ARCHITECT IVANCOMYCIN REAGENTS AND ARCHITECT IVANCOMYCIN CALIBRATORS, MODELS: 1P30-25 AND 1P30-01
Applicant
Biokit, S.A.
Product Code
LEH · Clinical Toxicology
Decision Date
Mar 19, 2008
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3950
Device Class
Class 2
Indications for Use
The ARCHITECT iVancomycin assay is an in vitro chemiluminescent microparticle immunoassay (CMIA) for the quantitative measurement of vancomycin in human serum or plasma on the ARCHITECT i System with STAT protocol capability. The ARCHITECT iVancomycin assay is used in the diagnosis and treatment of vancomycin overdose and in monitoring levels of vancomycin to help ensure appropriate therapy. The ARCHITECT iVancomycin Calibrators are for the calibration of the ARCHITECT i System with STAT protocol capability when used for the quantitative determination of vancomycin in human serum or plasma.
Device Story
The ARCHITECT iVancomycin assay is a quantitative CMIA for measuring vancomycin in human serum or plasma. It uses a competitive assay principle where sample vancomycin and acridinium-labeled vancomycin conjugate compete for binding sites on anti-vancomycin coated paramagnetic microparticles. The system measures the resulting chemiluminescent signal (RLUs), which is inversely proportional to the vancomycin concentration in the sample. The device is intended for use in clinical laboratories on the ARCHITECT i System with STAT protocol capability. Healthcare providers use the quantitative results to monitor therapeutic drug levels and manage potential overdose, aiding in clinical decision-making regarding antibiotic dosing. The assay provides a reportable range of 0.24–100.00 μg/mL.
Clinical Evidence
Clinical performance demonstrated via correlation study comparing ARCHITECT iVancomycin to AxSYM Vancomycin II, yielding a correlation coefficient of 0.996. Non-clinical performance data provided for precision, linearity, and interferences.
Technological Characteristics
CMIA technology; paramagnetic microparticles; acridinium-labeled conjugate; chemiluminescent detection. System: ARCHITECT i System with STAT protocol. Quantitative measurement via inverse relationship between vancomycin concentration and RLUs.
Indications for Use
Indicated for quantitative measurement of vancomycin in human serum or plasma to assist in diagnosis and treatment of vancomycin overdose and therapeutic drug monitoring.
Regulatory Classification
Identification
A vancomycin test system is a device intended to measure vancomycin, an antibiotic drug, in serum. Measurements obtained by this device are used in the diagnosis and treatment of vancomycin overdose and in monitoring the level of vancomycin to ensure appropriate therapy.
Predicate Devices
AxSYM Vancomycin II (k955851)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k072036
B. Purpose for Submission:
New device
C. Measurand:
Vancomycin
D. Type of Test:
Quantitative Immunoassay
E. Applicant:
Biokit S.A.
F. Proprietary and Established Names:
ARCHITECT iVancomycin Immunoassay
ARCHITECT iVancomycin Calibrators (A-F)
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| LEH - Radio Immunoassay | Class II | 21 CFR 862.3950
Vancomycin test system | Toxicology (91) |
| Product Code | Classification | Regulation Section | Panel |
| DLJ - Calibrator, drug specific | Class II | 21 CFR 862.3200
Clinical toxicology calibrator | Toxicology (91) |
H. Intended Use:
1. Intended use(s):
Refer to indications for use below.
2. Indication(s) for use:
Reagents
The ARCHITECT iVancomycin assay is an in vitro chemiluminescent microparticle immunoassay (CMIA) for the quantitative measurement of vancomycin in human serum or plasma on the ARCHITECT i System with STAT protocol capability. The ARCHITECT iVancomycin assay is used in the diagnosis and treatment of vancomycin overdose and in monitoring levels of vancomycin to help ensure appropriate therapy.
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Calibrators
The ARCHITECT iVancomycin Calibrators are for the calibration of the ARCHITECT i System with STAT protocol capability when used for the quantitative determination of vancomycin in human serum or plasma.
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
To be used with ARCHITECT i System with STAT protocol capability.
I. Device Description:
The device is supplied as ready-to-use, two-reagent kit. Microparticles containing reagent bottle 1 (6.6 mL) contains anti-vancomycin (mouse, monoclonal) coated goat anti-mouse (GAM) microparticles in TRIS buffer with protein (bovine) stabilizer and preservative: ProClin 300. Reagent bottle 2 (5.9 mL) contains Vancomycin acridinium-labeled conjugate in MES buffer with surfactant. Minimum concentration: 50 ng/mL. Preservative: ProClin 300.
