K151559 · Immco Diagnostics, Inc. · LJM · Mar 11, 2016 · Immunology
Device Facts
Record ID
K151559
Device Name
ImmuLisa Enhanced Centromere Antibody ELISA
Applicant
Immco Diagnostics, Inc.
Product Code
LJM · Immunology
Decision Date
Mar 11, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 866.5100
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K151559 · Mar 11, 2016
ImmuLisa Enhanced Centromere Antibody ELISA
Immco Diagnostics, Inc.
Retrospective clinical patient serum samples
Retrospective clinical samples were used to determine the clinical sensitivity and specificity of the ImmuLisa™ Enhanced Centromere Antibody ELISA by testing cohorts of patients with limited cutaneous systemic sclerosis (lcSSc)/CREST and various other autoimmune or infectious diseases.
Patients with lcSSc/CREST and patients with other autoimmune and infectious diseases; Sample Size: 124 lcSSc/CREST samples; 865 autoimmune and infectious disease control samples
Not applicable for this study
Clinical sensitivity and specificity
Indications for Use
An enzyme linked immunoassay (ELISA) for the qualitative or semiquantitative detection of anti-centromere antibodies in human serum or plasma to aid in the diagnosis of limited cutaneous systemic sclerosis / CREST in conjunction with other laboratory tests and clinical findings.
Device Story
ImmuLisa™ Enhanced Centromere Antibody ELISA is a solid-phase immunoassay for detecting anti-centromere IgG antibodies in human serum. Microwells are coated with recombinant purified CENP-A and CENP-B centromere antigens. Patient serum, calibrators, and controls are incubated in wells; specific antibodies bind to antigens. An enzyme-labeled anti-human IgG conjugate is added, followed by TMB substrate. A spectrophotometer reads the resulting color change at 450 nm. Results are expressed in ELISA units per milliliter (EU/ml) and reported as positive or negative. The device is used in clinical laboratory settings by trained laboratory personnel. Healthcare providers use these results as an aid in diagnosing limited cutaneous systemic sclerosis (lcSSc) or CREST syndrome, supporting clinical decision-making alongside other diagnostic findings.
Clinical Evidence
Clinical performance evaluated using 124 lcSSc/CREST samples and 865 autoimmune/infectious disease controls. Sensitivity was 53.2%; specificity was 95.5%. Method comparison against the predicate (n=407) showed 93.2% positive percent agreement, 95.4% negative percent agreement, and 95.1% overall agreement. Cross-reactivity testing on 669 specimens from various autoimmune/infectious conditions showed 2.7% positivity. Precision studies (n=80 replicates) showed total CVs ranging from 3.5% to 7.0%. Limit of Detection (LoD) is 3.9 EU/ml; linear range is 3.9–160 EU/ml.
Technological Characteristics
Solid-phase ELISA; recombinant purified CENP-A and CENP-B antigens; HRP-conjugated anti-human IgG; TMB substrate. Requires spectrophotometer (450 nm) and automated microplate washer. Linear range: 3.9–160 EU/mL. Traceable to in-house standards. No international reference preparation available.
Indications for Use
Indicated for qualitative or semi-quantitative detection of anti-centromere IgG antibodies in human serum to aid in the diagnosis of limited cutaneous systemic sclerosis (lcSSc) or CREST syndrome in patients, in conjunction with other clinical and laboratory findings.
Regulatory Classification
Identification
An antinuclear antibody immunological test system is a device that consists of the reagents used to measure by immunochemical techniques the autoimmune antibodies in serum, other body fluids, and tissues that react with cellular nuclear constituents (molecules present in the nucleus of a cell, such as ribonucleic acid, deoxyribonucleic acid, or nuclear proteins). The measurements aid in the diagnosis of systemic lupus erythematosus (a multisystem autoimmune disease in which antibodies attack the victim's own tissues), hepatitis (a liver disease), rheumatoid arthritis, Sjögren's syndrome (arthritis with inflammation of the eye, eyelid, and salivary glands), and systemic sclerosis (chronic hardening and shrinking of many body tissues).
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
A. 510(k) Number:
K151559
B. Purpose for Submission:
New device
C. Measurand:
IgG autoantibodies specific for Centromere protein
D. Type of Test:
Immunoassay, qualitative and semi-quantitative
E. Applicant:
IMMCO Diagnostics Inc.
