K223608
K223608
K223608
Re: K223608
Trade/Device Name: GEM Premier 7000 with iQM3
Regulation Number: 21 CFR 862.1120
Regulation Name: Blood Gases (pCO2, pO2) and Blood pH Test System
Regulatory Class: Class II
Product Code: CHL, JGS, CEM, CGZ, JFP, CGA, KHP, MQM, GKF, GKR, GHS, GLY
Dated: July 10, 2023
Received: July 11, 2023
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced
above and have determined the device is substantially equivalent (for the indications for use stated in the
enclosure) to legally marketed predicate 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) that do not require approval of a
premarket approval application (PMA). You may, therefore, market the device, subject to the general
controls provisions of the Act. Although this letter refers to your product as a device, please be aware that
some cleared products may instead be combination products. The 510(k) Premarket Notification Database
located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination
product submissions. The general controls provisions of the Act include requirements for annual registration,
listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and
adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We
remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be
subject to additional controls. Existing major regulations affecting your device can be found in the Code of
Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements
concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA
has made a determination that your device complies with other requirements of the Act or any Federal
statutes and regulations administered by other Federal agencies. You must comply with all the Act's
requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part
K223608 - Gabriella Erdosy Page 2
801 and Part 809); medical device reporting (reporting of medical device-related adverse events) (21 CFR
803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see
https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-
combination-products); good manufacturing practice requirements as set forth in the quality systems (QS)
regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for
combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-
542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part
807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part
803), please go to https://www.fda.gov/medical-devices/medical-device-safety/medical-device-reporting-
mdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including
information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-
devices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn
(https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the
Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See
the DICE website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-
assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE
by email ([email protected]) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Paula V. Caposino -S
Paula Caposino, Ph.D.
Acting Deputy Director
Division of Chemistry
and Toxicology Devices
OHT7: Office of In Vitro Diagnostics
Office of Product Evaluation and Quality
Center for Devices and Radiological Health
Enclosure
DEPARTMENT OF HEALTH AND HUMAN SERVICES Form Approved: OMB No. 0910-0120
Food and Drug Administration Expiration Date: 06/30/2023
Indications for Use See PRA Statement below.
Device Name
*sO2 = ratio between the concentration of oxyhemoglobin and oxyhemoglobin plus deoxyhemoglobin.
• pH, pCO2, and pO2 measurements in whole blood are used in the diagnosis and treatment of
life-threatening acid- base disturbances.
• Electrolytes in the human body have multiple roles. Nearly all metabolic processes depend on or
vary with electrolytes:
– Sodium (Na+) measurements are used in the diagnosis and treatment of aldosteronism, diabetes
insipidus, adrenal hypertension, Addison’s disease, dehydration, inappropriate antidiuretic
secretion, or other diseases involving electrolyte imbalance.
– Potassium (K+) measurements are used to monitor electrolyte balance in the diagnosis and
treatment
of disease conditions characterized by low or high blood potassium levels.
– Ionized calcium (Ca++) measurements are used in the diagnosis and treatment of parathyroid
disease, a variety of bone diseases, chronic renal disease, and tetany.
– Chloride (Cl-) measurements are used in the diagnosis and treatment of electrolyte and metabolic
disorders, such as cystic fibrosis and diabetic acidosis.
• Hematocrit (Hct) measurements in whole blood of the packed red cell volume of a blood sample are
used to distinguish normal from abnormal states, such as anemia and erythrocytosis (an increase in
the number of red cells).
• Glucose (Glu) measurement is used in the diagnosis, monitoring and treatment of carbohydrate
metabolism
disturbances including diabetes mellitus, neonatal hypoglycemia, idiopathic hypoglycemia, and
pancreatic islet cell carcinoma.
• Lactate (Lac) measurement is used:
– to evaluate the acid-base status of patients suspected of having lactic acidosis;
– to monitor tissue hypoxia and strenuous physical exertion;
– in the diagnosis of hyperlactatemia.
• Total Bilirubin (tBili) measurement is used to aid in assessing the risk of kernicterus and
hyperbilirubinemia in neonates.
• CO-Oximetry (tHb, COHb, MetHb, O2Hb, HHb, and sO2) evaluates the ability of the blood to carry
oxygen by measuring total hemoglobin and determining the percentage of functional and dysfunctional
hemoglobin species.
– Total Hemoglobin (tHb): Total hemoglobin measurements are used to measure the hemoglobin content
of whole blood for the detection of anemia.
– COHb: Carboxyhemoglobin measurements are used to determine the carboxyhemoglobin content of human
FORM FDA 3881 (6/20) Page 1 of 2 PSC Publishing Services (301) 443-6740 EF
blood as an aid in the diagnosis of carbon monoxide poisoning.
– MetHb: Methemoglobin measurements are used to determine different conditions of
methemoglobinemia.
– HHb: Deoxyhemoglobin, as a fraction of total hemoglobin, is used in combination with
oxyhemoglobin to measure oxygen status.
– O2Hb: Oxyhemoglobin, as a fraction of total hemoglobin, is used in combination with
deoxyhemoglobin to measure oxygen status.
