THE PRECISION / OPTIUM POINT OF CARE BLOOD GLUCOSE TEST STRIPS
K070984 · Abbott Diabetes Care, Inc. · LFR · Nov 1, 2007 · Clinical Chemistry
Device Facts
Record ID
K070984
Device Name
THE PRECISION / OPTIUM POINT OF CARE BLOOD GLUCOSE TEST STRIPS
Applicant
Abbott Diabetes Care, Inc.
Product Code
LFR · Clinical Chemistry
Decision Date
Nov 1, 2007
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Attributes
Real-World Evidence, Pediatric
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K070984 · Nov 1, 2007
THE PRECISION / OPTIUM POINT OF CARE BLOOD GLUCOSE TEST STRIPS
Abbott Diabetes Care, Inc.
Clinical patient samples (neonatal, venous, arterial, and capillary blood from patients with diabetes)
Clinical performance validation using patient samples collected in clinical settings to assess accuracy against a reference method (YSI) across various patient populations and sample types.
Clinical performance; Method comparison; Patient samples; Neonatal; Arterial; Lay user
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Prospective clinical method comparison
183 lay persons with diabetes; Sample Size: 183; Number of Sites: 3
YSI analyzer (reference method)
Accuracy based on ISO 15197 criteria
Clinical matrix comparison
175 neonates; Sample Size: 175; Number of Sites: 1
Laboratory plasma method
Accuracy based on ISO 15197 criteria
Clinical matrix comparison
120 patients; Sample Size: 120; Number of Sites: 1
Laboratory method and YSI reference method
Accuracy based on ISO 15197 criteria
Indications for Use
The Precision® and Optium® Point of Care Blood Test Strips quantitatively measure glucose (D-glucose) in fresh neonatal, venous, arterial, and fingertip capillary whole blood. The test strips are for use outside the body (in vitro diagnostic use) by healthcare professionals for use in healthcare facilities with either the Precision Xtra or Optium Blood Glucose Monitoring Systems. Home users may use the system for capillary samples only. The test strips are not for use in diagnosis or screening of diabetes mellitus, but to be used as an aid in monitoring the effectiveness of diabetes control programs.
Device Story
Test strips utilize amperometric biosensor technology; enzyme Glucose Dehydrogenase (GDH) catalyzes reaction with Nicotinamide Adenine Dinucleotide (NAD); reduced NAD (NADH) re-oxidized by electrochemical mediator 1,10 phenanthroline quinone (1,10PQ); electron transfer at electrode surface generates current proportional to glucose concentration. Meter translates current into glucose value after 20-second countdown; requires lot-specific information from ROM calibrator. Used in healthcare facilities by professionals or at home by patients for capillary blood monitoring. Output provides quantitative glucose concentration to aid in diabetes management.
Clinical Evidence
Performance verified through clinical and non-clinical laboratory testing. Evaluated parameters included altitude, dynamic range, precision, linearity, accuracy, interference, oxygen sensitivity, environmental factors, hematocrit, shipping, and shelf life. Results demonstrated substantial equivalence to the predicate device.
Technological Characteristics
Amperometric biosensor; reagent includes glucose dehydrogenase (GDH-NAD), NAD, and 1,10-phenanthroline quinine. Dimensions/form factor: test strip for use with Precision Xtra/Optium meters. Energy source: meter-powered electrochemical measurement. Connectivity: ROM calibrator for lot-specific data. Hematocrit range: 20-70%. Dynamic range: 20-500 mg/dL.
Indications for Use
Indicated for quantitative measurement of glucose in fresh neonatal, venous, arterial, and fingertip capillary whole blood. For use by healthcare professionals in clinical settings or by home users (capillary samples only) to monitor diabetes control programs. Not for diabetes diagnosis or screening.
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
Precision®/Optium® Point of Care Blood Glucose Test Strips (k021960)
Submission Summary (Full Text)
{0}
1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY TEMPLATE
A. 510(k) Number:
k070984
B. Purpose for Submission:
Modifications to previously 510(k) cleared glucose test strips.
The modifications are as follows: change in reagent formulation, decrease sample volume, expansion of the hematocrit range to 20%-70%, and change in strip artwork and color.
