K Number
K180349
Date Cleared
2018-04-05

(56 days)

Product Code
Regulation Number
862.3100
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

AssureTech Panel Dip Tests and AssureTech Quick Cup Tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cocaine, Marijuana Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamine, Phencyclidine. Methadone, EDDP, Nortriptyline and d-Propoxyphene in human urine at the cutoff concentrations of:

Drug(Identifier)Cut-off level
Amphetamine1000 ng/mL
Oxazepam300 ng/mL
Cocaine300 ng/mL
Marijuana50 ng/mL
Methamphetamine1000 ng/mL
Morphine300 ng/mL or 2000 ng/mL
Oxycodone100 ng/mL
Secobarbital300 ng/mL
Buprenorphine10 ng/mL
Methylenedioxy-methamphetamine500 ng/mL
Phencyclidine25 ng/mL
Methadone300 ng/mL
EDDP300 ng/mL
Nortriptyline1000 ng/mL
d-Propoxyphene300 ng/mL

Configuration of the AssureTech Panel Dip Tests and the AssureTech Quick Cup Tests can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Propoxyphene and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. 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 or LC/MS is the preferred confirmatory method.

For in vitro diagnostic use only.

Device Description

The AssureTech Panel Dip Tests and AssureTech Quick Cup Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, EDDP, Nortriptyline and Propoxyphene (target analytes) in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of Panel Dip Cards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch

AI/ML Overview

The provided document describes the validation of the AssureTech Panel Dip Tests and AssureTech Quick Cup Tests for qualitative and simultaneous detection of various drugs in human urine. The study presented focuses on the analytical performance, comparison with a predicate device, and a lay-user study.

Here's an analysis of the acceptance criteria and study proving the device meets them:

1. Acceptance Criteria and Reported Device Performance

The acceptance criteria are not explicitly stated as numerical targets in a dedicated table, but are implied by the results of the precision studies and lay-user studies demonstrating high percentages of correct results around the cutoff concentrations. For the lay-user study, the implicitly accepted performance is 90-100% correct results across various drug concentrations, particularly at and near the cutoff levels.

Here's a table summarizing the reported device performance, based on the lay-user study, for each tested drug, focusing on the "The percentage of correct results (%)" column. Note that the precision studies showed similar performance for different lots and concentration ranges.

Table of Acceptance Criteria (Implied) and Reported Device Performance (Lay-User Study)

Drug (Identifier)Cut-off level (ng/mL)Sample Conc. (% of Cutoff)Implied Acceptance Criteria (Min. % Correct)Reported Device Performance (Min. % Correct across all concentrations tested)
Amphetamine (AMP)1000-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Secobarbital (BAR)300-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Cocaine (COC)300-100%, -75%, -50%100%100%
-25%90%90%
+25%90%95%
+50%, +75%100%100%
Buprenorphine (BUP)10-100%, -75%, -50%100%100%
-25%90%(Missing data)
+25%90%(Missing data)
+50%, +75%100%100%
Methamphetamine (MET)1000-100%, -75%, -50%100%100%
-25%90%90%
+25%90%95%
+50%, +75%100%100%
Methadone (MTD)300-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Morphine (MOR)300/2000-100%, -75%, -50%100%100%
-25%90%90%
+25%90%90%
+50%, +75%100%100%
Oxycodone (OXY)100-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Phencyclidine (PCP)25-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Marijuana (THC)50-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Oxazepam (BZO)300-100%, -75%, -50%100%100%
-25%90%90%
+25%90%100%
+50%, +75%100%100%
Methylenedioxy-methamphetamine (MDMA)500-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
Nortriptyline (TCA)1000-100%, -75%, -50%100%100%
-25%90%95%
+25%90%90%
+50%, +75%100%100%
EDDP300-100%, -75%, -50%100%100%
-25%, +25%90%95%
+50%, +75%100%100%
d-Propoxyphene (PPX)300-100%, -75%, -50%100%100%
-25%90%100%
+25%90%95%
+50%, +75%100%100%

Note on Buprenorphine (BUP) results: The table for BUP in the document has missing values ("С Г لك ه" and blank for "No. of Negative"). This prevents reporting the exact percentages for those concentrations. However, the existing data for BUP still shows high performance where reported.

