K Number
K221605
Date Cleared
2023-07-25

(418 days)

Product Code
Regulation Number
862.3650
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Emit® II Plus Buprenorphine Assay is a homogeneous enzyme immunoassay with a 5 ng/mL cutoff. The assay is intended for use in laboratories for the qualitative and/or semiquantitative analyses of buprenorphine in human urine. Emit® II Plus assays are designed for use with a number of chemistry analyzers.

The semiquantitative mode is for the purpose of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as Liquid Chromatography/Mass Spectrometry (LC/MS) or permitting laboratories to establish quality control procedures.

The Emit® II Plus Burrenorphine Assay provides only a preliminary analytical test result. A more specific alternative chemical method(s) must be used to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry (GC/ MS) or LC/MS are the preferred confirmatory methods. Other chemical confirmation methods are available. Clinical consideration and professional judgment should be applied to any drug-of-abuse test result, particularly when preliminary positive results are used.

For Professional Use.

Caution: Federal (USA) law restricts this device to sale by or on the order of a licensed healthcare professional.

For in vitro diagnostic use.

Device Description

The Emit® II Plus Buprenorphine Assay is a homogeneous enzyme immunoassay technique used for the analysis of specific compounds in human urine. The assay is based on competition between drug in the specimen and drug labeled with the recombinant glucose-6-phosphate dehydrogenase (rG6PDH) for antibody binding sites. Enzyme activity decreases upon binding to the antibody, so the drug concentration in the specimen can be measured in terms of enzyme activity. Active enzyme converts nicotinamide adenine dinucleotide (NAD) to NADH in the presence of glucose-6phosphate (G6P), resulting in an absorbance change that is measured spectrophotometrically. Endogenous serum G6PDH does not interfere because the coenzyme NAD functions only with the bacterial (Leuconostoc mesenteroides) enzyme employed in the assay.

The Emit® II Plus Buprenorphine Assay reagents are provided liquid, ready to use and may be used directly from the refrigerator. The product is sold in three (3) kit sizes: 28 mL, 115 mL, and 1000 mL. Reagents 1 and 2 are provided as a matched set. They should not be interchanged with components of kits with different lot numbers.

Antibody/Substrate Reagent 1: Mouse monoclonal antibodies to buprenorphine (0.53 µg/mL)*.NAD (6.9 mM), G6P (10.9 mM), bovine serum albumin, preservatives, and stabilizers. *The antibody titer and enzyme conjugate activity may vary from lot to lot.

Enzyme Reagent 2: Norbuprenorphine labeled with bacterial rG6PDH (0.50 µg/mL), HEPES buffer, bovine serum albumin, preservatives, and stabilizers, where the antibody titer and enzyme conjugate activity may vary from lot to lot.

AI/ML Overview

The marketing submission for the Siemens Healthineers Emit® II Plus Buprenorphine Assay (K221605) demonstrates that the device meets its acceptance criteria through various performance studies. Below is a breakdown of the requested information:

1. Table of Acceptance Criteria and Reported Device Performance

The acceptance criteria are not explicitly stated as strict numerical thresholds in the provided document, but rather demonstrated through the qualitative agreement and recovery percentages, as well as precision and specificity profiles. Based on the "Method Comparison" results, the implicit acceptance criterion for qualitative agreement against LC/MS/MS is a high percentage, and for recovery, it's generally close to 100%. For specificity, it's low or negligible cross-reactivity with other substances (ideally less than the cutoff concentration when tested at high concentrations). For precision, it's low coefficient of variation (CV).

Metric / Acceptance CriteriaReported Device Performance (Emit® II Plus Buprenphine Assay on DxC 500 AU)
Method Comparison (Qualitative Agreement with LC/MS/MS)92.5% Agreement
Recovery vs Nominal ValueRanges from 95% to 104% (average ~98.5%)
Recovery vs LC/MS/MSRanges from 86% to 100% (average ~93.8%)
Precision (Repeatability %CV)1.1% to 6.6% (for relevant concentration ranges)
Precision (Within-Lab Precision %CV)2.8% to 6.6% (for relevant concentration ranges)
Total Reproducibility Precision %CV3.0% to 5.3%
Specificity (Cross-reactivity with Buprenorphine Metabolites)Buprenorphine: 98%, Norbuprenorphine: 106%, Glucuronides: 0.10%
Specificity (Cross-reactivity with Structurally Related Compounds)<0.1% for all tested compounds at 100,000 ng/mL
Specificity (Cross-reactivity with Structurally Un-Related Compounds)All tested compounds at high concentrations (µg/mL) showed 'Neg' response for the -40% Control and 'Pos' for the +40% Control, indicating no interference impacting the cutoff.
Interference (Endogenous and Exogenous Substances)All tested substances showed 'Neg' response for the -40% Control and 'Pos' for the +40% Control, indicating no interference impacting the cutoff.
Interference (pH and Specific Gravity)All tested pH and specific gravity levels showed 'Neg' response for the -40% Control and 'Pos' for the +40% Control, indicating no interference impacting the cutoff.

