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510(k) Data Aggregation
(29 days)
The SAFElife™ Fentanyl Urine Home Test (Cassette) is a competitive binding, lateral flow immunochromatographic assay for qualitative detection of Fentanyl in human urine at cutoff concentration of 1 ng/mL.
For in vitro diagnostic use. For Over The Counter (OTC) use.
The test provides only preliminary test results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Tandem Mass Spectrometry (LC/MS-MS) is the recommended confirmatory method.
The SAFElife™ Fentanyl (FTY) Urine Test Cassette is a competitive binding, lateral flow immunochromatoqraphic assay for qualitative detection of Fentanyl (FTY) in human urine at cutoff concentration of 1 ng/mL.
For in vitro diagnostic use.
lt is not intended to distinquish between prescription drug or abuse of the drug. Clinical consideration and professional judgment should be applied to the drug of abuse test result, particularly in evaluating a preliminary positive result.
The test provides only preliminary test results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Tandem Mass Spectrometry (LC/MS-MS) is the recommended confirmatory method.
The SAFElife™ T-Dip Fentanyl Urine Home Test (Dip Card) is a competitive binding, lateral flow immunochromatographic assay for qualitative detection of Fentanyl in human urine at cutoff concentration of 1 ng/mL.
For in vitro diagnostic use. For Over The Counter (OTC) use.
The test provides only preliminary test results. To obtain a confirmed analytical result, a more specific alternate chemical method must be used. Chromatography/Mass Spectrometry (GC/MS) or Liquid Chromatography/Tandem Mass Spectrometry (LC/MS-MS) is the recommended confirmatory method.
The SAFElife™ T-Dip Fentanyl (FTY) Urine Test Panel is a competitive binding, lateral flow immunochromatographic assay for qualitative detection of Fentanyl (FTY) in human urine at cutoff concentration of 1 ng/mL.
For in vitro diagnostic use.
It is not intended to distinguish between prescription drug or abuse of the drug. Clinical consideration and professional judgment should be applied to the drug of abuse test result, particularly in evaluating a preliminary positive result. The test provides only preliminary test results. To obtain a confirmed analytical result, a more specific alternate chemical must be used. Chromatography/Mass Spectrometry (GC/ MS) or Liquid Chromatography/Tandem Mass Spectrometry (LC/MS-MS) is the recommended confirmatory method.
The Wondfo SAFElife™ Fentanyl Tests are immunoassays intended for the qualitative detection of fentanyl in human urine. Each Wondfo SAFElife™ Fentanyl Test consists of a Test Device in format of Cassette or Dip Card, and a package insert. Each Test Device is sealed with sachets of desiccant in an aluminum pouch.
Acceptance Criteria & Study Analysis for SAFElife™ Fentanyl Urine Home Test
The SAFElife™ Fentanyl Urine Home Test (and its variants) are competitive binding, lateral flow immunochromatographic assays for qualitative detection of Fentanyl in human urine at a cutoff concentration of 1 ng/mL. The device provides preliminary test results, with confirmation requiring a more specific alternate chemical method like GC/MS or LC/MS-MS.
1. Acceptance Criteria and Reported Device Performance
The provided documentation does not explicitly state formal acceptance criteria in the typical "pass/fail" format for each performance characteristic. However, the study results implicitly demonstrate the device's acceptable performance based on standard expectations for qualitative drug screening tests.
Given the information, we can infer the acceptance criteria and compare them to the reported performance:
Acceptance Criteria (Inferred) | Reported Device Performance |
---|---|
Precision: | Cassette Precision: |
Consistent results for samples significantly below and above the cutoff concentration. | -100% to -50% cutoff: All 50 tests across 3 lots were negative (50-/0+). |
Acceptable performance around the cutoff, demonstrating the ability to differentiate positive and negative samples. | -25% cutoff: 46-48 negative, 2-4 positive across 3 lots. |
Cutoff (1 ng/mL): 23-28 positive, 22-27 negative across 3 lots. | |
+25% to +100% cutoff: All 50 tests across 3 lots were positive (50+/0-). | |
Dip Card Precision: | |
-100% to -50% cutoff: All 50 tests across 3 lots were negative (50-/0+). | |
-25% cutoff: 47-48 negative, 2-3 positive across 3 lots. | |
Cutoff (1 ng/mL): 23-28 positive, 22-27 negative across 3 lots. | |
+25% to +100% cutoff: All 50 tests across 3 lots were positive (50+/0-). | |
Stability: | The devices are stable at 36-86°F for 24 months based on accelerated stability study. |
Interference: | Over 100 common substances (medications, endogenous compounds) showed no interference at specified concentrations (typically 100 µg/mL or physiological/pathological levels) when spiked into drug-free urine and fentanyl-positive urine (at -50% and +50% cutoff). This indicates a high level of specificity against a wide range of potential interferents. |
No significant interference from common substances at physiological or therapeutic concentrations. | |
Specificity (Cross-Reactivity): | While some fentanyl analogs showed cross-reactivity (e.g., Acrylfentanyl, Isobutyryl fentanyl, Furanyl fentanyl at 100%; Butyryl fentanyl, Carfentanil at 50%), this is expected for drugs belonging to the same class or with similar chemical structures. Many other opioids (e.g., Morphine, Codeine, Buprenorphine, Oxycodone) and diverse compounds showed no cross-reactivity at 100 µg/mL, indicating good specificity against a broad range of other substances. |
Acceptable cross-reactivity profile, with minimal false positives from unrelated compounds, and expected reactivity to close analogs. | |
Effect of Urine Specific Gravity & pH: | No differences in test results were observed across specific gravity ranges of 1.000 to 1.035 and pH ranges of 4 to 9. All samples at or above +50% Cut-Off were positive, and all samples at or below -50% Cut-Off were negative. This demonstrates robust performance across varying urine physiological conditions. |
Robust performance across a physiologically relevant range of urine specific gravity and pH. | |
Method Comparison (Clinical Sample Performance): | Cassette: For 84 unaltered clinical samples (41 negative, 43 positive per LC/MS), typically 0 false positives for negative samples, 0-2 false negatives for high positive samples (with 1 false negative at 1.058 ng/mL, just over cutoff). A few "Near Cutoff Negative" (LC/MS between -50% and cutoff, i.e., 0.5-1 ng/mL) were reported positive by the rapid test, and some "Near Cutoff Positive" (LC/MS between cutoff and +50%, i.e., 1-1.5 ng/mL) were reported negative. The discordant results (e.g., sample 39 at 0.825 ng/mL, sample 41 at 0.914 ng/mL being positive) indicate reasonable performance near the cutoff. |
High concordance with a confirmatory method (LC/MS) for both negative and positive samples, especially for samples well away from the cutoff. | Dip Card: Similar performance to the cassette. For 84 samples, typically 0 false positives for negative samples. A few false negatives for samples just above cutoff (e.g., 1.038 ng/mL, 1.015 ng/mL, 1.077 ng/mL). Discordant results (e.g., samples at 0.885, 0.914, 0.804, 0.825 ng/mL reported positive) demonstrate appropriate sensitivity around the cutoff. Overall, the method comparison shows acceptable agreement with LC/MS, particularly for samples clearly above or below the cutoff. The expected variation occurs in samples very close to the 1 ng/mL cutoff. |
Lay-user Study: | Cassette & Dip Card: 100% correct results for samples well below (-100% to -50% cutoff) and well above (+25% to +75% cutoff). 95% correct results for -25% cutoff (0.7 ng/mL), with 1 out of 20 samples incorrectly read as positive. All lay users found instructions easy to follow, with a Flesch-Kincaid reading level below 7. This demonstrates the device's suitability for OTC (home) use. |
High percentage of correct results by lay users, demonstrating ease of use and interpretation in a home setting. |
2. Sample Size Used for the Test Set and Data Provenance
-
Precision Studies Test Set:
- For each of the 9 concentration levels, 50 tests were performed for each of the 3 device lots.
- Total tests for Precision (Cassette): 9 concentrations * 50 tests/concentration * 3 lots = 1350 tests.
- Total tests for Precision (Dip Card): 9 concentrations * 50 tests/concentration * 3 lots = 1350 tests.
- Data Provenance: The samples were "prepared by spiking fentanyl in negative samples." The document does not specify the country of origin but implies laboratory-prepared controlled samples. The study is prospective in nature as samples were prepared for the purpose of the study.
-
Interference Test Set: Not explicitly stated as a single "test set" size. "These urine samples were tested using three batches of each device." The number of samples for each interferent tested at specific concentrations (drug-free and fentanyl-spiked) is not quantified.
- Data Provenance: Laboratory-prepared controlled samples with spiked substances. Most likely retrospective analysis of prepared samples.
-
Specificity (Cross-Reactivity) Test Set: Similar to interference, not a single "test set" size. "drug metabolites and other components that are likely to interfere in urine samples were tested using three batches of device." The number of individual compounds tested is large (dozens of fentanyl analogs and many other opioids/non-opioids).
- Data Provenance: Laboratory-prepared controlled samples with spiked substances. Most likely retrospective analysis of prepared samples.
-
Effect of Urine Specific Gravity and pH Test Set: Not explicitly stated as a single "test set" size. "These samples were tested using three lots of device." Samples were prepared by spiking target fentanyl at -50% and +50% Cut-Off levels across specific gravity and pH ranges.
- Data Provenance: Laboratory-prepared controlled samples. Most likely retrospective analysis of prepared samples.
-
Method Comparison Studies Test Set:
- Cassette: 84 "unaltered clinical samples."
- Dip Card: 84 "unaltered clinical samples." (It's unclear if these are the same 84 samples for both formats or separate sets of 84).
- Data Provenance: "unaltered clinical samples." The country of origin is not specified, but the clinical nature suggests they were collected from human subjects. The study appears to be retrospective as these samples were "blind labeled" and then tested.
-
Lay-user Study Test Set:
- For each device format (Cassette and Dip Card), 7 different concentration levels were tested, with 20 samples per concentration.
- Total samples per device format: 7 concentrations * 20 samples/concentration = 140 samples.
- Total samples overall: 140 samples (Cassette) + 140 samples (Dip Card) = 280 samples.
- Data Provenance: Samples were "prepared at the following concentrations by spiking fentanyl into drug free-pooled urine specimens." The samples were then blind-labeled and randomized. The study is prospective since samples were prepared for the study.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Precision, Interference, Specificity, Effect of SG/pH, Lay-user Studies: The "ground truth" (actual fentanyl concentration or absence) was established by LC/MS (Liquid Chromatography/Mass Spectrometry) for all spiked samples. This is a highly accurate analytical method, and human experts are not directly establishing the ground truth in terms of visual interpretation for these studies. The LC/MS results are considered the definitive quantitative measurement.
- Method Comparison Studies: The ground truth for the 84 "unaltered clinical samples" was established by LC/MS. The document states, "The samples were blind labeled and compared to LC/MS results." No human experts (e.g., pathologists, radiologists) were involved in establishing the ground truth for these quantitative drug levels.
4. Adjudication Method for the Test Set
The concept of "adjudication" (e.g., 2+1, 3+1) typically applies to situations where multiple human readers are interpreting results and their agreement/disagreement needs to be resolved. In this case, the device output is a qualitative (positive/negative) result based on a visual line, and the ground truth is established by a quantitative analytical method (LC/MS).
- For the Precision studies, the results are quantitative counts of "positive" or "negative" for each lot and concentration, implying a direct read of the test.
- For the Method Comparison Studies, the rapid test results from the operators were directly compared to the LC/MS results. Discordant results are simply listed. No adjudication process is described for resolving discrepancies in the rapid test readings themselves among different operators, but rather the discrepancy is noted between the rapid test result and the LC/MS ground truth.
- For the Lay-user study, each participant (lay person) used one device and provided their result. The comparison was then made between the lay person's result and the LC/MS confirmed concentration. The study report only mentions "Lay person results" (No. of Positive / No. of Negative) implying their individual readings were collected and analyzed for correctness.
