(59 days)
The Chemtron Biotech, Inc.'s Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are rapid lateral flow immunoassays for the qualitative detection of up to six of the following drugs in a variety of combinations in human urine. The designated cutoff concentrations of each drug and the calibrators used for these drugs are as follows:
Analyte Abbreviation Calibrator Cutoff Concentration
Benzodiazepines BZO Oxazepam 300 ng/mL
Barbiturates BAR Secobarbital/Pentobarbital 300 ng/mL
Ecstasy MDMA/XTC d,l-Methylenedioxymethamphetamine 500 ng/mL
Methadone MTD Methadone 300 ng/mL
Opiates OPI/MOR Morphine 2000 ng/mL
Oxycodone OXY Oxycodone 100 ng/mL
The Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are intended for the qualitative detection of drugs of abuse for health care professionals, in vitro diagnostic and Over-The-Counter (OTC) use.
The BAR.BZO and OXY assay will yield preliminary positive results when BAR, BZO, and OXY is ingested at or above therapeutic doses. There are no uniformly recognized drug levels for Barbiturate, Benzodiazepine and Oxycodone in urine. The Chemtrue® Single/Multi-Panel Drug Screen Cassette and Div Card Tests shows the drug was or was not present at the cutoff level. This assay provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result. Gas chromatography/mass spectrometry (GC/MS) is the preferred confirmatory method for most drugs (HPLC is the preferred confirmatory method for tri-cyclic antidepressants). Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.
The Drugs of Abuse (DOA) Screen Panels are one-step lateral flow immunoassays in which chemically labeled drugs (drug-protein conjugates) compete for limited antibody binding sites with drugs that may be present in urine. The test device consists of up to six test strips placed in separate panels of a plastic holder. On each test strip, a drug-protein conjugate is striped on the test band of the membrane - known as the test region (T) and the drug antibody-colloidal gold conjugate pads are placed at one end of the membrane (opposite in morphine). In the absence of drugs in the urine, the solution of the colored antibody-colloidal gold conjugates move along with the sample solution upward chromatographically by capillary action across the membrane to the immobilized drug-protein conjugate zones on the test band region. The colored antibody-gold conjugates then complexes with the drug-protein conjugates to form visible lines. Therefore, the formation of the visible precipitant in the test band occurs when the test urine is negative for the drug. If any drug is present in the urine, the drug/metabolite antigen competes with the drugprotein conjugates on the test band region for the limited antibody on the colored drug antibodycolloidal gold conjugate pad. When a sufficient amount of drug is present in the urine, the drug will saturate the limited antibody binding sites and the colored antibody-colloidal gold conjugate cannot bind to the drug-protein conjugate at the test strip. Therefore, absence of the color band on the test region indicates a preliminary positive result.
A control band with a different antigen/antibody reaction is added to the membrane strip at the control region (C) to indicate that the test has performed properly. This control line is manufactured as a built-in internal control of the test device and should always appear regardless of the presence of drug or metabolite. If the control line does not appear the test cassette should be discarded. The presence of this colored band in the control region also serves 1) as verification that adequate specimen volume is added (flooding, if too much urine is added, or no flow, due to insufficient urine volume), 2) the test device is properly functioning, and 3) as reagent control.
The acceptance criteria for the Chemtrue® Single/Multi-Panel Drug Screen Dip Card / Cassette Tests are implicitly defined by the reported agreement with GC/MS values in the OTC accuracy study, with a target of "greater than 97.8% accuracy" for lay users and "≥97.8% agreement" with GC/MS. The study demonstrates that lay users can perform and interpret the results correctly with the specified accuracy, and that the device's performance is substantially equivalent to the GC/MS reference method.
