AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Accurature Multi-drug Urine Test Cup and Accurature Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Secobarbital, Buprenorphine, Oxazepam, Cocaine, Methylenedioxy-methamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Marijuana in human urine at the cut off concentrations of:

DrugAbbreviationCut-off
AmphetamineAMP1000ng/mL
SecobarbitalBAR300 ng/mL
BuprenorphineBUP10 ng/mL
OpzaepamBZO300 ng/mL
CocaineCOC300 ng/mL
Methylenedioxy-methamphetamineMDMA500 ng/mL
MethamphetamineMET1000ng/mL
MorphineMOR300 ng/mL
MethadoneMTD300 ng/mL
OxycodoneOXY100 ng/mL
PhencyclidinePCP25 ng/mL
MarijuanaTHC50 ng/mL

Configuration of the Accurature Multi-drug Urine Test Cup and Accurature Multi-drug UrineTest Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam Secobarbital and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method.

For over-the-counter use.

Multi-drug Urine Test Cup and Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Secobarbital, Buprenorphine, Oxazepam, Cocaine, Methylenedioxy-methamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Marijuana in human urine at the cut off concentrations of:

DrugAbbreviationCut-off
AmphetamineAMP1000ng/mL
SecobarbitalBAR300 ng/mL
BuprenorphineBUP10 ng/mL
OpzaepamBZO300 ng/mL
CocaineCOC300 ng/mL
Methylenedioxy-methamphetamineMDMA500 ng/mL
MethamphetamineMET1000ng/mL
MorphineMOR300 ng/mL
MethadoneMTD300 ng/mL
OxycodoneOXY100 ng/mL
PhencyclidinePCP25 ng/mL
MarijuanaTHC50 ng/mL

Configuration of the Multi-drug Urine Test Cup and Multi-drug Test Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam Secobarbital and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method.

For prescription use only.

Device Description

The subject device will be sold in two formats: Multi-drug Urine Test Dip Card and Multi-drug Urine Test Cup. Multi-Drug Urine Test Cup and Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Marijuana, Cocaine, Methamphetamine, Morphine, Oxazepam, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine and Methadone in human urine samples. Multi-Drug Urine Test devices detect each of analytes on different strips. A positive urine sample will not generate a colored-line for the specific drug tested in the designated region. A negative urine specimen or a urine sample containing Amphetamine, Marijuana, Cocaine, Methamphetamine, Morphine, Oxazepam, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine and Methadone at the concentration below the designated cutoff levels will generate a colored line in the designated test region for the drug. To serve as a test control, a color line will always appear at the control region.

AI/ML Overview

The provided document is a 510(k) Summary for the Shanghai Accurature Diagnostics Co., Ltd. Multi-drug Urine Test Cup and Multi-drug Urine Test Dip Card. It describes the device's indications for use, its substantial equivalence to a predicate device, and performance data from various studies.

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

1. A table of acceptance criteria and the reported device performance:

The document doesn't explicitly state "acceptance criteria" for precision or agreement. However, it indicates a "qualified" result for percentage agreement among positives and negatives in the comparison study (Section 10.1). For precision (Section 10.7), it states a cutoff coincidence rate of 79% (which is >55%) and a ±25% cutoff coincidence rate of 88% (which is >84%), both deemed "qualified." For the lay user study, the percentages of agreement for specific concentrations are presented. Given that these devices are screening tools, the implicit acceptance criteria would be high agreement rates (ideally 100% or very close) for negative and strongly positive samples, and reasonable agreement around the cutoff concentrations.

Here's a summary of the reported performance from the comparison study, which appears to be the primary study for establishing initial performance characteristics:

DrugDeviceAgreement among positivesAgreement among negativesReported Performance (Agreement)
AmphetamineCup98.3%100.0%Qualified
AmphetamineCard98.3%100.0%Qualified
SecobarbitalCup98.3%100.0%Qualified
SecobarbitalCard100.0%100.0%Qualified
BuprenorphineCup98.3%100.0%Qualified
BuprenorphineCard100.0%100.0%Qualified
OxazepamCup98.3%100.0%Qualified
OxazepamCard98.3%100.0%Qualified
CocaineCup97.5%100.0%Qualified
CocaineCard98.3%100.0%Qualified
Methylenedioxy-methamphetamineCup95.8%100.0%Qualified
Methylenedioxy-methamphetamineCard98.3%100.0%Qualified
MethamphetamineCup95.8%100.0%Qualified
MethamphetamineCard99.2%100.0%Qualified
MorphineCup97.5%100.0%Qualified
MorphineCard99.2%100.0%Qualified
MethadoneCup97.5%100.0%Qualified
MethadoneCard97.5%100.0%Qualified
OxycodoneCup99.2%100.0%Qualified
OxycodoneCard96.7%100.0%Qualified
PhencyclidineCup95.8%100.0%Qualified
PhencyclidineCard99.2%100.0%Qualified
MarijuanaCup99.2%100.0%Qualified
MarijuanaCard99.2%100.0%Qualified

