Randox Opiates Assay: The Randox Laboratories Ltd. Opiates Assay is an in vitro diagnostic test for the qualitative and semi-quantitative analysis of Opiates in human urine. The cut off for both the qualitative and semi-quantitative application is 2000ng/ml for morphine to which the assay is calibrated. Qualitative and semi-quantitative results can be utilized in the diagnosis and treatment of Opiate use or overdose. The Randox Opiates Assay has been developed for use on the RX series analysers, which includes the RX Daytona and the RX Imola. This in vitro diagnostic device is intended for prescription use only. 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. This assay provides only a preliminary analytical test result. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatograph/Mass Spectrometry (GC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. Randox Multidrug Calibrator Set: The Randox Multidrug Calibrator Set is for use on human urine samples. They are liquid calibrators containing Methamphetamine, Secobarbital, Methadone, and Morphine. There are 5 levels of calibrator. They have been developed for use in the calibration of Amphetamine, Barbiturates, Methadone and Opiate assays on the RX series analysers, which includes the RX Daytona and RX Imola. This in vitro diagnostic device is intended for prescription use only. Randox Multidrug Controls, Level 1 & 2: The Randox Multidrug Controls, level 1 and 2 are for use on human urine samples. They are liquid controls containing Methamphetamine, Secobarbital, Methadone, and Morphine. There are 2 levels of controls. They have been developed for use in the quality control of quality control of Amphetamine, Barbiturates, Methadone and Opiate assays on the RX series analysers, which includes the RX Daytona and RX Imola. This in vitro diagnostic device is intended for prescription use only.
Device Story
The Randox Opiates Assay is an in vitro diagnostic test for human urine; utilizes RX series analyzers (RX Daytona, RX Imola) for qualitative and semi-quantitative detection of opiates at a 2000ng/ml cutoff. The system includes liquid calibrators and controls containing Methamphetamine, Secobarbital, Methadone, and Morphine. The assay provides preliminary results; requires confirmation via GC/MS. Used by laboratory professionals to assist in diagnosing opiate use or overdose and to determine specimen dilution for confirmatory testing. Benefits include rapid preliminary screening to guide clinical decision-making and laboratory quality control.
Clinical Evidence
Bench testing only. Evaluated precision over 20 days (intra- and inter-assay) using spiked urine samples. Linearity/recovery assessed via serial dilutions. Analytical specificity tested against structurally related and unrelated compounds per CLSI EP7-A2. Method comparison performed on 128 clinical urine samples against GC/MS; results showed high agreement for both qualitative and semi-quantitative modes on RX Daytona and RX Imola analyzers.
Indicated for the qualitative and semi-quantitative analysis of Opiates in human urine to aid in the diagnosis and treatment of Opiate use or overdose. Intended for prescription use in clinical laboratory settings using RX series analyzers (RX Daytona, RX Imola).
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 ASSAY ONLY TEMPLATE
A. 510(k) Number:
k113747
B. Purpose for Submission:
New device
C. Measurand:
Opiates
D. Type of Test:
Qualitative and semi-quantitative immunoassay
E. Applicant:
Randox Laboratories Limited
F. Proprietary and Established Names:
Randox Opiates Assay
Randox Multi Drug Calibrator Set (DOA CAL)
Randox Multidrug Control Level 1 (DOA Control 1)
Randox Multidrug Control Level 2 (DOA Control 2)
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| DJG | Class II | 21 CFR § 862.3650, Opiates test system | 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.
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2. Indication(s) for use:
Randox Laboratories Ltd. Opiates Assay is an in vitro diagnostic test for the qualitative and semi-quantitative analysis of Opiates in human urine. The cut off for both the qualitative and semi-quantitative application is 2000ng/mL for morphine to which the assay is calibrated. Qualitative and semi-quantitative results can be utilized in the diagnosis and treatment of Opiate use or overdose. The Randox Opiates Assay has been developed for use on the RX series analysers, which includes the RX Daytona and the RX Imola. This in vitro diagnostic device is intended for prescription use only.
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.
This assay provides only a preliminary analytical test result. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatograph/Mass Spectrometry (GC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.
