K112414 · Phadia US, Inc. · MSV · Jun 22, 2012 · Immunology
Device Facts
Record ID
K112414
Device Name
ELIA B2-GLYCOPROTEIN I IGA IMMUNOASSAY
Applicant
Phadia US, Inc.
Product Code
MSV · Immunology
Decision Date
Jun 22, 2012
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 866.5660
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K112414 · Jun 22, 2012
ELIA B2-GLYCOPROTEIN I IGA IMMUNOASSAY
Phadia US, Inc.
Clinically defined human serum samples
Clinically defined sera were used to evaluate the performance of the new device and demonstrate substantial equivalence to the predicate device.
Clinically defined sera; Diagnostic validation
Clinical Evidence
Study Design
Population
Comparator
Key Endpoints
Retrospective analysis of clinically defined sera
Patients with clinical diagnoses relevant to APS and SLE
Predicate device (K040450)
Comparison of results between new and predicate device
Indications for Use
EliA™ β2-Glycoprotein I IgA is intended for the in vitro semi-quantitative measurement of IgA antibodies directed to β2-Glycoprotein I in human serum and plasma (heparin, EDTA, citrate) to aid in the diagnosis of antiphospholipid syndrome (APS) as well as thrombotic disorders related to systemic lupus erythematosus (SLE) in conjunction with other laboratory and clinical findings. EliA™ β2-Glycoprotein I IgA uses the EliA IgA method on the instruments Phadia® 100 and Phadia® 250.
Device Story
The EliA™ β2-Glycoprotein I IgA is an automated semi-quantitative immunofluorescence assay for detecting IgA antibodies to β2-Glycoprotein I in human serum or plasma. The device utilizes microwells coated with purified human β2-glycoprotein I antigen. Patient samples are processed on Phadia® 100 or Phadia® 250 automated analyzers; patient antibodies bind to the antigen; enzyme-labeled anti-IgA conjugate is added; after washing, a development solution is added to produce a fluorescent signal. The instrument measures fluorescence intensity, which is proportional to the concentration of bound IgA antibodies. Results are compared against a calibration curve to provide a semi-quantitative value. The device is intended for use in clinical laboratories by trained personnel to aid in the diagnosis of APS and SLE-related thrombotic disorders. The output assists clinicians in confirming clinical findings and managing patient care.
Clinical Evidence
Clinical performance was evaluated using 424 serum samples from patients with APS (n=124), SLE (n=100), and various other conditions (infections, MCTD, RA, cancer). Sensitivity for APS was 44.4% (equivocal as negative) to 53.2% (equivocal as positive), with specificity of 96.5% to 94.5%. For SLE, sensitivity was 13.0% to 30.0% with similar specificity. Method comparison against the predicate showed total percent agreement of 88.9%–89.7%.
Technological Characteristics
Semi-quantitative immunofluorescence assay. Components: β2-glycoprotein I coated microwells, β-galactosidase labeled anti-IgA conjugate, calibrators, and controls. Instrumentation: Phadia® 100/250 automated analyzers. Detection: Fluorescence. Measuring range: 0.3–183 U/mL. Calibration: Traceable to WHO IRP 67/86. Software: Automated processing and result calculation. Sterilization: Not applicable (reagents).
Indications for Use
Indicated for patients suspected of having antiphospholipid syndrome (APS) or thrombotic disorders related to systemic lupus erythematosus (SLE). For prescription use only.
Regulatory Classification
Identification
A multiple autoantibodies immunological test system is a device that consists of the reagents used to measure by immunochemical techniques the autoantibodies (antibodies produced against the body's own tissues) in serum and other body fluids. Measurement of multiple autoantibodies aids in the diagnosis of autoimmune disorders (disease produced when the body's own tissues are injured by autoantibodies).
Predicate Devices
Varelisa β2-Glycoprotein I IgA Antibodies (k040450)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
k112414
B. Purpose for Submission:
New device
C. Measurand:
IgA Antibodies to β2-Glycoprotein I
D. Type of Test:
Semi-quantitative immunofluorescence assay
E. Applicant:
Phadia US Inc.
