PRODIGY ASTRO Blood Glucose Monitoring System, PRODIGY ASTRO PRO Blood Glucose Monitoring System
Applicant
Ok Biotech Co., Ltd.
Product Code
NBW · Clinical Chemistry
Decision Date
Jul 20, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1345
Device Class
Class 2
Attributes
Pediatric
Indications for Use
Prodigy® Astro Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, palm, calf or thigh. The Prodig® Astro Blood Glucose Monitoring System is intended to be used in the home by a single person and should not be shared. The Prodigy® Astro Blood Glucose Monitoring System is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The Prodigy® Astro Blood Glucose Monitoring System should not be used for the diagnosis of, or screeming for diabetes, or for neonatal use. The alternative site testing should be done only during steady-state times (when glucose is not changing rapidly). PRODIGY No Coding Test Strips are intended for use with the PRODIGY Astro blood glucose meters to measure concentration of blood glucose in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, palm, calf or thigh for self-testing at home. Prodigy® Astro PRO Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, palm, calf or thigh. The Prodigy® Astro PRO Blood Glucose Monitoring System is intended for testing outside the body (in vitro diagnostic use) and is intended for multiple-patient use by healthcare professional healthcare settings as an aid to monitor the effectiveness of diabetes control. The Prodigy® Astro PRO Blood Glucose Monitoring System should not be used for the diagnosis of, or screening for diabetes, or for neonatal use. The alternative site testing should be done only during steady-state times (when glucose is not changing rapidly). PRODIGY PRO No Coding Test Strips are intended for use with the PRODIGY Astro PRO blood glucose meters to measure concentration of blood glucose in fresh capillary whole blood samples drawn from the fingertips, forearm, upper arm, palm, calf or thigh. The system should only be used with single-use, auto-disabling lancing devices.
Device Story
System comprises glucose meter and dry reagent biosensor test strips (Glucose Oxidase). Input: fresh capillary whole blood sample (0.7 µL). Operation: electrochemical biosensor with carbon electrodes; electrical current generated by glucose-enzyme reaction measured by meter; current strength proportional to glucose concentration. Output: quantitative blood glucose level displayed on screen. Used in home (Astro) or professional healthcare settings (Astro PRO). Healthcare providers/patients use output to monitor diabetes control effectiveness. Features automatic temperature compensation via thermistor. Astro PRO model validated for multi-patient use with germicidal wipes.
Clinical Evidence
Bench testing only. Evaluated precision (within-run/between-run CV < 5.0%), linearity (20-600 mg/dL), system accuracy (vs YSI 2300 reference), hematocrit (20-60%), and interference (26 substances). Accuracy study with 100 lay persons across multiple body sites showed >95% of results within ±15 mg/dL (<75 mg/dL) or ±15% (≥75 mg/dL). Robustness validated for cleaning/disinfection cycles (520 for Astro, 10950 for Astro PRO).
Technological Characteristics
Electrochemical biosensor; glucose oxidase (Aspergillus niger) reagent; 0.7 μL sample volume; 6-second test time; 20-600 mg/dL range. Powered by 2x 1.5V AAA batteries. Connectivity: wired data transmission to computer (no wireless). Disinfection: PDI Super Sani-Cloth. Standards: IEC 60601-1, IEC 60601-1-2, CLSI EP5-A, EP6-A, EP7-A2.
Indications for Use
Indicated for quantitative blood glucose measurement in people with diabetes to monitor diabetes control effectiveness. Samples: fresh capillary whole blood (fingertip, forearm, upper arm, palm, calf, thigh). Contraindications: neonates, critically ill patients, patients with dehydration, hypotension, shock, or hyper-osmolar state. Not for diagnosis or screening of diabetes.
Regulatory Classification
Identification
A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.
Special Controls
*Classification.* Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.
Predicate Devices
PRODIGY AutoCode Eject Blood Glucose Monitoring System (K141914)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION MEMORANDUM ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
K152599
B. Purpose for Submission:
New device
C. Measurand:
Capillary whole blood glucose from fingertip, forearm, upper arm, palm, calf and thigh.
D. Type of Test:
Quantitative Amperometric assay (Glucose Oxidase)
E. Applicant:
OK BIOTECH CO., LTD.
