K143577 · Sysmex America, Inc. · GKZ · Oct 12, 2015 · Hematology
Device Facts
Record ID
K143577
Device Name
XW-100 Automated Hematology Analyzer, XW QC CHECK
Applicant
Sysmex America, Inc.
Product Code
GKZ · Hematology
Decision Date
Oct 12, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 864.5220
Device Class
Class 2
Attributes
Pediatric
Indications for Use
The Sysmex XW-100™ is a quantitative automated hematology analyzer intended for in vitro diagnostic point-of-care use to classify and enumerate the following parameters for venous whole blood anticoagulated with K2/K3 EDTA: WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, LYMPH%, Other WBC%, NEUT%, LYMPH#, Other WBC#, NEUT#, RDW-SD, RDW-CV, and MPV. It is not for use in diagnosing or monitoring oncology patients, children under the age of 2, or for chronically or critically ill patients. XW QC CHECK is a stabilized whole blood matrix designed for statistical process control of the Sysmex XW-100 automated hematology analyzer. It is not intended for calibration of the analyzer. Assayed parameters include WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, LYMPH%, Other WBC%, NEUT%, LYMPH#, Other WBC#, NEUT#, RDW-SD, RDW-CV, and MPV.
Device Story
Sysmex XW-100 is an automated hematology analyzer for point-of-care use; performs complete blood count and 3-part leukocyte differential. Input: 15 μL venous whole blood (K2/K3 EDTA) manually loaded. Operation: hydrodynamic focusing; electrical resistance (impedance) for cell counting/sizing; photometric measurement for hemoglobin. Output: 17 hematology parameters; histograms for cell populations. Used in ambulatory GP offices by trained operators (high school diploma minimum). System features automated QC lockout via internet-downloaded range limits; factory-calibrated. Output used by clinicians for routine hematological assessment; aids in patient management decisions. Benefits: rapid, accurate blood analysis in non-laboratory settings.
Clinical Evidence
Equivalency studies performed in a point-of-care setting comparing XW-100 to the pocH-100i predicate demonstrated equivalent performance. Stability and precision studies for XW QC CHECK confirmed the control meets clinical acceptability criteria and maintains stability throughout its claimed shelf-life.
Technological Characteristics
Impedance-based cell counter; photometric hemoglobin measurement. Hydrodynamic focusing nozzle. Dimensions: 7"W x 14"H x 18"D. Connectivity: internet connection for QC range limit downloads. Reagents: XW Pack L (lyse), XW Pack D (diluent). Factory calibrated.
Indications for Use
Indicated for point-of-care quantitative hematology analysis of venous whole blood (K2/K3 EDTA) in adults and children aged 2 and older. Contraindicated for oncology patients, children under 2, and chronically or critically ill patients.
Regulatory Classification
Identification
An automated differential cell counter is a device used to identify one or more of the formed elements of the blood. The device may also have the capability to flag, count, or classify immature or abnormal hematopoietic cells of the blood, bone marrow, or other body fluids. These devices may combine an electronic particle counting method, optical method, or a flow cytometric method utilizing monoclonal CD (cluster designation) markers. The device includes accessory CD markers.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA document entitled “Class II Special Controls Guidance Document: Premarket Notifications for Automated Differential Cell Counters for Immature or Abnormal Blood Cells; Final Guidance for Industry and FDA.”
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
K143577
B. Purpose for Submission:
Clearance of a new device
C. Manufacturer and Instrument Name:
Sysmex America Inc., Sysmex XW-100 and XW QC CHECK
D. Type of Test or Tests Performed:
Complete blood count (WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, MPV), leukocyte 3-part differential (LYM%, other WBC%, NEUT%, LYM#, other WBC#, NEUT#), RDW-SD and RDW-CV.
E. System Descriptions:
1. Device Description:
The XW-100 Automated Hematology Analyzer, hereafter referred to as Sysmex XW-100, is an electrical resistance blood cell counter. The Sysmex XW-100 analyzes human whole blood specimens anticoagulated with dipotassium and tripotassium ethylenediaminetetraacetic acid (K₂EDTA and K₃EDTA) and reports results for the following 17 parameters: white blood cell (WBC), red blood cell (RBC), hemoglobin (HGB), hematocrit (HCT), mean corpuscular volume (MCV), mean corpuscular hemoglobin (MCH), mean corpuscular hemoglobin concentration (MCHC), platelet (PLT), percent lymphocytes (LYM%), percent other WBC (WBC%), percent neutrophils (NEUT%), absolute lymphocytes (LYM%), absolute other WBC (WBC%), absolute neutrophils (NEUT%), red cell distribution width standard deviation (RDW-SD), red cell distribution width coefficient of variation (RDW-CV), and mean platelet volume (MPV).
