Immunalysis Amphetamine Urine Enzyme Immunoassay, Immunalysis Amphetamine Urine Calibrator, Immunalysis Amphetamine Urine Control Set
Applicant
Immunalysis Corporation
Product Code
DKZ · Clinical Toxicology
Decision Date
Feb 6, 2015
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3100
Device Class
Class 2
Attributes
Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K143500 · Feb 6, 2015
Immunalysis Amphetamine Urine Enzyme Immunoassay, Immunalysis Amphetamine Urine Calibrator, Immunalysis Amphetamine Urine Control Set
Immunalysis Corporation
Anonymous and discarded clinical urine samples from clinical testing laboratories
Retrospective clinical urine samples were used to perform a method comparison study, evaluating the performance of the Immunalysis Amphetamine Urine Enzyme Immunoassay against LC/MS confirmation.
Anonymous and discarded clinical urine samples; Sample Size: Not explicitly stated (tables show 80 determinations per cutoff)
LC/MS (Liquid Chromatography Tandem Mass Spectrometry)
Qualitative and semi-quantitative assay performance (agreement with LC/MS)
Indications for Use
The Immunalysis Amphetamine Urine Enzyme Immunoassay Kit is a homogeneous enzyme immunoassay with dual cutoffs of 500 ng/mL and 1000 ng/mL. The assay is intended for use in laboratories for the qualitative and semiquantitative analysis of Amphetamine in human urine with automated clinical chemistry analyzers. This assay is calibrated against Amphetamine. This in-vitro device is for prescription use only. The semi-quantitative mode is for purposes of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as GC-MS or permitting laboratories to establish quality control procedures. The Immunalysis Amphetamine Urine Enzyme Immunoassay Kit provides only a preliminary analytical test result. A more specific alternate chemical must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry (GC-MS) or Liquid Chromatography/Mass Spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are used.
Device Story
The Immunalysis Amphetamine Urine Enzyme Immunoassay is a homogeneous enzyme immunoassay used in clinical laboratories to detect amphetamine in human urine. The device utilizes an antibody/substrate reagent containing monoclonal antibodies to amphetamine, G6P, and NAD, and an enzyme conjugate reagent containing amphetamine derivative labeled with G6PDH. When used on automated clinical chemistry analyzers, the assay provides qualitative or semi-quantitative results. The semi-quantitative mode assists laboratories in determining appropriate specimen dilutions for confirmatory testing. Results are preliminary; positive findings require confirmation via GC-MS or LC/MS. The device aids healthcare providers in drug abuse screening, where clinical judgment is required to interpret results. Benefits include rapid, automated screening for amphetamine presence in urine samples.
Clinical Evidence
Bench testing only. Precision evaluated per CLSI EP5-A2 (n=80 per cutoff). Method comparison performed against LC/MS using clinical urine samples (n=80 for 500 ng/mL cutoff; n=81 for 1000 ng/mL cutoff). Qualitative agreement for 500 ng/mL cutoff was 100% for both positives and negatives. Qualitative agreement for 1000 ng/mL cutoff was 98% for positives and 100% for negatives. Interference testing conducted per CLSI EP7-A2; no interference observed for tested endogenous substances, pH, or specific gravity ranges.
Technological Characteristics
Homogeneous enzyme immunoassay. Reagents: mouse monoclonal antibodies to Amphetamine, G6PDH-labeled Amphetamine, G6P, NAD, Tris buffer, Sodium Azide preservative. Liquid, ready-to-use form. Sensing principle: spectrophotometric measurement of G6PDH activity at 340 nm. Storage: 2–8°C. Compatible with automated clinical chemistry analyzers (e.g., Beckman Coulter AU400e).
Indications for Use
Indicated for the qualitative and semi-quantitative analysis of Amphetamine in human urine for prescription use in laboratory settings using automated clinical chemistry analyzers.
