alpha-AMYLASE DIRECT, alpha-AMYLASE EPS, alpha-AMYLASE PANCREATIC, BILIRUBIN DIRECT, BILIRUBIN TOTAL
Applicant
Biosystems S.A.
Product Code
JFJ · Clinical Chemistry
Decision Date
May 2, 2019
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1070
Device Class
Class 2
Indications for Use
alpha-AMYLASE DIRECT: Reagent for the measurement of alpha-amylase concentration in human serum, plasma or urine. The obtained values are useful as an aid in the diagnosis of acute and chronic pancreatitis. This reagent institus of in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory. alpha-AMYLASE EPS: Reagent for the measurement of alpha-amylase concentration in human serum, plasma or urine. The obtained values are useful as an aid in the diagnosis of acute and chronic pancreatitis. This reagent is for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory. alpha-AMYLASE PANCREATIC: Reagent for the measurement of pancreatic c-amylase concentration in human serum, plasma or urine. The obtained values are useful as an aid in the diagnosis of acute and chronin pancreatitis. This reagentis for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory. BILIRUBIN DIRECT: Reagent for the measurement of direct bilirubin concentration in human serum or plasma. Measurements of the levels of bilirubin are used in the diagnosis and treatment of liver, hematological and metabolic disorders, including hepatitis and gall bladder block. This reagent is for use in the BioSystems Blockers. Only for in vitro use in the clinical laboratory. BILIRUBIN TOTAL: Reagent for the measurement of total bilirubin concentration in human serum or plasma. Measurements of the levels of bilirubin are used in the diagnosis and treatment of liver, herrytological and metabolic disorders, including hepatitis and gall bladder block. This reagent is for nuse in the BioSystems Blockers. Only for in vitro use in the clinical laboratory.
Device Story
Photometric assays for clinical chemistry analysis; reagents react with patient samples (serum, plasma, urine) to produce colored complexes or enzymatic rate changes; measured via spectrophotometry at 405 nm or 535 nm on BioSystems BA400 analyzers. Amylase assays use enzymatic hydrolysis (CNP-G3 or 4-nitrophenyl-maltoheptaoside-ethylidene); pancreatic amylase assay uses monoclonal antibodies to inhibit salivary isoenzyme. Bilirubin assays use 3,5-dichlorophenyl diazonium salt reaction. Used in clinical laboratories by trained personnel; results aid physicians in diagnosing pancreatitis, liver, and metabolic disorders.
Clinical Evidence
Bench testing only. Precision evaluated per CLSI EP05-A3 (n=80 per level). Linearity evaluated per CLSI EP06-A. Detection limits (LoB, LoD, LoQ) evaluated per CLSI EP17-A2. Analytical specificity/interference evaluated per CLSI EP07-A2. Method comparison against predicate devices performed on BA400 analyzer showing high correlation (R > 0.99). No clinical studies performed.
Technological Characteristics
Photometric enzymatic and colorimetric assays. Reagents include buffers (MES, HEPES), substrates (CNP-G3, 4-Nitrophenyl-maltoheptaoside-ethylidene), enzymes (alpha-glucosidase), and diazonium salts. Analyzed on BioSystems BA400 automated clinical chemistry analyzer. Traceability to internal Master Calibrators or NIST SRM 916. Storage at 2-8°C.
Indications for Use
Indicated for measurement of alpha-amylase, pancreatic alpha-amylase, total bilirubin, or direct bilirubin in human serum, plasma, or urine to aid in diagnosis/treatment of pancreatitis, liver, hemolytic, hematological, or metabolic disorders. For prescription, in vitro diagnostic use in clinical laboratories using BioSystems BA400 analyzers.
Regulatory Classification
Identification
An amylase test system is a device intended to measure the activity of the enzyme amylase in serum and urine. Amylase measurements are used primarily for the diagnosis and treatment of pancreatitis (inflammation of the pancreas).
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k182474
B. Purpose for Submission:
New devices
C. Measurand:
α-Amylase
Pancreatic α-Amylase
Bilirubin Total
Bilirubin Direct
D. Type of Test:
α-Amylase assays: Quantitative, enzymatic assays
Bilirubin (Total and Direct) assays: Colorimetric, photometric assays
E. Applicant:
BioSystems S.A.
