AP-3000 BLOOD GLUCOSE MONITORING SYSTEM, MAJOR GLUCOSE CONTROL SOLUTION
Applicant
Bestgen Biotech Corp.
Product Code
CGA · Clinical Chemistry
Decision Date
Apr 24, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The AP-3000 Blood Glucose Monitoring System is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes at home. The AP-3000 Blood Glucose Monitoring Systems is intended for testing outside the body (in vitro diagnostic use). It is intended for use by lay users and should only be used by a single patient as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates. The AP-3000multi Blood Glucose Monitoring System is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes. The AP-3000multi Blood Glucose Monitoring Systems is intended for testing outside the body (in vitro diagnostic use). It is intended for multi-patient use in a professional healthcare setting, as an aid to monitor the effectiveness of diabetes control. This system is only used with single-use, auto-disabling lancing devices. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
Device Story
System measures capillary whole blood glucose via amperometric method using glucose oxidase enzyme. User applies blood sample to test strip; meter detects current proportional to glucose concentration. AP-3000 intended for home self-testing; AP-3000multi intended for professional multi-patient settings using single-use, auto-disabling lancing devices. Meter requires calibration via code on test strip vial. Output displayed on screen; aids patients/clinicians in monitoring diabetes control. System includes control solutions for accuracy verification. Multi-patient version validated for disinfection with Caviwipe to prevent cross-contamination.
Clinical Evidence
Performance evaluated in laboratory and clinical settings by healthcare professionals and lay users. Studies confirmed system performance meets intended use requirements. No specific sensitivity/specificity metrics provided in summary.
Indicated for quantitative measurement of glucose in fresh capillary whole blood from finger, palm, forearm, upper arm, calf, and thigh. Intended for persons with diabetes to monitor effectiveness of diabetes control. AP-3000 is for single-patient home use; AP-3000multi is for multi-patient professional healthcare use. Contraindicated for neonates, critically ill patients, patients in shock, dehydrated, hypotensive, or hyperosmolar patients. AST values not for CGM calibration or insulin-dosing calculators.
Regulatory Classification
Identification
A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
Special Controls
*Classification.* Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.
Predicate Devices
AP-1000 Blood Glucose Monitoring System (k090389)
Submission Summary (Full Text)
{0}
1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k103230
B. Purpose for Submission:
New device
C. Measurand:
Capillary whole blood glucose
D. Type of Test:
Quantitative, amperometric method, Glucose Oxidase
E. Applicant:
Bestgen Biotech Corporation
F. Proprietary and Established Names:
AP-3000 Blood Glucose Monitoring System
AP-3000multi Blood Glucose Monitoring System
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| CGA, glucose oxidase, glucose | Class II | 21 CFR § 862.1345 | Clinical Chemistry (75) |
| NBW, system, test, blood glucose, over the counter | Class II | 21 CFR § 862.1345 | Clinical Chemistry (75) |
| JJX, single (specified) analyte controls (assayed and unassayed) | Class I, reserved | 21 CFR § 862.1660 | Clinical Chemistry (75) |
H. Intended Use:
1. Intended use(s):
See indications for use below.
2. Indication(s) for use:
{1}
2
# AP-3000 Blood Glucose Monitoring System
The AP-3000 Blood Glucose Monitoring System is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes at home. The AP-3000 Blood Glucose Monitoring Systems is intended for testing outside the body (in vitro diagnostic use). It is intended for use by lay users and should only be used by a single patient as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
The AP-3000 Meter is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes at home. AP-3000 Blood Glucose Test Strips must be used with the AP-3000 Meter. The AP-3000 Meter is intended for testing outside the body (in vitro diagnostic use). It is intended for use by lay users and should only be used by a single patient as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
The AP-3000 Blood Glucose Test Strips are intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes at home. AP-3000 Blood Glucose Test Strips must be used with the AP-3000 Blood Glucose Meter. The AP-3000 Blood Glucose Test Strips are intended for self testing outside the body (in vitro diagnostic use). It is intended for use by lay users and should only be used by a single patient as an aid to monitor the effectiveness of diabetes control. It is intended to be used by a single person and should not be shared. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
MAJOR Level I/Level II Control Solution is for use with AP-3000 meter and AP-3000 Blood Glucose Test Strips as a quality control check to verify the accuracy of blood glucose test results.