J. Substantial Equivalence Information:
1. Predicate device name(s):
AxSYM Vancomycin II
2. Predicate 510(k) number(s):
k955851
3. Comparison with predicate:
Similarities
| Characteristics | New Device (k072036) | AxSYM Vancomycin II (k955851) |
| --- | --- | --- |
| Product Type | Immunoassay | Immunoassay |
| Intended Use (Reagent) | The ARCHITECT iVancomycin assay is an in vitro chemiluminescent microparticle immunoassay (CMIA) for the quantitative measurement of vancomycin in human serum or plasma on the ARCHITECT i System with STAT protocol capability. The ARCHITECT iVancomycin assay is used in the diagnosis and treatment of vancomycin overdose and in monitoring levels of vancomycin to help ensure appropriate therapy. | The AxSYM Vancomycin II assay is a reagent system for the quantitative measurement of vancomycin, an antibiotic drug, in serum or plasma. The measurements obtained are used in monitoring levels of vancomycin to ensure appropriate therapy. |
| Intended Use (Calibrators) | The ARCHITECT Vancomycin Calibrators are for the calibration of the ARCHITECT i System with STAT protocol capability when used for the | The AxSYM Vancomycin II Standard Calibrators are for the standard calibration of the AxSYM System when used for the |
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| Characteristics | New Device (k072036) | AxSYM Vancomycin II (k955851) |
| --- | --- | --- |
| | quantitative determination of vancomycin in human serum or plasma | quantitative determination of vancomycin in human serum or plasma. |
| Where Used | Clinical Laboratories | Clinical Laboratories |
| Assay Protocol | Competitive assay | Competitive assay |
| Interpretation of Results | Standard Curve | Standard Curve |
| Measuring Range | 0.24 μg/mL – 100.00 μg/mL | 2.0 μg/mL – 100 μg/mL |
| Specimen Type | Serum or Plasma (collected in lithium heparin, potassium EDTA, sodium citrate, sodium fluoride/potassium oxalate and sodium heparin tubes) | Serum or Plasma (collected in sodium heparin, citrate, EDTA or oxalate collection tubes) |
| Standardization/ Traceability | Internal Reference Calibrators are manufactured gravimetrically using USP Reference Standard Vancomycin Hydrochloride. The ARCHITECT /Vancomycin Calibrators are matched to the internal Reference Calibrators. | Abbott manufactures internal reference standards using Vancomycin Hydrochloride (USP Reference Standard). Vancomycin calibrators are manufactured gravimetrically and tested against these internal reference standards. |
| Calibrator Levels | 6 levels | 6 levels |
Differences
| Characteristics | New Device (k072036) | AxSYM Vancomycin II (k955851) |
| --- | --- | --- |
| Platform | ARCHITECT i System | AxSYM System |
| Methodology | Chemiluminescent Microparticle Immunoassay (CMIA) | Fluorescence Polarization Immunoassay (FPIA) |
| Matrix | MES buffer and stabilizers | Dextrose buffer and stabilizers |
| Components | Microparticles - 1 bottle (6.6 mL) Anti-vancomycin (mouse, monoclonal) coated goat anti-mouse (GAM) microparticles in TRIS buffer with protein (bovine) stabilizer. Preservative: ProClin 300. Conjugate - 1 bottle (5.9 mL) Vancomycin acridinium-labeled | 1 bottle (15.0mL) < 25% Vancomycin II Antiserum (Mouse, monoclonal) in buffer with protein stabilizers. Preservative: Sodium Azide (Reagent Bottle 1) 1 bottle (8.6 mL) Pretreatment Solution. Surfactant in TRIS buffer. |
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| Characteristics | New Device (k072036) | AxSYM Vancomycin II (k955851) |
| --- | --- | --- |
| | conjugate in MES buffer with surfactant. Minimum concentration: 50 ng/mL. Preservative: ProClin 300. | Preservative: Sodium Azide. (Reagent Bottle 2) 1 bottle (15.1 mL) < 0.01% Vancomycin II Fluorescein Tracer in buffer containing surfactant and stabilizers. Preservative: ProClin 300. (Reagent Bottle 3) |
| Matrix | MES buffer and stabilizers | Dextrose buffer and stabilizers |
K. Standard/Guidance Document Referenced (if applicable):
- CLSI EP5-A2: Evaluation of Precision Performance of Quantitative Measurement Methods; Second Edition
- CLSI EP6-A: Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline.