F. Proprietary and Established Names:
alpha-AMYLASE DIRECT
alpha-AMYLASE EPS
alpha-AMYLASE PANCREATIC
BILIRUBIN TOTAL
BILIRUBIN DIRECT
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JFJ | II | 21 CFR § 862.1070 Amylase test system | Clinical Chemistry (75) |
| CIG | II | 21 CFR § 862.1110 Bilirubin (total or direct) test system | |
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H. Intended Use:
1. Intended use(s):
See Indications for use below
2. Indication(s) for use:
alpha-AMYLASE DIRECT: Reagent for the measurement of alpha-amylase concentration in human serum, plasma or urine. The obtained values are useful as an aid in the diagnosis and of acute and chronic pancreatitis. This reagent is for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory.
alpha-AMYLASE EPS: Reagent for the measurement of alpha-amylase concentration in human serum, plasma or urine. The obtained values are useful as an aid in the diagnosis of acute and chronic pancreatitis. This reagent is for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory.
alpha-AMYLASE PANCREATIC: Reagent for the measurement of pancreatic $\alpha$-amylase concentration in human serum, plasma or urine. The obtained values are useful as an aid in the diagnosis of acute and chronic pancreatitis. This reagent is for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory.
BILIRUBIN TOTAL: Reagent for the measurement of total bilirubin concentration in human serum or plasma. Measurements of the levels of bilirubin are used in the diagnosis and treatment of liver, hemolytic hematological and metabolic disorders, including hepatitis and gall bladder block. This reagent is for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory.
BILIRUBIN DIRECT: Reagent for the measurement of direct bilirubin concentration in human serum or plasma. Measurements of the levels of bilirubin are used in the diagnosis and treatment of liver, hemolytic hematological and metabolic disorders, including hepatitis and gall bladder block. This reagent is for use in the BioSystems BA analyzers. Only for in vitro use in the clinical laboratory.
3. Special conditions for use statement(s):
These devices are intended for prescription use and in vitro diagnostic use only.
4. Special instrument requirements:
BioSystems BA400
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I. Device Description:
α-AMYLASE DIRECT:
MES 50 mmol/L, calcium chloride 5 mmol/L, sodium chloride 300 mmol/L, sodium thiocyanate 450 mmol/L, CNP-G3 2.25 mmol/L, pH 6.1.
α-AMYLASE EPS:
A: 2 x 60 mL. HEPES 50 mmol/L, calcium chloride 0.075 mmol/L, sodium chloride 90 mmol/L, magnesium chloride 13 mmol/L, α-glucosidase > 4 U/mL, pH 7.1.
B: 2 x 15 mL. HEPES 50 mmol/L, 4-Nitrophenyl-maltoheptaoside-ethylidene 18 mmol/L, pH 7.1.
α-AMYLASE PANCREATIC:
A: 2 x 60 mL. HEPES 50 mmol/L, calcium chloride 0.075 mmol/L, sodium chloride 90 mmol/L, magnesium chloride 13 mmol/L, α-glucosidase > 4 U/mL, pH 7.1, monoclonal antibodies (mouse) 50 mg/L.
B: 2 x 15 mL. HEPES 50 mmol/L, 4-Nitrophenyl-maltoheptaoside-ethylidene 18 mmol/L, pH 7.1.
BILIRUBIN DIRECT:
A: Phosphoric acid 90 mmol/L, HEDTA 4.5 mmol/L, sodium chloride 50 mmol/L, pH 1.5.
B: 3,5-dichlorophenyl diazonium 1.5 mmol/L.
BILIRUBIN TOTAL:
A: Hydrochloric acid 170 mmol/L, cetrimide 40 mmol/L, pH 0.9.
B: 3,5-dichlorophenyl diazonium 1.5 mmol/L.
