The EasyRA amylase Reagent (AMY) is for the measurement of a-Amylase in serum using the "EasyRA chemistry analyzer". Amylase measurements are used for the diagnosis and treatment of pancreatitis (inflammation of the pancreas) and other pancreatic disorders. For in vitro diagnostic use only. The EasyRA Blood Urea Nitrogen (BUN) Reagent is for the measurement of urea in serum using the "EasyRA chemistry analyzer". Urea measurements in serum are used for the diagnosis and treatment of certain renal and metabolic diseases. For in vitro diagnostic use only. The EasyRA Glucose hexokinase (GLU-H) Reagent is for the measurement of glucose in serum using the "EasyRA chemistry analyzer". Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and pancreatic islet cell carcinoma. . For in vitro diagnostic use only. The EasyRA Triglyceride (TRIG) Reagent is for the measurement of triglycerides in serum using the "EasyRA chemistry analyzer". Triglyceride measurements are used in the diagnosis and treatment of diabetes mellitus, nephrosis, liver obstruction, and other diseases involving lipid metabolism or various endocrine disorders. For in vitro diagnostic use only. The EasyRA Uric Acid (URIC) Reagent is for the measurement of uric acid in serum using the "EasyRA chemistry analyzer". Uric Acid measurements are used in the diagnosis and treatment of renal and metabolic disorders, including renal failure, gout, leukemia, psoriasis, starvation or other wasting conditions, and of patients receiving cytotoxic drugs. For in vitro diagnostic use only.
Device Story
Reagents for use on Medica EasyRA chemistry analyzer; measure amylase, BUN, glucose, triglycerides, and uric acid in human serum. Reagents provided in ready-to-use plastic wedges. Analyzer performs enzymatic reactions; monitors absorbance changes spectrophotometrically (Beer's Law). Used in clinical laboratory settings by trained personnel. Output provides quantitative analyte concentration; assists clinicians in diagnosing/treating conditions like pancreatitis, diabetes, renal failure, and lipid metabolism disorders. Benefits include rapid, automated diagnostic testing.
Clinical Evidence
No clinical data provided; substantial equivalence is based on bench testing and performance characteristics of the reagents on the EasyRA chemistry analyzer.
Technological Characteristics
Liquid, ready-to-use reagents in plastic wedges. Enzymatic reaction principles (e.g., hexokinase, urease, lipase, uricase). Detection via spectrophotometry at specific wavelengths (340 nm to 700 nm). Designed for use on Medica EasyRA chemistry analyzer. Storage 2–8 °C.
Indications for Use
Indicated for patients requiring quantitative measurement of amylase, BUN, glucose, triglycerides, or uric acid in serum to aid in the diagnosis and treatment of pancreatic, renal, metabolic, or lipid disorders.
Regulatory Classification
Identification
An amylase test system is a device intended to measure the activity of the enzyme amylase in serum and urine. Amylase measurements are used primarily for the diagnosis and treatment of pancreatitis (inflammation of the pancreas).
Submission Summary (Full Text)
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k080823
B. Purpose for Submission:
New device
C. Measurand:
Amylase, Blood Urea Nitrogen (BUN), Glucose, Triglyceride, Uric Acid
D. Type of Test:
Amylase-enzymatic reaction
Blood Urea Nitrogen (BUN)-kinetic reaction
Glucose-enzymatic reaction
Triglyceride-enzymatic reaction
Uric acid
E. Applicant:
Medica Corporation
F. Proprietary and Established Names:
EasyRA Amylase Reagent
EasyRA Blood Urea Nitrogen (BUN) Reagent
EasyRA Glucose-Hexokinase Reagent
EasyRA Triglyceride Reagent
EasyRA Uric Acid Reagent
G. Regulatory Information:
| Device Classification Name | Device Classification | Regulation Number | Product Code | Panel |
| --- | --- | --- | --- | --- |
| Amylase | Class II | 21 CFR 862.1070 | JFJ | Chemistry (75) |
| Urea Nitrogen | Class II | 21 CFR 862.1770 | CDQ | Chemistry (75) |
| Hexokinase, glucose | Class II | 21 CFR 862.1345 | CFR | Chemistry (75) |
| Triglyceride | Class I * | 21 CFR 862.1705 | CDT | Chemistry (75) |
| Uric acid | Class I, reserved | 21 CFR 862.1775 | KNK | Chemistry (75) |
*Meets limitations to exemption in 21 CFR 862.9(c)(4)
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H. Intended Use:
1. Intended use(s):
EasyRA Amylase Reagent
The EasyRA amylase Reagent (AMY) is for the measurement of a-Amylase in serum using the “EasyRA chemistry analyzer”. Amylase measurements are used for the diagnosis and treatment of pancreatitis (inflammation of the pancreas) and other pancreatic disorders. For *in vitro* diagnostic use only.
