K Number
K161214
Device Name
Wondfo Amphetamine Urine Test AMP 500 (Cup, Dipcard), Wondfo Cocaine Urine Test COC 150(Cup, Dipcard), Wondfo Methamphetamine Urine Test MET 500 (Cup, Dipcard)
Date Cleared
2016-06-27

(59 days)

Product Code
Regulation Number
862.3250
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Wondfo Amphetamine Urine Test AMP 500 Cup is an immunochromatographic assay for the qualitative determination of Amphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator). 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling. Wondfo Amphetamine Urine Test AMP 500 DipCard is an immunochromatographic assay for the qualitative determination of Amphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator). 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling. Wondfo Cocaine Urine Test COC 150 Cup is an immunochromatographic assay for the qualitative determination of Benzoylecgonine in human urine at a Cut-Off concentration of 150 ng/mL. This test is callbrated to Benzoylecgonine (calibrator). 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling. Wondfo Cocaine Urine Test COC 150 DipCard is an immunochromatographic assay for the qualitative determination of Benzoylecgonine in human urine at a Cut-Off concentration of 150 ng/mL. This test is callbrated to Benzoylecgonine (calibrator). 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling. Wondfo Methamphetamine Urine Test MET 500 Cup is an immunochromatographic assay for the qualitative determination of Methamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator). 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling. Wondfo Amphetamine Urine Test MET 500 DipCard is an immunochromatographic assay for the qualitative determination of Methamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator). The test provides only preliminary test results. A more specific alternative chemical 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.
Device Description
WONDFO Urine Test devices are immunochromatographic assays for cocaine, amphetamine and Methamphetamine. Each assay test is a lateral flow, one step system for the qualitative detection of Benzoylecgonine, or D-amphetamine or D-methamphetamine (target analyte) in human urine. The product is a single-use in vitro diagnostic device, which comes in the form of: DipCards, or Cups. It contains a Test Device (in one of the two formats), a package insert and a urine cup. Each test device is sealed with a desiccant in an aluminum pouch.
More Information

No
The device description and performance studies indicate a standard immunochromatographic assay, with no mention of AI or ML technology. The analysis relies on chemical reactions and visual interpretation of results.

No.
Explanation: The device is an in vitro diagnostic (IVD) test intended for qualitative determination of substances in human urine, providing preliminary test results for drug detection. It is not used for treatment or therapy.

Yes

The text explicitly states "For in vitro diagnostic use only" in the "Intended Use / Indications for Use" section for each test listed.

No

The device is described as an immunochromatographic assay in the form of DipCards or Cups, which are physical hardware components used for in vitro diagnostic testing. The description focuses on the chemical and physical aspects of the test, not software.

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

The intended use statement explicitly states: "For in vitro diagnostic use only."

Furthermore, the device description states: "The product is a single-use in vitro diagnostic device..."

These statements clearly indicate that the Wondfo Urine Test devices are intended for in vitro diagnostic use.

N/A

Intended Use / Indications for Use

Wondfo Amphetamine Urine Test AMP 500 Cup is an immunochromatographic assay for the qualitative determination of Amphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Amphetamine Urine Test AMP 500 DipCard is an immunochromatographic assay for the qualitative determination of Amphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Cocaine Urine Test COC 150 Cup is an immunochromatographic assay for the qualitative determination of Benzoylecgonine in human urine at a Cut-Off concentration of 150 ng/mL. This test is callbrated to Benzoylecgonine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Cocaine Urine Test COC 150 DipCard is an immunochromatographic assay for the qualitative determination of Benzoylecgonine in human urine at a Cut-Off concentration of 150 ng/mL. This test is callbrated to Benzoylecgonine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Methamphetamine Urine Test MET 500 Cup is an immunochromatographic assay for the qualitative determination of Methamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Amphetamine Urine Test MET 500 DipCard is an immunochromatographic assay for the qualitative determination of Methamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

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

DIO, DKZ, DJC

Device Description

WONDFO Urine Test devices are immunochromatographic assays for cocaine, amphetamine and Methamphetamine. Each assay test is a lateral flow, one step system for the qualitative detection of Benzoylecgonine, or D-amphetamine or D-methamphetamine (target analyte) in human urine. The product is a single-use in vitro diagnostic device, which comes in the form of: DipCards, or Cups. It contains a Test Device (in one of the two formats), a package insert and a urine cup. Each test device is sealed with a desiccant in an aluminum pouch.

