K Number
K151771
Date Cleared
2016-01-05

(189 days)

Product Code
Regulation Number
862.3170
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Immunalysis Benzodiazepines Urine Enzyme Immunoassay is a homogeneous enzyme immunoassay with a cutoff of 200ng/mL. The assay is intended for use in laboratories for the qualitative and semi-quantitative analysis of Benzodiazepines in human urine with automated clinical chemistry analyzers. This assay is calibrated against Oxazepam. This in-vitro device is for prescription use only.

The semi-quantitative mode is for purposes of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as Gas Chromatography/ Mass Spectrometry (GC-MS) or permitting laboratories to establish quality control procedures.

The Immunalysis Benzodiazepines Urine Enzyme Immunoassay Kit provides only a preliminary analytical test result. A more specific alternate chemical must be used in order to obtain a confirmed analytical result. GC-MS or Liquid Chromatography / Mass Spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are used.

The Immunalysis Multi-Drug Calibrators are intended for in vitro diagnostic use for the calibration of assays for the analytes currently listed in the package insert: Benzoylecgonine, Morphine and Oxazepam. The calibrators are designed for prescription use with immunoassays.

Device Description

The assay consists of antibody/ substrate reagent and enzyme conjugate reagent. The antibody/ substrate reagent includes monoclonal antibodies to Benzodiazepine, glucose-6-phosphate (G6P) and nicotinamide adenine dinucleotide (NAD) in HEPES buffer with Sodium Azide as a preservative. The enzyme conjugate reagent includes Benzodiazepines derivative labeled with glucose-6-phosphate dehydrogenase (G6PDH) in HEPES buffer with Sodium Azide as a preservative.

All of the Immunalysis Multi-Drug Calibrators are liquid and ready to use. Each contains a known concentration of a specific drug analyte as a mixture.

The negative calibrator is a processed, drug-free synthetic urine matrix with sodium azide as a preservative. The Level 1, 2, 3 and 4 calibrators are prepared by spiking known concentrations of drug analyte into the negative calibrator matrix. These five calibrators (negative, Level 1, 2, 3 and 4) are sold as individual bottles.

AI/ML Overview

Here's an analysis of the acceptance criteria and the studies performed for the Immunalysis Benzodiazepines Urine Enzyme Immunoassay, based on the provided text:

1. Table of Acceptance Criteria and Reported Device Performance

The document does not explicitly state acceptance criteria in a quantitative format for all aspects of the testing. However, we can infer the performance expectations from the study descriptions and reported results. The core acceptance for qualitative and semi-quantitative results (positive/negative determination around the cutoff) is that the device should accurately classify samples at various concentrations relative to the 200 ng/mL cutoff, and not be significantly affected by common interferents or physiological variations. For cross-reactivity, it's expected that related compounds will show a response, ideally correlating with their known activity, and unrelated compounds should not cause false positives.

Acceptance Criteria (Inferred)Reported Device Performance
Precision/Cutoff Characterization (Qualitative)
- Samples ≤ 150 ng/mL (negative region) should be Negative.Table 3: All 80 determinations at 0, 50, 100, 150 ng/mL were Negative.
- Samples ≥ 250 ng/mL (positive region) should be Positive.Table 3: All 80 determinations at 250, 300, 350, 400 ng/mL were Positive.
- Samples at 200 ng/mL (cutoff) should show a mixed result, ideally around 50% positive/negative (reflecting assay variability).Table 3: At 200 ng/mL, 37 Negative / 43 Positive (46.25% Negative / 53.75% Positive), indicating appropriate cutoff characterization.
Precision/Cutoff Characterization (Semi-Quantitative)
- Samples ≤ 150 ng/mL (negative region) should be Negative.Table 4: All 80 determinations at 0, 50, 100, 150 ng/mL were Negative.
- Samples ≥ 250 ng/mL (positive region) should be Positive.Table 4: All 80 determinations at 250, 300, 350, 400 ng/mL were Positive.
- Samples at 200 ng/mL (cutoff) should show a mixed result, ideally around 50% positive/negative.Table 4: At 200 ng/mL, 34 Negative / 46 Positive (42.5% Negative / 57.5% Positive), indicating appropriate cutoff characterization.
Specificity/Cross-Reactivity
- Structurally similar compounds should show cross-reactivity at expected levels.Tables 5 & 6: Shows varying cross-reactivity (e.g., Lorazepam 333.3%, Diazepam 200%, Clonazepam 111.1%), which is expected for benzodiazepines and their metabolites. Many compounds tested POS.
- Structurally unrelated compounds should not interfere (no false positives/negatives at ±25% cutoff).Table 7: All 109 structurally unrelated compounds tested at 100,000 ng/mL (or 500,000 ng/mL for some) showed Negative results at -25% Cutoff (150 ng/mL) and Positive results at +25% Cutoff (250 ng/mL) for both qualitative and semi-quantitative modes, indicating no interference.
- Endogenous compounds should not interfere.Table 8: All 15 endogenous compounds tested at high concentrations showed Negative results at -25% Cutoff (150 ng/mL) and Positive results at +25% Cutoff (250 ng/mL) for both qualitative and semi-quantitative modes, indicating no interference.
- Urine pH range (3.0-11.0) should not interfere.Table 11: No positive or negative interference observed across the entire pH range of 3.0 to 11.0 at ±25% of the cutoff.
- Urine specific gravity range (1.000-1.030) should not interfere.Table 12: No positive or negative interference observed across the entire specific gravity range of 1.000 to 1.030 at ±25% of the cutoff.
Linearity/Recovery
- Device should show consistent recovery across a range of spiked concentrations (typically within ±20% of expected).Table 13: Recovery ranged from 94.2% to 106.8% across expected concentrations from 100 ng/mL to 1100 ng/mL, demonstrating good linearity and recovery.
Method Comparison (Qualitative) vs. LC/MS
- High agreement with LC/MS confirmation for positive and negative samples.Table 14 & 15: 42 true positives, 0 false positives, 1 false negative, 43 true negatives. Agreement for qualitative positive samples (≥200ng/mL by LC/MS results) was 100% (42/42 samples correctly identified as positive by the device). Agreement for qualitative negative samples (<200ng/mL by LC/MS results) was 98% (43/44 samples correctly identified as negative by the device).
Method Comparison (Semi-Quantitative) vs. LC/MS
- High agreement with LC/MS confirmation for positive and negative samples.Table 16: (Table is identical to qualitative, implying the same results for semi-quantitative in terms of classification) Agreement for semi-quantitative positive samples (≥200ng/mL by LC/MS results) was 100% (42/42 samples correctly identified as positive by the device). Agreement for semi-quantitative negative samples (<200ng/mL by LC/MS results) was 98% (43/44 samples correctly identified as negative by the device).
Boric Acid InterferenceBoric acid should not cause false negative results (implied from other interference studies not causing issues).
Table 9 & 10: Boric Acid at 1% w/v was found to cause false negative results at ±25% and ±50% of the cutoff. This indicates a failure to meet the implied non-interference criteria, leading to a labeling limitation.