Therefore, an adjudication method in the traditional sense (e.g., expert panel review to resolve conflicting interpretations) was not applied, as the output is a qualitative visual reading compared to an analytical gold standard.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done
No, a Multi-Reader Multi-Case (MRMC) comparative effectiveness study was not done.
An MRMC study typically compares the performance of multiple human readers on multiple cases, often with and without AI assistance, to determine if the AI improves human reader performance (e.g., sensitivity, specificity, efficiency). The studies presented here focus on the standalone performance of the device itself (precision, analytical performance, and comparison to LC/MS) and a lay-user study for ease of use. There is no mention of human readers being compared with and without AI assistance.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
Yes, the primary studies presented are essentially standalone performance studies for the device.
The SAFElife™ Fentanyl Urine Home Test is a qualitative lateral flow immunoassay. Its "algorithm" is the biochemical reaction that produces a visual line. The precision studies, interference studies, specificity studies, effect of SG/pH studies, and method comparison studies all evaluate the device's ability to correctly classify samples as positive or negative based on its inherent properties, without human interpretation being the primary variable of interest for method comparison against LC/MS.
While the "reading" of the line is ultimately done by a human (either a trained operator in the method comparison or a lay-user in that specific study), the performance characteristics described (e.g., sensitivity at cutoff, cross-reactivity) are intrinsic to the device's chemical and physical design, functioning as an "algorithm-only" or "device-only" performance evaluation against a gold standard. The lay-user study specifically tests the human-in-the-loop aspect for OTC use, but the core analytical performance is evaluated as standalone.
7. The Type of Ground Truth Used
The primary ground truth used across all analytical performance studies (Precision, Interference, Specificity, Effect of SG/pH, and Method Comparison) and the Lay-user study was Liquid Chromatography/Mass Spectrometry (LC/MS).
LC/MS is a highly sensitive and specific analytical technique used to identify and quantify substances in complex mixtures, making it a robust "gold standard" for determining precise drug concentrations in urine samples.
8. The Sample Size for the Training Set
The document does not describe a "training set" in the context of an algorithm that learns from data. This device is a biochemical immunoassay, not a software-based AI algorithm that requires a training phase. Its performance is determined by its physical and chemical design, not by learning from a dataset.
Therefore, the concept of a "training set" is not applicable to this device.
9. How the Ground Truth for the Training Set Was Established
As noted above, a "training set" is not applicable because this is a biochemical immunoassay, not a machine learning algorithm.
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(34 days)
SAFECARE Fentanyl Urine Test Cassette is a competitive binding, lateral flow immunochromatographic assay for qualitative detection of fentanyl in human urine at the cutoff concentrations of 1 ng/mL. 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 or LC/MS is the preferred confirmatory method. The test is intended for over-the-counter use and for in vitro diagnostic use only.
The SAFECARE Fentanyl Urine Tests are immunoassays intended for the qualitative detection of fentanyl in human urine. Each SAFECARE Fentanyl Urine Test device consists of a Test Cassette, a Dropper and a package insert. Each Test Cassette is sealed with sachets of desiccant in an aluminum pouch.
Here's a breakdown of the acceptance criteria and the study details for the SAFECARE Fentanyl Urine Test Cassette, based on the provided FDA 510(k) summary:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly state "acceptance criteria" percentages (e.g., "must achieve X% sensitivity"). Instead, it presents performance data that implies the device met sufficient standards for clearance. The "performance" column below summarizes the key findings.
Category | Description of Performance (Implicit Acceptance Criteria) | Reported Device Performance |
---|---|---|
Precision | Demonstrate consistent and accurate results across different concentrations relative to the cutoff, ideally showing 100% agreement for concentrations significantly below or above the cutoff, and a mix around the cutoff. | Lot 1: 100% negative for -100%, -75%, -50% cutoff; 98% negative (1 positive) for -25% cutoff; 52% positive/48% negative for cutoff; 100% positive for +25%, +50%, +75%, +100% cutoff. |
Lot 2: 100% negative for -100%, -75%, -50% cutoff; 98% negative (1 positive) for -25% cutoff; 50% positive/50% negative for cutoff; 100% positive for +25%, +50%, +75%, +100% cutoff. | ||
Lot 3: 100% negative for -100%, -75%, -50% cutoff; 96% negative (2 positive) for -25% cutoff; 54% positive/46% negative for cutoff; 100% positive for +25%, +50%, +75%, +100% cutoff. | ||
Stability | Device must remain functional and accurate for a specified shelf life under defined storage conditions. | Devices are stable for 24 months at 36-86°F based on accelerated stability studies. |
Interference | No interference from a list of common physiological, pathological, or drug substances at specified concentrations when fentanyl is absent or at known concentrations (50% below/above cutoff). | No interference observed from a comprehensive list of compounds (e.g., Acetaminophen, Albumin, Glucose, Ibuprofen, Nicotine) at 100µg/mL or specified concentrations when fentanyl was at ±50% cutoff levels. |
Specificity (Cross-Reactivity) | Minimal to no cross-reactivity with structurally similar compounds or other common opioids/drugs, especially for compounds listed as "no cross-reactivity." For fentanyl analogs, a defined cross-reactivity profile. | Detected various fentanyl analogs with varying cross-reactivity percentages (e.g., Acetyl fentanyl: 100%, Ocfentanil: 40%). Showed no cross-reactivity for a list of over 30 opioid compounds (e.g., Codeine, Morphine, Buprenorphine) tested at 100 µg/mL. |
Effect of Urine Specific Gravity & pH | Device performance should not be significantly affected by variations in urine specific gravity (1.000-1.035) or pH (4-9) at critical fentanyl concentrations (50% below and 50% above cutoff). | All results were positive for samples at and above +50% Cut-Off and all negative for samples at and below -50% Cut-Off, regardless of specific gravity or pH within the tested ranges. |
Method Comparison (Clinical Samples) | Demonstrated agreement with a confirmatory method (LC/MS) for both negative and positive clinical urine samples across a range of fentanyl concentrations, including those near the cutoff. A low number of discordant results is expected, especially near the cutoff. | Operator 1: |
- 39/40 (97.5%) agreement for Negative/Low Negative/Near Cutoff Negative.
- 38/40 (95%) agreement for Near Cutoff Positive/High Positive.
- Discordant (1 positive at 0.985 ng/mL LC/MS; 2 negative at 1.055 and 1.097 ng/mL LC/MS).
Operator 2: - 40/40 (100%) agreement for Negative/Low Negative/Near Cutoff Negative.
- 39/40 (97.5%) agreement for Near Cutoff Positive/High Positive.
- Discordant (2 positive at 0.954 and 0.993 ng/mL LC/MS; 1 negative at 1.055 ng/mL LC/MS).
Operator 3: - 40/40 (100%) agreement for Negative/Low Negative/Near Cutoff Negative.
- 39/40 (97.5%) agreement for Near Cutoff Positive/High Positive.
- Discordant (2 positive at 0.980 and 0.985 ng/mL LC/MS; 1 negative at 1.055 ng/mL LC/MS). |
| Lay-User Study | High percentage of correct results by lay users when following instructions, particularly for concentrations clearly below or above the cutoff. User instructions should be easily understood. | Correct result percentages: 100% for -100%, -75%, -50% cutoff; 95% for -25% cutoff; 100% for +25%, +50%, +75% cutoff. All lay users indicated instructions were easily followed. Flesch-Kincaid score indicated reading grade level
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(183 days)
Lifelong Matrix/Lifelong Premium/Safeway syringe with or without needle is intended to be used for medical purposes to inject fluids into or withdraw fluids from the body.
The Lifelong Matrix/Lifelong Premium/SAFEWAY syringe with or without needle is a standard piston syringe that consists of a calibrated hollow barrel and a movable plunger. The needle consists of needle tube, needle hub, needle cap. At one end of the barrel there is a male Luer Slip/Lock connector (nozzle) for fitting the female connector (hub) of a hypodermic single lumen needle or for attaching other devices with a female Luer. The syringe and needles are sterilized by ETO gas. It is a non-pyrogenic and single use device. The main raw materials for syringes are polypropylene and thermoplastic elastomer and for needles raw materials are polypropylene and stainless steel (SS-304).
This document is a 510(k) premarket notification for a medical device (syringes and needles). The key to fulfilling your request is to understand that a 510(k) submission primarily relies on demonstrating substantial equivalence to a previously cleared predicate device, rather than proving novel performance against specific acceptance criteria like an AI/ML device would.
Therefore, the concepts of "acceptance criteria," "study that proves the device meets the acceptance criteria," "sample size for the test set," "data provenance," "number of experts for ground truth," "adjudication method," "MRMC study," "standalone performance," and "training set" do not directly apply in the context of this 510(k) submission for a non-AI/ML device like a syringe.
Instead, the submission focuses on comparing the proposed device's characteristics and performance to those of a previously cleared predicate device and demonstrating compliance with relevant industry standards.
Here's how to interpret the document in the context of your request, reframing the information to reflect what is actually present in a 510(k) for this type of device:
For a medical device like the Lifelong Matrix/Lifelong Premium/Safeway syringe with or without needle, the "acceptance criteria" and "study that proves the device meets the acceptance criteria" are primarily demonstrated through comparison to a legally marketed predicate device and compliance with established international and national standards. This is typical for a 510(k) premarket notification for a Class II device that is not an AI/ML product.
1. Table of Acceptance Criteria and Reported Device Performance:
Since this isn't an AI/ML device with specific accuracy metrics, the "acceptance criteria" are implicitly met by demonstrating similar technological characteristics and compliance with recognized standards as the predicate device. The "reported device performance" is presented as a comparison to the predicate and confirmation of adherence to these standards.
