CLUNGENE Amphetamine Tests are immunochromatographic assays for the qualitative determination of d-Amphetamine in human urine at cut-off concentration of 1000 ng/mL. The tests are available in a Cassette format, a Cup format, a Dip Card format, and a Split Key Cup format. The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use. CLUNGENE Cocaine Tests are immunochromatographic assays for the qualitative determination of Cocaine in human urine at cut-off concentration of 300 ng/mL. The tests are available in a Cassette format, a Cup format, a Dip Card format, and a Split Key Cup format. The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use. CLUNGENE Oxazepam Tests are immunochromatographic assays for the qualitative determination of Oxazepam in human urine at cut-off concentration of 300 ng/mL. The tests are available in a Cassette format, a Dip Card format, and a Split Key Cup format. The test may yield preliminary positive results even when prescription drug Oxazepam is ingested, at prescribed doses; it is not intended to distinguish between prescription use or abuse of this drug. There is no uniformly recognized cutoff concentration level for Oxazepam in urine. The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
Device Story
Lateral flow immunochromatographic assays for qualitative detection of d-Amphetamine, Cocaine, and Oxazepam in human urine; competitive binding principle; antibody-coated particles bind to drug-specific conjugate; colored line indicates negative result (drug below cutoff); absence of line indicates positive result (drug above cutoff); procedural control line confirms proper migration; available in Cassette, Cup, Dip Card, and Split Key Cup formats; intended for OTC and prescription use; results are preliminary and require GC/MS confirmation; clinical judgment required for positive results.
Clinical Evidence
No clinical diagnostic studies performed. Analytical performance validated via precision/reproducibility studies (1350 results per analyte/format) and method comparison against GC/MS. Consumer study conducted with 1680 subjects (140 per format/analyte) demonstrated lay-user ability to correctly interpret results across various drug concentrations relative to cutoff.
Technological Characteristics
Lateral flow immunochromatographic assay; competitive binding principle; qualitative; visually read; no instrumentation required; stable at 4-30°C for 24 months; internal procedural control line included.
Indications for Use
Indicated for qualitative detection of d-Amphetamine (1000 ng/mL), Cocaine (300 ng/mL), and Oxazepam (300 ng/mL) in human urine. Intended for OTC and prescription use to provide preliminary screening results. Not intended to distinguish between prescription use and abuse for Oxazepam.
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
The FIRST CHECK MULTI DRUG CUP Urine Test (k052115)
Submission Summary (Full Text)
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1
510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION
DECISION SUMMARY
ASSAY AND INSTRUMENT COMBINATION TEMPLATE
A. 510(k) Number:
k161251
B. Purpose for Submission:
New device
C. Measurand:
Amphetamines, Cocaine, and Oxazepam in urine
D. Type of Test:
Qualitative immunochromatographic assay
E. Applicant:
Hangzhou Clongene Biotech Co., Ltd.
F. Proprietary and Established Names:
Clungene Oxazepam Tests
Clungene Amphetamine Tests
Clungene Cocaine Tests
G. Regulatory Information:
1. Regulation section:
21 CFR, 862.3170 Benzodiazepine Test System
21 CFR, 862.3100 Amphetamine Test System
21 CFR, 862.3250 Cocaine Test System
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2. Classification:
All Class II
3. Product codes:
JXM, DKZ, DIO
4. Panel:
91- Toxicology
H. Intended Use:
1. Intended use(s):
See Indications for use below
2. Indication(s) for use:
CLUNGENE Amphetamine Tests are immunochromatographic assays for the qualitative determination of d-Amphetamine in human urine at cut-off concentration of 1000 ng/mL. The tests are available in a Cassette format, a Cup format, a Dip Card format, and a Split Key Cup format.
The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.
For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
CLUNGENE Cocaine Tests are immunochromatographic assays for the qualitative determination of Cocaine in human urine at cut-off concentration of 300 ng/mL. The tests are available in a Cassette format, a Cup format, a Dip Card format, and a Split Key Cup format.
The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.
For in vitro diagnostic use only. The tests are intended for over-the-counter and for
2
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prescription use.
CLUNGENE Oxazepam Tests are immunochromatographic assays for the qualitative determination of Oxazepam in human urine at cut-off concentration of 300 ng/mL. The tests are available in a Cassette format, a Cup format, a Dip Card format, and a Split Key Cup format.