2. Sample Size Used for the Test Set and the Data Provenance

  • Precision/Cutoff Characterization (Tables 3 & 4): 80 determinations for each concentration level (0, 50, 100, 150, 200, 250, 300, 350, 400 ng/mL). Given 20 days, 2 runs per day in duplicate, this means 20 days * 2 runs * 2 duplicates = 80 determinations. These were spiked drug-free urine samples.
  • Specificity and Cross-Reactivity (Tables 5 & 6): For each of the approximately 30 structurally related compounds, a "Result" (POS/NEG) is reported at a specific "Concentration Tested." The exact number of determinations per compound is not explicitly stated but is typically multiple replicates. The samples were drug-free urine spiked with the respective compounds.
  • Interference (Structurally Unrelated Compounds - Table 7): For each of the approximately 109 compounds, tests were performed at two concentrations (-25% and +25% of cutoff). The exact number of determinations is not specified. Samples were drug-free urine containing oxazepam at ±25% of the cutoff, spiked with the interferent.
  • Interference (Endogenous Compounds - Table 8): For each of the approximately 15 compounds, tests were performed at two concentrations (-25% and +25% of cutoff). The exact number of determinations is not specified. Samples were drug-free urine containing oxazepam at ±25% of the cutoff, spiked with the interferent.
  • Interference (Boric Acid - Tables 9 & 10): Tests were performed at ±25% and ±50% of the cutoff with 1% w/v Boric Acid. The exact number of determinations is not specified. Samples were drug-free urine containing oxazepam at these levels.
  • Interference (pH - Table 11): Tests were performed at 9 different pH values (3.0-11.0) at ±25% of the cutoff. The exact number of determinations is not specified. Samples were drug-free urine containing oxazepam at these levels.
  • Interference (Specific Gravity - Table 12): Tests were performed at 8 different specific gravity values (1.000-1.030) at ±25% of the cutoff. The exact number of determinations is not specified. Samples were drug-free urine containing oxazepam at these levels.
  • Linearity/Recovery (Table 13): 11 different concentrations were tested, each "in triplicate."
  • Method Comparison (Tables 14-16): 80 "unaltered, anonymous and discarded clinical urine samples."
    • Data Provenance: The Method Comparison study used "unaltered, anonymous and discarded clinical urine samples obtained from clinical testing laboratories." This implies retrospective data from (presumably) US clinical labs. All other studies (Precision, Specificity, Interference, Linearity) used artificially prepared samples (drug-free urine spiked with controlled concentrations of analytes/interferents).

3. Number of Experts Used to Establish the Ground Truth for the Test Set and the Qualifications of Those Experts

This type of in-vitro diagnostic device (IVD) study does not typically involve human experts to establish ground truth in the way medical imaging or pathology studies do. The ground truth for drug presence and concentration in urine samples is established using analytical gold standards like Mass Spectrometry (MS), specifically Gas Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Mass Spectrometry (LC/MS). These are laboratory techniques, not expert human interpretation.

4. Adjudication Method for the Test Set

Not applicable in the human expert sense. For analytical discrepancies between the device and the reference method (LC/MS in the Method Comparison study), standard laboratory protocols for investigating outliers or re-testing would be followed, but there isn't an "adjudication" by a panel of human experts.

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 was not done. This device is an automated in-vitro diagnostic (IVD) test, not an AI-assisted diagnostic imaging or interpretation tool that involves human readers. Its primary output is a quantitative or qualitative chemical result, not an image or diagnosis requiring human interpretation with or without AI assistance.

6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done

Yes, the studies presented are all standalone performance studies of the device (an immunoassay performed on an automated clinical chemistry analyzer). Its performance is evaluated directly against spiked samples or a reference method (LC/MS) without human interpretative input influencing the device's result. The output itself (positive/negative, semi-quantitative values) then requires professional judgment for clinical application, as stated in the Indications for Use, but the device's analytical performance itself is standalone.

