Measurand:
Not applicable to blood collection tube
C Type of Test:
Not applicable
## III Intended Use/Indications for Use:
A Intended Use(s):
See Indications for Use below.
Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
www.fda.gov
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K240455 - Page 2 of 10
## B Indication(s) for Use:
The BD Vacutainer Citrate Blood Collection Tube (0.109M buffered sodium citrate) is a sterile, single use tube used for the collection, containment, transport, and centrifugation of venous blood specimens to obtain plasma for in vitro diagnostic testing. It is used in settings where a venous blood sample is collected by a trained healthcare worker. The BD Vacutainer Citrate Blood Collection Tube is used for clinical laboratory testing in coagulation.
## C Special Conditions for Use Statement(s):
Rx - For Prescription Use Only
## D Special Instrument Requirements:
Not Applicable.
## IV Device/System Characteristics:
### A Device Description:
BD Vacutainer Citrate Blood Collection Tubes (BD Citrate Tubes) are for collection, containment, transport, and centrifugation of venous blood. The blood collection tube consists of a closure assembly (BD Hemogard Closure), a plastic configuration and a liquid additive (0.109 M buffered sodium citrate). The BD Citrate tubes are available with Hemogard Closure. Assembly which consists of a rubber stopper and protective plastic shield to reduce user exposure to blood. The buffered sodium citrate solution prevents specimen coagulation. The tubes are compatible with the BD Vacutainer Blood Collection Needles, Blood Collection Sets, Transfer Devices, Holders, and Adaptors.
### BD Citrate Tubes Configurations
| SKU # | Product Family | Tube Material | Tube Size (mm) | Draw Volume (mL) | Tube Closure |
| --- | --- | --- | --- | --- | --- |
| 363080 | 3.2% (0.109 M) Sodium Citrate | Plastic | 13x75 | 1.8 | Hemogard translucent shield with blue stopper |
| 363083 | 3.2% (0.109 M) Sodium Citrate | Plastic | 13x75 | 2.7 | Hemogard light blue shield with blue stopper |
| 366560 | 3.2% (0.109 M) Sodium Citrate | Plastic | 13x75 | 2.7 | Hemogard light blue shield with blue stopper |
### B Principle of Operation:
The BD Vacutainer Citrate Tubes are plastic, evacuated, and sterile (1.8 mL or 2.7 mL) tubes. The tubes contain a buffered sodium citrate used to anti-coagulate whole blood for hematological investigations. It acts as an extracorporeal anticoagulant by binding free calcium in the blood which is a necessary co-factor to several steps in the clotting/coagulation cascade. Anticoagulation with buffered sodium citrate is reversible with the addition of excess calcium.
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The blood collected into the BD Vacutainer Citrate Tube are centrifuged and the plasma portion (containing the specimen) is analyzed for coagulation parameters.
V Substantial Equivalence Information:
A Predicate Device Name(s): BD Vacutainer Safety Coagulation Tube
B Predicate 510(k) Number(s): K013971
C Comparison with Predicate(s):
| Device & Predicate Device(s): | K240455 | K013971 |
| --- | --- | --- |
| Device Trade Name | BD Vacutainer Citrate Blood Collection Tubes | BD Vacutainer Safety Coagulation Tube |
| General Device Characteristic Similarities | | |
| Indications For Use | The BD Vacutainer Citrate Blood Collection Tube (0.109M buffered sodium citrate) is a sterile, single use tube used for the collection, containment, transport, and centrifugation of venous blood specimens to obtain plasma for in vitro diagnostic testing. It is used in settings where a venous blood sample is collected by a trained healthcare worker. The BD Vacutainer Citrate Blood Collection Tube is used for clinical laboratory testing in coagulation. | BD Vacutainer Safety Coagulation tube is a plastic evacuated blood collection tube that provides a means of collecting, transporting and processing blood in a closed tube. The buffered sodium citrate additive provides an anticoagulated specimen that may be used for clinical laboratory coagulation assays. The benefits of a safety plastic coagulation tube with Hemogard Safety Closure Assembly are:
• Reduced risk of specimen tube breakage
• Reduced exposure to blood by laboratory personnel and to minimize blood splatter during stopper removal.
