ACCUWELL 17-ALPHA-HYDROXYPROESTERONE ENZYME IMMUNOASSAY WITH MODELS 6015XX-ECAH
Applicant
Neo-Genesis
Product Code
JLX · Clinical Chemistry
Decision Date
Mar 13, 2007
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 862.1395
Device Class
Class 1
Attributes
Real-World Evidence, Pediatric
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K060452 · Mar 13, 2007
ACCUWELL 17-ALPHA-HYDROXYPROESTERONE ENZYME IMMUNOASSAY WITH MODELS 6015XX-ECAH
Neo-Genesis
Public health laboratory neonatal screening registry/database; Retrospective clinical neonatal dried blood spot samples
Retrospective analysis of routine clinical screening samples was used to compare the device performance against a predicate device and to establish expected values/reference ranges for different neonatal populations.
Retrospective study; Neonatal screening; Method comparison; Reference range establishment
Neonates (various birth weights and ages at collection); Sample Size: Multiple cohorts (e.g., n=133, n=197, n=30 per subgroup); Number of Sites: 1 (U.S. department of public health laboratory)
Wallac Oy AutoDelfia Neonatal 17α-Hydroxyprogesterone Time-resolved fluoroimmunoassay
Correlation and percentile agreement with predicate device
Reference Range Study; Retrospective analysis of stored clinical samples; Follow-up/Duration: Samples stored for up to 7 months prior to testing
Infants (stratified by birth weight and age at collection); Sample Size: 444 (≥2500g, 1-3 days); 91 (<2500g, 1-3 days); 391 (≥2500g, ≥4 days)
Not applicable for this study
95th, 97.5th, and 99th percentile cut-off values
Indications for Use
The Accuwell 17α-Hydroxyprogesterone EIA Kit is designed for the quantitative measurement of 17α-Hydroxyprogesterone (17-OHP) concentrations in neonatal blood samples that have been collected onto Whatman [previously known as Schleicher and Schuell (S&S®) 903] specimen collection paper. The results are used to screen newborns for classical congenital adrenal hyperplasia (CAH).
Device Story
Accuwell 17α-Hydroxyprogesterone EIA Kit; quantitative enzyme immunoassay for 17-OHP in neonatal dried blood spots. Input: 1/8 inch disc from Whatman 903 collection paper. Principle: competitive enzyme immunoassay; 17-OHP in sample competes with HRP-labeled 17-OHP for rabbit anti-17-OHP binding sites on microplate. Output: colorimetric absorbance at 650 nm, inversely proportional to 17-OHP concentration. Used in clinical laboratories; processed via direct incubation or saline elution. Results used by clinicians to identify newborns requiring follow-up for CAH screening.
Clinical Evidence
Retrospective method comparison study using blinded neonatal dried blood spots (n=133 to 197 per population subset). Compared Accuwell EIA (three procedures: ON Direct, ON Eluate, 3Hr Eluate) against predicate. Correlation coefficients (R) ranged from 0.8421 to 0.9785. Analytical performance included precision (CVs 7.7-14.1%), linearity (3.8-250 ng/mL), and analytical sensitivity (1.5-2.3 ng/mL). No clinical sensitivity/specificity for CAH diagnosis reported; intended for screening.
Indicated for screening newborns for classical congenital adrenal hyperplasia (CAH) using neonatal blood samples collected on Whatman 903 filter paper. Prescription use only.
Regulatory Classification
Identification
A 17-hydroxyprogesterone test system is a device intended to measure 17-hydroxyprogesterone (a steroid) in plasma and serum. Measurements of 17-hydroxyprogesterone are used in the diagnosis and treatment of various disorders of the adrenal glands or the ovaries.
Predicate Devices
Wallac Oy AutoDelfia Neonatal 17α-Hydroxyprogesterone Time-resolved fluoroimmunoassay (k042425)
Submission Summary (Full Text)
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1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k060452
B. Purpose for Submission:
New Device
C. Measurand:
17-alpha-Hydroxyprogesterone
D. Type of Test:
Quantitative, Enzyme Immunoassay
E. Applicant:
Neo-Genesis
F. Proprietary and Established Names:
Accuwell 17-Alpha-Hyderoxyprogesterone Enzyme Immunoassay with Models 6015XX-ECAH
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JLX- Radioimmunoassay, 17-Hydroxyprogesterone | Class I, meets the limitation of exemptions, 21 CFR 862.9 (c), (2) | 21 CFR 862.1395, 17-Hydroxy-progesterone test system. 21 CFR 862.9 (c), (2) | 75 Clinical chemistry (CH) |
H. Intended Use:
1. Intended use(s):
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See indications for use below.