The Randox Multidrug Calibrator Set is for use on human urine samples. They are liquid calibrators containing Methamphetamine, Secobarbital, Methadone, and Morphine. There are 5 levels of calibrator. They have been developed for use in the calibration of Amphetamine, Barbiturates, Methadone and Opiate assays on the RX series analysers, which includes the RX Daytona and RX Imola. This in vitro diagnostic device is intended for prescription use only.
The Randox Multidrug Controls, Level 1 and 2 are for use on human urine samples. They are liquid controls containing Methamphetamine, Secobarbital, Methadone, and Morphine. There are 2 levels of controls. They have been developed for use in the quality control of Amphetamine, Barbiturates, Methadone and Opiate assays on the RX series analysers, which includes the RX Daytona and RX Imola. This in vitro diagnostic device is intended for prescription use only.
3. Special conditions for use statement(s):
The assay is for prescription use.
4. Special instrument requirements:
Performance studies contained in the 510(k) were carried out on the Rx Daytona and Rx Imola analyzers.
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I. Device Description:
Randox Opiates Assay consists of ready to use reagents. Reagent 1 (R1) contains mouse monoclonal anti-morphine antibodies, glucose-6-phosphate, NAD and sodium azide <0.1 % w/v. Reagent 2 (R2) contains morphine labeled G6PDH, buffer and sodium azide <0.1 % w/v.
The calibrators and controls are ready to use human urine-based liquid.
Methamphetamine, Secobarbital, and Methadone are previously cleared analytes.
J. Substantial Equivalence Information:
1. Predicate device name(s):
Microgenics DRI Opiate Assay
DRI Multi-Drug Calibrators and Controls
2. Predicate 510(k) number(s):
k011150
k983159
3. Comparison with predicate:
Assay
| Similarities | | |
| --- | --- | --- |
| Item | New Device
Randox Opiates Assay
Candidate device
(k113747) | Predicate
Microgenics DRI Opiates
Assay
(k011150) |
| Intended Use/
Indications for
Use | Qualitative and semi-quantitative analysis of
Opiates in human urine. | Same |
| Cut-off | 2000 ng/mL | 300 ng/mL or 2000 ng/mL |
| Sample Type | Human urine | Human urine |
| Test Principle | A competitive enzyme immunoassay 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 morphine labeled G6PDH conjugate is bound to antibody and enzyme activity is inhibited. When free drug is present in the | A homogenous enzyme immunoassay based on competition of an enzyme glucose-6-phosphate dehydrogenase (G6PDH) labeled drug and drug from urine sample for a fixed amount of specific antibody binding sites. Enzyme activity is determined spectrophotometrically at 340nm by measuring its ability to convert NAD to |
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| Similarities | | |
| --- | --- | --- |
| Item | New Device
Randox Opiates Assay
Candidate device
(k113747) | Predicate
Microgenics DRI Opiates
Assay
(k011150) |
| | sample, antibody binds to the free drug and the unbound morphine labeled G6PDH exhibits its maximum enzyme activity. Active enzyme converts NAD to NADH resulting in an absorbance change measured spectrophotometrically at 340nm. | NADH |
| Type of reagent | Liquid ready to use
Two reagent assay | Liquid ready to use
Two reagent assay |
| Methodology | Homogenous enzyme
Immunoassay | Homogenous enzyme
Immunoassay |
| Reagents | R1. Antibody/Substrate Reagent:
Mouse monoclonal anti-morphine antibodies, glucose-6-phosphate, NAD and sodium azide <0.1% w/v.
R2. Enzyme-Drug Conjugate Reagent: Morphine labeled G6PDH and sodium azide <0.1% w/v | R1. Antibody/Substrate Reagent:
Monoclonal anti-morphine antibodies, glucose-6-phosphate, NAD and sodium azide <0.1% w/v.
