TRUE METRIX SELF-MONITORING BLOOD GLUCOSE SYSTEM, TRUE METRIX PRO PROFESSIONAL MONITORING BLOOD GLUCOSE SYSTEM
K140100 · Nipro Diagnostics, Inc. · NBW · Aug 1, 2014 · Clinical Chemistry
Device Facts
Record ID
K140100
Device Name
TRUE METRIX SELF-MONITORING BLOOD GLUCOSE SYSTEM, TRUE METRIX PRO PROFESSIONAL MONITORING BLOOD GLUCOSE SYSTEM
Applicant
Nipro Diagnostics, Inc.
Product Code
NBW · Clinical Chemistry
Decision Date
Aug 1, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The TRUE METRIX Self Monitoring Blood Glucose System is intended for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm. The TRUE METRIX Self Monitoring Blood Glucose System is intended to be used by a single person and not shared. The TRUE METRIX Self Monitoring Blood Glucose System is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The TRUE METRIX Self Monitoring Blood Glucose System should not be used for the diagnosis or screening of diabetes or for neonatal use. Alternative site testing should be done only during steady-state times (when glucose is not changing rapidly). The TRUE METRIX Test Strips are for use with the TRUE METRIX Self Monitoring Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm. The TRUE METRIX PRO Professional Monitoring Blood Glucose System is intended for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm and venous whole blood. The TRUE METRIX PRO Professional Monitoring Blood Glucose System is intended for multiple-patient use in professional healthcare settings. Testing is performed outside the body (in vitro diagnostic use) as an aid to monitor the effectiveness of diabetes control. The TRUE METRIX PRO Professional Monitoring Blood Glucose System is used only with single-use, auto-disabling lancing devices. The system is not to be used for neonates or for the diagnosis or screening of diabetes. Alternative site testing should be done only during steady-state times (when glucose is not changing rapidly). The TRUE METRIX PRO Test Strips are for use with the TRUE METRIX PRO Blood Glucose Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm or venous whole blood.
Device Story
System measures glucose in capillary or venous whole blood via amperometric technology; utilizes glucose dehydrogenase-FAD reaction on plastic test strips. User inserts strip into meter; blood sample (0.5 μL) drawn into strip via capillary action; meter detects current, calculates glucose concentration, and displays plasma-equivalent value. Used at home (self-monitoring) or in professional healthcare settings (PRO version). Provides real-time glucose data to aid diabetes management; results used by patients or clinicians to monitor effectiveness of control. System includes meter, test strips, and control solutions. No coding required; calibration parameters embedded on strips.
Clinical Evidence
No clinical data provided in the document; substantial equivalence determination based on bench testing and technological comparison.
Technological Characteristics
Electrochemical glucose test system; consists of meter and disposable test strips. Supports capillary and venous whole blood samples. Professional version includes safety features for multi-patient use (auto-disabling lancing).
Indications for Use
Indicated for quantitative glucose measurement in capillary whole blood (fingertip/forearm) for self-testing by people with diabetes to monitor control; also indicated for venous whole blood (PRO version) in professional settings. Contraindicated for neonates, diabetes diagnosis/screening, and critically ill/shock/dehydrated/hyper-osmolar patients.
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.
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k140100
B. Purpose for Submission:
Modification of test strip mediator from hexaammineruthenium (III) and Meldola’s Blue to Potassium ferricyanide (III)
C. Measurand:
Capillary whole blood glucose from the finger and forearm, and venous whole blood
D. Type of Test:
Quantitative amperometric assay (Glucose Dehydrogenase-FAD)
E. Applicant:
Nipro Diagnostics, Inc.
F. Proprietary and Established Names:
TRUE METRIX Self Monitoring Blood Glucose System
TRUE METRIX PRO Professional Monitoring Blood Glucose System
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| NBW – Glucose Test System | Class II | 862.1345 | Chem (75) |
| LFR – Glucose Test System | Class II | 862.1345 | Chem (75) |
H. Intended Use:
1. Intended use(s):
Refer to Indications for Use
2. Indication(s) for use:
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# TRUE METRIX Self Monitoring Blood Glucose System
The TRUE METRIX Self Monitoring Blood Glucose System is intended for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm. The TRUE METRIX Self Monitoring Blood Glucose System is intended to be used by a single person and not shared.