EasyRA Blood Urea Nitrogen (BUN) Reagent
The EasyRA Blood Urea Nitrogen (BUN) Reagent is for the measurement of urea in serum using the “EasyRA chemistry analyzer”. Urea measurements in serum are used for the diagnosis and treatment of certain renal and metabolic diseases. For *in vitro* diagnostic use only.
EasyRA Glucose-Hexokinase Reagent
The EasyRA Glucose hexokinase (GLU-H) Reagent is for the measurement of glucose in serum using the “EasyRA chemistry analyzer”. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and pancreatic islet cell carcinoma. For *in vitro* diagnostic use only.
EasyRA Triglyceride Reagent
The EasyRA Triglyceride (TRIG) Reagent is for the measurement of triglycerides in serum using the “EasyRA chemistry analyzer”. Triglyceride measurements are used in the diagnosis and treatment of diabetes mellitus, nephrosis, liver obstruction, and other diseases involving lipid metabolism or various endocrine disorders. For *in vitro* diagnostic use only.
EasyRA Uric Acid Reagent
The EasyRA Uric Acid (URIC) Reagent is for the measurement of uric acid in serum using the “EasyRA chemistry analyzer”. Uric Acid measurements are used in the diagnosis and treatment of renal and metabolic disorders, including renal failure, gout, leukemia, psoriasis, starvation or other wasting conditions, and of patients receiving cytotoxic drugs. For *in vitro* diagnostic use only.
2. Indication(s) for use:
See intended use(s) above.
3. Special conditions for use statement(s):
For prescription use.
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4. Special instrument requirements:
Medica EasyRA chemistry analyzer
I. Device Description:
The EasyRA Amylase test is provided in 4 ready-to-use plastic wedges, each containing 39 mL of reagent. The reagent consists of a MES buffer with 2-chloro-4-nitrophenol-α-D-maltotrioside (CNPG3), sodium chloride, sodium acetate, calcium acetate, potassium thiocyanate, and sodium azide.
The EasyRA BUN test is provided in 4 ready-to-use plastic wedges, each containing 39 mL of reagent. The reagent consists of buffer with alpha-ketoglutarate, urease, glutamate dehydrogenase, adenosine diphosphate, NADH analog, stabilizers and preservatives.
The EasyRA Glucose test is provided in 4 ready-to-use plastic wedges, each containing 39 mL of reagent. The reagent consists of buffer, nicotinamide adenine dinucleotide (NAD), adenosine triphosphate (ATP), magnesium, hexokinase, glucose-6-phosphate dehydrogenase, stabilizers, and preservatives.
The EasyRA Triglycerides test is provided in 4 ready-to-use plastic wedges, each containing 37 mL of reagent. The reagent consists of buffer, magnesium (Mg++), p-chlorophenol, ATP, 4-aminoantipyrine, lipoprotein lipase, glycerol kinase, G-3-P oxidase, horseradish peroxidase, stabilizers and preservatives.
The EasyRA Uric Acid test is provided in 4 ready-to-use plastic wedges, each containing 37 mL of reagent. The reagent consists of 3,5-dichloro-2-hydroxybenzene sulfonate (DHBS), 4-aminoantipyrine, horseradish peroxidase, uricase, stabilizers and preservatives.