R2. Enzyme Conjugate Reagent: Morphine labeled G6PDH and sodium azide <0.1% w/v |
Calibrators and Controls
| Similarities | | |
| --- | --- | --- |
| Item | New Device
Randox Opiates Assay
Candidate device
(k113747) | Predicate
DRI Multi-Drug
Calibrators and Controls
(k983159) |
| Intended Use/
Indications for
Use | Same | Calibration and quality
control of various drug of
abuse Assays. |
| Analytes | Secobarbital, Methadone,
Methamphetamine and
Morphine | d-Methamphetamine,
Secobarbital, Oxazepam,
Benzoylecgonine,
Methadone, Methaqualone,
Morphine, Phencyclidine and
Propoxyphene |
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| Similarities | | |
| --- | --- | --- |
| Item | New Device
Randox Opiates Assay
Candidate device
(k113747) | Predicate
DRI Multi-Drug
Calibrators and Controls
(k983159) |
| Calibrators | Liquid ready to use (0, 300, 1000, 2000, 4000 ng/mL) | Liquid ready to use (300, 1000, 2000, 4000, 6000 ng/mL) |
| Controls | Liquid ready to use 1500, 2500 ng/mL | Liquid ready to use 300, 2000 ng/mL |
K. Standard/Guidance Document Referenced (if applicable):
EP7-A2 CLSI Interference Testing in Clinical Chemistry
EP17-A CLSI Protocols for Determination of Limits of Detection & Limits of Quantitation
L. Test Principle:
The Randox Laboratory Ltd. Opiates Assay 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, morphine-labeled G6PDH conjugate is bound to antibody, and the enzyme activity is inhibited. When free drug is present in the sample, the antibody will bind to the free drug and the unbound morphine-labeled G6PDH then exhibits its maximal enzyme activity. Active enzyme converts nicotinamide adenine dinucleotide (NAD) to NADH, resulting in an absorbance change that can be measured spectrophotometrically at 340 nm.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Precision was determined by spiking Morphine (1 mg/ml solution) into drug free urine at various concentrations (-100%, -75%, -50%, -25%, cut off, +25%, +50%, +75% and +100%). Concentrations were confirmed by GCMS. Intra-assay precision was performed over 20 nonconsecutive days. The between run testing was performed in replicate twice a day for 20 days. The qualitative and semi-quantitative results are presented below:
Rx Daytona and Rx Imola: Total Precision for qualitative mode
| Sample concentration | No. observation | Rx Daytona | Rx Imola |
| --- | --- | --- | --- |
| -100% cut off | 80 | 80 negative | 80 negative |
| -75% cut off | 80 | 80 negative | 80 negative |
| -50% cut off | 80 | 80 negative | 80 negative |
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| -25% cut off | 80 | 80 negative | 80 negative |
| --- | --- | --- | --- |
| +25% cut off | 80 | 80 positive | 80 positive |
| +50% cut off | 80 | 80 positive | 80 positive |
| +75% cut off | 80 | 80 positive | 80 positive |
| +100% cut off | 80 | 80 positive | 80 positive |
Rx Daytona and Rx Imola: Total Precision for semi-quantitative mode
| Sample concentration | No. observations | Rx Daytona | Rx Imola |
| --- | --- | --- | --- |
| -100% cut off | 80 | 80 negative | 80 negative |
| -75% cut off | 80 | 80 negative | 80 negative |
| -50% cut off | 80 | 80 negative | 80 negative |
| -25% cut off | 80 | 80 negative | 80 negative |
| +25% cut off | 80 | 80 positive | 80 positive |
| +50% cut off | 80 | 80 positive | 80 positive |
| +75% cut off | 80 | 80 positive | 80 positive |
| +100% cut off | 80 | 80 positive | 80 positive |
b. Linearity/assay reportable range:
Recovery across the range was determined by testing a series of samples that were diluted from the high concentration Morphine spiked urine sample. A high urine sample containing around 4000 ng/mL Morphine was serially diluted with analyte-free urine and tested in triplicates in the semi-quantitative mode. The results were averaged and compared to the expected result and the percent recovery was calculated. Results are presented in the tables below.