F. Proprietary and Established Names:
PRODIGY Astro Blood Glucose Monitoring System
PRODIGY Astro PRO Blood Glucose Monitoring System
G. Regulatory Information:
| Device | Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- | --- |
| PRODIGY Astro Blood Glucose Monitoring System | NBW, CGA (over the counter) | Class II | 21 CFR § 862.1345, glucose test system, over the counter, Glucose oxidase | 75-Chemistry |
| PRODIGY Astro PRO Blood Glucose Monitoring System | | | | |
H. Intended Use:
1. Intended use(s):
See indications for use below.
2. Indication(s) for use:
PRODIGY Astro Blood Glucose Monitoring System
Prodigy® Astro Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from fingertip, forearm, upper arm, palm, calf or thigh. The Prodigy® Astro
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Blood Glucose Monitoring System is intended to be used in the home by a single person and should not be shared. The Prodigy® Astro Blood Glucose Monitoring System is intended for self-testing outside the body (in vitro diagnostic use) by people with diabetes at home as an aid to monitor the effectiveness of diabetes control. The Prodigy® Astro Blood Glucose Monitoring System should not be used for the diagnosis of, or screening for diabetes, or for neonatal use. The alternative site testing should be done only during steady-state times (when glucose is not changing rapidly).
PRODIGY No Coding Test Strips are intended for use with the PRODIGY Astro blood glucose meter to measure concentration the of blood glucose in fresh capillary whole blood samples drawn from the fingertip, forearm, upper arm, palm, calf or thigh for self-testing at home.
## PRODIGY Astro PRO Blood Glucose Monitoring System
Prodigy® Astro PRO Blood Glucose Monitoring System is intended to be used for the quantitative measurement of glucose (sugar) in fresh capillary whole blood samples drawn from fingertip, forearm, upper arm, palm, calf or thigh. The Prodigy® Astro PRO Blood Glucose Monitoring System is intended for testing outside the body (in vitro diagnostic use) and is intended for multiple-patient use by healthcare professionals in healthcare professional settings as an aid to monitor the effectiveness of diabetes control. The Prodigy® Astro PRO Blood Glucose Monitoring System should not be used for the diagnosis of, or screening for diabetes, or for neonatal use. The alternative site testing should be done only during steady-state times (when glucose is not changing rapidly).
PRODIGY PRO No Coding Test Strips are intended for use with the PRODIGY Astro PRO blood glucose meter to measure concentration the of blood glucose in fresh capillary whole blood samples drawn from the fingertip, forearm, upper arm, palm, calf or thigh. The system should only be used with single-use, auto-disabling lancing devices.
## 3. Special conditions for use statement(s):
- For in vitro diagnostic use
- The system should not be used in neonates
- The system should not be used for diagnosis of or screening of diabetes mellitus
- The system should not be used in critically ill patients
- Not to be used for patients who are dehydrated, hypotensive, in shock or in a hyper-osmolar state
- PRODIGY Astro PRO blood glucose meter should only be used with single-use, auto-disabling lancing devices
- Alternative site sample results should NOT be used for calibrating CGMs or for insulin dosing calculations or when glucose levels may be rapidly changing or fluctuating such as after meals, exercise, or after taking insulin.
- Hematocrit levels below 20% or above 60% can cause false results.
## 4. Special instrument requirements:
PRODIGY Astro blood glucose meter
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PRODIGY Astro PRO blood glucose meter
I. Device Description:
The Prodigy Astro and Astro PRO Blood Glucose Monitoring Systems consist of a meter, test strips and control solutions (level 1 and level 2) sold separately.
The two systems are marketed either as a meter only with a carrying case, batteries, Owner's Manual, Quick Reference Guide, Logbook, and Warranty Card; or as a meter kit with a carrying case, batteries, Owner's Manual, Quick Reference Guide, Logbook, and Warranty Card, Prodigy Lancing Device (for the single-patient use version), Prodigy Lancets, Prodigy test strips, and Control Solution.
The Prodigy/Prodigy PRO No Coding Test Strips were previously evaluated as a component of the Prodigy Preferred Blood Glucose Monitoring System (k122338).
The Prodigy Control Solutions were previously cleared in k122338.
