SDI CA480 CLINICAL CHEMISTRY SYSTEM; SATURNO 300 CLINICAL CHEMISTRY SYSTEM
Applicant
Hemodiagnostica, LLC
Product Code
CFR · Clinical Chemistry
Decision Date
Dec 15, 2006
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The SDI CA480 Clinical Chemistry System includes a discrete, random access, microprocessor controlled clinical chemistry analyzer and dedicated reagents intended for in vitro diagnostic quantitative measurement of Glucose, Blood Urea Nitrogen (BUN), Sodium, Potassium and Chloride in serum. Other various chemistry assays are adaptable to the analyzer. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma. BUN measurements are used in the diagnosis and treatment of certain renal and metabolic diseases. Sodium measurements are used in the diagnosis and treatment of diseases involving electrolyte imbalance. Potassium measurements monitor electrolyte balance and are used in the diagnosis and treatment of disease conditions characterized by low or high blood potassium levels. Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders.
Device Story
The SDI CA480 is a discrete, random access, microprocessor-controlled clinical chemistry analyzer; performs photometric assays (Glucose, BUN) and potentiometric ISE assays (Na+, K+, Cl-). Input: serum samples via primary tubes or sample cups. Photometric assays use enzymatic reactions (hexokinase for glucose; urease/GLDH for BUN) measured at 340 nm. ISE module uses ion-selective membrane electrodes to measure potential relative to a reference electrode. System throughput: 300 photometric tests/hr and 180 ISE tests/hr. Operated by clinical laboratory personnel in a professional setting. Output: quantitative concentration values displayed to the user. Healthcare providers use results for diagnosis and treatment of metabolic, renal, and electrolyte disorders. System includes automated cuvette washing, sample/reagent pipetting via stepper motors, and optical fluid detection.
Clinical Evidence
Bench testing only. Precision studies (within-run and total) performed per CLSI EP-05. Linearity validated across claimed ranges. Method comparison studies against predicate devices (n=60-67) showed high correlation (r=0.9761 to 0.9998). Analytical sensitivity, LoD, and LoQ established for all analytes. Interference testing performed for hemoglobin, bilirubin, and lipemia.
Technological Characteristics
Discrete, random access, microprocessor-controlled photometric analyzer. Features halogen lamp, filter wheel, photodiode detector, and reusable quartz cuvettes. Integrated ISE module for electrolytes. Throughput 480 tests/hour. Automated cuvette wash/dry system. Hardware-controlled robotics for fluid handling.
Indications for Use
Indicated for in vitro diagnostic quantitative measurement of Glucose, BUN, Sodium, Potassium, and Chloride in serum for patients requiring diagnosis or treatment of carbohydrate metabolism disorders, renal/metabolic diseases, or electrolyte imbalances.
Regulatory Classification
Identification
A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
Special Controls
*Classification.* Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.
Predicate Devices
Model 550 Express (k872302)
Ciba Corning Model 664/FAST 4 System (k871028)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k061879
B. Purpose for Submission:
New Instrument with ISE, demonstrating equivalence for use with cleared reagents for Glucose (k880236), and Blood Urea Nitrogen (BUN) (k880078) Repacked for use on Hemodiagnostica’s instruments.
C. Measurand:
Glucose
BUN
Sodium (Na⁺)
Potassium (K⁺)
Chloride (Cl⁻)
D. Type of Test:
Glucose and BUN-Quantitative Photometric Assays
Na⁺, K⁺, and Cl⁻ Quantitative Ion Selective Electrode Assays
E. Applicant:
Hemodiagnostica, LLC
F. Proprietary and Established Names:
SDI CA480 Clinical Chemistry System
G. Regulatory Information:
1. Regulation section:
21 CFR §862.1345-Glucose test system.
21 CFR §862.1770-Urea nitrogen test system.
21 CFR §862.1665-Sodium test system.
21 CFR §862.1600-Potassium test system.
21 CFR §862.1170-Chloride test system.
21 CFR §862.2160-Discrete Photometric Chemistry Analyzer for Clinical Use
2. Classification:
II, II, II, II, II, I respectively
3. Product code:
CFR-Hexokinase, Glucose
CDN-Urease, Photometric, Urea Nitrogen
JGS-Electrode, Ion Specific, Sodium
CEM-Electrode, Ion Specific, Potassium
CGZ-Electrode, Ion-Specific, Chloride
JJE-Analyzer, Chemistry (Photometric, Discrete), For Clinical Use
4. Panel:
Chemistry (75)
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H. Intended Use:
1. Intended use(s):
See Indication(s) for use below
2. Indication(s) for use:
The SDI CA480 Clinical Chemistry System includes a discrete, random access, microprocessor controlled clinical chemistry analyzer and dedicated reagents intended for in vitro diagnostic quantitative measurement of Glucose, Blood Urea Nitrogen (BUN), Sodium, Potassium and Chloride in serum. Other various chemistry assays are adaptable to the analyzer.
Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma. BUN measurements are used in the diagnosis and treatment of certain renal and metabolic diseases. Sodium measurements are used in the diagnosis and treatment of diseases involving electrolyte imbalance. Potassium measurements monitor electrolyte balance and are used in the diagnosis and treatment of disease conditions characterized by low or high blood potassium levels. Chloride measurements are used in the diagnosis and treatment of electrolyte and metabolic disorders.
3. Special conditions for use statement(s):
For prescription use
4. Special instrument requirements:
SDI CA480 Clinical Chemistry System
I. Device Description:
The SDI CA480 is a discrete, random access, microprocessor controlled photometric and ISE analyzer with the capability to perform 300 clinical chemistry tests per hour plus 180 electrolyte tests per hour for a total of 480 tests per hour. The product is for use in a clinical capacity as a tool for in vitro diagnostics.
Glucose reagent
Reactive Ingredients:
G-6-PDH (L. mesenteroides), >1000 U/L;
HK (yeast), >1000 U/L; ATP, 1.0 mmol/L; NAD, 1.5 mmol/L;
0.100 mol/L Tris buffer, pH 7.5
BUN Reagent
Reactive Ingredients:
R1: GLDH (bovine liver), >1000 U/L; α-KG, 7.0 mmol/L;
Urease (jack bean), >30 KU/L; 0.06 mol/L tris buffer pH 7.8
R2: NADH (yeast), 3.2 mmol/L; buffer
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$\mathrm{Na}^{+}$ , $\mathrm{K}^{+}$ , and CT ISE Module
The integrated ISE module is included as a component to the SDI CA480. The ISE module being included has the capability to measure Sodium, Potassium and Chloride. The ISE module utilizes two positions on the sample wheel – a calibrant and a cleaning solution. The ISE module is connected by cable to the CPU of the SDI CA480. Commands to this module are handled by the software of the SDI CA480.
# J. Substantial Equivalence Information:
1. Predicate device name(s):
Model 550 Express, Ciba Corning Model 664/FAST 4 System
2. Predicate $510(\mathbf{k})$ number(s):
k872302, k871028 respectively
3. Comparison with predicate:
The SDI CA480 is substantially equivalent to the predicate devices, the Ciba Corning Model 550 Express (for photometric assays) and Ciba Corning Model 664/FAST 4 System (for ISE assays).
| | SDI CA480 | Model 550 Express |
| --- | --- | --- |
| 510(K) # | New | k872302 |
| System Principle | Discrete, random access, multi-test analysis | Discrete photometric clinical chemistry analyzer |
| Throughput | 300 tests per hour | 180 test per hour |
| Configuration | Analytical unit, Control Unit | Analytical Unit, Control Unit |
| Optical Measurement Unit | | |
| Measurement Modes | Absorbance | Absorbance |
| Detector | Photo-diode | Photo-diode array |
| Optical System | Wavelength range of 340 to 700 nm | Wavelength range of 340 to 600 nm |
| Filters | 340,380,405,510,546,578,620, and 700 nm | 340, 380, 405, 510, 540, 570, and 600 nm |
| Linear absorbance range | -.2 – 2.5 A at 340 nm | 0 – 2.5 A |
| Light Source | 20 W Halogen lamp | 20 W Halogen Lamp |
| Data Processing | | |
| Calibration curve | Factor, Linear, Logit-log 1, Logit-log 2, Spline, Exponential, Polynomial | Factor, Linear, Qualitative, 1-Logit4, 2-Logit5, 3-Exponential 5, 4-Polynomial5 |
| Cuvettes | Quartz non-disposable cuvettes | Disposable plastic cuvettes |
| Number of cuvettes | 39 (washed between tests) | Rack loaded system |
| Cuvette washing | Automatic washing system utilizing reagent grade water for washing and forced air / suction for drying | No cuvette washing system |
| Path length | 7 mm | 10 mm |
| Cuvette Volume | 600 μL | 450 μL |
| Reagent Volume | 500 μL max | 400 μL max |
