RAPIDFRET ORAL FLUID ASSAY FOR AMPHETAMINE, RAPIDFRET ORAL FLUID AMPHETAMINE CALIBRATOR SET, RAPIDFRET ORAL FLUID AMPHETAMINE CONTROL SET
K141748 · Biophor Diagnostics, Inc. · DKZ · May 20, 2015 · Clinical Toxicology
Device Facts
Record ID
K141748
Device Name
RAPIDFRET ORAL FLUID ASSAY FOR AMPHETAMINE, RAPIDFRET ORAL FLUID AMPHETAMINE CALIBRATOR SET, RAPIDFRET ORAL FLUID AMPHETAMINE CONTROL SET
Applicant
Biophor Diagnostics, Inc.
Product Code
DKZ · Clinical Toxicology
Decision Date
May 20, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3100
Device Class
Class 2
Indications for Use
The RapidFRET Oral Fluid Assay for Amphetamine is a homogeneous time-resolved fluorescence assay that is intended for prescription use in central laboratories only on the RapidFRET Integrated Workstation. The assay is used to perform a qualitative screen for amphetamine at 50 ng/mL in neat oral fluid samples collected with the RapidEASE Oral Fluid Collector. This assay provides only a preliminary result. To obtain a confirmed analytical result, a more specific alternate chemical method such as GC/MS or LC/MS/MS is required. Professional judgment should be applied to any drug test result, particularly when using preliminary positive results. For In Vitro Diagnostic Use Only. The RapidFRET Oral Fluid Calibrator Set and RapidFRET Oral Fluid Control Set are intended for use only with the RapidFRET Oral Fluid Assay for Amphetamine and samples collected with the RapidEASE Oral Fluid Collector. The cutoff calibrator is used to determine the cutoff level and translate the assay measurement into a positive result. The positive and negative controls are used to monitor laboratory systems, operators, precision, accuracy and assay conditions. For In Vitro Diagnostic Use Only.
Device Story
RapidFRET Oral Fluid Assay for Amphetamine is a homogeneous time-resolved fluorescence competitive immunoassay. Input: neat oral fluid samples collected via RapidEASE Oral Fluid Collector. Operation: competitive binding between drug in sample and donor-fluorophore-labeled drug for binding sites on acceptor-fluorophore-labeled monoclonal antibody. Proximity of fluorophores triggers FRET signal; signal intensity is inversely proportional to drug concentration. Output: qualitative positive/negative result determined by comparison to 50 ng/mL cutoff calibrator. Used in central laboratories; operated by professional laboratory staff. Results provide preliminary screening; require confirmation by GC/MS or LC/MS/MS. Clinical decision-making relies on professional judgment following preliminary positive results. Benefits include rapid screening for amphetamine presence in oral fluid.
Clinical Evidence
No clinical studies performed. Evidence consists of analytical bench testing. Precision study (N=88 per level) evaluated performance across 0-200% of cutoff. Method comparison study (N=415) compared RapidFRET results against LC/MS/MS reference method. Specificity testing evaluated 167 compounds for cross-reactivity and interference. Stability studies confirmed performance for room temperature (7 days), refrigerated (30 days), and frozen (4 months) storage.
Indicated for qualitative screening of amphetamine in neat oral fluid at a 50 ng/mL cutoff. Intended for prescription use in central laboratories by professional operators. Requires confirmation by alternate chemical methods (GC/MS or LC/MS/MS).
Regulatory Classification
Identification
An amphetamine test system is a device intended to measure amphetamine, a central nervous system stimulating drug, in plasma and urine. Measurements obtained by this device are used in the diagnosis and treatment of amphetamine use or overdose and in monitoring levels of amphetamine to ensure appropriate therapy.
Special Controls
*Classification.* Class II (special controls). An amphetamine 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
Roche Diagnostics DAT Oral Fluid Amphetamine (k110446)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k141748
B. Purpose for Submission:
New device
C. Measurand:
Amphetamine
D. Type of Test:
Qualitative enzyme immunoassay
E. Applicant:
Biophor Diagnostics, Inc.