Rx Imola:
| Expected Concentration (ng/mL) | Mean Observed Concentration (ng/mL) | Recovery (%) |
| --- | --- | --- |
| 0 | 0.00 | Not applicable |
| 40 | 22.89 | 57.22 |
| 80 | 61.05 | 76.31 |
| 120 | 80.83 | 67.36 |
| 160 | 123.87 | 77.42 |
| 200 | 193.14 | 96.57 |
| 240 | 242.39 | 101.00 |
| 280 | 284.74 | 101.69 |
| 320 | 342.59 | 107.06 |
| 360 | 358.97 | 99.71 |
| 400 | 427.08 | 106.77 |
| 800 | 848.26 | 106.03 |
| 1200 | 1200.17 | 100.01 |
| 1600 | 1554.89 | 97.18 |
| 2000 | 1949.07 | 97.45 |
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| 2400 | 2328.02 | 97.00 |
| --- | --- | --- |
| 2800 | 2923.36 | 104.41 |
| 3200 | 3219.68 | 100.61 |
| 3600 | 3543.00 | 98.42 |
| 4000 | 4161.60 | 104.04 |
Rx Daytona:
| Expected Concentration (ng/mL) | Mean Observed Concentration (ng/mL) | Recovery (%) |
| --- | --- | --- |
| 0 | 0.00 | Not applicable |
| 40 | 0.00 | 0.00 |
| 80 | 38.00 | 47.50 |
| 120 | 131.72 | 109.77 |
| 160 | 196.45 | 122.78 |
| 200 | 216.18 | 108.09 |
| 240 | 260.93 | 108.72 |
| 280 | 283.22 | 101.15 |
| 320 | 346.30 | 108.22 |
| 360 | 371.16 | 103.10 |
| 400 | 429.91 | 107.48 |
| 800 | 844.61 | 105.58 |
| 1200 | 1274.79 | 106.23 |
| 1600 | 1663.39 | 103.96 |
| 2000 | 1982.23 | 99.11 |
| 2400 | 2418.72 | 100.78 |
| 2800 | 2902.23 | 103.65 |
| 3200 | 3122.82 | 97.59 |
| 3600 | 3379.54 | 93.88 |
| 4000 | 4388.57 | 109.71 |
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Traceability and value assignment
The 5 level multi-drug calibrator (0 ng/mL, 300 ng/mL, 1000 ng/mL, 2000 ng/mL, 4000 ng/mL) and 2 level multi-drug control materials (1500 ng/mL, 2500 ng/mL) are both traceable to master lots that have been GC/MS quantified. The master lots were made by spiking morphine, methadone, methamphetamine and secobarbital at the appropriate levels into a buffered human urine matrix that also contains 0.05% sodium azide. The drugs used to make the calibrators and controls are supplied by Cerilliant Corporation the accuracy of which is ensured by purity determinations (GC/FID, HPLC and NMR) and gravimetric preparation using balances calibrated with NIST traceable weights. Each of the Randox calibrator/control level is value assigned using Rx Daytona and Rx Imola. The
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target value for each level is the median of the observed values.
## Stability
Real time stability testing including shelf-life and on-board stability studies were performed for the assay, controls and calibrators. The acceptance criteria were found to be adequate. The Randox Opiates assay reagents, controls and calibrators are stable for 18 moths when stored unopened at $2 - 8^{\circ}\mathrm{C}$ and 28 days on-board at approximately $10^{\circ}\mathrm{C}$.
