K092353 · Bio-Rad Laboratories, Inc. · LOL · Oct 29, 2009 · Microbiology
Device Facts
Record ID
K092353
Device Name
MONOLISA ANTI-HAV IGM EIA
Applicant
Bio-Rad Laboratories, Inc.
Product Code
LOL · Microbiology
Decision Date
Oct 29, 2009
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 866.3310
Device Class
Class 2
Attributes
Real-World Evidence, Pediatric
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K092353 · Oct 29, 2009
MONOLISA ANTI-HAV IGM EIA
Bio-Rad Laboratories, Inc.
Retrospective clinical samples
Retrospective clinical samples were used to compare the performance of the MONOLISA Anti-HAV IgM assay on the EVOLIS automated system against the manual reference method.
Method comparison; Retrospective samples
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Retrospective method comparison
Clinical serum/plasma samples; Sample Size: 691; Number of Sites: 3
Manual MONOLISA Anti-HAV IgM assay
Positive and negative percent agreement
Indications for Use
The MONOLISA™ Anti-HAV IgM EIA is an in vitro enzyme immunoassay kit intended for use in the qualitative detection of IgM antibodies to hepatitis A virus (anti-HAV IgM) in human (adult and pediatric) serum or plasma (EDTA, Heparin, Citrate, ACD). This assay is indicated for testing specimens from individuals who have signs and symptoms consistent with acute hepatitis. Assay results, in conjunction with other serological or clinical information, may be used for the laboratory diagnosis of individuals with acute or recent hepatitis A. The MONOLISA™ Anti-HAV IqM EIA is intended for manual use and with the Evolis™ Automated Microplate System in the detection of IgM antibodies to hepatitis A virus. Assay performance characteristics have not been established for immunocompromised or immunosuppressed patients, and cord blood or neonatal specimens. Warning: This assay is not intended for screening blood or solid or soft tissue donors.
Device Story
The MONOLISA™ Anti-HAV IgM EIA is an enzyme immunoassay (IgM antibody capture format) for detecting anti-HAV IgM in human serum or plasma. The assay uses microwells coated with antibodies to capture patient IgM; HAV viral antigen and HRP-labeled mouse monoclonal anti-HAV antibody are added. Bound HRP reacts with TMB substrate to produce a color change measured spectrophotometrically. The EVOLIS™ Automated Microplate System automates the entire process, including barcode scanning, sample/reagent dispensing, incubation, washing, and photometric measurement. Operated by laboratory personnel in a clinical setting, the system uses dedicated software to compare absorbance values against a cutoff to determine results. Automation reduces manual handling, improves throughput, and ensures consistent processing. The device aids clinicians in diagnosing acute or recent hepatitis A infection.
Clinical Evidence
Bench testing only. Method comparison study (n=691) showed 100% positive percent agreement (95% CI: 96.1-100%) and 99.7% negative percent agreement (95% CI: 98.8-99.9%) compared to manual method. Combination plate study (n=313) showed 100% positive percent agreement (95% CI: 92.7-100%) and 99.2% negative percent agreement (95% CI: 97.3-99.8%). Precision and reproducibility studies (within-run, between-run, between-day, between-site) demonstrated acceptable performance with total CVs generally <15%.
Technological Characteristics
Enzyme immunoassay (competitive format). Components: anti-human IgM coated microwells, HRP-labeled mouse monoclonal anti-HAV, TMB chromogen. Photometric detection at 450nm/620nm. EVOLIS system features: capacitive liquid level detection, disposable tips (300/1100 µL), automated incubation, and washing. Software-controlled via Windows 2000 PC. Sterilization: N/A (reagents).
Indications for Use
Indicated for qualitative detection of anti-HAV IgM in human adult and pediatric serum or plasma for individuals with signs/symptoms of acute hepatitis. Not for immunocompromised/immunosuppressed patients, neonates, or blood/tissue donor screening.