The TRUE METRIX Self Monitoring Blood Glucose System is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The TRUE METRIX Self Monitoring Blood Glucose System should not be used for the diagnosis or screening of diabetes or for neonatal use. Alternative site testing should be done only during steady-state times (when glucose is not changing rapidly).
The TRUE METRIX Test Strips are for use with the TRUE METRIX Self Monitoring Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm.
# TRUE METRIX PRO Professional Monitoring Blood Glucose System
The TRUE METRIX PRO Professional Monitoring Blood Glucose System is intended for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm and venous whole blood.
The TRUE METRIX PRO Professional Monitoring Blood Glucose System is intended for multiple-patient use in professional healthcare settings. Testing is performed outside the body (in vitro diagnostic use) as an aid to monitor the effectiveness of diabetes control. The TRUE METRIX PRO Professional Monitoring Blood Glucose System is used only with single-use, auto-disabling lancing devices. The system is not to be used for neonates or for the diagnosis or screening of diabetes. Alternative site testing should be done only during steady-state times (when glucose is not changing rapidly).
The TRUE METRIX PRO Test Strips are for use with the TRUE METRIX PRO Blood Glucose Meter to quantitatively measure glucose (sugar) in fresh capillary whole blood samples drawn from the fingertip or forearm or venous whole blood.
3. Special conditions for use statement(s):
TRUE METRIX Self Monitoring Blood Glucose System
- For over-the-counter use
- Not for neonatal use
- Not for screening or diagnosis of diabetes mellitus
- Not for use on critically ill patients, patients in shock, dehydrated patients or hyper-osmolar patients
- TRUE METRIX Self Monitoring System is for single-patient use only
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- Alternative site testing (AST) testing should only be done during steady-state times (when glucose is not changing rapidly).
- AST should not be used to calibrate continuous glucose monitors (CGMs).
- AST should not be used for insulin dose calculations.
## TRUE METRIX PRO Professional Monitoring Blood Glucose System
- For use by healthcare professionals
- Not for neonatal use
- Not for screening or diagnosis of diabetes mellitus
- The TRUE METRIX PRO has not been validated for use on critically ill patients, patients in shock, dehydrated patients or hyper-osmolar patients
- TRUE METRIX PRO Professional System is for multiple-patient use and should only be used with single-use, auto-disabling lancing devices.
- Alternative site testing (AST) testing should only be done during steady-state times (when glucose is not changing rapidly).
- AST should not be used to calibrate continuous glucose monitors (CGMs).
- AST should not be used for insulin dose calculations.
## 4. Special instrument requirements:
TRUE METRIX Self Monitoring Blood Glucose Meter
TRUE METRIX PRO Professional Monitoring Blood Glucose Meter
## I. Device Description:
The TRUE METRIX Self Monitoring Blood Glucose System and the TRUE METRIX PRO Professional Monitoring Blood Glucose Systems are comprised of the TRUE METRIX Self Monitoring Blood Glucose Meter or TRUE METRIX PRO Professional Monitoring Blood Glucose Meter, TRUE METRIX or TRUE METRIX PRO Test Strips, and TRUE METRIX glucose control solutions Level 1, 2, and 3. The TRUE METRIX glucose control solutions were cleared previously under k120989.
The meter, test strips and glucose control solutions may be marketed within a single package (Kit), or each of these components may be available for purchase separately or combined in different configurations. Labeling included with the complete System consists of a detailed instruction booklet (Owner's Booklet), test strip insert, control solution insert, quick reference card, log book for recording test results, and a carrying case.
