K Number
K240295
Device Name
InstaStrip Fentanyl Rapid Test (Urine); InstaStrip Fentanyl Dipstick Test (Urine)
Manufacturer
Date Cleared
2024-03-28

(56 days)

Product Code
Regulation Number
862.3650
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
InstaStrip Fentanyl Rapid Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL. The test is intended for over-the-counter (OTC) use. The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive. The InstaStrip Fentanyl Dipstick Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL. The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.
Device Description
InstaStrip Fentanyl Test is an immunoassay intended for the qualitative detection of fentanyl in human urine. Each InstaStrip Fentanyl Test device consists of a Test Strip, a Test Tube, a Dropper and a package insert. Each Test Strip is sealed with sachets of desiccant in an aluminum pouch.
More Information

Not Found

No
The device description and performance studies focus on immunoassay technology and chemical analysis, with no mention of AI or ML.

No

The device is intended for the qualitative detection of fentanyl in human urine, providing a preliminary analytical result for diagnostic purposes rather than therapy.

Yes
Explanation: The device is intended for the qualitative detection of fentanyl in human urine, which provides a preliminary analytical result. While it notes that a more specific method is needed for confirmation, its purpose is to detect and indicate the presence of a substance in the body, which is a diagnostic function.

No

The device description explicitly lists physical components like a Test Strip, Test Tube, and Dropper, indicating it is a hardware-based immunoassay test, not software only.

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

Here's why:

  • Intended Use: The intended use explicitly states the device is for the "qualitative detection of fentanyl in human urine." This involves testing a biological sample (urine) outside of the body to gain information about a person's health status (presence of fentanyl).
  • Device Description: The device is described as an "immunoassay intended for the qualitative detection of fentanyl in human urine." Immunoassays are a common type of IVD test.
  • Anatomical Site: The test is performed on "human urine," which is a biological specimen.
  • Performance Studies: The document details various performance studies, including method comparison studies using clinical samples and a lay user study. These types of studies are typical for demonstrating the performance of an IVD device.
  • Predicate Device: The mention of a "Predicate Device(s)" with a K number (K233417) is a strong indicator that this device is being submitted for regulatory review as an IVD, as predicate devices are used for comparison in the regulatory process for IVDs.

The fact that it's intended for "over-the-counter (OTC) use" and provides a "preliminary analytical result" that requires confirmation by a more specific method are characteristics of some types of IVDs, particularly those intended for home use or initial screening.

N/A

Intended Use / Indications for Use

InstaStrip Fentanyl Rapid Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL. The test is intended for over-the-counter (OTC) use.

The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.

The InstaStrip Fentanyl Dipstick Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL.

The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.

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

NGL

Device Description

InstaStrip Fentanyl Test is an immunoassay intended for the qualitative detection of fentanyl in human urine. Each InstaStrip Fentanyl Test device consists of a Test Strip, a Test Tube, a Dropper and a package insert. Each Test Strip is sealed with sachets of desiccant in an aluminum pouch.

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

over-the-counter (OTC) use.