J. Substantial Equivalence Information:
1. Predicate device name(s):
Roche Diagnostics α-Amylase Reagent
Roche Diagnostics BUN Reagent
Roche Diagnostics Glucose Reagent
Roche Diagnostics Triglycerides Reagent
Roche Diagnostics Uric Acid Reagent
2. Predicate K number(s):
k933397, k011843, k002694, k961282, k961281, k961586
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3. Comparison with predicate:
| Amylase Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica Amylase Reagent | Roche α-Amylase Reagent |
| Intended Use | Clinical chemistry reagent used to provide a quantitative measurement of amylase in human serum, using the EasyRA chemistry analyzer. | Clinical chemistry reagent used to provide a quantitative measurement of amylase in human serum, using an automated chemical analyzer |
| Test Methodology | An enzymatic reaction based on the catalytic activity of a serum based enzyme, which is quantified by monitoring the reaction rate. The chromogen absorbs light of specific wavelength, where the EasyRA measures absorbance according to Beer's law. | An enzymatic reaction based on the catalytic activity of a serum based enzyme, which is quantified by monitoring the reaction rate. The chromogen absorbs light of specific wavelength, where the COBAS-Mira measures absorbance according to Beer's law. |
| Sample type | Serum | Serum |
| Reagent type | Liquid ready-for-use | Liquid ready-for-use |
| Linearity range | 2 – 1200 U/L | Up to 2000 U/L |
| Wavelength | 405 nm | 405 nm |
| Reaction type | Enzyme | Enzyme |
| BUN Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica EasyRA BUN | Roche BUN Reagent |
| Intended Use | Clinical chemistry reagent used to provide a quantitative measurement of urea in human serum, using the EasyRA chemistry analyzer. | Clinical chemistry reagent used to provide a quantitative measurement of urea in human serum, using an automated chemical analyzer |
| Test Methodology | An enzymatic reaction of Urea to L-glutamate with the concurrent reduction of NADH to NAD. The rate of change in absorption of the NADH chromogen is monitored with time on the EasyRA to establish the amount of urea | An enzymatic reaction of Urea to L-glutamate with the concurrent reduction of NADH to NAD. The rate of change in absorption of the NADH chromogen is monitored with time on the Cobas- |
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| Gucose Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica EasyRA Bln | Roche Bln Reagent |
| | present. | Mira to establish the amount of urea present. |
| Sample type | Serum | Serum |
| Reagent type | Liquid ready-for-use | Liquid ready-for-use |
| Linearity range | 1.0 – 70.0 mg/dL | Up to 80 mg/dL |
| Wavelength | 340 nm | 340 nm |
| Reaction type | Kinetic | Kinetic |
| Reagent storage | 2 – 8 °C | 2 – 8 °C |
| Glucose Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica EasyRA Glu | Roche Glucose Reagent |
| Intended Use | Clinical chemistry reagent used to provide a quantitative measurement of Glucose in human serum, using the EasyRA chemistry analyzer. | Clinical chemistry reagent used to provide a quantitative measurement of Glucose in human serum, using an automated chemical analyzer |
| Test Methodology | An enzymatic reaction based on the complete oxidation of glucose in serum and the simultaneous reduction on NAD to NADH (chromogen). The chromogen absorbs light of specific wavelength, where the EasyRA measures absorbance according to Beer's law. | An enzymatic reaction based on the complete oxidation of glucose in serum and the simultaneous reduction on NAD to NADH (chromogen). The chromogen absorbs light of specific wavelength, where the COBAS-Mira measures absorbance according to Beer's law. |
| Sample type | Serum | Serum |
| Reagent type | Liquid ready-for-use | Liquid ready-for-use |
| Linearity range | 2 – 600 mg/dL | Up to 800 mg/dL |
| Wavelength | 340 nm | 340 nm |
| Reaction type | End point | End point |
| Reagent storage | 2 – 8 °C | 2 – 8 °C |
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| Triglycerides Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica EasyRA Trig | Roche Triglycerides |
| Intended Use | Clinical chemistry reagent used to provide a quantitative measurement of triglycerides in human serum, using the EasyRA chemistry analyzer. | Clinical chemistry reagent used to provide a quantitative measurement of triglycerides in human serum, using an automated chemical analyzer |