7. The Type of Ground Truth Used

  • Mass Spectrometry (MS): For the Precision/Cutoff Characterization, "The spiked concentrations were confirmed by mass spectrometry (MS)." For the Method Comparison study, "Results were obtained... with LC/MS." This is the primary gold standard for determining the true presence and concentration of drugs/metabolites in urine.
  • Spiked Concentrations: For precision, specificity, interference, and linearity studies, known concentrations of pure compounds spiked into drug-free urine served as the ground truth.

8. The Sample Size for the Training Set

The document describes an in-vitro diagnostic assay based on immunoassay technology. Immunoassays are fundamentally different from machine learning algorithms that require "training sets." They are analytical chemical reactions with pre-defined reagents and methodologies. Therefore, the concept of a "training set" in the context of machine learning does not apply here. The device's "training" or optimization would involve chemical formulation, antibody selection, and parameter tuning during its development phase, but not a data-driven training set in the AI sense.

9. How the Ground Truth for the Training Set Was Established

As explained in point 8, the concept of a "training set" as it relates to AI is not applicable to this immunoassay device. The "ground truth" for the development and optimization of such assays relies on analytical chemistry principles, precise formulation of reagents, and verification with reference methods using samples with known, carefully prepared concentrations of analytes.

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

January 5, 2016

IMMUNALYSIS CORPORATION JOSEPH GINETE REGULATORY AFFAIRS SPECIALIST II 829 TOWNE CENTER DR POMONA CA 91767

Re: K151771

Trade/Device Name: Immunalysis Benzodiazepines Urine Enzyme Immunoassay. Immunalysis Multi-drug Calibrators Regulation Number: 21 CFR 862.3170 Regulation Name: Benzodiazepine test system Regulatory Class: II Product Code: JXM, DKB Dated: December 24, 2015 Received: December 28, 2015

Dear Mr. Ginete:

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 (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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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,

Courtney

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)

Device Name

Immunalysis Benzodiazepines Urine Enzyme Immunoassay Immunalysis Multi-Drug Calibrators

Indications for Use (Describe)

The Immunalysis Benzodiazepines Urine Enzyme Immunoassay is a homogeneous enzyme immunoassay with a cutoff of 200ng/mL. The assay is intended for use in laboratories for the qualitative and semi-quantitative analysis of Benzodiazepines in human urine with automated clinical chemistry analyzers. This assay is calibrated against Oxazepam. This in-vitro device is for prescription use only.

The semi-quantitative mode is for purposes of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as Gas Chromatography/ Mass Spectrometry (GC-MS) or permitting laboratories to establish quality control procedures.

The Immunalysis Benzodiazepines Urine Enzyme Immunoassay Kit provides only a preliminary analytical test result. A more specific alternate chemical must be used in order to obtain a confirmed analytical result. GC-MS or Liquid Chromatography / Mass Spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are used.

The Immunalysis Multi-Drug Calibrators are intended for in vitro diagnostic use for the calibration of assays for the analytes currently listed in the package insert: Benzoylecgonine, Morphine and Oxazepam. The calibrators are designed for prescription use with immunoassays.

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)
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510(k) SUMMARY

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92(c).

  • A. Contact Information
1. Manufacturer:Immunalysis Corporation
2. Contact Name:Joseph Ginete
3. Contact Title:Regulatory Affairs Specialist II
4. Address:829 Towne Center Drive Pomona, CA 91767
5. Phone:(909) 482-0840
6. Fax:(909) 482-0850
7. Email:jginete@immunalysis.com
8. Summary prepared on:December 24, 2015
  • B. Device Information
      1. Trade Name: Immunalysis Benzodiazepine Urine Enzyme Immunoassay Immunalysis Multi-Drug Calibrators
      1. Common Name: Immunalysis Benzodiazepine Urine Enzyme Immunoassay Immunalysis Multi-Drug Calibrators

C. Regulatory Information

    1. Device Classification:
    1. Regulation Number: 21 CFR862.3170 Benzodiazepine Test System

II

21 CFR 862.3200 Clinical Toxicology Calibrator

    1. Panel: Toxicology(91)
  • JXM 4. Product Code:

DKB

  • D. Legally Marketed Device to Which We are Claiming Equivalence (807.92(A)(3))
1.Predicate Device:DRI® Benzodiazepines AssayLZI Multiple Analyte Drugs of Abuse Calibratorsand Controls
2.Predicate Company:MicrogenicsLin-Zhi International, Inc.
3.Predicate K Number:K930529K051088

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  • E. Device Description
      1. The assay consists of antibody/ substrate reagent and enzyme conjugate reagent. The antibody/ substrate reagent includes monoclonal antibodies to Benzodiazepine, glucose-6-phosphate (G6P) and nicotinamide adenine dinucleotide (NAD) in HEPES buffer with Sodium Azide as a preservative. The enzyme conjugate reagent includes Benzodiazepines derivative labeled with glucose-6-phosphate dehydrogenase (G6PDH) in HEPES buffer with Sodium Azide as a preservative.
      1. All of the Immunalysis Multi-Drug Calibrators are liquid and ready to use. Each contains a known concentration of a specific drug analyte as a mixture.