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Comparison Study (Section 10.1): The sample size is not explicitly stated as a single number. The tables show "agreement among positives" and "agreement among negatives" for each drug with percentages. While not directly stated, the implication is that a sufficient number of samples were tested to generate these percentages. The provenance of the data (country of origin, retrospective/prospective) is not mentioned.
  • Precision Study (Section 10.7): For each drug, the study tested "drug free," "-75%Cut off," "-50%Cut off," "+100% cutoff," "+75%Cut off," and "+50%Cut off" samples. The number of samples per concentration is not explicitly given, but the results for "-75%Cut off," "-50%Cut off," "drug free" samples were all negative, and "+100% cutoff," "+75%Cut off," "+50%Cut off" samples were all positive. The specific number of samples at the cutoff and ±25% cutoff concentrations that led to the "79%(>55%)" and "88%(>84%)" coincidence rates, respectively, is not provided.
  • Lay User Study (Section 10.8):
    • Test Cup: 603 laypersons. Urine samples were prepared at negative, +/-75%, +/-50%, +/-25% of the cutoff levels. Each layperson was given 1 blind-labeled sample.
    • Test Dip Card: 300 laypersons. Urine samples were prepared at negative, +/-75%, +/-50%, +/-25% of the cutoff levels. Each layperson was given 1 blind-labeled sample.
    • Data Provenance: Not specified (e.g., country of origin or retrospective/prospective). However, the study involved "three intended user sites" and "diverse educational and professional backgrounds."

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

  • Lay User Study (Section 10.8): The ground truth for the lay user study was established by LC/MS (Liquid Chromatography-Mass Spectrometry), which is a highly reliable analytical chemical method. This is not dependent on human expert interpretation of the test results themselves, but rather on instrument analysis. The samples were "spiking drug free-pooled urine specimens" with known concentrations, and these concentrations were "confirmed by LC/MS." Therefore, the ground truth is analytical, not expert consensus on the device's outcome.
  • For other studies like the Comparison Study and Precision, the method for establishing ground truth isn't explicitly detailed, but generally, for drug screening devices, analytical methods (like GC/MS or LC/MS) are considered the gold standard for ground truth.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

  • No information on adjudication methods such as 2+1 or 3+1 is provided. The studies appear to rely on objective measures (percentages of agreement with an assumed or analytically confirmed truth). For the lay user study, the ground truth was analytical (LC/MS), eliminating the need for reader adjudication.

5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

  • This question is not applicable to the provided document. The device is a lateral flow immunochromatographic assay (a rapid drug test), not an AI-powered diagnostic system or an imaging modality that would involve human readers interpreting images. Therefore, a multi-reader multi-case (MRMC) comparative effectiveness study with or without AI assistance is irrelevant to this device.

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

  • This question is not applicable. The device is a physical diagnostic kit (test cup/dip card) that provides a qualitative result (presence or absence of a line). It is not an algorithm, and its performance is inherently "standalone" in that it produces a result without further computational analysis. The "human-in-the-loop" aspect for this device involves a person performing the test and visually interpreting the lines, particularly in the over-the-counter (OTC) use case. The lay user study evaluates this "human-in-the-loop" performance.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

  • The primary type of ground truth used, particularly for the lay user study, was analytical chemical confirmation, specifically LC/MS (Liquid Chromatography-Mass Spectrometry). For the precision study, samples were prepared at specific concentrations relative to the cutoff, implying a known, analytically verified concentration as the ground truth. This is considered a highly objective and accurate method for determining the presence and concentration of substances.

8. The sample size for the training set

  • The document describes performance studies, cross-reactivity, interference, and a lay user study. It does not mention a "training set" in the context of machine learning or algorithm development. The device is a lateral flow immunoassay, which does not involve a training set as would be found in AI/ML applications. The studies described are for validation of the physical test device.

