The CAPI 3 HEMOGLOBIN(E) kit is designed for the separation of the normal hemoglobins (A, A2 and F) in human venous blood samples, and for the detection of the major hemoglobin variants (S, C, E and D), by capillary electrophoresis in alkaline buffer (pH 9.4) with the SEBIA CAPILLARYS 3 TERA instrument. The CAPILLARYS 3 TERA instrument is an automated analyzer which performs a complete hemoglobin profile for the quantitative analysis of the normal hemoglobin fractions A, A2 and F and for the detection of major hemoglobin variants S, C, E and D. The assay is performed on the hemolysate of whole blood samples collected in tubes containing K2EDTA or K3EDTA as anticoagulant. The CAPI 3 HEMOGLOBIN(E) is intended to be used in conjunction with other laboratory and clinical findings. For In Vitro Diagnostic Use.
Device Story
Device uses capillary electrophoresis in alkaline buffer (pH 9.4) to separate hemoglobin fractions in human venous whole blood. Input: whole blood samples in K2EDTA/K3EDTA tubes. Instrument: CAPILLARYS 3 TERA automated analyzer. Process: automated sampling, electrophoretic separation in silica capillaries, and absorbance spectrophotometry at 415 nm. Output: quantitative percentages of Hb A, A2, F, S, C, D, and E fractions and visual electrophoregram scans. Used in clinical laboratories by trained personnel. Results assist clinicians in identifying hemoglobinopathies and variants. Benefits: provides automated, high-throughput, accurate hemoglobin profiling compared to manual methods.
Clinical Evidence
Method comparison study of 304 samples (180 normal, 124 variant) against a commercially available capillary electrophoresis reference method. Results showed high correlation (r=0.987-1.000) across all fractions (Hb A, A2, F, S, C, D, E). No false positives observed. Precision evaluated per CLSI EP5-A3; total CVs for fractions ranged from 0.0% to 6.5%. Linearity confirmed across clinically relevant ranges.
Indicated for the separation of normal hemoglobins (A, A2, F) and detection of major hemoglobin variants (S, C, E, D) in human venous whole blood samples (K2EDTA or K3EDTA) using the CAPILLARYS 3 TERA instrument. Intended for use in conjunction with other laboratory and clinical findings.
Regulatory Classification
Identification
An abnormal hemoglobin assay is a device consisting of the reagents, apparatus, instrumentation, and controls necessary to isolate and identify abnormal genetically determined hemoglobin types.
Special Controls
*Classification.* Class II (special controls). A control intended for use with an abnormal hemoglobin assay is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 864.9.
Predicate Devices
CAPILLARYS HEMOGLOBIN(E) using the CAPILLARYS 2 FLEX-PIERCING instrument (K112550)
Submission Summary (Full Text)
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
A. 510(k) Number:
K180762
B. Purpose for Submission:
New Device
C. Measurand:
Hemoglobin A, F, A2, S, C, E, D
D. Type of Test:
Capillary electrophoresis
E. Applicant:
Sebia, Inc.
F. Proprietary and Established Names:
CAPI 3 HEMOGLOBIN(E)
G. Regulatory Information:
1. Regulation section:
21 CFR 864.7415, Abnormal hemoglobin assay
2. Classification:
Class II
3. Product code:
GKA, Abnormal hemoglobin quantitation
4. Panel:
Hematology(81)
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H. Intended Use:
1. Intended use(s):
The CAPI 3 HEMOGLOBIN(E) kit is designed for the separation of the normal hemoglobins (A, A2 and F) in human venous blood samples, and for the detection of the major hemoglobin variants (S, C, E and D), by capillary electrophoresis in alkaline buffer (pH 9.4) with the SEBIA CAPILLARYS 3 TERA instrument.
