The Ameditech ImmuTest Multi-Drug Screen BUP/PPX/COC150 is an in vitro screen test device for the qualitative detection of multi-drugs in human urine. The cutoff concentrations for this panel test are as follows: Buprenorphine (BUP) 10 ng/ml, Propoxyphene (PPX) 300 ng/ml, Cocaine metabolite (COC150) 150 ng/ml. This test uses multiple test strips in card format (test strips are placed in a card strip holder), cassette format (test strips are placed in a cassette strip holder), and cup format (test strips are placed in a lid strip holder). This test is used to obtain a visual, qualitative result and is intended for professional and laboratory use. This assay provides only a preliminary result. Clinical consideration and professional judgment must be applied to any drug of abuse test result, particularly in evaluating a preliminary positive result. In order to obtain a confirmed analytical result, a more specific alternate chemical method is needed. Gas Chromatography/Mass Spectroscopy (GC/MS) is the preferred confirmation method.
Device Story
Device is a lateral flow immunochromatographic test for qualitative detection of buprenorphine, propoxyphene, and cocaine metabolite in human urine; utilizes competitive binding principle. Input is human urine sample; output is visual colored line indicating presence or absence of drug. Used in professional/laboratory settings; operated by healthcare professionals. If drug concentration is below cutoff, antibody-coated particles bind to immobilized drug-specific conjugate, forming a visible line (negative result). If drug is present above cutoff, it saturates antibody binding sites, preventing line formation (positive result). Control line confirms proper sample volume and migration. Results are preliminary; requires GC/MS confirmation for clinical decision-making. Benefits include rapid, point-of-care screening for drug abuse.
Clinical Evidence
No clinical data provided; bench testing only.
Technological Characteristics
Lateral flow immunochromatographic assay; competitive binding principle. Formats: card, cassette, cup with drug-specific test strips (50-59 mm). No electronic components; visually read. Internal control line for sample volume/migration. No specific materials or standards cited.
Indications for Use
Indicated for professional use for the qualitative detection of buprenorphine, propoxyphene, and cocaine metabolites in human urine at specified cutoff concentrations (10 ng/ml, 300 ng/ml, and 150 ng/ml respectively). Provides preliminary analytical test results.
Regulatory Classification
Identification
An opiate test system is a device intended to measure any of the addictive narcotic pain-relieving opiate drugs in blood, serum, urine, gastric contents, and saliva. An opiate is any natural or synthetic drug that has morphine-like pharmocological actions. The opiates include drugs such as morphine, morphine glucoronide, heroin, codeine, nalorphine, and meperedine. Measurements obtained by this device are used in the diagnosis and treatment of opiate use or overdose and in monitoring the levels of opiate administration to ensure appropriate therapy.
Special Controls
*Classification.* Class II (special controls). An opiate 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).
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY DEVICE ONLY TEMPLATE
A. 510(k) Number:
k063015
B. Purpose of the Submission:
New device
C. Analyte:
Buprenorphine, Propoxyphene, and Cocaine metabolite
D. Type of Test:
Qualitative lateral flow immunochromatographic test, visually read
E. Applicant:
Ameditech, Inc.
F. Proprietary and Established Names:
ImmuTest Multi-Drug Screen BUP/PPX/COC150 (card, cassette, and cup format)
G. Regulatory Information:
1. Regulation section:
862.3650, Enzyme Immunoassay, Opiate test system
862.3700, Enzyme Immunoassay, Propoxyphene test system
862.3250, Enzyme Immunoassay, Cocaine and Cocaine metabolite test system
2. Classification:
Class II, DJG, JXN, DIO
3. Panel:
Toxicology (91)
H. Intended Use:
1. Intended use(s):
See Indications for use below.