The negative calibrator is a processed, drug-free synthetic urine matrix with sodium azide as a preservative. The Level 1, 2, 3 and 4 calibrators are prepared by spiking known concentrations of drug analyte into the negative calibrator matrix. These five calibrators (negative, Level 1, 2, 3 and 4) are sold as individual bottles. The concentration of drug analyte in the corresponding calibrators is summarized as follows:

Table 1 Immunalysis Multi-Drug Calibrators
AnalyteLevel 1Level 2Level 3Level 4
Benzoylecgonine150ng/mL300ng/mL500ng/mL1000ng/mL
Morphine100ng/mL300ng/mL500ng/mL1000ng/mL
PCP12.5ng/mL25ng/mL50ng/mL100ng/mL
Oxazepam100ng/mL200ng/mL500ng/mL1000ng/mL

F. Intended Use

    1. Immunalysis Benzodiazepine Urine Enzyme Immunoassay
      The Immunalysis Benzodiazepine Urine Enzyme Immunoassay is a homogeneous enzyme immunoassay with a cutoff of 200ng/mL. The assay is intended for use in laboratories for the qualitative and semi-quantitative analysis of Benzodiazepine in human urine with automated clinical chemistry analyzers. This assay is calibrated against Oxazepam. This in-vitro device is for prescription use only.

The semi-quantitative mode is for purposes of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as Gas Chromatography/ Mass Spectrometry (GC-MS) or permitting laboratories to establish quality control procedures.

The Immunalysis Benzodiazepine Urine Enzyme Immunoassay Kit provides only a preliminary analytical test result. A more specific alternate chemical method must be used in order to obtain a confirmed analytical result. GC-MS or Liquid Chromatography / Mass Spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to

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any drug of abuse test result, particularly when preliminary positive results are used.

    1. Immunalysis Multi-Drug Calibrators
      The Immunalysis Multi-Drug Calibrators are intended for in vitro diagnostic use for the calibration of assays for the analytes currently listed in the package insert: Benzoylecgonine, Morphine, PCP and Oxazepam. The calibrators are designed for prescription use with immunoassays.
  • G. Comparison of the new device with the predicate device

ItemBenzodiazepines Assay K930529Immunalysis Benzodiazepines Urine EIA
Intended UseFor the qualitative and semi-quantitative determination of the presence of Benzodiazepines in human urine at a cutoff of 200ng/mLFor the qualitative and semi-quantitative determination of the presence of Benzodiazepines in human urine at a cutoff of 200ng/mL
Type of ProductAnalytical ReagentsAnalytical Reagents
MeasuredAnalytesBenzodiazepineBenzodiazepine
Test MatrixUrineUrine
Cutoff Levels200ng/mL of Oxazepam200ng/mL of Oxazepam
Test SystemHomogeneous EnzymeImmunoassayHomogeneous Enzyme Immunoassay
MaterialsLiquid Ready-to-Use Two Reagent Assay (R1 and R2)Antibody/Substrate Reagents and Enzyme Labeled Conjugate
MassSpectroscopyConfirmationRequired for preliminary positive analytical resultsRequired for preliminary positive analytical results
AntibodySheep Polyclonal to BenzodiazepineMonoclonal antibody to Benzodiazepines
Storage2 – 8°C until expiration date2 - 8°C until expiration date
ItemLZI Multiple Analyte K051088Immunalysis Multi-Drug Calibrator
Analytebenzoylecgonine, d-methamphetamine, methadone,morphine, oxazepam,secobarbital, phencyclidine,propoxyphenebenzoylecgonine, morphine, PCP, oxazepam
MatrixUrineUrine
Calibrator Levels5 Levels – See Table 2 Below5 Levels (Negative and Level 1, 2, 3 and 4) -See Device Description Table 1
Storage2 – 8°C until expiration date2 - 8°C until expiration date

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Table 2 LZI Multiple Analyte DAU Calibrators and Controls
Multiple Analyte Calibrators
AnalyteLowCutoffIntermediateHigh
d-Methamphetamine250ng/mL500ng/mL750ng/mL1000ng/mL
Morphine1000ng/mL2000ng/mL4000ng/mL5000ng/mL
Phencyclidine12.5ng/mL25ng/mL50ng/mL100ng/mL
Benzoylecgonine75ng/mL150ng/mL300ng/mL1000ng/mL
Oxazepam100ng/mL200ng/mL500ng/mL1000ng/mL
Secobarbital100ng/mL200ng/mL500ng/mL1000ng/mL
Propoxyphene150ng/mL300ng/mL600ng/mL1000ng/mL
Methadone150ng/mL300ng/mL600ng/mL1000ng/mL
  • H. The following laboratory performance studies were performed to determine substantial equivalence of the Immunalysis Benzodiazepines Urine Enzyme Immunoassay to the predicate
      1. Precision/ Cutoff Characterization/ Reproducibility Precision/Cutoff Characterization - Study was performed for 20 days, 2 runs per day in duplicate on drug free urine (N=80) spiked with oxazepam to concentration of ±25%, ±50%, ±75%, and ±100% of the cutoff. The spiked concentrations were confirmed by mass spectrometry (MS). The study verified that the cutoff serves as a boundary between a negative and positive interpretation of a qualitative result. The instruments used for this was Beckman Coulter AU 400e.
      • a. The following is a summary table of the Qualitative Analysis for the 200ng/mL cutoff test data results.
Table 3 - Qualitative Analysis (for 200ng/mL cutoff)
Concentration (ng/mL)% of cutoff# of determinationsResult
0-100%8080 Negative
50-75%8080 Negative
100-50%8080 Negative
150-25%8080 Negative
200Cutoff8037 Neg / 43 Pos
250+25%8080 Positive
300+50%8080 Positive
350+75%8080 Positive
400+100%8080 Positive