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

  • Lay-user Study (Primary Test Set):

    • Sample Size: 310 lay persons for each device format (Panel Dip Tests and Quick Cup Tests). For each drug, there were varying numbers of samples at different concentrations: 20 samples at -100%, -75%, -25%, +25%, +75% cutoff, and 170 samples at -50% cutoff, and 40 samples at +50% cutoff.
    • Data Provenance: The origin of the urine samples (e.g., country of origin) is not specified. The study was conducted "in-house" (meaning by the manufacturer or their designated testing facility) and appears to be prospective in nature, as samples were prepared by spiking drugs into negative urine specimens, aliquoted, and then distributed blindly to users.
  • Comparison Studies (Clinical Samples):

    • Sample Size: For each drug, 80 unaltered clinical samples (40 negative and 40 positive). These were tested by three laboratory assistants for each device.
    • Data Provenance: The origin (e.g., country) of these clinical samples is not specified. They are described as "clinical samples," implying they were collected from real patients, making this a retrospective evaluation of existing samples.
  • Precision Studies:

    • Sample Size: For each drug concentration (-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), tests were performed in two runs per day for 25 days, for a total of 50 tests per concentration per lot. With 3 lots tested, this amounts to 150 tests per concentration.
    • Data Provenance: Samples were "prepared by spiking drug in negative samples," indicating these were lab-prepared samples, making it a prospective controlled study.

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

  • Lay-user Study Ground Truth: The ground truth for the lay-user study samples was established by LC/MS (Liquid Chromatography-Mass Spectrometry), which is a gold standard analytical method for drug concentration determination. The document states: "The concentrations of the samples were confirmed by LC/MS." No human experts are explicitly mentioned as establishing the ground truth for this set beyond the technical personnel operating the LC/MS.

  • Comparison Studies Ground Truth: The ground truth for the clinical samples in the comparison studies was also established by LC/MS. The document states: "The samples were blind labeled and compared to LC/MS results." Similarly, no human expert consensus or interpretation was required for establishing the ground truth for these samples, as LC/MS provides a quantitative, objective measure.

  • Precision Studies Ground Truth: The ground truth for these spiked samples was also established by LC/MS to confirm the prepared drug concentrations.

4. Adjudication Method for the Test Set

  • Lay-user Study: No adjudication method is described. Each lay participant evaluated their assigned blind-labeled sample independently. The results were then compared to the LC/MS ground truth.

  • Comparison Studies: No adjudication method is described. Three laboratory assistants independently ran the samples, and their results were compared directly to the LC/MS results. Discordant results are individually listed but no process for reconciling them or for a consensus reading is mentioned using these three viewers.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, and its effect size.

  • No MRMC study involving human readers improving with AI vs. without AI assistance was done. This device is a rapid, lateral flow immunochromatographic assay, not an AI-assisted diagnostic tool requiring human interpretation with or without AI. The "readers" in the comparison study are laboratory assistants interpreting the dip/cup test results, not radiologists or similar specialists interpreting complex images, and no AI component is involved for assistance.

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

  • Not applicable. The device itself is the "algorithm" in a sense, as it performs the chemical reaction to yield a positive or negative result. The studies assess the performance of this device. There is no separate, purely computational algorithm. The device's performance is inherently "standalone" in how it chemically processes the sample and displays a result, which is then visually interpreted by a human user (whether a lab assistant or a layperson).

7. The Type of Ground Truth Used

  • The primary type of ground truth used for both the precision studies, comparison studies, and the lay-user study was analytical confirmation by LC/MS (Liquid Chromatography-Mass Spectrometry). This is a highly accurate and objective method for determining the concentration of drugs in a sample, which then defines whether a sample is truly positive or negative relative to a specific cutoff.

8. The Sample Size for the Training Set

  • Not applicable / Not explicitly stated. This is a chemical assay, not a machine learning model, so there isn't a "training set" in the conventional AI/ML sense. The device's components and parameters are developed through R&D, not through training on a dataset. The results presented are for validation and performance evaluation.

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

  • Not applicable. As there is no "training set" for an AI/ML model for this type of device, the concept of establishing ground truth for a training set doesn't apply. The device's underlying chemistry and immunoassay principles are based on established scientific knowledge.

