K Number
K242540
Device Name
AllTest Multi-Drug Urine Test Panel; AllTest Multi-Drug Rapid Urine Test Panel
Date Cleared
2024-09-27

(32 days)

Regulation Number
862.3100
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
AllTest Multi-Drug Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine, Methylenedioxymethamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of: | Drug (Identifier) | Cut-off leve | |--------------------------------------------------------------|--------------| | Amphetamine (AMP) | 500 ng/mL | | Buprenorphine (BUP) | 10 ng/mL | | Secobarbital (BAR) | 300 ng/mL | | Oxazepam (BZO) | 300 ng/mL | | Cocaine (COC) | 150 ng/mL | | Methamphetamine (MET) | 500 ng/mL | | Methylenedioxymethamphetamine (MDMA) | 500 ng/mL | | Morphine (MOP/OPI) | 300 ng/mL | | Methadone (MTD) | 300 ng/mL | | Oxycodone (OXY) | 100 ng/mL | | Phencyclidine (PCP) | 25 ng/mL | | Nortriptyline (TCA) | 1000 ng/mL | | Marijuana (THC) | 50 ng/mL | | Fentanyl(FYL) | 1 ng/mL | AllTest Multi-Drug Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only. It is intended for OTC use. The tests may yield positive results for the prescription drugs 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 applied to any drug of abuse test result, particularly in evaluating a preliminary positive result. The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS or LC/MS is the recommended confirmatory method. AllTest Multi-Drug Rapid Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine, Methylenedioxymethamphetamine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of: | Drug (Identifier) | Calibrator | Cut-off (ng/mL) | |---------------------|---------------|-----------------| | Amphetamine (AMP) | d-Amphetamine | 500 | | Buprenorphine (BUP) | Buprenorphine | 10 | | Secobarbital (BAR) | Secobarbital | 300 | | Oxazepam (BZO) | Oxazepam | 300 | | Cocaine (COC) | Benzoylecgonine | 150 | | Methamphetamine (MET) | d-Methamphetamine | 500 | | Methylenedioxymethamphetamine (MDMA) | d,l-Methylenedioxymethamphetamine | 500 | | Morphine (MOP/OPI) | Morphine | 300 | | Methadone (MTD) | Methadone | 300 | | Oxycodone (OXY) | Oxycodone | 100 | | Phencyclidine (PCP) | Phencyclidine | 25 | | Nortriptyline (TCA) | Nortriptyline | 1000 | | Marijuana (THC) | 11-nor-Δ9-THC-9 COOH | 50 | | Fentanyl(FYL) | Fentanyl | 1 | AllTest Multi-Drug Rapid Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only. The tests may yield positive results for the prescription drugs when taken at or above prescribed doses. It is not intended to distinquish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly in evaluating a preliminary positive result. The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS or LC/MS is the recommended confirmatory method.
Device Description
AllTest Multi-Drug Urine Test Panel and AllTest Multi-Drug Rapid Urine Test Panel are immunochromatographic assays that use a lateral flow system for the qualitative detection of single or multiple drugs in human urine. The devices are a panel format. Each test device is sealed with sachets of desiccant in an aluminum pouch. The device is in a ready-to-use format and no longer requires assembly before use.
More Information

Not Found

No
The device description and performance studies indicate a standard lateral flow immunochromatographic assay, which does not involve AI or ML. There is no mention of algorithms, image processing for interpretation, or any form of learning from data.

No
This device is an in vitro diagnostic test designed to detect drugs in urine. It does not provide any form of therapy or treatment.

Yes

The document explicitly states, "It is for in vitro diagnostic use only." This indicates its purpose is to aid in diagnosis by detecting specific substances in human urine.

No

The device is a lateral flow immunochromatographic assay, which is a physical test strip that detects substances in urine. This involves hardware components and chemical reactions, not just software.

Based on the provided information, yes, this device is an IVD (In Vitro Diagnostic).

Here's why:

  • Explicit Statement: The "Intended Use / Indications for Use" section explicitly states: "It is for in vitro diagnostic use only."
  • Nature of the Test: The device performs a "qualitative and simultaneous detection of [various drugs] in human urine." This involves testing a biological sample (urine) in vitro (outside the body) to diagnose or provide information about a person's health status (in this case, the presence of certain drugs).
  • Regulatory Context: The submission includes details about performance studies, including method comparison studies against a reference method (LC-MS/MS) and a lay user study, which are typical requirements for IVD devices seeking regulatory clearance. The mention of a "Predicate Device(s)" with a K number (K241428) further indicates that this device is being compared to a previously cleared IVD.

