K170222 · American Bio Medica Corp. · LAF · Aug 15, 2017 · Clinical Toxicology
Device Facts
Record ID
K170222
Device Name
Rapid Tox Cup II
Applicant
American Bio Medica Corp.
Product Code
LAF · Clinical Toxicology
Decision Date
Aug 15, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 862.3610
Device Class
Class 2
Indications for Use
The Rapid TOX Cup II is an in vitro diagnostic drugs of abuse testing device intended for use in the qualitative detection of the following drugs of abuse testing in a human urine specimen: Amphetamines (D-amphetamine) (1000 & 500 ng/mL), Barbiturates (Butalbital) (300 ng/mL), Benzodiazepines (Oxazepam) (300 ng/mL), Buprenorphine (12.5 ng/mL), Cocaine (Benzoylecgonine) (300 & 150 ng/mL), MDMA (Methylenedioxymethamphetamine) (500 ng/mL), Methadone (300 ng/mL), Methamphetamine (D-methamphetamine) (1000 & 500 ng/mL), Opiates (Morphine) (2000 & 300 ng/mL), Oxycodone (100 ng/mL), Phencyclidine (25 ng/mL), Marijuana (11-nor-Δ9-THC-9-carboxylic-acid) (50 ng/mL), Tricyclic Antidepressants (Nortriptyline) (1000 ng/mL). The test is intended for over-the-counter use. This assay may yield positive results when barbiturates, benzodiazepines, or tricyclic antidepressants are ingested at or above therapeutic doses. There are no uniformly recognized cutoff levels for barbiturates, benzodiazepines, or tricyclic antidepressants in urine. The assay is not intended to distinguish between prescription use or abuse of these drugs. Rapid TOX Cup II provides only a preliminary analytical result. A more specific alternate method must be used in order to obtain a more confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical and professional judgment should be applied to any drug of abuse result, particularly when preliminary positive results are used.
Device Story
Rapid TOX Cup II is a urine collection cup with integrated temperature strip and test inserts; designed for qualitative detection of 13 drug classes. Operates via lateral flow immunoassay; urine sample migrates by capillary action across membrane strips containing immobilized drug conjugates and colloidal gold-labeled antibodies. Competitive binding principle: drug in urine competes with immobilized conjugate for antibody binding sites. Two visible lines (control and test) indicate negative result; one line (control only) indicates preliminary positive result. Used by untrained consumers or professionals in point-of-care settings. Provides preliminary screening results; requires follow-up with specific confirmatory methods like GC/MS or LC-MS/MS. Enables rapid initial assessment of drug presence to guide clinical or professional decision-making.
Clinical Evidence
Clinical evidence consists of a consumer user study evaluating performance by untrained individuals. Participants tested prepared samples at various concentrations (negative, low negative, near negative, near positive, high positive). Results demonstrated high concordance with expected outcomes across all 13 drug analytes, confirming that lay users can accurately interpret the qualitative results.
Technological Characteristics
Qualitative lateral flow immunoassay. Materials: Polyethylene cup. Dimensions: 64 mm x 3.5 mm test strips. Sensing: Competitive binding with colloidal gold-labeled antibody. Energy: None (passive capillary action). Connectivity: None. Sterilization: Not stated. Software: None.
Indications for Use
Indicated for qualitative detection of drugs of abuse in human urine specimens for over-the-counter use. Target population includes individuals seeking preliminary screening for amphetamines, barbiturates, benzodiazepines, buprenorphine, cocaine, MDMA, methadone, methamphetamines, opiates, oxycodone, phencyclidine, THC, and tricyclic antidepressants. Not intended to distinguish between prescription use and abuse.
Regulatory Classification
Identification
A methamphetamine test system is a device intended to measure methamphetamine, a central nervous system stimulating drug, in serum, plasma, and urine. Measurements obtained by this device are used in the diagnosis and treatment of methamphetamine use or overdose.
Special Controls
*Classification.* Class II (special controls). A methamphetamine 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
Rapid TOX Cup (k073078)
Submission Summary (Full Text)
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# 510(k) SUBSTANTIAL EQUIVALENCE DETERMINATION DECISION SUMMARY ASSAY ONLY TEMPLATE
A. 510(k) Number:
k170222
B. Purpose for Submission:
Modification to the test strip size of previously cleared Prescription-only device and addition of Over The Counter (OTC) claim.
