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510(k) Data Aggregation

    K Number
    K191924
    Date Cleared
    2019-08-16

    (29 days)

    Product Code
    Regulation Number
    862.3870
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Device Name :

    SAFECARE**®** THC Urine Strip Test

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

    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.

    Device Description

    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.

    AI/ML Overview

    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 CategorySpecific Metric (Inferred)Acceptance Threshold (Inferred/Observed)Reported Device PerformanceComments on Performance
    Analytical Performance
    PrecisionAgreement at variousHigh agreement expected, especially
    concentrationsat concentrations further from cutoff.
    -100% Cut-off100% Negative (0% Positive)Lot 1, 2, 3: 50-/0+Meets expectation
    -75% Cut-off100% Negative (0% Positive)Lot 1, 2, 3: 50-/0+Meets expectation
    -50% Cut-off100% Negative (0% Positive)Lot 1, 2, 3: 50-/0+Meets expectation
    -25% Cut-off100% Negative (0% Positive)Lot 1, 2, 3: 50-/0+Meets expectation
    Cut-off (50 ng/mL)~50% Positive, ~50% NegativeLot 1, 2: 25-/25+; Lot 3:Meets expectation
    26-/24+
    +25% Cut-off100% Positive (0% Negative)Lot 1, 2, 3: 50+/0-Meets expectation
    +50% Cut-off100% Positive (0% Negative)Lot 1, 2, 3: 50+/0-Meets expectation
    +75% Cut-off100% Positive (0% Negative)Lot 1, 2, 3: 50+/0-Meets expectation
    +100% Cut-off100% Positive (0% Negative)Lot 1, 2, 3: 50+/0-Meets expectation
    InterferenceNo interference fromNo false positives or negatives due toCompounds at 100µg/mLNo interference reported
    common substancesspecified interfering substances when(list provided) showed no
    drug is absent or present above cutoffinterference.
    SpecificityCross-reactivity withLow or no cross-reactivity withProvided specific cross-Demonstrated specificity
    related compoundsnon-target compounds.reactivity percentages for
    related cannabinoids.
    Urine Specific GravityCorrect results acrossCorrect classification (negative forSamples from 1.000 to 1.035Device performs reliably
    range of SG-25% cutoff, positive for +25% cutoff).with THC at +/-25% cutoffacross range of urine SG
    showed expected results.
    Urine pHCorrect results acrossCorrect classification (negative forSamples from pH 4 to 9 withDevice performs reliably
    range of pH-25% cutoff, positive for +25% cutoff).THC at +/-25% cutoffacross range of urine pH
    showed expected results.
    Comparison StudiesAgreement with LC/MSHigh agreement between device results
    for clinical samplesand LC/MS, particularly for samples
    not near the cutoff.
    Overall AgreementNot explicitly quantified, but inferredViewer 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 StudyEase of useInstructions are easily understood.All lay users indicatedInstructions are clear
    instructions were easy to
    Accuracy of self-testingHigh percentage of correct results,
    decreasing near the cutoff.
    -100% Cutoff100% agreement100% CorrectExcellent
    -75% Cutoff100% agreement100% CorrectExcellent
    -50% Cutoff100% agreement100% CorrectExcellent
    -25% Cutoff>90% agreement, with expected90% CorrectAcceptable, slight dip
    increase in discordance.near cutoff.
    +25% Cutoff>90% agreement, with expected95% CorrectAcceptable, slight dip
    increase in discordance.near cutoff.
    +50% Cutoff100% agreement100% CorrectExcellent
    +75% Cutoff100% agreement100% CorrectExcellent

    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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