K Number
K181790
Device Name
CLUNGENE Multi-Drug Test Dip Card, CLUNGENE Multi-Drug Test Easy Cup
Date Cleared
2018-07-26

(21 days)

Product Code
Regulation Number
862.3650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
CLUNGENE® Multi-Drug Test Dip Card is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Ampletamine, Oxazepam, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of: | Drug(Identifier) | Calibrator | Cut-off level | |-------------------------------|---------------------------------------|---------------| | Amphetamine | d-Amphetamine | 1000 ng/mL | | Oxazepam | Oxazepam | 300 ng/mL | | Cocaine | Benzoylecgonine | 300 ng/mL | | Marijuana | 11-Nor-△9-Tetrahydrocannabinol-9-COOH | 50 ng/mL | | Methamphetamine | d-Methamphetamine | 1000 ng/mL | | Morphine | Morphine | 300 ng/mL | | Oxycodone | Oxycodone | 100 ng/mL | | Secobarbital | Secobarbital | 300 ng/mL | | Methadone | Methadone | 300 ng/mL | | Buprenorphine | Buprenorphine | 10 ng/mL | | Methylenedioxymethamphetamine | D,L-Methylenedioxymethamphetamine | 500 ng/mL | | Phencyclidine | Phencyclidine | 25 ng/mL | | Tricyclic Antidepressants | Nortriptyline | 1000 ng/mL | Configuration of the CLUNGENE® Multi-Drug Test Dip Card can consist of any combination of the above listed drug analytes. The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline 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. GCMS or LC/MS is the preferred confirmatory method. For in vitro diagnostic use only. CLUNGENE® Multi-Drug Test Easy Cup is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Amphetamine, Oxazepam, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of: | Drug(Identifier) | Calibrator | Cut-off level | |-------------------------------|---------------------------------------|---------------| | Amphetamine | d-Amphetamine | 1000 ng/mL | | Oxazepam | Oxazepam | 300 ng/mL | | Cocaine | Benzoylecgonine | 300 ng/mL | | Marijuana | 11-Nor-△9-Tetrahydrocannabinol-9-COOH | 50 ng/mL | | Methamphetamine | d-Methamphetamine | 1000 ng/mL | | Morphine | Morphine | 300 ng/mL | | Oxycodone | Oxycodone | 100 ng/mL | | Secobarbital | Secobarbital | 300 ng/mL | | Methadone | Methadone | 300 ng/mL | | Buprenorphine | Buprenorphine | 10 ng/mL | | Methylenedioxymethamphetamine | D,L-Methylenedioxymethamphetamine | 500 ng/mL | | Phencyclidine | Phencyclidine | 25 ng/mL | | Tricyclic Antidepressants | Nortriptyline | 1000 ng/mL | Configuration of the CLUNGENE® Multi-Drug Test Easy Cup can consist of any combination of the above listed drug analytes. The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline 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. GCMS or LC/MS is the preferred confirmatory method. For in vitro diagnostic use only.
Device Description
The CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants (target analytes) in human urine. The products are single-use in vitro diagnostic devices. The CLUNGENE Multi-Drug Test Dip Card kit contains a Dip Card device, a package insert and a urine cup for sample collection. The CLUNGENE Multi-Drug Test Easy Cup kit contains a Cup device, a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.
More Information

No
The device is described as a lateral flow immunochromatographic assay, which is a traditional immunoassay technology that does not inherently incorporate AI or ML. The description focuses on the chemical and biological components of the test.

No
Explanation: This device is an in vitro diagnostic test designed to detect the presence of various drugs in human urine. It is explicitly stated "For in vitro diagnostic use only," indicating it is used for diagnosis, not treatment, of a condition. Therefore, it is not a therapeutic device.

Yes

The device explicitly states "For in vitro diagnostic use only" and is designed for the detection of substances in human urine, which falls under the definition of a diagnostic device.

No

The device is described as an immunochromatographic assay using a lateral flow system, which is a physical test strip or cup, not software.