J. Substantial Equivalence Information:
1. Predicate device name(s):
AMYL-α-Amylase EPS, BILD2- Bilirubin Direct Gen.2, BILT2- Bilirubin Total Gen.2
2. Predicate 510(k) number(s):
k100853
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3. Comparison with predicate:
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Candidate Device alpha-AMYLASE DIRECT (k182474) | Predicate Device AMYL-α-Amylase EPS (k100853) |
| Intended Use | Reagent for the measurement of α-amylase concentration in human serum, plasma or urine. | Same |
| Measurand | α-amylase | Same |
| Sample Type | Serum, plasma or urine | Same |
| Assay Technology | Direct Substrate | IFCC |
| Assay Range | 8.20-1300 U/L | 3-1500 U/L |
| Reagent storage | Store at 2-8 °C until the expiry date marked in the label. | Same |
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Candidate Device alpha-AMYLASE EPS (k182474) | Predicate Device AMYL-α-Amylase EPS (k100853) |
| Intended Use | Reagent for the measurement of α-amylase concentration in human serum, plasma or urine. | Same |
| Measurand | α-amylase | Same |
| Sample Type | Serum, plasma or urine | Same |
| Assay Technology | IFCC | Same |
| Assay Range | 14.3-1300 U/L | 3-1500 U/L |
| Reagent storage | Store at 2-8 °C until the expiry date | Same |
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Candidate Device alpha-AMYLASE PANCREATIC (k182474) | Predicate Device AMYL-α-Amylase EPS Pancreatic (k100853) |
| Intended Use | Reagent for the measurement of pancreatic α-amylase concentration in human serum, plasma or urine. | Same |
| Measurand | Pancreatic α-amylase | Same |
| Sample Type | Serum, plasma or urine | Same |
| Assay Technology | Immuno-inhibition | Same |
| Assay Range | 7.49-1300 U/L | 3-1500 U/L |
| Reagent storage | Store at 2-8 °C until the expiry date | Same |
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| Similarities and Differences | | |
| --- | --- | --- |
| Item | Candidate Device BILIRUBIN DIRECT (k182474) | Predicate Device BILD2- Bilirubin Direct Gen.2 (k100853) |
| Intended Use | Reagent for the measurement of direct bilirubin concentration in human serum or plasma. | Same |
| Measurand | Bilirubin | Same |
| Sample Type | Serum, plasma | Same |
| Assay Technology | Dichlorophenyl diazonium | Same |
| Assay Range | 0.14-15 mg/dL | 0.09-17 mg/dL |
| Reagent storage | Store at 2-8 °C until the expiry date | Same |
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Candidate Device BILIRUBIN TOTAL (k182474) | Predicate Device BILT2- Bilirubin Total Gen.2 (k100853) |
| Intended Use | Reagent for the measurement of total bilirubin concentration in human serum or plasma. | Same |
| Measurand | Bilirubin | Same |
| Sample Type | Serum, plasma | Same |
| Assay Technology | Dichlorophenyl diazonium | Same |
| Assay Range | 0.26-38 mg/dL | 0.1-38 mg/dL |
| Reagent storage | Store at 2-8 °C until the expiry date | Same |
# K. Standard/Guidance Document Referenced (if applicable):
CLSI - EP05-A3, Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline-Third Edition.
CLSI - EP06-A, Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline.
CLSI - EP17-A2, Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures; Approved Guideline-Second Edition.
# L. Test Principle:
The alpha-AMYLASE DIRECT reagent is a photometric assay in which the $\alpha$ -amylase catalyzes the hydrolysis of 2-chloro-4-nitrophenyl-malto-trioside (CNPG3) to 2-chloro-4-nitrophenol (CNP). The catalytic concentration is determined from the rate of 2-chloro-4-nitrophenol formation, measured at $405~\mathrm{nm}$ .
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The alpha-AMYLASE EPS reagent is a photometric assay in which the $\alpha$ -amylase catalyzes the hydrolysis of 4-nitrophenyl-maltoheptaoside-ethylidene to smaller oligosaccharides which are hydrolyzed by $\alpha$ -glucosidase liberating 4-nitrophenol. The catalytic concentration is determined from the rate of 4-nitrophenol formation, measured at $405~\mathrm{nm}$ .
The alpha-AMYLASE PANCREATIC reagent is a photometric assay in which pancreatic $\alpha$ -amylase catalyzes the hydrolysis of 4-nitrophenyl-maltoheptaoside-ethylidene to smaller oligosaccharides which are hydrolyzed by $\alpha$ -glucosidase liberating 4-nitrophenol. The catalytic concentration is determined from the rate of 4-nitrophenol formation, measured at $405~\mathrm{nm}$ . Specific antibodies inhibit the salivary isoenzyme and thus allow the measurement of pancreatic $\alpha$ -amylase.
