Chemtrue Multi-Panel Drug Screen Dip Card/Cup Tests, Chemtrue Multi-Panel Drug Screen Dip Card/Cup with OPI 2000 Tests
Applicant
Chemtron Biotech, Inc.
Product Code
DJG · Clinical Toxicology
Decision Date
Apr 18, 2016
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3650
Device Class
Class 2
Indications for Use
The Chemtrue® Multi-Panel Drug Screen Dip Card Tests are rapid lateral flow immunoassays for the qualitative detection of Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, Marijuana, Methamphetamine, Morphine, Phencyclidine, Ecstasy, Methadone, Oxycodone, Propoxyphene and Tricyclic Antidepressants (TCA) drugs in human urine. The tests are intended for prescription and Over-The-Counter (OTC) use. The tests provide only a preliminary result. A more specific alternative chemical method must be used in order to obtain a confirmed assay result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods. Clinical consideration and professional judgment should be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated. The tests are not intended to differentiate between drugs of abuse and prescription use of Benzodiazepines, Barbiturates, Buprenorphine, Oxycodone, Propoxyphene and Tricyclic Antidepressants. There are no uniformly recognized cut-off concentration levels for these drugs in urine.
Device Story
Rapid lateral flow immunoassay for qualitative detection of drugs of abuse in human urine; utilizes competitive binding principle with drug-protein conjugates and anti-drug antibody-colloidal gold conjugates. Available in Dip Card or Cup formats. User (clinician or lay-user) collects urine; sample migrates via capillary action across membrane. Presence of drug above cutoff prevents formation of visible test line (preliminary positive); absence of drug allows formation of visible line (negative). Control line indicates proper test performance. Results are visual; intended for preliminary screening only. Confirmatory testing via GC/MS or LC/MS required for positive results. Clinical judgment required for interpretation.
Clinical Evidence
Consumer study with 130 lay-users across three sites; evaluated ability to interpret results using provided package insert; samples included negative, 50%, 75%, 125%, and 150% of cutoff concentrations; results showed high agreement with GC/MS reference method across all analytes.
Technological Characteristics
Lateral flow chromatographic immunoassay; visual readout; single-use test cup or dip card with 1-14 drug test strips; competitive binding principle; stable for 24 months at 2-30°C; no instrumentation required.
Indications for Use
Indicated for qualitative detection of drugs of abuse (Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, Marijuana, Methamphetamine, Morphine, Phencyclidine, Ecstasy, Methadone, Oxycodone, Propoxyphene, TCA) in human urine. Intended for prescription and OTC use. Not for differentiating between illicit and prescription use of specific drugs.
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).
Predicate Devices
Innovacon Spectrum II Test Card with Integrated Cups (k061718)
QuickScreen™ Test (k103295)
ONSite CupKit™ (k060896)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION MEMORANDUM ASSAY ONLY TEMPLATE
A. 510(k) Number:
k153192
B. Purpose for Submission:
New device
C. Measurands:
Amphetamine, barbiturates, benzodiazepines, buprenorphine, cocaine, marijuana, methadone, methamphetamine, methylenedioxymethamphetamine (MDMA), morphine, opiates, oxycodone, phencyclidine, propoxyphene, and tricyclic antidepressants.
D. Type of Test:
Qualitative lateral flow chromatographic immunoassay
E. Applicant:
Chemtron Biotech, Inc.
F. Proprietary and Established Names:
Chemtrue® Multi-Panel Drug Screen Cup Tests
Chemtrue® Multi-Panel Drug Screen Cup with OPI2000 Tests
Chemtrue® Multi-Panel Drug Screen Dip Card Tests
Chemtrue® Multi-Panel Drug Screen Dip Card with OPI2000 Tests
G. Regulatory Information:
| Assay | Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- | --- |
| Amphetamine | DKZ | Class II | 21CFR 862.3100, Amphetamine Test System | Toxicology (91) |
| Barbiturates | DIS | Class II | 21 CFR 862.3150, Barbiturates Test System | Toxicology (91) |
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| Assay | Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- | --- |
| Benzodiazepines | JXM | Class II | 21 CFR 862.3170, Benzodiazepines Test System | Toxicology (91) |
| Buprenorphine | DJG | Class II | 21 CFR 862.3650, Opiate test system | Toxicology (91) |
| Cocaine | DIO | Class II | 21 CFR 862.3250, Cocaine and metabolites Test System | Toxicology (91) |
| Marijuana | LDJ | Class II | 21 CFR 862.3870, Cannabinoids Test System | Toxicology (91) |
| Methadone | DJR | Class II | 21 CFR 862.3620, Methadone Test System | Toxicology (91) |
| Methamphetamine | LAF | Class II | 21 CFR 862.3610, Methamphetamine Test System | Toxicology (91) |
| MDMA | DJC | Class II | 21 CFR 862.3610, Methamphetamine Test System | Toxicology (91) |
| Morphine | DNK | Class II | 21 CFR 862.3640, Morphine Test System | Toxicology (91) |
| Opiates | DJG | Class II | 21 CFR 862.3650, Opiate Test System | Toxicology (91) |
| Oxycodone | DJG | Class II | 21 CFR 862.3650, Opiate Test System | Toxicology (91) |
| Phencyclidine | LCM | Class II | Unclassified, Enzyme immunoassay Phencyclidine | Toxicology (91) |
| Propoxyphene | JXN | Class II | 21 CFR 862.3700 Propoxyphene test system | Toxicology (91) |
| Tricyclic Antidepressants | LFG | Class II | 21 CFR 862.3910, Tricyclic antidepressant drugs test system | Toxicology (91) |
# H. Intended Use:
1. Intended use(s):
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Refer to Indications for Use below
## 2. Indication(s) for use:
### Chemtrue® Multi-Panel Drug Screen Dip Card Tests
The Chemtrue® Multi-Panel Drug Screen Dip Card Tests are rapid lateral flow immunoassays for the qualitative detection of Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, Marijuana, Methamphetamine, Morphine, Phencyclidine, Ecstasy, Methadone, Oxycodone, Propoxyphene and Tricyclic Antidepressants (TCA) drugs in human urine. The test cut-off concentrations and the compounds the tests are calibrated to are as follows:
| Analyte | Abbreviation | Calibrator | Cutoff Concentration (ng/mL) |
| --- | --- | --- | --- |
| Amphetamine | AMP | d-Amphetamine | 300 |
| Amphetamine | AMP | d-Amphetamine | 500 |
| Amphetamine | AMP | d-Amphetamine | 1000 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 200 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 300 |
| Benzodiazepines | BZO | Oxazepam | 200 |
| Benzodiazepines | BZO | Oxazepam | 300 |
| Buprenorphine | BUP | Buprenorphine | 10 |
| Cocaine | COC | Benzoylecgonine | 150 |
| Cocaine | COC | Benzoylecgonine | 300 |
| Ecstasy | MDMA | d,l-Methylenedioxymethamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 300 |
| Methamphetamine | MAMP | d-Methamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 1000 |
| Marijuana | THC | 11-nor-Δ⁹-THC-9-COOH | 50 |
| Methadone | MTD | Methadone | 300 |
| Morphine | MOR | Morphine | 300 |
| Oxycodone | OXY | Oxycodone | 100 |
| Phencyclidine | PCP | Phencyclidine | 25 |
| Propoxyphene | PPX | Propoxyphene | 300 |
| Tricyclic Antidepressants | TCA | Nortriptyline | 1000 |
The multi test panels can consist of up to fourteen (14) of the above listed analytes in any combination. Only one cutoff concentration will be included per analyte per device. The tests are intended for prescription and Over-The-Counter (OTC) use.
The tests provide only a preliminary result. A more specific alternative chemical method must be used in order to obtain a confirmed assay result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods. Clinical consideration and professional judgment should
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be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated.
The tests are not intended to differentiate between drugs of abuse and prescription use of Benzodiazepines, Barbiturates, Buprenorphine, Oxycodone, Propoxyphene and Tricyclic Antidepressants. There are no uniformly recognized cut-off concentration levels for these drugs in urine.
# Chemtrue® Multi-Panel Drug Screen Dip Card with OPI2000 Tests
The Chemtrue® Multi-Panel Drug Screen Dip Card with OP2000 Tests are rapid lateral flow immunoassays for the qualitative detection of Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, Marijuana, Methamphetamine, Opiates, Phencyclidine, Ecstasy, Methadone, Oxycodone, Propoxyphene and Tricyclic Antidepressants (TCA) drugs in human urine. The test cut-off concentrations and the compounds the tests are calibrated to are as follows:
| Analyte | Abbreviation | Calibrator | Cutoff Concentration (ng/mL) |
| --- | --- | --- | --- |
| Amphetamine | AMP | d-Amphetamine | 300 |
| Amphetamine | AMP | d-Amphetamine | 500 |
| Amphetamine | AMP | d-Amphetamine | 1000 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 200 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 300 |
| Benzodiazepines | BZO | Oxazepam | 200 |
| Benzodiazepines | BZO | Oxazepam | 300 |
| Buprenorphine | BUP | Buprenorphine | 10 |
| Cocaine | COC | Benzoylecgonine | 150 |
| Cocaine | COC | Benzoylecgonine | 300 |
| Ecstasy | MDMA | d,l-Methylenedioxymethamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 300 |
| Methamphetamine | MAMP | d-Methamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 1000 |
| Marijuana | THC | 11-nor-Δ9-THC-9-COOH | 50 |
| Methadone | MTD | Methadone | 300 |
| Opiates | OPI | Morphine | 2000 |
| Oxycodone | OXY | Oxycodone | 100 |
| Phencyclidine | PCP | Phencyclidine | 25 |
| Propoxyphene | PPX | Propoxyphene | 300 |
| Tricyclic Antidepressants | TCA | Nortriptyline | 1000 |
The multi test panels can consist of up to fourteen (14) of the above listed analytes in any combination. Only one cutoff concentration will be included per analyte per device. The tests are intended for prescription and Over-The-Counter (OTC) use.
The tests provide only a preliminary result. A more specific alternative chemical method
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must be used in order to obtain a confirmed assay result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods. Clinical consideration and professional judgment should be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated.
The tests are not intended to differentiate between drugs of abuse and prescription use of Benzodiazepines, Barbiturates, Buprenorphine, Oxycodone, Propoxyphene and Tricyclic Antidepressants. There are no uniformly recognized cut-off concentration levels for these drugs in urine.
# Chemtrue® Multi-Panel Drug Screen Cup Tests
The Chemtrue® Multi-Panel Drug Screen Cup Tests are rapid lateral flow immunoassays for the qualitative detection of Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, Marijuana, Methamphetamine, Morphine, Phencyclidine, Ecstasy, Methadone, Oxycodone, Propoxyphene and Tricyclic Antidepressants (TCA) drugs in human urine. The test cut-off concentrations and the compounds the tests are calibrated to are as follows:
| Analyte | Abbreviation | Calibrator | Cutoff Concentration (ng/mL) |
| --- | --- | --- | --- |
| Amphetamine | AMP | d-Amphetamine | 300 |
| Amphetamine | AMP | d-Amphetamine | 500 |
| Amphetamine | AMP | d-Amphetamine | 1000 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 200 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 300 |
| Benzodiazepines | BZO | Oxazepam | 200 |
| Benzodiazepines | BZO | Oxazepam | 300 |
| Buprenorphine | BUP | Buprenorphine | 10 |
| Cocaine | COC | Benzoylecgonine | 150 |
| Cocaine | COC | Benzoylecgonine | 300 |
| Ecstasy | MDMA | d,l-Methylenedioxymethamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 300 |
| Methamphetamine | MAMP | d-Methamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 1000 |
| Marijuana | THC | 11-nor-Δ9-THC-9-COOH | 50 |
| Methadone | MTD | Methadone | 300 |
| Morphine | MOR | Morphine | 300 |
| Oxycodone | OXY | Oxycodone | 100 |
| Phencyclidine | PCP | Phencyclidine | 25 |
| Propoxyphene | PPX | Propoxyphene | 300 |
| Tricyclic Antidepressants | TCA | Nortriptyline | 1000 |
The multi test panels can consist of up to fourteen (14) of the above listed analytes in any combination. Only one cutoff concentration will be included per analyte per device. The
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tests are intended for prescription and Over-The-Counter (OTC) use.