## 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 Randox Laboratory Ltd. Opiate Assay was evaluated for interference according to the CLSI Guideline EP7-A2 recommendations. 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 2000 ng/mL. Drug-free urine samples were used as controls. Percent 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 $\times 100\%$ gives the percent cross reactivity. These studies were performed on both, the Rx Daytona and Rx Imola analyzers. Similar results were obtained with both analyzers and in both qualitative and semi-quantitative modes. The percent cross-reactivity of the tested compounds are presented below:
Structurally related compounds:
Rx Daytona Qualitative
| Compound | Tested concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| Morphine | 2000 | 100.00 |
| 6 Acetyl-morphine | 2000 | 99.98 |
| Ethylmorphine | 1872 | 106.87 |
| Codeine | 1785 | 112.03 |
| Dihydrocodeine | 4262 | 46.93 |
| Morphine-3-β-glucoronide | 83642 | 2.39 |
| Hydromorphone | 762735 | 0.26 |
| Hydrocodone | 7780 | 25.71 |
| Oxycodone | 684002 | 0.29 |
| Heroin | 5493 | 36.41 |
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Rx Imola Qualitative:
| Compound | Tested concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| Morphine | 2000 | 100.00 |
| 6 Acetyl-morphine | 1930 | 103.64 |
| Ethylmorphine | 2560 | 84.75 |
| Codeine | 1882 | 106.26 |
| Dihydrocodeine | 5886 | 33.98 |
| Morphine-3-β-glucoronide | 87471 | 2.29 |
| Hydromorphone | 892374 | 0.22 |
| Hydrocodone | 8965 | 22.31 |
| Oxycodone | 871511 | 0.23 |
| Heroin | 7386 | 27.08 |
Rx Daytona Semi-Quantitative
| Compound | Tested concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| Morphine | 2000 | 100.00 |
| 6 Acetyl-morphine | 2060 | 97.10 |
| Ethylmorphine | 1849 | 108.19 |
| Codeine | 1808 | 110.60 |
| Dihydrocodeine | 4639 | 43.11 |
| Morphine-3-β-glucoronide | 86029 | 2.32 |
| Hydromorphone | 803275 | 0.25 |
| Hydrocodone | 8471 | 23.61 |
| Oxycodone | 712764 | 0.28 |
| Heroin | 6035 | 33.14 |
Rx Imola Semi-Qualitative:
| Compound | Tested concentration (ng/mL) | Cross-reactivity (%) |
| --- | --- | --- |
| Morphine | 2000 | 100.00 |
| 6 Acetyl-morphine | 1801 | 111.07 |
| Ethylmorphine | 1827 | 109.48 |
| Codeine | 1801 | 111.05 |
| Dihydrocodeine | 4637 | 43.13 |
| Morphine-3-β-glucoronide | 80900 | 2.47 |
| Hydromorphone | 770636 | 0.26 |
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Structurally unrelated compounds:
Rx Daytona:
| Compound | Tested Concentration (ng/mL) | -25% of 2000 ng/mL opiate cut-off | | +25% of 2000 ng/mL opiate cut-off | |
| --- | --- | --- | --- | --- | --- |
| | | Qualitative | Semi-Quantitative | Qualitative | Semi-Quantitative |
| 11-hydroxy-delta9-THC | 100,000 | NEG | NEG | POS | POS |
| 11-nor9-carboxy-delta9-THC | 100,000 | NEG | NEG | POS | POS |
| Amitriptyline | 100,000 | NEG | NEG | POS | POS |
| Amobarbital | 100,000 | NEG | NEG | POS | POS |
| (+/-) Amphetamine D5 | 100,000 | NEG | NEG | POS | POS |
| Ascorbic acid | 100,000 | NEG | NEG | POS | POS |
| Aspirin | 100,000 | NEG | NEG | POS | POS |
| Benzolyecgonine | 100,000 | NEG | NEG | POS | POS |
| B-phenylethylamine | 100,000 | NEG | NEG | POS | POS |
| Caffeine | 100,000 | NEG | NEG | POS | POS |
| Cannabidiol | 100,000 | NEG | NEG | POS | POS |
| Chlorpheniramine | 100,000 | NEG | NEG | POS | POS |
| Cocaethylene | 100,000 | NEG | NEG | POS | POS |
| Cocaine | 100,000 | NEG | NEG | POS | POS |
| Cotinine | 100,000 | NEG | NEG | POS | POS |
| Delta9-THC | 100,000 | NEG | NEG | POS | POS |
| Diazepam | 100,000 | NEG | NEG | POS | POS |
| Ecgonine methyl ester | 100,000 | NEG | NEG | POS | POS |
| EDDP | 100,000 | NEG | NEG | POS | POS |
| EMDP | 100,000 | NEG | NEG | POS | POS |
| d,l-Ephedrine | 100,000 | NEG | NEG | POS | POS |
