IMPEDIMED - BODY COMPOSITION ANALYZER, MODEL IMP SFB7
Applicant
Impedimed Pty , Ltd.
Product Code
MNW · Cardiovascular
Decision Date
Apr 4, 2006
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 870.2770
Device Class
Class 2
Indications for Use
Imp SFB7 – A bioelectrical impedance analyzer/monitor that is intended to estimate the following body composition parameters: Fat-free Mass (FFM), Fat Mass (FM), Total Body Water (TBW), Intra cellular Fluid (ICF), Extra cellular Fluid (ECF), and Body Mass Index (BMI). The device measures current, voltage and phase angle (Phi), and from these values calculates resistance (R), reactance (Xc), and impedance (Z), which are used to estimate the above body composition parameters. The device/software will also display the Cole-Cole plot, resistance vs. frequency plot, reactance vs. frequency plot, subject height, age and sex. Biolmp Body Composition Analyzer PC Software: A PC software package that is intended to be used only with the ImpediMed Imp SFB7 Analyzer for uploading the MFBIA mode data on to the PC from Imp SFB7 via an Ethernet port for storing, processing and analysing of MFBIA bioimpedance measurements. This displays Cole-Cole plot, body composition parameters: Fatfree Mass (FFM), Fat Mass (FM), Total Body Water (TBW), Intra cellular Fluid (ICF), Extra cellular Fluid (ECF), Body Mass Index (BMI), and subject height, weight, age, sex, time, and date of measurement, Practitioner's name and Device serial number, and bioelectrical parameters resistance (R), reactance (Xc), and impedance (Z) and phase angle (Phi) at different frequencies (Between 4 kHz to 1000 kHz). The software can be used to generate patient body composition report displaying all the parameters stated above. These devices are intended to be used only on healthy patients, who wish to have their body composition estimated in the home or clinical environment.
Device Story
Imp SFB7 is a portable, battery-powered, multiple-frequency bioelectrical impedance analyzer (MFBIA). It uses tetra-polar (4-lead) electrodes to pass a constant 200 uA RMS current through the body across 256 frequencies (4 kHz to 1000 kHz). The device measures voltage, current, and phase angle to calculate impedance, resistance, and reactance. Data is processed using Cole-Cole plots and Hanai modeling to estimate total body water (TBW), extracellular fluid (ECF), intracellular fluid (ICF), fat-free mass (FFM), and fat mass (FM). Used in home or clinical environments by patients or practitioners. Data can be stored on-device or transferred via Ethernet to a PC running BioImp software for analysis, reporting, and visualization of body composition parameters. Provides objective body composition metrics to assist in health monitoring.
Clinical Evidence
No clinical data provided; bench testing only. Device performance validated through technical measurements of impedance, resistance, and reactance using a test cell and mathematical modeling (Cole-Cole/Hanai) to derive body composition parameters.
Technological Characteristics
Rechargeable battery-powered, portable, tetra-polar (4-lead) bioelectrical impedance analyzer. Frequency range: 4 kHz to 1000 kHz. Constant current source: 200 uA RMS. Connectivity: Ethernet for PC data transfer. Calibration via external test cell. Software utilizes Cole-Cole plots and Hanai modeling for fluid estimation.
Indications for Use
Indicated for healthy patients desiring body composition estimation in home or clinical settings.
Regulatory Classification
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.
Special Controls
*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.
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4 2006 APR
# ImpediMed Limited
Building 4B Garden City Office Park PO Box 4612 Eight Mile Plains QLD 4113 Australia
ABN 65 089 705 144
Telephone: +61 (0)7 3423 1777 Facsimile: +61 (0)7 3423 1496
Email: enquires@impedimed.com
## 510 (k) Summary ImpediMed Imp SFB7 Body Composition Analyzer
#### APPLICANT INFORMATION
ImpediMed Limited Company Name and address: 4B/2404, Logan Road Eight Mile Plains Brisbane, QLD - 4113 Mr Neville Bertwistle Contact Name and numbers: VP Operations Phone: (+61) 7 3423 1777 Fax: (+61) 7 3423 1496 E-mail: nbertwistle@impedimed.com Date of summary prepared: January 27, 2006 DEVICE IDENTIFICATION Trade/Proprietary name: Imp SFB7 Body Composition Analyzer Classification name: Impedance Plethysmograph Regulation number/CFR section: 21 CFR 870.2770 DSB Product code:
Classification panel: Cardiovascular Device class: Class II
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# lmpediMed Limited
Building 4B Garden City Office Park PO Box 4612 Eight Mile Plains QLD 4113 Australia
Telephone: +61 (0)7 3423 1777 Facsimile: +61 (0)7 3423 1496
BN 65 089 705 144
#### Email: enquires@impedimed.com
#### PREDICATED DEVICE
| Company: | Xitron Technologies, Inc |
|-----------------------|--------------------------|
| Device name: | Bio-Impedance Analyzer |
| 510 (K) number: | K 904109 |
| Product code: | DSB |
| Classification panel: | Cardiovascular |
| Device class: | Class II |
#### INDICATIONS FOR USE
The indications for use of this device are healthy patients, who wish to have their body composition estimated, in the home and clinical environment.