C. Measurand:
Whole blood glucose
D. Type of Test:
Quantitative, utilizing glucose dehydrogenase technology
E. Applicant:
Abbott Diabetes Care Inc.,
F. Proprietary and Established Names:
Precision® Point of Care Blood Glucose Test Strips and Optium® Point of Care Blood Glucose Test Strips
G. Regulatory Information:
1. Regulation section:
21 CFR 862.1345
2. Classification:
Class II
3. Product code:
LFR, NBW
4. Panel:
75 (Chemistry)
H. Intended Use:
1. Intended use(s):
{1}
See Indications for use below.
## 2. Indication(s) for use:
The Precision® and Optium® Point of Care Blood Test Strips quantitatively measure glucose (D-glucose) in fresh neonatal, venous, arterial, and fingertip capillary whole blood. The test strips are for use outside the body (in vitro diagnostic use) by healthcare professionals for use in healthcare facilities with either the Precision Xtra or Optium Blood Glucose Monitoring Systems. Home users may use the system for capillary samples only. The test strips are not for use in diagnosis or screening of diabetes mellitus, but to be used as an aid in monitoring the effectiveness of diabetes control programs.
## 3. Special conditions for use statement(s):
For professional and home use
In the package insert the manufacturer has stated the following limitations:
1. "If the test fails to start, sufficient blood sample may not have been applied to the test strip. Discard the current test strip, and repeat with new strip."
2. "Xylose may produce falsely elevated glucose results during a xylose absorption test for diagnostic evaluation of malabsorption"
3. Test results may be erroneously low if the patient is severely dehydrated, severely hypotensive, in shock or in a hyperglycemic-hyperosmolar state (with or without ketosis). Similar observations have been reported in the literature for other blood glucose monitoring systems.
## 4. Special instrument requirements:
Precision Xtra or Optium Blood Glucose meter (the sponsor claims that these meters are identical except for the name).
## I. Device Description:
The Precision®/Optium® Point of Care Blood Glucose Test Strips contain the following reagents in their strips: glucose dehydrogenase (GDH-NAD) ≥ 0.03U, NAD + (as sodium salt) ≥ 1.0 μg, phenanthroline quinine ≥ 0.02 μg, non-reactive ingredients ≥ 16.3 μg.
## J. Substantial Equivalence Information:
1. Predicate device name(s):
Precision®/Optium® Point of Care Blood Glucose Test Strips
2. Predicate 510(k) number(s):
{2}
k021960
3. Comparison with predicate:
| Similarities and Differences of the candidate and the predicate Blood Glucose Test Strips | | |
| --- | --- | --- |
| Item | Precision/Optium Point of Care Blood Glucose Test Strips (Predicate device) k021960 | Precision/Optium Point of Care Blood Glucose Test Strips (Candidate device) |
| Intended Use | Professional and Home Use | Same |
| Assay Time | 20 seconds | Same |
| Sample Volume | 2.5 μl | 0.6 μl |
| Second Application Time | 30 seconds | None- In the package insert the users were told the following: “If the test fails to start, sufficient blood sample may not have been applied to the test strip. Discard the current test strip, and repeat with new strip.” |
| Meter platforms | Precision Xtra or Optium glucose meters | Same |
| Dynamic range | 20-500 mg/dL | Same |
| Hematocrit range | 20-70% for glucose range <300 mg/dL; 20-60% for glucose range >300 mg/dL | 20-70% across the dynamic range |
