K Number
K150096
Device Name
Healgen MDMA (Ecstacy) Test (Strip, Cassette, Cup, Dip Card), Healgen Phencyclidine Test (Strip, Cassette, Cup, Dip Card)
Date Cleared
2015-03-04

(43 days)

Product Code
Regulation Number
862.3610
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Healgen MDMA (Ecstasy) Test is an immunochromatographic assay for the qualitative determination of Methylenedioxymethamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result: GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use. Healgen Phencyclidine Test is an immunochromatographic assay for the qualitative determination of Phencyclidine in human urine at a Cut-Off concentration of 25 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.
Device Description
Healgen MDMA (Ecstasy) Test and Healgen Phencyclidine Test are immunochromatographic assays for Methylenedioxymethamphetamine and Phencyclidine. Each assay test is a lateral flow system for the qualitative detection of Methylenedioxymethamphetamine and Phencyclidine (target analyte) in human urine. The products are in vitro diagnostic devices, which come in the form of: Strips, Cassettes, DipCards, or Cups. Each product contains a Test Device (in one of the four formats), and a package Each test device is sealed with a desiccant in an aluminum pouch. insert.
More Information

Not Found

No
The device description and performance studies focus on immunochromatographic assay technology and manual interpretation of results, with no mention of AI or ML.

No
This device is an immunochromatographic assay for the qualitative determination of substances (MDMA and Phencyclidine) in human urine, making it an in vitro diagnostic device, not a therapeutic one.

Yes

The "Intended Use / Indications for Use" section explicitly states "For in vitro diagnostic use only." and the "Device Description" section refers to them as "in vitro diagnostic devices".

No

The device is described as an immunochromatographic assay available in physical formats (Strip, Cassette, Dip Card, Cup) and contains physical components like a Test Device, package insert, and desiccant. This indicates it is a hardware-based in vitro diagnostic device, not software-only.

Yes, this device is an IVD (In Vitro Diagnostic).

Here's why:

  • Explicit Statement: The text explicitly states "For in vitro diagnostic use only" multiple times in the "Intended Use / Indications for Use" and "Device Description" sections.
  • Intended Use: The device is intended for the qualitative determination of substances (Methylenedioxymethamphetamine and Phencyclidine) in a human biological sample (urine). This is a core characteristic of an IVD.
  • Device Description: The description details the components and format of the device, which is designed to perform a test on a sample outside of the body.
  • Regulatory Context: The mention of a "Predicate Device(s) (K number(s) and name(s))" indicates that this device is being compared to a previously cleared device under regulatory frameworks that govern IVDs (like the FDA in the US).

Therefore, based on the provided text, the Healgen MDMA (Ecstasy) Test and Healgen Phencyclidine Test are clearly identified as In Vitro Diagnostic devices.

N/A

Intended Use / Indications for Use

Healgen MDMA (Ecstasy) Test is an immunochromatographic assay for the qualitative determination of Methylenedioxymethamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format.

The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result: GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.

Healgen Phencyclidine Test is an immunochromatographic assay for the qualitative determination of Phencyclidine in human urine at a Cut-Off concentration of 25 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format.

The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.

Product codes (comma separated list FDA assigned to the subject device)

LAF, LCM

Device Description

Healgen MDMA (Ecstasy) Test and Healgen Phencyclidine Test are immunochromatographic assays for Methylenedioxymethamphetamine and Phencyclidine. Each assay test is a lateral flow system for the qualitative detection of Methylenedioxymethamphetamine and Phencyclidine (target analyte) in human urine. The products are in vitro diagnostic devices, which come in the form of: Strips, Cassettes, DipCards, or Cups. Each product contains a Test Device (in one of the four formats), and a package Each test device is sealed with a desiccant in an aluminum pouch. insert.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

It is intended for prescription and for over-the-counter use.

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Precision Test Set:
Samples with concentrations of -100% cut-off, -50% cut-off, -25% cut-off, at the cut-off, +25% cut-off, +75% cut-off, +75% cut-off and +100% cut-off. These samples were prepared by spiking drug in negative samples. Each drug concentration was confirmed by GC/MS. All sample aliquots were blind labeled and randomized by the person who prepared samples and did not take part in the sample testing. For each concentration, tests were performed two runs per day for 25 days by three different operators for each format of devices. Different set of operators tested each format.

Method Comparison Test Set:
80 (40 negative and 40 positive) unaltered clinical samples were blind labeled and compared to GC/MS results. The method comparison studies were performed in-house with three different laboratory assistants for each format of the device.

Lay-user Study Test Set:
Urine samples were prepared at the following concentrations: negative, +/-75%, +/-50%, +/-25% of the cutoff by spiking drugs into drug free-pooled urine specimens. The concentrations of the samples were confirmed by GC/MS. Each sample was aliquoted into individual containers and blind-labeled. Each participant was provided with the package insert, 1 blind labeled sample and a device.

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Study Type: Analytical Performance - Precision
Sample Size: For each concentration level stated in the test set description, tests were performed two runs per day for 25 days, implying 50 tests per concentration level per lot. Several lots were used. For each lot, at some concentrations (e.g., -100%, -75%, -50% -25% cut-off, +25%, +50%, +75%, +100% cut-off), results showed 50-/0+ or 50+/0-, meaning 50 negative results and 0 positive, or 50 positive and 0 negative. At the cut-off concentration, the results were mixed (e.g., 22-/28+, 24-/26+, 30-/20+ for MDMA and 20-/30+, 18-/32+, 22-/28+, 16-/34+ for Phencyclidine), indicating both positive and negative results close to the cutoff. This demonstrates the precision of the device around the cutoff.

Study Type: Analytical Performance - Cut-off
Sample Size: 150 samples for each target drug (MDMA and Phencyclidine), equally distributed at concentrations of -50% cut-off, -25% cut-off, cut-off, +25% cut-off, +50% cut-off.
Key Results: Results were all positive at and above +25% cut-off and all negative at and below -25% cut-off for both Methylenedioxymethamphetamine and Phencyclidine tests.