2. Indication(s) for use:
The Accuwell 17α-Hydroxyprogesterone EIA Kit is designed for the quantitative measurement of 17α-Hydroxyprogesterone (17-OHP) concentrations in neonatal blood samples that have been collected onto Whatman 903® specimen collection paper. The results are used to screen newborns for classical congenital adrenal hyperplasia (CAH).
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
Microplate reader capable of reading a wavelength of 650 nm
I. Device Description:
The Accuwell 17α-Hydroxyprogesterone EIA Kit contains the following:
- Microplates coated with rabbit anti-17-OHP.
- Enzyme conjugate which contains 17-OHP derivative conjugated to horseradish peroxidase.
- Conjugate diluent which contains tris-buffer, bovine serum and preservatives.
- Wash buffer concentrate which is a concentrated solution of phosphate buffered saline containing a surfactant.
- Color developer which contains 3,3',5,5'-Tetramethylbenzidine in a diluted organic solvent with citrate buffer and hydrogen peroxide.
- Stopping reagent which is a dilute solution of sodium fluoride and a red dye.
- Multi-Analyte standards (0, 10, 25, 50, 100 and 250 ng/mL) serum equivalents. Each card of standards is made from human whole blood, adjusted to a hematocrit of 55% and each level is then spotted onto Whatman 903 specimen collection paper.
- Controls (15, 40 and 90 ng/mL) serum equivalent. Each control card is made from human whole blood, adjusted to a hematocrit of 55% and each level is then spotted onto Whatman specimen collection paper.
Human source material was tested and found negative for HIV 1 and 2, HBV and HCV using FDA approved methods.
J. Substantial Equivalence Information:
1. Predicate device name(s):
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Wallac Oy AutoDelfia Neonatal 17α-Hydroxyprogesterone Time-resolved fluoroimmunoassay
2. Predicate 510(k) number(s):
k042425
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Indications for use | Screening for increased levels of 17-OHP in newborns | Screening for increased levels of 17-OHP in newborns |
| Sample Requirements | Neonatal blood collected on Whatman 903 filter paper | Neonatal blood collected on Whatman 903 filter paper |
| Specimen | 1/8 inch spot punched from a standard collection card of Whatman 903 paper | 1/8 inch spot punched from a standard collection card of Whatman 903 paper |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Assay Type | Enzyme-immunoassay | Time-resolved fluoroimmunoassay |
| Detection Method | Peroxidase which remains bound to micro-wells reacts with peroxide and TMB subsequently converting the TMB from colorless to a blue color which is measured | Europium ions dissociated from the labeled antiserum form highly fluorescent chelates with components of an enhancement solution. Fluorescence in each well is then measured |
| Standard Range | 3.8 to250 ng/mL approximate serum equivalent | Up to 190 ng/mL approximate serum equivalent |
| Controls | Two levels concentration 14 and 40 ng/mL | Three levels concentration 15, 40 and 90 ng/mL |
K. Standard/Guidance Document Referenced (if applicable):
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4
| Area of Study | Reference Procedure | Reference Title |
| --- | --- | --- |
| Stability Testing | CEN | Stability of In Vitro Diagnostic reagents (13640) |
| Interference | CLSI/NCCLS EP7-A | Interference Testing in Clinical Chemistry |
| Method Comparison | CLSI/NCCLS EP9-A | Method Comparison and Bias Estimation using Patient Samples |
| Precision | CLSI/NCCLS EP5-A | Evaluation of Precision Performance of Quantitative Measurement Methods |
L. Test Principle:
The samples can be processed with two different methods; (1) a 1/8 inch disc from each blood spot is placed directly into designated wells of the coated microplate with an overnight incubation, (2) An elution is done using an 1/8 inch disc from each blood spot which is placed in the designated well of an uncoated microplate and saline is added to elute the blood from the dried blood spot. A portion of the eluate is then transferred into a designated well of the coated microplate with an overnight incubation or for 3 hours.
