K Number
K192515
Device Name
BIOEASY Marijuana Test Dip Card 40, BIOEASY Marijuana Test Dip Card 20, BIOEASY Marijuana Test Strip 40, BIOEASY Marijuana Test Strip 20
Date Cleared
2019-10-11

(28 days)

Product Code
Regulation Number
862.3870
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
BIOEASY Marijuana Test Dip Card 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL. 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. BIOEASY Marijuana Test Strip 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL. 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. BIOEASY Marijuana Test Dip Card 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL. 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. BIOEASY Marijuana Test Strip 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL. 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.
Device Description
The BIOEASY Marijuana Test Dip Card and the BIOEASY Marijuana Test Strip tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Marijuana in human urine. The products are single-use in vitro diagnostic devices. Each test kit contains a Test Device and a package insert. Each test device is sealed with a desiccant in an aluminum pouch
More Information

Not Found

No
The device description and performance studies indicate a standard lateral flow immunochromatographic assay, with no mention of AI or ML technology.

No
This device is an in vitro diagnostic test designed to detect Marijuana in human urine. It is used for screening purposes and provides preliminary results, not for treating any condition or disease.

Yes

Explanation: The "Intended Use / Indications for Use" section explicitly states "For in vitro diagnostic use only," and the "Device Description" section identifies the products as "single-use in vitro diagnostic devices."

No

The device description clearly states it is an immunochromatographic assay using a lateral flow system, which is a physical test strip or card, not software.

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

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section for all listed devices clearly states: "For in vitro diagnostic use only."
  • Device Description: The "Device Description" section explicitly states: "The products are single-use in vitro diagnostic devices."
  • Nature of the Test: The test is designed to detect a substance (Marijuana) in a human biological sample (urine) to provide information about a person's health status (presence of Marijuana). This is the fundamental definition of an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

BIOEASY Marijuana Test Dip Card 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL.

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.

BIOEASY Marijuana Test Strip 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL.

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.

BIOEASY Marijuana Test Dip Card 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL.

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.

BIOEASY Marijuana Test Strip 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL.

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.

Note: Section 6. Indications for Use repeats identical text.

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

LDJ

Device Description

The BIOEASY Marijuana Test Dip Card and the BIOEASY Marijuana Test Strip tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Marijuana in human urine. The products are single-use in vitro diagnostic devices. Each test kit contains a Test Device and a package insert. Each test device is sealed with a desiccant in an aluminum pouch

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Human urine

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Prescription Use

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

Not Found

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

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 11-Nor-△9-THC-9-COOH in negative samples. Each 11-Nor-△9-THC-9-COOH 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 six runs per day for 10 days per device lot in a randomized order.

Method comparison studies for the BIOEASY Marijuana test devices were performed in-house with three laboratory assistants for each device format. Operators ran 80 (40 negative and 40 positive) unaltered clinical samples. The samples were blind labeled and compared to LC/MS results.

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

Analytical Performance
a. Precision:
For Dip Card of 20ng/mL Cut-off
Lot 1: At -25% cutoff, 58-/2+; At cutoff, 32-/28+; At +25% cut off, 59+/1-
Lot 2: At -25% cutoff, 59-/1+; At cutoff, 29-/31+; At +25% cut off, 59+/1-
Lot 3: At -25% cutoff, 59-/1+; At cutoff, 30-/30+; At +25% cut off, 58+/2-

For Strip of 20ng/mL Cut-off
Lot 1: At -25% cutoff, 59-/1+; At cutoff, 30-/30+; At +25% cut off, 58+/2-
Lot 2: At -25% cutoff, 58-/2+; At cutoff, 32-/28+; At +25% cut off, 58+/2-
Lot 3: At -25% cutoff, 59-/1+; At cutoff, 31-/29+; At +25% cut off, 57+/3-

For Dip Card of 40ng/mL Cut-off
Lot 1: At -25% cutoff, 59-/1+; At cutoff, 31-/29+; At +25% cut off, 58+/2-
Lot 2: At -25% cutoff, 57-/3+; At cutoff, 28-/32+; At +25% cut off, 59+/1-
Lot 3: At -25% cutoff, 58-/2+; At cutoff, 29-/31+; At +25% cut off, 59+/1-

