K143534 · Roche Professional Diagnostics · LTK · Aug 6, 2015 · Immunology
Device Facts
Record ID
K143534
Device Name
Elecsys CA-125 II assay
Applicant
Roche Professional Diagnostics
Product Code
LTK · Immunology
Decision Date
Aug 6, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 866.6010
Device Class
Class 2
Indications for Use
Elecsys CA 125 II assay: Elecsys CA 125 II is an immunoassay for the in vitro quantitative determination of OC 125 reactive determinants in human serum, Li-heparin, K2-EDTA and K3-EDTA plasma, as well as Li-heparin plasma tubes containing separating gel on the cobas e 411 analyzer. These determinants are associated with a high molecular weight glycoprotein in serum and plasma of women with primary epithelial invasive ovarian cancer (excluding those with cancer of low malignant potential). This immunoassay is indicated for use as an aid in the detection of residual or recurrent ovarian carcinoma. This immunoassay is further indicated for use in monitoring patients for disease progress or response to therapy. The electrochemiluminescence immunoassay "ECLIA" is intended for use on the cobas e 411 immunoassay analyzers. Elecsys CA 125 II CalCheck: For use in the verification of the calibration established by the Elecsys CA 125 II reagent on the Elecsys and cobas e immunoassay analyzers.
Device Story
The Elecsys CA 125 II assay is an in vitro diagnostic immunoassay for quantitative measurement of OC 125 reactive determinants in human serum and plasma. It utilizes a sandwich test principle: biotinylated monoclonal CA 125-specific antibody and ruthenium-labeled monoclonal CA 125-specific antibody form a sandwich complex with the analyte; streptavidin-coated microparticles serve as the solid phase for electrochemiluminescence (ECLIA) detection. The device is used on the cobas e 411 analyzer in clinical laboratory settings. Results are calculated via a 2-point calibration curve and a master curve provided by reagent bar codes. The assay aids clinicians in detecting recurrent ovarian carcinoma and monitoring therapy response. The Elecsys CA 125 II CalCheck is a lyophilized product used to verify calibration of the assay. This submission modernizes labeling (LoB, LoD, LoQ data), updates sample:reagent ratios (20:70 μL), and extends calibration frequency to 8 weeks.
Clinical Evidence
Bench testing only. Performance evaluated on cobas e 411 analyzer per CLSI guidelines (EP5-A2, EP17-A2, EP6-A). Precision: within-run CVs 0.9-3.1%, total CVs 1.3-4.2%. LoB 0.6 U/mL, LoD 1.2 U/mL, LoQ 2 U/mL. Linearity verified across measuring range (2-3000 U/mL). No high-dose hook effect up to 50,000 U/mL. Method comparison (n=80) vs predicate showed Pearson correlation 0.995, slope 0.981. Interference testing confirmed robustness against common drugs, anticoagulants, and endogenous substances (hemolysis, bilirubin, lipemia, biotin, rheumatoid factor).
Indicated for women with primary epithelial invasive ovarian cancer (excluding low malignant potential) to aid in detection of residual or recurrent ovarian carcinoma and to monitor disease progress or response to therapy.
Regulatory Classification
Identification
A tumor-associated antigen immunological test system is a device that consists of reagents used to qualitatively or quantitatively measure, by immunochemical techniques, tumor-associated antigens in serum, plasma, urine, or other body fluids. This device is intended as an aid in monitoring patients for disease progress or response to therapy or for the detection of recurrent or residual disease.
Special Controls
*Classification.* Class II (special controls). Tumor markers must comply with the following special controls: (1) A guidance document entitled “Guidance Document for the Submission of Tumor Associated Antigen Premarket Notifications (510(k)s) to FDA,” and (2) voluntary assay performance standards issued by the National Committee on Clinical Laboratory Standards.