F. Proprietary and Established Names:
EliA™ β2-Glycoprotein I IgA Immunoassay
G. Regulatory Information:
1. Regulation section:
21 CFR §866.5660, Multiple Autoantibodies Immunological Test System
2. Classification:
Class II
3. Product code:
MSV, System, Test, Antibodies, β2-Glycoprotein I (β2-GPI)
4. Panel:
Immunology (82)
H. Intended Use:
1. Intended use(s):
EliA™ β2-Glycoprotein I IgA is intended for the in vitro semi-quantitative measurement of IgA antibodies directed to β2-Glycoprotein I in human serum and plasma (heparin, EDTA, citrate) to aid in the diagnosis of antiphospholipid syndrome (APS) as well as thrombotic disorders related to systemic lupus erythematosus (SLE) in conjunction with other laboratory and clinical findings. EliA™ β2-Glycoprotein I IgA uses the EliA IgA method on the instruments Phadia® 100 and Phadia® 250.
2. Indication(s) for use:
Same as intended use
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3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
Phadia® 100 and Phadia® 250 (formerly known as ImmunoCAP 100 and 250) (k061165)
I. Device Description:
The method specific reagents on Phadia® 100 and Phadia® 250 are identical; they are only filled in different containers.
Each device consists of:
- β2-glycoprotein I IgA wells are coated with human β2-glycoprotein I antigen – 2 carriers (12 wells each), ready to use;
- EliA method-specific sample diluent, PBS containing BSA, detergent and 0.095% sodium azide – 6 vials, 9 mL each, ready to use;
- EliA IgA conjugate, β-galactosidase labeled anti-IgA (mouse monoclonal antibodies) – 2 or 6 vials, 4.8 mL each, ready to use;
- Negative control: containing normal human serum from healthy donors – 6 single-use vials, 0.3 mL each, ready to use;
- EliA calibrators, human IgA in PBS (0, 0.3, 1.5, 5, 15, 80 μg/L) – 6 single-use vials, 0.3 mL each, ready to use;
- IgA curve control, human IgA (5μg/L) in PBS, 6 single-use vials, 0.3 mL each, ready to use.
The Phadia EliA™ Immunodiagnostic System is automated system for immunodiagnostic testing. The EliA™ reagents are available as modular packages, each purchased separately. All packages except the positive and negative controls are required to carry out an EliA™ β2-Glycoprotein I IgA Test.
J. Substantial Equivalence Information:
1. Predicate device name(s) and 510(k) number(s):
Valerisa β2-Glycoprotein I IgA Antibodies, k040450
2. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | New EliA™ Device | Predicate Varelisa IgA Device |
| Intended Use/Indications for Use | A semi-quantitative measurement of IgA antibodies directed to β2-Glycoprotein I in human serum and plasma (heparin, EDTA, citrate) to aid in the diagnosis of antiphospholipid syndrome (APS) as well as thrombotic | Same |
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| Similarities | | |
| --- | --- | --- |
| Item | New EliA™ Device | Predicate Varelisa IgA Device |
| | disorders related to systemic lupus erythematosus (SLE) in conjunction with other laboratory and clinical findings. | |
| Controls | Negative Control sera provided in a separate package | Same |
| Assay Type | ELISA | Same |
| Type of Test | Semi-quantitative | Semi-quantitative and qualitative |
| Antigen | Human purified β2-Glycoprotein I | Same |
| Solid phase | Microwells | Same |
| Differences | | |
| --- | --- | --- |
| Item | New EliA™ Device | Predicate Varelisa IgA Device |
| Instrumentation | Phadia® 100 and 250 automated immunoassay analyzers | ELISA reader |
| Reaction Temperature | 37°C controlled | Room temperature (18-25°C) |
| Detection Antibody (conjugate) | IgA Conjugate: anti-human IgA β-Galactosidase (mouse monoclonal antibodies) | IgA Conjugate: anti-human IgA horse-radish peroxidase |
| Signal | Fluorescence | Optical density |
| Calibration | Total IgA calibration | Analyte-specific IgA calibration |
| Calibrators | 0, 0.3, 1.5, 5, 15, 80 μg/L | 0, 4, 8, 20, 40, 100 U/mL |
| Calibration Curve | Human IgA, 5 μg/L Option to store curve up to 28 days and run curve controls in each assay for calibration | Calibration curve in each assay |
| Measuring Range | 0.3 – 183 U/mL | 1 – 100 U/mL |
| IgA Cut-off | Negative <7 U/mL Equivocal 7 – 10 U/mL Positive >10 U/mL | Negative <10 U/mL Equivocal 10 – 15 U/mL Positive >15 U/mL |
| Concept | Modular reagents concept (test-method specific and general reagents) | All reagents in a single kit |
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# K. Standard/Guidance Document Referenced (if applicable):
CLSI EP17-A, Protocols for Determination of Limits of Detection and Limits of Quantification, Approved Guideline.