For Strip of 40ng/mL Cut-off
Lot 1: At -25% cutoff, 58-/2+; At cutoff, 32-/28+; At +25% cut off, 59+/1-
Lot 2: At -25% cutoff, 59-/1+; At cutoff, 29-/31+; At +25% cut off, 57+/3-
Lot 3: At -25% cutoff, 58-/2+; At cutoff, 31-/29+; At +25% cut off, 58+/2-

c. Stability: The devices are stable at 4-30 ℃ for 24 months based on the accelerated stability study at 45 ℃ and real time stability determinations at both 4 ℃ and 30 ℃.

d. Interference: No interference was observed at a concentration of 100ug/mL (albumin at 100 mg/dL and ethanol at 1%) for compounds tested. There were no differences observed for both the strip and dip card formats at the two different cut-offs.

e. Specificity: Compounds tested for specificity showed varying cross-reactivity based on the cut-off concentration (20 ng/mL and 40 ng/mL). For example, at 20 ng/mL cut-off, 11-nor-Δ9-THC-9-COOH showed 100% cross-reactivity at 20 ng/mL, while Cannabidiol showed 100000 ng/mL.

f. Effect of Urine Specific Gravity and Urine pH: Urine samples with 1.000 to 1.035 specific gravity or pH 4 to 9 were tested. Results were all positive for samples at and above +50% Cut-Off and all negative for samples at and below -50% Cut-Off. No differences were observed for different device formats or cut-offs.

2. Comparison Studies (Method comparison studies performed in-house with 3 laboratory assistants for each device format using 80 unaltered clinical samples - 40 negative and 40 positive).
Strip Format of 20ng/mL Cut-off
Operator A: Positive (0 Negative, 0 Low Negative, 2 Near Cutoff Negative, 18 Near Cutoff Positive, 20 High Positive); Negative (6 Negative, 16 Low Negative, 16 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)
Operator B: Positive (0 Negative, 0 Low Negative, 3 Near Cutoff Negative, 18 Near Cutoff Positive, 20 High Positive); Negative (6 Negative, 16 Low Negative, 15 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)
Operator C: Positive (0 Negative, 0 Low Negative, 2 Near Cutoff Negative, 18 Near Cutoff Positive, 20 High Positive); Negative (6 Negative, 16 Low Negative, 16 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)

Dip Card Format of 20ng/mL Cut-off
Operator D: Positive (0 Negative, 0 Low Negative, 2 Near Cutoff Negative, 18 Near Cutoff Positive, 20 High Positive); Negative (6 Negative, 16 Low Negative, 16 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)
Operator E: Positive (0 Negative, 0 Low Negative, 2 Near Cutoff Negative, 19 Near Cutoff Positive, 20 High Positive); Negative (6 Negative, 16 Low Negative, 16 Near Cutoff Negative, 1 Near Cutoff Positive, 0 High Positive)
Operator F: Positive (0 Negative, 0 Low Negative, 3 Near Cutoff Negative, 18 Near Cutoff Positive, 20 High Positive); Negative (6 Negative, 16 Low Negative, 15 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)

Strip Format of 40ng/mL Cut-off
Operator A: Positive (0 negative, 0 low negative, 1 near cutoff negative, 17 near cutoff positive, 22 high positive); Negative (6 Negative, 13 Low Negative, 20 Near Cutoff Negative, 1 Near Cutoff Positive, 0 High Positive)
Operator B: Positive (0 negative, 0 low negative, 1 near cutoff negative, 16 near cutoff positive, 22 high positive); Negative (6 Negative, 13 Low Negative, 20 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)
Operator C: Positive (0 negative, 0 low negative, 1 near cutoff negative, 17 near cutoff positive, 22 high positive); Negative (6 Negative, 13 Low Negative, 20 Near Cutoff Negative, 1 Near Cutoff Positive, 0 High Positive)

