K Number
K151441
Manufacturer
Date Cleared
2015-06-29

(31 days)

Product Code
Regulation Number
862.3620
Reference & Predicate Devices
N/A
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

First Sign™ Drug of Abuse Tests are immunochromatographic assays for the qualitative determination of Methadone, Phencyclidine, and Oxycodone in human urine at cut-off concentrations of 300 ng/mL, 25 ng/mL, and 100 ng/mL, respectively. The tests are available in a Cup format and a Dip Card format.

The tests may yield preliminary positive results even when prescription drugs Methadone and Oxycodone are ingested, at prescribed doses; it is not intended to distinguish between prescription use or abuse of this drug. There are no uniformly recognized cutoff concentration levels for Methadone and Oxycodone in urine. The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry 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. The tests are intended for over-the-counter and for prescription use.

Device Description

First Sign™ Drug of Abuse Tests are immunochromatographic assays. Each assay test is a lateral flow system for the qualitative detection of Methadone, Phencyclidine, and Oxycodone in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of DipCards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.

AI/ML Overview

The provided text describes the performance characteristics and studies for the "First Sign® Drug of Abuse Cup Test" and "First Sign® Drug of Abuse Dip Card Test" for Methadone, Phencyclidine, and Oxycodone.

The acceptance criteria for each drug are implicitly defined by the reported performance, specifically in the precision, cut-off verification, and comparison studies. For instance, in the precision study, at -100% to -25% of the cut-off, all results were expected to be negative, and at +25% to +100% of the cut-off, all results were expected to be positive, with some allowance for variation at the exact cut-off concentration.

Here's a breakdown of the requested information:

1. A table of acceptance criteria and the reported device performance

The document does not explicitly state acceptance criteria in a separate table. However, the performance tables demonstrate the device's adherence to the expected behavior around the cut-off concentrations. The "Precision" section's implied criteria are 100% correct negatives for concentrations below -25% of the cut-off, 100% correct positives for concentrations above +25% of the cut-off, and a high percentage of correct results at +/-25% and at the cut-off values. The "Cut-off" section verifies the stated cut-off values.

Table: Acceptance Criteria (Implied from Precision and Cut-off Studies) and Reported Device Performance

DrugConcentration RangeImplied Acceptance: Expected ResultReported Performance (Precision Study: Examples from Lot 1/3)
Methadone (Cut-off: 300 ng/mL)-100% to -25% Cut-off (0-225 ng/mL)Negative50-/0+ (100% Negative)
Cut-off (300 ng/mL)Mix of Positive/Negative3-/47+ or 1-/49+ (mostly Positive)
+25% to +100% Cut-off (375-600 ng/mL)Positive50+/0- (100% Positive)
Phencyclidine (Cut-off: 25 ng/mL)-100% to -25% Cut-off (0-18.75 ng/mL)Negative50-/0+ (100% Negative)
Cut-off (25 ng/mL)Mix of Positive/Negative3-/47+ or 2-/48+ (mostly Positive)
+25% to +100% Cut-off (31.25-50 ng/mL)Positive50+/0- (100% Positive)
Oxycodone (Cut-off: 100 ng/mL)-100% to -25% Cut-off (0-75 ng/mL)Negative50-/0+ (100% Negative)
Cut-off (100 ng/mL)Mix of Positive/Negative4-/46+ or 3-/47+ (mostly Positive)
+25% to +100% Cut-off (125-200 ng/mL)Positive50+/0- (100% Positive)

