(84 days)
The Amedica Drug Screen THC/COC, OPI300, PPX, OXY, BAR/BZO Test is an in vitro diagnostic test for the rapid detection of THC, benzoylecgonine, morphine, oxycodone, secobarbital and oxazepam in human urine at the following cut-off concentration
| THC | 11-nor-Δ⁹-THC-9-COOH | 50 ng/ml |
|---|---|---|
| COC | benzoylecgonine | 300 ng/ml |
| OPI | morphine | 300 ng/ml |
| PPY | propoxyphene | 300 ng/ml |
| OXY | oxycodone | 100 ng/ml |
| BAR | secobarbital | 300 ng/ml |
| BZO | oxazepam | 300 ng/ml |
| This test kit is used to obtain a visual, qualitative result and is intended for use in laboratories and workplaces by trained users. It is not intended for over the counter sale. For in vitro diagnostic use |
Not Found
The provided 510(k) clearance letter and its associated documents (pages 1-3) offer limited information regarding the specific acceptance criteria and detailed study data typically found in a comprehensive medical device submission. This submission appears to be for an in-vitro diagnostic (IVD) drug screen test, which often relies on analytical performance rather than clinical efficacy studies with human readers.
Based on the available text, here's what can be inferred and what information is missing:
1. A table of acceptance criteria and the reported device performance
The document specifies "cut-off concentrations" for each drug, which serve as a critical component of the acceptance criteria for a qualitative drug test. The device's performance would be measured against these cut-offs, typically in terms of accuracy (e.g., sensitivity and specificity) at or around these concentrations. However, the reported device performance values (e.g., sensitivity, specificity, accuracy) are not included in the provided text.
| Drug | Analyte | Cut-off Concentration (Acceptance Criteria) | Reported Device Performance (e.g., Sensitivity, Specificity, Accuracy at cut-off) |
|---|---|---|---|
| THC | 11-nor-Δ⁹-THC-9-COOH | 50 ng/ml | Not provided in the document |
| COC | benzoylecgonine | 300 ng/ml | Not provided in the document |
| OPI | morphine | 300 ng/ml | Not provided in the document |
| PPY | propoxyphene | 300 ng/ml | Not provided in the document |
| OXY | oxycodone | 100 ng/ml | Not provided in the document |
| BAR | secobarbital | 300 ng/ml | Not provided in the document |
| BZO | oxazepam | 300 ng/ml | Not provided in the document |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not provided in the document. For an IVD, a test set would typically involve a specific number of both negative and positive urine samples (spiked or clinical) tested against the device. The data provenance would detail if the samples were collected retrospectively or prospectively, and their origin.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
This information is not provided and is generally not applicable in the same way it would be for an imaging AI device. For an IVD like a drug screen, the "ground truth" for the test set is established through a definitive analytical method, not human expert consensus.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This information is not provided. Adjudication methods are typically used when there is disagreement among human readers or when a definitive ground truth is difficult to establish through a single method. For a drug test, the ground truth is established by a confirmatory analytical method, so an adjudication method among experts is not relevant.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This information is not provided and is not applicable for this type of IVD device. MRMC studies are relevant for imaging or diagnostic devices where human interpretation is a key component and AI provides assistance. This device is a standalone qualitative drug screen. While "trained users" are mentioned, the device itself is not an AI or an assistance tool for human interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Yes, this device is a standalone qualitative drug screen. The "algorithm" here refers to the biochemical reactions and visual readout mechanism of the test itself, not a digital algorithm in the context of AI. The performance evaluation would have been done to assess the accuracy of the test in detecting the target analytes at or above the specified cut-off concentrations, without human intervention in the result determination beyond visual interpretation of the test line. The document does state: "This assay provides only a preliminary result... To obtain a confirmed analytical result, a more specific alternate chemical method is needed. Gas chromatography/mass spectroscopy (GC/MS) is the recommended confirmatory method." This clearly indicates the device's standalone role in providing an initial, qualitative result.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
The type of ground truth for an IVD drug screen is typically established by:
- Confirmatory Analytical Methods: Specifically, the document mentions Gas Chromatography/Mass Spectroscopy (GC/MS) as the recommended confirmatory method for obtaining a confirmed analytical result. This is the gold standard for drug detection and quantification in urine.
- Known Concentration Samples: Testing would also involve "spiked" urine samples where known concentrations of the drugs are added, allowing for precise determination of the device's accuracy at different concentrations, especially around the cut-off.
8. The sample size for the training set
This information is not provided. For an IVD of this nature, there isn't a "training set" in the machine learning sense. Instead, the device's design and manufacturing process would be refined based on extensive R&D and internal testing to optimize its performance characteristics (e.g., sensitivity, specificity, stability, reproducibility) before validation studies.