These benefits lead to increased safety of laboratory personnel and reduced necessity of repeat |
K240455 - Page 3 of 10
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| Device & Predicate Device(s): | K240455 | K013971 |
| --- | --- | --- |
| | | specimen collection. |
| Evacuated Blood Collection Tube | Yes | Same |
| Test Type | Coagulation | Same |
| Tube Material | Inner Tube: Polypropylene
Outer Tube: Polypropylene terephthalate | Same |
| Tube Size | 13 x 75mm | Same |
| Draw Volume | 1.8 mL or 2.7 mL | Same |
| Additive Type and Concentration | 0.109 M (3.2%) Sodium Citrate (liquid) in 2.7 mL and 1.8 mL | 2.7mL 0.109M (3.2%) Sodium Citrate (liquid), 1.8 mL 0.129M (3.2%) Sodium Citrate (liquid) |
| Closure Type/Color | 2.7mL: Hemogard light blue cap and blue stopper
1.8mL: Hemogard Translucent cap and blue stopper | Same |
| Sterilization Method | Gamma Irradiation | Same |
| Sterility Assurance Level (SAL) | 10^{-3} | Same |
| Shelf-life | 2.7 mL: 9 months
1.8 mL: 6 months | Same |
| General Device Characteristic Differences | | |
| Tube Type of Material | Plastic | Plastic and Glass |
VI Standards/Guidance Documents Referenced:
- CLSI GP34-A, Validation and Verification of Tubes for Venous and Capillary Blood Specimen Collection; Approved Guidance.
- CLSI GP39-A6, Tubes and Additives for Venous Blood Specimen Collection; Approved Standard – Sixth Edition.
- CLSI EP05-A3, Evaluation of Precision of Quantitative Measurement Procedures; Approved Guideline – Third Edition
- CLSI EP25, Evaluation of Stability of In Vitro Medical Laboratory Test Reagents, 2nd Edition.
- ANSI AAMI ISO 11137-1:2006/(R)2015 Sterilization of health care products - Radiation - Part 1: Requirements for development, validation, and routine control of a sterilization process for medical devices [Including: Amendment 1 (2013) and Amendment 2 (2019)].
- ANSI AAMI ISO 11137-2:2013/(R)2019 Sterilization of health care products - Radiation - Part 2: Establishing the sterilization dose.
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- ANSI/AAMI/ISO 11137-3:2017 Sterilization of health care products - Radiation - Part 3: Guidance on dosimetric aspects of development, validation and routine control.
- ANSI/AAMI/ISO 11737-1:2018 Sterilization of health care products - Microbiological methods - Part 1: Determination of a population of microorganisms on products.
- ANSI/AAMI/ISO 11737-2:2019 Sterilization of medical devices - Microbiological methods - Part 2: Tests of sterility performed in the definition, validation and maintenance of a sterilization process.
- ANSI AAMI ST67:2019 Sterilization of health care products - Requirements and guidance for selecting a sterility assurance level (SAL) for products labeled "sterile".
- ASTM D4169-16 Standard Practice for Performance Testing of Shipping Containers and Systems.
- EN ISO 14971:2019 Medical Devices – Application of risk management to medical devices.
## VII Performance Characteristics (if/when applicable):
## A Analytical Performance:
### 1. Precision/Reproducibility:
The study was conducted to evaluate the clinical performance of BD Vacutainer Citrate Tubes (2.7 mL) for repeatability (within-tube), lot-to-lot and tube-to-tube variation in comparison with Greiner Bio-One Vacuette Citrate Tubes (2.7 mL) for selected coagulation parameters (PT, INR, aPTT, D-Dimer, and Anti-Factor Xa). Blood from sixty-five subjects was collected into the study tubes, which consisted of three lots of each tube type. Samples were tested for the coagulation parameters within 4 hours of collection at room temperature on the STA Compact Max, Sysmex CS-2500 and Instrumentation Laboratory ACL TOP 750. Performance of the BD Vacutainer Citrate Tubes for between-lot variation and between-tube variation showed non inferiority for all tube comparisons for the coagulation parameters tested on instrument platforms when compared with the comparator device.