The Accuwell 17α-hydroxyprogesterone immunoassay (EIA) is based on the competition principle. An unknown amount of antigen present in the sample and a fixed amount of enzyme labeled antigen compete for the binding sites of the antibodies coated onto the wells. After incubation the wells are washed to stop the competition reaction and the color developer is added. The color development is terminated by the addition of the stopping reagent and the absorbance measured at 650 nm and is inversely proportional to the amount of the antigen in the sample. Results of samples can be determined directly using the standard curve.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Precision was assessed using three neonatal dried bloodspots prepared by the Centers for Disease Control and Prevention Neonatal Screening Quality Control Program. Samples were prepared using three different assay procedures: Over night Eluate (ON Eluate), Three hour Eluate (3 Hr Eluate) and Over Night Direct (ON Direct). Each of these samples was assayed in duplicate once a day for 20 days. Results are presented in the table below:
| | ON Eluate | | | 3 Hr Eluate | | | ON Direct | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Sample ID | CDC 451 | CDC 452 | CDC 453 | CDC 451 | CDC 452 | CDC 453 | CDC 451 | CDC 452 | CDC 453 |
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| Number | 40 | 40 | 40 | 40 | 40 | 40 | 40 | 40 | 40 |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Mean | 28.2 | 56.1 | 108.1 | 26.2 | 53.0 | 104.6 | 29.5 | 57.9 | 108.6 |
| SD | 3.0 | 4.9 | 12.3 | 3.4 | 4.1 | 11.9 | 4.2 | 5.8 | 13.2 |
| %CV | 10.7 | 8.8 | 11.4 | 12.9 | 7.7 | 11.3 | 14.1 | 10.0 | 12.2 |
| Within-Run SD | Sr | 1.0 | 2.1 | 2.9 | 1.9 | 2.2 | 5.4 | 1.5 | 4.4 |
| Between-Day SD | Sdd | 2.9 | 4.5 | 12.1 | 2.9 | 3.4 | 10.7 | 3.9 | 3.9 |
| Within Device SD | ST | 3.1 | 5.0 | 12.5 | 3.4 | 4.1 | 12.0 | 4.2 | 5.8 |
| Daily Mean Standard Error | B | 3.0 | 4.8 | 12.3 | 3.1 | 3.8 | 11.4 | 4.1 | 5.0 |
b. Linearity/assay reportable range:
The linearity of the Accuwell 17-OHP measurement was demonstrated by spiking four serum samples with purified analyte to concentrations of 3.8, 10, 25 and 300 ng/mL. Samples were inter-diluted to make a total of twelve levels with a range between 3.8 - 300 ng/mL. Each sample was combined with lysed, commercially obtained, human, red blood cells to obtain an equivalent hematocrit of 55%. The samples were the spotted onto filter paper and dried. Each sample was tested in quadruplicate for each assay procedure and the average recovery was calculated and plotted against the targeted recoveries. Linear regression of comparison data yielded the following relationship:
$$
\text{ON Eluate - } y = 1.0083x - 1.3865 \ r = 0.9998
$$
$$
3 \text{ Hr Eluate - } y = 1.1015x - 4.7189 \ r = 0.997
$$
$$
\text{ON Direct - } y = 1.1146x - 4.9283 \ r = 0.997
$$
The reportable range for the Accuwell 17-OHP measurements is 3.8-250 ng/mL
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The standards and controls are prepared using commercially available human serum stripped of the analyte then purified 17-OHP analyte is added gravimetrically to various concentrations. Each serum concentration is then mixed with lysed red blood cells to a hematocrit concentration equivalent to 55%. The blood mixtures are then spotted onto filter paper in ½ inch circles. The spotted cards are randomly selected throughout the lot and the
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concentrations tested. Each new lot of cards is tested against a standard curve prepared from the previously approved lots.
The stability of the standards and controls were determined by studies that support the expiration date of 12 months.
d. Detection limit:
The limit of the blank was determined by calculating 2 SD from the mean of n=26 sample aliquots (zero standard) in one run on a single day using each of the three assay procedures. The analytical sensitivity was estimated to be 2.2 ng/mL for the Over night Eluate, 1.5 ng/mL 3 Hour Eluate and 2.3 ng/mL Over Night Direct.
e. Analytical specificity:
Studies were performed to assess common or known substances that could interfere with the method. Hemoglobin up to 1200 mg/dL, bilirubin, conjugated and unconjugated up to 300 mg/dL, and lipids up to 1875 mg/dL caused no detectable interference.