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| | SDI CA480 | Model 550 Express |
| --- | --- | --- |
| 510(K) # | New | k872302 |
| Sample/Reagent Delivery | | |
| Pipetting System | Plunger driven by stepping motor | Motorized |
| Sample Dispense | Sample volume: 3 – 50 μL; 1 μL step | Sample volume: 3 – 30 μL |
| Reagent Dispense | Reagent 1 volume: 250 – 500 μL
Reagent 2 volume: 1 – 250 μL
1 μL step | Reagent Volume: 50 – 400 μL |
| | SDI CA480 | Model 664 |
| --- | --- | --- |
| 510(K) # | New | k871028 |
| System Principle | Potentiometric | Potentiometric (for Na, Cl, and K), Thermal Conductivity (for CO2) |
| Throughput | 180 test/hour | 270 test/hour (using ISE) |
| Fluids measured | Whole Serum, Plasma, Diluted Urine | Serum, Plasma, Whole Blood, Urine |
| Clinical Measurements | Sodium, Potassium, Chloride | Sodium, Potassium, Chloride, Bicarbonate |
| Electrode Maintenance | disposable (no filling necessary) | Refillable electrode modules |
| ISE Detector | Potentiometric | Potentiometric |
| Modes of Analysis | Random Access or STAT | Programmable Batch or STAT |
| Reagents / Calibrators | Provided Calibrant A and B | All Calibrant (All-Cal) |
| Cleaning | Provided Cleaning Solution | Wash Solution |
| Calibration Frequency | Every 30 minutes and by request. One point calibration done on every sample | Every 30 minutes or before a batch run |
| Sample Volume | 60 μL, 160 μL for diluted urine (10:1) | 170 μL (batch and stat), 85 μL (microstat) |
| Pipetting System | Probe driven by stepper motor | Motorized probe |
| Fluid Verification | Optical fluid detection with bubble detection capability | Optical fluid detection |
| Sample Dispensing | Aspiration and dispensation into ISE module | Aspiration from sample cup into fluidic/measurement system, no dispensing |
# K. Standard/Guidance Document Referenced (if applicable):
None referenced
# L. Test Principle:
Glucose
Glucose in the serum sample is phosphorylated by hexokinase using excess adenosine triphosphate (ATP) in the presence of magnesium ions to glucose-6-phosphate.
Glucose-6-phosphate is oxidized in the presence of nicotinamide adenine dinucleotide (NAD) by glucose-6-phosphate dehydrogenase (G-6-PDH) to 6-phosphogluconate and NADH which is measured at $340~\mathrm{nm}$ and is proportional to the amount of glucose present.
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BUN
Urea is converted to ammonia and $\mathrm{CO}_{2}$ by the enzyme urease. The ammonia produced is utilized by glutamate dehydrogenase (GLDH) to convert alpha-ketoglutarate ($\alpha$-KG) to glutamic acid, with the concomitant conversion of NADH to NAD which is measured at $340~\mathrm{nm}$, and is proportional to the amount of BUN present.
Sodium, Potassium and Chloride
The ISE Module of the SDI CA480 utilizes Ion Selective Electrode technology. The flow-through Sodium electrode uses selective membrane tubing, formulated to be sensitive to Sodium ions. The Potassium and Chloride electrodes employ similar designs with appropriate selective membrane materials. The potential of each electrode is measured relative to a fixed, stable voltage established by the double-junction silver / silver chloride reference electrode. An ion selective electrode develops a voltage that varies with the concentration of the ion to which it responds. The relationship between the voltage developed and the concentration of the sensed ion is logarithmic, as expressed by the Nernst equation:
$$
\mathrm{Ex} = \mathrm{Es} + \frac{\mathrm{nF}}{\mathrm{RT}} \log(\mathrm{C}\alpha)
$$
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Within-Run and Total Precision studies were carried out two levels of sera were prepared based on medical decision levels.