Here's a table summarizing the key comparisons that serve as the basis for "acceptance" in a 510(k) context for this device:
Characteristic/Test | Acceptance Criteria (Implicit for 510(k)) | Reported Device Performance (Subject Device K210103) | Comparison to Predicate (K060211) |
---|---|---|---|
Indications for Use | Same as predicate device | "Lifelong Matrix/Lifelong Premium/Safeway syringe with or without needle is intended to be used for medical purposes to inject fluids into or withdraw fluids from the body." | Identical |
Product Code | Same as predicate device (FMF, FMI) | FMF, FMI | Same |
Regulation Number | Same as predicate device (21 CFR 880.5860, 21 CFR 880.5570) | 21 CFR 880.5860, 21 CFR 880.5570 | Same |
Device Class | Same as predicate device (Class II) | Class II | Same |
Needle Gauge | Similar range as predicate device | 16G, 18G, 19G, 20G, 21G, 22G, 23G, 25G, & 26G | Same |
Syringe Size | Similar range to predicate device (smaller range acceptable if no new safety concerns) | 1mL, 2mL, 3mL, 5mL, 10mL & 20mL | Similar (Predicate has 30mL, 60mL, 100mL additional models; deemed to not raise new safety issues) |
Needle Length | Similar range to predicate device | 1", 1¼", 1½" (for 16G-24G) and ½", ¾", ⅝", 1", 1¼", 1½" (for 25G-26G) | Same |
Needle Bevel | Similar to predicate device | 09° to 13° | Same |
Needle Wall Type | Similar to predicate device | 16G to 25G Thin wall, 26G Regular wall | Same |
Needle Sharpness | Free from defects, sharpness force & gliding force within limit | Needles point appear sharp, free from feather, edges, burrs and hooks. Needle point sharpness force & gliding force is with in limit | Same |
Dose Accuracy | Within acceptable ISO 7886-1 limits (ranges provided in table) | Meets the specified ranges for various syringe sizes and tested volumes (e.g., 1mL: 0.392-0.412mL at 0.4mL volume) | Similar (Both conform to standards) |
Inner Diameter (Needle) | Within acceptable ISO 9626 limits (ranges provided in table) | Meets the specified ranges for various needle gauges (e.g., 16G: 1.281-1.289mm) | Similar & meets ISO 9626 |
Residual Volume (Dead Space) | Within acceptable ISO 7886-1 limits (ranges provided in table) | Meets the specified ranges for various syringe sizes (e.g., 1mL: 0.037-0.045mL) | Similar & meets ISO 7886-1 |
Needle Cover Removal Force | Within acceptable range | 15N to 25N | Similar |
Needle Hub/Needle Bond Strength | Within acceptable ISO 7864 limits (ranges provided in table) | Meets the specified ranges for various needle gauges (e.g., 16G: 110-195N) | Similar & meets ISO 7864 |
Sterility | EO sterilized, meets ISO 11135-1, ISO 10993-7 (residuals), USP (endotoxin) | EO sterilized, validated as per ISO 11135-1:2014. EO residual meets ISO 10993-7:2008. Bacterial endotoxin testing by Gel-Clot Method meets USP. | Same (Sterilization method) |
Biocompatibility | Conforms to ISO 10993 series for specified contact | Conforms to ISO 10993 series (10993-5, 10993-10, 10993-11, 10993-4, 10993-3). No Cytotoxicity, Irritation, Sensitization, Hemolysis. Material-mediated Pyrogenicity tested. | Same |
Packaging Integrity | Meets ISO 11607-2, ASTM F 1929-15 | Validated as per ISO 11607-2:2019. Testing performed as per ASTM F 1929-15. | Same (Adherence to standards) |
Shipping Validation | Meets ASTM D4169-16 | Conducted in accordance with ASTM D4169-16. | Same (Adherence to standards) |
Shelf-life | Established and validated via accelerated aging | 5 years. Validated using ASTM F1980-16. | Similar (Both seek to establish shelf-life) |
Conical Fitting | Meets relevant ISO standards for luer connectors | Complies with ISO 80369-7:2016 | Different standard (ISO 594-1/-2 for predicate vs. ISO 80369 for subject device), but ISO 80369 is an updated version and does not raise new safety concerns. |
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size: The document does not specify a distinct "test set" sample size in the way an AI/ML study would. Instead, compliance with various ISO and ASTM standards implies specific sample sizes and test methodologies as defined within those standards (e.g., how many syringes are tested for dose accuracy, or how many needles for bond strength). These details are not explicitly itemized in the summary provided, but rather are referenced by the standard itself.
- Data Provenance: The device manufacturer is Lifelong Meditech Private Limited, located in Gurugram, Haryana, India. All testing would have been conducted to demonstrate compliance with international standards (ISO, ASTM, USP) for the purpose of U.S. FDA clearance. The studies referenced are performance testing and biocompatibility testing, which are inherently prospective in nature, conducted on the actual manufactured device Lot(s) to demonstrate their properties.
3. Number of Experts Used to Establish Ground Truth and Qualifications:
- Not Applicable. For a medical device like a syringe and needle, "ground truth" is not established by human experts in the way it is for image interpretation in AI/ML. Instead, performance is measured against objective physical, chemical, and biological standards (e.g., volume accuracy, material composition, sterility, biocompatibility). These measurements are typically performed by technicians and validated by quality control personnel in certified laboratories.
4. Adjudication Method for the Test Set:
- Not Applicable. As "ground truth" is based on objective measurements against standards rather than subjective human interpretation, there is no need for an adjudication method.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done:
- No. An MRMC study is relevant for AI/ML devices that assist or replace human readers (e.g., radiologists interpreting images). This device is a syringe, a hardware medical device; its safety and effectiveness are not assessed via human reader performance.
6. If a Standalone (i.e., Algorithm Only Without Human-in-the-Loop Performance) Was Done:
- Not Applicable. This is not an AI/ML algorithm. Its "performance" is assessed directly through physical and chemical testing.
7. The Type of Ground Truth Used:
-
The "ground truth" for this device is based on objective measurements against established performance standards and material specifications. This includes:
- Dimensional accuracy (e.g., needle inner diameter, volume calibration)
- Physical properties (e.g., bond strength, plunger force, needle sharpness)
- Chemical properties (e.g., EO residuals, material composition)
- Biological properties (e.g., sterility, absence of pyrogens, biocompatibility)
- Functionality (e.g., luer lock compatibility)
These are defined by standards such as ISO 7886-1, ISO 7864, ISO 9626, ISO 80369-7, ISO 10993 series, ISO 11135-1, ASTM D4169-16, ASTM F1929-15, ASTM F1980-16, and USP guidelines.
8. The Sample Size for the Training Set:
- Not Applicable. This is not an AI/ML device, so there is no concept of a "training set" for an algorithm. The "training" for such a device is in its design, manufacturing process, and quality control, not via data-driven model training.
9. How the Ground Truth for the Training Set Was Established:
- Not Applicable. As there is no training set for an AI/ML algorithm, this question does not apply. The device's design and manufacturing are based on well-established engineering principles and adherence to regulatory and quality standards, the "ground truth" for which are the physical and chemical properties of materials and established mechanical and biological principles.
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(209 days)
SAFECARE® Multi-Drug Urine Test Dip Card is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, Nortriptyline d-Propoxyphene and 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP) in human urine at the cutoff concentrations of:
Drug(Identifier) | Cut-off level |
---|---|
Amphetamine | 500ng/mL |
Oxazepam | 300 ng/mL |
Cocaine | 150ng/mL |
Marijuana | 50 ng/mL |
Methamphetamine | 500ng/mL |
Morphine | 300ng/mL |
Oxycodone | 100 ng/mL |
Secobarbital | 300 ng/mL |
Buprenorphine | 10 ng/mL |
Methylenedioxy-methamphetamine | 500 ng/mL |
Phencyclidine | 25 ng/mL |
Methadone | 300 ng/mL |
Nortriptyline | 1000 ng/mL |
d-Propoxyphene | 300 ng/mL |
2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine | 300 ng/mL |
Configuration of SAFECARE® 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, Nortriptyline, Oxazepam, Secobarbital, Propoxyphene 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.
The tests are intended for over-the-counter use.
SAFECARE® Multi-Drug Urine Test Cup is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine. Oxazepam. Marijuana. Methamphetamine, Morphine. Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, Nortriptyline d-Propoxyphene and 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP) in human urine at the cutoff concentrations of:
Drug(Identifier) | Cut-off level |
---|---|
Amphetamine | 500ng/mL |
Oxazepam | 300 ng/mL |
Cocaine | 150ng/mL |
Marijuana | 50 ng/mL |
Methamphetamine | 500ng/mL |
Morphine | 300ng/mL |
Oxycodone | 100 ng/mL |
Secobarbital | 300 ng/mL |
Buprenorphine | 10 ng/mL |
Methylenedioxy-methamphetamine | 500 ng/mL |
Phencyclidine | 25 ng/mL |
Methadone | 300 ng/mL |
Nortriptyline | 1000 ng/mL |
d-Propoxyphene | 300 ng/mL |
2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine | 300 ng/mL |
Configuration of SAFECARE® Multi-Drug Urine Test Cup can consist of any combination of the above listed drug analytes.
The test may yield positive results for the prescription drugs Buprenorphine, Nortriptyline, Oxazepam, Secobarbital, Propoxyphene 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.
The tests are intended for over-the-counter use.
The SAFECARE® Dip Card Tests and SAFECARE® Cup Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Cannabinoids, Methamphetamine, Morphine, Secobarbital, Methadone, Methylenedioxymethamphetamine, Oxycodone, Buprenorphine, Phencyclidine, Nortriptyline, Propoxyphen and 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (target analytes) in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of Dip Cards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.
The provided document describes the performance characteristics and studies for the SAFECARE® Multi-Drug Urine Test Dip Card and SAFECARE® Multi-Drug Urine Test Cup. It does not describe an AI/ML device but rather an in-vitro diagnostic device (IVD) for drug screening. Therefore, several of the requested categories for AI/ML device evaluation are not applicable (e.g., number of experts, adjudication method, MRMC study, standalone performance, training set).
Here's the information extracted from the document, tailored to the nature of the device:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for qualitative drug tests are typically defined by precision around the cutoff concentration. The device is expected to consistently classify samples below the cutoff as negative and above the cutoff as positive. For samples near the cutoff, some variability in classification is expected.
Test Parameter / Drug (Cut-off) | Acceptance Criteria (Implicit from study design) | Reported Device Performance (Precision Study - Example for Dip Card, Lot 1) |
---|---|---|
Precision | Samples +25% Cut-off: 100% positive calls. Samples within +/-25% of Cut-off: Expected variability. | Amphetamine 500: |
-100% Cut-off: 50-/0+ (100% negative) | ||
-75% Cut-off: 50-/0+ (100% negative) | ||
-50% Cut-off: 50-/0+ (100% negative) | ||
-25% Cut-off: 50-/0+ (100% negative) | ||
Cut-off: 24-/26+ (48% negative, 52% positive) | ||
+25% Cut-off: 50+/0- (100% positive) | ||
+50% Cut-off: 50+/0- (100% positive) | ||
+75% Cut-off: 50+/0- (100% positive) | ||
+100% Cut-off: 50+/0- (100% positive) | ||
Cocaine 150: | ||
-100% Cut-off: 50-/0+ (100% negative) | ||
-75% Cut-off: 50-/0+ (100% negative) | ||
-50% Cut-off: 50-/0+ (100% negative) | ||
-25% Cut-off: 50-/0+ (100% negative) | ||
Cut-off: 24-/26+ (48% negative, 52% positive) | ||
+25% Cut-off: 50+/0- (100% positive) | ||
+50% Cut-off: 50+/0- (100% positive) | ||
+75% Cut-off: 50+/0- (100% positive) | ||
+100% Cut-off: 50+/0- (100% positive) | ||
Methamphetamine 500: | ||
-100% Cut-off: 50-/0+ (100% negative) | ||
-75% Cut-off: 50-/0+ (100% negative) | ||
-50% Cut-off: 50-/0+ (100% negative) | ||
-25% Cut-off: 50-/0+ (100% negative) | ||
Cut-off: 24-/26+ (48% negative, 52% positive) | ||
+25% Cut-off: 50+/0- (100% positive) | ||
+50% Cut-off: 50+/0- (100% positive) | ||
+75% Cut-off: 50+/0- (100% positive) | ||
+100% Cut-off: 50+/0- (100% positive) | ||
Morphine 300: | ||
-100% Cut-off: 50-/0+ (100% negative) | ||
-75% Cut-off: 50-/0+ (100% negative) | ||
-50% Cut-off: 50-/0+ (100% negative) | ||
-25% Cut-off: 50-/0+ (100% negative) | ||
Cut-off: 24-/26+ (48% negative, 52% positive) | ||
+25% Cut-off: 50+/0- (100% positive) | ||
+50% Cut-off: 50+/0- (100% positive) | ||
+75% Cut-off: 50+/0- (100% positive) | ||
+100% Cut-off: 50+/0- (100% positive) | ||
Lay-User Study (Accuracy) | For samples far from cutoff (e.g., -50% and +50%), approximately 100% correct results. For samples near cutoff (e.g., -25% and +25%), high accuracy (e.g., >90%). | AMP500: |
-50% Cutoff: 100% correct (0 Pos, 170 Neg) | ||
+50% Cutoff: 100% correct (40 Pos, 0 Neg) | ||
-25% Cutoff: 90% correct (2 Pos, 18 Neg) | ||
+25% Cutoff: 95% correct (19 Pos, 1 Neg) | ||
(Similar results reported for COC150, THC, BAR, BZO, MET500, MTD, MOP300, MDMA, OXY, BUP, PCP, TCA, PPX, EDDP) |
2. Sample sizes used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
-
Precision Study (Test Set):
- For each drug (Amphetamine, Cocaine, Methamphetamine, Morphine), 9 concentrations were tested around the cutoff (-100%, -75%, -50%, -25%, Cut-off, +25%, +50%, +75%, +100%).