2. Principles of Operation:
The patient sample is aspirated, measured, diluted with diluent (and lysed for WBC and hemoglobin measurement), then directed into a transducer chamber by a hydrodynamic focusing nozzle. The transducer chamber has a minute hole, or aperture. Electrodes are mounted on both sides of the aperture chamber, through which the direct current flows. Blood cells suspended in the diluted sample are injected through the aperture by the hydrodynamic focusing nozzle. The hydrodynamic focusing nozzle is positioned in front of the aperture and in line with the aperture's center. This method improves cell counting accuracy because all blood cells are separated from each other and pass through the
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aperture in one direction, one cell at a time. When a cell passes through the aperture, it causes a change in the direct current resistance, which is proportional to the cell's size. The resistance changes are captured as electric pulses. The various blood cell counts are calculated by counting the electric pulses that occur in each cell size category. The analyzer then determines blood cell volume and identifies rare and pathological cells by creating and analyzing histograms of the various cell populations using their respective pulse heights. Hemoglobin is measured photometrically by a non-cyanide method.
3. Modes of Operation:
The Sysmex XW-100 operates by automated whole blood analysis.
Does the applicant’s device contain the ability to transmit data to a computer, webserver, or mobile device?
Yes ☐ X ☐ or No ☐
Does the applicant’s device transmit data to a computer, webserver, or mobile device using wireless transmission?
Yes ☐ or No ☐ X ☐
4. Specimen Identification:
Specimen identification input is manual (by operator).
5. Specimen Sampling and Handling:
Samples are manually mixed and loaded into an onboard sample adapter one at a time. The Sysmex XW-100 processes anticoagulated venous whole blood collected in K₂EDTA or K₃EDTA collection containers.
6. Calibration:
The Sysmex XW-100 is factory calibrated.
7. Quality Control:
Quality control performance is to be evaluated using XW QC CHECK, a 3-level stabilized whole blood matrix quality control material designed for the statistical process control of the Sysmex XW-100. Assayed parameters include: WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, LYM%, Other WBC %, NEUT%, LYM#, Other WBC#, NEUT#, RDW-SD, RDW-CV, and MPV.
8. Software:
The software is purposed to operate the system featuring a simple and intuitive user interface and guide user workflows including instrument and error handling procedures.
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FDA has reviewed applicant’s Hazard Analysis and Software Development processes for this line of product types:
Yes ☐ X or No ☐
## F. Regulatory Information:
1. Regulation section:
21 CFR § 864.5220, Automated differential cell counter
21 CFR § 864.8625, Hematology Quality Control Mixture
2. Classification:
Class II
3. Product code:
GKZ – Counter, Differential Cell
JPK – Mixture, Hematology Quality Control
4. Panel:
Hematology (81)
## G. Intended Use:
1. Indication(s) for Use:
**Sysmex XW-100 Automated Hematology Analyzer**
The Sysmex XW-100™ is a quantitative automated hematology analyzer intended for *in vitro* diagnostic point-of-care use to classify and enumerate the following parameters for venous whole blood anticoagulated with K₂/K₃ EDTA: WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, LYM%, Other WBC%, NEUT%, LYM#, Other WBC#, NEUT#, RDW-SD, RDW-CV, and MPV. It is not for use in diagnosing or monitoring oncology patients, children under the age of 2, or for chronically or critically ill patients.
**XW QC CHECK**
XW QC CHECK is a stabilized whole blood matrix designed for statistical process control of the Sysmex XW-100 automated hematology analyzer. It is not intended for calibration of the analyzer. Assayed parameters include WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, LYM%, Other WBC%, NEUT%, LYM#, Other WBC#, NEUT#, RDW-SD, RDW-CV, and MPV.
2. Special Conditions for Use Statement(s):
The Sysmex XW-100™ is for use in ambulatory general practitioner's offices and is not intended for use in an environment where patients are critically or chronically ill such as emergency rooms, acute care centers, nursing or rehabilitation facilities.
The Sysmex XW-100™ is intended to be used by operators with a minimum of an earned
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high school diploma or equivalent and documented training in the use of the Sysmex XW-100™.
For prescription use only.