2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Precision Study:
    • Sample Size: For each drug and each format (Dip Card/Cup), 8 concentrations were tested across 3 lots, with samples run 2 times per day for 25 days by 3 different operators. This is not a simple count of unique clinical samples. It uses spiked samples. Each individual concentration point (e.g., -100% cut-off) had 50 measurements (2 tests/day * 25 days by each of 3 lots, but the values are given as 50-/0+ or 50+/0- for each lot, suggesting 50 replicates per lot at each concentration).
    • Data Provenance: The samples were "prepared by spiking drug in negative samples." The document does not specify the country of origin, but the testing was conducted "in-house." These are prospective, laboratory-prepared samples.
  • Cut-off Verification Study:
    • Sample Size: 150 samples ("equally distributed at concentrations of -50% cut-off; cut-off; +25% cut-off; +50% cut-off"). These were tested using three different lots of each device by three different operators.
    • Data Provenance: Similar to precision study, these were laboratory-prepared samples ("spiked drug in negative samples"). No country of origin is specified.
  • Comparison Studies (Clinical Samples):
    • Sample Size: 80 "unaltered clinical samples" for each drug (40 negative and 40 positive). This means 80 samples for Methadone, 80 for Phencyclidine, and 80 for Oxycodone, for both Dip Card and Cup formats (though the tables suggest the same samples were likely used for both formats for a given viewer).
    • Data Provenance: "in-house" studies, using "unaltered clinical samples." The origin of these clinical samples is not specified (e.g., country, retrospective/prospective).
  • Lay-user Study:
    • Sample Size: 280 lay persons for Methadone, 280 for Phencyclidine, and 280 for Oxycodone devices. Each participant received 1 blind-labeled sample. The samples themselves were prepared at 7 different concentrations, with 20 samples per concentration. This means a total of 140 samples for each drug (7 concentrations * 20 samples/concentration) were tested by the lay-users.
    • Data Provenance: "Urine samples were prepared... by spiking drugs into drug free-pooled urine specimens." The study was performed "at three intended user sites." No country of origin is specified. These are prospective, laboratory-prepared samples.

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)

  • Precision, Cut-off, and Lay-user Studies (Spiked Samples): The ground truth was established by the precise spiking of drugs into negative urine samples at known concentrations, confirmed by GC/MS (Gas Chromatography/Mass Spectrometry). This is an analytical chemistry method, and implicitly, the expertise lies in the laboratory personnel conducting these precise preparations and GC/MS confirmations. No further expert qualifications are provided.
  • Comparison Studies (Clinical Samples): The ground truth was established by GC/MS results for each of the 80 unaltered clinical samples per drug. No details on the number or qualifications of the GC/MS experts are provided, but GC/MS is the "preferred confirmatory method" for drug of abuse tests.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

  • Precision Study: "All sample aliquots were blind-labeled and randomized by the person who prepared samples and did not take part in the sample testing." Tests were performed by "three different operators." The results are aggregated, but no specific adjudication method among operators is explicitly described. It appears each operator's results were simply recorded.
  • Cut-off Verification Study: Tested by "three different operators." Similar to precision study, results are aggregated, no specific adjudication is mentioned.
  • Comparison Studies: "three different laboratory assistants" ("Viewer A, B, C") tested the samples. The tables show individual viewer results, followed by a list of "Discordant Results." This implies that there wasn't a formal adjudication method (like 2+1 or 3+1) in place to yield a single "device" result, but rather a comparison of each viewer's interpretation against the GC/MS ground truth.
  • Lay-user Study: Each "participant was provided with the package insert, 1 blind labeled sample and a device." The results appear to be individual lay person interpretations compared to the GC/MS ground truth, with no inter-lay user adjudication.

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

  • No, an MRMC comparative effectiveness study involving AI assistance was not done.
  • The studies involved human readers (laboratory assistants, lay-users) interpreting the device results, and these devices are immunochromatographic assays (lateral flow tests), not AI software. Therefore, there is no "AI vs without AI assistance" component to these studies.

6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

  • No, a standalone algorithm-only performance study was not done. The devices are physical tests interpreted by humans (either trained laboratory personnel or lay-users). They do not involve an algorithm separate from human interpretation.

7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)

  • For all studies (Precision, Cut-off, Comparison, Lay-user), the ground truth was established by Gas Chromatography/Mass Spectrometry (GC/MS) of the spiked or clinical urine samples. GC/MS is a highly accurate analytical method considered the gold standard for confirming drug concentrations.

8. The sample size for the training set

  • The document implies that these studies (precision, cut-off, comparison, lay-user) represent the validation of the device. It does not mention a separate "training set" in the context of machine learning or algorithm development, as this medical device is an immunoassay, not an AI/ML product. The development process for such a test would involve internal R&D and optimization, but the specific term "training set" as used in AI/ML is not applicable here.

9. How the ground truth for the training set was established

  • As a traditional immunoassay device, there is no "training set" in the AI/ML sense. The ground truth for the analytical and clinical performance studies was established using GC/MS of urine samples with known (spiked) or confirmed (clinical) drug concentrations.