Predicate Devices
Elecsys CA 125 II (k972162)
Elecsys CA 125 II CalCheck 5 (k102086)
Reference Devices
Elecsys PreciControl Tumor Marker (k972235)
Elecsys CA 125 II CalSet II (k140112)
Elecsys CA 125 II CalSet (k003969)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION MEMORANDUM
A. 510(k) Number:
K143534
B. Purpose for Submission:
New device
C. Measurand:
Cancer Antigen 125 (CA 125)
D. Type of Test:
Quantitative electrochemiluminescent immunoassay
E. Applicant:
Roche Diagnostics
F. Proprietary and Established Names:
Elecsys CA 125 II Assay
Elecsys CA 125 II CalCheck
G. Regulatory Information:
1. Regulation section:
21 CFR §866.6010: Tumor-associated antigen immunological test system
21 CFR §862.1660: Quality control material (assayed and unassayed)
2. Classification:
Class II (Elecsys CA 125 II Assay)
Class I (Elecsys CA 125 II CalCheck)
3. Product code:
LTK: Test, epithelial ovarian tumor-associated antigen (CA 125)
JJX: Single (specified) analyte controls (Assayed and Unassayed)
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4. Panel:
Immunology (82)
Chemistry (75)
H. Intended Use:
1. Intended use(s):
Elecsys CA 125 II assay:
Elecsys CA 125 II is an immunoassay for the in vitro quantitative determination of OC 125 reactive determinants in human serum, Li-heparin, K2-EDTA and K3-EDTA plasma, as well as Li-heparin plasma tubes containing separating gel on the cobas e 411 analyzer.
These determinants are associated with a high molecular weight glycoprotein in serum and plasma of women with primary epithelial invasive ovarian cancer (excluding those with cancer of low malignant potential).
This immunoassay is indicated for use as an aid in the detection of residual or recurrent ovarian carcinoma. This immunoassay is further indicated for use in monitoring patients for disease progress or response to therapy.
The electrochemiluminescence immunoassay "ECLIA" is intended for use on the cobas e 411 immunoassay analyzers.
Elecsys CA 125 II CalCheck:
For use in the verification of the calibration established by the Elecsys CA 125 II reagent on the Elecsys and cobas e immunoassay analyzers.
2. Indication(s) for use:
Same as Intended Use
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
For use on the cobas e 411 analyzer
I. Device Description:
The Elecsys CA 125 II Assay is a kit intended for use in the measurement of OC 125 reactive determinants in human serum or plasma. The assay employs a sandwich immunoassay
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format using biotinylated M11 monoclonal antibody as a capture reagent and ruthenium-labeled OC125 monoclonal antibody as a detection reagent. Streptavidin-coated microparticles are used for capture of antibody-antigen complexes and detection is by electrochemiluminescence.
Elecsys CA 125 II CalCheck calibration verification solutions comprise three levels—low, mid and high—each with a defined CA 125 concentration. The low solution concentration is near the lower detection limit of the assay. The mid solution is in the middle or at a clinically critical point of the measuring range. The high solution is near the upper limit of the measuring range.
## J. Substantial Equivalence Information:
1. Predicate device name(s) and numbers:
Elecsys CA 125 II (k972162)
Elecsys CA 125 II CalCheck (k102086)
2. Comparison with predicate:
| Similarities for Elecsys CA 125 II Assay | | |
| --- | --- | --- |
| Item | Device Elecsys CA 125 II Assay | Predicate Elecsys CA 125 II |
| Intended Use/Indications for Use | The Elecsys CA 125 II assay is an immunoassay for the in vitro quantitative determination of OC 125 reactive determinants in human serum, Li-heparin, K_{2}-EDTA and K_{3}-EDTA plasma, as well as Li-heparin plasma tubes on the cobas e 411 immunoassay analyzer. These determinants are associated with a high molecular weight glycoprotein in serum and plasma of women with primary epithelial invasive ovarian cancer (excluding those with cancer of low malignant potential). The Elecsys CA 125 II assay is indicated for use as an aid in the detection of residual or recurrent ovarian carcinoma. The Elecsys CA 125 II assay is further indicated for use in monitoring patients for disease progress or response to therapy. The electrochemiluminescence | Same |
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| Similarities for Elecsys CA 125 II Assay | | |
| --- | --- | --- |
| Item | Device Elecsys CA 125 II Assay | Predicate Elecsys CA 125 II |
| | immunoassay “ECLIA” is intended for use on the cobas e 411 immunoassay analyzers. | |
| Test Principle | Electrochemilumiscent Immunoassay | Same |
| Measurement Type | Quantitative | Same |
