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510(k) Data Aggregation

    K Number
    K181790

    Validate with FDA (Live)

    Date Cleared
    2018-07-26

    (21 days)

    Product Code
    Regulation Number
    862.3650
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    CLUNGENE® Multi-Drug Test Dip Card is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Ampletamine, Oxazepam, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

    Drug(Identifier)CalibratorCut-off level
    Amphetamined-Amphetamine1000 ng/mL
    OxazepamOxazepam300 ng/mL
    CocaineBenzoylecgonine300 ng/mL
    Marijuana11-Nor-△9-Tetrahydrocannabinol-9-COOH50 ng/mL
    Methamphetamined-Methamphetamine1000 ng/mL
    MorphineMorphine300 ng/mL
    OxycodoneOxycodone100 ng/mL
    SecobarbitalSecobarbital300 ng/mL
    MethadoneMethadone300 ng/mL
    BuprenorphineBuprenorphine10 ng/mL
    MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
    PhencyclidinePhencyclidine25 ng/mL
    Tricyclic AntidepressantsNortriptyline1000 ng/mL

    Configuration of the CLUNGENE® Multi-Drug Test Dip Card can consist of any combination of the above listed drug analytes.

    The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GCMS or LC/MS is the preferred confirmatory method.

    For in vitro diagnostic use only.

    CLUNGENE® Multi-Drug Test Easy Cup is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Amphetamine, Oxazepam, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

    Drug(Identifier)CalibratorCut-off level
    Amphetamined-Amphetamine1000 ng/mL
    OxazepamOxazepam300 ng/mL
    CocaineBenzoylecgonine300 ng/mL
    Marijuana11-Nor-△9-Tetrahydrocannabinol-9-COOH50 ng/mL
    Methamphetamined-Methamphetamine1000 ng/mL
    MorphineMorphine300 ng/mL
    OxycodoneOxycodone100 ng/mL
    SecobarbitalSecobarbital300 ng/mL
    MethadoneMethadone300 ng/mL
    BuprenorphineBuprenorphine10 ng/mL
    MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
    PhencyclidinePhencyclidine25 ng/mL
    Tricyclic AntidepressantsNortriptyline1000 ng/mL

    Configuration of the CLUNGENE® Multi-Drug Test Easy Cup can consist of any combination of the above listed drug analytes.

    The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GCMS or LC/MS is the preferred confirmatory method.

    For in vitro diagnostic use only.

    Device Description

    The CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants (target analytes) in human urine. The products are single-use in vitro diagnostic devices. The CLUNGENE Multi-Drug Test Dip Card kit contains a Dip Card device, a package insert and a urine cup for sample collection. The CLUNGENE Multi-Drug Test Easy Cup kit contains a Cup device, a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.

    AI/ML Overview

    This document describes the validation study for the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup, which are in vitro diagnostic devices for the qualitative detection of various drugs in human urine.

    Acceptance Criteria and Reported Device Performance

    The acceptance criteria are implied by the precision studies and the comparison studies. For the precision studies, the acceptance criterion is that samples significantly below the cutoff should test negative, samples significantly above the cutoff should test positive, and samples very close to the cutoff (e.g., +/- 25% of the cutoff) should show a mix of positive and negative results, reflecting the inherent variability at the decision point. For the comparison studies and lay-user studies, the implicit acceptance criterion is a high percentage of agreement with the reference method (LC/MS) or expected results, especially for samples far from the cutoff.

    Here is a summary table, focusing on the precision study and lay-user study data as they most directly reflect performance against concentration levels:

    Table of Acceptance Criteria and Reported Device Performance

    Assay/DrugAcceptance Criteria (Implicit)Reported Device Performance (CLUNGENE Multi-Drug Test Dip Card & Easy Cup combined data where available)
    Precision StudySee detailed tables in original document for each drug and lot.
    All Drugs at -100% to -50% Cut-off (Precision)All or nearly all samples should test Negative.Observed: 50-/0+ for all concentrations from -100% to -50% cutoff across all lots and drugs (Buprenorphine, Methylenedioxymethamphetamine, Phencyclidine, Nortriptyline). This indicates 100% negative results.
    All Drugs at +50% to +100% Cut-off (Precision)All or nearly all samples should test Positive.Observed: 50+/0- for all concentrations from +50% to +100% cutoff across all lots and drugs. This indicates 100% positive results.
    All Drugs at Cut-off (Precision)Results should show a mix of Positive and Negative, demonstrating performance at the cutoff. (e.g., ~50% P / ~50% N)Observed: Mixed results at cutoff (e.g., Buprenorphine Dip Card: Lot 1: 24-/26+, Lot 2: 25-/25+, Lot 3: 28-/22+). Similar mixed results for other drugs/lots, demonstrating expected performance at cutoff.
    Lay-User StudySee detailed tables in original document for each drug and concentration.
    All Drugs at -100% to -50% Cut-off (Lay-user)All or nearly all samples should test Negative (e.g., ≥95% correct).Observed: 100% correct negative results for all drugs from -100% to -50% cutoff across both Dip Card and Easy Cup.
    All Drugs at +50% to +75% Cut-off (Lay-user)All or nearly all samples should test Positive (e.g., ≥95% correct).Observed: 100% correct positive results for all drugs from +50% to +75% cutoff across both Dip Card and Easy Cup.
    All Drugs at -25% Cut-off (Lay-user)A high percentage of correct negative results (e.g., ≥90% correct is implied by the results).Observed: Ranged from 90% to 100% correct negative results. Some drugs (e.g., AMP, COC, MET, MOP, OXY, TCA for Dip Card, or AMP, MET, BZO for Easy Cup) showed 95% or 90% correct.
    All Drugs at +25% Cut-off (Lay-user)A high percentage of correct positive results (e.g., ≥90% correct is implied by the results).Observed: Ranged from 90% to 100% correct positive results. Some drugs (e.g., BAR, MTD, THC, for Dip Card, or AMP, BAR, TCA, MDMA for Easy Cup) showed 90% or 95% correct.
    Overall Lay-User Ease of UseAll lay users should indicate instructions are easily followed.All lay users indicated the device instructions can be easily followed. Flesch-Kincaid Grade Level was 7.