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

Not Found

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

Not Found

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

1. Analytical Performance

  • a. Precision: Precision studies were carried out for samples with concentrations of -100% cut off, -75% cut off, -50% cut off, -25% cut off, cut off, +25% cut off, +50% cut off, +75% cut off and +100% cut off. These samples were prepared by spiking fentanyl in negative samples. Each fentanyl concentration was confirmed by LC/MS. All sample aliquots were blindly labeled by the person who prepared the samples and didn't take part in the sample testing. For each concentration, tests were performed six tests per day for 10 days per device lot in a randomized order.
    • Lot 1: 60-/0+, 60-/0+, 60-/0+, 54-/6+, 32+/28-, 60+/0-, 60+/0-, 60+/0-, 60+/0-
    • Lot 2: 60-/0+, 60-/0+, 60-/0+, 55-/5+, 30+/30-, 60+/0-, 60+/0-, 60+/0-
    • Lot 3: 60-/0+, 60-/0+, 60-/0+, 55-/5+, 34+/26-, 60+/0-, 60+/0-, 60+/0-
  • c. Stability: The devices are stable at room temperature for 24 months based on the accelerated stability study.
  • d. Interference: Potential interfering substances found in human urine of physiological or pathological conditions were added to drug-free urine and target drug fentanyl urine with concentrations at 50% below and 50% above Cut-Off levels. These urine samples were tested using three batches of each device. Compounds that showed no interference at a concentration of 100µg/mL or specified concentrations are summarized in tables.
  • e. Specificity: To test specificity, drug metabolites and other components that are likely to interfere in urine samples were tested using three batches of device. The lowest concentration that caused a positive result for each compound are listed with their % Cross-Reactivity. The following opioids compounds were tested at a concentration of 100ug/mL and showed no cross-reactivity: 6-Acetyl morphine, Amphetamine, Buprenorphine, Buprenorphine glucuronide, Ceftriaxone, M-Chlorophenylpiperazine, Ciprofloxacin, Cocaine, Codeine, Dextromethorphan, Dihydrocodeine, Diphehydramine, Duloxetine, EDDP, EMDP, Fluoxetine, Haloperidol, Heroin, Hydrocodone, Hydromorphone, Ketamine, Levorphanol, MDMA, Meperidine, Methadone, Methamphetamine, Morphine, Morphine-3-glucuronide, Naloxone, Naltrexone, Norbuprenorphine, Norcodeine, Norketamine, Normeperidine, Normorphine, Noroxycodone, Ofloxacin, Oxycodone, Oxymorphone, Pentazocine (Talwin), Pipamperone, 1-(3-chlorophenyl) Piperazine (hydrochloride), Quinidine, Risperidone, Tapentadol, Thioridazine, Tilidine, Tramadol, Tramadol-O- Desmethyl, Tramadol-N- Desmethyl, Trazodone.
  • f. Effect of Urine Specific Gravity and Urine pH: Urine samples, with 1.000 to 1.035 specific gravity or urine samples with pH 4 to 9 were spiked with target fentanyl at 50% below and 50% above Cut-Off levels. These samples were tested using three lots of device. Results were all positive for samples at and above +50% Cut-Off and all negative for samples at and below -50% Cut-Off.

2. Comparison Studies
Method comparison studies for the InstaStrip Fentanyl Test were performed using three different lots of the device. Operators ran 85 (42 negative and 43 positive) unaltered clinical samples. The samples were blind labeled and compared to LC/MS results.

  • Lot 1: 0 positive for negative, low negative, and 1 positive for near cutoff negative; 7 positive for near cutoff positive, 36 positive for high positive. 11 negative for negative, 21 negative for low negative, 9 negative for near cutoff negative; 0 negative for near cutoff positive, 0 negative for high positive.
  • Lot 2: 0 positive for negative, low negative, and near cutoff negative; 7 positive for near cutoff positive, 36 positive for high positive. 11 negative for negative, 21 negative for low negative, 10 negative for near cutoff negative; 0 negative for near cutoff positive, 0 negative for high positive.
  • Lot 3: 0 positive for negative, low negative, and near cutoff negative; 6 positive for near cutoff positive, 36 positive for high positive. 11 negative for negative, 21 negative for low negative, 10 negative for near cutoff negative; 1 negative for near cutoff positive, 0 negative for high positive.
  • Discordant Results: Lot 1, Sample Number 310-13724, LC-MS/MS Result 0.9, InstaStrip Result Positive. Lot 3, Sample Number 280-06705, LC-MS/MS Result 1.0, InstaStrip Result Negative.

3. Lay-user study
A lay user study was performed at three intended user sites with 140 lay persons. They had diverse educational and professional backgrounds and ranged in age from 18 to >50 years. Urine samples were prepared at the following concentrations: -100%, +/- 75%, +/- 25% of the cut-off by spiking fentanyl into drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC/MS. Each sample was aliquoted into individual containers, blind-labeled and randomized. Each participant was provided with the package insert, 1 blind labeled sample and a device.