F. Proprietary and Established Names:
RapidFRET Oral Fluid Assay for Amphetamine
RapidFRET Oral Fluid Amphetamine Calibrator Set
RapidFRET Oral Fluid Amphetamine Control Set
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| DKZ | Class II | 21 CFR 862.3100, Amphetamine test system | 91-Toxicology |
| DLJ | Class II | 21 CFR 862.3200, Clinical toxicology calibrator | 91-Toxicology |
| LAS | Class I, reserved | 21 CFR 862.3280, Clinical toxicology control material | 91-Toxicology |
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H. Intended Use:
1. Intended use(s):
See Indications for Use below.
2. Indication(s) for use:
The RapidFRET Oral Fluid Assay for Amphetamine is a homogeneous time-resolved fluorescence assay that is intended for prescription use in central laboratories only on the RapidFRET Integrated Workstation. The assay is used to perform a qualitative screen for Amphetamine at 50 ng/mL in neat oral fluid samples collected with the RapidEASE Oral Fluid Collector. This assay provides only a preliminary result. To obtain a confirmed analytical result, a more specific alternate chemical method such as GC/MS or LC/MS/MS is required. Professional judgment should be applied to any drug test result, particularly when using preliminary positive results. For In Vitro Diagnostic Use Only.
The RapidFRET Oral Fluid Amphetamine Calibrator Set and RapidFRET Oral Fluid Amphetamine Control Set are intended for use only with the RapidFRET Oral Fluid Assay for Amphetamine and samples collected with the RapidEASE Oral Fluid Collector. The cutoff calibrator is used to determine the cutoff level and translate the assay measurement into a positive or negative result. The positive and negative controls are used to monitor laboratory systems, operators, precision, accuracy and assay conditions.
For In Vitro Diagnostic Use Only.
3. Special conditions for use statement(s):
For prescription use in central laboratories only.
4. Special instrument requirements:
RapidFRET Integrated Workstation
I. Device Description:
The RapidFRET® Oral Fluid Assay for Amphetamine is sold as a kit in two sizes. Each kit consists of 96 Well Microtiter Plates (round bottom plates), Amphetamine (AMP) Acceptor Reagent, AMP Donor Reagent, Matrix Blank Reagent, the RapidEASE Oral Fluid Collector, Negative Calibrator (0 ng/mL), Cutoff Calibrator (50 ng/mL), Negative Control (25 ng/mL, 50% cutoff), and Positive Control (75 ng/mL, 150% cutoff).
The Calibrators and Controls Sets are required for running the assay and are purchased separately from the Assay Kit.
J. Substantial Equivalence Information:
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1. Predicate device name(s):
Roche Diagnostics DAT Oral Fluid Amphetamine
2. Predicate 510(k) number(s):
k110446
3. Comparison with predicate:
| Similarities and Differences | | |
| --- | --- | --- |
| Item | Candidate Device (RapidFRET AMP) | Predicate Device (Roche AMP, k110446) |
| Indications for Use | Same, except only qualitative | Qualitative and semi-quantitative determination of amphetamine in human oral fluid in clinical setting. |
| Methodology | Same | Competitive homogeneous immunoassay. |
| Kit Components | Same | One Drug specific antibody reagent in liquid, ready to use format. One Drug conjugate reagent in liquid, ready to use format. |
| Neat Oral Fluid Cutoff Level | 50 ng/mL neat oral fluid. | 120 ng/mL neat oral fluid using a 40 ng/mL cutoff calibrator to account for sample dilution by collection device. |
| Platform | RapidFRET Integrated Workstation | Roche Modular P Analyzer |
| Sample Collection | Neat oral fluid is collected with the RapidEASE Oral Fluid Collector via direct expectoration. No diluent is used and sample is stored in glass sample tube with inert screw cap. | Oral fluid is collected with the Intercept Oral Specimen Collection Device. This device uses an absorbent swab and diluent. Sample is stored in plastic tube with snap cap. |
| Controls and Calibrator Levels | Calibrators are available at 0 ng/mL and 50 ng/mL. Controls are available at 25 ng/mL and 75 ng/mL. | Calibrators are available at 0 ng/mL and 40 ng/mL for qualitative mode. Controls are available at 20 ng/mL (0.5X) and 60 ng/mL (1.5X) levels. |
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K. Standard/Guidance Document Referenced (if applicable):
None referenced.