– sO2: Oxygen saturation, more specifically the ratio between the concentration of oxyhemoglobin
and oxyhemoglobin plus deoxyhemoglobin, is used to measure oxygen status.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
*DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the
time to review instructions, search existing data sources, gather and maintain the data needed and complete
and review the collection of information. Send comments regarding this burden estimate or any other aspect
of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services
Food and Drug Administration
Office of Chief Information Officer
Paperwork Reduction Act (PRA) Staff
[email protected]
“An agency may not conduct or sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB number.”
510(k) Summary
This 510(k) Summary of Safety and Effectiveness is being submitted in accordance with the requirements
of the Safe Medical Device Act of 1990 and 21 CFR 807.92.
Gabriella Erdosy
Director of Regulatory Affairs
Contact Person Phone: 781-861-4571
Fax: 781-861-4207
Email: [email protected]
Regulation Product
Analyte Regulatory Description Class Panel
Section Code
Blood Gases (pCO2, pO2) and Blood pH
pH, pCO2, pO2, 862.1120 II CHL
system
All required components for sample analysis are contained in the GEM PAK,
including sensors, optical cell for CO-Oximetry and total bilirubin, sampler,
pump tubing, distribution valve, waste container and Process Control
Solutions. The GEM PAK is an entirely closed analytical system. The operator
cannot introduce changes to the analytical process before or during the
GEM PAK’s use-life on board the instrument.
The GEM PAK has flexible menus and test volume options to assist facilities
in maximizing efficiency. The EEPROM on the GEM PAK includes all solution
values and controls the analyte menu and number of tests.
The setup of the instrument consists of inserting the GEM PAK into the
instrument. The instrument will perform an automated GEM PAK start-up
during which the following is performed: warm-up (15 minutes), sensor
conditioning (10 minutes), Process Control Solution (PCS) performance (15
PAK (Cartridge) minutes), all of which take about 40 minutes.
After GEM PAK start-up, Auto PAK Validation (APV) process is automatically
completed: two completely independent solutions traceable to NIST
standards, CLSI procedures or internal standards, containing two levels of
concentration for each analyte (PC Solution D and E), are run by the analyzer
to validate the integrity of the PC Solutions and the overall performance of
the analytical system.
Note: GEM PAKs that include tBili analyte will require the successful
performance of CVP 5 tBili.
Includes all necessary components for hemolysis detection, such as an
acoustofluidic flow cell, an LED light source and an optical detector, for
appropriate flagging of potassium measurements in whole blood samples
without additional sample volume or sample processing steps.
iQM3 is used as the quality control and assessment system for the GEM
Premier 7000 system. iQM3 is an active quality process control program
designed to provide continuous monitoring of the analytical process
Intelligent Quality Management before, during and after sample measurement with real-time, automatic
error detection, automatic correction of the system and automatic
(iQM3) documentation of all corrective actions, replacing the use of traditional
external QC.
iQM3 introduces hemolysis detection in whole blood samples, enhancing
quality assessment in the pre-analytical phase of testing.
GEM Premier 5000 PAK (Cartridge): GEM Premier 7000 PAK with iQM3
(Cartridge):
• Height: 6.75 inches • Height: 6.6 inches
Cartridge (PAK) Dimensions
• Width: 10 inches • Width: 10.2 inches
• Depth: 8 inches • Depth: 7.6 inches
• Weight: 8.1 pounds • Weight: Same
Addition of the new iQM quality check
The fluidic pathway directly connects
Fluidic Pathway module between Sensor Card and CO-
Sensor Card and CO-Ox module
Ox module
Additional time (11s) for the new iQM
Sample Fluidic Process Micro Mode (65 µL) quality check before analyte
measurements
PAK (Reagent) Bags Process Control Solution Bag (PCS) B Addition of Heparin
Cartridge fluidic components interface Modification to existing analyzer
Cartridge-Analyzer Interface with hardware components on the connection to support the iQM quality
analyzer check module
An analyzer capable of supporting the
An analyzer capable of supporting the
Instrument GEM Premier 7000 with iQM3
GEM Premier 5000 Cartridge (PAK)
Cartridge (PAK)
PAK Compatibility GEM Premier 5000 only GEM Premier 7000 with iQM3 only
NOTE: The following table compares internal Process Control (PC) Solutions in the GEM Premier 5000 PAK
(cartridge) to internal Process Control (PC) Solutions in the GEM Premier 7000 with iQM3 PAK (cartridge).
Category Predicate Device New Device
Trade Names Process Control (PC) Solutions Process Control (PC) Solutions
Verification (Internal Method Comparison, Internal Whole Blood Precision, Hemolysis Interference on Potassium,
Hemolysis Verification), Shelf-life and Use-life studies were performed to establish that the modifications
introduced with the addition of the new iQM quality check (Hemolysis detection module) of the GEM Premier 7000
with IQM3 do not impact the performance data represented in the Operators Manual. These studies followed
recognized guidelines:
• CLSI EP05-A3
• CLSI EP25-A
All verification activities were performed in accordance to established plans and protocols and design control
procedures. Testing verified that all acceptance criteria were met.
The technological and functional characteristics of the new GEM Premier 7000
with iQM3 as described above are substantially equivalent to that of the predicate
Conclusion device GEM Premier 5000. The analytical study results demonstrate that the GEM
Premier 7000 with iQM3 is safe and effective for its intended purpose and
equivalent in performance to the predicate device (K203790).