The test may yield preliminary positive results even when prescription drug Oxazepam is ingested, at prescribed doses; it is not intended to distinguish between prescription use or abuse of this drug. There is no uniformly recognized cutoff concentration level for Oxazepam in urine. The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.
For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
3. Special conditions for use statement(s):
For Over-The-Counter (OTC) use.
For In Vitro Diagnostic Use only.
4. Special instrument requirements:
Not applicable, as the device is a visually-read single use device
I. Device Description:
The CLUNGENE Amphetamine Tests, CLUNGENE Cocaine Tests, and CLUNGENE Oxazepam Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of d-Amphetamine, Cocaine and Oxazepam (target analytes) in human urine. The tests are available in Cassette, Dip Card, Cup, and Split Key Cup formats. The tests are the first step in a two-step process. The second step is to send the sample for laboratory testing if preliminary positive results are obtained.
J. Substantial Equivalence Information:
1. Predicate device name(s):
The FIRST CHECK MULTI DRUG CUP Urine Test
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2. Predicate 510(k) number(s):
k052115
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Predicate (k052115) | Candidate Device |
| Indication(s) for Use | For the qualitative determination of drugs of abuse in human urine | Same (but the number of drugs detected is different) |
| Methodology | Competitive binding, lateral flow immunochromatographic assays based on the principle of antigen antibody immunochemistry. | Same |
| Type of test | Qualitative | Same |
| Specimen Type | Human Urine | Same |
| Cutoff | AMP 1000 ng/mL, COC 300 ng/mL, BZO 300 ng/mL | Same |
| Intended Users | Lay Users (Over the Counter) | Same |
| Differences | | |
| Item | Predicate (k052115) | Candidate Device |
| Format | Cup | Cup, cassette, dip card |
| Analytes | Marijuana, Cocaine, Amphetamine, Methamphetamine, Ecstasy, Opiates, Phencyclidine, Benzodiazepines, Barbiturates, Methadone, Tricyclic Antidepressants, and Oxycodone | Amphetamines, cocaine, oxazepam |
K. Standard/Guidance Document Referenced (if applicable):
None referenced
L. Test Principle:
The CLUNGENE Amphetamine Tests, CLUNGENE Cocaine Tests, and CLUNGENE Oxazepam Tests utilize lateral flow immunochromatographic technology based on the principle of competitive binding. Drugs, if present in concentrations below the cutoff level,
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will not saturate the binding sites of antibody coated particles in the device. The antibody-coated particles will then be captured by immobilized drug-specific conjugate and a colored line will appear in the test line region. The colored line will not form if the sample contains drug in excess of the cutoff level because the drug will saturate all the binding sites of the drug-specific antibody. Each strip in the device contains a procedural control that appears in the control line region indicating that the sample has migrated properly on the test strip.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Precision study samples were prepared from negative urine samples spiked to nine different concentrations: +100%, +75% +50%, +25%, cut off, -25%, -50%, -75% and -100% of the drug cutoff concentration for each drug. All sample concentrations were confirmed by GC/MS. All aliquots for testing were blind labeled by the same person who prepared the samples but who did not take part in sample testing. For each combination of analyte and format, three operators read 50 results at each of the nine concentrations, for a total of 1350 results per analyte per format. Results are summarized below.
Cassette Format
| AMP | -100% cutoff | -75% cutoff | -50% cutoff | -25% cutoff | cutoff | +25% cutoff | +50% cutoff | +75% cutoff | +100% cutoff |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 28-/22+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 20-/30+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Dip card Format
| AMP | -100% cutoff | -75% cutoff | -50% cutoff | -25% cutoff | cutoff | +25% cutoff | +50% cutoff | +75% cutoff | +100% cutoff |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 19-/31+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 29-/21+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 22-/28+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
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Easy Cup Format
| AMP | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 28-/22+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 19-/31+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Split Key Cup
| AMP | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 27-/23+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 20-/30+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 31-/19+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Cassette Format
| COC | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 30-/20+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 23-/27+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Dip card Format
| COC | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 28-/22+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 29-/21+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
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Easy Cup Format
| COC | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 31-/19+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 23-/27+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Split Key Cup Format
| COC | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 21-/29+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 32-/18+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Cassette Format
| OXAZ | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 22-/28+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 27-/23+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Dip card Format
| OXAZ | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 21-/29+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 28-/22+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
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8
Easy Cup Format
| OXAZ | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 28-/22+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 21-/29+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
Split Key Cup Format
| OXAZ | -100% cut off | -75% cut off | -50% cut off | -25% Cutoff | cut off | 25% cut off | 50% cut off | 75% cut off | 100% cut off |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 30-/20+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 23-/27+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
b. Linearity/assay reportable range:
Not applicable. These devices are for qualitative use only.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
Procedural controls are included in the test strip and device. A colored line appearing in the control zone is considered as an internal procedural control. It confirms sufficient specimen volume, adequate membrane wicking and correct procedural technique. Control standards are not supplied with these tests; however, it is recommended that positive and negative controls be tested as a good laboratory practice to confirm the test procedure and to verify proper test performance. Users should follow local, state, and federal guidelines to run the external controls.