Cross-reactivity was assessed by testing compounds whose structures could potentially cause interference. The lists of compounds tested are listed below:
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| Substance | Cross Reactivity | Substance | Cross Reactivity |
| --- | --- | --- | --- |
| 21-Desoxycortisol | 2.4 % | Cholesterol | <0.01 % |
| 16α-Hydroxyprogestrone | 1.2 % | Corticosterone | <0.01 % |
| 11-Desoxycortisol | 0.6 % | Cortisol Glucuronide | <0.01 % |
| Progesterone | 0.5 % | Cortisone | <0.01 % |
| 5-Pregnen-3β,17-Diol-20-one 3 sulfate | 0.2 % | Cortisone 21-Sulphate Sodium Salt | <0.01 % |
| Cortisol | 0.06 % | Dehydroisoandrosterone | <0.01 % |
| Desoxycorticosterone | 0.06 % | Dehydroepiandrosterone Sodium Sulphate | <0.01 % |
| 1-Dehydrotestosterone | <0.01 % | Dexamethasone | <0.01 % |
| 5β-Dihydrocortisol | <0.01 % | Estriol | <0.01 % |
| 5β-Dihydrocortisone | <0.01 % | Estrone | <0.01 % |
| 6β-Hydroxycortisol | <0.01 % | Prednisolone | <0.01 % |
| 11-Dehydrocorticosterone | <0.01 % | Prednisone | <0.01 % |
| 16α-Hydroxypregnenolone | <0.01 % | Pregnenolone | <0.01 % |
| 17α-Estradiol | <0.01 % | Pregnenolone Sulphate, Sodium Salt | <0.01 % |
| 17α-Hydroxypregnenolone | <0.01 % | Spironolactone | <0.01 % |
| 17β-Estradiol | <0.01 % | Testosterone | <0.01 % |
| 20α-Hydroxyprogesterone | <0.01 % | Tetrahydrocortisol | <0.01 % |
| Aldosterone | <0.01 % | Tetrahydrocortisone | <0.01 % |
p
e
f. Assay cut-off:
See expected values below.
2. Comparison studies:
a. Method comparison with predicate device:
A retrospective study was conducted to compare the results obtained with the Accuwell 17-OHP EIA to those obtained by a currently marketed neonatal 17-OHP screening device. Test samples were submitted to the study as blinded neonatal dried blood spots collected in sequence under
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routine screening conditions from a U.S. department of public health laboratory. Original screening results for each sample using the predicate test kit were also obtained from the submitting laboratory for method comparison.
A summary of results of the method comparisons are provided in Tables 9 – 20, below. (Samples interpreted below as “Follow-Up” were not confirmed as positive for CAH.)
Values at the 99th, 97.5th, and 95th Percentiles for a Population of Babies ≥2500 gm and 0-1 Days of Age at Sample Collection
Table 9: Predicate vs. Accuwell O/N Direct
| 99th Percentile | | | | | 97.5th Percentile | | | | | 95th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | <27.5 | ≥27.5 | Totals: | Predicate | | <25.8 | ≥25.8 | Totals: | Predicate | | <21.8 | ≥21.8 | Totals: |
| Normal | <43.8 N=130 | 114 | 16 | 130 | Normal | <43.8 N=130 | 112 | 18 | 130 | Normal | <43.8 N=130 | 100 | 30 | 130 |
| Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 | Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 | Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 |
| Totals: | | 114 | 19 | 133 | Totals: | | 112 | 21 | 133 | Totals: | | 100 | 33 | 133 |
The Accuwell 17-OHP EIA (ON Direct) results for this population were: mean =16.5 ng/mL, with a range of 3.7 to 85.6 ng/mL; while the predicate kit yielded: mean =22.6 ng/mL, with a range of 10.1 to 86.0 ng/mL
The correlation was found to be: y (Predicate) = 0.970 (Accuwell ON Direct) + 6.569, R = 0.9570
Values at the 99th, 97.5th, and 95th, Percentiles for a
Table 10: Predicate vs. Accuwell O/N Eluate
| 99th Percentile | | | | | 97.5th Percentile | | | | | 95th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | <23.9 | ≥23.9 | Totals: | Predicate | | <22.3 | ≥22.3 | Totals: | Predicate | | <20.2 | ≥20.2 | Totals: |
| Normal | <43.8 N=130 | 106 | 24 | 130 | Normal | <43.8 N=130 | 103 | 27 | 130 | Normal | <43.8 N=130 | 101 | 29 | 130 |
| Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 | Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 | Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 |
| Totals: | | 106 | 27 | 133 | Totals: | | 103 | 30 | 133 | Totals: | | 101 | 32 | 133 |
Population of Babies ≥2500 gm and 0-1 Days of Age at Sample Collection
The Accuwell 17-OHP EIA (ON Eluate) results for this population were: mean =16.7 ng/mL, with a range of 5.3 to 65.6 ng/mL; while the predicate kit yielded: mean =22.6 ng/mL, with a range of 10.1 to 86.0 ng/mL.
