K Number
K231904
Device Name
Rapid Fentanyl (FYL) Test Strip, Rapid Fentanyl (FYL) Test Dipcard
Date Cleared
2024-03-08

(254 days)

Product Code
Regulation Number
862.3650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Rapid Fentanyl (FYL) Test Strip is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL. The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated. The Rapid Fentanyl (FYL) Test Dipcard is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL. The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.
Device Description
Rapid Fentanyl (FYL) Test Strip and Rapid Fentanyl (FYL) Test Dipcard are competitive binding, lateral flow immunochromatographic assays for qualitatively the detection of fentanyl at or above the cut-off concentration of 1 ng/mL. The tests can be performed without the use of an instrument. Test Strip and Test Dipcard use identical test strips made with same chemical formulation and manufacturing procedures.
More Information

Not Found

No
The device description and performance studies indicate a simple lateral flow immunochromatographic assay that provides a visual qualitative result. There is no mention of computational analysis, algorithms, or learning processes typically associated with AI/ML.

No.
This device is an in vitro diagnostic (IVD) test for screening fentanyl in urine, not a device used to provide therapy or treatment.

Yes

The "Intended Use / Indications for Use" section explicitly states "The tests is intended for in vitro diagnostics use." This directly indicates its purpose as a diagnostic device.

No

The device description explicitly states it is a "competitive binding, lateral flow immunochromatographic assay" and can be performed "without the use of an instrument," indicating it is a physical test strip/dipcard and not software.

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

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section explicitly states: "The tests is intended for in vitro diagnostics use."
  • Nature of the Test: The device is designed to detect Fentanyl in human urine, which is a biological sample taken from the body and tested in vitro (outside the body).
  • Purpose: The test is used for screening and provides a preliminary analytical result for a medical condition (drug use).
  • Regulatory Context: The mention of "prescription use including point of care sites" and the comparison to a predicate device (K220046) strongly indicate that this device is intended for use in a healthcare setting for diagnostic purposes, which falls under the purview of IVD regulations.

N/A

Intended Use / Indications for Use

The Rapid Fentanyl (FYL) Test Strip is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL.

The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

The Rapid Fentanyl (FYL) Test Dipcard is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL.

The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

Product codes

DJG

Device Description

Rapid Fentanyl (FYL) Test Strip and Rapid Fentanyl (FYL) Test Dipcard are competitive binding, lateral flow immunochromatographic assays for qualitatively the detection of fentanyl at or above the cut-off concentration of 1 ng/mL. The tests can be performed without the use of an instrument. Test Strip and Test Dipcard use identical test strips made with same chemical formulation and manufacturing procedures.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

prescription use including point of care sites.

