The Dimension® Hemoglobin A1c assay is an in vitro diagnostic assay for the quantitative determination of %HbA 1c (DCCT/NGSP) and mmol/mol HbA1c (IFCC) in human anticoagulated venous whole blood for use on the Dimension® clinical chemistry system. Measurement of Hemoglobin A1c is used as an aid in diagnosis and monitoring of long-term blood glucose control in patients with diabetes mellitus and as an aid in the identification of patients at risk for developing diabetes mellitus.
Device Story
Dimension® Hemoglobin A1c Assay is an in vitro diagnostic reagent system for use on Dimension® clinical chemistry analyzers. It measures HbA1c concentration in human anticoagulated venous whole blood samples. The device utilizes a quantitative turbidimetric inhibition immunoassay principle; reagents are provided in ready-to-use Flex® cartridges. The assay is operated by laboratory personnel in a clinical setting. The system performs absorbance spectroscopy to quantify HbA1c levels. Results are reported as %HbA1c (DCCT/NGSP) and mmol/mol HbA1c (IFCC). Healthcare providers use these quantitative results to assess long-term glycemic control, aiding in the diagnosis of diabetes and the identification of patients at risk for developing the condition.
Clinical Evidence
Bench testing only. Precision studies (n=720 results per sample) showed total CVs ranging from 1.6% to 2.8%. Linearity was confirmed across the 3.8-14.0% HbA1c range (r=0.9986). Method comparison against the Tosoh G8 reference method (n=147) showed high correlation (r=0.996). Interference testing confirmed no significant interference from common endogenous/exogenous substances or hemoglobin variants (HbS, HbC, HbD, HbE, HbA2), except for fetal hemoglobin (HbF).
Technological Characteristics
Quantitative turbidimetric inhibition immunoassay; uses polyclonal ovine anti-HbA1c antibodies. Reagents are liquid, ready-to-use in Dimension® Flex® cartridges. Instrument platform: Dimension® RxL clinical chemistry system (absorbance spectroscopy). Compatible with K2-EDTA, K3-EDTA, Na Fluoride/Na2-EDTA, Lithium Heparin, and Na Fluoride/K-Oxalate anticoagulants. Calibration frequency: every 30 days.
Indications for Use
Indicated for patients with diabetes mellitus or those at risk for developing diabetes mellitus. Used for quantitative determination of HbA1c in human anticoagulated venous whole blood to aid in diagnosis and monitoring of long-term blood glucose control.
Regulatory Classification
Identification
A hemoglobin A1c test system is a device used to measure the percentage concentration of hemoglobin A1c in blood. Measurement of hemoglobin A1c is used as an aid in the diagnosis of diabetes mellitus and as an aid in the identification of patients at risk for developing diabetes mellitus.
Special Controls
(b) Classification. Class II (special controls). Hemoglobin A1c test systems must comply with the following special controls: 1) The device must have initial and annual standardization verification by a certifying glycohemoglobin standardization organization deemed acceptable by FDA. 2) The premarket notification submission must include performance testing to evaluate precision, accuracy, linearity and interference, including the following: i) Performance testing of device precision must, at a minimum, use blood samples with concentrations near 5.0%, 6.5%, 8.0% and 12% hemoglobin A1c. This testing must evaluate precision over a minimum of 20 days using at least 3 lots of the device and 3 instruments, as applicable. ii) Performance testing of device accuracy must include a minimum of 120 blood samples that span the measuring interval of the new device and compare results of the new device to results of the standardized test method. Results must demonstrate little or no bias versus the standardized method. iii) Total error of the new device must be evaluated using single measurements by the new device compared to results of the standardized test method, and this evaluation must demonstrate a total error less than or equal to 6%. iv) Performance testing must demonstrate that there is little to no interference from common hemoglobin variants, including Hemoglobin C, Hemoglobin D, Hemoglobin E, Hemoglobin A2 and Hemoglobin S. 3) When assay interference from Hemoglobin F or interference with other hemoglobin variants with low frequency in the population is observed, a warning statement must be placed in a black box and must appear in all labeling material for these devices describing the interference and any affected populations.
*Classification.* Class II (special controls). The special controls for this device are:(1) The device must have initial and annual standardization verification by a certifying glycohemoglobin standardization organization deemed acceptable by FDA.
