The BD FACSLyric™ flow cytometer with the integrated BD FACSDuet™ Sample Preparation System is intended for use as an in vitro diagnostic device for immunophenotyping using up to six fluorescence detection channels and two light scatter channels using a blue (488-nm) and a red (640-nm) laser. It includes an automated sample preparation system used to prepare human peripheral whole blood samples for acquisition and analysis and is intended for use with in vitro diagnostic (IVD) assays and software that are indicated for use with the instrument.
Device Story
The BD FACSLyric Flow Cytometer is an in vitro diagnostic instrument for immunophenotyping. The subject device adds the BD FACSDuet Sample Preparation System, an automated accessory that prepares human peripheral whole blood samples (pipetting, mixing, incubation) and transfers them to the cytometer via a modified FACS Universal Loader. The system uses blue (488-nm) and red (640-nm) lasers to excite samples, with light scatter and fluorescence detected by PMTs. Data is processed by FACSuite Clinical software to perform acquisition and analysis. The device is operated by laboratory personnel in a clinical environment. The output consists of immunophenotyping results used by clinicians to aid in patient diagnosis and monitoring. Benefits include standardized, automated sample preparation, reduced manual labor, and consistent analytical performance compared to manual methods.
Clinical Evidence
Clinical performance was evaluated via a method comparison study across 3 sites with 399 enrolled specimens (29 non-evaluable), comparing the FACSLyric with integrated FACSDuet to the predicate with manual preparation. Inter-laboratory reproducibility was also assessed. Analytical performance included precision, repeatability, linearity, LoB/LoD/LoQ, reagent stability, carryover, and pipetting accuracy/precision. All studies met pre-defined acceptance criteria.
Technological Characteristics
Flow cytometer with 2-laser (blue 488nm, red 640nm) or 3-laser configurations. Detection via PMTs and photodiodes. Integrated FACSDuet system for automated sample prep. Software: FACSuite Clinical v1.4. Connectivity: Barcode reader for specimen ID. Sterilization: N/A (reagent-based). Standards: IEC 61010-1, IEC 61010-2-101, ISO 14971, CLSI EP series.
Indications for Use
Indicated for immunophenotyping of human peripheral whole blood samples using flow cytometry. Used for quantitative and semi-quantitative immunoassays. No specific age or gender restrictions stated; intended for clinical laboratory use.
Regulatory Classification
Identification
An automated differential cell counter is a device used to identify one or more of the formed elements of the blood. The device may also have the capability to flag, count, or classify immature or abnormal hematopoietic cells of the blood, bone marrow, or other body fluids. These devices may combine an electronic particle counting method, optical method, or a flow cytometric method utilizing monoclonal CD (cluster designation) markers. The device includes accessory CD markers.
Special Controls
*Classification.* Class II (special controls). The special control for this device is the FDA document entitled “Class II Special Controls Guidance Document: Premarket Notifications for Automated Differential Cell Counters for Immature or Abnormal Blood Cells; Final Guidance for Industry and FDA.”
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FDA
U.S. FOOD & DRUG
ADMINISTRATION
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY
INSTRUMENT ONLY
## I Background Information:
A 510(k) Number
K201814
B Applicant
Becton, Dickinson and Company
C Proprietary and Established Names
BD FACSLyric Flow Cytometer
BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System
D Regulatory Information
| Product Code(s) | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| OYE | Class II | 21 CFR 864.5220 - Automated Differential Cell Counter | HE - Hematology |
## II Submission/Device Overview:
A Purpose for Submission:
Modification of previously cleared instrument
B Type of Test:
Quantitative and Semi-Quantitative Flow Cytometric Immunoassays
## III Intended Use/Indications for Use:
A Intended Use(s):
BD FACSLyric Flow Cytometer
The BD FACSLyric Flow Cytometer is intended for use as an in vitro diagnostic device for immunophenotyping using up to six fluorescence detection channels and two light scatter
Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993-0002
www.fda.gov
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channels using a blue (488-nm) and a red (640-nm) laser. It is intended for use with in vitro diagnostic (IVD) assays and software that are indicated for use with the instrument.
BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System
The BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System is intended for use as an in vitro diagnostic device for immunophenotyping using up to six fluorescence detection channels and two light scatter channels using a blue (488-nm) and a red (640-nm) laser. It includes an automated sample preparation system used to prepare human peripheral whole blood samples for acquisition and analysis and is intended for use with in vitro diagnostic (IVD) assays and software that are indicated for use with the instrument.
## B Indication(s) for Use:
Same as above.
## C Special Conditions for Use Statement(s):
Rx - For Prescription Use Only
## IV Device/System Characteristics:
### A Device Description:
Refer to K170974 for detailed description and functioning of the BD FACSLyric flow cytometer.
The modified BD FACSLyric Flow Cytometer consists of the following components.
- FACSLyric Flow Cytometer (3-1, 4-2, 4-2-2, 4-3-3 and 4-3-5 optical configurations)
- FACSuite Clinical Software (version 1.4)
- Modified FACS Universal Loader: updated shaker and modification to the door lock and sensor connections
- Modified CMS firmware
BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation system consists of all the above components as FACSLyric Flow Cytometer and additionally contain:
- BD FACSDuet Sample Preparation system physically and data integrated with the BD FACSLyric Flow Cytometer
- FACSDuet fluidics that contain saline, deionized (DI) water and 10% bleach solution.
- Modified FACS Universal Loader: updated shaker, modification to the door lock and sensor connections, addition of stabilization bracket
### B Instrument Description Information:
1. Instrument Name:
BD FACSLyric Flow Cytometer
BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation system
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2. Specimen Identification:
BD FACSLyric Flow Cytometer: Manual Entry
BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation system: Barcode Reader
3. Specimen Sampling and Handling:
BD FACSLyric Flow Cytometer: Specimens will be manually prepared by the operator/user.
BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation system: Specimens will be automatically prepared by FACSDuet sample preparation system.
4. Calibration:
Calibration is performed with the IVD assay intended for use with the instruments.
5. Quality Control:
Quality control is performed with the IVD assay intended for use with the instruments.
V Substantial Equivalence Information:
A Predicate Device Name(s):
BD FACSLyric Flow Cytometer (3-1, 4-2, 4-2-2 and 4-3-3 optical configurations), BD FACSuite Clinical Software, BD Multitest 6-Color Assays, BD Multitest 4-Color Assays, BD Multitest 6-Color TBNK
B Predicate 510(k) Number(s):
K170974
C Comparison with Predicate(s):
| Device & Predicate Device(s): | K170974 (Predicate) | K201814 | |
| --- | --- | --- | --- |
| Device Trade Name | BD FACSLyric Flow Cytometer (3-1, 4-2, 4-2-2 and 4-3-3 Configurations) | BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System (3-1, 4-2, 4-2-2, 4-3-3, 4-3-5 Configurations) | BD FACSLyric Flow Cytometer (3-1, 4-2, 4-2-2, 4-3-3, 4-3-5 Configurations) |
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| General Device Characteristic Similarities | | | |
| --- | --- | --- | --- |
| Device Classification and Product Code | - Automated differential cell counter
- Regulatory Class: II
- Regulation Number: 21 CFR 864.5220
- Product Code: OYE | Same | Same |
| Assay Methodology | Flow Cytometry | Same | Same |
| Detection/Assay Principle | Immunofluorescence | Same | Same |
| Specimen Type | Peripheral whole blood | Same | Same |
| Sample Volume | 50 µL | Same | Same |
| Maximum Parameter Detectors | IVD detection channels
Six Fluorescence channels plus forward scatter and side scatter | Same | Same |
| IVD Lasers/Excitation | **Blue Laser:**
Wavelength: 488 nm
Optical power: 20 mW
**Red Laser:**
Wavelength: 640 nm
Optical power: 40 mW | Same | Same |
| Electronics | Up to 35000 events/sec | Same | Same |
| Forward Scatter Detection | Photodiode with built in 488/10 bandpass filter | Same | Same |
| Fluorescence and Side Scatter Detection | - Reflective optics with single transmission bandpass filter in front of each PMT
- High performance PMT modules for all fluorescence and side scatter channels
- Light collected by objective lens is delivered by fiber optics especially designed detector arrays | Same | Same |
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| | • The cuvette flow cell is gel-coupled by refractive index-matching optical gel to the fluorescence objective lens (1.2 NA) for optimal collection efficiency | | |
