The ADVIA 2120 and ADVIA 2120i with autoslide are quantitative, automated hematology analyzers that provide: - A complete blood count (CBC) consisting of WBC, RBC, Hgb, CN-Free Hgb, Calculated Hgb, MCV, Hct, MCH, MCHC, CHCM, RDW, HDW, CH, Plt, MPV. - A leukocyte differential count consisting of Neut (%/#), Lymph (%/#), Mono (%/#), Eos (%/#), Baso (%/#), LUC (%/#). - A reticulocyte analysis consisting of Retic (%/#), MCVg, MCVr, CHCMg, CHCMr, CHg, CHr. - A nucleated red blood cell count consisting of NRBC (%/#). - Enumeration of the total nucleated cell (TNC) count and RBC count for pleural, peritoneal, and peritoneal dialysis (PD) specimens. Note: Above measurands are determined (in whole blood, pleural, peritoneal, or peritoneal dialysis specimens with K2 and/or K3 EDTA anti-coagulants). - Quantitative determination of blood cells in Cerebrospinal Fluid (CSF) consisting of WBC, RBC, Neut (%/#), Lymph (%/#), Mono (%/#), MN (%/#), PMN (%/#). In addition, the system provides the added capability to automatically prepare and stain high quality blood smears on a microscope slide.
Device Story
ADVIA 2120/2120i are integrated hematology analyzers; system aspirates, dilutes, and analyzes whole blood, CSF, and body fluid samples; includes auto-sampler for tube processing and auto-slide module for wedge smear preparation/staining. Device replaces legacy 386ex CPU board with ARM9 CPU board. System uses analytical module to perform quantitative cell counts; computer workstation manages data, user interface, and reporting. Healthcare providers use results for CBC, differential, and morphology assessment to aid clinical decision-making. Benefits include automated, high-throughput hematology analysis and reflexive slide preparation.
Clinical Evidence
Bench testing only. Performance evaluated across three configurations (legacy hardware/software, legacy hardware/new software, new hardware/new software) using 219 whole blood, 20 body fluid, 80 NRBC, and 52 CSF samples. Regression analysis demonstrated equivalence in analytical performance (r > 0.98 for most parameters). Precision (within-run) and linearity met specifications for all modes. Carryover was <1% for all channels.
Technological Characteristics
Automated hematology analyzer; analytical module with auto-sampler and slide stainer. Sensing via flow cytometry/optical analysis. ARM9 CPU board running Nucleus OS. Connectivity via 100Base-TX Ethernet. Power: 100-240 Vac, 50/60Hz. Dimensions: 141cm x 86cm x 68cm. Weight: 193 kg.
Indications for Use
Indicated for quantitative, automated hematology analysis of whole blood, pleural, peritoneal, peritoneal dialysis, and cerebrospinal fluid (CSF) specimens in clinical settings. Provides CBC, leukocyte differential, reticulocyte analysis, NRBC count, and body fluid cell counts. For prescription use only.
Regulatory Classification
Identification
An automated differential cell counter is a device used to identify one or more of the formed elements of the blood. The device may also have the capability to flag, count, or classify immature or abnormal hematopoietic cells of the blood, bone marrow, or other body fluids. These devices may combine an electronic particle counting method, optical method, or a flow cytometric method utilizing monoclonal CD (cluster designation) markers. The device includes accessory CD markers.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA document entitled “Class II Special Controls Guidance Document: Premarket Notifications for Automated Differential Cell Counters for Immature or Abnormal Blood Cells; Final Guidance for Industry and FDA.”