The tests provide only a preliminary result. A more specific alternative chemical method must be used in order to obtain a confirmed assay result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods. Clinical consideration and professional judgment should be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated.
The tests are not intended to differentiate between drugs of abuse and prescription use of Benzodiazepines, Barbiturates, Buprenorphine, Oxycodone, Propoxyphene and Tricyclic Antidepressants. There are no uniformly recognized cut-off concentration levels for these drugs in urine.
# Chemtrue® Multi-Panel Drug Screen Cup with OPI2000 Tests
The Chemtrue® Multi-Panel Drug Screen Cup with OPI2000 Tests are rapid lateral flow immunoassays for the qualitative detection of Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, Marijuana, Methamphetamine, Opiates, Phencyclidine, Ecstasy, Methadone, Oxycodone, Propoxyphene and Tricyclic Antidepressants (TCA) drugs in human urine. The test cut-off concentrations and the compounds the tests are calibrated to are as follows:
| Analyte | Abbreviation | Calibrator | Cutoff Concentration (ng/mL) |
| --- | --- | --- | --- |
| Amphetamine | AMP | d-Amphetamine | 300 |
| Amphetamine | AMP | d-Amphetamine | 500 |
| Amphetamine | AMP | d-Amphetamine | 1000 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 200 |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 300 |
| Benzodiazepines | BZO | Oxazepam | 200 |
| Benzodiazepines | BZO | Oxazepam | 300 |
| Buprenorphine | BUP | Buprenorphine | 10 |
| Cocaine | COC | Benzoylecgonine | 150 |
| Cocaine | COC | Benzoylecgonine | 300 |
| Ecstasy | MDMA | d,l-Methylenedioxymethamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 300 |
| Methamphetamine | MAMP | d-Methamphetamine | 500 |
| Methamphetamine | MAMP | d-Methamphetamine | 1000 |
| Marijuana | THC | 11-nor-Δ9-THC-9-COOH | 50 |
| Methadone | MTD | Methadone | 300 |
| Opiates | OPI | Morphine | 2000 |
| Oxycodone | OXY | Oxycodone | 100 |
| Phencyclidine | PCP | Phencyclidine | 25 |
| Propoxyphene | PPX | Propoxyphene | 300 |
| Tricyclic Antidepressants | TCA | Nortriptyline | 1000 |
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The multi test panels can consist of up to fourteen (14) of the above listed analytes in any combination. Only one cutoff concentration will be included per analyte per device. The tests are intended for prescription and Over-The-Counter (OTC) use.
The tests provide only a preliminary result. A more specific alternative chemical method must be used in order to obtain a confirmed assay result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods. Clinical consideration and professional judgment should be applied to any drugs of abuse test result, particularly when preliminary positive results are indicated.
The tests are not intended to differentiate between drugs of abuse and prescription use of Benzodiazepines, Barbiturates, Buprenorphine, Oxycodone, Propoxyphene and Tricyclic Antidepressants. There are no uniformly recognized cut-off concentration levels for these drugs in urine.
3. Special conditions for use statement(s):
For in vitro diagnostic use only.
4. Special instrument requirements:
Not applicable, as the devices are visually-read single-use devices.
I. Device Description:
The devices consist of:
- A test cup or a test card with 1 to 14 drug test strips
- Transport vial, transport bag, and mailing box (for confirmation testing)
- Package insert (instructions for use)
J. Substantial Equivalence Information:
1. Predicate device name(s):
Innovacon Spectrum II Test Card, Innovacon Spectrum II Test Card with Integrated Cups Phamatech QuickScreen Cocaine 150 Test
2. Predicate 510(k) number(s):
k061718
k103295
3. Comparison with predicate:
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| Similarities - k103295 | | |
| --- | --- | --- |
| Item | Candidate Devices
Chemtrue® Drug Screen Dip Card Tests, Chemtrue® Drug Screen Dip Card with OPI2000 Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests with OPI2000 Tests | Predicate - k103295
Phamatech QuickScreen Cocaine 150 Test |
| Indications for Use | Same | Qualitative detection of drugs of abuse in urine |
| Analytes | Same | COC at 150 ng/mL |
| Methodology | Same | Qualitative lateral flow chromatographic immunoassay |
| Similarities - k061718 | | |
| --- | --- | --- |
| Item | Candidate Devices
Chemtrue® Drug Screen Dip Card Tests, Chemtrue® Drug Screen Dip Card with OPI2000 Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests with OPI2000 Tests | Predicate - k061718
Innovacon Spectrum II Test Card, Innovacon Spectrum II Test Card with Integrated Cups |
| Indications for Use | Same | Qualitative detection of drugs of abuse in urine |
| Analytes | Same | AMP at 300, 500, and 1000 ng/mL
BAR at 200 and 300 ng/mL
BZO at 200 and 300 ng/mL
BUP at 10 ng/mL
COC at 300 ng/mL
MDMA at 500 ng/mL
MET at 300, 500, and 1000 ng/mL
THC at 50 ng/mL
MTD at 300 ng/mL
MOR at 300 ng/mL
OPI at 2000 ng/mL
OXY at 100 ng/mL
PCP at 25 ng/mL
PPX at 300 ng/mL
TCA at 1000 ng/mL |
8
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| Similarities – k061718 | | |
| --- | --- | --- |
| Item | Candidate Devices Chemtrue® Drug Screen Dip Card Tests, Chemtrue® Drug Screen Dip Card with OPI2000 Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests with OPI2000 Tests | Predicate – k061718 Innovacon Spectrum II Test Card, Innovacon Spectrum II Test Card with Integrated Cups |
| Methodology | Same | Qualitative lateral flow chromatographic immunoassay |
| Differences – k103295 | | |
| --- | --- | --- |
| Item | Candidate Devices Chemtrue® Drug Screen Dip Card Tests, Chemtrue® Drug Screen Dip Card with OPI2000 Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests with OPI2000 Tests | Predicate - k103295 Phamatech QuickScreen Cocaine 150 Test |
| Intended Use | For prescription and Over-The-Counter (OTC) | For prescription and point-of-care use only |
| Differences - k061718 | | |
| --- | --- | --- |