F. Proprietary and Established Names:
ImmuLisa™ Enhanced Centromere Antibody ELISA
G. Regulatory Information:
1. Regulation section:
21 CFR §866.5100, Antinuclear antibody immunological test system
2. Classification:
Class II
3. Product code:
LJM, antinuclear antibody (enzyme-labeled), antigen, controls
4. Panel:
Immunology (82)
H. Intended Use:
1. Intended use(s):
An enzyme linked immunoassay (ELISA) for the qualitative or semiquantitative detection of anti-centromere antibodies in human serum or plasma to aid in the diagnosis of limited cutaneous systemic sclerosis / CREST in conjunction with other laboratory tests and clinical findings.
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2. Indication(s) for use:
Same as intended use
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
An ELISA microplate reader capable of reading absorbance values at 450 nm. If dual wavelength microplate reader is available, the reference filter should be set at 600–650 nm. An automatic microplate washer capable of accurately dispensing 200 µL of fluid is also required.
I. Device Description:
Each kit consists of 12- 1 x 8 antigen coated microwell strips, negative control, positive control, five assay calibrators, anti-human IgG-horse radish peroxidase conjugate, TMB substrate, stop solution, wash buffer and diluent.
J. Substantial Equivalence Information:
1. Predicate device name(s):
QUANTA Lite™ Centromere ELISA
2. Predicate 510(k) number(s):
K003959
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | ImmuLisa™ Centromere | Predicate Device |
| Intended Use | An enzyme linked Immunoassay (ELISA) for the qualitative or semi-quantitative detection of anti-centromere antibodies in human serum or plasma to aid in the diagnosis of limited cutaneous systemic sclerosis / CREST in conjunction with other laboratory tests and clinical findings. | QUANTA Lite Centromere (CENP-A & CENP-B) is an enzyme-linked immunosorbent assay (ELISA) for the semi-quantitative detection of Centromere antibodies, specifically reactive to the CENP-A and CENP-B antigens in human sera. Detection of these antibodies is an aid in diagnosis of certain connective tissue diseases such as the CREST variant of scleroderma. |
| Assay Type | ELISA | Same |
| Type of Test | Semi-quantitative and qualitative | Semi-quantitative |
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| Similarities | | |
| --- | --- | --- |
| Item | ImmuLisa™ Centromere | Predicate Device |
| Capture Antigen | Recombinant purified CENP-A and CENP-B Centromere antigens | Same |
| Conjugate | HRP conjugated anti-human IgG | Same |
| Substrate | TMB | Same |
| Traceability | International Reference Preparation is not available. Results are traceable to in-house standards. | Same |
| Sample Type | Serum | Same |
| Screening Dilution | 1:101 | Same |
| Negative Cut-off | < 20 EU/mL | < 20 units |
| Conjugate | HRP conjugated anti-human IgG | Same |
| Instrumentation | Spectrophotometer 450 nm | Same |
| Signal | Optical density | Same |
| Differences | | |
| --- | --- | --- |
| Item | ImmuLisa™ Centromere | Predicate Device |
| Positive Cutoff | >25 EU/mL | >20 units |
| Indeterminate Region | 20–25 EU/mL | Not applicable |
| Calibrators | Set of 5; values in EU/mL: 160,80 40, 20,1 and Cal D (20 EU/mL) for the single point calibration method | Single point calibrator |
| Linear Range | 3.9 EU/mL–160 EU/mL | Not specified |
| Limit of Detection | 3.9 EU/mL | Not specified |
# K. Standard/Guidance Document Referenced:
1. Evaluation of Precision Performance of Quantitative Measurement Methods (CLSI EP05-A2)
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2. Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline (CLSI EP6-A)
3. Interference Testing in Clinical Chemistry; Approved Guideline - Second Edition (CLSI EP07-A2)
4. Method Comparison and Bias Estimation Using Patient Samples (CLSI EP9-A2)
5. User Protocol for Evaluation of Qualitative Test Performance (CLSI EP12-A2)
6. Protocols for Determination of Limits of Detection and Limits of Quantitation; Approved Guideline (CLSI EP17-A)
L. Test Principle:
The test is performed as a solid phase immunoassay. Controls, calibrators and patient sera are incubated in the antigen coated wells to allow specific antibodies present in the serum to bind to the centromere antigen. Unbound antibodies and other serum proteins are removed by washing the microwells. Bound antibodies are detected by adding an enzyme labeled anti-human IgG conjugate to the microwells. Unbound conjugate is removed by washing. Enzyme substrate (TMB) is then added to the wells and the presence of antibodies is detected by a color change produced by the conversion of TMB substrate to a colored reaction product. The reaction is stopped and the intensity of the color change, which is proportional to the concentration of antibody, is read by a spectrophotometer at 450 nm.