2. Indication(s) for use:
The Ameditech ImmuTest Multi-Drug Screen BUP/PPX/COC150 is an in vitro screen test device for the qualitative detection of multi-drugs in human urine. The cutoff concentrations for this panel test are as follows:
| Test name | Calibrator | Cutoff (ng/ml) |
| --- | --- | --- |
| Buprenorphine (BUP) | Buprenorphine | 10 |
| Propoxyphene (PPX) | Propoxyphene | 300 |
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Cocaine metabolite (COC150)
Benzoylecgonine
150
This test uses multiple test strips in card format (test strips are placed in a card strip holder), cassette format (test strips are placed in a cassette strip holder), and cup format (test strips are placed in a lid strip holder).
This test is used to obtain a visual, qualitative result and is intended for professional and laboratory use.
This assay provides only a preliminary result. Clinical consideration and professional judgment must be applied to any drug of abuse test result, particularly in evaluating a preliminary positive result. In order to obtain a confirmed analytical result, a more specific alternate chemical method is needed. Gas Chromatography/Mass Spectroscopy (GC/MS) is the preferred confirmation method.
3. Special condition for use statement(s):
For prescription use only
4. Special instrument Requirements:
Not applicable, as the device is a visually read single-use device.
I. Device Description:
The ImmuTest Multi-Drug Screen BUP/PPX/COC150 consists of drug test strips and a plastic test strip holder. Each test strip detects one drug. The ImmuTest Multi-Drug Screen BUP/PPX/COC150 has three types of test formats: card format (test strips are placed in card strip holders), cassette (test strips are placed in cassette strip holders) and cup format (test strips are placed in lid strip holders). The length of the test strips is 59 mm for cassette and card format, and 50 mm for cup format.
J. Substantial Equivalence Information:
1. Predicate device name(s):
QuikStrip OneStep Buprenorphine Test
ACON One-Step Propoxyphene Test Device
ACON One-Step Cocaine-150 Test Strip
2. Predicate K number(s):
k042988, k040445 and k032903
3. Comparison with predicate:
The device is similar to or the same as the previously cleared predicate(s) in the following ways: test principles, indication for use, cut-off concentrations(s), used in a professional and point-of-care setting and sample matrix. The candidate device and the predicates are both visually-read single use devices.
K. Standard/Guidance Document Referenced (if applicable):
The sponsor did not reference any standards or guidance documents in this submission.
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# L. Test Principle:
The device employs lateral flow immunochromatographic technology and is based on the principle of competitive binding. Drugs, if present in concentrations below the cutoff level, will not saturate the binding sites of the antibody coated particles on the drug specific test strips. The antibody-coated particles will then be captured by immobilized drug-specific conjugate and a colored line will appear in the control region and the test region. If the sample contains drugs above the cutoff level, a colored line will not appear in the strips test region. Binding of drug in the sample causes the absence of a line at the test area, i.e., a positive result. When drug is not present in the sample, the drug-labeled conjugate binds at the test line, resulting in formation of a line, i.e., a negative result. Formation of a colored line in the control region indicates that the proper volume of urine has been added. If a colored line does not appear in the controls region, the test result is inconclusive and should be repeated. The absence or presence of the line is determined visually by the operator.
# M. Performance Characteristics (if/when applicable):
# 1. Analytical performance:
# a. Precision/Reproducibility:
Precision was determined by conducting a lot-to-lot precision study and also by conducting a four site precision study.