  • Results for % of Cutoff:
    • -100% (0 ng/mL Fentanyl): 20 samples, 0 positive, 20 negative, 100% correct.
    • -75% (0.19 ng/mL Fentanyl): 20 samples, 0 positive, 20 negative, 100% correct.
    • -50% (0.50 ng/mL Fentanyl): 20 samples, 0 positive, 20 negative, 100% correct.
    • -25% (0.69 ng/mL Fentanyl): 20 samples, 1 positive, 19 negative, 95% correct.
    • +25% (1.15 ng/mL Fentanyl): 20 samples, 20 positive, 0 negative, 100% correct.
    • +50% (1.44 ng/mL Fentanyl): 20 samples, 20 positive, 0 negative, 100% correct.
    • +75% (1.69 ng/mL Fentanyl): 20 samples, 20 positive, 0 negative, 100% correct.
  • Lay-users indicated that the device instructions can be easily followed. A Flesch-Kincaid reading analysis on the package insert revealed a reading grade level of less than 7.

4. Clinical Studies
Not applicable.

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.

K233417

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). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Instanosis Inc % Joe Shia Director LSI International Inc 504E Diamond Ave., Suite H Gaithersburg, Maryland 20877

Re: K240295

Trade/Device Name: InstaStrip Fentanyl Rapid Test (Urine); InstaStrip Fentanyl Dipstick Test (Urine) Regulation Number: 21 CFR 862.3650 Regulation Name: Opiate Test System Regulatory Class: Class II Product Code: NGL Dated: January 24, 2024 Received: February 1, 2024

Dear Joe Shia:

We have reviewed your section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (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).

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

1

product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS 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 (QS) 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,

Digitally signed by Joseph A. Joseph A. Kotarek -S Kotarek -S Date: 2024.03.2 Date: 2024.03.28

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

Enclosure

2

Indications for Use

510(k) Number (if known) K240295

Device Name InstaStrip Fentanyl Rapid Test (Urine)

InstaStrip Fentanyl Dipstick Test (Urine)

Indications for Use (Describe)

InstaStrip Fentanyl Rapid Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL. The test is intended for over-the-counter (OTC) use.

The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.

The InstaStrip Fentanyl Dipstick Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL.

The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.

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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510(k) SUMMARY K240295

  • March 25, 2024 1. Date: 2. Submitter: Instanosis Inc. 1004 w 9th Avenue, Suite 10 King of Prussia, PA 19406 3. Contact person: Joe Shia LSI International Inc. 504E Diamond Ave., Suite H Gaithersburg, MD 20877 Telephone: 240-505-7880 Email: shiajl@yahoo.com
    1. Device Names: InstaStrip Fentany1 Rapid Test (Urine) InstaStrip Fentanyl Dipstick Test (Urine)
Classification:Class 2
Product CodeClassificationRegulation SectionPanel
NGLII21 CFR § 862.3650
Opiate Test SystemToxicology (91)
    1. Predicate Devices:
      AllTest Fentanyl Urine Test Cassette (K233417)
    1. Indications for Use
      InstaStrip Fentanyl Rapid Test (Urine) is intended for the qualitative detection of fentany] in human urine at the cutoff value of 1.0 ng/mL. The test is intended for over-the-counter (OTC) use. The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.

The InstaStrip Fentanyl Dipstick Test (Urine) is intended for the qualitative detection of fentanyl in human urine at the cutoff value of 1.0 ng/mL.

The assay provides only a preliminary analytical result. A more specific alternative chemical method (e.g., gas or liquid chromatography and mass spectrometry) must be used in order to obtain a confirmed analytical result. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary test result is positive.

    1. Device Description
      InstaStrip Fentanyl Test is an immunoassay intended for the qualitative detection of fentanyl in human urine. Each InstaStrip Fentanyl Test device consists of a Test Strip, a Test Tube, a Dropper and a package insert. Each Test Strip is sealed with sachets of desiccant in an aluminum pouch.
    1. Substantial Equivalence Information
      A summary comparison of features of the InstaStrip Fentany] Test and the predicate devices is provided in following table.