The CAPILLARYS 3 TERA instrument is an automated analyzer which performs a complete hemoglobin profile for the quantitative analysis of the normal hemoglobin fractions A, A2 and F and for the detection of major hemoglobin variants S, C, E and D. The assay is performed on the hemolysate of whole blood samples collected in tubes containing K2EDTA or K3EDTA as anticoagulant. The CAPI 3 HEMOGLOBIN(E) is intended to be used in conjunction with other laboratory and clinical findings.
For In Vitro Diagnostic Use.
2. Indication(s) for use:
Same As Intended Use
3. Special conditions for use statement(s):
For prescription use only
4. Special instrument requirements:
CAPILLARYS 3 TERA
I. Device Description:
The CAPI 3 HEMOGLOBIN (E) kit consists of five components: (1) HEMOGLOBIN(E) buffer which is an alkaline buffer (pH 9.4) supplied in 700 mL vials, (2) Hemolyzing Solution, supplied in 700 mL vials, and (3) Filters, four per kit. The CAPI 3 HEMOGLOBIN (E) kit is used in conjunction with the SEBIA CAPILLARYS 3 TERA instrument.
J. Substantial Equivalence Information:
1. Predicate device name(s):
CAPILLARYS HEMOGLOBIN(E) using the CAPILLARYS 2 FLEX-PIERCING instrument
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2. Predicate 510(k) number(s):
K112550
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | New Device CAPI 3 HEMOGLOBIN(E) | Predicate CAPILLARYS HEMOGLOBIN(E) (K112550) |
| Intended Use | The CAPI 3 HEMOGLOBIN(E) kit is designed for the separation of the normal hemoglobins (A, A2 and F) in human venous blood samples, and for the detection of the major hemoglobin variants (S, C, E and D), by capillary electrophoresis in alkaline buffer (pH 9.4) with the SEBIA CAPILLARYS 3 TERA instrument. The CAPILLARYS 3 TERA instrument is an automated analyzer which performs a complete hemoglobin profile for the quantitative analysis of the normal hemoglobin fractions A, A2 and F and for the detection of major hemoglobin variants S, C, E and D. The assay is performed on the hemolysate of whole blood samples collected in tubes containing K2EDTA or K3EDTA as anticoagulant. The CAPI 3 HEMOGLOBIN(E) is intended to be used in conjunction with other laboratory and clinical findings. For In Vitro Diagnostic Use. | The CAPILLARYS HEMOGLOBIN(E) kit is designed for the separation of the normal hemoglobins (A, A2 and F) in human blood samples, and for the detection of the major hemoglobin variants (S, C, E and D), by capillary electrophoresis in alkaline buffer (pH 9.4) with the SEBIA CAPILLARYS 2 FLEX-PIERCING instrument. The CAPILLARYS HEMOGLOBIN(E) kit is designed for laboratory use. The CAPILLARYS 2 FLEX-PIERCING instrument is an automated analyzer which performs a complete hemoglobin profile for the quantitative analysis of the normal hemoglobin fractions A, A2 and F and for the detection of major hemoglobin variants S, C, E and D. The assay is performed on the hemolysate of whole blood samples collected in tubes containing K2EDTA or K3EDTA as anticoagulant. For In Vitro Diagnostic Use. |
| Specimen Type | Human whole blood | Same |
| Technology | Capillary electrophoresis | Same |
| Detection Absorbance Wavelength | 415 nm | Same |
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| Similarities | | |
| --- | --- | --- |
| Item | New Device CAPI 3 HEMOGLOBIN(E) | Predicate CAPILLARYS HEMOGLOBIN(E) (K112550) |
| Software | Phoresis | Same |
| Controls for Migration | Sebia Normal A2 Control | Same |
| Use of other Controls | SEBIA Normal Hb A2 Control, Hb AFSC Control and Hb AF Control | Same |
| Reagent Location | On Board | Same |
| Differences | | |
| --- | --- | --- |
| Item | New Device CAPI 3 HEMOGLOBIN(E) | Predicate CAPILLARYS HEMOGLOBIN(E) (K112550) |
| Number of Separation Units (Capillaries) | 12 parallel capillaries | 8 parallel capillaries |
| Bottle for Reagents | RFID | None |
| Reagent cups | Supplied in separate packaging | Supplied in the kit |
| Wash Solution | Supplied in separate packaging | Supplied in the kit |
# K. Standard/Guidance Document Referenced (if applicable):
- CLSI EP05-A3: Evaluation of Precision of Quantitative Measurement Procedures, 3rd Edition