| Test Methodology | An enzymatic reaction based on the catalytic activity of a serum based enzyme, which is quantified by monitoring the reaction rate. The chromogen absorbs light of specific wavelength, where the EasyRA measures absorbance according to Beer's law. | An enzymatic reaction based on the catalytic activity of a serum based enzyme, which is quantified by monitoring the reaction rate. The chromogen absorbs light of specific wavelength, where the COBAS-Mira measures absorbance according to Beer's law. |
| Sample type | Serum | Serum |
| Reagent type | Liquid ready-for-use | Liquid ready-for-use |
| Linearity range | 3 – 750 mg/dL | Up to 900 mg/dL |
| Wavelength | 520/700 nm | 550 nm |
| Reaction type | End point | End point |
| Reagent storage | 2 – 8 °C | 2 – 8 °C |
| Uric Acid Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica Easy RA Uric Acid | Roche Uric Acid |
| Intended Use | Clinical chemistry reagent used to provide a quantitative measurement of uric acid in human serum, using the EasyRA chemistry analyzer. | Clinical chemistry reagent used to provide a quantitative measurement of uric acid in human serum, using an automated chemical analyzer |
| Test Methodology | An enzymatic reaction based on the oxidation of Uric Acid to produce hydrogen peroxide in the presence of uricase. The H2O2is further reduced to produce a chromogen. The chromogen absorption is | An enzymatic reaction based on the oxidation of Uric Acid to produce hydrogen peroxide in the presence of uricase. The H2O2is further reduced to produce a chromogen. The chromogen absorption is |
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| Uric Acid Similarities and Differences | | |
| --- | --- | --- |
| Item | Medica Easy RA Uric Acid | Roche Uric Acid |
| | measured by the EasyRA and is directly related to the Uric Acid concentration using Beer’s Law. | reduced to produce a chromogen. The chromogen absorption is measured by the Cobas-Mira and is directly related to the Uric Acid using Beer’s Law. |
| Reagent type | Liquid ready-for-use | Liquid ready-for-use |
| Linearity range | 0.11 – 12 mg/dL | Up to 20 mg/dL |
| Wavelength | 520/600 nm | 550 nm |
| Reaction type | End point | End point |
| Reagent storage | 2 – 8 °C | 2 – 8 °C |
## K. Standard/Guidance Document Referenced (if applicable):
Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline (CLSI EP6-A)
Method Comparison and Bias Estimation Using Patient Samples; Approved Guideline-Second Edition (CLSI EP9-A2)
Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline- Second Edition (CLSI EP5-A2)
## L. Test Principle:
The Medica EasyRA Amylase test involves the use of a chromogenic substrate, 2-chloro-4-nitrophenol-α-D-maltotrioside (CNPG3). The rate of hydrolysis of CNPG3 by α-amylase to release 2-Chloro-4-nitrophenol can be detected spectrophotometrically to give a direct measurement of α-amylase activity in the sample.
For the Medica EasyRA BUN test, urea in the sample is first hydrolyzed by urease to give ammonia and carbon dioxide. The ammonia produced reacts with 2-oxoglutarate and stabilized NADH analog in the presence of glutamate dehydrogenase (GLDH) to form glutamate and NAD (II). The decrease in the concentration of the reduced cofactor (NADH), monitored at 340 nm is proportional to the concentration of the Urea in the sample.
For the Medica EasyRA GLU-H test, glucose is phosphorylated to form glucose-6-phosphate (G-6-P). G-6-P is then oxidized by glucose-6-phosphate dehydrogenase in the presence of NAD producing 6-phosphogluconate and NADH. The formation of
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NADH causes an increase in absorbance at 340 nm, which is proportional to the concentration of the glucose in the sample.
For the Medica EasyRA TRIG test, serum triglycerides are hydrolyzed to glycerol and free fatty acids by lipase. In the presence of ATP and glycerol kinase (GK), the glycerol is phosphorylated to glycerol-1-phosphate, which is then oxidized by glycerol phosphate oxidase (GPO) to produce hydrogen peroxide. The hydrogen peroxide causes oxidative coupling of p-chlorophenol and 4 amino-antipyrine, which produces a red colored quinoneimine dye complex. The absorbance of the dye at 520 nm is proportional to the concentration of triglyceride in the sample.