(2) The premarket notification submission must include performance testing to evaluate precision, accuracy, linearity, and interference, including the following:
(i) Performance testing of device precision must, at a minimum, use blood samples with concentrations near 5.0 percent, 6.5 percent, 8.0 percent, and 12 percent hemoglobin A1c. This testing must evaluate precision over a minimum of 20 days using at least three lots of the device and three instruments, as applicable.
(ii) Performance testing of device accuracy must include a minimum of 120 blood samples that span the measuring interval of the device and compare results of the new device to results of a standardized test method. Results must demonstrate little or no bias versus the standardized method.
(iii) Total error of the new device must be evaluated using single measurements by the new device compared to results of the standardized test method, and this evaluation must demonstrate a total error less than or equal to 6 percent.
(iv) Performance testing must demonstrate that there is little to no interference from common hemoglobin variants, including Hemoglobin C, Hemoglobin D, Hemoglobin E, Hemoglobin A2, and Hemoglobin S.
(3) When assay interference from Hemoglobin F or interference with other hemoglobin variants with low frequency in the population is observed, a warning statement must be placed in a black box and must appear in all labeling material for these devices describing the interference and any affected populations.
{0}
1
510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
ASSAY ONLY TEMPLATE
A. 510(k) Number:
k173909
B. Purpose for Submission:
Addition of a diagnostic claim to an existing device
C. Measurand:
Glycosylated Hemoglobin (HbA1c).
D. Type of Test:
Quantitative turbidimetric inhibition assay
E. Applicant:
Siemens Healthcare Diagnostics Inc.
F. Proprietary and Established Names:
Dimension Hemoglobin A1c Assay
G. Regulatory Information:
1. Regulation section:
21 CFR 862.1373
2. Classification:
Hemoglobin A1c Test System.
3. Product code:
PDJ
4. Panel:
Clinical Chemistry, 75
{1}
H. Intended Use:
1. Intended use(s):
See indications for use below.
2. Indication(s) for use:
The Dimension Hemoglobin A1c assay is an in vitro diagnostic assay for the quantitative determination of %HbA1c (DCCT/NGSP) and mmol/mol HbA1c (IFCC) in human anticoagulated venous whole blood for use on the Dimension clinical chemistry system. Measurement of Hemoglobin A1c is used as an aid in diagnosis of diabetes and monitoring of long-term blood glucose control in patients with diabetes mellitus and as an aid in the identification of patients at risk for developing diabetes mellitus.
3. Special conditions for use statement(s)
The Dimension Hemoglobin A1c assay has significant interference with fetal hemoglobin (HbF). Samples containing HbF may produce a negative bias (lower than actual results) with the Dimension Hemoglobin A1c assay. Hemoglobin A1c results are invalid for patients with abnormal amounts of HbF, including those with known Hereditary Persistence of Fetal Hemoglobin. For additional information on the interference of the HbF variant, refer to Interfering Substances.
For prescription use only
The Dimension Hemoglobin A1C Assay is designed only for accurate and precise measurement of mmol/mol HbA1c (IFCC) and % HbA1c (DCCT/NGSP). The individual results for total Hb and HbA1c concentration are not reported.
The Dimension A1C assay should not be used to diagnose diabetes during pregnancy. Hemoglobin A1c reflects the average blood glucose levels over the preceding 3 months (the average life span of a red blood cell) and therefore may be falsely low during pregnancy or any other condition associated with recent onset of hyperglycemia and/or decreased red blood cell survival.
The Dimension A1C assay should not be used to diagnose or monitor diabetes in patients with the following conditions: hemoglobinopathies except as demonstrated to produce acceptable performance (such as, sickle cell trait), abnormal red blood cell turnover (such as, anemias from hemolysis and iron deficiency), malignancies, and severe chronic hepatic and renal disease.
In cases of rapidly evolving Type 1 diabetes, the increase of HbA1c values might be delayed compared to the acute increase in glucose concentrations. In these conditions, diabetes mellitus must be diagnosed based on plasma glucose concentrations and/or the typical clinical symptoms.
This test should not replace glucose testing for patients with Type 1 diabetes, pediatric patients or pregnant women.
Any cause of shortened red blood cell survival (for example, hemolytic anemia or other
{2}
hemolytic diseases, pregnancy, or recent significant blood loss) will reduce the exposure of red blood cells to glucose with a consequent decrease in A1c values, Results of HbA1c are not reliable in patients with chronic blood loss and consequent variable erythrocyte lifespan
## 4. Special instrument requirements
Performance data below was collected on the Dimension RxL Clinical Chemistry System.
