K Number
K131509
Device Name
ZOE FLUID STATUS MONITOR
Date Cleared
2013-06-28

(35 days)

Product Code
Regulation Number
870.2770
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The ZOE Fluid Status Monitor is intended for patients: With fluid management problems - Taking diuretic medication - . Living with Heart Failure - Living with End-stage Renal Disease - Recovering from Coronary Artery Disease related event . - Suffering from Recurrent Dehydration . This device is intended for use under the direction of a physician, for the non-invasive monitoring and management of patients with fluid management problems in a variety of medically accepted clinical applications.
Device Description
The ZOE Fluid Status Monitor is a non-invasive; battery powered impedance monitor designed as an 'early warning' monitor for determining changes in the fluid status of patients with fluid management problems. The ZOE Fluid Status Monitor works by applying a low amplitude high frequency electrical current to the body and measuring the electrical impedance. Base Impedance also known as Zo, decreases when fluid increases and increases when fluid decreases. The ZOE Fluid Status Monitor is designed for use with disposable, self-adhesive silver / silver chloride electrodes that are readily available from Noninvasive Medical Technologies, Inc. NMT approved electrodes must be used with the ZOE Fluid Status Monitor. Zo readings obtained from unapproved electrodes may not be accurate!
More Information

Not Found

No
The summary describes a device that measures electrical impedance to monitor fluid status and does not mention any AI or ML components or capabilities.

No
The device is a monitor that determines changes in a patient's fluid status rather than providing therapy. It is described as an "early warning monitor" used for non-invasive monitoring and management.

No
The device is described as an "early warning" monitor for determining changes in fluid status, indicating a monitoring function rather than a diagnostic one.

No

The device description explicitly states it is a "battery powered impedance monitor" and works by applying an electrical current and measuring impedance, indicating it is a hardware device. It also mentions the use of disposable electrodes.

Based on the provided text, the ZOE Fluid Status Monitor is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD Definition: In Vitro Diagnostics are tests performed on samples taken from the human body, such as blood, urine, or tissue, to detect diseases, conditions, or infections.
  • ZOE Fluid Status Monitor Function: The description clearly states that the ZOE Fluid Status Monitor is a non-invasive device that works by applying an electrical current to the body and measuring electrical impedance. It does not analyze samples taken from the body.

Therefore, the ZOE Fluid Status Monitor falls under the category of a non-invasive medical device used for monitoring physiological parameters, not an IVD.

N/A

Intended Use / Indications for Use

The ZOE Fluid Status Monitor is intended for patients: With fluid management problems

  • Taking diuretic medication
  • . Living with Heart Failure
  • Living with End-stage Renal Disease
  • Recovering from Coronary Artery Disease related event .
  • Suffering from Recurrent Dehydration .

This device is intended for use under the direction of a physician, for the non-invasive monitoring and management of patients with fluid management problems in a variety of medically accepted clinical applications.

Product codes

DSB

Device Description

The ZOE Fluid Status Monitor is a non-invasive; battery powered impedance monitor designed as an 'early warning' monitor for determining changes in the fluid status of patients with fluid management problems.

The ZOE Fluid Status Monitor works by applying a low amplitude high frequency electrical current to the body and measuring the electrical impedance. Base Impedance also known as Zo, decreases when fluid increases and increases when fluid decreases.

The ZOE Fluid Status Monitor is designed for use with disposable, self-adhesive silver / silver chloride electrodes that are readily available from Noninvasive Medical Technologies, Inc. NMT approved electrodes must be used with the ZOE Fluid Status Monitor. Zo readings obtained from unapproved electrodes may not be accurate!

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

This device is intended for use under the direction of a physician, for the non-invasive monitoring and management of patients with fluid management problems in a variety of medically accepted clinical applications.

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

Not Found

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

Not Found

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

Not Found

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K112830

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 870.2770 Impedance plethysmograph.

(a)
Identification. An impedance plethysmograph is a device used to estimate peripheral blood flow by measuring electrical impedance changes in a region of the body such as the arms and legs.(b)
Classification. Class II (special controls). The device, when it is a body composition analyzer which is not intended to diagnose or treat any medical condition, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 870.9.

0

Image /page/0/Picture/1 description: The image shows the logo for Noninvasive Medical Technologies, Inc. The logo consists of the letters "NMT" inside of a partial circle on the left, and the words "Noninvasive Medical Technologies, Inc." on the right. The text is in a simple, sans-serif font and is black in color. The logo is clean and professional, and it conveys a sense of innovation and technology.

JUN 2 8 2013

This summary of safety and effectiveness is provided as part of this Premarket Notification in compliance with 21 CFR, Part 807, Subpart E, Section 807.92.

Noninvasive Medical Technologies, Inc.

APPLICANT

6412 S. Arville St.
Las Vegas, NV 922614
Tel: (888) 906-0413
Fax: (702) 614-4170
OFFICIAL CORRESPONDENTDr. Marc O'Griofa.MD (MB BCH BAO)
Chief Technology/Medical Officer
Tel: (888) 906-0413
Fax: (702) 614-4170
mogriofa@nmtinc.org
DATE PREPAIREDOctober 19,2012
TRADE NAMEZOE Fluid Status Monitor
MODELZOE 2b-5k
COMMON OR CLASSIFICATION NAMEImpedance Plethysmograph
DEVICE CLASSIFICATIONClass II per 21CFR §870.2770
PRODUCT CODEDSB
PREDICATE DEVICE NAMESZOE Fluid Status Monitor

The ZOE Fluid Status Monitor is substantially equivalent to the following currently marketed Predicate Device.

