The Roche Diagnostics Corporation OnTrak TesTstik™ for Morphine 2000 (M2K) is an in vitro test intended for professional use for the qualitative detection of morphine in urine at or above a cutoff concentration of 2000 ng/mL. OnTrak TesTstik provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result.
Device Story
OnTrak TesTcup M2K is an in vitro diagnostic device for professional use; performs qualitative detection of morphine in urine. Device utilizes microparticle capture inhibition; urine sample collected in cup; flows via capillary action across membrane. Membrane contains antibody-coated microparticles and drug conjugate. In absence of morphine, antibody binds drug conjugate, forming blue band (negative). In presence of morphine, drug binds antibody-coated microparticles, inhibiting binding to conjugate, preventing blue band formation (positive). Includes 'TEST VALID' area for procedural control. Healthcare providers use visual color-coded results to screen for morphine; positive results require confirmatory testing via alternate chemical methods (e.g., GC/MS). Benefits include rapid preliminary screening for drug presence.
Clinical Evidence
Bench testing only. Accuracy evaluated using 50 morphine-positive samples (confirmed by GC/MS at 2000 ng/mL cutoff) and 100 negative samples (screened by automated immunoassay). Results showed 100% agreement for both positive and negative samples. Precision evaluated with 100 replicates at various concentrations; >95% confidence at 150% of cutoff. Comparison to Abuscreen OnLine II for Opiates 2000 showed 99.3% agreement.
Technological Characteristics
Competitive microparticle capture inhibition assay. Reagents: Azo-blue dyed microparticles coated with mouse monoclonal anti-morphine antibody, drug conjugates immobilized on membrane, mouse monoclonal anti-BSA antibody. Qualitative visual color endpoint. Single-use urine collection cup form factor. No electronic components or software.
Indications for Use
Indicated for professional use for the qualitative detection of morphine in human urine at or above a 2000 ng/mL cutoff concentration. Provides preliminary analytical results; requires confirmation by alternate chemical method.
Regulatory Classification
Identification
A morphine test system is a device intended to measure morphine, an addictive narcotic pain-relieving drug, and its analogs in serum, urine, and gastric contents. Measurements obtained by this device are used in the diagnosis and treatment of morphine use or overdose and in monitoring levels of morphine and its analogs to ensure appropriate therapy.
Special Controls
*Classification.* Class II (special controls). A morphine 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).
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K990409
## 510(k) Summary
100 - 100
| Introduction | According to the requirements of 21 CFR 807.92, the following information<br>provides sufficient detail to understand the basis for a determination of<br>substantial equivalence. | | |
|-------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--|--|
| 1) Submitter<br>name, address,<br>contact | Roche Diagnostics Corporation<br>9115 Hague Rd.<br>Indianapolis, IN 46250<br>(317) 845-2000 | | |
| | Contact Person: Jennifer Tribbett | | |
| | Date Prepared: March 22,1999 | | |
#### 2) Device name
ー】
| Product Name | Classification Name | Class | CFR<br>Classification |
|------------------------|----------------------|-------|-----------------------|
| OnTrak TesTcup®<br>M2K | Morphine test system | II | 862.3640 |
! ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------
:
and the comments of the comments of
:
#### We claim substantial equivalence to the currently marketed Roche 3) Predicate device Diagnostics OnTrak TesTcup (K962411).
. . . . i
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### 510(k) Summary, Continued
| 4) Device<br>Description | The OnTrak TesTcup M2K is an in vitro test intended for professional use in<br>the qualitative detection of d,l-amphetamines (1000ng/mL), cocaine<br>metabolite (300 ng/mL), THC (50 ng/mL) and morphine (2000 ng/mL). |
|----------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | The TesTcup assays are based on the principle of microparticle capture<br>inhibition. The test relies on the competition between drug, which may be<br>present in the urine being tested, and drug conjugate immobilized on a<br>membrane in the test chamber. |
| | Urine is collected directly in the OnTrak TesTcup M2K. After closing the<br>cap and moving it to the "TEST" position, the sample reservoir is filled by<br>tilting the cup. Urine then flows through a membrane by capillary action and<br>reacts with antibody-coated microparticles and drug conjugate present on the<br>membrane. In the absence of drug, the antibody is free to interact with the<br>drug conjugate, causing the formation of a blue band ("negative" sign). |
| | When drug is present in the specimen, it binds to the antibody-coated<br>microparticles. If sufficient drug is present, the microparticles are inhibited<br>from binding the drug conjugate, and no blue band is formed. A positive<br>sample causes the membrane to remain white ("positive" sign). |
| | An additional antibody/antigen reaction occurs at the "TEST VALID" area<br>for all assays. The "TEST VALID" blue band forms when antibodies, which<br>are imbedded in the membrane, interact with, and bind to, the antigen on the<br>blue-dyed microparticles. |
| 5. Technology<br>Characteristics | Table 1 shown on the next pages outlines the technological characteristics<br>(methodologies) of the OnTrak TesTcup M2K in comparison to the predicate<br>device, OnTrak TesTcup. |
| 6. Substantial<br>Equivalence | Table 1 also provides the results of clinical and non-clinical studies<br>performed using the OnTrak TesTcup M2K. The significant performance<br>characteristics relied upon for a determination of substantial equivalence is<br>summarized in this chart. This information concludes that the performance of<br>the OnTrak TesTcup M2K device is substantially equivalent to the predicate<br>device. |
.