9. How the ground truth for the training set was established

  • As there is no "training set" for this type of device, this question is not applicable. The underlying principles of the immunoassay are based on chemical reactions, not on data learned from a training set.

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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 box, followed by the words "U.S. FOOD & DRUG" in blue, and "ADMINISTRATION" in a smaller font below.

Shanghai Accurature Diagnostics Co., Ltd. % Eva Li Consultant Shanghai SUNGO Management Consulting Co., Ltd. Room 1401, Dongfang Building, 1500# Century Ave., Shanghai 200122, China

Re: K23228

Trade/Device Name: Multi-drug Urine Test Cup Multi-drug Urine Test Dip Card Accurature Multi-drug Urine Test Cup Accurature Multi-drug Urine Test Dip Card Regulation Number: 21 CFR 862.3650 Regulation Name: Opiate Test System Regulatory Class: Class II Product Code: DJG, DIO, LDJ, LCM, JXM, LAF, DKZ, DIS, DJR, JXN, Dated: January 22, 2024 Received: January 22, 2024

Dear Eva Li:

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).

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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.Digitally signed by Joseph
Kotarek -SA. Kotarek -S
Date: 2024.02.23 17:32:56
-05'00'
Joseph Kotarek
Toxicology 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

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Indications for Use

510(k) Number (if known) K232228

Device Name

Accurature Multi-drug Urine Test Cup AccuratureMulti-drug Urine Test Dip Card

Indications for Use (Describe)

Accurature Multi-drug Urine Test Cup and Accurature Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Secobarbital, Buprenorphine, Oxazepam, Cocaine, Methylenedioxy-methamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Marijuana in human urine at the cut off concentrations of:

DrugAbbreviationCut-off
AmphetamineAMP1000ng/mL
SecobarbitalBAR300 ng/mL
BuprenorphineBUP10 ng/mL
OpzaepamBZO300 ng/mL
CocaineCOC300 ng/mL
Methylenedioxy-methamphetamineMDMA500 ng/mL
MethamphetamineMET1000ng/mL
MorphineMOR300 ng/mL
MethadoneMTD300 ng/mL
OxycodoneOXY100 ng/mL
PhencyclidinePCP25 ng/mL
MarijuanaTHC50 ng/mL

Configuration of the Accurature Multi-drug Urine Test Cup and Accurature Multi-drug UrineTest Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam Secobarbital and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method.

For over-the-counter use.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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Indications for Use

510(k) Number (if known) K232228

Device Name

Multi-drug Urine Test Cup Multi-drug Urine Test Dip Card

Indications for Use (Describe)

Multi-drug Urine Test Cup and Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Secobarbital, Buprenorphine, Oxazepam, Cocaine, Methylenedioxy-methamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Marijuana in human urine at the cut off concentrations of:

DrugAbbreviationCut-off
AmphetamineAMP1000ng/mL
SecobarbitalBAR300 ng/mL
BuprenorphineBUP10 ng/mL
OpzaepamBZO300 ng/mL
CocaineCOC300 ng/mL
Methylenedioxy-methamphetamineMDMA500 ng/mL
MethamphetamineMET1000ng/mL
MorphineMOR300 ng/mL
MethadoneMTD300 ng/mL
OxycodoneOXY100 ng/mL
PhencyclidinePCP25 ng/mL
MarijuanaTHC50 ng/mL

Configuration of the Multi-drug Urine Test Cup and Multi-drug Test Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam Secobarbital and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method.

For prescription use only.

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

X Prescription Use (Part 21 CFR 801 Subpart D)

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

CONTINUE ON A SEPARATE PAGE IF NEEDED.

{5}------------------------------------------------

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

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510(K)Summary(K232228)

1. Prepared date:Jan 14, 2024
2. Submitter:Shanghai Accurature Diagnostics Co.,Ltd.
Building 1,No.168 Banqiao East Road, Shanyang Town,
Jinshan District, Shanghai 201508, P.R.China
3. Contact person:Shuang He
+86-21-33691818
hes@kangliyixue.com
4. Device Name*:OTC use: Accurature Multi-drug Urine Test Dip Card
Accurature Multi-drug Urine Test Cup
Rx use: Multi-drug Urine Test Dip Card
Multi-drug Urine Test Cup
5. Classification:II

*The Device for OTC and Rx are exact same, only have different name.