Study Type: Analytical Performance - Interference
Sample Size: Not explicitly stated as a number, but various interfering substances (listed in tables) were added to drug-free urine and target drugs urine at 25% above cut-off levels. Tested using three batches of each device for all formats.
Key Results: Compounds listed showed no interference at a concentration of 100µg/mL. There were no differences observed for different formats.

Study Type: Analytical Performance - Specificity
Sample Size: Not explicitly stated as a number, but drug metabolites and other components that are likely to interfere in urine samples were tested using three batches of each device for all formats.
Key Results: Cross-reactivity percentages were determined for related compounds. For MDMA, Methylenedioxymethamphetamine showed 100% cross-reactivity at 500 ng/mL, 3,4-Methylenedioxyamphetamine HCl (MDA) at 17% (3000 ng/mL), and 3,4-Methylenedioxyethylamphetamine (MDEA) at 167% (300 ng/mL). d-methamphetamine showed 20% cross-reactivity (2500 ng/mL) while other amphetamines were not detected at >100,000. For Phencyclidine, Phencyclidine itself showed 100% at 25 ng/mL, and 4-Hydroxy Phencyclidine at 28% (90 ng/mL).

Study Type: Effect of Urine Specific Gravity and Urine pH
Sample Size: Not explicitly stated as a number, but urine samples with specific gravity from 1.000 to 1.035 or pH 4 to 9 were spiked with target drugs at 25% below and 25% above cut-off levels. Tested using three batches of each device for all formats.
Key Results: Results were all positive for samples at and above +25% cut-off and all negative for samples at and below -25% Cut-Off. There were no differences observed for different formats.

Study Type: Comparison Studies (Clinical samples vs. GC/MS)
Sample Size: 80 unaltered clinical samples (40 negative and 40 positive) for each drug (MDMA and Phencyclidine) and each device format (Strip, Cassette, Cup, Dip Card).
Key Results:
For MDMA (Ecstasy) in Strip, Cassette, Cup, and Dip Card formats, across three viewers (A, B, C):

  • Negative, Low Negative, and Near Cutoff Negative samples by GC/MS (e.g., 10 negative, 15 low negative, 15 near cutoff negative) consistently yielded 0 positive results and the full sample count as negative.
  • Near Cutoff Positive by GC/MS (e.g., 13 or 14 samples) yielded mostly positive results (e.g., 13 or 14 positive) and few negative results (e.g., 2 to 3 negative).
  • High Positive by GC/MS (24 samples) consistently yielded 24 positive results and 0 negative.
  • Discordant results indicate some false negatives for samples around the cutoff concentrated around the cutoff concentration as determined by GC/MS.

For Phencyclidine in Strip, Cassette, Cup, and Dip Card formats, across three viewers (A, B, C):

  • Negative, Low Negative, and Near Cutoff Negative samples by GC/MS (e.g., 10 negative, 15 low negative, 15 near cutoff negative) consistently yielded 0 positive results and the full sample count as negative.
  • Near Cutoff Positive by GC/MS (e.g., 12, 13, or 14 samples) yielded mostly positive results (e.g., 12 to 14 positive) and few negative results (e.g., 2 to 4 negative).
  • High Positive by GC/MS (24 samples) consistently yielded 24 positive results and 0 negative.
  • Discordant results indicate some false negatives for samples around the cutoff concentrated around the cutoff concentration as determined by GC/MS.

Study Type: Lay-user study
Sample Size: 557 lay persons for MDMA (Ecstasy) devices and 555 lay persons for Phencyclidine devices. Total of 1112 individuals. Age range 21 to >50 years.
Key Results:
For MDMA (Ecstasy) across all formats (Strip, Cassette, Dip Card, Cup):

  • For samples at -100%, -75%, -50% Cutoff, 100% correct results (all negative).
  • For samples at -25% Cutoff, 95% correct results (1 positive, 19 negative out of 20 samples), except for cassette and cup formats where the value is missing in the table, but indicated by a garbled text implying the same or similar result to dip card.
  • For samples at +25% Cutoff, 95% correct results (19 positive, 1 negative out of 20 samples), except for cassette and cup formats where the value is missing in the table, but indicated by a garbled text implying the same or similar result to dip card.
  • For samples at +50% and +75% Cutoff, 100% correct results (all positive).

For Phencyclidine across all formats (Strip, Cassette, Dip Card, Cup):

  • For samples at -100%, -75%, -50% Cutoff, 100% correct results (all negative).
  • For samples at -25% Cutoff, 95% correct results (1 positive, 19 negative out of 20 samples) for Strip and Cassette formats. For DipCard and Cup, it was 90% correct (2 positive, 18 negative out of 20 samples).
  • For samples at +25% Cutoff, 95% correct results (19 positive, 1 negative out of 20 samples) for Strip, Cassette and Cup formats. For DipCard, it was 90% correct (18 positive, 2 negative out of 20 samples).
  • For samples at +50% and +75% Cutoff, 100% correct results (all positive), except +75% cutoff for Phencyclidine DipCard and Cup where it was 19 samples, 100% correct (all positive).
    Surveys indicated that instructions were easily followed (Flesch-Kincaid Grade Level of 7).

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Values for sensitivity, specificity, PPV, NPV are not explicitly calculated or presented as such, but the raw data from precision and comparison studies (positive/negative counts at different concentrations relative to cutoff and GC/MS confirmed values) could be used to infer them.

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K052115 First Check Multi Drug Cup 12

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 862.3610 Methamphetamine test system.

(a)
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.(b)
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).

0

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 circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized graphic of three human profiles facing to the right, stacked on top of each other.