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

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section and the "Device Description" both explicitly state: "For in vitro diagnostic use only."
  • Nature of the Test: The device is a "competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of [various drugs] in human urine." This describes a test performed on a biological sample (urine) outside of the body (in vitro) to diagnose or detect the presence of substances.
  • Purpose: The purpose is to detect the presence of drugs in urine, which is a diagnostic activity.

The information provided clearly indicates that this device is intended to be used as an in vitro diagnostic tool.

N/A

Intended Use / Indications for Use

CLUNGENE® Multi-Drug Test Dip Card is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Ampletamine, Oxazepam, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

Drug(Identifier)CalibratorCut-off level
Amphetamined-Amphetamine1000 ng/mL
OxazepamOxazepam300 ng/mL
CocaineBenzoylecgonine300 ng/mL
Marijuana11-Nor-△9-Tetrahydrocannabinol-9-COOH50 ng/mL
Methamphetamined-Methamphetamine1000 ng/mL
MorphineMorphine300 ng/mL
OxycodoneOxycodone100 ng/mL
SecobarbitalSecobarbital300 ng/mL
MethadoneMethadone300 ng/mL
BuprenorphineBuprenorphine10 ng/mL
MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
PhencyclidinePhencyclidine25 ng/mL
Tricyclic AntidepressantsNortriptyline1000 ng/mL

Configuration of the CLUNGENE® Multi-Drug Test Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline 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. GCMS or LC/MS is the preferred confirmatory method.

For in vitro diagnostic use only.

CLUNGENE® Multi-Drug Test Easy Cup is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Amphetamine, Oxazepam, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

Drug(Identifier)CalibratorCut-off level
Amphetamined-Amphetamine1000 ng/mL
OxazepamOxazepam300 ng/mL
CocaineBenzoylecgonine300 ng/mL
Marijuana11-Nor-△9-Tetrahydrocannabinol-9-COOH50 ng/mL
Methamphetamined-Methamphetamine1000 ng/mL
MorphineMorphine300 ng/mL
OxycodoneOxycodone100 ng/mL
SecobarbitalSecobarbital300 ng/mL
MethadoneMethadone300 ng/mL
BuprenorphineBuprenorphine10 ng/mL
MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
PhencyclidinePhencyclidine25 ng/mL
Tricyclic AntidepressantsNortriptyline1000 ng/mL

Configuration of the CLUNGENE® Multi-Drug Test Easy Cup can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline 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. GCMS or LC/MS is the preferred confirmatory method.

For in vitro diagnostic use only.

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

NGL, NGG, OAW, NGM

Device Description

The CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants (target analytes) in human urine. The products are single-use in vitro diagnostic devices. The CLUNGENE Multi-Drug Test Dip Card kit contains a Dip Card device, a package insert and a urine cup for sample collection. The CLUNGENE Multi-Drug Test Easy Cup kit contains a Cup device, a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.

Mentions image processing

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Mentions AI, DNN, or ML

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Input Imaging Modality

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Anatomical Site

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Indicated Patient Age Range

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Intended User / Care Setting

Over-The-Counter Use

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

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

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

Precision studies were carried out for samples with concentrations of -100% cut off, -75% cut off, -50% cut off, -25% cut off, cut off, +25% cut off, +50% cut off, +75% cut off and +100% cut off. These samples were prepared by spiking drug in negative urine 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. Results are summarized in tables for Buprenorphine, Methylenedioxymethamphetamine, Phencyclidine Nortriptyline. The data for Methamphetamine, Morphine, Marijuana, and Amphetamine, Oxazepam, Cocaine, Secobarbital, Methadone and Oxycodone were reported in K180255.

Specificity: To test specificity, drug metabolites and other structurally related compounds that are likely to cross-react in urine samples were spiked into negative urine and were tested using three lots of each device. The lowest concentration that caused a positive result each listed for Buprenorphine, Methylenedioxymethamphetamine, Phencyclidine and Nortriptyline. The data for Methamphetamine, Morphine, Marijuana, Amphetamine, Oxazepam, Cocaine, Secobarbital, Methadone and Oxycodone were reported in K180255. There were no differences observed between the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup.