| Controls | Elecsys PreciControl Tumor Marker (k972235) | Same |
| Traceability | The method has been standardized against the Enzymun-Test CA 125 II method. This in turn has been standardized against the CA 125 II RIA from Fujirebio Diagnostics. | Same |
| Reagent Stability | Unopened at 2–8 °C: up to the stated expiration date After opening at 2–8 °C: 12 weeks | Same |
| Calibration Interval | After 7 days (when using the same reagent kit on the analyzer) As required, e.g. quality control findings outside the defined limits. | Same |
| Differences for Elecsys CA 125 II Assay | | |
| --- | --- | --- |
| Item | Device Elecsys CA 125 II Assay | Predicate Elecsys CA 125 II |
| Instrument(s) | cobas e 411 | Elecsys 2010, cobas e 411, MODULAR Analytics E170, cobas e 601, cobas e 602 |
| Sample Types | Serum collected using standard sampling tubes or tubes containing separating gel. Li-heparin, K2-EDTA and K3-EDTA, as well as Li-heparin plasma tubes containing separating gel. | Serum collected using standard sampling tubes or tubes containing separating gel. Plasma treated with Na-heparin, K3-EDTA, or sodium citrate |
| Measuring Range | 2.0–3000 U/mL | 0.6–5000 U/mL |
| Sensitivity | LoB = 0.6 U/mL LoD = 1.2 U/mL LoQ = 2.0 U/mL | Lower Detection Limit = 0.6 U/mL |
| Sample:Reagent Ratio | 20:70 uL | 40:60 uL |
| Calibrator | Elecsys CA 125 II CalSet II (k140112) | Elecsys CA 125 II CalSet (k003969) |
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| Differences for Elecsys CA 125 II Assay | | |
| --- | --- | --- |
| Item | Device Elecsys CA 125 II Assay | Predicate Elecsys CA 125 II |
| Reagent Stability | On the analyzers: 6 weeks | On the analyzers: 4 weeks |
| Calibration Interval | After 8 weeks when using the same reagent lot | After 1 month (28 days) when using the same reagent lot |
| Similarities for Elecsys CA 125 CalCheck | | |
| --- | --- | --- |
| Item | Device Elecsys CA 125 II CalCheck | Predicate Elecsys CA 125 II CalCheck 5 |
| Analyte | CA 125 | Same |
| Format | Lyophilized | Same |
| Stability | Unopened at 2–8 °C: up to the stated expiration date After opening at 20–25 °C: 4 hours | Same |
| Instruments | Elecsys and cobas e immunoassay analyzers | Same |
| Differences for Elecsys CA 125 CalCheck | | |
| --- | --- | --- |
| Item | Device Elecsys CA 125 II CalCheck | Predicate Elecsys CA 125 II CalCheck |
| Intended Use/Indication for Use | For use in the verification of the calibration established by the Elecsys CA 125 II reagent on the indicated Elecsys and cobas e immunoassay analyzers. | The Elecsys CA 125 II CalCheck 5 is an assayed control for use in calibration verification and for use in the verification of the assay range established by the Elecsys CA 125 II reagent on the indicated Elecsys and cobas e immunoassay analyzers |
| Levels | Three | Five |
| Handling | Reconstitute Check 1, Check 2, and Check 3 with exactly 1.0mL distilled or deionized water. Allow to stand closed for 15 minutes, then mix gently by inversion. | Reconstitute Check 1, Check 2, Check 3, Check 4 and Check 5 with exactly 1.0mL distilled or deionized water. Allow to stand closed for 15 minutes, then mix gently by inversion. |
| Matrix | Level 1: Equine serum | Level 1: Equine serum |
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| Differences for Elecsys CA 125 CalCheck | | |
| --- | --- | --- |
| Item | Device
Elecsys CA 125 II CalCheck | Predicate
Elecsys CA 125 II CalCheck |
| | Levels 2 & 3: Human serum matrix | Levels 2–5: Human serum matrix |
## K. Standard/Guidance Documents Referenced:
CLSI EP05–A3: Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline
CLSI EP06–A: Evaluation of the Linearity of Quantitative Analytical Methods
CLSI EP17–A2: Protocols for Determination of Limits of Detection and Limits of Quantitation, Approved Guideline
## L. Test Principle:
The Elecsys CA 125 II assay is a two-step sandwich immunoassay. First, sample is incubated with a biotinylated monoclonal CA 125-specific antibody and a monoclonal CA 125-specific antibody labeled with a ruthenium to form a sandwich complex. After addition of streptavidin-coated microparticles, the complex bounds to the solid phase via interaction of biotin and streptavidin. The reaction mixture is aspirated into the measuring cell where the microparticles are magnetically captured onto the surface of the electrode. Unbound substances are then removed. A voltage is applied to the electrode to induce chemiluminescent emission which is measured by a photomultiplier. The results are determined via a calibration curve that is instrument-specifically generated by 2-point calibration and a master curve provided via the reagent barcode.
