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510(k) Data Aggregation
(89 days)
ZOE FLUID STATUS MONITOR
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.
The ZOE Fluid Status Monitor Model ZOE3 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 Model ZOE3 works by applying a low amplitude high frequency electrical current to the body and measuring the electrical impedance also known as Zo, decreases when fluid increases and increases when fluid decreases. The ZOE Fluid Status Monitor Model ZOE3 is designed for use with disposable, self-adhesive silver i silver chloride electrodes that are readliy 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!
This 510(k) premarket notification for the ZOE Fluid Status Monitor Model ZOE3 does not contain the detailed performance study information requested.
The document states: "The ZOE Fluid Status Monitor Model ZOE3 has the same method of operation and is functionally equivalent to the predicate devices K112830 (November 13, 2012) & K131509 (June 28, 2013). The ZOE Fluid Status Monitor has the identical indications for use as the ZOE Fluid Status Monitor K112830 (November 13, 2012) & K131509 (June 28, 2013)." and "The ZOE3 Fluid Status Monitor does not raise any new issues of safety, effectiveness or performance of the device when compared to the existing predicate devices ZOE Fluid Status Monitor K112830 (November 13, 2012) & K131509 (June 28, 2013)."
This indicates that the device's acceptance is based on its substantial equivalence to previously cleared predicate devices, rather than new performance studies detailed in this specific submission. The submission focuses on general quality and safety testing relevant to device manufacturing and electrical standards, not clinical performance metrics.
Therefore, many of the requested details about a specific performance study are not available in this document.
Here's a breakdown of what can be extracted and what information is missing:
1. Table of acceptance criteria and the reported device performance:
- Acceptance Criteria: Not explicitly stated as quantifiable performance metrics for this specific submission, beyond meeting the general safety and functional equivalence of the predicate devices.
- Reported Device Performance: No specific performance metrics (e.g., accuracy, sensitivity, specificity) for fluid status monitoring are reported in this document for the ZOE3. The document only confirms functional equivalence to predicate devices.
2. Sample size used for the test set and the data provenance:
- Sample Size: Not specified.
- Data Provenance: Not specified, as no new clinical performance study is detailed here.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Number of Experts: Not applicable, as no new clinical performance study is detailed here.
- Qualifications of Experts: Not applicable.
4. Adjudication method (e.g., 2+1, 3+1, none) for the test set:
- Not applicable, as no new clinical performance study is detailed here.
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 an impedance monitor for fluid status, not an AI-assisted diagnostic imaging device with human readers.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- A standalone performance in the context of clinical metrics is not detailed. The device itself is "standalone" in its measurement, but the document does not present a standalone clinical performance study to establish new efficacy.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable, as no new clinical performance study is detailed here.
8. The sample size for the training set:
- Not applicable, as the document doesn't describe an AI/ML algorithm or a training set for clinical performance.
9. How the ground truth for the training set was established:
- Not applicable.
Summary of available information:
This 510(k) submission for the ZOE Fluid Status Monitor Model ZOE3 relies on substantial equivalence to predicate devices (K112830 and K131509) for its acceptance. It emphasizes that the new model has the "same method of operation" and is "functionally equivalent" with "identical indications for use." The only specific "testing" mentioned relates to quality assurance measures (Risk Analysis, Requirements Review, Design reviews, Code Inspections, Verification and Validation, H/W and S/W Implementation Verification Testing) and electrical safety and EMI safety standards (CAN/CSA C22.2 No. 60601-1:08, IEC 60601-1, IEC 60601-1-2). No new clinical performance studies are presented in this document.
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(35 days)
ZOE FLUID STATUS MONITOR
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.
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!
This document is a 510(k) premarket notification for the ZOE Fluid Status Monitor (Model ZOE 2b-5k). It addresses the safety and effectiveness of the device by establishing its substantial equivalence to a predicate device.
Acceptance Criteria and Device Performance:
The document does not detail specific quantitative acceptance criteria or a dedicated study showing the device meets such criteria in terms of accuracy, sensitivity, or specificity for diagnosing fluid status. Instead, the primary "acceptance criterion" for this 510(k) submission is substantial equivalence to a previously cleared predicate device.