C. Measurands:
Amphetamines, barbiturates, benzodiazepines, buprenorphine, cocaine, MDMA, methadone, methamphetamines, opiates, oxycodone, phencyclidine, THC/Cannabinoids, and tricyclic antidepressants.
D. Type of Test:
Qualitative lateral flow immunoassay
E. Applicant:
American Bio Medica Corporation, Inc.
F. Proprietary and Established Names:
Rapid TOX Cup II
G. Regulatory Information:
| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| DKZ | Class II | 21CFR 862.3100, Amphetamine Test System | Toxicology (91) |
| DIS | Class II | 21 CFR 862.3150, Barbiturates Test System | Toxicology (91) |
| JXM | Class II | 21 CFR 862.3170, Benzodiazepines Test System | Toxicology (91) |
| DJG | Class II | 21 CFR 862.3650, Opiate Test System | Toxicology (91) |
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| Product Code | Classification | Regulation Section | Panel |
| --- | --- | --- | --- |
| DIO | Class II | 21 CFR 862.3250, Cocaine and metabolites Test System | Toxicology (91) |
| LAF | Class II | 21 CFR 862.3610, Methamphetamine Test System | Toxicology (91) |
| DJR | Class II | 21 CFR 862.3620, Methadone Test System | Toxicology (91) |
| LCM | Unclassified, 510(k) required | Enzyme Immunoassay, Phencyclidine | Toxicology (91) |
| LDJ | Class II | 21 CFR 862.3870 Cannabinoid test system | Toxicology (91) |
| LFG | Class II | 21 CFR 862.3910, Tricyclic antidepressant drugs test system | Toxicology (91) |
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H. Intended Use:
1. Intended use(s):
Refer to Indications for Use.
2. Indication(s) for use:
The Rapid TOX Cup II is an in vitro diagnostic drugs of abuse testing device intended for use in the qualitative detection of the following drugs of abuse testing in a human urine specimen:
| Analyte | Calibrator | Cutoff (ng/mL) |
| --- | --- | --- |
| Amphetamine | D-amphetamine | 1000 |
| Amphetamine | D-amphetamine | 500 |
| Barbiturates (Butalbital) | Butalbital | 300 |
| Benzodiazepines (Oxazepam) | Oxazepam | 300 |
| Buprenorphine | Buprenorphine | 12.5 |
| Cocaine | Benzoylecgonine | 300 |
| Cocaine | Benzoylecgonine | 150 |
| MDMA | MDMA (Methylenedioxymethamphetamine) | 500 |
| Methadone | Methadone | 300 |
| Methamphetamine | D-methamphetamine | 1000 |
| Methamphetamine | D-methamphetamine | 500 |
| Opiates | Morphine | 2000 |
| Opiates | Morphine | 300 |
| Oxycodone | Oxycodone | 100 |
| Phencyclidine | Phencyclidine | 25 |
| Marijuana | 11-nor-Δ9-THC-9-carboxylic-acid | 50 |
| Tricyclic Antidepressants | Nortriptyline | 1000 |
The test is intended for over-the-counter use.
This assay may yield positive results when barbiturates, benzodiazepines, or tricyclic antidepressants are ingested at or above therapeutic doses. There are no uniformly recognized cutoff levels for barbiturates, benzodiazepines, or tricyclic antidepressants in urine. The assay is not intended to distinguish between prescription use or abuse of these drugs.
Rapid TOX Cup II provides only a preliminary analytical result. A more specific alternate method must be used in order to obtain a more confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical and professional judgment should be applied to any drug of abuse result, particularly when preliminary positive results are used.
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3. Special conditions for use statement(s):
For over-the-counter, 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 (and lid) with 3 to 5 drug test strips with each strip testing for either 1 or 4 drugs simultaneously. Configuration 1 provides 5 test strips to test for a total of 14 drugs. Configuration 2 provides 3 test strips to test for a total of 12 drugs. The test cup and lid come in a sealed foil pouch.
- Package insert (instructions for use)
- Pre-addressed mailing box, plastic transport bag and identification label to send the sample for confirmation lab testing.