## H. Substantial Equivalence Information:
1. Predicate Device Names and 510(k) numbers:
Sysmex® pocH-100i Automated Hematology Analyzer (K032677)
Para Check Quality Control (K852992)
2. Comparison with Predicate Device:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Intended Use | The Sysmex XW-100™ is a quantitative automated hematology analyzer intended for in vitro diagnostic point-of-care use to classify and enumerate the following parameters for venous whole blood anticoagulated with K2/K3 EDTA: WBC, RBC, HGB, HCT, MCV, MCH, MCHC, PLT, LYM%, Other WBC%, NEUT%, LYM#, Other WBC#, NEUT#, RDW-SD, RDW-CV, and MPV. It is not for use in diagnosing or monitoring oncology patients, children under the age of 2, or for chronically or critically ill patients. | The Sysmex pocH-100i Automated Hematology Analyzer is an automated cell counter intended for in vitro diagnostic use in CLIA non-waived clinical laboratories (not for Point of Care use in a CLIA waived laboratory). |
| Test Principle | Impedance technology (direct current detection) with hydrodynamic focusing for all parameters except hemoglobin, which is measured photometrically. | Same |
| Measuring Channel | Single hydrodynamic focused impedance chamber | Same |
| Sample Type | Anticoagulated (K2EDTA or K3EDTA) venous whole blood | Same |
| Sample aspiration volume | 15 μL | Same |
| Analysis Reagents | XW Pack L (lyse)
XW Pack D (diluent) | Same |
| System Throughput | 20 cycles per hour | Same |
| Test System Dimensions | Width: 7 inches
Height: 14 inches
Depth: 18 inches | Same |
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| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Sample Type | Anticoagulated (K_{2}EDTA or K_{3}EDTA) venous whole blood | Anticoagulated (K_{2}EDTA, K_{3}EDTA, or Na_{2}EDTA) venous whole blood |
| Mode of Operation | Whole blood mode | Whole blood mode
Pre-dilute mode |
| Calibration and Quality Control | XW QC CHECK controls are stored in the laboratory at room (ambient) temperature at 15°C–25°C or 59°F–77°F. Range limits are downloaded automatically by an internet connection. Expiration, cycle use, and performance validity checks are monitored and enforced by the system via a QC lock-out mechanism. | EIGHTCHECK controls are stored in the laboratory at 2–8°C. Range limits are entered manually by the operator via keystroke input. Expiry, cycle use limitations, and valid performance are not monitored by the system. |
| | The Sysmex XW-100 is factory calibrated using the SCS™-1000 calibrator (K943268); calibration is not performed by the end-user (point-of-care operator). | Calibration is performed on site by qualified personnel using the SCS™-1000 calibrator (K943268). |
I. Special Control/Guidance Document Referenced (if applicable):
CLSI H26-A2, Validation, Verification, and Quality Assurance of Automated Hematology Analyzers; Proposed Standard – Second Edition
CLSI EP10-A3, Preliminary Evaluation of Quantitative Clinical Laboratory Measurement Procedures; Approved Guideline – Third Edition
CLSI EP12-A2, User Protocol for Evaluation of Qualitative Test Performance; Approved Guideline – Second Edition
CLSI EP06-A, Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline
CLSI H20-A2, Reference Leukocyte (WBC) Differential Count (Proportional) and Evaluation of Instrumental Methods; Approved Standard – Second Edition
CLSI EP09-A3, Measurement Procedure Comparison and Bias Estimation Using Patient Samples; Approved Guideline – Third Edition
CLSI EP09-A2, Method Comparison and Bias Estimation Using Patient Samples; Approved Guideline – Second Edition
CLSI C24, Statistical QC for Quantitative Measurement Procedures: Principles and Definitions; Approved Guideline – Third Edition
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CLSI EP05-A2, Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline - Second Edition
CLSI EP28-A3c, Defining, Establishing, and Verifying Reference Intervals in the Clinical Laboratory; Approved Guideline - Third Edition
CLSI H18-A3, Procedure for the Handling and Processing of Blood Specimens; Approved Guideline - Third Edition
# J. Performance Characteristics:
# 1. Analytical Performance:
# a. Method Comparison
Method comparison studies were performed across three point-of-care clinical sites (with three operators per site) to assess the performance of the Sysmex XW-100 compared to the Sysmex pocH-100i analyzer utilizing a total of $391\mathrm{K}_2\mathrm{EDTA}$ venous whole blood samples. The study population included normal and abnormal pediatric $(N = 69)$ and adult subjects $(N = 322)$ .