- For each concentration, tests were performed two runs per day for 25 days, using 3 different lots of the device. This equates to 50 replicates per concentration per lot, totaling 450 tests per lot per drug.
- Total replicates for 4 drugs (AMP, COC, MET, MOP): 9 concentrations x 50 replicates/concentration x 3 lots = 1350 tests per drug. (Some data for other drugs were referenced from prior 510(k)s: K182654, K181968, K153646, K201120).
- Data Provenance: The document states "in-house" for comparison studies and "urine samples were prepared by spiking drug in negative samples" for precision studies. This suggests a controlled laboratory setting (likely prospective, artificial samples). The document does not specify the country of origin of the data.
-
Method Comparison Study (Clinical/Test Set):
- 80 "unaltered clinical samples" were used for each drug. These samples were split into categories: 10 negative, 10 low negative, 20 near cutoff negative, 20 near cutoff positive, 20 high positive for each drug.
- Total samples per device type (Dip Card or Cup) for 4 drugs mentioned: 80 samples x 4 drugs = 320 samples per device type.
- Data Provenance: "in-house" and "unaltered clinical samples," implying real-world samples but processed within the manufacturer's lab. The document does not specify the country of origin or whether these clinical samples were retrospective or prospectively collected for the study.
-
Lay-User Study (Test Set):
- 310 lay persons participated for each device format (Dip Card and Cup).
- Urine samples were prepared at 7 concentrations: negative, +/-75%, +/-50%, +/-25% of the cutoff.
- Total samples: For each drug, the number of samples varied across concentrations. For example, for AMP500, 20 samples at -100% cutoff, 20 at -75%, 170 at -50%, 20 at -25%, 20 at +25%, 40 at +50%, 20 at +75%. This totals 310 samples per drug per device format.
- Data Provenance: "at three intended user sites." Samples were "prepared by spiking drugs into drug free-pooled urine specimens," making them artificial but intended to mimic a range of concentrations. This suggests a prospective study design, mimicking real-world use conditions but with controlled samples.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Precision Study: Ground truth was established by preparing urine samples with known drug concentrations confirmed by LC/MS. No human experts were involved in establishing ground truth, as it was an analytical study.
- Method Comparison Study: The ground truth for clinical samples was established by LC/MS results. No mention of human experts for ground truth.
- Lay-User Study: Ground truth was established by LC/MS results of the prepared spiked urine samples.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This device is a qualitative diagnostic test read directly by users, not an AI/ML imaging device requiring expert adjudication. In the method comparison study, three laboratory assistants "ran" the samples, implying they performed the test, but the ground truth was LC/MS, not their consensus.
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
- Not applicable. This is not an AI/ML device, and no MRMC study comparing human readers with and without AI assistance was mentioned. The lay-user study evaluated the device's performance with lay users, not an "AI assistance" scenario.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not applicable. The device is a physical, lateral flow immunochromatographic assay. Its performance inherently involves a human interpreting the result line, even if it's a simple positive/negative visual interpretation. It is not an algorithm-only device. The precision and method comparison studies evaluate the device's analytical performance, which is its inherent "standalone" capability.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- LC/MS (Liquid Chromatography-Mass Spectrometry) was used as the ground truth method to confirm drug concentrations in both spiked samples (for precision and lay-user studies) and clinical samples (for method comparison studies). This is a highly accurate and quantitative analytical method.
8. The sample size for the training set
- Not applicable. This is not an AI/ML device that requires a "training set" in the machine learning sense. The device is based on immunoassay principles.
9. How the ground truth for the training set was established
- Not applicable, as there is no training set for an AI/ML device.
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(30 days)
SAFECARE® Multi-Drug Urine Test Dip Card is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, Nortriptyline d-Propoxyphene and 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP) in human urine at the cutoff concentrations listed. The test may yield positive results for the prescription drugs Buprenorphine, Oxazepam, Secobarbital, Propoxyphene 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. The tests are intended for over-the-counter use.
SAFECARE® Multi-Drug Urine Test Cup is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxy-methamphetamine, Phencyclidine, Methadone, Nortriptyline d-Propoxyphene and 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (EDDP) in human urine at the cutoff concentrations listed. The test may yield positive results for the prescription drugs Buprenorphine, Nortriptyline, Oxazepam, Secobarbital, Propoxyphene 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 or LC/MS is the preferred confirmatory method. The tests are intended for over-the-counter use.
The SAFECARE® Dip Card Tests and SAFECARE® Cup Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Cannabinoids, Methamphetamine, Morphine, Secobarbital, Methadone, Methylenedioxymethamphetamine, Oxycodone, Buprenorphine, Phencyclidine, Nortriptyline, Propoxyphen and 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine (target analytes) in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of Dip Cards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.
The provided text describes the performance characteristics of the SAFECARE® Multi-Drug Urine Test Dip Card and SAFECARE® Multi-Drug Urine Test Cup. The document details analytical performance (precision, linearity, stability, interference, specificity, effect of specific gravity and pH) and comparison studies (method comparison and lay-user study).
Here's a breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria for each analytical performance characteristic are implicitly defined by the successful results reported in the study. The study aims to demonstrate that the device performs as expected according to its intended use and analytical specifications.
-
Precision:
- Acceptance Criteria for -100% to -25% Cut-off: All samples should test negative.
- Acceptance Criteria for +25% to +100% Cut-off: All samples should test positive.
- Acceptance Criteria for Cut-off (nominal concentration): Approximately 50% positive and 50% negative results (reflecting the nature of the cut-off).
- Reported Device Performance (for 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine as an example):
- Dip Card (Lot 1, 2, 3):
- -100% Cut-off to -25% Cut-off: 50-/0+ (All negative)
- +25% Cut-off to +100% Cut-off: 50+/0- (All positive)
- Cut-off: 24-/26+, 25-/25+, 26-/24+ (Split between positive and negative, as expected)
- Cup (Lot 1, 2, 3):
- -100% Cut-off to -25% Cut-off: 50-/0+ (All negative)
- +25% Cut-off to +100% Cut-off: 50+/0- (All positive)
- Cut-off: 27-/23+, 24-/26+, 26-/24+ (Split between positive and negative, as expected)
- Dip Card (Lot 1, 2, 3):
-
Interference:
- Acceptance Criteria: No interference from common physiological or pathological substances at specified concentrations.
- Reported Device Performance: No interference observed for a comprehensive list of compounds at 100ug/mL (except albumin at 100mg/dL and ethanol at 1% volume).
-
Specificity (Cross-Reactivity):
- Acceptance Criteria: Related compounds should either not cross-react or cross-react at concentrations significantly higher than the cut-off, as defined by medical relevance.
- Reported Device Performance (for 2-ethylidene-1, 5-dimethyl-3, 3-diphenylpyrrolidine as an example):
- Methadone: Positive at 300000 ng/mL (0.1% cross-reactivity)
- EMDP: Positive at 300000 ng/mL (0.1% cross-reactivity)
- Doxylamine, Disopyramide, LAAM HCl, Alpha Methadol: Positive at >100,000 ng/mL (
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(29 days)
SAFECARE® THC Urine Strip Test is a competitive binding, lateral flow immunochromatographic assay for qualitative detection of Marijuana in human urine at the cutoff concentrations of 50 ng/mL.
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.
The test is intended for over-the-counter use.
SAFECARE® THC Urine Strip Test devices are immunochromatographic assays for the qualitative detection of 11-nor-A9-THC-9 COOH (target analyte) in human urine. The product is a single-use in vitro diagnostic device. It contains a Test Device and a package insert. Each test device is sealed with a desiccant in an aluminum pouch.
The provided document outlines the acceptance criteria and performance data for the SAFECARE® THC Urine Strip Test, which is a qualitative lateral flow immunoassay for detecting Marijuana in human urine.
Here's the breakdown of the requested information:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state formal "acceptance criteria" for precision or accuracy using specific numerical thresholds (e.g., >95% agreement). Instead, it presents the results of various performance studies. The overall acceptance is inferred from the device being deemed "substantially equivalent" to a predicate device.
However, based on the performance characteristics, we can infer performance goals for accuracy at different concentrations relative to the cutoff.
Acceptance Criteria Category | Specific Metric (Inferred) | Acceptance Threshold (Inferred/Observed) | Reported Device Performance | Comments on Performance |
---|---|---|---|---|
Analytical Performance | ||||
Precision | Agreement at various | High agreement expected, especially | ||
concentrations | at concentrations further from cutoff. | |||
-100% Cut-off | 100% Negative (0% Positive) | Lot 1, 2, 3: 50-/0+ | Meets expectation | |
-75% Cut-off | 100% Negative (0% Positive) | Lot 1, 2, 3: 50-/0+ | Meets expectation | |
-50% Cut-off | 100% Negative (0% Positive) | Lot 1, 2, 3: 50-/0+ | Meets expectation | |
-25% Cut-off | 100% Negative (0% Positive) | Lot 1, 2, 3: 50-/0+ | Meets expectation | |
Cut-off (50 ng/mL) | ~50% Positive, ~50% Negative | Lot 1, 2: 25-/25+; Lot 3: | Meets expectation | |
26-/24+ | ||||
+25% Cut-off | 100% Positive (0% Negative) | Lot 1, 2, 3: 50+/0- | Meets expectation | |
+50% Cut-off | 100% Positive (0% Negative) | Lot 1, 2, 3: 50+/0- | Meets expectation | |
+75% Cut-off | 100% Positive (0% Negative) | Lot 1, 2, 3: 50+/0- | Meets expectation | |
+100% Cut-off | 100% Positive (0% Negative) | Lot 1, 2, 3: 50+/0- | Meets expectation | |
Interference | No interference from | No false positives or negatives due to | Compounds at 100µg/mL | No interference reported |
common substances | specified interfering substances when | (list provided) showed no | ||
drug is absent or present above cutoff | interference. | |||
Specificity | Cross-reactivity with | Low or no cross-reactivity with | Provided specific cross- | Demonstrated specificity |
related compounds | non-target compounds. | reactivity percentages for | ||
related cannabinoids. | ||||
Urine Specific Gravity | Correct results across | Correct classification (negative for | Samples from 1.000 to 1.035 | Device performs reliably |
range of SG | -25% cutoff, positive for +25% cutoff). | with THC at +/-25% cutoff | across range of urine SG | |
showed expected results. | ||||
Urine pH | Correct results across | Correct classification (negative for | Samples from pH 4 to 9 with | Device performs reliably |
range of pH | -25% cutoff, positive for +25% cutoff). | THC at +/-25% cutoff | across range of urine pH | |
showed expected results. | ||||
Comparison Studies | Agreement with LC/MS | High agreement between device results | ||
for clinical samples | and LC/MS, particularly for samples | |||
not near the cutoff. | ||||
Overall Agreement | Not explicitly quantified, but inferred | Viewer A: 78/80 (97.5%) | High agreement for | |
from discordant results. | Viewer B: 78/80 (97.5%) | human readers | ||
Viewer C: 79/80 (98.75%) | ||||
Lay-User Study | Ease of use | Instructions are easily understood. | All lay users indicated | Instructions are clear |
instructions were easy to | ||||
Accuracy of self-testing | High percentage of correct results, | |||
decreasing near the cutoff. | ||||
-100% Cutoff | 100% agreement | 100% Correct | Excellent | |
-75% Cutoff | 100% agreement | 100% Correct | Excellent | |
-50% Cutoff | 100% agreement | 100% Correct | Excellent | |
-25% Cutoff | >90% agreement, with expected | 90% Correct | Acceptable, slight dip | |
increase in discordance. | near cutoff. | |||
+25% Cutoff | >90% agreement, with expected | 95% Correct | Acceptable, slight dip | |
increase in discordance. | near cutoff. | |||
+50% Cutoff | 100% agreement | 100% Correct | Excellent | |
+75% Cutoff | 100% agreement | 100% Correct | Excellent |
2. Sample Size Used for the Test Set and Data Provenance
- Precision Study:
- Sample Size: 9 different concentrations, with 50 tests performed for each concentration per lot (2 runs per day for 25 days). Since 3 lots were tested, this amounts to 9 concentrations * 50 tests/lot * 3 lots = 1350 tests in total for the precision study itself. The samples were prepared by spiking drug in "negative samples." The provenance is not explicitly stated but implies laboratory-prepared samples.