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

Over-the-counter (OTC) consumer 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

Not Found

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

  1. Analytical Performance - Precision Study:

    • Samples with concentrations of -100%, -75%, -50%, -25%, at, +25%, +50%, +75%, and +100% of the cut-off were prepared by spiking drug in negative samples.
    • Each drug concentration was confirmed by GC/MS.
    • All sample aliquots were blinded labeled and randomized.
    • For each concentration, tests were performed two runs per day for 25 days.
    • Results:
      • Amphetamine (AMP) Dip Card Format:
        • Lot 1: 50-/0+ for -100% to -25% cut-off; 43+/7- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 2: 50-/0+ for -100% to -25% cut-off; 44+/6- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 3: 50-/0+ for -100% to -25% cut-off; 44+/6- at cut-off; 50+/0- for +25% to +100% cut-off.
      • Amphetamine (AMP) Cup Format:
        • Lot 1: 50-/0+ for -100% to -25% cut-off; 44+/6- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 2: 50-/0+ for -100% to -25% cut-off; 43+/7- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 3: 50-/0+ for -100% to -25% cut-off; 44+/6- at cut-off; 50+/0- for +25% to +100% cut-off.
      • Cocaine (COC) Dip Card Format:
        • Lot 1: 50-/0+ for -100% to -50% cut-off; 50-/0+ for -25% cut-off; 50-/0+ for +25%, +50% cut-off; 43+/7- at cut-off; 50+/0- for +75%, +100% cut-off.
        • Lot 2: 50-/0+ for -100% to -25% cut-off; 44+/6- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 3: 50-/0+ for -100% to -25% cut-off; 43+/7- at cut-off; 50+/0- for +25% to +100% cut-off.
      • COC Cup Format:
        • Lot 1: 50-/0+ for -100% to -25% cut-off; 44+/6- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 2: 50-/0+ for -100% to -25% cut-off; 43+/7- at cut-off; 50+/0- for +25% to +100% cut-off.
        • Lot 3: 50-/0+ for -100% to -25% cut-off; 43+/7- at cut-off; 50+/0- for +25% to +100% cut-off.
      • Methamphetamine precision data was reported in K122961.
  2. Analytical Performance - Cut-off Study:

    • Sample Size: 150 samples equally distributed at concentrations of -50% cut-off; -25% cut-off; cut-off; +25% cut-off; +50% cut-off.
    • Study Design: Tested using three different lots of each device by three different operators.
    • Key Results: Results were all positive at and above +50% cut-off and all negative at and below -50% cut-off for Amphetamine, Cocaine and Methamphetamine (K122961).
  3. Analytical Performance - Interference Study:

    • Study Design: 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.
    • Key Results: Compounds listed in tables showed no interference at a concentration of 100µg/mL. No differences observed for different formats. MET interference data was reported in K122961.
  4. Analytical Performance - Specificity Study:

    • Study Design: Drug metabolites and other components likely to interfere in urine samples were tested using three batches of each device for all formats.
    • Key Results: The lowest detectable concentration was used to calculate cross-reactivity. No differences observed for different formats.
      • AMP: D-Amphetamine (100% reactivity at 500 ng/mL), L-Amphetamine (2% at 25000), D,L-Amphetamine (33% at 1500), Phentermine (33% at 1500), Hydroxyamphetamine (6% at 8000), Methylenedioxyamphetamine (MDA) (20% at 2500). d-Methamphetamine, l-Methamphetamine, ephedrine, Methylenedioxyethylamphetamine (MDE), 3,4-methylenedioxy-methamphetamine(MDMA) showed

§ 862.3250 Cocaine and cocaine metabolite test system.

(a)
Identification. A cocaine and cocaine metabolite test system is a device intended to measure cocaine and a cocaine metabolite (benzoylecgonine) in serum, plasma, and urine. Measurements obtained by this device are used in the diagnosis and treatment of cocaine use or overdose.(b)
Classification. Class II (special controls). A cocaine and cocaine metabolite 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).

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

June 27, 2016

GUANGZHOU WONDFO BIOTECH CO., LTD. C/O JOE SHIA 504 E DIAMOND AVE., SUITE I GAITHERSBURG MD 20877

Re: K161214

Trade/Device Name: Wondfo Amphetamine Urine Test AMP 500 (Cup, Dipcard), Wondfo Cocaine Urine Test COC 150(Cup. Dipcard). Wondfo Methamphetamine Urine Test MET 500 (Cup. Dipcard) Regulation Number: 21 CFR 862.3250 Regulation Name: Cocaine and cocaine metabolite test system Regulatory Class: II Product Code: DIO, DKZ, DJC Dated: April 21, 2016 Received: April 29, 2016

Dear Mr. 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 (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.