| --- | --- | --- | --- |
| Results Reporting | Software-assisted report generation | Same | Same |
| **General Device Characteristic Differences** | | | |
| Intended Use / Indications For Use | The BD FACSLyric flow cytometer is intended for use as an in vitro diagnostic device for immunophenotyping using up to six fluorescence detection channels and two light scatter channels using a blue (488-nm) and a red (640-nm) laser. It is intended for use with in vitro diagnostic (IVD) assays and software that are indicated for use with the instrument. | The BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System is intended for use as an in vitro diagnostic device for immunophenotyping using up to six fluorescence detection channels and two light scatter channels using a blue (488-nm) and a red (640-nm) laser. It includes an automated sample preparation system used to prepare human peripheral whole blood samples for acquisition and analysis and is intended for use with in vitro diagnostic (IVD) assays and software that are indicated for use with the instrument. | Same as predicate |
| Optical Configurations | • 2-laser (blue, red), 4-color (3-1)
• 2-laser (blue, red), 6-color (4-2)
• 3-laser (blue, red, violet), 8-color (4-2-2) | • 2-laser (blue, red), 4-color (3-1)
• 2-laser (blue, red), 6-color (4-2)
• 3-laser (blue, red, violet), 8-color (4-2-2) | • 2-laser (blue, red), 4-color (3-1)
• 2-laser (blue, red), 6-color (4-2)
• 3-laser (blue, red, violet), 8-color (4-2-2) |
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| | • 3-laser (blue, red, violet), 10-color (4-3-3) | • 3-laser (blue, red, violet), 10-color (4-3-3)
• 3 laser (blue, red, violet), 12-color (4-3-5) configuration | • 3-laser (blue, red, violet), 10-color (4-3-3)
• 3 laser (blue, red, violet), 12-color (4-3-5) configuration |
| --- | --- | --- | --- |
| Fluidics | FACSLyric Flow Cytometer fluidics -
• Uses FACSFlow as the sheath fluid
• Uses 10% bleach solution for system cleaning | FACSDuet fluidics-
• Uses DI water for washing the reagent and specimen probes
• Uses 10% bleach solution for cleaning the specimen probe during the FACSDuet End of Day Clean task.
• Uses saline for washing the specimen probe | Same as predicate |
| Software | FACSuite Clinical software (version 1.0) | • Modified FACSuite Clinical software (version 1.4)
• FACSDuet software | Modified FACSuite Clinical software (version 1.4) |
| Firmware | CMS firmware | • Modified CMS Firmware
• FACSDuet firmware | Modified CMS Firmware |
| Loader | FACS Universal Loader | Modified FACS Universal Loader with following changes:
• Updated shaker to have a more robust mechanism for the gripper fingers which hold on to the sample carrier;
• Modification to the door lock and sensor connections to enable automated transfer of sample carriers from FACSDuet to FACSLyric;
• Replacement of the loader outside cover (skins) and window, including relocation of loader label and | Modified FACS Universal Loader with the following changes:
• Updated shaker to have a more robust mechanism for the gripper fingers which hold on to the sample carrier;
• Modification to the door lock and sensor connections to enable automated transfer of sample carriers from FACSDuet to FACSLyric |
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| | | status light (for physical integration only);
• Addition of a stabilization bracket connecting FACS Universal Loader to FACSDuet instrument (for physical integration only.) | |
| --- | --- | --- | --- |
| Sample Introduction | • Manual loading onto the tube port of the flow cytometer
• Automated loading through a multi-tube FACS Universal Loader | FACSDuet instrument will automatically transfer the 30 or 40-tube sample carrier to the modified FACS Universal Loader | Same as predicate |
| Sample Preparation | Manual | Automated with FACSDuet Sample Preparation System | Manual |
| Pipetting | Reverse pipetting for peripheral blood | Automated Sample Preparation | Same as predicate |
| Specimen Tube Mixing | Mixing manually | Automated Sample Preparation | Same as predicate |
| Incubation Time | 15 minutes | 15–30 minutes | 15 minutes |
| Dimensions (W x D x H) | 63.3 x 57.9 x 57.9 cm
(24.93 x 22.8 x 22.8 in) | 282.9 x 77.1 x 85.0 cm
(111.4 x 30.4 x 33.5 in) | Same as predicate |
| Quality Control & Instrument Setup | • Daily QC performed using CS&T beads
• QC is also preformed every 6 months using CS&T beads. It includes all of the measurements performed in daily QC along with additional more detailed measurements and an automatic laser alignment.