For the Medica EasyRA Uric acid test, hydrogen peroxide is formed by the action of uricase on uric acid. The hydrogen peroxide is then reacted with 3,5-dichloro-2-hydroxybenzene sulfonate (DHBS) and 4-aminoantipyrine forming a red colored quinoneimine dye, with maximum absorbance at 520 nm.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Within Run and Total precision were determined following CLSI EP-A2. Three levels of commercial serum-based Quality Control material were tested on one EasyRA analyzer twice a day over a twenty-day period. The data is summarized below.
Additionally, to verify precision in the extended measuring range of each test (see section 1.b. below), one sample was diluted 1:2 with saline on board the analyzer and assayed twenty times (n=20) in one assay run.
Amylase
| | Level 1 | Level 2 | Level 3 | Diluted |
| --- | --- | --- | --- | --- |
| Mean (U/L) | 45 | 85 | 296 | 1781 |
| Within Run Precision: | | | | |
| Std. Dev. | 0.8 | 0.7 | 1.9 | |
| CV % | 1.8 | 0.8 | 0.6 | 0.9 |
| Total Precision: | | | | |
| Std. Dev. | 0.9 | 0.9 | 2.9 | |
| CV% | 1.9 | 1.1 | 1.0 | |
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BUN
| | Level 1 | Level 2 | Level 3 | Diluted |
| --- | --- | --- | --- | --- |
| Mean (mg/dL) | 15.2 | 21.3 | 55.0 | 96.2 |
| Within Run Precision: | | | | |
| Std. Dev. | 0.19 | 0.33 | 0.41 | |
| CV% | 1.28 | 1.55 | 0.74 | 1.4 |
| Total Precision: | | | | |
| Std. Dev. | 0.29 | 0.39 | 0.68 | |
| CV% | 1.93 | 1.90 | 1.24 | |
Glucose Hexokinase
| | Level 1 | Level 2 | Level 3 | Diluted |
| --- | --- | --- | --- | --- |
| Mean (mg/dL) | 61 | 111 | 270 | 805 |
| Within Run Precision: | | | | |
| Std. Dev. | 0.7 | 0.7 | 1.1 | |
| CV% | 1.1 | 0.6 | 0.4 | 1.98 |
| Total Precision: | | | | |
| Std. Dev. | 0.9 | 1.5 | 2.6 | |
| CV% | 1.5 | 1.4 | 1.0 | |
Triglycerides
| | Level 1 | Level 2 | Level 3 | Diluted |
| --- | --- | --- | --- | --- |
| Mean (mg/dL) | 78 | 90 | 252 | 1324 |
| Within Run Precision: | | | | |
| Std. Dev. | 0.7 | 0.6 | 1.3 | |
| CV% | 0.9 | 0.6 | 0.5 | 1.98 |
| Total Precision: | | | | |
| Std. Dev. | 1.6 | 1.0 | 2.8 | |
| CV% | 2.0 | 1.2 | 1.1 | |
Uric Acid
| | Level 1 | Level 2 | Level 3 | Diluted |
| --- | --- | --- | --- | --- |
| Mean (mg/dL) | 4.37 | 4.16 | 9.70 | 31.9 |
| Within Run Precision: | | | | |
| Std. Dev. | 0.04 | 0.05 | 0.07 | |
| CV% | 0.94 | 1.30 | 0.70 | 0.51 |
| Total Precision: | | | | |
| Std. Dev. | 0.19 | 0.18 | 0.23 | |
| CV% | 4.36 | 4.36 | 2.35 | |
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b. Linearity/assay reportable range:
Linearity studies were performed following the CLSI protocol EP6-A. Commercially available linearity standards were used unless noted otherwise.