## M. Performance Characteristics:
1. Analytical performance:
a. Precision/Reproducibility:
Total Imprecision: Six human sera were measured with two replicates and two runs per day for 20 days (n = 80). The human sera were pooled patient and single donor spiked samples. Samples were measured using one lot of reagent, on one instrument (cobas e 411), at two different sites as indicated in the table below. Analysis of variance (ANOVA) was used to calculate repeatability and reproducibility according to CLSI EP05-A3. All data met the manufacturer’s acceptance criteria for % CV and 95% confidence intervals for % CV.
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| Sample | Mean (U/mL) | Within-Run | | Between-Run | | Between-Day | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | SD | CV | SD | CV | SD | CV | SD | CV |
| 1 | 3.1 | 0.09 | 2.8% | 0.05 | 1.5% | 0.08 | 2.7% | 0.13 | 4.2% |
| 2 | 14.7 | 0.43 | 2.9% | 0.15 | 1.0% | 0.38 | 2.6% | 0.59 | 4.0% |
| 3 | 35.0 | 0.69 | 2.0% | 0.27 | 0.8% | 0.72 | 2.1% | 1.04 | 3.0% |
| 4 | 2399 | 59.5 | 2.5% | 8.24 | 0.3% | 52.3 | 2.2% | 79.6 | 3.3% |
| 5* | 121 | 1.13 | 0.9% | 0.79 | 0.7% | 0.63 | 0.5% | 1.52 | 1.3% |
| 6* | 330 | 3.61 | 1.1% | 1.88 | 0.6% | 1.80 | 0.5% | 4.45 | 1.3% |
| *Samples were tested at a site that is different from the first four samples | | | | | | | | | |
Site-to-Site Reproducibility: Five human sera were measured with two replicates and two runs per day for 10 days (n= 40), using one lot of reagent and one instrument (cobas e 411) at three different sites. The human sera were pooled patient and single donor spiked samples. At Site 1, the total precision for the five samples ranged from 1.4%-1.7% CV. At Site 2, the total precision for the five samples ranged from 0.9%-1.5% CV. At Site 3, the total precision for the five samples ranged from 2.4%-3.0% CV. The combined site-to-site reproducibility parameters are detailed in the table below. All values met the manufacturer's acceptance criteria.
| Sample | Mean (U/mL) | Within-Run | | Between-Run | | Between-Day | | Between-Sites | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| 1 | 15.3 | 0.17 | 1.1% | 0.13 | 0.8% | 0.24 | 1.6% | 0.40 | 2.6% | 0.52 | 3.4% |
| 2 | 48.6 | 0.49 | 1.0% | 0.36 | 0.7% | 0.64 | 1.3% | 1.29 | 2.6% | 1.56 | 3.2% |
| 3 | 49.2 | 0.39 | 0.8% | 0.39 | 0.8% | 0.75 | 1.5% | 1.39 | 2.8% | 1.68 | 3.4% |
| 4 | 122 | 1.04 | 0.9% | 0.89 | 0.7% | 1.57 | 1.3% | 2.45 | 2.0% | 3.22 | 2.6% |
| 5 | 331 | 3.14 | 1.0% | 2.01 | 0.6% | 4.41 | 1.3% | 6.34 | 1.9% | 8.57 | 2.6% |
Lot-to-Lot Reproducibility: Four human sera were measured with two replicates and two runs per day for 10 days (n= 40) using three lots of reagents on one instrument (cobas e 411) at one site. The human sera were pooled patient and single donor spiked samples. For Lot 1, the total precision for the four samples ranged from 3.4%-8.3% CV. For Lot 2, the total precision for the four samples ranged from 5.2%-8.6% CV. For Lot 3, the total precision for the four samples ranged from 3.3%-4.7%. The combined lot-to-lot reproducibility parameters are detailed in the table below. All values met the manufacturer's acceptance criteria.