Dip Card Format of 40ng/mL Cut-off
Operator D: Positive (0 negative, 0 low negative, 2 near cutoff negative, 17 near cutoff positive, 22 high positive); Negative (6 Negative, 13 Low Negative, 19 Near Cutoff Negative, 1 Near Cutoff Positive, 0 High Positive)
Operator E: Positive (0 negative, 0 low negative, 1 near cutoff negative, 16 near cutoff positive, 22 high positive); Negative (6 Negative, 13 Low Negative, 20 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)
Operator F: Positive (0 negative, 0 low negative, 2 near cutoff negative, 16 near cutoff positive, 22 high positive); Negative (6 Negative, 13 Low Negative, 19 Near Cutoff Negative, 2 Near Cutoff Positive, 0 High Positive)

3. Clinical Studies: Not applicable.

Conclusion: Based on the test principle and acceptable performance characteristics including precision, cut-off, interference, specificity, and method comparison studies of the devices, it's concluded that the BIOEASY Marijuana Test Dip Card and BIOEASY Marijuana Test Strip tests are substantially equivalent to the predicate.

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

Discordant Results are provided but sensitivity, specificity, PPV, NPV were not calculated. The results categorized by "Negative", "Low Negative", "Near Cutoff Negative", "Near Cutoff Positive", and "High Positive" represent classifications relative to the cutoff value, rather than typical key metrics.

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.

K182530

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.

Not Found

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).

Not Found

§ 862.3870 Cannabinoid test system.

(a)
Identification. A cannabinoid test system is a device intended to measure any of the cannabinoids, hallucinogenic compounds endogenous to marihuana, in serum, plasma, saliva, and urine. Cannabinoid compounds includedelta -9-tetrahydrocannabinol, cannabidiol, cannabinol, and cannabichromene. Measurements obtained by this device are used in the diagnosis and treatment of cannabinoid use or abuse and in monitoring levels of cannabinoids during clinical investigational use.(b)
Classification. Class II (special controls). A cannabinoid 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, with the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, and then the word "ADMINISTRATION" in a smaller font size, also in blue.

October 11, 2019

Shenzhen Bioeasy Biotechnology Co.,Ltd. % Joe Shia, Director LSI International Inc. 504E Diamond Ave., Suite I Gaithersburg, MD 20877

Re: K192515

Trade/Device Name: BIOEASY Marijuana Test Dip Card 40, BIOEASY Marijuana Test Dip Card 20, BIOEASY Marijuana Test Strip 40, BIOEASY Marijuana Test Strip 20 Regulation Number: 21 CFR 862.3870 Regulation Name: Cannabinoid test system Regulatory Class: Class II Product Code: LDJ Dated: September 3, 2019 Received: September 13, 2019

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. 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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's

1

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/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-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 Kelm, Ph.D. Acting Director Division of Chemistry and Toxicology Devices OHT7: Office of In Vitro Diagnostics and Radiological Health Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K192515

Device Name

BIOEASY Marijuana Test Dip Card 40; BIOEASY Marijuana Test Dip Card 20; BIOEASY Marijuana Test Strip 40; BIOEASY Marijuana Test Strip 20

Indications for Use (Describe)

BIOEASY Marijuana Test Dip Card 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL.

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.

BIOEASY Marijuana Test Strip 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL.

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.

BIOEASY Marijuana Test Dip Card 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL.

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.

BIOEASY Marijuana Test Strip 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL.

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.

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

Prescription Use (Part 21 CFR 201 Subpart D)
Over-The-Counter Use (21 CFR 201 Subpart G)

X Prescription Use (Part 21 CFR 801 Subpart D)

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

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K192515 510(k) SUMMARY

1. Date:October 10, 2019
2. Submitter:Shenzhen Bioeasy Biotechnology Co., Ltd.
No.2-1, Liuxian 1st Road
Baoan District
Shenzhen, China 518101
3. Contact person:Joe Shia
LSI International Inc.
504E Diamond Ave., Suite I
Gaithersburg, MD 20877
Telephone: 240-505-7880
Email: shiajl@yahoo.com
4. Device Name:BIOEASY Marijuana Test Dip Card 20
BIOEASY Marijuana Test Strip 20
BIOEASY Marijuana Test Dip Card 40
BIOEASY Marijuana Test Strip 40
Classification:Class 2
Product CodeClassificationRegulation SectionPanel
LDJII21 CFR § 862.3870, CannabinoidsToxicology (91)
CannabinoidsTest System
    1. Predicate Devices: K182530
      The Bioeasy Multi-Drug Test Cup
    1. Indications for Use
      BIOEASY Marijuana Test Dip Card 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL.