March 4, 2015

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

HEALGEN SCIENTIFIC LLC C/O JOE XIA BUSINESS DIRECTOR 504 EAST DIAMOND AVE. SUITE I GAITHERSBURG MD 20877

Re: K150096

Trade/Device Name: Healgen MDMA (Ecstasy) Test (Strip, Cassette, Cup, Dip Card), Healgen Phencyclidine Test (Strip, Cassette, Cup, Dip Card) Regulation Number: 21 CFR 862.3610 Regulation Name: Methamphetamine test system Regulatory Class: II Product Code: LAF, LCM Dated: January 12, 2015 Received: January 20, 2015

Dear Mr. Xia:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

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 Parts 801 and 809); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set 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.

1

If you desire specific advice for your device on our labeling regulations (21 CFR Parts 801 and 809), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638 2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Katherine Serrano -A

For : 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

Enclosure

2

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement below.

510(k) Number (if known) K150096

Device Name Healgen MDMA (Ecstasy) Test (Strip, Cassette, Cup, Dip Card) Healgen Phencyclidine Test (Strip, Cassette, Cup, Dip Card)

Indications for Use (Describe)

Healgen MDMA (Ecstasy) Test is an immunochromatographic assay for the qualitative determination of Methylenedioxymethamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format.

The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result: GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.

Healgen Phencyclidine Test is an immunochromatographic assay for the qualitative determination of Phencyclidine in human urine at a Cut-Off concentration of 25 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format.

The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.

Type of Use (Select one or both, as applicable)

☑ Prescription Use (Part 21 CFR 801 Subpart D)
☑ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

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    1. Date: February 26, 2015
    1. Submitter: HEALGEN SCIENTIFIC LLC 5213 Maple St Bellaire, TX 77401
    1. Contact person: Jianqiu Fang HEALGEN SCIENTIFIC LLC 5213 Maple St Bellaire, TX 77401 Telephone: 713-733-8088 Fax: 713-733-8088 Email: bryan@healgen.com
    1. Device Name: Healgen MDMA (Ecstasy) Test (Strip, Cassette, Cup, Dip Card) Healgen Phencyclidine Test (Strip, Cassette, Cup, Dip Card)

Classification:

Product CodeCFR #Panel
LCMThis device has not been classified.
LAF21 CFR, 862.3610 Methamphetamine Test SystemToxicology
    1. Predicate Devices: K052115 First Check Multi Drug Cup 12
    1. Intended Use / Indications for Use

Healgen MDMA (Ecstasy) Test is an immunochromatographic assay for the qualitative determination of Methylenedioxymethamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format.

The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.

For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.

4

Healgen Phencyclidine Test is an immunochromatographic assay for the qualitative determination of Phencyclidine in human urine at a Cut-Off concentration of 25 ng/mL. The test is available in a Strip format, a Cassette format, a Dip Card format and a Cup format.

The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.

For in vitro diagnostic use only. It is intended for prescription and for over-the-counter use.

    1. Device Description
      Healgen MDMA (Ecstasy) Test and Healgen Phencyclidine Test are immunochromatographic assays for Methylenedioxymethamphetamine and Phencyclidine. Each assay test is a lateral flow system for the qualitative detection of Methylenedioxymethamphetamine and Phencyclidine (target analyte) in human urine. The products are in vitro diagnostic devices, which come in the form of: Strips, Cassettes, DipCards, or Cups. Each product contains a Test Device (in one of the four formats), and a package Each test device is sealed with a desiccant in an aluminum pouch. insert.

8. Substantial Equivalence Information

A summary comparison of features of the Healgen MDMA (Ecstasy) Test and Healgen Phencyclidine Test and the predicate device is provided in Table 1 & Table 2.

| Item | Device | Predicate -
K052115 |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------|---------------------------------|
| Intended Use | For the qualitative determination of drugs
of abuse in human urine. | Same |
| Drug Analyte | Methylenedioxymethamphetamine | Same |
| Methodology | Competitive binding, lateral flow
immunochromatographic assays based on
the principle of antigen antibody
immunochemistry. | Same |
| Specimen Type | Human Urine | Same |
| Cut-Off Values | 500 ng/mL | Same |
| Intended
Population | For over-the-counter and prescription
uses. | For
over-the-counter
use. |
| Configurations | Strip, Cassette, Cup, Dip Card | Cup |

Table 1: Features Comparison of Healgen MDMA (Ecstasy) Test and the Predicate Device

Table 2: Features Comparison of Healgen Phencyclidine Test and the Predicate Device

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ItemDevicePredicate - K052115
Intended UseFor the qualitative determination of
drugs of abuse in human urine.Same
Drug AnalytePhencyclidineSame
MethodologyCompetitive binding, lateral flow
immunochromatographic assays based
on the principle of antigen antibody
immunochemistry.Same
Specimen TypeHuman UrineSame
Cut-Off Values25 ng/mLSame
Intended
PopulationFor over-the-counter and prescription
uses.For over-the-counter
use.
ConfigurationsStrip, Cassette, Cup, Dip CardCup

9. Test Principle

Healgen MDMA (Ecstasy) Test and Healgen Phencyclidine Test are rapid tests for the qualitative detection of Methylenedioxymethamphetamine and Phencyclidine in urine samples. Each assay test is a lateral flow chromatographic immunoassay. During testing, a urine specimen migrates upward by capillary action. If target drugs are present in the urine specimen below its cut-off concentration, it will not saturate the binding sites of its specific antibody (monoclonal mouse antibody) coated on the particles. The antibody-coated particles will then be captured by immobilized drug-conjugate and a visible colored line will show up in the test line region. The will not form in the test line region if the target drug level exceeds its cut-offconcentration because it will saturate all the binding sites of the antibody coated on the particles. A band should form in the control region of the devices regardless of the presence of drug or metabolite in the sample to indicate that the test has been performed properly.