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,

Courtney H. Lias -S

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

510(k) Number (if known) K161214

Device Name Wondfo Amphetamine Urine Test AMP 500 (Cup, DipCard) Wondfo Cocaine Urine Test COC 150 (Cup, DipCard)

Wondfo Methamphetamine Urine Test MET 500 (Cup, DipCard)

Indications for Use (Describe)

Wondfo Amphetamine Urine Test AMP 500 Cup is an immunochromatographic assay for the qualitative determination of Amphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Amphetamine Urine Test AMP 500 DipCard is an immunochromatographic assay for the qualitative determination of Amphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Cocaine Urine Test COC 150 Cup is an immunochromatographic assay for the qualitative determination of Benzoylecgonine in human urine at a Cut-Off concentration of 150 ng/mL. This test is callbrated to Benzoylecgonine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Cocaine Urine Test COC 150 DipCard is an immunochromatographic assay for the qualitative determination of Benzoylecgonine in human urine at a Cut-Off concentration of 150 ng/mL. This test is callbrated to Benzoylecgonine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

3

Wondfo Methamphetamine Urine Test MET 500 Cup is an immunochromatographic assay for the qualitative determination of Methamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator).

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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

Wondfo Amphetamine Urine Test MET 500 DipCard is an immunochromatographic assay for the qualitative determination of Methamphetamine in human urine at a Cut-Off concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator).

The test provides only preliminary test results. A more specific alternative chemical 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a twostep process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

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

Prescription Use (Part 21 CFR 801 Subpart D)

X Over-The-Counter Use (21 CFR 801 Subpart C)

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    1. Date: June 8, 2016
  1. Submitter: Wondfo Biotech Co., Ltd. South China University of Technology Guangzhou, P.R. China 510641
    1. Contact person: Joe Shia LSI International Inc. 504 East Diamond Ave., Suite I Gaithersburg, MD 20877 Telephone: 240-505-7880 Fax: 301-916-6213 Email:shiajl@yahoo.com
    1. Device Name: WONDFO Urine Test Amphetamine (Cup, DipCard) WONDFO Urine Test Cocaine (Cup, DipCard) WONDFO Urine Test Methamphetamine (Cup, DipCard)
Classification. Class II
Product
CodeCFR #Panel
DIO21 CFR, 862.3250 Cocaine Test SystemToxicology
DKZ21 CFR, 862.3100 Amphetamine Test SystemToxicology
DJC21 CFR, 862.3610 Methamphetamine Test SystemToxicology

Classification: Class II

    1. Predicate Devices:
      K122809 Advin Multi-Drug Screen Test
    1. Intended Use
      WONDFO Urine Test Amphetamine Cup is a rapid test for the qualitative detection of Amphetamine in human urine at a cutoff concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator).

The tests provide 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.

5

For in vitro diagnostic use only. This test is intended for over-the-counter (OTC) consumer use as the first step in a two-step process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

WONDFO Urine Test Amphetamine DipCard is a rapid test for the qualitative detection of Amphetamine in human urine at a cutoff concentration of 500 ng/mL. This test is calibrated to d-Amphetamine (calibrator).

The tests provide 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a two-step process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

WONDFO Urine Test Cocaine Cup is a rapid test for the qualitative detection of Benzoylecgonine in human urine at a cutoff concentration of 150 ng/ml. This test is calibrated to Benzoylecgonine (calibrator).

The tests provide 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a two-step process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

WONDFO Urine Test Cocaine DipCard is a rapid test for the qualitative detection of Benzoylecgonine in human urine at a cutoff concentration of 150 ng/ml. This test is calibrated to Benzoylecgonine (calibrator).

The tests provide 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a two-step process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

6

WONDFO Urine Test Methamphetamine Cup is a rapid test for the qualitative detection of Methamphetamine in human urine at a cutoff concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator).

The tests provide 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a two-step process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

WONDFO Urine Test Methamphetamine DipCard is a rapid test for the qualitative detection of Methamphetamine in human urine at a cutoff concentration of 500 ng/mL. This test is calibrated to d-Methamphetamine (calibrator).