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
VITROS® Chemistry Products AMPH Reagent, VITROS® Chemistry Products Calibrator Kit 26, VITROS® Chemistry Products FS Calibrator 1, VITROS® Chemistry Products DAT Performance Verifiers I, II, III, IV and V (K062077)
Submission Summary (Full Text)
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1
# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k143500
B. Purpose for Submission:
New device
C. Measurand:
Amphetamine
D. Type of Test:
Homogenous enzyme immunoassay
E. Applicant:
Immunalysis Corporation
F. Proprietary and Established Names:
Immunalysis Amphetamine Urine Enzyme Immunoassay
Immunalysis Amphetamine Urine Calibrators
Immunalysis Amphetamine Urine Controls
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| DKZ | Class II | 21 CFR 862.3100, Amphetamine test system | Toxicology (91) |
| DLJ | Class II | 21 CFR 862.3200, Clinical toxicology calibrator | Toxicology (91) |
| LAS | Class 1, reserved | 21 CFR 862.3280, Clinical toxicology control material | Toxicology (91) |
H. Intended Use:
1. Intended use(s):
{1}
Refer to Indications for Use below.
2. Indication(s) for use:
The Immunalysis Amphetamine Urine Enzyme Immunoassay Kit is a homogeneous enzyme immunoassay with dual cutoffs of 500 ng/mL and 1000 ng/mL. The assay is intended for use in laboratories for the qualitative and semi-quantitative analysis of Amphetamine in human urine with automated clinical chemistry analyzers. This assay is calibrated against Amphetamine. This in-vitro device is for prescription use only.
The semi-quantitative mode is for purposes of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as GC-MS or permitting laboratories to establish quality control procedures.
The Immunalysis Amphetamine Urine Enzyme Immunoassay Kit provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry (GC-MS) or Liquid Chromatography/Mass Spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are used.
Immunalysis Amphetamine Urine Controls: The Immunalysis Amphetamine Urine Controls are used as control materials in Immunalysis Amphetamine Urine Enzyme Immunoassay.
Immunalysis Amphetamine Urine Calibrators: The Immunalysis Amphetamine Urine Calibrators are used as calibrators in the Immunalysis Amphetamine Urine Enzyme Immunoassay for the qualitative and semi-quantitative determination of Amphetamine in urine on automated clinical chemistry analyzers.
3. Special conditions for use statement(s):
For prescription use only.
For in vitro diagnostic use only.
4. Special instrument requirements:
The Beckman Coulter AU400e Chemistry Analyzer was used to generate the performance data in this submission. Instruments must be capable of maintaining a constant reaction temperature, pipetting samples and reagents, mixing reagents, timing reactions and measuring enzyme rates precisely.
I. Device Description:
The assay consists of antibody/substrate reagent and enzyme conjugate reagent. The
2
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antibody/substrate reagent includes monoclonal mouse antibodies to Amphetamine, glucose-6-phosphate (G6P) and nicotinamide adenine dinucleotide (NAD) in Tris buffer with Sodium Azide as a preservative. The enzyme conjugate reagent contains glucose-6-phosphate dehydrogenase (G6PDH) labeled with Amphetamine in Tris buffer with Sodium Azide as a preservative.
Calibrators and control materials are prepared by mixing a commercially available standard solution of Amphetamine with BSA (Bovine Serum Albumin) to the desired concentrations. The negative standard is prepared with BSA Buffer and is compared to a negative reference standard to ensure that it is free of analyte.
The following calibrators and controls are available:
| 500 ng/mL Cutoff | |
| --- | --- |
| Level | Concentration (ng/mL) |
| LOW Control | 375 |
| Calibrator Level 1 | 500 |
| HIGH Control | 625 |
| Calibrator Level 2 | 1000 |
| Calibrator Level 3 | 1500 |
| Calibrator Level 4 | 2000 |
| 1000 ng/mL Cutoff | |
| --- | --- |
| Level | Concentration (ng/mL) |
| LOW Control | 750 |
| Calibrator Level 1 | 500 |
| HIGH Control | 1250 |
| Calibrator Level 2 | 1000 |
| Calibrator Level 3 | 1500 |
| Calibrator Level 4 | 2000 |
All reagents, calibrators, and controls are in a liquid, ready to use form.