Device stability has been evaluated through accelerated and real-time studies. A transport simulation study was performed to test extreme shipping temperatures. Protocols and acceptance criteria were reviewed and found to be acceptable. The manufacturer claims that the devices are stable at 4-30 °C for 24 months based on the accelerated stability study at 45°C, real time stability determination at both 4°C and 30°C and transport simulation conditions at -20°C and 40°C.
d. Detection limit:
See Precision/Reproducibility section in M.1.a above.
e. Analytical specificity:
Cross reactivity was evaluated by spiking the structurally similar compounds shown
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below into drug free urine. The concentrations specified below represent the lowest concentration tested that produced a positive result. Testing was performed as instructed in the package insert and three lots of each device were evaluated. No differences were seen between formats. Results are summarized below.
Amphetamine
| Potential cross-reactant | Lowest Concentration producing a positive result (ng/ml) | % Cross Reactivity |
| --- | --- | --- |
| D - Amphetamine | 1000 | 100% |
| L - Amphetamine | 50000 | 2% |
| D/L – Amphetamine | 3000 | 33% |
| Phentermine | 3000 | 33% |
| Hydroxyamphetamine | 5000 | 20% |
| MDA | 5000 | 20% |
| MDMA | Negative at 100000 | < 1% |
| MDE | Negative at 100000 | < 1% |
| D-methamphetamine | Negative at 100000 | < 1% |
| L-methamphetamine | Negative at 100000 | < 1% |
| Ephedrine | Negative at 100000 | < 1% |
| Pseudoephedrine | Negative at 100000 | < 1% |
Cocaine
| Potential cross-reactant | Highest Concentration producing a negative result (ng/ml) | % Cross Reactivity |
| --- | --- | --- |
| Benzoylecgonine | 300 | 100 |
| Cocaine HCl | 780 | 38.5 |
| Cocaethylene | 12500 | 2.4 |
| Ecgonine HCl | 32000 | 0.9 |
| Norcocaine | 100000 | 0.3 |
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Oxazepam
| Potential cross-reactant | Highest Concentration producing a negative result (ng/ml) | % Cross Reactivity |
| --- | --- | --- |
| Oxazepam | 300 | 100% |
| Alprazolam | 200 | 150% |
| a-Hydroxyalprazolam | 1250 | 24% |
| Bromazepam | 1500 | 20% |
| Chlordiazepoxide | 1500 | 20% |
| Clobazam | 100 | 300% |
| Clonazepam | 800 | 37% |
| Clorazepate dipotassium | 200 | 150% |
| Delorazepam | 1500 | 20% |
| Desalkylflurazepam | 400 | 75% |
| Diazepam | 200 | 150% |
| Estazolam | 2500 | 12% |
| Flunitrazepam | 400 | 75% |
| Midazolam | 12500 | 2% |
| Nitrazepam | 100 | 300% |
| Norchlordiazepoxide | 200 | 150% |
| Nordiazepam | 400 | 75% |
| Temazepam | 100 | 300% |
| Triazolam | 2500 | 12% |
| D/L-Lorazepam | 1500 | 20% |
Potential interfering substances were evaluated by spiking the compounds below into drug free urine and urine with drug concentrations at +/-25% of the cutoff. Each compound was spiked at 100,000 ng/mL and tested on three lots of each device. No interference was detected.