- CLSI EP06-A: Evaluation of Linearity of Quantitative Measurement Procedures: A Statistical Approach, Approved Guidelines
- CLSI EP07-A2: Interference Testing in Clinical Chemistry; Approved Guideline. 2nd Edition
- CLSI EP17-A2: CLSI EP05-A2: Evaluation of Precision Performance of Quantitative Measurement Methods, 2nd Edition
- CLSI EP28-A3c: Defining, Establishing, and Verifying Reference Intervals in Clinical Laboratory 3rd Edition
- FDA Guidance for General Principles of Software Validation-Guidance for Industry and FDA Staff
# L. Test Principle:
The SEBIA CAPI 3 HEMOGLOBIN(E) test in conjunction with the CAPILLARYS 3 TERA instrument utilizes the principle of capillary electrophoresis in free solution. The CAPILLARYS 3 instrument performs fully automated electrophoresis sequencing from the primary whole blood sample by directly sampling from capped collection tubes. Charged molecules are separated by their electrophoretic mobility in an alkaline buffer with a specific
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pH. Separation also occurs according to the electrolyte pH and electroosmotic flow. The hemoglobins, separated in silica capillaries, are directly detected at an absorbance wavelength of $415~\mathrm{nm}$ . The hemoglobin (Hb) fractions are separated by absorbance spectrophotometry. The hemoglobins are reported in $\%$ units along with an electrophoresis scan. The resulting electrophoregrams are evaluated visually for pattern abnormalities. Direct detection provides accurate relative quantification of individual hemoglobin fractions: A, F, A2, S, C, D, and E. By using alkaline pH buffer, normal and abnormal (or variant) hemoglobins are detected.
# M. Performance Characteristics (if/when applicable):
# 1. Analytical performance:
Note: All results below met the manufacturer's pre-specified acceptance criteria.
# a. Precision/Reproducibility:
Precision of the CAPI 3 Hemoglobin assay was evaluated according to CLSI guideline EP05-A3.
# Repeatability
Five control materials with different levels of hemoglobin variants were run using the CAPI 3 HEMOGLOBIN(E) procedure performed with one CAPILLARYS 3 TERA instrument and one lot of the CAPI 3 HEMOGLOBIN(E) kit. Each sample was analyzed in duplicate on 12 capillaries per run, two runs per day over 20 days yielding a total of 960 results per sample. The results are expressed as coefficient of variation (%CV).
%Hb A
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 1 | 97.3 | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |
| 2 | 93.5 | 0.1% | 0.1% | 0.0% | 0.1% | 0.1% |
| 3 | 44.2 | 0.3% | 0.4% | 0.3% | 0.5% | 0.8% |
| 4 | 54.2 | 0.4% | 0.0% | 0.1% | 0.3% | 0.5% |
| 5 | 67.15 | 0.5% | 0.1% | 0.2% | 0.3% | 0.6% |
%Hb A2
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 1 | 2.7 | 1.3% | 0.9% | 0.0% | 0.7% | 1.8% |
| 2 | 6.5 | 0.8% | 0.9% | 0.0% | 0.7% | 1.4% |
| 3 | 2.6 | 3.1% | 4.1% | 2.4% | 1.3% | 6.0% |
| 4 | 3.0 | 2.8% | 1.1% | 0.8% | 0.8% | 3.2% |
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%Hb F
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 3 | 26.8 | 0.4% | 0.1% | 0.5% | 0.2% | 0.7% |
%Hb S
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 3 | 17.5 | 0.4% | 0.5% | 0.1% | 0.7% | 1.0% |
%Hb C
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 3 | 8.9 | 0.9% | 0.8% | 0.4% | 1.1% | 1.7% |
%Hb D
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 4 | 40.6 | 0.5% | 0.2% | 0.1% | 0.3% | 0.6% |
%Hb E
| Sample | Mean (%) | Within Capillary | Between Capillary | Between Run | Between Day | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 5 | 22.6 | 1.0% | 0.1% | 0.4% | 0.3% | 1.1% |
Seven native EDTA venous whole blood samples with percentages of Hb A, Hb A2, Hb F, Hb S, Hb C, Hb D and Hb E fractions were analyzed on three CAPILLARYS 3 TERA instruments using one lot of CAPI 3 HEMOGLOBIN(E) kit for 7 days (with the exception of Hb E which has been analyzed for 6x days). Within each run, each sample was analyzed in duplicate on the same capillary. The results are expressed as coefficient of variation (%CV).