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
| Drug Analyte | Acceptance Criteria (Agreement with GC/MS - Implied) | Reported Performance (Dip Card - Overall Agreement) | Reported Performance (Cassette - Overall Agreement) |
|---|---|---|---|
| Barbiturates (BAR) | ≥ 97.8% | 98.9% | 100% |
| Benzodiazepines (BZO) | ≥ 97.8% | 100% | 100% |
| Ecstasy (MDMA) | ≥ 97.8% | 100% | 100% |
| Methadone (MTD) | ≥ 97.8% | 97.8% | 97.8% |
| Opiates (OPI 2000) | ≥ 97.8% | 100% | 100% |
| Oxycodone (OXY) | ≥ 97.8% | 97.8% | 98.9% |
| Overall for lay-users | > 97.8% accurate | > 97.8% accurate | > 97.8% accurate |
2. Sample Size Used for the Test Set and Data Provenance
- Sample Size for Test Set: The study involved a total of 200 OTC lay-users. 100 lay-users tested the Dip Card format, and 100 lay-users tested the Cassette format. Within each format, the results table shows varying numbers of samples tested for each drug, typically with 30 samples in each category (e.g., "no drug present," "GC/MS Negative," "Near cutoff negative," etc.), suggesting at least ~90 positive and ~90 negative samples per drug per format for GC/MS comparison, plus samples in the near-cutoff ranges. The exact total number of unique urine samples is not explicitly stated but implies a substantial number.
- Data Provenance: The data was generated from "three (3) independent sites" through an "OTC accuracy study." The nationality of the participants is not explicitly stated but, given the FDA submission, it can be inferred to be from the United States. The study appears to be prospective as it involved selecting and having lay-users perform tests.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- The ground truth for the test set was established using Gas Chromatography / Mass Spectrometry (GC/MS), which is referred to as "the preferred confirmatory method."
- There were no human experts explicitly described as establishing the ground truth for the test results themselves. The "experts" in this context would be the technicians or laboratory personnel operating and interpreting the GC/MS results, whose qualifications are not specified but are implicitly assumed to be trained professionals for performing such confirmatory chemical analyses.
4. Adjudication Method for the Test Set
- No explicit adjudication method (e.g., 2+1, 3+1) for the interpretation of the test device was used in the lay-user study. The lay-users themselves interpreted the results, and their interpretation was compared against the GC/MS ground truth.
- Discordant results were identified and reported with their GC/MS values, but no process of expert re-adjudication of the test device result itself is described. The agreement percentage directly reflects the lay-user interpretation versus GC/MS.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
- No MRMC comparative effectiveness study was done to compare human readers with AI assistance versus without AI assistance. This device is a rapid diagnostic test with a visual interpretation by the user (lay-user in this case), not an AI-powered diagnostic system that assists human readers.
6. Standalone Performance Study
- Yes, a standalone study was done, specifically the "OTC accuracy study." This study evaluated the performance of the algorithm (i.e., the rapid immunoassay device) when interpreted by a human (lay-users) without any additional human-in-the-loop assistance beyond the instructions provided. The device's performance was compared directly to objective GC/MS results. The results presented in Tables 1 and 2 show the direct agreement rates of the device's output (interpreted by lay-users) with the GC/MS reference.
7. Type of Ground Truth Used
- The type of ground truth used was chemical confirmatory method: Gas Chromatography / Mass Spectrometry (GC/MS). For tri-cyclic antidepressants, HPLC is mentioned as the preferred method, but the drugs in this submission primarily relied on GC/MS.
8. Sample Size for the Training Set
- The document does not explicitly state a sample size for a training set. This device is a rapid immunoassay, which does not typically involve a "training" phase in the same way machine learning or AI models do. The device's formulation and design are developed, and then its performance is validated through studies like the one described. The "Analytical sensitivity (Cut-off characteristics), precision (reproducibility), Accuracy (Method comparison study with clinical samples), specificity and stability study data were established in K111322," which was the predicate device. These earlier studies would have involved samples for the initial characterization and validation but are not detailed here as a "training set."
9. How the Ground Truth for the Training Set Was Established
- As there's no explicitly defined "training set" for an AI or machine learning algorithm, this question isn't directly applicable in the context of this immunoassay device. The ground truth for the development and validation of the immunoassay (e.g., for setting cut-off concentrations, verifying specificity) would have been established through controlled studies using spiked samples and clinical samples, with reference methods such as GC/MS. The document refers to "Performance Data" and states that "Analytical sensitivity (Cut-off characteristics), precision (reproducibility), Accuracy (Method comparison study with clinical samples), specificity and stability study data were established in K111322" (the predicate device's submission), implying that these data, likely using GC/MS or similar reference methods, formed the basis for establishing the device's characteristics.