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 lots of each device. Compounds that showed no interference at a concentration of 100ug/mL are summarized in the tables. There were no differences observed between the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup. To demonstrate that there is no interference from each of the thirteen drug analytes on the other twelve drug strips, devices in both CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup were tested using standard drug urine solutions at three fold cut-off drug concentrations of each drug analyte. Tests showed positive result only for each target drug and negative result for other drugs.

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 negative for samples at and below -25% Cut-Off. There were no differences observed between the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup.

Comparison Studies: Method comparison studies for the CLUNGENE Multi-Drug Test Dip Card and the CLUNGENE Multi-Drug Test Easy Cup 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 for Buprenorphine, Methylenedioxymethamphetamine, Phencyclidine and Nortriptyline. The data for Methamphetamine, Morphine, Marijuana, Amphetamine, Oxazepam, Cocaine, Secobarbital, Methadone and Oxycodone were reported in K180255.

Lay-user study: A lay user study was performed at three intended user sites with 300 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, +/-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. Results are shown in the provided tables. 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.

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

Key metrics are presented in tables in section 10. Performance Characteristics, under "Comparison Studies" and "Lay-user study" by showing the number of positive/negative results at various concentrations relative to the cutoff, and the percentage of correct results for the lay user study.

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

K142396

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

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

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§ 862.3650 Opiate test system.

(a)
Identification. An opiate test system is a device intended to measure any of the addictive narcotic pain-relieving opiate drugs in blood, serum, urine, gastric contents, and saliva. An opiate is any natural or synthetic drug that has morphine-like pharmocological actions. The opiates include drugs such as morphine, morphine glucoronide, heroin, codeine, nalorphine, and meperedine. Measurements obtained by this device are used in the diagnosis and treatment of opiate use or overdose and in monitoring the levels of opiate administration to ensure appropriate therapy.(b)
Classification. Class II (special controls). An opiate 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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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

July 26, 2018

Hangzhou Clongene Biotech Co.,Ltd. % Jesse Xia Manager LSI International 504 E Diamond Ave, Suite I Gaithersburg, MD 20877

Re: K181790

Trade/Device Name: CLUNGENE Multi-Drug Test Dip Card CLUNGENE Multi-Drug Test Easy Cup Regulation Number: 21 CFR 862.3650 Regulation Name: Opiate test system Regulatory Class: Class II Product Code: NGL, NGG, OAW, NGM Dated: June 25, 2018 Received: July 5, 2018

Dear Jesse Xia:

We have reviewed vour 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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 comprehensive regulatory information about mediation-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

2

Indications for Use

510(k) Number (if known) K181790

Device Name

CLUNGENE® Multi-Drug Test Dip Card CLUNGENE® Multi-Drug Test Easy Cup

Indications for Use (Describe)

CLUNGENE® Multi-Drug Test Dip Card is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Ampletamine, Oxazepam, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

Drug(Identifier)CalibratorCut-off level
Amphetamined-Amphetamine1000 ng/mL
OxazepamOxazepam300 ng/mL
CocaineBenzoylecgonine300 ng/mL
Marijuana11-Nor-△9-Tetrahydrocannabinol-9-COOH50 ng/mL
Methamphetamined-Methamphetamine1000 ng/mL
MorphineMorphine300 ng/mL
OxycodoneOxycodone100 ng/mL
SecobarbitalSecobarbital300 ng/mL
MethadoneMethadone300 ng/mL
BuprenorphineBuprenorphine10 ng/mL
MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
PhencyclidinePhencyclidine25 ng/mL
Tricyclic AntidepressantsNortriptyline1000 ng/mL

Configuration of the CLUNGENE® Multi-Drug Test Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline 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. GCMS or LC/MS is the preferred confirmatory method.

For in vitro diagnostic use only.