Regulatory Classification
Identification
HAV serological assays are devices that consist of antigens and antisera for the detection of hepatitis A virus-specific IgM, IgG, or total antibodies (IgM and IgG), in human serum or plasma. These devices are used for testing specimens from individuals who have signs and symptoms consistent with acute hepatitis to determine if an individual has been previously infected with HAV, or as an aid to identify HAV-susceptible individuals. The detection of these antibodies aids in the clinical laboratory diagnosis of an acute or past infection by HAV in conjunction with other clinical laboratory findings. These devices are not intended for screening blood or solid or soft tissue donors.
Special Controls
*Classification.* Class II (special controls). The special control is “Guidance for Industry and FDA Staff: Class II Special Controls Guidance Document: Hepatitis A Virus Serological Assays.” See § 866.1(e) for the availability of this guidance document.
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
K092353
B. Purpose for Submission:
This is a new 510k application for a new indication for the MONOLISA™ Anti-HAV IgM EIA with the EVOLIST™ Automated Microplate System. The MONOLISA™ Anti-HAV IgM EIA was previously cleared with a manual assay procedure.
C. Measurand:
Antibody to Hepatitis A (IgM)
D. Type of Test:
Enzyme immunoassay (competitive assay format)
E. Applicant:
Bio-Rad Laboratories
F. Proprietary and Established Names:
MONOLISA Anti-HAV IgM EIA/Hepatitis A test (IgM Antibody)
EVOLIS Automated Microplate System/Automated Laboratory Analyzer
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| LOL | Class II | 21 CFR 866.3310 | Microbiology (83) |
| JJE | Class I | 21 CFR 862.2160 | Chemistry (75) |
H. Intended Use:
1. Intended use:
The MONOLISA Anti-HAV IgM EIA is an in vitro enzyme immunoassay kit intended for use in the qualitative detection of IgM antibodies to hepatitis A virus (anti-HAV) in human (adult and pediatric) serum or plasma (EDTA, Heparin, Citrate, ACD). This assay is indicated for testing specimens from individuals who have signs and symptoms consistent with acute hepatitis. Assay results, in conjunction with other serological or clinical information, may be used for the laboratory diagnosis of individuals with acute or
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recent hepatitis A. The MONOLISA Anti-HAV IgM EIA is intended for manual use and with the Evolis Automated Microplate System in the detection of IgM antibodies to hepatitis A virus.
Assay performance characteristics have not been established for immunocompromised or immunosuppressed patients, and cord blood or neonatal specimens.
WARNING: This assay is not intended for screening blood or solid or soft tissue donors.
2. Indication(s) for use:
Same as Intended Use
3. Special conditions for use statement(s):
For prescription use only.
4. Special instrument requirements:
The assay may be run using a manual method or with the EVOLIS Automated Microplate System.
I. Device Description:
The MONOLISA Anti-HAV IgM EIA 192 test kit contains the following components:
- 2 Microwell strip plates. Wells are coated with polyclonal anti-human IgM
- Wash Solution Concentrate – Tris NaCl buffer, ProClin, Tween 20
- Negative Control – Human serum negative for anti-HAV IgM and total antibodies
- Positive Control – Human serum positive for anti-HAV IgM antibodies
- Calibrator – Human serum positive for anti-HAV IgM antibodies
- Sample Diluent – Tris buffer containing protein and sample indicator dye
- HAV Viral antigen – inactivated HAV virus in Tris buffer and ProClin
- Conjugate – Peroxidase labeled mouse monoclonal antibody to HAV in Tris buffer
- Substrate buffer – H₂O₂, buffer, DMSO
- Chromogen - TMB
- Stopping solution – 1N H₂SO₄
The EVOLIS Automated Microplate System is an automated microplate analyzer that performs all functions necessary for processing microplate assays. Functions include: barcode scanning, sample pre-dilutions, sample and reagent dispensing, plate incubations, plate wash cycles, photometric measurement of completed assay plates and results evaluation. The analyzer instrument is controlled via the EVOLIS software, a Windows 2000 application running on a separate dedicated PC. An operator loads the appropriate microplates, assay reagents, and patient and control samples, then selects assay parameters, loads sample information, initiates instrument processing, and generates results reports.