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| Sample | Mean | Within-Run | | Between-Run | | Between-Day | | Between-Lots | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| 1 | 3.06 | 0.13 | 4.1% | 0.01 | 0.4% | 0.18 | 6.0% | 0.08 | 2.7% | 0.24 | 7.8% |
| 2 | 14.98 | 0.39 | 2.6% | 0.00 | 0.0% | 0.51 | 3.4% | 0.44 | 2.9% | 0.77 | 5.2% |
| 3 | 35.4 | 1.00 | 2.8% | 0.00 | 0.0% | 1.44 | 4.1% | 0.63 | 1.8% | 1.87 | 5.3% |
| 4 | 2418 | 71.0 | 2.9% | 0.00 | 0.0% | 88.7 | 3.7% | 34.0 | 1.4% | 118 | 4.9% |
b. Linearity/assay reportable range:
Linearity: The studies followed CLSI EP06-A, where 15 dilutions were prepared by diluting three human serum samples and three human plasma samples spiked with CA 125 down across the lower end of the measuring range. Each dilution was measured in three replicates on cobas e411. Results are summarized in the following table:
| Sample | Dilution range (U/mL) | Slope (95% CI) | Intercept (95% CI) | R² | %CV Range |
| --- | --- | --- | --- | --- | --- |
| Serum Sample 1 | 0.31–3290 | 0.95 (0.95–0.95) | 0.02 (-0.224–0.271) | 0.99 | -0.2%–0.9% |
| Serum Sample 2 | 0.32–3139 | 1.00 (1.00–1.01) | 0.14 (-0.14–0.42) | 0.99 | -1.1%–6.7% |
| Serum Sample 3 | 0.31–3271 | 0.89 (0.88–0.89) | 0.10 (-0.15–0.35) | 0.99 | -1.6%–3.0% |
| Plasma Sample 1 | 0.30–3197 | 0.89 (0.88–0.90) | 0.00 (-0.39–0.40) | 0.99 | -3.8%–3.8% |
| Plasma Sample 2 | 0.27–3210 | 0.88 (0.88–0.89) | 0.30 (-0.10–0.70) | 0.99 | -3.5%–1.7% |
| Plasma Sample 3 | 0.40–3241 | 0.88 (0.87–0.89) | 0.03 (-0.36–0.43) | 0.99 | -5.4%–2.7% |
The data support linearity from 2.0–3000 U/mL. Values below the LoD are reported as <2.0 U/mL and values above the measuring range as >3000 U/mL.
Automatic dilution versus manual dilution: Three human serum samples were spiked with CA 125 to concentrations above the analytical measuring range. These samples were diluted 1:5 manually or automatically on the cobas e 411 analyzer using Diluent Universal. Each sample was measured in triplicate with one lot on one analyzer and the median value was used to compare percent recovery of the manual dilution to that of the automated dilution. The manufacturer's acceptance criteria of percent recovery 90–110% were met.
High dose hook effect: Hook effect was measured using two human serum samples spiked with CA 125 to 50000 U/mL. Each sample was then diluted with Diluent
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Universal to a level below the upper limit of the analytical measuring range and measured with a single replicate using one lot of reagent and one analyzer (cobas e 411). The data demonstrated the assay is not susceptible to antigen excess up to a concentration of 50000 U/mL.
c. Traceability and Stability:
i. Traceability:
There are no reference standards for CA 125. The results are reported in U/mL and the method has been standardized against the Enzymun-Test CA 125 II method. This in turn has been standardized against the CA 125 II RIA from Fujirebio Diagnostics.
ii. Kit Stability:
Shelf-Life Stability: A real-time stability study set the shelf-life stability of the Elecsys CA 125 II assay at 18 months when stored at 2–8°C.