Statistical analyses for the method comparison, demonstrating correlation between the Sysmex XW-100 and Sysmex pocH-100i analyzers, were provided based on Deming regressions and Bland-Altman plots for each blood parameter. The predefined acceptance criteria were successfully met.
Correlation and Estimated Bias of Sysmex XW-100 Compared to Sysmex pocH-100i - Combined Sites
| Parametr | N | (r) | Slope | 95% CI | | Intercept (95% CI) | 95% CI | | Mean Bias | Mean % Bias |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | Lower Limit | Upper Limit | | Lower Limit | Upper Limit | | |
| WBC | 389 | 0.999 | 1.015 | 1.007 | 1.024 | -0.028 | -0.098 | 0.042 | 0.11 | 1.5 |
| RBC | 391 | 0.995 | 0.982 | 0.970 | 0.993 | 0.064 | 0.014 | 0.115 | -0.01 | -0.3 |
| HGB | 391 | 0.994 | 0.986 | 0.974 | 0.998 | 0.237 | 0.094 | 0.381 | 0.06 | 0.6 |
| HCT | 391 | 0.991 | 0.977 | 0.960 | 0.994 | 0.757 | 0.142 | 1.371 | -0.10 | -0.2 |
| MCV | 390 | 0.983 | 1.005 | 0.986 | 1.025 | -0.490 | -2.190 | 1.209 | 0.00 | 0.0 |
| MCH | 391 | 0.946 | 1.011 | 0.978 | 1.043 | -0.074 | -1.026 | 0.877 | 0.24 | 0.8 |
| MCHC | 391 | 0.761 | 1.114 | 0.998 | 1.231 | -3.532 | -7.408 | 0.343 | 0.25 | 0.8 |
| PLT | 391 | 0.994 | 0.994 | 0.981 | 1.008 | 1.145 | -2.115 | 4.405 | -0.22 | 0.2 |
| MPV | 377 | 0.961 | 0.990 | 0.958 | 1.021 | 0.232 | -0.131 | 0.594 | 0.11 | 1.0 |
| LYMPH% | 316 | 0.993 | 1.003 | 0.988 | 1.018 | 0.084 | -0.254 | 0.421 | 0.16 | 1.5 |
| Other WBC% | 315 | 0.765 | 1.107 | 1.009 | 1.206 | -0.891 | -1.734 | -0.048 | 0.10 | 10.4 |
| NEUT% | 316 | 0.968 | 1.002 | 0.972 | 1.032 | -0.381 | -2.508 | 1.745 | -0.24 | -0.3 |
| LYMPH# | 316 | 0.994 | 1.021 | 1.008 | 1.034 | -0.006 | -0.031 | 0.019 | 0.03 | 2.2 |
| Other WBC# | 316 | 0.785 | 1.055 | 0.945 | 1.165 | -0.031 | -0.107 | 0.045 | 0.01 | 11.7 |
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| NEUT# | 315 | 0.993 | 1.009 | 1.000 | 1.018 | 0.005 | -0.049 | 0.060 | 0.06 | 1.1 |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| RDW-SD | 391 | 0.954 | 1.052 | 0.978 | 1.126 | -1.904 | -5.165 | 1.357 | 0.49 | 1.1 |
| RDW-CV | 390 | 0.989 | 1.012 | 0.990 | 1.034 | -0.001 | -0.312 | 0.311 | 0.18 | 1.2 |
## b. Flagging Comparison
A flagging comparison study was performed across three point-of-care clinical sites to evaluate flagging agreement between the candidate and comparative methods, the Sysmex XW-100 and Sysmex pocH-100i respectively. The Sysmex XW-100 flagging system includes flagging limits (+/-) and particle distribution analysis (PDA) for all claimed parameters as described in the instructions for use (IFU). A two-sided 95% confidence interval (CI) for each agreement estimate was calculated using the Bayesian method provided below.
| N=391 | Sysmex pocH-100i | | |
| --- | --- | --- | --- |
| Sysmex XW-100 | Positive | Negative | Total |
| Positive | 257 (a) | 10 (b) | 267 |
| Negative | 7 (c) | 117 (d) | 124 |
| Total | 264 | 127 | 391 |
**Positive Percent Agreement** = 100 × a/(a+c) = 100 × 257/(257+7) = 97.3%
95% CI: 94.6% to 98.6%
**Negative Percent Agreement** = 100 × d/(d+b) = 100 × 117/(117+10) = 92.1%
95% CI: 86.1% to 95.6%
**Overall Agreement** = 100 × (a+d)/n = 100 × (257+117)/(391) = 95.6%
95% CI: 93.1% to 97.2%
## c. Precision/Reproducibility
Precision performance of the Sysmex XW-100 was evaluated by performing repeatability and reproducibility studies across three point-of-care (POC) clinical sites with the intended POC operators.
The repeatability study was conducted for the WBC, RBC, HGB, HCT and PLT parameters with residual whole blood samples collected in K₂EDTA collection containers. The samples were selected to span the medical decision levels, the lower and upper limits of the analytical measuring range. Each sample was analyzed 10 consecutive times. SD (standard deviation) and CV% (coefficient of variation) were calculated and provided for each measurand at each site. The predefined acceptance criteria were met.
Reproducibility performance was conducted at each site over 20 operating days utilizing three levels of commercial control material (XW QC CHECK – low, normal
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and high) performing two runs per day and two replicates per run. To further demonstrate precision performance, SD (standard deviation) and CV% (coefficient of variation) of within-run, between-run, between-day, and between-device were calculated per site and for the combined sites for each measurand as shown below.