## I. Device Description:
The Dimension Hemoglobin A1c assay consists of three reagents packaged in Dimension Flex cartridges, that contain the antibody, buffers and reagents, are used with the Dimension RxL instrument. The HbA1c measurement is based on a turbidimetric inhibition immunoassay principle, and the measurement of total hemoglobin is based on a modification of the alkaline hematin reaction. Using the values obtained for each of these two analytes, the relative proportion of the total hemoglobin that is glycated is calculated and reported.
## J. Substantial Equivalence Information:
1. Predicate device name(s):
Roche Diagnostics Cobas c513 Tina-Quant HbA1cDx Gen.3 Assay
2. Predicate 510(k) number(s):
k160571
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device (Dimension Hemoglobin A1c Assay) | Predicate (Roche Diagnostics Cobas c513 Tina-Quant HbA1cDx Gen.3 Assay) |
| Intended Use | Intended for the the quantitative determination of mmol/mol HbA1c (IFCC) and % HbA1c (DCCT/NGSP) as an aid in the diagnosis of diabetes mellitus, as an aid to identify patients who may be at risk for developing diabetes | Same |
{3}
4
| | mellitus, and for the monitoring of longterm blood glucose control in individuals with diabetes mellitus. | |
| --- | --- | --- |
| Instrument platform | Absorbance spectroscopy | Same. |
| Assay principle | Quantitative turbidimetric inhibition immunoassay | Same |
| Traceability | The assigned HbA1c and total hemoglobin values are certified with the National Glycohemoglobin Standardization Program (NGSP). | Same |
| Reporting Units | % HbA1c NGSP/DCCT and mmol/mol IFCC | Same |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Measuring range | %HbA1c (NGSP units) 3.8 to 14.0% | %HbA1c 4.2 to 15.5% |
| | HbA1c (IFCC units) 18 to 130 mmol/mol | HbA1c 23 to 146 mmol/mol |
| Sample Type | Anticoagulated venous whole blood. Acceptable anticoagulants include: K2-EDTA K3-EDTA Na Fluoride/Na2-EDTA Lithium Heparin Na Fluoride/K-Oxalate | Anticoagulated whole blood or hemolysate Acceptable anticoagulants for both the hemolysate and whole blood applications include: Li-Heparin K2-EDTA K3-EDTA NaF/K-Oxalate |
K. Standard/Guidance Document Referenced (if applicable):
CLSI EP05-A3 Evaluation of Precision of Quantitative Measurement Procedures; Approved Guideline – Third Edition
CLSI EP06-A Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline
{4}
CLSI EP07-A2 Interference Testing in Clinical Chemistry; Approved Guideline – Second Edition
CLSI EP17-A2 Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures; Approved Guideline – Second Edition
CLSI EP25-A Evaluation of Stability of In Vitro Diagnostic Reagents; Approved Guideline
## L. Test Principle:
HbA1c determination is based on the turbidimetric inhibition immunoassay (TINIA) for hemolyzed whole blood. Glycohemoglobin in the sample reacts with anti-HbA1c to form soluble antigen-antibody complexes. Polyhaptens react with excess anti-HbA1c to form an insoluble antibody-polyhapten complex which can be measured turbidimetrically. This method uses tetradecyltrimethylammonium bromide (TTAB) as the detergent in the hemolyzing reagent. Sample pretreatment to remove labile HbA1c is not necessary. The instrument calculates the %HbA1c from the HbA1c/Hb ratio according to a user selected protocol and the percentage of HbA1c is displayed as the % HbA1c (DCCT/NGSP).
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Samples consisted of two (2) commercial quality controls (BioRad QC) and four (4) venous whole blood patient pools in K2-EDTA with target values of 5.0%, 6.5%, 8.0%, and 12.0% HbA1c.