9. How the ground truth for the training set was established
As there isn't a "training set" in the AI sense, this question is not applicable. The underlying chemical principles and immunoassay design are "trained" through biochemical research and optimization, with performance verified against known concentrations of analytes and confirmed by methods like GC/MS during development.
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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized caduceus, which is a symbol of medicine, with three horizontal lines representing the branches of government. The logo is surrounded by a circular border with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" written around it.
Food and Drug Administration 2098 Gaither Road Rockville MD 20850
MAY 1 7 2004
Mr. Jeff Chen President Amedica Biotech, Inc. 28301 Industrial Blvd, Suite K Hayward, CA 94545
K040464 Re:
K040-01-12-2014 Name: Amedica Drug Screen THC/COC, OP1300, PPX, OXY, BAR/BZO Test
Regulation Number: 21 CFR 862.3870 Regulation Name: Cannabinoid test system Regulatory Class: Class II Product Code: LDJ, DIO, DJG, JXN, DIS, JXM Dated: February 12, 2004 Received: February 23, 2004
Dear Mr. Chen:
We have reviewed your Section 510(k) premarket notification of intent to market the device we nave reviewed your betermined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate for use stated in the encreated 776, the enactment date of the Medical Device Amendments, or to conniered processified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). and Connetter for ( roy ) . roy ( reserve subject to the general controls provisions of the Act. The I ou mayy atests 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 (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895. In addition, FDA ean be found further announcements concerning your device in the Federal Register.
Please be advised that I·DA's issuance of a substantial equivalence determination does not mean r touse to actived a determination that your device complies with other requirements of the Act that 1171 has matures and regulations administered by other Federal agencies. You must or any I vatuall the Act's requirements, including, but not limited to: registration and listing (21 CHR Part 807); labeling (21 CFR Parts 801 and 809); and good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820).
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Page 2
This letter will allow you to begin marketing your device as described in your Section 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 information about the application of labeling requirements to your device, or questions on the promotion and advertising of your device, please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 594-3084. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http://www.fda.gov/cdrh/dsma/dsmamain.html.
Sincerely yours,
Seain M. Cooper, US, DVM.
Jean M. Cooper, MS, D.V.M. Director Division of Chemistry and Toxicology Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known): K040464
Device Name: Amedica Drug Screen THC/COC, OP1300, PPX, OXY, BAR/BZO Test
Indications For Use:
The Amedica Drug Screen THC/COC, OPI300, PPX, OXY, BAR/BZO Test is an in vitro diagnostic test for the rapid detection of THC, benzoylecgonine, morphine, oxycodone, secobarbital and oxazepam in human urine at the following cut-off concentration
| THC | 11-nor-Δ⁹-THC-9-COOH | 50 ng/ml |
|---|---|---|
| COC | benzoylecgonine | 300 ng/ml |
| OPI | morphine | 300 ng/ml |
| PPY | propoxyphene | 300 ng/ml |
| OXY | oxycodone | 100 ng/ml |
| BAR | secobarbital | 300 ng/ml |
| BZO | oxazepam | 300 ng/ml |
This test kit is used to obtain a visual, qualitative result and is intended for use in laboratories and workplaces by trained users. It is not intended for over the counter sale. For in vitro diagnostic use
Minimum training for operators is defined as those individuals who have received instructions for drugs of abuse testing from a physician or medical review officer. Operators may be lay users with no prior experience in running laboratory tests, but who are expected to perform at least 5 tests per week. Training should cover a variety of topics such as the value of confirmation testing, how to obtain confirmation testing, false positive results, false negative results, and quality control procedures. We recommend that operators take a written and practical exam before performing any testing and that employers keep documentation of the training.
This assay provides only a preliminary result. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly in evaluating a preliminary positive result. To obtain a confirmed analytical result, a more specific alternate chemical method is needed Gas chromatography/mass spectroscopy (GC/MS) is the recommended confirmatory method.
Prescription Use V (Part 21 CFR 801 Subpart D) AND/OR
Over-The-Counter Use (21 CFR 807 Subpart C)
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| NEEDED) | |
| can cooper | |
| Division Sign-Off |
Office of In Vitro Diagnostic Device Evaluation and of CDRH, Office of In Vitro Diagnostic Devices (OIVD)
510(k) K040464
Page 1 of _ l
§ 862.3870 Cannabinoid test system.
(a)
Identification. A cannabinoid test system is a device intended to measure any of the cannabinoids, hallucinogenic compounds endogenous to marihuana, in serum, plasma, saliva, and urine. Cannabinoid compounds includedelta -9-tetrahydrocannabinol, cannabidiol, cannabinol, and cannabichromene. Measurements obtained by this device are used in the diagnosis and treatment of cannabinoid use or abuse and in monitoring levels of cannabinoids during clinical investigational use.(b)
Classification. Class II (special controls). A cannabinoid 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).