The lot-to-lot precision study used drug free urine and urine samples containing drug at the cutoff, $50\%$ below the cutoff, $25\%$ below the cutoff, $25\%$ above the cutoff and $50\%$ above the cutoff. The samples were tested with three lots of the ImmuTest Multi-Drug Screen BUP/PPX/COC150 test format (cassette, card and cup formats) for 3 consecutive days. 10 samples for each of the 6 concentrations were tested daily for each lot. One lot per day for 3 days produced a total of 540 specimens per drug. All samples used were drug free urine spiked with the drugs listed below in the chart. All sample concentrations were confirmed by GC/MS. The results are summarized in the table below:
Table 1: Lot-to-lot assay precision:
| Drug | Conc. (ng/ml) | Card format | | | Cassette format | | | Cup format | | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | Lot 1 (+/-) | Lot 2 (+/-) | Lot 3 (+/-) | Lot 1 (+/-) | Lot 2 (+/-) | Lot 3 (+/-) | Lot 1 (+/-) | Lot2 (+/-) | Lot 3 (+/-) |
| BUP Cut-off | 0 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 |
| | 5 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 |
| | 7.5 | 6/24 | 8/22 | 9/21 | 7/23 | 8/11 | 6/24 | 7/23 | 9/21 | 6/24 |
| | 10 | 17/13 | 18/12 | 16/14 | 17/13 | 20/10 | 17/13 | 19/11 | 16/14 | 18/12 |
| | 12.5 | 24/6 | 22/8 | 21/9 | 24/6 | 26/4 | 23/7 | 22/8 | 24/6 | 23/7 |
| | 15 | 30/0 | 30/0 | 30/0 | 30/0 | 30/0 | 30/0 | 30/0 | 30/0 | 30/0 |
| | 0 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 | 0/30 |
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The results from this study showed that the sample solutions at $0\mathrm{ng / ml}$ (drug-free urine sample) and $50\%$ below cut-off were all identified as negatives and the sample solutions at $50\%$ above cut-off were all identified as positives. The results demonstrated that the performance for the cup and cassette devices were same as that for card device.
The assay precision of the ImmuTest Multi-drug screen was also evaluated by different users from 4 sites. Three sites were external and one site was in-house at Ameditech. The testing was conducted for 3 days and totaled 90 samples per drug. All samples used were drug free urine spiked with the drugs listed below in the chart. All sample concentrations were confirmed by GC/MS. The results are summarized in the table below:
Table 2: Four sites precision study
| Drug | Conc. | VH (+/-) | PVH (+/-) | SM (+/-) | Ameditech (+/-) | Total (+/-) |
| --- | --- | --- | --- | --- | --- | --- |
| Buprenorphine | 0 | 0/15 | 0/15 | 0/15 | 0/90 | 0/135 |
| BUP | 5 | 0/15 | 0/15 | 0/15 | 0/90 | 0/135 |
| | 7.5 | 3/12 | 5/10 | 2/13 | 22/68 | 30/105 |
| Cut-off | 10 | 6/9 | 9/6 | 7/8 | 46/44 | 69/66 |
| | 12.5 | 11/4 | 12/3 | 11/4 | 66/24 | 98/37 |
| | 15 | 15/0 | 15/0 | 15/0 | 90/0 | 135/0 |
| Propoxyphene | 0 | 0/15 | 0/15 | 0/15 | 0/90 | 0/135 |
| PPX | 150 | 0/15 | 0/15 | 0/15 | 0/90 | 0/135 |
| | 225 | 4/11 | 3/12 | 4/11 | 20/70 | 31/104 |
| Cut-off | 300 | 9/6 | 9/6 | 7/8 | 48/42 | 74/61 |
| | 375 | 12/3 | 11/4 | 10/5 | 63/27 | 100/35 |
| | 450 | 15/0 | 15/0 | 15/0 | 90/0 | 135/0 |
| Cocaine metabolite | 0 | 0/15 | 0/15 | 0/15 | 0/90 | 0/135 |
| COC150 | 75 | 0/15 | 0/15 | 0/15 | 0/90 | 0/135 |
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| | 112.5 | 2/13 | 4/11 | 3/12 | 20/70 | 27/108 |
| --- | --- | --- | --- | --- | --- | --- |
| Cut-off | 150 | 6/9 | 8/7 | 9/6 | 53/37 | 72/63 |
| | 187.5 | 10/5 | 11/4 | 12/13 | 66/24 | 101/34 |
| | 225 | 15/0 | 15/0 | 15/0 | 90/0 | 135/0 |
The results from this study showed that the sample solutions at 0 ng/ml (drug-free urine sample) and 50% below cut-off were all identified as negatives and the sample solutions at 50% above cut-off were all identified as positives by all study sites.
b. Linearity/assay reportable range:
Not applicable. The assay is intended for qualitative use.
c. Traceability (controls, calibrators, or method):
This device has internal process controls. A visible line appearing in the control region confirms that sufficient sample volume and that the correct technique has been used. In the labeling, users are instructed not to interpret the test if a visible line failed to appear in the control region. Controls are not supplied with this device. The presence of the control line serves as a built-in control, which indicates that the proper sample volume has been used and the reagents are migrating properly.