| Amphetamine | | |
| --- | --- | --- |
| 4-Acetamidophenol | Diazepam | O-Hydroxyhippuric acid |
| (-)-Cotinine | Diclofenac | Oxalic acid |
| (-)-Isoproterenol | Diflunisal | Oxazepam |
| (-)-Y-Ephedrine | Digoxin | Oxolinic acid |
| (±)-Chlorpheniramine | Diphenhydramine | Oxycodone |
| (IR,2S)-(-)-Ephedrine | Doxylamine | Oxymetazoline |
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| Amphetamine | | |
| --- | --- | --- |
| 3-Hydroxytyramine | Ecgonine hydrochloride | Papaverine |
| Acetophenetidin | Ecgonine methylester | Penicillin-G |
| Acetylsalicylic acid | Erythromycin | Pentazocaine |
| Aminopyrine | Estrone-3-sulfate | Pentobarbital |
| Amitriptyline | Ethyl-p-aminobenzoate | Perphenazine |
| Amobarbital | Fenfluramine | Phencyclidine |
| Amoxicillin | Fenoprofen | Phenelzine |
| Ampicillin | Furosemide | Phenobarbital |
| Ascorbic acid | Gentisic acid | Phenylpropanolamine |
| Aspartame | Hemoglobin | Prednisolone |
| Atropine | Hydralazine | Prednisone |
| Benzilic acid | Hydrochlorothiazide | Procaine |
| Benzoic acid | Hydrocodone | Promazine |
| Benzoylecgonine | Hydrocortisone | Promethazine |
| Bilirubin | Ibuprofen | Quinidine |
| Brompheniramine | Imipramine | Quinine |
| Caffeine | Isoxsuprine | Ranitidine |
| Cannabidiol | Ketamine | Salicylic acid |
| Cannabinol | Ketoprofen | Secobarbital |
| Chloralhydrate | L-Ephedrine | Sulfamethazine |
| Chloramphenicol | L-Phenylephrine | Sulindac |
| Chlordiazepoxide | Labetalol | Temazepam |
| Chloroquine | Levorphanol | Tetracycline |
| Chlorothiazide | Loperamide | Tetrahydrocortisone |
| Chlorpromazine | Maprotiline | Tetrahydrozoline |
| Cholesterol | Meperidine | Thebaine |
| Clomipramine | Meprobamate | Thiamine |
| Clonidine | Methadone | Thioridazine |
| Cocaine hydrochloride | Methylphenidate | Tolbutamine |
| Codeine | Morphine-3-D-glucuronide | Triamterene |
| Cortisone | N-Acetylprocainamide | Trifluoperazine |
| Creatinine | Nalidixic acid | Trimethoprim |
| D-Norpropoxyphene | Naloxone | Trimipramine |
| D-Propoxyphene | Naltrexone | Tryptamine |
| D/L-Octopamine | Naproxen | Uric acid |
| D/L-Propanolol | Niacinamide | Verapamil |
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| Amphetamine | | |
| --- | --- | --- |
| D/L-Thyroxine | Nifedipine | Zomepirac |
| D/L-Tyrosine | Norcodeine | β-Estradiol |
| Deoxycorticosterone | Norethindrone | Δ9-THC-COOH |
| Dextromethorphan | Noscapine | |
| Cocaine | | |
| --- | --- | --- |
| Acetaminophen | Diflunisal | Oxazepam |
| (-)-Cotinine | Digoxin | Oxolinic acid |
| (-)-Ψ-Ephedrine | Diphenhydramine | Oxycodone |
| (±)-3,4-Methylene dioxyamphetamine | Doxylamine | Oxymetazoline |
| (±)-Brompheniramine | Ecgonine methylester | p-Hydroxymethamphetamine |
| (±)-Chlorpheniramine | Erythromycin | Papaverine |
| (±)-Isoproterenol | Estrone-3-sulfate | Penicillin-G |
| 3-Hydroxytyramine | Ethyl-p-aminobenzoate | Pentobarbital |
| Acetophenetidin | Fenoprofen | Perphenazine |
| Acetylsalicylic acid | Furosemide | Phencyclidine |
| Aminopyrine | Gentisic acid | Phenelzine |
| Amitriptyline | Hemoglobin | Phenobarbital |
| Amobarbital | Hydralazine | Phentermine |
| Amoxicillin | hydrochloride | Phenylpropanolamine |
| Ampicillin | hydrochloride(±)-3,4-Methylene-dioxymethamphetamine | Prednisolone |
| Apomorphine | Hydrochlorothiazide | Prednisone |
| Aspartame | Hydrocodone | Procaine |
| Atropine | Hydrocortisone | Promazine |
| Benzilic acid | Ibuprofen | Promethazine |
| Benzoic acid | Imipramine | Quinidine |
| Benzphetamine | Iproniazid | Quinine |
| Caffeine | Isoxsuprine | Ranitidine |