Predicate Devices
ADVIA 2120 and 2120i Hematology Auto analyzers (K042251)
Reference Devices
k930148
k954954
k971998
k003796
k012904
k022668
k022331
k051693
k090346
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
k102644
B. Purpose for Submission:
Replacement of the Analytical Module (AM) CPU board utilized in the ADVIA 2120/2120i Hematology Analyzers
C. Manufacturer and Instrument Name:
Siemens Healthcare Diagnostics Inc.; ADVIA® 2120 Hematology Auto analyzer and 2120i Hematology Auto analyzer with Auto slide
D. Type of Test or Tests Performed:
Quantitative test for WBC, RBC, Hgb, CN-Free Hgb, Calculated Hgb, MCV, Hct, MCH, MCHC, CHCM, RDW, HDW, Plt, MPV, Neut (%/#), Lymph (%/#), Mono (%/#), Eos (%/#), Baso (%/#), LUC (%/#), NRBC (%/#), Reticulocyte [Retic (%/#), MCVg, MCVr, CHCMg, CHCMr, CHg, CHr], CSF [WBC, RBC, Neut (%/#), Lymph (%/#), Mono (%/#), MN (%/#), PMN (%/#)], and Body Fluid [TNC, RBC] parameters.
E. System Descriptions:
1. Device Description:
The ADVIA 2120/210i Hematology Systems with Auto Slide are an integrated option of hematology analyzers with complete blood cell count, leukocyte differential cell count, reticulocyte analysis capability, nucleated red blood cell count, quantitative determination of blood cells in Cerebrospinal Fluid (CSF), enumeration of the total nucleated cell (TNC) count and RBC count for pleural, peritoneal, and peritoneal dialysis (PD) specimens and a slide stainer designed to provide reflexive slide making/staining without user intervention based upon pre-selected, user-definable criteria.
The ADVIA 2120/210i Hematology systems with Auto slide consists of the following: an analytical module that aspirates, dilutes, and analyzes whole blood samples; an auto sampler that automatically mixes, identifies, and presents the samples for processing; a computer workstation that controls the instrument, provides primary user interface with the instrument and manages the data produced by the instrument; a printer that optionally generates reports based on the instrument results and an auto slide module that prepares a wedge smear from a drop of blood, places it on a microscope slide and stains the slide in accordance with Wright, Wright-Giemsa and May-Grunwald Giemsa Staining techniques.
2. Principles of Operation:
Refer to individual 510(k) clearances below:
k930148 (H*3 Reticulocyte measurands: Retic, MCVg, MCVr, CHCMg, CHCMr, CHg, CHr)
k954954 (Reticulocyte measurands: Retic, MCVg, MCVr, CHCMg, CHCMr, CHg, CHr)
k971998 (ADVIA 120 measurands except NRBC, body fluids and CSF)
k003796 (ADVIA 120 CSF measurands: CSF WBC, Neut, Lymph, Mono, MN, PMN)
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k012904 (ADVIA 120 CN-free Hgb measurand)
k022668 (ADVIA 120 Calculated Hgb measurand)
k022331 (ADVIA 120 revised measurands: CSF WBC, Neut, Lymph, Mono MN, PMN)
k042251 (ADVIA 2120 measurands except NRBC and body fluids)
k051693 (ADVIA 2120 with Auto slide, NRBC, all measurands except body fluids)
k090346 (ADVIA 2120/2120i Body fluids Application measurands: RBC, TNC)
3. Modes of Operation:
Refer to individual 510(k) clearances in item 2 above.
4. Specimen Identification:
Refer to individual 510(k) clearances in item 2 above.
5. Specimen Sampling and Handling:
Refer to individual 510(k) clearances in item 2 above.
6. Calibration:
Refer to individual 510(k) clearances in item 2 above.
7. Quality Control:
Refer to individual 510(k) clearances in item 2 above.
8. Software:
FDA has reviewed applicant’s Hazard Analysis and Software Development processes for this line of product types:
Yes ☐ X ☐ or No ☐
F. Regulatory Information:
1. Regulation section:
21 § CFR 864.5220, Automated differential cell counter
2. Classification:
Class II
3. Product code:
GKZ, Counter, differential cell
4. Panel:
Hematology (81)
G. Intended Use:
1. Indication(s) for Use:
The ADVIA 2120 and ADVIA 2120i with autoslide are quantitative, automated hematology analyzers that provide:
- A complete blood count (CBC) consisting of WBC, RBC, Hgb, CN-Free Hgb, Calculated Hgb, MCV, Hct, MCH, MCHC, CHCM, RDW, HDW, CH, Plt, MPV.
- A leukocyte differential count consisting of Neut (%/#), Lymph (%/#), Mono (%/#), Eos (%/#), Baso (%/#), LUC (%/#).