Open-Vial Stability: The assay reagents can be stored opened at 2–8°C for up to 12 weeks.
On-Board Stability: The assay reagents can be stored on-board the cobas e 411 analyzer at 20±3°C for up to 6 weeks.
iii. Sample Stability:
Ten human samples for each sample type (serum, K₂-EDTA-plasma, K₃-EDTA-plasma, Li-heparin-plasma) that covered the analytical measuring range were tested under four different conditions: 2–8°C, 15–25°C, -20°C, and after multiple freeze/thaw cycles. Each sample was measured with three replicates and percent recovery was compared to the sample stored at -80°C. Samples were determined to be stable for up to 5 days at 2–8°C, up to 8 hours at 15–25°C, up to 24 weeks at -20°C or following 2 freeze/thaw cycles.
d. Detection limit:
The Limit of Blank (LoB) and Limit of Detection (LoD) were determined according to CLSI EP17-A2. To estimate LoB, five measurand-free human serum samples were measured in six runs on two instruments with three different reagent lots (n = 60 replicates per reagent lot). LoB was calculated as the highest 95th percentile value from the three reagent lots. The LoB was determined to be 0.6 U/mL. To determine LoD, five human serum samples with low analyte values were measured in six runs on two instruments with three different reagent lots (n = 60 replicates per reagent lot). LoD was calculated from the following equation: LoD = LoB + 1.653 x (total standard deviation). The Limit of Quantitation (LoQ) was determined using six
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pooled human serum samples that were diluted to have CA 125 concentrations between $1.0 - 6.3\mathrm{U / mL}$ . Each sample was measured in six runs, on two instruments, with three different reagent lots ( $n = 72$ replicates per reagent lot). The detection limit values are presented in the table below:
| LoB | LoD | LoQ |
| --- | --- | --- |
| 0.6 U/mL | 1.2 U/mL | 2.0 U/mL |
# e. Analytical specificity:
# i. Endogenous Interference:
Interferences were assessed by testing two human serum samples with CA 125 concentrations of 35 and $2260~\mathrm{U / mL}$ . Each sample was split in half, and a high concentration of each potentially interfering endogenous substance was spiked into one half. The spiked sample was then mixed with the non-spiked half to create a series of eleven samples containing different concentrations of the potential interferent and tested in. a single replicate. The manufacturer's acceptance criteria for non-interference were met and the assay was not affected by the following substances at the indicated concentrations:
| Interfering Substance | Final Test Concentration |
| --- | --- |
| Biotin | 70 ng/mL |
| Triglycerides (Intralipid) | 3800 mg/dL |
| Bilirubin | 75 mg/dL |
| Rheumatic Factor | 1500 IU/mL |
| Hemoglobin | 3200 mg/dL |
| HAMA | 805 μg/mL |
# ii. Exogenous Interference:
A total of 16 common drugs and 23 cancer drugs were tested for interference using two spiked human serum samples with CA 125 concentrations of 11 and $313\mathrm{U / mL}$ . Each sample was spiked with a high concentration of interferent and measured with three replicates in one run using one reagent lot on one analyzer (cobas e 411). The manufacturer's acceptance criteria for non-interference were met and the assay was not affected by the following drugs at the indicated concentrations:
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| Final Test Concentration (mg/L) | | | |
| --- | --- | --- | --- |
| Common Drugs | | Cancer Drugs | |
| Acetylcysteine | 553 | Carboplatin | 1000 |
| Ampicillin-Na | 1000 | Cisplatin | 225 |
| Ascorbic Acid | 300 | Cyclophosphamide | 1000 |
| Cyclosporine | 5 | Dexamethasone | 20 |
| Cefoxitin | 2500 | Docetaxel (Taxotere) | 112 |
