LZI CANNABINOIDS (CTHC) HOMOGENEOUS ENZYME IMMUNOASSAY, CALIBRATORS, CONTROL
K110239 · Lin-Zhi International, Inc. · LDJ · Jun 23, 2011 · Clinical Toxicology
Device Facts
Record ID
K110239
Device Name
LZI CANNABINOIDS (CTHC) HOMOGENEOUS ENZYME IMMUNOASSAY, CALIBRATORS, CONTROL
Applicant
Lin-Zhi International, Inc.
Product Code
LDJ · Clinical Toxicology
Decision Date
Jun 23, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3870
Device Class
Class 2
Indications for Use
The LZI Cannabinoids (cTHC) Enzyme Immunoassay is intended for the qualitative and semi-quantitative determination of Cannabinoids in human urine using 11-nor-Δ⁹-THC-9-COOH (the major metabolite of THC referred to here as cTHC) as calibrator at the cutoff values of 25, 50, or 100 ng/mL. The assay is designed for prescription use with a number of automated clinical chemistry analyzers. The semi-quantitative mode is for purposes of (1) enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as GCMS or (2) permitting laboratories to establish quality control procedures. The Cannabinoids (cTHC) Drugs of Abuse (DOA) Calibrators are for use as calibrators in the qualitative and semi-quantitative calibration of the LZI Cannabinoids (cTHC) Enzyme Immunoassay. The Cannabinoids (cTHC) Drugs of Abuse (DOA) Controls are for use as assayed quality control materials to monitor the precision of the LZI Cannabinoids (cTHC) Enzyme Immunoassay. The assay provides only a preliminary analytical result. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas or liquid chromatography/mass spectrometry (GC/MS or LC/MS) is the preferred confirmatory methods. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.
Device Story
LZI Cannabinoids (cTHC) Enzyme Immunoassay is a homogeneous enzyme immunoassay for detecting cannabinoid metabolites in human urine. Input: human urine sample. Principle: competitive binding between drug in sample and drug-labeled G6PDH enzyme for fixed antibody sites. In absence of drug, antibody binds labeled enzyme; in presence of drug, antibody binds free drug, leaving labeled enzyme active. Enzyme activity measured spectrophotometrically at 340 nm via NAD to NADH conversion. Used in clinical laboratories on automated chemistry analyzers (e.g., Hitachi 717). Output: qualitative (positive/negative) or semi-quantitative (concentration estimate) result. Provides preliminary screening; requires GC/MS or LC/MS confirmation. Benefits: rapid screening for drug presence to guide clinical decision-making and laboratory dilution protocols.
Clinical Evidence
No clinical studies performed. Evidence consists of analytical bench testing: precision (CLSI EP5-A2, N=88 per cutoff), linearity/recovery, analytical specificity (cross-reactivity with related/unrelated compounds), and method comparison against GC/MS/LC/MS using clinical urine samples. Method comparison showed high agreement with confirmatory methods across all cutoffs.
Indicated for qualitative and semi-quantitative determination of cannabinoids (11-nor-A-THC-9-COOH) in human urine at 25, 50, or 100 ng/mL cutoffs. For prescription use in clinical laboratories to aid in drug screening; requires confirmatory testing (GC/MS or LC/MS) for positive results.
Regulatory Classification
Identification
A cannabinoid test system is a device intended to measure any of the cannabinoids, hallucinogenic compounds endogenous to marihuana, in serum, plasma, saliva, and urine. Cannabinoid compounds include delta-9-tetrahydrocannabinol, cannabidiol, cannabinol, and cannabichromene. Measurements obtained by this device are used in the diagnosis and treatment of cannabinoid use or abuse and in monitoring levels of cannabinoids during clinical investigational use.
Special Controls
*Classification.* Class II (special controls). A cannabinoid 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).
Predicate Devices
Lin-Zhi International, Inc. Cannabinoid (THC) Enzyme Immunoassay, Calibrators and Controls for Hitachi 717 Systems (k021887 & k021449)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k110239
B. Purpose for Submission:
New device
C. Measurand:
Cannabinoids
D. Type of Test:
Qualitative and semi-quantitative immunoassay
E. Applicant:
Lin-Zhi International, Inc.
F. Proprietary and Established Names:
LZI Cannabinoids (cTHC) Enzyme Immunoassay
LZI Cannabinoids (cTHC) Drugs of Abuse (DAU) Calibrators
LZI Cannabinoids (cTHC) Drugs of Abuse (DAU) Controls
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| LDJ | Class II | 21 CFR § 862.3870, Enzyme Immunoassay, Cannabinoids | 91-Toxicology |
| DLJ | Class II | 21 CFR § 862.3200, Calibrators, Drug specific | 91-Toxicology |
| LAS | Class I, reserved | 21 CFR 862.3280 Clinical Toxicology control material | 91-Toxicology |
H. Intended Use:
1. Intended use(s):
See Indications for use, below.