- A reticulocyte analysis consisting of Retic (%/#), MCVg, MCVr, CHCMg, CHCMr, CHg, CHr.
- A nucleated red blood cell count consisting of NRBC (%/#).
- Enumeration of the total nucleated cell (TNC) count and RBC count for pleural, peritoneal, and peritoneal dialysis (PD) specimens.
Note: Above measurands are determined (in whole blood, pleural, peritoneal,
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or peritoneal dialysis specimens with K2 and/or K3 EDTA anti-coagulants).
- Quantitative determination of blood cells in Cerebrospinal Fluid (CSF) consisting of WBC, RBC, Neut $(\%/\#)$ , Lymph $(\%/\#)$ , Mono $(\%/\#)$ , MN $(\%/\#)$ , PMN $(\%/\#)$ .
In addition, the system provides the added capability to automatically prepare and stain high quality blood smears on a microscope slide.
2. Special Conditions for Use Statement(s):
For prescription use only.
# H. Substantial Equivalence Information:
1. Predicate Device Name(s) and 510(k) numbers:
ADVIA 2120 Hematology Auto analyzer with current CPU board; k042251
2. Comparison with Predicate Device:
| Similarities | | | |
| --- | --- | --- | --- |
| Item | ADVIA 2120 and 2120i with current 386ex CPU | | ADVIA 2120/2120i with ARM9 CPU |
| Parameters | CBC Results | WBC, RBC, HGB, HCT, MCV, MCH, MCHC, CHCM, RDW, HDW, CH, PLT | Same |
| | Differential Results | NEUT, LYMPH, MONO, EOS, BASO, LUC, NRBC (% and absolute) | |
| | Platelet Results | PLT, MPV | |
| | Reticulocyte Results | %RETIC, #RETIC, MCVr, CHCMr, CHr, MCVg, MCVr, CHCMg, CHg | |
| | CSF Results | CSF RBC, CSF WBC, CSF MN, CSF PMN, CSF NEUT, CSF LYMPH, CSF MONO | |
| | BF Results | TNC, RBC | |
| Morphology Results | WBC: | Left Shift, Atypical Lymph, Blasts, Immature Granulocytes, Myeloperoxidase Deficiency | Same |
| | RBC and PLT: | NRBC, ANISO, MICRO, MACRO, HC VAR, HYPO, HYPER, RBC Fragments, RBC Ghosts, Platelet Clumps, Large Platelets | |
| User Interface personal computer | Intel based processorWindows 2000Floppy driveNetwork cardModem | | Same |
| User Interface external peripherals | KeyboardMouseHand-held barcode scannerPrinter | | Same |
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| Similarities | | |
| --- | --- | --- |
| Item | ADVIA 2120 and 2120i with current 386ex CPU | ADVIA 2120/2120i with ARM9 CPU |
| Electrical Power | Voltage selectable for single-phase: 100 Vac (6 Amps) - 240 Vac (3 Amps)
Frequency: 50/60Hz | Same |
| Temperature | Operating: 18°C to 32°C
Storage:-29°C to 60°C | Same |
| Relative Humidity | Operating: 15%-80% (noncondensing) | Same |
| Sample Mode Volumes | Automatic Closed-Tube: 175μL
Manual Closed-Tube: 175μL
Manual Open-Tube: 175μL | Same |
| Test Selectivity/Throughput | CBC 120 samples/hr
CBC/Diff 120 samples/hr
CBC/Diff/Retic 74 samples/hr
CBC/Retic 74 samples/hr
Retic 74 samples/hr
With Autoslide slide making enabled:
CBC 108 samples/hr
CBC/Diff 108 samples/hr | Same |
| Sample Capacity | 150 samples
15 racks of 10 tubes | Same |
| Barcode reader | Reads up to 14 digits
Automatic label code discrimination
Compatible barcode types:
1. Codabar
2. Interleaved 2 of 5
3. Code 39
4. Code 128
5. EAN and JAN (8 and 13) | Same |
| Data Management | • TDC version 9 or higher
• Database storage capacity of 10,000 records, including graphics
• Review and edit capability
○ User-defined windows
○ User-defined reports