Semi-quantitative results are determined from a series of five calibrators (160 EU/mL, 80 EU/mL, 40 EU/mL, 20 EU/mL, and 1 EU/mL). Values less than 20 EU/mL are considered negative results while values greater than 25 EU/mL are considered positive; results between 20 EU/mL and 25 EU/mL are considered 'indeterminate'. Qualitative results are determined using a ratio of the absorbance of the sample to the absorbance of the cut-off calibrator (20 EU/mL). The ratio is multiplied by the concentration of the cut-off calibrator to give a numerical value. Values greater than 20 EU/mL are reported as positive.
M. Performance Characteristics:
1. Analytical performance:
a. Precision/Reproducibility:
Semi-Quantitative Precision:
Sera from seven patients from the Intended Use population were selected to cover the analytical measuring range of the assay and included samples in the negative range, ~20% below cut-off, around the cut-off, ~20% above cut-off and in the moderate positive range of the assays. Samples were run in duplicate, twice per day for 20 days (n = 80 replicates per sample). Assays were run by two operators on two different sets of equipment, each using a multichannel pipettor, microplate washer and microplate reader. The manufacturer's pre-determined acceptance criteria met for all measures.
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Semi-Quantitative Precision:
| | | Repeatability | | Between Days | | Inter-operator | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | EU/mL Mean | SD | %CV | SD | %CV | SD | %CV | SD | %CV |
| 1 | 8.5 | 0.3 | 4.1 | 0.3 | 3.3 | 0.2 | 2.8 | 0.4 | 5.2 |
| 2 | 16.4 | 0.5 | 3.0 | 0.8 | 5.2 | 0.6 | 3.6 | 1.0 | 6.0 |
| 3 | 20.4 | 0.9 | 4.4 | 0.5 | 2.3 | 0.5 | 2.5 | 1.0 | 5.0 |
| 4 | 23.8 | 0.5 | 1.9 | 0.8 | 3.5 | 0.5 | 2.2 | 0.9 | 4.0 |
| 5 | 49.0 | 1.5 | 3.0 | 2.2 | 4.5 | 1.5 | 3.1 | 2.6 | 5.4 |
| 6 | 105.1 | 1.7 | 1.6 | 2.7 | 2.6 | 2.4 | 2.3 | 3.2 | 3.0 |
| 7 | 150.6 | 4.7 | 3.1 | 2.7 | 1.8 | 0.0 | 0.0 | 5.4 | 3.6 |
# Operator-to-Operator Reproducibility:
The sponsor provided operator-to-operator reproducibility for the manual method. This study incorporated three operators running five replicates per assay over three days. The data are summarized in the following table:
| Sample | Mean EU/mL | Operator 1 %CV | Operator 2 %CV | Operator 3 %CV | Total %CV |
| --- | --- | --- | --- | --- | --- |
| Low Negative | 7.9 | 10.1 | 12.4 | 10.5 | 10.8 |
| Cut-off - 20% | 16.3 | 7.5 | 6.6 | 5.1 | 6.5 |
| Cut-off | 20.6 | 6.1 | 6.3 | 4.5 | 5.8 |
| Cut-off + 20% | 23.5 | 5.4 | 5.0 | 5.4 | 5.3 |
| Moderate Positive | 43.0 | 5.9 | 5.6 | 4.2 | 5.2 |
| High Positive | 95.8 | 3.2 | 3.2 | 3.7 | 3.8 |
| High Positive | 154.0 | 3.9 | 3.8 | 2.8 | 3.5 |
The manufacturer's pre-determined acceptance criteria were met for all measures.