XW QC CHECK Low Level Control
| Measurand | N | Mean | Within-run | | Between-run | | Between-day | | Between-site | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | SD | CV% | SD | CV% | SD | CV% | SD | CV% | SD | CV% |
| WBC | 256 | 2.904 | 0.086 | 2.96 | 0.041 | 1.41 | 0.000 | 0.00 | 0.042 | 1.46 | 0.104 | 3.59 |
| RBC | 256 | 2.392 | 0.028 | 1.18 | 0.005 | 0.22 | 0.004 | 0.16 | 0.033 | 1.38 | 0.044 | 1.84 |
| HGB | 256 | 6.332 | 0.091 | 1.44 | 0.032 | 0.51 | 0.000 | 0.00 | 0.029 | 0.45 | 0.101 | 1.59 |
| HCT | 256 | 18.67 | 0.224 | 1.20 | 0.089 | 0.48 | 0.135 | 0.72 | 0.202 | 1.08 | 0.342 | 1.83 |
| MCV | 256 | 78.05 | 0.226 | 0.29 | 0.158 | 0.20 | 0.553 | 0.71 | 0.183 | 0.23 | 0.644 | 0.83 |
| MCH | 256 | 26.47 | 0.500 | 1.89 | 0.000 | 0.00 | 0.000 | 0.00 | 0.280 | 1.06 | 0.573 | 2.17 |
| MCHC | 256 | 33.92 | 0.659 | 1.94 | 0.000 | 0.00 | 0.321 | 0.95 | 0.237 | 0.70 | 0.770 | 2.27 |
| PLT | 256 | 56.80 | 2.759 | 4.86 | 0.000 | 0.00 | 1.454 | 2.56 | 1.079 | 1.90 | 3.299 | 5.81 |
| MPV | 256 | 10.53 | 0.275 | 2.61 | 0.000 | 0.00 | 0.067 | 0.64 | 0.023 | 0.22 | 0.284 | 2.69 |
| LYMPH# | 256 | 0.712 | 0.040 | 5.62 | 0.023 | 3.16 | 0.000 | 0.00 | 0.008 | 1.09 | 0.047 | 6.54 |
| Other WBC# | 254 | 0.259 | 0.061 | 23.52 | 0.000 | 0.00 | 0.007 | 2.85 | 0.008 | 3.11 | 0.062 | 23.89 |
| NEUT# | 254 | 1.933 | 0.094 | 4.87 | 0.018 | 0.92 | 0.010 | 0.50 | 0.024 | 1.22 | 0.099 | 5.13 |
| LYMPH% | 256 | 24.58 | 1.012 | 4.12 | 0.382 | 1.56 | 0.000 | 0.00 | 0.032 | 0.13 | 1.082 | 4.40 |
| Other WBC% | 254 | 8.875 | 1.880 | 21.18 | 0.000 | 0.00 | 0.000 | 0.00 | 0.000 | 0.00 | 1.880 | 21.18 |
| NEUT% | 254 | 66.56 | 2.140 | 3.22 | 0.000 | 0.00 | 0.358 | 0.54 | 0.000 | 0.00 | 2.170 | 3.26 |
| RDW-SD | 256 | 42.01 | 0.328 | 0.78 | 0.000 | 0.00 | 0.244 | 0.58 | 0.271 | 0.64 | 0.490 | 1.17 |
| RDW-CV | 256 | 15.26 | 0.106 | 0.69 | 0.067 | 0.44 | 0.143 | 0.94 | 0.081 | 0.53 | 0.207 | 1.36 |
XW QC CHECK Normal Level Control
| Measurand | N | Mean | Within-run | | Between-run | | Between-day | | Between-site | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | SD | CV% | SD | CV% | SD | CV% | SD | CV% | SD | CV% |
| WBC | 256 | 6.946 | 0.193 | 2.77 | 0.000 | 0.00 | 0.072 | 1.03 | 0.085 | 1.22 | 0.222 | 3.20 |
| RBC | 256 | 4.482 | 0.037 | 0.83 | 0.020 | 0.45 | 0.030 | 0.68 | 0.058 | 1.30 | 0.078 | 1.74 |
| HGB | 256 | 13.26 | 0.191 | 1.44 | 0.000 | 0.00 | 0.093 | 0.70 | 0.128 | 0.97 | 0.248 | 1.87 |
| HCT | 256 | 38.27 | 0.325 | 0.85 | 0.203 | 0.53 | 0.341 | 0.89 | 0.375 | 0.98 | 0.635 | 1.66 |
| MCV | 256 | 85.39 | 0.209 | 0.24 | 0.179 | 0.21 | 0.473 | 0.55 | 0.240 | 0.28 | 0.597 | 0.70 |
| MCH | 256 | 29.60 | 0.448 | 1.51 | 0.000 | 0.00 | 0.184 | 0.62 | 0.367 | 1.24 | 0.608 | 2.05 |
| MCHC | 256 | 34.67 | 0.539 | 1.56 | 0.000 | 0.00 | 0.364 | 1.05 | 0.361 | 1.04 | 0.744 | 2.15 |
| PLT | 256 | 222.5 | 5.890 | 2.65 | 1.259 | 0.57 | 3.118 | 1.40 | 4.920 | 2.21 | 8.379 | 3.77 |
| MPV | 256 | 10.20 | 0.146 | 1.44 | 0.027 | 0.26 | 0.086 | 0.84 | 0.034 | 0.34 | 0.175 | 1.72 |
| LYMPH# | 256 | 2.168 | 0.097 | 4.46 | 0.000 | 0.00 | 0.040 | 1.85 | 0.007 | 0.32 | 0.105 | 4.84 |
| Other WBC# | 254 | 0.689 | 0.104 | 15.08 | 0.033 | 4.75 | 0.000 | 0.00 | 0.023 | 3.38 | 0.111 | 16.16 |
| NEUT# | 254 | 4.089 | 0.170 | 4.15 | 0.000 | 0.00 | 0.047 | 1.14 | 0.050 | 1.22 | 0.183 | 4.47 |
| LYMPH% | 256 | 31.18 | 0.834 | 2.67 | 0.000 | 0.00 | 0.221 | 0.71 | 0.263 | 0.84 | 0.902 | 2.89 |