○ User-defined ranges based on age and sex for Normal, Rerun, Panic, and Delta Check criteria
• Bi-directional and host query communication protocols
• Quality control
○ 3D bar graph
○ Levey-Jennings plot
○ SDI graph
○ Table format
• Remote QC
• ILQC programs
• Patient moving average
• User assistance
○ Context sensitive help
○ Operator’s guide
○ Procedure wizards
○ Problem solving diagnostics
○ Remote diagnostics | Same |
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| Similarities | | |
| --- | --- | --- |
| Item | ADVIA 2120 and 2120i with current 386ex CPU | ADVIA 2120/2120i with ARM9 CPU |
| Reagents | • CBC TIMEPAC
○ Baso
○ HGB
○ RBC/PLT
○ Defoamer
• CN-Free CBC TIMEPAC
○ Baso
○ CN-Free HGB
○ RBC/PLT
○ Defoamer
• DIFF TIMEPAC
○ Perox 1
○ Perox 2
○ Perox 3
○ Perox Sheath
• autoRetic
• EZ KLEEN
• Sheath/Rinse
• CSF | Same |
| Calibrators | • ADVIA OPTIpoint
• ADVIA SETpoint | Same |
| Controls | • ADVIA TESTpoint Low
• ADVIA TESTpoint Normal
• ADVIA TESTpoint High
• ADVIA TESTpoint Retic Low
• ADVIA TESTpoint Retic High
• ADVIA TESTpoint 3-in-1 Abnormal1
• ADVIA TESTpoint 3-in-1 Normal
• ADVIA TESTpoint 3-in-1 Abnormal2 | Same |
| Differences | | |
| --- | --- | --- |
| Item | ADVIA 2120 and 2120i with current 386ex CPU | ADVIA 2120/2120i with ARM9 CPU |
| Real-time Control | Intel 386ex CPU running Nucleus OS | ARM9 CPU running Nucleus OS |
| User Interface software | ADVIA 2120/2120i user interface software (v5.8) | ADVIA 2120/2120i user interface software (v6.0) |
| Communication Interface | BNC Ethernet cable (10Base-2) | RJ-45 Ethernet Cable (100Base-TX) |
I. Special Control/Guidance Document Referenced (if applicable):
CLSI EP9-A2, Method Comparison and Bias Estimation Using Patient Samples;
Approved Guideline-Second Edition
CLSI EP6-A, Evaluation of the Linearity of Quantitative Measurement Procedures: A
Statistical Approach; Approved Guideline
CLSI H26-A2, Validation, Verification, and Quality Assurance of Automated
Hematology Analyzers; Proposed Standard-Second Edition
J. Performance Characteristics:
1. Analytical Performance:
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# a. Accuracy:
Testing was performed in three hardware/software configurations as follows:
| Configuration 1 | Configuration 2 | Configuration 3 |
| --- | --- | --- |
| System software V5.8 | System software V6.0 | System software V6.0 |
| 386ex CPU board (P/N: 067-1452-01) | | ARM 9 CPU board, Cycle 2 (P/N: 067-B794-01) |
| CPU Cover/Shield (P/N: 067-1448-01) | | CPU Cover/Shield (P/N: 067-1627-01) |
| BNC Cable (P/N: 067-B391-02) | | RJ45 Ethernet Cable (P/N: 664-1516-01) |
Configuration 1 is the current hardware/software configuration. Configuration 2 is the current hardware configuration, but uses a software version that can support both hardware configurations. Configuration 3 has both the new hardware and new software configuration.
Testing was performed on 219 whole blood samples, 20 body fluid samples, 80 NRBC samples, and 52 CSF samples. All samples were assayed on an ADVIA 2120i in all three configurations. Samples were run duplicate, but only the first replicate was used for the analysis. The results of the regression analysis comparing all three configurations show equivalence in analytical performance, meeting bias specifications set by the sponsor.