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

  • Method Comparison: 120 native urine individual patient samples. The samples were collected from external suppliers, received frozen, and thawed before testing. 21% were within -50% of the cutoff and 19% within +50% of the cutoff. The provenance is not explicitly stated in terms of country of origin but implies human urine samples from external suppliers. The study design is retrospective, using previously collected samples.
  • Recovery: 9 urine samples prepared by spiking buprenorphine into negative urine pools.
  • Precision (Repeatability and Within-Lab): 11 urine samples prepared by spiking buprenorphine into negative urine pools.
  • Precision (Reproducibility): 3 urine samples (Negative Control, Cutoff Calibrator, Positive Control from Emit II Plus Specialty Drug Control line).
  • Limit of Detection: 4 blank samples and 4 low-level samples (buprenorphine spiked into drug-free urine). A minimum of 60 replicate measurements per sample set.
  • Specificity and Cross-reactivity: The number of unique compounds tested is substantial (listed in Tables 9, 10, and 11), with samples assayed in five replicates for each compound.
  • Interference: Various endogenous and exogenous substances, as well as pH and specific gravity variations, were tested at specified concentrations. Samples were assayed in five replicates.

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

  • For the Method Comparison study, the ground truth was established by LC/MS/MS (Liquid Chromatography/Mass Spectrometry/Mass Spectrometry). This is a highly specific and sensitive analytical method considered the gold standard for drug confirmation testing. No human experts are explicitly described as establishing the ground truth; it's based on the instrumental analytical results.
  • For Recovery, the ground truth (nominal value) for spiked samples was determined gravimetrically based on stock concentration and confirmed by LC/MS/MS.
  • For Precision, Limit of Detection, Specificity, and Interference, the ground truth is based on the known concentrations of spiked substances or the known characteristics of the samples (e.g., drug-free urine, specific pH levels). Instrumental analysis is used to determine the device's measurement against these known values.

4. Adjudication Method for the Test Set

  • For the qualitative analysis in the Method Comparison, the results from the Emit® II Plus Buprenorphine Assay on DxC 500 AU were compared directly against the results from LC/MS/MS. A 2x2 box plot was used to assess qualitative agreement. There is no mention of a human adjudication method (e.g., 2+1 or 3+1), as the comparison is between two analytical methods.

5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

  • No MRMC comparative effectiveness study was done. This device is an in vitro diagnostic assay, not an AI-assisted interpretation device that would involve human readers.

6. Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study

  • Yes, the entire performance evaluation presented is a standalone study of the analytical performance of the Emit® II Plus Buprenorphine Assay on the DxC 500 AU Clinical Chemistry Analyzer. There is no human-in-the-loop component for interpreting the assay's results; the device produces qualitative or semi-quantitative analytical results directly.

7. Type of Ground Truth Used

  • Analytical Ground Truth:
    • LC/MS/MS (Liquid Chromatography/Mass Spectrometry/Mass Spectrometry) for method comparison and as a reference for recovery studies.
    • Known concentrations of spiked urine samples (gravimetrically determined nominal values) for recovery, precision, limit of detection, specificity, and interference studies. This involves preparing samples with precisely known amounts of the analyte or interfering substances.
    • Drug-free urine pools for negative controls and spiking experiments.

8. Sample Size for the Training Set

  • The document describes performance evaluation studies for a device, not a machine learning algorithm that requires a "training set." Therefore, there is no mention of a training set or its sample size in the context of this device's regulatory submission.

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

  • As this is not a machine learning-based device, there is no training set and thus no ground truth established for a training set. The studies focus on demonstrating the analytical performance of the immunoassay against recognized analytical standards and spiked samples with known concentrations.

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is a blue square with the letters "FDA" in white, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Siemens Healthcare Diagnostics Inc. Julie Warren Regulatory Affairs Professional 500 GBC Dr. P.O. Box 6101, Mailstop 514 Newark, DE 19714

Re: K221605

Trade/Device Name: Emit® II Plus Buprenorphine Assay Regulation Number: 21 CFR 862.3650 Regulation Name: Opiate Test System Regulatory Class: Class II Product Code: DJG Dated: March 16, 2023 Received: March 17, 2023

Dear Julie Warren:

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 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

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  1. 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 (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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/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.