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April 5, 2018

Assure Tech (Hangzhou) Co., Ltd. % Joe Shia Manager LSI International 504 E Diamond Ave, Suite I Gaithersburg, MD 20877

Re: K180349

Trade/Device Name: AssureTech Panel Dip Tests, AssureTech Quick Cup Tests Regulation Number: 21 CFR 862.3100 Regulation Name: Amphetamine test system Regulatory Class: Class II Product Code: NFT, NFW, NFY, NGG, NGL, NFV, PTH, NGM, PTG, QAW, QBF Dated: February 5, 2018 Received: February 8, 2018

Dear Joe Shia:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801 and Part 809); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR

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

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.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely, Kellie B. Kelm -S

for Courtney H. Lias, Ph.D. Director Division of Chemistry and Toxicology Devices Office of In Vitro Diagnostics and Radiological Health Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K180349

Device Name AssureTech Panel Dip Tests AssureTech Quick Cup Tests

Indications for Use (Describe)

AssureTech Panel Dip Tests and AssureTech Quick Cup Tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cocaine, Marijuana Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamine, Phencyclidine. Methadone, EDDP, Nortriptyline and d-Propoxyphene in human urine at the cutoff concentrations of:

Drug(Identifier)Cut-off level
Amphetamine1000 ng/mL
Oxazepam300 ng/mL
Cocaine300 ng/mL
Marijuana50 ng/mL
Methamphetamine1000 ng/mL
Morphine300 ng/mL or 2000 ng/mL
Oxycodone100 ng/mL
Secobarbital300 ng/mL
Buprenorphine10 ng/mL
Methylenedioxy-methamphetamine500 ng/mL
Phencyclidine25 ng/mL
Methadone300 ng/mL
EDDP300 ng/mL
Nortriptyline1000 ng/mL
d-Propoxyphene300 ng/mL

Configuration of the AssureTech Panel Dip Tests and the AssureTech Quick Cup Tests can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Propoxyphene and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. 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 or LC/MS is the preferred confirmatory method.

For in vitro diagnostic use only.

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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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K180349 510(k) SUMMARY

Email: customerservice@assurelabs.com.

  • March 13, 2018 1. Date: 2. Submitter: Assure Tech. Co., Ltd. Building 1, No.10, Xiyuansan Road, Westlake Economic Zone Hangzhou, China, 310030 3. Contact person: Eric Lin Assure Tech. Co., Ltd. Building 1, No.10, Xiyuansan Road, Westlake Economic Zone Hangzhou, China, 310030 Telephone: 510-860-4680
    1. Device Name: AssureTech Panel Dip Tests AssureTech Quick Cup Tests
Classification:Class 2
Product CodeClassificationRegulation SectionPanel
NFTAmphetamineII21 CFR § 862.3100, AmphetamineTest SystemToxicology (91)
NFWCannabinoidsII21 CFR § 862.3870, CannabinoidsTest SystemToxicology (91)
NFYCocaineII21 CFR § 862.3250, Cocaine andCocaine Metabolites Test SystemToxicology (91)
NGGMethamphetamineII21 CFR § 862.3610,Methamphetamine Test SystemToxicology (91)
NGLMorphineII21 CFR § 862.3650, MorphineTest SystemToxicology (91)
NFVOxazepamII21 CFR § 862.3170,Benzodiazepine Test SystemToxicology (91)
NGLOxycodoneII21 CFR § 862.3650, Opiate TestSystemToxicology (91)
PTHSecobarbitalII21 CFR § 862.3150, BarbiturateTest SystemToxicology (91)
NGLBuprenorphineII21 CFR § 862.3650,Opiate Test SystemToxicology (91)
NGGMethylenedioxy-methamphetamineII21 CFR § 862.3610,Methamphetamine Test SystemToxicology (91)
NGMPhencyclidineunclassifiedEnzyme ImmunoassayPhencyclidineToxicology (91)
PTGMethadoneII21 CFR § 862.3620, MethadoneTest SystemToxicology (91)

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PTG2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine(EDDP)II21 CFR § 862.3620, MethadoneTest SystemToxicology (91)
QAWNortriptylineII21 CFR, 862.3910 TricyclicAntidepressant Drugs Test SystemToxicology (91)
QBFPropoxypheneII21 CFR, 862.3700 PropoxypheneTest SystemToxicology (91)
    1. Predicate Devices: K153050
      The CO-INNOVATION BIOTECH Rapid Multi-Drug Test Dip Card and Rapid Multi-Drug Test Cup
    1. Indications for Use
      AssureTech Panel Dip Tests and AssureTech Quick Cup Tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, EDDP, Nortriptyline and d-Propoxyphene in human urine at the cutoff concentrations of:
Drug(Identifier)Cut-off level
Amphetamine1000 ng/mL
Oxazepam300 ng/mL
Cocaine300 ng/mL
Marijuana50 ng/mL
Methamphetamine1000 ng/mL
Morphine300 ng/mL or 2000 ng/mL
Oxycodone100 ng/mL
Secobarbital300 ng/mL
Buprenorphine10 ng/mL
Methylenedioxy-methamphetamine500 ng/mL
Phencyclidine25 ng/mL
Methadone300 ng/mL
EDDP300 ng/mL
Nortriptyline1000 ng/mL
d-Propoxyphene300 ng/mL