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510(k) Summary
NOV 2 9 2012
AS REQUIRED BY 21 CFR 807.92(c)
The Assigned 510(k) number is K123080
Date of Summary: September 28th, 2012
Common Name: Drugs of Abuse Screening Tests
Classification Name: Immunoassay for the detection of drugs of abuse
Trade/Proprietary Name:
Chemtron Biotech, Inc.'s Chemtrue® Single / Multi-Panel Drug Screen Dip Card / Cassette Tests, contain 1 to 6 of the following DOA test(s) in each device:
-
- Benzodiazepines (BZO) test strip
-
- Barbiturates (BAR) test strip
-
- Ecstasy (MDMA/XTC) test strip
-
- Methadone (MTD) test strip
- Opiates /Morphine (OPI/MOR/MOP) cut-off: 2000ng/mL test strip 5.
-
- Oxycodone (OXY) test strip
Owner:
Ellen Meng . President, Chemtron Biotech, Inc. 8370 Juniper Creek Lane, #1-2 San Diego. CA 92126 TEL: (858) 530-2868 FAX: (858) 530-2878
Contact Person:
Jane Zhang, Director of QA/RA Official FDA Correspondent 8370 Juniper Creek Lane, #1-2 San Diego, CA 92126 Office: (858) 530-2868 Mobile: (858) 997-7472 FAX: (858) 530-2878
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Substantial Equivalency
The Chemtrue® Single/Multi-Panel Drug Screen Test is substantially equivalent to other tests currently on the market.
Predicate Device Name
Predicate Device 510(k)#
Chemtrue® Single/Multi-Panel Drug Screen Dip Card/Cassette Tests K11322
Intended Use
The Chemtrue® test device is intended for the qualitative detection of drugs of abuse, for Overthe-Counter (OTC) and in vitro diagnostic use.
The assay provides only a preliminary analytical test result. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory methods.
The BAR,BZO and OXY assay will yield preliminary positive results when BAR, BZO, and OXY is ingested at or above therapeutic doses. There are no uniformly recognized drug levels for Barbiturate, Benzodiazepine and Oxycodone in urine. The Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests shows the drug was or was not present at the cutoff level. This assay provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result. Gas chromatography/mass spectrometry (GC/MS) is the preferred confirmatory method for most drugs (HPLC is the preferred confirmatory method for tri-cyclic antidepressants). Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.
Technological Characteristics and Science Principles
The Drugs of Abuse (DOA) Screen Panels are one-step lateral flow immunoassays in which chemically labeled drugs (drug-protein conjugates) compete for limited antibody binding sites with drugs that may be present in urine. The test device consists of up to six test strips placed in separate panels of a plastic holder. On each test strip, a drug-protein conjugate is striped on the test band of the membrane - known as the test region (T) and the drug antibody-colloidal gold conjugate pads are placed at one end of the membrane (opposite in morphine). In the absence of drugs in the urine, the solution of the colored antibody-colloidal gold conjugates move along with the sample solution upward chromatographically by capillary action across the membrane to the immobilized drug-protein conjugate zones on the test band region. The colored antibody-gold conjugates then complexes with the drug-protein conjugates to form visible lines. Therefore, the formation of the visible precipitant in the test band occurs when the test urine is negative for the drug. If any drug is present in the urine, the drug/metabolite antigen competes with the drugprotein conjugates on the test band region for the limited antibody on the colored drug antibodycolloidal gold conjugate pad. When a sufficient amount of drug is present in the urine, the drug will saturate the limited antibody binding sites and the colored antibody-colloidal gold conjugate
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cannot bind to the drug-protein conjugate at the test strip. Therefore, absence of the color band on the test region indicates a preliminary positive result.