J. Substantial Equivalence Information:
1. Predicate device name(s):
PRODIGY AutoCode Eject Blood Glucose Monitoring System
2. Predicate 510(k) number(s):
K141914
3. Comparison with predicate:
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Predicate Device
PRODIGY AutoCode Eject Blood Glucose Monitoring System (k141914) | Candidate Devices
Prodigy Astro Blood Glucose Monitoring System and Prodigy Astro PRO Blood Glucose Monitoring System (k152599) |
| Indications for Use | It is intended to be used for quantitative measurement of glucose in fresh capillary whole blood from fingertip, forearm, upper arm, palm, calf or thigh as an aid to monitor the effectiveness of diabetes control in people with diabetes. | Same |
| Speaking function | Yes | No |
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| Use Setting | At home for single patient use only | Prodigy Astro Blood Glucose Monitoring System is for single patient use at home. Prodigy Astro PRO Blood Glucose Monitoring System is for multiple patient use in professional healthcare settings. |
| --- | --- | --- |
| Detection method | Amperometry | Same |
| Enzyme | Glucose Oxidase | Same |
| Memory | 450 records with time and date | Same |
| Measuring range | 20 - 600 mg/dL | Same |
| Sample type | Capillary whole blood | Same |
| Sample sites | fingertip, forearm, upper arm, palm, calf or thigh | Same |
| Sample volume | 0.7 μL | Same |
| Sample test time | 6 seconds | Same |
| Hematocrit range | 20% - 60% | Same |
| Operating conditions | 50-104°F, 10~85% R.H. (non-condensing) | Same |
| Strip storage conditions | 39.2-104°F, 10~85% R.H. (non-condensing) | Same |
| Power Source | 1.5V AAA Alkaline battery x 2 | Same |
| Meter Size | 100 mm (L) × 56 mm (W) × 23 mm (H) | 108.5 mm (L) × 62.5 mm (W) × 30 mm (H) |
| Meter Weight | Approximately 79 g (with battery installed) | Approximately 105 g (with battery installed) |
# K. Standard/Guidance Document Referenced (if applicable):
IEC 60601-1, Medical electrical equipment Part I. General requirements for safety (2005).
IEC 60601-1-2, Medical electrical equipment Part 2. Electromagnetic compatibility - Requirements and Tests (2007).
CLSI EP5-A: Evaluation of precision performance of quantitative measurements methods; Approved Guideline - $2^{\mathrm{nd}}$ edition (1999).
CLSI EP6-A: Evaluation of the linearity of quantitative measurement procedures: A statistical approach (2003).
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CLSI EP7-A2: Interference testing in clinical chemistry; Approved guideline – 2nd edition (2005).
L. Test Principle:
The test is based on electrochemical biosensor technology and the principle of capillary action. A blood sample is drawn into the test strip by capillary action, and reacts with reagents (glucose oxidase from Aspergillus niger) on the test strip. This reaction produces an electrical current which is proportional to the concentration of glucose in the samples. The electrical current is measured by the meter and is displayed to the user as a corresponding blood glucose concentration.
M. Performance Characteristics (if/when applicable):
The Prodigy Astro Blood Glucose Monitoring System and the Prodigy Astro PRO Blood Glucose Monitoring System differ only in name and intended use (single- vs. multiple-patient use). Therefore, one set of performance data is appropriate to support both the systems. All performance studies provided here is representative performance from one of the two candidate devices.