• Daily instrument setup using CS&T beads | • FACSLyric flow cytometer: Same
• FACSDuet instrument:
- Initialization
- Verification of dispense accuracy and precision
- Process controls: Multi-Check Control and Multi-Check CD4 Low Control | Same as predicate |
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VI Standards/Guidance Documents Referenced:
The following FDA Guidelines were followed in the assessment of this device’s modifications and in the preparation of this submission:
| Organization | Standard and Version | Title |
| --- | --- | --- |
| CLSI | EP05-A3 | Evaluation of Precision Performance of Quantitative Measurement Methods |
| CLSI | EP6-A | Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach |
| CLSI | EP17-A2 | Protocols for Determination of Limits of Detection and Limits of Quantification |
| CLSI | EP25-A | Evaluation of Stability of In Vitro Diagnostic Reagents |
| CLSI | H26-A2 | Validation, Verification, and Quality Assurance of Automated Hematology Analyzers |
| CLSI | EP09c | Measurement Procedure Comparison and Bias Estimation Using Patient Samples |
| IEC | 61010-1 | Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use – Part 1: General Requirements |
| IEC | 61010-2-101 | Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use – Part 2-101: Particular Requirements for In Vitro Diagnostic (IVD) Medical Equipment. |
| EN-ISO | 14971:2012 | Application of Risk Management to Medical Devices |
| ISO | 14971:2007 | Application of Risk Management to Medical Devices |
VII Performance Characteristics (if/when applicable):
A Analytical Performance:
The performance of the modified instruments was evaluated by using BD Multitest 6-colcor TBNK with Trucount Tubes (K060375) as a representative reagent. As the BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System represents the more complex configuration and uses the same flow cytometer with some minor differences in sample loader comparing to the modified BD FACSLyric Flow Cytometer without FACSDuet, the analytical performance was validated only on the integrated system.
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All results below met the manufacturer's pre-specified acceptance criteria.
1. Precision/Reproducibility:
The precision and reproducibility studies were performed based on CLSI guidance document EP05-A3, Evaluation of Precision of Quantitative Measurement Procedures; Approved Guideline-Third Edition.