#### DEVICE DESCRIPTION
The Imp SFB7 is a multiple frequency bioelectrical impedance analyzer. The device accurately measures current, voltage and phase angle, and calculates impedance, resistance and reactance. These measurements and calculations are used to estimate the body composition: fat-free mass (FFM) and fat mass (FM), and fluid distribution: total body water (TBW), intracellular fluid (ICF), and extracellular fluid (ECF).
The device has 2 modes of operation
- 1. MFBIA Mode This is a Multiple Frequency Bioelectrical Impedance mode. Impedance readings are taken by applying all 256 frequencies sequentially in a very short time in the range of 4 kHz to 1000 kHz.
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# ImpediMed Limited
ABN 65 089 705 144
Building 4B Garden City Office Park PO Box 4612 Eight Mile Plains QLD 4113 Australia
Telephone: +61 (0)7 3423 1777 Facsimile: +61 (0)7 3423 149€
- Email: enquires@impedimed.com 2. Selected Frequencies Mode - Any three user selected frequencies between 4 kHz to 1000 kHz and five pre set (5, 10, 50, 100, 500 kHz) frequencies are used to measure impedance of a subject.
In MFBIA and Selected Frequencies mode, selection of single, continuous measurements or measurements at a selected interval of time is available. Over 1000 records can be stored and analyzed on Imp SFB7 or can be downloaded to a PC or laptop loaded with an optional Biolmp Body Composition Analysis software via an Ethernet connection.
## TECHNOLOGICAL CHARECTERISTICS
The ImpediMed Imp SFB7 Body Composition Analyzer is a rechargeable battery powered, accurate, portable, multiple frequency bioelectrical impedance analysis instrument operating in tetra-polar (4 leads - 2 current source and 2 voltage sensing) mode. The device accurately measures current, voltage and phase angle, and calculates impedance, resistance and reactance.
Bioimpedance analyzers calculate complex impedance or opposition to the flow of an electric current by the body. The applied electrical current travels through the extra cellular fluid of the body and through the lean muscle-organs via the intracellular fluid. Impedance is low in lean tissue, extra cellular fluid and intracellular fluid, where electrolytes are primarily contained, but high in fat tissue because fat is primarily an insulator containing very few conducting elements. Therefore impedance can be related to the total water volume of the body because the impedance is a direct measure of both intracellular and extra cellular fluid. In the Imp SFB7 a small constant current, typically 200 uA RMS, with in the frequency range of 4 kHz to 1000 kHz sequentially, is passed between two current electrodes spanning the body. The voltage drop measured between a second pair of voltage-sensing electrodes is used to calculate the
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Image /page/3/Picture/0 description: The image shows the logo for ImpediMed. The logo is a stylized letter "I" with three curved lines extending from the left side of the "I". Above the logo is the text "K052319 PAGE 4 OF 4". The text indicates that this is page 4 of 4 of document K052319.
# ImpediMed Limited
ABN 65 089 705 144
Telephone: +61 (0)7 3423 1777 Building 4B Facsimile: +61 (0)7 3423 1496 Garden City Office Park PQ Box 4612 Eight Mile Plains QLD 4113 Email: enquires@impedimed.com Australia complex impedance value. The calibration of the device may be checked with the aid of the supplied test cell.
### MFBIA Mode:
Imp SFB7 in MFBIA mode works by calculating the complex impedance, applying all 256 frequencies (4 kHz to 1000 kHz) sequentially in a very short time to reduce the time to complete the test and the inconvenience to the subject.