The BILIRUBIN DIRECT reagent is a photometric assay in which the direct bilirubin in the sample reacts with 3,5-dichlorophenyl diazonium salt forming a colored complex that can be measured by spectrophotometry at $535~\mathrm{nm}$ .
The BILIRUBIN TOTAL reagent is a photometric assay in which both the direct and indirect bilirubin in the sample reacts with 3,5-dichlorophenyl diazonium salt in the presence of cetrimide forming a colored complex that can be measured by spectrophotometry at $535~\mathrm{nm}$ .
# M. Performance Characteristics (if/when applicable):
# 1. Analytical performance:
# a. Precision/Reproducibility:
Precision studies were performed according to the CLSI EP5-A3 guideline. For alpha-AMYLASE DIRECT, alpha-AMYLASE EPS and alpha-AMYLASE PANCREATIC, three levels of commercial biochemistry control serum (human serum matrix) or Urine, Level I, II and III, and for BILIRUBIN DIRECT and BILIRUBIN TOTAL, four levels of commercial biochemistry control serum (human serum matrix) Level I, II, III and IV were tested on two runs per day, two measurements per run, for twenty days with total of 80 observations. The results of the precision studies are summarized in the tables below:
alpha-AMYLASE DIRECT:
| Matrix | Samples | n | Mean (U/L) | Repeatability | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | SD | CV% | SD | CV% |
| Serum | QC 1 | 80 | 53.3 | 0.8 | 1.6 | 1.6 | 2.2 |
| | QC 2 | 80 | 201 | 1.0 | 0.5 | 0.5 | 0.9 |
| | QC 3 | 80 | 1061 | 6.7 | 0.6 | 0.6 | 1.5 |
| Urine | QC 1 | 80 | 92 | 2.3 | 2.5 | 2.3 | 2.5 |
| | QC 2 | 80 | 407 | 10.1 | 2.5 | 10.2 | 2.5 |
| | QC 3 | 80 | 2078 | 12.6 | 0.6 | 35.4 | 1.7 |
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alpha-AMYLASE EPS:
| Matrix | Samples | n | Mean (U/L) | Repeatability | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | SD | CV% | SD | CV% |
| Serum | QC 1 | 80 | 54.3 | 0.9 | 1.7 | 1.9 | 3.5 |
| | QC 2 | 80 | 207 | 4.5 | 2.2 | 4.9 | 2.4 |
| | QC 3 | 80 | 1090 | 4.3 | 0.4 | 16.9 | 1.6 |
| Urine | QC 1 | 80 | 103 | 2.3 | 2.2 | 2.8 | 2.7 |
| | QC 2 | 80 | 384 | 4.7 | 1.2 | 7.8 | 2.0 |
| | QC 3 | 80 | 2161 | 26.1 | 1.2 | 36.6 | 1.7 |
alpha-AMYLASE PANCREATIC:
| Matrix | Samples | n | Mean (U/L) | Repeatability | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | SD | CV% | SD | CV% |
| Serum | QC 1 | 80 | 52.7 | 0.6 | 1.0 | 1.2 | 2.2 |
| | QC 2 | 80 | 156 | 2.1 | 1.4 | 2.2 | 1.4 |
| | QC 3 | 80 | 1058 | 6.1 | 0.6 | 11.7 | 1.1 |
| Urine | QC 1 | 80 | 66.2 | 1.4 | 2.1 | 1.6 | 2.5 |
| | QC 2 | 80 | 366 | 5.4 | 1.5 | 6.2 | 1.7 |
| | QC 3 | 80 | 2259 | 43.8 | 1.9 | 45.2 | 2.0 |
BILIRUBIN DIRECT:
| Matrix | Samples | n | Mean (mg/dL) | Repeatability | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | SD | CV% | SD | CV% |
| Serum | QC 1 | 80 | 0.35 | 0.03 | 7.7 | 0.03 | 8.0 |
| | QC 2 | 80 | 0.61 | 0.03 | 4.1 | 0.03 | 5.0 |
| | QC 3 | 80 | 1.68 | 0.03 | 2.0 | 0.05 | 2.9 |
| | QC 4 | 80 | 15.1 | 0.09 | 0.6 | 0.19 | 1.3 |
BILIRUBIN TOTAL:
| Matrix | Samples | n | Mean (mg/dL) | Repeatability | | Total | |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | | | SD | CV% | SD | CV% |
| Serum | QC 1 | 80 | 1.03 | 0.09 | 8.5 | 0.09 | 8.7 |
| | QC 2 | 80 | 2.08 | 0.07 | 3.3 | 0.07 | 3.3 |
| | QC 3 | 80 | 4.90 | 0.05 | 0.9 | 0.09 | 1.8 |
| | QC 4 | 80 | 30.9 | 0.13 | 0.4 | 0.33 | 1.1 |
b. Linearity/assay reportable range:
Linearity studies were conducted according to the CLSI EP06-A guideline. Eleven levels of dilutions were prepared by mixing different proportions of samples with high and low concentration of each analyte.