    The study performed to prove the device meets acceptance criteria involved several components:

    1. Sample Sizes and Data Provenance:

    • Test Set (Analytical Performance - Precision): For precision studies, for each drug and each concentration (-100% to +100% cut-off), 50 individual tests were performed across two runs per day for 25 days, for a total of 50 tests per concentration level per drug for each device type (Dip Card and Easy Cup). This was repeated for three different manufacturing lots.
    • Test Set (Comparison Studies): 80 unaltered clinical samples (40 negative and 40 positive) were used for each drug. Data provenance is "in-house" suggesting the tests were conducted at the manufacturer's facility. The samples were "clinical samples," implying human origin, but specific country of origin or whether they were retrospectively collected or prospectively collected is not explicitly stated. They were "unaltered."
    • Test Set (Lay-User Study): 300 lay persons were involved for each device format (Dip Card and Easy Cup). Urine samples prepared at various concentrations (-100%, -75%, -50%, -25%, +25%, +50%, +75% of cutoff) by spiking drugs into drug-free pooled urine specimens. The distribution of samples given to each participant is not explicitly detailed beyond "1 blind labeled sample and a device." The total number of individual tests performed in the lay-user study appears to be substantial given the breakdown of samples across concentrations for each drug and the 300 participants.
    • Data Provenance (General): While "in-house" is mentioned for comparison studies, specific origin countries or retrospective/prospective nature of the broader data (e.g., interference, specificity) are not explicitly stated, although given the manufacturer is based in China, it is likely data collection occurred there.

    2. Number of Experts and Qualifications for Ground Truth - Test Set:

    • Experts: For the analytical (precision) and comparison studies, the ground truth for drug concentrations was established by LC/MS (Liquid Chromatography-Mass Spectrometry). This is a highly sensitive and specific analytical chemistry method considered to be the "gold standard" for confirming drug concentrations in biological samples. Therefore, the "experts" in this context are the analytical chemists and laboratory personnel who performed and interpreted the LC/MS results. Their specific qualifications (e.g., number of years' experience, specific certifications) are not detailed in this document, but LC/MS analysis requires specialized training and expertise.
    • For the lay-user study, the ground truth for the spiked samples was also established by LC/MS.

    3. Adjudication Method for the Test Set:

    • For the analytical (precision) studies, the samples were "blindly labeled by the person who prepared the samples and didn't take part in the sample testing." This indicates blinding, but no formal adjudication method (like 2+1 or 3+1 consensus) among different readers of the device results is mentioned, as the device results are qualitative (positive/negative) and read directly. The consistency across multiple lots and runs serves as a robustness check.
    • For the comparison studies, "three laboratory assistants" for each device ran the samples. Their individual results are reported in detail, showing where discrepancies from the LC/MS ground truth occurred for each viewer and sample. There is no explicit mention of an adjudication process among these three laboratory assistants for their readings of the device results; their individual performance is reported.
    • For the lay-user study, each of the 300 participants read their own single device. There was no reader adjudication among the lay users for their interpretation of the device results.

    4. MRMC Comparative Effectiveness Study:

    • No Multi-Reader Multi-Case (MRMC) comparative effectiveness study was explicitly done in the typical sense of human readers with and without AI assistance. This device is a rapid, lateral flow immunochromatographic assay, not an AI-powered diagnostic imaging or algorithm. The "human readers" (laboratory assistants and lay users) are interpreting the visual lines on the test card/cup directly, not using "AI assistance."
    • Therefore, the concept of "effect size of how much human readers improve with AI vs without AI assistance" is not applicable to this type of device and study.

    5. Standalone Performance:

    • Yes, a standalone performance study was done for the device itself. The precision studies directly evaluate the device's ability to correctly classify samples based on their concentration relative to the cutoff, independent of human interpretation variability (as the readings are a simple visual presence/absence of a line). The comparison studies similarly assess the device's performance against the gold standard (LC/MS) when read by trained laboratory professionals.

    6. Type of Ground Truth Used:

    • The primary ground truth used for both analytical performance (precision, interference, specificity) and comparison studies was LC/MS (Liquid Chromatography-Mass Spectrometry). This is an objective chemical method that provides precise quantitative measurements of drug concentrations, which are then used to define positive or negative status relative to the established cutoff concentrations.
    • For the lay-user study, the ground truth for the spiked samples was also confirmed by LC/MS.

    7. Sample Size for the Training Set:

    • This information is not provided in the document. As this is a rapid in vitro diagnostic device (immunochromatographic assay) and not an AI/machine learning algorithm, there isn't a "training set" in the computational sense. The device's performance relies on its biochemical design and manufacturing consistency rather than a trained model.

    8. How Ground Truth for Training Set was Established:

    • As there is no "training set" for an AI model, this question is not applicable in the context of this device. The development of such devices typically involves extensive R&D, antibody selection, and optimization of chemical components, rather than data-driven training with a ground truth dataset in the way an AI algorithm would be.
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