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

Not Found

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

Not Found

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

8.1 Cross-reactivity with structurally similar compounds: To test the cross reactivity of the test, 3 lots of test Strip and test Dipcard was used to test with drug metabolites and drug structurally similar compounds in urine. All the components were added to drug-free normal human urine. Each sample was tested in 3 replicates using 3 lots of Strip and test Dipcard. If any positive result was observed, the compounds were further diluted with known drug-free urine specimen sequentially to different concentrations and tested in quintuplicate, until the highest concentration that generates a negative result was identified. The cross reacting substances with the lowest concentration that produced a positive result was identified.
8.2 Interference: The following compounds were added to drug-free urine and target drug fentanyl urine with concentrations at 50% below and 50% above Cut-Off levels. All potential interfering substances were added at a concentration of 100µg/mL (despropionyl fentanyl (4-ANPP) at 50 ug/mL, norcarfentanil at 5 ug/mL and remifentanil at 10 ug/ mL) or specified concentrations. The urine specimens were tested with 3 lots of test Strip and test Dipcard. None of the compounds listed were shown to interfere.
8.3 Effect of urinary pH: The pH of an aliquot negative urine pool is adjusted to a pH range of 3 to 9 in 1 pH unit increments and spiked with target fentanyl at 50% below and 50% above cutoff levels. Each sample was tested by 3 lots of test Strip and test Dipcard. The results demonstrate that varying ranges of pH do not interfere with the performance of the test.
8.4 Effect of Urinary specific gravity: The specific gravity studies were conducted on different specific gravity including 1.000,1.010, 1.020, 1.030, 1.040 specimens and spiked with target drug fentanyl with concentrations at 50% below and 50% above Cut-Off levels. Each sample was tested by 3 lots of test Strip and test Dipcard. The results demonstrate that varying ranges of urinary specific gravity do not affect the test result.
8.5 Precision: Precision studies were performed using 3 lots of test Strip and test Dipcard. Drug free specimens were spiked with target drug fentanyl at 0, ±75% cutoff, ±25% cutoff and +100% cutoff of drug. The concentrations of the target drugs were confirmed with LC/MS. Each concentration of the urine specimen was divided into aliquot was blindly labeled by a nonparticipant. Separate sets of blinded coded samples were assigned and randomized prior to testing. The study was conducted by 6 operators at 3 Point-of-Care sites. Two operators per location tested 3 aliquots at each concentration for each lot per day (3 runs/day) for 10 non-consecutive days using one device lot per location. One operator tested the test strip format and the second operator test dipcard format. There were 1620 observations by 3 sites at 9 concentrations.
8.6 Accuracy: 80 clinical urine specimens were analyzed by LC/MS and by 3 lots of Rapid Fentanyl (FYL) Test Strip and Rapid Fentanyl (FYL) Test Dipcard. Samples were divided by concentration into five categories: drug free, less than half the cutoff negative, near cutoff positive, and high positive.

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

Not Found

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.

K220046

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

§ 862.3650 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).

0

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: a symbol on the left and the FDA name on the right. The symbol on the left is a stylized image of a human figure, while the FDA name on the right is written in blue letters. The words "U.S. FOOD & DRUG ADMINISTRATION" are written in a clear, sans-serif font.

Co-Innovation Biotech Co.,Ltd. Hong Feng Product Manager No.9 Baihe 3 Street, Economic And Technological Development East Zone, Guangzhou. Guangdong 510530 China

Re: K231904

Trade/Device Name: Rapid Fentanyl (FYL) Test Strip, Rapid Fentanyl (FYL) Test Dipcard Regulation Number: 21 CFR 862.3650 Regulation Name: Opiate Test System Regulatory Class: Class II Product Code: DJG Dated: February 2, 2024 Received: February 2, 2024

Dear Hong Feng:

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 (the 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 available 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.

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

1

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review. the OS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safetyreporting-combination-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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.
Kotarek -S
Joseph Kotarek
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

Digitally signed by Joseph A. Kotarek -S
Date: 2024.03.08 11:37:33
-05'00'

2

Indications for Use

510(k) Number (if known) K231904

Device Name Rapid Fentanyl (FYL) Test Strip Rapid Fentanyl (FYL) Test Dipcard

Indications for Use (Describe)

The Rapid Fentanyl (FYL) Test Strip is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL.

The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

The Rapid Fentanyl (FYL) Test Dipcard is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL.

The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

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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3

Section 5 - 510(k) Summary

Date of Summary Preparation: March 6, 2024 510 (K) number:K231904

1. Submitter's Identifications

Submitter: Co-Innovation Biotech Co., Ltd. Address: No.9 Baihe 3 Street, Economic And Technological Development East Zone , Guangzhou,510530, Guangdong P.R. CHINA Contact Person: Hong Feng Contact Email Address: fenghongfda@126.com Telephone: + 86 -20-82109823 Fax: + 86 -20-82109823

2. Correspondent's Identifications

Correspondent's Name: Co-Innovation Biotech Co., Ltd. Address: No.9 Baihe 3 Street, Economic And Technological Development East Zone , Guangzhou,510530, Guangdong P.R. CHINA Contact Person: Hong Feng Contact Email Address: fenghongfda@126.com Telephone: + 86 -20-82109823 Fax: + 86 -20-82109823

3. Name of the Device

Recommended classification regulation: 21 CFR 862.3650 Opiate test system

Device class: ClassII Panel: Toxicology (91) Product code: DJG Common Name:

Fentanyl (FYL) Test System

Proprietary names:

Rapid Fentanyl (FYL) Test Strip Rapid Fentanyl (FYL) Test Dipcard

4. The Predicate Devices

K220046 Superbio Fentanyl Urine Detection Kit

5. Device Description

4

Rapid Fentanyl (FYL) Test Strip and Rapid Fentanyl (FYL) Test Dipcard are competitive binding, lateral flow immunochromatographic assays for qualitatively the detection of fentanyl at or above the cut-off concentration of 1 ng/mL. The tests can be performed without the use of an instrument. Test Strip and Test Dipcard use identical test strips made with same chemical formulation and manufacturing procedures.

6. Intended Use of Device

The Rapid Fentanyl (FYL) Test Strip is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL.

The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

The Rapid Fentanyl (FYL) Test Dipcard is a rapid, screening test for the qualitative detection of Fentanyl (FYL) in human urine at the cut-off concentration of 1 ng/mL. The tests is intended for in vitro diagnostics use. It is intended for prescription use including point of care sites. This assay provides only a preliminary analytical test result. To obtain a confirmed analytical result, a more specific alternative chemical method must be used. Gas Chromatography/ Mass spectrometry (GC/MS) or Liquid chromatography/Mass spectrometry (LC/MS) is the preferred confirmatory method. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

7. Comparison to Predicate Devices:

A summary comparison of features of the Rapid Fentanyl (FYL) Test Strip and Rapid Fentanyl (FYL) Test Dipcard and the predicate devices is provided in the following Table:

ItemDevicePredicate (K220046)
Indication for useQualitative detection of fentanyl in urineSame
Intended UsersPrescription UseSame
SpecimenUrineSame
Cutoff1 ng/mLSame
ResultsQualitativeSame

5

| Methodology | Competitive binding, Lateral flow
immunochromatographic assay based
on the principle of antigen antibody
immunochemistry | Same |
|-------------------|-----------------------------------------------------------------------------------------------------------------------------------|-----------------------------|
| Configuration | Strip and Dipcard | Same |
| Platform Required | No | Immunofluorescence Analyzer |
| Storage | 4-30°C | Same |

Remark:

The subject devices have all features of the predicate device except Platform Required.

8. Performance Data:

8.1 Cross-reactivity with structurally similar compounds

To test the cross reactivity of the test, 3 lots of test Strip and test Dipcard was used to test with drug metabolites and drug structurally similar compounds in urine. All the components were added to drug-free normal human urine. Each sample was tested in 3 replicates using 3 lots of Strip and test Dipcard. If any positive result was observed, the compounds were further diluted with known drug-free urine specimen sequentially to different concentrations and tested in quintuplicate, until the highest concentration that generates a negative result was identified. The cross reacting substances with the lowest concentration that produced a positive result was identified and is listed in the table below.

| Compound | Lowest
Concentration
(ng/mL) | %
Cross-reactivity |
|-----------------------------|------------------------------------|-----------------------|
| Norfentanyl | 10,000 | 0.01 |
| Acetyl fentanyl | 1.2 | 83.3 |
| Acetyl norfentanyl | 10,000 | 0.01 |
| Acrylfentanyl | 1.5 | 66.7 |
| Butyryl fentanyl | 1.6 | 62.5 |
| Carfentanil | 500 | 0.2 |
| (±)-3-cis-methylfentanyl | 5 | 20 |
| 4-Fluoro-isobutyrylfentanyl | 3 | 33.3 |
| Furanyl fentanyl | 1.8 | 55.6 |
| ω-1-Hydroxyfentanyl | 20,000 | 0.01 |
| (±) β-hydroxythiofentanyl | 2.8 | 35.7 |
| Isobutyryl fentanyl | 1.5 | 66.7 |
| Ocfentanil | 1.8 | 55.6 |