# Qualitative Reproducibility:
Studies were performed under the guidance of CLSI EP12-A2 "User Protocol for Evaluation of Qualitative Test Performance." Eighty replicates each of sera in the negative range: $20\%$ below the cut-off, at the cut-off, $20\%$ above the cut-off and in the moderate positive range of the assays were tested to evaluate the reproducibility of the qualitative method of analysis. The results were calculated using single-point (qualitative) analysis as indicated in the product insert. The manufacturer's predetermined acceptance criteria were met. Results are summarized below.
| Sample | Mean EU/mL | % Negative | % Positive |
| --- | --- | --- | --- |
| Low Negative | 7.9 | 100 | 0 |
| Cut-off -20% | 16.2 | 100 | 0 |
| Cut-off | 20.4 | 37 | 63 |
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| Sample | Mean EU/mL | % Negative | % Positive |
| --- | --- | --- | --- |
| Cut-off +20% | 23.4 | 1 | 99 |
| Moderate Positive | 44.5 | 0 | 100 |
| High Positive | 79.3 | 0 | 100 |
| High Positive | 149.4 | 0 | 100 |
Lot-to-Lot Reproducibility:
Inter-lot reproducibility was tested by using samples spanning the assay range. Three lots of material were used in the study. Seven samples were tested in duplicate on three different lots of the kit. Assays were run by two operators on two different sets of equipment, each using a multichannel pipettor, microplate washer and microplate reader. There was no recalibration of this equipment over the course of this study. The manufacturer's pre-determined acceptance criteria were met for all measures.
Lot-to-Lot Reproducibility:
| Sample | EU/mL | Lot 1 %CV | Lot 2 %CV | Lot 3 %CV | Between Lots %CV |
| --- | --- | --- | --- | --- | --- |
| 1 | 8.0 | 9.2 | 8.7 | 8.2 | 9.0 |
| 2 | 16.2 | 7.1 | 6.6 | 7.0 | 6.9 |
| 3 | 20.2 | 6.3 | 5.2 | 7.2 | 6.7 |
| 4 | 23.0 | 6.2 | 5.1 | 5.8 | 6.2 |
| 5 | 43.3 | 5.0 | 5.7 | 6.4 | 6.1 |
| 6 | 96.5 | 3.6 | 3.1 | 3.1 | 3.7 |
| 7 | 154.0 | 4.2 | 4.6 | 3.8 | 4.4 |
Control Material Precision Studies:
Positive and negative control materials were tested in duplicate, twice per day for 20 days for a total of 80 replicates per sample. Assays were run by two operators on two different sets of equipment.
| | | Repeatability | | Between Runs | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | Mean | SD | %CV | SD | %CV | SD | %CV |
| Negative Control | 5.3 | 0.1 | 2.2 | 0.4 | 7.6 | 0.4 | 7.3 |
| Positive Control | 82.6 | 2.4 | 2.9 | 5.1 | 6.2 | 5.1 | 6.2 |
b. Linearity/assay reportable range:
Positive samples with values throughout the measuring range were selected and assayed in duplicate, at equidistant dilutions to determine linear range of the assays.
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The linear range of the assay was determined to be 3.9–160 EU/mL.
| Sample | Dilution Range (EU/mL) | Slope (95% CI) | Y-Intercept (95% CI) | R² | % Recovery |
| --- | --- | --- | --- | --- | --- |
| 1 | 3.2–46.0 | 1.05 (0.97 –1.13) | -0.67 (-2.88 –1.53) | 0.994 | 92 –116 |
| 2 | 6.3–123.1 | 1.02 (0.95 –1.10) | -0.18 (-5.64 –5.29) | 0.995 | 93 –104 |
| 3 | 4.9–188.1 | 1.03 (0.95 –1.11) | 1.42 (-7.15 –9.98) | 0.984 | 87 –102 |
High dose hook effect: High concentrations specimens were serially diluted (from approximated 407 EU/mL) to assess the presence of a decrease in assay signal associated with antigen excess (hook effect). A hook effect at concentrations up to 407 EU/mL was not seen.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
i) Traceability:
There are currently no recognized international standards for the measurement of anti-centromere antibodies. Calibrator and Control values are directly traceable to in-house standards.
ii) Value Assignment:
Calibrators and Positive Controls are dilutions of pooled Centromere antibody-positive sera. The sponsor formulates new calibrator and control lots from an array of antibody positive sera obtained from commercial plasma centers stored frozen at -70°C. The calibrators and controls are taken from different pooled sera. All source sera has been tested and found negative for infectious disease as stated in the product insert. Manufactured calibrator sets are stored in aliquots frozen at -70°C. As new lots of calibrators are developed, comparison studies are performed to calibrate values against original calibrators. Each lot of calibrator is also tested in comparison with normal human sera, clinical samples and internal standards.
iii) Stability:
Shelf life stability:
Accelerated and open kit studies for each device were performed on three lots of components/reagents. Accelerated studies were conducted with materials incubated at 37°C. In these conditions, one day is considered equivalent to one month stored at 2°–8°C. Materials are removed from the incubator for testing at three-day intervals for a minimum of 18 days.