# L. Test Principle:
The EliA™ $\beta 2$ -glycoprotein I IgA wells are coated with purified human $\beta 2$ -glycoprotein I. If present in the patient's specimen, antibodies bind to their specific antigen. After washing away non-bound antibodies, enzyme-labeled antibodies against human IgA antibodies (EliA IgA Conjugate) are added to form an antibody-conjugate complex. After incubation, non-bound conjugate is washed away and the bound complex is incubated with a Development Solution. After stopping the reaction, the fluorescence in the reaction mixture is measured. The higher the value of fluorescent signal detected by the instrument, the higher the amount of antibody bound and detected in the sample tested. To evaluate test results, the response for patient samples is compared directly to the response for calibrators.
# M. Performance Characteristics (if/when applicable):
# 1. Analytical performance:
# a. Precision/Reproducibility:
To determine the precision of the assays on Phadia® 100 and Phadia® 250 instrument, the variability was assessed on 8 samples. Each sample was run in 4 replicates for 7 days on 3 instruments. One batch was used to determine the precision of the assays on Phadia® 100 (equal to 84 replicate determinations per sample). Three batches were used to determine the precision of the assays on Phadia® 250 (equal to 252 replicate determinations per sample). The results are summarized in the tables below:
EliA™ β2-Glycoprotein I IgA on Phadia® 100 (n=84)
| Mean value U/mL | Intra-Run CV% | Inter-Run CV% | Total Imprecision %CV |
| --- | --- | --- | --- |
| 9.7 | 2.7 | 3.0 | 4.0 |
| 25.7 | 2.9 | 3.4 | 4.4 |
| 135.9 | 3.3 | 5.3 | 6.3 |
| 7.0 | 3.2 | 3.1 | 4.6 |
| 7.4 | 2.7 | 3.7 | 4.5 |
| 8.4 | 4.2 | 0.9 | 4.3 |
| 10.3 | 3.0 | 2.3 | 3.8 |
| 3.7 | 12.6 | 4.6 | 13.4 |
EliA™ β2-Glycoprotein I IgA on Phadia® 250 (n = 252)
| Mean value U/mL | Intra Run CV% | Inter Run CV% | Lot to Lot CV% | Total Imprecision %CV |
| --- | --- | --- | --- | --- |
| 10.4 | 3.9 | 1.4 | 3.0 | 4.1 |
| 27.7 | 3.9 | 1.8 | 4.0 | 4.3 |
| 146.6 | 5.2 | 3.7 | 4.6 | 6.3 |
| 7.0* | 2.3 | 2.1 | not done | 3.1 |
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| 7.4* | 2.8 | 2.0 | not done | 3.6 |
| --- | --- | --- | --- | --- |
| 8.8 | 4.9 | 1.6 | 1.6 | 5.2 |
| 10.8 | 3.9 | 1.4 | 4.2 | 4.1 |
| 3.9 | 9.7 | 6.9 | 9.4 | 11.9 |
\* $\mathrm{n} = {84}$
# b. Linearity/assay reportable range:
Eight patient serum samples were diluted in sample diluent and tested with one batch of EliA™ $\beta 2$ -Glycoprotein I IgA and one set of system reagents on Phadia® 100 or Phadia® 250. The ratios of observed/expected values were calculated. Depending on the lot specific EliA™ well factor, the upper limit of the measuring range may vary between different solid phase batches. The results are summarized below:
EliA™ $\beta 2$ -Glycoprotein I IgA on Phadia® 100
| Dilution range (U/mL) | Slope | Intercept | R² |
| --- | --- | --- | --- |
| 57.5 – 0.9 | 0.99 | -0.28 | 0.998 |
| 32.5 - 0.6 | 0.99 | 0.39 | 1.000 |
| 116.7 – 3.9 | 0.94 | -1.63 | 0.999 |
| 39.0 – 1.2 | 1.02 | -0.62 | 0.999 |
| 9.2 – 0.3 | 1.03 | 0.02 | 0.997 |
| 14.9 – 0.2 | 1.02 | 0.05 | 0.996 |
| 191.6 – 67.9 | 1.10 | 6.13 | 0.991 |
The claimed linear range for $\beta 2$ -Glycoprotein I IgA is $0.3 - 183~\mathrm{U / mL}$
EliA™ $\beta 2$ -Glycoprotein I IgA on Phadia® 250
| Dilution range (APL-U/mL) | Slope | Intercept | R² |
| --- | --- | --- | --- |
| 68.0 – 1.0 | 1.01 | -0.62 | 1.000 |
| 41.3 – 0.6 | 1.07 | 0.37 | 0.999 |
| 106.6 – 1.8 | 0.94 | 0.12 | 1.000 |
| 96.1 -1.6 | 0.93 | 0.58 | 0.999 |
| 9.7 – 0.5 | 1.03 | 0.04 | 0.998 |
| 9.2 – 0.6 | 1.04 | -0.17 | 1.000 |
| 215.4 – 75.3 | 0.90 | 18.78 | 0.987 |
The claimed linear range for $\beta 2$ -Glycoprotein I IgA is $0.3 - 183~\mathrm{U / mL}$
# Hook Effect/Over the Range Results:
Hook effect was investigated by using a serum sample above the highest calibration point. A high positive sample was diluted and the dilutions were measured in four replicates and compared to Cal-80 (80 $\mu$ g/L about 180 U/mL).