The correlation was found to be: y (Predicate) = 1.049 (Accuwell ON Direct) + 5.066, R =
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0.9257
Values at the $99^{\text{th}}$ , $97.5^{\text{th}}$ , and $95^{\text{th}}$ Percentiles for a
Population of Babies $\geq 2500$ gm and 0-1 Days of Age at Sample Collection
Table 11: Predicate vs. Accuwell 3 Hour Eluate
| 99th Percentile | | | | | 97.5th Percentile | | | | | 95th Percentile | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up |
| Predicate | | <23.0 | ≥23.0 | Totals: | Predicate | | <21.7 | ≥21.7 | Totals: | Predicate | | <19.8 | ≥19.8 |
| Normal | <43.8 N=130 | 104 | 26 | 130 | Normal | <43.8 N=130 | 103 | 27 | 130 | Normal | <43.8 N=130 | 99 | 31 |
| Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 | Follow-Up | ≥43.8 N=3 | 0 | 3 | 3 | Follow-Up | ≥43.8 N=3 | 0 | 3 |
| Totals: | | 104 | 29 | 133 | Totals: | | 103 | 30 | 133 | Totals: | | 99 | 34 |
The Accuwell 17-OHP EIA (3Hr Eluate) results for this population were: mean = 17.3 ng/mL, with a range of 5.1 to 71.1 ng/mL; while the predicate kit yielded: mean = 22.6 ng/mL, with a range of 10.1 to 86.0 ng/mL.
The correlation was found to be: y (Predicate) = 0.998 (Accuwell ON Direct) + 5.410, R = 0.9291
Values at the $95^{\text{th}}$ Percentile for a
Population of Babies $\geq 2500$ gm and 2-3 Days of Age at Sample Collection
Table 12: Predicate vs. Accuwell O/N Direct
| 95th Percentile | | | | |
| --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | |
| Predicate | | < 18.5 | ≥ 18.5 | Totals: |
| Normal | < 29.2 N=118 | 113 | 5 | 118 |
| Follow-Up | ≥ 29.2 N = 15 | 0 | 15 | 15 |
| Totals: | | 113 | 20 | 133 |
The Accuwell 17-OHP EIA (ON Direct) results for this population were: mean = 11.3 ng/mL, with a range of 3.4 to 81.1 ng/mL; while the predicate kit yielded: mean = 16.2 ng/mL, with a range of 6.9 to 81.0 ng/mL.
The correlation was found to be: y (Predicate) = 1.045 (Accuwell ON Direct) + 4.392, R = 0.9785
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Values at the $95^{\text{th}}$ Percentile for a
Population of Babies $\geq 2500$ gm and 2-3 Days of Age at Sample Collection
Table 13: Predicate vs. Accuwell O/N Eluate
| 95th Percentile | | | | |
| --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | |
| Predicate | | < 18.7 | ≥ 18.7 | Totals: |
| Normal | < 29.2N=118 | 114 | 4 | 118 |
| Follow-Up | ≥ 29.2N = 15 | 0 | 15 | 15 |
| Totals: | | 114 | 19 | 133 |
The Accuwell 17-OHP EIA (ON Eluate) results for this population were: mean = 12.2 ng/mL, with a range of 3.4 to 67.5 ng/mL; while the predicate kit yielded: mean = 16.2 ng/mL, with a range of 6.9 to 81.0 ng/mL.