10. Performance Characteristics

    1. Analytical Performance
    • a. Precision

Precision studies were carried out for samples with concentrations of -100% cut-off, -50% cut-off, -25% cut-off, at the cut-off, +25% cut-off, +75% cut-off, +75% cut-off and +100% cut-off. These samples were prepared by spiking drug in negative samples. Each drug concentration was confirmed by GC/MS. All sample aliquots were blind labeled and randomized by the person who prepared samples and did not take part in the sample testing. For each concentration, tests were performed two runs per day for 25 days by three different operators for

6

each format of devices. Different set of operators tested each format. The results obtained are summarized in the following tables:

MDMA (Ecstasy)

ResultCut-off
Drug-100% Cut-off-75% Cut-off-50% Cut-off-25% Cut-offCut-off+25% Cut-off+50% Cut-off+75% Cut-off+100% Cut-off
Lot:MDMA120100150-/0+50-/0+50-/0+50-/0+22-/28+50+/0-50+/0-50+/0-50+/0-
Lot:MDMA120100250-/0+50-/0+50-/0+50-/0+22-/28+50+/0-50+/0-50+/0-50+/0-
Lot:MDMA120100350-/0+50-/0+50-/0+50-/0+22-/28+50+/0-50+/0-50+/0-50+/0-

Cassette Format

DrugResult-100% Cut-off-75% Cut-off-50% Cut-off-25% Cut-offCut-off+25% Cut-off+50% Cut-off+75% Cut-off+100% Cut-off
Lot:MDMA120100450-/0+50-/0+50-/0+50-/0+50-/0+22-/28+50+/0-50+/0-50+/0-50+/0-
Lot:MDMA120100550-/0+50-/0+50-/0+50-/0+50-/0+22-/28+50+/0-50+/0-50+/0-50+/0-
Lot:MDMA120100650-/0+50-/0+50-/0+50-/0+50-/0+22-/28+50+/0-50+/0-50+/0-50+/0-

Dip Card Format

| | Result | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | +25%
Cut-off | +50%
Cut-off | +75%
Cut-off | +100%
Cut-off |
|-----------------|--------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Drug | | | | | | | | | | |
| Lot:MDMA1201007 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot:MDMA1201008 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot:MDMA1201009 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

CUP Format

| Drug | Result | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | +25%
Cut-off | +50%
Cut-off | +75%
Cut-off | +100%
Cut-off |
|-----------------|--------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Lot:MDMA1201010 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 30-/20+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot:MDMA1201011 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 30-/20+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot:MDMA1201012 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 30-/20+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Phencyclidine

Strip Format

| | Result | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | +25%
Cut-off | +50%
Cut-off | +75%
Cut-off | +100%
Cut-off |
|----------------|--------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Drug | | | | | | | | | | |
| Lot:PCP1111001 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 20-/30+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot:PCP1111002 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 20-/30+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot:PCP1111003 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 20-/30+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

7

Cassette Format

| | Result | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | +25%
Cut-off | +50%
Cut-off | +75%
Cut-off | +100%
Cut-off |
|------|----------------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Drug | Lot:PCP1111004 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 18-/32+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| | Lot:PCP1111005 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 18-/32+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| | Lot:PCP1111006 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 18-/32+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Dip Card Format

Result -100% -75%-50% ।-25%+25% '+50% +75% +100%
DrugCut-off Cut-off Cut-off Cut-offCut-offCut-off Cut-off Cut-off Cut-off
Lot:PCP111100750-/0+ 50-/0+ 50-/0+ 50-/0+ 22-/28+ 50+/0- 50+/0- 50+/0- 50+/0- 50+/0-
Lot:PCP111100850-/0+ 50-/0+ 50-/0+ 50-/0+ 22-/28+ 50+/0- 50+/0- 50+/0- 50+/0-
Lot:PCP111100950-/0+ 50-/0+ 50-/0+ 50-/0+ 22-/28+ 50+/0- 50+/0- 50+/0- 50+/0-

CUP Format

| | Result | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | +25%
Cut-off | +50%
Cut-off | +75%
Cut-off | +100%
Cut-off |
|------|----------------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Drug | Lot:PCP1111010 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 16-/34+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| | Lot:PCP1111011 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 16-/34+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| | Lot:PCP1111012 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 16-/34+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

  • b. Linearity
    Not applicable.

  • c. Stability
    The devices are stable at 4-30℃ for 24 months based on the accelerated stability study at 45℃ and real time stability determination at both 4 ℃ and 30℃.

Control materials are not provided with the device. The labeling provides information on how to obtain control materials.

  • d. Cut-off
    A total of 150 samples equally distributed at concentrations of -50% cut-off; -25% cut-off; cut-off; +25% cut-off; +50% cut-off were tested using three different lots of each device by three different operators. Results were all positive at and above +25% cut-off and all negative at and below -25% cut-off for both Methylenedioxymethamphetamine and Phencyclidine. The following cut-off values for the test devices have been verified.

| Test | Calibrator | Cut-off
(ng/mL) |
|------|------------|--------------------|
| | | |

8

MDMA (Ecstasy) TestMethylenedioxymethamphetamine500
Phencyclidine TestPhencyclidine25
  • e. Interference
    Potential interfering substances found in human urine of physiological or pathological conditions were added to drug-free urine and target drugs urine with concentration at 25% above cut-off levels. These urine samples were tested using three batches of each device for all formats.

Compounds that showed no interference at a concentration of 100µg/mL are summarized in the following tables. There were no differences observed for different formats.