Variance Components and Confidence Intervals (CI)
| Instrument | Analyte | Tube Type | Source | Mean | SD (95% CI) | CV% (95% CI) |
| --- | --- | --- | --- | --- | --- | --- |
| Stago STA Compact Max | D-Dimer (μg/mL FEU) | BD Citrate | Between-Lot | 1.592 | 0.004 (0.000, 0.028) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 1.592 | 0.006 (0.000, 0.031) | 0.0% (0.0%, 0.0%) |
| | | | Within-Tube | 1.592 | 0.138 (0.127, 0.152) | 8.4% (7.7%, 9.3%) |
| | | | Total | 1.592 | 0.138 (0.107, 0.197) | 8.4% (6.5%, 12.0%) |
| Stago STA Compact Max | D-Dimer (μg/mL FEU) | Greiner Citrate | Between-Lot | 1.580 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 1.580 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
| | | | Within-Tube | 1.580 | 0.168 (0.154, 0.184) | 8.9% (8.1%, 9.7%) |
| | | | Total | 1.580 | 0.168 (0.129, 0.239) | 8.9% (6.8%, 12.6%) |
| Sysmex CS-2500 | D-Dimer (μg/mL FEU) | BD Citrate | Between-Lot | 1.656 | 0.000 (0.000, 0.000) | 1.6% (1.0%, 4.3%) |
| | | | Between-Tube | 1.656 | 0.014 (0.000, 0.028) | 1.5% (0.0%, 2.3%) |
| | | | Within-Tube | 1.656 | 0.107 (0.098, 0.117) | 3.6% (3.2%, 4.1%) |
| | | | Total | 1.656 | 0.108 (0.083, 0.152) | 4.2% (3.2%, 5.9%) |
| Sysmex CS-2500 | D-Dimer (μg/mL FEU) | Greiner Citrate | Between-Lot | 1.681 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 1.681 | 0.014 (0.000, 0.038) | 0.6% (0.0%, 1.2%) |
| | | | Within-Tube | 1.681 | 0.172 (0.158, 0.188) | 4.3% (4.0%, 4.7%) |
| | | | Total | 1.681 | 0.172 (0.133, 0.243) | 4.4% (3.4%, 6.2%) |
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| Instrument | Analyte | Tube Type | Source | Mean | SD (95% CI) | CV% (95% CI) |
| --- | --- | --- | --- | --- | --- | --- |
| Stago STA Compact Max | INR | BD Citrate | Between-Lot | 1.268 | 0.024 (0.021,0.031) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 1.268 | 0.022 (0.010, 0.029) | 0.0% (0.0%, 0.0%) |
| | | | Within-Tube | 1.268 | 0.034 (0.030, 0.038) | 2.8% (2.6%, 3.1%) |
| | | | Total | 1.268 | 0.047 (0.036, 0.065) | 2.8% (2.2%, 4.0%) |
| Stago STA Compact Max | INR | Greiner Citrate | Between-Lot | 1.260 | 0.012 (0.011, 0.016) | 1.1% (0.7%, 2.0%) |
| | | | Between-Tube | 1.260 | 0.015 (0.006, 0.020) | 0.2% (0.0%, 1.0%) |
| | | | Within-Tube | 1.260 | 0.024 (0.022, 0.027) | 2.1% (1.9%, 2.4%) |
| | | | Total | 1.260 | 0.031 (0.024, 0.043) | 2.4% (1.9%, 3.4%) |
| Sysmex CS-2500 | INR | BD Citrate | Between-Lot | 1.309 | 0.007 (0.000, 0.019) | 1.4% (1.0%, 2.4%) |