# AP-3000multi Blood Glucose Monitoring System
The AP-3000multi Blood Glucose Monitoring System is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes. The AP-3000multi Blood Glucose Monitoring Systems is intended for testing outside the body (in vitro diagnostic use). It is intended for multi-patient use in a professional healthcare setting, as an aid to monitor the effectiveness of diabetes control. This system is only used with single-use, auto-disabling
{2}
lancing devices. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
The AP-3000multi Meter is intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes. AP-3000multi Blood Glucose Test Strips must be used with the AP-3000multi Meter. AP-3000multi Meter is intended for testing outside the body (in vitro diagnostic use). It is intended for multi-patient use in a professional healthcare setting, as an aid to monitor the effectiveness of diabetes control. This system is only used with single-use, auto-disabling lancing devices. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
The AP-3000multi Blood Glucose Test Strips are intended for use in the quantitative measurement of glucose in fresh capillary whole blood from the finger and from the alternative sites (palm, forearm, upper arm, calf, and thigh) for self testing by persons with diabetes. AP-3000multi Blood Glucose Test Strips must be used with the AP-3000multi Meter. AP-3000multi Blood Glucose Test Strips are intended for testing outside the body (in vitro diagnostic use). It is intended for multi-patient use in a professional healthcare setting, as an aid to monitor the effectiveness of diabetes control. This system is only used with single-use, auto-disabling lancing devices. It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
MAJOR Level I/Level II Control Solution is for use with AP-3000multi meter and AP-3000multi Blood Glucose Test Strips as a quality control check to verify the accuracy of blood glucose test results.
3. Special conditions for use statement(s):
- Testing is done outside the body (in vitro diagnostic use).
- The alternative site testing (palm, forearm, upper arm, calf, and thigh) in this system can be used only during steady-state blood glucose conditions.
- It is not intended for the diagnosis of or screening for diabetes mellitus, and is not intended for use on neonates.
- Not for use on critically ill patients, patients in shock, dehydrated patients, hypotensive patients or hyperosmolar patients.
- AST value should not be used to calibrate Continuous Glucose Monitors (CGMs) or entered into an insulin-dosing calculator for determining insulin dose.
- Multiple patient use device should only use single use, auto disabling lancing devices.
- Single-patient use device is for use on single-patient use only and should not be shared.
4. Special instrument requirements:
AP-3000 Blood Glucose Meter and AP-3000 Blood Glucose Test Strips
AP-3000multi Blood Glucose Meter and AP-3000multi Blood Glucose Test Strips
{3}
Disposable, single use lancet devices are used with the AP-3000multi BGMS.
# I. Device Description:
The AP-3000 Blood Glucose Monitoring System consists of the AP-3000 Blood Glucose Meter, AP-3000 Blood Glucose Test Strips, MAJOR Control Solutions (Level I and II), lancing device, User's Guide and Quick Guide. The AP-3000 Blood Glucose Meter must be calibrated with the code found on the test strip vial label. This device can be used to measure fresh capillary blood from the finger, or alternative sites (palm, forearm, upper arm, calf, and thigh).
The AP-3000multi Blood Glucose Monitoring System consists of the AP-3000multi Blood Glucose Meter, AP-3000multi Blood Glucose Test Strips, MAJOR Control Solutions (Level I and II), single use lancing devices, User's Guide and Quick Guide. The AP-3000 Blood Glucose Meter must be calibrated with the code found on the test strip vial label. This device can be used to measure fresh capillary blood from the finger, or alternative sites (palm, forearm, upper arm, calf, and thigh).