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Image /page/0/Picture/1 description: The image shows the seal of the Department of Health & Human Services - USA. The seal features a stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" are arranged in a circular pattern around the eagle. The seal is black and white.

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

June 29, 2015

W.H.P.M., INC. C/O JOE SHIA MANAGER 504 E DIAMOND AVE., SUITE I GAITHERSBURG MD 20877

Re: K151441

Trade/Device Name: First Sign® Drug Of Abuse Cup Test, First Sign® Drug Of Abuse Dip Card Test Regulation Number: 21 CFR 862.3620 Regulation Name: Methadone test system Regulatory Class: II Product Code: DJR, LCM, DJG Dated: May 22, 2015 Received: May 29, 2015

Dear Joe Shia:

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 -S

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

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Indications for Use

510(k) Number (if known) K151441

Device Name First Sign® Drug of Abuse Cup Test First Sign® Drug of Abuse Dip Card Test

Indications for Use (Describe)

First Sign™ Drug of Abuse Tests are immunochromatographic assays for the qualitative determination of Methadone, Phencyclidine, and Oxycodone in human urine at cut-off concentrations of 300 ng/mL, and 100 ng/mL, respectively. The tests are available in a Cup format and a Dip Card format.

The tests may yield preliminary positive results even when prescription drugs Methadone and Oxycodone are ingested, at prescribed doses; it is not intended to distinguish between prescription use or abuse of this drug. There are no uniformly recognized cutoff concentration levels for Methadone and Oxycodone in urine. The tests provide only preliminary test results. A more specific alternative chemical must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry 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. The tests are intended for over-the-counter and for prescription use.

Type of Use (Select one or both, as applicable)
-------------------------------------------------
区 Prescription Use (Part 21 CFR 801 Subpart D)
区 Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) SUMMARY K151441

1. Date:June 26, 2015
2. SubmitterW.H.P.M., Inc.5358 Irwindale Ave.Irwindale, CA 91706
3. Contact person:John WanW.H.P.M., Inc.5358 Irwindale Ave.Irwindale, CA 91706Telephone: 626-443-8480

Fax: 626-443-8065 Email: johnwan@whpm.com

    1. Device Name: First Sign® Drug of Abuse Cup Test First Sign® Drug of Abuse Dip Card Test
Product CodeClassCFR #Panel
DJRClass II21 CFR, 862.3620 Methadone Test SystemToxicology
LCMUnclassifiedPhencyclidineToxicology
DJGClass II21 CFR, 862.3650 Opiate Test SystemToxicology
    1. Predicate Devices: K052115 First Check Multi Drug Cup 12
    1. Intended Use

First Sign™ Drug of Abuse Tests are immunochromatographic assays for the qualitative determination of Methadone, Phencyclidine, and Oxycodone in human urine at cut-off concentrations of 300 ng/mL, 25 ng/mL, and 100 ng/mL, respectively. The tests are available in a Cup format and a Dip Card format.

The tests may yield preliminary positive results even when prescription drugs Methadone and Oxycodone are ingested, at prescribed doses; it is not intended to distinguish between prescription use or abuse of this drug. There are no uniformly recognized cutoff concentration levels for Methadone and Oxycodone in urine. The tests provide only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry is the preferred confirmatory method. Clinical consideration and professional judgment

{4}------------------------------------------------

should be exercised with any drug of abuse test result, particularly when the preliminary result is positive.

For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.

7. Device Description

First Sign™ Drug of Abuse Tests are immunochromatographic assays. Each assay test is a lateral flow system for the qualitative detection of Methadone, Phencyclidine, and Oxycodone in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of DipCards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample Each test device is sealed with a desiccant in an aluminum pouch. collection.

8. Substantial Equivalence Information

A summary comparison of features of the First Sign™ Drug of Abuse Test and the predicate device is provided in Table 1, Table 2 & Table 3.