External controls are available from commercial sources to ensure proper kit performance. In the labeling the sponsor recommends that the external control values are within established limits and if the values of external control do not fall within established limits, the test results are invalid.
d. Detection limit:
Sensitivity of this assay is characterized by validating performance around the claimed cutoff concentration of the assay, including a determination of the lowest concentration of drug that is capable of producing a positive result. The sponsor tested the device to determine the analytical sensitivity at and around the designated cutoff concentrations. Drug free urine and urine samples containing drug at the cutoff, 50% below the cutoff, 25% below the cutoff, 25% above the cutoff and 50% above the cutoff were tested with three lots of the ImmuTest Multi-Drug Screen BUP/PPX/COC150 test format (Cassette card and cup formats) for 3 consecutive days. 10 samples for each of the 6 concentrations were tested daily for each lot. A total of 540 specimens cups were used for three lots, three days testing. All sample concentrations were confirmed by GC/MS analysis. The test results were independently interpreted by two readers. The results are summarized in the table below:
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| Drug | Conc. (ng/ml) | # Tested | Card Format | | Cassette Format | | Cup Format | |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| | | | A (+/-) | B (+/-) | A (+/-) | B (+/-) | A (+/-) | B (+/-) |
| Buprenorphine | 0 | 90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 |
| BUP | 5 | 90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 |
| Cut-off | 7.5 | 90 | 23/67 | 24/66 | 21/69 | 24/66 | 22/68 | 24/66 |
| | 10 | 90 | 51/39 | 54/36 | 54/36 | 51/39 | 53/37 | 52/38 |
| | 12.5 | 90 | 67/23 | 75/15 | 73/17 | 71/19 | 69/21 | 70/20 |
| | 15 | 90 | 90/0 | 90/0 | 90/0 | 90/0 | 90/0 | 90/0 |
| Propoxyphene | 0 | 90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 |
| PPX | 150 | 90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 |
| Cut-off | 225 | 90 | 23/67 | 22/68 | 23/67 | 25/65 | 25/65 | 21/69 |
| | 300 | 90 | 52/38 | 50/40 | 56/34 | 50/40 | 51/39 | 54/36 |
| | 375 | 90 | 70/20 | 71/19 | 69/21 | 66/24 | 72/18 | 69/21 |
| | 450 | 90 | 90/0 | 90/0 | 90/0 | 90/0 | 90/0 | 90/0 |
| Cocaine metabolite | 0 | 90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 |
| COC150 | 75 | 90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 | 0/90 |
| Cut-off | 112.5 | 90 | 24/66 | 23/67 | 27/63 | 24/66 | 23/67 | 22/68 |
| | 150 | 90 | 52/38 | 52/38 | 52/38 | 54/36 | 52/38 | 56/34 |
| | 187.5 | 90 | 72/18 | 73/17 | 70/20 | 66/24 | 73/17 | 71/19 |
| | 225 | 90 | 90/0 | 90/0 | 90/0 | 90/0 | 90/0 | 90/0 |
e. Analytical specificity:
The specificity for the ImmuTest Multi-Drug Screen BUP/PPX/COC150 (cassette format) was determined by testing various drugs, drug metabolites, and other compounds that are likely to be present in urine. All compounds were prepared in drug-free normal human urine.