The reported "device performance" is based on the claim of functional equivalence and identical indications for use as the predicate device.
Acceptance Criteria Category | Specific Criteria | Reported Device Performance |
---|---|---|
Functional Equivalence | Method of operation is the same as the predicate device. | The ZOE Fluid Status Monitor has the same method of operation as the predicate device (K112830). |
Indications for Use | Indications for use are identical to the predicate device. | The ZOE Fluid Status Monitor has identical indications for use as the predicate device (K112830). |
Safety and Effectiveness Issues | Does not raise any new issues of safety, effectiveness, or performance. | The ZOE Fluid Status Monitor does not raise any new issues of safety, effectiveness, or performance compared to the predicate device. |
Electrical Safety | Compliance with UL 2601-1 / CSA C22.2 No. 60601. | The ZOE Fluid Status Monitor complies with UL 2601-1 / CSA C22.2 No. 60601. |
EMC/EMI Compliance | Compliance with EN 60601-1-2 and EN 60601-1:2003. | The ZOE met all electrical and electromagnetic compatibility (EMI) safety requirements, including EN 60601-1:2003 and EN 60601-1-2. |
Quality Management System | Manufactured under a certified Quality Management System. | Noninvasive Medical Technology is certified to ISO13485 2003. |
Study Details:
The document describes a 510(k) premarket notification process, not a clinical study in the traditional sense that generates new performance data to prove efficacy. The "study" here is the comparative analysis against the predicate device to demonstrate substantial equivalence.
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Sample size used for the test set and the data provenance: Not applicable. This document does not describe a clinical test set with human subjects for performance evaluation. The "test set" for this 510(k) is the comparison of device characteristics (design, materials, operating principles, indications for use, safety standards) to the predicate device.
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth in a clinical sense (e.g., diagnosis of a condition) is not established in this document. The "ground truth" for the substantial equivalence claim is the pre-existing FDA clearance of the predicate device (K112830).
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Adjudication method for the test set: Not applicable. There was no clinical test set requiring adjudication.
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If a multi-reader multi-case (MRMC) comparative effectiveness study was done: No. An MRMC study was not described or performed for this 510(k) submission. The document focuses on device characteristics and regulatory compliance, not on human reader performance with or without AI assistance.
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If a standalone (i.e., algorithm only without human-in-the-loop performance) was done: The ZOE Fluid Status Monitor is a hardware device (impedance plethysmograph) that measures electrical impedance. It does not appear to involve an AI algorithm that would have standalone performance in the way a diagnostic imaging algorithm might. Its "performance" revolves around accurate impedance measurement, which is addressed by electrical safety and EMC testing, not standalone algorithmic evaluations.
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The type of ground truth used: For the purposes of this 510(k) submission, the "ground truth" is the established safety and effectiveness of the predicate device (ZOE Fluid Status Monitor K112830), as previously cleared by the FDA. The current device is deemed "substantially equivalent" based on direct comparison of its attributes to those of the predicate. Compliance with electrical safety and EMC standards (UL 2601-1 / CSA C22.2 No. 60601, EN 60601-1, EN 60601-1-2) serves as "ground truth" for those specific engineering performance aspects.
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The sample size for the training set: Not applicable. This is not an AI/machine learning device that requires a training set in the conventional sense.
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How the ground truth for the training set was established: Not applicable, as there is no training set mentioned for this device.
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(40 days)
ZOE FLUID STATUS MONITOR
The ZOE™ Fluid Status Monitor is indicated for patients:
- With fluid management problems o
- Taking diuretic medication o
- Living with Heart Failure o
- Living with End-stage Renal Disease o
- Recovering from Coronary Artery Disease related event o
- Suffering from Recurrent Dehydration o
The ZOE™ Fluid Status Monitor is contraindicated for use with patients:
- With allergies to electrode hydrogel O
- Skin sensitivities to electrode hydrogel o
- Skin breakdown in areas on the chest where ZOE electrode placement is o required.
This device is intended for use by qualified health care practitioners, 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.