| | | | Between-Tube | 1.309 | 0.000 (0.000, 0.000) | 2.0% (1.6%, 2.3%) |
| | | | Within-Tube | 1.309 | 0.089 (0.082, 0.098) | 0.5% (0.4%, 0.5%) |
| | | | Total | 1.309 | 0.089 (0.070, 0.125) | 2.4% (1.9%, 3.4%) |
| Sysmex CS-2500 | INR | Greiner Citrate | Between-Lot | 1.298 | 0.021 (0.000, 0.035) | 1.7% (1.3%, 2.3%) |
| | | | Between-Tube | 1.298 | 0.000 (0.000, 0.000) | 1.1% (0.9%, 1.3%) |
| | | | Within-Tube | 1.298 | 0.069 (0.064, 0.076) | 0.5% (0.5%, 0.6%) |
| | | | Total | 1.298 | 0.072 (0.056, 0.101) | 2.1% (1.6%, 2.9%) |
| Stago STA Compact Max | PT (sec) | BD Citrate | Between-Lot | 15.73 | 0.00 (0.00, 0.00) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 15.73 | 0.01 (0.00, 0.07) | 0.0% (0.0%, 0.0%) |
| | | | Within-Tube | 15.73 | 0.39 (0.36, 0.43) | 2.2% (2.0%, 2.4%) |
| | | | Total | 15.73 | 0.39 (0.310.55) | 2.2% (1.7%, 3.1%) |
| Stago STA Compact Max | PT (sec) | Greiner Citrate | Between-Lot | 15.65 | 0.03 (0.00, 0.06) | 0.8% (0.6%, 1.5%) |
| | | | Between-Tube | 15.65 | 0.00 (0.00, 0.00) | 0.1% (0.0%, 0.7%) |
| | | | Within-Tube | 15.65 | 0.27 (0.25, 0.30) | 1.6% (1.5%, 1.9%) |
| | | | Total | 15.65 | 0.28 (0.21, 0.39) | 1.8% (1.4%, 2.6%) |
| Sysmex CS-2500 | PT (sec) | BD Citrate | Between-Lot | 13.43 | 0.57 (0.50, 0.70) | 0.2% (0.0%, 0.5%) |
| | | | Between-Tube | 13.43 | 0.69 (0.57, 0.80) | 0.1% (0.0%, 0.5%) |
| | | | Within-Tube | 13.43 | 0.07 (0.06, 0.08) | 2.1% (2.0%, 2.3%) |
| | | | Total | 13.43 | 0.90 (0.70, 1.26) | 2.1% (1.7%, 3.0%) |
| Sysmex CS-2500 | PT (sec) | Greiner Citrate | Between-Lot | 13.33 | 0.66 (0.53, 0.87) | 1.6% (1.3%, 2.2%) |
| | | | Between-Tube | 13.33 | 0.36 (0.29, 0.42) | 1.0% (0.8%, 1.2%) |
| | | | Within-Tube | 13.33 | 0.07 (0.07, 0.08) | 0.5% (0.5%, 0.6%) |
| | | | Total | 13.33 | 0.76 (0.59, 1.06) | 2.0% (1.5%, 2.7%) |
| Stago STA Compact Max | aPTT (sec) | BD Citrate | Between-Lot | 43.09 | 1.60 (0.99, 4.14) | 0.1% (0.0%, 0.9%) |
| | | | Between-Tube | 43.09 | 2.57 (1.93, 3.08) | 0.5% (0.0%, 1.1%) |
| | | | Within-Tube | 43.09 | 1.82 (1.62, 2.07) | 4.1% (3.7%, 4.5%) |
| | | | Total | 43.09 | 3.53 (2.72, 5.02) | 4.1% (3.2%, 5.8%) |
| Stago STA Compact Max | aPTT (sec) | Greiner Citrate | Between-Lot | 43.95 | 0.36 (0.00, 1.33) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 43.95 | 0.95 (0.00, 1.67) | 1.3% (0.0%, 2.1%) |
| | | | Within-Tube | 43.95 | 3.86 (3.54, 4.25) | 5.0% (4.6%, 5.6%) |