Joseph A. Digitally signed by Kotarek -S Date: 2023.07.25

Joseph Kotarek, Ph.D. Branch Chief Division of Chemistry and Toxicology Devices OHT7: Office of In Vitro Diagnostics Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K221605

Device Name Emit® II Plus Buprenorphine Assay

Indications for Use (Describe)

The Emit® II Plus Buprenorphine Assay is a homogeneous enzyme immunoassay with a 5 ng/mL cutoff. The assay is intended for use in laboratories for the qualitative and/or semiquantitative analyses of buprenorphine in human urine. Emit® II Plus assays are designed for use with a number of chemistry analyzers.

The semiquantitative mode is for the purpose of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as Liquid Chromatography/Mass Spectrometry (LC/MS) or permitting laboratories to establish quality control procedures.

The Emit® II Plus Burrenorphine Assay provides only a preliminary analytical test result. A more specific alternative chemical method(s) must be used to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry (GC/ MS) or LC/MS are the preferred confirmatory methods. Other chemical confirmation methods are available. Clinical consideration and professional judgment should be applied to any drug-of-abuse test result, particularly when preliminary positive results are used.

For Professional Use.

Caution: Federal (USA) law restricts this device to sale by or on the order of a licensed healthcare professional.

For in vitro diagnostic use.

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

Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the words is a graphic of orange dots arranged in a circular pattern.

This 510(k) Summary of Safety and Effectiveness is being submitted in accordance with the requirements of Safe Medical Device Act of 1990 and 21 CFR 807.92.

The assigned 510(k) number is: K221605

1. Submitter

Siemens Healthcare Diagnostics Inc. 500 GBC Dr. P.O. Box 6101 Newark, DE 19714

Primary Contact Person: Julie Warren Date of Preparation: July 7, 2023

2. Device Information

Trade NameEmit® II Plus Buprenorphine Assay
Common NameBuprenorphine Assay
DeviceEnzyme Immunoassay, Opiates
Review PanelToxicology
Product CodeDJG
Submission Type510(k)
Regulation Number21 CFR § 862.3650
Device Class2

3. Purpose of Submission

The purpose of this premarket notification is for the Emit® II Plus Buprenorphine Assay on the DxC 500 AU Clinical Chemistry Analyzer.

4. Predicate Device

Predicate Device Name: Emit® II Plus Buprenorphine Assay 510(k) Number: K150606

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5. Device Description

Emit® II Plus Buprenorphine Assay

The Emit® II Plus Buprenorphine Assay is a homogeneous enzyme immunoassay technique used for the analysis of specific compounds in human urine. The assay is based on competition between drug in the specimen and drug labeled with the recombinant glucose-6-phosphate dehydrogenase (rG6PDH) for antibody binding sites. Enzyme activity decreases upon binding to the antibody, so the drug concentration in the specimen can be measured in terms of enzyme activity. Active enzyme converts nicotinamide adenine dinucleotide (NAD) to NADH in the presence of glucose-6phosphate (G6P), resulting in an absorbance change that is measured spectrophotometrically. Endogenous serum G6PDH does not interfere because the coenzyme NAD functions only with the bacterial (Leuconostoc mesenteroides) enzyme employed in the assay.

The Emit® II Plus Buprenorphine Assay reagents are provided liquid, ready to use and may be used directly from the refrigerator. The product is sold in three (3) kit sizes: 28 mL, 115 mL, and 1000 mL. Reagents 1 and 2 are provided as a matched set. They should not be interchanged with components of kits with different lot numbers.

Antibody/Substrate Reagent 1

Mouse monoclonal antibodies to buprenorphine (0.53 µg/mL)*.NAD (6.9 mM), G6P (10.9 mM), bovine serum albumin, preservatives, and stabilizers.

*The antibody titer and enzyme conjugate activity may vary from lot to lot.

Enzyme Reagent 2

Norbuprenorphine labeled with bacterial rG6PDH (0.50 µg/mL), HEPES buffer, bovine serum albumin, preservatives, and stabilizers, where the antibody titer and enzyme conjugate activity may vary from lot to lot.

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6. Intended Use/Indications for Use

Emit® II Plus Buprenorphine Assay

The Emit® II Plus Buprenorphine Assay is a homogeneous enzyme immunoassay with a 5 ng/mL cutoff. The assay is intended for use in laboratories for the qualitative and/or semiquantitative analyses of buprenorphine in human urine. Emit® II Plus assays are designed for use with a number of chemistry analyzers.

The semiquantitative mode is for the purpose of enabling laboratories to determine an appropriate dilution of the specimen for confirmation by a confirmatory method such as Liquid Chromatography/Mass Spectrometry (LC/MS) or permitting laboratories to establish quality control procedures.