| Enzyme | Glucose Dehydrogenase | Same |
| Cofactor | Nicotinamide Adenine Dinucleotide | Same |
K. Standard/Guidance Document Referenced (if applicable):
1. CLSI EP5-A, Evaluation of Precision Performance of Clinical Chemistry Devices; Approved Guideline.
2. CLSI EP7-A2 Interference Testing in Clinical Chemistry; Approved Guideline- Second edition
3. CLSI EP9-A2 Method Comparison and Bias Estimation Using Patient Samples; Approved Guideline Second edition
4. ISO 15197:2003, In Vitro Diagnostic Test Systems – Requirements for Blood Glucose Monitoring Test Systems for Self Managing Diabetes Mellitus
L. Test Principle:
The test principal of this device is based on amperometric biosensor technology, by determination of glucose oxidized by the enzyme (Glucose Dehydrogenase, GDH)
{3}
catalyzed reaction with Nicotinamide Adenine Dinucleotide (NAD). The reduced form of NAD (NADH) is re-oxidized by reaction with the electrochemical mediator, 1,10 phenanthroline quinine (1,10PQ). The reduced mediator is re-oxidized via electron transfer at the electrode surface. This current is translated into a number by the meter, after applying lot specific information from the ROM calibrator and after a 20 second count-down; a concentration value is then presented to the user.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
A precision study were performed to assess the precision and repeatability of the Precision POC modified test strips responses using venous whole blood concentrations between 30 and 350 mg/dL (spiked samples). Blood samples were collected from healthy donors into tubes that contained heparin. Four Precision meters and three lots of blood glucose test strips were tested with 20 replicates on one day. The precision of all three lots of the test strips was shown below:
| Level | Mean of glucose (mg/dL) | Within-run (SD) | % CV |
| --- | --- | --- | --- |
| 1 | 29.9 | 1.5 | 5.0 |
| 2 | 51.0 | 1.8 | 3.6 |
| 3 | 92.3 | 3.1 | 3.4 |
| 4 | 140.2 | 4.6 | 3.3 |
| 5 | 217.9 | 6.7 | 3.1 |
| 6 | 343.7 | 10.2 | 3.0 |
In addition, precision and repeatability of the modified test strips were tested with controls solutions (low, mid, and high). Four Precision meters and three lots of strips were tested in duplicate for each glucose control solution for 20 days. The precision of all three lots of the test strips was shown below:
| Glucose control solution level | Mean of glucose (mg/dL) | Within-run (SD) | Total imprecision (SD) | Total % CV |
| --- | --- | --- | --- | --- |
| Low | 40.9 | 1.8 | 2.2 | 5.4 |
| Mid | 83.6 | 4.2 | 5.1 | 6.1 |
| High | 272.9 | 3.2 | 4.2 | 1.5 |
#### b. Linearity/assay reportable range:
A linearity study was performed using capillary whole blood samples collected from 24 donors. The capillary samples were spiked to varying glucose concentrations, distributed throughout the testing range. Three lots of blood
{4}
glucose test strips were tested in duplicate with each blood sample. Ranges of samples tested were from 26 to 495 mg/dL. YSI glucose analyzer was used as a reference method. The linear regression of all three lots is shown below:
Y = 0.98X - 3.0, r = 0.995, N = 288, (X = YSI method, Y = Meter)
In addition, the sponsor performed a dynamic range study to evaluate the glucose values at the extreme ranges. Glucose levels at concentrations of 10, 20, 500, 600, and 700 mg/dL were tested between the YSI method and the glucose meters. When the YSI glucose level tested at 24 mg/dL, the glucose meters read 22 mg/dL (N=30).
The dynamic range study and the linearity study support the sponsor's claim that the linearity range of the modified test strips is 20 to 500 mg/dL.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
No change to traceability. The Precision POC blood glucose test strip is traceable to YSI which employs NIST SRM 917b reference material.
d. Detection limit:
See linearity/reportable range studies above.
e. Analytical specificity:
i.) An interference study was performed to determine the effect of 27 potential interference substances. Blood samples were obtained in heparinized tubes, pooled and then spiked to a glucose level of approximately 100 mg/dL. Stock solutions of the potential interferents were prepared and spiked into the tested pool sample with different concentrations. The % bias was calculated based on the differences between the spiked sample and the control pool sample. The sponsor's acceptance criterion is ≤13% bias for not significant interference. All the interference substances tested met the sponsor's acceptance criterion except for xylose; therefore, the sponsor put a warning in the limitation section of the package insert.
