VITROS Chemistry Products BARB Reagent: For in vitro diagnostic use only. VITROS Chemistry Products BARB Reagent is used on VITROS 5,1 FS Chemistry Systems for the semi-quantitative or qualitative determination of barbiturates (BARB) in human urine using a cutoff of either 200 ng/mL or 300 ng/mL. Measurements obtained with the VITROS BARB method are used in the diagnosis and treatment of barbiturates use or overdose. The VITROS Chemistry Products BARB assay is intended for use by professional laboratory personnel. It provides only a preliminary test result. A more specific alternative chemical method must be used to confirm a result obtained with this assay. Gas chromatography/mass spectrometry (GC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug-of-abuse test result, particularly when evaluating a preliminary positive result. VITROS Chemistry Products Calibrator Kit 26: For in vitro diagnostic use only. VITROS Chemistry Products Calibrator Kit 26 is used to calibrate VITROS 5,1 FS Chemistry Systems for the qualitative or semi-quantitative measurement of drugs of abuse. VITROS Chemistry Products FS Calibrator 1: For in vitro diagnostic use only. VITROS Chemistry Products FS Calibrator 1 is used in conjunction with VITROS Chemistry Products Calibrator Kits to calibrate VITROS 5,1 FS Chemistry Systems. VITROS Chemistry Products DAT Performance Verifiers I, II, III, IV, and V: For in vitro diagnostic use only. VITROS Chemistry Products DAT Performance Verifiers are assayed controls used to monitor performance of urine drugs of abuse screening assays on VITROS 5,1 FS Chemistry Systems.
Device Story
Homogeneous enzyme immunoassay for barbiturate detection in human urine; performed on VITROS 5,1 FS Chemistry Systems. Input: urine sample, calibrators, controls. Process: sample treated with surfactant; competitive binding between barbiturates in sample and secobarbital-labeled G6P-DH enzyme for antibody binding sites. Enzyme activity inversely proportional to barbiturate concentration; active enzyme converts NAD+ to NADH. Output: absorbance change measured spectrophotometrically at 340 nm, correlating to barbiturate concentration. Used in clinical laboratories by professional personnel. Results aid diagnosis/treatment of barbiturate use/overdose; requires confirmatory testing (GC/MS). Benefits include rapid, automated screening for drug abuse.
Clinical Evidence
No clinical studies performed. Evidence consists of analytical bench testing. Method comparison study of 102 human urine samples against GC/MS reference method showed overall agreement of 82.4% at 200 ng/mL cutoff and 80.4% at 300 ng/mL cutoff. Precision assessed per CLSI EP5/EP12; linearity per CLSI EP6-A; interference per CLSI EP7-A2.
Technological Characteristics
Homogeneous enzyme immunoassay; sheep polyclonal antibodies; G6P-DH enzyme label. Liquid, ready-to-use reagents. Analyzed on VITROS 5,1 FS Chemistry System via spectrophotometry. Calibrators and controls derived from human urine. Standards referenced: CLSI EP9-A2, EP5-A, EP6-A, EP7-P, EP17-A, EP12-A.
Indications for Use
Indicated for professional laboratory use in the qualitative or semi-quantitative determination of barbiturates in human urine for the diagnosis and treatment of barbiturate use or overdose. Provides preliminary results requiring GC/MS confirmation.
Regulatory Classification
Identification
A barbiturate test system is a device intended to measure barbiturates, a class of hypnotic and sedative drugs, in serum, urine, and gastric contents. Measurements obtained by this device are used in the diagnosis and treatment of barbiturate use or overdose and in monitoring levels of barbiturate to ensure appropriate therapy.
Special Controls
*Classification.* Class II (special controls). A barbiturate test system is not exempt if it is intended for any use other than employment or insurance testing or is intended for Federal drug testing programs. The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9, provided the test system is intended for employment and insurance testing and includes a statement in the labeling that the device is intended solely for use in employment and insurance testing, and does not include devices intended for Federal drug testing programs (*e.g.,* programs run by the Substance Abuse and Mental Health Services Administration (SAMHSA), the Department of Transportation (DOT), and the U.S. military).
