K231459 · Resonance Health Analysis Services Pty, Ltd. · LNH · Jun 20, 2023 · Radiology
Device Facts
Record ID
K231459
Device Name
HepaFatSmart (V2.0.0)
Applicant
Resonance Health Analysis Services Pty, Ltd.
Product Code
LNH · Radiology
Decision Date
Jun 20, 2023
Decision
SESE
Submission Type
Special
Regulation
21 CFR 892.1000
Device Class
Class 2
Attributes
AI/ML, Software as a Medical Device, Pediatric
AI Performance
Output
Algorithm
Acceptance
Observed
Dev DS
Dev Readers
Test DS
Test Readers
Volumetric liver fat fraction (VLFF)
Convolutional neural network
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Sensitivity 100.0% (97.3–100.0%) and Specificity 98.6% (94.9–99.6%) at 4.1% VLFF threshold.
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Validation study: 300 subjects (281 passed IQC rules) with different clinical conditions across a broad age range and fat level scanned from different MRI centres.
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Proton density fat fraction (PDFF)
Convolutional neural network
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—
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Validation study: 300 subjects (281 passed IQC rules) with different clinical conditions across a broad age range and fat level scanned from different MRI centres.
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Steatosis grading
Convolutional neural network
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Sensitivity 98.8% (93.6–99.8%) and Specificity 98.0% (94.9–99.2%) at 12.1% VLFF threshold; Sensitivity 100.0% (93.8–100.0%) and Specificity 99.6% (97.5–99.9%) at 16.2% VLFF threshold.
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Validation study: 300 subjects (281 passed IQC rules) with different clinical conditions across a broad age range and fat level scanned from different MRI centres.
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Indications for Use
HepaFatSmart is intended for the quantitative measurement of volumetric liver fat fraction (VLFF), proton density fat fraction (PDFF) and steatosis grading. HepaFatSmart is an application that is used for the non-invasive evaluation of liver tissue by utilising magnetic resonance images to evaluate the difference in resonance frequencies between hydrogen nuclei in water and triglyceride fat. The quantitative triglyceride fat fraction is based on the measurement of a magnetic resonance parameter that reflects the ratio of the proton density signal of triglyceride fat to the total proton density signal in the liver.
Device Story
HepaFatSmart is an AI-assisted SaMD for quantitative liver fat assessment. It takes DICOM MRI datasets (Gradient Recalled Echo) as input via a secure portal (FAST). The device uses a convolutional neural network (CNN) to automatically predict a liver region of interest (ROI) and applies computer vision to remove artifacts and blood vessels. It calculates Alpha, VLFF, PDFF, and steatosis grade, and performs automated liver iron assessment to accept/reject analysis. Used by radiologists in clinical settings, it produces PDF and DICOM reports containing fat distribution maps and confidence intervals. The output supports clinical diagnosis, management of fatty liver/metabolic syndromes, and donor screening. By automating ROI selection, it minimizes human error and improves reproducibility compared to manual methods. It does not contact patients, control other devices, or deliver treatment; clinical judgment remains primary.
Clinical Evidence
Bench testing and validation study (n=300, 281 passed IQC). Repeatability study (n=42) showed 100% reproducibility. Validation study compared HepaFatSmart to reference standard HepaFat-Scan. Results showed high agreement: sensitivity and specificity for predicting VLFF thresholds (4.1%, 12.1%, 16.2%) were >98%. Bland-Altman analysis showed small bias (0.2%) and improved performance over predicate HepaFat-Al.
Technological Characteristics
SaMD; utilizes Gradient Recalled Echo (GRE) MRI data. Core technology: Convolutional Neural Network (CNN) for liver ROI prediction; computer vision for artifact/vessel removal. Algorithmic modules for Alpha, VLFF, PDFF, steatosis grade, and iron assessment. Cloud-based or onsite deployment via FAST portal. Software is 'locked' post-training. DICOM input/output.
Indications for Use
Indicated for individuals of all ages and genders with confirmed or suspected fatty liver disease; support clinical decision-making for patients with fatty liver-related disease or metabolic syndromes; aid in assessment and screening of living liver transplant donors.
Regulatory Classification
Identification
A magnetic resonance diagnostic device is intended for general diagnostic use to present images which reflect the spatial distribution and/or magnetic resonance spectra which reflect frequency and distribution of nuclei exhibiting nuclear magnetic resonance. Other physical parameters derived from the images and/or spectra may also be produced. The device includes hydrogen-1 (proton) imaging, sodium-23 imaging, hydrogen-1 spectroscopy, phosphorus-31 spectroscopy, and chemical shift imaging (preserving simultaneous frequency and spatial information).
Special Controls
*Classification.* Class II (special controls). A magnetic resonance imaging disposable kit intended for use with a magnetic resonance diagnostic device only is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 892.9.