%Hb A
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 1 | 97.5 | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |
| 2 | 95.2 | 0.1% | 0.0% | 0.0% | 0.0% | 0.1% |
| 3 | 56.7 | 0.3% | 0.0% | 0.2% | 0.2% | 0.4% |
| 4 | 67.6 | 0.6% | 0.2% | 1.1% | 0.0% | 1.2% |
| 5 | 56.5 | 0.3% | 0.3% | 1.3% | 0.0% | 1.3% |
| 6 | 62.0 | 0.2% | 0.1% | 0.9% | 0.0% | 1.0% |
| 7 | 62.0 | 0.5% | 0.4% | 0.0% | 0.0% | 0.7% |
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%Hb A2
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 1 | 2.5 | 1.1% | 0.6% | 0.0% | 0.3% | 1.3% |
| 2 | 4.8 | 1.4% | 0.0% | 0.4% | 0.5% | 1.5% |
| 3 | 3.2 | 1.7% | 0.0% | 0.0% | 0.5% | 1.8% |
| 4 | 2.7 | 5.2% | 0.4% | 3.8% | 0.0% | 6.5% |
| 5 | 2.8 | 1.4% | 0.8% | 1.7% | 0.0% | 2.3% |
| 6 | 1.9 | 1.7% | 1.6% | 2.6% | 0.0% | 3.5% |
| 7 | 3.2 | 3.0% | 1.6% | 3.3% | 0.0% | 4.8% |
%Hb F
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 6 | 34.9 | 0.4% | 0.2% | 2.4% | 0.0% | 2.5% |
%Hb S
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 3 | 40.1 | 0.4% | 0.1% | 0.2% | 0.4% | 0.6% |
%Hb C
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 7 | 34.3 | 1.1% | 0.3% | 0.8% | 0.0% | 1.4% |
%Hb D
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 5 | 38.6 | 0.4% | 0.3% | 1.3% | 0.0% | 1.4% |
%Hb E
| Sample | Mean (%) | Within Run | Between Run | Between Day | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- |
| 4 | 23.5 | 0.8% | 0.0% | 1.4% | 0.0% | 1.6% |
Reproducibility studies were performed using a total of nine EDTA venous whole blood samples that included three frozen and six contrived samples with different percentages of the Hb A, Hb A2, Hb F, Hb S, Hb C, Hb D and Hb E fractions. The samples were analyzed in duplicate on two capillaries per run, two runs per day using three lots on each of three instruments over 6 days yielding a total of 432 per sample results. The results are expressed as coefficient of variation (%CV).