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1
510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
ASSAY ONLY TEMPLATE
A. 510(k) Number:
k062165
B. Purpose for Submission:
New device
C. Measurand:
Barbiturates
D. Type of Test:
Qualitative and semi-quantitative enzyme immunoassay
E. Applicant:
Ortho-Clinical Diagnostics, Inc.
F. Proprietary and Established Names:
VITROS Chemistry Products BARB Reagent
VITROS Chemistry Products Calibrator 26
VITROS Chemistry Products FS Calibrator 1
VITROS Chemistry Products DAT Performance Verifiers I, II, III, IV and V
G. Regulatory Information:
1. Regulation section:
21 CFR 862.3150, Barbiturates test system
21 CFR 862.3200, Clinical Toxicology Calibrator
21 CFR 862.3180, Clinical Toxicology Control
2. Classification:
Class II, (reagent, calibrator)
Class I, reserved (control)
3. Product code:
DIS, DLJ and DIF
4. Panel:
Toxicology (91)
{1}
H. Intended Use:
1. Intended use(s):
See Indications for use.
2. Indication(s) for use:
VITROS Chemistry Products BARB Reagent: For in vitro diagnostic use only. VITROS Chemistry Products BARB Reagent is used on VITROS 5,1 FS Chemistry Systems for the semi-quantitative or qualitative determination of barbiturates (BARB) in human urine using a cutoff of 200 ng/mL or 300 ng/mL. Measurements obtained with the VITROS BARB method are used in the diagnosis and treatment of barbiturates use or overdose.
The VITROS Chemistry Products BARB assay is intended for use by professional laboratory personnel. It provides only a preliminary test result. A more specific alternative chemical method must be used to confirm a result with this assay. Gas Chromatography/Mass Spectrometry (GC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug-of-abuse test result, particularly when evaluating a preliminary positive result.
VITROS Chemistry Products Calibrator Kit 26: For in vitro diagnostic use only.
VITROSChemistry Products Calibrator Kit 26 is used to calibrate VITROS 5,1 FS Chemistry Systems for the qualitative or semi-quantitative measurement of drugs of abuse.
VITROS Chemistry Products DAT Performance Verifiers I, II, III, IV & V: For in vitro diagnostic use only. VITROS Chemistry Products DAT Performance Verifiers are assayed controls used to monitor performance of urine drugs of abuse screening assays on VITROS 5,1 FS Chemistry Systems.
3. Special conditions for use statement(s):
For use by professional laboratory personnel. For in vitro diagnostic use only.
4. Special instrument requirements:
Ortho-Clinical Diagnostics VITROS 5,1 FS Chemistry System
I. Device Description:
The VITROS Chemistry Products BARB Reagent consists of two dual chambered reagent packs containing two ready-to-use liquid reagents. The reactive ingredients in Reagent 1 include sheep polyclonal antibodies reactive to secobarbital, Glucose 6-phosphate and Nicotinamide adenine nucleotide (NAD). The other ingredients in Reagent 1 include inorganic salt, organic salt, inorganic polymer, protease inhibitor, surfactant and preservative. The reactive ingredients in Reagent 2 include secobarbital labeled with glucose-6-phosphate dehydrogenase. The other ingredients in Reagent 2 include buffers, organic salt, inorganic salt, proteins, protease inhibitors, biological material, surfactant and preservatives.
VITROS Chemistry Products Calibrator Kit 26 is prepared from human urine to which drugs of abuse,
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metabolites of drugs of abuse, organic salts, surfactants and preservative have been added. VITROS Chemistry Products FS Calibrator 1 is prepared from sodium chloride and processed water. These products are used to calibrate VITROS 5,1 FS Chemistry Systems for the qualitative and semi-quantitative measurement of barbiturates (BARB).
VITROS DAT Performance Verifiers I, II, III, IV & V are prepared from a human urine pool to which analytes, surfactant and preservative have been added. These are assayed controls used to monitor performance of VITROS BARB Reagent on VITROS 5,1 FS Chemistry Systems.
The product labeling for the calibrator and controls contain warnings regarding the presence of human sourced materials and recommend the use of Universal Precautions when handling these products.