CLUNGENE® Multi-Drug Test Easy Cup is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Amphetamine, Oxazepam, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

Drug(Identifier)CalibratorCut-off level
Amphetamined-Amphetamine1000 ng/mL
OxazepamOxazepam300 ng/mL
CocaineBenzoylecgonine300 ng/mL
Marijuana11-Nor-△9-Tetrahydrocannabinol-9-COOH50 ng/mL
Methamphetamined-Methamphetamine1000 ng/mL
MorphineMorphine300 ng/mL

3

OxycodoneOxycodone100 ng/mL
SecobarbitalSecobarbital300 ng/mL
MethadoneMethadone300 ng/mL
BuprenorphineBuprenorphine10 ng/mL
MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
PhencyclidinePhencyclidine25 ng/mL
Tricyclic AntidepressantsNortriptyline1000 ng/mL

Configuration of the CLUNGENE® Multi-Drug Test Easy Cup can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Nortriptyline 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. GCMS 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)

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K181790

510(k) SUMMARY

    1. Date: July 25, 2018 2. Submitter: Hangzhou Clongene Biotech Co., Ltd. 20 Longquan Road Hangzhou 311121, China
  • Zheng Shujian 3. Contact person: Hangzhou Clongene Biotech Co., Ltd. 20 Longquan Road Hangzhou 311121, China Telephone: 86 571 88262120 Email: frank@clongene.com.
    1. Device Name: CLUNGENE Multi-Drug Test Dip Card CLUNGENE Multi-Drug Test Easy Cup
Classification:Class 2
Product CodeClassificationRegulation SectionPanel
NFT
AmphetamineII21 CFR § 862.3100, Amphetamine Test SystemToxicology
(91)
NFW
CannabinoidsII21 CFR § 862.3870, Cannabinoids Test SystemToxicology
(91)
NFY
CocaineII21 CFR § 862.3250, Cocaine Test SystemToxicology
(91)
NGG
MethamphetamineII21 CFR § 862.3610,
Methamphetamine Test SystemToxicology
(91)
NGL
MorphineII21 CFR § 862.3650, Opiate Test SystemToxicology
(91)
NFV
OxazepamII21 CFR § 862.3170,
Benzodiazepine Test SystemToxicology
(91)
NGL
OxycodoneII21 CFR § 862.3650, Opiate Test SystemToxicology
(91)
PTH
SecobarbitalII21 CFR § 862.3150, Barbiturate Test SystemToxicology
(91)
PTG
MethadoneII21 CFR § 862.3620, Methadone Test SystemToxicology
(91)
NGL
BuprenorphineII21 CFR § 862.3650,
Opiate Test SystemToxicology
(91)
NGG
Methylenedioxy-
methamphetamineII21 CFR § 862.3610, Methamphetamine Test SystemToxicology
(91)
NGM
PhencyclidineunclassifiedEnzyme Immunoassay PhencyclidineToxicology
(91)
QAW
NortriptylineII21 CFR, 862.3910 Tricyclic
Antidepressant Drugs Test SystemToxicology
(91)
    1. Predicate Devices: K142396
      The Chemtrue® Multi-Panel Drug Screen Dip Card Tests
    1. Intended Use

5

CLUNGENE® Multi-Drug Test Dip Card is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

DrugCalibratorCut-off
Amphetamined-Amphetamine1000 ng/mL
SecobarbitalSecobarbital300 ng/mL
OxazepamOxazepam300 ng/mL
CocaineBenzoylecgonine300 ng/mL
Methamphetamined-Methamphetamine1000 ng/mL
MorphineMorphine300 ng/mL
MethadoneMethadone300 ng/mL
OxycodoneOxycodone100 ng/mL
Marijuana11-Nor-△9-Tetrahydrocannabinol-9 COOH50 ng/mL
BuprenorphineBuprenorphine10 ng/mL
MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
PhencyclidinePhencyclidine25 ng/mL
Tricyclic AntidepressantsNortriptyline1000 ng/mL

Configuration of the CLUNGENE® Multi-Drug Test Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital. Nortriptyline 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.