| | | | Total | 43.95 | 4.00 (3.09, 5.67) | 5.2% (4.0%, 7.4%) |
| Sysmex CS-2500 | aPTT (sec) | BD Citrate | Between-Lot | 40.84 | 0.00 (0.00, 0.00) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 40.84 | 0.13 (0.00, 0.59) | 0.0% (0.0%, 0.0%) |
| | | | Within-Tube | 40.84 | 3.01 (2.77, 3.31) | 3.9% (3.6%, 4.2%) |
| | | | Total | 40.84 | 3.02 (2.34, 4.25) | 3.9% (3.0%, 5.5%) |
| Sysmex CS-2500 | aPTT (sec) | Greiner Citrate | Between-Lot | 40.88 | 2.20 (1.64, 3.36) | 1.0% (0.4%, NA) |
| | | | Between-Tube | 40.88 | 2.27 (1.83, 2.63) | 4.8% (3.9%, 5.5%) |
| | | | Within-Tube | 40.88 | 0.50 (0.44, 0.56) | 0.8% (0.7%, 0.9%) |
| | | | Total | 40.88 | 3.20 (2.48, 4.51) | 4.9% (3.8%, 7.0%) |
| IL TOP 750 | Anti-Factor Xa (IU/mL) | BD Citrate | Between-Lot | 0.474 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
| | | | Between-Tube | 0.474 | 0.000 (0.000, 0.000) | 0.3% (0.0%, 1.1%) |
| | | | Within-tube | 0.474 | 0.021 (0.020, 0.023) | 6.8% (6.3%, 7.4%) |
| | | | Total | 0.474 | 0.021 (0.017, 0.028) | 6.8% (5.5%, 8.9%) |
| | | | Between-Lot | 0.471 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
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| Instrument | Analyte | Tube Type | Source | Mean | SD (95% CI) | CV% (95% CI) |
| --- | --- | --- | --- | --- | --- | --- |
| IL TOP 750 | Anti-Factor Xa (IU/mL) | Greiner Citrate | Between Tube | 0.471 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
| | | | Within-tube | 0.471 | 0.023 (0.022, 0.025) | 9.6% (9.0%, 10.4%) |
| | | | Total | 0.471 | 0.023 (0.019, 0.030) | 9.6% (7.8%, 12.7%) |
| Stago STA Compact Max | Anti-Factor Xa (IU/mL) | BD Citrate | Between-Lot | 0.944 | 0.001 (0.000, 0.007) | 0.1% (0.1%, 0.2%) |
| | | | Between Tube | 0.944 | 0.000 (0.000, 0.000) | 0.1% (0.0%, 1.7%) |
| | | | Within-tube | 0.944 | 0.035 (0.032, 0.039) | 3.7% (3.2%, 4.3%) |
| | | | Total | 0.944 | 0.035 (0.026, 0.054) | 3.7% (2.7%, 5.7%) |
| Stago STA Compact Max | Anti-Factor Xa (IU/mL) | Greiner Citrate | Between-Lot | 0.936 | 0.011 (0.006, 0.036) | 2.2% (1.5%, 4.1%) |
| | | | Between Tube | 0.936 | 0.000 (0.000, 0.000) | 0.0% (0.0%, 0.0%) |
| | | | Within-tube | 0.936 | 0.027 (0.024, 0.03) | 3.7% (3.4%, 4.2%) |
| | | | Total | 0.936 | 0.029 (0.021, 0.044) | 4.3% (3.2%, 6.7%) |
2. Linearity:
Not Applicable.
3. Analytical Specificity/Interference:
Not Applicable.
4. Assay Reportable Range:
Not Applicable.