2. Indication(s) for use:
The LZI Cannabinoids (cTHC) Enzyme Immunoassay is intended for the qualitative and semi-quantitative determination of Cannabinoids in human urine using 11-nor-Δ⁹-THC-9-COOH (the major metabolite of THC
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referred to here as cTHC) as calibrator at the cutoff values of 25, 50, or 100 ng/mL. The assay is designed for prescription use with a number of automated clinical chemistry analyzers.
The semi-quantitative mode is for purposes of
(1) enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as GCMS or
(2) permitting laboratories to establish quality control procedures.
The Cannabinoids (cTHC) Drugs of Abuse (DOA) Calibrators are for use as calibrators in the qualitative and semi-quantitative calibration of the LZI Cannabinoids (cTHC) Enzyme Immunoassay.
The Cannabinoids (cTHC) Drugs of Abuse (DOA) Controls are for use as assayed quality control materials to monitor the precision of the LZI Cannabinoids (cTHC) Enzyme Immunoassay.
The assay provides only a preliminary analytical result. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas or liquid chromatography/mass spectrometry (GC/MS or LC/MS) is the preferred confirmatory methods. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.
3. Special conditions for use statement(s):
The assay is for in vitro prescription use only.
4. Special instrument requirements:
Performance data was provided for Hitachi 717 analyzer.
I. Device Description:
The LZI Cannabinoids (cTHC) Enzyme Immunoassay consists of two separately packaged reagents (R1 and R2):
| Reagent | Description |
| --- | --- |
| R1 | Contains mouse monoclonal anti-cannabinoid antibody, glucose-6-phosphate (G6P), nicotinamide adenine dinucleotide (NAD), and sodium azide as a preservative. |
| R2 | Contains cannabinoid derivative-labeled glucose-6-phosphate dehydrogenase (G6PDH) in buffer with sodium azide as a preservative. |
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The calibrators and controls are ready to use human urine-based liquid.
## J. Substantial Equivalence Information:
1. Predicate device names
Homogeneous enzyme immunoassay for the determination of cannabinoids (THC) level in urine
Cannabinoid Calibrators and Controls
2. Predicate 510(k) number(s):
k021887
k021449
3. Comparison with predicate:
| ITEM | The LZI Cannabinoids (cTHC) Enzyme Immunoassay
LZI Cannabinoids (cTHC) Drugs of Abuse (DAU) Calibrators
LZI Cannabinoids (cTHC) Drugs of Abuse (DAU) Controls | Homogeneous enzyme immunoassay for the determination of cannabinoids (THC) level in urine (021887)
Cannabinoid Calibrators (021449) |
| --- | --- | --- |
| Cutoff | 25, 50, and 100 ng/ml | 20, 50 and 100 |
| Intended Use | Qualitative and semi-quantitative analysis of cannabinoids in human urine | Same |
| Sample type | Human urine | Same |
| Type of reagent | Liquid ready to use
Two reagent assay | Same |
| Calibrators | Liquid ready to use (5 levels)
THC 25 : 0, 12.5, 25, 37.5, and 50 ng/mL
THC 50: 0, 25, 50, 75 and 100 ng/mL
THC 100: 0, 50, 100, 150, 200 ng/mL) | Liquid ready to use (5 levels) |
| Controls | Liquid ready to use (2 levels)
THC 25: 18.75, 31.25 ng/mL
THC 50: 37.5, 62.5 ng/mL
THC 100: 75, 125 ng/mL | Liquid ready to use (2 levels) |
## K. Standard/Guidance Document Referenced (if applicable):
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- CLSI Protocol EP5-A2: Evaluation of Precision Performance of Quantitative Method-Second Edition
# L. Test Principle:
The LZI Cannabinoids (cTHC) is an immunoassay with ready-to-use liquid reagent. The assay is based on competition between drug in the sample and drug labeled with the enzyme glucose-6-phosphate dehydrogenase (G6PDH) for a fixed amount of antibody in the reagent. In the absence of drug in the sample, the antibody binds the conjugated 11-nor- $\Delta^9$ -THC-9-COOH -labeled G6PDH. When free drug is present in the sample, the antibody will bind to the free drug and the unbound 11-nor- $\Delta^9$ -THC-9-COOH -labeled G6PDH exhibits its maximal enzyme activity. The G6PDH activity is measured spectrophotometrically at $340~\mathrm{nm}$ because of conversion of NAD to NADH.