CLUNGENE® Multi-Drug Test Easy Cup is competitive binding, lateral flow immunochromatographic assay for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants in human urine at the cutoff concentrations of:

DrugCalibratorCut-off
Amphetamined-Amphetamine1000 ng/mL
SecobarbitalSecobarbital300 ng/mL
OxazepamOxazepam300 ng/mL
CocaineBenzoylecgonine300 ng/mL
Methamphetamined-Methamphetamine1000 ng/mL
MorphineMorphine300 ng/mL
MethadoneMethadone300 ng/mL
OxycodoneOxycodone100 ng/mL
Marijuana11-Nor-△9-Tetrahydrocannabinol-9 COOH50 ng/mL
BuprenorphineBuprenorphine10 ng/mL
MethylenedioxymethamphetamineD,L-Methylenedioxymethamphetamine500 ng/mL
PhencyclidinePhencyclidine25 ng/mL
Tricyclic AntidepressantsNortriptyline1000 ng/mL

6

Configuration of the CLUNGENE® Multi-Drug Test Easy Cup can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital. Nortriptyline 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.

    1. Device Description
      The CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants (target analytes) in human urine. The products are single-use in vitro diagnostic devices. The CLUNGENE Multi-Drug Test Dip Card kit contains a Dip Card device, a package insert and a urine cup for sample collection. The CLUNGENE Multi-Drug Test Easy Cup kit contains a Cup device, a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.

8. Substantial Equivalence Information

A summary comparison of features of the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup and the predicate devices is provided in following tables.

ItemDevicePredicate - K142396
Indication(s)
for UseFor the qualitative determination of drugs of
abuse in human urine.Same (but the number of
drugs detected is different)
Calibrator and
Cut-Off ValuesAmphetamine (AMP): 1,000 ng/ml
Oxazepam (BZO):300 ng/ml
Cocaine(COC): 300 ng/ml
11-Nor-△9-Tetrahydrocannabinol-9-COOH
(THC):50 ng/ml
Methamphetamine (MET): 1,000 ng/ml
Morphine (MOR): 300ng/mL
Oxycodone(OXY) : 100 ng/ml
Secobarbital (BAR): 300 ng/ml
Methadone (MTD): 300 ng/ml
Buprenorphine (BUP): 10 ng/ml
D.L-Methylenedioxymethamphetamine
(MDMA): 500 ng/ml
Phencyclidine (PCP): 25ng/ml
Nortriptyline (TCA): 1000ng/mlSame
Table 1: Features Comparison of CLUNGENE Multi-Drug Test Dip Card and the
Predicate Devices

7

| Methodology | Competitive binding, lateral flow
immunochromatographic assays based on the
principle of antigen antibody
immunochemistry. | Same |
|----------------|-------------------------------------------------------------------------------------------------------------------------------------|------|
| Type of Test | Qualitative | Same |
| Specimen Type | Human Urine | Same |
| Intended Use | For over-the-counter | Same |
| Configurations | Dip Card | Same |

Table 2: Features Comparison of CLUNGENE Multi-Drug Test Easy Cup Tests and the
Predicate Devices
ItemDevicePredicate - K142396
Indication(s)
for UseFor the qualitative determination of
drugs of abuse in human urine.Same (but the number of
drugs detected is different)
Calibrator and Cut-Off
ValuesAmphetamine (AMP): 1,000 ng/ml
Oxazepam (BZO):300 ng/ml
Cocaine(COC): 300 ng/ml
11-Nor-△9-Tetrahydrocannabinol-9-COOH
(THC):50 ng/ml
Methamphetamine (MET): 1,000 ng/ml
Morphine (MOR): 300ng/mL
Oxycodone(OXY) : 100 ng/mL
Secobarbital (BAR): 300 ng/ml
Methadone (MTD): 300 ng/ml
Buprenorphine (BUP): 10 ng/ml
D,L-Methylenedioxymethamphetamine
(MDMA): 500 ng/ml
Phencyclidine (PCP): 25ng/ml
Nortriptyline (TCA): 1000ng/mlSame
MethodologyCompetitive binding, lateral flow
immunochromatographic assays based on
the principle of antigen antibody
immunochemistry.Same
Type of TestQualitativeSame
Specimen TypeHuman UrineSame
Intended UseFor over-the-counterSame
ConfigurationsCupDip Card
    1. Test Principle
      The CLUNGENE Multi-Drug Test Dip Card, and CLUNGENE Multi-Drug Test Easy Cup are