Configuration of the AssureTech Panel Dip Tests and the AssureTech Quick Cup Tests can consist of any combination of the above listed drug analytes.

The test may vield positive results for the prescription drugs Buprenorphine. Nortriptyline, Oxazepam, Secobarbital, Propoxyphene and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. 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 or LC/MS is the preferred confirmatory method. For in vitro diagnostic use only.

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    1. Device Description
      The AssureTech Panel Dip Tests and AssureTech Quick Cup Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, EDDP, Nortriptyline and Propoxyphene (target analytes) in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of Panel Dip Cards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch
    1. Substantial Equivalence Information
      A summary comparison of features of the AssureTech Panel Dip Tests and AssureTech Quick Cup Tests and the predicate devices is provided in following tables.
ItemDevicePredicate - K153050
Indication(s)for UseFor the qualitative determination of drugs ofabuse in human urine.Same (but the number ofdrugs detected is different)
Calibrator andCut-Off ValuesAmphetamine (AMP): 1,000 ng/mlOxazepam (BZO):300 ng/mlCocaine(COC): 300 ng/mlMarijuana (THC):50 ng/mlMethamphetamine (MET): 1,000 ng/mlMorphine (MOR): 300ng/mL or 2000 ng/mlOxycodone(OXY) : 100 ng/mlSecobarbital (BAR): 300 ng/mlBuprenorphine (BUP): 10 ng/mlMethylenedioxy-methamphetamine(MDMA):500 ng/mlPhencyclidine (PCP): 25 ng/mlMethadone (MTD): 300 ng/ml2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP): 300 ng/mlNortriptyline (TCA): 1000 ng/mlPropoxyphene (PPX): 300 ng/mlSame
MethodologyCompetitive binding, lateral flowimmunochromatographic assays based on theprinciple of antigen antibodyimmunochemistry.Same
Type of TestQualitativeSame
Specimen TypeHuman UrineSame
Intended UseFor over-the-counterSame

Table 1: Features Comparison of AssureTech Panel Dip Tests and the Predicate Devices

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ConfigurationsDip CardSame
--------------------------------

Table 2: Features Comparison of AssureTech Quick Cup Tests and the Predicate Devices

ItemDevicePredicate - K153050
Indication(s)for UseFor the qualitative determination ofdrugs of abuse in human urine.Same (but the number ofdrugs detected is different)
Calibrator and Cut-OffValuesAmphetamine (AMP): 1,000 ng/mlOxazepam (BZO):300 ng/mlCocaine(COC): 300 ng/mlMarijuana (THC):50 ng/mlMethamphetamine (MET): 1,000 ng/mlMorphine (MOR): 300ng/mL or 2000 ng/mlOxycodone(OXY) : 100 ng/mlSecobarbital (BAR): 300 ng/mlBuprenorphine (BUP): 10 ng/mlMethylenedioxy-methamphetamine(MDMA): 500 ng/mlPhencyclidine (PCP): 25 ng/mlMethadone (MTD): 300 ng/ml2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP): 300 ng/mlNortriptyline (TCA): 1000 ng/mlPropoxyphene (PPX): 300 ng/mlSame
MethodologyCompetitive binding, lateral flowimmunochromatographic assays based onthe principle of antigen antibodyimmunochemistry.Same
Type of TestQualitativeSame
Specimen TypeHuman UrineSame
Intended UseFor over-the-counterSame
ConfigurationsCupSame

9. Test Principle

The AssureTech Panel Dip Tests, and AssureTech Quick Cup Tests are rapid tests for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, EDDP, Nortriptyline and Propoxyphene in urine samples. The tests are lateral flow chromatographic immunoassays. During testing, a urine specimen migrates upward by capillary action. If target drugs present in the urine specimen are below the cut-off concentration, it will not saturate the binding sites of its specific monoclonal mouse antibody coated on the particles. The antibody-coated particles will then be captured by immobilized

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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 to indicate that the tests have been performed properly.