## J. Substantial Equivalence Information:
### 1. Predicate device name(s):
TRUE METRIX Self Monitoring Blood Glucose System
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TRUE METRIX PRO Professional Monitoring Blood Glucose System
2. Predicate 510(k) number(s):
k132072
3. Comparison with predicate:
Similarities
| Item | Candidate Device | Predicate Device (k132072) |
| --- | --- | --- |
| | TRUE METRIX Self Monitoring Blood Glucose System | TRUE METRIX Self Monitoring Blood Glucose System |
| Intended Use | Same | It is intended to be used for quantitative measurement of glucose in capillary whole blood as an aid to monitor the effectiveness of diabetes control in people with diabetes. |
| Acceptable sample matrices | Same | Capillary whole blood samples from the fingertip or forearm |
| Sample Volume | Same | 0.5 μL |
| Measuring Range (mg/dL) | Same | 20 – 600 |
| Power Source | Same | One 3 volt lithium battery |
| Meter Memory Display | Same | 500 blood glucose test results; 1 control result |
| Test Time | Same | 4 seconds |
| Control Solution | Same | TRUE METRIX Control Solution Levels 1, 2, and 3 |
| Identification of Control Solution and Results | Same | Automatically distinguishes control solutions from whole blood samples |
| Hematocrit Range (%) | Same | 20 – 70 |
| Altitude | No effect up to 10, 200 ft. | No effect up to 10,150 ft. |
| Coding | Same | No coding required |
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Similarities (cont)
| Item | Candidate Device | Predicate Device (k132072) |
| --- | --- | --- |
| | TRUE METRIX Pro Professional Monitoring Blood Glucose System | TRUE METRIX Self Monitoring Blood Glucose System |
| Intended Use | Same as TRUE METRIX PRO Professional Monitoring Blood Glucose System cleared under k132072 | It is intended to be used for quantitative measurement of glucose in whole blood as an aid to monitor the effectiveness of diabetes control in people with diabetes. |
| Acceptable sample matrices | Same | Capillary whole blood samples from the fingertip or forearm, and venous whole blood |
| Sample Volume | Same | 0.5 μL |
| Measuring Range (mg/dL) | Same | 20 – 600 |
| Power Source | Same | One 3 volt lithium battery |
| Meter Memory Display | Same | 500 blood glucose test results; 1 control result |
| Test Time | Same | 4 seconds |
| Control Solution | Same | TRUE METRIX Control Solution Levels 1, 2, and 3 |
| Identification of Control Solution and Results | Same | Automatically distinguishes control solutions from whole blood samples |
| Hematocrit Range (%) | Same | 20 – 70 |
| Altitude | No effect up to 10, 200 ft. | No effect up to 10,150 ft. |
| Coding | Same | No coding required |
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Differences
| Item | Candidate Device | Predicate Device (k132072) |
| --- | --- | --- |
| | TRUE METRIX Self Monitoring Blood Glucose System | TRUE METRIX Self Monitoring Blood Glucose System |
| Broken LCD Display Message | Broken LCD displays error message of two lines of three dashes across meter display | Broken LCD displays E-4 error message. |
| Interferents | Xylose, Uric acid, Ascorbic acid | Xylose |
| Mediator | Potassium ferricyanide (III) | hexaammineruthenium (III) and Meldola’s Blue |
Differences
| Item | Candidate Device | Predicate Device (k132072) |
| --- | --- | --- |
| | TRUE METRIX PRO Professional Monitoring Blood Glucose System | TRUE METRIX PRO Professional Monitoring Blood Glucose System |
| Broken LCD Display Message | Broken LCD displays error message of two lines of three dashes across meter display | Broken LCD displays E-4 error message. |
| Interferents | Xylose, Uric acid, Ascorbic acid | Xylose |
| Acceptable sample types | Capillary (fingertip and forearm) and venous (Sodium heparin only) | Capillary (fingertip and forearm) and venous (Sodium heparin, Lithium heparin, EDTA) |
| Mediator | Potassium ferricyanide (III) | hexaammineruthenium (III) and Meldola’s Blue |
K. Standard/Guidance Document Referenced (if applicable):
1. EN ISO 15197: In Vitro Diagnostic Test Systems - Requirements for blood glucose monitoring systems for self-testing in managing diabetes mellitus, 2003
2. ISO 14197: Medical Devices - Application of risk management to medical devices, 2007
3. CLSI GP14-A: Labeling of Home-Use In Vitro Testing Products, 1996
L. Test Principle:
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The TRUE METRIX/TRUE METRIX PRO Blood Glucose Test Strip is a plastic strip containing chemicals and electrodes. When inserted into a TRUE METRIX Meter, glucose is measured using amperometric technology employing a glucose dehydrogenase-FAD reaction. When whole blood or TRUE METRIX Glucose Control Solutions are drawn into the sample well of the strip, glucose in the sample reacts with the chemicals and produces an electrical current. The meter measures the current and calculates the amount of glucose. The result is displayed as a plasma equivalent value.