Configuration 1 versus Configuration 2
| CBC/Diff Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| WBC | 0.999 | 1.03 | -0.27 | 0.5 | 11.45 | 11.54 | 0.09 | ±0.15 |
| RBC | 0.998 | 1.00 | 0.01 | 0.05 | 3.28 | 3.29 | 0.01 | ±0.05 |
| Hgb | 0.997 | 0.98 | 0.1 | 0.1 | 9.2 | 9.2 | 0.0 | ±0.1 |
| MCV | 0.998 | 0.99 | 0.9 | 0.6 | 91.1 | 91.0 | -0.1 | ±1.0 |
| CHCM | 0.995 | 0.99 | 0.4 | 0.2 | 32.8 | 32.9 | 0.1 | ±0.5 |
| RDW | 0.999 | 1.00 | 0.0 | 0.1 | 16.9 | 16.9 | 0.0 | ±1.0 |
| HDW | 0.999 | 0.99 | 0.04 | 0.03 | 3.23 | 3.25 | 0.02 | ±0.2 |
| Plt | 0.998 | 0.98 | 3 | 14 | 236 | 234 | -2 | ±6 |
| MPV | 0.890 | 0.84 | 1.8 | 0.8 | 10.5 | 10.7 | 0.2 | ±0.5 |
| %Neut | 0.995 | 0.99 | 0.8 | 2.5 | 61.4 | 61.3 | -0.1 | ±0.5 |
| %Lymph | 0.991 | 0.98 | 0.7 | 2.6 | 22.1 | 22.3 | 0.2 | ±0.5 |
| %Mono | 0.989 | 0.98 | 0.1 | 1.1 | 8.0 | 7.9 | -0.1 | ±1.5 |
| %Eos | 0.944 | 0.99 | 0.1 | 0.7 | 1.9 | 1.9 | 0.0 | ±0.2 |
| %Baso | 0.969 | 1.00 | 0.0 | 0.4 | 0.7 | 0.7 | 0.0 | ±0.2 |
| %LUC | 0.985 | 0.98 | 0.0 | 1.7 | 6.2 | 6.0 | -0.2 | ±0.5 |
| %Retic | 0.992 | 0.99 | 0.02 | 0.31 | 2.2 | 2.2 | 0.0 | ±0.5 |
| CHr | 0.989 | 0.98 | 0.4 | 0.6 | 32.7 | 32.5 | -0.2 | ±0.5 |
| %NRBC | 0.819 | 0.75 | 1.1 | 2.0 | 5.2 | 5.0 | -0.2 | ±0.5 |
| | | | | | | | | |
| Body Fluid Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| TNC | 0.998 | 1.03 | -2.7 | 25.4 | 299 | 304 | 5 | ±10 |
| RBC | 0.99997 | 1.01 | 0.1 | 0.8 | 29 | 29 | 0 | ±10 |
| | | | | | | | | |
| CSF Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| TNC | 0.999 | 1.00 | 0.0 | 0.0 | 1.0 | 1.0 | 0 | ±0.1 |
| RBC | 0.99997 | 0.99 | 0.0 | 0.0 | 0.0 | 0.0 | 0 | 0.0 |
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| CBC/Diff Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| WBC | 0.995 | 1.06 | -9 | 33 | 245 | 251 | 6 | ±15 |
| RBC | 0.999 | 1.01 | -3 | 23 | 355 | 357 | 2 | ±15 |
| %MN | 0.992 | 1.00 | 0.6 | 2.3 | 52 | 53 | 1 | n/a |
| %PMN | 0.992 | 1.00 | -0.7 | 2.3 | 48 | 47 | -1 | n/a |
| %Neut | 0.992 | 1.00 | -0.6 | 2.2 | 47 | 47 | 0 | n/a |
| %Lymph | 0.988 | 1.06 | -1.3 | 2.5 | 38 | 39 | 1 | n/a |
| %Mono | 0.826 | 0.71 | 4.0 | 1.9 | 14 | 14 | 0 | n/a |
Configuration 1 versus Configuration 3
| CBC/Diff Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| WBC | 0.999 | 1.03 | -0.24 | 0.6 | 11.45 | 11.56 | 0.11 | ±0.15 |