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# J. Substantial Equivalence Information:
1. Predicate device name: MONOLISA Anti-HAV IgM EIA
2. Predicate 510(k) number: K063319
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Intended Use/Indications for Use | An in vitro enzyme immunoassay kit intended for use in the qualitative detection of IgM antibodies to hepatitis A virus (anti-HAV) in human (adult and pediatric) serum or plasma (EDTA, Heparin, Citrate, ACD) | An in vitro enzyme immunoassay kit intended for use in the qualitative detection of IgM antibodies to hepatitis A virus (anti-HAV) in human (adult and pediatric) serum or plasma (EDTA, Heparin, Citrate, ACD) |
| Assay procedure | Per the instructions in the package insert | Per the instructions in the package insert |
| Plate incubation | 60 ± 5 minutes at 37°C + 2°C | 60 ± 5 minutes at 37°C + 2°C |
| Plate washing | Wash with ≥ 370 μL of Working Wash Solution per well, and 30 - 60 second soak between each wash cycle for a total of 5 cycles. | Wash with ≥ 370 μL of Working Wash Solution per well, and 30 - 60 second soak between each wash cycle for a total of 5 cycles. |
| Result interpretation | Result interpretations, based on sample O.D.s, are determined according to package insert criteria. | Result interpretations, based on sample O.D.s, are determined according to package insert criteria. |
| Photometric measurement of completed assay plates | Read absorbance using 450 nm filter with 620 nm as the reference | Read absorbance using 450 nm filter with 615 to 630 nm as the reference |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Sample and reagent dispensing | Samples and reagents are dispensed by the automated system | Samples and reagents are dispensed manually |
| Barcode reading | Sample and reagent ID are verified automatically | NA or can be performed manually with barcode wand |
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| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Plate incubation | Plates are automatically moved to the incubation chamber | Plates are moved manually to an incubation chamber |
| Plate wash cycles | Plates are automatically washed | Plates are moved manually to an automated plate washer |
| Data management | Archives and retrieves data and sample information | NA |
| Spectrophotometric verification of sample and reagent pipeting | Performed automatically | Optional verification visually or with microplate reader |
## K. Standard/Guidance Documents Referenced:
- Guidance on Informed Consent for In Vitro Diagnostic Device Studies Leftover Human Specimens that are Not Individually Identifiable (April 2006)
- Statistical Guidance on Reporting Results from Studies Evaluating Diagnostic Tests; Guidance for Industry and FDA Reviewers (March 2007)
- Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices (May 2005)
- Evaluation of Precision Performance of Qualitative Measurement Methods, CLSI EP5-A2
- User Protocol for Evaluation of Qualitative Test Performance, CLSI EP15-A2
## L. Test Principle:
Patient specimens, a calibrator, and controls are incubated with anti-human IgM antibodies coated on the microwells. If IgM antibodies to HAV are present in a specimen or control, they bind to the antibody. Excess sample is removed by a wash step. The HAV Viral Antigen and the Conjugate (containing horseradish peroxidase - labeled mouse monoclonal antibody to HAV) are successively added to the microwells and allowed to incubate. The presence of anti-HAV IgM in the sample enables the HAV Viral Antigen and the Conjugate to bind to the solid phase. Excess Conjugate and HAV Viral Antigen are removed by a wash step, and a TMB Chromogen /Substrate solution is added to the microwells and allowed to incubate. If a sample contains anti-HAV IgM, the bound enzyme (HRP) causes the colorless tetramethylbenzidine (TMB) in the Chromogen solution to change to blue. The blue color turns yellow after the addition of a Stopping Solution. If a sample does not contain anti-HAV IgM, the Chromogen/Substrate solution in the well remains colorless during the substrate incubation, and after the addition of the Stopping Solution. The color intensity is measured spectrophotometrically. Absorbance value readings for patient specimens are compared to the cutoff value.