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Samples were analyzed on one BA-400 instrument in duplicate. The results of the regression analysis are shown below:
| Analyte | Matrix | Slope | Intercept | r2 | Range Conc. tested | Claimed range |
| --- | --- | --- | --- | --- | --- | --- |
| alpha-AMYLASE DIRECT (U/L) | Serum | 1.011 | -3.50 | 1.000 | 0.0 - 1400 | 8.18 - 1300 |
| | Urine | 1.006 | 1.58 | 1.000 | 0.0 - 2700 | 19.2 - 2600 |
| alpha-AMYLASE EPS (U/L) | Serum | 0.981 | 3.48 | 1.000 | 0.0 - 1400 | 14.3 - 1300 |
| | Urine | 0.982 | 9.72 | 1.000 | 0.0 - 2700 | 19.1 - 2600 |
| alpha-AMYLASE PANCREATIC (U/L) | Serum | 0.982 | 2.13 | 1.000 | 0.0 - 1300 | 8.18 - 1300 |
| | Urine | 0.990 | 4.46 | 1.000 | 0.0 - 2700 | 19.6 - 2600 |
| BILIRUBIN DIRECT (mg/dL) | Serum | 0.999 | 0.003 | 1.000 | 0.08 - 22.80 | 0.14 - 15.00 |
| BILIRUBIN TOTAL (mg/dL) | Serum | 0.972 | 0.327 | 0.999 | 0.00 - 38.00 | 0.32 - 38.00 |
The linearity studies support the sponsor's claimed measuring ranges as described in the table above.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability:
alpha-AMYLASE DIRECT reagent: Values assigned and traceable to an internal BioSystems Master Calibrator (BMC).
alpha-AMYLASE-EPS reagent: Values assigned and traceable to C-SER/IFCC; International Federation of Clinical Chemistry and Laboratory Medicine.
alpha-AMYLASE-PANCREATIC reagent: Values assigned and traceable to C-SER/IFCC; International Federation of Clinical Chemistry and Laboratory Medicine.
BILIRUBIN DIRECT Reagent: Values assigned and traceable to an internal BioSystems Master Calibrator (BMC).
BILIRUBIN TOTAL Reagent: Values assigned and traceable to SRM 916 (NIST) Standard Reference Materials.
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d. Detection limit:
Detection capabilities studies for each analyte were evaluated based upon the CLSI EP17-A2 guideline.
Limit of blank (LoB) studies were performed by testing 5 blank samples in replicates of 4 over 3 days, on two lots for a total of 120 observations. LoB was defined as the highest result that can reasonably be expected from a blank sample for a given error probability with $\alpha = 0.05$ .
Limit of detection (LoD) studies were performed by testing 5 pool of human serum or urine with analyte concentrations close to expected detection limit for each analyte. Samples were tested in replicates of 4 over 3 days, on two lots for a total of 120 observations. The LoD was estimated based on a probability of error of $5\%$ ( $\beta = 0.05$ ).
Limit of quantitation (LoQ) studies were performed using 4 to 5 pools of human serum or urine with analytes concentrations closed to the expected LoQ of the corresponding assay. Samples were tested in replicates of 4 over 3 days, on two lots for a total of 120 observations. The sponsor defines LoQ as the lowest concentration of a measurand with an imprecision $\leq 10\%$ .