J. Substantial Equivalence Information:
1. Predicate device name(s):
Rapid TOX Cup
2. Predicate 510(k) number(s):
k073078
3. Comparison with predicate:
| Similarities | | |
| --- | --- | --- |
| Item | Candidate Device: Rapid TOX Cup II | Predicate – k073078 Rapid TOX Cup |
| Specimen | Urine | Same |
| Test Format | Cup | Same |
| Intended Use | Qualitative detection of one or more drugs of abuse | Same |
| Methodology | Qualitative one-step lateral flow immunoassay | Same |
| Differences | | |
| --- | --- | --- |
| | Candidate Device: Rapid TOX Cup II | Predicate – k073078 Rapid TOX Cup |
| Use Setting | Over-the-counter use | For professional use only |
| Analytes | Amphetamine 1000 ng/mL | Amphetamine 1000 ng/mL |
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| Differences | | |
| --- | --- | --- |
| | Candidate Device: Rapid TOX Cup II | Predicate – k073078 Rapid TOX Cup |
| | Amphetamine 500 ng/mL
Methamphetamine 1000 ng/mL
Methamphetamine 500 ng/mL
3,4-methylenedioxymethamphetamine (MDMA) 500 ng/mL
Buprenorphine 12.5 ng/mL
Benzodiazepines (Oxazepam) 300 ng/mL
Barbiturates (Butalbital) 300 ng/mL
Oxycodone 100 ng/mL
Methadone 300 ng/mL
Phencyclidine 25 ng/mL
Opiates 300 ng/mL
Opiates 2000 ng/mL
Cocaine (Benzoylecgonine) 300 ng/mL
Cocaine (Benzoylecgonine) 150 ng/mL
Tricyclic Antidepressants (Nortriptyline) 1000 ng/mL
THC/Cannabinoids (11 norΔ9-THC-9-carboxylic acid) 50 ng/mL | Amphetamine 500 ng/mL
Methamphetamine 1000 ng/mL
Methamphetamine 500 ng/mL
3,4-methylenedioxymethamphetamine (MDMA) 1000 ng/mL
3,4-methylenedioxymethamphetamine (MDMA) 500 ng/mL
Buprenorphine 12.5 ng/mL
Benzodiazepines (Oxazepam) 300 ng/mL
Barbiturates (Butalbital) 300 ng/mL
Oxycodone 100 ng/mL
Methadone 300 ng/mL
Phencyclidine 25 ng/mL
Propoxyphene 300 ng/mL
Opiates 300 ng/mL
Opiates 2000 ng/mL
Cocaine (Benzoylecgonine) 300 ng/mL
Cocaine (Benzoylecgonine) 150 ng/mL
Tricyclic Antidepressants (Nortriptyline) 1000 ng/mL
THC/Cannabinoids (11 norΔ9-THC-9-carboxylic acid) 50 ng/mL |
| Test Strip size | 64 mm x 3.5 mm | 84 mm x 5 mm |
| Jar and insert size | Insert is a smaller size to accommodate smaller test strips; Jar is same size (8oz) with a wider mouth to facilitate sample collection | Insert accommodates strip size Jar is 8oz. |
| Cup composition | Polyethylene | Polypropylene |
K. Standard/Guidance Document Referenced (if applicable):
None referenced.
L. Test Principle:
Each Rapid TOX Cup II test device contains test strips for several drugs of abuse. The test
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strip consists of a membrane strip with an immobilized drug conjugate. A colloidal gold-labeled antibody complex is dried at one end of the membrane. The specifically labeled drug (drug conjugate) competes for antibody binding sites with drugs or metabolites that may be present in the urine specimen.
An internal quality control line, comprised of a different antibody/antigen reaction is contained in on each membrane strip. The control line is not influenced by the presence or absence of drug analytes in the urine specimen, and therefore, it should be visible in all samples tested.
In the absence of specified drug(s) in the urine specimen, the colloidal gold-labeled antibody complex moves with the urine by capillary action to contact the immobilized drug conjugate. An antibody-antigen reaction occurs forming a visible line in the "test" area. The formation of two (2) visible lines (control and test lines) occurs when the test is negative or below the cutoff for the drug.
When a drug analyte is present in the urine specimen, the drug or metabolite will compete with the immobilized drug conjugate in the test area for the antibody binding sites on the colloidal gold-labeled antibody complex. If a sufficient amount of drug analyte is present, it will fill all of the available binding sites, thus preventing attachment of the labeled antibody to the drug conjugate. The formation of a control line, and the absence of a test line is indicative of a preliminary positive result.
## M. Performance Characteristics (if/when applicable):
### 1. Analytical performance:
#### a. Precision/Reproducibility:
Each analyte for the precision study was tested at the following concentrations: Negative, and -75%, -50%, -25%, +25%, +50% and +75% of the specific cutoff for each drug assay. The panels were blinded and randomized prior to testing. Testing was performed using 3 lots of ABMC test strips and was performed once a day by 3 operators over 12 consecutive days, and the results of this testing are summarized as follows for each device.
