CHEMTRUE SINGLE/MULTI-PANEL DRUG SCREEN CASSETTE/DIPCARD
Applicant
Chemtron Biotech, Inc.
Product Code
JXM · Clinical Toxicology
Decision Date
Sep 14, 2011
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3170
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K111322 · Sep 14, 2011
CHEMTRUE SINGLE/MULTI-PANEL DRUG SCREEN CASSETTE/DIPCARD
Chemtron Biotech, Inc.
Clinical urine specimens
Clinical urine specimens were used in a method comparison study to evaluate the accuracy of the Chemtrue® Drug Screen tests by comparing results against GC/MS reference method values.
Method comparison (Accuracy) study; Retrospective clinical specimen correlation study
Human urine specimens; Sample Size: Varies by analyte (e.g., 203 for BZO, 190 for BAR, 101 for MDMA, 104 for MTD, 106 for OPI, 106 for OXY)
GC/MS reference method
Positive, negative, and overall percent agreement
Indications for Use
The Chemtrue® test device is intended for the qualitative detection of drugs of abuse, for in vitro diagnostic use and for prescription use ONLY. The test provides only a preliminary result. A more specific alternative chemical method must be used in order to obtain a confirmed assay result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods. Clinical consideration and professional judgment should be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated.
Device Story
Rapid lateral flow immunoassay for qualitative detection of drugs of abuse in human urine; utilizes competitive binding between rabbit monoclonal antibodies and drug-labeled conjugate; visual readout of test lines; absence of line indicates positive result; presence of line indicates negative result; internal process control confirms sample volume and wicking; intended for prescription use in clinical settings; provides preliminary results requiring confirmation by GC/MS or LC/MS; aids healthcare providers in identifying potential drug use; benefits include rapid screening for clinical decision-making.
Clinical Evidence
Clinical performance evaluated via method comparison study against GC/MS reference method. Samples with concentrations above cut-off were presumptive positive; below were negative. Results showed high agreement: BZO (98.5% overall), BAR (98.4% overall), MDMA (98% overall), MTD (99% overall), OPI/MOR (100% overall), and OXY (99.1% overall).
Technological Characteristics
One-step lateral flow competitive immunoassay. Components: plastic holder, test strips with drug-protein conjugate, anti-drug antibody-colloidal gold conjugate pads. Detection via visual color band formation. Storage: 2-30°C. No electronic components or software.
Indications for Use
Indicated for qualitative detection of up to six drugs (Benzodiazepines, Barbiturates, Ecstasy, Methadone, Opiates, Oxycodone) in human urine. For prescription use only; not for point-of-care or OTC use. Requires confirmatory testing via GC/MS or LC/MS.
Regulatory Classification
Identification
A benzodiazepine test system is a device intended to measure any of the benzodiazepine compounds, sedative and hypnotic drugs, in blood, plasma, and urine. The benzodiazepine compounds include chlordiazepoxide, diazepam, oxazepam, chlorzepate, flurazepam, and nitrazepam. Measurements obtained by this device are used in the diagnosis and treatment of benzodiazepine use or overdose and in monitoring levels of benzodiazepines to ensure appropriate therapy.
Special Controls
*Classification.* Class II (special controls). A benzodiazepine 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
ACON, One Step Drug Screen Test Card For Single and Multi Drug Screen Test Cards (k061718)
Submission Summary (Full Text)
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510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
ASSAY ONLY TEMPLATE
A. 510(k) Number:
k111322
B. Purpose for Submission:
New device
C. Measurand:
Benzodiazepines, Barbiturates, Ecstasy, Methadone, Opiates and Oxycodone
D. Type of Test:
Qualitative immunoassay
E. Applicant:
Chemtron Biotech, Inc.