Testing was performed at one site over twenty (20) testing days by two (2) operators using three (3) instruments and three (3) reagent lots on each instrument. One (1) calibration was performed over the duration of the study. Each testing day, two (2) runs were performed (with a minimum of 2 hours in between) each with two replicates for a total of 720 results for each sample. Results are summarized in the tables below:
Precision (All Instruments, all reagent lots, %HbA1c)
| Mean %HbA1c | Repeatability | | Between Run | | Between Day | | Between Lot | | Between Instrument | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| Human1, 5.3% | 0.05 | 0.9 | 0.04 | 0.7 | 0.01 | 0.1 | 0.07 | 1.4 | 0.09 | 1.6 | 0.13 | 2.4 |
| Human2, 6.4% | 0.05 | 0.7 | 0.03 | 0.5 | 0.03 | 0.4 | 0.09 | 1.4 | 0.00 | 0.0 | 0.11 | 1.7 |
| Human3, 7.8% | 0.06 | 0.8 | 0.04 | 0.5 | 0.03 | 0.3 | 0.10 | 1.3 | 0.00 | 0.0 | 0.13 | 1.6 |
{5}
6
| Mean %HbA1c | Repeatability | | Between Run | | Between Day | | Between Lot | | Between Instrument | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| Human4, 11.9% | 0.09 | 0.8 | 0.05 | 0.0 | 0.05 | 0.0 | 0.06 | 0.0 | 0.18 | 0.3 | 0.22 | 1.8 |
| QC 1, 5.2% | 0.05 | 1.0 | 0.04 | 0.8 | 0.02 | 0.4 | 0.03 | 0.5 | 0.11 | 2.1 | 0.13 | 2.6 |
| QC 2, 9.5% | 0.08 | 0.8 | 0.06 | 0.7 | 0.03 | 0.3 | 0.12 | 1.2 | 0.03 | 0.3 | 0.16 | 1.7 |
## Precision (Instrument 1, all reagent lots, %HbA1c)
| Mean %HbA1c | Repeatability | | Between Run | | Between Day | | Between Lot | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| Human1, 5.4% | 0.05 | 0.9 | 0.04 | 0.7 | 0.02 | 0.3 | 0.11 | 2.1 | 0.13 | 2.4 |
| Human2, 6.5% | 0.05 | 0.8 | 0.04 | 0.6 | 0.02 | 0.3 | 0.07 | 1.1 | 0.10 | 1.5 |
| Human3, 8.0% | 0.06 | 0.8 | 0.05 | 0.7 | 0.01 | 0.2 | 0.01 | 0.2 | 0.08 | 1.0 |
| Human4, 11.9% | 0.10 | 0.8 | 0.04 | 0.4 | 0.04 | 0.3 | 0.24 | 2.0 | 0.27 | 2.3 |
| QC 1, 5.3% | 0.06 | 1.1 | 0.06 | 1.2 | 0.01 | 0.1 | 0.12 | 2.3 | 0.15 | 2.8 |
| QC 2, 9.6% | 0.07 | 0.8 | 0.05 | 0.5 | 0.03 | 0.4 | 0.00 | 0.0 | 0.09 | 1.0 |
## Precision (Instrument 2, all reagent lots, %HbA1c)
| Mean %HbA1c | Repeatability | | Between Run | | Between Day | | Between Lot | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| Human1, 5.4% | 0.05 | 0.9 | 0.04 | 0.7 | 0.00 | 0.0 | 0.07 | 1.3 | 0.09 | 1.7 |
| Human2, 6.4% | 0.04 | 0.7 | 0.03 | 0.5 | 0.04 | 0.6 | 0.03 | 0.4 | 0.07 | 1.1 |
| Human3, 7.8% | 0.06 | 0.7 | 0.04 | 0.6 | 0.04 | 0.5 | 0.05 | 0.6 | 0.09 | 1.2 |
| Human4, 11.9% | 0.09 | 0.7 | 0.07 | 0.6 | 0.07 | 0.6 | 0.16 | 1.3 | 0.21 | 1.8 |
| QC 1, 5.2% | 0.04 | 0.8 | 0.02 | 0.4 | 0.03 | 0.6 | 0.08 | 1.6 | 0.10 | 1.9 |
| QC 2, 9.5% | 0.08 | 0.8 | 0.07 | 0.7 | 0.04 | 0.4 | 0.03 | 0.3 | 0.12 | 1.2 |
## Precision (Instrument 3, all reagent lots, %HbA1c)
| Mean %HbA1c | Repeatability | | Between Run | | Between Day | | Between Lot | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | SD | CV | SD | CV | SD | CV | SD | CV | SD | CV |
| Human1, 5.3% | 0.05 | 1.0 | 0.04 | 0.7 | 0.00 | 0.0 | 0.11 | 2.1 | 0.13 | 2.4 |
| Human2, 6.4% | 0.05 | 0.8 | 0.02 | 0.4 | 0.02 | 0.3 | 0.05 | 0.8 | 0.08 | 1.3 |
| Human3, 7.8% | 0.07 | 0.9 | 0.01 | 0.2 | 0.03 | 0.3 | 0.04 | 0.5 | 0.08 | 1.0 |
| Human4, 1.9% | 0.08 | 0.7 | 0.03 | 0.3 | 0.04 | 0.3 | 0.15 | 1.3 | 0.18 | 1.5 |
| QC 1, 5.1% | 0.05 | 1.0 | 0.04 | 0.7 | 0.02 | 0.4 | 0.12 | 2.4 | 0.14 | 2.7 |
| QC 2, 9.4% | 0.09 | 0.9 | 0.07 | 0.7 | 0.02 | 0.2 | 0.03 | 0.3 | 0.12 | 1.2 |
{6}
b. Linearity/assay reportable range:
Linearity testing was conducted in accordance with CLSI EP06-A, Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline. Nine (9) samples were used with %HbA1c levels that spanned the assay range. The sponsor performed first order linear regression.