- Comparison Studies (Clinical Samples):
- Sample Size: 80 unaltered clinical samples (40 negative and 40 positive).
- Data Provenance: The document states "unaltered clinical samples." The country of origin for these clinical samples is not specified. It is a retrospective analysis as the samples were collected and then tested.
- Lay-User Study:
- Sample Size: 140 lay persons tested individual samples. There were 7 concentration levels, with 20 samples per concentration. So, 7 concentrations * 20 samples/concentration = 140 samples in total.
- Data Provenance: The samples were "spiked drug THC into drug free-pooled urine specimens." The country of origin is not specified. It is a prospective study in the sense that the lay users tested the devices with prepared samples, but the samples themselves were laboratory-prepared.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications
- Precision Study: The ground truth was established by laboratory preparation of samples with known concentrations confirmed by LC/MS. No human experts are explicitly mentioned for ground truth.
- Comparison Studies (Clinical Samples): The ground truth was established by LC/MS results. "LC/MS is the preferred confirmatory method." The number of LC/MS operators or analysts is not specified, nor are their qualifications.
- Lay-User Study: The ground truth for the prepared urine samples was established by LC/MS. The number of LC/MS operators or analysts is not specified, nor are their qualifications.
4. Adjudication Method for the Test Set
- Precision Study: Not applicable, as results were quantitative (known concentrations) rather than subjective interpretations needing adjudication.
- Comparison Studies (Clinical Samples): The document mentions "three different laboratory assistants" performing the tests. Their results were compared to LC/MS. There is no explicit adjudication method stated for discrepancies between human readers or between human readers and LC/MS. The discordant results table simply lists them.
- Lay-User Study: Not explicitly stated. Each lay person provided their own result. Their individual results were then compared to the LC/MS confirmed concentration.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study Was Done, and the Effect Size of How Much Human Readers Improve with AI vs without AI Assistance
- No, an MRMC comparative effectiveness study was not done.
- This device is a standalone diagnostic strip test intended for visual interpretation, not an AI-assisted diagnostic tool. Therefore, there is no AI component or human readers improving with/without AI assistance.
6. If a Standalone (i.e. algorithm only without human-in-the-loop performance) Was Done
- Yes, in essence, the "device performance" in all studies represents a standalone performance relative to the ground truth (LC/MS). The device itself (the strip test) produces a visual result. While a human reads the result, the performance studies assess the accuracy of the device's output (presence/absence of a line) against known concentrations.
- For the "Comparison Studies," the performance of the "Safecare THC Urine Strip Test" is measured for each viewer by comparing their reading of the device against LC/MS. This measures the combined device-human performance.
- For the "Lay-User Study," it also measures the combined device-lay user performance.
7. The Type of Ground Truth Used
- For all performance studies (Precision, Comparison, Lay-User), the ground truth was primarily established by LC/MS (Liquid Chromatography-Mass Spectrometry). This is a highly accurate and quantitative laboratory method.
- For the precision study, it specifies "THC drug concentration was confirmed by LC/MS."
- For the comparison studies, it states "The samples were blind labeled and compared to LC/MS results. LC/MS is the preferred confirmatory method."
- For the lay-user study, it states "The concentrations of the samples were confirmed by LC/MS."
8. The Sample Size for the Training Set
- Based on the provided document, this is a 510(k) submission for a diagnostic device. Such submissions typically focus on analytical and clinical performance validation rather than explicitly detailing a "training set" for an algorithm.
- There is no information provided regarding a "training set" as this is not an AI/machine learning device. The immunoassay device relies on chemical reactions, not on data training.
9. How the Ground Truth for the Training Set Was Established
- As there is no mention of a "training set" or an algorithm that requires training, this question is not applicable based on the provided document.
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(55 days)
SAFECARE® Multi-Drug Urine Test Dip Card is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Marijuana, Methamphetamine, Morphine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxymethamine, Phencyclidine, Methadone, Nortriotyline and d-Propoxyphene in human urine at the cutoff concentrations of:
Drug(Identifier) | Cut-off level |
---|---|
Amphetamine | 1000 ng/mL |
Oxazepam | 300 ng/mL |
Cocaine | 300 ng/mL |
Marijuana | 50 ng/mL |
Methamphetamine | 1000 ng/mL |
Morphine | 2000 ng/mL |
Oxycodone | 100 ng/mL |
Secobarbital | 300 ng/mL |
Buprenorphine | 10 ng/mL |
Methylenedioxymethamphetamine | 500 ng/mL |
Phencyclidine | 25 ng/mL |
Methadone | 300 ng/mL |
Nortriptyline | 1000 ng/mL |
d-Propoxyphene | 300 ng/mL |
Configuration of SAFECARE® 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. Propoxyphene 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. GCMS or LC/MS is the preferred confirmatory method.
The tests are intended for over-the-counter use.
SAFECARE® Multi-Drug Urine Test Cup is competitive binding, lateral flow immunichromatographic assays for qualitative and simultaneous detection of Amphetanine, Oxazepam, Methamphetamine, Morghine, Oxycodone, Secobarbital, Buprenorphine, Methylenedioxymethamphetamine, Phencyclidine, Methadone, Nortriptyline and d-Propoxyphene in human urine at the cutoff concentrations of:
Drug(Identifier) | Cut-off level |
---|---|
Amphetamine | 1000 ng/mL |
Oxazepam | 300 ng/mL |
Cocaine | 300 ng/mL |
Marijuana | 50 ng/mL |
Methamphetamine | 1000 ng/mL |
Morphine | 2000 ng/mL |
Oxycodone | 100 ng/mL |
Secobarbital | 300 ng/mL |
Buprenorphine | 10 ng/mL |
Methylenedioxymethamphetamine | 500 ng/mL |
Phencyclidine | 25 ng/mL |
Methadone | 300 ng/mL |
Nortriptyline | 1000 ng/mL |
d-Propoxyphene | 300 ng/mL |
Configuration of SAFECARE® Multi-Drug Urine Test Cup contination of the above listed drug analytes.
The test may yield positive results for the prescription drugs Buprenorphine. Oxazenam, Secobarbital, Propoxyphene 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. GCMS or LC/MS is the preferred confirmatory method.
The tests are intended for over-the-counter use.
The SAFECARE Dip Card Tests and SAFECARE Cup Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Cannabinoids, Methamphetamine, Morphine, Secobarbital, Methadone, Methylenedioxymethamphetamine, Oxycodone, Buprenorphine, Phencyclidine, Nortriptyline and Propoxyphene (target analytes) in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of Dip Cards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.
The document describes the performance characteristics and studies for the SAFECARE Multi-Drug Urine Test Dip Card and SAFECARE Multi-Drug Urine Test Cup.
Here's an analysis of the acceptance criteria and study that proves the device meets them:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state "acceptance criteria" in a separate section. However, the performance data presented implies a very high standard for accuracy, particularly around the established cutoff concentrations. The "precision" studies demonstrate the device's ability to consistently produce correct results for samples at varying concentrations relative to the cutoff. The "comparison studies" compare the device's qualitative results to a quantitative gold standard (LC/MS) to establish concordance. The "lay-user study" assesses the ability of untrained individuals to correctly use and interpret the device.
Based on the provided data, the implied acceptance criteria for qualitative immunoassay devices for drug testing would typically be:
- 100% agreement for samples significantly below the cutoff (Negative).
- 100% agreement for samples significantly above the cutoff (Positive).
- High percentage agreement for samples near the cutoff (typically >90%).
For the Precision Study (Analytical Performance - "Test Set" Data):
The table below summarizes the reported performance for Methylenedioxymethamphetamine (MDMA), Oxycodone, Buprenorphine, Phencyclidine, Nortriptyline, and Propoxyphene (results from 3 lots, 50 tests per concentration per lot, per device type). The format is (Number of Negative Results)/(Number of Positive Results)
.
Drug (Identifier) | Cut-off Level | Concentration | Reported Performance (Typical across 3 lots) | Implied Acceptance Criteria Met? |
---|---|---|---|---|
Methylenedioxymethamphetamine (MDMA) (Dip Card & Cup) | 500 ng/mL | -100% Cut-off | 50-/0+ | Yes (100% negative) |
-75% Cut-off | 50-/0+ | Yes (100% negative) | ||
-50% Cut-off | 50-/0+ | Yes (100% negative) | ||
-25% Cut-off | 50-/0+ | Yes (100% negative) | ||
Cut-off | 25-/25+ or 26-/24+ | Yes (near 50/50 split at cutoff) | ||
+25% Cut-off | 50+/0- | Yes (100% positive) | ||
+50% Cut-off | 50+/0- | Yes (100% positive) | ||
+75% Cut-off | 50+/0- | Yes (100% positive) | ||
+100% Cut-off | 50+/0- | Yes (100% positive) | ||
Oxycodone (Dip Card & Cup) | 100 ng/mL | -100% Cut-off | 50-/0+ | Yes (100% negative) |
-75% Cut-off | 50-/0+ | Yes (100% negative) | ||
-50% Cut-off | 50-/0+ | Yes (100% negative) | ||
-25% Cut-off | 50-/0+ | Yes (100% negative) | ||
Cut-off | 24-/26+ or 26-/24+ or 25-/25+ | Yes (near 50/50 split at cutoff) | ||
+25% Cut-off | 50+/0- | Yes (100% positive) | ||
+50% Cut-off | 50+/0- | Yes (100% positive) | ||
+75% Cut-off | 50+/0- | Yes (100% positive) | ||
+100% Cut-off | 50+/0- | Yes (100% positive) | ||
Buprenorphine (Dip Card & Cup) | 10 ng/mL | -100% Cut-off | 50-/0+ | Yes (100% negative) |
-75% Cut-off | 50-/0+ | Yes (100% negative) | ||
-50% Cut-off | 50-/0+ | Yes (100% negative) | ||
-25% Cut-off | 50-/0+ | Yes (100% negative) | ||
Cut-off | 27-/23+, 25-/25+, 24-/26+, 26-/24+ | Yes (near 50/50 split at cutoff) | ||
+25% Cut-off | 50+/0- | Yes (100% positive) | ||
+50% Cut-off | 50+/0- | Yes (100% positive) | ||
+75% Cut-off | 50+/0- | Yes (100% positive) | ||
+100% Cut-off | 50+/0- | Yes (100% positive) | ||
Phencyclidine (Dip Card & Cup) | 25 ng/mL | -100% Cut-off | 50-/0+ | Yes (100% negative) |
-75% Cut-off | 50-/0+ | Yes (100% negative) | ||
-50% Cut-off | 50-/0+ | Yes (100% negative) | ||
-25% Cut-off | 50-/0+ | Yes (100% negative) | ||
Cut-off | 26-/24+, 25-/25+, 24-/26+ | Yes (near 50/50 split at cutoff) | ||
+25% Cut-off | 50+/0- | Yes (100% positive) | ||
+50% Cut-off | 50+/0- | Yes (100% positive) | ||
+75% Cut-off | 50+/0- | Yes (100% positive) | ||
+100% Cut-off | 50+/0- | Yes (100% positive) | ||
Nortriptyline (Dip Card & Cup) | 1000 ng/mL | -100% Cut-off | 50-/0+ | Yes (100% negative) |
-75% Cut-off | 50-/0+ | Yes (100% negative) | ||
-50% Cut-off | 50-/0+ | Yes (100% negative) | ||
-25% Cut-off | 50-/0+ | Yes (100% negative) | ||
Cut-off | 25-/25+, 26-/24+, 24-/26+ | Yes (near 50/50 split at cutoff) | ||
+25% Cut-off | 50+/0- | Yes (100% positive) | ||
+50% Cut-off | 50+/0- | Yes (100% positive) | ||
+75% Cut-off | 50+/0- | Yes (100% positive) | ||
+100% Cut-off | 50+/0- | Yes (100% positive) | ||
Propoxyphene (Dip Card & Cup) | 300 ng/mL | -100% Cut-off | 50-/0+ | Yes (100% negative) |
-75% Cut-off | 50-/0+ | Yes (100% negative) | ||
-50% Cut-off | 50-/0+ | Yes (100% negative) | ||
-25% Cut-off | 50-/0+ | Yes (100% negative) | ||
Cut-off | 23-/27+, 26-/24+, 24-/26+, 25-/25+ | Yes (near 50/50 split at cutoff) | ||
+25% Cut-off | 50+/0- | Yes (100% positive) | ||
+50% Cut-off | 50+/0- | Yes (100% positive) | ||
+75% Cut-off | 50+/0- | Yes (100% positive) | ||
+100% Cut-off | 50+/0- | Yes (100% positive) |
For the Lay-user Study:
The acceptance criteria for the lay-user study would typically be a high percentage of correct results, especially for samples clearly negative or positive, and a reasonable proportion around the cutoff. The document shows the "percentage of correct results (%)" for each concentration level. The implied acceptance criteria for OTC urine drug screens are usually very high concordance (e.g., >90%) with the ground truth for samples away from the cutoff, and some level of agreement for near-cutoff samples (where variability is expected). The device performance meets these generally implied high standards, especially for samples clearly below or above the cutoff (100% for most categories). For samples near +/-25% of cutoff, the accuracy ranges from 85-95%, which is typical for qualitative tests and acceptable for over-the-counter use where confirmation is recommended for positive results.
