← Product Code [GGC](/submissions/HE/subpart-f%E2%80%94automated-and-semi-automated-hematology-devices/GGC) · K100103

# SPECIALTY ASSAYED CONTROL-2 (K100103)

_Helena Laboratories · GGC · Dec 15, 2010 · Hematology · SESE_

**Canonical URL:** https://fda.innolitics.com/submissions/HE/subpart-f%E2%80%94automated-and-semi-automated-hematology-devices/GGC/K100103

## Device Facts

- **Applicant:** Helena Laboratories
- **Product Code:** [GGC](/submissions/HE/subpart-f%E2%80%94automated-and-semi-automated-hematology-devices/GGC.md)
- **Decision Date:** Dec 15, 2010
- **Decision:** SESE
- **Submission Type:** Traditional
- **Regulation:** 21 CFR 864.5425
- **Device Class:** Class 2
- **Review Panel:** Hematology

## Indications for Use

The S.A.C.-2 is an assayed abnormal control plasma intended for use in clinical laboratories when testing human plasma for the following coagulation deficiencies: Prothrombin time (PT), activated Partial Thromboplastin Time (aPTT), Factor II, V, VII, VIII, IX, X, XI, XII deficiencies, Fibrinogen, von Willebrand Factor antigen, Ristocetin cofactor, Protein C activity, and Protein S activity (total and free). The control material can be used with manual assays, electro-mechanical, or photo-optical clot detection methods.

## Device Story

S.A.C.-2 is a lyophilized, buffered abnormal control plasma derived from human donors; used in clinical laboratories to verify performance of coagulation assays. Input: human plasma samples tested via manual, electro-mechanical, or photo-optical coagulation instruments. Device serves as a quality control material to ensure accuracy of clinical testing for coagulation deficiencies (PT, aPTT, factors, fibrinogen, vWF, Protein C/S). Healthcare providers use the control results to validate assay performance before reporting patient results. Benefits include ensuring reliability of diagnostic testing for coagulation disorders.

## Clinical Evidence

Bench testing only. Precision/reproducibility evaluated per CLSI EP5-A2 using three operators, multiple reagent systems, and analyzers; all parameters achieved CV ≤ 15%. Stability testing confirmed analytes remain within assigned ranges and within 20% of 0-hour values after 4.5 hours at 2-8°C.

## Technological Characteristics

Lyophilized, buffered human plasma collected in 4% sodium citrate. Reconstituted control is stable for 4 hours at 2-8°C. Compatible with manual, mechanical, and photo-optical coagulation instrumentation. No electronic or software components.

## Regulatory Identification

A multipurpose system for in vitro coagulation studies is a device consisting of one automated or semiautomated instrument and its associated reagents and controls. The system is used to perform a series of coagulation studies and coagulation factor assays.

## Special Controls

*Classification.* Class II (special controls). A control intended for use with a multipurpose system for in vitro coagulation studies is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 864.9.

## Predicate Devices

- Specialty Assayed Control-2 (S.A.C.-2) (k941872)

## Submission Summary (Full Text)

> This content was OCRed from public FDA records by [Innolitics](https://innolitics.com). If you use, quote, summarize, crawl, or train on this content, cite Innolitics at https://innolitics.com.
>
> Innolitics is a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices, including [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/).

{0}

1

# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY

A. 510(k) Number:
k100103

B. Purpose for Submission:
Change of manufacturing location for a currently marketed device

C. Measurand:
Abnormal control for Prothrombin Time (PT), activated Partial Thromboplastin Time (aPTT), Factors II, V, VII, X, VIII, IX, XI, XII, Fibrinogen, von Willebrand Factor Antigen, Ristocetin Cofactor, Protein C, Protein S (total and free)

D. Type of Test:
Hemostasis quality control

E. Applicant:
Helena Laboratories Corporation

F. Proprietary and Established Names:
Specialty Assayed Control-2 (S.A.C.-2)

G. Regulatory Information:
1. Regulation section:
21 CFR 864.5425, Multipurpose system for in vitro coagulation studies
2. Classification:
II
3. Product code:
GGC, Control, plasma, abnormal
4. Panel:
81 Hematology

H. Intended Use:
1. Intended use(s):
The S.A.C.-2 is an assayed abnormal control plasma intended for use in clinical laboratories when testing human plasma for the following coagulation deficiencies: Prothrombin time (PT), activated Partial Thromboplastin Time (aPTT), Factor II, V, VII, VIII, IX, X, XI, XII deficiencies, Fibrinogen, von Willebrand Factor antigen, Ristocetin cofactor, Protein C activity, and Protein S activity (total and free). The control material can be used with manual assays, electro-mechanical, or photo-optical clot detection methods.
2. Indication(s) for use:
Same as Intended Use
3. Special conditions for use statement(s):
Prescription use only
4. Special instrument requirements:
Mechanical and photo-optical instrumentation

I. Device Description:
The S.A.C.-2 is an assayed abnormal control plasma from normal human donors intended for use in clinical laboratories when testing human plasma for the following coagulation deficiencies: Prothrombin time (PT), activated Partial Thromboplastin

{1}

Time (aPTT), Factor II, V, VII, VIII, IX, X, XI, XII deficiencies, Fibrinogen, von Willebrand Factor antigen, Ristocetin cofactor, Protein C activity, and Protein S activity (total and free).