## J. Substantial Equivalence Information:
1. Predicate device name(s):
Syva EMIT II Plus Barbiturate assay
Bio-Rad Liquicheck Urine Toxicology Controls
2. Predicate 510(k) number(s):
k993987
k022707
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Intended Use | For use in the semi-quantitative or qualitative determination of barbiturates in human urine. | Same |
| Reagent | Liquid, ready to use | Same |
| Principle | Homogeneous enzyme immunoassay | Same |
| Matrix | Urine | Same |
| Antibody | Sheep polyclonal | Same |
| Differences | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Instrumentation | VITROS 5,1 FS Chemistry Systems | Multiple automated clinical chemistry analyzers |
| Calibrators | 6 levels | Qualitative: 3 levels
Semi-quantitative: 5 levels |
| Controls: Number of levels | 5 levels | Two levels |
## K. Standard/Guidance Document Referenced (if applicable):
CSLI EP9-A2: Method Comparison and Bias Estimation Using Patient Samples
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CLSI EP5-A: Evaluation of Precision Performance of Clinical Chemistry Devices
CLSI EP6-A: Evaluation of the Linearity of Quantitative Measurement Procedures, A Statistical Approach
CLSI EP7-P: Interference Testing in Clinical Chemistry
CLSI EP17-A: Protocols for Demonstration, Verification and Evaluation of Limits of Detection and Quantitation
CLSI EP12-A: User Protocols for Evaluation of Qualitative Test Performance
## L. Test Principle:
The VITROS BARB assay is a homogenous immunoassay based on the competition between barbiturates in the treated urine sample and secobarbital labeled with the enzyme glucose-6-phosphate dehydrogenase (G6P-DH) for antibody binding sites. Enzyme activity decreases upon binding to the antibody, therefore the concentration of barbiturates in the urine sample is directly proportional to measured enzyme activity. Active enzyme converts oxidized nicotinamide adenine dinucleotide $(\mathrm{NAD}^{+})$ to NADH, resulting in an absorbance change that is measured spectrophotometrically.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Semi-quantitative precision was assessed with quality control materials on the VITROS 5,1 FS Chemistry System following CLSI Protocol EP5 and EP12. The samples were run in duplicate, twice a day for twenty-two days using two reagent lots and four instruments. Each run consisted of five control fluids to assess assay imprecision at approximately $\pm 25\%$ of the 200 and $300~\mathrm{ng/mL}$ cutoff concentrations. The results are presented in the table below.
| Mean Conc. ng/mL | Within-Day SD | Within-Lab SD | Within-Lab %CV | No. Observations |
| --- | --- | --- | --- | --- |
| 143 | 6.8 | 10.3 | 7.2 | 86 |
| 215 | 6.0 | 10.5 | 4.9 | 84 |
| 240 | 6.2 | 11.5 | 4.8 | 86 |
| 378 | 7.9 | 14.1 | 3.7 | 84 |
| 632 | 12.8 | 20.5 | 3.2 | 86 |
Qualitative imprecision was assessed using drug-spiked human urine pools with concentrations targeted at approximately $\pm 25\%$ of the 200 and $300~\mathrm{ng/mL}$ cutoff concentrations. The concentrations of the targeted test fluids were confirmed by GC/MS. The sponsor performed one to two runs per day with two replicates per run for 22 days using a single lot of reagent on one analyzer. The results are presented below:
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| Cutoff ng/mL | Test Fluid Concentration ng/mL | No. Observations | Number of Correct Results |
| --- | --- | --- | --- |
| 200 | 143 | 86 | 86/86 |
| 200 | 240 | 86 | 86/86 |
| 300 | 215 | 84 | 84/84 |
| 300 | 378 | 84 | 84/84 |
b. Linearity/assay reportable range:
The sponsor followed CLSI EP6-A: "Evaluation of the Linearity of Quantitative Analytical Methods; Approved Guideline" in determining the linear range of their device.