The following compounds produce positive results when tested at levels greater than the concentrations listed below.
| Compound | Concentration (ng/ml) |
| --- | --- |
| Buprenorphine | |
| Buprenorphine-3-beta-D-glucuronide | 10 |
| Norbuprenorphine | 7.5 |
| Norbuprenorphine-3-beta-D-glucuronide | 25,000 |
| Codeine | 150 |
| Morphine | >100,000 |
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Nalorphine 10,000
## Propoxyphene
D-Propoxyphene 300
D-Norpropoxyphene 300
## Cocaine Metabolite
Benzoylecgonine 150
Cocaine 5,000
Ecgonine >100,000
Cocaethylene >100,000
Ecgonine methyl esters >100,000
## Interference Studies:
The following compounds were evaluated for potential positive and/or negative interference with the Multi-Drug Screen BUP/PPX/COC150 (cassette format). Drug controls at 50% below and 50% above cutoff levels, prepared in the Sensitivity Study section, were used in this study. All compounds were dissolved in the 50% below and 50% above cutoff controls and tested with ImmuTest Multi-Drug Screen BUP/PPX/COC150. An unaltered sample was used as a control. The interferents tested were at concentrations up to 100 µg/mL. The results of the interference study were showed in the tables below.
Results of the positive interference study are presented below:
| Compound | BUP | PPX | COC150 |
| --- | --- | --- | --- |
| Unaltered Drug Control | - | - | - |
| Acetaminophen | - | - | - |
| Acetone | - | - | - |
| Albumin | - | - | - |
| Ampicillin | - | - | - |
| Ascorbic Acid | - | - | - |
| Aspartame | - | - | - |
| Aspirin | - | - | - |
| Atropine | - | - | - |
| Benzocaine | - | - | - |
| Bilirubin | - | - | - |
| Caffeine | - | - | - |
| Chloroquine | - | - | - |
| (+)-Chlorpheniramine | - | - | - |
| (+/-)-Chlorpheniramine | - | - | - |
| Creatine | - | - | - |
| Dexbrompheniramine | - | - | - |
| Dextromethorphan | - | - | - |
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| Compound | BUP | PPX | COC150 |
| --- | --- | --- | --- |
| 4-Dimethylaminoantipyrine | - | - | - |
| Diphenhydramine | - | - | - |
| Dopamine | - | - | - |
| (+/-)-Ephedrine | - | - | - |
| Erythromycin | - | - | - |
| Ethanol | - | - | - |
| Furosemide | - | - | - |
| Glucose | - | - | - |
| Guaiacol Glyceryl Ether | - | - | - |
| Hemoglobin | - | - | - |
| Ibuprofen | - | - | - |
| (+/-)-Isoproterenol | - | - | - |
| Ketamine | - | - | - |
| Levorphanol | - | - | - |
| Lidocaine | - | - | - |
| (1R,2S)-(-)-N-Methyl-Ephedrine | - | - | - |
| (+)-Naproxen | - | - | - |
| Niacinamide | - | - | - |
| Nicotine | - | - | - |
| (+/-)-Norephedrine | - | - | - |
| Oxalic acid | - | - | - |
| Penicillin-G | - | - | - |
| Pheniramine | - | - | - |
| Phenothiazine | - | - | - |
| l-Phenylephrine | - | - | - |
| β-phenylethylamine | - | - | - |
| Procaine | - | - | - |
| Quinidine | - | - | - |
| Ranitidine | - | - | - |
| Riboflavin | - | - | - |
| Sodium Chloride | - | - | - |
| Sulindac | - | - | - |
| Theophylline | - | - | - |
| Tyramine | - | - | - |
Results of the negative interference study are presented below:
| Compound | BUP | PPX | COC150 |
| --- | --- | --- | --- |
| Unaltered Drug Control | + | + | + |
| Acetaminophen | + | + | + |
| Acetone | + | + | + |
| Dexamethasone | + | + | + |
| Dextrandazole | + | + | + |
| Dextrandose | + | + | + |
| Dextrandopimel | + | + | + |
| Dextrandophorone | + | + | + |
| Dextrandophorone | + | + | + |
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| Compound | BUP | PPX | COC150 |
| --- | --- | --- | --- |
| Albumin | + | + | + |
| Ampicillin | + | + | + |
| Ascorbic Acid | + | + | + |
| Aspartame | + | + | + |
| Aspirin | + | + | + |
| Atropine | + | + | + |
| Benzocaine | + | + | + |
| Bilirubin | + | + | + |
| Caffeine | + | + | + |
| Chloroquine | + | + | + |
| (+)-Chlorpheniramine | + | + | + |
| (+/-)-Chlorpheniramine | + | + | + |
| Creatine | + | + | + |
| Dexbrompheniramine | + | + | + |
| Dextromethorphan | + | + | + |