ManufacturerDevice Name510-K NumberDecision Date
Noninvasive Medical
Technologies, Inc.ZOE Fluid Status MonitorK11283011/13/2012

Device Description:

The ZOE Fluid Status Monitor is a non-invasive; battery powered impedance monitor designed as an 'early warning' monitor for determining changes in the fluid status of patients with fluid management problems.

The ZOE Fluid Status Monitor works by applying a low amplitude high frequency electrical current to the body and measuring the electrical impedance. Base Impedance also known as Zo, decreases when fluid increases and increases when fluid decreases.

The ZOE Fluid Status Monitor is designed for use with disposable, self-adhesive silver / silver chloride electrodes that are readily available from Noninvasive Medical Technologies, Inc. NMT approved electrodes must be used with the ZOE Fluid Status Monitor. Zo readings obtained from unapproved electrodes may not be accurate!

Labeling:

Federal (United States) Law restricts this device to sale by or on the order of a physician or licensed healthcare professional.

Indications for Use:

The ZOE Fluid Status Monitor is intended for patients: With fluid management problems

  • Taking diuretic medication き
  • . Living with Heart Failure

1

  • � Living with End-stage Renal Disease
  • Recovering from Coronary Artery Disease related event .
  • Suffering from Recurrent Dehydration .

This device is intended for use under the direction of a physician, for the non-invasive monitoring and management of patients with fluid management problems in a variety of medically accepted clinical applications.

Predicate Device Discussion:

The ZOE Fluid Status Monitor has the same method of operation and is functionally equivalent to the predicate device K112830 (November 13, 2012). The ZOE Fluid Status Monitor has the identical indications for use as the predicate devices the ZOE Fluid Status Monitor K112830 (November 13, 2012)

Performance Characteristics:

There is no performance standards published for Product Code DSB Impedance Plethysmograph (870.2770)

Quality and Safety Testing:

Noninvasive Medical Technology is presently certified to ISO13485 2003 as of 9/27/09 by IQ Net and NEMKO AS (Registration Number 908132) All products are designed and manufactured under Quality Management, System. The following quality assurance measures were applied to the Zoe Fluid Status Monitor:

  • Risk Analysis .
  • Requirements Review .
  • Design reviews ●
  • . Code Inspections
  • Verification and Validation .
  • ◆ H/W and S/W Implementation Verification Testing

The ZOE Fluid Status Monitor underwent testing to assess the overall electrical safety by an independent testing house. The ZOE Fluid Status Monitor complies with the electrical standards of the Underwriters Laboratories UL 2601-1 / CSA C22.2 No. 60601 The ZOE met all electrical and electromagnetic compatibility (EMI) safety requirements, set forth in the European national Safety Requirements LVD Low voltage Directive testing to Safety of Medical Devices EN 60601-1:2003, EMC testing to Emissions / Immunity Requirements for EMC/EMI requirements for Medical Devices EN 60601-1-2 which reasonably assures the device is safe when used as directed for its prescribed intended use.

Conclusion:

The ZOE Fluid Status Monitor has the same method of operation and is functionally equivalent to the predicate device. ). The ZOE Fluid Status Monitor has the identical indications for use as the predicate devices the ZQE Fluid Status Monitor K112830 (November 13, 2012)The ZOE Fluid Status Monitor does not raise any new issues of safety, effectiveness or performance of the device when compared to the existing predicate device ZOE Fluid Status Monitor K112830 (November 13, 2012)

2

Image /page/2/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo is a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the top half of the circle. Inside the circle is a stylized image of an eagle with its wings spread, with three horizontal lines above the eagle's head.

DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

June 28, 2013

Noninvasive Medical Technologies, Inc. c/o Marc O Griofa, M.D., Ph.D., F.A.W.M. Chief Medical/Technology Officer 6412 S. Arville Street Las Vegas, NV 89118

Re: K131509

Trade/Device Name: ZOE Fluid Status Monitor (Model ZOE 2b-5K) Regulation Number: 21 CFR 870.2770 Regulation Name: Impedance Plethysmograph Regulatory Class: Class II (two) Product Code: DSB Dated: May 30, 2013 Received: May 31, 2013

Dear Dr. O Griofa:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice; labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

3

Page 2 - Dr. Marc O Griofa

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

Sincerely yours,

Owen P. Earis -S

for

Bram D. Zuckerman, M.D. Director Division of Cardiovascular Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

4

K131509

pg I of I

Special 510(k) Premarket Notification - ZOE Fluid Status Monitor Model ZOE2b-Sk

Indications for Use Statement

510(k) Number

Previously Cleared as: K112830 (11/13/2012)

Device Name: ZOE Fluid Status Monitor Model Number: ZOE 2b-5K

Indications for Use:

The ZOE Fluid Status Monitor is intended for patients:

  • With fluid management problems .
  • Taking diuretic medication �
  • Living with Heart Failure ●
  • Living with End-stage Renal Disease .
  • Recovering from Coronary Artery Disease related event .
  • Suffering from Recurrent Dehydration .

This device is intended for use under the direction of a physician, for the non-invasive monitoring and management of patients with fluid management problems in a variety of medically accepted clinical applications.

Prescription Use (Part 21 CFR 801 Subpart D) AND/OR

Over-The-Counter Use (21 CFR 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED) .

Concurrence of CDRH, Office of Device Evaluation (ODE)

Owen P. Faris -S
2013.06.28 14:18:47
-04'00'

Noninvasive Medical Technologies, Inc.