J. Substantial Equivalence Information:
1. Predicate device name(s):
Ortho-Clinical Diagnostics VITROS Chemistry Products AMPH Reagent, Calibrators, and Performance Verifiers
2. Predicate 510(k) number(s):
k062077
3. Comparison with predicate:
{3}
| Similarities - Reagent | | |
| --- | --- | --- |
| Item | Device | Predicate (k062077) |
| Intended Use | Same | For the qualitative and semiquantitative determination of the presence of amphetamine |
| Cutoffs | Same | 500 and 1000 ng/mL |
| Matrix | Same | Urine |
| Methodology | Same | Homogenous Enzyme Immunoassay |
| Storage | Same | 2 – 8°C until expiration date |
| Reagent Form | Same | Liquid, ready to use |
| Differences - Reagent | | |
| --- | --- | --- |
| Item | Device | Predicate |
| Antibodies | Mouse monoclonal antibody to Amphetamine | Mouse Monoclonal antibodies to Amphetamine and Methamphetamine |
| Similarities - Calibrators | | |
| --- | --- | --- |
| Item | Device | Predicate (k062077) |
| Calibrator Form | Refrigerated liquid ready to use | Frozen liquid ready to use |
| Differences - Calibrators | | |
| --- | --- | --- |
| Item | Device | Predicate (k062077) |
| Calibrator Levels | Five | Six |
| Storage | 2 – 8°C | ≤ -18°C |
| Similarities - Controls | | |
| --- | --- | --- |
| Item | Device | Predicate (k062077) |
| Storage | Same | 2 – 8°C |
| Differences - Controls | | |
| --- | --- | --- |
| Item | Device | Predicate (k062077) |
| Control Levels | Four | Five |
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5
K. Standard/Guidance Document Referenced (if applicable):
- CLSI EP5-A2: Evaluation of Precision Performance of Quantitative Measurement Methods; Approved Guideline – Second Edition
- CLSI EP7-A2: Interference Testing in Clinical Chemistry; Approved Guideline – Second Edition
L. Test Principle:
The assay is based on the competition of Amphetamine labeled enzyme glucose-6-phosphate dehydrogenase (G6PDH) and the free drug in the urine sample for a fixed amount of antibody binding sites. In the absence of the free drug in the sample, the antibody binds the drug enzyme conjugate and enzyme activity is inhibited. This creates a dose response relationship between drug concentration in the urine sample and enzyme activity. The enzyme G6PDH activity is determined at 340 nm spectrophotometrically by the conversion of NAD to NADH.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
The sponsor performed precision studies in-house following the guidelines provided in CLSI EP5-A2. The study was performed using drug free urine samples spiked with amphetamine and analyzed on a Beckman Coulter / Olympus AU400e Chemistry Analyzer. Samples were measured in duplicate in two runs per day for 20 days (n = 80). The data are summarized in the following table:
Qualitative analysis (500 ng/mL cutoff)
| Concentration (ng/mL) | % of cutoff | Result |
| --- | --- | --- |
| 0 | -100 | 80 Neg / 0 Pos |
| 125 | -75 | 80 Neg / 0 Pos |
| 250 | -50 | 80 Neg / 0 Pos |
| 375 | -25 | 80 Neg / 0 Pos |
| 500 | Cutoff | 48 Neg / 32 Pos |
| 625 | +25 | 80 Pos / 0 Neg |
| 750 | +50 | 80 Pos / 0 Neg |
| 875 | +75 | 80 Pos / 0 Neg |
| 1000 | +100 | 80 Pos / 0 Neg |
