S TEST REAGENT CARTRIDGE BUN AND S TEST REAGENT CARTRIDGE CRE
K132462 · Hitachi Chemical Diagnostics, Inc. · CDN · Oct 28, 2013 · Clinical Chemistry
Device Facts
Record ID
K132462
Device Name
S TEST REAGENT CARTRIDGE BUN AND S TEST REAGENT CARTRIDGE CRE
Applicant
Hitachi Chemical Diagnostics, Inc.
Product Code
CDN · Clinical Chemistry
Decision Date
Oct 28, 2013
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1770
Device Class
Class 2
Indications for Use
The S TEST Reagent Cartridge Blood Urea Nitrogen (BUN) is intended for the quantitative measurement of BUN in serum, lithium heparin plasma, K3 EDTA plasma, and sodium citrate plasma on the Hitachi Clinical Analyzer E40. The test system is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only. BUN measurements are used in the diagnosis and treatment of certain renal and metabolic diseases. The S TEST reagent cartridge Creatinine (CRE) is intended for the quantitative measurement of creatinine in serum, lithium heparin plasma, K3 EDTA plasma, and sodium citrate plasma on the Hitachi Clinical Analyzer E40. The test system is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only. Creatinine measurements are used in the diagnosis and treatment of renal diseases, in monitoring renal dialysis, and as a calculation basis for measuring other urine analytes.
Device Story
Ready-to-use reagent cartridges for Hitachi Clinical Analyzer E40; input: human serum or plasma samples. BUN assay uses kinetic UV rate method with urease and glutamate dehydrogenase; Creatinine assay uses enzymatic method with creatinase, sarcosine oxidase, and peroxidase to form quinone pigment. 2D barcode on cartridge provides lot-specific calibration data to analyzer; no user calibration required. System measures absorbance changes to determine analyte concentration. Used in clinical labs or physician offices by trained personnel. Output: quantitative concentration values (mg/dL) displayed on analyzer. Results assist clinicians in diagnosing/treating renal and metabolic diseases and monitoring dialysis.
Clinical Evidence
Clinical performance evaluated at three external physician office laboratory (POL) sites. Precision study (n=30 replicates per sample per site) showed total %CVs ranging from 0.6% to 6.8% for BUN and CRE. Method comparison studies (n=75 for BUN, n=45 for CRE) against reference laboratory methods demonstrated high correlation (r=0.999) and linear regression slopes between 0.94 and 0.98, confirming accuracy in the intended use environment.
Technological Characteristics
Ready-to-use reagent cartridges with 2D barcode identification. BUN reagents: urease, glutamate dehydrogenase, NADPH, alpha-ketoglutaric acid. Creatinine reagents: creatinase, sarcosine oxidase, catalase, creatininase, peroxidase, TODB, 4-aminoantipyrine. Kinetic UV rate (BUN) and enzymatic colorimetric (CRE) detection. Analyzed on Hitachi Clinical Analyzer E40. Traceable to ReCCS JCCRM 521 standard. No user calibration required.
Indications for Use
Indicated for quantitative measurement of BUN and creatinine in serum, lithium heparin plasma, K3 EDTA plasma, and sodium citrate plasma. Used for diagnosis/treatment of renal and metabolic diseases and monitoring renal dialysis. Intended for clinical laboratories or physician office laboratories. Prescription use only.
Regulatory Classification
Identification
A urea nitrogen test system is a device intended to measure urea nitrogen (an end-product of nitrogen metabolism) in whole blood, serum, plasma, and urine. Measurements obtained by this device are used in the diagnosis and treatment of certain renal and metabolic diseases.