2. Sample Size Used for the Test Set and Data Provenance
- Precision Studies (Test Set):
- For each drug, device type (Dip Card/Cup), and each of the 9 concentration levels: 50 tests were performed per concentration.
- This was repeated for 3 different lots for each device type.
- Therefore, for a single drug and device type, the test set size for precision was: 9 concentrations * 50 tests/concentration * 3 lots = 1350 tests.
- Data Provenance: The samples were prepared by "spiking drug in negative samples" and confirmed by LC/MS. This suggests controlled, prospective laboratory-prepared samples rather than retrospective clinical samples from specific countries. The testing was "in-house."
- Comparison Studies (Test Set):
- For each drug and device type (Dip Card/Cup): 80 unaltered clinical samples (40 negative and 40 positive) were used.
- Data Provenance: "unaltered clinical samples." The document does not specify the country of origin, but given the manufacturer (China) and submission to US FDA, the samples could be from various global sources or acquired for the study. It's a retrospective analysis against independently confirmed samples.
- Lay-user Study (Test Set):
- For each device format (presumably Dip Card and Cup, though only combined results are shown in the given table): 300 lay persons participated.
- The total number of samples processed for each drug across the different concentration levels in the lay-user study tables is: 20 + 20 + 160 + 20 + 20 + 40 + 20 = 300 samples. (It seems 300 samples were tested for each drug type, probably with each of the 300 lay users testing one sample)
- Data Provenance: Urine samples were "prepared at the following concentrations; negative, +/-75%, +/-50%, +/-25% of the cutoff by spiking drugs into drug free-pooled urine specimens." These were laboratory-prepared samples. The study involved "three intended user sites."
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Precision Studies: Ground truth was established by LC/MS (Liquid Chromatography-Mass Spectrometry), which is a definitive quantitative analytical method. It's an instrumental method, so human "experts" in interpretation are typically not specified in the same way as for imaging or clinical diagnosis. The samples were "blindly labeled by the person who prepared the samples," which indicates blinding to the LC/MS results during the device testing.
- Comparison Studies: Ground truth was established by LC/MS results. The document states, "The samples were blind labeled and compared to LC/MS results." These are definitive chemical analysis results.
- Lay-user Study: Ground truth for the samples was established by LC/MS confirmation of the spiked drug concentrations.
4. Adjudication Method for the Test Set
- Precision Studies: No explicit human adjudication method mentioned, as the device results are quantitative categories (positive/negative) and compared to definitive LC/MS values. The results are reported as counts (e.g., 25-/25+).
- Comparison Studies: The device results were read by "three laboratory assistants." For discordant results, the individual viewer's result is listed against the LC/MS truth, but no specific human adjudication process (e.g., 2+1 majority voting) is described for resolving discrepancies among the assistants or between the assistants and LC/MS. The LC/MS is the definitive ground truth here.
- Lay-user Study: The results are presented as aggregated counts of positive/negative readings by the lay users compared to the known ground truth (LC/MS confirmed concentrations). No human adjudication process is mentioned among the lay users.
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
- No, an MRMC comparative effectiveness study was not done. This type of study is relevant for AI-assisted diagnostic devices where human readers interpret images or complex data, and the AI serves as an aid.
- This device is a qualitative, over-the-counter urine drug test. Its performance is evaluated against chemical analytical ground truth, and its usability is assessed with lay users, not by evaluating how it assists expert readers.
6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done
- This device is a physical, qualitative immunoassay test kit, not a standalone algorithm/AI for analysis. The "performance" of the device itself (the reaction on the dip card/cup) is evaluated.
- However, the Comparison Studies and Precision Studies could be considered the "standalone" performance of the device when read by trained laboratory personnel (3 laboratory assistants), as it's the device's output itself being compared to LC/MS.
- The Lay-user study evaluates the device performance when interpreted by the intended "human-in-the-loop" (a lay user).
7. The Type of Ground Truth Used (expert consensus, pathology, outcomes data, etc.)
- The primary ground truth used for all performance studies (Precision, Comparison, Lay-user) is quantitative chemical analysis by LC/MS (Liquid Chromatography-Mass Spectrometry). This is a highly accurate and widely accepted method for confirming drug concentrations in urine.
- For the precision and lay-user studies, urine samples were spiked with known concentrations of drugs, and these concentrations were confirmed by LC/MS.
- For the comparison studies, "unaltered clinical samples" were used, with LC/MS providing the definitive truth for the presence and concentration of drugs.
8. The Sample Size for the Training Set
- This document describes premarket notification (510(k)) for a drug test kit, which is a physical diagnostic device based on immunochromatography, not an AI/Machine Learning algorithm.
- Therefore, there is no "training set" in the context of machine learning model development. The device's performance relies on its physical and chemical design, not on a trained algorithm.
9. How the Ground Truth for the Training Set Was Established
- As there is no AI/ML algorithm or training set, this question is not applicable.
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(27 days)
SAFECARE® Multi-Drug Urine Test Dip Card is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cocaine, Cannabinoids, Methamphetamine, Morphine, Secobarbital and Methadone in human urine at the cutoff concentrations of:
Drug (Identifier) | Cut-off level |
---|---|
Amphetamine | 1000 ng/mL |
Oxazepam | 300 ng/mL |
Cocaine | 300 ng/mL |
Cannabinoids | 50 ng/mL |
Methamphetamine | 1000 ng/mL |
Morphine | 2000 ng/mL |
Secobarbital | 300 ng/mL |
Methadone | 300 ng/mL |
Configuration of SAFECARE® 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 Oxazepam and Secobarbital 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 or LC/MS is the preferred confirmatory method. The tests are intended for over-the-counter use.
SAFECARE® Multi-Drug Urine Test Cup is competitive binding, lateral flow immunochromatographic assays for qualitative and simultaneous detection of Amphetamine, Oxazepam, Cannabinoids, Methamphetamine, Morphine, Secobarbital and Methadone in human urine at the cutoff concentrations of:
Drug (Identifier) | Cut-off level |
---|---|
Amphetamine | 1000 ng/mL |
Oxazepam | 300 ng/mL |
Cocaine | 300 ng/mL |
Cannabinoids | 50 ng/mL |
Methamphetamine | 1000 ng/mL |
Morphine | 2000 ng/mL |
Secobarbital | 300 ng/mL |
Methadone | 300 ng/mL |
Configuration of SAFECARE® Multi-Drug Urine Test Cup combination of the above listed drug analytes.
The test may yield positive results for the prescription drugs Oxazepam and Secobarbital 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. The tests are intended for over-the-counter use.
The SAFECARE Dip Card Tests and SAFECARE Cup Tests are immunochromatographic assays that use a lateral flow system for the qualitative detection of Amphetamine, Oxazepam, Cocaine, Marijuana, Methamphetamine, Morphine, Secobarbital and Methadone (target analytes) in human urine. The products are single-use in vitro diagnostic devices, which come in the formats of Dip Cards or Cups. Each test kit contains a Test Device (in one of the two formats), a package insert and a urine cup for sample collection. Each test device is sealed with a desiccant in an aluminum pouch.
The document describes the SAFECARE Multi-Drug Urine Test Dip Card and SAFECARE Multi-Drug Urine Test Cup devices, which are qualitative lateral flow immunochromatographic assays for detecting various drugs in human urine.
Here's an analysis of the acceptance criteria and study data provided:
1. Table of Acceptance Criteria and Reported Device Performance
The document does not explicitly state pre-defined acceptance criteria in terms of a minimum performance threshold (e.g., "sensitivity must be >90%"). Instead, it presents the results of precision, specificity, linearity, stability, interference, and comparison studies, implying that the observed performance across these studies is considered acceptable for substantial equivalence. For the qualitative tests, the key performance indicator is the ability to correctly identify samples both above and below the cut-off concentrations.
Below is a summary of the reported device performance for selected drugs based on "Precision" and "Lay-user study" data. The "Precision" study shows how consistently the device performs near the cut-off, while the "Lay-user study" assesses the device's accuracy when used by the intended over-the-counter users.
Acceptance Criteria (Implied for consistency and accuracy related to cut-off)
- Precision: High agreement (ideally 100% negative/positive) for samples far from the cutoff (e.g., -100%, -75%, +75%, +100% cutoff). Some variability (mixed positive/negative results) is expected and acceptable near the cutoff (e.g., -25%, cutoff, +25%).
- Lay-user Performance (Percentage of correct results): High percentage of correct results, especially for samples significantly above or below the cutoff. Some deviation might be acceptable near the cutoff.
Reported Device Performance (Excerpt for Secobarbital Dip Card and for all drugs in Lay-user study)
Precision Study - Secobarbital Dip Card (Illustrative Example from document, similar patterns for other drugs)
Concentration % of Cut-off | Lot 1 (Negative/Positive) | Lot 2 (Negative/Positive) | Lot 3 (Negative/Positive) |
---|---|---|---|
-100% Cut-off | 50-/0+ | 50-/0+ | 50-/0+ |
-75% Cut-off | 50-/0+ | 50-/0+ | 50-/0+ |
-50% Cut-off | 50-/0+ | 50-/0+ | 50-/0+ |
-25% Cut-off | 50-/0+ | 50-/0+ | 50-/0+ |
Cut-off | 25-/25+ | 26-/24+ | 26-/24+ |
+25% Cut-off | 50+/0- | 50+/0- | 50+/0- |
+50% Cut-off | 50+/0- | 50+/0- | 50+/0- |
+75% Cut-off | 50+/0- | 50+/0- | 50+/0- |
+100% Cut-off | 50+/0- | 50+/0- | 50+/0- |
Interpretation for Precision (e.g., Secobarbital Dip Card):
- For samples far below the cutoff (-100%, -75%, -50%, -25%), all 50 tests consistently showed negative results (50-/0+), indicating perfect agreement for negative samples sufficiently below the cutoff.
- For samples far above the cutoff (+25%, +50%, +75%, +100%), all 50 tests consistently showed positive results (50+/0-), indicating perfect agreement for positive samples sufficiently above the cutoff.
- At the exact cutoff, there was an expected mix of positive and negative results (e.g., 25-/25+, 26-/24+), demonstrating the device's performance around the critical concentration.