| Cannabidiol | Ketamine | Salicylic acid |
| Cannabinol | Ketoprofen | Secobarbital |
| Chloralhydrate | L-Ascorbic acid | Serotonin |
| Chloramphenicol | L-Phenylephrine | Sulfamethazine |
| Chlordiazepoxide | Labetalol | Sulindac |
| Chloroquine | Levorphanol | Temazepam |
{12}
| Cocaine | | |
| --- | --- | --- |
| Chlorothiazide | Loperamide | Tetracycline |
| Chlorpromazine | Maprotiline | Tetrahydrocortisone 3 (β-D-glucuronide) |
| Cholesterol | Meperidine | Tetrahydrozoline |
| Clomipramine | Meprobamate | Thebaine |
| Clonidine | Methadone | Thiamine |
| Codeine | Methoxyphenamine | Thioridazine |
| Cortisone | Morphine Sulfate | Tolbutamide |
| Creatinine | Morphine-3-β-D-glucuronide | Triamterene |
| D-Norpropoxyphene | N-Acetylprocainamide | Trifluoperazine |
| D-Propoxyphene | Nalidixic acid | Trimethoprim |
| D-Pseudoephedrine | Naloxone | Trimipramine |
| D/L-Amphetamine Sulfate | Naltrexone | Tryptamine |
| D/L-Octopamine | Naproxen | Tyramine |
| D/L-Propranolol | Niacinamide | Uric acid |
| D/L-Tryptophan | Nifedipine | Verapamil |
| D/L-Tyrosine | Norcodeine | Zomepirac |
| Deoxycorticosterone | Norethindrone | β-Estradiol |
| Dextromethorphan | Noscapine | β-Phenylethylamine |
| Diazepam | O-Hydroxyhippuric acid | |
| Diclofenac | Oxalic acid | |
| Oxazepam | | |
| --- | --- | --- |
| 4-Acetamidophenol | D-Propoxyphene | Naproxen |
| (-)-cotinine | D-Pseudoephedrine | Niacinamide |
| (-)-Y-Ephedrine | D/L-Amphetamine | Nifedipine |
| (+)-3,4-Methylenedioxy-amphetamine | D/L-Octopamine | Norethindrone |
| (+)-3,4-Methylenedioxy-methamphetamine | D/L-Propranolol | Noscapine |
| (±)-Chlorpheniramine | D/L-Tryptophan | O-Hydroxyhippuric acid |
| (±)-Chlorpheniramine | D/L-Tyrosine | Oxalic acid |
| (±)-Isoproterenol | Dextromethorphan | Oxolinic acid |
| 3-Hydroxytyramine | Diclofenac | p-Hydroxy- methamphetamine |
| Acetophenetidin | Diflunisal | Pentobarbital |
| Acetylsalicylic acid | Digoxin | Perphenazine |
| Aminopyrine | Diphenhydramine | Phencyclidine |
| Amitriptyline | Doxylamine | Phenelzine |
{13}
| Oxazepam | | |
| --- | --- | --- |
| Amobarbital | Ecgonine hydrochloride | Phenobarbital |
| Amoxicillin | Ecgonine methylester | Phentermine |
| Ampicillin | Fenoprofen | Phenylpropanolamine |
| Apormorphine | Furosemide | Prednisone |
| Aspartame | Gentisic acid | Quinine |
| Atropine | Hemoglobin | Ranitidine |
| Benzilic acid | Hydrocortisone | Salicylic acid |
| Benzoic acid | Ibuprofen | Secobarbital |
| Benzoylecgonine | Imipramine | Serotonin (5-Hydroxytyramine) |
| Benzphetamine | Iproniazid | Sertraline |
| Bilirubin | Isoxsuprine | Sulfamethazine |
| Brompheniramine | Ketamine | Sulindac |
| Caffeine | Ketoprofen | Tetrahydrocortisone |
| Caffeine | l-Ascorbic Acid | Tetrahydrozoline |
| Cannabidiol | L-Phenylephrine | Thiamine |
| Chloralhydrate | Labetalol | Thioridazine |
| Chloramphenicol | Loperamide | Tolbutamide |
| Chloroquine | Maprotiline | Triamterene |
| Chlorothiazide | Meperidine | Trifluoperazine |
| Chlorpromazine | Meprobamate | Trimethoprim |
| Cholesterol | Methadone | Tryptamine |
| Clomipramine | Methoxyphenamine | Tyramine |
| Clonidine | N-Acetylprocainamide | Uric acid |
| Cocaine hydrochloride | Nalidixic acid | Verapamil |
| Cortisone | Nalorphine | Zomepirac |
| Creatinine | Naloxone | β-Phenylethylamine |
| D-Norpropoxyphene | Naltrexone | |
To evaluate the effect of specific gravity, twelve drug free urine samples with specific gravities ranging from 1.000-1.035 were spiked with each drug to $\pm 25\%$ of the cutoff values. Three lots of each device were used to test all samples.