Amphetamines 1000
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 250 | -75% | 36 neg / 0 pos |
| 500 | -50% | 36 neg / 0 pos |
| 750 | -25% | 33 neg / 3 pos |
| 1250 | +25% | 0 neg / 36 pos |
| 1500 | +50% | 0 neg / 36 pos |
| 1750 | +75% | 0 neg / 36 pos |
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Methamphetamines 1000
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 250 | -75% | 36 neg / 0 pos |
| 500 | -50% | 36 neg / 0 pos |
| 750 | -25% | 31 neg / 5 pos |
| 1250 | +25% | 0 neg / 36 pos |
| 1500 | +50% | 0 neg / 36 pos |
| 1750 | +75% | 0 neg / 36 pos |
Amphetamines 500
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 125 | -75% | 36 neg / 0 pos |
| 250 | -50% | 36 neg / 0 pos |
| 375 | -25% | 27 neg / 9 pos |
| 625 | +25% | 0 neg / 36 pos |
| 750 | +50% | 0 neg / 36 pos |
| 875 | +75% | 0 neg / 36 pos |
Methamphetamines 500
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 125 | -75% | 36 neg / 0 pos |
| 250 | -50% | 36 neg / 0 pos |
| 375 | -25% | 31 neg / 5 pos |
| 625 | +25% | 0 neg / 36 pos |
| 750 | +50% | 0 neg / 36 pos |
| 875 | +75% | 0 neg / 36 pos |
MDMA 500
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 125 | -75% | 36 neg / 0 pos |
| 250 | -50% | 36 neg / 0 pos |
| 375 | -25% | 28 neg / 8 pos |
| 625 | +25% | 0 neg / 36 pos |
| 750 | +50% | 0 neg / 36 pos |
| 875 | +75% | 0 neg / 36 pos |
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Cocaine 300
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 75 | -75% | 36 neg / 0 pos |
| 150 | -50% | 36 neg / 0 pos |
| 225 | -25% | 33 neg / 3 pos |
| 375 | +25% | 0 neg / 36 pos |
| 450 | +50% | 0 neg / 36 pos |
| 525 | +75% | 0 neg / 36 pos |
Cocaine 150
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 37.5 | -75% | 36 neg / 0 pos |
| 75 | -50% | 36 neg / 0 pos |
| 112.5 | -25% | 32 neg / 4 pos |
| 187.5 | +25% | 0 neg / 36 pos |
| 225 | +50% | 0 neg / 36 pos |
| 262.5 | +75% | 0 neg / 36 pos |
Opiates 2000
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 500 | -75% | 36 neg / 0 pos |
| 1000 | -50% | 36 neg / 0 pos |
| 1500 | -25% | 30 neg / 6 pos |
| 2500 | +25% | 0 neg / 36 pos |
| 3000 | +50% | 0 neg / 36 pos |
| 3500 | +75% | 0 neg / 36 pos |
Opiates 300
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 75 | -75% | 36 neg / 0 pos |
| 150 | -50% | 36 neg / 0 pos |
| 225 | -25% | 30 neg / 6 pos |
| 375 | +25% | 0 neg / 36 pos |
| 450 | +50% | 0 neg / 36 pos |
| 525 | +75% | 0 neg / 36 pos |
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Benzodiazepines 300
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 75 | -75% | 36 neg / 0 pos |
| 150 | -50% | 36 neg / 0 pos |
| 225 | -25% | 30 neg / 6 pos |
| 375 | +25% | 0 neg / 36 pos |
| 450 | +50% | 0 neg / 36 pos |
| 525 | +75% | 0 neg / 36 pos |
Barbiturates 300
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 75 | -75% | 36 neg / 0 pos |
| 150 | -50% | 36 neg / 0 pos |
| 225 | -25% | 30 neg / 6 pos |
| 375 | +25% | 0 neg / 36 pos |
| 450 | +50% | 0 neg / 36 pos |
| 525 | +75% | 0 neg / 36 pos |
Methadone 300
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 75 | -75% | 36 neg / 0 pos |
| 150 | -50% | 36 neg / 0 pos |
| 225 | -25% | 34 neg / 2 pos |
| 375 | +25% | 0 neg / 36 pos |
| 450 | +50% | 0 neg / 36 pos |
| 525 | +75% | 0 neg / 36 pos |
PCP 25
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 6.25 | -75% | 36 neg / 0 pos |
| 12.5 | -50% | 36 neg / 0 pos |
| 18.75 | -25% | 33 neg / 3 pos |
| 31.25 | +25% | 0 neg / 36 pos |
| 37.5 | +50% | 0 neg / 36 pos |
| 43.75 | +75% | 0 neg / 36 pos |
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THC 50
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 12.5 | -75% | 36 neg / 0 pos |
| 25 | -50% | 36 neg / 0 pos |