| Other WBC% | 254 | 9.915 | 1.416 | 14.28 | 0.715 | 7.21 | 0.000 | 0.00 | 0.241 | 2.43 | 1.604 | 16.18 |
| NEUT% | 254 | 58.90 | 1.635 | 2.78 | 0.411 | 0.70 | 0.000 | 0.00 | 0.052 | 0.09 | 1.687 | 2.86 |
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| Measurand | N | Mean | Within-run | | Between-run | | Between-day | | Between-site | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | SD | CV% | SD | CV% | SD | CV% | SD | CV% | SD | CV% |
| RDW-SD | 256 | 43.02 | 0.288 | 0.67 | 0.000 | 0.00 | 0.129 | 0.30 | 0.156 | 0.36 | 0.352 | 0.82 |
| RDW-CV | 256 | 14.38 | 0.097 | 0.68 | 0.025 | 0.17 | 0.137 | 0.95 | 0.073 | 0.51 | 0.185 | 1.28 |
XW QC CHECK High Level Control
| Measurand | N | Mean | Within-run | | Between-run | | Between-day | | Between-site | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | SD | CV% | SD | CV% | SD | CV% | SD | CV% | SD | CV% |
| WBC | 256 | 18.12 | 0.295 | 1.63 | 0.000 | 0.00 | 0.141 | 0.78 | 0.254 | 1.40 | 0.414 | 2.28 |
| RBC | 256 | 5.324 | 0.047 | 0.89 | 0.019 | 0.35 | 0.028 | 0.52 | 0.065 | 1.21 | 0.087 | 1.63 |
| HGB | 256 | 17.25 | 0.142 | 0.82 | 0.047 | 0.27 | 0.085 | 0.49 | 0.180 | 1.04 | 0.249 | 1.44 |
| HCT | 256 | 47.94 | 0.416 | 0.87 | 0.232 | 0.48 | 0.353 | 0.74 | 0.447 | 0.93 | 0.743 | 1.55 |
| MCV | 256 | 90.06 | 0.221 | 0.25 | 0.230 | 0.26 | 0.456 | 0.51 | 0.218 | 0.24 | 0.598 | 0.66 |
| MCH | 256 | 32.41 | 0.398 | 1.23 | 0.071 | 0.22 | 0.220 | 0.68 | 0.461 | 1.42 | 0.651 | 2.01 |
| MCHC | 256 | 35.99 | 0.434 | 1.21 | 0.179 | 0.50 | 0.348 | 0.97 | 0.427 | 1.19 | 0.723 | 2.01 |
| PLT | 256 | 507.1 | 9.535 | 1.88 | 1.593 | 0.31 | 4.705 | 0.93 | 12.305 | 2.43 | 16.340 | 3.22 |
| MPV | 256 | 10.06 | 0.097 | 0.96 | 0.071 | 0.71 | 0.041 | 0.40 | 0.044 | 0.44 | 0.134 | 1.33 |
| LYMPH# | 256 | 6.404 | 0.144 | 2.24 | 0.029 | 0.45 | 0.000 | 0.00 | 0.163 | 2.55 | 0.219 | 3.42 |
| Other WBC# | 256 | 2.763 | 0.218 | 7.90 | 0.000 | 0.00 | 0.053 | 1.92 | 0.012 | 0.42 | 0.225 | 8.14 |
| NEUT# | 256 | 8.951 | 0.254 | 2.84 | 0.000 | 0.00 | 0.076 | 0.85 | 0.083 | 0.92 | 0.278 | 3.11 |
| LYMPH% | 256 | 35.35 | 0.557 | 1.58 | 0.286 | 0.81 | 0.000 | 0.00 | 0.423 | 1.20 | 0.756 | 2.14 |
| Other WBC% | 256 | 15.25 | 1.175 | 7.70 | 0.000 | 0.00 | 0.296 | 1.94 | 0.000 | 0.00 | 1.211 | 7.94 |
| NEUT% | 256 | 49.40 | 1.148 | 2.32 | 0.000 | 0.00 | 0.195 | 0.39 | 0.388 | 0.78 | 1.227 | 2.48 |
| RDW-SD | 256 | 45.57 | 0.328 | 0.72 | 0.156 | 0.34 | 0.342 | 0.75 | 0.443 | 0.97 | 0.667 | 1.46 |
| RDW-CV | 256 | 14.67 | 0.186 | 1.27 | 0.078 | 0.53 | 0.356 | 2.43 | 0.317 | 2.16 | 0.518 | 3.53 |
# c. Linearity
Linearity of the WBC, RBC, HGB, HCT, and PLT parameters was evaluated using a linearity kit (RANGE CHECK™ X II - K960557) of known concentrations. The Sysmex XW-100 met the predefined acceptance criteria. The findings of the polynomial regression analysis indicate that the Sysmex XW-100 exhibits linearity across the claimed range.
| Parameter | Linearity Performance Specifications |
| --- | --- |
| WBC | 1.0–99.9×103/μL |
| RBC | 0.3–7.00×106/μL |
| HGB | 0.1–25.0 g/dL |
| HCT | 10.0–60.0% |
| PLT | 10.0–999×103/μL |
{9}
10
d. Carryover
Carryover of the Sysmex XW-100 was evaluated by assaying whole blood K₂EDTA samples with high WBC, RBC, HGB, and PLT counts. Three high concentration (H1, H2, and H3) samples were consecutively analyzed followed by three low concentration (L1, L2, L3) samples. Three sets of carryover sequences were run for each type of carryover test on three separate instruments.