5. Traceability, Stability, Expected Values (Controls, Calibrators, or Methods):
Shelf-Life Stability
Shelf-life stability studies were conducted by using BD Vacutainer Citrate Tubes at 7 months for $1.8\mathrm{mL}$ BD Citrate Tubes and at 10 months for $2.7\mathrm{mL}$ BD Citrate Tubes, respectively, comparing with BD Vacutainer Citrate Tubes that were near manufacture date (<30 days). The studies were conducted by testing selected routine coagulation parameters. Sixty-nine normal and abnormal samples (on anticoagulants) were included in this study. The results showed that the shelf-life for BD Citrate Tubes is 6 months $(1.8\mathrm{mL})$ and 9 months $(2.7\mathrm{mL})$ when stored at $4 - 25^{\circ}\mathrm{C}$ .
Within-Tube Stability
Within-tube stability was evaluated by using BD Vacutainer Citrate Tubes stored at room temperature for routine coagulation parameters PT/INR, aPTT, Anti-Factor Xa and D-Dimer. Sixty normal and abnormal (on anticoagulants) samples were tested at time zero (t0), 4 hours, 8 hours measuring Anti-Factor Xa, D-Dimer, PT/INR, and aPTT; Sixty-eight normal and abnormal (on anticoagulants) samples were tested at 0, 16, and 24 hours measuring D-Dimer, INR, and PT. The BD Vacutainer Citrate Tubes results showed clinical equivalence of within-tube stability for PT/INR at 24 hours, D-Dimer at 16 hours, and aPTT, Anti-Factor Xa at 8 hours. All analytes tested at every time point were tested at room temperature (15-25 °C).
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Additional Bench Testing on the Candidate Device
Benchtop studies were conducted to assess draw volume, X-value, stopper/shield separation, second stopper pullout, stopper leakage, tube leakage, drop testing, centrifugation, moisture loss, ship testing, and the trace metal content prior to blood draw. The study protocols were reviewed, and performance was considered acceptable.
6. Detection Limit:
Not Applicable.
7. Assay Cut-Off:
Not Applicable.
B Comparison Studies:
1. Method Comparison with Predicate Device:
The method comparison study was conducted at five clinical sites including 219 participants with 18 years of age or older. Fresh venous whole blood was collected into BD Vacutainer Citrate Tubes (BD Citrate) and Greiner Bio-One Vacuette Citrated Tubes (Greiner Citrate). Samples were tested for representative tests including, Prothrombin Time with International Normalized Ratio (PT/INR), Activated Partial Thromboplastin Time (aPTT), D-Dimer, and Anti-Factor Xa. An additional tube (Greiner K2EDTA) for hematocrit was drawn for study eligibility. Participant populations included healthy/normal participants, patients on oral anticoagulant therapy, and patients on unfractionated heparin. The study was tested on two platforms (Diagnostica Stago STA Compact Max and Instrumentation Laboratory ACL TOP). For each analyte on each platform, Deming or Passing-Bablok regression was used to estimate average differences between the evaluation tube (BD Citrate) and comparator (Greiner Citrate) tubes at the medically relevant points for each analyte on each platform. The results are summarized in the following table:
Regression Parameter Estimates: BD Citrate (2.7 mL) vs Greiner Citrate
| Instrument | Analyte | Number of Pairs | Intercept (95% CI) | Slope (95% CI) | Correlation Coefficient |
| --- | --- | --- | --- | --- | --- |
| IL TOP | Anti-Factor Xa | 89 | 0 (0, 0) | 1 (1, 1.03) | 0.992 |
| Stago | Anti-Factor Xa | 82 | 0 (-0.01, 0.02) | 1.02 (1, 1.03) | 0.996 |
| IL TOP | D-Dimer | 78 | -4.93 (-15.48, 5.63) | 1.02 (0.98, 1.05) | 0.999 |
| Stago | D-Dimer | 136 | -0.01 (-0.04, 0.01) | 1.04 (0.99, 1.09) | 0.959 |
| IL TOP | INR | 193 | -0.01 (-0.03, 0.01) | 1.03 (1.01, 1.04) | 0.996 |
| Stago | INR | 210 | -0.03 (-0.05, -0.02) | 1.03 (1.02, 1.04) | 0.997 |
| IL TOP | PT | 193 | -0.23 (-0.42, -0.04) | 1.03 (1.02, 1.05) | 0.997 |
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| Instrument | Analyte | Number of Pairs | Intercept (95% CI) | Slope (95% CI) | Correlation Coefficient |
| --- | --- | --- | --- | --- | --- |
| Stago | PT | 210 | -0.5 (-0.68, -0.34) | 1.03 (1.02, 1.04) | 0.998 |
| IL TOP | aPTT | 193 | 0.69 (-0.2, 1.82) | 0.97 (0.94, 1) | 0.875 |
| Stago | aPTT | 208 | 0.23 (-0.29, 0.77) | 0.97 (0.96, 0.99) | 0.929 |
2. Matrix Comparison:
Not Applicable.