ItemDevicePredicate - K052115
Indication(s)for UseFor the qualitative determination ofMethadone in human urine.Same
CalibratorMethadoneSame
MethodologyCompetitive binding, lateral flowimmunochromatographic assays based onthe principle of antigen antibodyimmunochemistry.Same
Specimen TypeHuman UrineSame
Cut-Off Values300 ng/mLSame
IntendedPopulationFor over-the-counter and prescriptionuses.For over-the-counter use.
ConfigurationsCup, Dip CardCup

Table 1: Features Comparison of First Sign™ Methadone Test and the Predicate Device

Table 2: Features Comparison of First Sign™ Phencyclidine Test and the Predicate Device

ItemDevicePredicate - K052115
Indication(s)for UseFor the qualitative determination ofPhencyclidine in human urine.Same
CalibratorPhencyclidineSame
MethodologyCompetitive binding, lateral flowSame

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ItemDevicePredicate - K052115
immunochromatographic assays basedon the principle of antigen antibodyimmunochemistry.
Specimen TypeHuman UrineSame
Cut-Off Values25 ng/mLSame
IntendedPopulationFor over-the-counter and prescriptionuses.For over-the-counteruse.
ConfigurationsCup, Dip CardCup

Table 3: Features Comparison of First Sign™ Oxycodone Test and the Predicate Device

ItemDevicePredicate - K052115
Indication(s)for UseFor the qualitative determination ofOxycodone in human urine.Same
CalibratorOxycodoneSame
MethodologyCompetitive binding, lateral flowimmunochromatographic assays basedon the principle of antigen antibodyimmunochemistry.Same
Specimen TypeHuman UrineSame
Cut-Off Values100 ng/mLSame
IntendedFor over-the-counter and prescriptionFor over-the-counter
Populationuses.use.
ConfigurationsCup, Dip CardCup

9. Test Principle

First Sign™ Drug of Abuse Tests are rapid tests for the qualitative detection of Methadone, Phencyclidine, and Oxycodone 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 colored line will not form in the test line region if the target drug level exceeds its cutoff concentration 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.

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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 each format of devices. Different set of operators tested each format. The results obtained are summarized in the following tables:
Result-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
Drug
Lot 150-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+1-/49+50+/0-50+/0-50+/0-50+/0-

Methadone Dip Card Format

Methadone Cup Format

Drug-100% Cut-off-75% Cut-off-50% Cut-off-25% Cut-off+25% Cut-off+50% Cut-off+75% Cut-off+100% Cut-off
Lot 450-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-
Lot 550-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-
Lot 650-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-

Phencyclidine Dip Card Format

Result-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
Drug
Lot 150-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+2-/48+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+2-/48+50+/0-50+/0-50+/0-50+/0-

Phencyclidine Cup Format

Result-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
DrugLot 450-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
DrugLot 550-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
DrugLot 650-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-

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DrugResultCut-off
-100%Cut-off-75%Cut-off-50%Cut-off-25%Cut-off+25%Cut-off+50%Cut-off+75%Cut-off+100%Cut-off
Lot 150-/0+50-/0+50-/0+50-/0+4-/46+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Oxycodone Cup Format
DrugResultCut-off
-100%Cut-off-75%Cut-off-50%Cut-off-25%Cut-off+25%Cut-off+50%Cut-off+75%Cut-off+100%Cut-off
Lot 450-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Lot 550-/0+50-/0+50-/0+50-/0+3-/47+50+/0-50+/0-50+/0-50+/0-
Lot 650-/0+50-/0+50-/0+50-/0+2-/48+50+/0-50+/0-50+/0-50+/0-

Oxycodone Dip Card Format

b. Linearity

Not applicable.

c. Stability

The devices are stable at 4-30°C (39-86°F) for 24 months based on the accelerated stability study at 50°C. 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; cutoff; +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 Methadone, Phencyclidine and Oxycodone. The following cut-off values for the test devices have been verified.

TestCalibratorCut-off (ng/mL)
First Sign™ Methadone TestMethadone300
First Sign™ Phencyclidine TestPhencyclidine25
First Sign™ Oxycodone TestOxycodone100

e. Interference

Potential interfering substances found in human urine of physiological or pathological conditions were added to drug-free urine and to urine containing target drugs at 25% below and 25% above cut-off levels. These urine samples were tested using three batches of each device for all formats.

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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.