The correlation was found to be: y (Predicate) = 1.156 (Accuwell ON Eluate) + 2.030, R = 0.9729
Values at the $95^{\text{th}}$ Percentile for a
Population of Babies $\geq 2500$ gm and 2-3 Days of Age at Sample Collection
Table 14: Predicate vs. Accuwell 3 Hour Eluate
| 95th Percentile | | | | |
| --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | |
| Predicate | | < 17.7 | ≥ 17.7 | Totals: |
| Normal | < 29.2N=118 | 115 | 3 | 118 |
| Follow-Up | ≥ 29.2N = 15 | 0 | 15 | 15 |
| Totals: | | 115 | 18 | 133 |
The Accuwell 17-OHP EIA (3Hr Eluate) results for this population were: mean = 12.8 ng/mL, with a range of 4.5 to 69.6 ng/mL; while the predicate kit yielded: mean = 16.2 ng/mL, with a range of 6.9 to 81.0 ng/mL.
The correlation was found to be: y (Predicate) = 1.150 (Accuwell ON Direct) + 1.495, R = 0.9691
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Values at the $97.5^{\text{th}}$ and $95^{\text{th}}$ Percentiles for a
Population of Babies $\geq 2500$ gm and $\geq 4$ Days of Age at Sample
Collection
Table 15: Predicate vs. Accuwell O/N Direct
| 97.5th Percentile | | | | | 95th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | < 14.8 | ≥ 14.8 | Totals: | Predicate | | < 11.5 | ≥ 11.5 | Totals: |
| Normal | < 21.9 N=192 | 181 | 11 | 192 | Normal | < 21.9 N=192 | 170 | 22 | 192 |
| Follow-Up | ≥ 21.9 N = 5 | 0 | 5 | 5 | Follow-Up | ≥ 21.9 N = 5 | 0 | 5 | 5 |
| Totals: | | 181 | 16 | 197 | Totals: | | 170 | 27 | 197 |
The Accuwell 17-OHP EIA (ON Direct) results for this population were: mean $= 7.3 \, \mathrm{ng/mL}$ , with a range of 2.2 to $22.6 \, \mathrm{ng/mL}$ ; while the predicate kit yielded: mean $= 9.5 \, \mathrm{ng/mL}$ , with a range of 2.7 to $31.0 \, \mathrm{ng/mL}$ .
The correlation was found to be: $y$ (Predicate) = 1.090 (Accuwell ON Direct) + 1.565, $R = 0.9538$
Values at the $97.5^{\text{th}}$ and $95^{\text{th}}$ Percentiles for a
Population of Babies $\geq 2500$ gm and $\geq 4$ Days of Age at Sample Collection
Table 16: Predicate vs. Accuwell O/N Eluate
| 97.5th Percentile | | | | | 95th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | < 15.2 | ≥ 15.2 | Totals: | Predicate | | < 13.6 | ≥ 13.6 | Totals: |
| Normal | < 21.9 N=192 | 181 | 11 | 192 | Normal | < 21.9 N=192 | 178 | 14 | 192 |
| Follow-Up | ≥ 21.9 N = 5 | 1 | 4 | 5 | Follow-Up | ≥ 21.9 N = 5 | 0 | 5 | 5 |
| Totals: | | 182 | 15 | 197 | Totals: | | 178 | 19 | 197 |
The Accuwell 17-OHP EIA (ON Eluate) results for this population were: mean $= 7.8 \, \mathrm{ng/mL}$ , with a range of 1.4 to $26.5 \, \mathrm{ng/mL}$ ; while the predicate kit yielded: mean $= 9.5 \, \mathrm{ng/mL}$ , with a range of 2.7 to $31.0 \, \mathrm{ng/mL}$ .
