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510(k) Data Aggregation

    K Number
    K121065
    Date Cleared
    2013-05-24

    (413 days)

    Product Code
    Regulation Number
    862.3100
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    Polymed Therapeutics Fastep Dipstick Drugs of Abuse Screen Device and Polymed Therapeutics Fastep Dipcard Drugs of Abuse Screen Device are rapid chromatographic immunoassays for the qualitative and simultaneous detection of one to seven of the following drugs in a variety of combinations in human urine. The cutoff concentrations and direct calibrator for these drugs are as follows:

    AnalyteAbbreviationDirect CalibratorCutoff (ng/mL)
    AmphetamineAMPAmphetamine1000
    BenzodiazepinesBZOOxazepam300
    CocaineCOCBenzoylecgonine300
    MarijuanaTHC11-nor-Δ9-THC9-COOH50
    MorphineMORMorphine2000
    PhencyclidinePCPPhencyclidine25
    EcstasyMDMA3,4-Methylenediioxy-MET500

    For prescription use in central laboratories only. This assay provides only a preliminary analytical test result. A more specific alternative chemical method must be used in order to obtain a confirmed analytical result. Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS) are the preferred confirmatory method.

    Clinical consideration and professional judgment should be applied to any drug of abuse test result, particularly when preliminary positive results are indicated.

    Device Description

    One-step, colloidal gold based chromatographic immunoassay for the rapid, qualitative detection of Marijuana, Cocaine, Phencyclidine, Morphine, Amphetamine, Benzodiazepines, and MDMA (Ecstasy) in human urine.

    AI/ML Overview

    The provided document describes the Polymed Therapeutics' Fastep™ Dipstick and Dipcard Drugs of Abuse Screen Devices. Here's an analysis of the acceptance criteria and study proving its performance:

    1. Table of Acceptance Criteria and Reported Device Performance

    The device is evaluated against its ability to detect specific drugs of abuse in human urine at defined cutoff concentrations. The performance is assessed by comparing its results to confirmed analytical methods (GC/MS and/or LC/MS) and a predicate device. While explicit "acceptance criteria" are not numerically stated in the provided text (e.g., "sensitivity must be >95%"), the reported performance indicates that it demonstrated "substantial equivalence" to the established confirmatory methods and predicate devices for all specified drugs. This "substantial equivalence" effectively serves as the acceptance criterion in the context of a 510(k) submission.

    AnalyteAbbreviationCutoff (ng/ml)Reported Device Performance (vs. GC/MS, LC/MS and Predicate)
    AmphetamineAMP1000Substantial equivalence demonstrated
    BenzodiazepinesBZO300Substantial equivalence demonstrated
    CocaineCOC300Substantial equivalence demonstrated
    MarijuanaTHC50Substantial equivalence demonstrated
    MorphineMOR2000Substantial equivalence demonstrated
    PhencyclidinePCP25Substantial equivalence demonstrated
    EcstasyMDMA500Substantial equivalence demonstrated

    2. Sample Size Used for the Test Set and Data Provenance

    The document mentions "blind-labeled clinical specimen correlation study" and "blind-labeled spiked control studies." However, specific sample sizes for these test sets are not provided in the given text.

    The data provenance is not explicitly stated. The term "clinical specimen" suggests human-derived samples, but their geographic origin (country) and whether they are retrospective or prospective are not mentioned.

    3. Number of Experts Used to Establish the Ground Truth for the Test Set and Their Qualifications

    The ground truth for the test set was established by Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS). These are analytical laboratory methods, not human expert evaluations for establishing ground truth in this context. Therefore, no human experts were used in this specific manner for ground truth establishment.

    4. Adjudication Method for the Test Set

    Since the ground truth was established by instrumental analytical methods (GC/MS/LC/MS), there was no adjudication method involving human experts for the test set. The analytical results from GC/MS/LC/MS are considered definitive.

    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

    There is no mention of an MRMC comparative effectiveness study in the document. This device is a rapid chromatographic immunoassay, not an AI-powered diagnostic imaging or interpretation tool that would typically involve human readers.

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

    This device is an immunoassay that provides a qualitative result. It is inherently a "standalone" device in that its performance is judged on its own ability to detect the drugs without human-in-the-loop interpretation beyond reading the visual result (which is a standard part of such tests). The studies described ("clinical specimen correlation study" and "spiked control studies") evaluate the performance of the device itself.

    7. The Type of Ground Truth Used

    The type of ground truth used was confirmed analytical results from Gas Chromatography / Mass Spectrometry (GC/MS) or Liquid Chromatography / Mass Spectrometry (LC/MS). These are objective, gold- standard laboratory methods for drug detection and quantification.

    8. The Sample Size for the Training Set

    The document does not explicitly mention a separate "training set" or its sample size. Immunoassays like this are typically developed and validated using a series of experiments (which could be considered part of a broader development/training phase), but the specific terminology of "training set" as used in machine learning is not applicable here. The presented studies seem to focus on the validation/test phase of the device.

    9. How the Ground Truth for the Training Set was Established

    As no explicit "training set" is mentioned in the machine learning sense, the method for establishing its ground truth is also not described. If we consider the broader development process, the ground truth for establishing the performance characteristics of the assay (e.g., setting cutoffs, ensuring specificity) would also rely on confirmed analytical methods like GC/MS and LC/MS.

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