The tests provide 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. This test is intended for over-the-counter (OTC) consumer use as the first step in a two-step process to provide consumers with information concerning the presence or absence of the above stated drugs or their metabolites in a urine sample. Information regarding confirmatory testing- the second step in the process, is provided in the package labeling.

    1. Device Description
      WONDFO Urine Test devices are immunochromatographic assays for cocaine, amphetamine and Methamphetamine. Each assay test is a lateral flow, one step system for the qualitative detection of Benzoylecgonine, or D-amphetamine or D-methamphetamine (target analyte) in human urine. The product is a single-use in vitro diagnostic device, which comes in the form of: DipCards, or Cups. It contains a Test Device (in one of the two formats), a package insert and a urine cup. Each test device is sealed with a desiccant in an aluminum pouch.
    1. Substantial Equivalence Information
      A summary comparison of features of the WONDFO Urine Test and the predicate device is provided in Table 1, Table 2 & Table 3.
Table 1: Features Comparison of WONDFO Cocaine Test and the Predicate Device

| Item | Device | Predicate -
K122809 |
|--------------------------|-------------------------------------------------------------------------|------------------------|
| Indication(s)
for Use | For the qualitative determination of
Benzoylecgonine in human urine. | Same |

7

| Item | Device | Predicate -
K122809 |
|------------------------|-------------------------------------------------------------------------------------------------------------------------------------|----------------------------|
| Calibrator | Benzoylecgonine | 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 | 150 ng/mL | Same |
| Intended
Population | For over-the-counter and prescription
uses. | Same |
| Configurations | Cup, Dip Card | Cup, Dip Card,
Cassette |

Table 2: Features Comparison of WONDFO Amphetamine Test and the Predicate Device

ItemDevicePredicate - K122809
Indication(s)
for UseFor the qualitative determination of
D-amphetamine in human urine.Same
CalibratorD-amphetamineSame
MethodologyCompetitive binding, lateral flow
immunochromatographic assays based
on the principle of antigen antibody
immunochemistry.Same
Specimen TypeHuman UrineSame
Cut-Off Values500 ng/mLSame
Intended
PopulationFor over-the-counter and prescription
uses.Same
ConfigurationsCup, Dip CardCup, Dip Card,
Cassette

Table 3: Features Comparison of WONDFO Methamphetamine Test and the Predicate Device

ItemDevicePredicate - K122809
Indication(s)
for UseFor the qualitative determination of
D-methamphetamine in human urine.Same
CalibratorD-methamphetamineSame

8

ItemDevicePredicate - K122809
MethodologyCompetitive binding, lateral flow
immunochromatographic assays based
on the principle of antigen antibody
immunochemistry.Same
Specimen TypeHuman UrineSame
Cut-Off Values500 ng/mLSame
Intended
PopulationFor over-the-counter and prescription
uses.Same
ConfigurationsCup, Dip CardCup, Dip Card,
Cassette

9. Test Principle

WONDFO Urine Tests are rapid tests for the qualitative detection of Benzoylecgonine, or D-amphetamine or D-methamphetamine 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.

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 blinded labeled and randomized. For each concentration, tests were performed two runs per day for 25 days. The results obtained are summarized in the following tables:

| 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 1 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 43+/7- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Amphetamine (AMP) Dip Card Format

9

| | 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 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 44+/6- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Drug | Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 44+/6- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Amphetamine (AMP) 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 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 44+/6- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Drug | Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 43+/7- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Drug | Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 44+/6- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Cocaine (COC) Dip Card 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 1 | | 50-/0+ | 50-/0+ | | 50-/0+ | 50-/0+ | 43+/7- | 50+/0- |
| Lot 2 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 44+/6- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 43+/7- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

COC 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 1 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 44+/6- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 43+/7- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 43+/7- | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

The Methamphetamine precision data was reported in K122961.

  • b. Linearity
    Not applicable, these are visually read devices.

  • c. Stability

10

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; -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 +50% cut-off and all negative at and below -50% cut-off for Amphetamine, Cocaine and Methamphetamine (K122961). The following cut-off values for the test devices have been verified.
TestCalibratorCut-off (ng/mL)
WONDFO Urine Test Amphetamine
Cup (DipCard)D-amphetamine500
WONDFO Urine Test Cocaine Cup
(DipCard)Benzoylecogonine150
WONDFO Urine Test
Methamphetamine Cup (DipCard)D-methamphetamine500

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.