| 37.5 | -25% | 35 neg / 1 pos |
| 62.5 | +25% | 0 neg / 36 pos |
| 75 | +50% | 0 neg / 36 pos |
| 87.5 | +75% | 0 neg / 36 pos |
TCA 1000
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 250 | -75% | 36 neg / 0 pos |
| 500 | -50% | 36 neg / 0 pos |
| 750 | -25% | 30 neg / 6 pos |
| 1250 | +25% | 0 neg / 36 pos |
| 1500 | +50% | 0 neg / 36 pos |
| 1750 | +75% | 0 neg / 36 pos |
Buprenorphine 12.5
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 3.125 | -75% | 36 neg / 0 pos |
| 6.25 | -50% | 36 neg / 0 pos |
| 9.375 | -25% | 33 neg / 3 pos |
| 15.625 | +25% | 0 neg / 36 pos |
| 18.75 | +50% | 0 neg / 36 pos |
| 21.875 | +75% | 0 neg / 36 pos |
Oxycodone 100
| Concentration (ng/mL) | % of cutoff | Results (Neg / Pos) |
| --- | --- | --- |
| 0 | 0 | 36 neg / 0 pos |
| 25 | -75% | 36 neg / 0 pos |
| 50 | -50% | 36 neg / 0 pos |
| 75 | -25% | 35 neg / 1 pos |
| 125 | +25% | 0 neg / 36 pos |
| 150 | +50% | 0 neg / 36 pos |
| 175 | +75% | 0 neg / 36 pos |
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b. Linearity/assay reportable range:
Not applicable. These devices are intended for qualitative use only.
c. Traceability, Stability, Expected values (controls, calibrators, or methods):
The device has internal process controls. A control line appears in the control region confirming that sufficient sample volume has been applied to the test strip and that the sample has migrated correctly on the test strip. Users are informed that the test is invalid if the colored line does not appear in the control region. There are no external controls supplied with the device.
Device stability has been evaluated through accelerated and real-time studies. 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 $2 - 30^{\circ}\mathrm{C}$ . Real-time studies are ongoing.
d. Detection limit:
See precision data in Section M1a above for assay performance around the claimed cutoff concentrations.
e. Analytical specificity:
The cross-reactivity of structurally similar compounds was evaluated in k073078.
Interferences. Potential interference of structurally dissimilar and endogenous compounds was evaluated in k073078. The following additional compounds were also tested for interference, where exogenous and endogenous compounds into samples at - 50% and -50% of the cutoff. No positive or negative interference was observed from any of the following compounds when present at 100,000 ng/mL:
| Acetaminophen | AcetylsalicylicAcid/Aspirin | Albumin |
| --- | --- | --- |
| Amikacin | Ampicillin | Arterenal |
| Atropine | Benzoic Acid | Bilirubin |
| Caffeine | Creatine | Ethanol |
| Glucose | Hemoglobin | Lidocaine |
| Methanol | Oxalic Acid | Penicillin-G |
| Phenylpropanalamine | Ranitidine | Salicylic Acid |
| Thioridazine | Trifluoperazine | Uric Acid |
| Vitamin C | | |
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# Specific gravity and pH
The effect of specific gravity for each analyte was evaluated by testing positive and negative samples at specific gravities ranging from 1.00 to 1.035. No interference was observed for all specific gravities tested.
The effect of pH for each analyte was evaluated by testing positive and negative samples over a range of pH levels. No interference was observed for all pH levels tested.
## 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:
The sponsor performed a method comparison study using unaltered clinical specimens and compared results from the Rapid TOX Cup II (RTC II) to a reference method. Results are summarized below:
AMP 500
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1* | 6 | 50 |
| Negative | 38 | 4 | 0 | 0 |
*For the single false positive for Amphetamines, the concentration was determined by GC/MS to be 487 ng/mL.