To evaluate the effects of pH, a negative urine pool was aliquoted and the pH of each aliquot was adjusted to 4.00 to 9.00, in increments of $1\mathrm{pH}$ unit. Three lots of each device were used to test all samples. The aliquots were then spiked with amphetamine, cocaine, or Oxazepam to concentrations $25\%$ below and $25\%$ above the cutoff concentrations.
The pH and specific gravity ranges tested did not affect the results from the device.
{14}
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:
a. Method comparison with predicate device:
Method comparison samples consisted of 80 clinical samples (40 negative and 40 positive) for each drug. The samples were masked and randomized by a person who prepared the samples and who didn't take part in the sample testing. Operators were blinded to the sample identity. Each sample concentration of the drug was confirmed by GC-MS. The drug concentration ranges tested were as follows: drug-free, $\leq 50\%$ cut-off, $-50\%$ cut-off to cut-off, Cut-off to $+50\%$ cut-off, and $\geq 50\%$ cut-off, for each drug.
The above samples were tested using one lot of each format of the devices. Twelve (three for each format) laboratory assistants performed the test following the instructions for use. The obtained results were compared to the GC/MS results. The results are summarized below:
Amphetamine
| Cassette | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 1 | 20 | 20 |
| | Negative | 10 | 15 | 14 | 0 | 0 |
| Viewer B | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 18 | 20 |
| | Negative | 10 | 15 | 15 | 2 | 0 |
Discordant Results with Amphetamine Cassette
| Viewer | GC/MS Result | Cassette Viewer Results |
| --- | --- | --- |
| Viewer A | 963 | Positive |
| Viewer B | 1005 | Negative |
| Viewer C | 1005 | Negative |
| Viewer C | 1037 | Negative |
{15}
16
| Panel Dip | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
| Viewer B | Positive | 0 | 0 | 0 | 18 | 20 |
| | Negative | 10 | 15 | 15 | 2 | 0 |
| Viewer C | Positive | 0 | 0 | 1 | 20 | 20 |
| | Negative | 10 | 15 | 14 | 0 | 0 |
Discordant Results with Amphetamine Panel Dip
| Viewer | GC/MS Result | Panel Dip Viewer Results |
| --- | --- | --- |
| Viewer C | 963 | Positive |
| Viewer A | 1005 | Negative |
| Viewer B | 1005 | Negative |
| Viewer B | 1037 | Negative |
| Split- Key Cup | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 0 | 20 | 20 |
| | Negative | 1 | 15 | 15 | 0 | 0 |
| Viewer B | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 1 | 15 | 14 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 1 | 15 | 15 | 1 | 0 |
{16}
Discordant Results with Amphetamine Split-Key Cup
| Viewer | GC/MS Result | Split-Key Cup Viewer Results |
| --- | --- | --- |
| Viewer B | 963 | Positive |
| Viewer B | 1005 | Negative |
| Viewer C | 1005 | Negative |
| Easy Cup | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 0 | 18 | 20 |
| | Negative | 10 | 15 | 15 | 2 | 0 |
| Viewer B | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 10 | 15 | 14 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 2 | 20 | 20 |
| | Negative | 10 | 15 | 13 | 0 | 0 |
Discordant Results with Amphetamine Easy Cup
| Viewer | GC/MS Result | Easy Cup Viewer Results |
| --- | --- | --- |
| Viewer B | 963 | Positive |
| Viewer C | 963 | Positive |
| Viewer C | 952 | Positive |
| Viewer A | 1005 | Negative |
| Viewer A | 1037 | Negative |
| Viewer B | 1005 | Negative |
{17}
18
# Cocaine
| Cassette | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 1 | 20 | 20 |
| | Negative | 10 | 15 | 14 | 0 | 0 |
| Viewer B | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 10 | 15 | 14 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 20 | 20 |
| | Negative | 10 | 15 | 15 | 0 | 0 |
# Discordant Results with Cocaine Cassette
| Viewer | GC/MS Result | Cassette Viewer Results |
| --- | --- | --- |
| Viewer A | 284 | Positive |
| Viewer B | 284 | Positive |
| Viewer B | 307 | Negative |
{18}
19
| Panel Dip | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 2 | 20 | 20 |
| | Negative | 10 | 15 | 13 | 0 | 0 |
| Viewer B | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
Discordant Results with Cocaine Panel Dip
| Viewer | GC/MS Result | Panel Dip Viewer Results |
| --- | --- | --- |
| Viewer B | 311 | Negative |
| Viewer C | 311 | Negative |
| Viewer A | 296 | Positive |
| Viewer A | 284 | Positive |
| Split Key Cup | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 0 | 20 | 20 |
| | Negative | 10 | 15 | 15 | 0 | 0 |