Predicate Devices
Roche cobas c systems (k100853)
Submission Summary (Full Text)
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
ASSAY ONLY TEMPLATE
A. 510(k) Number:
k132462
B. Purpose for Submission:
New Device
C. Measurand:
Blood Urea Nitrogen
Creatinine
D. Type of Test:
Blood Urea Nitrogen: Quantitative, Kinetic
Creatinine: Quantitative, Enzymatic
E. Applicant:
Hitachi Chemical Diagnostics, Inc
F. Proprietary and Established Names:
Hitachi S TEST Reagent Cartridge Blood Urea Nitrogen (BUN)
Hitachi S TEST Reagent Cartridge Creatinine (CRE)
G. Regulatory Information:
1. Regulation section:
21 CFR 862.1770, Blood urea nitrogen (BUN) test system
21 CFR 862.1225, Creatinine (CRE) test system
2. Classification:
Class II
{1}
3. Product code:
CDN, CGX
4. Panel:
Clinical Chemistry (75)
H. Intended Use:
1. Intended use(s):
See indications for use below.
2. Indication(s) for use:
The S TEST Reagent Cartridge Blood Urea Nitrogen (BUN) is intended for the quantitative measurement of BUN in serum, lithium heparin plasma, K3 EDTA plasma, and sodium citrate plasma on the Hitachi Clinical Analyzer E40. The test system is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only. BUN measurements are used in the diagnosis and treatment of certain renal and metabolic diseases.
The S TEST reagent cartridge Creatinine (CRE) is intended for the quantitative measurement of creatinine in serum, lithium heparin plasma, K3 EDTA plasma, and sodium citrate plasma on the Hitachi Clinical Analyzer E40. The test system is intended for use in clinical laboratories or physician office laboratories. For in vitro diagnostic use only. Creatinine measurements are used in the diagnosis and treatment of renal diseases, in monitoring renal dialysis, and as a calculation basis for measuring other urine analytes.
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
Hitachi Clinical Analyzer E40 (k111753)
I. Device Description:
The S TEST Reagent Cartridge BUN is provided ready-to-use. The 2D code label on the front of each cartridge automatically identifies the reagent to the system. It consists of the following reagents:
BUN Reagent (1):
Glutamate dehydrogenase (E.coli)
Nicotinamide adenine dinucleotide phosphate (reduced form)
$\alpha$-Ketoglutaric acid
2-Amino-2-hydroxymethyl-1,3-propanediol Buffer (pH 9.1)
{2}
BUN Reagent (2):
Urease (Jack bean)
$\alpha$-Ketoglutaric acid
2-Amino-2-hydroxymethyl-1,3-propanediol Buffer (pH 7.3)
The S TEST Reagent Cartridge CRE is provided ready-to-use. The 2D code label on the front of each cartridge automatically identifies the reagent to the system. It consists of the following reagents:
CRE Reagent (1):
Sarcosine oxidase (E. coli)
N,N-Bis(4-sulfobutyl)-3-methylaniline disodium salt
Creatinase (E. coli)
Catalase (Micrococcus lysodeikticus)
Good's buffer (pH 7.8)
CRE Reagent (2):
Creatininase (E. coli)
4-Aminoantipyrine
Peroxidase (Horseradish)
Good's buffer (pH 8.2)
## J. Substantial Equivalence Information:
1. Predicate device name(s):
Roche cobas c systems
2. Predicate 510(k) number(s):
k100853
3. Comparison with predicate:
| Similarities and Differences Blood Urea Nitrogen (BUN) | | |
| --- | --- | --- |
| Item | Candidate Device | Predicate Device |
| Intended Use | For in vitro quantitative measurement of BUN | Same |
| Testing Environment | Physician office or clinical lab | Clinical lab |
| Test Principle | Kinetic test (UV rate) with urease and glutamate dehydrogenase | Kinetic test with urease and glutamate dehydrogenase |
| Specimen Type | Human serum or plasma | Human serum, plasma, or urine |