“Xylose may produce falsely elevated glucose results during a xylose absorption test for diagnostic evaluation of malabsorption”
ii.) A hematocrit study was performed to evaluate the hematocrit variation effect of the modified test strips. Oxygenated venous blood samples with up to 6 different Hct levels (10, 15, 20, 45, 55, and 70%) were prepared and used. Four different glucose target concentrations of oxygenated venous blood concentrations (35, 60, 90, and 400 mg/dL) were prepared. The % difference between the glucose strips results and YSI results were calculated and summarized as follows:
5
{5}
% difference between strip and YSI reference at HCT of 20%:
| Target Glucose Level (mg/dL) | 35 mg/dL | | 50 mg/dL | | 90 mg/dL | 400 mg/dL |
| --- | --- | --- | --- | --- | --- | --- |
| Range of Glucose by YSI (mg/dL) | 36.3 – 41.4 | | 52.5 – 61.5 | | 94.8 – 111.0 | 402.5 – 486.3 |
| Lot1 | -5.2% | -2.0 mg/dL | 6.4% | 3.8 mg/dL | -0.1 | 9.6 |
| Lot2 | -18.0% | -7.0 mg/dL | -8.6% | -5.1 mg/dL | -7.0 | 1.9 |
| Lot3 | -17.9% | -7.0 mg/dL | -9.4% | -5.5 mg/dL | -8.0 | 4.2 |
| All lots | -13.7% | -5.3 mg/dL | -3.9% | -2.3 mg/dL | -5.0 | 5.2 |
% difference between strip and YSI reference at HCT of 45%:
| Target Glucose Level (mg/dL) | 35 mg/dL | | 50 mg/dL | | 90 mg/dL | 400 mg/dL |
| --- | --- | --- | --- | --- | --- | --- |
| Range of Glucose by YSI (mg/dL) | 36.3 – 41.4 | | 52.5 – 61.5 | | 94.8 – 111.0 | 402.5 – 486.3 |
| Lot1 | -13.0% | -4.8mg/dL | -11.8% | -6.7mg/dL | -6.5 | -4.6 |
| Lot2 | -24.7% | -9.2mg/dL | -21.8% | -12.4mg/dL | -12.4 | -9.1 |
| Lot3 | -26.8% | -9.9mg/dL | -23.8% | -13.6mg/dL | -12.5 | -10.0 |
| All lots | -21.5% | -8.0mg/dL | -19.1% | -10.9mg/dL | -10.4 | -7.9 |
% difference between strip and YSI reference at HCT of 70%:
| Target Glucose Level (mg/dL) | 35 mg/dL | | 50 mg/dL | | 90 mg/dL | 400 mg/dL |
| --- | --- | --- | --- | --- | --- | --- |
| Range of Glucose by YSI (mg/dL) | 36.3 – 41.4 | | 52.5 – 61.5 | | 94.8 – 111.0 | 402.5 – 486.3 |
| Lot1 | -25.3% | -10.1mg/dL | -15.3% | -8.9mg/dL | -12.8 | -17.6 |
| Lot2 | -30.4% | -12.2mg/dL | -21.1% | -12.1mg/dL | -17.7 | -18.6 |
| Lot3 | -33.3% | -13.3mg/dL | -22.4% | -12.7mg/dL | -18.8 | -19.6 |
| All lots | -29.6% | -11.9mg/dL | -19.6% | -11.2mg/dL | -16.4 | -18.6 |
In addition, the sponsor calculated the mean % bias of the hematocrits from the reference Hct of 45%. The results are summarized in the table below:
Mean difference (% mean bias) from the 45% Hct:
| Glucose Target range | Lot | 20% Hct | 45% Hct | 70% Hct |
| --- | --- | --- | --- | --- |
| 35 mg/dL | Lot 1 | 8% | 0% | -12% |
| | Lot 2 | 7% | 0% | -6% |
| | Lot 3 | 9% | 0% | -6% |
| | All lots | 8% | 0% | -8% |
| 50 mg/dL | Lot 1 | 18% | 0% | -12% |
| | Lot 2 | 13% | 0% | -6% |
| | Lot 3 | 14% | 0% | -6% |
| | All lots | 15% | 0% | -8% |
{6}
| 90 mg/dL | Lot 1 | 6% | 0% | -12% |
| --- | --- | --- | --- | --- |
| | Lot 2 | 5% | 0% | -6% |
| | Lot 3 | 4% | 0% | -6% |
| | All lots | 5% | 0% | -8% |
| 400 mg/dL | Lot 1 | 14% | 0% | -12% |
| | Lot 2 | 11% | 0% | -6% |
| | Lot 3 | 14% | 0% | -6% |
| | All lots | 13% | 0% | -8% |
The sponsor claimed that the reportable hematocrit range was 20%-70% for the modified glucose test strips.