Number of reagent lots: 3
Replicates of each solution: 3
Two urine pools were prepared with barbiturate concentrations at the low (0 ng/mL) and high (1000 ng/mL) end of the calibration range. The two pools were mixed to give 13 admixtures of intermediate barbiturate concentrations. Linearity was evaluated using three assay reagent lots and comparing the measured results against the expected results from 13 pooled samples. A linear regression was performed and the results indicated acceptable linearity across the concentration range tested (3 - 890 ng/mL). The claimed reportable range of the VITROS BARB assay is 60 - 800 ng/mL.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The assigned values for the calibrators and controls are traceable to the Cerillant secobarbital standard catalogue S-005 and are verified by GC/MS.
Real time and accelerated stability studies were conducted; protocols and acceptance criteria were described and found to be acceptable. These studies support the sponsor's stability claims for the following products:
| Reagent | Storage | Stability* |
| --- | --- | --- |
| Unopened | 2-8°C | 12 months |
| Opened | On board analyzer, system tu | ≤14 days |
| Opened | On board analyzer, system tu | ≤30 minutes |
| Calibrator | Storage | Stability* |
| --- | --- | --- |
| Unopened | ≤18°C | 8 months |
| Opened | 2-8°C | 4 weeks |
| Controls | Storage | Stability* |
| --- | --- | --- |
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| Controls | Storage | Stability* |
| --- | --- | --- |
| Unopened | 2-8°C | 6 months |
| Opened | 2-8°C | 4 weeks |
*NOTE: Real time stability studies are ongoing.
d. Detection limit:
The detection limit was determined according to protocol recommendations in CLSI EP-17 on three different lots of reagent and one instrument platform. The claimed lower limit for VITROS BARB assay is $60\mathrm{ng / mL}$ .
e. Analytical specificity:
The sponsor conducted interference studies following CLSI EP7-A2. The substances listed in the table below were determined not to interfere in the two secobarbital concentrations tested, 200 and $300\mathrm{ng / mL}$ , up to the concentrations shown:
| Compound | Concentration Tested | |
| --- | --- | --- |
| | Conventional | SI |
| Ammonia | 570 mg/dL | 334.6 μmol/L |
| Ascorbic Acid | 500 mg/dL | 28.4 mmol/L |
| Bilirubin | 26 mg/dL | 444.6 μmol/L |
| Brompheniramine | 100,000 ng/mL | 313.2 μmol/L |
| Calcium | 30 mg/dL | 7.5 mmol/L |
| Ciprofloxacin | 100,000 ng/mL | 300.3 μmol/L |
| Citric acid | 100 mg/dL | 5.2 mmol/L |
| Cloxacillin | 100,000 ng/mL | 229.4μmol/L |
| creatinine | 300 mg/dL | 26.5 mmol/L |
| Desipramine | 100,000 ng/mL | 330.2 μmol/L |
| dextromethorphan | 100,000 ng/mL | 368.5 μmol/L |
| Dicyclomine | 100,000 ng/mL | 289.1 μmol/L |
| Dipethylpropione | 100,000 ng/mL | 487.1 μmol/L |
| Doxylamine | 100,000 ng/mL | 369.8 μmol/L |
| Ethacrylic acid | 100,000 ng/mL | 329.9 μmol/L |
| Ethanol | 780 mg/dL | 169.3 mmol/L |
| Glucose | 4000 mg/dL | 222 mmol/L |
| Hemoglobin | 500 mg/dL | 5 g/L |
| Human IgG | 200 mg/dL | 2 g/L |
| Human serum album | 200 mg/dL | 2 g/L |