Therefore, the device clearly falls under the definition of an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

AllTest Multi-Drug Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine, Methylenedioxymethamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of:

Drug (Identifier)Cut-off level
Amphetamine (AMP)500 ng/mL
Buprenorphine (BUP)10 ng/mL
Secobarbital (BAR)300 ng/mL
Oxazepam (BZO)300 ng/mL
Cocaine (COC)150 ng/mL
Methamphetamine (MET)500 ng/mL
Methylenedioxymethamphetamine (MDMA)500 ng/mL
Morphine (MOP/OPI)300 ng/mL
Methadone (MTD)300 ng/mL
Oxycodone (OXY)100 ng/mL
Phencyclidine (PCP)25 ng/mL
Nortriptyline (TCA)1000 ng/mL
Marijuana (THC)50 ng/mL
Fentanyl(FYL)1 ng/mL

AllTest Multi-Drug Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only. It is intended for OTC use.

The tests may yield positive results for the prescription drugs 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 applied to any drug of abuse test result, particularly in evaluating a preliminary positive result.

The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS or LC/MS is the recommended confirmatory method.

AllTest Multi-Drug Rapid Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine, Methylenedioxymethamphetamine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of:

Drug (Identifier)CalibratorCut-off (ng/mL)
Amphetamine (AMP)d-Amphetamine500
Buprenorphine (BUP)Buprenorphine10
Secobarbital (BAR)Secobarbital300
Oxazepam (BZO)Oxazepam300
Cocaine (COC)Benzoylecgonine150
Methamphetamine (MET)d-Methamphetamine500
Methylenedioxymethamphetamine (MDMA)d,l-Methylenedioxymethamphetamine500
Morphine (MOP/OPI)Morphine300
Methadone (MTD)Methadone300
Oxycodone (OXY)Oxycodone100
Phencyclidine (PCP)Phencyclidine25
Nortriptyline (TCA)Nortriptyline1000
Marijuana (THC)11-nor-Δ9-THC-9 COOH50
Fentanyl(FYL)Fentanyl1

AllTest Multi-Drug Rapid Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only.

The tests may yield positive results for the prescription drugs 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 applied to any drug of abuse test result, particularly in evaluating a preliminary positive result.

The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS or LC/MS is the recommended confirmatory method.

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

NFT, PTH, NGL, NFV, NFY, PTG, NGG, NGM, OAW, NFW

Device Description

AllTest Multi-Drug Urine Test Panel and AllTest Multi-Drug Rapid Urine Test Panel are immunochromatographic assays that use a lateral flow system for the qualitative detection of single or multiple drugs in human urine.

The devices are a panel format. Each test device is sealed with sachets of desiccant in an aluminum pouch. The device is in a ready-to-use format and no longer requires assembly before use.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Urine (human)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

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

The method comparison studies for the device were performed in-house with three operators. Operators ran 80 (40 negative and 40 positive) unaltered urine clinical samples for each drug. The samples were blind labeled and compared to LC-MS/MS results.

A lay user study was performed at three intended user sites with 140 lay persons. 48 males and 92 females tested AllTest Multi-Drug Urine Test Panel. They had diverse educational and professional backgrounds and their ages ranged from 21 to > 50. Urine samples were prepared at the following concentrations; -100%, +/-75%, +/-50%, +/-25% of the cutoff by spiking drug(s) into drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC-MS/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.

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

Analytical Performance: Precision/Reproducibility
Precision studies were carried out for samples with concentrations of +100% cutoff, +75% cutoff, +50% cutoff, +25% cutoff, cutoff, -25% cutoff, -50% cutoff, -75% cut off and -100% cutoff. Samples were prepared by spiking target drugs in drug-free urine samples. Each drug concentration was confirmed by LC-MS/MS. For each concentration, tests were performed two runs per day for 25 days using three lots of test panels.

Analytical Performance: Linearity/Assay Reportable Range
Not applicable. This device is intended for qualitative use only.

Analytical Performance: Stability
The device is stable at 2-30°C for 24 months based on real time stability study.