The following table summarizes the linear regression results.
| Units | Slope | y-intercept | Correlation coefficient |
| --- | --- | --- | --- |
| NGSP (%HbA1c) | 0.9719 | 0.3264 | 0.9986 |
| IFCC (mmol/mol) | 0.9774 | 2.1431 | 0.9976 |
The linearity results support the claimed reportable measuring range of 3.8-14.0 % HbA1c (18 to 130 mmol/mol).
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability:
The Hemoglobin A1C assay on the Dimension RxL system is certified with the National Glycohemoglobin Standardization Program (NGSP). See NGSP website for current certification at http://www.ngsp.org.
The International Federation of Clinical Chemistry (IFCC) units of mmol/mol are calculated using the Master Equation NGSP (%) = 0.09148 x IFCC (mmol/mol) + 2.152. HbA1c results are provided to the customers using two different units: NGSP equivalent units (%) and IFCC equivalent units (mmol/mol).
d. Detection limit:
Limit of Blank (LoB) and Limit of Detection (LoD) testing was conducted in accordance with CLSI EP17-A2, Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures. LoB and LoD were determined for HbA1c (%), total hemoglobin (tHb) (g/dL) and HbA1c (g/dL).
LoB testing was performed over three testing days by one operator using one instrument and two kit lots. One calibration was performed for each kit lot (total of two). On each testing day, five replicate measurements were taken for each of five blank samples for a total of 75 replicates for each kit lot.
LoD testing was performed over three testing days by one operator using one instrument and two kit lots. One calibration was performed for each kit lot (total of two). On each testing day, four replicate measurements were taken for each of five (5) low level patient samples for a total of 75 total replicates for each kit lot.
{7}
Calculations were performed following the classical approach described in EP17-A2. LoB was calculated using the Nonparametric Option and LoD was calculated using Parametric Analysis.
The detection limits are summarized in the table below:
| | Limit of Blank | Limit of Detection |
| --- | --- | --- |
| tHb | 0.0 g/dL | 0.5 g/dL |
| HbA1c | 0.21 g/dL | 0.23 g/dL |
| % HbA1c | 3.6 % | 3.7 % |
# e. Analytical specificity:
# i. Endogenous interferents
Interference studies were performed to assess endogenous substances that could interfere with the Dimension Hemoglobin A1c Assay. The interfering substances were evaluated in venous whole blood K2 EDTA samples. Four replicates for each interferent were tested on the Dimension Hemoglobin A1c Assay at each of 2 target HbA1c levels: $6.5 \pm 1\%$ and $8.0 \pm 1\%$ . The sponsor's definition of definition of non-significant interference is $\leq 5.0\%$ mean relative deviation between the tested and the control samples.
Concentrations at which no significant interference $(\leq 5.0\%)$ was observed.