| 4-Dimethylaminoantipyrine | + | + | + |
| Diphenhydramine | + | + | + |
| Dopamine | + | + | + |
| (+/-)-Ephedrine | + | + | + |
| Erythromycin | + | + | + |
| Ethanol | + | + | + |
| Furosemide | + | + | + |
| Glucose | + | + | + |
| Guaiacol Glyceryl Ether | + | + | + |
| Hemoglobin | + | + | + |
| Ibuprofen | + | + | + |
| (+/-)-Isoproterenol | + | + | + |
| Ketamine | + | + | + |
| Levorphanol | + | + | + |
| Lidocaine | + | + | + |
| (1R,2S)-(-)-N-Methyl-Ephedrine | + | + | + |
| (+)-Naproxen | + | + | + |
| Niacinamide | + | + | + |
| Nicotine | + | + | + |
| (+/-)-Norephedrine | + | + | + |
| Oxalic acid | + | + | + |
| Penicillin-G | + | + | + |
| Pheniramine | + | + | + |
| Phenothiazine | + | + | + |
| l-Phenylephrine | + | + | + |
| β-phenylethylamine | + | + | + |
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| Compound | BUP | PPX | COC150 |
| --- | --- | --- | --- |
| Procaine | + | + | + |
| Quinidine | + | + | + |
| Ranitidine | + | + | + |
| Riboflavin | + | + | + |
| Sodium Chloride | + | + | + |
| Sulindac | + | + | + |
| Theophylline | + | + | + |
| Tyramine | + | + | + |
# Urinary pH studies:
Sample solutions containing drug concentrations that were $50\%$ above and $50\%$ below the cutoff used in the sensitivity studies were adjusted for $\mathsf{pH}$ between the range of 4 to 9 in 1.0 increments using either $1.0\mathrm{N}$ HCl or $1.0\mathrm{N}$ NaOH solution. The $\mathsf{pH}$ adjusted sample solutions were tested in triplicate with the ImmuTest Multi-Drug Screen BUP/PPX/COC150. An unaltered sample was used as a control. The results are summarized in the table below:
| Drug | | Unaltered (+/-) | pH 4 (+/-) | pH 5 (+/-) | pH 6 (+/-) | pH 7 (+/-) | pH 8 (+/-) | pH 9 (+/-) |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| BUP | (-50%) | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 |
| | (+50%) | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 |
| PPX | (-50%) | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 |
| | (+50%) | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 |
| COC 150 | (-50%) | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 |
| | (+50%) | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 |
# Urinary Specific Gravity studies:
Sample solutions containing drug concentrations that were $50\%$ above and $50\%$ below the cutoff used in the sensitivity studies were adjusted to specific gravities that ranged from 1.003 to 1.04. Specific Gravity was determined by the weight of the sample solution divided by the volume $(\mathrm{g / mL})$ . The specific gravity adjusted samples were tested in triplicate with the ImmuTest Multi-Drug Screen BUP/PPX/COC150. An unaltered sample was used as a control. The results are summarized in the table below:
| Drug | | Unaltered (+/-) | SG 1.003 (+/-) | SG 1.02 (+/-) | SG 1.03 (+/-) | SG 1.04 (+/-) |
| --- | --- | --- | --- | --- | --- | --- |
| BUP | (-50%) | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 |
| | (+50%) | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 |
| PPX | (-50%) | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 |
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| | (+50%) | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 |
| --- | --- | --- | --- | --- | --- | --- |
| COC15 0 | (-50%) | 0/3 | 0/3 | 0/3 | 0/3 | 0/3 |
| | (+50%) | 3/0 | 3/0 | 3/0 | 3/0 | 3/0 |
f. Assay cut-off:
The Substance Abuse and Mental Health Services Administration (SAMHSA) has not recommended a cut-off concentration for Buprenorphine and Propoxyphene. The cut-offs for those drugs were chosen based on the levels used by predicate devices. SAMHSA has recommended a cutoff concentration for cocaine metabolite at 300 ng/mL and the ImmuTest Multi-Drug Screen BUP/PPX/COC150 has a cutoff at 150ng/mL for cocaine metabolite. Characterization of how the device performs analytically around the claimed cutoff concentration appears in the precision section above.