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Qualitative analysis (1000 ng/mL cutoff)
| Concentration | % of cutoff | Result |
| --- | --- | --- |
| 0 | -100 | 80 Neg / 0 Pos |
| 250 | -75 | 80 Neg / 0 Pos |
| 500 | -50 | 80 Neg / 0 Pos |
| 750 | -25 | 80 Neg / 0 Pos |
| 1000 | Cutoff | 47 Neg / 33 Pos |
| 1250 | +25 | 80 Pos / 0 Neg |
| 1500 | +50 | 80 Pos / 0 Neg |
| 1750 | +75 | 80 Pos / 0 Neg |
| 2000 | +100 | 80 Pos / 0 Neg |
Semi-quantitative analysis (500 ng/mL cutoff)
| Concentration | % of cutoff | Result |
| --- | --- | --- |
| 0 | -100 | 80 Neg / 0 Pos |
| 125 | -75 | 80 Neg / 0 Pos |
| 250 | -50 | 80 Neg / 0 Pos |
| 375 | -25 | 80 Neg / 0 Pos |
| 500 | Cutoff | 31 Neg / 49 Pos |
| 625 | +25 | 80 Pos / 0 Neg |
| 750 | +50 | 80 Pos / 0 Neg |
| 875 | +75 | 80 Pos / 0 Neg |
| 1000 | +100 | 80 Pos / 0 Neg |
Semi-quantitative analysis (1000 ng/mL cutoff)
| Concentration | % of cutoff | Result |
| --- | --- | --- |
| 0 | -100 | 80 Neg / 0 Pos |
| 250 | -75 | 80 Neg / 0 Pos |
| 500 | -50 | 80 Neg / 0 Pos |
| 750 | -25 | 80 Neg / 0 Pos |
| 1000 | Cutoff | 36 Neg / 44 Pos |
| 1250 | +25 | 80 Pos / 0 Neg |
| 1500 | +50 | 80 Pos / 0 Neg |
| 1750 | +75 | 80 Pos / 0 Neg |
| 2000 | +100 | 80 Pos / 0 Neg |
b. Linearity/assay reportable range:
A drug free urine pool was spiked with a high concentration of Amphetamine at a level above the highest calibrator and was used as the high value specimen. Additional pools were made by serially diluting the high value specimen with drug free urine in increments of approximately 10%. Aliquots from each pool were analyzed in duplicate in the semi-quantitative mode. The results of the study are
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summarized below:
| Expected concentration (ng/mL) | Measured concentration (ng/mL) | Recovery (%) |
| --- | --- | --- |
| 200 | 152.3 | 76.2 |
| 400 | 367.5 | 91.9 |
| 500 | 504.4 | 100.9 |
| 600 | 614.4 | 102.4 |
| 800 | 856.5 | 107.1 |
| 1000 | 1026.9 | 102.7 |
| 1200 | 1171.4 | 97.6 |
| 1400 | 1357.1 | 96.9 |
| 1600 | 1461.1 | 91.3 |
| 1800 | 1714.0 | 95.2 |
| 2000 | 2046.5 | 102.3 |
| 2200 | 2256.4 | 102.6 |
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Controls and calibrators are traceable to a commercially available amphetamine standard solution. The amphetamine standard is diluted with BSA (Bovine Serum Albumin) Buffer to make the calibrator and controls to the desired concentrations. Calibrator and control concentrations are confirmed by GC/MS or LC/MS/MS.
Stability protocols and acceptance criteria for the calibrators and controls were reviewed and found to be acceptable. The sponsor claims that when stored at $2 - 8^{\circ}\mathrm{C}$ calibrators and controls are stable for one year. The sponsor claims that once opened, the calibrators and controls are stable for 6 months when stored at $2 - 8^{\circ}\mathrm{C}$.
Values are assigned to the controls and calibrators once the GC/MS or LC/MS/MS results are within the acceptable ranges. The negative standard is prepared with BSA Buffer. The standard is compared to a reference negative standard to ensure that it is free of analyte. The value is assigned when the test is within the acceptable range.
d. Detection limit:
Not applicable.