6

| Para-fluorobutyrylfentanyl

(p-FBF)333.3
Para-fluoro fentanyl333.3
Sufentanil6250.16
Valeryl fentanyl2.540

8.2 Interference

Clinical urine samples may contain substances that could potentially interfere with the test. The following compounds were added to drug-free urine and target drug fentanyl urine with concentrations at 50% below and 50% above Cut-Off levels. All potential interfering substances were added at a concentration of 100µg/mL (despropionyl fentanyl (4-ANPP) at 50 ug/mL, norcarfentanil at 5 ug/mL and remifentanil at 10 ug/ mL) or specified concentrations are summarized in the following tables. The urine specimens were tested with 3 lots of test Strip and test Dipcard. None of the compounds listed below were shown to interfere.

Opioids compounds

6-Acetyl morphineEDDPMethadoneNormeperidineTapentadol
AlfentanilEMDPMorphineNormorphineThioridazine
AmphetamineFluoxetineMorphine-3-glucur
onideNoroxycodoneTilidine
BuprenorphineHeroinNaloxoneOxycodoneTramadol
Buprenorphineglucur
onideHydrocodoneNaltrexoneOxymorphoneTramadol-O-De
smethyl
CodeineHydromorph
oneNorbuprenorphinePentazocine
(Talwin)Tramadol-N-De
smethyl
Despropionyl
fentanyl (4-ANPP)
(50ug/mL)KetamineNorcarfentanil
(5ug/mL)PipamperoneTrazodone
DextromethorphanLevorphanolNorcodeineRemifentanil
(10ug/mL)
DihydrocodeineMeperidineNorketamineRisperidone

Commonly ingested medications or substances

AcetaminophenDoxepin (50ug/ml)Nortriptyline (25ug/ml)
Acetone (1000mg/dL)Ecgonine methyl esterNoscapine
AcetophenetidinEphedrineO-Hydroxyhippuric acid
Acetylsalicylic acidErythromycinOctopamine
Albumin (100mg/dL)Ethanol (1%)Oxalic acid (100 mg/dL)
AlbuterolFenoprofenOxazepam
AminopyrineFluphenazineOxolinic acid
Amitriptyline (35ug/ml)FurosemideOxymetazoline
AmobarbitalGalactose (10mg/dL)Papaverine
AmoxicillinGamma Globulin
(500mg/dL)Penicillin G
AmpicillinGentisic acidPerphenazine
ApomorphineGlucose (3000mg/dL)Phencyclidine
Ascorbic acidHemoglobinPhenelzine
AspartameHydralazinePhenobarbital
AtropineHydrochlorothiazidePrednisone
Benzilic acidHydrocortisonePropoxyphene (50ug/ml)
Benzoic acidHydroxytyraminePropranolol
BenzoylecgonineIbuprofenPseudoephedrine
BilirubinImipramine (30ug/ml)Quinine
Boric Acid (1%)IsoproterenolRanitidine
Bupropion (50ug/ml)IsoxsuprineRiboflavin (7.5mg/dL)
CaffeineKetamineSalicylic acid
CarbamazepineKetoprofenSecobarbital
Chloral hydrateLabetalolSerotonin
(5-Hydroxytyramine)
ChloramphenicolLidocaine (50ug/ml)Sulfamethazine
ChlorothiazideLoperamideSulindac
ChlorpromazineMaprotiline (50ug/ml)Tetrahydrocortisone
3-(β-Dglucuronide)
CholesterolMeperidineTetrahydrocortisone 3-acetate
Clomipramine (50ug/ml)MeprobamateTetrahydrozoline
ClonidineMethapyrilene (10ug/ml)Thiamine
CortisoneMethaqualone (50ug/ml)Thioridazine
CotinineMethoxyphenamineTriamterene
CreatinineMetronidazole (300ug/ml)Trifluoperazine
Cyclobenzaprine(10ug/ml)N-AcetylprocainamideTrimethoprim
DeoxycorticosteroneNaCl (4000mg/dL)Tyramine
Desipramine (50ug/ml)Nalidixic acidUrea (2000mg/dL)
DextromethorphanNaloxoneUric acid
DiclofenacNaltrexoneValproic acid (250ug/ml)
DiflunisalNaproxenVenlafaxine
DigoxinNiacinamideVerapamil
DiphenhydramineNicotine (10ug/ml)Zomepirac
DL-TryptophanNifedipineβ-Estradiol
DL-TyrosineNorethindrone