| l-Ephedrine | 100,000 | NEG | NEG | POS | POS |
| d-Ephedrine | 100,000 | NEG | NEG | POS | POS |
| LAAM | 100,000 | NEG | NEG | POS | POS |
| MBDB | 100,000 | NEG | NEG | POS | POS |
| MDA | 100,000 | NEG | NEG | POS | POS |
| MDEA | 100,000 | NEG | NEG | POS | POS |
| MDMA | 100,000 | NEG | NEG | POS | POS |
| Methadone | 100,000 | NEG | NEG | POS | POS |
| d-Methamphetamine | 100,000 | NEG | NEG | POS | POS |
| Paracetamol | 100,000 | NEG | NEG | POS | POS |
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Rx Imola:
| Compound | Tested Concentration (ng/mL) | -25% of 2000 ng/mL opiate cut-off | | +25% of 2000 ng/mL opiate cut-off | |
| --- | --- | --- | --- | --- | --- |
| | | Qualitative | Semi-Quantitative | Qualitative | Semi-Quantitative |
| 11-hydroxy-delta9-THC | 100,000 | NEG | NEG | POS | POS |
| 11-nor9-carboxy-delta9-THC | 100,000 | NEG | NEG | POS | POS |
| Amitriptyline | 100,000 | NEG | NEG | POS | POS |
| Amobarbital | 100,000 | NEG | NEG | POS | POS |
| (+/-) Amphetamine D5 | 100,000 | NEG | NEG | POS | POS |
| Ascorbic acid | 100,000 | NEG | NEG | POS | POS |
| Aspirin | 100,000 | NEG | NEG | POS | POS |
| Benzolyecgonine | 100,000 | NEG | NEG | POS | POS |
| B-phenylethylamine | 100,000 | NEG | NEG | POS | POS |
| Caffeine | 100,000 | NEG | NEG | POS | POS |
| Cannabidiol | 100,000 | NEG | NEG | POS | POS |
| Chlorpheniramine | 100,000 | NEG | NEG | POS | POS |
| Cocaethylene | 100,000 | NEG | NEG | POS | POS |
| Cocaine | 100,000 | NEG | NEG | POS | POS |
| Cotinine | 100,000 | NEG | NEG | POS | POS |
| Delta9-THC | 100,000 | NEG | NEG | POS | POS |
| Diazepam | 100,000 | NEG | NEG | POS | POS |
| Ecgonine methyl ester | 100,000 | NEG | NEG | POS | POS |
| EDDP | 100,000 | NEG | NEG | POS | POS |
| EMDP | 100,000 | NEG | NEG | POS | POS |
| d,l-Ephedrine | 100,000 | NEG | NEG | POS | POS |
| l-Ephedrine | 100,000 | NEG | NEG | POS | POS |
| d-Ephedrine | 100,000 | NEG | NEG | POS | POS |
| LAAM | 100,000 | NEG | NEG | POS | POS |
| MBDB | 100,000 | NEG | NEG | POS | POS |
| MDA | 100,000 | NEG | NEG | POS | POS |
| MDEA | 100,000 | NEG | NEG | POS | POS |
| MDMA | 100,000 | NEG | NEG | POS | POS |
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| Methadone | 100,000 | NEG | NEG | POS | POS |
| --- | --- | --- | --- | --- | --- |
| d-Methamphetamine | 100,000 | NEG | NEG | POS | POS |
| Paracetamol | 100,000 | NEG | NEG | POS | POS |
| S,S (+)
Pseudoephedrine | 100,000 | NEG | NEG | POS | POS |
| R,R (-)
Pseudoephedrine | 100,000 | NEG | NEG | POS | POS |
| Temazepam | 100,000 | NEG | NEG | POS | POS |
| Ibuprofen | 100,000 | NEG | NEG | POS | POS |
| d-amphetamine | 100,000 | NEG | NEG | POS | POS |
Endogenous compounds:
The following endogenous compounds were added into drug-free urine and urine containing Opiate at the concentrations of $\pm 25\%$ surrounding the assay cut-off. These samples were tested using both, the Rx Daytona and Rx Imola analyzers. The substances listed in the table below were determined not to interfere at the concentration shown:
| Compound | Tested Concentration |
| --- | --- |
| Total bilirubin | 15 mg/dL |
| Direct bilirubin | 5 mg/dL |
| Hemoglobin | 115 mg/dL |
| Creatinine | 30 mg/dL |
| Urea | 258 mg/dL |
| Glucose | 2000 mg/dL |
| HAS | 500 mg/dL |
| Ethanol | 1000 mg/dL |
| Acetone | 1000 mg/dL |
| Gamma globulin | 500 mg/dL |
| Oxalic acid | 100 mg/dL |
| Riboflavin | 7.5 mg/dL |
| Sodium chloride | 6000 mg/dL |
| Boric acid | 1000 mg/dL |
| Sodium azide | 1000 mg/dL |
| Sodium fluoride | 1000 mg/dL |
In addition, the performance of the assay was evaluated under varying pH levels of: 3, 5, 7, 9 and 11, which had no effect on results. Further, variations in specific gravity between 1.00 and 1.03 also had no effect on results. These studies were performed at concentrations $\pm 25\%$ of the cut-off.
