VITROS CHEMISTRY PRODUCTS METD REAGENT, CALIBRATOR KIT 26, DAT PERFORMANCE, VERIFIERS I, II, III, IV & V
K062637 · Ortho-Clinical Diagnostics, Inc. · DJR · Nov 22, 2006 · Clinical Toxicology
Device Facts
Record ID
K062637
Device Name
VITROS CHEMISTRY PRODUCTS METD REAGENT, CALIBRATOR KIT 26, DAT PERFORMANCE, VERIFIERS I, II, III, IV & V
Applicant
Ortho-Clinical Diagnostics, Inc.
Product Code
DJR · Clinical Toxicology
Decision Date
Nov 22, 2006
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3620
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K062637 · Nov 22, 2006
VITROS CHEMISTRY PRODUCTS METD REAGENT, CALIBRATOR KIT 26, DAT PERFORMANCE, VERIFIERS I, II, III, IV & V
Ortho-Clinical Diagnostics, Inc.
Patient urine samples
Patient urine samples were used to compare the performance of the VITROS METD assay against the predicate EMIT II Plus Methadone assay to demonstrate substantial equivalence.
EMIT II Plus Methadone assay on the OLYMPUS AU400 System
Performance agreement between the new VITROS METD assay and the predicate method
Indications for Use
VITROS Chemistry Products METD Reagent: For in vitro diagnostic use only. VITROS Chemistry Products METD Reagent is used on VITROS 5,1 FS Chemistry Systems for the semi-quantitative or qualitative determination of methadone (METD) in human urine using a cutoff of either 150 ng/mL or 300 ng/mL. Measurements obtained with the VITROS METD method are used in the diagnosis and treatment of methadone use or overdose. The VITROS Chemistry Products METD 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.
Device Story
VITROS Chemistry Products METD Reagent is a homogeneous enzyme immunoassay for methadone detection in human urine. Used on VITROS 5,1 FS Chemistry Systems; operated by professional laboratory personnel. Input: urine sample treated with surfactant (DAT Diluent 2). Principle: competitive binding between methadone in sample and enzyme-labeled methadone (G6P-DH) for antibody binding sites. Enzyme activity is inversely proportional to methadone concentration. Output: spectrophotometric absorbance change at 340 nm, converted to semi-quantitative or qualitative methadone concentration. Results are preliminary; require GC/MS confirmation. Clinical utility: aids diagnosis/treatment of methadone use or overdose.
Clinical Evidence
Performance of the VITROS METD assay was evaluated by comparing results against the EMIT II Plus Methadone assay on the OLYMPUS AU400 system. Results demonstrated good agreement between the two immunoassay methods. No clinical prospective or retrospective studies were required; equivalence was established via analytical performance comparison.
Indicated for the qualitative or semi-quantitative determination of methadone in human urine for the diagnosis and treatment of methadone use or overdose. Intended for use by professional laboratory personnel as a preliminary screening test.
Regulatory Classification
Identification
A methadone test system is a device intended to measure methadone, an addictive narcotic pain-relieving drug, in serum and urine. Measurements obtained by this device are used in the diagnosis and treatment of methadone use or overdose and to determine compliance with regulations in methadone maintenance treatment.
Special Controls
*Classification.* Class II (special controls). A methadone 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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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k062637
B. Purpose for Submission:
New product
C. Measurand:
Methadone
D. Type of Test:
Semi-quantitative and qualitative homogeneous enzyme immunoassay
E. Applicant:
Ortho-Clinical Diagnostic
F. Proprietary and Established Names:
VITROS Chemistry Products METD Reagent
VITROS Chemistry Products Calibrator Kit 26
VITROS Chemistry Products DAT Performance Verifiers I. II, III, IV, and V
G. Regulatory Information:
1. Regulation section:
21 CFR §862.3620, Methadone Test System
21 CFR §862.3200, Clinical Toxicology Calibrator
21 CFR §862.3280, Clinical Toxicology Control Material
2. Classification:
Class II (Reagent, Calibrator)
Class I, Reserved (Control)
3. Product code:
DJR; DKB; DIF
4. Panel:
Toxicology (91)
H. Intended Use:
1. Intended use(s):
See Indications for Use below.