| Item | Candidate Devices Chemtrue® Drug Screen Dip Card Tests, Chemtrue® Drug Screen Dip Card with OPI2000 Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests, Chemtrue® Multi-Panel Drug Screen Cup Tests with OPI2000 Tests | Predicate – k061718 Innovacon Spectrum II Test Card, Innovacon Spectrum II Test Card with Integrated Cups |
| Intended Use | For prescription and Over-The-Counter (OTC) | For prescription use only |
K. Standard/Guidance Document Referenced (if applicable):
Guidance for Industry and Food and Drug Administration Staff: Design Considerations for Devices Intended for Home Use, November 24, 2014
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L. Test Principle:
The devices are rapid lateral flow immunoassays in which drug-protein conjugates in the test device compete with drugs or drug metabolites that may be present in urine. On each test strip, a drug-protein conjugate is added to the test band of the membrane – known as the test region (T), and the anti-drug antibody-colloidal gold conjugate pads are placed at the forward end of the membrane. If target drugs are present in the urine specimen below its cut-off concentration, the solution of the colored antibody-colloidal gold conjugates moves along with the sample solution by capillary action across the membrane to the immobilized drug-protein conjugate zone on the test band region. The colored antibody-gold conjugates then complexes with the drug-protein conjugates to form visible lines. Therefore, the formation of the visible precipitant in the test band indicates a negative result. If the target drug level exceeds its cut-off concentration, the drug/metabolite antigen competes with drug protein conjugates on the test band region for the limited antibody on the colored drug antibody-colloidal gold conjugate pad. The drug will saturate the limited antibody binding sites and the colored antibody-colloidal gold conjugate cannot bind to the drug-protein conjugate at the test region of the test strip. Therefore, absence of the color band on the test region indicates a preliminary positive result. A band should form in the control region (C) of the devices regardless of the presence of drug in the sample to indicate that the test has been performed properly.
M. Performance Characteristics (if/when applicable):
1. Analytical performance:
a. Precision/Reproducibility:
Dipcard format
| Drug | Concentration Tested | Operator 1/Lot 1 | Operator 2/Lot 2 | Operator 3/Lot 3 | Total of the three operators |
| --- | --- | --- | --- | --- | --- |
| | | Neg/Pos | Neg/Pos | Neg/Pos | Neg/Pos |
| AMP 300 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 5/5 | 4/6 | 5/5 | 14/16 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| BAR 200 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 5/5 | 5/5 | 6/4 | 16/14 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
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| BZO 200 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| --- | --- | --- | --- | --- | --- |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 3/6 | 5/4 | 6/6 | 14/16 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| COC 150 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 3/4 | 4/7 | 7/5 | 14/16 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| MAMP 300 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 6/4 | 4/5 | 6/5 | 16/14 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| AMP 500 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 4/3 | 4/6 | 8/5 | 16/14 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| MAMP 500 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 4/5 | 3/4 | 9/5 | 16/14 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| PPX 300 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 4/5 | 4/5 | 7/5 | 15/15 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
Cup format
| AMP 300 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| --- | --- | --- | --- | --- | --- |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 1/4 | 7/5 | 9/4 | 17/13 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
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| BAR 200 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| --- | --- | --- | --- | --- | --- |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 5/4 | 5/7 | 5/4 | 15/15 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| BZO 200 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 6/7 | 3/3 | 6/5 | 15/15 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| COC 150 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| --- | --- | --- | --- | --- | --- |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 5/2 | 4/5 | 4/10 | 13/17 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| MAMP 300 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 1/4 | 8/5 | 6/6 | 15/15 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| AMP 500 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 3/5 | 6/2 | 7/7 | 16/14 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| MAMP 500 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 4/7 | 5/4 | 4/6 | 13/17 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| PPX 300 | Negative | 10/0 | 10/0 | 10/0 | 30/0 |
| | 50% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | 75% of cutoff | 10/0 | 10/0 | 10/0 | 30/0 |
| | cutoff | 5/4 | 2/5 | 8/6 | 15/15 |
| | 125% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
| | 150% of cutoff | 0/10 | 0/10 | 0/10 | 0/30 |
Precision performance for the remaining fourteen drugs (AMP 1000, BAR 300, BZO
{12}
300, BUP 10, COC 300, MDMA 500, MAMP 1000, THC 50, MTD 300, MOR 300, OP 2000, OXY 100, PCP 25, and TCA 1000) was established in k142396.
# b. Linearity/assay reportable range:
Not applicable. These devices are intended for qualitative use only.
# c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Stability: Device stability has been evaluated through accelerated and real-time studies. The real-time studies are ongoing. Protocols and acceptance criteria were described and found to be acceptable. The manufacturer claims that the devices are stable for two years (24 months) when stored at $2 - 30^{\circ}\mathrm{C}$ .