Real time stability of three kit lots was tested using five specimens with reactivities across the analytical measuring range; current results support a six month shelf life stability claim.
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Open Kit Stability:
For open kit stability studies, materials are opened and stored as required for bench-top usage, then assayed at 15, 45 and 90 day intervals. Open vial stability studies demonstrate opened reagents are stable at 45 days, but the sponsor chose a more restrictive one month open kit stability claim.
d. Detection limit:
The Limit of Blank (LoB) and the Limit of Detection (LoD) were determined using 60 replicates of the blank and 10 replicates each of 6 low-level (normal human) samples by following CLSI EP17-A. Sixty samples of diluent were run as blank samples and six different normal human sera were each assayed 10 times. LoB was determined to be 3.5 and LoD was determined to be 3.9 EU/ml.
e. Analytical specificity:
Interference:
The studies were performed according to CLSI EP07-A2, Interference Testing in Clinical Chemistry, Approved Guideline- Second Edition. Interference was studied by mixing sera with known Centromere antibody levels with serum samples containing potentially interfering substances and studying deviation from expected results. Samples were selected from the negative range, near the assay cutoff and in the low, moderate and high positive range less than the value of the top calibrator. No significant interference (defined as > 15% deviation from expected) was demonstrated in the Centromere assay for the following substances at the levels indicated: Hemoglobin (2 g/L), Bilirubin (342 μmol/L), Rheumatoid Factor (100 EU/mL), Triglycerides (37 mmol/L) and Cholesterol (13 mmol/L).
Comparison to Reference Sera:
Twelve ANA human reference sera from the Centers for Disease Control and Prevention were tested with the ImmuLisa Centromere Antibody ELISA. As expected, the CDC sample known to contain anti-Centromere antibodies tested strongly positive. The eleven other samples were negative. The other samples represent other ANA-type antigens such as SS-A, SS-B, Jo-1, etc.
Ten ANA human reference sera from the Association of Medical Laboratory Immunologists were tested with the ImmuLisa Centromere Antibody ELISA. As expected, the AMLI sample known to contain anti-Centromere antibodies tested strongly positive. The nine other samples were negative. The other samples represent other ANA-type antigens such as SS-A, SS-B, Jo-1, etc.
f. Assay Cut-off:
Positive assay cut-offs were assigned a unit values of 25 EU/mL for the semi-quantitative method and 20 EU/mL for the qualitative method, based on the standardized method used by other IMMCO products. Indeterminate/borderline results (defined as 20–25 EU/mL) for the semi-quantitative method, are
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recommended to be retested and evaluated along with other laboratory methods for detection of antibodies to ENA.
## 2. Comparison studies:
a. Method comparison with predicate device:
A method comparison study was performed with the QUANTA Lite™ Centromere ELISA kit, using 119 samples from patients with limited system sclerosis (LcSSc)/ CREST Syndrome (SSc)] and 288 disease controls. Sample values were within the analytical measuring range for the device. Performance relative to the predicate was determined by calculating agreement where borderline values were considered positive or negative. Qualitative results were the same as those obtained when semi-quantitative indeterminate values are considered positive.
| Borderline values considered positive | Quanta Lite Centromere Antibody ELISA | | | |
| --- | --- | --- | --- | --- |
| | | Positive | Negative | Total |
| IMMCO Centromere Ab ELISA | Positive | 55 | 16 | 71 |
| | Negative | 4 | 332 | 336 |
| | Total | 59 | 348 | 407 |
Positive Percent Agreement: 93.2% (95% CI 88.7–97.8%)
Negative Percent Agreement: 95.4% (95% CI 92.5–97.3%)
Total Agreement: 95.1% (95% CI 92.4–96.9%)
| Borderline values considered negative | Quanta Lite Centromere Antibody ELISA | | | |
| --- | --- | --- | --- | --- |
| | | Positive | Negative | Total |
| IMMCO Centromere Ab ELISA | Positive | 51 | 13 | 64 |
| | Negative | 8 | 335 | 343 |
| | Total | 59 | 348 | 407 |
Positive Percent Agreement: 86.4% (95% CI 74.5–93.6%)
Negative Percent Agreement: 96.3% (95% CI 93.5–97.9%)
Total Agreement: 94.8% (95% CI 92.2–96.6%)
The manufacturer’s pre-determined acceptance criteria were met for all measures.