No hook effect was observed for concentrations up to 2877.2 U/mL.
Results above the upper limit of the measuring range are reported as "above". No recommendations are made for dilution of samples outside measuring range in the
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Package Insert.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability:
The IgA calibrators are traceable (via unbroken chain of calibrations) to the International Reference Preparation (IRP) 67/86 of Human Serum Immunoglobulins A, G and M from WHO. New batches of IgA calibrators are compared to a secondary standard (standardized with the IRP) or the IRP directly and adjusted accordingly to meet the correct concentration.
The instrument measures specific IgA concentrations in $\mu \mathrm{g} / \mathrm{L}$. By using a conversion factor given by the lot-specific code of the EliA™ $\beta 2$-Glycoprotein I IgA Well, the results are automatically converted to U/mL.
Stability:
The EliA™ IgA system reagents, EliA™ APS Positive Control and EliA™ Negative Control are already FDA cleared under k063775, k091845 and k072393, respectively.
Shelf life:
Accelerated study was done to determine the shelf life EliA™ $\beta 2$-Glycoprotein I IgA wells and was determined to be 24 months. Real time stability test is ongoing.
On board stability:
The onboard stability EliA™ $\beta 2$-Glycoprotein I IgA carriers (containing the antigen coated wells) was tested over 6 weeks using 3 positive and 2 negative samples only on the Phadia® 250 instrument since for Phadia® 100 the reagents are stored off the instrument and are only loaded as needed for an assay. The on-board stability for the Phadia® 250 instrument was determined to be 28 days at $2 - 8^{\circ}\mathrm{C}$.
Open Stability:
Stability of the foilbag containing the EliA™ wells after first opening was tested using k082759 tTG test and determined to be 9 months at $2 - 8^{\circ}\mathrm{C}$.
d. Detection limit:
The limit of blank (LoB) and limit of detection (LoD) studies were done on both Phadia® 100 and Phadia® 250. One negative and five blood donors with low antibody concentration were measured in twelve replicates in each of six runs on six different days (12 replicates x 6 runs x 6 days = 432 replicates per sample). On Phadia® 250 the runs are spread on three instruments, with two runs per instrument. On Phadia® 100 there is one run per instrument. The results are summarized in the table below:
| EliA™ β2-Glycoprotein I IgA (U/mL) | LoB | LoD |
| --- | --- | --- |
| Phadia® 100 | 0.17 | 0.25 |
| Phadia® 250 | 0.14 | 0.19 |
It was decided to use a single LoD of $0.3\mathrm{U / mL}$ for the study.
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# e. Analytical specificity:
Endogenous Interference: A study was run to investigate whether high concentrations of potentially interfering substances in serum, like bilirubin, hemoglobin, lipemic factor and rheumatoid factor adversely affect the results of the new devices. Three serum samples were prediluted in EliA™ Sample Diluent and spiked with the different interfering substances or their respective blank solutions, and analyzed in triplicates. A calibration curve was run in duplicate. The runs were repeated twice. One batch of EliA™ antigen wells and one batch of system reagents were used throughout the studies.