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ItemDevicePredicate – K233417
Indication(s)
for UseFor the qualitative determination of
fentanyl in human urine.Same
Calibrator and Cut-Off
ValuesFentanyl (FTY)
1 ng/mlSame
MethodologyCompetitive binding, lateral flow
immunochromatographic assays based
on the principle of antigen antibody
immunochemistry.Same
Type of TestQualitativeSame
Specimen TypeHuman UrineSame
Intended UseFor OTC useSame
ConfigurationsStripCassette
Storage15-30°C4-30°C

Table 1: Features Comparison of InstaStrip Fentanyl Test and the Predicate Device

    1. Test Principle
      The InstaStrip-Fentanyl Rapid Test is an immunoassay technique that is based on competitive lateral flow immunoassay to detect the presence of fentanyl in human urine samples. The urine sample is added to a provided test tube containing dried rabbit monoclonal antibody-gold nanoparticle (Ab-AuNP) conjugates. This mixture is applied to the InstaStrip-Fentanyl test strip. The pre-immobilized fentanyl-BSA on the test line competes with fentanyl in the urine sample for binding to the Ab-AuNPs. The device is designed so that when the fentanyl concentration in the urine sample exceeds 1 ng/mL, the test line is no longer visible. The test line will be visible and the result is negative when the fentanyl concentration in the urine sample is less than 1 ng/mL. No matter whether the sample contains the corresponding analyte or not, the quality control area (C) will develop a colored line, which is the criteria for judging whether the chromatography process is normal or not.
    1. Performance Characteristics
      1. Analytical Performance
      • a. Precision

Precision studies were carried out for samples with concentrations of -100% cut off, -75% cut off, -50% cut off, -25% cut off, cut off, +25% cut off, +50% cut off, +75% cut off and +100% cut off. These samples were prepared by spiking fentanyl in negative samples. Each fentanyl concentration was confirmed by LC/MS. All sample aliquots were blindly labeled by the person who prepared the samples and didn't take part in the sample testing. For each concentration, tests were performed six tests per day for 10 days per device lot in a randomized order.

Lot Number-100% cut off-75% cut off-50% cut off-25% cutoffcut off+25% cut off+50% cut off+75% cut off+100% cut off
Lot 160-/0+60-/0+60-/0+54-/6+32+/28-60+/0-60+/0-60+/0-60+/0-

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Lot 260-/0+60-/0+60-/0+55-/5+30+/30-60+/0-60+/0-60+/0-
Lot 360-/0+60-/0+60-/0+55-/5+34+/26-60+/0-60+/0-60+/0-

c. Stability

The devices are stable at room temperature for 24 months based on the accelerated stability study.

d. Interference

Potential interfering substances found in human urine of physiological or pathological conditions were added to drug-free urine and target drug fentanyl urine with concentrations at 50% below and 50% above Cut-Off levels. These urine samples were tested using three batches of each device. Compounds that showed no interference at a concentration of 100µg/mL or specified concentrations are summarized in the following tables.