Quality control: Control materials are not supplied with the devices; however the labeling provides information on how to obtain quality control materials.
# d. Detection limit:
See Precision/Reproducibility section in M.1.a above.
# e. Analytical specificity:
For each drug and cutoff, specificity was evaluated by spiking various concentrations of similarly structured drug compounds into drug-free urine. Results are expressed as a minimum concentration of metabolite or compound required to produce a response approximately equivalent to the cutoff concentration of the assay. The percent cross-reactivity of those compounds is listed below:
| Target Drug and Cutoff | Compound | Concentration Equivalent to the Cutoff (ng/mL) | Cross-Reactivity (%) |
| --- | --- | --- | --- |
| AMP 300 | D,L-AMP | 600 | 50.0 |
| | L-AMP | >30000 | <1 |
| | D-Methamphetamine | >30000 | <1 |
| | L-Methamphetamine | >30000 | <1 |
| | D,L-Methamphetamine | >30000 | <1 |
| | +/- MDMA | >30000 | <1 |
| | Ephedrine | >30000 | <1 |
| | D,L-MDA | 300 | 100.0 |
| | D,L-MDEA | >30000 | <1 |
| | Pseudoephedrine | >30000 | <1 |
| | Phentermine | 4000 | 7.5 |
| | Phenylephrine | >30000 | <1 |
| | Tyramine | >30000 | <1 |
{13}
| AMP 500 | D,L-AMP | 700 | 62.5 |
| --- | --- | --- | --- |
| L-AMP | 50000 | <1 |
| D-Methamphetamine | 50000 | <1 |
| L-Methamphetamine | 50000 | <1 |
| D,L-Methamphetamine | 50000 | <1 |
| D,L MDMA | 50000 | <1 |
| D,L-MDA | 700 | 100.0 |
| D,L-MDEA | 50000 | <1 |
| Ephedrine | 50000 | <1 |
| Pseudoephedrine | 50000 | <1 |
| Phentermine | 4000 | 10.0 |
| Phenylephrine | 50000 | <1 |
| Tyramine | 50000 | <1 |
| AMP 1000 | D,L-AMP | 1500 | 62.5 |
| L-AMP | 100000 | <1 |
| 0-Methamphetamine | 100000 | <1 |
| L-Methamphetamine | 100000 | <1 |
| D,L-Methamphetamine | 100000 | <1 |
| D,LMDMA | 100000 | <1 |
| D,L-MDA | 900 | 100.0 |
| D,L-MDEA | 100000 | <1 |
| Ephedrine | 100000 | <1 |
| Pseudoephedrine | 100000 | <1 |
| Phentermine | 6000 | 14.3 |
| Phenylephrine | 100000 | <1 |
| Tyramine | 100000 | <1 |
| BAR 200 | Alphenal | 300 | 66.7 |
| Amobarbital | 400 | 50.0 |
| Aprobarbital | 400 | 50.0 |
| Barbital | 6000 | 3.3 |
| Butabarbital | 300 | 66.7 |
| Butalbital | 1000 | 20.0 |
| Cyclopentobarbital | 240 | 83.3 |
| Phenobarbital | 1400 | 14.3 |
| BAR 300 | Alphenal | 500 | 60.0 |
| Amobarbital | 600 | 50.0 |
| Aprobarbital | 500 | 60.0 |
| Barbital | 10000 | 3.0 |
| Butabarbital | 500 | 60.0 |
| Butalbital | 2000 | 15.0 |
| Cyclopentobarbital | 500 | 60.0 |
| Phenobarbital | 2000 | 15.0 |
14
{14}
| BENZ 200 | Alprazolam | 200 | 100.0 |
| --- | --- | --- | --- |
| | Alphahydroxyalprazolam | 200 | 100.0 |
| | Bromazepam | 200 | 100.0 |
| | Chlordiazepoxide | 400 | 50.0 |
| | Clobazam | 600 | 33.3 |
| | Clonazepam | 20000 | 1.0 |
| | Clorazepate | 1800 | 11.1 |
| | Desalkyflurazepam | 800 | 25.0 |
| | Diazepam | 300 | 66.7 |
| | Estazolam | 200 | 100.0 |
| | Flunitrazepam | 4600 | 4.3 |
| | Flurazepam | 200 | 100.0 |
| | Lorazepam | 600 | 33.3 |
| | Lormetazepam | 2800 | 7.1 |
| | Midazolam | 8000 | 2.5 |
| | Nitrazepam | 800 | 25.0 |
| | Nordiazepam | 5200 | 3.8 |
| | Temazepam | 400 | 50.0 |
| | Trialozam | 1200 | 16.7 |
| BENZ 300 | Alprazolam | 300 | 100.0 |
| | Alphahydroxyalprazolam | 300 | 100.0 |
| | Bromazepam | 300 | 100.0 |
| | Chlordiazepoxide | 600 | 50.0 |
| | Clobazam | 800 | 37.5 |
| | Clonazepam | 30000 | 1.0 |
| | Clorazepate | 2000 | 15.0 |
| | Desalkyflurazepam | 1000 | 30.0 |
| | Diazepam | 500 | 60.0 |
| | Estazolam | 300 | 100.0 |
| | Flunitrazepam | 4800 | 6.3 |
| | Flurazepam | 300 | 100.0 |
| | Lorazepam | 800 | 37.5 |
| | Lormetazepam | 3600 | 8.3 |
| | Midazolam | 10000 | 3.0 |
| | Nitrazepam | 1000 | 30.0 |
| | Nordiazepam | 8000 | 3.8 |
| | Temazepam | 600 | 50.0 |
| | Triazolam | 1800 | 16.7 |
| BUP 10 | Buprenorphine | 10 | 100 |
| | Norbuprenorphine | 10 | 100 |
| | Morphine | 1000 | <1 |
| | Codeine | 1000 | <1 |
{15}
| COC 150 | Cocaethylene | 150 | 100.0 |
| --- | --- | --- | --- |
| | Cocaine | 180 | 83.3 |
| COC 300 | Ecgonine | 15000 | <1 |
| | Ecgonine HCl | 15000 | <1 |