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b. Matrix comparison:
Not applicable.
# 3. Clinical studies:
# a. Clinical Sensitivity and Specificity:
The clinical sensitivity and specificity of the IMMCO Centromere assay was evaluated in 989 serum samples representing various autoimmune and infectious conditions; the performance was assessed against the clinical diagnosis. Borderline results were considered positive and negative for these analyses. When results were calculated by the qualitative method, sensitivity and specificity are identical to the semi-quantitative results when borderline results are considered positive.
| Borderline values considered positive | Diagnosis -lcSSC | | | |
| --- | --- | --- | --- | --- |
| | | lcSSC/ CREST | Controls | Total |
| IMMCO Centromere Ab ELISA | Positive | 66 | 39 | 105 |
| | Negative | 58 | 826 | 884 |
| | Total | 124 | 865 | 989 |
Sensitivity $= 53.2\%$ (95% C.I. $= 44.1 - 62.2\%$ )
Specificity $= 95.5\%$ (95% C.I. $= 93.8 - 96.7\%$
| Borderline values considered negative | Diagnosis -lcSSC | | | |
| --- | --- | --- | --- | --- |
| | | lcSSC/ CREST | Controls | Total |
| IMMCO Centromere Ab ELISA | Positive | 61 | 35 | 96 |
| | Negative | 63 | 830 | 893 |
| | Total | 124 | 865 | 989 |
Sensitivity $= 49.2\%$ (95% C.I. $= 40.2 - 58.3\%$ )
Specificity $= 96.0\%$ (95% C.I. $= 94.4 - 97.2\%$ )
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The distribution of the Centromere positivity rate in the cohort is in the Table below:
| Cohort | n | #Pos1 | %Pos1 |
| --- | --- | --- | --- |
| Limited cutaneous systemic sclerosis | 124 | 66 | 53.2% |
| Diffuse cutaneous scleroderma | 39 | 1 | 2.6% |
| Anti-phospholipid syndrome | 36 | 4 | 11.1% |
| Anti-phospholipid syndrome with SLE | 20 | 0 | 0.0% |
| Celiac Disease | 35 | 2 | 11.4% |
| Churg-Strauss syndrome | 27 | 0 | 0.0% |
| Crohn's disease | 25 | 0 | 0.0% |
| Granulomatosis with polyangiitis | 27 | 0 | 0.0% |
| Graves' disease | 20 | 0 | 0.0% |
| Hashimoto's thyroiditis | 20 | 0 | 0.0% |
| Osteoarthritis | 20 | 0 | 0.0% |
| Polymyositis/Dermatomyositis | 30 | 1 | 3.3% |
| Rheumatoid Arthritis | 24 | 1 | 4.2% |
| Sjögren's Syndrome | 37 | 2 | 5.4% |
| Systemic Lupus Erythematosus | 92 | 1 | 1.1% |
| Thrombocytopenia | 15 | 2 | 13.3% |
| Ulcerative Colitis | 25 | 0 | 0.0% |
| Autoimmune hepatitis | 30 | 4 | 13.3% |
| Mixed Connective Tissue Disease | 30 | 2 | 6.7% |
| Primary Biliary Cirrhosis | 30 | 6 | 20.0% |
| IDDM | 30 | 1 | 3.3% |
| CMV | 20 | 0 | 0.0% |
| Hepatitis C | 20 | 0 | 0.0% |
| HSV-1 | 20 | 3 | 15.0% |
| HSV-2 | 20 | 0 | 0.0% |
| Lyme disease | 20 | 0 | 0.0% |
| Mononucleosis | 20 | 1 | 5.0% |
| Rubella | 20 | 0 | 0.0% |
| Syphilis | 17 | 0 | 0.0% |
| Toxoplasmosis | 20 | 0 | 0.0% |
| Advanced chronic renal failure | 30 | 3 | 10.0% |
| Cancers2 | 46 | 3 | 6.5% |
1. Indeterminate results were considered positive
2. Cancers included breast, colorectal, lung, ovarian and pancreatic.
The manufacturer's pre-determined acceptance criteria were met for all measures.
Clinical cut-off:
Not applicable
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4. Expected values/Reference range:
Test results in a normal population are expected to be negative. A study of 117 normal, apparently disease-free samples tested with the anti-Centromere assay yielded no borderline results (0.0%) and no positive results (0.0%).
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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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.