Carryover % was determined using the following calculation: % Carryover = (LTV1−LTV3)/(HTV3−LTV3) × 100. The results of the carryover study were within the predefined specifications.
e. Interfering Substances
A verification study was conducted to determine the interference level with the hematology results generated by the Sysmex XW-100 for the following interfering substances: Bilirubin F, Bilirubin C, hemolytic hemoglobin, chyle, and lipids (Intralipid). Six whole blood K₂EDTA tubes were collected from each of the three study subjects. A total of 3 samples were contrived with the specified interferent at various dilutions, mixed, and then analyzed three times.
There was no significant Bilirubin F interference up to a concentration of 37.1 mg/dL for the WBC, RBC, HGB, and PLT parameters. There was no significant bilirubin F interference for HCT up to a concentration of 29.6 mg/dL.
There was no significant Bilirubin C interference up to a concentration of 38.1 mg/dL for the WBC, RBC, HGB, HCT, and PLT parameters.
There was no significant hemolysis interference up to a concentration of 936 mg/dL for the WBC, RBC, HCT, and PLT parameters. There was no significant hemolysis interference up to a concentration of 749 mg/dL for the HGB parameter.
There was no significant Intralipid interference up to a concentration of 55.980 OD for the WBC, RBC, and HCT parameters. There was no significant Intralipid interference up to a concentration of 1.119 OD for the HGB parameter and up to a concentration of 11.196 OD for the PLT parameter.
There was no significant chyle interference up to a concentration of 2579 FTU for the WBC, RBC, HGB, HCT, and PLT parameters.
f. Quality Control Stability
The XW QC CHECK 30-day open-vial stability claim was substantiated by performing three runs over eight time points spanning the 30-day claim utilizing two vials from each of the three QC lots, one operator, and two Sysmex XW-100 analyzers at one internal site.
{10}
The 45-day closed-vial stability claim was substantiated by performing three runs over ten time points spanning the 45-day end date claim utilizing two vials from each of the three QC lots, one operator, and two Sysmex XW-100 analyzers at one internal site.
The control vials used in the open and closed-vial stability studies were stored and used in accordance with the instructions for use at room temperature (59–86°F or 15–30°C).
2. Other Supportive Instrument Performance Data Not Covered Above:
a. Sample Stability
Whole blood stability was evaluated using a total of 20 (10 normal and 10 abnormal) K₂EDTA whole blood samples on the Sysmex XW-100. The samples were run in triplicate to obtain the baseline on time zero. Single measurements of each sample were subsequently obtained at 8 hours, 12 hours, 24 hours, 36 hours, and 48 hours at room temperature (18–26°C) and refrigerated temperature (2–8°C). The mean percent difference was calculated for each sample and was within the predefined acceptance criteria. Whole blood samples stored at room temperature (59–77°F or 15–25°C) are stable for up to 8 hours and samples stored refrigerated (36–46°F or 2–8°C) are stable for up to 36 hours.
b. Anticoagulant Comparison (K₂EDTA vs. K₃EDTA)
Anticoagulant comparison studies were performed to demonstrate comparability between K₂EDTA and K₃EDTA whole blood samples for all reportable parameters. A total of 10 paired whole blood samples (K₂EDTA, K₃EDTA) were collected from study subjects. The samples were run in duplicate on the Sysmex XW-100 and the results of the K₂EDTA samples were compared to the corresponding results of the K₃EDTA sample from the same study subject. The results of the study met the predefined bias limits for all reportable parameters.
| Parameter | Unit | K₂EDTA Average Mean Value | K₃EDTA Average Mean Value | Mean Difference | Mean% Difference |
| --- | --- | --- | --- | --- | --- |
| WBC | 10³/μL | 6.9 | 6.9 | 0.0 | -0.1 |
| RBC | 10⁶/ μL | 4.96 | 4.94 | 0.0 | -0.4 |
| HGB | g/dL | 13.8 | 13.7 | -0.1 | -1.0 |
| HCT | % | 43.3 | 43.0 | -0.3 | -0.7 |
| MCV | fL | 87.4 | 87.2 | -0.2 | -0.2 |
| MCH | pg | 27.8 | 27.7 | -0.1 | -0.4 |
| MCHC | g/dL | 31.8 | 31.7 | -0.1 | -0.2 |
| PLT | 10³/μL | 294 | 296 | 1.8 | 0.6 |
| MPV | fL | 10.8 | 11.0 | 0.2 | 1.9 |
| RDW-SD | fL | 42.3 | 42.2 | -0.1 | -0.2 |
| RDW-CV | % | 13.5 | 13.4 | 0.0 | -0.3 |
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| NEUT% | % | 62.3 | 62.2 | -0.2 | -0.3 |
| --- | --- | --- | --- | --- | --- |
| LYMPH% | % | 29.8 | 29.7 | -0.1 | -0.3 |
| Other WBC% | % | 7.9 | 8.0 | 0.0 | 0.6 |
| NEUT# | # | 2.03 | 2.03 | 0.0 | 0.0 |
| LYMPH# | # | 2.03 | 2.03 | 0.0 | 0.0 |
| Other WBC# | # | 0.54 | 0.54 | 0.0 | -0.5 |
# c. Determination of limit of blank, lower limits of detection and quantitation
Limit of Blank (LoB) was determined by performing 60 repeat measurements using two blank samples containing XW-Pack D (system diluent). The mean, SD, and LoB were calculated for the WBC, RBC, HGB, HCT, and PLT parameters.