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%Hb A
| Sample | Mean (% | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | 97.7 | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |
| 2 | 94.8 | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1% |
| 3 | 98.3 | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% | 0.0% |
| 4 | 62.9 | 0.2% | 0.3% | 0.0% | 0.2% | 0.3% | 0.0% | 0.5% |
| 5 | 63.0 | 0.4% | 0.1% | 0.3% | 0.4% | 0.2% | 0.0% | 0.6% |
| 6 | 74.7 | 0.2% | 0.3% | 0.0% | 0.1% | 0.1% | 0.2% | 0.4% |
| 7 | 57.2 | 0.2% | 0.2% | 0.0% | 0.2% | 0.2% | 0.0% | 0.4% |
| 8 | 94.2 | 0.1% | 0.1% | 0.0% | 0.0% | 0.0% | 0.0% | 0.1% |
| 9 | 28.4 | 0.5% | 0.2% | 0.1% | 0.4% | 0.0% | 0.7% | 1.0% |
%Hb A2
| Sample | Mean % | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 1 | 2.3 | 1.4% | 0.6% | 0.4% | 0.5% | 0.4% | 0.5% | 1.7% |
| 2 | 5.2 | 0.8% | 0.5% | 0.0% | 0.7% | 0.6% | 0.0% | 1.3% |
| 3 | 1.7 | 1.5% | 1.0% | 0.0% | 0.6% | 0.7% | 0.0% | 2.1% |
| 4 | 3.2 | 1.2% | 1.1% | 0.0% | 0.4% | 0.6% | 0.3% | 1.8% |
| 5 | 3.2 | 2.2% | 1.5% | 0.0% | 1.8% | 0.5% | 1.5% | 3.6% |
| 6 | 3.5 | 1.5% | 1.6% | 0.0% | 1.2% | 0.7% | 1.7% | 3.1% |
| 7 | 2.6 | 1.3% | 1.2% | 0.0% | 0.8% | 0.7% | 0.0% | 2.0% |
| 8 | 2.2 | 1.3% | 0.9% | 0.0% | 0.5% | 0.3% | 0.2% | 1.7% |
| 9 | 2.6 | 1.3% | 0.8% | 0.4% | 0.6% | 0.6% | 0.6% | 1.9% |
%Hb F
| Sample | Mean % | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 8 | 3.6 | 1.3% | 1.4% | 0.0% | 1.1% | 0.3% | 1.2% | 2.5% |
| 9 | 69.0 | 0.2% | 0.1% | 0.0% | 0.2% | 0.0% | 0.3% | 0.4% |
%Hb S
| Sample | Mean % | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 4 | 33.9 | 0.4% | 0.4% | 0.0% | 0.4% | 0.4% | 0.0% | 0.9% |
%Hb C
| Sample | Mean % | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 5 | 33.5 | 0.7% | 0.3% | 0.5% | 0.7% | 0.3% | 0.3% | 1.1% |
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$\% \mathrm{HbD}$
| Sample | Mean % | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 7 | 40.2 | 0.2% | 0.2% | 0.0% | 0.2% | 0.2% | 0.0% | 0.5% |
$\% \mathrm{HbE}$
| Sample | Mean % | Within capillary | Between capillary | Between Run | Between Day | Between Lot | Between instrument | Total |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| 6 | 21.8 | 0.4% | 0.8% | 0.0% | 0.4% | 0.3% | 0.3% | 1.0% |
# b. Linearity/assay reportable range:
A linearity study was performed per CLSI EP06-A: Evaluation of Quantitative Measuring Procedures; A Statistical Approach. Mixtures of two different blood samples were mixed at different proportions and tested in triplicate and analyzed using the CAPI 3 HEMOGLOBIN(E) procedure on the CAPILLARYS 3 instrument. The tests were determined to be linear within the reportable ranges studied for each of the following hemoglobins fractions: Hb A (1.0–97.3%), HbS (1.1–89.7%), HbA2 (0.2–9.1%), HbF (0.5–83.1%), HbC (0.3–82%), Hb D (1.1–43.5%), Hb E (0.3–86.9%).
# c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Reagent Stability: The CAPI 3 HEMOGLOBIN(E) reagents used with the CAPILLARYS 3 TERA instrument are the same reagents that were presented in the predicate device, CAPILLARYS HEMOGLOBIN(E) kit using the CAPILLARYS 2 FLEX PIERCING instrument (K112550). The reagent bottles are the same with the exception the CAPI 3 HEMOGLOBIN(E) kit and the CAPI 3 WASH SOLUTION contain an RFID tag on the bottle(s).