The precision study was performed by testing Streck CD Chex plus Normal (CDN) and Streck CD Chex CD4 Low (CDL) as stable samples. Daily measurements were obtained in two separate runs (separated by at least two hours from the start of the first run's acquisition to the start of second run's acquisition) over 21 testing days. System precision performance for the enumeration of the T-, B- and NK- lymphocyte subset percentages and absolute counts was evaluated across three FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation systems, executed by three operators using three reagent lots for each assay through the study. The precision based on the results of absolute counts and percentage lymphocytes are summarized in the following tables:
Precision of Absolute Count Test Results for Each Subset
| Control Level | Subset | Mean (cells/μL) | Within-Run % CV | Total % CV |
| --- | --- | --- | --- | --- |
| CDL | CD3+ | 746.17 | 3.85 | 5.30 |
| | CD3+CD4+ | 174.87 | 6.39 | 6.57 |
| | CD3+CD8+ | 514.67 | 5.17 | 5.33 |
| | CD19+ | 213.05 | 5.52 | 6.39 |
| | CD16+CD56+ | 194.76 | 5.82 | 6.98 |
| CDN | CD3+ | 1762.40 | 5.74 | 7.98 |
| | CD3+CD4+ | 1109.82 | 6.97 | 7.52 |
| | CD3+CD8+ | 630.75 | 7.77 | 8.43 |
| | CD19+ | 268.73 | 7.34 | 9.51 |
| | CD16+CD56+ | 223.94 | 7.98 | 10.28 |
Precision of Percentage of Lymphocyte (%) Test Results for Each Subset
| Control Level | Subset | Mean (% Lymphocyte) | Within-Run % CV | Total % CV |
| --- | --- | --- | --- | --- |
| CDL | % CD3+ | 64.11 | 1.49 | 1.49 |
| | % CD3+CD4+ | 15.02 | 4.66 | 4.72 |
| | % CD3+CD8+ | 44.16 | 2.42 | 2.49 |
| | % CD19+ | 18.31 | 4.04 | 4.04 |
| | %CD16+CD56+ | 16.73 | 4.60 | 4.60 |
| CDN | % CD3+ | 77.76 | 1.09 | 1.09 |
| | % CD3+CD4+ | 48.97 | 1.93 | 1.96 |
| | % CD3+CD8+ | 27.77 | 2.95 | 3.42 |
| | % CD19+ | 11.86 | 5.31 | 5.39 |
| | %CD16+CD56+ | 9.88 | 5.97 | 5.97 |
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The whole blood repeatability was evaluated using 27 samples comprised of patient and normal whole blood specimens with at least 50% of specimens from HIV patients. System repeatability was determined by enumeration of CD3+, CD3+CD4+, CD3+CD8+, CD19+ and CD16+56+ lymphocyte subset percentages and absolute counts across three FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation systems with three reagent lots. Each specimen was tested with two replicates/reagent lot/instrument. The precision based on the results of absolute counts and percentage lymphocytes are summarized in the following tables:
Precision (Whole Blood) of Absolute Count Test Results for Each Subset
| Subset | Mean (cells/μL) | Within-Run % CV | Total % CV |
| --- | --- | --- | --- |
| CD3+ | 1610.26 | 4.17 | 4.32 |
| CD3+CD4+ | 174.87 | 4.92 | 5.03 |
| CD3+CD8+ | 657.09 | 5.17 | 5.35 |
| CD19+ | 213.05 | 7.47 | 7.47 |
| CD16+CD56+ | 927.05 | 10.13 | 10.41 |
Percentage (Whole Blood) of Lymphocyte (%) Test Results for Each Subset
| Subset | Mean (% Lymphocyte) | Within-Run % CV | Total % CV |
| --- | --- | --- | --- |
| CD3+ | 76.74 | 0.97 | 0.97 |
| CD3+CD4+ | 31.34 | 0.93 | 0.93 |
| CD3+CD8+ | 43.94 | 1.03 | 1.04 |
| CD19+ | 12.07 | 0.72 | 0.72 |
| CD16+CD56+ | 10.71 | 0.85 | 0.86 |
Inter-laboratory reproducibility was performed by testing two levels of Streck CD-check plus (CDN) and CD-chem plus CD4 low (CDL) samples at three different clinical sites for a total of 15 days (two runs/day) using three reagent lots. The test was done with a minimum of one operator per instrument per site. The reproducibility based on the results of absolute counts are summarized in the following table:
| Control Level | Subset | Mean (cells/μL) | Within-Run % CV | Between-Run % CV | Between-Day % CV | Between-Site % CV | Total % CV |
| --- | --- | --- | --- | --- | --- | --- | --- |
| CDL | CD3+ | 944.80 | 5.98 | 0.00 | 1.65 | 4.01 | 7.59 |
| | CD3+CD4+ | 162.68 | 8.74 | 0.00 | 1.30 | 4.30 | 9.97 |
| | CD3+CD8+ | 705.39 | 6.29 | 0.00 | 1.66 | 3.76 | 7.69 |
| | CD19+ | 352.33 | 6.55 | 0.00 | 1.58 | 3.85 | 7.93 |
| | CD16+CD56+ | 331.07 | 7.38 | 0.00 | 1.22 | 4.17 | 8.72 |
| CDN | CD3+ | 1959.56 | 5.33 | 0.00 | 1.06 | 3.52 | 6.64 |
| | CD3+CD4+ | 1281.09 | 5.52 | 0.00 | 1.02 | 3.56 | 6.81 |
| | CD3+CD8+ | 654.89 | 6.38 | 0.00 | 1.56 | 2.25 | 7.00 |
| | CD19+ | 314.41 | 7.35 | 0.00 | 0.78 | 3.49 | 8.27 |
| | CD16+CD56+ | 286.50 | 8.10 | 1.91 | 0.36 | 3.86 | 9.32 |
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2. Linearity:
The linearity of the assay run on the BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System was performed based on CLSI EP6-A, Evaluation of the Linearity of Quantitative Measurement Procedures: A Statistical Approach; Approved Guideline.
Triplicate measurements of 11 lymphocyte subsets covering the anticipated linear ranges were tested using three reagent lots on three different BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems. In addition, seven supplemental concentration levels for CD4 were used to evaluate linearity over the medical decision point at 50 and 250 cells/μL for CD4 absolute counts. The results of the absolute counts in supporting the linear range for each subset are summarized in the following table:
| Subset | Linear Range (cells/μL) |
| --- | --- |
| CD3+ | 5 – 5282 |
| CD3+CD4+ | 3 – 3188 |
| CD3+CD8+ | 2 – 3268 |
| CD19+ | 0 – 2295 |
| CD16+CD56+ | 1 – 1287 |
3. Analytical Specificity/Interference:
Not applicable
4. Accuracy (Instrument):
The study was performed in accordance with CLSI EP09c, Measurement Procedure Comparison and Bias Estimation Using Patient Samples by testing 370 samples at three different clinical sites (minimum 40 samples/site) to demonstrate the equivalence of the BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System to the FACSLyric Flow Cytometer using manual sample preparation (predicate). CD4+ bins were designed to cover the analytical measuring range (AMR). Each sample was stained with BD Multicolor 6-color TBNK reagents and run on one new instrument system and one predicate instrument at each site. Deming regression analysis was performed with all data combined for each subset, and the results of the absolute counts and percentage lymphocytes are summarized in the following tables:
Regression Analysis Using Absolute Count Test Results for Each Subset
| Subset | Range (cells/μL) | Slope (95% CI) | Intercept |
| --- | --- | --- | --- |
| Abs CD3+ | 89–10753 | 1.00 (0.99, 1.01) | -3.96 |
| Abs CD3+CD4+ | 3–7201 | 1.00 (0.99, 1.00) | -1.19 |
| Abs CD3+CD8+ | 50–5083 | 1.00 (0.99, 1.02) | -5.19 |
| Abs CD19+ | 8–1919 | 0.99 (0.97, 1.00) | -0.45 |
| Abs CD16+CD56+ | 9–2171 | 1.01 (0.98, 1.03) | 2.18 |
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Regression Analysis Using Percentage of Lymphocyte (%) Test Results for Each Subset
| Subset | Range (% of Lymphocyte) | Slope (95% CI) | Intercept |
| --- | --- | --- | --- |
| % CD3+ | 45.26–99.14 | 1.00 (0.99, 1.02) | -0.31 |
| % CD3+CD4+ | 0.27–85.83 | 0.99 (0.98, 1.00) | 0.15 |
| % CD3+CD8+ | 1.54–86.88 | 1.01 (0.99, 1.01) | 0.17 |
| % CD19+ | 0.13–33.03 | 0.99 (0.98, 1.01) | -0.04 |
| % CD16+CD56+ | 0.5–47.54 | 1.01 (0.99, 1.03) | 0.11 |
5. Carry-Over:
The carryover studies were performed based on CLSI H26-A2, Validation, Verification, and Quality Assurance of Automated Hematology Analyzers; Approved Standard- Second Edition.