1. Analytical performance:
a. Precision/Reproducibility:
The sponsor performed within-run precision studies using venous whole blood samples spiked to five different glucose concentration levels (30 to 50, 51 to 110, 111 to 150, 151 to 250, 251 to 400 mg/dL). Each glucose concentration level was analyzed in replicates of 10, with 3 test strip lots and 10 meters, for a total of 300 tests per each glucose level for 10 meter. Results are summarized below:
| Lot 1 | | | | |
| --- | --- | --- | --- | --- |
| Glucose Level (mg/dL) | Mean (mg/dL) | n | SD (mg/dL) | %CV |
| 30 to 50 | 45.6 | 100 | 1.1 | 2.5 |
| 51 to 110 | 79.6 | 100 | 2.4 | 3.0 |
| 111 to 150 | 130.8 | 100 | 3.6 | 2.7 |
| 151 to 250 | 196.0 | 100 | 5.4 | 2.7 |
| 251 to 400 | 324.0 | 100 | 9.5 | 2.9 |
| Lot 2 | | | | |
| --- | --- | --- | --- | --- |
| Glucose Level (mg/dL) | Mean (mg/dL) | n | SD (mg/dL) | %CV |
| 30 to 50 | 45.5 | 100 | 1.1 | 2.4 |
| 51 to 110 | 79.6 | 100 | 2.4 | 3.0 |
| 111 to 150 | 130.1 | 100 | 3.4 | 2.6 |
| 151 to 250 | 196.5 | 100 | 5.7 | 2.9 |
| 251 to 400 | 323.1 | 100 | 9.2 | 2.8 |
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| Lot 3 | | | | |
| --- | --- | --- | --- | --- |
| Glucose Level (mg/dL) | Mean (mg/dL) | n | SD (mg/dL) | %CV |
| 30 to 50 | 45.4 | 100 | 1.2 | 2.6 |
| 51 to 110 | 79.3 | 100 | 2.2 | 2.8 |
| 111 to 150 | 130.7 | 100 | 3.4 | 2.6 |
| 151 to 250 | 195.6 | 100 | 5.1 | 2.6 |
| 251 to 400 | 323.0 | 100 | 9.0 | 2.8 |
Intermediate (between run) precision was evaluated using 3 levels of glucose control solutions (30 – 50 mg/dL; 96 – 144 mg/dL and 250 – 420 mg/dL) over 10 days with 3 test strip lots. For each level, on each day, 5 meters were used for testing, with 10 replicates collected per meter for a total of 50 replicates per lot for each glucose level per day.
Intermediate Precision:
| Lot 1 | | | |
| --- | --- | --- | --- |
| Glucose Level (mg/dL) | Mean (mg/dL) | SD (mg/dL) | %CV |
| 30 - 50 | 39.9 | 2.0 | 5.0 |
| 96 - 144 | 117.0 | 3.5 | 3.0 |
| 250 - 420 | 261.4 | 7.8 | 3.0 |
| Lot 2 | | | |
| --- | --- | --- | --- |
| Glucose Level (mg/dL) | Mean (mg/dL) | SD (mg/dL) | %CV |
| 30 - 50 | 40.0 | 2.0 | 5.1 |
| 96 - 144 | 116.9 | 3.5 | 3.0 |
| 250 - 420 | 261.1 | 7.9 | 3.0 |
| Lot 3 | | | |
| --- | --- | --- | --- |
| Glucose Level (mg/dL) | Mean (mg/dL) | SD (mg/dL) | %CV |
| 30 - 50 | 40.0 | 2.0 | 5.0 |
| 96 - 144 | 116.9 | 3.5 | 3.0 |
| 250 - 420 | 261.3 | 7.6 | 2.9 |
b. Linearity/assay reportable range:
Linearity testing was performed using venous whole blood samples. The evaluation was conducted with 10 meters and 3 test strip lots. Samples with the following glucose concentrations (mg/dL) were prepared: 15.1, 20.0, 50.1, 92.0, 150, 250.3,
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300.3, 349.8, 399.8, 449.8, 510.0, 601.3 and 630.5 (as established using a laboratory reference method (YSI 2300 analyzer)). Ten strips from each lot were used for testing at each glucose concentration for a total of $n = 30$ tests per glucose concentration. The evaluation yielded the following regression equation based on all samples:
| Lot | Slope | y-intercept | R² |
| --- | --- | --- | --- |
| 1 | 0.9993 | 1.2852 | 0.9998 |
| 2 | 1.0054 | -1.352 | 0.9996 |
| 3 | 0.9942 | 0.5085 | 0.9999 |
The results of the study support the sponsor's claimed glucose measuring range of 20-600 mg/dL. The meter displays "Lo" with glucose values below 20mg/dL, and "HI" with glucose values over 600 mg/dL. The "Lo" and "Hi" functions were validated and demonstrated to function as intended.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
# Traceability:
The system is traceable to the NIST SRM #917c glucose reference material. The method comparison study was performed using the candidate device and YSI as the reference method (see Section 2.a. above).
# Control Solution Value Assignment and Stability:
Prodigy Control Solutions were previously cleared in k122338.