| Endogenous interfering factor | Concentration |
| --- | --- |
| Bilirubin (Conjugated) | 66 mg/dL |
| Bilirubin (Unconjugated) | 66 mg/dL |
| Glucose | 2000 mg/dL |
| Rheumatoid Factor | 750 IU/mL |
| Protein: Total | 22 g/dL |
| Triglycerides | 600 mg/dL |
# ii. Exogenous Interference
Interference studies were performed to assess common or known exogenous substances that could interfere with the Dimension Hemoglobin A1c Assay. The interfering substances were evaluated in venous whole blood K2-EDTA samples. Four replicates for each interferent were tested on the Dimension Hemoglobin A1c Assay at each of 2 target HbA1c levels: $6.5 \pm 1\%$ and $8.0 \pm 1\%$ . The sponsor's definition of non-significant interference is $\leq 5.0\%$ mean relative deviation between the tested and the control samples. Results demonstrated that no significant interference was observed with the following substances up to the listed concentrations:
{8}
| Substance | Highest Concentration Tested with no Significant Interference |
| --- | --- |
| Acetaminophen | 20 mg/dL |
| Ampicillin | 100 mg/dL |
| Acetylsalicylic acid | 100 mg/dL |
| Ascorbic acid | 30 mg/dL |
| Calcium dobesilate | 20 mg/dL |
| Cefoxin sodium | 250 mg/dL |
| Cholesterol | 503 mg/dL |
| Cyclosporin | 1.66 mg/dL |
| Doxycycline hyclate | 5 mg/dL |
| Heparin | 5 U/mL |
| Ibuprofen | 50 mg/dL |
| Insulin | 593 μU/mL |
| Intralipid | 1000 mg/dL |
| Levodopa | 2 mg/dL |
| Metformin | 4 mg/dL |
| Methyldopa | 2 mg/dL |
| Metronidazole | 20 mg/dL |
| N-acetylcysteine | 166.3 mg/dL |
| Phenylbutazone | 40 mg/dL |
| Rifampicin | 6 mg/dL |
| Rosiglitazone | 0.8mg/dL |
| Salicylic acid | 60 mg/dL |
| Theophylline | 10 mg/dL |
iii. Cross Reactivity with Hemoglobin Derivatives
Testing to evaluate potential interference of hemoglobin derivatives on the Dimension Hemoglobin A1c Assay was performed according to CLSI EP07-A2, Interference Testing in Clinical Chemistry; Approved Guideline – Second Edition.
The effect of each hemoglobin derivative was evaluated using a paired difference analysis that compared HbA1c values between control samples (Anticoagulated K2-EDTA venous whole blood) and test samples (Anticoagulated K2-EDTA venous whole blood spiked with the derivative being tested). Four replicates were tested for each sample at three HbA1c levels: 5.0 ± 1.0%, 6.5 ± 1.0%, and 8.0 ± 1.0%. The results demonstrate no significant cross reactivity with Acetylated Hb up to 50 mg/dL of acetylsalicylic acid, Carbamylated Hb up to 10 mmol/L of Cyanate, or Labile Hb up to 1500 mg/dL of Glucose.
To verify that HbA1a, HbA1b, or HbA0 derivatives did not interfere with assay
{9}
performance, the sponsor evaluated the assay's HbA1c recovery of venous whole blood K2-EDTA patient samples with known HbA1c, HbA1a, HbA1b, and HbA0 concentrations. The highest concentrations tested with no interference were 2.2, 1.0, and $84.1\%$ for HbA1a, HbA1b, and HbA0, respectively. The data support the sponsor's claim that HbA0, HbA1a, and HbA1b do not interfere with assay results.
# iv. Hemoglobin Variants
Interference testing to determine the effect of hemoglobin variants on the Dimension Hemoglobin A1c Assay was performed in accordance with CLSI EP07-A2, Interference Testing in Clinical Chemistry; Approved Guideline – Second Edition.