iii.) An altitude study was performed to determine the accuracy of the modified strips at 7,200 ft above sea level. Capillary samples were taken from 63 subjects and tested on the Precision POC test strips and the YSI glucose analyzer. The glucose concentration range tested was 48-410 mg/dL and the hematocrit range was 31-56 %. The Passing Bablok regressions results were as follows:
Results (Y) vs. YSI reference method (X):
$$
Y = 0.91X + 5.68, r = 0.98, N = 54
$$
The overall accuracy according to the ISO acceptance criteria were as follow:
98.1% (106/108) of results fall within ± 15 mg/dL of YSI reference at glucose concentrations < 75 mg/dL and within ± 20% of YSI reference at glucose concentrations ≥75 mg/dL.
iv.) A temperature and humidity testing was performed to determine the effects of variation in temperature and humidity on the response of Precision POC test strips with spiked venous blood samples. Testing was conducted using six Precision glucose meters against the YSI glucose analyzer. Three lots of blood glucose test strips were tested with 12 replicate strips per blood glucose level (50, 90, and 350 mg/dL) and environmental condition (temperatures at 15, 25, and 40°C; humidity at 10, 50, and 90%). The % difference from the control condition (24°C/50%) between the glucose strips results and YSI results were calculated and summarized as follows:
{7}
| Target glucose level (mg/dL) | Temp. (°C) | Humidity (%) | Test strip lot | | | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | Lot 1 | Lot 2 | Lot 3 | All lots |
| 50 | 15 | 10 | -2mg/dL | -2mg/dL | -2mg/dL | -2mg/dL |
| | | 90 | -1mg/dL | 0mg/dL | 0mg/dL | -1mg/dL |
| | 40 | 10 | -1mg/dL | -2mg/dL | -2mg/dL | -2mg/dL |
| | | 90 | 6mg/dL | 4mg/dL | 3mg/dL | 4mg/dL |
| 90 | 15 | 10 | -4% | -3% | -3% | -4% |
| | | 90 | 0% | 2% | 3% | 3% |
| | 40 | 10 | -7% | -9% | -8% | -8% |
| | | 90 | 2% | -3% | -1% | -2% |
| 350 | 15 | 10 | -14% | -12% | -13% | -13% |
| | | 90 | -5% | -2% | -3% | -3% |
| | 40 | 10 | 0% | -2% | -4% | -3% |
| | | 90 | 7% | 5% | 7% | 6% |
The sponsor claimed that the temperature between $15 - 40^{\circ}\mathrm{C}$ ( $59^{\circ} - 104^{\circ}\mathrm{F}$ ) and humidity between $10 - 90\%$ provides acceptable glucose results.
f. Assay cut-off:
Not applicable.
# 2. Comparison studies:
a. Method comparison with predicate device and reference method:
183 lay persons with diabetes in three different clinics performed a finger-stick test using the modified test strips on the Precision glucose meter. A trained operator then performed a second finger-stick on the patient and tested on the same glucose meter. In addition, the trained operator also performed a veni-puncture to obtain a venous sample from the patient. Venous samples were analyzed on the YSI analyzer (reference method). The glucose concentration range tested was $39 - 485\mathrm{mg / dL}$ and the hematocrit range was $25 - 56\%$ . The linear regressions results were as follows:
Lay user's results (Y) vs. YSI reference method (X):
$$
\mathrm {Y} = 0. 9 4 \mathrm {X} + 1. 6 4, \mathrm {r} = 0. 9 8, \mathrm {N} = 1 5 6
$$
Trained operator's results (Y) vs. YSI reference method (X):
$$
\mathrm {Y} = 0. 9 2 \mathrm {X} + 2. 7 8, \mathrm {r} = 0. 9 9, \mathrm {N} = 1 5 6
$$
In addition, system accuracy based on ISO 15197 acceptance criteria was calculated. Number and % of results within $\pm 15\mathrm{mg / dL}$ (for glucose $< 75~\mathrm{mg / dL}$ ) or within $\pm 20\%$ (for glucose $\geq 75\mathrm{mg / dL}$ ) of YSI reference by User:
{8}
9
| User | Within 15 mg/dL or 20% |
| --- | --- |
| Lay user | (152/156) 97.4% |
| Trained operator | (155/156) 99.4% |
## b. Matrix comparison:
i.) Neonate blood samples were conducted with 175 patients in a clinic against a laboratory plasma method. Capillary samples from the neonates were run in duplicate with 3 different lots of test strips. The glucose concentration range tested was 31-123 mg/dL and the hematocrit range was 27-66%. The linear regressions results were as follows:
Neonate capillary sample (Y) vs. laboratory plasma method (X):
$$
\mathrm {Y} = 1.08 \mathrm {X} - 13.70, \mathrm {r} = 0.96, \mathrm {N} = 330
$$
The overall accuracy according to the ISO acceptance criteria for the neonate samples was as follow:
95.5% (315/330) of results fall within ± 15 mg/dL of YSI reference at glucose concentrations < 75 mg/dL and within ± 20% of YSI reference at glucose concentrations ≥75 mg/dL.