## M. Performance Characteristics:
1. Analytical performance:
a. Precision/Reproducibility:
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A 21-member panel consisting of the following was tested: three (3) serum samples with six (6) corresponding plasma samples (EDTA K2, EDTA K3, Sodium Citrate, Sodium Heparin, Lithium Heparin, ACD) at three (3) different levels [1 low positive near the cutoff (Panel Set 1), 1 negative near the cutoff (Panel Set 2) and 1 negative (Panel Set 3)]. Two replicates each of the twenty-four (24) member panel were assayed twice a day for 20 days. The data were analyzed following the CLSI guidance EP5A2. The mean ratio, the Standard Deviation (SD) and percent coefficient of variation (%CV) were calculated for each panel member.
| Panel Member | N | Mean S/CO | Within run1 | | Between Run2 | | Between Day3 | | Total4 | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | SD | CV (%) | SD | CV (%) | SD | CV (%) | SD | CV (%) |
| Positive Control | 80 | 1.97 | 0.035 | 1.8 | 0.091 | 4.6 | 0.163 | 8.3 | 0.190 | 9.7 |
| High Negative | 80 | 0.10 | 0.006 | 6.1 | 0.015 | 14.9 | 0.015 | 14.7 | 0.022 | 21.8 |
| Cutoff Control | 80 | 3.78 | 0.146 | 3.9 | 0.132 | 3.5 | 0.166 | 4.4 | 0.256 | 6.8 |
| Serum (1) | 80 | 1.55 | 0.036 | 2.3 | 0.076 | 4.9 | 0.138 | 8.9 | 0.161 | 10.4 |
| EDTA K2 (1) | 80 | 1.44 | 0.020 | 1.4 | 0.075 | 5.2 | 0.131 | 9.1 | 0.152 | 10.6 |
| EDTA K3 (1) | 80 | 1.49 | 0.030 | 2.0 | 0.083 | 5.6 | 0.126 | 8.5 | 0.154 | 10.3 |
| Sodium Citrate (1) | 80 | 1.48 | 0.033 | 2.2 | 0.086 | 5.8 | 0.140 | 9.5 | 0.168 | 11.3 |
| Sodium Heparin (1) | 80 | 1.41 | 0.024 | 1.7 | 0.080 | 5.7 | 0.132 | 9.4 | 0.156 | 11.1 |
| Lithium Heparin (1) | 80 | 1.39 | 0.026 | 1.9 | 0.077 | 5.5 | 0.120 | 8.7 | 0.145 | 10.5 |
| ACD (1) | 80 | 1.64 | 0.021 | 1.3 | 0.107 | 6.6 | 0.144 | 8.8 | 0.181 | 11.0 |
| Serum (2) | 80 | 0.62 | 0.016 | 2.7 | 0.031 | 5.0 | 0.059 | 9.5 | 0.068 | 11.1 |
| EDTA K2 (2) | 80 | 0.69 | 0.016 | 2.3 | 0.034 | 5.0 | 0.077 | 11.3 | 0.086 | 12.5 |
| EDTA K3 (2) | 80 | 0.69 | 0.014 | 2.0 | 0.046 | 6.6 | 0.073 | 10.5 | 0.087 | 12.5 |
| Sodium Citrate (2) | 80 | 0.74 | 0.014 | 1.9 | 0.044 | 5.9 | 0.075 | 10.1 | 0.088 | 11.9 |
| Sodium Heparin (2) | 80 | 0.66 | 0.011 | 1.6 | 0.041 | 6.2 | 0.061 | 9.2 | 0.074 | 11.2 |
| Lithium Heparin (2) | 80 | 0.66 | 0.020 | 3.0 | 0.040 | 6.1 | 0.058 | 8.9 | 0.073 | 11.1 |
| ACD (2) | 80 | 0.78 | 0.012 | 1.5 | 0.052 | 6.7 | 0.072 | 9.2 | 0.090 | 11.5 |
| Serum (3) | 80 | 0.10 | 0.004 | 3.6 | 0.010 | 9.7 | 0.010 | 10.1 | 0.015 | 14.5 |
| EDTA K2 (3) | 80 | 0.11 | 0.005 | 4.7 | 0.011 | 10.3 | 0.009 | 8.2 | 0.015 | 14.0 |
| EDTA K3 (3) | 80 | 0.10 | 0.004 | 4.2 | 0.010 | 9.5 | 0.011 | 10.6 | 0.015 | 14.8 |
| Sodium Citrate (3) | 80 | 0.10 | 0.003 | 2.9 | 0.009 | 9.2 | 0.010 | 9.6 | 0.014 | 13.8 |
| Sodium Heparin (3) | 80 | 0.10 | 0.004 | 3.8 | 0.009 | 8.7 | 0.010 | 9.9 | 0.014 | 13.7 |
| Lithium Heparin (3) | 80 | 0.10 | 0.015 | 4.5 | 0.010 | 9.5 | 0.010 | 9.2 | 0.014 | 14.0 |
| ACD (3) | 78 | 0.10 | 0.005 | 4.3 | 0.010 | 10.0 | 0.009 | 8.7 | 0.015 | 13.9 |
1 Within Run: variability of the assay performance from replicate to replicate
2 Between Run: variability of the assay performance from Run to Run
3 Between Day: variability of the assay performance from Day to Day
4 Total: Total variability of the assay performance includes within run, between run and between days
A 6-member panel consisting of diluted plasma specimens (negative and different levels of positive) was tested in triplicate, once a day for 5 days with the MONOLISA Anti-HAV IgM EIA at 3 separate clinical trial sites. Each panel was coded with a different number on each day tested in order to blind the operator to the expected value of the sample. One (1) lot was used at each of 3 sites.