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.

BIOEASY Marijuana Test Dip Card 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL.

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.

BIOEASY Marijuana Test Strip 20 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 20 ng/mL.

4

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.

BIOEASY Marijuana Test Strip 40 is competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 40 ng/mL.

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.

    1. Device Description
      The BIOEASY Marijuana Test Dip Card and the BIOEASY Marijuana Test Strip tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Marijuana in human urine. The products are single-use in vitro diagnostic devices. Each test kit contains a Test Device and a package insert. Each test device is sealed with a desiccant in an aluminum pouch
    1. Substantial Equivalence Information
      A summary comparison of features of the BIOEASY Marijuana Test devices and the predicate devices is provided in following table.
ItemDevicePredicate - K182530
Indication(s) for UseFor the qualitative determination of marijuana in human urine.Same (but the number of drugs detected is different)
Calibrator and Cut-Off ValuesMarijuana (THC)
20 ng/ml
or 40 ng/ml50 ng/ml
MethodologyCompetitive binding, lateral flow immunochromatographic assays based on the principle of antigen antibody immunochemistry.Same
Type of TestQualitativeSame
Specimen TypeHuman UrineSame
Intended UseFor prescription useFor over-the-counter
ConfigurationsDip Card and StripCup

Table 1: Features Comparison of BIOEASY Marijuana Test devices and the Predicate Devices

9. Test Principle

The BIOEASY Marijuana Test Dip Card and the BIOEASY Marijuana Test Strip tests are rapid tests for the qualitative detection of Marijuana in urine samples. The tests are lateral flow

5

chromatographic immunoassays. During testing, a urine specimen migrates upward by capillary action. If the target drug present in the urine specimen is 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 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

a. Precision

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 11-Nor-△9-THC-9-COOH in negative samples. Each 11-Nor-△9-THC-9-COOH 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 six runs per day for 10 days per device lot in a randomized order. The results obtained are summarized in the following tables.

Lot Number-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 160-/0+60-/0+60-/0+58-/2+32-/28+59+/1-60+/0-60+/0-60+/0-
Lot 260-/0+60-/0+60-/0+59-/1+29-/31+59+/1-60+/0-60+/0-60+/0-
Lot 360-/0+60-/0+60-/0+59-/1+30-/30+58+/2-60+/0-60+/0-60+/0-

Dip Card of 20ng/mL Cut-off

Strip of 20ng/mL Cut-off

| Lot
Number | -100%
cut off | -75%
cut off | -50%
cut off | -25%
cutoff | cut off | +25%
cut off | +50%
cut off | +75%
cut off | +100%
cut off |
|---------------|------------------|-----------------|-----------------|----------------|---------|-----------------|-----------------|-----------------|------------------|
| Lot 1 | 60-/0+ | 60-/0+ | 60-/0+ | 59-/1+ | 30-/30+ | 58+/2- | 60+/0- | 60+/0- | 60+/0- |
| Lot 2 | 60-/0+ | 60-/0+ | 60-/0+ | 58-/2+ | 32-/28+ | 58+/2- | 60+/0- | 60+/0- | 60+/0- |
| Lot 3 | 60-/0+ | 60-/0+ | 60-/0+ | 59-/1+ | 31-/29+ | 57+/3- | 60+/0- | 60+/0- | 60+/0- |

Dip Card of 40ng/mL Cut-off

| Lot
Number | -100%
cut off | -75%
cut off | -50%
cut off | -25%
cutoff | cut off | +25%
cut off | +50%
cut off | +75%
cut off | +100%
cut off |
|---------------|------------------|-----------------|-----------------|----------------|---------|-----------------|-----------------|-----------------|------------------|
| Lot 1 | 60-/0+ | 60-/0+ | 60-/0+ | 59-/1+ | 31-/29+ | 58+/2- | 60+/0- | 60+/0- | 60+/0- |
| Lot 2 | 60-/0+ | 60-/0+ | 60-/0+ | 57-/3+ | 28-/32+ | 59+/1- | 60+/0- | 60+/0- | 60+/0- |
| Lot 3 | 60-/0+ | 60-/0+ | 60-/0+ | 58-/2+ | 29-/31+ | 59+/1- | 60+/0- | 60+/0- | 60+/0- |