The package insert includes the complete list of all structurally related and unrelated compounds and metabolites tested.
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f. Assay cut-off:
Analytical performance of the device around the claimed cut-off is described in precision section (1 a.) above.
2. Comparison studies:
a. Method comparison with predicate device:
One hundred twenty eight unaltered clinical urine samples were evaluated by the Randox Opiate assay and compared to a GC/MS. Results from the study are presented below:
Rx Daytona – Semi-quantitative
| GC/MS for opiates (based on cross reactivity profile) → | Negative | Less than half the Cut-Off | Near Cut-off Negative (concentration between 50% below the cut-off and the cut-off concentration for Opiates) | Near Cut-off Positive (concentration between 50% above the cut-off and the cut-off concentration for Opiates) | High Positive (concentration > 50% above the cut-off concentration for Opiates) | Percent Agreement with GC/MS for Opiates (based on cross reactivity profile) |
| --- | --- | --- | --- | --- | --- | --- |
| 2000 ng/mL cut-off Opiate Assay ↓ | | | | | | |
| Positive | 0 | 0 | 9 | 21 | 41 | 92.5% |
| Negative | 43 | 2 | 7 | 5 | 0 | 85.2% |
Rx Daytona Qualitative
| GC/MS for opiates (based on cross reactivity profile) → | Negative | Less than half the Cut-Off | Near Cut-off Negative (concentration between 50% below the cut-off and the cut-off concentration for Opiates) | Near Cut-off Positive (concentration between 50% above the cut-off and the cut-off concentration for Opiates) | High Positive (concentration > 50% above the cut-off concentration for Opiates) | Percent Agreement with GC/MS for Opiates (based on cross reactivity profile) |
| --- | --- | --- | --- | --- | --- | --- |
| 2000 ng/mL cut-off Opiate Assay ↓ | | | | | | |
| Positive | 0 | 0 | 6 | 19 | 42 | 90.9 |
| Negative | 43 | 2 | 10 | 6 | 0 | 90.2 |
{13}
Rx Imola – Semi-quantitative
| GC/MS for opiate (based on cross reactivity profile) → | Negative | Less than half the Cut-Off | Near Cut-off Negative (concentration between 50% below the cut-off and the cut-off concentration for Opiates) | Near Cut-off Positive (concentration between 50% above the cut-off and the cut-off concentration for Opiates) | High Positive (concentration > 50% above the cut-off concentration for Opiates) | Percent Agreement with GC/MS for Opiates (based on cross reactivity profile) |
| --- | --- | --- | --- | --- | --- | --- |
| 2000 ng/mL cut-off Opiate Assay ↓ | | | | | | |
| Positive | 0 | 0 | 9 | 22 | 41 | 94.0 |
| Negative | 43 | 2 | 7 | 4 | 0 | 85.2 |
Rx Imola – Qualitative
| GC/MS for Morphine (based on cross reactivity profile) → | Negative | Less than half the Cut-Off | Near Cut-off Negative (concentration between 50% below the cut-off and the cut-off concentration for Opiates) | Near Cut-off Positive (concentration between 50% above the cut-off and the cut-off concentration for Opiates) | High Positive (concentration > 50% above the cut-off concentration for Opiates) | Percent Agreement with GC/MS for Opiates (based on cross reactivity profile) |