# Sample Stability:
Storage at refrigerated temperatures: Eleven whole blood samples with different hemoglobin fractions (Hb A, Hb A2, Hb F, Hb S, Hb C and Hb E) were analyzed upon receipt and after one week of storage at $2 - 8^{\circ}\mathrm{C}$ with the CAPI 3 HEMOGLOBIN(E) on the CAPILLARYS 3 TERA instrument. The results obtained met the acceptance criteria. Sample stability for the CAPI 3 HEMOGLOBIN(E) kit on the CAPILLARYS 3 TERA instrument was determined to be 7 days at $2 - 8^{\circ}\mathrm{C}$ .
Storage at frozen temperatures: Thirteen whole blood samples with different hemoglobin fractions (Hb A, Hb A2, Hb F, Hb S, Hb Cand Hb D) were analyzed upon receipt and after 3 months of storage at $-70$ or $-80^{\circ}\mathrm{C}$ , with the CAPI 3 HEMOGLOBIN(E) assay performed with the CAPILLARYS 3 TERA instrument. The results obtained met the acceptance criteria. Sample stability for the CAPI 3 HEMOGLOBIN(E) kit on the CAPILLARYS 3 TERA instrument was determined to be 3 months at $-70$ or $-80^{\circ}\mathrm{C}$ .
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# d. Detection limit:
The Limit of Blank (LoB), Limit of Detection (LoD), and Limit of Quantitation was performed per CLSI EP17-A2 guideline, Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures; Approved Guideline - Second Edition.
LoB: Two lots of the CAPI 3 HEMOGLOBIN(E) kit were used to detect the percentages of the fraction in the designated hemoglobin position. Five blood samples (B1-B5) were analyzed. For each lot of CAPI 3 HEMOGLOBIN(E) kit, each of the five samples was analyzed on 3 days with four replicates per day using one CAPILLARYS 3 TERA instrument in order to obtain 60 data points per lot.
LoD: Two lots of the CAPI 3 HEMOGLOBIN(E) kit were used to detect the percentages of the fraction in the designated hemoglobin position. Five blood samples were analyzed. For each lot of CAPI 3 HEMOGLOBIN(E) kit, each of the five samples was analyzed on 3 days with four replicates per day using one CAPILLARYS 3 TERA instrument in order to obtain 60 data points per lot. The LoD was determined using the sample from which the hemoglobin fraction is always detected.
LoQ: The LoQ was determined using precision profile approach. The LoQ is determined on four fractions representing the four intervals of migration of the Hb fractions of interest: the C/A2/E mobility interval using Hb A2 as the target analyte representing HbA2, Hb C and Hb E fractions; the D/S mobility interval using Hb S as the target analyte representing Hb S and Hb D fractions; Hb F and Hb A. Four different blood samples were tested with two lots of the CAPI 3 HEMOGLOBIN(E) kit performed on three CAPILLARYS 3 TERA instruments. Testing was performed for 5 days, two runs per day. Within each run, each sample was analyzed three times in order to obtain 90 data points per sample and 360 data points per lot.
| Hemoglobin | LoB | LoD | LoQ |
| --- | --- | --- | --- |
| A | 0.1% | 1.0% | 1.0% |
| A2 | 0.1% | 0.2% | 0.2% |
| F | 0.2% | 0.4% | 0.5% |
| S | 0.1% | 0.9% | 1.1% |
| C | 0.1% | 0.3% | 0.3% |
| D | 0.1% | 0.7% | 1.1% |
| E | 0.1% | 0.3% | 0.3% |
# e. Analytical specificity:
Interference studies were conducted following CLSI EP07-A2, Interference Testing in Clinical Chemistry, using six samples (normal Hb A2 level, increased Hb A2 level Hb S, HbC, HbD, HbE). Each sample was analyzed three times.