The correlation was found to be: $y$ (Predicate) = 1.070 (Accuwell ON Eluate) + 1.172, $R = 0.9142$
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Values at the $97.5^{\text{th}}$ and $95^{\text{th}}$ Percentiles for a
Population of Babies $\geq 2500$ gm and $\geq 4$ Days of Age at Sample Collection
Table 17: Predicate vs. Accuwell 3 Hour Eluate
| 97.5th Percentile | | | | | 95th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | < 15.6 | ≥ 15.6 | Totals: | Predicate | | < 14.1 | ≥ 14.1 | Totals: |
| Normal | < 21.9N=192 | 176 | 16 | 192 | Normal | < 21.9N=192 | 174 | 18 | 192 |
| Follow-Up | ≥ 21.9N = 5 | 0 | 5 | 5 | Follow-Up | ≥ 21.9N = 5 | 0 | 5 | 5 |
| Totals: | | 176 | 21 | 197 | Totals: | | 174 | 23 | 197 |
The Accuwell 17-OHP EIA (3Hr Eluate) results for this population were: mean $= 8.3$ ng/mL, with a range of 2.2 to $28.4\mathrm{ng / mL}$ ; while the predicate kit yielded: mean $= 9.5$ ng/mL, with a range of 2.7 to $31.0\mathrm{ng / mL}$ .
The correlation was found to be: $y$ (Predicate) = 1.024 (Accuwell 3Hr Eluate) + 1.081, $R = 0.9350$
Values at the $99^{\text{th}}$ and $97.5^{\text{th}}$ Percentiles for a
Population of Babies 1400 - 2500 gm and 1-6 Days of Age at Sample Collection
Table 18: Predicate vs. Accuwell O/N Direct
| 99th (100th) Percentile | | | | | 97.5th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | < 46.0 | ≥ 46.0 | Totals: | Predicate | | < 43.9 | ≥ 43.9 | Totals: |
| Normal | < 45.1N=28 | 28 | 0 | 28 | Normal | < 40.3N=26 | 26 | 0 | 26 |
| Follow-Up | ≥ 45.1N = 2 | 1 | 1 | 2 | Follow-Up | ≥ 40.3N = 4 | 3 | 1 | 4 |
| Totals: | | 29 | 1 | 30 | Totals: | | 29 | 1 | 30 |
The Accuwell 17-OHP EIA (ON Direct) results for this population were: mean $= 19.3$ ng/mL, with a range of 6.5 to $47.8\mathrm{ng / mL}$ ; while the predicate kit yielded: mean $= 25.5$ ng/mL, with a range of 9.0 to $65.0\mathrm{ng / mL}$ .
The correlation was found to be: $y$ (Predicate) = 1.22 (Accuwell ON Direct) + 1.971, $R = 0.9556$
{12}
Values at the $99^{\text{th}}$ and $97.5^{\text{th}}$ Percentiles for a
Population of Babies 1400 - 2500 gm and 1-6 Days of Age at Sample Collection
Table 19: Predicate vs. Accuwell O/N Eluate
| 99th (100th) Percentile | | | | | 97.5th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | <31.7 | ≥31.7 | Totals: | Predicate | | <28.4 | ≥28.4 | Totals: |
| Normal | <45.1N=28 | 24 | 4 | 28 | Normal | <40.3N=26 | 23 | 3 | 26 |
| Follow-Up | ≥45.1N=2 | 1 | 1 | 2 | Follow-Up | ≥40.3N=4 | 1 | 3 | 4 |
| Totals: | | 25 | 5 | 30 | Totals: | | 24 | 6 | 30 |
The Accuwell 17-OHP EIA (ON Eluate) results for this population were: mean $= 19.2$ ng/mL, with a range of 6.7 to $40.2\mathrm{ng / mL}$ ; while the predicate kit yielded: mean $= 25.5$ ng/mL, with a range of 9.0 to $65.0\mathrm{ng / mL}$ .