A control band with a different antigen/antibody reaction is added to the membrane strip at the control region (C) to indicate that the test has performed properly. This control line is manufactured as a built-in internal control of the test device and should always appear regardless of the presence of drug or metabolite. If the control line does not appear the test cassette should be discarded. The presence of this colored band in the control region also serves 1) as verification that adequate specimen volume is added (flooding, if too much urine is added, or no flow, due to insufficient urine volume), 2) the test device is properly functioning, and 3) as reagent control.
Comparison with Predicate
The Chemtron Biotech, Inc.'s Chemtrue® Single/Multi-panel Drug Screen Cassette and Dip Card tests are similar or the same as the previously cleared predicate(s) in the following ways: test principle, indication for used in a professional, point-of-care setting, OTC use, read time and sample matrix. The candidate device and the predicates are both visually-read single use devices. All of these products are based on the same technological characteristics, scientific principle and similar testing procedures. The similarities and differences between these tests are summarized as follows:
| SIMILARITIES | ||
|---|---|---|
| Item | Chemtrue® Device | Predicate Kit |
| Indications For Use | A rapid qualitative lateral flow immunoassayfor the detection of potential abuse of one ormore drugs | Same |
| Specimen | Urine | Same |
| Technological Characteristics andPrinciple | One-Step lateral flow competitiveImmunoassay | Same |
| Device Design/Performance | Positive result1 colored line | Same |
| Negative result2 colored lines | Same | |
| Detection reagentColloidal gold | Same | |
| Accuracy AssessmentConfirm with GC/MS reference method | Same | |
| Drug Analytes and Cut-off | Benzodiazepines 300 ng/mLBarbiturates 300 ng/mLEcstasy (MDMA) 500 ng/mLMethadone 300 ng/mLOpiates 2000 ng/mLOxycodone 100 ng/mL | Same |
| Safety and Precaution | All urine specimens should be consideredpotentially hazardous and handled in the samemanner as infectious agent. | Same |
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| Read time | 5 minutes | Same | |
|---|---|---|---|
| Storage | $2-30 \degree C (36-86\degree F)$ | Same | |
| DIFFERENCES | |||
| Item | Chemtrue® Device | Predicate Kit | |
| Intended use | For Over-the-Counter (OTC) Use | For Prescription Use Only |
DISCUSSION AND CONCLUSION:
Based on the technological characteristics/principle, features of the device design, test specimen matrix, test method and performance characterizations, as the set forth above, it can be concluded that Chemtrue® Single/ Multi-panel Drug Screen tests are substantially equivalent to the predicate kit and the other like products that are manufactured by Alere and Alfa Scientific Design Inc. presently distributed commercially.
Performance Data:
Chemtron Biotech, Inc. has reviewed the requirements of Section 514 of the Act, which states that to date no performance standards has been established for drug screen test systems by the FDA.
However, the studies listed in the notification were conducted according to "Assessing the Safety and Effectiveness of Home-Use in vitro Diagnostic Devices (IVDs): Draft Points to Consider Regarding Labeling and Premarket Submissions (Text Only). Center for Devices and Radiological Health. October 1988", "The Draft Guidance for Industry and FDA Staff" -" Premarket Submission and Labeling Recommendations for Drugs of Abuse Screening Tests, issued on: December 2, 2003", including the design of draft labeling and package inserts.
Chemtrue® Single / Multi-panel Drug Screen Cassette and Dip Card tests are one-step, lateral flow, colloidal gold based chromatographic immunoassays for the rapid, qualitative detection of Benzodiazepines, Barbiturates, MDMA, Methadone, Opiates (Morphine) 2000 and Oxycodone in human urine. They are intended for Over-the-Counter (OTC) Use.
This assay provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result. Gas chromatography/mass spectrometry (GC/MS) is the preferred confirmatory method for most drugs (HPLC is the preferred confirmatory method for tri-cyclic antidepressants). Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.