# J. Substantial Equivalence Information:
| Predicate device name | Predicate 510(k) number |
| --- | --- |
| AP-1000 Blood Glucose Monitoring System | k090389 |
Comparison with predicate:
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Device (k103230) | Predicate (k090389) |
| Indications for Use | For the quantitative measurement of glucose, as an aid to monitor the effectiveness of diabetes control. | Same |
| Testing Site | Fingertips and alternate site testing (palm, forearm, upper arm, calf, and thigh) | Fingertips |
| Detection Method | Amperometry | Same |
| Enzyme | Glucose Oxidase (Aspergillus niger) | Same |
| Measurement Range | 20 to 600 mg/dL | Same |
| Hematocrit Range | 20 to 60% | 30-55% |
| Sample Volume | 0.7 μl | 0.6 μl |
| Reaction Time | 7 seconds | 6 seconds |
| Memory | 448 measurements | 960 measurements |
| Temperature Range | 50 to 104°F | Same |
| Humidity Range | 0 to 85% | 20 to 80% |
{4}
5
K. Standard/Guidance Document Referenced (if applicable):
ISO 15197. In vitro diagnostic test systems. Requirements for blood-glucose monitoring systems for self-testing in managing diabetes mellitus.
L. Test Principle:
The AP-3000 and AP-3000multi Blood Glucose Monitoring Systems use electrochemical methodologies. The systems quantitatively measure blood glucose levels using an amperometric method, which involves detecting the current produced from glucose oxidation. The electrons generated during this reaction are transferred from the blood to the electrodes. The magnitude of the resultant current is proportional to the concentration of glucose in the specimen and the signal is converted into a readout displayed on the meter.
M. Performance Characteristics (if/when applicable):
The AP-3000 and AP-3000multi Blood Glucose Monitoring Systems are the same meters and use the same test strip; however they have separate names due to their different indications for use (single- vs. multiple-patient use).
1. Analytical performance:
a. Precision/Reproducibility:
Within-run precision was measured by using five spiked venous whole blood samples (hematocrit ranging from 35% to 50%). Each sample was tested on three lots of test strips on ten meters. Ten replicates were tested per meter, test strip lot, and glucose concentration, (n=100 tests per test strip lot). Results are summarized below:
| Sample | Mean (mg/dL) | Strip Lot | SD (mg/dL) | %CV |
| --- | --- | --- | --- | --- |
| 1 | 46 | 1 | 2.3 | 5.3 |
| | | 2 | 2.2 | 5.0 |
| | | 3 | 2.2 | 5.0 |
| 2 | 95 | 1 | 2.4 | 2.6 |
| | | 2 | 2.3 | 2.5 |
| | | 3 | 2.4 | 2.6 |
| 3 | 129 | 1 | 2.3 | 1.9 |
| | | 2 | 2.2 | 1.8 |
| | | 3 | 2.5 | 2.0 |
| 4 | 230 | 1 | 5.5 | 2.5 |
| | | 2 | 5.9 | 2.6 |
| | | 3 | 5.9 | 2.6 |
| 5 | 350 | 1 | 10.6 | 3.0 |
| | | 2 | 10.3 | 2.9 |
| | | 3 | 10.7 | 3.0 |
Between-day precision was measured by reading three levels of control solutions.