Analytical Performance: Analytical Specificity/Interference
To test the specificity, drug metabolites and other components that are likely to cross-react in urine samples were spiked into drug-free urine samples were tested using three lots of the device. Percent cross-reactivity was calculated as the cutoff concentration divided by the concentration of analyte tested that yielded a positive result, multiplied by 100.
Non-structurally related compounds were added to drug-free urine and to urine samples containing the target drugs at 50% below and 50% above each corresponding cutoff.
Interference by pH and specific gravity were also evaluated using pooled urine specimens with concentrations of 0 (drug-free), at 50% below and 50% above each corresponding cutoff. The results demonstrated that pH levels of 4 to 9 and specific gravity levels of 1.000 to 1.035 do not affect the results of the assays.

Method Comparison Study
The method comparison studies for the device were performed in-house with three operators. Operators ran 80 (40 negative and 40 positive) unaltered urine clinical samples for each drug. The samples were blind labeled and compared to LC-MS/MS results.

Lay Person Study
A lay user study was performed at three intended user sites with 140 lay persons. 48 males and 92 females tested AllTest Multi-Drug Urine Test Panel. They had diverse educational and professional backgrounds and their ages ranged from 21 to > 50. Urine samples were prepared at the following concentrations; -100%, +/-75%, +/-50%, +/-25% of the cutoff by spiking drug(s) into drug free-pooled urine specimens. The concentrations of the samples were confirmed by LC-MS/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. The results indicate high agreement percentages (ranging from 90.0% to 100%) across various drug concentrations for all tested analytes. Participants also indicated that the device instruction is easy to understand and follow, with a Flesch-Kincaid reading Grade Level of 7.

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.

K241428

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

§ 862.3100 Amphetamine test system.

(a)
Identification. An amphetamine test system is a device intended to measure amphetamine, a central nervous system stimulating drug, in plasma and urine. Measurements obtained by this device are used in the diagnosis and treatment of amphetamine use or overdose and in monitoring levels of amphetamine to ensure appropriate therapy.(b)
Classification. Class II (special controls). An amphetamine 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 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, 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.

Hangzhou Alltest Biotech Co.,Ltd % Jenny Xia, Director LSI International Inc 504E Diamond Ave., Suite H Gaithersburg, Maryland 20877

Re: K242540

Trade/Device Name: AllTest Multi-Drug Urine Test Panel; AllTest Multi-Drug Rapid Urine Test Panel Regulation Number: 21 CFR 862.3100 Regulation Name: Amphetamine test system Regulatory Class: Class II Product Code: NFT, PTH, NGL, NFV, NFY, PTG, NGG, NGM, OAW, NFW Dated: August 23, 2024 Received: August 26, 2024

Dear Jenny Xia:

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.

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 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

1

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.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

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 mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely, Joseph A. Digitally signed by Kotarek -S Date: 2024.09.27
Kotarek -S Date: 2024.09.20 Joseph Kotarek Branch Chief for Toxicology Division of Chemistry and Toxicology Devices OHT7: Office of In Vitro Diagnostics Office of Product Evaluation and Quality Center for Devices and Radiological Health

2

Indications for Use

Submission Number (if known)

K242540

Device Name

AllTest Multi-Druq Urine Test Panel; AllTest Multi-Drug Rapid Urine Test Panel

Indications for Use (Describe)

AllTest Multi-Drug Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine, Methylenedioxymethamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of:

Drug (Identifier)Cut-off leve
Amphetamine (AMP)500 ng/mL
Buprenorphine (BUP)10 ng/mL
Secobarbital (BAR)300 ng/mL
Oxazepam (BZO)300 ng/mL
Cocaine (COC)150 ng/mL
Methamphetamine (MET)500 ng/mL
Methylenedioxymethamphetamine (MDMA)500 ng/mL
Morphine (MOP/OPI)300 ng/mL
Methadone (MTD)300 ng/mL
Oxycodone (OXY)100 ng/mL
Phencyclidine (PCP)25 ng/mL
Nortriptyline (TCA)1000 ng/mL
Marijuana (THC)50 ng/mL
Fentanyl(FYL)1 ng/mL
AllTost Multi-Drug Urine Test Panel can be a single drug tes

rug Urine Test Panel can be a single druq test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only. It is intended for OTC use.