8

rapid tests for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Methadone, Buprenorphine, Phencyclidine, Methylenedioxymethamphetamine and Tricyclic Antidepressants 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 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 cutoffconcentration 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
    • a. Precision

Precision studies were carried out for samples with concentrations of -100% cut off, -75% cut off. -50% cut off. -25% cut off. cut off. +25% cut off. +50% cut off , +75% cut off and +100% cut off. These samples were prepared by spiking drug in negative urine 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 Buprenorphine, Methylenedioxymethamphetamine, Phencyclidine Nortriptyline. The data for Methamphetamine, Morphine, Marijuana, and Amphetamine, Oxazepam, Cocaine, Secobarbital, Methadone and Oxycodone were reported in K180255.

| Concentration by
LC/MS (ng/mL) | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | Cut-off
+25% | Cut-off
+50% | Cut-off
+75% | Cut-off
+100% |
|-----------------------------------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Lot
Number | 0 | 2.65 | 5.01 | 7.74 | 10.47 | 12.68 | 14.58 | 16.62 | 20.30 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 28-/22+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Buprenorphine

CLUNGENE Multi-Drug Test Easy Cup

CLUNGENE Multi-Drug Test Dip Card

| Concentration by
LC/ MS (ng/mL) | -100%
Cut-off | -75%
Cut-off | -50%
Cut-off | -25%
Cut-off | Cut-off | Cut-off
+25% | Cut-off
+50% | Cut-off
+75% | Cut-off
+100% |
|------------------------------------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| Lot
Number | 0 | 2.65 | 5.01 | 7.74 | 10.47 | 12.68 | 14.58 | 16.62 | 20.30 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 29-/21+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 22-/28+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Methylenedioxymethamphetamine

CLUNGENE Multi-Drug Test Dip Card

9

| Concentration by
LC/MS (ng/mL) | -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
Number | 0 | 121 | 259 | 394 | 517 | 634 | 747 | 861 | 960 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 27-/23+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Concentration by
LC/MS (ng/mL) | -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
Number | 0 | 121 | 259 | 394 | 517 | 634 | 747 | 861 | 960 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Phencyclidine CLUNGENE Multi-Drug Test Dip Card

| Concentration by
LC/MS (ng/mL)
Lot
Number | -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 |
|----------------------------------------------------|------------------|-----------------|-----------------|-----------------|---------|-----------------|-----------------|-----------------|------------------|
| | 0 | 5.8 | 13.0 | 19.2 | 25.9 | 32.0 | 37.1 | 43.6 | 49.9 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

CLUNGENE Multi-Drug Test Easy Cup

| Concentration by
LC/MS (ng/mL) | -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
Number | 0 | 5.8 | 13.0 | 19.2 | 25.9 | 32.0 | 37.1 | 43.6 | 49.9 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 21-/29+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 27-/23+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 24-/26+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

Nortriptyline

CLUNGENE Multi-Drug Test Dip Card

| Concentration by
LC/MS (ng/mL) | -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
Number | 0 | 258 | 529 | 788 | 1054 | 1262 | 1476 | 1692 | 1929 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 18-/32+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 26-/24+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 27-/23+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

CLUNGENE Multi-Drug Test Easy Cup

10

| Concentration by
LC/MS (ng/mL) | -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
Number | 0 | 258 | 529 | 788 | 1054 | 1262 | 1476 | 1692 | 1929 |
| Lot 1 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 25-/25+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 2 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 27-/23+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |
| Lot 3 | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | 22-/28+ | 50+/0- | 50+/0- | 50+/0- | 50+/0- |

The following cut-off values are verified.

Drug(Identifier)Cut-off level
Buprenorphine (BUP)10 ng/mL
Methylenedioxymethamphetamine (MDMA)500 ng/mL
Phencyclidine (PCP )25 ng/mL
Nortriptyline (TCA)1000 ng/mL

b. Linearity

Not applicable.

c. Stability

The devices are stable at 4-30 ℃ for 24 months based on the accelerated stability study at 45 °C. Real time stability studies are ongoing.