The Emit® II Plus Buprenorphine Assay provides only a preliminary analytical test result. A more specific alternative chemical method(s) must be used to obtain a confirmed analytical result. Gas Chromatography/Mass Spectrometry (GC/MS) or LC/MS are the preferred confirmatory methods. Other chemical confirmation methods are available. Clinical consideration and professional judgment should be applied to any drug-of-abuse test result, particularly when preliminary positive results are used.

For Professional Use.

Caution: Federal (USA) law restricts this device to sale by or on the order of a licensed healthcare professional.

For in vitro diagnostic use.

7. Comparison of Technological Characteristics with the Predicate Device

The similarities and differences between the proposed device Emit II Plus Buprenorphine Assay on Beckman Coulter DxC AU 500 Clinical Chemistry Analyzer and the predicate device, Emit II Plus Buprenorphine Assay, were compared side by side.

FeaturePredicate Device:Emit II Plus BuprenorphineAssayProposed Device:Emit II Plus BuprenorphineAssay
Intended UseA homogeneous enzymeimmunoassay with a 5ng/mL cutoff. The assay isintended for use inlaboratories for thequalitative and/orSame

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Image /page/6/Picture/0 description: The image shows the logo for Siemens Healthineers. The word "SIEMENS" is written in teal, and the word "Healthineers" is written in orange below it. To the right of the words is a graphic of orange dots arranged in a pattern.

FeaturePredicate Device:Emit II Plus BuprenorphineAssayProposed Device:Emit II Plus BuprenorphineAssay
semiquantitative analyses ofbuprenorphine in humanurine. Preliminary analyticaltest result.
AnalyteBuprenorphineSame
Cutoff Level5 ng/mLSame
MeasurementQualitative, semi-quantitativeSame
MethodologyEMIT® technology:Homogeneous enzymeimmunoassaySame
DetectionAbsorbance changemeasuredSpectrophotometrically at340nmSame
InstrumentAnalyzers must be capableof maintaining a constantreaction temperature,pipette specimens/reagents,mix thoroughly, measureenzyme rates precisely andtime the reaction accurately.Beckman Coulter DxC 500AU Analyzer
Sample TypeHuman UrineSame
Reagent form and storageLiquid - ready to use, on-board storageSame
Calibrator0, 2.5, 5, 15, and 25 ng/mLSame
Control LevelsPositive: 7 ng/mLNegative: 3 ng/mLSame

8. Performance Data

The following performance studies were conducted to demonstrate substantial equivalence of the Emit II Plus Buprenorphine Assay on the DXC 500 AU Clinical Chemistry Analyzer to the Emit II Plus Buprenorphine Assay previously cleared under premarket notification 510(k), K150606.

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8.1 Method Comparison

The method comparison study was evaluated in accordance with CLSI EP09c 3rd Edition Measurement Procedure Comparison and Bias Estimation Using Patient Samples Evaluation of Precision Performance of Quantitative Measurement Methods and CLSI EP 12-A2 User Protocol for Evaluation of Qualitative Test Performance to determine accuracy and verification of the 5 ng/mL cutoff.

One hundred twenty (120) native urine individual patient samples were collected from external suppliers. The samples were received frozen, and thawed before testing. The samples were distributed across the assay range, 21% of which were within -50% of the cutoff and 19% of which were within +50% of the cutoff.

Each specimen was tested on the DxC 500 AU and on LC/MS/MS The results were analyzed using a 2x2 box plot to assess qualitative agreement relative to the 5 ng/mL cutoff value.

LC/MS/MS
NegPos
Emit II PlusBuprenorphine on DxC500 AUNeg480
Pos963

Table 1. Method Comparison - Qualitative Analysis

Result: 92.5% Agreement

Table 2. Method Comparison - Discordant Results

SampleIDDxC500 AU(ng/mL)Buprenorphine(ng/mL)Norbuprenorphine(ng/mL)Buprenorphine+Norbuprenorphine(ng/mL)DxC 500AUPos/NegLC/MS/MSPos/Neg
BUP356.10.04.24.2PosNeg
BUP456.00.04.64.6PosNeg
BUP516.10.04.34.3PosNeg
BUP605.60.03.83.8PosNeg
BUP626.10.03.93.9PosNeg
BUP875.50.04.34.3PosNeg
BUP955.60.04.54.5PosNeg
BUP1016.30.04.84.8PosNeg
BUP1095.00.04.34.3PosNeg

Emit® II Plus Buprenorphine Assay Traditional 510(k)

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One hundred twenty (120) samples were tested. Relative to the 5 ng/mL cutoff, fortyeight (48) samples were negative by Emit II Plus Buprenorphine Assay and LC/MS/MS, and sixty-three (63) were positive. Nine (9) discordant samples were observed as positive by Emit II Plus Buprenorphine and negative by LC/MS/MS.