## M. Performance Characteristics (if/when applicable):
1. Analytical performance: Please note: The TRUE METRIX Self Monitoring Blood Glucose System and TRUE METRIX PRO Professional Monitoring Blood Glucose System are identical and the performance characteristics below are applicable to both systems.
### a. Precision/Reproducibility:
The sponsor performed precision studies using venous whole blood collected into sodium heparin collection tubes. The samples were spiked to five different glucose concentration ranges and 100 samples were prepared at each glucose concentration. One operator collected the results using three test strip lots and ten meters. Results are summarized below:
Within-lot precision for glucose: Lot 1
| Glucose Level | Number of tests | Mean (mg/dL) | SD (mg/dL) | CV (%) |
| --- | --- | --- | --- | --- |
| 1 | 100 | 44 | 1.6 | 3.6 |
| 2 | 100 | 89 | 3.6 | 4.0 |
| 3 | 100 | 150 | 4.9 | 3.3 |
| 4 | 100 | 208 | 7.4 | 3.6 |
| 5 | 100 | 329 | 9.6 | 2.9 |
Within-lot precision for glucose: Lot 2
| Glucose Level (mg/dL) | Number of tests | Mean (mg/dL) | SD (mg/dL) | CV (%) |
| --- | --- | --- | --- | --- |
| 1 | 100 | 44 | 1.8 | 4.1 |
| 2 | 100 | 84 | 2.4 | 2.9 |
| 3 | 100 | 140 | 4.3 | 3.1 |
| 4 | 100 | 201 | 6.3 | 3.1 |
| 5 | 100 | 317 | 8.0 | 2.5 |
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Within-lot precision for glucose: Lot 3
| Glucose Level (mg/dL) | Number of tests | Mean (mg/dL) | SD (mg/dL) | CV (%) |
| --- | --- | --- | --- | --- |
| 1 | 100 | 43 | 1.7 | 4.0 |
| 2 | 100 | 85 | 2.5 | 2.9 |
| 3 | 100 | 140 | 3.8 | 2.7 |
| 4 | 100 | 199 | 7.3 | 3.7 |
| 5 | 100 | 316 | 8.7 | 2.8 |
Intermediate precision was evaluated using three levels of glucose control solutions with concentrations in the ranges below using three test strip lots. Per lot, each control level was measured ten times per day over ten days using ten meters, for a total of 100 results per control level per strip lot. Results are summarized below.