AminopyrineEthyl-p-aminobenzoatePapaverine
AmitryptylineFenoprofenPenicillin-G
AmobarbitalFurosemidePentazocine hydrochloride
AmoxicillinGentisic acidPentobarbital
AmpicillinHemoglobinPerphenazine
L-Ascorbic acidHydralazinePhencyclidine
DL-Amphetamine sulfateHydrochlorothiazidePhenelzine
ApomorphineHydrocodonePhenobarbital
AspartameHydrocortisonePhentermine
AtropineO-Hydroxyhippuric acidL-Phenylephrine
Benzilic acidp-Hydroxyamphetamineβ-Phenylethylamine
Benzoic acidp-HydroxymethamphetaminePhenylpropanolamine
Benzoylecgonine3-HydroxytyraminePrednisolone
BenzphetamineIbuprofenPrednisone
BilirubinImipramineProcaine
CaffeineIproniazidPromazine
Cannabidiol(±) - IsoproterenolPromethazine
CannabinolIsoxsuprineDL-Propranolol
ChloralhydrateKetamineD-Propoxyphene
ChloramphenicolKetoprofenD-Pseudoephedrine
ChlorothiazideLabetalolQuinacrine
ChlorpromazineLevorphanolQuinidine
ChlorquineLoperamideQuinine
CholesterolMaprotilineRanitidine
ClomipramineMeperidineSalicylic acid
ClonidineMeprobamateSecobarbital
CocaethyleneMethamphetamineSerotonin
TemazepamMethoxyphenamineSulfamethazine
Cocaine hydrochloride(±)-3,4-Methylenedioxy- amphetamine hydrochlorideSulindac
Codeine(±)-3,4-Methylenedioxy- methamphetamine hydrochlorideTetracycline
CortisoneMorphine-3-β-D glucuronideTetrahydrocortisone 3- (β-D-glucuronide)
(-) CotinineMorphine SulfateTetrahydrozoline
CreatinineNalidixic acidThebaine
DeoxycorticosteroneNaloxoneThiamine
DextromethorphanNaltrexoneThioridazine
DiazepamNaproxenDL-Tyrosine
DiclofenacNiacinamideTolbutamide
DiflunisalNifedipineTriamterene
DigoxinNorcodeinTrifluoperazine
DiphenhydramineNorethindroneTrimethoprim
Ecgonine hydrochlorideD-NorpropoxypheneTrimipramine
Ecgonine methyl esterNoscapineTryptamine
(-) -Ψ -EphedrineDL-OctopamineDL-Tryptophan
[1R,2S] (-) EphedrineOxalic acidTyramine
(L) - EpinephrineOxazepamUric acid
ErythromycinOxolinic acidVerapamil
β-EstradiolOxycodoneZomepirac
Estrone-3-sulfateOxymetazoline

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Phencyclidine

Acetaminophen(+) EphedrineOxycodone
AcetophenetidinErythromycinOxymetazoline
N-Acetylprocainamideβ-EstradiolPapaverine
Acetylsalicylic acidEstrone-3-sulfatePenicillin-G
AminopyrineEthyl-p-aminobenzoatePentazocine hydrochloride
AmitryptylineFenoprofenPentobarbital
AmobarbitalFurosemidePerphenazine
AmoxicillinGentisic acidPhenelzine
AmpicillinHemoglobinPhenobarbital
Ascorbic acidHydralazinePhentermine
D,L-AmphetamineHydrochlorothiazideL-Phenylephrine
Apomorphine acidHydrocodoneβ-Phenylethylamine
AspartameHydrocortisonePhenylpropanolamine
AtropineO-HydroxyhippuricPrednisolone
Benzilic acidp-HydroxymethamphetaminePrednisone
Benzoic acid3-HydroxytyramineProcaine
BenzoylecgonineIbuprofenPromazine
BenzphetamineImipraminePromethazine
BilirubinIproniazidD,L-Propanolol
Brompheniramine(±) - IsoproterenolD-Propoxyphene
CaffeineIsoxsuprineD-Pseudoephedrine
CannabidiolKetamineQuinidine
CannabinolKetoprofenQuinine