The tests may yield positive results for the prescription drugs 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 applied to any drug of abuse test result, particularly in evaluating a preliminary positive result.

The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS or LC/MS is the recommended confirmatory method.

AllTest Multi-Drug Rapid Urine Test Panel tests are competitive binding, lateral flow

immunochromatographic assays for qualitative and simultaneous detection of Amphetamine,

Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine,

Methylenedioxymethamphetamine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of:

Drug (Identifier)CalibratorCut-off (ng/mL)
Amphetamine (AMP)d-Amphetamine500
Buprenorphine (BUP)Buprenorphine10
Secobarbital (BAR)Secobarbital300
Oxazepam (BZO)Oxazepam300

3

Cocaine (COC)Benzoylecgonine150
Methamphetamine (MET)d-Methamphetamine500
Methylenedioxymethamphetamine (MDMA)d,l-Methylenedioxymethamphetamine500
Morphine (MOP/OPI)Morphine300
Methadone (MTD)Methadone300
Oxycodone (OXY)Oxycodone100
Phencyclidine (PCP)Phencyclidine25
Nortriptyline (TCA)Nortriptyline1000
Marijuana (THC)11-nor-Δ9-THC-9 COOH50
Fentanyl(FYL)Fentanyl1

AllTest Multi-Drug Rapid Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only.

The tests may yield positive results for the prescription drugs when taken at or above prescribed doses. It is not intended to distinquish between prescription use or abuse of these drugs. Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly in evaluating a preliminary positive result.

The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS or LC/MS is the recommended confirmatory method.

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 K242540

  • August 23, 2024 Date: 1. Hangzhou AllTest Biotech Co., Ltd. 2. Submitter: Plant Bldg. 3, 4, 5, No. 550 Yinhai Street, Baiyang Street, Hangzhou ETDZ, Jianggan District 3. Contact person: Jenny Xia LSI International Inc. 504 East Diamond Ave., Suite H Gaithersburg, MD 20877 Telephone: 301-525-6856 Email: jxia@lsi-consulting.org
    1. Device Name: AllTest Multi-Drug Urine Test Panel AllTest Multi-Drug Rapid Urine Test Panel Classification: Class II ਨ.

| Product Code

Target DrugRegulation SectionPanel
NFT
Amphetamine (AMP)862.3100, Amphetamine Test SystemToxicology
PTH
Secobarbital (BAR)862.3150, Barbiturate Test SystemToxicology
NGL
Buprenorphine (BUP)
Fentanyl (FYL)
Morphine (MOP/OPI)
Oxycodone (OXY)862.3650, Opiate Test SystemToxicology
NFV
Oxazepam (BZO)862.3170, Benzodiazepine Test SystemToxicology
NFY
Cocaine (COC)862.3250, Cocaine and cocaine
metabolite test systemToxicology
PTG
Methadone (MTD)862.3620, Methadone Test SystemToxicology
NGG
Methylenedioxymethamphetamine
(MDMA)
Methamphetamine (MET)862.3610,
Methamphetamine Test SystemToxicology
NGM
Phencyclidine (PCP)UnclassifiedToxicology
QAW
Nortriptyline (TCA)862.3910 Tricyclic antidepressant drugs
test systemToxicology

5

| NFW

Cannabinoids (THC)862.3870, Cannabinoids Test SystemToxicology
---------------------------------------------------------------------------

6. Predicate Devices:

AllTest Multi-Drug Urine Test Cup (K241428)

7. Intended Use

AllTest Multi-Drug Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine, Methylenedioxymethamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of:

Drug (Identifier)Cut-off level
Amphetamine (AMP)500 ng/mL
Buprenorphine (BUP)10 ng/mL
Secobarbital (BAR)300 ng/mL
Oxazepam (BZO)300 ng/mL
Cocaine (COC)150 ng/mL
Methamphetamine (MET)500 ng/mL
Methylenedioxymethamphetamine (MDMA)500 ng/mL
Morphine (MOP/OPI)300 ng/mL
Methadone (MTD)300 ng/mL
Oxycodone (OXY)100 ng/mL
Phencyclidine (PCP)25 ng/mL
Nortriptyline (TCA)1000 ng/mL
Marijuana (THC)50 ng/mL
Fentanyl(FYL)1 ng/mL

AllTest Multi-Drug Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only. It is intended for OTC use.