Hereafter, Multi-drug Urine Test Dip card and Multi-drug Urine Test Cup represented both OTC and Rx use.

Product CodeRegulation SectionPanel
DKZ21 CFR § 862.3100, AmphetamineTest SystemToxicology
LDJ21 CFR § 862.3870, CannabinoidsTest System
DIO21 CFR § 862.3250, Cocaine andCocaine Metabolites Test System
LAF21 CFR § 862.3610,Methamphetamine Test System
DJG21 CFR § 862.3650, Opiate TestSystem
JXM21 CFR § 862.3170,Benzodiazepine Test System
DJG21 CFR § 862.3650, Opiate TestSystem
DIS21 CFR § 862.3150, BarbiturateTest System
DJG21 CFR § 862.3650, Opiate TestSystem
LAF21 CFR § 862.3610,Methylenedioxy-methamphetamine Test System
LCMEnzyme ImmunoassayPhencyclidine
DJR21 CFR § 862.3620, MethadoneTest System

6. Description of the device:

The subject device will be sold in two formats: Multi-drug Urine Test Dip Card and Multi-drug Urine Test Cup.

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Multi-Drug Urine Test Cup and Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Marijuana, Cocaine, Methamphetamine, Morphine, Oxazepam, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine and Methadone in human urine samples. Multi-Drug Urine Test devices detect each of analytes on different strips. A positive urine sample will not generate a colored-line for the specific drug tested in the designated region. A negative urine specimen or a urine sample containing Amphetamine, Marijuana, Cocaine, Methamphetamine, Morphine, Oxazepam, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine and Methadone at the concentration below the designated cutoff levels will generate a colored line in the designated test region for the drug. To serve as a test control, a color line will always appear at the control region.

7. The Predicate Devices:

K153050 Device name: Rapid Single/Multi-drug test Cup Rapid Single/Multi-drug test Dipcard Co-Innovation Biotech Co.,Ltd.

8. Indication for use:

Multi-drug Urine Test Cup and Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Secobarbital, Buprenorphine, Oxazepam, Cocaine, Methylenedioxy-methamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Marijuana in human urine at the cut off concentrations of:

DrugAbbreviationCut-off
AmphetamineAMP1000ng/mL
SecobarbitalBAR300 ng/mL
BuprenorphineBUP10 ng/mL
OxazepamBZO300 ng/mL
CocaineCOC300 ng/mL
Methylenedioxy-methamphetamineMDMA500 ng/mL
MethamphetamineMET1000ng/mL
MorphineMOR300 ng/mL
MethadoneMTD300 ng/mL
OxycodoneOXY100 ng/mL
PhencyclidinePCP25 ng/mL
MarijuanaTHC50 ng/mL

Configuration of the Multi-drug Urine Test Cup and Multi-drug Urine Test Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical must be used in order to obtain a confirmed analytical result. GC/MS or LC/MS is the preferred confirmatory method. For prescription use only.

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Accurature Multi-drug Urine Test Cup and Accurature Multi-drug Urine Test Dip Card are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Secobarbital, Buprenorphine, Oxazepam, Cocaine, Methylenedioxy-methamine, Methamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Marijuana in human urine at the cut off concentrations of:

DrugAbbreviationCut-off
AmphetamineAMP1000ng/mL
SecobarbitalBAR300 ng/mL
BuprenorphineBUP10 ng/mL
OxazepamBZO300 ng/mL
CocaineCOC300 ng/mL
Methylenedioxy-methamphetamineMDMA500 ng/mL
MethamphetamineMET1000ng/mL
MorphineMOR300 ng/mL
MethadoneMTD300 ng/mL
OxycodoneOXY100 ng/mL
PhencyclidinePCP25 ng/mL
MarijuanaTHC50 ng/mL

Configuration of the Accurature Multi-drug Urine Test Cup and Accurature Multi-drug urineTest Dip Card can consist of any combination of the above listed drug analytes.

The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital and Oxycodone when taken at or above prescribed doses. It is not intended to distinguish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. The test provides only preliminary test results. A more specific alternative chemical must be used in order to obtain a confirmed analytical result. GC/MS or LC/MS is the preferred confirmatory method. For over-the-counter use.

