UNICEL DXH 800 COULTER CELLULAR ANALYSIS SYSTEM
K120771BECKMAN COULTER, INC. · cleared 2013-03-22 · product code GKZ · Hematology
Premarket evidence — what FDA accepted
source quote (p.2)
“The UniCel® DxH 800 COULTER® Cellular Analysis System (DxH 800) is intended for In Vitro Diagnostic Use in clinical laboratories. The DxH 800 System provides automated complete blood count, leukocyte differential, nucleated red blood cell (NRBC) enumeration and reticulocyte analysis as well as an automated method for enumeration of the Total Nucleated Cells (TNC) and Red Blood Cells (RBC) in body fluids. Pulse counts and digitized pulse measurements are sent to the System Manager for processing by the algorithms where the reported parameter values, flags and histograms are generated.”
source quote (p.8)
“The data collected during each of the analytical processes is transferred to the System Manager where the digital raw values are processed by the algorithm using mathematical approaches designed for finding optimal separation between clusters of data. The identified clusters are used to calculate the frequency of cells within each population, generate parameter values, flags, histograms and data plots.”
Validation studies (12)
Retrospective clinical
sample size not stated
endpoints: accuracy claims (Bias and/or Difference) limits over the measuring ranges; performance requirements and provides results within acceptance limits for parameters reported from whole blood, when compared to the predicate device and for differential parameters when compared to manual reference results; performance requirements and provides results within acceptance limits for parameters reported from body fluid, when compared to the manual chamber count
standards: CLSI H26-A2, CLSI EP9-A2, CLSI H20-A2, CLSI H56-A
Retrospective clinical
sample size not stated
endpoints: equivalency of results (within defined limits) between the whole blood analytical cycles (test panels); equivalency between specimens analyzed as whole blood and as Pre-dilute (PD) specimens
standards: CLSI H26-A2, CLSI EP15-A2
Retrospective clinical
sample size not stated
endpoints: comparability between the sampling modes available on the updated DxH 800; comparable results for all parameters reported, for specimens analyzed using the sampling methods available (automated closed vial, manual closed vial and manual single tube open vial)
standards: CLSI H26-A2, CLSI EP15-A2
Bench
sample size not stated
endpoints: long term imprecision of the device; meets the performance requirements (within acceptance limits) for reproducibility (long term imprecision) using control products
standards: CLSI H26-A2, CLSI EP05-A2
Bench
sample size not stated
endpoints: short term imprecision of the device; meets performance requirements for repeatability, (within acceptance limits) for all parameters reported
standards: CLSI H26-A2, CLSI EP05-A2, CLSI H56-A
Bench
sample size not stated
endpoints: Limit of Blank, Lower Limit of Detection and Lower Limit of Quantitation testing; meets the performance requirements for LoB, LLoD and LLOQ results (within acceptance limits), for the WBC and PLT parameters in whole blood and the BF-TNC and BF-RBC parameters in body fluids
standards: CLSI H26-A2, CLSI EP17-A
Retrospective clinical
sample size not stated
endpoints: Clinical Sensitivity and Specificity to assess the ability of a test to detect presence or absence of a condition/abnormality; WBC Differential Suspect message flagging capability of the system
standards: CLSI H26-A2, CLSI H20-A2
Bench
sample size not stated
endpoints: linearity of the device; linear results, within acceptance limits, for Whole blood and Body Fluid
standards: CLSI H26-A2, CLSI EP06-A
Bench
sample size not stated
endpoints: whole blood and body fluid carryover performance; substantiate the modified NRBC carryover claim; meets the whole blood and body fluid carryover performance requirements (within acceptance limits), for the parameters measured
standards: CLSI H26-A2
Bench
sample size not stated
endpoints: equivalency of results for whole blood specimens collected into K2 and K3EDTA; comparable results, for all parameters reported, from specimens collected into K2 and K3EDTA
standards: CLSI H26-A2, CLSI H3-A6, CLSI H04-A6, CLSI EP15-A2
Bench
sample size not stated
endpoints: whole blood specimen stability; whole blood long term, short term and pre-dilute sample stability
Retrospective clinical
sample size not stated
endpoints: comparability of whole blood reference ranges for an adult population to the ranges established for the predicate device
standards: CLSI C28-A3
Reported performance (0 observations)
FDA source did not state a quantitative performance metric — non-reporting is itself the signal.
Each value carries its own analysis unit and task — never compare or pool across devices. Source: 510(k) summary PDF.
Predicate network
Postmarket — what happened after clearance
- recall_reason_pattern
Software/algorithm-related recall in product code GKZ (Abbott Laboratories, initiated 2025-09-18): "Software issue for hq analyzer results in system not visibly applying appropriate flagging to results when saturation is present which may result in incorrect results." Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:97788
- recall_reason_pattern
Software/algorithm-related recall in product code GKZ (Abbott Laboratories, initiated 2025-03-18): "When expired reagents are scanned or manually entered, the system will change the expiration date to current or future date without notifying user that an expired reagent is being " Recalling firm is another firm in the same product code.
first seen 2026-07-08 · recall res_event_number:96567
Recalls attributed to this device
Recalling firm matches this device's applicant (Beckman Coulter Inc.) — same firm and product code, not necessarily this device · initiated 2025-08-13
Hematology analyzers configured with HGB photometers may result in erroneously high hemoglobin (HGB) results on samples with elevated white blood cell (WBC) counts.
recall event 97464 (openFDA)
Recalling firm matches this device's applicant (Beckman Coulter Inc.) — same firm and product code, not necessarily this device · initiated 2025-08-13
Hematology analyzers configured with HGB photometers may result in erroneously high hemoglobin (HGB) results on samples with elevated white blood cell (WBC) counts.