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Table 4 - Semi-Quantitative Analysis (for 200ng/mL cutoff)
Concentration (ng/mL)% of cutoff# of determinationsResult
0-100%8080 Negative
50-75%8080 Negative
100-50%8080 Negative
150-25%8080 Negative
200Cutoff8034 Neg / 46 Pos
250+25%8080 Positive
300+50%8080 Positive
350+75%8080 Positive
400+100%8080 Positive
  • b. The following is a summary table of the Semi-Quantitative Analysis for the 200ng/mL cutoff test data results.
    1. Specificity and Cross-Reactivity Various Benzodiazepines or structurally similar compounds were spiked into drug free urine at levels that will yield a result that is equivalent to the cutoff. The study verified assay performance relative to the ability of the device to exclusively determine certain drugs, in both the qualitative and semi-quantitative modes. The instrument used for this test was a Beckman Coulter AU 400e.
ucturelly Roloted Compounds (for 200 ng/m] cutoff) - Quelitotive
below:
a. The qualitative result summary table for the 200ng/mL cutoff is outlined
Table 5 - Structurally Related Compounds (for 200 ng/mL cutoff) - Qualitative
CompoundConcentration Tested (ng/mL)ResultCross-Reactivity (%)
Oxazepam200POS100.0
Alpha-hydroxyalprazolam110POS181.8
Alprazolam120POS166.7
7-Aminoclonazepam100,000NEG< 0.002
7-Aminoflunitrazepam3,500POS5.7
7-Aminonitrazepam35,000POS0.6
Bromazepam750POS26.7
Chlordiazepoxide1,600POS12.5
Clorazepate200POS100.0
Clobazam650POS30.8
Clonazepam180POS111.1
Demoxepam5,500POS3.6
Desalkyflurazepam75POS266.7
Diazepam100POS200.0
Estazolam225POS88.9
Flunitrazepam125POS160.0
Flurazepam110POS181.8
Lorazepam60POS333.3
Lorazepam glucuronide180POS111.1
Lormetazepam50POS400.0

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IMMUNALYSIS

Table 5 - Structurally Related Compounds (for 200 ng/mL cutoff) - Qualitative
CompoundConcentration Tested (ng/mL)ResultCross-Reactivity (%)
Medazepam500POS40.0
Midazolam40POS500.0
Nitrazepam700POS28.6
Norchlordiazepoxide2,200POS9.1
Nordiazepam180POS111.1
Oxazepam glucuronide1,300POS15.4
Prazepam95POS210.5
Temazepam110POS181.8
Temazepam glucuronide700POS28.6
Triazolam50POS400.0

b. The semi-quantitative result summary table for the 200ng/mL cutoff is outlined below:

Table 6 - Structurally Related Compounds (for 200ng/mL cutoff) - Semi-Quantitative
CompoundConcentration Tested (ng/mL)ResultCross-Reactivity (%)
Oxazepam200POS100.0
Alpha-hydroxyalprazolam110POS181.8
Alprazolam120POS166.7
7-Aminoclonazepam100,000NEG< 0.002
7-Aminoflunitrazepam3,500POS5.7
7-Aminonitrazepam35,000POS0.6
Bromazepam750POS26.7
Chlordiazepoxide1,600POS12.5
Clorazepate200POS100.0
Clobazam650POS30.8
Clonazepam180POS11.1
Demoxepam5,500POS3.6
Desalkyflurazepam75POS266.7
Diazepam100POS200.0
Estazolam225POS88.9
Flunitrazepam125POS160.0
Flurazepam110POS181.8
Lorazepam60POS333.3
Lorazepam glucuronide180POS111.1
Lormetazepamરે0POS400.0
Medazepam500POS40.0
Midazolam40POS500.0
Nitrazepam700POS28.6
Norchlordiazepoxide2,200POS9.1
Nordiazepam180POS11.1
Oxazepam glucuronide1,300POS15:4
PrazepamતેરPOS210.5
Temazepam110POS181.8
Temazepam glucuronide700POS28.6
Triazolamર૦POS400.0