Impedance calculations made over a range of frequencies (4 kHz-1000 kHz) are used to create a Cole-Cole plot. Hanai modeling, which treats body as a concentrated suspension of cells in a conductive medium is used to estimate extracellular fluid (ECF) at low frequency and total body water (TBW) at high frequency. Intra cellular fluid (ICF) is then estimated by the difference between TBW and ECF. Fat free mass (FFM) is estimated from measured TBW assuming the hydration constant of a person as 73.2%. Fat mass (FM) is estimated from the difference between body mass and fat free mass.
## Selected Frequencies Mode:
Imp SFB7 in Selected Frequencies mode has 5 pre set frequencies (5, 10, 50, 100, 500 kHz) and allows user to enter 3 frequencies of their choice in the range of 4 kHz to 1000 kHz to measure impedance of a subject. It measures, displays, and stores the impedance readings for these selected frequencies.
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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
4 2006 APR
Mr. Neville Bertwistle VP Operations ImpediMed Pty Limited Building 4B/2404 Logan Road, Eight Mile Plains Brisbane, Queensland AUSTRALIA 4113
Re: K052319
Trade/Device Name: ImpediMed Imp SFB7 Body Composition Analyzer & BioImp Body Composition Analyzer PC Software Regulation Number: 21 CFR 8870.2770 Regulation Name: Impedance plethysmograph Regulatory Class: II Product Code: MNW Dated: undated Received: March 13, 2006
Dear Mr. Bertwistle:
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 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). You may, therefore, market the device. subject to the general controls provisions of the Act. However, you are responsible to determine that the medical devices you use as components in the kit have either been determined as substantially equivalent under the premarket notification process (Section 510(k) of the act), or were legally on the market prior to May 28, 1976, the enactment date of the Medical Device Amendments. Please note: If you purchase your device components in bulk (i.e., unlinished) and further process (e.g., sterilize) you must submit a new 510(k) before including these components in your kit. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, and labeling, and prohibitions against misbranding and adulteration.
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.
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Page 2 - Mr. Neville Bertwistle
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); 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.
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on the labeling regulation, please contact the Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification'(21 CFR Part 807.97). 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) 443-6597, or at its Internet address http://www.fda.gov/cdrh.dsma/dsmamain.html.
Sincerely yours.
Nancy C. Brogdon
Nancy C. Brogdon Director, Division of Reproductive. Abdominal and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health
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# Indications for Use
## 510(k) Number (if known): K052319
Device Name(s): Imp SFB7 Biolmp Body Composition Analyzer PC Software
## Indications for Use:
(1) Imp SFB7 – A bioelectrical impedance analyzer/monitor that is intended to estimate the following body composition parameters: Fat-free Mass (FFM), Fat Mass (FM), Total Body Water (TBW), Intra cellular Fluid (ICF), Extra cellular Fluid (ECF), and Body Mass Index (BMI). The device measures current, voltage and phase angle (Phi), and from these values calculates resistance (R), reactance (Xc), and impedance (Z), which are used to estimate the above body composition parameters. The device/software will also display the Cole-Cole plot, resistance vs. frequency plot, reactance vs. frequency plot, subject height, age and sex.
(2) Biolmp Body Composition Analyzer PC Software: A PC software package that is intended to be used only with the ImpediMed Imp SFB7 Analyzer for uploading the MFBIA mode data on to the PC from Imp SFB7 via an Ethernet port for storing, processing and analysing of MFBIA bioimpedance measurements. This displays Cole-Cole plot, body composition parameters: Fatfree Mass (FFM), Fat Mass (FM), Total Body Water (TBW), Intra cellular Fluid (ICF), Extra cellular Fluid (ECF), Body Mass Index (BMI), and subject height, weight, age, sex, time, and date of measurement, Practitioner's name and Device serial number, and bioelectrical parameters resistance (R), reactance (Xc), and impedance (Z) and phase angle (Phi) at different frequencies (Between 4 kHz to 1000 kHz). The software can be used to generate patient body composition report displaying all the parameters stated above.
These devices are intended to be used only on healthy patients, who wish to have their body composition estimated in the home or clinical environment.
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)
Nancy C brogdon
vision of Reproductive. Abdomin adiological Devices 0(k) Number
Page 1 of
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.