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| Panel Member | N | Mean | Within Run¹ | | Between Day² | | Between Site³ | | Total⁴ | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | CO/S | SD | %CV | SD | %CV | SD | %CV | SD | %CV |
| P1 | 90 | 0.16 | 0.02 | 13.5 | 0.01 | 8.9 | 0.00⁵ | 0.0 | 0.026 | 16.1 |
| P2 | 89 | 0.72 | 0.02 | 3.3 | 0.03 | 3.8 | 0.021 | 2.9 | 0.042 | 5.8 |
| P3 | 90 | 1.18 | 0.04 | 3.4 | 0.03 | 2.9 | 0.031 | 2.6 | 0.061 | 5.2 |
| P4 | 90 | 1.17 | 0.45 | 3.9 | 0.04 | 3.1 | 0.032 | 2.8 | 0.066 | 5.7 |
| P5 | 90 | 3.05 | 0.08 | 2.6 | 0.10 | 3.2 | 0.084 | 2.8 | 0.151 | 5.0 |
| P6 | 88 | 3.63 | 0.18 | 4.8 | 0.14 | 4.0 | 0.000⁵ | 0.0 | 0.227 | 6.3 |
| P7 | 90 | 1.90 | 0.08 | 4.0 | 0.07 | 3.7 | 0.044 | 2.3 | 0.113 | 5.9 |
| P8 | 88 | 0.11 | 0.01 | 9.7 | 0.02 | 13.0 | 0.000⁵ | 0.0 | 0.018 | 16.2 |
| P9 | 88 | 3.46 | 0.23 | 6.6 | 0.23 | 6.6 | 0.106 | 3.1 | 0.339 | 9.8 |
¹ Within run: Variability of the assay performance from replicate to replicate
² Between day: Variability of the assay performance from day to day
³ Between site: Variability of the assay performance from site to site
⁴ Total: Total variability of the assay performance includes within run, between days and between sites
⁵ Negative variances were rounded to zero, per statistical convention
b. Linearity/assay reportable range:
K063319
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
See K063319
d. Detection limit:
See K063319
e. Analytical specificity:
See K063319
f. Assay cut-off:
See K063319
2. Comparison studies:
a. Method comparison with predicate device:
Six-hundred ninety-one retrospective samples were tested on the MONOLISA Anti-HAV IgM assay, using a total of four (4) EVOLIS instruments at three sites. The same samples were tested manually (reference method) on the MONOLISA Anti-HAV IgM assay.
Specimens that were borderline with the reference assay and negative with EVOLIS were considered as false negative for the EVOLIS; specimens that were borderline with the
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reference assay and reactive with EVOLIS were considered as false positive for the EVOLIS.
| Manual Anti-HAV Results | EVOLIS Anti-HAV IgM Results | | | |
| --- | --- | --- | --- | --- |
| | Reactive | Borderline | Nonreactive | Total |
| Reactive | 94 | 0 | 0 | 94 |
| Borderline | 1 | 0 | 0 | 1 |
| Nonreactive | 1 | 0 | 595 | 596 |
| Total | 96 | 0 | 595 | 691 |
The positive percent agreement with the reference method, manual testing, is 100% (94/94) with a 95% confidence interval of 96.1 – 100%. The negative percent agreement with the reference method is 99.7% (595/597) with a 95% confidence interval of 98.8 – 99.9%.