Since the neonatal clinical samples did not cover the claimed measuring range, results from a study of spiked samples with high glucose concentrations and varying hematocrits were provided by the sponsor to demonstrate acceptable performance using ISO acceptance criteria. See Hematocrit study above.
ii.) Venous blood samples using EDTA and heparin samples were conducted with 144 patients against the YSI reference method. The glucose concentration range tested was 70-540 mg/dL (by YSI) and the hematocrit range was 20-50%. The Passing Bablok regressions were as follows:
Regression Results against YSI by Strip Lot
| Tube | Lot | Slope | Intercept (mg/dL) | Slope 95% confidence interval | Intercept 95% confidence interval | r | N |
| --- | --- | --- | --- | --- | --- | --- | --- |
| EDTA | Lot 1 | 0.96 | 12.50 | 0.93 to 0.98 | 9.19 to 15.53 | 0.99 | 190 |
| | Lot 2 | 0.92 | 9.39 | 0.89 to 0.95 | 6.29 to 13.72 | 0.99 | 190 |
| | Lot 3 | 0.93 | 9.56 | 0.90 to 0.95 | 5.53 to 13.07 | 0.99 | 190 |
| Heparin | Lot 1 | 0.96 | 13.06 | 0.93 to 0.99 | 10.21 to15.73 | 0.99 | 184 |
| | Lot 2 | 0.94 | 8.52 | 0.91 to 0.97 | 4.86 to 11.73 | 0.99 | 184 |
| | Lot 3 | 0.93 | 8.52 | 0.90 to 0.96 | 4.82 to 11.88 | 0.99 | 184 |
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The overall accuracy according to the ISO acceptance criteria for the EDTA samples was as follow:
98.9% (564/570) of results fall within ± 15 mg/dL of YSI reference at glucose concentrations < 75 mg/dL and within ± 20% of YSI reference at glucose concentrations ≥75 mg/dL.
The overall accuracy according to the ISO acceptance criteria for the heparin samples was as follow:
98.7% (545/552) of results fall within ± 15 mg/dL of YSI reference at glucose concentrations < 75 mg/dL and within ± 20% of YSI reference at glucose concentrations ≥75 mg/dL.
iii.) Arterial blood samples were conducted with 120 patients in a clinic against a laboratory method and the YSI reference method. The glucose concentration range tested was 43-311 mg/dL (by YSI) and the hematocrit range was 19-50%. The linear regressions results were as follows:
Regression Results against YSI by Strip Lot
| Lot | Slope | Intercept (mg/dL) | Slope 95% confidence interval | Intercept 95% confidence interval | r | N |
| --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 1.00 | 3.87 | 0.98 to 1.03 | 0.38 to 7.11 | 0.98 | 234 |
| Lot 2 | 0.99 | 0.40 | 0.95 to 1.03 | -4.07 to 5.02 | 0.97 | 234 |
| Lot 3 | 0.97 | -0.76 | 0.93 to 1.00 | -4.98 to 3.92 | 0.97 | 233 |
The overall accuracy according to the ISO acceptance criteria were as follow:
99.0% (694/701) of results fall within ± 15 mg/dL of YSI reference at glucose concentrations < 75 mg/dL and within ± 20% of YSI reference at glucose concentrations ≥75 mg/dL.
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 section 2a above.
4. Clinical cut-off:
Not applicable
{10}
5. Expected values/Reference range:
Expected blood glucose levels for people without diabetes (referenced from American Diabetes Association Clinical Practice Recommendations):
The expected glucose range for a non-diabetic, non-pregnant fasting adult is ≤100 mg/dL (5.6 mmol/L). Two hours after meals is ≤140 mg/dL (7.8 mmol/L).
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.
11
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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.