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ChloralhydrateLabetalolRanitidine
ChloramphenicolLoperamideSalicylic acid
ChlordiazepoxideMaprotilineSecobarbital
ChlorothiazideMeperidineSerotonin (5-Hydroxytyramine)
(+) ChlorpheniramineMeprobamateSulfamethazine
ChlorpromazineMethadoneSulindac
ChlorquineMethoxyphenamineTemazepam
Cholesterol(+) 3,4-Methylenedioxy-amphetamineTetracycline
Clomipramine(+)3,4-Methylenedioxy-methamphetamineTetrahydrocortisone3 (β-Dglucuronide)
ClonidineMorphine-3-β-D glucuronideTetrahydrozoline
Cocaine hydrochlorideMorphine SulfateThiamine
CodeineNalidixic acidThioridazine
CortisoneNaloxoneD, L-Tyrosine
(-) CotinineNaltrexoneTolbutamide
CreatinineNaproxenTriamterene
DeoxycorticosteroneNiacinamideTrifluoperazine
DextromethorphanNifedipineTrimethoprim
DiazepamNorcodeinTrimipramine
DiclofenacNorethindroneTryptamine
DiflunisalD-NorpropoxypheneD, L-Tryptophan
DigoxinNoscapineTyramine
DiphenhydramineD,L-OctopamineUric acid
DoxylamineOxalic acidVerapamil
Ecgonine hydrochlorideOxazepamZomepirac
Ecgonine methylesterOxolinic acid

Oxycodone

AcetophenetidinEthyl-p-aminobenzoatePapaverine
Acetylsalicylic acidβ-EstradiolPenicillin-G
AminopyrineEstrone-3-sulfatePerphenazine
AmoxicillinErythromycinPhenelzine
AmpicillinFenoprofenL-Phenylephrine
ApomorphineFurosemideβ-Phenylethylamine
AspartameGentisic acidPhenylpropanolamine
AtropineHemoglobinPrednisone
Benzilic acidHydralazineLoperamide

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Benzoic acidHydrochlorothiazideQuinine
BenzphetamineHydrocortisoneQuinidine
BilirubinO-Hydroxyhippuric acidRanitidine
Deoxycorticosterone3-HydroxytyramineSalicylic acid
CaffeineLabetalolSerotonin
ChloralhydrateD, L-IsoproterenolSulfamethazine
ChloramphenicolMeprobamateSulindac
ChlorothiazideMethoxyphenamineTetracycline
D,L-ChlolrpheniramineNalidixic acidTetrahydrocortisone
ChlorpromazineNaloxoneMorphine-3-β-D-glucuronide
ChlorquineNaltrexoneTetrahydrozoline
CholesterolNaproxenThiamine
ClonidineNiacinamideThioridazine
L-CotinineNifedipineD,L-Tyrosine
CortisoneIsoxsuprineTolbutamide
CreatinineD,L-PropanololTriamterene
D-PseudoephedrineKetoprofenTrifluoperazine
DextromethorphanNorethindroneTrimethoprim
DiclofenacD-NorpropoxypheneTyramine
DiflunisalNoscapineD,L-Tryptophan
DigoxinD,L-OctopamineUrine acid
DiphenhydramineOxalic acidVerapamil
L-EphedrineOxolinic acidZomepirac
Ecgonine methylesterOxymetazoline

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.

MethadoneCut-off=300 ng/mLResult%Cross-Reactivity
MethadonePositive at 300 ng/mL100%
LAAMPositive at 100003%
Alpha MethadolNegative at 100000Not Detected

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DoxylamineNegative at 100000Not Detected
EMDPNegative at 100000Not Detected
EDDPNegative at 100000Not Detected
PhencyclidineCut-off=25 ng/mL)Result% Cross-Reactivity
PhencyclidinePositive at 25 ng/mL100%
4-HydroxyphencyclidinePositive at 250 ng/mL10%
Phencyclidine MorpholinePositive at 625 ng/mL4%
OxycodoneResult% Cross-
Cut-off=100 ng/mLReactivity
OxycodonePositive at 100 ng/mL100%
DihydrocodeinePositive at 50000 ng/mL0.2%
HydrocodonePositive at 10000 ng/mL1%
HeroinNegative at 100000Not Detected
Morphine-3-b-glucuronideNegative at 100000Not Detected
CodeineNegative at 100000Not Detected
HydromorphoneNegative at 100000Not Detected
MorphineNegative at 100000Not Detected
AcetylmorphineNegative at 100000Not Detected
BuprenorphineNegative at 100000Not Detected
EthylmorphineNegative at 100000Not Detected

g. Effect of Urine Specific Gravity and Urine pH

To investigate the effect of urine specific gravity and urine pH, urine samples with a range of 1.000 to 1.035 specific gravity or urine samples with a range of 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.