| --- | --- | --- | --- | --- | --- | --- |
| 2000 ng/mL cut-off Opiate Assay ↓ | | | | | | |
| Positive | 0 | 1 | 6 | 22 | 41 | 94.0 |
| Negative | 43 | 2 | 9 | 4 | 0 | 88.5 |
GC/MS Summary of Discordant Results:
Rx Daytona – Semi-quantitative
| Cut-off value (ng/mL) for Morphine | Randox Opiates Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) based on cross reactivity profile |
| --- | --- | --- |
| 2000 | POS | 1798 (Morphine) |
| | POS | 1306 (Morphine) |
| | POS | 462 (Morphine) & 629 (Codeine) |
| | POS | 588 (Morphine) & 431 (Codeine) |
| | POS | 728 (Morphine) & 250 (Codeine) |
| | POS | 252 (Morphine) & 784 (Codeine) |
| | POS | 1550 (Morphine) |
| | POS | 1990 (Morphine) |
| | POS | 1550 (Morphine) |
| | NEG | 2313 (Morphine) |
| | NEG | 1967 (Morphine) & 910 (Hydromorphone) |
| | NEG | 2300 (Morphine) |
{14}
15
Rx Daytona – Qualitative
| Cut-off value (ng/mL) for Morphine | Randox Opiates Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) based on cross reactivity profile |
| --- | --- | --- |
| 20008 | POS | 462 (Morphine) & 629 (Codeine) |
| | POS | 588 (Morphine) & 431 (Codeine) |
| | POS | 728 (Morphine) & 250 (Codeine) |
| | POS | 252 (Morphine) & 784 (Codeine) |
| | POS | 1990 (Morphine) |
| | POS | 1550 (Morphine) |
| | NEG | 1967 (Morphine) & 910 (Hydromorphone) |
| | NEG | 2313 (Morphine) |
| | NEG | 2300 (Morphine) |
| | NEG | 2100 (Morphine) |
| | NEG | 2500 (Morphine) |
| | NEG | 2700 (Morphine) |
Rx Imola – Semi-quantitative
| Cut-off value (ng/mL) for Morphine | Randox Opiates Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) based on cross reactivity profile |
| --- | --- | --- |
| 2000 | POS | 1967 (Morphine) |
| | POS | 1306 (Morphine) |
| | POS | 462 (Morphine) & 629 (Codeine) |
| | POS | 588 (Morphine) & 431 (Codeine) |
| | POS | 728 (Morphine) & 250 (Codeine) |
| | POS | 252 (Morphine) & 784 (Codeine) |
| | POS | 1990 (Morphine) |
| | POS | 1550 (Morphine) |
| | NEG | 2174 (Morphine) |
| | NEG | 2313 (Morphine) |
| | NEG | 2300 (Morphine) |
| | NEG | 2100 (Morphine) |
Rx Imola – Qualitative
| Cut-off value (ng/mL) for Morphine | Randox Opiates Assay (POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) based on cross reactivity profile |
| --- | --- | --- |
| 2000 | POS | 1967 (Morphine) |
| | POS | 462 (Morphine) & 629 (Codeine) |
| | POS | 588 (Morphine) & 431 (Codeine) |
| | POS | 728 (Morphine) & 250 (Codeine) |
| | POS | 252 (Morphine) & 784 (Codeine) |
| | POS | 1990 (Morphine) |
{15}
16
| | POS | 1550 (Morphine) |
| --- | --- | --- |
| | NEG | 2174 (Morphine) |
| | NEG | 2300 (Morphine) |
| | NEG | 2100 (Morphine) |
| | NEG | 2313 (Morphine) |
b. Matrix comparison:
Not applicable. The test is only for urine specimens.
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable. Not reviewed for this device type.
b. Clinical specificity:
Not applicable.
c. Other clinical supportive data (when a. and b. are 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.