{5}
Each sample was tested on three lots of test strips, twenty replicates per day for ten days using ten meters, (n=200 tests per test strip lot). Results are summarized below:
| Sample | Mean (mg/dL) | Strip Lot | SD (mg/dL) | %CV |
| --- | --- | --- | --- | --- |
| 1 | 45 | 1 | 2.2 | 5.1 |
| | | 2 | 2.5 | 5.6 |
| | | 3 | 2.6 | 5.8 |
| 2 | 125 | 1 | 2.9 | 2.4 |
| | | 2 | 3.0 | 2.5 |
| | | 3 | 2.7 | 2.2 |
| 3 | 325 | 1 | 7.2 | 2.2 |
| | | 2 | 7.1 | 2.2 |
| | | 3 | 6.8 | 2.1 |
b. Linearity/assay reportable range:
A linearity study was performed using ten spiked venous whole blood samples with the following concentrations: 10, 19, 42, 72, 123, 172, 260, 366, 480 and 595 mg/dL, which ranged from 10 to 595 mg/dL. All samples were tested on three lots of test strips, ten meters (ten measurements per test strip lot), on the AP-3000 Blood Glucose Meter. Glucose concentrations were tested on the YSI 2300 analyzer to generate the expected values. The observed values were plotted against the expected values and an appropriate line fitted by standard linear regression was generated with results summarized below:
Linear Regression Analysis:
Lot 1: $y = 0.9793x + 0.989, r^2 = 0.9992.$
Lot 2: $y = 0.9677x + 2.171, r^2 = 0.9993.$
Lot 3: $y = 0.9764x + 1.064, r^2 = 0.9996.$
Based upon the results, the sponsor claims a measurement range of 20 to 600 mg/dL for the AP-3000 and AP-3000 multi Blood Glucose Monitoring System
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Two levels of Control Solution (Level I and II) are included with each test kit. For each glucose control solution, a reference measurement was taken using an YSI 2300 analyzer. One hundred fifty measurements obtained with candidate meters were performed (30 bottles * 5 measurements/per bottle) for each glucose control solution and the mean value, SD and CV were calculated. Level I and II glucose control solutions were found to have ranges of 70-77 mg/dL and 200-215 mg/dL, respectively.
Stability characteristics of both levels of Glucose Control Solutions were determined using real time studies. The open vial stability was evaluated at 2, 25 and 30°C (all temperatures at 50% humidity), while the unopened vial stability was evaluated at 25°C (50% humidity). The sponsor claimed open vial stability of 90 days stored at 2 to 30°C and an unopened vial stability of 20 months stored at 25°C.
{6}
The stability characteristics of the test strips were evaluated in real-time open and closed vial studies. Open vial stability was determined by evaluating test strips stored at three temperatures (4, 30 and 40°C; 60% humidity) during a 100 day period. Closed vial stability was determined by evaluating test strips stored at three temperatures (4, 25 and 40°C; 50% humidity) during a 20 month period. Based upon their results, the sponsor claims an open vial stability of 90 days and an unopened shelf-life stability of 20 months stored at 4 to 40°C.
d. Detection limit:
The measuring range of the AP-3000 and AP-3000 multi Blood Glucose Monitoring System is 20 to 600 mg/dL. This range was verified by the linearity study (see section M.1.b.).
e. Analytical specificity:
Interference testing of exogenous and endogenous substances was performed using a protocol based on CLSI EP7-A. A venous blood sample (hematocrit level of 40 ±2%) was adjusted to two different glucose concentrations (125 and 250 mg/dL). Each potential interfering substance was added at several concentrations to an aliquot of each of the two glucose concentrations (test) and compared to the same sample without the potential interfering substance (control). Each interferent-glucose sample was tested using ten different meters and three lots of test strips. The YSI 2300 glucose analyzer was used as the reference method. The results are as follows:
| The following substances up to concentrations listed shall have no significant effect on test results (≤±10% difference) | |
| --- | --- |
| Acetaminophen | 0.5 mg/dL |
| Ascorbic Acid | 1.2 mg/dL |
| Bilirubin, Conjugated | 20 mg/dL |
| Cholesterol | 500 mg/dL |
| Creatinine | 30 mg/dL |
| Dopamine | 1.0 mg/dL |
| Ibuprofen | 40 mg/dL |
| L-DOPA | 1.0 mg/dL |
| Tetracycline | 4.0 mg/dL |
| Tolbutamide | 100 mg/dL |
| Triglyceride | 3,000 mg/dL |
| Uric Acid | 2.0 mg/dL |
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
The sponsor conducted an accuracy study, AP-3000 Blood Glucose Monitoring
{7}
System versus YSI-2300 Glucose Analyzer, at a single site with 100 patients over 10 days (10 patients per day) using two glucose meters and one test strip lot. A healthcare professional collected fingertip capillary blood into EDTA tubes. A portion of the collected sample was used to measure glucose concentration on an YSI-2300 Glucose Analyzer.