Specimen Carryover
Specimen carry over studies were performed to determine whether results were affected by contamination from neighboring samples. System carryover was evaluated by estimating the percent carryover of abnormally high leukocyte count samples to abnormally low leukocyte count samples. Fifty-four (54) samples were acquired for high and 54 samples were acquired for the low leukocyte concentrations across three FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems from a total of six donors. Specimen to specimen carryover results across all three instruments and donors was < 0.2% (i.e., 2000 ppm v/v).
Bleach to specimen carryover was evaluated on three different BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems by performing the end of the day clean maintenance task using bleach and the pipetting deionized water in each specimen tube. This was repeated 12 times with 12 different specimen tubes which were combined into one tube to measure the residual bleach. Bleach to specimen carryover over all three instruments was < 0.00002% (i.e., 0.2 ppm v/v).
Reagent Carryover
The reagent carryover within the BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems was evaluated by measuring optical density of FITC and PBS reagents using a spectrophotometer, before and after 100 cycles of reagent probe dispenses and washes, to assess the adequacy of probe washes to prevent contamination. The reagent carryover was found to be < 0.01% (i.e., 100 ppm v/v).
B Other Supportive Instrument Performance Characteristics Data:
1. Detection Limit:
Limit of Blank (LoB), Limit of Detection (LoD) and Limit of Quantitation (LoQ) were determined per CLSI EP17-A2, Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures; Approved Guideline.
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For LoB, five donor samples with a minimum of 60 replicates per reagent lot, were evaluated across four days using three different BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems. There were 194 data points collected in total for three reagent lots.
For LoD, four low concentration samples with a minimum of 60 replicates per reagent lot were evaluated across four days using three different BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems for low concentration samples per reagent lot. The samples were cell-free plasma reconstituted with normal donor whole blood to a concentration of $10 \pm 5$ CD4 cells/uL. A total of 180 points were collected in total for three reagent lots.
For LoQ, four low concentration pools were created by diluting normal whole blood with cell free plasma to achieve CD4 absolute counts of 10, 20, 30 and 50 cells/μL. Fifteen replicates were prepared from each of the concentration pools and were stained with three different reagent lots. Ten replicates from each of the concentration pools were run on three different BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation System whereas five replicates were run on the BD FACSLyric Flow cytometer (predicate device).
The determined LoB, LoD and LoQ are shown in the following table:
| Subset | LoB (cells/μL) | LoD (cells/μL) | LoQ (cells/μL) |
| --- | --- | --- | --- |
| CD3+ | 2 | 6 | 18 |
| CD3+CD4+ | 1 | 4 | 9 |
| CD3+CD8+ | 2 | 8 | 13 |
| CD19+ | 0 | 2 | 7 |
| CD16+CD56+ | 0 | 3 | 12 |
2. In-use Reagent Stability Performance:
The study was performed in accordance with CLSI EP25-A, Evaluation of Stability of In Vitro Diagnostic Reagents to evaluate the in-use reagent stability of the Multitest 6-color TBNK on the FACSDuet instrument for a minimum of 5 days with the vials remaining uncapped for 8 hours per day inside the FACSDuet instrument. The enumeration of CD3+, CD3+CD4+, CD3+CD8+, CD19+ and CD16+CD56+ was tested over three different BD FACSLyric Flow Cytometer with the integrated BD FACSDuet Sample Preparation Systems using three reagent lots. The unopened vials stored refrigerated (2–8 °C) from the same lots were used as control reagents. Samples that were stained with control reagents were either prepared by Automated sample preparation and acquired on the subject device or by manual preparation and acquired on unintegrated FACSLyric flow cytometer (predicate device). The results for the absolute counts and percentage lymphocytes between the test (Day 5) and the control reagents for the automatic sample preparation and manual sample preparation method are summarized in the following table:
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| Subset | Absolute Count (cells/μL) (Mean % Bias) | | Percent Lymphocyte (%) (Mean % Bias) | |
| --- | --- | --- | --- | --- |
| | Automatic | Manual | Automatic | Manual |
| CD3+ | -2.51 | -0.12 | 0.08 | 0.02 |
| CD3+CD4+ | -2.48 | -0.07 | 0.14 | 0.21 |
| CD3+CD8+ | -2.30 | -0.34 | 0.04 | -0.10 |
| CD19+ | -2.50 | -0.14 | -0.11 | -0.12 |
| CD16+CD56+ | -2.06 | 3.57 | 0.03 | 0.11 |
3. Equivalence between 15- and 30-minutes Incubation time:
The study was performed to demonstrate the equivalency between the sample staining incubation time of 15 minutes for the manual preparation versus the staining incubation time of 15-30 minutes on the FACSDuet instrument for the following four comparisons:
a. Between FACSDuet 30 minutes incubation time and manual sample preparation 15 minutes incubation time.