F. Proprietary and Established Names:
Chemtrue Single/Multi-Panel Drug Screen Cassette and Dip Card Tests
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| JXM | II | 862.3170 Benzodiazepine test system | 91, Toxicology |
| DIS | II | 862.3150 Barbiturate test system | 91, Toxicology |
| DJC | II | 862.6310 Methamphetamine test system | 91, Toxicology |
| DJR | II | 862.3620 Methadone test system | 91, Toxicology |
| DJG | II | 862.3650 Opiate test system | 91, Toxicology |
H. Intended Use:
1. Intended use(s):
See indication for use below
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2. Indication(s) for use:
The Chemtron Biotech, Inc.'s Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are rapid lateral flow immunoassays for the qualitative detection of up to six of the following drugs in a variety of combinations in human urine. The designed cutoff concentrations and the calibrators used for these drugs are as follows:
| Analyte | Abbreviation | Calibrator | Cutoff |
| --- | --- | --- | --- |
| Benzodiazepines | BZO | Oxazepam | 300 ng/mL |
| Barbiturates | BAR | Secobarbital/ Pentobarbital | 300 ng/mL |
| Ecstasy | MDMA/ XTC | d,l-Methylenedioxyethamphetamine | 500 ng/mL |
| Methadone | MTD | Methadone | 300 ng/mL |
| Opiates | OPI/MOR | Morphine | 2000 ng/mL |
| Oxycodone | OXY | Oxycodone | 100 ng/mL |
The Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are intended for the qualitative detection of drugs of abuse for in vitro diagnostic and prescription use ONLY. They are not intended for point-of-care settings or over the counter use. These assays provide only a preliminary result. A more specific alternative chemical method must be used in order to obtain a confirmed assay result. Gas Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Mass Spectrometry (LC/MS) are the preferred confirmatory methods.
Clinical consideration and professional judgment should be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated.
3. Special conditions for use statement(s):
In vitro diagnostic use, prescription use only
Not for point-of-care or over the counter use
4. Special instrument requirements:
Not applicable, as the devices are visually-read single-use devices.
I. Device Description:
The devices are for use in human urine. The Chemtrue Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are single-test test strips. The Chemtrue Single/Multi-Panel Drug Screen Cassette and Dip Card Tests contain test cassettes and package inserts (instructions for use).
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J. Substantial Equivalence Information:
1. Predicate device name(s):
ACON, One Step Drug Screen Test Card For Single and Multi Drug Screen Test Cards
2. Predicate K number(s):
k061718
3. Comparison with predicate:
| Item | Device | Predicate |
| --- | --- | --- |
| Intended use | Qualitative detection of drugs-of-abuse in urine for prescription and In Vitro Diagnostic Use ONLY | Same |
| Test Principle | One-Step lateral flow competitive immunoassay | Same |
| Specimen | Urine | Same |
| Cutoff | Benzodiazepines 300 ng/mL
Barbiturates 300 ng/mL
Ecstasy (MDMA) 500 mg/dL
Methadone 300 ng/ml
Opiates (Morphine) 2000 ng/mL
Oxycodone 100 ng/mL | Same |
| Read time | 5 minutes | Same |
| Storage | 2-30 °C (36-86 F) | Same |
| Time to read results | Do not read after 8 minutes | Results remain stable for up to 4 hours after test initiation |
K. Standard/Guidance Document Referenced (if applicable):
None were referenced
L. Test Principle:
Chemtron Biotech’s Chemtrue Single/Multi-Panel Drug Screen Cassette and Dip Card Tests employs lateral flow immunochromatographic technology.
Benzodiazepine, Barbiturates, Ecstasy, Methadone, Opiates and Oxycodone are detected in human urine by competitive binding between rabbit monoclonal
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antibodies to one of its respective drug and drug-labeled conjugate (containing a chromagen). Binding of the 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. The absence or presence of the line is determined visually by the operator.