| Viewer B | Positive | 0 | 0 | 0 | 18 | 20 |
| | Negative | 10 | 15 | 15 | 2 | 0 |
| Viewer C | Positive | 0 | 0 | 1 | 20 | 20 |
| | Negative | 10 | 15 | 14 | 0 | 0 |
{19}
20
Discordant Results with Cocaine Split-Key Cup
| Viewer | GC/MS Result | Split Cup Viewer Results |
| --- | --- | --- |
| Viewer C | 284 | Positive |
| Viewer B | 311 | Negative |
| Viewer B | 307 | Negative |
Discordant Results with Cocaine Easy Cup
| Easy Cup | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 0 | 18 | 20 |
| | Negative | 10 | 15 | 15 | 2 | 0 |
| Viewer B | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 10 | 15 | 14 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
| Viewer | Sample Number | GC/MS Result | Easy Cup Viewer Results |
| --- | --- | --- | --- |
| Viewer B | COC45 | 284 | Positive |
| Viewer A | COC35 | 311 | Negative |
| Viewer A | COC66 | 307 | Negative |
| Viewer B | COC66 | 307 | Negative |
| Viewer C | COC35 | 311 | Negative |
{20}
Oxazepam
| Cassette | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
| Viewer B | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 10 | 15 | 14 | 1 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
Discordant Results with Oxazepam Cassette
| Viewer | GC/MS Result | Cassette Viewer Results |
| --- | --- | --- |
| Viewer B | 291 | Positive |
| Viewer A | 309 | Negative |
| Viewer B | 311 | Negative |
| Viewer C | 308 | Negative |
| Panel Dip | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 10 | 15 | 14 | 1 | 0 |
| Viewer B | Positive | 0 | 0 | 0 | 20 | 20 |
| | Negative | 10 | 15 | 15 | 0 | 0 |
| Viewer C | Positive | 0 | 0 | 1 | 20 | 20 |
| | Negative | 10 | 15 | 14 | 0 | 0 |
{21}
Discordant Results with Oxazepam Panel Dip
| Viewer | GC/MS Result | Panel Dip Viewer Results |
| --- | --- | --- |
| Viewer A | 291 | Positive |
| Viewer C | 298 | Positive |
| Viewer A | 308 | Negative |
| Split- Key Cup | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 1 | 18 | 20 |
| | Negative | 10 | 15 | 14 | 2 | 0 |
| Viewer B | Positive | 0 | 0 | 1 | 18 | 20 |
| | Negative | 10 | 15 | 14 | 2 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 19 | 20 |
| | Negative | 10 | 15 | 15 | 1 | 0 |
Discordant Results with Oxazepam Split-Key Cup
| Viewer | GC/MS Result | Split Cup Viewer Results |
| --- | --- | --- |
| Viewer A | 298 | Positive |
| Viewer B | 291 | Positive |
| Viewer A | 311 | Negative |
| Viewer A | 309 | Negative |
| Viewer B | 311 | Negative |
| Viewer B | 323 | Negative |
| Viewer C | 308 | Negative |
{22}
23
| Easy Cup | | Negative | Low Negative by GC/MS (less than -50%) | Near Cutoff Negative by GC/MS (Between -50% and cutoff) | Near Cutoff Positive by GC/MS (Between the cutoff and +50%) | High Positive by GC/MS (greater than +50%) |
| --- | --- | --- | --- | --- | --- | --- |
| Viewer A | Positive | 0 | 0 | 1 | 18 | 20 |
| | Negative | 10 | 15 | 14 | 2 | 0 |
| Viewer B | Positive | 0 | 0 | 2 | 18 | 20 |
| | Negative | 10 | 15 | 13 | 2 | 0 |
| Viewer C | Positive | 0 | 0 | 1 | 19 | 20 |
| | Negative | 10 | 15 | 14 | 1 | 0 |
Discordant Results for Oxazepam Easy Cup
| Viewer | GC/MS result | Easy Cup Viewer Results |
| --- | --- | --- |
| Viewer A | 298 | Positive |
| Viewer B | 298 | Positive |
| Viewer B | 291 | Positive |
| Viewer B | 311 | Negative |
| Viewer A | 308 | Negative |
| Viewer A | 309 | Negative |
| Viewer B | 309 | Negative |
| Viewer C | 291 | Positive |
| Viewer C | 311 | Negative |
b. Matrix comparison:
Not applicable
3. Clinical studies:
a. Clinical Sensitivity:
Not applicable
b. Clinical specificity:
Not applicable
{23}
c. Other clinical supportive data (when a. and b. are not applicable):
A consumer study was performed at three testing sites with a total of 1680 test subjects, with diverse educational backgrounds representative of U.S. demographics. A total of 140 users tested each format of each analyte. The study was performed by spiking drug free urine sample pools with drug at concentrations of 0%, 25%, 50%, 75%, 125%, 150%, and 175% of each drug cutoff. Each participant received one blinded sample, one test device format, and one English language package insert for the device they were to test. The only instructions provided to users were the package inserts for the device being tested. Participants ranged in age from 21 to greater than 50 years of age. None of the participants had experience using drug testing products before.