The total range of samples tested was 26.9 to $442\mathrm{mg / dL}$ , with a hematocrit range of $41 - 45\%$ . Five samples $< 50\mathrm{mg / dL}$ and five samples $>430\mathrm{mg / dL}$ were glycolyzed or spiked, respectively. Linear regression results are presented below:
# Linear Regression Analysis:
Meter #1: $y = 1.0764x - 8.8568$ , $r^2 = 0.9964$ , $n = 100$
Meter #2: $y = 1.0785x - 9.1703$ , $r^2 = 0.9969$ , $n = 100$
| For glucose concentrations <75 mg/dL | | | |
| --- | --- | --- | --- |
| User | Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL |
| Meter #1 | 11/15 (73%) | 15/15 (100%) | 15/15 (100%) |
| Meter #2 | 13/15 (87%) | 15/15 (100%) | 15/15 (100%) |
| For glucose concentrations ≥75 mg/dL | | | | |
| --- | --- | --- | --- | --- |
| User | Within ± 5 % | Within ± 10 % | Within ± 15 % | Within ± 20 % |
| Meter #1 | 67/85 (79%) | 84/85 (99%) | 85/85 (100%) | 85/85 (100%) |
| Meter #2 | 67/85 (79%) | 85/85 (100%) | 85/85 (100%) | 85/85 (100%) |
# AST Testing Data
The sponsor conducted a consumer study and alternative site testing study. At a single site, the sponsor conducted alternative site studies on palm, forearm, upper arm, calf and thigh with a total of 150 lay users. Each participant obtained samples from their fingertip, palm, forearm, upper arm, calf and thigh and tested these samples on the AP-3000 Blood Glucose meter using only the instructions in the user's manual and test strip insert. A healthcare professional collected blood from fingertip, palm, forearm, upper arm, calf and thigh and tested the sample using the same meter. Venous blood was also collected by healthcare professional and measured on an YSI-2300 Glucose Analyzer. Linear regression results from lay users and professionals are presented below.
| AST Site | User | Linear Regression Results | Sample Size (n) |
| --- | --- | --- | --- |
| Finger | Lay User | y = 1.033x - 3.962, r² = 0.9908 | 150 |
| Palm | Lay User | y = 0.9922x - 0.3956, r² = 0.983 | 150 |
| Forearm | Lay User | y = 0.985x + 0.8029, r² = 0.9813 | 150 |
| Upper arm | Lay User | y = 0.9607x + 2.7539, r² = 0.9808 | 150 |
| Calf | Lay User | y = 0.9818x + 1.1073, r² = 0.9802 | 150 |
| Thigh | Lay User | y = 0.9812x + 1.0691, r² = 0.98 | 150 |
| Finger | Professional | y = 1.0144x - 1.1774, r² = 0.9916 | 150 |
| Palm | Professional | y = 0.9913x + 0.0034, r² = 0.987 | 150 |
{8}
All alternative site results met the ISO 15197 accuracy criteria where ninety-five percent (95%) of the individual glucose results fell within $\pm 15\mathrm{mg / dL}$ of the YSI results at glucose concentrations $< 75\mathrm{mg / dL}$ and within $\pm 20\%$ at glucose concentrations $\geq 75\mathrm{mg / dL}$ .