2. Comparison studies:
a. Method comparison with predicate device and GC/MS:
The ImmuTest Multi-Drug Screen BUP/PPX/COC150 device was compared to the commercially available drug screen tests (New Bay Bioresearch QuikStrip One Step BUP test, ACON One-step PPX test, and ACON COC150 One Step Cocaine test). Sixty (60) negative urine samples collected from presumed non-user volunteers were tested by both ImmuTest Multi-Drug Screen BUP/PPX/COC150 and commercially available drug screen tests. Of these negative urine samples tested, all were found negatives by both methods. In a separate study, clinical urine samples obtained from clinical testing laboratories where they were analyzed by GC/MS were tested by both Multi-Drug Screen BUP/PPX/COC150 device and commercially available drug screen tests.
A total of 270 samples were obtained from clinical testing laboratories. An additional 39 diluted samples were also included and were prepared by diluting positive samples with negative urine. This was done in order to obtain more samples near the cutoff concentrations. The results are summarized in the tables below:
Candidate device vs. Predicate device:
| | | | Predicate device | | % Agreement with Predicate device |
| --- | --- | --- | --- | --- | --- |
| Test | | | Positive | Negative | |
| BUP | ImmuTest | Positive | 43 | 0 | 100 |
| | | Negative | 0 | 85 | 100 |
| PPX | ImmuTest | Positive | 68 | 2 | 100 |
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| | | Negative | 0 | 74 | 97.5 |
| --- | --- | --- | --- | --- | --- |
| COC150 | ImmuTest | Positive | 68 | 0 | 98.6 |
| | | Negative | 1 | 84 | 100 |
Candidate device vs. GC/MS:
| ImmuTest Multi-Drug Screen BUP/PPX/CO C150 | GC/MS Negative | GC/MS Near Cutoff Negative (between -50% Cutoff and Cutoff) | GC/MS Near Cutoff Positive (between Cutoff and +50% Cutoff) | GC/MS Positive (greater than +50% Cutoff) | Percent Agreement with GC/MS |
| --- | --- | --- | --- | --- | --- |
| BUP | 0 | 5-8 ng/mL | 11-15 ng/mL | 16-890 ng/mL | % Agreement |
| Positive | 0 | 0 | 8 | 35 | 97.7 |
| Negative | 18 | 6 | 1 | 0 | 100 |
| PPX | 0 | 150-250 ng/mL | 310-445 ng/mL | 500-55,752 ng/mL | % Agreement |
| Positive | 0 | 0 | 6 | 64 | 98.6 |
| Negative | 10 | 7 | 1 | 0 | 100 |
| COC150 | 0 | 75-140 ng/mL | 170-223 ng/mL | 228-33,770 ng/mL | % Agreement |
| Positive | 0 | 1 | 7 | 60 | 100 |
| Negative | 15 | 10 | 0 | 0 | 96.2 |
## b. Matrix comparison:
Not applicable. The assay is intended for only one sample matrix.
## 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:
No elicit drugs should be present in urine.
## N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
{12}
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
13
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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.