2. Indication(s) for use:
VITROS Chemistry Products METD Reagent is used on VITROS 5,1 FS
Chemistry Systems for the semi-quantitative or qualitative determination of
methadone (METD) in human urine using a cutoff of either 150 ng/mL or 300
ng/mL. Measurements obtained with the VITROS METD method are used in the
diagnosis and treatment of methadone use or overdose.
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The VITROS Chemistry Products METD 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 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 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):
This device is for use by professional laboratory personnel. For in vitro diagnostic use only.
The VITROS Chemistry Products METD 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.
4. Special instrument requirements:
Ortho-Clinical Diagnostics VITROS 5,1 FS Chemistry System
I. Device Description:
The VITROS METD Reagent is a dual chambered package containing ready-to-use liquid reagents that are used to detect methadone in urine. Sample, calibrators, and controls are automatically treated with surfactant (DAT Diluent 2) prior to addition of reagents. Treated sample is added to Reagent 1 containing antibodies reactive to methadone, glucose-6-phosphate and nicotinamide adenine dinucleotide $(\mathrm{NAD}^{+})$ , followed by Reagent 2 containing methadone labeled with the enzyme glucose-6-phosphate dehydrogenase (G6P-DH).
VITROS Chemistry Products Calibrator Kit 26 is prepared from human urine to which drugs of abuse, metabolites of drugs of abuse, organic salts, surfactants and preservative have been added.
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 the VITROS METD Reagent on VITROS 5,1 FS Chemistry Systems.
The product labeling for the Calibrator Kit 26 and Performance Verifiers contain warnings regarding the presence of human sourced materials and recommend the use
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of Universal Precautions when handling these products.
## J. Substantial Equivalence Information:
1. Predicate device name(s):
EMIT II Plus Methadone Assay
Liquicheck Urine Toxicology Controls
2. Predicate 510(k) number(s):
k010962; k022707
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Intended Use | For use in the qualitative and semi-quantitative analysis of methadone 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 | Six levels | Four levels |
| Controls | Five levels | Two levels |
## K. Standard/Guidance Document Referenced (if applicable):
CSLI EP9-A2: Method Comparison and Bias Estimation Using Patient Samples
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 METD Reagent is a dual chambered package containing ready-to-use liquid reagents that are used to detect methadone in urine. Sample, calibrators, and controls are automatically treated with surfactant (DAT Diluent 2) prior to addition of reagents. Treated sample is added to Reagent 1 containing antibodies reactive to methadone, glucose-6-phosphate and nicotinamide adenine dinucleotide $(\mathrm{NAD}^{+})$,
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followed by Reagent 2 containing methadone labeled with the enzyme glucose-6-phosphate dehydrogenase (G6P-DH). The assay is based on competition between methadone in the treated urine sample and the methadone 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 methadone 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 at $340~\mathrm{nm}$ .
# M. Performance Characteristics (if/when applicable):
# 1. Analytical performance:
# a. Precision/Reproducibility:
Precision was evaluated with human urine-based quality control materials on the VITROS 5,1 FS Chemistry System following CLSI Protocol EP5 and CLSI protocol EP12.
Semi-Quantitative
| System | Conventional Units (ng/mL) and SI Units (μg/L) | | | Within Lab CV%** | No. Observ. | No. Days |
| --- | --- | --- | --- | --- | --- | --- |
| | Mean Conc. | Within Day SD* | Within Lab SD** | | | |
| VITROS 5,1 FS | 108 | 5.1 | 6.2 | 5.7% | 88 | 22 |
| | 149 | 5.7 | 6.8 | 4.6% | 87 | 22 |
| | 190 | 5.2 | 6.5 | 3.4% | 88 | 22 |
| | 233 | 4.8 | 6.6 | 2.8% | 88 | 22 |
| | 312 | 4.0 | 4.5 | 1.4% | 88 | 22 |
| | 377 | 4.0 | 5.6 | 1.5% | 88 | 22 |
| | 624 | 17.3 | 22.8 | 3.7% | 88 | 22 |
* Within Day imprecision was determined using two runs per day with two replications per run.