b. Between 15 and 30 minutes incubation time using manual sample preparation.
c. Between FACSDuet and manual sample preparation using incubation time of 15 minutes.
d. Between FACSDuet and manual sample preparation using incubation time of 30 minutes.
For each of the four sample preparation types, 12 donor samples with 5 replicates per donor (60 replicates in total) were tested for enumeration of the $\mathrm{CD3 + }$ , $\mathrm{CD3 + CD4 + }$ , $\mathrm{CD3 + CD8 + }$ , $\mathrm{CD19 + }$ and $\mathrm{CD16 + CD56 + }$ cells. Mean bias (\%) of absolute counts for all four comparisons were calculated and the results support the equivalence between 15 and 30 minutes incubation time.
4. Equivalency of Software for the BD FACSLyric Flow Cytometer:
There were three software versions (v1.1.1, v1.3 and v1.4) releases from the predicate (v 1.0, predicate) to the current modified BD FACSLyric Flow Cytometer (v 1.4). Equivalency of software versions between the predicate system and the subject device was performed as follows:
Equivalency between software v1.1.1 and v1.3
A study was performed to evaluate the optical equivalence between the predicate instrument (the BD FACSLyric 10-color configuration with software v1.1.1) and subject device (the BD FACSLyric 12-color configuration with software v1.3.). The clinical samples containing both HIV positive patient samples and normal samples were tested for absolute enumeration of the lymphocyte subsets on three subject instruments and three predicate instruments using three reagent lots. The results for the absolute counts and percentage lymphocytes are summarized in the following table:
K201814 - Page 14 of 15
{14}
| Subset | Absolute Count (cells/μL) (Mean % Bias) | Percent Lymphocyte (%) (Mean % Bias) |
| --- | --- | --- |
| CD3+ | -0.17 | -0.21 |
| CD3+CD4+ | -0.52 | -0.54 |
| CD3+CD8+ | -0.83 | -0.86 |
| CD19+ | 0.27 | 0.03 |
| CD16+CD56+ | 1.29 | 0.15 |
Equivalency between software v1.3 and v1.4
Twenty clinical samples containing both HIV positive samples and normal samples were evaluated for absolute count measurement to determine equivalency between FACSLyric containing v1.3 and FACSLyric containing v1.4. The results for the absolute counts and percentage lymphocytes are summarized in the following table:
| Subset | Absolute Count (cells/μL) (Mean % Bias) | Percent Lymphocyte (%) (Mean % Bias) |
| --- | --- | --- |
| CD3+ | -1.50 | 0.21 |
| CD3+CD4+ | -0.94 | 0.55 |
| CD3+CD8+ | -1.49 | 0.25 |
| CD19+ | -0.10 | -0.09 |
| CD16+CD56+ | -0.58 | 0.03 |
## VIII Proposed Labeling:
The labeling supports the finding of substantial equivalence for this device.
## IX Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
K201814 - Page 15 of 15
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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.