The correlation was found to be: $y$ (Predicate) = 1.234 (Accuwell ON Direct) + 1.812, $R = 0.8770$
Values at the $99^{\text{th}}$ and $97.5^{\text{th}}$ Percentiles for a
Population of Babies 1400 - 2500 gm and 1-6 Days of Age at Sample Collection
Table 20: Predicate vs. Accuwell 3Hr Eluate
| 99th (100th) Percentile | | | | | 97.5th Percentile | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | Accuwell | Normal | Follow-up | | | Accuwell | Normal | Follow-up | |
| Predicate | | <33.3 | ≥33.3 | Totals: | Predicate | | <27.7 | ≥27.7 | Totals: |
| Normal | <45.1N=28 | 26 | 2 | 28 | Normal | <40.3N=26 | 23 | 3 | 26 |
| Follow-Up | ≥45.1N=2 | 1 | 1 | 2 | Follow-Up | ≥40.3N=4 | 2 | 2 | 4 |
| Totals: | | 27 | 3 | 30 | Totals: | | 25 | 5 | 30 |
The Accuwell 17-OHP EIA (3Hr Eluate) results for this population were: mean $= 19.3$ ng/mL, with a range of 6.6 to $39.2\mathrm{ng / mL}$ ; while the predicate kit yielded: mean $= 25.5$ ng/mL, with a range of 9.0 to $65.0\mathrm{ng / mL}$ .
The correlation was found to be: $y$ (Predicate) = 1.174 (Accuwell 3Hr Eluate) + 2.795, R = 0.8421
b. Matrix comparison:
Not applicable.
{13}
14
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):
See the method comparison study above and the expected values below.
4. Clinical cut-off:
See expected values below.
5. Expected values/Reference range:
In a separate study of 444 infants whose samples were collected for testing at 1-3 days of age and whose birth weights were ≥ 2500 gm, 17-OHP concentrations were measured using each of the Accuwell 17-OHP methods. Samples were collected on S&S filter paper no. 903 and stored for up to 7 months prior to Accuwell testing. Based on the results obtained, the sponsor provides the following guidelines in the labeling for samples taken at 1-3 days of age from babies with birth weights ≥ 2500 gm. The data show the cut-off values at which re-testing or other follow-up should be considered.
Accuwell Expected Values at the 95th, 97.5th and 99th Percentiles for a Population of Babies ≥2500 gm and 1-3 Days of Age at Sample Collection
| Accuwell O/N Direct | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| 1-3 | 444 | 20.8 | 25.0 | 27.8 |
| Accuwell O/N Eluate | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| 1-3 | 444 | 19.1 | 21.7 | 23.9 |
{14}
15
| Accuwell 3 hr Eluate | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| 1-3 | 444 | 19.3 | 21.5 | 24.3 |
In the same study, a small sample (n = 91) of infants with birth weights < 2500 gm were tested using the Accuwell 17-OHP assay methods. The study showed the following:
Accuwell Expected Values at the 95th, 97.5th and 99th Percentiles for a Population of Babies <2500 gm and 1-3 Days of Age at Sample Collection
| Accuwell O/N Direct | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | N | 95th | 97.5th | 99th |
| 1-3 | 91 | 33.9 | 43.9 | 46.4 |
| Accuwell O/N Eluate | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| 1-3 | 91 | 25.7 | 31.7 | 40.9 |
| Accuwell 3 Hr Eluate | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| 1-3 | 91 | 26.3 | 32.5 | 40.5 |
In a study of 391 infants whose samples were collected for testing at ≥ 4 days of age and whose birth weights were ≥ 2500 gm, 17-OHP concentrations were measured using each of the Accuwell 17-OHP methods. Samples were collected on S&S filter paper no. 903 and stored for up to 7 months prior to Accuwell testing. Based on the results obtained, the following guidelines can be given for samples taken at ≥ 4 days of age from babies with birth weights ≥ 2500 gm. The data show the cut-off values at which re-testing or other follow-up should be considered.
Accuwell Expected Values at the 95th, 97.5th and 99th Percentiles for a Population of Babies ≥2500 gm and 1-3 Days of Age at Sample Collection
| Accuwell O/N Direct | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| ≥ 4 | 391 | 11.5 | 14.8 | 21.1 |
{15}
| Accuwell O/N Eluate | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| ≥4 | 391 | 13.6 | 15.2 | 19.5 |
| Accuwell 3 hr Eluate | | 17-OHP (ng/mL serum) | | |
| --- | --- | --- | --- | --- |
| | | Percentiles | | |
| Age (days) | n | 95th | 97.5th | 99th |
| ≥4 | 391 | 14.1 | 15.6 | 19.4 |
The values shown here should be used only as a guideline, and were calculated based on a specific population of samples as defined by the manufacturer. The sponsor recommends in the labeling that each laboratory should establish its own cut-off values for 17-OHP in its own population.
## 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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Learn the FDA Browser
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.