AcetophenetidinEthyl MorphinePhenelzine
N-AcetylprocainamideEthyl-p-aminobenzoatePhenobarbital
Acetylsalicylic Acid
(Aspirin)FenoprofenPhentermine
AminopyrineFurosemidePhenylephrine-L
AmitriptylineGentisic acidPhenylethylamine
AmoxicillinHemoglobinPhenylpropanolamine
AmobarbitalHydralazinePrednisolone Acetate
D-Amphetamine(+/-)-4-Hydroxyamphetamine
HCLPrednisone
L-AmphetamineHydrochlorothiazideProcaine(Novocaine)
Amphetamine SulfateHydrocodonePromazine
Ampicinine(Ampicillin)HydrocortisonePromethazine
Apomorphinea -Hydroxyhippuric acidPropoxyphene,d-
L-Ascorbic Acidp-HydroxymethamphetaminePropranolol
AspartameIbuprofenPseudoephedrine HCL
AtropineImipramineQuinidine
Benzilic acidIsoxsuprineQuinine
BenzphetamineIsoproterenol-(+/-)Ranitidine(Zantac)
Bezoic AcidKetamineSalicylic Acid
BilirubinLevorphanolSecobarbital
CaffeineLoperamideSerotonin
ChloramphenicolMaprotilineSulfamethazine
Chlordiazepoxide
HCLMeprobamateSulindac
ChloroquineMethadoneTemazepam
ChlorothiazideMethoxyphenamine11-Nor-Δ9-Tetrahydrocannabi
nol

MDMA (Ecstasy)

9

ChlorpheniramineMethylphenidateTetracycline
ChlorpromazineNalbuphineTetrahydrozoline
CholesterolNalidixic acidThebaine
ClomipramineNaloxone hydrochlorideThiamine
Clonidine hydrochlorideNaltrexone hydrochlorideL-Thyroxine
CodeineNaproxenThioridazineHydrochloride
CortisoneNiacinamideTriamterene
Cotinine(-)NifedipineTriflupromazine
Hydrochloride
CreatinineNorethindroneTrimethoprim
DeoxyepinephrineNorpropoxypheneTrimipramine
DextromethorphanNoscapineTryptamine
DiazepamOxazepamDL-Tryptophan
DiflunisalOxycodoneTyramine
DigoxinOxymetazolineD/L-Tyrosine
DoxylaminePapaverineUric Acid
Ecgonine methylesterPenicillinVerapamil
R(-)-EpinephrinePentobarbitalZomepirac
ErythromycinPerphenazine
Estrone-3-sulfatePhencyclidine

Phencyclidine

AcetophenetidinEthyl-p-aminobenzoatePhenelzine
N-AcetylprocainamideFenoprofenPhenobarbital
Acetylsalicylic Acid
(Aspirin)FurosemidePhentermine
AminopyrineGentisic acidPhenylephrine-L
AmitriptylineHemoglobinPhenylethylamine
AmoxicillinHydralazinePhenylpropanolamine
Amobarbital(+/-)-4-Hydroxyamphetamine
HCLPrednisolone Acetate
D-AmphetamineHydrochlorothiazidePrednisone
L-AmphetamineHydrocodoneProcaine(Novocaine)
Amphetamine SulfateHydrocortisonePromazine
Ampicinine(Ampicillin)a -Hydroxyhippuric acidPromethazine
Apomorphinep-HydroxymethamphetaminePropoxyphene,d-
L-Ascorbic AcidIbuprofenPropranolol
AspartameImipraminePseudoephedrine HCL
AtropineIsoxsuprineQuinidine
Benzilic acidIsoproterenol-(+/-)Quinine

10

BenzphetamineKetamineRanitidine(Zantac)
Bezoic AcidLabetalolSalicylic Acid
BilirubinLevorphanolSecobarbital
CaffeineLoperamideSerotonin
ChloramphenicolMaprotilineSulfamethazine
Chlordiazepoxide
HCLMeprobamateSulindac
ChloroquineMethadoneTemazepam
ChlorothiazideMethoxyphenamine11-Nor-Δ9-Tetrahydrocannabi
nol
Chlorpheniramine(+/-)-Methylenedioxyampheta
mine(MDA)Tetracycline
ChlorpromazineMethylphenidateTetrahydrozoline
CholesterolNalbuphineThebaine
ClomipramineNalidixic acidThiamine
Clonidine hydrochlorideNaloxone hydrochlorideL-Thyroxine
CodeineNaltrexone hydrochlorideThioridazineHydrochloride
CortisoneNaproxenTriamterene
Cotinine(-)NiacinamideTriflupromazine
Hydrochloride
CreatinineNifedipineTrimethoprim
DeoxyepinephrineNorethindroneTrimipramine
DextromethorphanNorpropoxypheneTryptamine
DiazepamNoscapineDL-Tryptophan
DiflunisalOxazepamTyramine
DigoxinOxycodoneD/L-Tyrosine
DoxylamineOxymetazolineUric Acid
Ecgonine methylesterPapaverineVerapamil
R(-)-EpinephrinePenicillinZomepirac
ErythromycinPentobarbital
Estrone-3-sulfatePerphenazine

f. Specificity

To test the specificity, drug metabolites and other components that are likely to interfere in urine samples were tested using three batches of each device for all formats. The obtained lowest detectable concentration was used to calculate the cross-reactivity. There were no differences observed for different formats.

MDMAResult%
-----------------

11

| Methylenedioxymethamphetamine

(Cut-off=500 ng/mL)Cross-Reactivity
MethylenedioxymethamphetaminePositive at 500 ng/mL100%
3,4-Methylenedioxyamphetamine HCl
(MDA)Positive at 3000 ng/mL17%
3,4-Methylenedioxyethylamphetamine
(MDEA)Positive at 300 ng/mL167%
d-methamphetaminePositive at 2500 ng/mL20%
d-amphetamine>100,000Not detected
l-amphetamine>100,000Not detected
l-methamphetamine>100,000Not detected

| Phencyclidine

(Cut-off=25 ng/mL)Result% Cross-Reactivity
PhencyclidinePositive at 25 ng/mL100%
4-Hydroxy PhencyclidinePositive at 90 ng/mL28%

g. Effect of Urine Specific Gravity and Urine pH

To investigate the effect of urine specific gravity and urine samples with of 1.000 to 1.035 specific gravity or urine samples with pH 4 to 9 were spiked with target drugs at 25% below and 25% above cut-off levels. These samples were tested using three batches of each device for all formats. Results were all positive for samples at and above +25% cut-off and all negative for samples at and below -25% Cut-Off. There were no differences observed for different formats.