10. Performance Characteristics

    1. Analytical Performance
    • Precision a.

Precision studies were carried out for samples with concentrations of -100% cut off, -75% cut off, -50% cut off, -25% cut off, +25% cut off, +50% 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 LC/MS. All sample aliquots were blindly labeled by the person who prepared the samples and didn't take part in the sample testing. For each concentration, tests were performed two runs per day for 25 days per device in a randomized order. The results obtained are summarized in the following tables for 2ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP), Nortriptyline (TCA) and Propoxyphene (PPX). The rest data were reported in the K170049.

EDDP

Panel Dip

LotNumber-100%cut off-75%cut off-50%cut off-25%cutoffcut off+25%cut off+50%cut off+75%cut off+100%cut off
Lot 150-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+10-/40+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-

Quick Cup

LotNumber-100%cut off-75%cut off-50%cut off-25%cutoffcut off+25%cut off+50%cut off+75%cut off+100%cut off
Lot 150-/0+50-/0+50-/0+50-/0+10-/40+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-

Nortriptyline

Panel Dip

LotNumber-100%cut off-75%cut off-50%cut off-25%cutoffcut off+25%cut off+50%cut off+75%cut off+100%cut off
Lot 150-/0+50-/0+50-/0+50-/0+10-/40+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+10-/40+50+/0-50+/0-50+/0-50+/0-

Quick Cup

LotNumber-100%cut off-75%cut off-50%cut off-25%cutoffcut off+25%cut off+50%cut off+75%cut off+100%cut off
Lot 150-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+8-/42+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+8-/42+50+/0-50+/0-50+/0-50+/0-

Propoxyphene

Panel Dip

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LotNumber-100%cut off-75%cut off-50%cut off-25%cutoffcut off+25%cut off+50%cut off+75%cut off+100%cut off
Lot 150-/0+50-/0+50-/0+50-/0+12-/38+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+11-/39+50+/0-50+/0-50+/0-50+/0-
Quick Cup
LotNumber-100%cut off-75%cut off-50%cut off-25%cutoffcut off+25%cut off+50%cut off+75%cut off+100%cut off
Lot 150-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-
Lot 250-/0+50-/0+50-/0+50-/0+8-/42+50+/0-50+/0-50+/0-50+/0-
Lot 350-/0+50-/0+50-/0+50-/0+9-/41+50+/0-50+/0-50+/0-50+/0-

c. Stability

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

d. Interference

Potential interfering substances found in human urine of physiological or pathological conditions were added to drug-free urine and target drugs urine with concentrations at 25% below and 25% above Cut-Off levels. These urine samples were tested using three batches of each device. Compounds that showed no interference at a concentration of 100µg/mL (albumin was tested at 100 mg/dL) are summarized in the following tables. There were no differences observed for different devices.

Acetaminophenβ-EstradiolOxalic acid
AcetophenetidinErythromycinOxolinic acid
N-AcetylprocainamideFenoprofenOxymetazoline
Acetylsalicylic acidFurosemidePapaverine
Albumin (100 mg/dL)Gentisic acidPenicillin G
AminopyrineHemoglobinPerphenazine
AmoxicillinHydralazinePhenelzine
AmpicillinHydrochlorothiazidePrednisone
ApomorphineHydrocortisone(±)-Propranolol
Ascorbic acidO-Hydroxyhippuric acidPseudoephedrine
Aspartame3-HydroxytyramineQuinine
AtropineIbuprofenRanitidine
Benzilic acidIsoproterenolSalicylic acid
Benzoic acidIsoxsuprineSerotonin (5- Hydroxytyramine)
BilirubinKetamineSulfamethazine
Chloral hydrateKetoprofenSulindac
ChloramphenicolLabetalolTetrahydrocortisone 3-(β-Dglucuronide)
ChlorothiazideLoperamideTetrahydrocortisone 3-acetate
ChlorpromazineMeperidineTetrahydrozoline
CholesterolMeprobamateThiamine
ClonidineMethoxyphenamineThioridazine
CortisoneNalidixic acidTriamterene
(-)-CotinineNaloxoneTrifluoperazine
CreatinineNaltrexoneTrimethoprim
DeoxycorticosteroneNaproxenDL-Tryptophan
DextromethorphanNiacinamideTyramine

{10}------------------------------------------------

DiclofenacNifedipineDL-Tyrosine
DiflunisalNorethindroneUric acid
DigoxinNoscapineVerapamil
Diphenhydramine(±)-OctopamineZomepirac
Ecgonine methyl ester

e. Specificity

To test specificity, drug metabolites and other components that are likely to interfere in urine samples were tested using three batches of each device. The lowest concentration that caused a positive result for each compound are listed below for 2-ethylidene-1. 5dimethyl-3, 3-diphenylpyrrolidine (EDDP), Nortriptyline (TCA) and Propoxyphene (PPX). The rest data were reported in the K170049. There were no differences observed for different devices.