The EVOLIS was also evaluated by performing a combination of 2 assays on the same plate. In this study 313 samples were tested with the MONOLISA Anti-HAV IgM assay on a combination plate on the EVOLIS (both the Anti-HAV IgM EIA and Anti-HAV EIA assays were run in a single microplate frame). Results were compared to the same samples tested manually (the reference method, individual plate format) on the MONOLISA Anti-HAV IgM assay. Specimens that were borderline with the reference assay (manual individual plate) and negative with EVOLIS (combination plate) were considered as false negative for the EVOLIS (combination plate).
| Manual Anti-HAV IgM Results - Individual Plate | EVOLIS™ Anti-HAV IgM Results - Combination Plate | | | |
| --- | --- | --- | --- | --- |
| | Reactive | Borderline | Nonreactive | Total |
| Reactive | 49 | 0 | 0 | 49 |
| Borderline | 1 | 0 | 0 | 1 |
| Nonreactive | 0 | 1 | 262 | 263 |
| Total | 50 | 1 | 262 | 313 |
The positive percent agreement with the reference method, manual testing, is 100% (49/49) with a 95% confidence interval of 92.7 – 100%. The negative percent agreement with the reference method is 99.2% (262/264) with a 95% confidence interval of 97.3 – 99.8%.
b. Matrix comparison:
See K063319
3. Clinical studies:
a. Clinical Sensitivity:
See K063319
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b. Clinical specificity:
See K063319
c. Other clinical supportive data (when a. and b. are not applicable):
Not applicable.
4. Clinical cut-off:
Not applicable.
5. Expected values/Reference range:
See K063319
## N. Instrument Name:
EVOLIS Automated Microplate System
## O. System Descriptions:
1. Modes of Operation:
The EVOLIS Automated Microplate System is an open tube, batch mode analyzer with a continuous load option. The reagent bottles used from the test kit are placed on the instrument with the caps removed. The sample tubes can be the primary tubes with stoppers removed or the serum/plasma can be poured off into identified test tubes.
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ X or No ☐
3. Specimen Identification:
Specimen information may be entered either by EVOLIS system barcode reading directly off the specimen tube or entered manually by the user.
4. Specimen Sampling and Handling:
The system can store and distribute samples from different types of vessels into dilution vessels and microplates. The samples can be accessed in any order. Sample addition is via a 300 µL disposable tip. The system can load and unload samples and assay reagents while it is operating.
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The pipetting system utilizes a liquid syringe pump and system fluid. The system uses disposable tips (300 µL and 1100 µL), and can aspirate and dispense fluids from a variety of different vessels. Key functions of the system are liquid level detection, using capacitive sensing, verification of fluid distribution, and the detection of clots and blocked tips. If the pipettor does not detect a sufficient volume an error is displayed. The pipettor automatically flushes with system fluid between each aspirate/dispense cycle of samples and reagent during a pipetting sequence. Mixing occurs during the transfer of sample, addition of diluents, and other reagents.
Intermediate vessels are used to dilute samples when the level of dilution exceeds the volume available in the final reaction vessel. Mixing is utilized to obtain a homogeneous mixture after preparing the dilution. The instrument has space for at least one microplate to be used as a dilution position.
5. Calibration:
The system performs a self-test each time EVOLIS software is launched. During the self-test the instrument hardware is initialized and the status of all instrument modules is verified. The self-test evaluates the following systems: Pipettor, washer, photometer, plate transport, incubators, system communications, and other user-defined maintenance.
Users are instructed in the Operator's Manual to perform the following Performance Evaluation Procedures monthly: Plate Transport Check, Photometer Verification Check, Fluidics Panel Check.
6. Quality Control:
Assay includes positive and negative controls that are run with each batch.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
N/A
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.