9. Substantial Equivalence Information

A summary comparison of features of the subject device and the predicate devices is provided in the following Table

ItemSubject devicePredicate deviceK153050Comparison
Indication(s) for useQualitative detection of drugs-of-abuse in human urine (Amphetamine, Secobarbital , Buprenorphine, Oxazepam , Cocaine, Methylenedioxy-methamphetamine, Methamphetamine 、Morphine, Methadone, Oxycodone , Phencyclidine, Marijuana)Qualitative detection of drugs-of-abuse in human urine (Amphetamine, Barbiturates, Benzodiazepines, Buprenorphine, Cocaine, 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine, Methylenedioxymethamphetamine, Methamphetamine, Morphine300, Morphine2000, Methadone, Oxycodone, Phencyclidine, Propoxyphene, Tri-cyclic Antidepressants, Marijuana)Same (but the number of drugs detected different)
Intended UsersOver the Counter (OTC) Use and Prescription UseOver the Counter (OTC) Use and Prescription UseSame

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MethodologyCompetitive binding, lateral flowimmunochromatographic assaysbased on the principle of antigenantibody immunochemistry.Competitive binding, lateral flowimmunochromatographicassaysbased on the principle of antigenantibody immunochemistry.Same
SpecimenHuman UrineHuman UrineSame
CutoffAmphetamine:1000ng/mLSecobarbital:300ng/mLBuprenorphine:10ng/mLOxazepam:300ng/mLCocaine:300 ng/mLMethylenedioxymethamphetamine:500 ng/mLMethamphetamine:1000ng/mLMorphine:300ng/mLMethadone:300ng/mLOxycodone:100ng/mLPhencyclidine:25ng/mLMarijuana:50 ng/mLAmphetamine:1000ng/mLBarbiturates:300ng/mLBuprenorphine:10ng/mLBenzodiazepines:300ng/mLCocaine:300 ng/mLEDDP:300ng/mLMethylenedioxymethamphetamine:500 ng/mLMethamphetamine:1000ng/mLMorphine:300ng/mLMorphine:2000ng/mLMethadone:300ng/mLOxycodone:100ng/mLPhencyclidine:25ng/mLPropoxyphene:300 ng/mLTri-cyclic Antidepressants:1000 ng/mLMarijuana:50 ng/mLSame
ConfigurationsDipcard and CupDipcard and CupSame

Remark:

The subject devices have all features of the predicate device except the number of drugs detected. These differences do not affect the performance characteristics of the subject devices.

  1. performance Data

  2. 1 Comparison Study

Different operators to test the same sample, the results are consistent. The Multi-drug Urine Test Cup/ Test

Dip Card has good comparison. The Summarize/results are as follows:

CupCard
AmphetamineResultAmphetamineResult
% agreement among positives:98.3%Qualified98.3%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
SecobarbitalResultSecobarbitalResult
% agreement among positives:98.3%Qualified100.0%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
BuprenorphineResultBuprenorphineResult
% agreement among positives:98.3%Qualified100.0%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
OxazepamResultOxazepamResult
% agreement among positives:98.3%Qualified98.3%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
CocaineResultCocaineResult

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

% agreement among positives:97.5%Qualified98.3%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
Methylenedioxy-methamphetamineResultMethylenedioxy-methamphetamineResult
% agreement among positives:95.8%Qualified98.3%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
MethamphetamineResultMethamphetamineResult
% agreement among positives:95.8%Qualified99.2%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
MorphineResultMorphineResult
% agreement among positives:97.5%Qualified99.2%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
MethadoneResultMethadoneResult
% agreement among positives:97.5%Qualified97.5%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
OxycodoneResultOxycodoneResult
% agreement among positives:99.2%Qualified96.7%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
PhencyclidineResultOxycodoneResult
% agreement among positives:95.8%Qualified99.2%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified
MarijuanaResultMarijuanaResult
% agreement among positives:99.2%Qualified99.2%Qualified
% agreement among negatives :100.0%Qualified100.0%Qualified

10.2 Cross Reactivity

Cross reactivity study is complemented, the result showed when there are substances of the corresponding concentration in the urine, the Test Cup and Test Dip Card may produce false positive results.