# M. Performance Characteristics (if/when applicable):
# 1. Analytical performance:
# a. Precision/Reproducibility:
Precision was performed and evaluated according to the CLSI Document EP5-A2, Evaluation of Precision Performance of Quantitative Measurement Methods. The sponsor conducted precision studies on the Hitachi 717 analyzer using samples containing 11-nor- $\Delta^9$ -THC-9-COOH. Samples were prepared by spiking a negative human urine pool with 11-nor- $\Delta^9$ -THC-9-COOH for all three cutoff values. Samples were tested in 2 replicates per run, 2 runs per day for 22 days, total $N = 88$ . The qualitative and semi-quantitative results confirmed by GC/MS for the cutoff values of 25 (THC 25), 50 (THC 50), or $100\mathrm{ng / mL}$ (THC 100) are presented below:
Qualitative Precision Data
| 25 ng/mL Cutoff Result (THC 25): | | Within Run | | Total Precision | |
| --- | --- | --- | --- | --- | --- |
| Sample concentration (ng/mL) | % of Cutoff | Number of Determination | Immunoassay Result | Number of Determination | Immunoassay Result |
| 0 | negative | 22 | 22 Negative | 88 | 88 Negative |
| 6.25 | -75% | 22 | 22 Negative | 88 | 88 Negative |
| 12.50 | -50% | 22 | 22 Negative | 88 | 88 Negative |
| 18.75 | -25% | 22 | 22 Negative | 88 | 88 Negative |
| 25.00 | Cutoff | 22 | 11 Pos/11 Neg | 88 | 48 Pos/40 Neg |
| 31.25 | 25% | 22 | 22 Positive | 88 | 88 Positive |
| 37.50 | 50% | 22 | 22 Positive | 88 | 88 Positive |
| 43.75 | 75% | 22 | 22 Positive | 88 | 88 Positive |
| 50.00 | 200% | 22 | 22 Positive | 88 | 88 Positive |
Semi-Quantitative Precision Data
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| 25 ng/mL Cutoff Result (THC 25): | | Within Run | | Total Precision | |
| --- | --- | --- | --- | --- | --- |
| Sample concentration (ng/mL) | % of Cutoff | Number of Determination | Immunoassay Result | Number of Determination | Immunoassay Result |
| 0 | negative | 22 | 22 Negative | 88 | 88 Negative |
| 6.25 | -75% | 22 | 22 Negative | 88 | 88 Negative |
| 12.50 | -50% | 22 | 22 Negative | 88 | 88 Negative |
| 18.75 | -25% | 22 | 22 Negative | 88 | 88 Negative |
| 25.00 | Cutoff | 22 | 3 Pos/19 Neg | 88 | 19 Pos/69 Neg |
| 31.25 | 25% | 22 | 22 Positive | 88 | 88 Positive |
| 37.50 | 50% | 22 | 22 Positive | 88 | 88 Positive |
| 43.75 | 75% | 22 | 22 Positive | 88 | 88 Positive |
| 50.00 | 200% | 22 | 22 Positive | 88 | 88 Positive |
## Qualitative Precision Data
| 50 ng/mL Cutoff Result (THC 50): | | Within Run | | Total Precision | |
| --- | --- | --- | --- | --- | --- |
| Sample concentration (ng/mL) | % of Cutoff | Number of Determination | Immunoassay Result | Number of Determination | Immunoassay Result |
| 0 | negative | 22 | 22 Negative | 88 | 88 Negative |
| 12.5 | -75% | 22 | 22 Negative | 88 | 88 Negative |
| 25.0 | -50% | 22 | 22 Negative | 88 | 88 Negative |
| 37.5 | -25% | 22 | 22 Negative | 88 | 88 Negative |
| 50.0 | Cutoff | 22 | 5 Pos/17 Neg | 88 | 32 Pos/56 Neg |
| 62.5 | 25% | 22 | 22 Positive | 88 | 88 Positive |
| 75.0 | 50% | 22 | 22 Positive | 88 | 88 Positive |
| 87.5 | 75% | 22 | 22 Positive | 88 | 88 Positive |
| 100.0 | 200% | 22 | 22 Positive | 88 | 88 Positive |
## Semi-Quantitative Precision Data
| 50 ng/mL Cutoff Result (THC 50): | | Within Run | | Total Precision | |
| --- | --- | --- | --- | --- | --- |
| Sample concentration (ng/mL) | % of Cutoff | Number of Determination | Immunoassay Result | Number of Determination | Immunoassay Result |
| 0 | negative | 22 | 22 Negative | 88 | 88 Negative |
| 12.5 | -75% | 22 | 22 Negative | 88 | 88 Negative |
| 25.0 | -50% | 22 | 22 Negative | 88 | 88 Negative |
| 37.5 | -25% | 22 | 22 Negative | 88 | 88 Negative |
| 50.0 | Cutoff | 22 | 11 Pos/11 Neg | 88 | 38 Pos/50 Neg |
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| 62.5 | 25% | 22 | 22 Positive | 88 | 88 Positive |
| --- | --- | --- | --- | --- | --- |
| 75.0 | 50% | 22 | 22 Positive | 88 | 88 Positive |
| 87.5 | 75% | 22 | 22 Positive | 88 | 88 Positive |
| 100.0 | 200% | 22 | 22 Positive | 88 | 88 Positive |