EDDP(Cut-off=300 ng/mL)ResultPositive at (ng/mL)% Cross-Reactivity
EDDP(2-ethylidene-1,5-dimethyl-3,3-diphenylpyrrolidine)300100%
EMDP (2-Ethyl-5-methyl-3,3-diphenylpyrroline)>100000<0.3%
Disopyramide75400%
Methadone>100000<0.3%
LAAM (Levo-alpha-acetylmethadol) HCl>100000<0.3%
Alpha Methadol>100000<0.3%
Doxylamine>100000<0.3%
Nortriptyline(Cut-off=1000 ng/mL)ResultPositive at (ng/mL)% Cross-Reactivity
Nortriptyline1000100%
Amitriptyline750133.3%
Clomipramine1000010%
Desipramine200500%
Doxepin125080%
Imipramine625160%
Maprotiline200050%
Nordoxepin1000100%
Promazine150066.7%
Promethazine250004%
Trimipramine300033.3%
Cyclobenzaprine Hydrochloride500020%
Norclomipramine300033.3%
Propoxyphene(Cut-off=300 ng/mL)ResultPositive at (ng/ml)% Cross-Reactivity
d-Propoxyphene300100%
Norpropoxyphene33390.1%

f. Effect of Urine Specific Gravity and Urine pH

To investigate the effect of urine specific gravity and urine pH, urine samples, with 1.000 to 1.035 specific gravity or urine samples with pH 4 to 9 were spiked with target drugs at 25% below and 25% above Cut-Off levels. These samples were tested using three lots of each device. Results were all positive for samples at and above +25% Cut-Off and all

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negative for samples at and below -25% Cut-Off. There were no differences observed for different devices.

2. Comparison Studies

Method comparison studies for the AssureTech Panel Dip Tests and the AssureTech Quick Cup Tests were performed in-house with three laboratory assistants for each device. Operators ran 80 (40 negative and 40 positive) unaltered clinical samples for each drug. The samples were blind labeled and compared to LC/MS results. The results are presented in the tables below for 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP), Nortriptyline (TCA) and Propoxyphene (PPX). The rest data were reported in the K170049.

EDDP

PanelDipNegativeLowNegative byLC/MS(less than-50%)Near CutoffNegative byLC/MS(Between-50% andcutoff)Near CutoffPositive byLC/MS(Between thecutoff and+50%)High Positiveby LC/MS(greater than+50%)
ViewerAPositive0021425
Negative1020810
ViewerBPositive0001525
Negative10201000
ViewerCPositive0011425
Negative1020910

Discordant Results

ViewerSample NumberLC/MS ResultDip Card Viewer Results
Viewer A86905295Positive
Viewer A36355290Positive
Viewer C63254295Positive
Viewer A24973308Negative
Viewer C24082307Negative
QuickCupNegativeLow Negative byLC/MS(less than-50%)Near Cutoff Negative byLC/MS(Between-50% andcutoff)Near Cutoff Positive byLC/MS(Between thecutoff and+50%)High Positiveby LC/MS(greater than+50%)
ViewerAPositive0011525
Negative1020900
ViewerBPositive0011425
Negative1020910
ViewerCPositive0011425
Negative1020910

Discordant Results

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ViewerSample NumberLC/MS ResultQuick CupViewer Results
Viewer A47796296Positive
Viewer B63254295Positive
Viewer C36355290Positive
Viewer B24082307Negative
Viewer C24973308Negative

Nortriptyline

PanelDipNegativeLow Negative byLC/MS(less than -50%)Near Cutoff Negative byLC/MS(Between -50% andcutoff)Near Cutoff Positive byLC/MS(Between the cutoff and+50%)High Positive byLC/MS(greater than +50%)
ViewerAPositive0001525
Negative10201000
ViewerBPositive0011425
Negative1020910
ViewerCPositive0001425
Negative10201010