- CLSI EP17-A: Protocol for Determination of Limits of Detection and Limits of Quantitation; Approved Guideline.
- CLSI EP7-A2: Interference Testing in Clinical Chemistry: Approved Guideline- Second Edition
L. Test Principle:
The ARCHITECT iVancomycin assay is a one-step STAT immunoassay for the quantitative measurement of vancomycin in human serum or plasma using CMIA technology, with flexible assay protocols, referred to as Chemiflex. Sample, anti-vancomycin coated paramagnetic microparticles, and vancomycin acridinium-labeled conjugate are combined to create a reaction mixture. The anti-vancomycin coated microparticles bind to vancomycin present in the sample and to the vancomycin acridinium-labeled conjugate. After washing, pre-trigger and trigger solutions are added to the reaction mixture. The resulting chemiluminescent reaction is measured as relative light units (RLUs). An indirect relationship exists between the amount of vancomycin in the sample and the RLUs detected by the ARCHITECT i System optics.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Following CLSI EP5-A2, the sponsor evaluated the precision using two lots of reagents and three levels of Multiconstituent Controls (MCC Level 1, MCC Level 2, MCC Level 3) and three serum panels prepared by adding vancomycin into a pool of human sera to obtain desired concentration of vancomycin. Precision tests were run on two ARCHITECT i systems. Studies were carried out in duplicates of two runs per day over 20 days (total of 80 data points). The sponsor's acceptance was designed to maintain $\leq 10\%$ total CV. The results are tabulated below.
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| Sample | Instrument/Reagent Lot | n | Mean(μg/mL) | Within RunSD %CV | | Between RunSD %CV | | TotalSD %CV | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Level 1 | 1/1 | 80 | 6.9 | 0.16 | 2.3 | 0.09 | 1.3 | 0.22 | 3.1 |
| | 2/2 | 80 | 6.1 | 0.11 | 1.6 | 0.11 | 1.6 | 0.35 | 5.0 |
| Level 2 | 1/1 | 80 | 20.3 | 0.37 | 1.9 | 0.36 | 1.9 | 0.66 | 3.4 |
| | 2/2 | 80 | 18.6 | 0.39 | 2.0 | 0.23 | 1.2 | 0.95 | 4.9 |
| Level 3 | 1/1 | 80 | 35.9 | 0.66 | 2.0 | 0.86 | 2.6 | 1.15 | 3.5 |
| | 2/2 | 80 | 33.1 | 0.70 | 2.1 | 0.54 | 1.6 | 1.68 | 5.1 |
| Panel 1 | 1/1 | 80 | 6.5 | 0.18 | 2.8 | 0.06 | 0.9 | 0.24 | 3.8 |
| | 2/2 | 80 | 5.7 | 0.14 | 2.3 | 0.05 | 0.9 | 0.27 | 4.4 |
| Panel 2 | 1/1 | 80 | 37.3 | 0.96 | 2.9 | 0.70 | 2.1 | 1.38 | 4.2 |
| | 22 | 80 | 33.8 | 0.87 | 2.7 | 0.14 | 0.4 | 1.60 | 4.9 |
| Panel 3 | 1/1 | 80 | 67.4 | 1.89 | 2.7 | 2.43 | 3.4 | 4.40 | 6.2 |
| | 2/2 | 80 | 70.1 | 2.11 | 3.0 | 1.38 | 2.0 | 3.16 | 4.5 |
b. Linearity/assay reportable range:
The sponsor conducted studies on the T60 instrument to evaluate the dilution recovery of the ARCHITECT iVancomycin assay using CLSI Document EP6-A as a guideline. The sponsor used five pooled frozen serum samples (Vancomycin values: $40 - 86\mu \mathrm{g} / \mathrm{mL}$ ) and a calibrator (Calibrator F: $105\mu \mathrm{g} / \mathrm{mL}$ ) diluted manually with both ARCHITECT iVancomycin Calibrator A and ARCHITECT Multi-assay manual diluent. Each of the five samples was diluted to maintain 11 test concentration levels separately using Calibrator A and multi-assay diluent. Testing was done using one reagent lot and running duplicates of each diluent level. The results demonstrated at each dilution level for all five samples, and for both Calibrator A and ARCHITECT Multi-assay manual diluent, diluted sample values recovered from $98\%$ to $117\%$ . Based on the recovery data and the limit of detection described below, the sponsor established the assay reportable range for ARCHITECT iVancomycin assay as $0.24\mu \mathrm{g} / \mathrm{mL} - 100.00\mu \mathrm{g} / \mathrm{mL}$ .