Each person performed the test and filled out a questionnaire to evaluate the ease of use of the device. All of the users correctly answered the questions on the questionnaire and rated the clarity of the package insert as either "very clear" or "clear". The participant test results were compared to GC/MS results and are summarized below.
Comparison between GC/MS and Lay Person Results for Amphetamine Cassette
| % of Cutoff | Number of samples | d-Amphetamine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 250 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 500 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 750 | 0 | 20 | 100 |
| +25% Cutoff | 20 | 1250 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 1500 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 1750 | 20 | 0 | 100 |
{24}
Comparison between GC/MS and Lay Person Results for Amphetamine Dip Card
| % of Cutoff | Number of samples | d-Amphetamine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 250 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 500 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 750 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 1250 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 1500 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 1750 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Amphetamine Split-Key Cup
| % of Cutoff | Number of samples | d-Amphetamine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 250 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 500 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 750 | 2 | 18 | 90 |
| +25% Cutoff | 20 | 1250 | 18 | 2 | 90 |
| +50% Cutoff | 20 | 1500 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 1750 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Amphetamine Easy Cup
| % of Cutoff | Number of samples | d-Amphetamine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 250 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 500 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 750 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 1250 | 18 | 2 | 90 |
| +50% Cutoff | 20 | 1500 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 1750 | 20 | 0 | 100 |
{25}
Comparison between GC/MS and Lay Person Results for Cocaine Cassette
| % of Cutoff | Number of samples | Cocaine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 375 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Cocaine Dip Card
| % of Cutoff | Number of samples | Cocaine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 375 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Cocaine Split-Key Cup
| % of Cutoff | Number of samples | Cocaine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 375 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
{26}
Comparison between GC/MS and Lay Person Results for Cocaine Easy Cup
| % of Cutoff | Number of samples | Cocaine Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 375 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Oxazepam Cassette
| % of Cutoff | Number of samples | Oxazepam Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 0 | 20 | 100 |
| +25% Cutoff | 20 | 375 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Oxazepam Dip Card
| % of Cutoff | Number of samples | Oxazepam Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 375 | 20 | 0 | 100 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
27
{27}
Comparison between GC/MS and Lay Person Results for Oxazepam Split-Key Cup
| % of Cutoff | Number of samples | Oxazepam Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 2 | 18 | 90 |
| +25% Cutoff | 20 | 375 | 19 | 1 | 95 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
Comparison between GC/MS and Lay Person Results for Oxazepam Easy Cup
| % of Cutoff | Number of samples | Oxazepam Concentration by GC/MS (ng/mL) | Lay person results | | Percentage of correct results (%) |
| --- | --- | --- | --- | --- | --- |
| | | | No. of Positive | No. of Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 75 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 150 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 225 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 375 | 18 | 2 | 90 |
| +50% Cutoff | 20 | 450 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 525 | 20 | 0 | 100 |
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.
{28}
R. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
29
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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.