7

8.3 Effect of urinary pH

8

The pH of an aliquot negative urine pool is adjusted to a pH range of 3 to 9 in 1 pH unit increments and spiked with target fentanyl at 50% below and 50% above cutoff levels. Each sample was tested by 3 lots of test Strip and test Dipcard. The results demonstrate that varying ranges of pH do not interfere with the performance of the test.

8.4 Effect of Urinary specific gravity

The specific gravity studies were conducted on different specific gravity including 1.000,1.010, 1.020, 1.030, 1.040 specimens and spiked with target drug fentanyl with concentrations at 50% below and 50% above Cut-Off levels. Each sample was tested by 3 lots of test Strip and test Dipcard. The results demonstrate that varying ranges of urinary specific gravity do not affect the test result.

8.5 Precision

Precision studies were performed using 3 lots of test Strip and test Dipcard. Drug free specimens were spiked with target drug fentanyl at 0, ±75% cutoff, ±25% cutoff and +100% cutoff of drug. The concentrations of the target drugs were confirmed with LC/MS. Each concentration of the urine specimen was divided into aliquot was blindly labeled by a nonparticipant. Separate sets of blinded coded samples were assigned and randomized prior to testing. The study was conducted by 6 operators at 3 Point-of-Care sites. Two operators per location tested 3 aliquots at each concentration for each lot per day (3 runs/day) for 10 non-consecutive days using one device lot per location. One operator tested the test strip format and the second operator test dipcard format. There were 1620 observations by 3 sites at 9 concentrations.

| Approximat
e
concentratio
n of sample | % of cutoff | Number of
determinat
ions per
lot | Result | | Lot 1 | | Lot 2 | | Lot 3 | |
|------------------------------------------------|-------------|--------------------------------------------|----------|----------|----------|----------|----------|----------|-------|--|
| | | | Positive | Negative | Positive | Negative | Positive | Negative | | |
| 0ng/ml | Negative | 60 | 0 | 60 | 0 | 60 | 0 | 60 | | |
| 0.25ng/ml | -75%cutoff | 60 | 0 | 60 | 0 | 60 | 0 | 60 | | |
| 0.5ng/ml | -50%cutoff | 60 | 0 | 60 | 0 | 60 | 0 | 60 | | |
| 0.75ng/ml | -25%cutoff | 60 | 4 | 56 | 2 | 58 | 6 | 54 | | |
| 1ng/ml | cutoff | 60 | 36 | 24 | 34 | 26 | 32 | 28 | | |
| 1.25ng/ml | +25%cutoff | 60 | 54 | 6 | 56 | 4 | 56 | 4 | | |
| 1.5ng/ml | +50%cutoff | 60 | 60 | 0 | 60 | 0 | 60 | 0 | | |
| 1.75ng/ml | +75%cutoff | 60 | 60 | 0 | 60 | 0 | 60 | 0 | | |
| 2ng/ml | +100%cutoff | 60 | 60 | 0 | 60 | 0 | 60 | 0 | | |

Rapid Fentanyl (FYL) Test Strip:

9

| Approximat
e
concentratio
n of sample | % of cutoff | Number of
determinati
ons per lot | Result | | Lot 1 | | Lot 2 | | Lot 3 | |
|------------------------------------------------|-------------|-----------------------------------------|--------|----------|----------|----------|----------|----------|----------|--|
| | | | | Positive | Negative | Positive | Negative | Positive | Negative | |
| 0ng/ml | Negative | 60 | 0 | 60 | 0 | 60 | 0 | 60 | | |
| 0.25ng/ml | -75%cutoff | 60 | 0 | 60 | 0 | 60 | 0 | 60 | | |
| 0.5ng/ml | -50%cutoff | 60 | 0 | 60 | 0 | 60 | 0 | 60 | | |
| 0.75ng/ml | -25%cutoff | 60 | 4 | 56 | 4 | 56 | 2 | 58 | | |
| 1ng/ml | cutoff | 60 | 34 | 26 | 34 | 26 | 36 | 24 | | |
| 1.25ng/ml | +25%cutoff | 60 | 56 | 4 | 58 | 2 | 56 | 4 | | |
| 1.5ng/ml | +50%cutoff | 60 | 60 | 0 | 60 | 0 | 60 | 0 | | |
| 1.75ng/ml | +75%cutoff | 60 | 60 | 0 | 60 | 0 | 60 | 0 | | |
| 2ng/ml | +100%cutoff | 60 | 60 | 0 | 60 | 0 | 60 | 0 | | |

Rapid Fentanyl (FYL) Test Dipcard:

8.6 Accuracy

80 clinical urine specimens were analyzed by LC/MS and by 3 lots of Rapid Fentanyl (FYL) Test Strip and Rapid Fentanyl (FYL) Test Dipcard. Samples were divided by concentration into five categories: drug free, less than half the cutoff negative, near cutoff positive, and high positive. Results were as follows:

Rapid Fentanyl (FYL) Test Strip:

| Operator | Co-Innovation
Result | Drug
free by
LC/MS
analysis | Less than
half the
cutoff
concentration
by LC/MS
analysis | Near Cutoff
Negative
(Between
50% below
the cutoff and
the cutoff
concentration) | Near Cutoff
Positive
(Between the
cutoff and
50% above
the cutoff
concentration) | High Positive
(greater than
50% above
the cutoff
concentration) | Total |
|----------|-------------------------|--------------------------------------|--------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------|-------|
| Site1 | Positive | 0 | 0 | 1 | 8 | 31 | 80 |
| | Negative | 27 | 5 | 7 | 1 | 0 | |
| Site2 | Positive | 0 | 0 | 1 | 8 | 31 | 80 |
| | Negative | 27 | 5 | 7 | 1 | 0 | |
| Site3 | Positive | 0 | 0 | 1 | 8 | 31 | 80 |
| | Negative | 27 | 5 | 7 | 1 | 0 | |

Analysis of Discordant Results Rapid Fentanyl (FYL) Test Strip

10

Rapid Fentanyl (FYL) Test StripLC/MS Analysis
OperatorCutoff(ng/mL)Test ResultDrug Concentration (ng/mL)Drug in Urine
Site 11Positive0.76Fentanyl
1Negative1.04Fentanyl
Site 21Positive0.76Fentanyl
1Negative1.04Fentanyl
Site 31Positive0.76Fentanyl
1Negative1.04Fentanyl

Rapid Fentanyl (FYL) Test Dipcard:

OperatorCo-Innovation ResultDrug free by LC/MS analysisLess than half the cutoff concentration by LC/MS analysisNear Cutoff Negative (Between 50% below the cutoff and the cutoff concentration)Near Cutoff Positive (Between the cutoff and 50% above the cutoff concentration)High Positive (greater than 50% above the cutoff concentration)Total
Site1Positive00183180
Site1Negative27571080
Site2Positive00183180
Site2Negative27571080
Site3Positive00183180
Site3Negative27571080

Analysis of Discordant Results Rapid Fentanyl (FYL) Test Dipcard

Rapid Fentanyl (FYL) Test DipcardLC/MS Analysis
OperatorCutoff(ng/m
L)Test ResultDrug
Concentration
(ng/mL)Drug in Urine
Site 11Positive0.76Fentanyl
1Negative1.04Fentanyl
Site 21Positive0.76Fentanyl
1Negative1.04Fentanyl
Site 31Positive0.76Fentanyl

11

| | | | 11
Negative | 4 / 4
1.V | Company of Children Company of Children
Fentanyi |

-----------------------------------------------------------------------------------------

9. Conclusion:

The data collected in the performance and accuracy studies demonstrate that the Rapid Fentanyl (FYL) Test are substantially equivalent to the predicate device.

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