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The sponsor provides calibrator materials and recommends using commercially available control materials for quality control procedure. The sponsor provided the protocols for preparation and value assignment for calibrators. The Internal Standard Calibrators are manufactured gravimetrically using purified synthetic Vancomycin from the US Pharmacopeia (USP) Reference Standard Vancomycin (Ref. 1709007). The ARCHITECT iVancomycin Calibrators are matched to the Internal Standard Calibrators, which consists of calibrator buffer (MES, Dextrose and ProClin 300), Vancomycin and stabilizer.
The sponsor conducted all stability studies including accelerated stability studies for long-term storage. The sponsor's studies demonstrated the following limits: open-vial stability of 4 months; long-term storage of 8 months; and on-board stability of 30 days. The assay labeling indicates that when the reagent is stored and handled as directed, the reagents are stable until expiration date on the bottle.
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# d. Limit of Detection:
To demonstrate the lower limit of the assay range, the sponsor performed the limit of detection (LOD) and limit of blank (LOB) tests using CLSI document EP17-A "Protocol for Determination of Limits of Detection and Limits of Quantitation; Approved Guideline" The sponsor used 2 instruments, 2 lots of reagents and 2 lots of calibrators for testing on a panel of 4 samples with low vancomycin concentrations and a sample (NHS) with $0\mu \mathrm{g / mL}$ . The samples with vancomycin were prepared by diluting low vancomycin serum sample $(11.6\mu \mathrm{g / mL})$ with NHS sample to achieve concentrations of 1.0, 1.5, 2 and $2.5\mu \mathrm{g / mL}$ . Three runs were performed for each reagent lot. Each run consisted of 20 replicates of NHS $(0\mu \mathrm{g / mL})$ and 5 replicates of each panel member for a total of 60 replicates of NHS and 15 replicates of each panel member were analyzed. Based on the 95th percentile calculation described in the CLSI EP17-A, LOD was determined using the algorithm, $\mathrm{LoD} = \mathrm{LoB} + [1.645 / (1 - 1 / 4\times \mathrm{df})]\sigma \mathrm{S}$ . The mean LOB and LOD were determined as $0.12\mu \mathrm{g / mL}$ and $0.24\mu \mathrm{g / mL}$ , respectively.
# e. Analytical specificity:
Following instructions in CLSI document EP7-A2, the sponsor evaluated the effect of known endogenous interferents on Architect i System using one lot of reagents. The interferents and the test range included triglycerides (2500 mg/dL), hemoglobin (500 mg/dL), low protein (3 g/dL), high protein (10 g/dL), HAMA (1000 ng/mL), rheumatoid factor 500 IU/mL, and bilirubin (20 mg/dL). Five human serum samples with Vancomycin concentrations targeted at 5, 10, 25, 40 and 80 μg/mL were used to prepare the interfering panel. These human serum samples were spiked with the interferent for the test sample. An equal volume of interferent diluent was spiked into the samples to prepare the control sample. The results are listed in the table below. The sponsor claimed no interference with recovery ± 15% for the above interferents and up to the concentrations tested.