Between-day precision for glucose: Lot 1
| Glucose Level (mg/dL) | Number of tests | Mean (mg/dL) | SD (mg/dL) | % CV |
| --- | --- | --- | --- | --- |
| 21 to 51 | 100 | 33 | 1.4 | 4.2 |
| 97 to 131 | 100 | 108 | 3.8 | 3.5 |
| 281 to 381 | 100 | 313 | 8.8 | 2.8 |
Between-day precision for glucose: Lot 2
| Glucose Level (mg/dL) | Number of tests | Mean (mg/dL) | SD (mg/dL) | % CV |
| --- | --- | --- | --- | --- |
| 19 to 49 | 100 | 33 | 1.6 | 4.8 |
| 93 to 125 | 100 | 105 | 3.8 | 3.6 |
| 270 to 366 | 100 | 306 | 10.3 | 3.4 |
Between-day precision for glucose: Lot 3
| Glucose Level (mg/dL) | Number of tests | Mean (mg/dL) | SD (mg/dL) | % CV |
| --- | --- | --- | --- | --- |
| 19 to 49 | 100 | 33 | 1.5 | 4.5 |
| 92 to 124 | 100 | 106 | 3.5 | 3.3 |
| 265 to 359 | 100 | 303 | 8.6 | 2.8 |
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b. Linearity/assay reportable range:
Linearity was evaluated using three test strip lots and nine mixed pools of venous blood with glucose concentrations of 22, 42, 88, 159, 251, 318, 412, 503, and 592 mg/dL as measured by the YSI reference method. Each level was measured in replicates of ten with each of three test strip lots and the values from the candidate meter were compared with those obtained from the YSI2300. Results from linear regression analysis are summarized below:
Test strip lot #1: $y = 0.9804x - 3.7435$ ; $r^2 = 0.9996$
Test strip lot #2: $y = 0.967x - 2.3211$ ; $r^2 = 0.9995$
Test strip lot #3: $y = 0.9994x - 1.3666$ ; $r^2 = 0.9994$
The results of the study support the sponsor's claimed glucose measurement range of 20 - 600 mg/dL.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability
The TRUE METRIX Self Monitoring Blood Glucose System and the TRUE METRIX Pro™ Professional Monitoring Blood Glucose System are traceable to the NIST SRM 917c glucose standard. The method comparison study was performed using the candidate device and YSI 2300 glucose analyzer as the reference method.
Test Strip Stability
Test strip stability was assessed in accelerated studies. The manufacturer claims a shelf life stability of 21 months and an open-vial stability of 4 months at the recommended storage temperatures of $40^{\circ}\mathrm{F}$ to $86^{\circ}\mathrm{F}$ and $10 - 85\%$ relative humidity (RH). Real-time studies are ongoing.
Control solution value assignment and stability were established in k120989. The sponsor claims that the shelf life stability is 24 months and the open-vial stability is 3 months when stored at the recommended storage temperatures of $36^{\circ}\mathrm{F}$ to $86^{\circ}\mathrm{F}$ .
d. Detection limit:
The measuring range of the device is $20 - 600\mathrm{mg / dL}$ . This range was validated by the linearity study (M.1.b).
e. Analytical specificity:
Interference studies were performed by spiking venous blood to two levels of glucose
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concentrations (approximately 80 and 300 mg/dL). Each of these samples was then divided into three aliquots; one containing the potential interferent at the normal/therapeutic level, one containing the potential interferent at the abnormal/toxic level, and the third as a control sample. According to the sponsor, significant interference is considered to occur if the bias between spiked sample glucose results and control sample glucose results is > ± 10%.
| Potential Interfering Substance | Highest concentration tested that did not cause interference (mg/dL) |
| --- | --- |
| Acetaminophen | 30 |
| Acetone | 20 |
| Ascorbic Acid | 2 |
| Bilirubin | 15 |
| Caffeine | 6 |
| Cholesterol | 250 |
| Creatinine | 5 |
| Dopamine | 0.1 |
| Ethanol | 400 |
| Galactose | 15 |
| Gentisic Acid | 1.8 |
| Glipizide | 0.2 |
| Glutathione | 10 |
| Hemoglobin | 1400 |
| Ibuprofen | 50 |
| Icodextrin | 20 |
| L-Dopa | 4 |
| Maltose | 250 |
| Maltotetraose | 70 |
| Maltotriose | 180 |
| Metformin | 4 |
| Methyldopa | 1.5 |
| Naproxen Sodium | 50 |
| Paralidoxime Iodide | 21 |
| Salicylate | 70 |
| Tetracycline | 1.5 |
| Tolazamide | 5 |
| Tolbutamide | 64 |
| Triglycerides | 1000 |
| Uric Acid | 5 |
| Xylose | 7 |
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The sponsor has the following limitations in their labeling:
- Ascorbic acid may cause interference at concentrations greater than 2 mg/dL.