## Qualitative Precision Data
| 100 ng/mL Cutoff Result (THC 100): | | Within Run | | Total Precision | |
| --- | --- | --- | --- | --- | --- |
| Sample concentration (ng/mL) | % of Cutoff | Number of Determination | Immunoassay Result | Number of Determination | Immunoassay Result |
| 0 | negative | 22 | 22 Negative | 88 | 88 Negative |
| 25 | -75% | 22 | 22 Negative | 88 | 88 Negative |
| 50 | -50% | 22 | 22 Negative | 88 | 88 Negative |
| 75 | -25% | 22 | 22 Negative | 88 | 88 Negative |
| 100 | Cutoff | 22 | 16 Pos/6 Neg | 88 | 53 Pos/35 Neg |
| 125 | 25% | 22 | 22 Positive | 88 | 88 Positive |
| 150 | 50% | 22 | 22 Positive | 88 | 88 Positive |
| 175 | 75% | 22 | 22 Positive | 88 | 88 Positive |
| 200 | 200% | 22 | 22 Positive | 88 | 88 Positive |
## Semi-Quantitative Precision Data
| 100 ng/mL Cutoff Result (THC 100): | | Within Run | | Total Precision | |
| --- | --- | --- | --- | --- | --- |
| Sample concentration (ng/mL) | % of Cutoff | Number of Determination | Immunoassay Result | Number of Determination | Immunoassay Result |
| 0 | negative | 22 | 22 Negative | 88 | 88 Negative |
| 25 | -75% | 22 | 22 Negative | 88 | 88 Negative |
| 50 | -50% | 22 | 22 Negative | 88 | 88 Negative |
| 75 | -25% | 22 | 22 Negative | 88 | 88 Negative |
| 100 | Cutoff | 22 | 22 Negative | 88 | 10 Pos/78 Neg |
| 125 | 25% | 22 | 22 Positive | 88 | 88 Positive |
| 150 | 50% | 22 | 22 Positive | 88 | 88 Positive |
| 175 | 75% | 22 | 22 Positive | 88 | 88 Positive |
| 200 | 200% | 22 | 22 Positive | 88 | 88 Positive |
## b. Linearity/assay reportable range:
The sponsor performed recovery studies by serially diluting a spiked urine pool containing 11-nor- $\Delta^9$ -THC-9-COOH for all three cutoff concentrations (THC 25, THC 50 and THC 100 ng/mL). Each sample from these studies was run in 10 replicates on the Hitachi 717 analyzer. The results were averaged and compared
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to the expected result and the percent recovery was calculated. The linearity results are presented below:
THC 25
| Expected Concentration (ng/mL) | Observed Concentration (ng/mL) | % Recovery (Observed/Expected x 100) |
| --- | --- | --- |
| 0 | 0.9 | Not applicable |
| 5 | 5.4 | 108.78 |
| 10 | 9.6 | 95.61 |
| 15 | 13.4 | 89.34 |
| 20 | 18.0 | 90.08 |
| 25 | 23.3 | 93.35 |
| 30 | 28.0 | 93.47 |
| 35 | 33.4 | 95.32 |
| 40 | 38.9 | 97.28 |
| 45 | 44.3 | 98.53 |
| 50 | 47.6 | 95.12 |
THC 50
| Expected Concentration (ng/mL) | Observed Concentration (ng/mL) | % Recovery (Observed/Expected x 100) |
| --- | --- | --- |
| 0 | 0.4 | Not applicable |
| 10 | 11.3 | 112.9 |
| 20 | 20.2 | 101.1 |
| 30 | 29.6 | 98.5 |
| 40 | 39.2 | 98.0 |
| 50 | 51.6 | 103.2 |
| 60 | 62.2 | 103.7 |
| 70 | 74.0 | 105.7 |
| 80 | 82.7 | 103.4 |
| 90 | 92.9 | 103.3 |
| 100 | 101.6 | 101.6 |
THC 100
| Expected Concentration (ng/mL) | Observed Concentration (ng/mL) | % Recovery (Observed/Expected x 100) |
| --- | --- | --- |
| 0 | 1.93 | Not applicable |
| 15 | 21.5 | 143.20 |
| 40 | 44.8 | 111.95 |
| 60 | 62.4 | 104.02 |
| 80 | 80.0 | 99.96 |
| 100 | 103.2 | 103.21 |
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| 120 | 128.1 | 106.71 |
| --- | --- | --- |
| 140 | 137.5 | 98.21 |
| 160 | 157.3 | 98.33 |
| 180 | 181.3 | 100.74 |
| 200 | 195.2 | 97.60 |
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability and value assignment
**Stability**
A stock solution of 1000 µg/mL 11-nor-Δ⁹-THC-9-COOH purchased from a commercial source is spiked into the calibrator and controls to the desired concentration. The concentration of the calibrator and controls are confirmed by GC/MS. Purity determination and gravimetric preparation using balances calibrated with NIST traceable weights ensure the accuracy of the stock standard solution. The sponsor claimed open-recapped and closed stability of 18 months at 2 to 8°C for the calibrator and control bottles. After the calibrator and control bottles are initially opened, the screw-on caps can be resealed. The study protocols, summary of the results and acceptance criteria were reviewed and found to be adequate.