Strip of 40ng/mL Cut-off

| Lot
Number | -100%
cut off | -75%
cut off | -50%
cut off | -25%
cutoff | cut off | +25%
cut off | +50%
cut off | +75%
cut off | +100%
cut off |
|---------------|------------------|-----------------|-----------------|----------------|---------|-----------------|-----------------|-----------------|------------------|
| Lot 1 | 60-/0+ | 60-/0+ | 60-/0+ | 58-/2+ | 32-/28+ | 59+/1- | 60+/0- | 60+/0- | 60+/0- |
| Lot 2 | 60-/0+ | 60-/0+ | 60-/0+ | 59-/1+ | 29-/31+ | 57+/3- | 60+/0- | 60+/0- | 60+/0- |

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Lot 360-/0+60-/0+60-/0+58-/2+31-/29+58+/2-60+/0-60+/0-60+/0-
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c. Stability

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

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 50% below and 50% above Cut-Off levels. These urine samples were tested using three batches of each device. Compounds that showed no interference at a concentration of 100ug/mL (albumin was tested at 100 mg/dL and ethanol was tested at 1%) are summarized in the following tables. There were no differences observed for both the strip and dip card formats at the two different cut-offs.

Acetaminophenß-EstradiolOxalic acid
AcetophenetidinErythromycinOxolinic acid
N-AcetylprocainamideEthanol (1% v/v)Oxymetazoline
Acetylsalicylic acidFenoprofenPapaverine
Albumin (100 mg/dL)FurosemidePenicillin G
AminopyrineGentisic acidPerphenazine
AmoxicillinHemoglobinPhenelzine
AmpicillinHydralazinePrednisone
ApomorphineHydrochlorothiazide(±)-Propranolol
Ascorbic acidHydrocortisonePseudoephedrine
AspartameO-Hydroxyhippuric acidQuinine
Atropine3-HydroxytyramineRanitidine
Benzilic acidIbuprofenSalicylic acid
Benzoic acidIsoproterenolSerotonin (5- Hydroxytyramine)
BilirubinIsoxsuprineSulfamethazine
Chloral hydrateKetamineSulindac
Tetrahydrocortisone 3-(β-
ChloramphenicolKetoprofenDglucuronide)
ChlorothiazideLabetalolTetrahydrocortisone 3-acetate
ChlorpromazineLoperamideTetrahydrozoline
CholesterolMeperidineThiamine
ClonidineMeprobamateThioridazine
CortisoneMethoxyphenamineTriamterene
(-)-CotinineNalidixic acidTrifluoperazine
CreatinineNaloxoneTrimethoprim
DeoxycorticosteroneNaltrexoneDL-Tryptophan
DextromethorphanNaproxenTyramine
DiclofenacNiacinamideDL-Tyrosine
DiflunisalNifedipineUric acid
DigoxinNorethindroneVerapamil
DiphenhydramineNoscapineZomepirac
Ecgonine methyl ester(±)-Octopamine

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 format. The lowest concentration that caused a positive result for each compound are listed below. There are no differences for different device formats.

7

For cut-off 20ng/mL
THC(Cannabinoids)
(11-nor-Δ9-THC-9-COOH, Cut-off = 20 ng/mL)Result% Cross-Reactivity
11-nor-Δ9-THC-9-COOHPositive at 20 ng/mL100%
11-Hydroxy-Δ9-TetrahydrocannabinolPositive at 20 ng/mL100%
11-Nor-Δ8-Tetrahydrocannabinol-9-COOHPositive at 20 ng/mL100%
CannabinolPositive at 8000 ng/mL0.25%
Δ8-TetrahydrocannabinolPositive at 6000 ng/mL0.33%
Δ9-TetrahydrocannabinolPositive at 6000 ng/mL0.33%
CannabidiolPositive> 100000 ng/mL100000 ng/mL