Stability and value assignment protocols and acceptance criteria for the two levels of control solutions (level 1 and level 2) were evaluated and found to be acceptable in k122338 to support the labeled claims: closed-vial stability of 24 months at $39 - 86^{\circ}\mathrm{F}$ and open-vial stability of 90 days when stored at the recommended storage temperature $(39 - 86^{\circ}\mathrm{F})$ or until the expiration date printed on the label, whichever comes first.
# Test Strip Stability:
Stability protocols and acceptance criteria for the Prodigy No/Prodigy PRO No Coding Test Strips were evaluated in k122338 and found to be acceptable to support closed-vial stability of 24 months and open-vial stability of 90 days when test strips are stored at $39.2 - 104^{\circ}\mathrm{F}$ and $10 - 85\%$ relative humidity or until the expiration date printed on the label, whichever comes first. The labeling instructs the users not to freeze the test strips.
d. Detection limit:
See linearity study in Section M1b above.
e. Analytical specificity:
Interference studies were performed by spiking endogenous and exogenous substances into venous whole blood. Each potential interferent was tested at three
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glucose levels (approximately 81.5, 245, and 445 mg/dL). Fifteen replicates were measured for each test sample. Results of test samples with the potential interferent measured on the Prodigy Astro Blood Glucose Meter System were compared to samples measured on a laboratory-based reference method (YSI 2300 analyzer) and bias and percent bias were calculated. This procedure was performed for three test strip lots using five meters. The compounds at the concentrations listed below did not have significant interference (defined by the sponsor as percent bias ≤ ±10%):
| Interfering substance | Concentration with no Significant Interference |
| --- | --- |
| Acetaminophen | 8.0 mg/dL |
| Ascorbic acid | 5.0 mg/dL |
| Aspirin | 60 mg/dL |
| Bilirubin | 90 mg/dL |
| Cholesterol | 500 mg/dL |
| Creatinine | 5.0 mg/dL |
| Dopamine | 2.0 mg/dL |
| EDTA | 360 mg/dL |
| Galactose | 900 mg/dL |
| Gentisic acid | 5.0 mg/dL |
| Glutathione | 53 mg/dL |
| Haemoglobin | 500 mg/dL |
| Heparin | 8000 U/dL |
| Hydroxyurea | 3.0 mg/dL |
| Ibuprofen | 50 mg/dL |
| Icodextrin | 13 mg/dL |
| L-dopa | 10 mg/dL |
| Maltose | 900 mg/dL |
| Methyldopa | 3.0 mg/dL |
| Pralidoxime iodide | 25 mg/dL |
| Salicylate | 60 mg/dL |
| Tolazamide | 50 mg/dL |
| Tolbutamide | 400 mg/dL |
| Triglyceride | 2,000 mg/dL |
| Uric acid | 8.0 mg/dL |
| Xylose | 100 mg/dL |
Based on these results, the sponsor includes the following in their test strip labeling:
- Do not use the PRODIGY Self-Monitoring Blood Glucose System during or after a Xylose Absorption Test. This may falsely raise glucose results. Please check with your Doctor before using the PRODIGY Self-Monitoring Blood Glucose System.
- The system exhibits interference from Acetaminophen, ascorbic acid and Ibuprofen. If you are taking acetaminophen containing drugs (Tylenol, etc., >8.0 mg/dL in your blood), or ibuprofen containing drugs (Advil, etc., > 50.0
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mg/dL in your blood) or vitamin C (ascorbic acid, > 5.0 mg/dL in your blood), you may obtain inaccurate readings from this blood glucose monitoring system. Please check with your doctor before using the PRODIGY Self-Monitoring Blood Glucose System.
- High uric acid concentrations (>8 mg/dL in your blood) may interfere with the glucose measurements with this device. If you have medical conditions that are associated with high uric acid level or hyperuricemia (e.g. gout), then please check with your Doctor before using the PRODIGY Self-Monitoring Blood Glucose System.