Drugconcentration (ng/mL)
Amphetamine
D-Amphetamine1,000
D,L-Amphetamine (AmphetamineSulfate)1,000
Phentermine1,300
(+/-)-4-Hydroxyamphetamine HCL700
1-Amphetamine50,000
Methylenedioxyethylamphetamine100,000
Secobarbital
Secobarbital300
Amobarbital300
Aprobarbital300
Phenobarbital300
Oxazepam
Buprenorphine10
Buprenorphine -3-D-Glucuronide10
Chlordiazepoxide2000
Clorazepate200
Oxazepam
Alprazolam200
Bromazepam1,500
Chlordiazepoxide HCL1,500
Clobazam100
Clonazepam750
Clorazepate Dipotassium200
Delorazepam1,500
Desalkylflurazepam400
Diazepam200
Estazolam2,500
Flunitrazepam400
A-Hydroxyalprazolam1260
(±) Lorazepam1,500
RS-Lorazepam glucuronide160
Midazolam12,500
Nitrazepam100
Norchlordiazepoxide200
Nordiazepam400
Oxazepam300
Temazepam100
Triazolam2,500
Cocaine
Benzoylecogonine300
Cocaethylene300
CocaineHCl300
Ecgonine HCl35000
Methylenedioxy-methamphetamine
D,L-3,4-Methylenedioxymethamphetamine(MDMA)500
Methamphetamine
D-Methamphetamine1,000
Methamphetamine1000
L(-)-Methamphetamine8000
d-Amphetamine100,000
3,4-methylenedioxyampheta mine(MDA)100,000
Morphine
Morphine300
Codeine300
Norcodeine7500
Morphine 3-b-D-glucuronide300
Methadone
Methadone300
(±)2-Ethyl-1,5-dimethyl-3,3-diphenylpyrrolinium50000
Oxycodone
Oxycodone100
Naloxone50000
Naltrexone50000
Morphine 3- β-D-glucuronide50000
Phencyclidine
Phencyclidine25
Marijuana
11-nor-Δ9-THC-9-COOH50
11-Nor-Δ9-Tetrahydrocannabinol50
11-Nor-Δ8-Tetrahydrocannabinol50
Cannabidiol100,000
Δ8- Tetrahydrocannabinol10,000

{11}------------------------------------------------

{12}------------------------------------------------

10.3 Interference

Potential interfering substances were added to drug-free urine samples with target drugs of ±25% cutoff level.The substances in the table up did not affect the Test Dip Card/Test Cup at concentrations of 100ug/ml.All samples with a concentration of -25% cutoff and drug free test results are aegative, and all samples with a concentration of+25% cutoff test results are positive.

Interference of Different pH 10.4

The results are all positive for samples at +50% cutoff and all negative for samples at -50% cutoff. The results

show that when the pH of samples are in the range of 4-9, there is no effect on the test results.

10:5 Interference of Specific Gravity

The results all positive for samples at +50% cutoff and all negative for samples at -50% cutoff. The results show that when the gravity is in the range of 1.000-1.035, there is no effect on the test results.

10.6 Cut-off

The cut-off value is

CalibratorCut-off (ng/mL)
Amphetamine1000
Secobarbital300
Buprenorphine10

{13}------------------------------------------------

Oxazepam300
Cocaine300
Methylenedioxy-methamphetamine500
Methamphetamine1000
Morphine300
Methadone300
Oxycodone100
Phencyclidine25
Marijuana50

10.7 Precision

As the results ,all the results of drug free,-75%Cut off,-50%Cut off are negative, and all the results of +100% cutoff,+75%Cut off,+50%Cut off are positive, and cutoff coincidence rate of the test results is 79%(>55%),±25% cutoff coincidence rate of the test results is 88%(>84%),so the Precision of kit is qualified.

10.8 Lay User Study

A lay user study were performed at three intended user sites with 603 laypersons for Test Cup and 300 laypersons for Test Dip Card).They should have diverse educational and professional backgrounds and ranged in age from 21 to 50. Urine samples are prepared at the following concentrations; negative, +/-75%, +/-50%, +/-25% of the cut off by spiking drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC/MS. Each sample was aliquoted into individual containers and blind-labeled. Each participant was provided with the package insert, 1 blind labeled sample and a device. They will be asked to fill out an English questionnaire after finishing the test.

