ELECTROFLUIDGRAPH

K091369 · Akern USA, LLC · MNW · Oct 14, 2009 · Cardiovascular

Device Facts

• Record ID: K091369
• Device Name: ELECTROFLUIDGRAPH
• Applicant: Akern USA, LLC
• Product Code: MNW · Cardiovascular
• Decision Date: Oct 14, 2009
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 870.2770
• Device Class: Class 2

Intended Use

The ElectroFluidGraph™is used to estimate the subject's body composition parameters of Fat Free Mass, Fat Mass, Total Body Water and Extra-Cellular Water; in "generally healthy" subjects of 21 to 87 years old.

Device Story

ElectroFluidGraph is an impedance plethysmograph used to estimate body composition parameters including Fat Free Mass, Fat Mass, Total Body Water, and Extra-Cellular Water. Device operates by measuring electrical impedance of the subject's body. Intended for over-the-counter use in generally healthy adults. Output provides quantitative body composition metrics to the user to assist in health monitoring.

Clinical Evidence

No clinical data provided; bench testing only.

Technological Characteristics

Impedance plethysmograph; measures electrical impedance to derive body composition parameters. Class II device under 21 CFR 870.2770.

Indications for Use

Indicated for estimation of body composition (Fat Free Mass, Fat Mass, Total Body Water, Extra-Cellular Water) in generally healthy adults aged 21 to 87 years.

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.

Submission Summary (Full Text)

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Image /page/0/Picture/0 description: The image shows the seal of the Department of Health & Human Services - USA. The seal is circular and contains an image of an eagle. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" is written around the eagle.

## DEPARTMENT OF HEALTH & HUMAN SERVICES

Public Health Service

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

Akern USA, LLC c/o Kevin Walls, RAC Principal Consultant Regulatory Insight, Inc. 5401 S. Cottonwood Court GREENWOOD VILLAGE CO 80121

OCT 1 4 2009

Re: K091369

Trade/Device Name: ElectroFluidGraph" Regulation Number: 21 CFR §870.2770 Regulation Name: Impedance plethysmograph Regulatory Class: II Product Code: MNW Dated: August 13, 2009 Received: August 14, 2009

Dear Mr. Walls:

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.

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.

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

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device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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 [phone] or [phone] or at its Internet address http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.

<http://www.fda.gov/MedicalDevices/ResourceforYou/Industry/default.htm>

Sincerely yours,

Janine M. Morris

Janine M. Morris Acting Director, Division of Reproductive, Abdominal, and Radiological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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## Indications for Use

510(k) Number (if known): K091369

Device Name: ElectroFluidGraph™

Indications for Use: The ElectroFluidGraph™is used to estimate the subject's body composition parameters of Fat Free Mass, Fat Mass, Total Body Water and Extra-Cellular Water; in "generally healthy" subjects of 21 to 87 years old.

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 OF NEEDED)

## Concurrence of CDRH, Office of Device Evaluation (ODE)

Tomh Wh

(Division Sign-Off) Division of Reproductive, Abdominal, and Radiological Devices

510(k) Number

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