d. Detection limit:
Performance at low drug concentrations in the semi-quantitative assay was characterized by determination of recovery (see section b above).
e. Analytical specificity:
The sponsor performed studies to evaluate effect of different substances on the performance of the assay for all three cutoff concentrations. These studies were performed by spiking structurally related and unrelated compounds into drug-free and drug-containing urine samples. Drug-containing urine samples were tested at two different concentrations, +25% and -25% of the cut-off concentration of 25, 50 and 100 ng/mL. Drug-free urine samples were used as controls. % cross-reactivity was calculated using the cross-reactant concentration that gives a reaction absorbance which matches the reaction absorbance obtained by the cut-off calibrator. The cut-off calibrator concentration divided by the cross-reactant concentration that achieved the matching reactant absorbance x 100% gives the % cross reactivity. The percent cross-reactivity of the tested compounds is summarized below:
Structurally related compounds:
THC 25
| Compound | Target concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| THC 25 | 25 | 100 |
| THC 25 | 50 | 100 |
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| 11-nor-Δ⁹-THC-9-COOH | 25 | 100% |
| --- | --- | --- |
| 8-β-hydroxy-Δ⁹-THC | 40 | 65.45% |
| 8-β-dihydroxy-Δ⁹-THC | 40 | 50.54% |
| Cannabidiol | 4,500 | 0.48% |
| Cannabinol | 120 | 23.51% |
| exo - THC | 50 | 57.53% |
| l-11-Hydroxy-Δ⁹-THC | 40 | 93.99% |
| l-11-Nor-Δ⁹-THC-Carboxylic Acid | 25 | 97.30% |
| l-11-Nor-Δ⁹-THC-Carboxylic acil-Glucuronide | 1,500 | 1.42% |
| Δ⁸-THC | 50 | 63.59% |
| Δ⁹-THC | 100 | 35.79% |
THC 50
| Compound | Target concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| 11-nor-Δ⁹-THC-9-COOH | 50 | 100% |
| 8-β-hydroxy-Δ⁹-THC | 80 | 58.00% |
| 8-β-dihydroxy-Δ⁹-THC | 90 | 45.44% |
| Cannabidiol | 9,000 | 0.51% |
| Cannabinol | 220 | 21.07% |
| exo - THC | 90 | 52.00% |
| l-11-Hydroxy-Δ⁹-THC | 55 | 96.00% |
| l-11-Nor-Δ⁹-THC-Carboxylic Acid | 50 | 98.80% |
| l-11-Nor-Δ⁹-THC-Carboxylic acil-Glucuronide | 5,000 | 1.41% |
| Δ⁸-THC | 90 | 51.78% |
| Δ⁹-THC | 140 | 33.11% |
THC 100
| Compound | Target concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| 11-nor-Δ⁹-THC-9-COOH | 100 | 100% |
| 8-β-hydroxy-Δ⁹-THC | 140 | 60.68% |
| 8-β-dihydroxy-Δ⁹-THC | 160 | 44.81% |
| Cannabidiol | 16,000 | 0.53% |
| Cannabinol | 400 | 24.50% |
| exo - THC | 160 | 60.00% |
| l-11-Hydroxy-Δ⁹-THC | 100 | 101.50% |
| l-11-Nor-Δ⁹-THC-Carboxylic Acid | 100 | 97.40% |
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Structurally unrelated compounds:
THC 25
| Compound | Tested Concentration (ng/mL) | -25% 11-nor-Δ9-THC-9-COOH (18.75 ng/mL) | +25% 11-nor-Δ9-THC-9-COOH (31.25 ng/mL) |
| --- | --- | --- | --- |
| Acetaminophen | 500,000 | Negative | Positive |
| Acetylsalicylic acid | 500,000 | Negative | Positive |
| Amitryptyline | 100,000 | Negative | Positive |
| Amobarbital | 500,000 | Negative | Positive |
| Amphetamine | 500,000 | Negative | Positive |
| Benzolyecgonine | 500,000 | Negative | Positive |
| Burpropion | 500,000 | Negative | Positive |
| Caffeine | 500,000 | Negative | Positive |