Discordant Results

ViewerSample NumberLC/MS ResultDip CardViewer Results
Viewer B50313942Positive
Viewer B770631081Negative
Viewer C770631081Negative
QuickCupNegativeLow Negative byLC/MS(less than-50%)Near CutoffNegative byLC/MS(Between-50% andcutoff)Near CutoffPositive byLC/MS(Between thecutoff and+50%)High Positiveby LC/MS(greater than+50%)
ViewerA Positive0001425
ViewerA Negative10201010
ViewerB Positive0001425
ViewerB Negative10201010
ViewerC Positive0011525
ViewerC Negative1020900

Discordant Results

ViewerSample NumberLC/MS ResultQuick CupViewer Results
Viewer C50313942Positive
Viewer A770631081Negative

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Viewer B548031130Negative
---------------------------------

Propoxyphene

PanelDipNegativeLow Negative byLC/MS(less than -50%)Near Cutoff Negative byLC/MS(Between -50% andcutoff)Near Cutoff Positive byLC/MS(Between the cutoff and+50%)High Positive by LC/MS(greater than +50%)
ViewerAPositive0011525
Negative1020900
ViewerBPositive0011525
Negative1020900
ViewerCPositive0001525
Negative10201000

Discordant Results

ViewerSample NumberLC/MS ResultDip CardViewer Results
Viewer A31727294Positive
Viewer B34150298Positive
QuickCupNegativeLow Negative byLC/MS(less than-50%)Near CutoffNegative byLC/MS(Between-50% andcutoff)Near CutoffPositive byLC/MS(Between thecutoff and+50%)High Positiveby LC/MS(greater than+50%)
ViewerAPositive0001425
ViewerANegative10201010
ViewerBPositive0011525
ViewerBNegative1020900
ViewerCPositive0011425
ViewerCNegative1020910

Discordant Results

ViewerQuick Cup
Sample NumberLC/MS ResultViewer Results
Viewer Bર્ભ્યતેત્તેર287Positive
Viewer C34150298Positive
Viewer A27051રેતે જેવે છે. આ ગામનાં પ્રાથમિક શાળા, પંચાયતઘર, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામનાં પ્રાથમિક શાળા, આંગણવાડી તેમ જ દૂધની ડેરી જેવી સવલતો પ્રાપ્ય થNegative
Viewer C27051359Negative

Lay-user study

A lay user study was performed at three intended user sites with 310 lay persons for each device format. The lay users had diverse educational and professional backgrounds and ranged in age from 18 to > 50 years. Urine samples were prepared at the following concentrations; negative,

{14}------------------------------------------------

+/-75%, +/-50%, +/-25% of the cutoff by spiking drugs into drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC/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. Each device was tested. Typical results are shown below. The results summary for AMP:

% of CutoffNumber of samplesDrug Concentration by LC/MS (ng/mL)Lay person ResultsThe percentage of correct results (%)
No. of PositiveNo. of Negative
-100% Cutoff200020100
-75% Cutoff20248020100
-50% Cutoff1705080170100
-25% Cutoff2075211995
+25% Cutoff20125519195
+50% Cutoff401506400100
+75% Cutoff201748200100

The results summary for BAR:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentageof correct results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100
-75% Cutoff2073020100
-50% Cutoff1701510170100
-25% Cutoff2022311995
+25% Cutoff2037819195
+50% Cutoff20456400100
+75% Cutoff20521200100

The results summary for COC:

% of CutoffNumber ofsamplesDrugConcentration byLC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
-100% Cutoff200No. ofPositive0No. ofNegative20100
-75% Cutoff2076020100
-50% Cutoff1701540170100
-25% Cutoff2022221890
+25% Cutoff2037719195
+50% Cutoff40452400100
+75% Cutoff20528200100

The results summary for BUP:

% of CutoffNumber ofsamplesDrugConcentration byLC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100
-75% Cutoff202.6020100
-50% Cutoff1704.80170100

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-25% Cutoff20С Гلك ه19તેર
+25% Cutoff2012.619તેરી જેવી સવલતો પ્રાપ્ય થયેલી છે. આ ગામના લોકોનો મુખ્ય વ્યવસાય ખેતી, ખેતમજૂરી તેમ જ પશુપાલન છે. આ ગામમાં મુખ્યત્વે ખેત-ઉપયોગ મુખ્યત્વે આવેલું એક ગામના લોકોનો મુખ્ય વ્યવસાય
+50% Cutoff4015.440100
+75% Cutoff2017.320100