The results of the lay user method comparison (Test Cup)

Amphetamine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentage agreement(%)
No. ofPositiveNo. ofNegative
00.00020100.0%
-75%Cut off253.8674020100.0%
-50%Cut off508.54520161100.0%
-25%Cut off736.2487020100.0%
+25%Cut off1197.575819195.0%
+50%Cut off1501.0527420100.0%
+75%Cut off1678.9382200100.0%
Secobarbital
% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentage agreement(%)
No. ofPositiveNo. ofNegative
00.00020100.0%
-75%Cut off71.5804020100.0%
-50%Cut off147.77710161100.0%
-25%Cut off226.3641020100.0%
+25%Cut off364.0221200100.0%
+50%Cut off419.027420100.0%
+75%Cut off515.8795200100.0%
Buprenorphine
Lay person results
% of CutoffConcentration byLC/MS (ng/mL)No. ofPositiveNo. ofNegativeThe percentage agreement(%)
00.00020100.0%
-75%Cut off2.4489020100.0%
-50%Cut off4.7310161100.0%
-25%Cut off7.2609020100.0%
+25%Cut off11.7585200100.0%
+50%Cut off14. 2329420100.0%
+75%Cut off16.8724200100.0%
Oxazepam
Lay person results
% of CutoffConcentration byLC/MS (ng/mL)No. ofPositiveNo. ofNegativeThe percentage agreement(%)
00.00020100.0%
-75%Cut off70.446020100.0%
-50%Cut off151.30730161100.0%
-25%Cut off220.6369020100.0%
+25%Cut off389.965319195.0%
+50%Cut off461.6992420100.0%
+75%Cut off502.0942200100.0%
Cocaine
Lay person results
% of CutoffConcentration byLC/MS (ng/mL)No. ofPositiveNo. ofNegativeThe percentageagreement (%)
00.00020100.0%
-75%Cut off70.446020100.0%
-50%Cut off151.30730161100.0%
-25%Cut off220.6369020100.0%
+25%Cut off389.9653200100.0%
+50%Cut off461.6992420100.0%
+75%Cut off502.0942200100.0%
Methylenedioxy-methamphetamine
Lay person results
% of CutoffConcentration byLC/MS (ng/mL)No. ofPositiveNo. ofNegativeThe percentageagreement (%)
00.00020100.0%
-75%Cut off114. 1879020100.0%
-50%Cut off257.91090161100.0%
-25%Cut off359.2816020100.0%
+25%Cut off613.3061200100.0%
+50%Cut off692.4385420100.0%
+75%Cut off918.3664200100.0%

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

{15}------------------------------------------------

Methamphetamine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. ofNegative
00.00020100.0%
-75%Cut off257.2811020100.0%
-50%Cut off519.59080161100.0%
-25%Cut off780.8035020100.0%
+25%Cut off1127.6588200100.0%
+50%Cut off1435.7586420100.0%
+75%Cut off1795.7356200100.0%

Morphine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. ofNegative
00.00020100.0 %
-75%Cut off74.9251020100.0 %
-50%Cut off148.70610161100.0 %
-25%Cut off210.2795020100.0 %
+25%Cut off354.7366200100.0 %
+50%Cut off420.8013420100.0 %
+75%Cut off476.5929200100.0 %

Methadone

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. ofNegative
00.00020100.0%
-75%Cut off76.2488020100.0%
-50%Cut off157.01630161100.0%
-25%Cut off206.975020100.0%
+25%Cut off356.592219195.0%
+50%Cut off454.0655420100.0%
+75%Cut off519.0941200100.0%

0xycodone

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. ofNegative
00.00020100.0%
-75%Cut off22.5121020100.0%
-50%Cut off45.93040161100.0%

{16}------------------------------------------------

-25%Cut off70.8923020100.0%
+25%Cut off131.2278200100.0%
+50%Cut off144.5957420100.0%
+75%Cut off174.6656200100.0%

Phencyclidine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. ofNegative
00.00020100.0%
-75%Cut off5.6551020100.0%
-50%Cut off11.86590161100.0%
-25%Cut off19.3029020100.0%
+25%Cut off29.5142200100.0%
+50%Cut off38.0936420100.0%
+75%Cut off41.2136200100.0%

Marijuana

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentage
No. ofNo. ofagreement (%)
PositiveNegative
00.00020100.0%
-75%Cut off12.9481020100.0%
-50%Cut off23.58490161100.0%
-25%Cut off36.2969020100.0%
+25%Cut off59.5132200100.0%
+50%Cut off74.5304420100.0%
+75%Cut off90.3451200100.0%