L. Test Principle:
The RapidFRET Oral Fluid Assay for Amphetamine is an In Vitro Diagnostic competitive immunoassay used to detect amphetamine in human oral fluid. This is a ready-to-use homogenous system that involves energy transfer between an acceptor fluorophore labeled to an mouse monoclonal antibody and a donor fluorophore labeled to drug. The assay is based on competition between drug in the sample and drug labeled with the donor fluorophore for a fixed number of binding sites on the antibody reagent. When acceptor and donor fluorophores are brought into close proximity through a binding event, energy transfer occurs. The fluorescence resonance energy transfer (FRET) signal is measured at the wavelength of the acceptor fluorophore and is inversely proportional to the amount of drug in the sample. A Cutoff Calibrator is used to translate the sample measurement into a positive or negative result. Controls are used to establish and monitor precision and accuracy.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
All performance testing of the RapidFRET Oral Fluid Assay for Opiates was performed on the RapidFRET Integrated Workstation.
a. Precision/Reproducibility:
A precision study was performed using three lots of the RapidFRET Amphetamine assay. Negative oral fluid pools were spiked with amphetamine at 0%, 25%, 50%, 75%, 100%, 125%, 150%, 175% and 200% of the cutoff level of 50 ng/mL. These samples were processed through the RapidEASE Oral Fluid Collector and analyzed four times daily for a minimum of 20 days by two laboratory operators. The drug levels in the spiked samples were confirmed by quantitative methods, GC/MS or LC/MS/MS.
Representative data from one lot is summarized in the table below. The percentage of negative and positive results was consistent across the three lots tested. Precision data from this lot was collected over 43 days total with 22 collection days. Two professional laboratory operators were used to collect this data.
| | 0% | 25% | 50% | 75% | 100% | 125% | 150% | 175% | 200% |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| POS | 0 | 0 | 0 | 0 | 32 | 87 | 88 | 88 | 88 |
| NEG | 88 | 88 | 88 | 88 | 56 | 0 | 0 | 0 | 0 |
| N | 88 | 88 | 88 | 88 | 88 | 87* | 88 | 88 | 88 |
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*One sample was lost due to instrument aspiration error.
b. Linearity/assay reportable range:
Not applicable.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
## Traceability – Calibrators and Controls
Calibrators and controls are ready-to-use synthetic oral fluid solutions. The cutoff calibrator and controls are prepared by spiking known concentrations of amphetamine into synthetic oral fluid to obtain the cutoff level calibrator, and the positive and negative controls. The negative calibrator is drug free synthetic oral fluid.
Calibrators and controls are prepared from amphetamine from commercial primary standards purchased from a commercial vendor that uses NIST traceable weights and specific assays, such as HPLC and GC/MS, to confirm drug levels.
## Value Assignment - Calibrators and Controls
Calibrator and Control lots are value assigned during the manufacturing process in two steps. During the first stage, following bottling and labeling, new lots are assayed against at least one previously accepted, released and unexpired Calibrator and Control lot using RapidFRET reagents. Results are qualitatively evaluated for performance relative to the previously accepted lots. During the second stage, each new manufactured lot of Calibrator (Cutoff only) or Control (POS and NEG) is quantitatively confirmed by mass spectrometry (MS)-based method for target analyte concentration. Protocols and acceptance criteria were reviewed and found to be acceptable.
## Calibrators and Controls Stability Studies
Real-time stability studies were conducted on multiple lots of RapidFRET Oral Fluid Calibrators and RapidFRET Oral Fluid Controls. The stability protocols for open and closed vial were reviewed and found acceptable. The open vial and closed vial study results support the open vial stability claim of 30 days and closed vial stability claim of 12 months when stored at 2 to 8 °C for the RapidFRET Oral Fluid Calibrators and RapidFRET Oral Fluid Controls.