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IMMUNALYSIS

    1. Interference Structurally unrelated compounds were evaluated in qualitative and semi-quantitative modes by spiking the potential interferent into drug free urine containing oxazepam at ±25% of the cutoff. All potential interferents analyzed verified that assay performance is unaffected by externally ingested compounds. The instrument used for this test was a Beckman Coulter AU 400e.
    • a. The following is a table of the structurally non-similar compounds for the 200ng/mL cutoff:
Table 7 - Structurally Unrelated Compounds (for 200ng/mL cutoff)
Concentration-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
CompoundTested(ng/mL)QualitativeSemi-QuantitativeQualitativeSemi-Quantitative
4-Bromo-2,5,Dimethoxyphenethylamine100,000NegativeNegativePositivePositive
6-Acetylcodeine100,000NegativeNegativePositivePositive
6-Acetylmorphine100,000NegativeNegativePositivePositive
Acetaminophen500,000NegativeNegativePositivePositive
Acetylsalicylic Acid500,000NegativeNegativePositivePositive
Amitriptyline100,000NegativeNegativePositivePositive
Amobarbital100,000NegativeNegativePositivePositive
S-(+) Amphetamine100,000NegativeNegativePositivePositive
Benzoylecgonine500,000NegativeNegativePositivePositive
Benzylpiperazine100,000NegativeNegativePositivePositive
Buprenorphine100,000NegativeNegativePositivePositive
Bupropion100,000NegativeNegativePositivePositive
Butabarbital100,000NegativeNegativePositivePositive
Caffeine500,000NegativeNegativePositivePositive
Carbamazepine100,000NegativeNegativePositivePositive
Chlorpromazine100,000NegativeNegativePositivePositive
cis-Tramadol100,000NegativeNegativePositivePositive
Clomipramine100,000NegativeNegativePositivePositive
Cannabidiol100,000NegativeNegativePositivePositive
Cannabinol100,000NegativeNegativePositivePositive
Carisoprodol100,000NegativeNegativePositivePositive
Cocaine100,000NegativeNegativePositivePositive
Codeine100,000NegativeNegativePositivePositive
Cotinine100,000NegativeNegativePositivePositive
Cyclobenzaprine100,000NegativeNegativePositivePositive
Delta-9-THC100,000NegativeNegativePositivePositive
Desipramıne100,000NegativeNegativePositivePositive
N-desmethyltapentadol100,000NegativeNegativePositivePositive
Dextromethorphan100,000NegativeNegativePositivePositive
Dihydrocodeine100,000NegativeNegativePositivePositive
Diphenhydramine500,000NegativeNegativePositivePositive
Doxepin100,000NegativeNegativePositivePositive
Ecgonine100,000NegativeNegativePositivePositive
Ecgonine methyl ester100,000NegativeNegativePositivePositive
EDDP100,000NegativeNegativePositivePositive
Concentration-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
CompoundTested(ng/mL)QualitativeSemi-QuantitativeQualitativeSemi-Quantitative
1R,2S(-)-Ephedrine100,000NegativeNegativePositivePositive
1S,2R(+)-Ephedrine100,000NegativeNegativePositivePositive
Ethyl β-D-glucuronide100,000NegativeNegativePositivePositive
Ethylmorphine100,000NegativeNegativePositivePositive
Fenfluramine100,000NegativeNegativePositivePositive
Fentanyl100,000NegativeNegativePositivePositive
Fluoxetine100,000NegativeNegativePositivePositive
Heroin100,000NegativeNegativePositivePositive
Hexobarbital100,000NegativeNegativePositivePositive
Hydrocodone100,000NegativeNegativePositivePositive
Hydromorphone100,000NegativeNegativePositivePositive
11-hydroxy-delta-9-THC100,000NegativeNegativePositivePositive
Ibuprofen100,000NegativeNegativePositivePositive
Imipramine100,000NegativeNegativePositivePositive
Ketamine100,000NegativeNegativePositivePositive
Lamotrigine100,000NegativeNegativePositivePositive
Levorphanol Tartrate100,000NegativeNegativePositivePositive
Lidocaine100,000NegativeNegativePositivePositive
LSD100,000NegativeNegativePositivePositive
Maprotiline100,000NegativeNegativePositivePositive
(+)-MDA100,000NegativeNegativePositivePositive
MDEA100,000NegativeNegativePositivePositive
MDMA100,000NegativeNegativePositivePositive
Meperidine100,000NegativeNegativePositivePositive
Meprobamate100,000NegativeNegativePositivePositive
Methadone500,000NegativeNegativePositivePositive
S(+)-Methamphetamine100,000NegativeNegativePositivePositive
Methaquolone100,000NegativeNegativePositivePositive
Methylphenidate100,000NegativeNegativePositivePositive
Morphine100,000NegativeNegativePositivePositive
Morphine-3 -glucuronide100,000NegativeNegativePositivePositive
Morphine-6 -glucuronide100,000NegativeNegativePositivePositive
Nalorphine100,000NegativeNegativePositivePositive
Naloxone100,000NegativeNegativePositivePositive
Naltrexone100,000NegativeNegativePositivePositive
Norbuprenorphine100,000NegativeNegativePositivePositive
Norcodeine100,000NegativeNegativePositivePositive
Normorphine100,000NegativeNegativePositivePositive
Norpropoxyphene100,000NegativeNegativePositivePositive
Norpseudoephedrine100,000NegativeNegativePositivePositive
Nortriptyline100,000NegativeNegativePositivePositive
Oxycodone100,000NegativeNegativePositivePositive
Oxymorphone100,000NegativeNegativePositivePositive
Table 7 - Structurally Unrelated Compounds (for 200ng/mL cutoff)
Concentration-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
CompoundTested(ng/mL)QualitativeSemi-QuantitativeQualitativeSemi-Quantitative
PCP100,000NegativeNegativePositivePositive
Pentazocine100,000NegativeNegativePositivePositive
Pentobarbital100,000NegativeNegativePositivePositive
Phentermine100,000NegativeNegativePositivePositive
Phenobarbital100,000NegativeNegativePositivePositive
Phenylephedrine100,000NegativeNegativePositivePositive
Phenylpropanolamine100,000NegativeNegativePositivePositive
Phenytoin100,000NegativeNegativePositivePositive
PMA100,000NegativeNegativePositivePositive
Propoxyphene100,000NegativeNegativePositivePositive
Propranolol100,000NegativeNegativePositivePositive
Protriptyline100,000NegativeNegativePositivePositive
R,R(-)-Pseudoephedrine100,000NegativeNegativePositivePositive
S,S(+)-Pseudoephedrine100,000NegativeNegativePositivePositive
Ranitidine100,000NegativeNegativePositivePositive
Ritalinic Acid100,000NegativeNegativePositivePositive
Salicylic Acid100,000NegativeNegativePositivePositive
Secobarbial100,000NegativeNegativePositivePositive
Sertraline100,000NegativeNegativePositivePositive
Sufentanil Citrate100,000NegativeNegativePositivePositive
11-nor-9 carboxy THC100,000NegativeNegativePositivePositive
Theophylline100,000NegativeNegativePositivePositive
Thioridazine100,000NegativeNegativePositivePositive
Trifluoromethylphenyl-piperazine100,000NegativeNegativePositivePositive
Trimipramine100,000NegativeNegativePositivePositive
Trazodone100,000NegativeNegativePositivePositive
Venlafaxine100,000NegativeNegativePositivePositive
Zolpidem Tartrate100,000NegativeNegativePositivePositive