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# 510(k) Summary, Continued
## Table 1
| Item | OnTrak TesTcup M2K for Morphine 2000 | OnTrak TesTcup |
|--------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Methodology | Competitive microparticle capture inhibition | Same |
| Measurement | Qualitative | Same |
| Sample Type | Urine | Same |
| Endpoint read | Color | Same |
| Morphine Cutoff | 2000 ng/mL | 300 ng/mL |
| Reagent (active ingredients) | • Azo-blue dyed microparticles coated with mouse monoclonal anti-morphine antibody<br>• Drug conjugates immobilized on a membrane<br>• Mouse monoclonal anti-BSA antibody immobilized on membrane | Same |
| Controls | OnTrak TesTcup Positive and Negative Controls | Same |
| Performance: Precision | >95% confidence at 150% cutoff<br>When one hundred (100) replicates of urine standards containing different concentrations of drug were tested with OnTrak TesTcup, the following results were found: | >95% confidence at 150% cutoff |
| | Standard (ng/mL) | Morphine 2000 Assay |
| | | = + |
| | 0 | 100 0 |
| | 500 | 100 0 |
| | 1000 | 98 2 |
| | 1500 | 60 40 |
| | 2500 | 0 100 |
| | 3000 | 0 100 |
| Item | OnTrak TesTcup M2K for<br>Morphine 2000 | OnTrak TesTcup |
| Morphine<br>Performance:<br>Accuracy | OnTrak TesTcup M2K was<br>evaluated using specimens screened<br>by an automated immunoassay and<br>confirmed positive by GC/MS at<br>2000 ng/mL cutoff. All fifty (50)<br>samples positive for morphine were<br>positive by OnTrak TesTcup M2K<br>(100%). | OnTrak TesTcup was evaluated<br>using specimens screened by<br>an automated immunoassay<br>and confirmed positive by<br>GC/MS at the 300 ng/mL<br>cutoff. All ninety (90) samples<br>positive for morphine were<br>positive by OnTrak TesTcup<br>(100%). |
| | One hundred (100) urine samples,<br>obtained from a clinical laboratory<br>and screened negative by an<br>automated immunoassay relative to<br>a 2000 ng/mL cutoff for morphine<br>were evaluated using OnTrak<br>TesTcup M2K. All one hundred<br>were negative for morphine by<br>OnTrak TesTcup M2K (100%). | Three hundred seven (307)<br>urine samples, obtained from a<br>clinical laboratory and screened<br>negative by an automated<br>immunoassay relative to a 300<br>ng/mL cutoff for morphine<br>were evaluated using OnTrak<br>TesTcup. Three hundred five<br>were negative for morphine by<br>OnTrak TesTcup (>99%). |
| | All positive and negative samples<br>were also assayed by, and compared<br>to, Abuscreen OnLine II for Opiates<br>2000. One hundred fifty (150)<br>samples tested by both OnTrak<br>TesTcup M2K and Abuscreen<br>OnLine II for Opiates 2000<br>demonstrated 99.3% agreement. | All positive and negative<br>samples were also assayed by,<br>and compared to, Abuscreen<br>OnTrak for Morphine. Three<br>hundred ninety seven (397)<br>samples tested by both OnTrak<br>TesTcup and Abuscreen<br>OnTrak for Morphine<br>demonstrated 99.8%<br>agreement. |
: ・
. .
{3}------------------------------------------------
## 510(k) Summary, Continued
## TABLE 1 -Continued-
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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Image /page/4/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with three lines representing its body and wings. The eagle is enclosed in a circle, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is written around the circle.
Public Health Service
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
APR 1 5 1999
Jennifer L. Tribbett Regulatory Affairs Specialist Roche Diagnostics Corporation 9115 Hague Road Indianapolis, IN 46250-0457
K990409 Re: Trade Name: OnTrak TesTstik M2K Regulatory Class: II Product Code: DJJ, DMY Dated: January 25, 1999 Received: February 9, 1999
Dear Ms. Tribbett:
We have reviewed your Section 510(k) notification of intent to market the device referenced above and we have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (Premarket Approval), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the Current Good Manufacturing Practice requirements, as set forth in the Quality System Regulation (OS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic QS inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory action. In addition, FDA may publish further announcements concerning your device in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.
{5}------------------------------------------------
Page 2
Under the Clinical Laboratory Improvement Amendments of 1988 (CLIA-88), this device may require a CLIA complexity categorization. To determine if it does, you should contact the Centers for Disease Control and Prevention (CDC) at (770)488-7655.
This letter will allow you to begin marketing your device as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diagnostic devices), please contact the Office of Compliance at (301) 594-4588. Additionally, for questions on the promotion and advertising of your device, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 807.97). Other general information on your responsibilities under the Act may be obtained from the Division of Small Manufacturers Assistance at its toll free number (800) 638-2041 or at (301) 443-6597 or at its internet address "http://www.fda.gov/cdrh/dsmamain.html"
Sincerely yours,
Steven Autman
Steven I. Gutman, M.D., M.B.A. Director Division of Clinical Laboratory Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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510(k) Number (if known): Device Name: Roche Diagnostics Corporation, OnTrak TesTstik™ for Morphine 2000 (M2K)
Indications for Use:
The Roche Diagnostics Corporation OnTrak TesTstik™ for Morphine 2000 (M2K) is an in vitro t st intended for professional use for the qualitative detection of morphine in urine at or above a cutoff concentration of 2000 ng/mL
OnTrak TesTstik provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result.
Jean Cooper
(Division Sign-Off)
Division of Clinical Laboratory Devices
510(k) Number K990469
Concurrence of CDRH, Office of Device Evaluation (ODE)
Prescription Use (Per 21 CFR 801.109)
OR
Over-The-Counter Use -------
(Optional Format 1-2-96)
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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.
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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.
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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
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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.
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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.
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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.
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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.