| Interferent | Sample | Expected (Control Vanco Conc. μg/mL) | Observed (Test Vanco Conc. μg/mL) | % Recovery | Mean % Recovery |
| --- | --- | --- | --- | --- | --- |
| Hemoglobin 500 mg/dL | 1 | 4.5 | 4.6 | 101.5 | 104.4 |
| | 2 | 8.9 | 9.4 | 104.6 | |
| | 3 | 22.1 | 22.8 | 102.8 | |
| | 4 | 39.8 | 42.1 | 105.9 | |
| | 5 | 76.6 | 82.0 | 107.1 | |
| Bilirubin 20 mg/dL | 1 | 4.3 | 4.3 | 100.0 | 101.6 |
| | 2 | 8.7 | 8.7 | 100.2 | |
| | 3 | 21.4 | 21.5 | 100.7 | |
| | 4 | 39.1 | 39.9 | 102.1 | |
| | 5 | 73.1 | 76.9 | 105.1 | |
| Triglycerides 2500 mg/dL | 1 | 4.5 | 4.6 | 101.7 | 99.9 |
| | 2 | 9.1 | 9.0 | 98.7 | |
| | 3 | 23.1 | 23.1 | 99.9 | |
| | 4 | 42.3 | 41.9 | 99.1 | |
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| Interferent | Sample | Expected (Control Vanco Conc. μg/mL) | Observed (Test Vanco Conc. μg/mL) | % Recovery | Mean % Recovery |
| --- | --- | --- | --- | --- | --- |
| | 5 | 83.7 | 83.6 | 99.9 | |
| High Protein 10 g/dL (100g/L)* | 2 | 8.7 | 8.7 | 100.0 | 98.9 |
| | 6 | 13.7 | 13.3 | 97.3 | |
| | 3 | 21.9 | 22.4 | 101.9 | |
| | 4 | 40.5 | 39.1 | 96.5 | |
| | 5 | 77.9 | 76.9 | 98.7 | |
| Low Protein 3 g/dL (30 g/L)* | 2 | 8.7 | 8.4 | 96.9 | 106.6 |
| | 6 | 13.7 | 14.3 | 104.2 | |
| | 3 | 21.9 | 23.6 | 107.5 | |
| | 4 | 40.5 | 44.5 | 110.0 | |
| | 5 | 77.9 | 89.2 | 114.5 | |
| RF 500 IU/mL | 1 | 4.3 | 4.3 | 99.0 | 99.3 |
| | 2 | 8.6 | 8.4 | 98.2 | |
| | 3 | 21.0 | 21.5 | 102.1 | |
| | 4 | 38.7 | 38.7 | 99.8 | |
| | 5 | 75.3 | 73.3 | 97.3 | |
| HAMA 1000 ng/mL | 1 | 4.6 | 4.6 | 101.1 | 99.8 |
| | 2 | 9.0 | 8.9 | 99.0 | |
| | 3 | 22.2 | 22.5 | 101.1 | |
| | 4 | 40.9 | 40.4 | 98.7 | |
| | 5 | 76.7 | 76.0 | 99.2 | |
* Sample 1 when diluted had an initial concentration of Vancomycin less than 2μg/mL, less than the designed LoD of the assay. An additional sample 6 target at 15μg/mL was added to the data set.
Following CLSI EP7-A2 guidelines, the sponsor conducted a study to evaluate the potential cross-reactivity of the ARCHITECT iVancomycin assay when tested with structurally similar compounds. A pool of sera containing essentially no residual vancomycin was split into 3 different parts. Two parts were spiked with vancomycin to reach target concentrations of 7 and 35 μg/mL and the third part was not spiked with vancomycin. Therapeutic interferents listed in the table below were dissolved at concentrations 20 times greater than the desired testing concentrations. Therapeutic concentrates were spiked into the samples above to prepare the test sample and an equal volume of the interferent diluent was spiked to the samples to prepare the control sample. Each sample was tested in three replicates. Based on these studies, the sponsor demonstrated when there is no vancomycin present, all tested therapeutics have no potential cross-reactivity above the LOD. In the presence of vancomycin, no influence from tested therapeutics was observed based on the criteria, change in vancomycin measured should be less than the designed LOD of the assay and the mean % Recovery of Vancomycin is 100 +/- 10%.
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Potential interfering therapeutics with ARCHITECT iVancomycin assay tested at a concentration of 500 µg/mL (exception: CDP-1 was tested at 50 µg/mL and Methotrexate, tested at 227 µg/mL).
| Acetaminophen | Chlorothiazide | Isoniazid | Rifampin |
| --- | --- | --- | --- |
| Amikacin | Ciprofloxacin | Kanamycin B | Salicylic acid |
| Amphotericin B | Erythromycin | Methotrexate | Spectinomycin |
| Ampicillin | Ethambutol | Methylprednisolone | Streptomycin |
| Caffeine | 5-fluorocytosine | Naproxen | Sulfadiazine |
| CDP-1 | Furosemide | Neomycin | Sulfamethixazole |
| Cephalexin | Gentamicin | Nirtrofurantoin | Tetracycline |
| Cephalosporin C | Heparin | Penicillin G | Ticarcillin |
| Cephalothin | Hydrochlorothiazide | Penicillin V | Tobramycin |
| Clindamycin | Ibuprofen | Prednisolone | Trimethoprim |
| Chloramphenicol | | | |
f. Assay cut-off:
Not Applicable.