Anticoagulated (K2-EDTA) human venous whole blood samples with known concentrations of hemoglobin variant were obtained from several commercial sources. The effect of each hemoglobin variant on assay performance was evaluated by analyzing these samples and comparing the $\% \mathrm{HbA1c}$ values obtained by using the candidate assay on the Dimension RxL system to comparator $\% \mathrm{HbA1c}$ values obtained on the Trinity Biotech Ultra 2 (HbC, HbD, HbE, HbS, HbA2), Tosoh HLC723G8 (HbA2, HbF), and Bio-Rad Variant II Turbo (HbC). Four replicates were tested for each sample. Results are shown below:
Hb Variant Distribution
| Hb Variant | Number of Samples | % Concentration of Variant in Sample | %HbA1c Concentration Range |
| --- | --- | --- | --- |
| HbC | 37 | 26.1 – 40.0% | 4.4 – 15.7 % |
| HbD | 20 | 24.8 – 38.4% | 5.0 – 13.0% |
| HbE | 22 | 19.7 – 30.4% | 4.7 – 11.0% |
| HbS | 22 | 27.2 – 36.3% | 5.3 – 14.0% |
| HbA2 | 23 | 4.3 – 6.2% | 5.1 – 8.4% |
| HbF | 20 | 4.3 – 29.3% | 4.3 – 10.1% |
Hb Variant Results
| Hb Variant | % Bias (Range of % Bias) for ~6% HbA1c | % Bias (Range of % Bias) for ~8% HbA1c |
| --- | --- | --- |
| HbC | -1.0% [-5.0% to 4.9%] | -0.9% [-4.6% to 4.4%] |
| HbD | -2.2% [-4.9% to 4.4%] | -2.5% [-4.4% to -1.3%] |
| HbE | -2.1% [-4.9% to 3.1%] | -2.5% [-4.3% to -1.0%] |
| HbS | -1.3% [-4.7% to 4.9%] | -2.0% [-4.9% to 3.5%] |
| HbA2 | 0.1% [-4.8% to 3.6%] | -2.0% [-3.0% to -1.1%] |
| HbF | HbF interferes with this assay | |
Significant interference was defined by the sponsor as $\geq \pm 5\%$ change in HbA1c value in the presence of the hemoglobin variant relative to control. The results show there was no significant interference for HbS ( $\leq 36.3\%$ ), HbC ( $\leq 40.0\%$ ), HbD ( $\leq 38.4\%$ ),
{10}
HbE (≤30.4%), and HbA2 (≤6.2%) at the concentrations tested in this study.
The labeling contains the following limitation:
This device has significant negative interference with fetal hemoglobin (HbF). HbA1c results are invalid for patients with abnormal amounts of HbF including those with known Hereditary Persistence of Fetal Hemoglobin.
f. Assau cut-off:
Not applicable
2. Comparison studies:
a. Method comparison with predicate device:
Method comparison testing was performed in accordance with CLSI EP09-A3, Measurement Procedure Comparison and Bias Estimation Using Patient Samples; Approved Guideline – Third Edition. 147 human venous K2-EDTA whole blood samples with values spanning the assay range (4.5 to 12.6%) were tested. The candidate device results were compared to those obtained from testing at a NGSP secondary reference laboratory on the Tosoh G8 method. The distribution of samples spanning the measuring interval were as follows:
Distribution of Samples
| Range of Results (%HbA1c) | Percentage of Samples | Number of Samples |
| --- | --- | --- |
| <5 | 4.8% | 7 |
| 5 – 6 | 12.2 | 18 |
| 6 – 6.5 | 20.4 | 30 |
| 6.5 – 7 | 21.8 | 32 |
| 7 – 8 | 14.3 | 21 |
| 8 – 9 | 8.2 | 12 |
| >9 | 18.4 | 27 |
| Total | 100% | 147 |
Deming and Passing-Bablok regression analysis was performed for the candidate system results versus the NGSP assigned comparator value. A summary is provided below:
N=147, sample range 4.8 – 13.2% HbA1c and 25.7 – 120.8 mmol/mol.
{11}
Method Comparison Regression
| Units | Regression | Slope | 95 % CI | y-intercept | 95 % CI | Pearson correlation coefficient (r) |
| --- | --- | --- | --- | --- | --- | --- |
| NGSP | Passing-Bablok | 0.983 | [0.966; 1.001] | 0.030 | [-0.095; 0.144] | 0.996 |
| | Deming | 0.978 | [0.957; 1.000] | 0.052 | [-0.094; 0.198] | |
| IFCC | Passing-Bablok | 0.973 | [0.955; 0.992] | 0.437 | [-0.474; 1.450] | 0.996 |
| | Deming | 0.970 | [0.948; 0.992] | 0.532 | [-0.603; 1.666] | |

Scatter plot with Passing-Bablok

{12}

Scatter plot with Deming

i. Bias Estimation Table
Bias Estimation Table, Passing-Bablok
| %HbA1c | Bias | % Bias |
| --- | --- | --- |
| 5.00 | -0.05 | -1.10 |
| 6.50 | -0.08 | -1.24 |
| 8.00 | -0.11 | -1.33 |
| 12.00 | -0.17 | -1.45 |
{13}
Bias Estimation Table, Deming
| %HbA1c | Bias | % Bias |
| --- | --- | --- |