| Reportable Range | 1.5 to 80 mg/dL | 1.4 to 112 mg/dL |
| Detection Wavelength | 546/340 nm | 700/340 nm |
| Detection Limit | 0.8 mg/dL | 1.4 mg/dL |
| Linearity | 0.9 to 110 mg/dL | 1.4 to 112 mg/dL |
| Instrument platform | Hitachi Clinical Analyzer E40 | Roche cobas c systems |
{3}
| Similarities and Differences Creatinine (CRE) | | |
| --- | --- | --- |
| Item | Candidate Device | Predicate Device |
| Intended Use | For in vitro quantitative measurement of CRE | Same |
| Testing Environment | Physician office or clinical lab | Clinical lab- cobas |
| Test Principle | Enzymatic with creatinase and formation of quinone pigment | Kinetic colorimetric assay based on Jaffe method |
| Specimen Type | Human serum or plasma | Human serum, plasma, or urine |
| Reportable Range | 0.1 to 25.0 mg/dL | 0.2 to 24.9 mg/dL |
| Detection Wavelength | 546/700 nm | 570/505 nm |
| Detection Limit | 0.1 mg/dL | 0.2 mg/dL |
| Linearity | 0.1 to 31.3 mg/dL | 0.2 to 24.9 mg/dL |
| Instrument platform | Hitachi Clinical Analyzer E40 | Roche cobas c systems |
# K. Standard/Guidance Document Referenced (if applicable):
CLSI EP5-A2: Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline-Second Edition
CLSI-EP6-A: Evaluation of Linearity of Quantitative Measurement Procedures, A statistical Approach; Approved Guideline
CLSI-EP7-A2: Interference Testing in Clinical Chemistry; Approved Guideline
CLSI EP17-A: Protocols for Determination of Limits of Detection and Limits of Quantitation; Approved Guideline
# L. Test Principle:
Blood Urea Nitrogen: Urea is degraded by urease into ammonia. When glutamate dehydrogenase (GLD) reacts with ammonia and alfa-ketoglutaric acid to produce glutamic acid, NADPH is converted into NADP with a decrease of absorbance at $340~\mathrm{nm}$ . The concentration of urea nitrogen can be determined by measuring the amount of change in absorbance.
Creatinine: As the first reaction, creatine in samples is decomposed into water and oxygen by the action of creatinase, sarcosine oxidase, and catalase. Subsequently, as the second reaction, creatinine in samples is converted into creatine by the action of creatininase, and then sarcosine is formed by creatinase. After that, the quinone pigment is formed by oxidation condensation between N,N-Bis (4-sulfobutyl)-3-methylaniline disodium salt (TODB) and 4-aminoantipyrine in the presence of peroxidase (POD) and hydrogen peroxide is formed by sarcosine oxidase. The concentration of creatinine can be determined by measuring the absorbance of the resulting quinone pigment (purple-red).
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M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Precision studies for the S TEST Reagent Cartridge BUN were performed following CLSI EP5-A2 with three levels of analytes (low, middle and high) and one instrument. Serum samples were tested in duplicate, twice a day, for 20 days for a total of 80 results per level. The samples were neat serum samples. Results for BUN precision are summarized below:
| Analyte | Sample | Mean (mg/dL) | Within Run | | Total | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | SD | %CV | SD | %CV |
| BUN | Low | 7.24 | 0.22 | 3.0 | 0.36 | 5.0 |
| | Middle | 14.07 | 0.23 | 1.6 | 0.38 | 2.7 |
| | High | 49.05 | 0.58 | 1.2 | 1.13 | 2.3 |
Precision studies for the S TEST Reagent Cartridge CRE were performed following CLSI EP5-A2 with four levels of analytes (low, middle, high and very high) and one instrument. Serum samples were tested in duplicate, twice a day, for 20 days for a total of 80 results per level. The samples were archived (stored frozen) patient serum samples. Results for creatinine precision are summarized below:
| Analyte | Sample | Mean (mg/dL) | Within Run | | Total | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | SD | %CV | SD | %CV |
| CRE | Low | 0.59 | 0.04 | 6.8 | 0.05 | 8.5 |
| | Middle | 1.75 | 0.04 | 2.3 | 1.75 | 3.4 |
| | High | 6.55 | 0.08 | 1.2 | 0.19 | 2.9 |
| | Very High | 20.34 | 0.18 | 0.9 | 0.29 | 1.4 |
Precision was evaluated at three POL sites. BUN was evaluated using 6 lots of reagent and Creatinine was evaluated using 3 lots. Each site received three blinded serum samples (A, B, C) that were chosen to represent low, intermediate, and high concentrations of the analytes. Each sample was assayed six times per day for 5 days resulting in 30 results per level. The BUN samples were a combination of neat and spiked specimens. The Creatinine samples were commercial controls. The results are listed below:
Physician Office Precision: BUN
| Sample | Site | Mean (mg/dL) | Within run Precision | | Total Precision | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | SD (mg/dL) | %CV | SD (mg/dL) | %CV |
| A | 1 | 12.04 | 0.13 | 1.1 | 0.22 | 1.8 |
| | 2 | 10.92 | 0.26 | 2.3 | 0.39 | 3.6 |
| | 3 | 11.68 | 0.24 | 2.0 | 0.23 | 2.0 |
| | 1 | 46.94 | 0.37 | 0.8 | 0.69 | 1.5 |
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| B | 2 | 45.40 | 0.48 | 1.1 | 0.65 | 1.4 |
| --- | --- | --- | --- | --- | --- | --- |
| | 3 | 46.40 | 0.48 | 1.0 | 0.66 | 1.4 |
| C | 1 | 75.68 | 0.71 | 0.9 | 0.69 | 0.9 |
| | 2 | 74.29 | 0.60 | 0.8 | 0.85 | 1.2 |
| | 3 | 75.23 | 0.41 | 0.5 | 0.47 | 0.6 |
Physician Office Precision: Creatinine
| Sample | Site | Mean (mg/dL) | Within run Precision | | Total Precision | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | SD (mg/dL) | %CV | SD (mg/dL) | %CV |
| A | 1 | 0.58 | 0.03 | 5.0 | 0.04 | 6.8 |
| | 2 | 0.60 | 0.00 | 0.0 | 0.00 | 0.0 |
| | 3 | 0.51 | 0.03 | 6.7 | 0.03 | 6.7 |
| B | 1 | 1.80 | 0.03 | 1.8 | 0.07 | 3.8 |
| | 2 | 1.80 | 0.03 | 1.8 | 0.07 | 3.8 |
| | 3 | 1.61 | 0.03 | 2.0 | 0.07 | 4.4 |
| C | 1 | 6.52 | 0.05 | 0.7 | 0.13 | 2.1 |
| | 2 | 6.38 | 0.05 | 0.8 | 0.08 | 1.2 |
| | 3 | 5.95 | 0.07 | 1.2 | 0.31 | 5.2 |
# b. Linearity/assay reportable range:
The claimed measuring range for BUN is $1.5 - 80\mathrm{mg / dL}$ . The linearity of the BUN assay was assessed following CLSI EP6-A with commercially available linearity sets which include 7 samples (0.9 to $110.0\mathrm{mg / dL}$ ). All samples were tested in duplicate on one Hitachi Clinical Analyzer E40. Recoveries were within $\pm 10\%$ or $2.5\mathrm{mg / dL}$ . The summary of the linear regression analysis of the data is below:
$$
y = 0. 9 5 4 8 x + 0. 6 1 6 8; R ^ {2} = 0. 9 9 7 7
$$
The BUN assay data demonstrates linearity between $0.9\mathrm{mg / dL}$ and $110\mathrm{mg / dL}$ and support the sponsor's claimed measuring range of 1.5 to $80\mathrm{mg / dL}$ .
The claimed measuring range for Creatinine is $0.1 - 25\mathrm{mg / dL}$ . The linearity of the creatinine assay was assessed following CLSI EP6-A with commercially available linearity sets which include 11 samples (0.1 to $31.3\mathrm{mg / dL}$ ). All samples were tested in duplicate on one Hitachi Clinical Analyzer E40. Recoveries were within $\pm 10\%$ or $0.2\mathrm{mg / dL}$ . The summary of the linear regression analysis of the data is below:
$$
y = 1. 0 2 0 1 x + 0. 0 4 5 7; R ^ {2} = 0. 9 9 9 1
$$
The creatinine assay data demonstrates linearity between $0.1\mathrm{mg / dL}$ and $31.3\mathrm{mg / dL}$ and support the sponsor's claimed measuring range of 0.1 to $25\mathrm{mg / dL}$ .