The results of the detection limit studies are presented in the table below:
| Assays | Matrix | LoB | LoD | LoQ | Claimed Range |
| --- | --- | --- | --- | --- | --- |
| alpha-AMYLASE DIRECT (U/L) | Serum | 0.50 | 1.64 | 8.18 | 8.18 - 1300 |
| | Urine | 1.36 | 5.14 | 19.2 | 19.2 - 2600 |
| alpha-AMYLASE EPS (U/L) | Serum | 1.53 | 4.63 | 14.3 | 14.3 - 1300 |
| | Urine | 4.48 | 8.90 | 19.1 | 19.1 - 2600 |
| alpha-AMYLASE PANCREATIC (U/L) | Serum | 2.26 | 4.95 | 8.14 | 8.18 - 1300 |
| | Urine | 3.06 | 6.42 | 19.6 | 19.6 - 2600 |
| BILIRUBIN DIRECT (mg/dL) | Serum | 0.07 | 0.10 | 0.14 | 0.14 - 15.00 |
| BILIRUBIN TOTAL (mg/dL) | Serum | 0.14 | 0.21 | 0.32 | 0.32 - 38.00 |
e. Analytical specificity:
Interference studies were performed in accordance with the CLSI EP07-A2 guideline. For alpha-AMYLASE DIRECT, alpha-AMYLASE EPS, alpha-AMYLASE PANCREATIC, specimens consist on human serum and urine representing low and high concentrations of the analyte, with and without added increasing concentration of the substance tested for interference. Interference studies for BILIRUBIN TOTAL and BILIRUBIN DIRECT were conducted using serum samples. Samples were spiked
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with increasing concentrations of the potential interferents and analyzed in duplicate. Interference was calculated as: (b-a)/a, where a and b are the concentration of measurand found without (a) and with (b) interferent. The sponsor states that interference is considered to be non-significant if the difference between the samples with and without interferent are within $10\%$ .
The results of the interference studies are summarized in the table below.
| Analyte | Interferent | Highest concentration tested that did not show significant interference |
| --- | --- | --- |
| alpha-AMYLASE DIRECT | Bilirubin | 30 mg/dL |
| | Hemoglobin | 200 mg/dL |
| | Triglycerides | 1756 mg/dL |
| alpha-AMYLASE EPS | Bilirubin | 30 mg/dL |
| | Hemoglobin | 604mg/dL |
| | Triglycerides | 659 mg/dL |
| alpha-AMYLASE PANCREATIC | Bilirubin | 30 mg/dL |
| | Hemoglobin | 500 mg/dL |
| | Triglycerides | 1625 mg/dL |
| BILIRUBIN DIRECT | Hemoglobin | 25 mg/dL |
| | Triglycerides | 975 mg/dL |
| BILIRUBIN TOTAL | Hemoglobin | 500 mg/dL |
| | Triglycerides | 512 mg/dL |
Exogenous interferences:
| Analyte | Matrix | Interferent | Highest concentration tested that did not show significant interference |
| --- | --- | --- | --- |
| alpha-AMYLASE DIRECT | Serum | Acetaminophen | 20 mg/dL |
| | | Ascorbic Acid | 30 mg/dL |
| | | Acetylsalicylic Acid | 70 mg/dL |
| | Urine | Ascorbic Acid | 30 mg/dL |
| alpha-AMYLASE EPS | Serum | Acetaminophen | 20 mg/dL |
| | | Ascorbic Acid | 30 mg/dL |
| | | Acetylsalicylic Acid | 70 mg/dL |
| | Urine | Ascorbic Acid | 30 mg/dL |
| alpha-AMYLASE PANCREATIC | Serum | Acetaminophen | 20 mg/dL |
| | | Ascorbic Acid | 30 mg/dL |
| | | Acetylsalicylic Acid | 70 mg/dL |
| | Urine | Ascorbic Acid | 30 mg/dL |
| BILIRUBIN DIRECT | Serum | Acetaminophen | 20 mg/dL |
| | | Ascorbic Acid | 30 mg/dL |
| BILIRUBIN TOTAL | Serum | Acetaminophen | 20 mg/dL |
| | | Ascorbic Acid | 30 mg/dL |
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f. Assay cut-off:
Not applicable
## 2. Comparison studies:
a. Method comparison with predicate device:
Method comparison studies were conducted by testing native human serum, plasma and urine samples (as applicable) on the $\alpha$-AMYLASE DIRECT, $\alpha$-AMYLASE EPS, $\alpha$-AMYLASE PANCREATIC, BILIRUBIN DIRECT and BILIRUBIN TOTAL candidate assays on the BA400 analyzer and the predicate devices.