## Sample Shipment – Stability Study
A neat oral fluid pool was spiked with amphetamine to approximate 0%, 25%, 50%, 75%, 100%, 125%, 150%, 175% and 200% of the cutoff. Each spike was subsequently processed through a RapidEASE Oral Fluid Collection device to mimic actual collection process. Aliquots were stored and handled according to the collector insert. Samples were shipped multiple times at ambient temperature (4°C to 30°C) and at low to high relative humidity conditions (7% to 100% R.H.) from California to North Carolina and back to California by FedEx Standard Overnight Express. Samples were evaluated at various time points quantitatively by MS based method
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Amphetamine average recovery versus target concentration ranged from 92.8% to 102.0% across all spike levels during the course of 11 shipping days (4 cross country shipments plus carrier storage). Study data indicates that neat oral fluid samples containing amphetamine, transported in the RapidEASE Oral Fluid Collector showed quantitative stability around the cutoff under conditions exceeding those outlined in product insert for expected use.
## Sample handling and Storage - Stability Studies
Conditions for oral fluid sample handling and storage were evaluated by preparing oral fluid samples with amphetamine from approximately 0% Cutoff (0 ng/mL) to 200% Cutoff (100 ng/mL) in approximately 25% increments. Samples were processed through RapidEASE oral fluid collection devices and stored under various conditions including room temperature, refrigerated (2 - 8 °C) and frozen (-10 to -25 °C). Samples were periodically sampled and analyzed. For each storage condition two sets of 9 levels each (18 samples total) were prepared and analyzed. Frozen storage study is ongoing. Average percent target recoveries ranged from 94.3% to 99.1% after storage at room temperature for 30 days, 93.4% to 98.5% after 56 days of refrigeration, and 91.5% to 100.9% freezing for 163 days. Based on the sample handling and storage study results, the sponsor has included the following statement in the labeling, "Room temperature storage for up to 7 days, refrigerated storage (2°C to 8°C) up to 30 days and frozen storage (-10°C to -25°C) for up to 4 months."
## Sample Recovery Study
Recovery studies were conducted by aliquoting neat, human oral fluid pool into glass tubes and spiking with amphetamine to achieve concentrations ranging from 0% of cutoff (0 ng/mL) to 200% of cutoff (100 ng/mL) in replicates of five for each level in increments of 25% (12.5 ng/mL). Approximately half of the volume of each of these 'PRE-RapidEASE' samples was then removed and processed through a new RapidEASE Oral Fluid collector, mimicking as closely as possible the actual sample collection protocol, resulting in a 'PRE-RapidEASE' sample. The concentration of amphetamine in both the PRE-RapidEASE and the POST-RapidEASE samples for each spike level were measured by Mass Spectrometry. The results are summarized below:
| % Cutoff | Average Pre-RapidEASE Amphetamine (ng/dL) | Average Post-RapidEASE Amphetamine (ng/dL) | Average Percent Recovery |
| --- | --- | --- | --- |
| 200 % | 95.84 | 98.20 | 102.5% |
| 175 % | 79.42 | 81.72 | 102.9% |
| 150 % | 73.50 | 76.06 | 103.5% |
| 125 % | 57.80 | 60.64 | 104.6% |
| 100 % | 50.24 | 50.88 | 101.3% |
| 75 % | 34.30 | 34.88 | 101.7% |
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d. Detection limit:
Not applicable.
e. Analytical specificity:
A compound library of approximately 167 different structurally related and unrelated compounds including metabolites, Over-The-Counter and prescription medications and other drugs of abuse were used to evaluate cross reactivity and interference. Structurally related compounds were spiked at 30,000 ng/mL into neat oral fluid pool aliquots with 0 ng/mL amphetamine for cross-reactivity determinations, and structurally unrelated compounds were spiked at 30,000 ng/mL into neat oral fluid pool aliquots with 25 ng/mL and 75 ng/mL of amphetamine for interference determinations. All samples were processed with the RapidEASE Collector and tested with the RapidFRET AMP assay.