| Heparin | 5000 U | Doxorubicin | 75 |
| Levodopa | 20 | Pegylated, Liposomal Doxorubicin (CAELYX) | 75 |
| Methyldopa +1.5 | 15 | Leucovorin | 750 |
| Metronidazole | 200 | Melphalan | 15 |
| Phenylbutazone | 400 | Methotrexate | 1000 |
| Doxycycline | 30 | Lynparza (Olaparib) | 800 |
| Acetylsalicylic Acid | 1000 | Paclitaxel | 265 |
| Rifampicin | 64 | 5-Fluorouracil | 500 |
| Acetaminophen | 200 | Avastin | 750 |
| Ibuprofen | 500 | Tarceva | 150 |
| Theophylline | 100 | MabThera | 750 |
| | Herceptin | 600 | |
| | | Tamoxifen | 50 |
| | | Mitomycin | 25 |
| | | Etoposide | 400 |
| | | Flutamide | 1000 |
| | | Gemcitabine | 1500 |
| | | Taxol | 5.5 |
f. Assay Cut-Off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
A total of 80 native, single-donor human serum samples spanning the dynamic range (4.7–2680 U/mL) were assayed in singleton with the predicate device and the new device on the Elecsys 2010 analyzer using CA 125 II Cal Set (k003969). Regression statistics are based on the balance of the paired results and the data are as follows:
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| Regression Fit | Regression Equation | Slope (95% CI) | Intercept (95% CI) | R² |
| --- | --- | --- | --- | --- |
| Passing-Bablok | y = 0.98 x + 1.2 | 0.94 to 1.00 | 0.33–1.82 | 0.99 |
# b. Comparison between previous and updated calibrators:
A total of 111 native, single donor human serum samples spanning the dynamic range (3.2–2,621 U/mL) were assayed in singleton with the new device on the cobas e 411 analyzer using either the previous calibrator set (Elecsys CA 125 II Cal Set, K003969) or the updated calibrator set (Elecsys CA 125 II Cal Set II, K140112). Regression statistics are based on the balance of the paired results and the data are as follows:
| Regression Fit | Regression Equation | Slope (95% CI) | Intercept (95% CI) | R² |
| --- | --- | --- | --- | --- |
| Passing-Bablok | y = 0.99 x - 0.82 | 0.993–0.994 | -0.827–-0.818 | 1.00 |
# c. Matrix comparison
A study was performed to demonstrate that heparin plasma (Li-heparin or drawn into Li-heparin Plasma Separation Tubes) and EDTA $\mathrm{(K_2}$ -EDTA-, $\mathrm{K}_3$ -EDTA) plasma matrices yield comparable values as serum in the Elecsys CA 125 II assay. A total of 51 or 52 matrix-matched samples spread across the assay range (2.2-2980 U/mL) were assayed in duplicate using one reagent lot and one analyzer (cobas e 411). Passing-Bablok regression analysis was performed and the corresponding slopes of regression and coefficient determination are summarized in the following table:
| Plasma Type | N | Range Tested (U/mL) | Slope (95% CI) | Intercept (95% CI) | Correlation |
| --- | --- | --- | --- | --- | --- |
| Li-Heparin | 52 | 2.3–2980 | 0.98 (0.94–0.99) | 0.11 (-0.03–0.48) | 1.0 |
| K2-EDTA | 51 | 2.3–2962 | 0.98 (0.97–0.99) | 0.04 (-0.26–0.13) | 1.0 |
| K3-EDTA | 51 | 2.3–2962 | 1.00 (0.96–1.02) | -0.45 (-0.74–-0.01) | 1.0 |
| Li-Heparin Separation Tubes | 51 | 2.3–2980 | 0.98 (0.92–1.00) | -0.35 (-0.69–0.18) | 1.0 |
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3. Clinical studies:
Not Applicable
4. Clinical cut-off:
Not Applicable
5. Expected values/Reference range:
Expected Values in Normal Healthy Individuals: To determine the reference range of the Elecsys CA 125 II assay in healthy women, 120 pre-menopausal and 120 postmenopausal women were tested (total = 240 subjects). Ages ranged from 18 to 87 years and represented whites (96%), Hispanic/Latino (0.4%), Asian (0.4%) and African American (2.5%) subjects. The mean, SD, median, range and 5th to 95th percentile of CA125 concentrations, and percent below the upper limit of normal (ULN) as observed in the data, are shown for each group in the table below.