Within-run (Repeatability) data were generated according to CLSI procedure (EP-05)
Glucose Precision:
| Within Run
n=40 | Level 1 | Level 2 | Level 3 |
| --- | --- | --- | --- |
| Mean (mg/dL) | 50.5 | 112 | 296 |
| S.D. (mg/dL) | 1.19 | 1.21 | 2.75 |
| C.V. (%) | 2.36 | 1.08 | 0.93 |
| Total | | | |
| n=50 | (5 days / 2 runs per day / 5 samples per run) | | |
| Mean (mg/dL) | 50.47 | 113.22 | 296.69 |
| S.D. (mg/dL) | 1.45 | 1.01 | 2.14 |
| C.V. (%) | 2.88 | 0.89 | 0.72 |
BUN Precision:
| Within Run
n=20 | Level 1 | Level 2 |
| --- | --- | --- |
| Mean (mg/dL) | 10.3 | 19.95 |
| S.D. (mg/dL) | 0.98 | 1.00 |
| C.V. (%) | 9.50 | 5.01 |
| Total | | |
| n=50 | (5 days / 2 runs per day / 5 samples per run) | |
| Mean (mg/dL) | 9.66 | 21.17 |
| S.D. (mg/dL) | 0.79 | 1.19 |
| C.V. (%) | 8.13 | 5.62 |
| Sodium | Within-Run | | Total | |
| --- | --- | --- | --- | --- |
| | Level 1 | Level 2 | Level 1 | Level 2 |
| | n = 20 | | n = 50 | |
| Mean | 134.50 | 161.35 | 130.64 | 160.91 |
| SD | 1.05 | 0.59 | 1.78 | 1.90 |
| C.V | 0.78% | 0.36% | 1.37% | 1.18% |
| (%) | | | | |
| Range | 133 - | 160 - | 128.5- 135.5 | 156.5 - |
| Potassium | Within-Run | | Total | |
| --- | --- | --- | --- | --- |
| | Level 1 | Level 2 | Level 1 | Level 2 |
| | n = 20 | | n = 50 | |
| Mean | 2.94 | 6.02 | 3.00 | 6.02 |
| SD | 0.07 | 0.07 | 0.11 | 0.10 |
| C.V (%) | 2.54% | 1.16% | 3.74% | 1.74% |
| Range | 2.8 -3.1 | 5.9 - | 2.8 - 3.25 | 5.75 - |
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| | Within-Run | | Total | |
| --- | --- | --- | --- | --- |
| Chloride | Level 1 | Level 2 | Level 1 | Level 2 |
| | n = 20 | | n = 50 | |
| Mean | 74.85 | 110.75 | 74.82 | 111.88 |
| SD | 1.27 | 1.45 | 1.10 | 1.36 |
| C.V (%) | 1.69% | 1.31% | 1.47% | 1.22% |
| Range | 73 - 77 | 109 - 115 | 72 - 77.5 | 108.5 - 114.5 |
## b. Linearity/assay reportable range:
The measurement range for glucose is 3 to 550 mg/dL
The measurement range for BUN is 4 mg/dL to 105 mg/dL.
The measurement range for Sodium is 100 to 170 mmol/L
The measurement range for Potassium is 2.0 to 7.0 mmol/L
The measurement range for Chloride is 65 to 120 mmol/L
The linearity study was performed according to CLSI guidance using commercially available linearity material
| GLU | | Linearity Limit | | | 550 | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| List No. | Published Values | Observed Values | | | Mean | | 2 * S.D. | Recovery |
| | | Run 1 | Run 2 | Run 3 | Run 4 | | | |
| 9201 | 25.0 | 27.0 | 26.0 | 26.0 | 28.0 | 26.75 | 1.91 | 107.00% |
| 9202 | 200.0 | 203.0 | 202.0 | 204.0 | 203.0 | 203.00 | 1.63 | 101.50% |
| 9203 | 375.0 | 379.0 | 378.0 | 380.0 | 379.0 | 379.00 | 1.63 | 101.07% |
| 9204 | 550.0 | 561.0 | 560.0 | 560.0 | 562.0 | 560.75 | 1.91 | 101.95% |
| 9205 | 725.0 | 742.0 | 745.0 | 744.0 | 745.0 | 744.00 | 2.83 | 102.62% |
| | | | | | | Avg. Recovery | | 102.83% |
| BUN | | Linearity Limit | | | 105 | | | |
| No. | Published Values | Observed Values | | | Mean | | 2 * S.D. | Recovery |