| Chlorpheniramine | 500,000 | Negative | Positive |
| Chlorpromazine | 100,000 | Negative | Positive |
| Cocaine | 500,000 | Negative | Positive |
| Codeine | 500,000 | Negative | Positive |
| Dextromethorpan | 100,000 | Negative | Positive |
| Ecgonine methyl ester | 500,000 | Negative | Positive |
| d,l-Ephedrine | 500,000 | Negative | Positive |
| Imipramine | 100,000 | Negative | Positive |
| JWH-018(1-pentyl-3(1-naphthoyl)indole) | 500,000 | Negative | Positive |
| JWH-073(1-butyl-3(1-naphthoyl)indole) | 500,000 | Negative | Positive |
| Lidocaine | 500,000 | Negative | Positive |
| Meperidine | 500,000 | Negative | Positive |
| Methadone | 500,000 | Negative | Positive |
| Methamthetamine | 500,000 | Negative | Positive |
| Methaqualone | 500,000 | Negative | Positive |
| Morpine | 500,000 | Negative | Positive |
| Nortriptyline | 100,000 | Negative | Positive |
| Oxazepam | 500,000 | Negative | Positive |
| Phencyclidine | 500,000 | Negative | Positive |
| Phentobarbital | 500,000 | Negative | Positive |
| Promethazine | 100,000 | Negative | Positive |
| Propoxyphene | 500,000 | Negative | Positive |
| Ranitidine | 500,000 | Negative | Positive |
| Ranitidine | 500,000 | Negative | Positive |
| Sulfadiazine | 500,000 | Negative | Positive |
| Sulfadiazine | 500,000 | Negative | Positive |
| Toluidine | 500,000 | Negative | Positive |
| Toluidine | 500,000 | Negative | Positive |
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| Secobarbital | 500,000 | Negative | Positive |
| --- | --- | --- | --- |
| Valproic acid | 500,000 | Negative | Positive |
THC 50
| Compound | Tested Concentration (ng/mL) | -25% 11-nor-Δ⁹-THC-9-COOH (37.5 ng/mL) | +25% 11-nor-Δ⁹-THC-9-COOH (62.5 ng/mL) |
| --- | --- | --- | --- |
| Acetaminophen | 500,000 | Negative | Positive |
| Acetylsalicylic acid | 500,000 | Negative | Positive |
| Amitryptyline | 500,000 | Negative | Positive |
| Amobarbital | 500,000 | Negative | Positive |
| Amphetamine | 500,000 | Negative | Positive |
| Benzolyecgonine | 500,000 | Negative | Positive |
| Burpropion | 500,000 | Negative | Positive |
| Caffeine | 500,000 | Negative | Positive |
| Chlorpheniramine | 500,000 | Negative | Positive |
| Chlorpromazine | 500,000 | Negative | Positive |
| Cocaine | 500,000 | Negative | Positive |
| Codeine | 500,000 | Negative | Positive |
| Dextromethorpan | 100,000 | Negative | Positive |
| Ecgonine methyl ester | 500,000 | Negative | Positive |
| d,l-Ephedrine | 500,000 | Negative | Positive |
| Imipramine | 500,000 | Negative | Positive |
| JWH-018(1-pentyl-3(1-naphthoyl)indole) | 500,000 | Negative | Positive |
| JWH-073(1-butyl-3(1-naphthoyl)indole) | 500,000 | Negative | Positive |
| Lidocaine | 500,000 | Negative | Positive |
| Meperidine | 500,000 | Negative | Positive |
| Methadone | 500,000 | Negative | Positive |
| Methamthetamine | 500,000 | Negative | Positive |
| Methaqualone | 500,000 | Negative | Positive |
| Morpine | 500,000 | Negative | Positive |
| Nortriptyline | 500,000 | Negative | Positive |
| Oxazepam | 500,000 | Negative | Positive |
| Phencyclidine | 500,000 | Negative | Positive |
| Phentobarbital | 500,000 | Negative | Positive |
| Promethazine | 100,000 | Negative | Positive |