| RBC | 0.998 | 1.00 | -0.01 | 0.04 | 3.28 | 3.27 | -0.01 | ±0.05 |
| Hgb | 0.996 | 0.99 | 0.0 | 0.2 | 9.2 | 9.2 | 0.0 | ±0.1 |
| MCV | 0.996 | 0.99 | 0.7 | 0.8 | 91.1 | 90.9 | -0.2 | ±1.0 |
| CHCM | 0.994 | 0.98 | 0.7 | 0.2 | 32.8 | 32.9 | 0.1 | ±0.5 |
| RDW | 0.999 | 1.00 | 0.0 | 0.2 | 16.9 | 16.9 | 0.0 | ±1.0 |
| HDW | 0.998 | 1.00 | 0.01 | 0.04 | 3.23 | 3.26 | 0.03 | ±0.2 |
| Plt | 0.997 | 0.99 | 0 | 18 | 234 | 234 | 0 | ±6 |
| MPV | 0.906 | 0.83 | 2.0 | 0.7 | 10.5 | 10.8 | 0.3 | ±0.5 |
| %Neut | 0.996 | 0.99 | 0.6 | 2.3 | 61.4 | 61.5 | 0.1 | ±0.5 |
| %Lymph | 0.991 | 1.00 | 0.1 | 2.7 | 22.1 | 22.2 | 0.1 | ±0.5 |
| %Mono | 0.987 | 0.98 | 0.0 | 1.2 | 8.0 | 7.8 | -0.2 | ±1.5 |
| %Eos | 0.962 | 0.97 | 0.0 | 0.6 | 1.9 | 1.8 | -0.1 | ±0.2 |
| %Baso | 0.966 | 0.98 | 0.0 | 0.4 | 0.7 | 0.7 | 0.0 | ±0.2 |
| %LUC | 0.986 | 0.97 | 0.2 | 1.6 | 6.2 | 6.1 | -0.1 | ±0.5 |
| %Retic | 0.991 | 1.02 | 0.03 | 0.34 | 2.21 | 2.28 | 0.1 | ±0.5 |
| CHr | 0.992 | 0.98 | 0.4 | 0.5 | 32.7 | 32.6 | -0.1 | ±0.5 |
| %NRBC | 0.814 | 0.78 | 1.0 | 2.1 | 5.2 | 5.0 | -0.2 | ±0.5 |
| | | | | | | | | |
| Body Fluid Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| TNC | 0.996 | 1.03 | -16 | 34 | 299 | 292 | -7 | ±10 |
| RBC | 0.9998 | 1.00 | 0.0 | 2.0 | 29 | 29 | 0 | ±10 |
| | | | | | | | | |
| CSF Parameter | r | Slope | Intercept | Syx | Average X | Average Y | Observed Bias | Bias Specs |
| WBC | 0.996 | 1.02 | -4 | 29 | 245 | 246 | 1 | ±15 |
| RBC | 0.999 | 0.99 | 3 | 17 | 355 | 354 | -1 | ±15 |
| %MN | 0.993 | 1.01 | 0.3 | 2.2 | 52 | 53 | 1 | n/a |
| %PMN | 0.993 | 1.01 | -0.8 | 2.2 | 48 | 47 | -1 | n/a |
| %Neut | 0.993 | 1.01 | -1.0 | 2.1 | 47 | 47 | 0 | n/a |
| %Lymph | 0.988 | 0.99 | 0.9 | 2.4 | 38 | 39 | 1 | n/a |
| %Mono | 0.878 | 0.85 | 2.0 | 1.8 | 14 | 14 | 0 | n/a |
b. Precision/Reproducibility:
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Whole blood samples, simulated body fluid and CSF samples were assayed in 20 consecutive replicates on an ADVIA 2120i in configurations 2 and 3 to verify that the two test configurations meet the within run precision specifications. The observed results pass the precision specifications if either the SD or the CV% specification is met.