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 lots of each device. Compounds that showed no interference at a concentration of 100ug/mL are summarized in the following tables. There were no differences observed between the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup.

Acetaminophen (4-Acetamidophenol)Ecgonine methyl esterD,L-Octopamine
AcetophenetidinEMDPOxalic acid
N-AcetylprocainamideErythromycinOxolinic acid
Acetylsalicylic acidβ-EstradiolOxymetazoline
AlbuminFenoprofenPapaverine
AminopyrineFurosemidePenicillin-G
AmoxicillinGentisic acidPerphenazine
AmpicillinHemoglobinPhenelzine
ApomorphineHydralazinePrednisone
Ascorbic acidHydrochlorothiazideDL-Propranolol
AspartameHydrocortisoneD-Pseudoephedrine
AtropineO-Hydroxyhippuric acidQuinine
Benzilic acid3-HydroxytyramineRanitidine
Benzoic acidIbuprofenSalicylic acid
BilirubinD,L-IsoproterenolSerotonin (5- Hydroxytyramine)
ChloralhydrateIsoxsuprineSulfamethazine
ChloramphenicolKetamineSulindac

11

ChlorothiazideKetoprofenTetrahydrocortisone, 3-acetate
ChlorpromazineLabetalolTetrahydrocortisone 3-(β- Dglucuronide)
CholesterolLoperamideTetrahydrozoline
ClonidineMaprotilineThiamine
CortisoneMeperidineThioridazine
(-) CotinineMeprobamateTriamterene
CreatinineMethoxyphenamineDL-Tyrosine
DeoxycorticosteroneNalidixic acidTrifluoperazine
DextromethorphanNaloxoneTrimethoprim
DiclofenacNaltrexoneD L-Tryptophan
DiflunisalNaproxenTyramine
DigoxinNiacinamideUric acid
DiphenhydramineNifedipineVerapamil
DisopyramideNorethindroneZomepirac
EDDPNoscapine

To demonstrate that there is no interference from each of the thirteen drug analytes on the other twelve drug strips, devices in both CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup were tested using standard drug urine solutions at three fold cut-off drug concentrations of each drug analyte. Tests showed positive result only for each target drug and negative result for other drugs.

e. Specificity

To test specificity, drug metabolites and other structurally related compounds that are likely to cross-react in urine samples were spiked into negative urine and were tested using three lots of each device. The lowest concentration that caused a positive result each listed for for Buprenorphine. for Methylenedioxymethamphetamine, Phencyclidine and Nortriptyline. The data for Methamphetamine, Morphine, Marijuana, Amphetamine, Oxazepam, Cocaine, Secobarbital, Methadone and Oxycodone were reported in K180255. There were no differences observed between the CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup.

| Buprenorphine
(Cut-off=10 ng/mL) | Result
Positive at (ng/mL) | % Cross-Reactivity |
|-------------------------------------|-------------------------------|--------------------|
| Buprenorphine | 10 | 100% |
| Buprenorphine -3-D-Glucuronide | 15 | 67% |
| Norbuprenorphine | 20 | 50% |
| Norbuprenorphine-3-D-Glucuronide | 200 | 5% |
| Morphine | >100000 | 100000 | 100000 | 100000 | 100000 | 100000 | 100000 | 50 years. Urine samples were prepared at the following concentrations; negative, +/-75%, +/-50%, +/-25% of the cutoff by spiking drugs into drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC/MS. Each sample was aliquoted into individual containers and blind-labeled. Each participant was provided with the package insert,

17

1 blind labeled sample and a device. Each device was tested. Results are shown below. CLUNGENE Multi-Drug Test Dip Card

