AVL OPTI-CHECK PH/ BLOOD GAS/ ELECTROLYTE/THB/ SO2 CONTROL
Applicant
Avl Scientific Corp.
Product Code
JJY · Clinical Chemistry
Decision Date
Jan 22, 1998
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.1660
Device Class
Class 1
Indications for Use
AVL OPTI-check assayed control is intended to be used to monitor the measurement of pH, PCO2, PO2, sodium, potassium, total hemoglobin content and oxygen saturation in the AVL OPTI Critical Care Analyzer, as well as other devices measuring the same parameters and ionized calcium and chloride.
Device Story
AVL OPTI-check is an aqueous liquid control solution used for daily quality assurance in clinical laboratories. It contains a stable suspension of polystyrene microbeads that mimic the optical properties of erythrocytes by reflecting and absorbing red and infrared light; this allows the device to simulate whole blood measurements for total hemoglobin (tHb) and oxygen saturation (SO2) on the AVL OPTI Critical Care Analyzer. The solution also contains clinically relevant concentrations of pH, PCO2, PO2, sodium, potassium, ionized calcium, and chloride. Laboratory personnel use the control to verify instrument performance before analyzing patient specimens or after obtaining suspicious results. By ensuring the analyzer is functioning correctly, the device helps clinicians maintain the accuracy of diagnostic data used for patient monitoring and therapeutic decision-making.
Clinical Evidence
Bench testing only. Precision was evaluated over 20 days (two runs/day, two replicates/run) on AVL OPTI Critical Care Analyzers. Clinical correlation studies compared the AVL OPTI Critical Care Analyzer to predicate devices using remnant patient whole blood and serum specimens. Results showed no significant difference (P < 0.05) for all analytes evaluated (pH, PCO2, PO2, Na, K, ctHb, SO2). Imprecision was within manufacturer-stated claims.
Technological Characteristics
Aqueous liquid control solution containing pH, PCO2, PO2, sodium, potassium, ionized calcium, chloride, and a stable suspension of polystyrene microbeads. The microbeads act as optical simulators for erythrocytes to enable tHb and SO2 measurement. Designed for use with the AVL OPTI Critical Care Analyzer and other conventional blood gas/electrolyte instrumentation.
Indications for Use
Indicated for use as an in vitro diagnostic quality control material to monitor the accuracy and precision of clinical analyzers measuring pH, PCO2, PO2, electrolytes (sodium, potassium, ionized calcium, chloride), total hemoglobin (tHb), and oxygen saturation (SO2) in patient samples.
Regulatory Classification
Identification
A quality control material (assayed and unassayed) for clinical chemistry is a device intended for medical purposes for use in a test system to estimate test precision and to detect systematic analytical deviations that may arise from reagent or analytical instrument variation. A quality control material (assayed and unassayed) may be used for proficiency testing in interlaboratory surveys. This generic type of device includes controls (assayed and unassayed) for blood gases, electrolytes, enzymes, multianalytes (all kinds), single (specified) analytes, or urinalysis controls.
Predicate Devices
Multi-Function Blood Gas Control, Bionostics, Inc. (K880447)
Control for Blood Gases, Electrolytes and Glucose, Bionostics, Inc. (K911755)
Submission Summary (Full Text)
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# 510(k) Summary
JAN 2 2 1998
cientific corporat
(a) (1) Submitter's name, address AVL Scientific Corporation 33 Mansell Court Roswell, GA 30076
Contact Person Randy Byrd Quality Assurance Manager (770) 587-4040 x 631
Date of preparation of this summary:
- Device trade or proprietary name: (2)
AVL OPTI-Check Control
8 January 1998
Device common or usual name or classification name
Multi Analyte Control Solution
| | CLASSIFICATION | | |
|--------------------------------|----------------|-------|-----------|
| PRODUCT NOMENCLATURE | NUMBER | CLASS | PANEL |
| MULTI ANALYTE CONTROL SOLUTION | 75 JJY | I | CHEMISTRY |
#### (3) Substantial Equivalence
A VL OPTI-check is substantially equivalent in function, safety and efficacy to a number of currently marketed devices known as 'Combi' or 'Multi-Analyte' control solutions, namely:
Multi-Function Blood Gas Control, Bionostics, Inc., K880447
Control for Blood Gases, Electrolytes and Glucose, Bionostics, Inc., K911755
#### Description of the new device (4)
OPTI-check is a specially formulated aqueous liquid material intended to for use to monitor all analytes measured by the OPTI. It contains a stable suspension of polystyrene microbeads which reflect and partially absorb red and infrared light similar to erythrocytes, allowing true simulation of the measurement of tHb and SO2 in exactly the same manner as these analytes are determined in whole blood by the AVL OPTI Critical Care Analyzer. The three control levels contain three different concentrations of microbeads to simulate low, medium, and high hematocrit blood samples. OPT-check provides a convenient method of performing daily QC checks for laboratories selecting to measure liquid QC material as a part of their quality assurance program.