8.2 Recovery

The recovery was evaluated in accordance with the following testing protocol. Nine (9) urine samples were prepared by spiking buprenorphine into negative urine pools. The following levels were tested: 2.0, 3.0, 4.0, 5.0, 8.0, 12.0, 18.0, 22.0, and 25.0 ng/mL.

Experimental design was (1) reagent lot, one (1) calibrator lot, one (1) instrument, one (1) calibration with two (2) replicate measurements each. Samples were assayed in five (5) replicates. Samples were additionally analyzed by LC/MS/MS to determine the reference value. The nominal value was determined gravimetrically based on the stock concentration.

SampleIDNominalValue(ng/mL)DxC 500 AUValue(ng/mL)%Recoveryvs NominalLC/MS/MS(ng/mL)% RecoveryvsLC/MS/MS
BUP12.01.9952.286
BUP23.02.9973.291
BUP34.04.11034.493
BUP45.04.9985.196
BUP58.07.6958.886
BUP612.011.69713.189
BUP718.018.110118.1100
BUP822.022.910422.9100
BUP925.024.79925.696

Table 3. Recovery of Emit II Plus Buprenorphine - Semi-Quantitative Analysis

8.3 Precision

Repeatability and Within-Lab Precision

The precision was evaluated in accordance with CLSI EP05-A3 Evaluation of Precision Performance of Quantitative Measurement Methods.

Eleven (11) urine samples were prepared by spiking buprenorphine into negative urine pools, aliquoted and frozen prior to the start of testing. The following levels were tested: 0, 1.25, 2.5, 3.0, 3.75, 5.0, 6.25, 7.0, 7.5, 8.75, and 10.0 ng/mL.

Experimental design was a 20x2x2 design using (1) reagent lot, one (1) calibrator lot, one (1) instrument, one (1) calibration, twenty (20) test days and two (2) runs per test

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day with two (2) replicate measurements each. Each day, two runs were performed, with a minimum of two (2) hours in between.

SampleConcentration(ng/mL)% of theCutoff# ofResultsResults(Pos/Neg)Mean(mA/min)
0.0-100%8080 Negative280
1.25-75%8080 Negative297
2.5-50%8080 Negative316
3.0-40%8080 Negative323
3.75-25%8080 Negative333
5.00%8021 Negative59 Positive363
6.25+25%8080 Positive380
7.0+40%8080 Positive392
7.5+50%8080 Positive402
8.75+75%8080 Positive427
10.0+100%8080 Positive444

Table 4. Precision of Emit II Plus Buprenorphine Qualitative Analysis

Table 5. Precision of Emit II Plus Buprenorphine Semi-Quantitative Analysis

RepeatabilityWithin-Lab Precision
SampleConcentration(ng/mL)% of theCutoff# ofResultsResults(Pos/Neg)Mean(ng/mL)SD%CVSD%CV
0.0-100%8080 Negative0.10.06-0.11-
1.25-75%8080 Negative1.20.086.60.086.6
2.5-50%8080 Negative2.30.093.70.114.6
3.0-40%8080 Negative2.70.072.80.155.7
3.75-25%8080 Negative3.30.082.50.154.4
5.00%8024 Negative56 Positive5.10.081.60.183.5
6.25+25%8080 Positive6.10.081.30.213.4
7.0+40%8080 Positive6.80.111.70.243.5
7.5+50%8080 Positive7.30.081.10.212.9
8.75+75%8080 Positive8.80.101.10.242.8
10.0+100%8080 Positive9.70.101.10.373.8

Reproducibility Precision

The reproducibility was evaluated in accordance with the following protocol.

Three (3) urine samples were tested: Emit II Plus Specialty Drug Control Negative (3 ng/mL) Emit II Plus Specialty Drug Cal/Ctrl (Cutoff Calibrator), and the Emit II Plus Specialty Drug Control Positive (7 ng/mL).

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Experimental design was a 3x5x5 design; 3 (Sites/Instruments) x 5 (replicates per day) for a total seventy-five (75) replicates per reagent lot. To capture lot-to-lot variability, three (3) Emit II Plus Buprenorphine reagent lots were processed in parallel in this study design. Testing was completed by three (3) operators. Each testing day, one (1) run was performed on three (3) instruments.