** Within Lab imprecision was determined using a single lot of reagents with one analyzer and five calibrations.
Qualitative imprecision was assessed using test fluids targeted at $\pm 25\%$ of each cutoff. The imprecision was determined as the confidence level of obtaining a correct result with known positive or negative fluids.
Qualitative*
| System | Cutoff Level (ng/mL & g/L) | Test Fluid at ±25% Cutoff | Number of Observations | Number of Correct Interpretations | Confidence Level |
| --- | --- | --- | --- | --- | --- |
| VITROS 5,1 FS | 150 | -25% | 88 | 88 | >95% negative reading |
| | 150 | +25% | 88 | 88 | >95% positive reading |
| | 300 | -25% | 88 | 88 | >95% negative reading |
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Qualitative*
| System | Cutoff Level (ng/mL & μg/L) | Test Fluid at ±25% Cutoff | Number of Observations | Number of Correct Interpretations | Confidence Level |
| --- | --- | --- | --- | --- | --- |
| | 300 | +25% | 88 | 88 | >95% positive reading |
* Determined using two runs per day with two replicates per run for 22 days, using a single lot of reagents with one analyzer and five calibrations
b. Linearity/assay reportable range:
The sponsor followed CLSI EP6-A in determining the linear range of their device. Two urine pools were prepared with methadone concentrations at the low (0 ng/mL) and high (1000 ng/mL) end of the calibration range. The two pools were mixed to give 14 admixtures of intermediate concentrations. Linearity was evaluated using two assay reagent lots and comparing the measured results against the expected results from 16 pooled samples. A linear regression was performed and the results indicated acceptable linearity across the methadone concentration range tested (12 to 736 ng/mL). The reportable range of the VITROS METD assay is 40-735 ng/mL.
Recovery of Semi-Quantitative Results
Eleven admixtures spanning the reportable range (40 to 735 ng/mL) were prepared from two human urine-based pools. Methadone values for the admixtures were calculated based on gravimetric addition of methadone with GC/MS verification of the high and low pools. Percent recovery was calculated using the concentration obtained by the VITROS Chemistry Products METD Assay versus the nominal methadone value.
Recovery of Methadone
| Nominal Methadone Concentration (ng/mL) | VITROS METD Assay (ng/mL) | % Recovery |
| --- | --- | --- |
| 56 | 53 | 94.8 |
| 75 | 74 | 99.3 |
| 100 | 98 | 98.4 |
| 150 | 150 | 100.0 |
| 200 | 204 | 102.2 |
| 250 | 255 | 101.9 |
| 300 | 297 | 99.0 |
| 375 | 370 | 98.8 |
| 500 | 489 | 97.8 |
| 625 | 632 | 101.1 |
| 700 | 693 | 99.1 |
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c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The assigned values for the calibrators and controls are traceable to the Cerilliant methadone standard catalogue M-110 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 manufacturer's stability claims. Real time studies are ongoing
d. Detection limit:
The detection limit was determined according to protocol recommendations in CLSI EP-17. The claimed lower limit for VITROS METD assay is $40\mathrm{ng / mL}$
e. Analytical specificity:
The specificity of the VITROS Chemistry Products METD assay for various methadone metabolites and structurally similar compounds was estimated by generating a dose-response curve for each of the compounds listed below. The quantity $(\mathrm{ng / mL})$ of a compound necessary to produce a value equivalent to the methadone quantity $(\mathrm{ng / mL})$ at each cutoff value is listed below. If a sample contains more than one compound detected by the assay, lower quantities of cross-reactant than those listed below may produce a value approximately equivalent to or greater than that of the cutoff value due to their combined effects.
Substances that Cross-react with METD
| Compound | Quantity (ng/mL) equivalent to 150 ng/mL of methadone | % cross-reactivity * | Quantity (ng/mL) equivalent to 300 ng/mL of methadone | % cross-reactivity * |
| --- | --- | --- | --- | --- |
| L-A-methadol | 302 | 49.67% | 2625 | 11.43% |
| LAMM | 385 | 38.96% | 5400 | 5.56% |
| thioridazine | 54,000 | 0.28% | >300,000 | <0.1% |
| EDDP | 171,000 | 0.09% | >300,000 | <0.1% |
| sertraline | 300,000 | 0.05% | >1,000,000 | <0.03% |
| EMDP | >300,000 | <0.05% | >300,000 | <0.1% |
* The VITROS METD Assay cutoff value (ng/mL) divided by the amount of cross-reactant (ng/mL) that produces a value equivalent to the cutoff value, multiplied by 100.