The device also has an internal process control (goat monoclonal anti-rabbit IgG) which indicates that an adequate volume of sample has been added and that the immunochromatographic strip is intact.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Dip Card
| Drug | Concentration Tested | Operator1/Lot One | Operator 2/Lot Two | Operator 3/Lot Three | Total |
| --- | --- | --- | --- | --- | --- |
| | | Neg/Pos | Neg/Pos | Neg/Pos | Neg/Pos |
| BZO | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 9/1 | 9/1 | 9/1 | 27/3 |
| | Cutoff | 6/4 | 4/6 | 6/4 | 16/14 |
| | +25% | 1/9 | 2/8 | 1/9 | 4/26 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| BAR | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 9/1 | 9/1 | 9/1 | 27/3 |
| | Cutoff | 5/5 | 5/5 | 7/3 | 17/13 |
| | +25% | 2/8 | 2/8 | 1/9 | 5/25 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| MDMA | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 10/0 | 9/1 | 10/0 | 29/1 |
| | Cutoff | 6/4 | 7/3 | 6/4 | 19/11 |
| | +25% | 1/9 | 0/10 | 1/9 | 2/28 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| MTD | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 10/0 | 10/0 | 10/0 | 30/0 |
| | Cutoff | 7/3 | 4/6 | 2/8 | 13/17 |
| | +25% | 1/9 | 1/9 | 0/10 | 2/28 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| OPI | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
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| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| --- | --- | --- | --- | --- | --- |
| | -25% | 10/0 | 10/0 | 10/0 | 30/0 |
| | Cutoff | 7/3 | 8/2 | 8/2 | 23/7 |
| | +25% | 2/8 | 0/10 | 1/9 | 3/27 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| OXY | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 9/1 | 10/0 | 10/0 | 29/1 |
| | Cutoff | 4/6 | 7/3 | 5/5 | 16/14 |
| | +25% | 0/10 | 2/8 | 1/9 | 27/3 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
Cassette
| Drug | Concentration Tested | Operator1/Lot One | Operator 2/Lot Two | Operator 3/Lot Three | Total |
| --- | --- | --- | --- | --- | --- |
| | | Neg/Pos | Neg/Pos | Neg/Pos | Neg/Pos |
| BZO | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 9/1 | 9/1 | 9/1 | 27/3 |
| | Cutoff | 6/4 | 6/4 | 5/5 | 17/13 |
| | +25% | 2/8 | 2/8 | 1/9 | 5/25 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| BAR | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 9/1 | 9/1 | 10/0 | 28/2 |
| | Cutoff | 5/5 | 5/5 | 6/4 | 16/14 |
| | +25% | 3/7 | 2/8 | 2/8 | 7/23 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| MDMA | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 9/1 | 9/1 | 10/0 | 28/2 |
| | Cutoff | 5/5 | 5/5 | 6/4 | 16/14 |
| | +25% | 2/8 | 0/10 | 1/9 | 3/27 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| MTD | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 10/0 | 8/2 | 10/0 | 28/2 |
| | Cutoff | 4/6 | 4/6 | 6/4 | 14/16 |
| | +25% | 0/10 | 1/9 | 0/10 | 1/29 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| OPI | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 10/0 | 10/0 | 10/0 | 30/0 |
| | Cutoff | 3/7 | 7/3 | 6/4 | 16/14 |
| | +25% | 2/8 | 2/8 | 1/9 | 5/25 |
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| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
| --- | --- | --- | --- | --- | --- |
| OXY | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | -50% | 10/0 | 10/0 | 10/0 | 30/0 |
| | -25% | 8/2 | 10/0 | 10/0 | 28/2 |
| | Cutoff | 5/5 | 3/7 | 4/6 | 12/18 |
| | +25% | 0/10 | 1/9 | 0/10 | 1/29 |
| | +50% | 0/10 | 0/10 | 0/10 | 0/30 |
b. Linearity/assay reportable range:
Not applicable, the device is intended for qualitative use
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
This device has internal process controls. A colored line appearing in the control region confirms sufficient sample volume and adequate membrane wicking. Users are informed that the test is invalid if a line fails to appear in the control region.
Control materials are not supplied with this device; however it is good laboratory practice to confirm the test procedure and to verify proper test performance. Users should follow all applicable guidelines for testing QC materials.
Stability:
Accelerated studies have been conducted. Protocols and acceptance criteria were described and found to be acceptable. The manufacturer claims the following expiration date:
When stored at 2–30 °C product is stable until expiration date which is 24 months.
Real time studies have been conducted and are on-going.
Read time stability was performed for Chemtrue Single/Multi-Panel Drug Screen Dip Card and Cassette. A drug-free urine was spiked with the appropriate drug at 50% cutoff, 150% cutoff, as well as a negative urine was used to perform the study. All samples were analyzed fifteen times at each concentration with three lots of test strips at 1-5 minute intervals from 1-20 minutes. Data supports the recommended read time of 5 minutes for each device.
d. Detection limit:
See Precision/Reproducibility section in M 1.a above.