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b. Endogenous compounds interference was evaluated in qualitative and semi-quantitative modes by spiking the potential interferent into drug free urine containing oxazepam at ± 25% of the cutoff. All potential interferents analyzed verified that assay performance is unaffected by internally existing physiological conditions. The instrument used for this test was a Beckman Coulter AU 400e. The following is a summary table of the endogenous compounds results for the 200ng/mL cutoff:

Table 8 - Endogenous Compounds (for 200ng/mL cutoff)
CompoundConcentrationTested(ng/mL)-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
QualitativeSemi-QuantitativeQualitativeSemi-Quantitative
Acetone1.0 g/dLNegativeNegativePositivePositive
Ascorbic Acid1.5 g/dLNegativeNegativePositivePositive
Bilirubin0.002 g/dLNegativeNegativePositivePositive

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Table 8 - Endogenous Compounds (for 200ng/mL cutoff)
Concentration-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
CompoundTested(ng/mL)QualitativeSemi-QuantitativeQualitativeSemi-Quantitative
Creatinine0.5 g/dLNegativeNegativePositivePositive
Ethanol1.0 g/dLNegativeNegativePositivePositive
Galactose0.01 g/dLNegativeNegativePositivePositive
y-Globulin0.5 g/dLNegativeNegativePositivePositive
Glucose2.0 g/dLNegativeNegativePositivePositive
Hemoglobin0.115 g/dLNegativeNegativePositivePositive
Human Serum Albumin0.5 g/dLNegativeNegativePositivePositive
Oxalic Acid0.1 g/dLNegativeNegativePositivePositive
Riboflavin0.0075 g/dLNegativeNegativePositivePositive
Sodium Azide1% w/vNegativeNegativePositivePositive
Sodium Chloride6.0 g/dLNegativeNegativePositivePositive
Sodium Fluoride1% w/vNegativeNegativePositivePositive
Urea6.0 g/dLNegativeNegativePositivePositive
  • c. Boric Acid interference was also evaluated at a concentration of 1% w/v, at ±25% and ±50%of the cutoff, in both the qualitative and semiquantitative modes. The following is a summary table of the test results at ±25% of the assay cutoff of 200ng/mL:
Table 9 - Boric Acid (for 200ng/mL cutoff)
CompoundConcentration(ng/mL)-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
TestedQualitativeSemi-QuantitativeQualitativeSemi-Quantitative
Boric Acid1% w/vNegativeNegativeNegativeNegative

d. The following is a summary table of the test results at ±50% of the assay cutoff of 200ng/mL:

CompoundConcentration Tested (ng/mL)-50% Cutoff (100ng/mL)+50% Cutoff (300ng/mL)
Boric Acid1% w/vQualitative NegativeSemi-Quantitative NegativeQualitative NegativeSemi-Quantitative Negative

e. Boric Acid at a concentration of 1% w/v was found to cause false negative results at ±25% and ±50% ng/mL of the cutoff in both the qualitative and semi-quantitative modes. The following statement is provided in the Limitations section of the labeling: Boric Acid at 1%w/v may cause false negative results. Boric Acid is not recommended as a preservative for urine.

  • f. To evaluate potential interference from th pH of urine, device performance in the qualitative and semi-quantitative modes was tested using a range of urine pH values (3.0, 4.0, 5.0, 6.0, 7.0, 8.0, 9.0, 10.0 and 11.0). All test samples were prepared in drug free urine containing oxazepam at ±25% of the 200ng/mL cutoff. No positive or negative interference was observed at urine pH values ranging from 3.0 to 11.0 for

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Table 11 - Effect of pH (for 200ng/mL cutoff)
Test ParameterValue-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
Qualitative Semi-QuantitativeQualitative Semi-Quantitative
pH3.0NEGNEGPOSPOS
pH4.0NEGNEGPOSPOS
pH5.0NEGNEGPOSPOS
pH6.0NEGNEGPOSPOS
pH7.0NEGNEGPOSPOS
pH8.0NEGNEGPOSPOS
pH9.0NEGNEGPOSPOS
pH10.0NEGNEGPOSPOS
pH11.0NEGNEGPOSPOS

each test mode. The following is a summary table of the effect of pH results for the 200ng/mL cutoff:

g. To evaluate potential interference from the specific gravity of urine, device performance in the qualitative and semi-quantitative modes was tested using a range of physiologically relevant urine specific gravity values (1.000, 1.002, 1.005, 1.010, 1.015, 1.020, 1.025 and 1.030). All test samples were prepared in drug free urine containing oxazepam at ±25% of the 200ng/mL cutoff. No positive or negative interference was observed at urine specific gravity values ranging from 1.000 to 1.030 for each test mode. The following is a summary table of the effect of specific gravity results for the 200ng/mL cutoff:

Table 12 - Effect of Specific Gravity (for 200ng/mL cutoff)
Test ParameterValue-25% Cutoff (150ng/mL)+25% Cutoff (250ng/mL)
QualitativeSemi-QuantitativeQualitativeSemi-Quantitative
Specific Gravity1.000NEGNEGPOSPOS
Specific Gravity1.002NEGNEGPOSPOS
Specific Gravity1.005NEGNEGPOSPOS
Specific Gravity1.010NEGNEGPOSPOS
Specific Gravity1.015NEGNEGPOSPOS
Specific Gravity1.020NEGNEGPOSPOS
Specific Gravity1.025NEGNEGPOSPOS
Specific Gravity1.030NEGNEGPOSPOS
    1. Linearity/ Recovery A linearity study in the semi-quantitative mode was conducted by spiking a drug free urine pool with a high concentration of oxazepam as a high value specimen. Additional pools were made by serially diluting the high value specimen with drug free urine to achieve concentrations ranging from 100ng/mL to 1100ng/mL. Each pool was tested in triplicate to calculate the mean concentration values that were used to calculate drug recovery. The instrument used for this test was a Beckman Coulter AU 400e.

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Table 13 - Linearity/ Recovery
Expected Concentration (ng/mL)Mean Concentration (ng/mL)Recovery (%)
10094.294.2
200213.7106.8
300313.9104.6
400389.797.4
500511.6102.3
600637.2106.2
700693.299.0
800820.7102.6
900907.6100.8
10001025.3102.5
11001061.196.5

a. The following is a summary table of the linearity/recovery:

    1. Method Comparison Eighty unaltered, anonymous and discarded clinical urine samples obtained from clinical testing laboratories were analyzed for benzidiazepines with the candidates on a Beckman Coulter AU 400e clinical chemistry analyzer and with LC.MS. Results were obtained in both qualitative and semi-quantitative modes.
    • a. The following is a comparison table of qualitative assay performance for the 200ng/mL cutoff:

Table 14 - Method Comparison (for 200ng/mL cutoff) - Qualitative

LC/MS Confirmation
(+)(-)
TestDevice(+)420
(-)143
  • b. The following is a summary table of qualitative assay performance for the 200ng/mL cutoff:
Table 15 - Assay Performance verified by LC/MS – 200ng/mL Cutoff
TypeBenzodiazepines ConcentrationAgreement (%)
< 100ng/mL100 ~ 199 ng/mL200 ~ 300 ng/mL> 300 ng/mL
Qualitative/Positive00438100
Qualitative/Negative3671098

c. The following is a comparison table of semi-quantitative assay performance for the 200ng/mL cutoff:

Table 16 - Method Comparison (for 200ng/mL cutoff) - Semi-Quantitative LC/MS Confirmation

LC/MS Confirmation
(+)(-)
TestDevice(+)420
(-)143

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TypeBenzodiazepines ConcentrationAgreement (%)
< 100ng/mL100 ~ 199 ng/mL200 ~ 300 ng/mL> 300 ng/mL
Semi-Quantitative/ Positive00438100
Semi-Quantitative / Negative3671098
  • d. The following is a summary table of semi-quantitative assay performance for the 200ng/mI_cutoff.

6. Immunalysis Multi-Drug Calibrators Analytical Performance

  • a. Traceability all components of the calibrators have been traced to a commercially available oxazepam solution.
  • b.Closed Vial Stability (Accelerated) A closed vial stability study was performed at 25℃ to establish the initial vial expiration dating. All calibrator levels (1, 2, 3, and 4) were within specifications for Day 0, 8, 16, 24, 32, and 40. This accelerated stability study was performed to establish initial expiration dating. The stability study supported an initial expiration date of 12 months after testing on LC/MS. Real time stability studies are ongoing.
  • c. Open Vial Stability An open vial stability study was performed at 5°C to establish the initial open vial expiration dating on LC/MS. All calibrator levels (1, 2, 3, and 4) were within specifications for Day 0, 19, 26, 33, 41, and 60. This stability study supported an initial open vial expiration date of 60 days.
  • d. Value Assignment Calibrators are manufactured and are tested by mass spectrometry. The negative calibrator is a processed, drug free urine matrix. The standard is compared to a reference negative standard to ensure that it is free of analyte. The non-zero calibrators are prepared by spiking a known concentration of oxazepam in the negative calibrator matrix. If any of the analytes are not of the acceptable range, then the calibrator is adjusted and re-tested. Values are assigned to the calibrators once the mass spectrometry results are within the acceptable ranges.
  • I. Proposed Labeling

The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809.10

  • J. Conclusion
    The information provided in this pre-market notification demonstrates that the Immunalysis Benzodiazepines Urine Enzyme Immunoassay is substantially equivalent to the legally marketed predicate device for its general intended use.

§ 862.3170 Benzodiazepine test system.

(a)
Identification. A benzodiazepine test system is a device intended to measure any of the benzodiazepine compounds, sedative and hypnotic drugs, in blood, plasma, and urine. The benzodiazepine compounds include chlordiazepoxide, diazepam, oxazepam, chlorzepate, flurazepam, and nitrazepam. Measurements obtained by this device are used in the diagnosis and treatment of benzodiazepine use or overdose and in monitoring levels of benzodiazepines to ensure appropriate therapy.(b)
Classification. Class II (special controls). A benzodiazepine test system is not exempt if it is intended for any use other than employment or insurance testing or is intended for Federal drug testing programs. The device is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9, provided the test system is intended for employment and insurance testing and includes a statement in the labeling that the device is intended solely for use in employment and insurance testing, and does not include devices intended for Federal drug testing programs (e.g., programs run by the Substance Abuse and Mental Health Services Administration (SAMHSA), the Department of Transportation (DOT), and the U.S. military).