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c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability:
Each lot of the S TEST Reagent Cartridge Blood Urea Nitrogen (BUN) is calibrated by the manufacturer prior to shipment using material traceable to Reference Material Institute for Clinical Chemistry Standards (ReCCS) Standard Serum JCCRM 521. The 2D code printed on each cartridge provides the analyzer with lot-specific calibration data. BUN concentration is directly determined by multiplying the change in absorbance of the unknown samples by the calibrator factor on the barcode. No calibration is needed by the user.
Each lot of S TEST Reagent Cartridge Creatinine (CRE) is calibrated by the manufacturer prior to shipment using material traceable to ReCCS standard serum JCCRM 521; this standard is traceable to IDMS. The 2D code printed on each cartridge provides the analyzer with lot-specific calibration data. CRE concentration is directly determined by multiplying the change in absorbance of the unknown samples by the calibrator factor on the barcode. No calibration is needed by the user.
Commercially available controls are required and users should follow Federal, state, and local requirements.
Stability:
Real-time shelf-life studies for the BUN reagent cartridge were performed. A two-level control set was tested in replicates of five with three lots of cartridges across six analyzers. The protocols for stability and acceptance criteria were reviewed and are acceptable and support a stability claim of 12 months when stored at 2-8°C.
Real-time shelf-life studies for the Creatinine reagent cartridge were performed. A two-level control set was tested in replicates of five with three lots of cartridges across six analyzers. The protocols for stability and acceptance criteria were reviewed and are acceptable and support a stability claim of 18 months when stored at 2-8°C.
d. Detection limit:
The limit of blank (LoB) and limit of detection (LoD) studies for the S TEST Reagent Cartridge BUN and Reagent Cartridge CRE were performed in accordance to CLSI EP17-A. The analytical sensitivity was defined as the limit of detection, and the LoD was calculated from the LoB. LoB was determined using a blank sample assayed 20 times per day for three days for a total of 60 replicates. The LoB was estimated as the mean of the 57th and 58th highest values for the true blanks. LoD was determined using five low samples assayed four times per day for three days, for a total of 60 replicate results. The LoD was calculated as the LoB + 1.645 x SD of the low samples.
LoQ for the S TEST Reagent Cartridge BUN and CRE was assessed by preparing several low samples to cover the lower limit of the analyte range. Each sample was assayed in replicates of six. The mean, standard deviation and percent coefficient of variation were calculated for the six replicates at each sample and a plot (expected
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values (X) against $\% \mathrm{CV}$ (Y)) was generated. LoQ was defined at the value of sample where the interassay precision is $< 20\%$ CV.
The LoQ study supported performance with low level BUN specimens ( $\sim 4\mathrm{mg / dL}$ ) but the low end of the reportable range was defined by a functional sensitivity study. Six samples between $0.5\mathrm{mg / dL}$ and $10\mathrm{mg / dL}$ were tested. Each sample was assayed in replicates of six. The mean, standard deviation and percent $\% \mathrm{CVs}$ were calculated for the six replicates. A plot of expected (X) against actual (Y) concentrations and a plot of expected values (X) against $\% \mathrm{CV}$ (Y) was generated. The data support an LoQ of $0.8\mathrm{mg / dL}$ and the low end of the measuring range is claimed to be $1.5\mathrm{mg / dL}$ .
The LoQ study supported performance with low level Creatinine specimens ( $\sim 0.3$ mg/dL) but the low end of the reportable range was defined by a functional sensitivity study. Six samples between $0.05\mathrm{mg / dL}$ and $0.5\mathrm{mg / dL}$ . Each sample was assayed in replicates of six. The mean, standard deviation and percent $\% \mathrm{CVs}$ were calculated for the six replicates. A plot of expected (X) against actual (Y) concentrations and a plot of expected values (X) against $\% \mathrm{CV}$ (Y) was generated. The data support an LoQ of $0.1\mathrm{mg / dL}$ and the low end of the measuring range is claimed to be $0.1\mathrm{mg / dL}$ .