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e. Analytical specificity:
Cross-reactivity was established by spiking structurally related compounds into drug-free urine and diluting each to obtain various concentrations. Results are expressed as a minimum concentration of metabolite or compound required to produce a response approximately equivalent to the cutoff concentration of the assay. Testing was performed on both devices (dip card and cassette). Both devices produced similar results. The percent cross-reactivity of those compounds are presented below:
Structurally related:
Benzodiazepines
| Substances | Concentration (ng/mL) | % Cross-reactivity |
| --- | --- | --- |
| Oxazepam | 300 | 100 |
| Alprazolam | 3000 | 100 |
| Alpha-Hydroxyalprazolam | 100 | 300 |
| Bromazepam | 500 | 60 |
| Chlordiazepoxide | 2,500 | 12 |
| Clobazam | 200 | 150 |
| Clonazepam | 10,000 | 3 |
| Clorazepate | 350 | 85.7 |
| Desalkylflurazepam | 65 | 462 |
| Diazepam | 200 | 150 |
| Estazolam | 500 | 60 |
| Flunitrazepam | 375 | 80 |
| Flurazepam | 90 | 333 |
| Lorazepam | 600 | 50 |
| Lormetazepam | 7,500 | 4 |
| Midazolam | 900 | 33.3 |
| Nitrazepam | 200 | 150 |
| Nordiazepam | 150 | 200 |
| Sertraline | | |
| Temazepam | 350 | 85.7 |
| Triazolam | 1,000 | 30 |
Barbiturates
| Substances | Concentration (ng/mL) | % Cross-reactivity |
| --- | --- | --- |
| Secobarbital | 300 | 100 |
| Pentobarbital | 300 | 100 |
| Alphenal | 500 | 60 |
| Amobarbital | 400 | 75 |
| Aprobarbital | 350 | 85.7 |
| Barbital | 5,000 | 6 |
| Butabarbital Butisol | 250 | 120 |
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| Butalbital | 3,000 | 10 |
| --- | --- | --- |
| Cyclopentobarbital | 750 | 40 |
| Phenobarbital | 250 | 120 |
Ecstasy (MDMA)
| Substances | Concentration (ng/mL) | % Cross-reactivity |
| --- | --- | --- |
| D,1 (3,4)-Methylenedioxymethamphetamine (MDMA) | 500 | 100 |
| 3,4-Methylenedioxyamphetamine (MDA) | 15,000 | 3.3 |
| 3,4-Methylenedioxyethylamphetamine (MDEA) | 1,000 | 50 |
| d-Methamphetamine | 100,000 | 0.5 |
Methadone
| Substances | Concentration (ng/mL) | % Cross-reactivity |
| --- | --- | --- |
| Methadone | 300 | 100 |
| Doxylamine | 100,000 | 0.3 |
| EDDP | 100,000 | 0.3 |
| Pheniramine | 100,000 | 0.3 |
Opiates
| Substances | Concentration (ng/mL) | % Cross-reactivity |
| --- | --- | --- |
| Morphine | 2000 | 100 |
| Codeine | 2000 | 100 |
| 6-Acetylmorphine | 1500 | 133.3 |
| Diacetyl morphine (Heroin) | 2000 | 100 |
| Ethylmorphine | 1500 | 133.3 |
| Hydrocodone | 50,000 | 4 |
| Hydromorphone | 50,000 | 4 |
| Norcodeine | 100,000 | 2 |
| Normorphine | 100,000 | 2 |
| Oxycodone | 100,000 | 2 |
| Oxymorphone | 100,000 | 2 |
| Paracetamol | 100,000 | 2 |
| Thebaine | 100,000 | 2 |
Oxycodone
| Substances | Concentration (ng/mL) | % Cross-reactivity |
| --- | --- | --- |
| Oxycodone | 100 | 100 |
| Codeine | 100,000 | 0.1 |
| Hydrocodone | 100,000 | 0.1 |
| Oxymorphone | 100,000 | 0.1 |
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# Structurally un-related:
This study was performed by spiking structurally unrelated compounds and endogenous substances at a concentration of $100\mu \mathrm{g / mL}$ into urine samples containing drug at $+/-25\%$ of the respective drug cutoff concentrations. The substances at $100\mu \mathrm{g / mL}$ concentration were also tested at $+/-50\%$ respective drug cutoff concentrations, if a false result was observed at $+/-25\%$ cutoff levels. Testing was performed on both devices (dip card and cassette). The following compounds showed no interference when tested at the $+/-50\%$ drug concentration:
| Acetaminophen | 5,5-Diphenylhydantoin | Oxalic Acid |
| --- | --- | --- |
| Acetylsalicylic Acid | Dopamine | Papaverine |
| Albumin | (-)-ephedrine | Perphenazine |
| Amoxicillin | l-Erythromycin | Phenelzine |
| R-(-)-Apomorphine | Estradiol | L-Phenylephrine |
| L-Ascorbic Acid | Estrone | Phenylethylamine |
| Atropine | Ethanol | Phenylpropanolamine |
| Baclofen | Fenofibrate | Prednisone |
| Benzocaine | Fentanyl | Promazine |
| Benzoic Acid | Fotemustine | Promethazine |
| Bilirubin | Furosemide | D-Propoxyphene |
| Buprenorphine | Gemfibrozil | d,l Propranolol |
| Cannabidiol | Gentisic acid | d-Pseudoephedrine |
| Carisoprodol | Glucose | Pyridoxal-5-phosphate |
| Cholesterol | Guaiacol glyceryl ether | Pyridoxine |
| Chloral hydrate | Hemoglobin | Pyrilamine |
| Chloramphenicol | Hydralazine | Pyrogallol |
| Chlordiazepoxide | Hydrocortisone | Quinidine |
| (+)-Chlorpheniramine | 3-Hydroxytyramine | Quinine |
| Chlorpromazine | (+/-)-Isoproterenol | Quinolinic Acid |
| Chlorprothixene | Ketamine | Riboflavin |
| Clofibrate | Meprobamate | Salicylic Acid |
| Clonidine | Methapyrilene | Sodium Chloride |
| Cortisone | Methylphenidate | Sulfamethazine |
| (-)-Cotinine | Nalidixic Acid | Sulindac |
| Creatine Hydrate | Naloxone | Tetracycline |
| Creatinine | Naltrexone | Tetrahydrozoline |
| Cyclobenzaprine | (+)-Naproxen | Thiamine |
| Cyclodextrin-r | Niacinamide | Thioridazine |
| Cyproheptadine | Nicotinic Acid | Tramadol |
| Deoxycorticosterone | Nifedipine | Trifluoperazine |
| Dextromethorphan | 19-Norethindrone | Tryptamine |
| Diclofenac | Norpropoxyphene | Tyramine |
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| Diflunisal | Nortriptyline | Uric Acid |
| --- | --- | --- |
| 4-Dimethyl-aminoantipyrine | Noscapine | Zomepirac sodium salt |
| Diphenhydramine | Octopamine | |
Evaluation of SG and pH on test results:
To evaluate the effect of pH value on the test results, urine controls at 50%, 75%, 125% and 150% of the cutoff value were used. Each control level was adjusted by either 1N NaOH solution or 1N HCl to the pH levels at 3.0, 3.5, 4.0, 4.5, 5.0, 5.5, 6.0, 6.5, 7.0, 7.5, 8.0 and 8.5. Each test sample was tested in duplicate.
To evaluate the effect of specific gravity, urine controls at +/-25% and +/-50% of the cut-off values were spiked with DI water or sugar to obtain specific gravities of 1.002, 1.010, 1.015, 1.020, 1.025, and 1.030. Each test sample was tested in duplicate.
The testing results demonstrate that varying pH's and specific gravities do not affect urine testing results around each analyte cut-off.
f. Assay cut-off:
Characterization of how the device performs analytically around the claimed cutoff concentration appears in the precision section, M1.a, above.