Amylase
For the Amylase assay, the concentrations of samples tested ranged from 1 to 1360 U/L. The data was analyzed using linear regression as well as second and third order non-linear fitted polynomial regression. The third order model fit the data better than the linear and second order models. However, for all dilution points the relative differences between the linear and third order models were within ±15% or below the medical decision point of 100 U/L ±15 U/L. The results are summarized below.
Fitted regression models are:
Linear: y = 1.0007x + 1.2297, Std. Error=16.487
Second order: y = 2E-05x² + 0.9733x + 4.0426, Std. Error 16.559
Third order: y = 1E-07x³ - 0.0002x² + 1.0785x - 0.1589,
Std. Error=15.434
The results of this study support the sponsor's claim that the device is linear from 2 U/L to 1200 U/L.
The extended measuring range (1201 to 2400 U/L) was evaluated with four standards with target values ranging from 1100 to 2400 U/L. Recovery with the Easy RA on-board dilution was compared to manual dilutions. Recoveries ranged from 99% to 103%.
BUN
For the BUN assay, the concentrations of samples tested ranged from 0.9 to 73.7 mg/dL. A BUN stock solution was prepared gravimetrically from commercially available material. Dilutions of varying BUN concentration were then prepared using saline and tested. The data was analyzed using linear regression as well as second and third order non-linear fitted polynomial regression. The third order model fit the data better than the linear and second order models. However, for all dilution points the relative differences between the first and third order models were within ±4.5% or ±1.22 mg/dL at or below the medical decision point of 27 mg/dL. The results are summarized below.
Fitted regression models are:
Linear: y = 0.9593 x + 0.5657, Std. Error=0.715
Second order: y = -0.0011x² + 1.0329 x + 0.0669, Std. Error=0.494
Third order: y = -1E-05x³ - 0.0004x² + 0.9923x - 0.2103,
Std. Error=0.493
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The results of this study support the sponsor’s claim that the device is linear from 1 mg/dL to 70 mg/dL.
The extended measuring range (71 to 140 mg/dL) was evaluated with four standards with values ranging from 90 to 130 mg/dL. Recovery with the Easy RA on-board dilution was compared to manual dilutions. Recoveries ranged from 99% to 102%.
## Glucose-hexokinase
For the Glucose assay, the concentrations of samples tested ranged from 2 to 716 mg/dL. The data was analyzed using linear regression as well as second and third order non-linear fitted polynomial regression; however, the first order regression had the best fit. The analysis yielded the following equation:
Linear: $y = 0.9898x + 1.39$, Std. Error=3.451
The results of this study support the sponsor’s claim that the device is linear from 2 mg/dL to 600 mg/dL.
The extended measuring range (601 to 1200 mg/dL) was evaluated with three standards with values ranging from 675 to 1062 mg/dL. Recovery with the Easy RA on-board dilution was compared to manual dilutions. Recoveries ranged from 98% to 99%.
## Triglycerides
For the Triglycerides assay, the concentrations of samples tested ranged from 2 to 852 mg/dL. The data was analyzed using linear regression as well as second and third order non-linear fitted polynomial regression. The third order model fit the data better than the linear and second order models. However, for all dilution points the relative differences between the first and third order models were within ±12.5% or ±20 mg/dL below the medical decision point of 160 mg/dL. The results are summarized below.
Fitted regression models are:
Linear: $y = 0.9794x + 2.085$, Std. Error=4.094
Second order: $y = -7E - 05x^2 + 1.03x - 1.6287$, Std. Error=1.825
Third order: $y = -6E - 08x^3 - 8E - 06x^2 + 1.007x - 0.9432$
Std. Error= 1.651
The results of this study support the sponsor’s claim that the device is linear from 3 mg/dL to 750 mg/dL.
The extended measuring range (751 to 1400 mg/dL) was evaluated with three standards with values ranging from 798 to 1228 mg/dL. Recovery with the Easy RA on-board dilution was compared to manual dilutions. Recoveries ranged from 101-102%.
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# Uric Acid
For the uric acid assay, the concentrations of samples tested ranged from 0.11 to 23.46 mg/dL. The data was analyzed using linear regression as well as second and third order non-linear fitted polynomial regression. The third order model fit the data better than the linear and second order models. However, for all dilution points the relative differences between the first and third order models were within ±8.5% or ±0.51 mg/dL, whichever is greater. The results are summarized below.