- Uric acid may cause interference at concentrations greater than 5 mg/dL.
- Do not use the TRUE METRIX System during a xylose absorption test. This may falsely raise glucose results.
- Use fresh, capillary whole blood from the fingertip or forearm. Venous whole blood drawn into only a sodium heparin blood collection tube may also be used for testing. Mix well before sampling. Do not use venous whole blood collected in sodium fluoride blood collection tubes for testing, as this may cause false low results.
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
The sponsor performed a study to assess the performance of the TRUE METRIX Self-Monitoring Blood Glucose System. One hundred (100) fingerstick samples and one hundred (100) forearm samples were collected in separate studies. Results were analyzed by comparing blood glucose results from the TRUE METRIX meter obtained by the lay user against the YSI reference value. The samples ranged from 34 - 494 mg/dL (fingerstick) and 58 to 308 mg/dL (forearm) as measured by YSI. The results are summarized in the tables below:
Fingerstick samples
| Glucose concentrations < 75 mg/dL | | |
| --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL |
| 2 / 3 (66.7%) | 3 / 3 (100%) | 3 / 3 (100%) |
| Glucose concentrations ≥ 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5% | within ± 10% | within ± 15% | within ± 20% |
| 46 / 97 (47.4%) | 76 / 97 (78.4%) | 95 / 97 (97.9%) | 97 / 97 (100%) |
| Linear regression analysis | |
| --- | --- |
| n | 100 |
| slope | 1.05 |
| y-intercept | -2.51 |
| r² | 0.99 |
| range (mg/dL) | 34 - 494 |
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Forearm samples
| Glucose concentrations < 75 mg/dL | | |
| --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL |
| 2 / 4 (50.0%) | 3 / 4 (75.0%) | 4 / 4 (100%) |
| Glucose concentrations ≥ 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5% | within ± 10% | within ± 15% | within ± 20% |
| 37 / 96 (38.5%) | 63 / 96 (65.6%) | 91 / 96 (94.8%) | 96 / 96 (100%) |
| Linear regression analysis | |
| --- | --- |
| n | 100 |
| slope | 1.04 |
| y-intercept | 3.79 |
| r² | 0.98 |
| Range (mg/dL) | 58 – 308 |
## b. Matrix comparison:
To assess the performance of the TRUE METRIX PRO Professional Monitoring Blood Glucose System using venous blood, 110 venous samples were collected into sodium heparin collection tubes. An additional eleven samples were spiked or allowed to glycolyze to obtain enough values $< 50\mathrm{mg/dL}$ or $>400\mathrm{mg/dL}$. The final range of glucose concentrations as measured by the reference method was 36 to 539 mg/dL. The results obtained from the True Metrix BGMS were compared to results obtained using the reference method (YSI). Results are summarized below:
| Glucose concentrations < 75 mg/dL | | |
| --- | --- | --- |
| within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL |
| 7 / 7 (100%) | 7 / 7 (100%) | 7 / 7 (100%) |
| Glucose concentrations ≥ 75 mg/dL | | | |
| --- | --- | --- | --- |
| within ± 5% | within ± 10% | within ± 15% | within ± 20% |
| 66 / 114 (58%) | 103 / 114 (90%) | 112 / 114 (98%) | 114 / 114 (100%) |
| Linear regression analysis | |
| --- | --- |
| n | 121 |
| slope | 0.99 |
| y-intercept | 5.40 |
| r² | 0.99 |
| Range (mg/dL) | 36 - 539 |
Only sodium heparin venous samples may be used with this blood glucose system.
## 3. Clinical studies:
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a. Clinical Sensitivity:
Not applicable
b. Clinical specificity:
Not applicable
c. Other clinical supportive data:
Not applicable
4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
Expected Results for people without diabetes*:
Plasma Blood Glucose Result Before eating < 100 mg/dL
2 hours after a meal <140 mg/dL
* American Diabetes Association. Diagnosis and Classification of Diabetes Mellitus.
Diabetes Care, Volume 37, Supplement 1, January 2014.