The control is prepared from a normal pool of human plasma collected in  $4\%$  sodium citrate. The pool has 0.03M Hepes buffer and is lyophilized to ensure stability of all plasma coagulation factors. All factors are adjusted to be in the abnormal range.

# J. Substantial Equivalence Information:

1. Predicate device name(s): Specialty Assayed Control-2 (S.A.C.-2)
2. Predicate 510(k) number(s): k941872
3. Comparison with predicate:

|  Similarities  |   |   |   |
| --- | --- | --- | --- |
|  Item |   | Device | Predicate  |
|  Intended Use | The S.A.C.-2 is an assayed abnormal control plasma intended for use in clinical laboratories when testing human plasma for the following coagulation deficiencies: Prothrombin time (PT), activated Partial Thromboplastin Time (aPTT), Factor II, V, VII, VIII, IX, X, XI, XII deficiencies, Fibrinogen, von Willebrand Factor antigen, Ristocetin cofactor, Protein C activity, and Protein S activity (total and free). The control material can be used with manual assays, electro-mechanical, or photo-optical clot detection methods. |   | The S.A.C.-2 is an assayed abnormal control plasma which may be used in many facets of testing in the coagulation laboratory  |
|  Analytes | Prothrombin time (PT), activated Partial Thromboplastin time (aPTT), Factor II, V, VII, VIII, IX, X, XI, XII deficiencies, fibrinogen, von Willebrand Factor antigen, Ristocetin cofactor, Protein C activity, and Protein S activity (total and free). |   | Same  |
|  Reagent | Lyophilized, buffered human plasma collected in 4% sodium citrate |   | Same  |
|  Stability (reconstituted) | 4 hours at 2 - 8°C |   | Same  |
|  Packaging | 10 x 1 mL vials |   | Same  |
|  Instrumentation | Mechanical and photo-optical instruments |   | Same  |
|  Differences  |   |   |
| --- | --- | --- |
|  Item | Device | Predicate  |
|  Analytes (Kinetic) | Analytes no longer available in control F VIII, X, plasminogen, antithrombin III, protein C, a2-antiplasmin | Included in control F VIII, X, plasminogen, antithrombin III, protein C, a2-antiplasmin  |
|  Analytes (Immunological RID) | Analytes no longer available in control Plasminogen, antithrombin III | Included in control Plasminogen, antithrombin III  |

{2}

3

K. Standard/Guidance Document Referenced. (if applicable):
CLSI, EP5-A2-Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guidelines-Second Edition

L. Test Principle:
The control plasma may be used when performing tests on manual assays, mechanical or photo- optical coagulation instruments in conjunction with suitable commercial reagents.

M. Performance Characteristics (if/when applicable):

1. Analytical performance:
a. Precision/Reproducibility:
Precision studies were performed at Helena Laboratories with three operators, using various reagent systems and analyzers. Duplicate determinations of all analytes were made on five vials from four lots of control, as described in CLSI, EP5-A2. All parameters fell within acceptance criteria (CV of ≤ 15%).
b. Linearity/assay reportable range:
Not applicable
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Assays are acceptable if the mean values are as follows:

|  Assay | Mean Value  |
| --- | --- |
|  Prothrombin Time (PT) | ≥14.0 seconds  |
|  Activated Partial Thromboplastin Time (aPTT) | >35.0 seconds  |
|  Factor Assays | ≤50 %  |
|  Fibrinogen | ≤ 140 mg/dL  |
|  Rocket von Willebrand Factor Antigen | ≤50%  |
|  Rocket Protein C | ≤50%  |
|  Rocket Protein S | ≤50%  |
|  Rocket Protein S (Free) | ≤50%  |
|  Ristocetin Cofactor | ≤50%  |
|  ELISA Protein C | ≤50%  |
|  ELISA Protein S, S (Free), Monoclonal Free S | ≤50%  |
|  ELISA von Willebrand Factor Antigen | ≤50%  |

Stability studies were performed on each analyte using duplicate determinations on three vials from each of three lots of control. Each analyte was tested at 0 hours and at 4.5 hours with storage at 2 to 8°C. Acceptance criteria for the studies was defined as falling within assigned range and for the 4.5 hour data point to be within 20% of the 0 hour data point. All parameters fell within acceptable performance.

d. Detection limit
Not applicable

e. Analytical specificity:
Not applicable

f. Assay cut-off:
Not applicable

{3}

N. Proposed Labeling:
The labeling is sufficient and 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.

4

---

**Source:** [https://fda.innolitics.com/submissions/HE/subpart-f%E2%80%94automated-and-semi-automated-hematology-devices/GGC/K100103](https://fda.innolitics.com/submissions/HE/subpart-f%E2%80%94automated-and-semi-automated-hematology-devices/GGC/K100103)

**Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices. If you're preparing [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/), [get in touch](https://innolitics.com/contact).

**Cite:** Innolitics at https://innolitics.com