| | % of Cut-off | Number
of
samples | Concentration by
LC/MS
(ng/mL) | Lay person results | | The
percentage
of correct
results
(%) |
|-----------------------------------|---------------|--------------------------------------|--------------------------------------|--------------------|---------------------------------------------------|---------------------------------------------------|
| Drugs | | | | No. of
Positive | No. of
Negative | |
| AMP | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 250 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 500 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 750 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 1250 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 1500 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 1750 | 20 | 0 | 100 |
| BAR | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 375 | 18 | 2 | 90 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| COC | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 375 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| BZO | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 375 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| MET | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 250 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 500 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 750 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 1250 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 1500 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 1750 | 20 | 0 | 100 |
| MTD | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 375 | 18 | 2 | 90 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| MOP | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 2 | 18 | 90 |
| | +25% Cut-off | 20 | 375 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| OXY | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 25 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 50 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 75 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 125 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 150 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 175 | 20 | 0 | 100 |
| | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 12.5 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 25 | 0 | 160 | 100 |
| THC | -25% Cut-off | 20 | 37.5 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 62.5 | 18 | 2 | 90 |
| | +50% Cut-off | 40 | 75 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 87.5 | 20 | 0 | 100 |
| | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 250 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 500 | 0 | 160 | 100 |
| TCA | -25% Cut-off | 20 | 750 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 1250 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 1500 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 1750 | 20 | 0 | 100 |
| | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 2.5 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 5 | 0 | 160 | 100 |
| BUP | -25% Cut-off | 20 | 7.5 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 12.5 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 15 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 17.5 | 20 | 0 | 100 |
| | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 6.25 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 12.5 | 0 | 160 | 100 |
| PCP | -25% Cut-off | 20 | 18.75 | 2 | 18 | 90 |
| | +25% Cut-off | 20 | 31.25 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 37.5 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 43.75 | 20 | 0 | 100 |
| | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 125 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 250 | 0 | 160 | 100 |
| MDMA | -25% Cut-off | 20 | 375 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 625 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 750 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 875 | 20 | 0 | 100 |
| CLUNGENE Multi-Drug Test Easy Cup | | | | | | |
| | of
samples | Concentration by
LC/MS
(ng/mL) | No. of
Positive | No. of
Negative | The
percentage of
correct
results
(%) | |
| AMP | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 250 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 500 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 750 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 1250 | 18 | 2 | 90 |
| | +50% Cut-off | 40 | 1500 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 1750 | 20 | 0 | 100 |
| BAR | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 375 | 18 | 2 | 90 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| COC | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 375 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| BZO | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 375 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| MET | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 250 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 500 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 750 | 2 | 18 | 90 |
| | +25% Cut-off | 20 | 1250 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 1500 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 1750 | 20 | 0 | 100 |
| MTD | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 375 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| MOP | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 75 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 150 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 225 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 375 | 20 | 0 | 100 |
| | | | | | | |
| | +50% Cut-off | 40 | 450 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 525 | 20 | 0 | 100 |
| OXY | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 25 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 50 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 75 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 125 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 150 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 175 | 20 | 0 | 100 |
| THC | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 12.5 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 25 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 37.5 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 62.5 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 75 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 87.5 | 20 | 0 | 100 |
| TCA | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 250 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 500 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 750 | 1 | 19 | 95 |
| | +25% Cut-off | 20 | 1250 | 18 | 2 | 90 |
| | +50% Cut-off | 40 | 1500 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 1750 | 20 | 0 | 100 |
| BUP | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 2.5 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 5 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 7.5 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 12.5 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 15 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 17.5 | 20 | 0 | 100 |
| PCP | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 6.25 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 12.5 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 18.75 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 31.25 | 20 | 0 | 100 |
| | +50% Cut-off | 40 | 37.5 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 43.75 | 20 | 0 | 100 |
| MDMA | -100% Cut-off | 20 | 0 | 0 | 20 | 100 |
| | -75% Cut-off | 20 | 125 | 0 | 20 | 100 |
| | -50% Cut-off | 160 | 250 | 0 | 160 | 100 |
| | -25% Cut-off | 20 | 375 | 0 | 20 | 100 |
| | +25% Cut-off | 20 | 625 | 19 | 1 | 95 |
| | +50% Cut-off | 40 | 750 | 40 | 0 | 100 |
| | +75% Cut-off | 20 | 875 | 20 | 0 | 100 |

18

19

20

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

21

3. Clinical Studies

Not applicable.

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 CLUNGENE Multi-Drug Test Dip Card and CLUNGENE Multi-Drug Test Easy Cup are substantially equivalent to the predicate.