The LoB, LoD and LoQ for Blood Urea Nitrogen and Creatinine are tabulated below:
| Analyte | LoB (g/dL) | LoD (g/dL) | LoQ (g/dL) |
| --- | --- | --- | --- |
| Blood Urea Nitrogen (BUN) | 0.52 | 0.8 | 0.8 |
| Creatinine (CRE) | 0.03 | 0.06 | 0.1 |
The sponsor's claimed measuring range of BUN is 1.5 to $80\mathrm{mg / dL}$ and Creatinine is 0.1 to $25\mathrm{mg / dL}$ .
# e. Analytical specificity:
An interference study was performed in accordance with CLSI EP7-A. Two levels of commercial control sera containing approximately $12\mathrm{mg / dL}$ and $30\mathrm{mg / dL}$ BUN and $1.5\mathrm{mg / dL}$ and $5.7\mathrm{mg / dL}$ creatinine were spiked to six levels with each interferent (ascorbic acid, unconjugated bilirubin, hemoglobin and lipemia) and all seven samples were tested in replicates of three by the Hitachi Clinical Analyzer E40. The spiked sample results mean was compared to its neat control mean result and recoveries were calculated. The sponsor defines non-interference as the mean results from the testing of the spiked samples within $10\%$ of the mean of the neat samples. Recoveries were between $90\%$ and $110\%$ of the neat value. The highest level tested with non significant interference is listed below.
| Substance | Blood Urea Nitrogen (BUN) | Creatinine (CRE) |
| --- | --- | --- |
| | Highest level tested with no interference | Highest level tested with no interference |
| Ascorbic acid | 50 mg/dL | 25 mg/dL |
| Bilirubin (unconjugated) | 50 mg/dL | 25 mg/dL |
| Hemoglobin | 1000 mg/dL | 250 mg/dL |
| Lipemia (Intralipid) | 1000 mg/dL | 1000 mg/dL |
The sponsor states in the labeling that hemolyzed specimens should not be used for creatinine.
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f. Assay cut-off:
Not applicable
## 2. Comparison studies:
a. Method comparison with predicate device:
A total of 162 (for BUN) and 100 (for creatinine) serum specimens, spanning the dynamic range were assayed in singleton using the Hitachi system and the predicate device. The BUN study set included four diluted and four spiked samples and the creatinine study set included four spiked samples to ensure the dynamic range was fully evaluated. Results obtained were analyzed by Deming regression and summarized in the following table:
| Analyte | Comparative Methods | N | Range of Samples mg/dL | Deming Regression | | r |
| --- | --- | --- | --- | --- | --- | --- |
| | | | | Slope (95% CI) | y-Intercept (95% CI) | |
| Blood Urea Nitrogen (BUN) | Hitachi vs. Roche | 162 | 2.4 – 78.5 | 0.96 (0.95 to 0.97) | -0.3 (-0.64 to 0.10) | 0.997 |
| Creatinine (CRE) | Hitachi vs. Roche | 100 | 0.5 – 24.7 | 0.99 (0.98 to 1.00) | -0.1 (-0.18 to -0.07) | 0.999 |
## Physician office accuracy (Method Comparison): BUN
Method comparison was performed at three POL sites on the Hitachi E40 Analyzer vs. the predicate device at the central laboratory. Each site and the central laboratory tested approximately 75 blinded neat serum samples (ranging from 5.7 to 73.6 mg/dL) that were chosen to represent a full range of BUN concentrations. The data was analyzed by Deming regression and is summarized below.