| Propoxyphene | 500,000 | Negative | Positive |
| Ranitidine | 500,000 | Negative | Positive |
| Secobarbital | 500,000 | Negative | Positive |
| Valproic acid | 500,000 | Negative | Positive |
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THC 100
| Compound | Tested Concentration (ng/mL) | -25% 11-nor-Δ⁹-THC-9-COOH (75 ng/mL) | +25% 11-nor-Δ⁹-THC-9-COOH (125 ng/mL) |
| --- | --- | --- | --- |
| Acetaminophen | 500,000 | Negative | Positive |
| Acetylsalicylic acid | 500,000 | Negative | Positive |
| Amitryptyline | 500,000 | Negative | Positive |
| Amobarbital | 500,000 | Negative | Positive |
| Amphetamine | 500,000 | Negative | Positive |
| Benzolyecgonine | 500,000 | Negative | Positive |
| Burpropion | 500,000 | Negative | Positive |
| Caffeine | 500,000 | Negative | Positive |
| Chlorpheniramine | 500,000 | Negative | Positive |
| Chlorpromazine | 500,000 | Negative | Positive |
| Cocaine | 500,000 | Negative | Positive |
| Codeine | 500,000 | Negative | Positive |
| Dextromethorpan | 100,000 | Negative | Positive |
| Ecgonine methyl ester | 500,000 | Negative | Positive |
| d,l-Ephedrine | 500,000 | Negative | Positive |
| Imipramine | 500,000 | Negative | Positive |
| JWH-018(1-pentyl-3(1-naphthoyl)indole) | 500,000 | Negative | Positive |
| JWH-073(1-butyl-3(1-naphthoyl)indole) | 500,000 | Negative | Positive |
| Lidocaine | 500,000 | Negative | Positive |
| Meperidine | 500,000 | Negative | Positive |
| Methadone | 500,000 | Negative | Positive |
| Methamthetamine | 500,000 | Negative | Positive |
| Methaqualone | 500,000 | Negative | Positive |
| Morpine | 500,000 | Negative | Positive |
| Nortriptyline | 500,000 | Negative | Positive |
| Oxazepam | 500,000 | Negative | Positive |
| Phencyclidine | 500,000 | Negative | Positive |
| Phentobarbital | 500,000 | Negative | Positive |
| Promethazine | 100,000 | Negative | Positive |
| Propoxyphene | 500,000 | Negative | Positive |
| Ranitidine | 500,000 | Negative | Positive |
| Secobarbital | 500,000 | Negative | Positive |
| Valproic acid | 500,000 | Negative | Positive |
Endogenous compounds:
{12}
The following endogenous compounds were added into drug-free urine and drug containing urine sample at the concentrations of $\pm 25\%$ surrounding all three cutoff concentrations. The substances listed in the table below were determined not to interfere at the concentration shown:
THC 25, THC 50 and THC 100
| Compound | Tested Concentration (mg/dL) |
| --- | --- |
| Acetone | 1000 |
| Ascorbic acid | 500 |
| Creatinine | 500 |
| Ethanol | 1000 |
| Galactose | 10 |
| γ-Globulin | 500 |
| Glucose | 1500 |
| Hemoglobin | 300 |
| Human Serum Albumin | 500 |
| Oxalic acid | 100 |
| Riboflavin | 0.25 (THC25) 0.65 (THC50, THC100) |
| Sodium chloride | 2000 |
| Urea | 2000 |
In addition, pH levels of 3 to 11 had no effect on the performance of the assay. Further, variations in specific gravity between 1.002 and 1.024 had no effect on results.
The package insert includes the complete list of all structurally related and unrelated compounds and metabolites tested.
# f. Assay cut-off:
Analytical performance of the device around the claimed cutoff is described in precision section (1 a.) above.