Lay-user Study - Percentage of Correct Results (Summary across drugs for Dip Card)
Drug | % of Cutoff | Percentage of Correct Results (%) |
---|---|---|
Amphetamine | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 95 (19 negative out of 20) | |
+25% | 85 (17 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Cocaine | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 90 (18 negative out of 20) | |
+25% | 90 (18 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Cannabinoids | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 90 (18 negative out of 20) | |
+25% | 95 (19 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Secobarbital | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 95 (19 negative out of 20) | |
+25% | 90 (18 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Oxazepam | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 85 (17 negative out of 20) | |
+25% | 95 (19 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Methamphetamine | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 85 (17 negative out of 20) | |
+25% | 90 (18 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Methadone | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 95 (19 negative out of 20) | |
+25% | 90 (18 positive out of 20) | |
+50% | 100 | |
+75% | 100 | |
Morphine | -100% | 100 |
-75% | 100 | |
-50% | 100 | |
-25% | 95 (19 negative out of 20) | |
+25% | 95 (19 positive out of 20) | |
+50% | 100 | |
+75% | 100 |
Interpretation for Lay-user Study:
The lay-user study for both Dip Card and Cup formats consistently shows 100% correct results for samples well above (+50%, +75%) and well below (-50%, -75%, -100%) the cutoff. Near the cutoff point (-25% and +25%), the percentage of correct results typically drops to between 85% and 95%, which is expected given the concentrations are close to the detection threshold. The study indicates the devices perform as intended for over-the-counter use.
2. Sample size used for the test set and the data provenance
- Precision Study: For each drug and each device type (Dip Card/Cup), the samples were prepared at 9 different concentrations relative to the cut-off (-100%, -75%, -50%, -25%, cut-off, +25%, +50%, +75%, +100%). For each concentration, tests were performed "two runs per day for 25 days per device in a randomized order." This implies a total of 50 tests per concentration per drug per device, for each of the three lots.
- Example for Secobarbital Dip Card: 9 concentrations * 50 tests/concentration * 3 lots = 1350 test results.
- Data Provenance: "These samples were prepared by spiking drug in negative samples." The document specifies these are "spiked" samples into "negative samples" (presumably drug-free urine), and concentrations were confirmed by LC/MS. This suggests laboratory-controlled samples (retrospective fabrication) rather than patient-derived clinical samples.
- Comparison Studies (Lab Assistant/Clinical Performance): For each drug, "Operators ran 80 (40 negative and 40 positive) unaltered clinical samples for each drug."
- This means 80 clinical samples per drug were used.
- Data Provenance: "unaltered clinical samples." The document states this was "performed in-house," but does not specify the country of origin. Given the submitter is Safecare Biotech (Hangzhou) Co. Ltd. from China, the in-house clinical samples likely originated from China. The samples were compared to LC/MS results.
- Lay-user Study: "A lay user study was performed at three intended user sites with 240 lay persons for each device format."
- The test set comprised urine samples prepared at 7 different concentrations relative to the cut-off (negative, +/-75%, +/-50%, +/-25% of the cutoff). The document indicates for each concentration, approximately 20 to 100 samples were tested for each drug (e.g., 20 at -100% cutoff, 100 at -50% cutoff, 40 at +50% cutoff, totaling around 20 * 5 + 100 * 2 = 300 test results per drug).
- Data Provenance: "Urine samples were prepared at the following concentrations; negative, +/-75%, +/-50%, +/-25% of the cutoff by spiking drugs into drug free-pooled urine specimens." Concentrations confirmed by LC/MS. This implies laboratory-controlled spiked samples, similar to the precision study.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Precision Studies & Lay-user Study: The ground truth (drug concentration) was established by LC/MS (Liquid Chromatography-Mass Spectrometry), which is a highly accurate analytical method. The document does not specify human experts for establishing ground truth for these studies, as the LC/MS directly provides quantitative measurements.
- Comparison Studies (Lab Assistant/Clinical Performance): The ground truth for the "unaltered clinical samples" was established by LC/MS results. The study mentions "three laboratory assistants" who "ran" the tests and "compared to LC/MS results," but these assistants are the operators of the device under test, not the ground truth experts.
4. Adjudication method for the test set
- Precision Studies & Lay-user Study: The ground truth was based on objective analytical measurements (LC/MS). There was no human "adjudication" in the sense of reconciling differing expert opinions. The comparison was directly between the device's qualitative result and the known quantitative drug concentration relative to the cut-off.
- Comparison Studies (Lab Assistant/Clinical Performance): The document does not describe an explicit adjudication method. The results from the device, interpreted by "three laboratory assistants," were directly compared to the LC/MS results, which served as the gold standard. Discordant results are individually reported (e.g., Viewer A found Positive, LC/MS was 289 ng/mL), but no adjudication of discrepant viewer readings against each other or a higher authority is mentioned. Each viewer's interpretation was compared against the LC/MS.
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
- Not Applicable. This device is a rapid diagnostic test (lateral flow immunochromatographic assay), not an AI-assisted diagnostic tool. Therefore, an MRMC comparative effectiveness study involving AI assistance for human readers was not performed or described. The "readers" in the "Comparison Studies" are "three laboratory assistants" interpreting the visual lines on the test.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable. This device is a manual, visually interpreted lateral flow assay. It does not employ an algorithm for interpretation. The performance is inherently "standalone" in the sense that the device produces a visual result, but it requires human interpretation. The "Lay-user study" specifically assesses performance without expert human-in-the-loop, relying on typical users' interpretation.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- The primary ground truth used in all analytical and comparative studies (Precision, Comparison, Lay-user) was Liquid Chromatography-Mass Spectrometry (LC/MS) results. This is a gold standard analytical method for precise and accurate quantification of drug concentrations.
- For the comparison studies, "unaltered clinical samples" were used, and their status (positive/negative relative to cutoff) was determined by LC/MS.
8. The sample size for the training set
- The document does not describe any "training set." These are diagnostic devices that do not involve machine learning or AI models requiring a training phase for their interpretation logic. Their "training" is in their manufacturing process and the inherent biochemical reactions.
9. How the ground truth for the training set was established
- Not Applicable as there is no training set described for this type of device.
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(88 days)
SAFECARE Urine Test Amphetamine Cassette is a rapid test for the qualitative detection of Amphetamine in human urine at a cutoff concentration of 1000 ng/mL.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Amphetamine Cup is a rapid test for the qualitative detection of Amphetamine in human urine at a cutoff concentration of 1000 ng/mL.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Amphetamine DipCard is a rapid test for the qualitative detection of Amphetamine in human urine at a cutoff concentration of 1000 ng/mL.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Cocaine Cassette is a rapid test for the qualitative detection of Benzoylecgonine in human urine at a cutoff concentration of 300 ng/ml.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Cocaine Cup is a rapid test for the qualitative detection of Benzoylecgonine in human urine at a cutoff concentration of 300 ng/ml.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Cocaine DipCard is a rapid test for the qualitative detection of Benzoylecgonine in human urine at a cutoff concentration of 300 ng/ml.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Marijuana Cassette is a rapid test for the qualitative detection of Cannabinoids in human urine at a cutoff concentration of 50 ng/mL.
The tests provide 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. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Marijuana Cup is a rapid test for the qualitative detection of Cannabinoids in human urine at a cutoff concentration of 50 ng/mL.
The tests provide only preliminary test results. A more specific alternative chemical must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test Marijuana DipCard is a rapid test for the qualitative detection of Cannabinoids in human urine at a cutoff concentration of 50 ng/mL.
The tests provide only preliminary test results. A more specific alternative chemical must be used in order to obtain a confirmed analytical result. GC/MS is the preferred confirmatory method. Clinical consideration and professional judgment should be exercised with any drug of abuse test result, particularly when the preliminary result is positive. For in vitro diagnostic use only. The tests are intended for over-the-counter and for prescription use.
SAFECARE Urine Test devices are immunochromatographic assays for cocaine, amphetamine and marijuana. Each assay test is a lateral flow, one step system for the qualitative detection of Benzoylecgonine, or D-amphetamine or 11-nor-A9-THC-9 COOH (target analyte) in human urine. The product is a single-use in vitro diagnostic device, which comes in the form of: DipCards, or Cups or Cassettes. It contains a Test Device (in one of the three formats), a package insert and a urine cup. Each test device is sealed with a desiccant in an aluminum pouch.
The provided document describes the acceptance criteria and study results for the SAFECARE Urine Test Amphetamine, Cocaine, and Marijuana devices.
Here's an organized summary of the information requested:
Acceptance Criteria and Device Performance Study
The SAFECARE Urine Test devices are qualitative tests for the detection of Amphetamine, Cocaine (Benzoylecgonine), and Marijuana (Cannabinoids) in human urine at specific cutoff concentrations. The study aims to demonstrate the device's accuracy and reliability through analytical performance and comparison studies.
1. Acceptance Criteria and Reported Device Performance
The acceptance criteria are not explicitly stated as numerical targets (e.g., Sensitivity > X%, Specificity > Y%). However, the study design implicitly establishes acceptance criteria through its reported performance, which demonstrates consistent and accurate results around the cutoff concentrations. Given that this is a 510(k) submission and the conclusion states "acceptable performance characteristics" and "substantially equivalent to the predicate," the presented performance implicitly meets the FDA's requirements for substantial equivalence.
Interpreted Acceptance Criteria (Implicitly met by study results):
- Precision: Consistent results across different lots and repeated testing at various concentrations relative to the cutoff. For concentrations well below the cutoff (-100%, -75%, -50% cutoff), results should be consistently negative. For concentrations well above the cutoff (+50%, +75%, +100% cutoff), results should be consistently positive. At concentrations near the cutoff (-25%, cutoff, +25% cutoff), there should be an expected distribution of positive and negative results, demonstrating appropriate cutoff sensitivity.
- Cut-off Verification: All samples at and above +50% cut-off are positive, and all samples at and below -50% cut-off are negative.
- Interference/Specificity: No interference from common physiological substances or cross-reactivity from specified compounds at tested concentrations should lead to false positives/negatives at 25% above cutoff.
- Method Comparison: High agreement with GC/MS results for both negative and positive clinical samples. Low rates of discordant results, particularly for samples well below or well above the cutoff.
- Lay-user Performance: High percentages of correct results when performed by lay users, indicating ease of understanding and use. This is especially critical for over-the-counter devices.
Reported Device Performance (Excerpt for Amphetamine Dip Card - Precision Study):
Drug | Result | -100% Cut-off | -75% Cut-off | -50% Cut-off | -25% Cut-off | Cut-off | +25% Cut-off | +50% Cut-off | +75% Cut-off | +100% Cut-off |
---|---|---|---|---|---|---|---|---|---|---|
Lot 1 | Negative | 50 | 50 | 50 | 47 | 24 | 1 | 0 | 0 | 0 |
Positive | 0 | 0 | 0 | 3 | 26 | 49 | 50 | 50 | 50 | |
Lot 2 | Negative | 50 | 50 | 50 | 48 | 26 | 2 | 0 | 0 | 0 |
Positive | 0 | 0 | 0 | 2 | 24 | 48 | 50 | 50 | 50 | |
Lot 3 | Negative | 50 | 50 | 50 | 49 | 26 | 3 | 0 | 0 | 0 |
Positive | 0 | 0 | 0 | 1 | 24 | 47 | 50 | 50 | 50 |
Self-correction made: The table in the document uses "50-/0+" format where 50- means 50 negative results and 0+ means 0 positive results. This was separated into two rows for clarity as "Negative" and "Positive".