| For glucose concentrations <75 mg/dL | | | | |
| --- | --- | --- | --- | --- |
| AST Site | User | Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL |
| Finger | Lay User | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Palm | Lay User | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Forearm | Lay User | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Upper arm | Lay User | 7/8 (88%) | 8/8 (100%) | 8/8 (100%) |
| Calf | Lay User | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Thigh | Lay User | 6/8 (75%) | 8/8 (100%) | 8/8 (100%) |
| Finger | Professional | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Palm | Professional | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Forearm | Professional | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Upper arm | Professional | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Calf | Professional | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| Thigh | Professional | 8/8 (100%) | 8/8 (100%) | 8/8 (100%) |
| For glucose concentrations ≥75 mg/dL | | | | | |
| --- | --- | --- | --- | --- | --- |
| AST Site | User | Within ± 5 % | Within ± 10 % | Within ± 15 % | Within ± 20 % |
| Finger | Lay User | 137/142 (96%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Palm | Lay User | 122/142 (86%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Forearm | Lay User | 118/142 (83%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Upper arm | Lay User | 107/142 (75%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Calf | Lay User | 107/142 (75%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Thigh | Lay User | 105/142 (74%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Finger | Professional | 139/142 (98%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Palm | Professional | 128/142 (90%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Forearm | Professional | 120/142 (85%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Upper arm | Professional | 118/142 (83%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Calf | Professional | 110/142 (77%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
| Thigh | Professional | 109/142 (77%) | 142/142 (100%) | 142/142 (100%) | 142/142 (100%) |
{9}
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):
Not applicable
4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
Expected blood glucose values for nondiabetic adults are as follows:
Before eating < 100 mg/dL
Two hours after meals < 140 mg/dL
Reference:
American Diabetes Association: Diabetes Care, Volume 34, Supplement 1, January 2011, p. S11-S61.
N. Instrument Name:
AP-3000 Blood Glucose Meter and AP-3000multi Blood Glucose Meter
O. System Descriptions:
1. Modes of Operation:
Each test strip is single use and must be replaced with a new strip for additional readings.
Does the applicant’s device contain the ability to transmit data to a computer, webserver, or mobile device?:
Yes ☐ or No ☑
Does the applicant’s device transmit data to a computer, webserver, or mobile device using wireless transmission?:
Yes ☐ or No ☑
2. Software:
{10}
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ X or No ☐
3. Specimen Identification:
There is no sample identification function with this device. Samples are applied directly to the test strip as they are collected.
4. Specimen Sampling and Handling:
This device is intended to be used with capillary whole blood from the finger palm, forearm, upper arm, calf, and thigh which can be applied directly to the test strip.
5. Calibration:
The AP-3000 and AP-3000 multi Blood Glucose Meters must be calibrated with the code found on the current test strip vial label. No further calibration is required.
6. Quality Control:
The sponsor has two levels of controls (Level I and II) supplied with this meter. When a test strip is inserted into the meter, each control can be measured by following the instructions for “Quality Control Testing” provided in the User Manual for the meter. An acceptable range for each control level is printed on the test strip vial label. The user is instructed to contact Customer Service if the control results fall outside these ranges.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The “Performance Characteristics” Section above:
- A usability study was performed to assess the readability of the labeling for the US market by surveying the 150 lay users that participated in the study. Participants varied in age, education, and gender. These lay users also completed a questionnaire to response to whether the device is easy to use and the ‘Instructions for use’ were written in a way that makes it easy to use. The majority of the users responded that the device is very easy to use.
- Flesch-Kincaid readability assessment was conducted and the results showed that the labeling (User’s Guide, test strip package insert and control solution package insert) was written at the 8th grade level.
- Customer service is available between 8:30 am and 5:30 PM—Pacific Standard Time, Monday through Friday. Users are instructed to contact their healthcare providers outside hours of operation. The toll free US phone number is 1-888-873-1021 for customer support.