# 2. Comparison studies:
a. Method comparison with predicate device:
# THC 25:
Forty-four (44) positive and forty-three (43) negative unaltered clinical urine samples were evaluated by the LZI Cannabinoids (cTHC) Enzyme Immunoassay and compared to GC/MS or LC/MS for 11-nor- $\Delta^9$ -THC-9-COOH concentration. Results from the study are presented below:
{13}
THC 25 - Qualitative
| THC 25 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | High Positive > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 7 | 15 | 29 | 100.00% |
| Negative | 12 | 16 | 7 | 0 | 0 | 83.72% |
THC 25 - Semi-quantitative
| THC 25 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 7 | 15 | 29 | 100.00% |
| Negative | 12 | 16 | 7 | 0 | 0 | 83.72% |
Summary of Discordant Results in Qualitative/Semi-Quantitative mode:
| Discordant Cut-off THC 25 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 25 ng/mL | POS | 7 |
| | POS | 19 |
| | POS | 20 |
| | POS | 21 |
| | POS | 23 |
| | POS | 23 |
| | POS | 24 |
| | POS | 24 |
A new study with additional unaltered patient samples (eleven (11) positive and twelve (12) negative)) was performed to support method comparison. Results from the additional study are presented below:
{14}
THC 25 - Qualitative mode
| THC 50 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | High Positive > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 1 | 3 | 8 | 100.00% |
| Negative | 2 | 7 | 2 | 0 | 0 | 91.67% |
THC 25 - Semi-quantitative mode
| THC 50 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | High Positive > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 1 | 3 | 8 | 100.00% |
| Negative | 2 | 7 | 2 | 0 | 0 | 91.67% |
| Discordant Cut-off THC 50 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 50 ng/mL | POS | 16 |
# THC 50:
Forty-three (43) positive and forty-three (43) negative unaltered clinical urine samples were evaluated by the LZI Cannabinoids (cTHC) Enzyme Immunoassay and compared to GC/MS or LC/MS for 11-nor- $\Delta^9$ -THC-9-COOH concentration. Results from the study are presented below:
{15}
THC 50 - Qualitative mode
| THC 50 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | High Positive > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 5 | 15 | 28 | 100.00% |
| Negative | 11 | 17 | 9 | 0 | 0 | 86.00% |
THC 50 - Semi-quantitative mode
| THC 50 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 3 | 15 | 28 | 100.00% |
| Negative | 11 | 17 | 12 | 0 | 0 | 93% |
Summary of Discordant Results in Qualitative mode:
| Discordant Cut-off THC 50 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 50 ng/mL | POS | 7 |
| | POS | 27 |
| | POS | 36 |
| | POS | 37 |
| | POS | 46 |
| | POS | 48 |
Summary of Discordant Results in Semi-Quantitative mode:
| Discordant Cut-off THC 50 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 50 ng/mL | POS | 36 |
| | POS | 46 |
| | POS | 48 |
A new study with additional unaltered patient samples (twenty-two (22) positive and
{16}
twenty-five (25) negative)) was performed to support method comparison. Results from the additional study are presented below:
THC 50 – Qualitative mode
| THC 50 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | High Positive > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 3 | 0 | 22 | 100.00% |
| Negative | 0 | 19 | 3 | 0 | 0 | 92.00% |
THC 50 – Semi-quantitative mode
| THC 50 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 2 | 0 | 22 | 100.00% |
| Negative | 0 | 19 | 4 | 0 | 0 | 92.00% |
Summary of Discordant Results in Qualitative mode:
| Discordant Cut-off THC 50 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 50 ng/mL | POS | 44.7 |
| | POS | 48 |
| | POS | 49.3 |
Summary of Discordant Results in Quantitative mode:
| Discordant Cut-off THC 50 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 50 ng/mL | POS | 44.7 |
| | POS | 48 |
THC 100:
Forty (40) positive and forty-two (42) negative unaltered clinical urine
{17}
samples were evaluated by the LZI Cannabinoids (cTHC) Enzyme Immunoassay and compared to GC/MS or LC/MS for 11-nor- $\Delta^9$ -THC-9-COOH concentration. Results from the study are presented below:
THC 100 - Qualitative mode
| THC 100 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | High Positive > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 4 | 15 | 25 | 100.00% |
| Negative | 2 | 30 | 6 | 0 | 0 | 90.48% |
THC 100 - Semi-quantitative mode
| THC 100 | Negative | < 50% of the cutoff | Near Cutoff Negative (between 50% below the cutoff and the cutoff) | Near Cutoff Positive (concentration between 50% above the cutoff and the cutoff) | > 50% above the cutoff | % Agreement |
| --- | --- | --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 4 | 15 | 25 | 100.00% |
| Negative | 2 | 30 | 6 | 0 | 0 | 90.48% |
Summary of Discordant Results in Qualitative/Semi-Quantitative mode:
| Discordant Cut-off THC 100 | LZI Cannabinoid Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
| 100 ng/mL | POS | 83 |
| | POS | 83 |
| | POS | 85 |
| | POS | 96 |
b. Matrix comparison:
Not applicable. The test is only for urine specimens.
# 3. Clinical studies:
a. Clinical Sensitivity:
{18}
Not applicable. Not reviewed for this device type.
b. Clinical specificity:
Not applicable. Not reviewed for this device type.
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.
19
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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.