f. Assay cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
To assess system accuracy, results from the Prodigy Astro Blood Glucose Monitoring System were compared to a reference method (YSI 2300 analyzer). Venous samples and capillary samples from fingerstick, forearm, palm, upper arm, calf and thigh were obtained by professional users from 100 participants with glucose concentrations ranging from 50.9 to 415 mg/dL. To obtain extreme blood glucose concentrations, six samples were altered. The meter results relative to YSI are summarized below:
Fingertip Testing
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL | |
| 11/15 (73.3%) | 14/15 (93.3%) | 15/15 (100%) | |
| For glucose concentrations ≥75 mg/dL | | | |
| Within ± 5% | Within ± 10% | Within ± 15% | Within ± 20% |
| 54/85 (63.5%) | 76/85 (89.4%) | 84/85 (98.8%) | 85/85 (100%) |
Palm Testing
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL | |
| 12/15 (80%) | 15/156 (100%) | 15/15 (100%) | |
| For glucose concentrations ≥75 mg/dL | | | |
| Within ± 5% | Within ± 10% | Within ± 15% | Within ± 20% |
| 50/85 (58.8%) | 76/85 (89.4%) | 84/85 (98.8%) | 85/85 (100%) |
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Forearm Testing
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL | |
| 9/15 (60%) | 15/15 (100%) | 15/15 (100%) | |
| For glucose concentrations ≥75 mg/dL | | | |
| Within ± | Within ± 10% | Within ± 15% ± | Within ± 20 % |
| 53/85 (62.4%) | 74/85 (87.1%) | 82/85 (96.5%) | 85/85 (100%) |
Upper arm Testing
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL | |
| 10/15 (66.7%) | 14/15 (93.3%) | 15/15 (100%) | |
| For glucose concentrations ≥75 mg/dL | | | |
| Within ± 5% | Within ± 10% | Within ± 15% ± | Within ± 20 % |
| 55/85 (64.7%) | 77/85 (90.6%) | 83/85 (97.6%) | 85/85 (100%) |
Calf Testing
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL | |
| 10/15 (66.7%) | 15/15 (100%) | 15/15 (100%) | |
| For glucose concentrations ≥75 mg/dL | | | |
| Within ± 5% | Within ± 10% | Within ± 15% | Within ± 20 % |
| 51/85 (60%) | 74/85 (87.1%) | 81/85 (95.3%) | 85/85 (100%) |
Thigh Testing
| For glucose concentrations < 75 mg/dL | | | |
| --- | --- | --- | --- |
| Within ± 5 mg/dL | Within ± 10 mg/dL | Within ± 15 mg/dL | |
| 10/15 (66.7%) | 14/15 (93.3%) | 15/15 (100%) | |
| For glucose concentrations ≥75 mg/dL | | | |
| Within ± 5% | Within ± 10% | Within ± 15% | Within 20 % |
| 52/85 (61.2%) | 80/85 (94.1%) | 84/85 (98.8%) | 85/85 (100%) |
Results of linear regression (N=100) are shown below:
Fingertip: $y = 0.9956x + 0.9796$ ; $R^2 = 0.9865$
Palm: $y = 1.0143x + 2.1599$ ; $R^2 = 0.9847$
Forearm: $y = 1.0187x - 2.316$ ; $R^2 = 0.9838$
Upper arm: $y = 1.0001x - 1.3378$ ; $R^2 = 0.9836$
Calf: $y = 0.9995x - 0.5912$ ; $R^2 = 0.9831$
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Thigh: $y = 1.0239x - 2.0456$ ; $R^2 = 0.9873$
b. Matrix comparison:
Not applicable
# 3. Clinical studies:
a. Clinical Sensitivity:
Not applicable
b. Clinical specificity:
Not applicable
c. Other clinical supportive data (when a. and b. are not applicable):
# User Performance study:
To assess the performance of the Prodigy Astro Blood Glucose Monitoring System in the hands of the intended users, the sponsor performed a study with 103 lay user participants who collected and tested samples from their own fingertip, palm, forearm, upper arm, calf and thigh. Results were analyzed by comparing blood glucose results obtained by the lay users with the Prodigy Astro Blood Glucose Monitoring System against results obtained using a laboratory reference method (YSI 2300 analyzer). The glucose concentrations in the samples ranged from approximately 55.8 to $403\mathrm{mg / dL}$ as measured by the laboratory reference method. Results are summarized in the tables below:
For glucose concentrations $< 75\mathrm{mg / dL}$
| Site | Within ± 5 mg/dL | within ± 10 mg/dL | within ± 15 mg/dL |
| --- | --- | --- | --- |
| Finger | 12/19 (63.2%) | 16/19 (84.2%) | 19/19 (100%) |