The substances listed in the table, at the concentrations shown, were tested according to CLSI Protocol EP7 and found not to interfere, bias $< 28 \mathrm{ng} / \mathrm{mL}$ at $150 \mathrm{ng} / \mathrm{mL}$ methadone and bias $< 57 \mathrm{ng} / \mathrm{mL}$ at $300 \mathrm{ng} / \mathrm{mL}$ methadone.
Substances that Do Not Interfere with METD
| Compound | Concentration | |
| --- | --- | --- |
| ammonia | 570 mg/dL | 316 mmol/L |
| ascorbic acid | 500 mg/dL | 28.4 mmol/L |
| bilirubin | 26 mg/dL | 444 μmol/L |
| calcium | 30 mg/dL | 7.5 mmol/L |
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Substances that Do Not Interfere with METD
| Compound | Concentration | |
| --- | --- | --- |
| ciprofloxacin | 10 mg/dL | 302 μmol/L |
| citric acid | 100 mg/dL | 5.2 mmol/L |
| cloxacillin | 10 mg/dL | 230 μmol/L |
| creatinine | 300 mg/dL | 26.5 mmol/L |
| diethylproprione | 10 mg/dL | 487 μmol/L |
| ethacrynic acid | 10 mg/dL | 330μmol/L |
| ethanol | 780 mg/dL | 169 mmol/L |
| glucose | 4000 mg/dL | 222 mmol/L |
| hemoglobin | 500 mg/dL | 5.00 g/L |
| human igg | 200 mg/dL | 2.00 g/L |
| human serum albumin | 200 mg/dL | 2.00 g/L |
| indomethacin | 10 mg/dL | 279 μmol/L |
| iron | 0.1 mg/dL | 17.9 μmol/L |
| potassium | 587 mg/dL | 150 mmol/L |
| magnesium | 60 mg/dL | 24.7 mmol/L |
| metronidazole | 10 mg/dL | 584 μmol/L |
| nylidrine | 10 mg/dL | 334 μmol/L |
| oxalic acid | 300 mg/dL | 23.8 mmol/L |
| ph = 4 | | |
| ph= 9 | | |
| phenylbutazone | 10 mg/dL | 324 μmol/L |
| phosphate | 950 mg/dL | 100 mmol/L |
| pyruvate | 200 mg/dL | 22.8 mmol/L |
| ranitidine hcl | 10 mg/dL | 318μmol/L |
| riboflavin | 2 mg/dL | 53 μmol/L |
| theophylline | 10 mg/dL | 555 μmol/L |
| tolmetin/tolectin | 10 mg/dL | 390 μmol/L |
| trimethobenzamide hcl | 10 mg/dL | 257 μmol/L |
| tyramine | 10 mg/dL | 576 μmol/L |
| urea | 3000 mg/dL | 499.5 mmol/L |
| uric acid | 120 mg/dL | 7.14 mmol/L |
f. Assay cut-off:
The stated cutoff of this assay is either 150ng/mL or 300 ng/mL.
2. Comparison studies:
a. Method comparison with predicate device:
A total of 140 human urine samples were assayed using the VITROS Chemistry Products METD Reagent and a commercially available immunoassay method. Percent agreement was evaluated at assay cutoffs of 150 and 300 ng/mL.
To challenge performance at the 150 ng/mL cutoff value, 43 of the 140 samples tested had concentrations within +/- 50% of the cutoff value.
To challenge performance at the 300 ng/mL cutoff value, 56 of the 140 samples tested had concentrations within +/- 50% of the cutoff value.
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Predicate Device Comparison - METD
| Cutoff Value (ng/mL) | | Commercial Negative | Commercial Positive | % Agreement | | |
| --- | --- | --- | --- | --- | --- | --- |
| | | | | % Agreement Negative | % Agreement Positive | % Agreement Overall |
| 150 | VITROS Positive | 1* | 91 | 98.0 | 100 | 99.3 |
| | VITROS Negative | 48 | 0 | | | |
| 300 | VITROS Positive | 1* | 48 | 98.9 | 100 | 99.3 |
| | VITROS Negative | 91 | 0 | | | |
*See Commercial Method Summary of Discordant Results below.