Concise Summary of OTC Accuracy Study:
A panel format was evaluated in separate studies at these three (3) sites. A total of 200 OTC layusers from these three separate (3) sites were selected and participated in the study. 100 OTC lay-users tested the Dip Card format and 100 lay-users tested the Cassette format. These lay
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users were between the ages of 21 to 79 with varying education levels. Male and female were in proportion. For details, refer to "Performance Characteristics" section, page 36 of this submiss io n.
| Table 1. OTC accuracy study result summary for the Chemtrue® Dip Card Test | ||||||||
|---|---|---|---|---|---|---|---|---|
| (-) | (+) | |||||||
| Chemtrue® DrugScreen Dip Card Test | Nodrugpresent | GC/MSNegative(-50% to-25% cutoff) | Near cutoffnegative(-25% cutoff tocutoff) | Near cutoffpositive (cutoffto +25% cutoff) | GC/MSPositive(+25% to +50%cutoff) | GC/MSPositive(+50% to 200%cutoff) | %Agreementwith GC/MSvalues | |
| BAR | (+) | 0 | 0 | 0 | 29 | 30 | 30 | 98.9% |
| (-) | 30 | 30 | 30 | 1 | 0 | 0 | 100% | |
| BZO | (+) | 0 | 0 | 0 | 30 | 30 | 30 | 100% |
| (-) | 30 | 30 | 30 | 0 | 0 | 0 | 100% | |
| MDMA | (+) | 0 | 0 | 1 | 30 | 30 | 30 | 100% |
| (-) | 30 | 30 | 29 | 0 | 0 | 0 | 98.9% | |
| MTD | (+) | 0 | 0. | 2 | 30 | 30 | 30 | 100% |
| (-) | 30 | 30 | 28 | 0 | 0 | 0 | 97.8% | |
| OPI 2000 | (+) | 0 | 0 | 0 | 30 | 30 | 30 | 100% |
| (-) | 30 | 30 | 30 | 0 | 0 | 0 | 100% | |
| OXY | (+) | 0 | 0 | 2 | 30 | 30 | 30 | 100% |
| (-) | 30 | 30 | 28 | 0 | 0 | 0 | 97.8% |
| A. O OTC accuracy study results are summarized in Table 1 and 2 below: | ||
|---|---|---|
| able 1. OTC accuracy study result summary for the Chemtrue® Dip Card Test |
Table 2. OTC accuracy study result summary for the Chemtrue® Cassette Test
| (-) | (+) | % | ||||||
|---|---|---|---|---|---|---|---|---|
| No drugpresent | GC/MSNegative(-50% to-25% cutoff) | Near cutoffnegative(-25% cutoff tocutoff) | Near cutoffpositive (cutoffto +25% cutoff) | GC/MSPositive(+25% to +50%cutoff) | GC/MSPositive(+50% to 200%cutoff) | AgreementwithGC/MSvalues | ||
| Chemtrue® DrugScreen Cassette Test | BAR (+) | 0 | 0 | 0 | 30 | 30 | 30 | 100% |
| (-) | 30 | 30 | 30 | 0 | 0 | 0 | 100% | |
| BZO (+) | 0 | 0 | 0 | 30 | 30 | 30 | 100% | |
| (-) | 30 | 30 | 30 | 0 | 0 | 0 | 100% | |
| MDMA (+) | 0 | 0 | 0 | 30 | 30 | 30 | 100% | |
| (-) | 30 | 30 | 30 | 0 | 0 | 0 | 100% | |
| MTD (+) | 0 | 0 | 2 | 30 | 30 | 30 | 100% | |
| (-) | 30 | 30 | 28 | 0 | 0 | 0 | 97.8% | |
| OPI 2000 (+) | 0 | 0 | 0 | 30 | 30 | 30 | 100% | |
| (-) | 30 | 30 | 30 | 0 | 0 | 0 | 100% | |
| OXY (+) | 0 | 0 | 1 | 30 | 30 | 30 | 100% | |
| (-) | 30 | 30 | 29 | 0 | 0 | 0 | 98.9% |
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The OTC accuracy study results showed that lay-users can perform the testing and interpret the results correctly with greater than 97.8% accuracy. It also demonstrated the substantial equivalency between the Chemtrue® Single/ Multi-Panel Drug Screen tests and the GC/MS reference method with ≥97.8% agreement for both Dip Card and Cassette formats.