| Palm | 12/19 (63.2%) | 18/19 (94.7%) | 19/19 (100%) |
| Forearm | 12/19 (63.2%) | 18/19 (94.7%) | 19/19 (100%) |
| Upper arm | 14/19 (73.7%) | 18/19 (94.7%) | 19/19 (100%) |
| Calf | 12/19 (63.2%) | 16/19 (84.2%) | 19/19 (100%) |
| Thigh | 12/19 (63.2%) | 17/19 (89.5%) | 19/19 (100%) |
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For glucose concentrations $\geq 75\ \mathrm{mg/dL}$
| Site | Within ± 5 % | Within ± 10 % | Within ± 15 % | Within ± 20 % |
| --- | --- | --- | --- | --- |
| Finger | 51/84
(60.7%) | 72/84
(85.7%) | 82/84
(97.6%) | 84/84
(100%) |
| Palm | 58/84
(69.0%) | 77/84
(91.7%) | 81/84
(96.4%) | 84/84
(100%) |
| Forearm | 53/84
(63.1%) | 74/84
(88.1%) | 82/84
(97.6%) | 84/84
(100%) |
| Upper arm | 55/84
(65.5%) | 78/84
(92.9%) | 81/84
(96.4%) | 84/84
(100%) |
| Calf | 53/84
(63.1%) | 72/84
(85.7%) | 82/84
(97.6%) | 84/84
(100%) |
| Thigh | 54/84
(64.3%) | 74/84
(88.1%) | 81/84
(96.4%) | 84/84
(100%) |
Linear Regression Analysis:
| Sample Site | Slope | Intercept | R² | N |
| --- | --- | --- | --- | --- |
| Fingertip | 0.9691 | 1.7595 | 0.9774 | 103 |
| Palm | 0.9866 | 0.9495 | 0.9831 | 103 |
| Forearm | 0.9633 | 2.4022 | 0.9801 | 103 |
| Upper arm | 0.9989 | 1.4899 | 0.9862 | 103 |
| Calf | 0.9665 | 0.4658 | 0.9816 | 103 |
| Thigh | 0.9815 | 1.0802 | 0.9811 | 103 |
Usability Study: Users completed questionnaires regarding ease of use (on a scale of 1 (much not agreeable), 2 (not agreeable), 3 (no comment), 4 (agreeable) to 5 (very agreeable)) as well as specific questions to test understanding of information in the user manual. The users of the device were able to understand and follow the instructions provided in the labeling to perform the blood glucose testing.
4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
The sponsor provided the following information for expected glucose values for persons
{12}
without diabetes:
The normal adult fasting blood glucose range for a nondiabetic person is Less than 100 mg/dL (5.55 mmol/L) and less than 140 mg/dL (7.77 mmol/L) up to 2 hours after meals.
Source: American Diabetes Association. Classification and diagnosis of diabetes. Sec. 2. In Standards of Medical Care in Diabetes - 2016. Diabetes Care 2016; 39 (Suppl. 1):S16.
N. Instrument Name:
PRODIGY Astro Blood Glucose Meter
PRODIGY Astro PRO Blood Glucose Meter
O. System Descriptions:
1. Modes of Operation:
Each test strip is single use and requires a sample volume of >0.7 μL.
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 ☐
2. Software:
FDA has reviewed applicant’s Hazard Analysis and software development processes for this line of product types:
Yes ☐ X ☐ or No ☐
3. Specimen Identification:
There is no sample identification function with this device. Samples are applied directly to the test strip as they are collected.
4. Specimen Sampling and Handling:
The system is intended to be used with capillary whole blood from the finger, palm, forearm, upper arm, calf and thigh. The whole blood sample is applied directly to the test strip by capillary action.
13
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5. Calibration:
Calibration is automatic. There is no user input for coding.
6. Quality Control:
Two levels of aqueous glucose control solutions are available (sold separately) for use with this system. Instructions on how to order the control solutions are included in the user manual. The meter has a function for the user to select that they wish to run a control solution to prevent control results from being stored in the internal memory as patient results. Recommendations on when to test the control materials are provided in the labeling. The control solution readings are not included in the average of the patient results when the measurements are performed in the "control solution mode". An acceptable range for each control level is printed on the test strip vial label. The user is cautioned not to use the meter if the control result falls outside these ranges.