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June 20, 2023
Resonance Health Analysis Services Pty Ltd % Mitchell Wells Managing Director 141 Burswood Road Burswood, Western Australia 6100 Australia
Re: K231459
Trade/Device Name: HepaFatSmart (V2.0.0) Regulation Number: 21 CFR 892.1000 Regulation Name: Magnetic resonance diagnostic device Regulatory Class: Class II Product Code: LNH Dated: May 19, 2023 Received: May 19, 2023
Dear Mitchell Wells:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.
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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 of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Daniel M. Krainak, Ph.D. Assistant Director DHT8C: Division of Radiological Imaging and Radiation Therapy Devices OHT8: Office of Radiological Health Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Submission Number (if known)
K231459
Device Name
HepaFatSmart (V2.0.0)
#### Indications for Use (Describe)
Intended use:
HepaFatSmart is intended for the quantitative measurement of volumetric liver fat fraction (VLFF), proton density fat fraction (PDFF) and steatosis grading.
HepaFatSmart is an application that is used for the non-invasive evaluation of liver tissue by utilising magnetic resonance images to evaluate the difference in resonance frequencies between hydrogen nuclei in water and triglyceride fat. The quantitative triglyceride fat fraction is based on the measurement of a magnetic resonance parameter that reflects the ratio of the proton density signal of triglyceride fat to the total proton density signal in the liver.
Indications for use:
Support clinical diagnoses in individuals with confirmed or suspected fatty liver disease;
Support the subsequent clinical decision making processes for patients under management for fatty liver related disease or metabolic syndromes;
Aid in the assessment and screening of living donors for liver transplant.
Results, when interpreted by a trained physician can be used to support clinical diagnoses about the status of liver fat content, the subsequent clinical decision making processes for the management of fatty liver related diseases, metabolic syndromes, liver donor screening and lifestyle change. HepaFatSmart can be used to analyse the MRI images of patients of all populations independent of age and gender, with suspected clinical conditions related to the level of liver fat.
Type of Use (Select one or both, as applicable)
> Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)
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# 510(K) SUMMARY
This Summary has been prepared in accordance with 21 CFR 807.92.
# General Information
| Date Prepared | 07 June 2023 |
|-----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Submitted by | Resonance Health Analysis Service Pty Ltd<br>141 Burswood Rd<br>Burswood 6100<br>AUSTRALIA |
| Main Contact | Mitchell Wells<br>Managing Director,<br>Resonance Health Analysis Services Pty Ltd<br>mitchellw@resonancehealth.com<br>Tel: +61 8 9286 5300<br>Fax: +61 8 9286 5399 |
| US Contact (US Agent) | Michael van der Woude<br>Director & GM<br>Emergo Global Representation LLC<br>2500 Bee Cave Road, Building 1, Suite 300<br>Austin, TX 78746<br>Phone: 512 3279997<br>Fax : 512 3279998<br>Email : USAgent@ul.com |
# Device Information
| Name of Device | HepaFatSmart |
|------------------------|-----------------------------------------------|
| Trade/proprietary Name | HepaFatSmart (V2.0.0) |
| Classification | Class II |
| Product Code | LNH |
| CFR Section | 892.1000 Magnetic Resonance Diagnostic Device |
| Panel | Radiology |
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# Description of the Device
HepaFatSmart is an SaMD designed to automatically analyse magnetic resonance imaging (MRI) datasets for quantitative assessment of a patient's liver fat, in form of volumetric liver fat fraction (VLFF), proton density fat fraction (PDFF), and steatosis grade. It is an Al assisted, automated version of HepaFat-Scan (another SaMD of Resonance Health). To carry out an analysis, the user simply uploads DICOM images to FAST, Resonance Health's secured user portal and job management system. No other user input is required for the analysis thereby minimising the impact of human error on obtained results. HepaFatSmart requires DICOM images as input data that have been acquired according to the HepaFatSmart (same as HepaFat-Scan) protocol.
The key components for the HepaFatSmart are:
- . MRI Protocol: A specific MRI protocol for acquisition of the raw image data. The MRI protocol is critical to ensure the quality of the end results. Its adherence is verified by the HepaFatSmart IQC module, an automated algorithm that checks the correctness of each parameter in the protocol.
- . HepaFatSmart: An image analysis software predicting a suitable liver region of interest (ROI) utilizing Al-assisted SaMD technology then performing the Alpha measurement and anomaly (excessive iron) detection. It is composed of one (1) convolutional neural network (CNN) performing liver ROI detection with undesired components (artefacts and major blood vessels) considered/removed using a computer vision technique with machine learning technology. Background noise correction is not considered as there is no or very minimal impact on the analysis outcome. Following the training of the Al assisted device, the system is completely 'locked down' for final validation prior to release in commercial use to ensure reproducibility of the results. In principle, the HepaFatSmart v2.0.0 uses the same MRI data analysis approach as HepaFat-Scan.