| Imipramine | 10 mg/dL | 357 μmol/L |
| Indomethacin | 10 mg/dL | 280 μmol/L |
{6}
| Compound | Concentration Tested | |
| --- | --- | --- |
| | Conventional | SI |
| Iron | 100 ug/dL | 18 μmol/L |
| KCl | 1118 mg/dL | 150 mmol/L |
| l-hyoscyamine | 10 mg/dL | 346 μmol/L |
| Magnesium | 60 mg/dL | 24.7 mmol/L |
| Meperidine | 10 mg/dL | 404 μmol/L |
| Methoxyphenamine | 10 mg/dL | 558 μmol/L |
| Metronidazole | 10 mg/dL | 584 μmol/L |
| NaCl | 6000 mg/dL | 1027 mmol/L |
| Nylidrine | 10 mg/dL | 334 μmol/L |
| Ofloxacin | 10 mg/dL | 277 μmol/L |
| Oxalic acid | 300 mg/dL | 24 mmol/L |
| pH = 4 | | |
| pH = 9 | | |
| Phenytoloxamine | 10 mg/dL | 392 μmol/L |
| Phenylbutazone | 10 mg/dL | 324 μmol/L |
| Phosphate | 1420 mg/dL | 100 mmol/L |
| Promethazine | 10 mg/dL | 312 μmol/L |
| Propanolol | 10 mg/dL | 386 μmol/L |
| Pyruvate | 100 mg/dL | 11 mmol/L |
| Riboflavin | 2 mg/dL | 53 μmol/L |
| Tolmetin/tolectin | 10 mg/dL | 389 μmol/L |
| Trihexylphenidyl | 10 mg/dL | 296 μmol/L |
| Trimethobenzamide | 10 mg/dL | 257 μmol/L |
| Tripelannamine | 10 mg/dL | 392 μmol/L |
| Triprolidine | 10 mg/dl | 359 μmol/L |
| Tyramine | 10 mg/dL | 576 μmol/L |
| Urea | 3000 mg/dL | 500 mmol/L |
| Uric acid | 120 mg/dL | 7 mmol/L |
The sponsor determined that a high specific gravity does not interfere with the assay by evaluating the primary causes of high specific gravity: high concentrations of NaCl, protein and glucose in urine.
The specificity of VITROS BARB assay for common barbiturates and structurally similar compounds was determined by generating a dose response curve for each of the compounds and determining the approximate quantity of each compound that is equivalent in assay reactivity to a secobarbital 200 ng/mL and 300 ng/mL cutoff.
{7}
| Compound | Conc. equivalent to 200 ng/mL | Approx. % Cross-reactivity | Conc. equivalent to 300 ng/mL | Approx. % Cross-reactivity |
| --- | --- | --- | --- | --- |
| Alphenal | 100 | 200 | 230 | 130.2 |
| Talbutal | 188 | 106.7 | 311 | 96.5 |
| Secobarbital | 200 | 100 | 300 | 100 |
| Aprobarbital | 219 | 91.4 | 415 | 72.3 |
| Butabarbital | 238 | 84.2 | 472 | 63.5 |
| Butalbital | 263 | 76.2 | 472 | 63.5 |
| Pentobarbital | 281 | 71.1 | 472 | 63,5 |
| Cyclopentobarbital | 350 | 57.1 | 611 | 49.1 |
| Butobarbital | 375 | 53.3 | 864 | 34.7 |
| Amobarbital | 450 | 44.4 | 922 | 32.6 |
| Allobarbital | 563 | 35.6 | 1152 | 26.0 |
| Phenobarbital | 1000 | 20 | 3456 | 8.7 |
| Barbital | 1875 | 10.7 | 6106 | 4.9 |
| 5-ethyl-5-(4-hydroxyphenyl) barbituric acid | 2250 | 8.9 | 9792 | 3.1 |
| Thiopental | 6250 | 3.2 | 40320 | 0.7 |
f. Assay cut-off:
There is a description of the analytical performance of the device around the 200 ng/mL and 300 ng/mL cutoffs in section M.1.d. The test is designed to yield a positive result when the drug exceeds these cutoff concentrations in the urine sample.
2. Comparison studies:
a. Method comparison with predicate device:
A total of 102 human urine samples were assayed using the VITROS Chemistry Products BARB Reagent and GC/MS reference method. Percent agreement was evaluated at assay cutoff values of 200 ng/mL and 300ng/mL.