Acetaminophen (500 µg/mL)DoxepinNortriptyline
Acetone (1000 mg/dL)Ecgonine methyl esterNoscapine
AcetophenetidinEphedrineO-Hydroxyhippuric acid
Acetylsalicylic acidErythromycinOctopamine
Albumin (500 mg/dL)Ethanol (1%)Oxalic acid (100 mg/dL)
AlbuterolFenoprofenOxazepam
AminopyrineFluphenazineOxolinic acid
AmitriptylineFurosemideOxymetazoline
AmobarbitalGalactose (10 mg/dL)Papaverine
AmoxicillinGamma globulin (500 mg/dL)Penicillin G
AmpicillinGentisic acidPerphenazine
ApomorphineGlucose (3000 mg/dL)Phencyclidine
Ascorbic Acid (560 mg/dL)Hemoglobin (500 mg/dL)Phenelzine
AspartameHydralazinePhenobarbital
AtropineHydrochlorothiazidePrednisone
Benzilic acidHydrocortisonePropoxyphene
Benzoic acidHydroxytyraminePropranolol
BenzoylecgonineIbuprofen (500 µg/mL)Pseudoephedrine
BilirubinImipramineQuinine (15 µg/mL)
Boric acid (1% w/v)IsoproterenolRanitidine
BupropionIsoxsuprine (20 µg/mL)Riboflavin (10 mg/dL)
CaffeineKetamineSalicylic acid
CarbamazepineKetoprofenSecobarbital
Chloral hydrateLabetalol (15 µg/mL)Serotonin (5-hydroxytyramine)
ChloramphenicolLidocaineSulfamethazine
ChlorothiazideLoperamideSulindac
ChlorpromazineMaprotilineTetrahydrocortisone 3-(β-D-glucuronide)
CholesterolMeperidineTetrahydrocortisone 3-acetate
ClomipramineMeprobamateTetrahydrozoline
ClonidineMethapyrileneThiamine
CortisoneMethaqualoneThioridazine
CotinineMethoxyphenamineTriamterene
Creatinine (500 mg/dL)Metronidazole (300 µg/mL)Trifluoperazine
CyclobenzaprineN-AcetylprocainamideTrimethoprim
DeoxycorticosteroneNaCl (4000 mg/dL)Tyramine

6

DesipramineNalidixic acidUrea (2000 mg/dL)
DextromethorphanNaloxoneUric acid
DiclofenacNaltrexoneValproic acid (250 $\mu$ g/mL)
DiflunisalNaproxenVenlafaxine
DigoxinNiacinamideVerapamil (20 $\mu$ g/mL)
DiphenhydramineNicotineZomepirac
DL-TryptophanNifedipine$\beta$ -Estradiol
DL-TyrosineNorethindrone

e.Specificity

To test specificity, drug metabolites and other components that are likely to interfere in urine samples were tested using three batches of device. The lowest concentration that caused a positive result for each compound are listed below.

| Fentanyl (Cutoff=1ng/mL) | Minimum
concentration required
to obtain a positive
result (ng/mL) | % Cross-Reactivity |
|-------------------------------------|-----------------------------------------------------------------------------|--------------------|
| Acetyl fentanyl | 1 | 100 |
| Acetyl norfentanyl | >10000 | 10000 | 10000 | 10000 | 10000 | 10000 | 10000 | 10000 | 10000 | 10000 | 50 years. Urine samples were prepared at the following concentrations: - 100%, +/- 75%, +/- 25% of the cut-off by spiking fentanyl into drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC/MS. Each sample was aliquoted into individual containers, blind-labeled and randomized. Each participant was provided with the package insert, 1 blind labeled sample and a device. The results are summarized below:

| % of Cutoff | Number
of
samples | Fentanyl Concentration
by LC/MS
(ng/mL) | Lay person results | | The
percentage of |
|--------------|-------------------------|-----------------------------------------------|--------------------|--------------------|------------------------|
| | | | No. of
Positive | No. of
Negative | correct results
(%) |
| -100% Cutoff | 20 | 0 | 0 | 20 | 100 |
| -75% Cutoff | 20 | 0.19 | 0 | 20 | 100 |
| -50% Cutoff | 20 | 0.50 | 0 | 20 | 100 |
| -25% Cutoff | 20 | 0.69 | 1 | 19 | 95 |
| +25% Cutoff | 20 | 1.15 | 20 | 0 | 100 |
| +50% Cutoff | 20 | 1.44 | 20 | 0 | 100 |
| +75% Cutoff | 20 | 1.69 | 20 | 0 | 100 |

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 the package insert and the score revealed a reading grade level of less than 7.

    1. Clinical Studies
      Not applicable.
    1. Conclusion
      Based on the test principle and acceptable performance characteristics including precision, cut-off, interference, specificity, method comparison and Lay-user studies of the devices, it's concluded a substantial equivalence decision.