| 5.00 | -0.06 | -1.16 |
| 6.50 | -0.09 | -1.40 |
| 8.00 | -0.12 | -1.55 |
| 12.00 | -0.21 | -1.77 |
ii. Total Error Calculation and Estimation Table
The bias estimation values determined in the method comparison study and precision estimates determined in the precision study were used to determine the total error at each of the levels listed in the tables below. Total error was calculated by the following equation:
$$
\% \mathrm{TE} = | \% \mathrm{Bias} | + (1.96 \times \% \mathrm{CV}) \times (1 + \% \mathrm{Bias} / 100)
$$
Total Error Summary, Passing-Bablok
| %HbA1c | % Bias | % CV | % TE |
| --- | --- | --- | --- |
| 5.0 | -1.10 | 2.4 | 5.8 |
| 6.5 | -1.24 | 1.7 | 4.5 |
| 8.0 | -1.33 | 1.6 | 4.4 |
| 12.0 | -1.45 | 1.8 | 4.9 |
Total Error Summary, Deming
| %HbA1c | % Bias | % CV | % TE |
| --- | --- | --- | --- |
| 5.0 | -1.16 | 2.4 | 5.8 |
| 6.5 | -1.40 | 1.7 | 4.7 |
| 8.0 | -1.55 | 1.6 | 4.6 |
| 12.0 | -1.77 | 1.8 | 5.2 |
b. Matrix comparison:
Matrix comparison testing was conducted to demonstrate equivalence between five different anticoagulants using 79 matched sets of whole human blood collected in all five anticoagulant tubes containing K2 EDTA, K3 EDTA, Na Fluoride/Na2 EDTA, Lithium Heparin, and Na Fluride/K-Oxalate. Regression analysis was used to analyze the measured values with K2-EDTA values as the comparator. Pearson correlation coefficient between K2-EDTA compared to the five other anticoagulants was 0.999 for each pair.
Deming Regression Analysis
| Anticoagulant | Comparator | N | Slope | y-intercept |
| --- | --- | --- | --- | --- |
| K3 EDTA | K2 EDTA | 79 | 0.997 | 0.011 |
| Na Fluoride/Na2 EDTA | K2 EDTA | 79 | 1.003 | -0.033 |
| K3 EDTA | K2 EDTA | 79 | 1.003 | -0.033 |
{14}
| Anticoagulant | Comparator | N | Slope | y-intercept |
| --- | --- | --- | --- | --- |
| Lithium Heparin | K2 EDTA | 79 | 1.008 | -0.042 |
| Na Fluoride/K-Oxalate | K2 EDTA | 79 | 1.007 | -0.018 |
Passing-Bablok Regression Analysis
| Anticoagulant | Comparator | N | Slope | y-intercept |
| --- | --- | --- | --- | --- |
| K3 EDTA | K2 EDTA | 79 | 0.994 | 0.030 |
| Na Fluoride/Na2 EDTA | K2 EDTA | 79 | 0.997 | 0.006 |
| Lithium Heparin | K2 EDTA | 79 | 1.006 | -0.038 |
| Na Fluoride/K-Oxalate | K2 EDTA | 79 | 1.010 | -0.037 |
These results support the use of the Dimension Hemoglobin A1c Assay with samples collected in K2-EDTA, K3-EDTA, Na Fluoride/Na2-EDTA, Na Fluoride/K-Oxalate or Lithium Heparin tubes.
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):
Not applicable
4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
The reference interval was taken from the American Diabetes Association, Diagnosis and Classification of Diabetes Mellitus. Diabetes Care 2017; 40 (Supplement 1): S11-S24.7
{15}
| Suggested Diagnosis | HbA1c (%) | HbA1c (mmol/mol) |
| --- | --- | --- |
| Diabetic | ≥6.5 | ≥48 |
| Prediabetic | 5.7-6.4 | 39-47 |
| Normal | <5.7 | <39 |
# N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Parts 801 and 809, as applicable, and the special controls for this device type under 21 CFR 862.1373.
# O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
Predicate graph will load when search results are available.
Embedding visualization will load when search results are available.
PDF viewer will load when search results are available.
Loading panels...
Select an item from Submissions
Click any panel, subpart, regulation, product code, or device to see details here.
Section Matches
Results will appear here.
Product Code Matches
Results will appear here.
Special Control Matches
Results will appear here.
Loading collections...
Loading
My Alerts
You will receive email notifications based on the filters and frequency you set for each alert.
Sort by:
Create Alert
Search Filters
Agent Token
Create a read-only bearer token for Claude, ChatGPT, or other agents that can call HTTP APIs.
Copy this now. It will not be shown again.
Connected apps
Apps you authorized through browser sign-in. Disconnecting revokes their access immediately.
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.