C Clinical Studies:
1. Clinical Sensitivity:
Not Applicable.
2. Clinical Specificity:
Not Applicable.
3. Other Clinical Supportive Data (When 1. and 2. Are Not Applicable):
A. Draw Volume Performance
The draw volume study is conducted to demonstrate functional draw volume performance of BD Vacutainer Citrate tube products to confirm retention of vacuum by comparing the results from the control at time zero (t0) to time points over the claimed shelf-life. A sample size of n=90, evenly divided between each of the three product lots, was collected at each test interval for each sterilization dose and storage condition. The results showed that the BD Vacutainer Citrate Tubes (2.7 mL and 1.8 mL) met the draw volume acceptance criteria for all intervals of accelerated aging to support a shelf life of 6 months (1.8 mL) and 9 months (2.7 mL).
B. Breakage Resistance During Drop and Centrifugation Testing
This study is conducted to demonstrate functional breakage resistance performance during drop testing for plastic tubes and during centrifugation for plastic tubes.
Drop Breakage Resistance: The test article is filled, centrifuged, stored at frozen and refrigerated temperatures, and then dropped from a set height. Samples are subsequently inspected for breakage and leakage. A sample size of n=183, evenly divided between each of the three (3) product lots, was collected at each test interval for each sterilization dose and storage condition.
K240455 - Page 9 of 10
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Centrifugation Breakage Resistance: The test article is filled, centrifuged, and subsequently inspected for breakage and leakage. A sample size of n=300, evenly divided between each of the three (3) product lots, was collected at each test interval for each sterilization dose and storage condition.
The results showed that the BD Vacutainer Citrate Blood Collection tubes (1.8 mL and 2.7 mL) met the drop and centrifugation breakage acceptance criteria to support the current claimed shelf life of 9 months for the BD Vacutainer 2.7 mL Citrate Blood Collection and 6 months for the BD Vacutainer 1.8 mL Citrate Blood Collection tube.
## C. Stopper Pullout
Stopper Pullout testing is to demonstrate functional stopper performance in the event that the stopper is removed from the tube to access the sample and then reinserted. 90 samples were measured for First Stopper Pullout Force, and n=90 samples were measured for Needle Withdrawal Force. Results demonstrate that the force holding the stopper in the tube is greater than the force required to remove the collection needle from the stopper during sample collection. Second Stopper Pullout testing is to demonstrate functional stopper performance in the event that the stopper is removed from the tube to access the sample and then reinserted. The tests confirmed the acceptance criteria was met.
## D. Ship Testing
Ship testing was performed to evaluate packaging efficacy and safety during simulated shipping and handling conditions. Shipping and handling were simulated for temperature fluctuations, vibrations during shipping, and dropping. A sample size of at least n=30 shelf packs, evenly divided between each of the three (3) product lots, was collected. The result demonstrated that all tubes (1.8 mL and 2.7 mL) met the Ship Testing acceptance criteria. Results indicated no occurrence of damage from Ship Testing.
## D. Clinical Cut-Off:
Not Applicable.
## E. Expected Values/Reference Range:
Not Applicable.
## VIII. Proposed Labeling:
The labeling supports the finding of substantial equivalence for this device.
## IX. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.