| Healthy Subjects | |
| --- | --- |
| Premenopausal | 120 |
| Postmenopausal | 120 |
| Total Samples | 240 |
| Age Range (years) | 18–87 |
| Results (U/mL) | |
| Mean | 17.2 |
| Standard Deviation | 11.9 |
| Median | 14.1 |
| Min | 4.1 |
| Max | 127 |
| 5th Percentile | 6.4 |
| 95th Percentile | 38.1 |
| Percent below ULN* | 95% |
Expected Values in Non-Ovarian Malignancy Conditions: To evaluate the performance of the Elecsys CA 125 II assay in subjects with other malignant and benign conditions, the assay was evaluated in 199 subjects with various cancers (bladder cancer, breast cancer, gastrointestinal cancer, endometrial cancer, lung cancer) and in 411 women with benign conditions. A total of 80 women with conditions other than cancers (hypertension and pregnancy) were also included. A total of 690 specimens were analyzed. The mean, standard deviation, mean, 5th to 95th percentiles of CA125 concentrations, and percent below the ULN, as observed in the data, are shown for each condition group. Elevated CA 125 concentrations can be found in samples from patients with serositis or other
{13}
tumors besides ovarian carcinoma, endometrial carcinoma and carcinoma of the fallopian tube.
| Subjects with Non-Ovarian Malignancies | | | | | |
| --- | --- | --- | --- | --- | --- |
| | Endometrial | Breast | Gastro-intestinal | Lung | Bladder |
| Premenopausal | 12 | 12 | 9 | 3 | 2 |
| Postmenopausal | 28 | 28 | 31 | 37 | 37 |
| Total Samples | 40 | 40 | 40 | 40 | 39 |
| Age Range (years) | 35–83 | 39–92 | 33–85 | 43–82 | 30–91 |
| Results U/mL | | | | | |
| Mean | 87.2 | 70.6 | 34.2 | 32.7 | 29.2 |
| Standard Deviation | 202 | 144 | 57.8 | 18.7 | 36.5 |
| Median | 20.6 | 18.5 | 16.2 | 30.2 | 18.5 |
| Min | 6.9 | 4.5 | 7.1 | 9.3 | 4.4 |
| Max | 1117 | 811 | 306 | 64.3 | 215 |
| 5thPercentile | 8.6 | 4.8 | 7.2 | 10.6 | 5.8 |
| 95thPercentile | 656 | 348 | 231 | 62.3 | 101 |
| Percent below ULN* | 70% | 75% | 82% | 58% | 82% |
| Subjects with Benign Conditions and Conditions Other than Cancers | | | | |
| --- | --- | --- | --- | --- |
| | Benign Gynecologic | Benign Non-Gynecologic | Pregnant | Hypertension |
| Premenopausal | 219 | 2 | 40 | 4 |
| Postmenopausal | 152 | 38 | 0 | 36 |
| Total Samples | 371 | 40 | 40 | 40 |
| Age Range (years) | 18–89 | 25–89 | 19–40 | 36–91 |
| Results (U/mL) | | | | |
| Mean | 44.4 | 38.6 | 20.6 | 20.8 |
| Standard Deviation | 94.0 | 87.4 | 10.0 | 16.6 |
| Median | 20.6 | 15.8 | 18.0 | 15.9 |
| Min | 4.2 | 3.6 | 11.5 | 6.0 |
| Max | 995 | 541 | 64.9 | 89.1 |
| 5th Percentile | 7.8 | 6.4 | 12.0 | 6.2 |
| 95th Percentile | 132 | 183 | 44.9 | 61.8 |
| Percent below ULN* | 76% | 85% | 92% | 90% |
{14}
*ULN is calculated as the 95th percentile value for apparently health women. For this assay, the ULN = 38.1 U/mL.
## 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.
15
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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.