recall event 97464 (openFDA)
Recalling firm matches this device's applicant (Beckman Coulter Inc.) — same firm and product code, not necessarily this device · initiated 2025-08-13
Hematology analyzers configured with HGB photometers may result in erroneously high hemoglobin (HGB) results on samples with elevated white blood cell (WBC) counts.
recall event 97464 (openFDA)
Recalling firm matches this device's applicant (Beckman Coulter Inc.) — same firm and product code, not necessarily this device · initiated 2025-08-13
Hematology analyzers configured with HGB photometers may result in erroneously high hemoglobin (HGB) results on samples with elevated white blood cell (WBC) counts.
recall event 97464 (openFDA)
Recall and MAUDE counts are product-code-level (reports aren't reliably attributable to one device); a recall is shown as device-attributed only when the recall record itself lists this clearance number. Signals are descriptive observables with sources — never a judgment that the device is unsafe or drifting. Snapshot 2026-07-08.
Reimbursement — how devices like this got paid
Not yet tracked — no payment pathway indexed for this clearance (the reimbursement corpus is a growing seed set).
Applicable FDA guidance — what the submission is measured against
FDA guidance documents and guiding principles applicable to 510(k) AI/ML devices in the Hematology panel. A curated reference index, not legal or regulatory advice — each item states its own status, and a draft is never binding.
- Final guidance2026-01Clinical Decision Support Software
Clinical decision support · SaMD (general)
New final guidance issued Jan 2026, superseding the Sept 2022 version; narrows the device-CDS scope. Applies to software that informs clinical management.
- Final guidance2026-01General Wellness: Policy for Low Risk Devices
SaMD (general) · Clinical decision support
Revised final (Jan 2026); now addresses noninvasive products estimating physiologic parameters (SpO2, BP, glucose). Reshapes the device / non-device line for AI wellness features.
- Final guidance2025-09Computer Software Assurance for Production and Quality Management System Software
SaMD (general) · Postmarket
Final (Sept 2025). Covers software used in production/QMS (incl. ML development-pipeline tooling), superseding Section 6 of the 2002 GPSV — not device software functions themselves.
- Final guidance2025-06Cybersecurity in Medical Devices: Quality Management System Considerations and Content of Premarket Submissions
Cybersecurity · Software premarket content
Reissued June 2025 (retitled 'Quality Management System', was Sept 2023 'Quality System'); adds coverage of FD&C Act §524B cyber devices.
- Final guidance2024-12Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence-Enabled Device Software Functions
Predetermined Change Control Plan · AI/ML lifecycle · Software premarket content
Final (Dec 2024). Supersedes the April 2023 AI/ML PCCP draft.
- Final guidance2023-10Electronic Submission Template for Medical Device 510(k) Submissions
Software premarket content
eSTAR has been mandatory for 510(k)s since Oct 2023 — operationally unavoidable, though not AI-specific.
- Final guidance2023-08Off-The-Shelf Software Use in Medical Devices
Software premarket content · SaMD (general)
Final (Aug 2023). Applies when a device incorporates off-the-shelf software components (common in ML stacks).
- Final guidance2023-06Content of Premarket Submissions for Device Software Functions
Software premarket content · SaMD (general)
Final (June 2023); replaced the May 2005 'Software Contained in Medical Devices' guidance. Documentation level drives the software content of the submission.
- Final guidance2022-09Policy for Device Software Functions and Mobile Medical Applications
SaMD (general) · Clinical decision support
Current version Sept 2022. Frames which software functions FDA regulates as devices.
- Final guidance2021-10De Novo Classification Process (Evaluation of Automatic Class III Designation)
De Novo pathway
Final (Oct 2021), issued with the De Novo final rule. Most relevant to first-of-a-kind devices without a predicate (DEN-numbered clearances).
- Final guidance2016-12Postmarket Management of Cybersecurity in Medical Devices
Cybersecurity · Postmarket
- Final guidance2002-01General Principles of Software Validation
SaMD (general) · Software premarket content
Still active except Section 6 (superseded Sept 2025 by the Computer Software Assurance final guidance).
- Draft guidance2025-01Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations
AI/ML lifecycle · Software premarket content · Transparency
Draft as of July 2026 (published Jan 2025); finalization is on CDRH's FY2026 agenda but not yet published. Treat as FDA's stated direction, not a binding expectation.
- Draft guidance2024-08Predetermined Change Control Plans for Medical Devices
Predetermined Change Control Plan · Postmarket
Draft (Aug 2024) extending PCCPs beyond AI to all devices under FD&C §515C; not final as of July 2026.
- Guiding principles2024-06Transparency for Machine Learning-Enabled Medical Devices: Guiding Principles
Transparency · AI/ML lifecycle
- Guiding principles2023-10Predetermined Change Control Plans for Machine Learning-Enabled Medical Devices: Guiding Principles
Predetermined Change Control Plan · AI/ML lifecycle
FDA/Health Canada/MHRA joint principles (Oct 2023); companion to the GMLP and Transparency principles.
- Guiding principles2021-10Good Machine Learning Practice for Medical Device Development: Guiding Principles
AI/ML lifecycle · SaMD (general)
FDA/Health Canada/MHRA joint principles (Oct 2021). Foundational, not a binding guidance; IMDRF issued a related GMLP document Jan 2025.
Applicability is derived from the device's FDA advisory panel and pathway — cross-cutting guidances apply to every AI/ML device; panel-specific ones are flagged. Titles, dates, and links verified against fda.gov as of July 2026.