AMP 1000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 43 |
| Negative | 45 | 9 | 0 | 0 |
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BAR 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 37 |
| Negative | 35 | 5 | 0 | 0 |
BZO 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 37 |
| Negative | 54 | 8 | 0 | 0 |
BUP 12.5
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 11 | 46 |
| Negative | 172 | 10 | 0 | 0 |
COC 150
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 5 | 51 |
| Negative | 33 | 7 | 0 | 0 |
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COC 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 37 |
| Negative | 35 | 9 | 0 | 0 |
MDMA 500
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 7 | 33 |
| Negative | 50 | 4 | 0 | 0 |
MTD 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 8 | 41 |
| Negative | 31 | 10 | 0 | 0 |
METH 500
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 5 | 42 |
| Negative | 41 | 4 | 0 | 0 |
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METH 1000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 5 | 39 |
| Negative | 47 | 6 | 0 | 0 |
OPI 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 56 |
| Negative | 152 | 5 | 0 | 0 |
OPI 2000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 40 |
| Negative | 164 | 5 | 0 | 0 |
OXY 100
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 5 | 62 |
| Negative | 35 | 10 | 0 | 0 |
{15}
PCP 25
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1* | 5 | 35 |
| Negative | 30 | 10 | 0 | 0 |
*For the single false positive for PCP, the concentration was determined by GC/MS to be 24.8 ng/mL
TCA 1000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 11 | 29 |
| Negative | 40 | 5 | 0 | 0 |
THC 50
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 0 | 6 | 35 |
| Negative | 24 | 25 | 0 | 0 |
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.
{16}
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. A total of 430 demographically diverse untrained consumers at three sites took part in the study, with enrollment and testing over the course of five (5) days. Each day, individual participants tested two (2) contrived samples using one of two product configurations. On the last day, 20 participants only tested one (1) contrived sample.
Samples were created by spiking the analyte into drug-free urine pool. Each sample was aliquoted into an individual blind-labeled container. The concentrations analyzed for each analyte and cutoff were negative, 25%, 50%, 75%, 125%, 150%, and 175% of the cutoff, and were confirmed by a reference method. The results are summarized below:
AMP 500
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 5 | 40 | 20 |
| Negative | 40 | 35 | 0 | 0 |
AMP 1000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 40 | 20 |
| Negative | 100 | 39 | 0 | 0 |
BAR 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 3 | 40 | 20 |
| Negative | 100 | 37 | 0 | 0 |
{17}
BZO 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 3 | 40 | 20 |
| Negative | 80 | 37 | 0 | 0 |
BUP 12.5
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 2 | 40 | 20 |
| Negative | 160 | 38 | 0 | 0 |
COC 150
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 2 | 40 | 20 |
| Negative | 40 | 38 | 0 | 0 |
COC 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 40 | 20 |
| Negative | 60 | 39 | 0 | 0 |
{18}
MDMA 500
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 4 | 40 | 20 |
| Negative | 40 | 36 | 0 | 0 |
MTD 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 40 | 20 |
| Negative | 60 | 39 | 0 | 0 |
METH 500
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 3 | 40 | 20 |
| Negative | 40 | 37 | 0 | 0 |
METH 1000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 2 | 40 | 20 |
| Negative | 80 | 38 | 0 | 0 |
{19}
OPI 300
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 3 | 40 | 20 |
| Negative | 40 | 37 | 0 | 0 |
OPI 2000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 3 | 40 | 20 |
| Negative | 80 | 37 | 0 | 0 |
OXY 100
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 40 | 20 |
| Negative | 100 | 39 | 0 | 0 |
PCP 25
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 2 | 40 | 20 |
| Negative | 100 | 38 | 0 | 0 |
20
{20}
21
# TCA 1000
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 2 | 40 | 20 |
| Negative | 100 | 38 | 0 | 0 |
# THC 50
| Candidate Device Results | Negative by the predicate device or less than half the cutoff concentration by GC/MS analysis | Near Cutoff Negative (Between 50% below the cutoff and the cutoff concentration) | Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration) | High Positive (greater than 50% above the cutoff concentration) |
| --- | --- | --- | --- | --- |
| Positive | 0 | 1 | 40 | 20 |
| Negative | 100 | 39 | 0 | 0 |
4. Clinical cut-off:
Not applicable.
5. Expected values/Reference range:
Not applicable.
N. Proposed Labeling:
The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10.
O. Conclusion:
The submitted information in this premarket notification is complete and supports a substantial equivalence decision.
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Learn the FDA Browser
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.