e. Analytical specificity:
Potential interference from non-structurally related compounds and endogenous compounds was evaluated in both the qualitative and semi-quantitative modes by following CLSI EP 7-A2: Interference Testing in Clinical Chemistry. Potential interferents were spiked into drug free urine containing Amphetamine at $\pm 25\%$ of the cutoff $(375~\mathrm{ng / mL}$ and $625~\mathrm{ng / mL}$ for the $500~\mathrm{ng / mL}$ cutoff or $750~\mathrm{ng / mL}$ and 1,250
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ng/mL for the 1,000 ng/mL cutoff). The following compounds at 100,000 ng/mL were found not to interfere with the assay at either cutoff in qualitative or semi-quantitative mode.
| 4-Bromo-2,5, Dimethoxyphenethylamine |
| --- |
| 6-Acetylmorphine |
| 7-Aminoclonazepam |
| Alprazolam |
| Amitriptyline |
| Amobarbital |
| Benzylpiperazine |
| Bromazepam |
| Buprenorphine |
| Bupropion |
| Butabarbital |
| Caffeine |
| Carbamazepine |
| Chlorpromazine |
| Chlorodiazepoxide |
| Tramadol |
| Clobazam |
| Clomipramine |
| Clonazepam |
| Cocaine |
| Codeine |
| Cyclobenzaprine |
| N-Desmethyltapentadol |
| Delta-9-THC |
| Desipramine |
| Dextromethorphan |
| Diazepam |
| Dihydrocodeine |
| Doxepin |
| EDDP |
| Ethyl β-D-glucuronide |
| Ethylmorphine |
| Flunitrazepam |
| Fluoxetine |
| Flurazepam |
| Heroin |
| Hexobarbital |
| --- |
| Hydrocodone |
| Hydromorphone |
| 11-hydroxy-delta-9-THC |
| Ibuprofen |
| Imipramine |
| Ketamine |
| Levorphanol Tartrate |
| Lidocaine |
| Lorazepam |
| LSD |
| Maprotiline |
| Meperidine |
| Meprobamate |
| Methaquolone |
| Methylphenidate |
| Morphine |
| Morphine-6 -glucuronide |
| Nalorphine |
| Naloxone |
| Naltrexone |
| Nitrazepam |
| Norbuprenorphine |
| Norcodeine |
| Nordiazepam |
| Normorphine |
| Norpropoxyphene |
| Nortriptyline |
| Oxazepam |
| Oxycodone |
| Oxymorphone |
| PCP |
| Pentazocine |
| Pentobarbital |
| Phenobarbital |
| Phenytoin |
| Prazepam |
| --- |
| Propranolol |
| Protriptyline |
| Ranitidine |
| Ritalinic Acid |
| Secobarbial |
| Sufentanil Citrate |
| Temazepam |
| 11-nor-9 carboxy THC |
| Thioridazine |
| Triazolam |
| Trifluoromethylphenyl-piperazine |
| Trimipramine |
| Venlafaxine |
{8}
In addition, Acetaminophen, Acetylsalicylic Acid, Benzoylecgonine, and Methadone were found not to interfere at a concentration of 500,000 ng/mL.
The following endogenous substances at the concentrations listed below did not interfere with the assay at either cutoff in qualitative or semi-quantitative mode:
| Compound | Concentration Tested |
| --- | --- |
| Acetone | 1.0 g/dL |
| Ascorbic Acid | 1.5 g/dL |
| Bilirubin | 0.002 g/dL |
| Creatinine | 0.5 g/dL |
| Ethanol | 1.0 g/dL |
| Galactose | 0.01 g / dL |
| γ-Globulin | 0.5 g/dL |
| Glucose | 2.0 g/dL |
| Hemoglobin | 0.150 g/dL |
| Human Serum Albumin | 0.5 g/dL |
| Oxalic Acid | 0.1 g/dL |
| Riboflavin | 0.0075 g/dL |
| Sodium Azide | 1% w/v |
| Sodium Chloride | 6.0 g/dL |
| Sodium Fluoride | 1% w/v |
| Urea | 6.0 g/dL |
Boric acid at a concentration of 1% w/v did not interfere with the assay at either cutoff in qualitative or semi-quantitative mode. However, the labeling conservatively recommends that Boric Acid not be used as a preservative for urine samples.