| Parameter | Mean | SD | LoB |
| --- | --- | --- | --- |
| WBC | 0.0 x 103/μL | 0.0 x 103/μL | 0.0 x 103/μL |
| RBC | 0.0 x 106/μL | 0.0 x 106/μL | 0.0 x 106/μL |
| HGB | 0.0 g/dL | 0.0 g/dL | 0.0 g/dL |
| HCT | 0.0% | 0.0% | 0.0% |
| PLT | 0.0 x 103/μL | 0.0 x 103/μL | 0.0 x 103/μL |
To determine the Limit of Detection (LoD), a total of 60 replicate measurements of three low level samples with target values of $0.3 - 0.5 \times 10^{3} / \mu \mathrm{L}$ for WBC, $0.02 - 0.04 \times 10^{6} / \mu \mathrm{L}$ for RBC, $0.1 - 0.4 \mathrm{~g} / \mathrm{dL}$ for HGB, $0.1 - 0.3\%$ for HCT, and $10 - 14 \times 10^{3} / \mu \mathrm{L}$ for PLT were performed in the whole blood analysis mode.
Limit of Quantitation (LoQ) was determined by using the test results from the LoD study to determine the bias and imprecision for that level of analyte. A total of 45 replicate measurements from three samples (15 measurements per sample) at the lowest concentration for each analyte were performed to verify precision at the low end of the analytical measuring range. The mean, SD, and 2SD were calculated for the WBC, RBC, HGB, HCT, and PLT parameters.
The results of the LoD and LoQ for the Sysmex XW-100™ met the expected lower measuring range for WBC, RBC, HGB, HCT, and PLT.
| Parameter | Unit | LoD | LoQ |
| --- | --- | --- | --- |
| WBC | 103/μL | 0.1 | 0.248 |
| RBC | 106/μL | 0.01 | 0.014 |
| HGB | g/dL | 0.1 | 0.3 |
| HCT | % | 0.1 | 0.3 |
| PLT | 103/μL | 2 | 6 |
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# d. Reference Intervals
Adult reference intervals for the Sysmex XW-100™ were verified in comparison to the pre-established reference intervals for the Sysmex pocH-100i utilizing whole blood samples collected from 121 normal subjects ( $\geq$ 21 years of age).
| Parameter | Unit | Male (N=52) | Female (N=64) |
| --- | --- | --- | --- |
| | | Verified Reference Interval | Verified Reference Interval |
| WBC | 10^3/μL | 4.5-9.9 | 4.1-9.7 |
| RBC | 10^6/μL | 4.02-6.01 | 3.95-5.61 |
| HGB | g/dL | 12.4-17.3 | 11.4-16.0 |
| HCT | % | 37.8-50.7 | 34.9-47.9 |
| MCV | fL | 80.0-94.9 | 80.9-94.9 |
| MCH | pg | 25.9-32.1 | 26.6-32.2 |
| MCHC | g/dL | 32.3-36.2 | 32.2-35.7 |
| PLT | 10^3/μL | 164-343 | 185-369 |
| MPV | fL | 9.4-12.3 | 9.5-12.3 |
| LYMPH% | % | 17.4-50.9 | 19.6-56.7 |
| Other WBC% | % | 1.7-18.3 | 1.4-14.3 |
| NEUT% | % | 44.1-71.1 | 37.2-71.1 |
| LYMPH# | # | 1.0-3.2 | 1.2-4.1 |
| Other WBC# | # | 0.1-1.7 | 0.1-1.7 |
| NEUT# | # | 2.4-5.9 | 2.6-7.4 |
| RDW-SD | fL | 38.9-46.1 | 38.3-46.0 |
| RDW-CV | % | 11.9-14.4 | 12.0-14.4 |
A reference range verification study was performed for the infant $(N = 27)$ , adolescent and transitional adolescent $(N = 96)$ pediatric populations by comparing 123 samples collected from pediatric patients ranging from 2 to 21 years of age within each pediatric subcategory shown below. The results of the study verified the pediatric intervals published in Soldin, Brugnara and Wong, Pediatric Reference Intervals, AACC Press 6th Edition 2007.
| Pediatric Category | Age Range |
| --- | --- |
| Child | 2 to < 12 years old |
| Adolescent | 12 to < 18 years old |
| Transitional adolescent | 18 to ≤ 21 years old |
# K. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
{13}
L. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
14
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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.