| | | Run 1 | Run 2 | Run 3 | Run 4 | | | |
| 9201 | 5.0 | 5.0 | 5.0 | 4.0 | 5.0 | 4.75 | 1.00 | 95.00% |
| 9202 | 37.5 | 37.0 | 38.0 | 38.0 | 38.0 | 37.75 | 1.00 | 100.67% |
| 9203 | 70.0 | 71.0 | 72.0 | 72.0 | 73.0 | 70.00 | 1.63 | 100.00% |
| 9204 | 102.5 | 104.0 | 103.0 | 105.0 | 104.0 | 104.00 | 1.63 | 101.46% |
| 9205 | 135.0 | 138.0 | 136.0 | 138.0 | 138.0 | 137.50 | 2.00 | 101.85% |
| | | | | | | Avg. Recovery | | 99.80% |
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| Sodium | | Linearity Limit | | | 160 | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| List No. | Published Values | Observed Values | | | | Mean | 2 S.D. | Recovery |
| | | Run 1 | Run 2 | Run 3 | Run 4 | | | |
| 9201 | 100 | 104 | 103 | 104 | 104 | 103.75 | 1.00 | 103.75% |
| 9202 | 118 | 120 | 120 | 121 | 118 | 119.75 | 2.52 | 101.48% |
| 9203 | 136 | 138 | 138 | 138 | 138 | 138.00 | 0.00 | 101.47% |
| 9204 | 154 | 151 | 156 | 156 | 156 | 154.75 | 5.00 | 100.49% |
| 9205 | 172 | 174 | 173 | 173 | 171 | 172.75 | 2.52 | 100.44% |
| | | | | | | Avg. Recovery | | 101.53% |
| | Potassium | Linearity Limit | | | 6.5 | | | |
| List No. | Published Values | Observed Values | | | | Mean | 2 S.D. | Recovery |
| | | Run 1 | Run 2 | Run 3 | Run 4 | | | |
| 9201 | 1.75 | 1.80 | 2.00 | 1.80 | 1.90 | 1.88 | 0.19 | 107.14% |
| 9202 | 4.50 | 4.30 | 4.30 | 4.40 | 4.50 | 4.38 | 0.19 | 97.22% |
| 9203 | 7.25 | 6.90 | 7.10 | 7.00 | 7.30 | 7.08 | 0.34 | 97.59% |
| 9204 | 10.00 | 9.70 | 9.90 | 9.80 | 10.00 | 9.85 | 0.26 | 98.50% |
| 9205 | 12.75 | 12.50 | 12.60 | 12.60 | 12.50 | 12.55 | 0.12 | 98.43% |
| | | | | | Avg. Recovery | | | 99.78% |
| | Chloride | Linearity Limit | | | 120 | | | |
| List No. | Published Values | Observed Values | | | | Mean | 2 S.D. | Recovery |
| | | Run 1 | Run 2 | Run 3 | Run 4 | | | |
| 9201 | 60.0 | 60.0 | 62.0 | 61.0 | 62.0 | 61.25 | 1.91 | 102.08% |
| 9202 | 88.5 | 89.0 | 90.0 | 90.0 | 90.0 | 89.75 | 1.00 | 101.41% |
| 9203 | 117.0 | 118.0 | 118.0 | 119.0 | 120.0 | 118.75 | 1.91 | 101.50% |
| 9204 | 145.5 | 145.0 | 144.0 | 145.0 | 145.0 | 144.75 | 1.00 | 99.48% |
| 9205 | 174.0 | 177.0 | 175.0 | 176.0 | 175.0 | 175.75 | 1.91 | 101.01% |
| | | | | | Avg. Recovery | | | 101.10% |
c. Traceability, Stability, Expected values (controls, calibrators, or methods): Traceability information for the assays was reviewed under k880236 for Glucose, k880078 for BUN and k000926 for Sodium, Potassium and Chloride.
d. Detection limit: Glucose
A calibration factor of approximately 750 was obtained, which is equivalent to
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an analytical sensitivity of 1.33 $\Delta$mAbs per mg/dL.
## Limit of Detection:
10 samples containing no analyte were measured and the LoD calculated. The Limit of Detection for Glucose was found to be 3 mg/dL.
## Limit of Quantitation:
40 samples containing known low amount of analyte were measured. Precision was evaluated, with a maximum C.V. (%) of 20% allowed. The Limit of Quantitation for Glucose was found to be 3 mg/dL.