N. Instrument Names:
TRUE METRIX Self Monitoring Blood Glucose Meter
TRUE METRIX PRO Professional Monitoring Blood Glucose Meter
O. System Descriptions:
1. Modes of Operation
Each test strip is single use and requires a sample volume of 0.5 mL.
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ X ☐ or No ☐
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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:
The device is intended to be used with venous whole blood and capillary whole blood from the finger or forearm only. The whole blood sample is applied directly to the test strip by capillary action.
5. Calibration:
This is a no-coding system: Test strip lot-specific calibration is accomplished by embedding the Calibration Code onto each test strip, which then provides the Calibration Code information to the meter when the test strip is inserted into the meter. The test strip provides the meter with the optimal Calibration Code parameters determined for the specific test strip lot.
6. Quality Control:
Three levels of aqueous glucose control solutions are available with this system (Manufactured by Bionostics, Inc.). Control solutions are sold separately. When a control solution is applied, the meter automatically detects and identifies the glucose control sample prior to displaying the glucose measurement. The meter identifies that the measurement is from a control sample by displaying the "Control Symbol" in the meter display. Recommendations on when to test the control materials are provided in the labeling. The control solution readings are not included in the average of the patient results. An acceptable range for each control level is printed on the test strip vial label. The user is cautioned not to use the meter if the control result falls outside these ranges.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
1. Customer Service Availability. The True Metrix Customer Care Service Center is available 24 hours a day, 365 days a year by calling 1-800-803-6025.
2. Hematocrit. The effect of different hematocrit levels on the performance of the TRUE METRIX Blood Glucose System was evaluated using venous whole blood samples with hematocrit levels of 20, 30, 42, 55, and 70%, at glucose concentrations of 40, 75, 120, 350, and 500 mg/dL. Each sample was then tested 10 times using the TRUE METRIX meter and the values were compared with those obtained from YSI analyzer. The results supported the sponsor's claim that hematocrit values from 20 – 70% will produce accurate glucose results.
3. Sample volume. The recommended minimum sample volume for this device is 0.5μL. To evaluate the effect of sample volume, the sponsor performed a study using
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eight meters, three test strip lots, and sample sizes of 0.3, 0.4, 0.5, and 0.6 µL. The sample volumes smaller than recommended produced an error code and no results, while the recommended and larger sample volumes produced accurate results. These results support the sponsor’s claimed minimum sample size of 0.5 µL.
4. **Temperature and Humidity.** The sponsor performed temperature and humidity studies using venous blood samples at 70, 250 and 500 mg/dL to evaluate the effect of combined temperature and humidity conditions. Temperatures ranging from 5° to 40°C (41 to 104 °F) and relative humidity from 10% to 90% were evaluated and meter results were compared to YSI values. No significant bias (relative to YSI) was observed with the temperature and humidity combinations tested. These results obtained at the extremes of the claimed temperature and humidity ranges support the claims in the labeling that the system can be used in conditions of 41° to 104°F (5° to 40°C) with relative humidity of 10 to 90%.
5. **Altitude.** Venous whole blood samples were collected into sodium heparin anticoagulant tubes and adjusted to low, mid, and high target glucose concentrations. The actual reference concentrations to which the meter measurements were compared ranged from 38-43 mg/dL, 121-127 mg/dL, and 521-559 mg/dL, respectively. These samples were then tested at an altitude of 10, 200 feet and compared to the YSI reference measurement. The study evaluated three test strip lots using five meters per lot. The results demonstrate acceptable bias and indicate acceptable performance to the claimed altitude of 10,200 ft.
6. **Infection control.** There were no changes to the exterior materials of the device. Please see summary of infection control studies in k120989.
7. **EMC testing.** The sponsor states that Electromagnetic Compatibility was not affected by the modifications made (the addition of uric acid and ascorbic acid as interferents as the result of a mediator change, and a change in error message displayed in the case of a broken LCD display.). EMC testing was performed by Intertek Testing Services NA Inc. for the predicate device in k120989. Verification of Compliance certificates were provided and testing was found to be adequate.
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.