{8}
GC/MS Reference Method Comparison for BARB
| | | Commercial Method | | | | %Agreement | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Cutoff Value (ng/mL) | | Low Negative | Near Cutoff Negative | Near Cutoff Positive | High Positive | %Agreement Negative | %Agreement Positive | %Agreement Overall |
| 200 | | (<-50%) <100 ng/mL | (-50% to cutoff) 100-200 ng/mL | (cutoff to +50%) 200-300 ng/mL | (>+50%) >300 ng/mL | 68.4 | 100.0 | 82.4 |
| | VITROS Positive | 0 | 18 | 18 | 27 | | | |
| | VITROS Negative | 27 | 12 | 0 | 0 | | | |
| 300 | | (<-50%) <150 ng/mL | (-50% to cutoff) 150-300 ng/mL | (cutoff to +50%) 300-450 ng/mL | (>+50%) >450 ng/mL | 73.3 | 100.0 | 80.4 |
| | VITROS Positive | 1 | 19 | 11 | 16 | | | |
| | VITROS Negative | 41 | 14 | 0 | 0 | | | |
Summary of Discordant Samples: GC/MS
| 200 ng/mL Cutoff | VITROS BARB Assay (ng/mL) | GC/MS Reference Method (ng/mL) |
| --- | --- | --- |
| | 203 | 369 phenobarbital |
| | 208 | 408 phenobarbital |
| | 203 | 434 phenobarbital |
| | 204 | 451 phenobarbital |
| | 212 | 496 phenobarbital |
| | 201 | 520 phenobarbital |
| | 203 | 663 phenobarbital |
| | 213 | 803 phenobarbital |
| | 376 | 119 butalbital |
| | 352 | 170 butalbital |
| | 276 | 177 butalbital |
| | 286 | 185 butalbital |
| | 327 | 215 butalbital |
| | 305 | 221 butalbital |
| | 369 | 224 butalbital |
| | 351 | 236 butalbital |
| | 341 | 248 butalbital |
| 369 | 253 butalbital | |
Summary of Discordant Samples: GC/MS
| 300 ng/mL Cutoff | VITROS BARB Assay (ng/mL) | GC/MS Reference Method (ng/mL) |
| --- | --- | --- |
| | 376 | 119 butalbital |
| | 352 | 170 butalbital |
| | 327 | 215 butalbital |
| | 305 | 221 butalbital |
| | 369 | 224 butalbital |
| | 351 | 236 butalbital |
| | 341 | 248 butalbital |
| | 369 | 253 butalbital |
| | 334 | 308 butalbital |
| | 381 | 322 butalbital |
{9}
A total of 102 unaltered human urine samples were assayed on the device and a commercially available immunoassay method for barbiturates. Percent agreement was evaluated at assay cutoff values of 200 and 300 ng/mL. To challenge performance at the 200 ng/mL cutoff value, 25 of the 102 samples tested had concentrations within +/- 50% of the cutoff value, 10 samples below the cutoff value and 15 above the cutoff value. To challenge performance at the 300 ng/mL cutoff value, 54 of the 102 samples tested had concentrations within +/- 50% of the cutoff value, 25 samples below the cutoff value and 29 above the cutoff value.
Commercial Method Comparison for BARB
| | | Commercial Method | | | | %Agreement | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Cutoff Value (ng/mL) | | Low Negative | Near Cutoff Negative | Near Cutoff Positive | High Positive | %Agreement Negative | %Agreement Positive | %Agreement Overall |
| 200 | | (<-50%) <100 ng/mL | (-50% to cutoff) 100-200 ng/mL | (cutoff to +50%) 200-300 ng/mL | (>+50%) >300 ng/mL | 100.0 | 94.0 | 96.1 |
| | VITROS Positive | 0 | 0 | 11 | 52 | | | |
| | VITROS Negative | 25 | 10 | 4 | 9 | | | |
| 300 | | (<-50%) <150 ng/mL | (-50% to cutoff) 150-300 ng/mL | (cutoff to +50%) 300-450 ng/mL | (>+50%) >450 ng/mL | 100.0 | 90.4 | 95.1 |
| | VITROS Positive | 0 | 0 | 24 | 23 | | | |
| | VITROS Negative | 25 | 25 | 5 | 0 | | | |
b. Matrix comparison:
Not applicable
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable
{10}
b. Clinical specificity:
Not applicable
c. Other clinical supportive data (when a. and b. are not applicable):
Not applicable
4. Clinical cut-off:
Not applicable
5. Expected values/Reference range:
Not applicable.
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
11
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Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
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.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
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.