The results summary for MET:

% of CutoffNumber ofsamplesDrugConcentration byLC/MS(ng/mL)Lay person ResultsThe percentage of
No. ofPositiveNo. ofNegativecorrect results(%)
-100% Cutoff200020100
-75% Cutoff20255020100
-50% Cutoff1704960170100
-25% Cutoff2075721890
+25% Cutoff20125819195
+50% Cutoff401504400100
+75% Cutoff201744200100

The results summary for MTD:

% of CutoffNumber of samplesDrug Concentration by LC/MS(ng/mL)Lay person ResultsThe percentage of correct results (%)
No. of PositiveNo. of Negative
-100% Cutoff200020100
-75% Cutoff2073020100
-50% Cutoff1701550170100
-25% Cutoff2022811995
+25% Cutoff2037719195
+50% Cutoff40454400100
+75% Cutoff20528200100

The results summary for MOR:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage of
No. ofPositiveNo. ofNegativecorrect results(%)
-100% Cutoff200020100
-75% Cutoff2077020100
-50% Cutoff1701550170100
-25% Cutoff2022721890
+25% Cutoff2037118290
+50% Cutoff40447400100
+75% Cutoff20521200100

The results summary for OXY:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200200100
-75% Cutoff2023200100
-50% Cutoff170530170100

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-25% Cutoff207211995
+25% Cutoff2012819195
+50% Cutoff40154400100
+75% Cutoff20171200100

The results summary for PCP:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100
-75% Cutoff207020100
-50% Cutoff170110170100
-25% Cutoff201811995
+25% Cutoff203219195
+50% Cutoff4039400100
+75% Cutoff2044200100

The results summary for THC:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100
-75% Cutoff2013020100
-50% Cutoff170240170100
-25% Cutoff203811995
+25% Cutoff206419195
+50% Cutoff4077400100
+75% Cutoff2086200100

The results summary for BZO:

% of CutoffNumber ofsamplesDrugConcentration byLC/MS(ng/mL)Lay person ResultsThe percentage of
No. ofPositiveNo. ofNegativecorrect results (%)
-100% Cutoff200020100
-75% Cutoff2073020100
-50% Cutoff1701460170100
-25% Cutoff2022821890
+25% Cutoff20377200100
+50% Cutoff40452400100
+75% Cutoff20519200100

The results summary for MDMA:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage of
No. ofPositiveNo. ofNegativecorrect results(%)
-100% Cutoff200020100
-75% Cutoff20121020100
-50% Cutoff1702530170100

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-25% Cutoff2037111995
+25% Cutoff2062819195
+50% Cutoff40756400100
+75% Cutoff20879200100

The results summary for TCA:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results (%)
-100% Cutoff200020100
-75% Cutoff20254020100
-50% Cutoff1705050170100
-25% Cutoff2075511995
+25% Cutoff20125818290
+50% Cutoff401508400100
+75% Cutoff201745200100

The results summary for EDDP:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100
-75% Cutoff2073020100
-50% Cutoff1701480170100
-25% Cutoff2022811995
+25% Cutoff2037319195
+50% Cutoff40454400100
+75% Cutoff20523200100

The results summary for PPX:

% of CutoffNumber ofsamplesDrug Concentrationby LC/MS(ng/mL)Lay person ResultsThe percentage ofcorrect results(%)
No. ofPositiveNo. ofNegative
-100% Cutoff200020100
-75% Cutoff2073020100
-50% Cutoff1701540170100
-25% Cutoff20228020100
+25% Cutoff2037819195
+50% Cutoff40453400100
+75% Cutoff20523200100

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.

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11. Conclusion

Based on the test principle and acceptable performance characteristics including precision, cut-off, interference, specificity, method comparison, and lay-user studies of the devices, it's concluded that the AssureTech Panel Dip Tests and AssureTech Quick Cup Tests are substantially equivalent to the predicate.

§ 862.3100 Amphetamine test system.

(a)
Identification. An amphetamine test system is a device intended to measure amphetamine, a central nervous system stimulating drug, in plasma and urine. Measurements obtained by this device are used in the diagnosis and treatment of amphetamine use or overdose and in monitoring levels of amphetamine to ensure appropriate therapy.(b)
Classification. Class II (special controls). An amphetamine 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).