Samples with concentrations around 6.5, 10 and $47\mathrm{U / mL}$ were tested. The ratio of blank/spiked sample was $0.89 - 1.04$ . No interference was observed up to the concentrations listed in the table below:
| Potential Interfering Compound | Concentration |
| --- | --- |
| Bilirubin F | 20.6 mg/dL |
| Bilirubin C | 21.1 mg/dL |
| Hemoglobin | 519 mg/dL |
| Lipemic factor | 1% |
| Rheumatoid factor | 500 IU/mL |
Carry-over: A study was carried out on two Phadia® 250 instruments using the test EliA Celikey IgA, cleared under k062787 (for tTG). A serum sample was diluted 1:100 using the instrument dilution and manual dilution. No carry over effect was observed.
# f. Assay cut-off:
A study was done on 400 apparently healthy blood donor samples from Caucasian individuals equally distributed by sex and age in order to evaluate expected values for each of the antigens in the submission in the normal population and to confirm the defined cut-off. The samples were measured on the Phadia® 250 instrument. The 99th percentile of the 400 samples were calculated and taken into account for setting of the cut-off. The following values were selected for the cut-off:
| EliA™ β2-Glycoprotein I IgA | |
| --- | --- |
| <7 U/mL | Negative |
| 7 – 10 U/mL | Equivical |
| >10 U/mL | Positive |
# 2. Comparison studies:
# a. Method comparison with predicate device:
A total of 424 serum samples were collected in a laboratory specialized in APS diagnosis from patients with APS $(n = 124)$ , Systemic Lupus Erythematosus (SLE; $n = 100$ ), viral infections $(n = 60)$ , mixed connective tissue diseases (MCTD; $n = 50$ ),
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rheumatoid arthritis (n = 40), non-viral infections (n = 20), syphilis (n = 20) or cancer (n = 10). Samples were analyzed with the EliA™ β2-Glycoprotein I IgA and Varelisa β2-Glycoprotein I IgA assays. Additional 88 samples with known antibody status and unconfirmed clinical diagnosis were analyzed with β2-Glycoprotein I IgA. The test was run in single determination and values outside the measuring range were excluded from statistical analyses. The results are summarized in the tables below:
EliA™ β2-Glycoprotein I – Equivocal results evaluated as negative:
| | Valerisa β2-Glycoprotein I IgA (U/mL) | | | |
| --- | --- | --- | --- | --- |
| | | Positive >15 | Negative <15 | Total |
| EliA™ β2-Glycoprotein I IgA (U/mL) | Positive >10 | 85 | 33 | 118 |
| | Negative ≤10 | 17 | 351 | 368 |
| | Total | 102 | 384 | 486 |
Positive percent agreement: 83.3% (85/102) (95% CI: 74.7% – 90.0%)
Negative percent agreement: 91.4% (351/384) (95% CI: 88.1% – 94.0%)
Total percent agreement: 89.7% [(85+351)/486] (95% CI: 86.7% – 92.3%)
EliA™ β2-Glycoprotein I – Equivocal results evaluated as positive:
| | Valerisa β2-Glycoprotein I IgA (U/mL) | | | |
| --- | --- | --- | --- | --- |
| | | Positive >10 | Negative <10 | Total |
| EliA™ β2-Glycoprotein I IgA (U/mL) | Positive ≥7 | 118 | 37 | 155 |
| | Negative <7 | 17 | 314 | 331 |
| | Total | 135 | 351 | 486 |
Positive percent agreement: 87.4% (118/135) (95% CI: 80.6% – 92.5%)
Negative percent agreement: 89.5% (314/351) (95% CI: 85.8% – 92.5%)
Total percent agreement: 88.9% [(118+314)/486] (95% CI: 85.8% – 91.5%)
b. Matrix comparison:
Serum, lithium heparin plasma, citrate plasma and EDTA plasma were collected from the same patients (n = 50) to demonstrate that the plasma results do not deviate from the corresponding serum results and are within the pre-defined specifications. Samples were spiked with a serum sample of high antibody titer to cover the measuring range. Samples were tested in duplicates. Passing & Bablok regression plots were generated using the first replicate only and by plotting the concentration observed from the control tube (serum) versus the concentration for each test collection tube. The corresponding slopes of regression and coefficient determination are summarized in the tables below:
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| | Range tested (U/mL) | Slope (95% CI) | Intercept (95% CI) | R² |
| --- | --- | --- | --- | --- |
| Serum vs. citrate plasma | 1.1 – 201.2 | 1.05 (0.99 – 1.07) | 0.10 (-0.28 – 0.20) | 1.00 |
| Serum vs EDTA plasma | 1.3 – 193.8 | 1.03 (0.99 – 1.07) | 0.06 (-0.08 – 0.30) | 1.00 |
| Serum vs heparin plasma | 1.5 – 196.8 | 1.04 (1.01 – 1.06) | -0.01 (-0.25 – 0.18) | 1.00 |
c. Instrument comparison
Performance of EliA™ β2-Glycoprotein I IgA was evaluated on the Phadia® 100 and Phadia® 250 instruments using 32 positive and 4 negative samples. The samples were analyzed in six runs in single replicates on three Phadia®100 and three Phadia® 250 instruments, with 2 runs on each instrument. The regression analysis results are summarized as follows:
| | Intercept | Slope |
| --- | --- | --- |
| Estimate | -0.538 | 1.045 |
| 95% CI | -1.076 to 0.160 | 0.986 to 1.081 |
3. Clinical studies:
a. Clinical Sensitivity and specificity:
The clinical samples that were used for the method comparison were used to determine sensitivity and specificity of each assay. SLE samples with unknown APS status were also evaluated for their sensitivity/specificity. The results are summarized in the tables below:
EliA™ β2-Glycoprotein I IgA – diagnostic group APS - equivocal results evaluated as negative:
| | Diagnostic Group – APS | | |
| --- | --- | --- | --- |
| | + | - | total |
| Positive test >10 U/mL | 55 | 7 | 62 |
| Negative test ≤10 U/mL | 69 | 193 | 262 |
| Total | 124 | 200 | 324 |
Sensitivity (95% CI): 44.4% (35.4% – 53.5%)
Specificity (95% CI): 96.5% (92.9% – 98.6%)
EliA™ β2-Glycoprotein I IgA – diagnostic group APS - equivocal results evaluated as positive:
| | Diagnostic Group – APS | | |
| --- | --- | --- | --- |
| | + | - | total |
| Positive test >7 U/mL | 66 | 11 | 77 |
| Negative test ≤7 U/mL | 58 | 189 | 247 |
| Total | 124 | 200 | 324 |
Sensitivity (95% CI): 53.2% (44.1% – 62.2%)
Specificity (95% CI): 94.5% (90.4% – 97.2%)
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EliA™ β2-Glycoprotein I IgA – diagnostic group SLE - equivocal results evaluated as negative:
| | Diagnostic Group – SLE | | |
| --- | --- | --- | --- |
| | + | - | total |
| Positive test > 10 U/mL | 13 | 7 | 20 |
| Negative test ≤10 U/mL | 87 | 193 | 280 |
| Total | 100 | 200 | 300 |
Sensitivity (95% CI): 13.0% (7.1% – 21.2%)
Specificity (95% CI): 96.5% (92.9% – 98.6%)
EliA™ β2-Glycoprotein I IgA – diagnostic group SLE - Equivocal results evaluated as positive:
| | Diagnostic Group – SLE | | |
| --- | --- | --- | --- |
| | + | - | total |
| Positive test ≥7 U/mL | 30 | 11 | 41 |
| Negative test <7 U/mL | 70 | 189 | 259 |
| Total | 100 | 200 | 300 |
Sensitivity (95% CI): 30.0% (21.2% – 40.0%)
Specificity (95% CI): 94.5% (90.4% – 97.2%)
The table below shows the results for each clinical subgroup:
| Condition | Number of samples | No (%) pos on EliA™ | No (%) pos. on predicate |
| --- | --- | --- | --- |
| APS | 124 | 55 (44.4%) | 37 (29.8%) |
| SLE | 100 | 13 (13%) | 16 (16%) |
| MCTD | 50 | 1 (2%) | 3 (6%) |
| Syphilis | 20 | 1 (5%) | 2 (10%) |
| Viral infection | 60 | 3 (5%) | 3 (5%) |
| Bacterial infections | 20 | 1 (5%) | 0 (0%) |
| RA | 40 | 1 (2.5%) | 0 (0%) |
| Cancer | 10 | 0 (0%) | 0 (0%) |
c. Other clinical supportive data (when a. and b. are not applicable):
Not applicable
4. Clinical cut-off:
Same as assay cut-off
5. Expected values/Reference range:
The expected value in the normal population is negative. The sponsor states that the proportion of sera from a normal population found positive by the EliA™ β2-Glycoprotein I IgA test is up to 3%. The proportions of positive sera in apparently healthy and asymptomatic individuals increase with age, and men tend to show higher values. Expected values may vary depending on the population tested.
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N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.