Fitted regression models are:
Linear: y = 1.0336 x - 0.173, Std. Error=0.279
Second order: y = 0.005x² + 0.9246 x + 0.0315, Std. Error=0.093
Third order: y = -0.0002x³ + 0.0017x² + 0.867x + 0.0827,
Std. Error=0.076
The results of this study support a claimed assay range of 0.11 to 12 mg/dL.
The extended measuring range (12 to 24 mg/dL) was evaluated with two standards with values 19.6 and 25 mg/dL. Recovery with the Easy RA on-board dilution was compared to manual dilutions. Recoveries were 98% for each standard tested.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Calibrators and controls were reviewed under a separate 510(k) and are sold separately.
d. Detection limit:
To determine the limit of blank (LoB) for each EasyRA test (Amylase, BUN, Glucose, Triglyceride, Uric Acid) deionized water was assayed twenty (20) times on each of three Easy RA analyzers for a total of sixty (60) replicates. The data were analyzed following the recommendations in CLSI EP 17.
To determine the limit of detection (LoD) for each test a serum sample with low analyte concentration was prepared and analyzed 20 times on each of three EasyRA analyzers.
The results for LoB and LoD are summarized in the following table:
| Device | LoB | LoD |
| --- | --- | --- |
| Amylase | 0.78 U/L | 1.04 U/L |
| BUN | 0.68 mg/dL | 1.0 mg/dL |
| Glucose | 0.56 mg/dL | 1.0 mg/dL |
| Triglycerides | 1.35 mg/dL | 2.16 mg/dL |
| Uric Acid | 0.065 mg/dL | 0.11 mg/dL |
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e. Analytical specificity:
Evaluation of interfering substances was based on CLSI EP-7A and performed at two concentrations of analyte. Samples with increasing amounts of hemoglobin, bilirubin or triglycerides (Intralipid®) were tested and compared to the same sample without added interferent, unless otherwise noted.
Studies to evaluate potential lipid interference in the Glu-H test were performed using LipoClear lipid clearing reagent.
The sponsor defined interference as the highest level tested that does not cause >10% change in analytical result.
The results are summarized in the table below.
| | Analyte level tested | No interference up to |
| --- | --- | --- |
| Amylase | | |
| Hemoglobin | 68 U/L, 92 U/L | 125 mg/dL |
| | | |
| Triglyceride | 57 U/L, 97 U/L | 1374 mg/dL |
| | | |
| Bilirubin | 86 U/L, 93 U/L | 25 mg/dL |
| | | |
| BUN | | |
| Hemoglobin | 16.2 mg/dL, 28 mg/dL | 300 mg/dL |
| | | |
| Triglyceride | 18.1 mg/dL, 31.6 mg/dL | 811 mg/dL |
| | | |
| Bilirubin | 19.6 mg/dL, 30 mg/dL | 20 mg/dL |
| | | |
| Glu-H | | |
| Hemoglobin | 42 mg/dL, 94 mg/dL | 31 mg/dL |
| | | |
| Triglyceride | 150 mg/dL, 250 mg/dL | 450mg/dL |
| | | |
| Bilirubin | 45 mg/dL, 82 mg/dL | 10 mg/dL |
| | | |
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| Triglycerides | | |
| --- | --- | --- |
| Hemoglobin | 136 mg/dL, 149 mg/dL | 500 mg/dL |
| | | |
| Bilirubin | 122 mg/dL, 298 mg/dL | 5.5 mg/dL |
| Uric Acid | | |
| Hemoglobin | 3.35 mg/dL, 5.53 mg/dL | 52 mg/dL |
| | | |
| Triglyceride | 3.84 mg/dL, 5.8 mg/dL | 400 mg/dL |
| | | |
| Bilirubin | 2.24 mg/dL, 4.82 mg/dL | 25 mg/dL |
The labeling for all tests contains precautionary language that hemolyzed samples should not be used. For glucose and triglycerides, there is an additional warning that icteric samples should not be used.