Effect of pH: The sponsor evaluated the effect of pH on the test results using both qualitative and semi-quantitative modes. Drug free urine containing Amphetamine at ±25% of the cutoff (375 ng/mL and 625 ng/mL for the 500 ng/mL cutoff and 750 ng/mL and 1250 ng/mL for the 1000 ng/mL cutoff) were pH adjusted using hydrochloric acid or sodium hydroxide. pH values of 3.0, 4.0, 5.0, 6.0, 7.0, 8.0, 9.0, 10.0 and 11.0 did not interfere with the test result at either cutoff in qualitative or semi-quantitative mode.
Effect of specific gravity: The sponsor evaluated the effect of specific gravity on the test results using both qualitative and semi-quantitative modes. Drug free urine containing Amphetamine at ±25% of the cutoff (375 ng/mL and 625 ng/mL for the 500 ng/mL cutoff and 750 ng/mL and 1250 ng/mL for the 1000 ng/mL cutoff) were adjusted using salt or albumin. Specific Gravity values of 1.000, 1.002, 1.005, 1.010, 1.015, 1.020, 1.025 and 1.030 did not interfere with the test result at either cutoff in qualitative or semi-quantitative mode.
9
{9}
Cross reactivity from structurally related compounds was evaluated in the qualitative and semi-quantitative modes by spiking into drug-free urine. Each potential cross-reacting compound was spiked and evaluated independently, and each spiked sample was tested in singlicate. The compounds tested and the concentration approximately equivalent to the 500 and 1000 ng/mL cutoffs are listed below:
| 500 ng/mL cutoff | | |
| --- | --- | --- |
| Compound | Concentration Tested (ng/mL) | Cross-Reactivity (%) |
| (+) Amphetamine | 500 | 100.0 |
| (-) Amphetamine | 100,000 | 0.5 |
| (±) Amphetamine | 1,300 | 38.5 |
| 3,4-Methylenedioxyamphetamine (MDA) | 1,500 | 33.3 |
| para-Methoxyamphetamine (PMA) | 2,000 | 25.0 |
| Tyramine | 100,000 | 0.5 |
| 3,4-Methylenedioxy-methamphetamine (MDMA) | 500,000 | 0.1 |
| Methylenedioxyethylamphetamine (MDEA) | 100,000 | 0.5 |
| Phenylpropanolamine | 500,000 | 0.1 |
| Phentermine | 1,000,000 | 0.05 |
| (+) Methamphetamine | 1,000,000 | 0.05 |
| (-) Methamphetamine | 1,000,000 | N.D. |
| (+) Ephedrine | 1,000,000 | N.D. |
| (-) Ephedrine | 1,000,000 | N.D. |
| (+) Pseudoephedrine | 1,000,000 | N.D. |
| (-) Pseudoephedrine | 1,000,000 | N.D. |
| Phenylephrine | 1,000,000 | N.D. |
| Diphenylhydramine | 1,000,000 | N.D. |
| Fenfluramine | 1,000,000 | N.D. |
| 1000 ng/mL cutoff | | |
| --- | --- | --- |
| Compound | Concentration Tested (ng/mL) | Cross-Reactivity (%) |
| (+) Amphetamine | 500 | 100.0 |
| (-) Amphetamine | 100,000 | 0.5 |
| (±) Amphetamine | 1,300 | 38.5 |
| 3,4-Methylenedioxyamphetamine (MDA) | 1,500 | 33.3 |
| para-Methoxyamphetamine (PMA) | 2,000 | 25.0 |
| Tyramine | 100,000 | 0.5 |
| 3,4-Methylenedioxy-methamphetamine (MDMA) | 500,000 | 0.1 |
| Methylenedioxyethylamphetamine (MDEA) | 100,000 | 0.5 |
| Phenylpropanolamine | 500,000 | 0.1 |
| Phentermine | 1,000,000 | 0.05 |
| (+) Methamphetamine | 1,000,000 | 0.05 |
| (-) Methamphetamine | 1,000,000 | N.D. |
| (+) Ephedrine | 1,000,000 | N.D. |
| (-) Ephedrine | 1,000,000 | N.D. |
| (+) Pseudoephedrine | 1,000,000 | N.D. |
| (-) Pseudoephedrine | 1,000,000 | N.D. |
{10}