2. Comparison studies:
a. Method comparison with predicate device:
To demonstrate the substantial equivalence to the predicate device, the sponsor conducted a method comparison study with samples using ARCHITECT iVancomycin Reagent on ARCHITECT i System and Abbott AxSYM Vancomycin II. Using a total of 206 frozen serum samples (range: 0-100 µg/mL) (86 samples were spiked to achieve concentrations of 40-100 µg/mL, 120 natural samples ranged from 0-40 µg/mL), the study was performed over 4 days, generating calibration curves on each testing day. Samples that fell within the measuring range for each assay were used for calculations. A total of 192 samples were used for calculations. The analysis of data using Passing & Bablok and least squares method produced regression equations y = 0.9249x + 0.0502 and y = 0.9016x + 0.7905. The following table demonstrates the correlation between the two methods. Fourteen samples were not included in the analysis because they were below the detection limit.
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| ARCHITECT vs. AxSYM | | 95% CI | |
| --- | --- | --- | --- |
| Correlation Coefficient (Pearson) | 0.9964 | 0.9952 | 0.9973 |
| Passing & Bablok slope | 0.9249 | 0.9123 | 0.9381 |
| Passing & Bablok intercept | 0.0502 | -0.1172 | 0.2509 |
| Linear (least square) Regression slope | 0.9016 | 0.8906 | 0.9126 |
| Linear Regression (least square) intercept | 0.7905 | 0.2915 | 1.2895 |
| Concentration range AxSYM (μg/mL) | | 2.1-94.3 | |
| Concentration range ARCHITECT (μg/mL) | | 1.4-83.5 | |
| N | | 192 | |
A bias analysis of ARCHITECT iVancomycin vs AxSYM Vancomycin II performed on the same 192 specimens (2.1 to $94.3~\mu \mathrm{g / Ml}$ ) exhibited an average bias of $-7.29\%$ (95% CI: -23.40 to $8.82\%$ ). Within the typical therapeutic range of vancomycin therapy (5-40 $\mu \mathrm{g / mL}$ ), the average bias was $-4.41\%$ (95% CI: -19.51 to $10.70\%$ ).
# b. Matrix comparison:
The sponsor conducted matrix comparison studies using 20 matched serum and plasma samples prepared with five different anticoagulants (K-EDTA, Na-Citrate, Na-Fluoride/K-Oxalate, Na-Heparin and Li-Heparin) used for plasma. Serum tubes without anticoagulants were used as the control. To evaluate the anticoagulant effect along the assay measuring range, each of the 20 sets of serum/plasma tubes were spiked with vancomycin to obtain 10 different spiking concentrations. (5, 7.5, 10, 15, 20, 30, 40, 60, 70 and $80~\mu \mathrm{g / mL}$ ). The samples were analyzed in triplicate with one lot of ARCHITECT iVancomycin reagents on the ARCHITECT i System. Based on the sponsor's acceptance criteria of mean $\%$ recovery value within $100\pm 10\%$ of the serum value, data tabulated below supports the plasma can be used to determine the vancomycin level in blood.
| Sample type | No. | Mean % recovery vs. Serum |
| --- | --- | --- |
| Serum with no additive | 20 | Control |
| K-EDTA | 20 | 100.6 |
| Na-Citrate | 20 | 106.9 |
| Na-Fluoride/K-Oxalate | 20 | 101.0 |
| Na-Heparin | 20 | 101.4 |
| Li-Heparin | 20 | 101.2 |
# 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):
# 4. Clinical cut-off: Not Applicable.
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5. Expected values/Reference range*:
In the labeling, the sponsor states, as supported by literature, therapeutic peak serum levels of 20 to 40 µg/mL and trough levels of 5 to 10 µg/mL have been reported to be effective for most strains of staphylococci and streptococci. The sponsor recommends in the labeling that users establish the therapeutic levels of vancomycin based on patient differences and bacterial susceptibility. For diagnostic purposes, the test findings should always be assessed in conjunction with the patient’s medical history, clinical examinations, and other findings.
* 1. Wilhelm MP. Vancomycin. Mayo Clin Proc 1991;66:1165–70.
* 2. Cook FV, Farrar WE Jr. Vancomycin revisited. Ann Intern Med 1978;88(6):813–8.
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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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.