| COC 300 | Cocaethylene | 300 | 100.0 |
| | Cocaine | 300 | 100.0 |
| COC 300 | Ecgonine | 30000 | <1 |
| | Ecgonine HCl | 30000 | <1 |
| MDMA 500 | MDA | 15000 | 3.3 |
| | MDEA | 1000 | 50 |
| MDMA 500 | d-Methamphetamine | 50000 | <1 |
| | d-Amphetamine | 50000 | <1 |
| MAMP 300 | L-Methamphetamine | 2000 | 15.0 |
| | D,L-Methamphetamine | 1600 | 18.8 |
| | D-Amphetamine | 30000 | <1 |
| | L-Amphetamine | 30000 | <1 |
| | D,L-Amphetamine | 30000 | <1 |
| | MDA | 30000 | <1 |
| | MDEA | 20000 | 1.5 |
| | MDMA | 2000 | 15.0 |
| | Ephedrine | 30000 | <1 |
| | Pseudoephedrine | 30000 | <1 |
| | Phenylephrine | 30000 | <1 |
| | Phentermine | 30000 | <1 |
| MAMP 500 | L-Methamphetamine | 2500 | 20.0 |
| | D,L-Methamphetamine | 2000 | 25.0 |
| | D-Amphetamine | 50000 | <1 |
| | L-Amphetamine | 50000 | <1 |
| | D,L-Amphetamine | 50000 | <1 |
| | MDA | 50000 | <1 |
| | MDEA | 25000 | 2.0 |
| | MDMA | 2600 | 19.2 |
| | Ephedrine | 50000 | <1 |
| | Pseudoephedrine | 50000 | <1 |
| | Phenylephrine | 50000 | <1 |
| | Phentermine | 50000 | <1 |
{16}
The sponsor also evaluated the potential for positive and negative interference from non-structurally related compounds, endogenous compounds, pH, and specific gravity. The structurally unrelated compounds and endogenous substances study was performed by spiking structurally unrelated compounds and endogenous substances at a concentration of $100\mu \mathrm{g / mL}$ into urine samples containing drug at $\pm 25\%$ of the respective drug cutoff concentrations.
The following substances showed no positive or negative interference in this study:
| Albumin | Creatinine | Riboflavin |
| --- | --- | --- |
| Bilirubin | Glucose | Sodium Chloride |
| Cholesterol | Hemoglobin | Uric Acid |
| Acetaminophen | Diphenylhydantoin | Octopamine |
| Acetone | Dopamine | Oxalic Acid |
| Acetylsalicylic Acid | Erythromycin | Papaverine |
| Amoxicillin | Estradiol | Penicillin-G |
| Ampicillin | Estrone | Perphenazine |
| Apomorphine | Ethanol | Phenelzine |
| Ascorbic Acid | Fenofibrate | Phenylethylamine |
| Aspirin | Fentanyl | Prednisone |
| Aspartame | Fotemustine | Promazine |
| Atropine | Furosemide | Promethazine |
| Baclofen | Gemfibrozil | Propoxyphene |
| Benzocaine | Guaiacolglyceryl ether | Propranolol |
| Benzoic Acid | Gentisic Acid | Pyridoxine |
| Carisoprodol | Hydralazine | Pyrilamine |
{17}
| Chloramphenicol | Hydrocortisone | Pyrogallol |
| --- | --- | --- |
| Chlordiazepoxide | Hydroxytyramine | Quinidine |
| Chlorpheniramine | Isoproterenol | Quinine |
| Chlorpromazine | Ketamine | Quinolinic Acid |
| Clofibrate | Meprobamate | Ranitidine |
| Clonidine | Methapyrilene | Salicylic Acid |
| Cortisone | Methylphenidate | Sulfamethazine |
| Cotinine | Nalidixic Acid | Sulindac |
| Creatine Hydrate | Naloxone | Tetracycline |
| Cyclobenzaprine | Naltrexone | Tetrahydrozoline |
| Cyclodextrin-r | Naproxen | Thiamine |
| Cyproheptadine | Niacinamide | Thioridazine |
| Deoxycorticosterone | Nicotinic Acid | Tramadol |
| Dextromethorphan | Nifedipine | Trifluoperazine |
| Diclofenac | Norethindrone | Tryptamine |
| Diflunisal | Norpropoxyphene | Tyramine |
| Dimethyl-aminoantipyrine | Noscapine | Zomepirac sodium salt |
| Diphenhydramine | | |
To evaluate the effect of pH value on the test results, urine controls at $\pm 25\%$ of the cutoff value were used. Each control level was adjusted by either 1N NaOH solution or 1N HCl to pH levels of 2.0, 3.0, 4.0, 4.5, 5.0, 5.5, 6.0, 6.5, 7.0, 7.5, 8.0 and 9.0. Each test sample was tested in duplicate.
To evaluate the effect of specific gravity, urine controls at $\pm 25\%$ of the cutoff values were spiked with deionized water or sugar to obtain specific gravities of 1.001, 1.010, 1.015, 1.020, 1.025, and 1.030. Each test sample was tested in duplicate.
The results demonstrated that pH and specific gravity do not affect the results from the device.
f. Assay cut-off:
Characterization of how the device performs analytically around the claimed cutoff concentration appears in the precision section, M.1.a., above.