| 1000 ng/mL cutoff | | |
| --- | --- | --- |
| (+) Amphetamine | 1000 | 100.0 |
| (-) Amphetamine | 200,000 | 0.5 |
| (±) Amphetamine | 2500 | 40.0 |
| MDA | 2000 | 50.0 |
| PMA | 4000 | 25.0 |
| Tyramine | 400,000 | 0.3 |
| MDMA | 1,000,000 | N.D. |
| MDEA | 400,000 | 0.3 |
| Phenylpropanolamine | 1,000,000 | N.D. |
| Phentermine | 1,000,000 | N.D. |
| (+) Methamphetamine | 1,000,000 | N.D. |
| (-) Methamphetamine | 1,000,000 | N.D. |
| (+) Ephedrine | 1,000,000 | N.D. |
| (-) Ephedrine | 1,000,000 | N.D. |
| (+) Pseudoephedrine | 1,000,000 | N.D. |
| (-) Pseudoephedrine | 1,000,000 | N.D. |
| Phenylephrine | 1,000,000 | N.D. |
| Diphenylhydramine | 1,000,000 | N.D. |
| Fenfluramine | 1,000,000 | N.D. |
f. Assay cut-off:
Analytical performance of the device around the claimed cutoff is described in the precision section M.1.a. above.
2. Comparison studies:
a. Method comparison with predicate device:
The method comparison study was performed in-house using unaltered, clinical urine samples obtained from clinical testing laboratories. A total of 80 samples were analyzed using the 500 ng/mL cutoff, and 81 were analyzed using the 1000 ng/mL cutoff. Each sample was run in singlicate on a Beckman Coulter AU400e Chemistry Analyzer and the result was compared to that obtained by liquid chromatography/mass spectroscopy (LC/MS). The results of the assay performance compared to LC/MS are summarized below:
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500 ng/mL cutoff (n = 80)
| Candidate Device Result | Amphetamine Concentration by LC/MS (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | < 250 | 250 – 499 | 500 – 750 | > 750 |
| Qualitative / POS | 0 | 0 | 4 | 36 |
| Qualitative / NEG | 36 | 4 | 0 | 0 |
| Semi-quant / POS | 0 | 0 | 4 | 36 |
| Semi-quant / NEG | 36 | 4 | 0 | 0 |
Qualitative agreement among positives = 40 / 40 (100%)
Qualitative agreement among negatives = 40 / 40 (100%)
Semi-quant agreement among positives = 40 / 40 (100%)
Semi-quant agreement among negatives = 40 / 40 (100%)
1000 ng/mL cutoff (n = 81)
| Candidate Device Result | Amphetamine Concentration by LC/MS (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | < 500 | 500 – 999 | 1000 – 1500 | > 1500 |
| Qualitative / POS | 0 | 0 | 4 | 36 |
| Qualitative / NEG | 34 | 6 | *1 | 0 |
| Semi-quant / POS | 0 | 0 | 4 | 36 |
| Semi-quant / NEG | 34 | 6 | *1 | 0 |
Qualitative agreement among positives = 40 / 41 (98%)
Qualitative agreement among negatives = 40 / 40 (100%)
Semi-quant agreement among positives = 40 / 41 (98%)
Semi-quant agreement among negatives = 40 / 40 (100%)
*Discordant sample – 1000 ng/mL cutoff
| Candidate Device Result | | | | LC/MS result (ng/mL) |
| --- | --- | --- | --- | --- |
| Sample ID | Qualitative result | Semi-quantitative | | |
| | | Conc (ng/mL) | Result | |
| 395246ZA | NEG | 620.6 | NEG | 1173 |
b. Matrix comparison:
Not applicable. This device is intended to be used with urine samples only.
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable.
b. Clinical specificity:
Not applicable.
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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.