The tests may yield positive results for the prescription drugs 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 applied to any drug of abuse test result, particularly in evaluating a preliminary positive result.

The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS is the recommended confirmatory method.

6

AllTest Multi-Drug Rapid Urine Test Panel tests are competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Buprenorphine, Secobarbital, Oxazepam, Cocaine, Methamphetamine,

Methylenedioxymethamphetamine, Morphine, Methadone, Oxycodone, Phencyclidine, Nortriptyline, Marijuana and Fentanyl in human urine at the cutoff concentrations of:

| Drug (Identifier) | Calibrator | Cut-off
(ng/mL) |
|------------------------------------------|---------------------------------------|--------------------|
| Amphetamine (AMP) | d-Amphetamine | 500 |
| Buprenorphine (BUP) | Buprenorphine | 10 |
| Secobarbital (BAR) | Secobarbital | 300 |
| Oxazepam (BZO) | Oxazepam | 300 |
| Cocaine (COC) | Benzoylecgonine | 150 |
| Methamphetamine
(MET) | d-Methamphetamine | 500 |
| Methylenedioxymetham
phetamine (MDMA) | d,l-
Methylenedioxymethamphetamine | 500 |
| Morphine (MOP/OPI) | Morphine | 300 |
| Methadone (MTD) | Methadone | 300 |
| Oxycodone (OXY) | Oxycodone | 100 |
| Phencyclidine (PCP) | Phencyclidine | 25 |
| Nortriptyline (TCA) | Nortriptyline | 1000 |
| Marijuana (THC) | 11-nor-Δ9-THC-9 COOH | 50 |
| Fentanyl (FYL) | Fentanyl | 1 |

AllTest Multi-Drug Rapid Urine Test Panel can be a single drug test panel or used for any combination of the above listed analytes. It is for in vitro diagnostic use only.

The tests may yield positive results for the prescription drugs 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 applied to any drug of abuse test result, particularly in evaluating a preliminary positive result.

The tests provide only preliminary results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. GC/MS is the recommended confirmatory method.

Device Description 8.

AllTest Multi-Drug Urine Test Panel and AllTest Multi-Drug Rapid Urine Test Panel are immunochromatographic assays that use a lateral flow system for the qualitative detection of single or multiple drugs in human urine.

The devices are a panel format. Each test device is sealed with sachets of desiccant in an aluminum pouch. The device is in a ready-to-use format and no longer requires assembly before use.

7

Similarities
ItemCandidate Device
(K242540)Predicate
(K241428)
Intended useQualitative detection of drugs of abuse in urine. For prescription use or over-the-counter useSame
MethodologyCompetitive binding, lateral flow immunochromatographic assay based on antigen-antibody reactionSame
Type of TestQualitativeSame
Specimen TypeHuman urineSame
Target Drug
and Cut Off
ValuesTarget DrugsCutoff (ng/mL) Same
Amphetamine(AMP)500
Secobarbital (BAR)300
Buprenorphine (BUP)10
Oxazepam (BZO)300
Cocaine (COC)150
Methylenedioxymethamphetamine (MDMA)500
Methamphetamine (MET)500
Morphine (MOP/OPI)300
Methadone (MTD)300
Oxycodone (OXY)100
Phencyclidine (PCP)25
Nortriptyline (TCA)1000
Cannabinoids (THC)50
Fentanyl (FYL)1
Differences
ConfigurationTest PanelTest Cup

Substantial Equivalence Information 0

10. Standard/Guidance Document Reference (if applicable)

None referenced.

11. Test Principle

AllTest Multi-Drug Urine Test Panel or AllTest Multi-Drug Rapid Urine Test Panel is a competitive immunoassay that is used to screen for the presence of various drugs and drug metabolites in urine. It is chromatographic absorbent device in which, drugs within a urine sample, competitively combined to a limited number of drug monoclonal antibody (mouse) conjugate binding sites.

When the test is activated, the urine is absorbed into each test strip by capillary action, mixes with the respective drug monoclonal antibody conjugate, and flows across a pre-coated membrane. When a drug within the urine sample is below the detection level of the test, respective drug monoclonal antibody conjugate binds to the respective drug-protein conjugate immobilized in the Test Region (T) of the test strip. This produces a colored Test line in the Test

8

Region (T) of the strip, which, regardless of its intensity, indicates a negative test result.