Whole Blood Precision
| | | Configuration 2 | | | Configuration 3 | | | Specifications | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Parameter | n | Mean | SD | % CV | Mean | SD | % CV | SD | % CV |
| WBC | 20 | 4.32 | 0.1 | 2.36 | 4.36 | 0.1 | 2.24 | 0.2 | 2.66 |
| RBC | 20 | 4.35 | 0.03 | 0.7 | 5.04 | 0.02 | 0.4 | 0.06 | 1.2 |
| Hgb | 20 | 12.8 | 0.10 | 0.76 | 15.1 | 0.09 | 0.58 | 0.14 | 0.93 |
| MCV | 20 | 90.1 | 0.2 | 0.19 | 88.9 | 0.2 | 0.25 | 0.7 | 0.78 |
| CHCM | 20 | 33.5 | 0.04 | 0.1 | 34.7 | 0.06 | 0.2 | 0.25 | 0.8 |
| RDW | 20 | 13.0 | 0.07 | 0.52 | 13.3 | 0.06 | 0.43 | 0.25 | 1.92 |
| HDW | 20 | 2.52 | 0.012 | 0.46 | 2.50 | 0.009 | 0.38 | 0.1 | 3.57 |
| Plt | 20 | 325 | 8.0 | 2.45 | 205 | 6.0 | 2.91 | 8.8 | 2.93 |
| %Neut | 20 | 53.3 | 0.7 | 1.29 | 68.0 | 0.5 | 0.69 | 1.4 | 2.15 |
| %Lymph | 20 | 26.9 | 0.9 | 3.2 | 15.1 | 0.6 | 4.1 | 1.1 | 4.4 |
| %Mono | 20 | 8.5 | 0.6 | 6.6 | 9.9 | 0.5 | 5.1 | 0.9 | 15 |
| %Eos | 20 | 7.6 | 0.4 | 5.4 | 5.0 | 0.4 | 7.5 | 0.5 | 25 |
| %Baso | 20 | 0.8 | 0.1 | 16.2 | 0.7 | 0.1 | 10.2 | 0.5 | 50 |
| %LUC | 20 | 2.9 | 0.3 | 10.8 | 1.2 | 0.2 | 17.2 | 0.5 | 25 |
| %Retic | 20 | 1.2 | 0.1 | 7.1 | 0.9 | 0.1 | 6.2 | 0.4 | 20 |
Body Fluid Precision
| Autosampler | | | | | | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | Configuration 2 | | | Configuration 3 | | | Specifications | |
| Parameter | n | Mean | SD | % CV | Mean | SD | % CV | SD | % CV |
| TNC | 20 | 521 | 22.4 | 4.3 | 523 | 25.6 | 4.9 | n/a | ≤15 |
| RBC | 20 | 53 | 1.8 | 3.4 | 52 | 2.0 | 3.7 | n/a | ≤10 |
| | | | | | | | | | |
| Manual Closed Tube Sampler | | | | | | | | | |
| | | Configuration 2 | | | Configuration 3 | | | Specifications | |
| Parameter | n | Mean | SD | % CV | Mean | SD | % CV | SD | % CV |
| TNC | 20 | 517 | 18.8 | 3.6 | 516 | 22.2 | 4.3 | n/a | ≤15 |
| RBC | 20 | 52 | 1.6 | 3.0 | 53 | 1.8 | 3.3 | n/a | ≤10 |
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| Manual Open Tube Sampler | | | | | | | | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | Configuration 2 | | | Configuration 3 | | | Specifications | |
| Parameter | n | Mean | SD | % CV | Mean | SD | % CV | SD | % CV |
| TNC | 20 | 505 | 23.5 | 4.7 | 460 | 33.9 | 7.4 | n/a | ≤15 |
| RBC | 20 | 54 | 2.0 | 3.8 | 50 | 1.6 | 3.1 | n/a | ≤10 |
CSF Precision
| | | Configuration 2 | | | Configuration 3 | | | Specifications | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Parameter | n | Mean | SD | % CV | Mean | SD | % CV | SD | % CV |
| WBC | 20 | 88 | 3.8 | 4.3 | 100 | 3.3 | 3.3 | ≤15 | ≤15 |
| RBC | 20 | 111 | 6.5 | 5.9 | 102 | 4.5 | 4.4 | ≤15 | ≤15 |
| %MN | 20 | 93 | 5.1 | 5.5 | 94 | 4.2 | 4.5 | ≤20 | ≤20 |
| %PMN | 20 | 91 | 4.4 | 4.8 | 105 | 5.9 | 5.6 | ≤20 | ≤20 |
c. Linearity:
Linearity was tested using commercially prepared linearity controls. Each level of the control was assayed 4 times in configurations 2 and 3. Linearity was tested in whole blood, body fluid, and CSF modes. The table below summarizes linearity results.