While the product is optimized for performance on the AVL OPTI Critical Care Analyzer, it may be used to monitor the measurement of blood gas and electrolyte values in conventional instrumentation. OPTI-check contains clinically relevant quantities of pH, PCO2, PO2, sodium, potassium, ionized calcium and chloride, and suitable concentrations of microbeads to simulate clinically relevant values of tHb and oxygen saturation.
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#### Intended use of the device (ર)
AVL OPTI-check assayed control is intended to be used to monitor the measurement of pH, PCO2, PO2, sodium, potassium, total hemoglobin content and oxygen saturation in the AVL OPTI Critical Care Analyzer, as well as other devices measuring the same parameters and ionized calcium and chloride.
#### Technological characteristics of the device. (6)
AVL OPTI-check is technologically equivalent to currently marketed products to which substantial equivalence is claimed. It contains a low concentration, stable suspension of polystyrene microbeads which reflect and partially absorb red and infrared light similar to erythrocytes, allowing true simulation of the measurement of tHb and SO2 in exactly the same manner as these analytes are determined in whole blood by the AVL OPTI Critical Care Analyzer.
### (b) (1) Summary of non-clinical tests submitted with the premarket notification for the device.
Typical Within-Run (Swr), Between-Day (Sdd) and Total (ST) precision were determined from two runs per day with 2 replicates per run for 20 days on two AVL OPTI Critical Care Analyzers.
### (b) (2) Summary of clinical tests submitted with the premarket notification for the device.
Typical Within-Run (Swr), Between-Dav (Sdd) and Total (ST) precision were determined from two runs per day with 2 replicates per run for 20 days on a single AVL OPTI Critical Care Analyzer. Additionally, clinical testing was conducted to demonstrate the correlation of AVL OPTI Critical Care Analyzer to predicate devices in a clinical setting, operated by personnel trained to perform and report these analyses. Specimens analyzed in these tests were remnant from patient specimens of both whole blood and serum collected for routing analysis on existing instrumentation.
### (b) (3) Conclusions drawn from the clinical and non-clinical trials.
All evaluation of measurement imprecision was within manufacturer's stated claims and comparison of measurement between the OPTI Critical Care Analyzer and other instrumentation showed no significant difference (P < 0.05) for all analytes evaluated. Acceptable performance on precision evaluation conducted concurrently to acceptable correlation to predicate devices in measurement of pH, PCO2, PO2, Na, K, ctHb and SO2 supports the use of AVL OPTI-check to monitor the measurement of these analytes, and demonstrates it substantially equivalent to other products with similar intended uses.
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Image /page/2/Picture/1 description: The image is a black and white logo for the U.S. Department of Health and Human Services. The logo features a stylized caduceus symbol, which is a traditional symbol of medicine, with three intertwined strands. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" is arranged in a circular pattern around the caduceus symbol.
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
JAN 2 2 1998
Randy Byrd · Quality Assurance Manger AVL Scientific Corporation 33 Mansell Court 30076 Roswell, Georgia
Re : K974822 AVL OPTI-check pH Control Regulatory Class: I Product Code: JJY December 19, 1997 Dated: Received: December 24, 1997
Dear Mr. Byrd:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act). You may, therefore, market the device, subject to the general controls provisions The general controls provisions of the Act of the Act. include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set -forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory In addition, FDA may publish further announcements action. concerning your device in the Federal Register. Please note: this response to your premarket notification submission does
not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or requlations.
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Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity To determine if it does, you should contact categorization. the Centers for Disease Control and Prevention (CDC) at (770) 488-7655.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4588. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html".
Sincerely yours,
Steven Gutman
Steven I. Gutman, M.D., M.B.A. Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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## 510(k) Number: K974822
### AVL OPTI-check Control Solution Device Name:
AVL OPTI-check assayed control is intended to be used to monitor the measurement of pH, PCO2, PO2, sodium, potassium, total hemoglobin content and oxygen saturation in the AVL OPTI Critical Care Analyzer, as well as other devices measuring the same parameters and ionized calcium and chloride.
For In Vitro Diagnostic Use
### Indications for Use
The determination of acid-base status, and concentration of carbon dioxide, oxygen, electrolytes, total hemoglobin and oxygen saturation is an important adjunct to patient monitoring for a variety of clinical conditions described in the labeling for those devices used for these purposes. Since therapeutic regimes are often determined by the results obtained in patient samples, the instruments used for these analyses must meet stringent requirements for accuracy and precision of measurement. It should be the goal of the quality control program in institutions performing these analyses to determine the instrumentation is working properly before the analysis and report of patient specimens, or after any suspicious results have been obtained.
974822
(Division Sign-Off Division of Clinical Laboratory Devic 510(k) Number
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use (Per 21 CFR 801.109)
OR
Over-The-Counter Use _______
(Optional Format 1-2-96)
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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.
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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?
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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.
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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?
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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.
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Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
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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.
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A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
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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.