2. Comparison studies:
a. Method comparison with predicate device:
The method comparison study was conducted to evaluate the performance of the device for detection of benzodiazepine, barbiturate, MDMA, opiates, methadone and oxycodone, with 2 operators (1 operator/device). In the method comparison study, 203 unaltered clinical samples (85 negative and 118 positive) benzodiazepine, 190 unaltered clinical samples (85 negative and 105 positive) barbiturate, 100 unaltered clinical samples (60 negative and 40 positive) MDMA, 106 unaltered clinical samples (65 negative and 41 positive) opiates, 104 unaltered clinical samples (60 negative and 44 positive) methadone, 106 unaltered clinical samples (59 negative and 47 positive) oxycodone were tested with the proposed devices and compared against the results obtained with GC/MS. The results of the studies are presented below:
Benzodiazepine
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| | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) | % Agreement |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Dip Card | Positive | 0 | 0 | 1 | 35 | 82 | 99.2% |
| | Negative | 43 | 9 | 32 | 1 | 0 | 98.8% |
| Cassette | Positive | 0 | 0 | 1 | 34 | 82 | 98.3% |
| | Negative | 43 | 9 | 32 | 2 | 0 | 98.8% |
Barbiturates
| | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) | % Agreement |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Dip Card | Positive | 0 | 0 | 1 | 42 | 62 | 99.1% |
| | Negative | 43 | 8 | 33 | 1 | 0 | 98.8% |
| Cassette | Positive | 0 | 0 | 1 | 41 | 62 | 98.1% |
| | Negative | 43 | 8 | 33 | 2 | 0 | 98.8% |
MDMA
| | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) | % Agreement |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Dip Card | Positive | 0 | 0 | 1 | 12 | 28 | 97.6% |
| | Negative | 43 | 5 | 11 | 1 | 0 | 98.3% |
| Cassette | Positive | 0 | 0 | 1 | 12 | 28 | 97.6% |
| | Negative | 43 | 5 | 11 | 1 | 0 | 98.3% |
Opiates
| | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) | % Agreement |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Dip Card | Positive | 0 | 0 | 0 | 19 | 22 | 100% |
| | Negative | 43 | 10 | 12 | 0 | 0 | 100% |
| Cassette | Positive | 0 | 0 | 0 | 19 | 22 | 100% |
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| | Negative | 43 | 10 | 12 | 0 | 0 | 100% |
| --- | --- | --- | --- | --- | --- | --- | --- |
Methadone
| | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) | % Agreement |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Dip Card | Positive | 0 | 0 | 1 | 15 | 28 | 97.7% |
| | Negative | 43 | 5 | 11 | 1 | 0 | 98.3% |
| Cassette | Positive | 0 | 0 | 1 | 16 | 28 | 100% |
| | Negative | 43 | 5 | 11 | 0 | 0 | 98.3% |
Oxycodone
| | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) | % Agreement |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Dip Card | Positive | 0 | 0 | 1 | 11 | 36 | 100% |
| | Negative | 43 | 6 | 9 | 0 | 0 | 98.3% |
| Cassette | Positive | 0 | 0 | 1 | 11 | 36 | 100% |
| | Negative | 43 | 6 | 9 | 0 | 0 | 98.3% |
Discordant Tables:
Dip Card
| Cutoff value (ng/mL) | Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) | |
| --- | --- | --- | --- |
| | | Drug/Metabolite | GC/MS value (ng/ml) |
| Benzodiazepine 300 | positive | Oxazepam | 298 |
| Benzodiazepine 300 | negative | Alprazolam | 322 |
| Barbiturate 300 | positive | Pentobarbital | 290 |
| Barbiturate 300 | negative | Pentobarbital | 302 |
| MDMA 500 | positive | MDMA | 498 |
| MDMA 500 | negative | MDMA | 526 |
| Methadone 300 | positive | Methadone | 298 |
| Methadone 300 | negative | Methadone | 334 |
| Oxycodone 100 | positive | Oxycodone | 94 |
Cassette
| Cutoff value (ng/mL) | Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) |
| --- | --- | --- |
{12}
| | | Drug/Metabolite | GC/MS value (ng/ml) |
| --- | --- | --- | --- |
| Benzodiazepine 300 | positive | Oxazepam | 298 |
| Benzodiazepine 300 | negative | Oxazepam | 303 |
| Benzodiazepine 300 | negative | Alprazolam | 322 |
| Barbiturate 300 | positive | Pentobarbital | 290 |
| Barbiturate 300 | negative | Pentobarbital | 309 |
| Barbiturate 300 | negative | Butalbital | 328 |
| MDMA 500 | positive | MDMA | 498 |
| MDMA 500 | negative | MDMA | 526 |
| Methadone 300 | positive | Methadone | 298 |
| Oxycodone 100 | positive | Oxycodone | 94 |
b. Matrix comparison:
Not applicable. The assay is intended for only one sample matrix, urine
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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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.