No interference was seen with the tested structurally unrelated compounds. The list of compounds that do not interfere with the assay are listed in the table below:
| Cotinine | Clonazepam | Levorphanol |
| --- | --- | --- |
| (-) Ephedrine | Clorazepate | Lidocaine |
| (-) Epinephrine | Cocaethylene | l-Methamphetamine |
| (+) Brompheniramine | Cocaine | Loperamide |
| (+) Chlorpheniramine | Codeine | Lorazepam |
| (+) Naproxen | Creatine | l-Phenylalanine |
| (+/-) Chlorpheniramine | Cyclizine | l-Phenylephrine |
| (+/-) Epinephrine | Cyclobenzaprine | LSD |
| Isoprenaline | d-Ephedrine | Maprotiline |
| (+/-) Methadone | Desipramine | MBDB |
| (+/-) Pseudoephedrine | Dexbrompheniramine | Medazepam |
| (R, 2R) Pseudoephedrine | Dextromethorphan | Meperidine |
| 11-Hydroxy-Δ-9-THC | D-Glucose | Mephentermine |
| 4-Aminophenylsulfone | Diacetylmorphine (Heroin) | Methadol |
| 4-Dimethylaminoantipyrine | Diazepam | Methaqualone |
| 4-Hydroxy-PCP | Dihydrocodeine | Methylphenidate |
| 6-Monoacetylmorphine | Diphenhydramine | Morphine |
| Acetaminophen | Diphenylhydantoin | Morphine-3βDG |
| Acetylsalicylic acid | d-Methamphetamine | Nalorphine |
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| Alprazolam | Dopamine | Naloxone |
| --- | --- | --- |
| Amitriptyline | Doxepin | Naltrexone |
| Amobarbital | Doxylamine | Niacinamide |
| Ampicillin | d-Propoxyphene | Nicotine |
| Aprobarbital | Ecgonine | Nitrazepam |
| Ascorbic acid | Ecgonine methyl ester | N-Methylephedrine |
| Aspartame | EDDP | Norcocaine |
| Atropine | Erythromycin | Nordiazepam |
| Benzocaine | Ethylmorphine | Norketamine |
| Benzoylecgonine | Fenfluramine | Normorphine |
| Bromazepam | Fenoprofen | Norpropoxyphene |
| Buprenorphine | Fentanyl | Nortriptyline |
| Butabarbital | Flunitrazepam | O-Desmethylvenlafaxine |
| Butalbital | Fluoxetine | Oxalic acid |
| Caffeine | Flurazepam | Oxazepam |
| Cannabidiol | Furosemide | Oxycodone |
| Cannabinol | Glipizide | Oxymorphone |
| Carbamazepine | Guaiacol glycerol | Pantoprazole |
| Chlordiazepoxide | Hydrocodone | PCM (PCP Analog) |
| Chloroquine | Hydromorphone | Penicillin G |
| Chlorothiazide | Ibuprofen | Pentazocine |
| Chlorpromazine | Imipramine | Pentobarbital |
| Clobazam | Isoxsuprine | Perphenazine |
| Clomipramine | Ketamine | Phencyclidine |
| Phendimetrazine | Protriptyline | Trifluoperazine |
| Pheniramine | Quetiapine | Trimethobenzamide |
| Phenobarbital | Quinidine | Trimipramine |
| Phenothiazine | Ranitidine | Venlafaxine |
| PMMA | Rifampin | Δ-8-THC |
| Prazepam | Secobarbital | Δ-9-THC |
| Primidone | Sulindac | Δ-9-THC acid |
| Procaine | Theophylline | Buproprion |
| Procainamide | Tramadol | Hydroxy-buproprion |
| Promethazine | Triazolam | Dihydrobupropion |
For cross-reactivity, the compounds that gave an unexpected result were further titrated to determine the concentration at which the cross-reacting compound yielded a result approximately equivalent to the cutoff. The cross-reactivity of structurally related compounds is summarized in the table below:
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| Cross-Reactivity Data | | | |
| --- | --- | --- | --- |
| Compound | Level (ng/mL) | Cutoff Equivalent Concentration | Cross-Reactivity |
| Benzodioxolylbutanamine | 30,000 | 388 | 13% |
| Phenethylamine | 30,000 | 5,500 ng/mL | 0.9% |
| Methylenedioxyamphetamine | 30,000 | 95 | 53% |
| Methylenedioxyethylamphetamine | 30,000 | 24,167 ng/mL | 0.2% |
| Methylenedioxymethamphetamine | 30,000 | NEG | 0.0% |
| Phentermine | 30,000 | 1,789 ng/mL | 2.8% |
| para-Methoxyamphetamine | 30,000 | 533 | 9.4% |
| l-Amphetamine | 30,000 | 4,987 ng/mL | 1.0% |
| d-Amphetamine | 3,750 | 50 | 100% |
| d/l-Amphetamine | 60,000 | 118 | 42.4% |
| d-Methamphetamine | 30,000 | NEG | 0.0% |
| l-Methamphetamine | 30,000 | NEG | 0.0% |
| Ephedrine | 30,000 | NEG | 0.0% |
The RapidFRET AMP assay also exhibits cross-reactivity with the compound, Dimethylcathinone (DMC), a metabolite of the designer drug dimethylmethcathinone and member of the cathinone class of drugs that share significant structural similarities to amphetamine. The labeling of the device contains explicit details regarding dimethylcathinone cross-reactivity.