- . Volumetric Liver Fat Fraction Measurement (VLFF): A software module (algorithmic) that incorporates a conversion lookup table relating Alpha to VLFF is added to allow production of a VLFF report.
- . Proton Density Fat Fraction Measurement (PDFF): A software module (algorithmic) that incorporates a conversion lookup table relating VLFF to PDFF is added to allow production of a PDFF report.
- . Steatosis Grade Measurement: A software module (algorithmic) that incorporates a conversion lookup table relating VLFF to a steatosis grade.
- . Excessive liver iron assessment: An additional software module (algorithmic) that estimates the impact of liver iron content as per the inclusion criteria based on an algorithm to determine the analysis outcome (accept or reject).
The output of HepaFatSmart is the automatically generated reports in both PDF and DICOM (secondary captured) formats. Visually, the PDF and DICOM reports are identical except that the DICOM report also contains relevant header information. The HepaFatSmart report is populated with information stored in the DICOM header of the MRI images, the analysis result, where an Alpha value is converted into a VLFF value, a PDFF value, and a steatosis grade, and the associated confidence interval and normal range.
The HepaFatSmart report also contains pictures of two (2) echo times (TEs) (1st Out-of-Phase, 1st OP, and In-Phase, IP) of the analysed slice, a predicted liver ROI superimposed with one (IP) of the two TE images, and a fat distribution map. This is essential for the radiologist to check if the image
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analysed is a liver image, the Al predicted ROI is placed correctly within the liver region, and the result provided is valid and consistent with other relevant clinical considerations.
HepaFatSmart SaMD can be accessed through a cloud-based or onsite platform. Resonance Health has developed its own cloud-based platform, called 'FAST'. Alternatively, HepaFatSmart can be offered on third parties' (channel partner) platforms.
It is important to note that HepaFatSmart as a medical device does not:
- come into direct contact with patients or end-users;
- . control any other device used on the patient;
- . deliver any treatment or energy to the patient; or
- . provide diagnostic information upon which inappropriate (or lack of) treatment likely to result in serious adverse events is based; as clinical judgment would be used in the patient's clinical management, based upon a range of other factors relating to the patient.
# INTENDED USE
The intended use of HepaFatSmart is:
HepaFatSmart is intended for the quantitative measurement of volumetric liver fat fraction (VLFF), proton density fat fraction (PDFF) and steatosis grading.
HepaFatSmart is an application that is used for the non-invasive evaluation of liver tissue by utilising magnetic resonance images to evaluate the difference in resonance frequencies between hydrogen nuclei in water and triglyceride fat. The quantitative triglyceride fat fraction is based on the measurement of a magnetic resonance parameter that reflects the ratio of the proton density signal of triglyceride fat to the total proton density signal in the liver.
# INDICATIONS FOR USE
- Support clinical diagnoses in individuals with confirmed or suspected fatty liver disease;
- Support the subsequent clinical decision-making processes for patients under management for fatty liver related disease or metabolic syndromes;
- Aid in the assessment and screening of living donors for liver transplant.
- . Results, when interpreted by a trained physician can be used to support clinical diagnoses about the status of liver fat content, the subsequent clinical decision-making processes for the management of fatty liver related diseases, metabolic syndromes, liver donor screening and lifestyle change.
HepaFatSmart can be used to analyse the MRI images of patients of all population independent of age and gender, with suspected clinical conditions related to the level of liver fat.
# PREDICATE INFORMATION
HepaFatSmart is substantially equivalent to the predicate device HepaFat-Scan (Resonance Health Analysis Services- K122035) and better than HepaFat-Al (Resonance Health Services - K201039).
# SUBSTANTIAL EQUIVALENCE INFORMATION
The table below summarizes the main similarities and differences between HepaFat-Al and the predicate.