P. Other Supportive Instrument Performance Characteristics Data Not Covered In The "Performance Characteristics" Section above:
1. Hematocrit Study: To evaluate the effect of hematocrit on the Prodigy Astro Blood Glucose Monitoring System, venous blood samples were adjusted to hematocrit levels of 15 %, 20 %, 30 %, 42 %, 60 % and 65 %. Each hematocrit level was tested at five glucose concentration intervals (30-50, 51-110, 111-150, 151-250, 251-400 mg/dL) for a total of 30 samples. Results from the meter were compared to results obtained using a laboratory-based reference measurement (YSI 2300 analyzer). The evaluation of percent bias relative to values obtained on the YSI 2300 analyzer demonstrated acceptable performance across the claimed hematocrit range of 20-60%.
2. Altitude study: To evaluate the effect of altitude on the Prodigy Astro Blood Glucose Monitoring System, meters were tested at six altitudes above sea level (298 ft; 2,920 ft; 4,790 ft; 6,234 ft; 8,563ft and 11,161 ft). Five glucose levels (43.5, 82.0, 130, 198, and 316 mg/dL) were tested at each altitude. The evaluation included testing each sample with three strip lots and three sets of meters. Each lot included 10 replicates for a total of 30 replicates per glucose level/altitude combination. Results were compared to results obtained using a laboratory-based reference measurement (YSI 2300 analyzer) and demonstrated that altitudes up to 11,000 feet above sea level have no significant effect on blood glucose measurements.
3. Sample Volume: To verify the minimum sample volume requirement, venous whole blood samples with volumes ranging from 0.5 -1.5 μL were tested. Sample concentrations included five glucose levels (40.3, 76.6, 111.9, 176.6, and 340.7 mg/dL) tested at each volume. Testing included ten meters and ten strips from each of three lots for each glucose concentration/sample volume combination for a total of 30 measurements per volume/glucose level combination. Values obtained were compared to values obtained using a laboratory-based reference method (YSI 2300 analyzer). Results support a minimum sample volume of 0.7 μL for the Prodigy Astro/Prodigy Astro PRO blood glucose monitoring systems.
14
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4. Temperature and humidity studies: To evaluate system performance under the extremes of the recommended temperature and humidity conditions, sample testing was performed at temperatures of 50, 77, and 104°F, and R.H. of 10 and 85%; each temperature was tested at both R.H. conditions using venous whole blood at glucose concentrations 49, 149, and 319 mg/dL. The evaluation included ten Prodigy Astro meters, and three strip lots with a total of 30 replicates per glucose level/environmental condition combination. The results obtained on the Prodigy Astro blood glucose monitoring system were compared to those obtained on the YSI 2300, and support the operating conditions of temperatures of 50 - 104°F (10-40°C) and RH of 10-85%.
5. Infection Control and Robustness Studies: The Prodigy Astro Blood Glucose Monitoring System is intended for single-patient use and the Prodigy Astro Pro Blood Glucose Monitoring System is intended for multiple-patient use in clinical settings. Disinfection efficacy testing on the surface materials of the meter demonstrated complete inactivation of hepatitis B virus (HBV) with the chosen disinfectant, PDI SUPER SANI-CLOTH germicidal disposable wipes (EPA Registration # 9480-4). Robustness studies were also performed by the sponsor demonstrating that there was no change in performance or external materials of the meter after: 1) 520 cleaning and disinfection cycles (a total of 1040 wipes) designed to simulate 3 years of single-patient use for the Prodigy Astro Blood Glucose Monitoring System, and 2) 10,950 cleaning and disinfection cycles (a total of 21,900 wipes) designed to simulate three years of multiple-patient device use for the Prodigy Astro Pro Blood Glucose Monitoring System. Labeling was reviewed for adequate instructions for the validated cleaning and disinfection procedures.
6. The sponsor provided appropriate documentation certifying that electromagnetic (EMC) testing was performed and the Prodigy Astro/Prodigy Astro Pro Blood Glucose Monitoring Systems were found to be compliant.
7. Flesch-Kincaid readability assessment was conducted on all labeling and demonstrated that the User Manuals for the Prodigy Astro and Prodigy Astro Pro BGMS are written at an 8th grade level or below.
8. The meter manual states that customer service is available (Mon-Fri, 9AM to 5PM EST) by calling 1-800-243-2636.
Q. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.