2. Comparison studies:
The sponsor performed a method comparison study comparing performance of the test strips of the cup devices to the GC/MS reference method. Results are summarized below:
a. Method comparison with predicate device:
{18}
# Dipcard Format
AMP 300
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff –50% | cutoff –50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 14 | 27 |
| NEG | 31 | 11 | 0 | 0 |
Agreement among positives = 41/41 = 100%
Agreement among negatives = 42/42 = 100%
AMP 500
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff –50% | cutoff –50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 12 | 31 |
| NEG | 31 | 14 | 0 | 0 |
Agreement among positives = 43/43 = 100%
Agreement among negatives = 45/45 = 100%
BAR 200
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff –50% | cutoff –50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 26 | 14 |
| NEG | 34 | 9 | 0 | 0 |
Agreement among positives = 40/40 = 100%
Agreement among negatives = 43/44 = 98%
*Sample contained pentobarbital at 185 ng/mL
BENZ 200
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff –50% | cutoff –50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 26 | 14 |
| NEG | 31 | 16 | 0 | 0 |
Agreement among positives = 40/40 = 100%
Agreement among negatives = 47/47 = 100%
COC 150
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff –50% | cutoff –50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 15 | 28 |
| NEG | 31 | 10 | 0 | 0 |
Agreement among positives = 43/43 = 100%
Agreement among negatives = 41/41 = 100%
19
{19}
MAMP 300
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 14 | 34 |
| NEG | 31 | 9 | 0 | 0 |
Agreement among positives = 48/48 = 100%
Agreement among negatives = 40/41 = 98%
* Sample contained methamphetamine at 296 ng/mL
MAMP 500
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 11 | 30 |
| NEG | 31 | 11 | 0 | 0 |
Agreement among positives = 41/41 = 100%
Agreement among negatives = 42/43 = 98%
*Sample contained methamphetamine at 494 ng/mL
PPX 300
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 12 | 33 |
| NEG | 31 | 10 | 0 | 0 |
Agreement among positives = 45/45 = 100%
Agreement among negatives = 41/41 = 100%
Cup Format
AMP 300
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 14 | 27 |
| NEG | 31 | 10 | 0 | 0 |
Agreement among positives = 41/41 = 100%
Agreement among negatives = 41/42 = 98%
*Sample contained amphetamine at 229 ng/mL
{20}
AMP 500
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 11 | 31 |
| NEG | 31 | 13 | 1† | 0 |
Agreement among positives = 42/43 = 98%
Agreement among negatives = 44/45 = 98%
*Sample contained amphetamine at 441 ng/mL
†Sample contained amphetamine at 510 ng/mL
BAR 200
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 26 | 14 |
| NEG | 34 | 9 | 0 | 0 |
Agreement among positives = 40/40 = 100%
Agreement among negatives = 43/44 = 98%
*Sample contained pentobarbital at 185 ng/mL
BENZ 200
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 26 | 14 |
| NEG | 31 | 16 | 0 | 0 |
Agreement among positives = 40/40 = 100%
Agreement among negatives = 47/47 = 100%
COC 150
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 15 | 28 |
| NEG | 31 | 10 | 0 | 0 |
Agreement among positives = 43/43 = 100%
Agreement among negatives = 41/41 = 100%
MAMP 300
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 1* | 14 | 34 |
| NEG | 31 | 9 | 0 | 0 |
Agreement among positives = 48/48 = 100%
Agreement among negatives = 40/41 = 98%
*Sample contained methamphetamine at 296 ng/mL
{21}
MAMP 500
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 11 | 30 |
| NEG | 31 | 12 | 0 | 0 |
Agreement among positives $= 41 / 41 = 100\%$
Agreement among negatives $= 43 / 43 = 100\%$
PPX 300
| Candidate Device Result | Concentration by reference method (ng/mL) | | | |
| --- | --- | --- | --- | --- |
| | ≤ cutoff -50% | cutoff -50% to the cutoff | cutoff to cutoff +50% | ≥ cutoff +50% |
| POS | 0 | 0 | 12 | 33 |
| NEG | 31 | 10 | 0 | 0 |
Agreement among positives $= 45 / 45 = 100\%$
Agreement among negatives $= 41 / 41 = 100\%$
b. Matrix comparison:
Not applicable. These devices are for use with urine samples only.
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):
A consumer study was performed for all analytes to evaluate the ability of untrained users to interpret the devices properly when given only the labeling (package insert) provided with the devices. One hundred and thirty (130) lay-users participated in this study from three (3) intended user sites with GC/MS confirmed urine samples in the following concentration ranges: negative, $50\%$ , $75\%$ , $125\%$ and $150\%$ of the cutoff. Samples were created by spiking drugs into drug-free urine pool. Each sample was aliquoted into an individual blind-labeled container. Each lay-user was provided with a package insert in English only and up to two (2) random blind labeled samples with the tests of each device format. The results are summarized below:
{22}