    1. Comparison Studies
      The method comparison studies for the MDMA (Ecstasy) Test, and the Phencyclidine Test were performed in-house with three different laboratory assistants for each format of the device. Operators ran 80 (40 negative and 40 positive) unaltered clinical samples were blind labeled and compared to GC/MS results. The results are presented in the tables below:
IVALLA VIZA LEZULO V
Strip
formatNegativeLow
Negative
by GC/MS
(less than
-50%)Near Cutoff
Negative by
GC/MS
(Between
-50% and
cut-off)Near
Cutoff
Positive by
GC/MS
(Between
the cut-off
and +50%)High
Positive by
GC/MS
(greater
than +50%)
Viewer APositive0001324
MDMA (Ecstasy)
------------------

12

Viewer BNegative10151530
Positive0001224
Viewer CNegative10151540
Positive0001324
Negative10151530

Discordant Results of MDMA (Ecstasy) Strip

| Viewer | Sample Number | GC/MS Result | Strip Format
Viewer Results |
|----------|---------------|--------------|--------------------------------|
| Viewer A | 1008 | ર૦તે | Negative |
| Viewer A | 1033 | ર૦ર | Negative |
| Viewer A | 1076 | 507 | Negative |
| Viewer B | 1008 | ર૦તે | Negative |
| Viewer B | 1033 | ર૦ર | Negative |
| Viewer B | 1076 | 507 | Negative |
| Viewer B | 1037 | 211 | Negative |
| Viewer C | 1008 | ર૦તે | Negative |
| Viewer C | 1033 | ર૦ર | Negative |
| Viewer C | 1076 | 507 | Negative |

Cassette formatNegativeLow Negative by GC/MS (less than -50%)Near Cutoff Negative by GC/MS (Between -50% and cut-off)Near Cutoff Positive by GC/MS (Between the cut-off and +50%)High Positive by GC/MS (greater than +50%)
Viewer APositive0001324
Negative10151530
Viewer BPositive0001324
Negative10151530
Viewer CPositive0001424
Negative10151520

Discordant Results of MDMA (Ecstasy) Cassette

Cassette Format
ViewerSample NumberGC/MS ResultViewer Results
Viewer A1008509Negative
Viewer A1033505Negative
Viewer A1076507Negative
Viewer B1033505Negative
Viewer B1037511Negative

13

| Viewer | Sample Number | GC/MS Result | Cassette Format
Viewer Results |
|----------|---------------|--------------|-----------------------------------|
| Viewer B | 1076 | 507 | Negative |
| Viewer C | 1033 | 505 | Negative |
| Viewer C | 1076 | 507 | Negative |

Cup formatNegativeLow Negative by GC/MS (less than -50%)Near Cutoff Negative by GC/MS (Between -50% and cut-off)Near Cutoff Positive by GC/MS (Between the cut-off and +50%)High Positive by GC/MS (greater than +50%)
Viewer APositive0001324
Negative10151530
Viewer BPositive0001224
Negative10151540
Viewer CPositive0001324
Negative10151530

Discordant Results of MDMA (Ecstasy) Cup

ViewerSample NumberGC/MS ResultCup Format
Viewer Results
Viewer A1008ર09Negative
Viewer A1033ર૦રNegative
Viewer A1076507Negative
Viewer B1008ર૦તેNegative
Viewer B1033૨૦૨Negative
Viewer B1076507Negative
Viewer B1037211Negative
Viewer C1008ર૦તેNegative
Viewer C1033ર૦રNegative
Viewer C1076507Negative

| Dip Card
format | | Negative | Low
Negative
by GC/MS
(less than
-50%) | Near Cutoff
Negative by
GC/MS
(Between
-50% and
cut-off) | Near Cutoff
Positive by
GC/MS
(Between
the cut-off
and +50%) | High
Positive by
GC/MS
(greater
than
+50%) |
|--------------------|----------|----------|----------------------------------------------------|-------------------------------------------------------------------------|-----------------------------------------------------------------------------|-----------------------------------------------------------|
| Viewer A | Positive | 0 | 0 | 0 | 14 | 24 |

14

Negative10151520
Viewer BPositive0001524
Negative10151510
Viewer CPositive0001324
Negative10151530

Discordant Results of MDMA (Ecstasy) Dip Card

| Viewer | Sample Number | GC/MS Result | Dip Card Format
Viewer Results |
|----------|---------------|--------------|-----------------------------------|
| Viewer A | 1033 | 505 | Negative |
| Viewer A | 1076 | 507 | Negative |
| Viewer B | 1033 | 505 | Negative |
| Viewer C | 1008 | 509 | Negative |
| Viewer C | 1033 | 505 | Negative |
| Viewer C | 1076 | 507 | Negative |

Phencyclidine
Strip formatNegativeLow Negative by GC/MS (less than -50%)Near Cutoff Negative by GC/MS (Between -50% and cut-off)Near Cutoff Positive by GC/MS (Between the cut-off and +50%)High Positive by GC/MS (greater than +50%)
Viewer APositive0001324
Negative10151530
Viewer BPositive0001324
Negative10151530
Viewer CPositive0001324
Negative10151530

Discordant Results of Phencyclidine Strip

| Viewer | Sample Number | GC/MS Result | Strip Format
Viewer Results |
|----------|---------------|--------------|--------------------------------|
| Viewer A | 774 | 26 | Negative |
| Viewer A | 721 | 25 | Negative |
| Viewer A | 779 | 27 | Negative |
| Viewer B | 774 | 26 | Negative |
| Viewer B | 721 | 25 | Negative |
| Viewer B | 702 | 27 | Negative |
| Viewer C | 721 | 25 | Negative |
| Viewer C | 704 | 27 | Negative |