2. Comparison Studies

The method comparison studies for the First Sign™ Drug Tests (Cup and Dip Card) for Methadone, Phencyclidine, and Oxycodone 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

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samples for each drug. The samples were blind labeled and compared to GC/MS results. The results are presented in the tables below:

Methadone
Dip CardformatNegativeLowNegativeby GC/MS(less than -50%)Near CutoffNegative byGC/MS(Between -50% andcut-off)NearCutoffPositive byGC/MS(Betweenthe cut-offand +50%)HighPositive byGC/MS(greaterthan +50%)
Viewer APositive0001226
Negative10102020
Viewer BPositive0011326
Negative10101910
Viewer CPositive0011326
Negative10101910

Discordant Results of Methadone Dip Card

ViewerSample NumberGC/MS ResultDipcard FormatViewer Results
Viewer A83001724325Negative
Viewer A83001691337Negative
Viewer B94639074353Negative
Viewer B83001695274Positive
Viewer C83002140366Negative
Viewer C83002176289Positive
CupformatNegativeLowNegativeby GC/MS(less than -50%)Near CutoffNegative byGC/MS(Between -50% andcut-off)NearCutoffPositive byGC/MS(Betweenthe cut-offand +50%)HighPositive byGC/MS(greaterthan +50%)
Viewer APositive0011326
Negative10101910
Viewer BPositive0011326
Negative10101910
Viewer CPositive0011226
Negative10101920

Discordant Results of Methadone Cup

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ViewerSample NumberGC/MS ResultCup FormatViewer Results
Viewer A83001695274Positive
Viewer A83001691337Negative
Viewer B83002176289Positive
Viewer B83001707331Negative
Viewer C83002164242Positive
Viewer C83001724325Negative
Viewer C94639074353Negative

Phencyclidine

Dip CardformatNegativeLowNegativeby GC/MS(less than -50%)Near CutoffNegative byGC/MS(Between -50% andcut-off)NearCutoffPositive byGC/MS(Betweenthe cut-offand +50%)HighPositive byGC/MS(greaterthan +50%)
Viewer APositive0011326
Negative10101910
Viewer BPositive0011326
Negative10101910
Viewer CPositive0001226
Negative10102020

Discordant Results of Phencyclidine DipCard

ViewerSample NumberGC/MS ResultDipCard FormatViewer Results
Viewer A8300201520.6Positive
Viewer A8300208527.9Negative
Viewer B8300196821.4Positive
Viewer B8300202928.3Negative
Viewer C8300208527.9Negative
Viewer C8300206228.7Negative
CupformatNegativeLowNegativeby GC/MS(less than -50%)Near CutoffNegative byGC/MS(Between -50% andcut-off)NearCutoffPositive byGC/MSHighPositive byGC/MS(greaterthan +50%)
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------

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(Betweenthe cut-offand +50%)
Viewer APositive0021326
Negative10101810
Viewer BPositive0001226
Negative10102020
Viewer CPositive0001326
Negative10102010

Discordant Results of Phencyclidine Cup

ViewerSample NumberGC/MS ResultCup FormatViewer Results
Viewer A8300201520.6Positive
Viewer A8300178021.3Positive
Viewer A8300207729.3Negative
Viewer B8300208527.9Negative
Viewer B8300202928.3Negative
Viewer C8300197827.7Negative

Oxycodone

DipCardformatNegativeLowNegativeby GC/MS(less than -50%)Near CutoffNegative byGC/MS(Between -50% and cut-off)Near CutoffPositive byGC/MS(Betweenthe cut-offand +50%)HighPositive byGC/MS(greaterthan+50%)
Viewer APositive00213
Negative10101810
Viewer BPositive0001226
Negative10102020
Viewer CPositive0011326
Negative10101910

Discordant Results of Oxycodone DipCard

ViewerSample NumberGC/MS ResultDipCard FormatViewer Results
Viewer A8300209589Positive
Viewer A8300204099Positive