Over the ranges tested, none of the results exceeded the maximum deviation specified.
| Parameter | Analytical Range | Configuration 2 Range tested | Configuration 2 Range tested | Specifications |
| --- | --- | --- | --- | --- |
| WBC (10³cells/μL) | 0.02 – 400 | 0.00 – 448.60 | 0.00 – 405.52 | Maximum deviation: ±0.5 x 10³cells/μL or 5.0% (whichever is greater) |
| RBC (10⁶cells/μL) | 0.0 – 7.0 | 0.00 – 7.67 | 0.00 – 7.67 | Maximum deviation: ±0.1 x 10⁶ cells/μL |
| Hgb (g/dL) | 0.0 – 22.5 | 0.0 – 25.0 | 0.0 – 24.5 | Maximum deviation: ±0.2g/dL or ±2.0% (whichever is greater) |
| PLT (10³cells/μL) | 5 – 3500 | 0 – 5196 | 0 – 3675 | Maximum deviation: ±5 or ±5.0% (whichever is greater) |
| %Retic (%) | 0.2 – 24.5 | 0.8 – 26.4 | 0.7 – 26.3 | Maximum deviation: ±5.0% |
| CSF WBC Low (cells/μL) | 0 – 50 | 0 – 52 | 0 – 52 | Maximum Deviation: ±5 cells/μL |
| CSF RBC Low (cells/μL) | 0 – 50 | 0 – 46 | 0 – 51 | Maximum Deviation: ±5 cells/μL |
| CSF RBC High (cells/μL) | 50 – 1500 | 0 – 1509 | 0 – 1508 | Maximum Deviation: ±10% |
| Body Fluid TNC Low (cells/μL) | 0.02 – 400 | 1 – 542 | 0 – 618 | Maximum deviation: ±10 cells/μL or ±10.0% (whichever is greater) |
| Body Fluid RBC (10³cells/μL) | 0.1 – 6.76 | 0 – 7190 | 0 - 7105 | Maximum deviation: ±10x10³cells/μL or ±10.0% (whichever is greater) |
{9}
d. Carryover:
Carryover was tested for the WBC, RBC, Hgb, Plt, and retic channels of the system. A carryover set consisted of assaying a high pool followed by 3 aspirations of phosphate buffered saline. The carryover procedure consisted of performing 10 carryover sets. Carryover was tested in configurations 2 and 3, and within each configuration, carryover was tested with the Autosampler (AS), the manual closed tube sampler (MCTS), and the manual opened tube sampler (MOTS). Carryover in the reticulocyte channel was calculated using the RTC-RBC count (i.e. the RBC count derived from the reticulocyte channel). The observed results for the 10 carryover sets met specifications for all parameters, having less than $1\%$ carryover in both configurations.
| Parameter / Configuration | Average % Carryover | | |
| --- | --- | --- | --- |
| | ACTS | MCTS | MOTS |
| WBC – Configuration 2 | 0.18 | 0.33 | 0.21 |
| WBC – Configuration 3 | 0.19 | 0.26 | 0.17 |
| RBC – Configuration 2 | 0.14 | 0.14 | 0.14 |
| RBC – Configuration 3 | 0.14 | 0.14 | 0.40 |
| Hgb – Configuration 2 | 0.00 | 0.00 | 0.00 |
| Hgb – Configuration 3 | 0.00 | 0.00 | 0.00 |
| PLT – Configuration 2 | 0.23 | 0.25 | 0.22 |
| PLT – Configuration 3 | 0.82 | 0.83 | 0.83 |
| RTC-RBC – Configuration 2 | 0.14 | 0.15 | 0.21 |
| RTC-RBC – Configuration 3 | 0.14 | 0.14 | 0.24 |
e. Interfering Substances:
Refer to related $510(\mathrm{k})$ clearances in item 2 above.
f. Background Counts:
Refer to related $510(\mathrm{k})$ clearances in item 2 above.
2. Other Supportive Instrument Performance Data Not Covered Above:
Not applicable
K. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
L. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.