Lay-User Performance (Excerpt for Amphetamine Cup):
% of Cutoff | Number of samples | d-Amphetamine Concentration by GC/MS (ng/mL) | No. of Positive | No. of Negative | The percentage of correct results (%) |
---|---|---|---|---|---|
-100% Cutoff | 20 | 0 | 0 | 20 | 100 |
-75% Cutoff | 20 | 250 | 0 | 20 | 100 |
-50% Cutoff | 20 | 500 | 0 | 20 | 100 |
-25% Cutoff | 20 | 750 | 3 | 17 | 85 |
+25% Cutoff | 20 | 1250 | 18 | 2 | 90 |
+50% Cutoff | 20 | 1500 | 20 | 0 | 100 |
+75% Cutoff | 20 | 1750 | 20 | 0 | 100 |
2. Sample Size for the Test Set and Data Provenance
All test sets (precision, cut-off, interference, specificity, method comparison, and lay-user studies) appear to use data that is retrospective in nature, as samples were "prepared by spiking drug in negative samples" or "unaltered clinical samples" were "blind labeled and compared to GC/MS results". The provenance of the data is not explicitly stated as a country of origin but implies laboratory-prepared or collected clinical samples, likely within China where the manufacturer is located, or a contract lab.
Sample Sizes for Test Sets:
- Precision Study:
- For each drug (Amphetamine, Cocaine, Marijuana) and each format (Dip Card, Cup, Cassette):
- 9 concentration levels (-100% to +100% of cut-off).
- Each concentration tested 50 times (2 runs per day for 25 days) for each of 3 lots.
- Total observations per drug/format: 9 concentrations * 50 tests/concentration * 3 lots = 1350 observations.
- For each drug (Amphetamine, Cocaine, Marijuana) and each format (Dip Card, Cup, Cassette):
- Cut-off Verification Study:
- For each drug (Amphetamine, Cocaine, Marijuana) and each format (Dip Card, Cup, Cassette):
- 5 concentration levels (-50%, -25%, cut-off, +25%, +50% of cut-off).
- Total samples: 150 samples (equally distributed across 5 concentrations, so 30 samples per concentration) tested using 3 different lots by 3 different operators.
- For each drug (Amphetamine, Cocaine, Marijuana) and each format (Dip Card, Cup, Cassette):
- Interference/Specificity Studies:
- Urine samples (drug-free and spiked at +25% cut-off) tested for each interfering substance/cross-reactant compound. Number of tests per substance (e.g., 3 batches of each device for all formats) is not explicitly listed per substance but implied to be sufficient.
- Method Comparison Studies:
- For each drug (Amphetamine, Cocaine, Marijuana) and each format (Dip Card, Cup, Cassette):
- 80 unaltered clinical samples (40 negative, 40 positive).
- Total samples per drug/format tested by 3 viewers: 80 samples * 3 viewers = 240 observations.
- For each drug (Amphetamine, Cocaine, Marijuana) and each format (Dip Card, Cup, Cassette):
- Lay-user Study:
- For Amphetamine devices: 420 lay persons.
- For Cocaine devices: 420 lay persons.
- For Marijuana devices: 420 lay persons.
- Each person tested one blind labeled sample and a device.
- Sample concentrations used: 7 levels (-100% to +75% of cut-off), 20 samples per level. Total samples per drug: 7 concentrations * 20 samples/concentration = 140 samples.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications
- For Analytical Performance (Precision, Cut-off, Interference, Specificity): The ground truth for spiked samples (negative samples spiked with known concentrations of drug) was established by GC/MS (Gas Chromatography/Mass Spectrometry), which is the "preferred confirmatory method" and considered the gold standard for drug detection and quantification in toxicology. No "experts" in the sense of clinicians or radiologists were used. The document doesn't specify the qualifications of the personnel performing GC/MS.
- For Method Comparison Studies: The ground truth for the 80 unaltered clinical samples was established by GC/MS. These GC/MS results are the reference against which the device's performance was compared.
- For Lay-user Study: The ground truth for the prepared urine samples was confirmed by GC/MS.
4. Adjudication Method for the Test Set
- For Precision Studies: The testing was "performed two runs per day for 25 days" (total 50 tests per concentration per lot). The results are presented as counts of positive/negative. There is no mention of an adjudication method among multiple readers for these analytical studies.
- For Cut-off Verification Study: Testing was performed by "three different operators." There is no explicit adjudication method stated for these observations. The results are presented as all positive or all negative for certain concentration ranges, which implies agreement or a predefined interpretation across operators.
- For Method Comparison Studies: "Three different laboratory assistants" were the "operators" or "viewers" (referred to as Viewer A, B, C) who read the device results. The document lists discordant results individually for each viewer, indicating that results were compared viewer-by-viewer against GC/MS. There is no explicit multi-reader adjudication method (e.g., majority vote like 2+1 or 3+1) mentioned for reaching a consensus device result; rather, individual reader agreement with GC/MS is analyzed.
- For Lay-user Study: Lay persons independently read the results. The comparison is between the lay person's reading and the GC/MS ground truth. No adjudication among lay persons is described.
5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study
No MRMC comparative effectiveness study was mentioned. The study performed a method comparison where individual "viewers" (laboratory assistants) read the devices and their results were compared to GC/MS. There is no comparison of human readers' performance with AI assistance versus without AI assistance, as these are rapid qualitative test devices, not AI-powered diagnostic algorithms.
6. Standalone (Algorithm Only) Performance
The SAFECARE Urine Test devices are immunochromatographic assays, not software algorithms or AI-driven systems. Their performance is inherently standalone (device-only, interpreted by a human user). The reported precision, cut-off, interference, specificity, and method comparison data represent the standalone performance of these physical tests.
7. Type of Ground Truth Used
- GC/MS (Gas Chromatography/Mass Spectrometry): This is consistently stated as the ground truth method for confirming drug concentrations in all performance studies (precision, cut-off, interference, specificity, method comparison, and lay-user studies). GC/MS is a highly accurate analytical method considered the gold standard for drug testing.
8. Sample Size for the Training Set
These devices are immunochromatographic assays, not machine learning or AI models, therefore they do not have a "training set" in the computational sense. Their development typically involves chemical and biological optimization, with analytical and clinical validation serving as the equivalent of performance evaluation.
9. How the Ground Truth for the Training Set Was Established
As noted above, these devices do not involve a training set as they are not AI/ML-based. The development of such diagnostic tests relies on established immunochemistry principles and rigorous analytical validation to ensure sensitivity, specificity, and accuracy against a gold standard like GC/MS.
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(101 days)
Single use device that is indicated for use as an accessory with sterile 1 mL-long staked needle prefilled ISO Standard glass syringes to aid in the protection of healthcare professionals, patients who self-inject doctor prescribed medications, and individuals that assist self-injecting patients, from accidental needle sticks. The devices can be used on a wide range of patients including children and adults.
This submission is provided for modifications to the predicate device, which includes design changes and a plunger rod raw material change. For details, please refer to Attachment 1 for Design Modifications Rationale. The Safe'n'Sound® Staked Passive Delivery System – Cone Version is a single use anti-needle stick accessory for use with sterile 1 mL-long staked needle prefilled ISO Standard glass syringes. It fits with 1 mL-long staked syringes with a maximum needle length of 1/2" and consists of a subassembly (body, cone, sleeve, and spring) and a loose plunger rod.
The provided document is a 510(k) summary for the Safe'n'Sound® Staked Passive Delivery System - Cone Version. It describes the device, its intended use, and its substantial equivalence to a predicate device. However, it does not contain specific acceptance criteria, reported device performance metrics in a quantitative manner, detailed study protocols, sample sizes for training or test sets, information on ground truth establishment, or expert involvement in adjudication for a medical image analysis or diagnostic AI device.
The document outlines performance testing in general terms: "Bench testing has been performed on the Safe'n'Sound® Staked Passive Delivery System - Cone version. It confirmed the product functions as intended and is substantially equivalent to the predicate device. Biocompatibility testing performed demonstrates that the product meets ISO 10993-5 and ISO 10993-10 requirements." It also mentions "Simulated clinical use testing has been performed. It confirmed that the Safe'n'Sound® Staked Passive Delivery System - Cone version could be used safely and effectively to shield needles inside the protection device after use."
Since this is a submission for a piston syringe accessory and not an AI/ML medical device for diagnosis or image analysis, many of the requested categories (like MRMC studies, standalone algorithm performance, number of experts for ground truth, sample sizes for training/test sets, or specific acceptance criteria for diagnostic performance) are not applicable or are not detailed in the provided text.
Based on the nature of the device (a mechanical accessory for syringes), the "acceptance criteria" would primarily revolve around functional performance, safety, and biocompatibility, rather than diagnostic accuracy metrics like sensitivity or specificity.
Therefore, I cannot populate most of the requested table and information as it pertains to AI/ML device studies. I will address what can be inferred from the document.
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Criteria (Inferred from document) | Reported Device Performance (Inferred from document) |
---|---|---|
Functional Performance | Device functions as intended (e.g., aids in protection from accidental needle sticks, effectively shields needles after use). | "Confirmed the product functions as intended and is substantially equivalent to the predicate device." "Confirmed that the Safe'n'Sound® Staked Passive Delivery System - Cone version could be used safely and effectively to shield needles inside the protection device after use." |
Biocompatibility | Meets ISO 10993-5 (In Vitro Cytotoxicity) and ISO 10993-10 (Irritation and Skin Sensitization) requirements. | "Biocompatibility testing performed demonstrates that the product meets ISO 10993-5 and ISO 10993-10 requirements." |
Safety | Prevents accidental needle sticks from prefilled 1 mL-long staked needle ISO Standard glass syringes for healthcare professionals, self-injecting patients, and individuals assisting them. Performs safely during simulated clinical use. | "Aids in the protection of healthcare professionals, patients who self-inject doctor prescribed medications, and individuals that assist self-injecting patients, from accidental needle sticks." "Confirmed that the Safe'n'Sound® Staked Passive Delivery System - Cone version could be used safely and effectively..." |
Rigidity | Plunger rod is sufficiently stiff to improve rigidity (implied comparative acceptance vs. predicate or previous material). | New polypropylene resin for the plunger rod is "slightly stiffer to improve rigidity." The changes (including material change) "have proven to be insignificant based upon design and process validations, bench testing, biocompatibility testing and simulated clinical use studies performed," implying the new rigidity meets functional requirements. |
Insertion Force | Reduced insertion force for prefilled syringes (implied comparative acceptance vs. predicate due to sleeve design changes). | "Sleeve design changes, including syringe clips (2 of 6) are reduced in size so that insertion force of the prefilled syringe is reduced." The changes "have proven to be insignificant based upon design and process validations, bench testing, biocompatibility testing and simulated clinical use studies performed," implying the reduced force is acceptable and functional. |
Material/Design Changes | Changes to design (body, cone, sleeve clips) and plunger rod material (new polypropylene resin) do not negatively impact safety or effectiveness and maintain substantial equivalence to the predicate device. | "These design changes have proven to be insignificant based upon design and process validations, bench testing, biocompatibility testing and simulated clinical use studies performed." "The Safe'n'Sound® Staked Passive Delivery System - Cone version raises no new issues of safety or effectiveness." |
Due to the nature of the device and the provided document, the following sections cannot be answered with specific details as they pertain primarily to diagnostic AI/ML studies and are not documented here for this mechanical device.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- The document mentions "Bench testing" and "Simulated clinical use testing" but does not specify sample sizes for these tests or data provenance.
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)
- This is not applicable as the device is a mechanical accessory, not a diagnostic tool requiring expert interpretation for "ground truth".
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- This is not applicable for a mechanical device.
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 is not applicable as the device is a syringe accessory, not an AI diagnostic tool that assists human readers.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- This is not applicable as the device is a mechanical accessory, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- For a mechanical device like this, "ground truth" would be established via engineering specifications, functional requirements, and safety standards (e.g., successful needle shielding, no accidental sticks, material integrity). The document does not detail the specific methodology for establishing this "ground truth" beyond stating successful testing.
8. The sample size for the training set
- This is not applicable as there is no "training set" for a mechanical device in this context.
9. How the ground truth for the training set was established
- This is not applicable as there is no "training set" for a mechanical device.
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