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Self-Monitoring Blood Glucose Test Systems for Over-the-Counter Use: Guidance for Industry and Food and Drug Administration Staff

FinalCenter for Devices and Radiological Health09/29/2020
Process ValidationDesign Controlcalibrationcybersecurity controlsfailure alert mechanismsfail-safe mechanismsrisk analysis

Description

This guidance document describes studies and information that FDA recommends be used when submitting premarket notifications (510(k)s) for self-monitoring blood glucose test systems (SMBGs) which are for over-the-counter (OTC) home use by lay-users.1This guidance document is intended to guide manufacturers in conducting appropriate performance studies and preparing 510(k) submissions for these device types and replaces the final guidance entitled "Self-Monitoring Blood Glucose Test Systems for Over-the-Counter Use" issued on October 11, 2016.

Key Topics

Terms and concepts identified from this document

Scope & Applicability

Product Classes

2
Self-Monitoring Blood Glucose Test Systems

Devices intended for over-the-counter home use by lay-users.; Guidance for industry and FDA staff regarding OTC use; Devices intended for over-the-counter use to monitor blood glucose.; Guidance for over-the-counter use of blood glucose test systems.; The device type being evaluated for interference and robustness.; The guidance applies to SMBG systems for over-the-counter use.; Guidance for over-the-counter use systems

Blood Glucose Monitoring Systems

Intended for use by healthcare professionals

Stakeholders

3
Lay-users

non-professional users of pulse oximeters

third party test strip manufacturers

manufacturers other than the meter manufacturer

lay-user

Individuals with wide ranges in age and dexterity using SMBGs at home; The intended user population of SMBGs is the lay-user.; Intended user population for OTC SMBG; instructions to contact healthcare provider

Regulatory Context

Regulatory Activities

3
510(k)

Premarket notification submission type

Special 510(k)

FDA recommends you submit a Special 510(k)

510(k) submission

Submission including device performance data and biocompatibility conclusions

Document Types

5
Labeling

Cybersecurity information should be included in device labeling

Package Insert

Labeling information including dosage, administration, and safety sections

Control solution insert

Readability assessment should be performed on the control solution insert.; Package insert for controls

Test strip insert

Readability assessment should be performed on the test strip insert.; Package insert for test strips

User Manual

Documentation accompanying electronic products that can be provided in paper or electronic form

Attributes

9
Moderate Level of Concern

Former risk classification for CADe devices under the superseded guidance.; Typical risk classification for CADe software

Contact time

Factor influencing the effectiveness of cleaning and sanitizing agents.

open vial life

Open vial stability mimics conditions where the vial is opened and closed.

shelf life

Information recommended for inclusion in the notification

Hematocrit

A physiological property that can contribute to analytical error in glucose monitoring.; High altitude can result in changes to hematocrit.

Measuring range

The entire claimed measuring range of the device.

Basic Documentation Level

Level of documentation required based on risk; documentation threshold for software functions; Risk-based documentation category; Outcome for software functions with low risk of death or serious injury

within-run precision

Imprecision under conditions of repeated measurement of the same sample.

intermediate precision

Imprecision under simulated normal use conditions over multiple days.

Technical Details

Substances

10
Hematocrit

Substance/factor evaluated during interference testing.

plasma

SMBGs should report results in terms of plasma equivalents

whole blood samples

Used for accuracy and precision evaluations.

glucose controls

Used in precision studies over 5 days.

Ascorbic acid

Antioxidant used to inhibit NDSRI formation; antioxidant used to inhibit nitrosamine formation

Acetaminophen

Known or potential interferent for blood glucose measurement.; Listed as an example interferent in the recommended summary table format.

70% ethanol

Not effective against viral bloodborne pathogens

10% bleach

May lead to physical degradation of the device

control material

Composition and levels of material used to verify system performance.; External control solutions used to check system performance.

venous whole blood

Sample type used for within-run precision and linearity studies.

Testing Methods

10
Precision Evaluation Study

Performance evaluation study recommended for SMBGs.

Alternative Site Testing

sampling from anatomical sites other than the fingertip

laboratory method

Used for periodic technique review and comparison

Accuracy Evaluation

Performed using whole blood samples spanning the claimed measuring range.

Precision Evaluation

Demonstrates precision calculated is within labeled performance.