Discordant results: Total of nine (9) discordant results were observed and listed in tables below: Table 3. Chemtrue® 6-Panel Drug Screen Dip Card Tests
| Sample Code | Cutoff Value(ng/mL) | Analyte assay(POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) | |
|---|---|---|---|---|
| Drug/Metabolite | GC/MS Value (ng/mL) | |||
| Aa79 | 300 | + | Methadone | 218 |
| Aa133 | 300 | + | Methadone | 218 |
| Ae83 | 500 | + | MDMA | 403 |
| Ab98 | 300 | - | Pentobarbital | 390 |
| Ab80 | 100 | + | Oxycodone | 70 |
| Ab146 | 100 | + | Oxycodone | 70 |
Table 4. Chemtrue 6-Panel Drug Screen Cassette Tests
| Sample Code | Cutoff Value(ng/mL) | Analyte assay(POS/NEG) | Drug/Metabolite GC/MS value (ng/mL) | |
|---|---|---|---|---|
| Drug/Metabolite | GC/MS Value (ng/mL) | |||
| Ba67 | 300 | + | Methadone | 218 |
| Ba73 | 300 | + | Methadone | 218 |
| Bb176 | 100 | + | Oxycodone | 70 |
The concentrations of these nine (9) discordant results were at ±25% of the cutoff levels [eight (8) were at -25% of the cut-off and one (1) was at +25% of the cut-off] which were cose to the cut off of the drug test.
- B. The OTC accuracy study results within site and between the sites, in comparison to the GC/MS values: The study results for all six (6) drug tests for both Dip Card and Cassette formats from three (3) independent sites are summarized in Tables below:
Barbiturates 300:
| Site 1 | Site 2 | Site 3 | ||
|---|---|---|---|---|
| Agreement | Within Site | 100% | 100% | 99.2% |
| Between Sites | 99.7% |
Benzodiaze pines 300:
| Site 1 | Site 2 | Site 3 | ||
|---|---|---|---|---|
| Agreement | Within Site | 100% | 100% | 100% |
| Between Sites | 100% |
MDMA 500:
| Site 1 | Site 2 | Site 3 | ||
|---|---|---|---|---|
| Agreement | Within Site | 100% | 100% | 99.2% |
| Between Sites | 99.7% |
Methadone 300:
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| Site 1 | Site 2 | Site 3 | ||
|---|---|---|---|---|
| Agreement | Within Site | 100% | 99.2% | 97.7% |
| Between Sites | 99% | |||
| Opiates 2000: | ||||
| Site 1 | Site 2 | Site 3 | ||
| Agreement | Within Site | 100% | 100% | 100% |
| Between Sites | 100% | |||
| Oxycodone 100: | ||||
| Site 1 | Site 2 | Site 3 |
| Site 1 | Site 2 | Site 3 | ||
|---|---|---|---|---|
| Agreement | Within Site | 100% | 98.3% | 99.2% |
| Between Sites | 99.2% |
Conclusion: The results demonstrate that there is no significant difference of the testing results by the lay-users from the independent three (3) sites. An overall greater than 97.7% agreement was obtained within the site and between the sites. The results are comparable to the FDA cleared Instant-View Drug Screen Test device K063545 and the device performance is substantially equivalent to the predicate kit and other like products that are manufactured by Alere and Alfa Scientific Design Inc. and presently distributed commercially.
Package Insert Evaluations:
The package inserts were analyzed and received a 7th grade Flesh-Kincaid reading score and a Flesch Reading Ease score of 83. The evaluation was also conducted through a questionnaire survey of 200 lay-users with both Dip Card and Cassette formats. The results demonstrate that a minimum of 95% rating as "Easy/Very easy to understand" to follow the instruction, perform the test and interpret the results for both Chemtrue® Drug Screen Dip Card and Cassette formats. For details, refer to Section G-7, Package insert evaluation and analysis, page 40 and 41 of this submission. The raw data is enclosed in ATTACHMENT E of this submission.
Analytical sensitivity (Cut-off characteristics), precision (reproducibility), Accuracy (Method comparison study with clinical samples), specificity and stability study data were established in K111322.