$^{1}$ Usui, K., Aramamaki, T, et. al., Legal Medicine, 16, (2014), 222-226.
To evaluate the effect of endogenous substances, pH, food, drinks, medications, and tobacco products that may be present in oral fluid samples, aliquots of a neat oral fluid pool were prepared and spiked with the potential interferent and amphetamine to achieve approximately $+/- 50\%$ of the cutoff. Samples were then processed through a RapidEASE Oral Fluid Collector and analyzed. No negative or positive interference was observed in this study.
| Compound Name | Neat Oral Fluid Concentration |
| --- | --- |
| Human Serum Albumin (HSA) | 1.0 mg/mL |
| Alcohol (Ethanol) | 1% v/v |
| Baking Soda | 6% w/v |
| Whole Blood | 0.4% v/v |
| Hemoglobin | 0.5 mg/mL |
| Hydrogen Peroxide, OTC (3%) | 6% v/v |
| Sodium Chloride | 18 ng/mL |
| pH 5, 6, 7, 8, 9 | N/A |
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| Cholesterol | 45 ng/mL |
| --- | --- |
| Denture Adhesive | 0.6% w/v |
| Ascorbic Acid | 1 mg/mL |
| Bilirubin | 150 ug/mL |
| IgA | 0.1 mg/mL |
| IgG | 0.5 mg/mL |
| IgM | 0.1 mg/mL |
| Antiseptic Mouthwash | 1 oz. |
| Cough Syrup | 1 teaspoon |
| Cranberry Juice | 6 oz. |
| Orange Juice | 8 oz. |
| Tooth Paste | 1 gram |
| Chewing Tobacco | 1 gram |
| Cigarettes | 1 cigarette |
| Chewing Gum | 1 piece |
| Hard Candy | 1 piece |
| Teeth Whitening Strips | 2 strips |
| Cola | 12 oz. |
| Water | 6 oz. |
| Antacid | 2 x 500 mg tablets |
| Coffee | 8 oz. |
| Salivary α-Amylase | 2,500 units / mL |
There is the possibility that other substances and/or factors not listed above may interfere with the test.
f. Assay cut-off:
Analytical performance of the device around the cutoff is described in the precision section M.1.a. above.
2. Comparison studies:
a. Method comparison with predicate device:
Neat oral fluid was collected with the RapidEASE Oral Fluid Collector from volunteers. A total of 415 samples were randomized and blinded to the instrument operator and assayed using the RapidFRET amphetamine assay and LC/MS reference method. The results are summarized in the table below:
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| Accuracy | | | | |
| --- | --- | --- | --- | --- |
| N = 415 | Negative by the predicate device or less than half the cutoff concentration by MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| Positive | 14* | 0 | 6 | 35 |
| Negative | 321 | 37 | 2** | 0 |
*Of the fourteen samples, twelve samples contained MDA above the cutoff equivalent cross reactivity level (in ng/mL: 151, 113, 109, 93, 90, 82, 73, 70, 56, 51, 51, and 51). The remaining two samples contained high levels of Dimethylcathinone (DMC), a metabolite of the designer drug dimethylmethcathinone and member of the cathinone class of drugs that share significant structural similarities to amphetamine.¹ **Samples contained 71.6 ng/mL and 70.3 ng/mL amphetamine.
¹ Usui, K., Aramamaki, T, et. Al., Legal Medicine, 16, (2014), 222-226.
b. Matrix comparison:
Not applicable. Oral fluid is the only acceptable matrix.
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable.
b. Clinical specificity:
Not applicable.
c. Other clinical supportive data (when a. and b. are not applicable):
Not applicable.
4. Clinical cut-off:
Not applicable.
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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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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.