SampleNMean(ng/mL)SD%CV
Negative Control2253.10.175.3
Cutoff Calibrator2255.00.183.7
Positive Control2257.10.213.0
Table 6. Total Reproducibility Precision of Emit II Plus Buprenorphine Assay
Table 7. Reproducibility Precision of Emit II Plus Buprenorphine Assay
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RepeatabilityBetween DayBetween LotBetween Instrument/Site
SampleNMean (ng/mL)SD%CVSD%CVSD%CVSD%CV
Negative Control2253.10.113.60.061.80.030.80.113.4
Cutoff Calibrator2255.00.112.20.071.40.000.00.132.6
Positive Control2257.10.121.70.081.20.050.70.152.1

8.4 Limit of Detection

The limits of detection, Limit of Blank (LoB) and Limit of Detection (LoD) were evaluated in accordance with CLSI EP17-A2: Evaluation of Detection Capability for Clinical Laboratory Measurement Procedures.

Blank samples were drug-free negative urine, and the low samples were drug-free urine spiked with buprenorphine.

Experimental design was (2) reagent lots, one (1) calibrator lot, one (1) instrument, one (1) calibration, three (3) testing days, four (4) blank samples with minimum of sixty (60) replicate measurements (across all blank samples, days, instrument) and four (4) samples, each containing a low level of measurand (LoD) with minimum of sixty (60) replicate measurements (across all low-level samples, days, instrument).

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Table 8. Limit of Detection Summary

SampleLimit ofDetectionLot 1 (ng/mL)Limit ofDetectionLot 2(ng/mL)Limit ofDetectionFinal (ng/mL)ClaimedLimit ofDetection(ng/mL)
LoD

8.5 Specificity and Cross-reactivity

The specificity was evaluated in accordance with CLSI EP07-ED3 Interference Testing Clinical Chemistry.

The experimental design was one (1) reagent lot, one (1) calibrator lot, one (1) instrument, one (1) sample pool for each compound tested. The samples were assayed in five (5) replicates.

Table 9. Specificity - Buprenorphine Metabolites

CompoundConcentrationTested (ng/mL)Mean(ng/mL)Cutoff(ng/mL)% Cross-reactivity
Buprenorphine5 ng/mL4.95.098%
Norbuprenorphine5 ng/mL5.35.0106%
BuprenorphineGlucuronide1,000 ng/mL1.45.00.10%
NorbuprenorphineGlucuronide1,000 ng/mL1.45.00.10%

Table 10. Cross-reactivity - Structurally Related Compounds

DescriptionConcentration@ TestingMeanRate(mA/min)CutoffRate(mA/min)Responsevs. Cutoff(Pos/Neg)Mean(ng/mL)%Cross-reactivity to 5ng/mL Cutoff
6-Acetylcodeine100,000 ng/mL131167Neg-0.6<0.1%
6-Acetylmorphine100,000 ng/mL137167Neg0.4<0.1%
Codeine100,000 ng/mL135167Neg0.1<0.1%
Dextromethorphan100,000 ng/mL137167Neg0.3<0.1%
Dihydrocodeine100,000 ng/mL136167Neg0.3<0.1%
Ethyl Morphine100,000 ng/mL136167Neg0.3<0.1%
Heroin100,000 ng/mL133167Neg0.0<0.1%
Hydrocodone100,000 ng/mL136167Neg0.2<0.1%

Emit® II Plus Buprenorphine Assay Traditional 510(k)

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DescriptionConcentration@ TestingMeanRate(mA/min)CutoffRate(mA/min)Responsevs. Cutoff(Pos/Neg)Mean(ng/mL)%Cross-reactivity to 5ng/mL Cutoff
Hydromorphone100,000 ng/mL137167Neg0.4<0.1%
Levorphanol100,000 ng/mL141167Neg1.0<0.1%
Morphine100,000 ng/mL135167Neg0.1<0.1%
Morphine 3-glucuronide100,000 ng/mL137167Neg0.4<0.1%
Morphine 6-glucuronide100,000 ng/mL136167Neg0.3<0.1%
Nalorphine100,000 ng/mL136167Neg0.3<0.1%
Naloxone100,000 ng/mL138167Neg0.6<0.1%
Naltrexone100,000 ng/mL137167Neg0.4<0.1%
Norcodeine100,000 ng/mL135167Neg0.1<0.1%
Normorphine100,000 ng/mL136167Neg0.2<0.1%
Noroxycodone100,000 ng/mL135167Neg0.2<0.1%
Noroxymorphone100,000 ng/mL136167Neg0.2<0.1%
Oxycodone100,000 ng/mL136167Neg0.3<0.1%
Oxymorphone100,000 ng/mL137167Neg0.4<0.1%