4-AcetamidophenolL-EphedrineOxycodone
Acetophenetidin(-) Y EphedrineOxymetazoline
N-AcetylprocainamideErythromycinPapaverine
Acetylsalicylic acidß-EstradiolPenicillin-G
AminopyrineEstrone-3-sulfatePentazocaine
AmitryptylineEthyl aminobenzoatePentobarbital
AmobarbitalFenfluraminePerphenazine
AmoxicillinFenoprofenPhencyclidine
AmpicillinFurosemidePhenelzine
Ascorbic acidGentisic acidPhenobarbital
AspartameHemoglobinPhetoin
AtropineHydralazineL-Phenylephrine
Benzilic acidHydrochlorothiazidePhenylpropanolamine

AMP

11

Benzoic acidHydrocodonePrednisolone
BenzoylecgonineHydrocortisonePrednisone
BilirubinO-Hydroxyhippuric acidProcaine
Brompheniramine3-HydroxytyraminePromazine
CaffeineIbuprofenPromethazine
CannabidiolImipramineD,L-Propanolol
Cannabinol(-) IsoproterenolD-Propoxyphene
ChloralhydrateIsoxsuprineQuinidine
ChloramphenicolKetamineQuinine
ChlordiazepoxideKetoprofenRanitidine
ChlorothiazideLabetalolSalicylic acid
(±)-ChlorpheniramineLevorphanolSecobarbital
ChlorpromazineLoperamideSulfamethazine
ChloroquineMaprotilineSulindac
CholesterolMeperidineTemazepam
ClomipramineMeprobamateTetracycline
ClonidineMethadoneTetrahydrocortisone
Cocaine hydrochlorideMethylphenidateTetrahydrozoline
CodeineMorphine-3-DglucuronideΔ9-THC-COOH
CortisoneNalidixic acidThebaine
(-) CotinineNaloxoneThiamine
CreatinineNaltrexoneThioridazine
DeoxycorticosteroneNaproxenD,L-Thyroxine
DextromethorphanNiacinamideTolbutamide
DiazepamNifedipineTriamterene
DiclofenacNorcodeinTrifluoperazine
DiflunisalNorethindroneTrimethoprim
DigoxinD-NorpropoxypheneTrimipramine
DiphenhydramineNoscapineTryptamine
DoxylamineD,L-OctopamineD, L-Tyrosine
Ecgonine hydrochlorideOxalic acidUric acid
Ecgonine methylesterOxazepamVerapamil
(1R,2S)-(-)-EphedrineOxolinic acidZomepirac

COC

AcetaminophenEstrone-3-sulfateOxymetazoline
AcetophenetidinEthyl-p-aminobenzoatePapaverine
N-AcetylprocainamideFenoprofenPenicillin-G
Acetylsalicylic acidFurosemidePentobarbital
AminopyrineGentisic acidPerphenazine
AmitryptylineHemoglobinPhencyclidine
AmobarbitalHydralazinePhenelzine
AmoxicillinHydrochlorothiazidePhenobarbital
AmpicillinHydrocodonePhentermine
L-Ascorbic acidHydrocortisoneL-Phenylephrine
DL-Amphetamine SulfateO-Hydroxyhippuric acidβ-Phenylethylamine
Apomorphinep-HydroxymethamphetaminePhenylpropanolamine
Aspartame3-HydroxytyraminePrednisolone
AtropineIbuprofenPrednisone
Benzilic acidImipramineProcaine
Benzoic acidIproniazidPromazine
Benzphetamine(±) - IsoproterenolPromethazine
(±) -BrompheniramineIsoxsuprineDL-Propranolol
CaffeineKetamineD-Propoxyphene
CannabidiolKetoprofenD-Pseudoephedrine
CannabinolLabetalolQuinidine
ChloralhydrateLevorphanolQuinine
ChloramphenicolLoperamideRanitidine
ChlordiazepoxideMaprotilineSalicylic acid
ChlorothiazideMeperidineSecobarbital
(±) -ChlorpheniramineMeprobamateSerotonin
ChlorpromazineMethadoneSulfamethazine
ChloroquineMethoxyphenamineSulindac
Cholesterol(±) -3,4-Methylene
dioxyamphetamineTemazepam
ClomipramineMethylene-
dioxymethamphetamineTetracycline
ClonidineMorphine-3-B-D glucuronideTetrahydrocortisone
3-(β-D glucuronide)
CodeineMorphine SulfateTetrahydrozoline
CortisoneNalidixic acidThebaine
(-) CotinineNaloxoneThiamine
CreatinineNaltrexoneThioridazine
DeoxycorticosteroneNaproxenDL-Tyrosine
DextromethorphanNiacinamideTolbutamide
DiazepamNifedipineTriamterene
DiclofenacNorcodeinTrifluoperazine
DiflunisalNorethindroneTrimethoprim
DigoxinD-NorpropoxypheneTrimipramine
DiphenhydramineNoscapineTryptamine
DoxylamineDL-OctopamineDL-Tryptophan
Ecgonine methylesterOxalic acidTyramine
(-) - Ψ-EphedrineOxazepamUric acid
ErythromycinOxolinic acidVerapamil
ß-EstradiolOxycodoneZomepirac