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| Interferent | Maximum Concentration |
| --- | --- |
| Bilirubin | 20.6 mg/dL or 352μmol/L |
| Triglycerides | 2.2 g/dL or 25.1mmol/L |
| Excess EDTA | 7.2mg/mL |
f. Assay cut-off:
Not Applicable
2. Comparison studies:
a. Method comparison with predicate device: The method comparison was conducted at two sites which was found to be acceptable given that the CAPILLARYS 3 TERA instrument has been evaluated in a previous clearance (K161928). At site 1, a total of 153 samples including three controls were analyzed. At site 2, a total of 151 samples including one control were analyzed. Regression analysis was not performed for the Hb D fraction in site 2 due to insufficient data.
Site 1
| Fraction | N | % Hb range | Correlation coefficient (r) | Slope (95% CI) | Intercept (95% CI) |
| --- | --- | --- | --- | --- | --- |
| Hb A | 150 | 16.9–98.7 | 1.000 | 1.010 (1.008, 1.012) | -0.993 (-1.174, -0.812) |
| Hb A2 | 148 | 0.5–9.2 | 0.998 | 0.986 (0.976, 0.996) | 0.005 (-0.026, 0.037) |
| Hb F | 22 | 0.8–83.1 | 1.000 | 1.009 (1.005, 1.012) | -0.008 (-0.145, 0.129) |
| Hb S | 13 | 1.8–89.7 | 1.000 | 1.010 (1.004, 1.015) | -0.025 (-0.240, 0.191) |
| Hb C | 13 | 2.0–89.5 | 1.000 | 1.008 (1.000, 1.015) | 0.099 (-0.167, 0.365) |
| Hb D | 9 | 3.3–43.7 | 1.000 | 1.015 (1.009, 1.021) | -0.068 -0.245 to 0.109 |
| Hb E | 13 | 5.0–86.9 | 1.000 | 1.001 (0.996, 1.007) | 0.183 0.014 to 0.353 |
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Site 2 (U.S.)
| Fraction | N | %Hb range | Correlation coefficient (r) | Slope (95% CI) | Intercept (95% CI) |
| --- | --- | --- | --- | --- | --- |
| Hb A | 148 | 15.7–98.3 | 1.000 | 1.020 (1.017, 1.023) | -1.928 (-2.176, -1.681) |
| Hb A2 | 151 | 0.9–6.1 | 0.987 | 1.017 (0.990, 1.043) | -0.005 (-0.084, 0.074) |
| Hb F | 30 | 0.5–34.3 | 0.999 | 1.009 (0.992, 1.026) | -0.127 (-0.298, 0.044) |
| Hb S | 33 | 25.8–78.3 | 0.999 | 1.006 (0.993, 1.018) | 0.475 (-0.057, 0.006) |
| Hb C | 11 | 25.2–37.3 | 0.997 | 1.069 (1.011, 1.127) | -1.431 (-3.333, 0.472) |
| Hb E | 4 | 22.1–91.9 | 1.000 | 1.002 (0.987, 1.017) | 0.625 (-0.117, 1.367) |
b. Matrix comparison:
Not applicable; the CAPI 3 HEMOGLOBIN(E) kit using the CAPILLARYS 3 TERA instrument is intended to be used with venous whole blood only.
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:
Twenty normal samples from the U.S. healthy population were analyzed with the CAPI 3 HEMOGLOBIN(E) on the CAPILLARYS 3 TERA instrument for the reference range verification study according to the CLSI EP28-A3c guideline, Defining, Establishing,
{12}
and Verifying Reference Intervals in the Clinical Laboratory; Approved Guideline – Third Edition.
The results are as follows:
Hemoglobin A (HbA): 96.7 – 97.8%
Hemoglobin F (HbF): < 0.5%
Hemoglobin A2 (HbA2): 2.2 – 3.2%
Major hemoglobin variants (S, C, E and D) should not be present in normal hemoglobin samples.
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Parts 801 and 809, as applicable.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
13
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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.