Table 11. Cross-reactivity - Structurally Un-Related Compounds

CompoundConc.Tested(µg/mL)-40%ControlMean Semi-Quant(ng/mL)-40% ControlResponse vs.Cutoff(Pos/Neg)+40%ControlMean Semi-Quant(ng/mL)+40% ControlResponse vs.Cutoff (Pos/Neg)
10,11-Dihydrocarbamazepine85.02.8Neg6.9Pos
Acetaminophen1000.02.5Neg7.0Pos
Acetylsalicylic Acid1500.02.5Neg7.0Pos
Amitriptyline100.03.1Neg7.5Pos
Amoxicillin500.02.5Neg6.9Pos
AZT (Zidovudine)2000.02.5Neg6.8Pos
Brompheniramine75.02.7Neg6.9Pos
Caffeine1000.02.7Neg7.0Pos
Captopril500.02.6Neg6.9Pos
CompoundConc.Tested(µg/mL)-40%ControlMean Semi-Quant(ng/mL)-40% ControlResponse vs.Cutoff(Pos/Neg)+40%ControlMean Semi-Quant(ng/mL)+40% ControlResponse vs.Cutoff (Pos/Neg)
Chlordiazepoxide100.02.6Neg7.1Pos
Chlorpromazine10.02.9Neg7.2Pos
Cimetidine1000.02.9Neg7.4Pos
Clomipramine2.52.8Neg7.3Pos
Clonidine1000.02.9Neg7.2Pos
Cyclobenzaprine125.03.1Neg7.6Pos
d-Amphetamine700.02.9Neg7.3Pos
Desipramine800.03.3Neg8.0Pos
Diazepam100.03.1Neg7.4Pos
Digoxin0.012.9Neg6.9Pos
Diphenhydramine1000.04.6Neg8.8Pos
d-Methamphetamine500.02.9Neg7.2Pos
Doxepin100.03.0Neg7.6Pos
EDDP (2-Ethylidene-1.5dimethyl-3.3-duogenylidine)1000.03.6Neg8.3Pos
EMDP100.02.7Neg7.0Pos
Enalapril500.02.7Neg7.3Pos
Fluoxetine500.03.0Neg7.8Pos
Glutethimide500.02.8Neg7.4Pos
Haloperidol100.02.7Neg7.4Pos
Hydroxyzine (dihydrochloride)500.03.3Neg8.0Pos
lbuprofen1000.02.9Neg7.4Pos
Imipramine200.03.2Neg7.6Pos
Ketamine100.02.6Neg7.0Pos
Ketorolac Tromethamine400.02.3Neg6.7Pos
LAAM (L-a-AcetyImethadol)25.02.7Neg7.4Pos
L-Cotinine100.02.6Neg7.0Pos
CompoundConc.Tested(µg/mL)-40%ControlMean Semi-Quant(ng/mL)-40% ControlResponse vs.Cutoff(Pos/Neg)+40%ControlMean Semi-Quant(ng/mL)+40% ControlResponse vs.Cutoff (Pos/Neg)
Levofloxacin100.02.8Neg7.1Pos
Levothyroxine (L-Thyroxine)50.02.6Neg7.1Pos
Lidocaine1000.02.7Neg7.1Pos
Lormetazepam1.02.5Neg7.0Pos
LSD10.02.5Neg7.1Pos
MDMA (Ecstasy)1000.02.6Neg7.3Pos
Meperidine800.02.9Neg7.5Pos
Methadone500.03.3Neg7.9Pos
Methaqualone600.03.0Neg7.6Pos
NAPA (N-Acetylprocainamide)400.02.6Neg6.8Pos
Naproxen1000.02.4Neg6.6Pos
Nicotinic Acid500.02.5Neg7.2Pos
Nifedipine500.02.5Neg6.4Pos
Nordiazepam100.02.7Neg7.2Pos
Nortriptyline250.02.6Neg7.4Pos
Oxazepam300.02.4Neg6.6Pos
Perphenazine150.02.9Neg7.6Pos
Phencyclidine900.04.6Neg8.9Pos
Phenobarbital500.02.5Neg7.1Pos
Phenelzine (sulfate)100.02.6Neg6.0Pos
Phenytoin1000.02.4Neg6.0Pos
Procainamide (HCI)1000.02.6Neg7.0Pos
Procyclidine (HCI)800.03.2Neg8.0Pos
Promethazine (HCI)100.03.7Neg8.1Pos
Propoxyphene1000.03.5Neg8.0Pos
Protriptyline (HCI)200.03.3Neg7.9Pos
Pseudoephedrine1000.02.7Neg7.0Pos
CompoundConc.Tested(µg/mL)-40%ControlMean Semi-Quant(ng/mL)-40% ControlResponse vs.Cutoff(Pos/Neg)+40%ControlMean Semi-Quant(ng/mL)+40% ControlResponse vs.Cutoff (Pos/Neg)
Quinacrine (HCI)900.04.8Neg9.0Pos
Ranitidine1000.02.6Neg7.1Pos
Ritalin1000.02.7Neg7.5Pos
Salicylic Acid500.02.5Neg7.1Pos
Scopolamine500.02.5Neg6.9Pos
Secobarbital1000.02.7Neg7.5Pos
Tapentadol100.02.4Neg7.0Pos
THC (11-nor-A9-THC-9-COOH)100.02.4Neg6.7Pos
Thioridazine100.04.1Neg8.6Pos
Tramadol1000.03.0Neg7.8Pos
Trazodone5.02.4Neg6.8Pos
Trimethoprim1000.02.5Neg7.1Pos
Triprolidine (zymine)50.02.6Neg7.2Pos
Tyramine100.02.5Neg6.9Pos
Verapamil500.02.8Neg7.6Pos
Zolpidem100.02.7Neg7.1Pos