Summary of Discordant Results: Commercial Method
| Cutoff Value (ng/mL) | VITROS METD Assay (ng/mL) | Commercial Method (ng/mL) |
| --- | --- | --- |
| 150 | 199 | 149 |
| 300 | 310 | 291 |
A total of 139 human urine samples were assayed using the VITROS Chemistry Products METD Reagent and a GC/MS reference method for methadone. Percent agreement was evaluated at assay cutoff values of 150 and 300 ng/mL.
To challenge performance at the 150 ng/mL cutoff value, 59 of the 139 samples tested had concentrations within +/- 50% of the cutoff value.
To challenge performance at the 300 ng/mL cutoff value, 42 of the 139 samples tested had concentrations within +/- 50% of the cutoff value.
GC/MS Reference Method Comparison for METD
| | | GC/MS Reference Method | | | | % Agreement | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Cutoff Value (ng/mL) | | Low Negative | Near Cutoff Negative | Near Cutoff Positive | High Positive | % Agreement Negative | % Agreement Positive | % Agreement Overall |
| 150 | | (<-50%) <75 ng/mL | (-50% to cutoff) 75-150 ng/mL | (cutoff to +50%) 150-225 ng/mL | (>+50%) >225 ng/mL | 64.0 | 100 | 80.6 |
| | VITROS Positive | 1* | 26* | 18 | 46 | | | |
| | VITROS Negative | 33 | 15 | 0 | 0 | | | |
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GC/MS Reference Method Comparison for METD
| | | GC/MS Reference Method | | | | % Agreement | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Cutoff Value (ng/mL) | | Low Negative | Near Cutoff Negative | Near Cutoff Positive | High Positive | % Agreement Negative | % Agreement Positive | % Agreement Overall |
| 300 | | (<-50%) <150 ng/mL | (-50% to cutoff) 150-300 ng/mL | (cutoff to +50%) 300-450 ng/mL | (>+50%) >450 ng/mL | 87.5 | 100 | 90.6 |
| | VITROS Positive | 1* | 12* | 13 | 22 | | | |
| | VITROS Negative | 74 | 17 | 0 | 0 | | | |
*See GC/MS Summary of Discordant Results below
| Summary of Discordant Results: GC/MS | | | |
| --- | --- | --- | --- |
| Cutoff Value (ng/mL) | VITROS METD (ng/mL) | GC/MS (ng/mL) | Major Drug Present by GC/MS |
| 150 | 151 | 136 | Methadone |
| | 156 | 128 | |
| | 160 | 141 | |
| | 162 | 125 | |
| | 166 | 83 | |
| | 170 | 115 | |
| | 171 | 132 | |
| | 178 | 115 | |
| | 181 | 146 | |
| | 181 | 149 | |
| | 182 | 108 | |
| | 199 | 124 | |
| | 199 | <RR | |
| | 211 | 125 | |
| | 228 | 130 | |
| | 231 | 137 | |
| | 231 | 143 | |
| | 238 | 119 | |
| | 246 | 82 | |
| | 248 | 127 | |
| | 249 | 88 | |
| | 261 | 139 | |
| | 265 | 102 | |
| | 271 | 119 | |
| | 271 | 122 | |
| | 277 | 136 | |
| 310 | 112 | | |
| 300 | 310 | 112 | Methadone |
| | 310 | 284 | |
| | 314 | 269 | |
| | 316 | 223 | |
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| Summary of Discordant Results: GC/MS | | | |
| --- | --- | --- | --- |
| Cutoff Value (ng/mL) | VITROS METD (ng/mL) | GC/MS (ng/mL) | Major Drug Present by GC/MS |
| | 320 | 219 | |
| | 322 | 190 | |
| | 323 | 290 | |
| | 325 | 262 | |
| | 327 | 253 | |
| | 331 | 297 | |
| | 332 | 297 | |
| | 354 | 152 | |
| | 586 | 292 | |
b. Matrix comparison:
Not applicable; this device is for use with urine only.
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable.
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.
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6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
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.