| Chemtrue® Cup Test | Candidate Device Result | (-) | | | (+) | | % Agreement with reference method |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | <50% of the C/O | Negative (50% of the C/O) | Near cutoff Negative (50% of the cutoff to the cutoff) | Near cutoff positive (cutoff to 125% of the cutoff) | Positive (≥125% of the C/O) | |
| AMP1000 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| AMP500 | + | 0 | 0 | 0 | 26 | 21 | 100% |
| | - | 60 | 23 | 39 | 0 | 0 | 100% |
| AMP300 | + | 0 | 0 | 0 | 23 | 48 | 100% |
| | - | 51 | 21 | 25 | 0 | 0 | 100% |
| BAR300 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| BAR200 | + | 0 | 0 | 0 | 43 | 22 | 100% |
| | - | 194 | 26 | 22 | 0 | 0 | 100% |
| BUP | + | 0 | 0 | 0 | 39 | 23 | 100% |
| | - | 189 | 35 | 21 | 0 | 0 | 100% |
| BZO300 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| BZO200 | + | 0 | 0 | 0 | 22 | 24 | 100% |
| | - | 184 | 37 | 40 | 0 | 0 | 100% |
| COC300 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| COC150 | + | 0 | 0 | 0 | 37 | 41 | 100% |
| | - | 182 | 25 | 22 | 0 | 0 | 100% |
| MDMA | + | 0 | 0 | 1 | 37 | 39 | 100% |
| | - | 189 | 21 | 20 | 0 | 0 | 99.50% |
{23}
| Chemtrue® Dipcard Test | Candidate Device Result | (-) | | | (+) | | % Agreement with reference method |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | <50% of the C/O | Negative (50% of the C/O) | Near cutoff Negative (50% of the cutoff to the cutoff) | Near cutoff positive (cutoff to 125% of the cutoff) | Positive (≥125% of the C/O) | |
| MET 1000 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| MET 500 | + | 0 | 0 | 0 | 26 | 22 | 100% |
| | - | 55 | 41 | 25 | 0 | 0 | 100% |
| MET 300 | + | 0 | 0 | 0 | 23 | 42 | 100% |
| | - | 56 | 22 | 25 | 0 | 0 | 100% |
| MTD | + | 0 | 0 | 0 | 21 | 20 | 100% |
| | - | 208 | 21 | 37 | 0 | 0 | 100% |
| MOR300 | + | 0 | 0 | 0 | 19 | 58 | 100% |
| | - | 56 | 19 | 18 | 0 | 0 | 100% |
| OPI2000 | + | 0 | 0 | 0 | 20 | 20 | 100% |
| | - | 58 | 20 | 20 | 0 | 0 | 100% |
| OXY | + | 0 | 0 | 0 | 39 | 21 | 100% |
| | - | 176 | 21 | 20 | 0 | 0 | 100% |
| PCP | + | 0 | 0 | 0 | 21 | 20 | 100% |
| | - | 192 | 39 | 35 | 0 | 0 | 100% |
| PPX | + | 0 | 0 | 1 | 38 | 40 | 100% |
| | - | 185 | 22 | 21 | 0 | 0 | 99.60% |
| TCA | + | 0 | 0 | 1 | 20 | 36 | 100% |
| | - | 177 | 21 | 22 | 0 | 0 | 99.60% |
| THC | + | 0 | 0 | 0 | 21 | 37 | 100% |
| | - | 190 | 39 | 20 | 0 | 0 | 100% |
{24}
| Chemtrue® Dipcard Test | Candidate Device Result | (-) | | | (+) | | % Agreement with reference method |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | <50% of the C/O | Negative (50% of the C/O) | Near cutoff Negative (50% of the cutoff to the cutoff) | Near cutoff positive (cutoff to 125% of the cutoff) | Positive (≥125% of the C/O) | |
| AMP1000 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| AMP500 | + | 0 | 0 | 0 | 28 | 21 | 100% |
| | - | 54 | 39 | 41 | 0 | 0 | 100% |
| AMP300 | + | 0 | 0 | 1 | 24 | 46 | 100% |
| | - | 53 | 21 | 23 | 0 | 0 | 99% |
| BAR300 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| BAR200 | + | 0 | 0 | 0 | 43 | 22 | 100% |
| | - | 194 | 26 | 22 | 0 | 0 | 100% |
| BUP 10 | + | 0 | 0 | 0 | 35 | 26 | 100% |
| | - | 202 | 35 | 23 | 0 | 0 | 100% |
| BZO300 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| BZO200 | + | 0 | 0 | 0 | 21 | 25 | 100% |
| | - | 184 | 37 | 40 | 0 | 0 | 100% |
| COC300 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
| COC150 | + | 0 | 0 | 0 | 37 | 40 | 100% |
| | - | 183 | 25 | 22 | 0 | 0 | 100% |
| MDMA | + | 0 | 0 | 0 | 38 | 39 | 100% |
| | - | 204 | 20 | 20 | 0 | 0 | 100% |
| MET1000 | + | 0 | 0 | 0 | 10 | 10 | 100% |
| | - | 60 | 10 | 10 | 0 | 0 | 100% |
{25}
| Chemtrue® Dipcard Test | Candidate Device Result | (-) | | | (+) | | % Agreement with reference method |
| --- | --- | --- | --- | --- | --- | --- | --- |
| | | <50% of the C/O | Negative (50% of the C/O) | Near cutoff Negative (50% of the cutoff to the cutoff) | Near cutoff positive (cutoff to 125% of the cutoff) | Positive (≥125% of the C/O) | |
| MET500 | + | 0 | 0 | 0 | 22 | 36 | 100% |
| | - | 55 | 44 | 26 | 0 | 0 | 100% |
| MET300 | + | 0 | 0 | 1 | 24 | 43 | 100% |
| | - | 57 | 20 | 23 | 0 | 0 | 99% |
| MTD 300 | + | 0 | 0 | 0 | 20 | 20 | 100% |
| | - | 222 | 21 | 38 | 0 | 0 | 100% |
| MOR 300 | + | 0 | 0 | 0 | 19 | 59 | 100% |
| | - | 51 | 34 | 19 | 0 | 0 | 100% |
| OP2000 | + | 0 | 0 | 0 | 19 | 19 | 100% |
| | - | 59 | 21 | 20 | 0 | 0 | 100% |
| OXY | + | 0 | 0 | 0 | 39 | 21 | 100% |
| | - | 191 | 20 | 20 | 0 | 0 | 100% |
| PCP | + | 0 | 0 | 0 | 35 | 22 | 100% |
| | - | 194 | 35 | 35 | 0 | 0 | 100% |
| PPX | + | 0 | 0 | 0 | 38 | 40 | 100% |
| | - | 185 | 22 | 22 | 0 | 0 | 100% |
| TCA | + | 0 | 0 | 0 | 21 | 36 | 100% |
| | - | 174 | 35 | 25 | 0 | 0 | 100% |
| THC | + | 0 | 0 | 0 | 21 | 38 | 100% |
| | - | 203 | 39 | 20 | 0 | 0 | 100% |
4. Clinical cut-off:
Not applicable.
5. Expected values/Reference range:
Not applicable.
{26}
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.
27
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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.