Deming Regression

Suitable analysis procedure for calculating confidence intervals.

Linear Regression

Plotting the results and using the slope to represent beta results in the following graphs.

SMOG

Recommended computer program to assess the readability grade level of the labeling.

Flesch-Kincaid

Recommended computer program to assess the readability grade level of the labeling.

Linearity Evaluation Study

Performance evaluation study recommended for SMBGs.

Processes

10
Method Comparison/User Evaluation

Study to assess system accuracy in the hands of intended users.

Cleaning and Disinfection Procedures

Procedures that must be validated to reduce bloodborne pathogen transmission.; Validated procedures required to prevent disease transmission between patients.

specimen collection

Labeling must provide instructions for collection and preparation

Intermittent Sampling

Occurs when a user adds more sample before measurement is complete.

Sample Perturbation Study

Demonstrates how SMBG handles events like wicking blood away.

Short Sample Detection

System should detect reduced blood volume to avoid inaccurate results.

Altitude Effects

Studies on the effects of altitude on SMBG device performance.

System Operating Conditions Testing

Assesses performance under various temperature and humidity conditions.

Test Strip Stability Testing

Studies assessing performance throughout stability claims.

Electrostatic Discharge/Electromagnetic Interference Testing

A type of flex study recommended for SMBG systems.

Clinical Concepts

8
Human Immunodeficiency Virus

Infection requiring medical data collection in pregnancy

Hypoglycemia

patients with type 2 diabetes may face unique safety issues such as a risk for hypoglycemia

Diabetes Mellitus

Intended use for people with diabetes

Anemia

Expected toxicity with many MDS drugs

Ketoacidosis

Conditions known to interfere with glucose monitoring should be included in labeling.

Hematocrit

Hematocrit values should be determined and recorded for each study participant.

Hepatitis B Virus

The pathogen (HBV) being screened in blood donations.

hypoglycemic range

Low blood glucose readings range where ISO 15197 is considered insufficient.

Identified Hazards

Hazards

1
Bloodborne Pathogen Transmission

Safety risk addressed through cleaning and disinfection validation.; Risk that device features should be designed to minimize.; Risk from use of device on multiple patients; risk of disease transmission when using SMBGs

Standards & References

External Standards

5
CLSI EP-18A2

Risk Management Techniques to Identify and Control Laboratory Error Sources

CLSI GP-14

Labeling of Home-Use In Vitro Testing Products

ASTM E1053-11

Standard Test Method for Efficacy of Virucidal Agents

ASTM E2362-09

Standard Practice for Evaluation of Pre-saturated Towelettes

CLSI document EP6-A

Evaluation of the Linearity of Quantitative Measurement Procedures.

Specifications

8
performance specifications

Includes response time, settling time, and steady state-deviation; Criteria for sensors, actuators, and algorithms

measuring range

Labeling should indicate display when glucose is outside range

10,000 feet

Minimum altitude for testing SMBG effects.

95% confidence intervals

Statistical requirement for reporting interference testing results.

50 mg/dL to 400 mg/dL

SMBGs should minimally be able to measure blood glucose accurately between 50 mg/dL and 400 mg/dL.

99% within +/- 20%

99% of all SMBG results are within +/- 20% of the comparator results.

95% within +/- 15%

95% of all SMBG results in this study are within +/- 15% of the comparator results.

8th grade level

For a product intended for home use, the reading level should be at an 8th grade level or less.

Related CFR Sections (3)

Enforcement Impact

Deficiencies cited in Warning Letters referencing the same regulations

Adulterated under section 501(f)(1)(B)
21
Misbranded under section 502(o)
19
Failure to establish and maintain procedures to control the design of the device
10
Failure to adequately develop, maintain, and implement written MDR procedures
10
Failure to establish and maintain procedures for implementing corrective and preventive action
10
Failure to establish and maintain procedures for receiving, reviewing, and evaluating complaints
8
Unapproved Device Violations
8
Failure to establish and maintain procedures for implementing corrective and preventive actions
8
Failure to adequately establish and maintain procedures for receiving, reviewing, and evaluating complaints
8
Failure to develop, maintain, and implement written Medical Device Reporting (MDR) procedures
7

Related Warning Letters (10)

Related MFDS Guidelines

Korean regulatory guidelines covering similar topics

See Also (8)