When sample drug levels are at or above the detection level of the tree drug in the sample binds to the respective drug monoclonal antibody conjugate, preventing the respective drug monoclonal antibody conjugate from binding to the respective drug-protein conjugate immobilized in the Test Region (T) of the device. This prevents the development of a distinct colored band in the test region, indicating a preliminary positive result.

To serve as a procedure control, a colored line will appear at the Control Region (C) of each strip, if the test has been performed properly.

12. Performance Characteristics

A. Analytical performance

a. Precision/Reproducibility:

Precision studies were carried out for samples with concentrations of +100% cutoff, +50% cutoff, +25% cutoff, cutoff, -25% cutoff, -50% cutoff, -75% cut off and -100% cutoff. Samples were prepared by spiking target drugs in drug-free urine samples. Each drug concentration was confirmed by LC-MS/MS. For each concentration, tests were performed two runs per day for 25 days using three lots of test panels. The results obtained are summarized in the following tables:

| Drug | Lot
Number | +100%
cutoff | +75%
cutoff | +50%
cutoff | +25%
cutoff | Cutoff | -25%
cutoff | -50%
cutoff | -75%
cutoff | -100%
cut-off |
|-------------|---------------|-----------------|----------------|----------------|----------------|---------|----------------|----------------|----------------|------------------|
| AMP
500 | Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 22-/28+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 2 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 24-/26+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 3 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 21-/29+ | 49-/1+ | 50-/0+ | 50-/0+ | 50-/0+ |
| BAR
300 | Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 23-/27+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 2 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 23-/27+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 3 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 21-/29+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| BUP 10 | Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 24-/26+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 2 | 0-/50+ | 0-/50+ | 0-/50+ | 50+/0- | 25-/25+ | 49-/1+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 3 | 0-/50+ | 0-/50+ | 0-/50+ | 50+/0- | 24-/26+ | 49-/1+ | 50-/0+ | 50-/0+ | 50-/0+ |
| BZO
300 | Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 24-/26+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 2 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 24-/26+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 3 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 24-/26+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| MDMA
500 | Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 22-/28+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 2 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 25-/25+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 3 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 22-/28+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| MET
500 | Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 22-/28+ | 49-/1+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 2 | 0-/50+ | 0-/50+ | 0-/50+ | 1-/49+ | 23-/27+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| | Lot 3 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 25-/25+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ |
| Lot 1 | 0-/50+ | 0-/50+ | 0-/50+ | 0-/50+ | 23-/27+ | 50-/0+ | 50-/0+ | 50-/0+ | 50-/0+ | |

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MOP/Lot 20-/50+0-/50+0-/50+0-/50+22-/28+50-/0+50-/0+50-/0+50-/0+
OPI
300Lot 30-/50+0-/50+0-/50+0-/50+24-/26+50-/0+50-/0+50-/0+50-/0+
MTD
300Lot 10-/50+0-/50+0-/50+0-/50+22-/28+50-/0+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+1-/49+24-/26+50-/0+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+0-/50+25-/25+50-/0+50-/0+50-/0+50-/0+
OXY
100Lot 10-/50+0-/50+0-/50+0-/50+23-/27+49-/1+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+0-/50+21-/29+50-/0+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+0-/50+23-/27+50-/0+50-/0+50-/0+50-/0+
PCP 25Lot 10-/50+0-/50+0-/50+1-/49+25-/25+50-/0+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+0-/50+23-/27+50-/0+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+0-/50+24-/26+50-/0+50-/0+50-/0+50-/0+
TCA
1000Lot 10-/50+0-/50+0-/50+0-/50+24-/26+50-/0+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+0-/50+22-/28+50-/0+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+1-/49+24-/26+50-/0+50-/0+50-/0+50-/0+
THC
50Lot 10-/50+0-/50+0-/50+0-/50+25-/25+49-/1+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+0-/50+23-/27+50-/0+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+1-/49+25-/25+50-/0+50-/0+50-/0+50-/0+
COC
150Lot 10-/50+0-/50+0-/50+50+/0-28+/22-50-/0+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+50+/0-29+/21-49-/1+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+49+/1-26+/24-50-/0+50-/0+50-/0+50-/0+
FYL 1Lot 10-/50+0-/50+0-/50+0-/50+22-/28+49-/1+50-/0+50-/0+50-/0+
Lot 20-/50+0-/50+0-/50+0-/50+20-/30+49-/1+50-/0+50-/0+50-/0+
Lot 30-/50+0-/50+0-/50+0-/50+23-/27+48-/2+50-/0+50-/0+50-/0+

b. Linearity/assay reportable range:

Not applicable. This device is intended for qualitative use only.

c. Stability:

The device is stable at 2-30°C for 24 months based on real time stability study.

d. Analytical specificity/Interference:

To test the specificity, drug metabolites and other components that are likely to cross-react in urine samples were spiked into drug-free urine samples were tested using three lots of the device.

Percent cross-reactivity, provided in the below table, was calculated as the cutoff concentration divided by the concentration of analyte tested that yielded a positive result, multiplied by 100.

Drug/CutoffCompoundMinimum concentration required to obtain a positive result% Cross-Reactivity
(ng/mL)
Hydroxyamphetamine500010%
(+/-)-
Methylenedioxyamphetamine(MD
A)252000%
D,L-Amphetamine500100%
D-Amphetamine500100%
Diethylstilbestrol>100000100000

24

| | Cutoff
(ng/mL) | | Concentration | | | | | | |
|------|-------------------|---------------|---------------|--------|--------|--------|--------|--------|--------|
| Drug | | Results | -100% | -75% | -50% | -25% | +25% | +50% | +75% |
| | | | cutoff | cutoff | cutoff | cutoff | cutoff | cutoff | cutoff |
| AMP | 500 | Negative | 20 | 20 | 20 | 19 | 1 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 19 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 95.0% | 100% | 100% |
| BAR | 300 | Negative | 20 | 20 | 20 | 19 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 100% | 100% | 100% |
| BZO | 300 | Negative | 20 | 20 | 20 | 19 | 1 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 19 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 95.0% | 100% | 100% |
| BUP | 10 | Negative | 20 | 20 | 20 | 18 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 2 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 90.0% | 100% | 100% | 100% |
| COC | 150 | Negative | 20 | 20 | 20 | 18 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 2 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 90.0% | 100% | 100% | 100% |
| MDMA | 500 | Negative | 20 | 20 | 20 | 19 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 100% | 100% | 100% |
| MET | 500 | Negative | 20 | 20 | 20 | 18 | 2 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 2 | 18 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 90.0% | 90.0% | 100% | 100% |
| MOP | 300 | Negative | 20 | 20 | 20 | 18 | 1 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 2 | 19 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 90.0% | 95.0% | 100% | 100% |
| MTD | 300 | Negative | 20 | 20 | 20 | 19 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 100% | 100% | 100% |
| OXY | 100 | Negative | 20 | 20 | 20 | 19 | 1 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 19 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 95.0% | 100% | 100% |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 95.0% | 100% | 100% |
| PCP | 25 | Negative | 20 | 20 | 20 | 19 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 100% | 100% | 100% |
| TCA | 1000 | Negative | 20 | 20 | 20 | 19 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 1 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 95.0% | 100% | 100% | 100% |
| THC | 50 | Negative | 20 | 20 | 20 | 18 | 1 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 2 | 19 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 90.0% | 95.0% | 100% | 100% |
| FYL | 1 | Negative | 20 | 20 | 20 | 18 | 0 | 0 | 0 |
| | | Positive | 0 | 0 | 0 | 2 | 20 | 20 | 20 |
| | | Total | 20 | 20 | 20 | 20 | 20 | 20 | 20 |
| | | Agreement (%) | 100% | 100% | 100% | 90.0% | 100.0% | 100% | 100% |

Result of AllTest Multi-Drug Urine Test Panel:

25

Participants were given surveys on the ease of understanding the instruction for use. All participants indicated that the device instruction is easy to understand and follow. A Flesch-Kincaid reading analysis was performed on each package insert and the scores revealed a reading Grade Level of 7.

Clinical Studies: Not applicable.

13. Conclusion

Based on the test principle and performance characteristics of the device including precision, cut-off, interference, specificity, method comparison, and lay-user studies of the devices, it is concluded that AllTest Multi-Drug Urine Test Panel and AllTest Multi-Drug Rapid Urine Test Panel are substantially equivalent to the predicate device.