Emit® II Plus Buprenorphine Assay Traditional 510(k)

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Emit® II Plus Buprenorphine Assay Traditional 510(k)

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Emit® II Plus Buprenorphine Assay Traditional 510(k)

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8.6 Interference

Interference was evaluated in accordance with CLSI EP07-ED3 Interference Testing Clinical Chemistry.

Urine testing samples were prepared by spiking exogenous materials (metabolites and structurally related compounds) into urine samples at ± 40% positive and negative control levels (3 ng/mL and 7 ng/mL respectively).

The experimental design was one (1) reagent lot, one (1) calibrator lot, one (1) instrument, one (1) sample pool for each compound tested. The samples were assayed in five (5) replicates.

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InterferentSampleInterferenceconcentration-40%ControlResponsevs. QualCutoff(Pos/Neg)-40%ControlSampleMean(ng/mL)+40%ControlResponsevs. QualCutoff(Pos/Neg)+40%ControlSampleMean(ng/mL)
Acetone1.0 g/dLNeg2.6Pos6.3
Ascorbic Acid1.5 g/dLNeg2.9Pos6.3
Bilirubin(Conjugated)2.0 mg/dLNeg2.2Pos6.2
Bilirubin(Unconjugated)2.0 mg/dLNeg2.4Pos5.9
Creatinine0.5 g/dLNeg2.7Pos6.3
Ethanol1.0 g/dLNeg2.5Pos6.4
IgG0.5 g/dLNeg2.5Pos7.1
Glucose2.0 g/dLNeg2.5Pos6.1
Hemoglobin115 mg/dLNeg3.0Pos6.7
Human SerumAlbumin0.5 g/dLNeg2.9Pos6.7
Oxalic Acid0.1 g/dLNeg2.5Pos6.5
Riboflavin7.5 mg/dLNeg2.5Pos6.4
Sodium Chloride6.0 g/dLNeg2.5Pos6.6
Urea6.0 g/dLNeg2.4Pos6.2
Sodium Azide1% w/vNeg2.5Pos6.4
Sodium Fluoride1% w/vNeg2.5Pos6.1
Galactose1.0 g/dLNeg2.5Pos5.8
InterferentSample-40% ControlResponse vs.Qual Cutoff(Pos/Neg)-40%ControlMean(ng/mL)+40% ControlResponse vs.Qual Cutoff(Pos/Neg)+40%ControlMean(ng/mL)
pH 3Neg2.9Pos7.2
pH 4Neg2.9Pos7.5
pH 5Neg3.0Pos7.3
pH 6Neg3.0Pos7.3
pH 7Neg2.6Pos7.0
pH 8Neg2.4Pos6.9
pH 9Neg2.6Pos6.2
pH 10Neg2.6Pos6.0
pH 11Neg2.5Pos6.2
sG 1.002Neg2.7Pos6.4
sG 1.005Neg2.9Pos6.8
sG 1.010Neg2.9Pos7.0
sG 1.015Neg2.9Pos7.2
sG 1.020Neg2.9Pos7.2
sG 1.025Neg3.0Pos7.2
sG 1.030Neg2.6Pos7.0
sG 1.035Neg2.5Pos6.9

Table 12. Interference – Endogenous and Exogenous Substances

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Table 13. Interference – pH and Specific Gravity

9. Conclusion

Based on a comparison of the technological characteristic similarities and differences, the Emit® II Plus Buprenorphine Assay (K150606) and the Emit® II Plus Buprenorphine Assay have equivalent intended use and technology attributes. Performance studies were completed to demonstrate the performance of the proposed device to the predicate device were substantially equivalent. Through the accuracy comparison of both methods to the reference LC/MS/MS as well as performance studies of precision, recovery, and specificity, the substantial equivalence is supported.

§ 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).