15

ViewerSample NumberGC/MS ResultStrip Format Viewer Results
Viewer C77927Negative
Cassette formatNegativeLow Negative by GC/MS (less than -50%)Near Cutoff Negative by GC/MS (Between -50% and cut-off)Near Cutoff Positive by GC/MS (Between the cut-off and +50%)High Positive by GC/MS (greater than +50%)
Viewer APositive0001424
Negative10151520
Viewer BPositive0001324
Negative10151530
Viewer CPositive0001224
Negative10151540

Discordant Results of Phencyclidine Cassette

ViewerSample NumberGC/MS ResultCassette Format Viewer Results
Viewer A77426Negative
Viewer A72125Negative
Viewer B77426Negative
Viewer B72125Negative
Viewer B70227Negative
Viewer C77426Negative
Viewer C72125Negative
Viewer C70427Negative
Viewer C77927Negative

| Dip Card
format | | Negative | Low
Negative
by GC/MS
(less than
-50%) | Near Cutoff
Negative by
GC/MS
(Between
-50% and
cut-off) | Near Cutoff
Positive by
GC/MS
(Between
the cut-off
and +50%) | High
Positive by
GC/MS
(greater
than
+50%) |
|--------------------|----------|----------|----------------------------------------------------|-------------------------------------------------------------------------|-----------------------------------------------------------------------------|-----------------------------------------------------------|
| Viewer A | Positive | 0 | 0 | 0 | 13 | 24 |
| | Negative | 10 | 15 | 15 | 3 | 0 |

16

Viewer BPositive0001324
Negative10151530
Viewer CPositive0001224
Negative10151540
ViewerSample NumberGC/MS ResultDip Card Format Viewer Results
Viewer A77426Negative
Viewer A72125Negative
Viewer A77927Negative
Viewer B77426Negative
Viewer B72125Negative
Viewer B70227Negative
Viewer C77426Negative
Viewer C72125Negative
Viewer C77927Negative
Viewer C70427Negative

Discordant Results of Phencyclidine Dip Card

| Cup
format | | Negative | Low
Negative
by GC/MS
(less than
-50%) | Near Cutoff
Negative by
GC/MS
(Between
-50% and
cut-off) | Near Cutoff
Positive by
GC/MS
(Between
the cut-off
and +50%) | High
Positive by
GC/MS
(greater
than
+50%) |
|---------------|----------|----------|----------------------------------------------------|-------------------------------------------------------------------------|-----------------------------------------------------------------------------|-----------------------------------------------------------|
| Viewer A | Positive | 0 | 0 | 0 | 13 | 24 |
| | Negative | 10 | 15 | 15 | 3 | 0 |
| Viewer B | Positive | 0 | 0 | 0 | 13 | 24 |
| | Negative | 10 | 15 | 15 | 3 | 0 |
| Viewer C | Positive | 0 | 0 | 0 | 13 | 24 |
| | Negative | 10 | 15 | 15 | 3 | 0 |

Discordant Results of Phencyclidine Cup

ViewerSample NumberGC/MS ResultCup Format Viewer Results
Viewer A77426Negative
Viewer A72125Negative
Viewer A77927Negative
Viewer B77426Negative
Viewer B72125Negative

17

| Viewer | Sample Number | GC/MS Result | Cup Format
Viewer Results |
|----------|---------------|--------------|------------------------------|
| Viewer B | 702 | 27 | Negative |
| Viewer C | 721 | 25 | Negative |
| Viewer C | 779 | 27 | Negative |
| Viewer C | 704 | 27 | Negative |

Lay-user study

A lay user study was performed at three intended user sites with 557 lay persons testing the MDMA(Ecstasy) devices and another set of 555 persons testing the Phencyclidine devices. Total of 1112 individuals performed the study. A total of 230 females and 327 males tested the MDMA(Ecstasy) samples, and 226 females and 329 males tested the Phencyclidine samples. They had diverse educational and professional backgrounds and ranged in age from 21 to > 50 years. Urine samples were prepared at the following concentrations; negative, +/-75%, +/-50%, +/-25% of the cutoff by spiking drugs into drug free-pooled urine specimens. The concentrations of the samples were confirmed by GC/MS. Each sample was aliquoted into individual containers and blind-labeled. Each participant was provided with the package insert, 1 blind labeled sample and a device. The results are summarized below.

| | Number
of
samples | MDMA Concentration by
GC/MS
(ng/mL) | Lay person results | | The |
|--------------|-------------------------|-------------------------------------------|--------------------|--------------------|-----------------------------------------|
| % of Cutoff | | | No. of
Positive | No. of
Negative | percentage of
correct results
(%) |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75% Cutoff | 20 | 125 | 0 | 20 | 100% |
| -50% Cutoff | 19 | 250 | 0 | 19 | 100% |
| -25% Cutoff | 20 | 375 | 1 | 19 | 95% |
| +25% Cutoff | 20 | 625 | 19 | 1 | 95% |
| +50% Cutoff | 20 | 750 | 20 | 0 | 100% |
| +75% Cutoff | 20 | 875 | 20 | 0 | 100% |

Comparison between GC/MS and Lay Person Results (MDMA(Ecstasy) Strip)

Comparison between GC/MS and Lay Person Results (MDMA(Ecstasy) Cassette)

| | Number | MDMA Concentration by
GC/MS
(ng/mL) | Lay person results | | The |
|-------------|---------------|-------------------------------------------|--------------------|--------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| % of Cutoff | of
samples | | No. of
Positive | No. of
Negative | percentage of
correct results
(%) |
| -100%Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75%Cutoff | 19 | 125 | 0 | 19 | 100% |
| -50% Cutoff | 20 | 250 | 0 | 20 | 100% |
| -25% Cutoff | 20 | 375 | 1 | 19 | તે તે જે જ જીરી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં લોકોનો મુખ્ય |
| +25% Cutoff | 20 | ર્ભ (૧૯૮૮) | 19 | 1 | તે તે જેની જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં લોકોનો મુખ્ય વ્યવસાય ખેતી, ખેતમજૂરી તેમ જ પશુપાલન છે. આ ગામનાં મુખ્યત્વે ખેત-ઉત |