The sponsor did not perform any studies to investigate the effect of exogenous substances however a literature reference is included to alert users that potential interferences from substances such as common over-the-counter and prescription pharmaceuticals should be checked.
The sponsor cites the following references for exogenous interference in the labeling.
Young DS. Effects of Drugs on Clinical Laboratory Tests 4th ed. Washington, DC: AACC Press; 1995.
Young DS. Effects of Preanalytical Variables on Clinical Laboratory Tests. 2nd ed. Washington, DC. AACC Press; 1997.
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
Studies were performed using CLSI EP9-A2 as a guide.
Amylase
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A total of 99 serum samples were tested with the Medica EasyRA amylase test system and with the Roche Amylase reagent on the COBAS MIRA test system. Of these sera, seven (7) were either spiked with amylase to create samples with high amylase concentration or diluted to create low level samples. Samples ranged in value from 2 to $1150\mathrm{U/L}$ amylase and were tested in singlicate on the Medica test system and in duplicate on the Roche test system. The comparison resulted in a slope of 1.025, an intercept of 6.11, and a correlation coefficient of $\mathbb{R}^2 = 0.996$.
## BUN
A total of 60 serum samples were tested with the Medica EasyRA BUN test system and with the Roche BUN reagent on the COBAS MIRA test system. Of these sera, three (3) were spiked with BUN to create samples with high BUN concentration. Samples ranged in value from 5.4 to $65.5\mathrm{mg/dL}$ BUN and were tested in singlicate on the Medica test system and in duplicate on the Roche test system. The comparison resulted in a slope of 1.04, an intercept of 1.04, and a correlation coefficient of $\mathbb{R}^2 = 0.995$.
## Glucose
A total of 60 serum samples were tested with the Medica EasyRA Glu-H test system and with the Roche Glu-H reagent on the COBAS MIRA test system. Of these sera three (3) were either spiked with glucose to create samples with high glucose concentration or diluted. Samples ranged in value from 3 to $579\mathrm{mg/dL}$ and were tested in singlicate on the Medica test system and in duplicate on the Roche test system. The comparison resulted in a slope of 0.999, an intercept of -4.02, and a correlation coefficient of $\mathbb{R}^2 = 0.997$.
## Triglycerides
A total of 60 serum samples were tested with the Medica EasyRA Triglycerides test system and with the Roche Triglycerides reagent on the COBAS MIRA test system. Of these sera three (3) were spiked to create samples with high triglycerides concentration. Samples ranged in value from 3 to $726\mathrm{mg/dL}$ and were tested in singlicate on the Medica test system and in duplicate on the Roche test system. The comparison resulted in a slope of 0.994, an intercept of 8.01, and a correlation coefficient of $\mathbb{R}^2 = 0.998$.
## Uric Acid
A total of 48 serum samples were tested with the Medica EasyRA Uric Acid test system and with the Roche Uric Acid reagent on the COBAS MIRA test system. Of these sera five (5) were spiked to create samples with high uric acid concentration. Samples ranged in value from 1.49 to $12\mathrm{mg/dL}$ and were tested in singlicate on the Medica test system and in duplicate on the Roche test system. The comparison resulted in a slope of 1.04, an intercept of -0.19, and a correlation coefficient of $\mathbb{R}^2 = 0.991$.
15
{15}
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):
4. Clinical cut-off: Not applicable
5. Expected values/Reference range:
The following reference is listed in the package insert: Tietz NW. Textbook of Clinical Chemistry, 3rd ed. WB Saunders and Co., Philadelphia, PA, p. 831-832 (1994).
Reference ranges for analytes in this review are as follows:
| | Normal Range |
| --- | --- |
| Amylase | 25-94 U/L |
| BUN | 11-37 mg/dL |
| Glucose | 70-105 mg/dL |
| Triglycerides | 40-160 mg/dL (Men) |
| | 35-135 mg/dL (Women) |
| Uric Acid | 3.5-7.2 mg/dL (Men) |
| | 2.6-6.0 mg/dL (Women) |
The labeling contains recommendations that each laboratory should establish their own range of expected values.
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
{16}
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
17
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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.