The ZOE™ Fluid Status Monitor is a non-invasive, battery powered thoracic base impedance monitor designed as an 'early warning' monitor for determining changes in the fluid status of patients with fluid management problems.
The ZOE works by applying a minimal current to the patient. measuring electrical impedance changes throughout the thorax as aortic blood flow increases and decreases in response to each heartbeat. Base Impedance also known as Zo, decreases when fluid increases and rises when less fluid exists in the chest. This device incorporates a proprietary algorithm to calculate the Zo value.
The ZOE is designed for use with disposable, self-adhesive silver / silver chloride electrodes that are readily available / commercially approved within the United States for other approved cardiovascular monitoring systems.
This 510(k) submission for the ZOE™ Fluid Status Monitor does not provide specific acceptance criteria in terms of quantitative performance metrics (e.g., accuracy, sensitivity, specificity, or agreement rates) that were evaluated in a study to "prove the device meets the acceptance criteria."
Instead, the submission focuses on demonstrating substantial equivalence to a predicate device (the Renaissance Technology, Inc. IQ System™) based on:
- Similar patient interface design.
- Same intended uses and operating principles (effectiveness) for the Zo measurement function.
- Same or similar operational features.
- Same or similar safety features.
The document explicitly states: "The ZOE does not raise any new issues of safety, effectiveness or performance of the device when compared to the existing predicate device."
Therefore, it implicitly relies on the established safety and effectiveness of the predicate device. The information provided heavily emphasizes compliance with electrical and safety standards rather than clinical performance metrics for the ZOE device itself.
Given this, I cannot fill out all requested sections as the information is not present in the provided text.
Here's a breakdown of what can be extracted and what is missing:
Acceptance Criteria and Device Performance (Based on Provided Document)
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Table of Acceptance Criteria and Reported Device Performance:
Acceptance Criteria Reported Device Performance Substantial Equivalence to Predicate Device (Renaissance IQ System™) for Zo measurement function: a. Patient interface design similarities. Verified to be "very similar." b. Identical intended uses and operating principles (effectiveness) for Zo measurement. Verified as "the SAME." c. Same or similar operational features. Verified as "the SAME or SIMILAR." d. Same or similar safety features. Verified as "the SAME or very SIMILAR." Compliance with Electrical and Safety Standards: a. UL 2601-1 / CSA C22.2 No. 60601 Device complies and "has passed an inspection to these standards by an independent testing house." b. EN 60601-1:2003 (LVD Low Voltage Directive) Device "met all electrical and electromagnetic compatibility (EMI) safety requirements." c. EN 60601-1-2 (EMC testing for Emissions/Immunity) Device "met all electrical and electromagnetic compatibility (EMI) safety requirements." Does not raise new issues of safety, effectiveness, or performance compared to predicate. Confirmed: "The ZOE does not raise any new issues of safety, effectiveness or performance of the device when compared to the existing predicate device." Reasonable assurance of safety and effectiveness for intended use. Confirmed: "With the information provided, the safety and effectiveness of the product can be reasonably assured."
Missing Information (Not provided in the document for the ZOE™ Fluid Status Monitor):
The document explicitly states: "Clinical performance data has been submitted." However, the summary does not elaborate on the specific acceptance criteria for this clinical data, nor does it present the results of such a study. The primary argument for substantial equivalence is based on the Zo measurement function being the same as the predicate and compliance with electrical safety standards, implying that extensive stand-alone clinical performance studies with specific metrics for the ZOE device were not the main basis of this 510(k) summary.
Therefore, the following points cannot be answered from the provided text:
- Sample size used for the test set and the data provenance: Not specified.
- Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable as no specific performance study with a test set and ground truth is detailed.
- Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
- 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 monitor, not an AI-assisted diagnostic tool for human readers.
- If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: The document implies that the "operating principles" and "Zo measurement function" are the same as the predicate, which involved a proprietary algorithm. However, specific performance metrics for this algorithm in a standalone clinical evaluation are not presented.
- The type of ground truth used (expert consensus, pathology, outcomes data, etc.): Not specified for any clinical performance data.
- The sample size for the training set: Not applicable; the document does not describe a training set in the context of device development or machine learning.
- How the ground truth for the training set was established: Not applicable.
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