| Site | N | Range of Samples mg/dL | Deming Regression | | r |
| --- | --- | --- | --- | --- | --- |
| | | | Slope (95% CI) | y-Intercept (95% CI) | |
| 1 | 75 | 6.0 to 73.6 | 0.98 (0.96 to 0.99) | -0.23 (-0.59 to 0.13) | 0.999 |
| 2 | 74 | 5.7 to 69.3 | 0.94 (0.93 to 0.95) | -0.24 (-0.50 to 0.01) | 0.999 |
| 3 | 73 | 5.7 to 70.8 | 0.95 (0.93 to 0.96) | -0.04 (-0.41 to 0.32) | 0.999 |
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Physician office accuracy (Method Comparison): Creatinine
Method comparison was performed at three POL sites on the Hitachi E40 Analyzer vs. the predicate device at the central laboratory. Each site and the central laboratory tested approximately 45 blinded serum samples (ranging from 0.6 to $24.1\mathrm{mg / dL}$ , a combination of neat serum specimens and 4 spiked samples) that were chosen to represent a full range of creatinine concentrations. The data was analyzed by Deming regression and is summarized below.
| Site | N | Range of Samples mg/dL | Deming Regression | | r |
| --- | --- | --- | --- | --- | --- |
| | | | Slope (95% CI) | y-Intercept (95% CI) | |
| 1 | 45 | 0.6 to 23.5 | 0.97 (0.96 to 0.98) | -0.06 (-0.13 to 0.02) | 0.999 |
| 2 | 44 | 0.6 to 24.1 | 0.98 (0.96 to 0.99) | -0.09 (-0.19 to 0.02) | 0.999 |
| 3 | 47 | 0.6 to 22.8 | 0.96 (0.95 to 0.96) | -0.04 (-0.10 to 0.02) | 0.999 |
# b. Matrix comparison:
Lithium heparinized plasma, EDTA plasma and sodium citrate plasma was analyzed as a secondary sample matrix to serum. Thirty-six (36 matched clinical specimens (serum and each plasma type) with BUN concentrations spanning the dynamic range (including 2 diluted and 4 spiked samples) were assayed in singleton and in a blinded fashion on one analyzer and S TEST Reagent Cartridge BUN. Thirty-nine (39) matched clinical specimens (serum and each plasma type) with creatinine concentrations spanning the dynamic range (including 6 diluted samples) were assayed in singleton and in a blinded fashion on one analyzer and S TEST Reagent Cartridge CRE. The results were analyzed by least-squares linear regression and are summarized below:
| Analyte | Comparative Matrices | Serum Range (mg/dL) | N | Least-Squares Linear Regression | | r |
| --- | --- | --- | --- | --- | --- | --- |
| | | | | Slope (95% CI) | y-Intercept (95% CI) | |
| Blood Urea Nitrogen (BUN) | Serum (x) vs. Heparinized Plasma (y) | 2.4–75.3 | 36 | 1.01 (1.00 to 1.03) | -0.56 (-0.84 to -0.28) | 0.999 |
| | Serum (x) vs. EDTA Plasma (y) | | 36 | 1.01 (1.00 to 1.03) | -0.61 (-0.94 to 0.27) | 0.999 |
| | Serum (x) vs. Na Citrate Plasma (y) | | 36 | 0.99 (0.97 to 1.01) | -0.98 (-1.42 to -0.54) | 0.998 |
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11
| Creatinine (CRE) | Serum (x) vs. Heparinized Plasma (y) | 0.1–24.5 | 39 | 0.99
(0.98 to 1.00) | -0.02
(-0.08 to 0.05) | 0.999 |
| --- | --- | --- | --- | --- | --- | --- |
| | Serum (x) vs. EDTA Plasma (y) | | 39 | 1.01
(1.00 to 1.02) | -0.06
(-0.15 to 0.03) | 0.999 |
| | Serum (x) vs. Na Citrate Plasma (y) | | 39 | 1.00
(0.99 to 1.02) | -0.05
(-0.14 to 0.05) | 0.999 |
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:
The expected values are stated within the labeling based on the literature. The manufacturer recommends each laboratory determine the expected values for its particular population.
Blood Urea Nitrogen Reference range: 6 – 20 mg/dL¹
Creatinine Reference range: Males: 0.62 – 1.10 mg/dL; Females: 0.45 – 0.75 mg/dL¹
1. Tietz, Fundamentals of Clinical Chemistry, 6th Edition, WB Saunders Company, 2008.
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.