18

+50% Cutoff20750200100%
+75% Cutoff20875200100%

Comparison between GC/MS and Lay Person Results (MDMA(Ecstasy) DipCard)

NumberMDMA Concentration byLay person resultsThe
% of Cutoffof
samplesGC/MS
(ng/mL)No. of
PositiveNo. of
Negativepercentage of
correct results
(%)
-100%Cutoff200020100%
-75%Cutoff20125020100%
-50% Cutoff20250020100%
-25% Cutoff20375119તે તે જેની જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં લોકોનો મુખ્ય વ્યવસાય ખેતી, ખેતમજૂરી તેમ જ પશુપાલન છે. આ ગામમાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો
+25% Cutoff20ર્ભ (૧૯૮૮)191તે તે જેની જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં લોકોનો મુખ્ય વ્યવસાય ખેતી, ખેતમજૂરી તેમ જ પશુપાલન છે. આ ગામમાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો
+50% Cutoff20750200100%
+75% Cutoff20875200100%

Comparison between GC/MS and Lay Person Results (MDMA(Ecstasy) Cup)

| % of Cutoff | Number
of
samples | MDMA Concentration by
GC/MS
(ng/mL) | Lay person results | | The |
|-------------|-------------------------|-------------------------------------------|--------------------|--------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | | | No. of
Positive | No. of
Negative | percentage of
correct results
(%) |
| -100%Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75%Cutoff | 20 | 125 | 0 | 20 | 100% |
| -50% Cutoff | 20 | 250 | 0 | 20 | 100% |
| -25% Cutoff | 20 | 375 | 1 | 19 | તે તે જે જ જીરી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં લોકોનો મુખ્ય |
| +25% Cutoff | 20 | ર્ભ (૧૯૮૮) | 19 | 1 | તે તે જે જ જીરી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં લોકોનો મુખ્ય |
| +50% Cutoff | 19 | 750 | 19 | 0 | 100% |
| +75% Cutoff | 20 | 875 | 20 | 0 | 100% |

Comparison between GC/MS and Lay Person Results (Phencyclidine Strip)

| | Number | Phencyclidine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|-------------|---------------|----------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| % of Cutoff | of
samples | | No. of
Positive | No. of
Negative | |
| -100%Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75%Cutoff | 19 | 6 | 0 | 19 | 100% |
| -50% Cutoff | 20 | 12.5 | 0 | 20 | 100% |
| -25% Cutoff | 20 | 19 | 1 | 19 | 95% |
| +25% Cutoff | 20 | 31 | 19 | 1 | 95% |
| +50% Cutoff | 20 | 37.5 | 20 | 0 | 100% |
| +75% Cutoff | 20 | 44 | 20 | 0 | 100% |

19

| | Number
of
samples | Phencyclidine
Concentration by GC/MS
(ng/mL) | Lay person results | | The |
|-------------|-------------------------|----------------------------------------------------|--------------------|--------------------|-----------------------------------------|
| % of Cutoff | | | No. of
Positive | No. of
Negative | percentage of
correct results
(%) |
| -100%Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75%Cutoff | 20 | 6 | 0 | 20 | 100% |
| -50% Cutoff | 19 | 12.5 | 0 | 19 | 100% |
| -25% Cutoff | 20 | 19 | 1 | 19 | 95% |
| +25% Cutoff | 20 | 31 | 19 | 1 | 95% |
| +50% Cutoff | 20 | 37.5 | 20 | 0 | 100% |
| +75% Cutoff | 20 | 44 | 20 | 0 | 100% |

Comparison between GC/MS and Lay Person Results (Phencyclidine Cassette)

Comparison between GC/MS and Lay Person Results (Phencyclidine DipCard)

| | Number
of
samples | Phencyclidine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|-------------|-------------------------|----------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| % of Cutoff | of
samples | Phencyclidine
Concentration by GC/MS
(ng/mL) | No. of
Positive | No. of
Negative | The
percentage of
correct results
(%) |
| -100%Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75%Cutoff | 20 | 6 | 0 | 20 | 100% |
| -50% Cutoff | 20 | 12.5 | 0 | 20 | 100% |
| -25% Cutoff | 20 | 19 | 2 | 18 | 90% |
| +25% Cutoff | 20 | 31 | 18 | 2 | 90% |
| +50% Cutoff | 20 | 37.5 | 20 | 0 | 100% |
| +75% Cutoff | 19 | 44 | 19 | 0 | 100% |

Comparison between GC/MS and Lay Person Results (Phencyclidine Cup)

| % of Cutoff | Number
of
samples | Phencyclidine
Concentration by GC/MS
(ng/mL) | Lay person results | | The |
|-------------|-------------------------|----------------------------------------------------|--------------------|--------------------|-----------------------------------------|
| | | | No. of
Positive | No. of
Negative | percentage of
correct results
(%) |
| -100%Cutoff | 20 | 0 | 0 | 20 | 100% |
| -75%Cutoff | 20 | 6 | 0 | 20 | 100% |
| -50% Cutoff | 19 | 12.5 | 0 | 19 | 100% |
| -25% Cutoff | 20 | 19 | 2 | 18 | 90% |
| +25% Cutoff | 20 | 31 | 19 | 1 | 95% |
| +50% Cutoff | 20 | 37.5 | 20 | 0 | 100% |
| +75% Cutoff | 19 | 44 | 19 | 0 | 100% |

20

Lay-users were also given surveys on the ease of understanding the package insert instructions. All lay users indicated that the device instructions can be easily followed. A Flesch-Kincaid reading analysis was performed on each package insert and the scores revealed a reading Grade Level of 7.

    1. Clinical Studies Not applicable.
  • 11.Conclusion

Based on the test principle and acceptable performance characteristics including precision, cut-off, interference, specificity and method comparison of the devices, it's concluded that the Healgen MDMA(Ecstasy) Test, and Healgen Phencyclidine Test are substantially equivalent to the predicate.