510(k) Summary was prepared by: Jane Zhang on September 28th, 2012 and updated on November 26, 2012.
7
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Image /page/7/Picture/0 description: The image shows the logo for the Department of Health & Human Services (HHS) of the United States. The logo features the HHS emblem, which is a stylized representation of a human figure embracing the world. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is arranged in a circular pattern around the emblem.
DEPARTMENT OF HEALTH & HUM AN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-002
November 29, 2012
Chemtron Biotech, Inc. c/o Jane Zhang 8370 Juniper Creek Lane Suite 1-2 San Diego, CA 92126
Re: K123080
Trade/Device Name: Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests
Regulation Number: 21 CFR §862.3170 Regulation Name: Benzodiazepine Test System Regulatory Class: Class II Product Code: JXM, DIS, DJC, DJR, DNK, DJG Dated: September 28, 2012 Received: October 25, 2012
Dear Ms. Zhang:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and 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) that do not require approval of a premarket approval application (PMA). 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 (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set
{8}------------------------------------------------
Page 2 - Ms. Zhang
forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Parts 801 and 809), please contact the Office of In Vitro Diagnostics and Radiological Health at (301) 796-5450. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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) 796-7100 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours,
Carol C. Benson
Courtney H. Lias, Ph.D Director Division of Chemistry and Toxicology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health
for
Enclosure
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Indications for Use
510(k) Number (if known): K123080
Device Name: Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests
Indications for Use:
The Chemtron Biotech, Inc.'s Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are rapid lateral flow immunoassays for the qualitative detection of up to six of the following drugs in a variety of combinations in human urine. The designated cutoff concentrations of each drug and the calibrators used for these drugs are as follows:
| Analyte | Abbreviation | Calibrator | Cutoff Concentration |
|---|---|---|---|
| Benzodiazepines | BZO | Oxazepam | 300 ng/mL |
| Barbiturates | BAR | Secobarbital/Pentobarbital | 300 ng/mL |
| Ecstasy | MDMA/XTC | d,l-Methylenedioxymethamphetamine | 500 ng/mL |
| Methadone | MTD | Methadone | 300 ng/mL |
| Opiates | OPI/MOR | Morphine | 2000 ng/mL |
| Oxycodone | OXY | Oxycodone | 100 ng/mL |
The Chemtrue® Single/Multi-Panel Drug Screen Cassette and Dip Card Tests are intended for the qualitative detection of drugs of abuse for health care professionals, in vitro diagnostic and Over-The-Counter (OTC) use.
The BAR.BZO and OXY assay will yield preliminary positive results when BAR, BZO, and OXY is ingested at or above therapeutic doses. There are no uniformly recognized drug levels for Barbiturate, Benzodiazepine and Oxycodone in urine. The Chemtrue® Single/Multi-Panel Drug Screen Cassette and Div Card Tests shows the drug was or was not present at the cutoff level. This assay provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result. Gas chromatography/mass spectrometry (GC/MS) is the preferred confirmatory method for most drugs (HPLC is the preferred confirmatory method for tri-cyclic antidepressants). Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.
| Prescription Use X | AND/OR | Over-The-Counter Use |
|---|---|---|
| (Part 21 CFR 801 Subpart D) |
Over-The-Counter Use (21 CFR 801 Subpart C)
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Concurrence of CDRH, Office of In Vitro Diagnostics and Radiological Health (OIR) 2000 ( of the Dir Division Sign-Off Office of In Vitro Diagnostics and Radiological Health
510(k) K123080
§ 862.3170 Benzodiazepine test system.
(a)
Identification. A benzodiazepine test system is a device intended to measure any of the benzodiazepine compounds, sedative and hypnotic drugs, in blood, plasma, and urine. The benzodiazepine compounds include chlordiazepoxide, diazepam, oxazepam, chlorzepate, flurazepam, and nitrazepam. Measurements obtained by this device are used in the diagnosis and treatment of benzodiazepine use or overdose and in monitoring levels of benzodiazepines to ensure appropriate therapy.(b)
Classification. Class II (special controls). A benzodiazepine 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).