- The device is intended for single (AP-3000 Blood Glucose Monitoring System) and multiple-patient use (AP-3000 multi Blood Glucose Monitoring System). Caviwipe Disinfecting Towelettes (Metrex Research Corporation, EPA registration #46781-8) were validated demonstrating complete inactivation of Hepatitis B surface antigen for
11
{11}
use with the blood glucose meter and the lancing device (for use only with the single-patient use system). The sponsor also demonstrated that there was no change in performance or in the external materials of the meter and lancing device after 18,250 cleaning and disinfection cycles for the meter (5000 cycles for the lancing device) designed to simulate 5 years of device use. Each robustness cycle tested consisted of one pre-clean wipe and one disinfecting wipe. Labeling was reviewed for adequate instructions for the validated cleaning and disinfection procedures.
- EMC testing was evaluated and certified by Electronics Testing Center and a test report was submitted stating that the AP-3000 passed all tests; dated July 30, 2010.
- Temperature and humidity operating conditions were evaluated for temperatures ranging from -20 to $50^{\circ}\mathrm{C}$ and relative humidity ranging from 0 to $93\%$. Protocol and acceptance criteria were provided and found to be acceptable. The results support the sponsor's claimed operating temperature of 4 to $40^{\circ}\mathrm{C}$ and humidity range of 0 to $85\%$.
- A study was conducted to evaluate the effect of altitude of the AP-3000 BGMS. A venous blood sample adjusted to five different glucose concentrations (54, 81, 126, 271 and $453\mathrm{mg/dL}$) was tested on two meters and a single lot of test strips. Each venous blood sample was evaluated by the YSI 2300 glucose analyzer. Tests were performed at six different elevations (sea level, 2624 feet, 4921 feet, 6266 feet, 7119 feet and 10,742 feet). The meter readings obtained were compared to the YSI method, the percent bias against the YSI results was calculated and all results were found to support the sponsor claims that the AP-3000 BGMS can be used at altitudes up to 10,742 feet.
- A study was conducted to evaluate the potential interference from hematocrit using seven different hematocrit levels (15%, 20%, 30%, 40%, 50%, 60% and 70%). For each hematocrit level, five different glucose concentrations (10, 70, 170, 285 and 450 mg/dL) were tested against the YSI-2300 Glucose Analyzer. Each glucose level/hematocrit combination was tested on twenty meters and two lots of test strips. The differences of the glucose meter results at each hematocrit/glucose combination were calculated against YSI-2300 Glucose Analyzer results at 40% hematocrit. The bias relative to YSI was acceptable to support the claim that hematocrit levels of 20 to 60% do not significantly affect the glucose results.
- A sample volume study was performed to verify the test strip sample volume requirement for the AP-3000 BGMS. A venous blood sample adjusted to three glucose concentrations (66, 105 and $230\mathrm{mg/dL}$) was tested on one lot of test strips and ten meters. Each blood sample was applied to test strips at five sample volumes (0.6, 0.7, 0.8, 0.9, 1.0 and $1.1\mu\mathrm{l}$). Protocols and acceptance criteria were provided and found to be acceptable. The sponsor concluded that sample volume of $\geq 0.7\mu\mathrm{L}$ produced accurate results.
12
{12}
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.
13
Predicate graph will load when search results are available.
Embedding visualization will load when search results are available.
PDF viewer will load when search results are available.
Loading panels...
Select an item from Submissions
Click any panel, subpart, regulation, product code, or device to see details here.
Section Matches
Results will appear here.
Product Code Matches
Results will appear here.
Special Control Matches
Results will appear here.
Loading collections...
Loading
My Alerts
You will receive email notifications based on the filters and frequency you set for each alert.
Sort by:
Create Alert
Search Filters
Agent Token
Create a read-only bearer token for Claude, ChatGPT, or other agents that can call HTTP APIs.
Copy this now. It will not be shown again.
Connected apps
Apps you authorized through browser sign-in. Disconnecting revokes their access immediately.
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.