The results of the regression analysis are summarized below:
| Analyte | Specimen Type | N | Slope | Intercept | R | Test range* | Claimed Measuring Range |
| --- | --- | --- | --- | --- | --- | --- | --- |
| alpha-AMYLASE DIRECT (U/L) | Serum | 83 | 0.994 | 4.74 | 0.999 | 17.5-1285 | 8.18-1300 |
| | Li Heparin Plasma | 110 | 0.951 | 2.75 | 0.995 | 19.3-1295 | |
| | Urine | 136 | 1.029 | 21.65 | 0.998 | 79-2572 | 19.2-2600 |
| alpha-AMYLASE EPS (U/L) | Serum | 136 | 1.075 | 0.04 | 0.997 | 13.9-1287 | 14.3-1300 |
| | Li Heparin Plasma | 111 | 1.109 | -5.317 | 0.999 | 19.3-1217 | |
| | Urine | 136 | 0.932 | 2.77 | 0.993 | 86.7-2363 | 19.1-2600 |
| alpha-AMYLASE PANCREATIC (U/L) | Serum | 110 | 1.000 | -1.20 | 0.999 | 12.0-1289 | 8.18-1300 |
| | Li Heparin Plasma | 115 | 1.011 | -3.176 | 0.998 | 12.0-1283 | |
| | Urine | 81 | 1.063 | -1.30 | 1.000 | 12.0-2410 | 19.6-2600 |
| BILIRUBIN DIRECT (mg/dL) | Serum | 125 | 1.005 | 0.02 | 0.997 | 0.33-15.0 | 0.14-15 |
| | Li Heparin Plasma | 142 | 1.029 | 0.01 | 0.997 | 0.12-14.0 | |
| BILIRUBIN TOTAL (mg/dL) | Serum | 108 | 1.015 | 0.09 | 0.997 | 0.55-35.1 | 0.32-38 |
| | K₃ EDTA plasma | 106 | 1.02 | 0.02 | 0.998 | 0.28-28.8 | |
*Concentrations tested based on the results reported by the predicate devices.
Method comparison data supports that serum and lithium heparin plasma are acceptable samples types for the BILIRUBIN DIRECT assay. Studies also support that serum and $\mathrm{K}_3$ EDTA plasma samples are acceptable sample types for the
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BILIRUBIN TOTAL assay. The alpha-AMYLASE DIRECT, alpha-AMYLASE EPS, alpha-AMYLASE PANCREATIC assays can be used with serum, lithium heparin plasma and urine specimens.
b. Matrix comparison:
Not applicable. Different sample types were assessed in other analytical studies described above.
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 following reference ranges are cited from the literature:
alpha-AMYLASE DIRECT¹:
Serum and plasma: 22 - 80 U/L
Urine: <321 U/L
alpha-AMYLASE EPS²,³:
Serum and plasma: 28 - 100 U/L
Urine: 16 - 491 U/L
alpha-AMYLASE PANCREATIC²,³:
Serum and Plasma: 13-53 U/L
Urine: 7 - 356 U/L
BILIRUBIN DIRECT¹,⁴:
Adults: 0 - 0.3 mg/dL
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BILIRUBIN TOTAL¹:
Adults: 0 - 2.0 mg/dL
1- Tietz Textbook of Clinical Chemistry and Molecular Diagnostics, 5th ed. Burtis CA, Ashwood ER, Bruns DE. WB Saunders Co, 2012.
2- IFCC primary reference procedures for the measurement of catalytic activity concentrations of enzymes at 37°C. Part 8. Reference procedure for the measurement of catalytic concentration of α-amylase. Clin Chem Lab Med 2006; 44: 1146-1155.
3- Junge W, Werner W, Wilke B et al. Development and evaluation of assays for the determination of total and pancreatic amylase at 37°C according to the principle recommended by the IFCC. Clin Biochem 2001;34:607-615.
4- McPherson RA, Pincus MR. Henry's Clinical Diagnosis and Management by Laboratory Methods. 20st ed. Saunders Elsevier, 2001:1427.
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Parts 809.10.
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.