{17}------------------------------------------------

The results of the lay user method comparison (Test Dip Card)

Amphetamine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off253.8674019100.0%
-50%Cut off508.54520160100.0%
-25%Cut off736.2487020100.0%
+25%Cut off1197.5758200100.0%
+50%Cut off1501.0527410100.0%
+75%Cut off1678.9382200100.0%

Secobarbital

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off71.5804019100.0%
-50%Cut off147.77710160100.0%
-25%Cut off226.3641020100.0%
+25%Cut off364.0221200100.0%
+50%Cut off419.027410100.0%
+75%Cut off515.8795200100.0%

Buprenorphine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off2.4489019100.0%
-50%Cut off4.7310160100.0%
-25%Cut off7.2609020100.0%
+25%Cut off11.758519195.0%
+50%Cut off14.2329410100.0%
+75%Cut off16.8724200100.0%

Oxazepam

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off70.446019100.0%
-50%Cut off151.30730160100.0%
-25%Cut off220.6369020100.0%

{18}------------------------------------------------

Shanghai Accurature Diagnostics Co., Ltd. Building 1,No.168 Banqiao East Road, Shanyang Town, Jinshan District, Shanghai 201508,P.R.China

+25%Cut off389. 9653200100.0%
+50%Cut off461.6992410100.0%
+75%Cut off502. 0942200100.0%

Cocaine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off70.446019100.0%
-50%Cut off151.30730160100.0%
-25%Cut off220.6369020100.0%
+25%Cut off389.9653200100.0%
+50%Cut off461.6992410100.0%
+75%Cut off502.0942200100.0%

Methylenedioxy-

methamphetamine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off114. 1879019100.0%
-50%Cut off257. 91090160100.0%
-25%Cut off359. 2816020100.0%
+25%Cut off613. 3061200100.0%
+50%Cut off692. 4385410100.0%
+75%Cut off918. 3664200100.0%

Methamphetamine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0 %
-75%Cut off257.2811019100.0 %
-50%Cut off519.59080160100.0 %
-25%Cut off780.8035020100.0 %
+25%Cut off1127.6588200100.0 %
+50%Cut off1435.7586410100.0 %
+75%Cut off1795.7356200100.0 %

Morphine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
00.00No. ofPositiveNo. of Negative100.0%
-75%Cut off74.9251019100.0%

{19}------------------------------------------------

Shanghai Accurature Diagnostics Co., Ltd. Building 1,No.168 Banqiao East Road, Shanyang Town, Jinshan District, Shanghai 201508,P.R.China

-50%Cut off148.70610160100.0%
-25%Cut off210.2795020100.0%
+25%Cut off354.7366200100.0%
+50%Cut off420.8013410100.0%
+75%Cut off476.5929200100.0%

Methadone

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off76.2488019100.0%
-50%Cut off157.01630160100.0%
-25%Cut off206.975020100.0%
+25%Cut off356.5922200100.0%
+50%Cut off454.0655410100.0%
+75%Cut off519.0941200100.0%

0xycodone

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off22.5121019100.0%
-50%Cut off45.93040160100.0%
-25%Cut off70.8923020100.0%
+25%Cut off131.2278200100.0%
+50%Cut off144.5957410100.0%
+75%Cut off174.6656200100.0%

Phencyclidine

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
No. ofPositiveNo. of Negative
00.00020100.0%
-75%Cut off5.6551019100.0%
-50%Cut off11.86590160100.0%
-25%Cut off19.3029020100.0%
+25%Cut off29.5142200100.0%
+50%Cut off38.0936410100.0%
+75%Cut off41.2136200100.0%

Marijuana

% of CutoffConcentration byLC/MS (ng/mL)Lay person resultsThe percentageagreement (%)
00.00No. ofPositiveNo. of Negative100.0%
020

{20}------------------------------------------------

-75%Cut off12.9481019100.0%
-50%Cut off23.58490160100.0%
-25%Cut off36.2969020100.0%
+25%Cut off59.5132200100.0%
+50%Cut off74.5304410100.0%
+75%Cut off90.3451200100.0%

Shanghai Accurature Diagnostics Co., Ltd. Building 1,No.168 Banqiao East Road, Shanyang Town, Jinshan District, Shanghai 201508,P.R.China

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

11. Conclusion

The data collected in the performance and comparison studies demonstrate that subject devices are substantially equivalent to the predicate.

§ 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).