## BUN
A calibration factor of approximately 796 was obtained, which is equivalent to a sensitivity of 1.26 $\Delta$mAbs per mg/dL.
## Limit of Detection:
10 samples containing no analyte were measured and the LoD calculated. The Limit of Detection for BUN was found to be 4 mg/dL.
## Limit of Quantitation:
40 samples containing known low amount of analyte were measured. Precision was evaluated, with a maximum C.V. (%) of 20% allowed. The Limit of Quantitation for BUN was found to be 4 mg/dL.
## ISE
The calibration factor for each assay is 1000, which gives a sensitivity of 1.00 $\Delta$mAbs per mmol/dL.
The ISE measurable range is based on linearity studies only.
## e. Analytical specificity:
### Glucose
**Hemoglobin:**
Hemolyzed sample (>200 mg/dL hemoglobin) will interfere with this assay.
**Bilirubin:**
No significant interference (±10%) from bilirubin up to 6.0 mg/dL.
**Lipemia:**
Lipemic samples (>275 mg/dL) measured as triglycerides will interfere with this assay.
### BUN
**Hemoglobin:**
No significant interference (±10%) from hemoglobin up to 200 mg/dL.
**Bilirubin:**
Samples with high Bilirubin (>3.5 mg/dL) will interfere with this assay.
**Lipemia:**
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No significant interference $(\pm 10\%)$ from triglyceride up to $250~\mathrm{mg/dL}$.
ISE
Hemoglobin:
Hemoglobin shows interference with potassium. Do not use hemolyzed samples for potassium. No significant interference from hemoglobin on sodium and chloride up to $2000\mathrm{mg/dL}$.
Lipemia:
No significant interference from lipemia up to $1000\mathrm{mg/dL}$ measured as triglycerides on sodium, potassium or chloride.
Bilirubin:
No significant interference from Bilirubin up to $31\mathrm{mg/dL}$ on sodium, potassium or chloride.
For a comprehensive review of drug interference see Young, et al$^{1}$.
f. Assay cut-off:
Not Applicable
2. Comparison studies:
a. Method comparison with predicate device:
A method comparison was performed between the SDI CA480 and the predicate Ciba Corning Express 550 (for BUN and Glucose) and Ciba Corning 664 (for Na, K, and Cl) according to CLSI protocols across the claimed assay ranges. Linear regression results are summarized below:
| Analyte | n | r | y = | Range |
| --- | --- | --- | --- | --- |
| BUN | 60 | 0.9988 | y = 0.933x + 0.94 | 4 - 105 |
| Glucose | 67 | 0.9998 | y = 0.981x + 0.99 | 4 - 559 |
| Sodium | 60 | 0.9905 | y = 0.998x -1.26 | 86 - 173 |
| Potassium | 60 | 0.9946 | y = 0.977x + 0.06 | 1.6 - 7.1 |
| Chloride | 60 | 0.9761 | y = 1.019x -2.34 | 64 - 125 |
b. Matrix comparison:
Not Applicable
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
$^{1}$ Young, D.S., et al, Clin. Chem. 21:1D (1975)
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5. Expected values/Reference range:
Glucose: 70 - 105 mg/dL
BUN: 7 - 18 mg/dL
Sodium: 136 - 145 mmol/L
Potassium: 3.5 - 5.1 mmol/L
Chloride: 98 - 107 mmol/L
References from Tietz, N.W., Fundamentals of Clinical Chemistry, 2nd ed., .B.
Saunders Co., Philadelphia, p. 2190, (1994)
N. Instrument Name:
Hemodiagnostica, SDI CA480 Chemistry Analyzer
O. System Descriptions:
1. Modes of Operation:
Random Access or STAT modes
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ X or No ☐
3. Specimen Identification:
Manual entry, Worklist downloads and Bar Code
4. Specimen Sampling and Handling:
Direct primary tube sampling or sample cups
5. Calibration:
Photometric Calibration curves:
Factor, Linear, Logit-log 1, Logit-log 2, Spline, Exponential, and Polynomial
ISE Potentiometric Calibrant A and B, every 30 minutes and by request. One point calibration done on every sample.
6. Quality Control:
Analyzer has a Quality Control program to monitor assay trends.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
None
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. 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.