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36     CHAPTER 2 Analytical performance of SMBG systems




                         Analytical performance according to FDA
                         In the United States, the FDA oversees and regulates SMBG systems and blood
                         glucose monitoring test systems for prescription POC use. FDA regulates these
                         for all phases of market release: premarket notification for market approval,
                         manufacturing and performance standards, and postmarketing surveillance. Before
                         2014, the FDA utilized the ISO 15197:2003 standard for approving glucose meters
                         in the United States. The FDA introduced draft guidance in 2014 and later finalized
                         this guidance in 2016, implementing its own standard for BGMs for self-monitoring
                         that was similar to the ISO 15197:2013. Similar to its modern ISO counterpart, the
                         2016 FDA guidelines require 95% of measurements to fall within  15% of the refer-
                         ence BG concentration for BG values   100 mg/dL. However, the FDA also requires
                         this same level of performance (  15%) for BG values across the entire range, as
                         opposed to the more forgiving ISO 2013 criteria of an absolute amount of
                          15 mg/dL for BG values < 100 mg/dL. It is important to note that the FDA criteria
                         are especially stringent for the severe hypoglycemic range. For example, 15% of
                         54 mg/dL only allows for a variance of 8 mg/dL. The accuracy requirements are
                         unchanged in the latest 2018 draft guidance. A summary of the various analytical
                         accuracy requirements are found in Table 2.1.
                            Similar to ISO 15197:2013, the latest 2016 and 2018 FDA guidelines require
                         daily precision testing over 10 days. The 2016 guidance requires that a minimum
                         of three test strip lots be scrutinized, but the 2018 draft guidance proposes a
                         reduction to only two test strip lots.






                         Table 2.1 International and food and drug administration analytical
                         accuracy requirements for blood glucose monitors for self-monitoring.
                          Accuracy standard            Minimum accuracy requirements
                          ISO 15197 2013               95% of glucose values must be within  15 mg/dL
                                                       of reference for values <75 mg/dL or within 20%
                                                       of reference for values  75 mg/dL
                          ISO 15197 2016               95% of glucose values must be within  15 mg/dL
                                                       of reference for values <100 mg/dL or within 15%
                                                       of reference for values  100 mg/dL
                          FDA 2016 for over-the-counter  95% of glucose values must be within 15% of
                          BGMs (FDA 2016)              reference, and 99% of glucose values must be
                                                       within 20% of reference
                          FDA 2018 Draft Guidance for over-  Same as FDA 2016
                          the-counter BGMs (FDA 2018)
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