12

13

MET: The MET interference data was reported in K122961.

  • 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.
AMPResultReactivity
(D- Amphetamine, Cut-off=500 ng/mL)Positive at 500 ng/mL100%
L - Amphetamine250002%
D,L - Amphetamine150033%
Phentermine150033%
Hydroxyamphetamine80006%
Methylenedioxyamphetamine (MDA)250020%
d-MethamphetamineNegative at 10000050 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.

| % of Cutoff | Number
of
samples | d-Amphetamine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|--------------|-------------------------|----------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| | | | No. of
Positive | No. of
Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 126.3 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 248.6 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 377.1 | 1 | 19 | 95.0 |
| +25% Cutoff | 20 | 625.8 | 18 | 2 | 90.0 |
| +50% Cutoff | 20 | 753.2 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 874.3 | 20 | 0 | 100 |

Comparison between GC/MS and Lay Person Results AMP Cup

Comparison between GC/MS and Lay Person Results AMP Dip Card

| % of Cutoff | Number
of
samples | d-Amphetamine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results |
|-------------|-------------------------|----------------------------------------------------|--------------------|--------|-----------------------------------------|
| | | | No. of | No. of | |

18

PositiveNegative(%)
-100% Cutoff200020100
-75% Cutoff20126.3020100
-50% Cutoff20248.6020100
-25% Cutoff20377.121890.0
+25% Cutoff20625.818290.0
+50% Cutoff20753.2200100
+75% Cutoff20874.3200100

Comparison between GC/MS and Lay Person Results COC Cup

| | Number
of
samples | Benzoylecgonine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|--------------|-------------------------|------------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| % of Cutoff | | | No. of
Positive | No. of
Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 38.1 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 75.6 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 113.4 | 2 | 18 | 90.0 |
| +25% Cutoff | 20 | 186.7 | 18 | 2 | 90.0 |
| +50% Cutoff | 20 | 226.3 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 259.8 | 20 | 0 | 100 |

Comparison between GC/MS and Lay Person Results COC Dip Card

| % of Cutoff | Number
of
samples | Benzoylecgonine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|--------------|-------------------------|------------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| | | | No. of
Positive | No. of
Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 38.1 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 75.6 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 113.4 | 2 | 18 | 90.0 |
| +25% Cutoff | 20 | 186.7 | 18 | 2 | 90.0 |
| +50% Cutoff | 20 | 226.3 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 259.8 | 20 | 0 | 100 |

Comparison between GC/MS and Lay Person Results MET Cup

| % of Cutoff | Number
of
samples | Methamphetamine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|-------------|-------------------------|------------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| | | | No. of
Positive | No. of
Negative | |

19

-100% Cutoff200020100
-75% Cutoff20124.8020100
-50% Cutoff20251.3020100
-25% Cutoff20377.621890.0
+25% Cutoff20625.918290.0
+50% Cutoff20748.3200100
+75% Cutoff20878.1200100

Comparison between GC/MS and Lay Person Results MET Dip Card

| % of Cutoff | Number
of
samples | Methamphetamine
Concentration by GC/MS
(ng/mL) | Lay person results | | The
percentage of
correct results
(%) |
|--------------|-------------------------|------------------------------------------------------|--------------------|--------------------|------------------------------------------------|
| | | | No. of
Positive | No. of
Negative | |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 124.8 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 251.3 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 377.6 | 2 | 18 | 90.0 |
| +25% Cutoff | 20 | 625.9 | 18 | 2 | 90.0 |
| +50% Cutoff | 20 | 748.3 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 878.1 | 20 | 0 | 100 |

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 WONDFO Urine Test devices are substantially equivalent to the predicate.