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Viewer A83001639120Negative
Viewer B83001639120Negative
Viewer B83002092116Negative
Viewer C9463901185Positive
Viewer C83002092116Negative
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 APositive0011226
Negative10101920
Viewer BPositive0021326
Negative10101810
Viewer CPositive0001226
Negative10102020

Discordant Results of Oxycodone Cup

ViewerSample NumberGC/MS ResultCup FormatViewer Results
Viewer A8300209589Positive
Viewer A83001639120Negative
Viewer A83002092116Negative
Viewer B8300209685Positive
Viewer B8300204099Positive
Viewer B83001638117Negative
Viewer C83001639120Negative
Viewer C83001638117Negative

Lay-user study

A lay user study was performed at three intended user sites with 280 lay persons testing the Methadone devices, 280 lay persons testing the Phencyclidine devices and 280 lay persons testing the Oxycodone devices. A total of 136 females and 144 males tested the Methadone samples, 141 females and 139 males tested Phencyclidine samples, and 141 females and 139 males tested the Oxycodone 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

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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.

% of CutoffNumberofsamplesMethadoneConcentration by GC/MS(ng/mL)Lay person resultsThepercentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100%
-75% Cutoff2074020100%
-50% Cutoff20148020100%
-25% Cutoff2022221890%
+25% Cutoff2037819195%
+50% Cutoff20452200100%
+75% Cutoff20530200100%

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

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

% of CutoffNumber of samplesMethadone Concentration by GC/MS (ng/mL)Lay person resultsThe percentage of correct results (%)
-100% Cutoff200No. of Positive 0No. of Negative 20100%
-75% Cutoff2074No. of Positive 0No. of Negative 20100%
-50% Cutoff20148No. of Positive 0No. of Negative 20100%
-25% Cutoff20222No. of Positive 1No. of Negative 1995%
+25% Cutoff20378No. of Positive 19No. of Negative 195%
+50% Cutoff20452No. of Positive 20No. of Negative 0100%
+75% Cutoff20530No. of Positive 20No. of Negative 0100%

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

NumberPhencyclidineConcentration by GC/MS(ng/mL)Lay person resultsThe
% of CutoffofsamplesNo. ofPositiveNo. ofNegativepercentage ofcorrect results(%)
-100% Cutoff200020100%
-75% Cutoff206020100%
-50% Cutoff2012.2020100%
-25% Cutoff2019020100%
+25% Cutoff2031.319195%
+50% Cutoff2037200100%
+75% Cutoff2044200100%

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% of CutoffNumber of samplesPhencyclidineConcentration by GC/MS(ng/mL)Lay person resultsThepercentage ofcorrect results(%)
-100% Cutoff200020100%
-75% Cutoff206020100%
-50% Cutoff2012.2020100%
-25% Cutoff2019020100%
+25% Cutoff2031.318290%
+50% Cutoff2037200100%
+75% Cutoff2044200100%

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

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

NumberOxycodoneLay person resultsThe
% of CutoffofsamplesConcentration by GC/MS(ng/mL)No. ofPositiveNo. ofNegativepercentage ofcorrect results(%)
-100%Cutoff200020100%
-75%Cutoff2024020100%
-50% Cutoff2049020100%
-25% Cutoff2074119તે તે જેવી 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% Cutoff20124191તે તે જેની જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામમાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામમાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી ત
+50% Cutoff20148200100%
+75% Cutoff20173200100%

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

% of CutoffNumberofsamplesOxycodoneConcentration by GC/MS(ng/mL)Lay person resultsThepercentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100%
-75% Cutoff2024020100%
-50% Cutoff2049020100%
-25% Cutoff207411995%
+25% Cutoff2012419195%
+50% Cutoff20148200100%
+75% Cutoff20173200100%

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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.
    1. 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 First Sign™ Drug of Abuse Dip Card Test and First Sign™ Drug of Abuse Cup Test are substantially equivalent to the predicate.

§ 862.3620 Methadone test system.

(a)
Identification. A methadone test system is a device intended to measure methadone, an addictive narcotic pain-relieving drug, in serum and urine. Measurements obtained by this device are used in the diagnosis and treatment of methadone use or overdose and to determine compliance with regulations in methadone maintenance treatment.(b)
Classification. Class II (special controls). A methadone 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).