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| | HepaFatSmart | HepaFat-Al | HepaFat-Scan |
|------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Regulatory Class | ll | ll | ll |
| 510(k) number | K231459 | K201039 | K122035 |
| Classification Name | System, Nuclear<br>Magnetic Resonance<br>Imaging, System, Image<br>Processing Radiological | System, Nuclear Magnetic<br>Resonance Imaging,<br>System, Image Processing<br>Radiological | System, Nuclear Magnetic<br>Resonance Imaging,<br>System, Image Processing<br>Radiological |
| CFR Section | 892.1000 | 892.1000 | 892.1000 |
| Product Code and<br>Classification Panel | LNH | LNH | LNH |
| Device Name | HepaFatSmart | HepaFat-Al | HepaFat-Scan |
| Trade/Common<br>Name | HepaFatSmart | HepaFat-Al | HepaFat-Scan |
| Description | Standalone software<br>platform designed to<br>automatically analyse<br>within seconds magnetic<br>resonance imaging (MRI)<br>datasets using the<br>method of HepaFat-Scan<br>with the liver ROI<br>predicted to generate an<br>estimate of the patient's<br>volumetric liver fat<br>fraction (VLFF),<br>converted into proton<br>density fat fraction<br>(PDFF) and steatosis<br>grade. No user input is<br>required for the analysis<br>thus minimising the<br>impact of human error<br>on obtained results. | Standalone software<br>platform designed to<br>automatically analyse<br>within seconds magnetic<br>resonance imaging (MRI)<br>datasets to generate an<br>estimate of the patient's<br>volumetric liver fat fraction<br>(VLFF), converted into<br>proton density fat fraction<br>(PDFF) and steatosis grade.<br>No user input is required<br>for the analysis thus<br>minimising the impact of<br>human error on obtained<br>results. | Standalone software<br>application to facilitate the<br>import and visualization of<br>multi-slice, gradient-echo<br>MRI data sets<br>encompassing the<br>abdomen, with<br>functionality independent<br>of the MRI equipment, to<br>provide objective and<br>reproducible<br>determination of the<br>triglyceride fat fraction in<br>magnetic resonance<br>images of the liver. It<br>utilises magnetic<br>resonance images that<br>exploit the difference in<br>resonance frequencies<br>between hydrogen nuclei<br>in water and triglyceride<br>fat. The quantitative<br>triglyceride fat fraction is<br>based on the<br>measurement of a<br>magnetic resonance<br>parameter that reflects<br>the ratio of the proton<br>density signal of<br>triglyceride fat to the total<br>proton density signal in<br>the liver. |
| | HepaFatSmart | HepaFat-Al | HepaFat-Scan |
| Technology | Convolutional neural<br>networks for the<br>prediction of the liver<br>region of interest (ROI).<br>Algorithmic for the<br>image quality checking<br>and calculated Alpha<br>conversion into VLFF,<br>PDFF and Steatosis<br>grade.<br>Algorithms for the<br>measurement and<br>calculation of Alpha<br>VLFF, PDFF and Steatosis<br>grade. | Convolutional neural<br>networks for the image<br>analysis.<br>Algorithmic for the image<br>quality checking and Alpha<br>conversion into VLFF. | Algorithmic, with human<br>interaction for Region of<br>Interest (ROI) selection. |
| Intended Use | HepaFatSmart is<br>intended for the<br>quantitative<br>measurement of<br>volumetric liver fat<br>fraction (VLFF), proton<br>density fat fraction<br>(PDFF) and steatosis<br>grading.<br>HepaFatSmart is an<br>application that is used<br>for the non-invasive<br>evaluation of liver tissue<br>by utilising magnetic<br>resonance images to<br>evaluate the difference<br>in resonance frequencies<br>between hydrogen<br>nuclei in water and<br>triglyceride fat. The<br>quantitative triglyceride<br>fat fraction is based on<br>the measurement of a<br>magnetic resonance<br>parameter that reflects<br>the ratio of the proton<br>density signal of<br>triglyceride fat to the<br>total proton density<br>signal in the liver. | HepaFat-Al is intended for<br>quantitative measurement<br>of the triglyceride fat<br>fraction in magnetic<br>resonance images of the<br>liver, also known as<br>volumetric liver fat fraction<br>(VLFF).<br>It utilises magnetic<br>resonance images that<br>exploit the difference in<br>resonance frequencies<br>between hydrogen nuclei<br>in water and triglyceride<br>fat. The quantitative<br>triglyceride fat fraction is<br>based on the<br>measurement of a<br>magnetic resonance<br>parameter that reflects the<br>ratio of the proton density<br>signal of triglyceride fat to<br>the total proton density<br>signal in the liver.<br>When interpreted by a<br>trained physician, the<br>results provide information<br>that can aid in diagnosis. | HepaFat-Scan is a software<br>device intended for<br>quantitative measurement<br>of the triglyceride fat<br>fraction in magnetic<br>resonance images of the<br>liver. It utilises magnetic<br>resonance images that<br>exploit the difference in<br>resonance frequencies<br>between hydrogen nuclei<br>in water and triglyceride<br>fat. The quantitative<br>triglyceride fat fraction is<br>based on the<br>measurement of a<br>magnetic resonance<br>parameter that reflects<br>the ratio of the proton<br>density signal of<br>triglyceride fat to the total<br>proton density signal in<br>the liver.<br>When interpreted by a<br>trained physician, the<br>results provide<br>information that can aid in<br>diagnosis. |
| Indications | Support clinical<br>• diagnoses in<br>individuals with | HepaFat-Al is indicated to:<br>• Assess the volumetric<br>liver fat fraction | HepaFat-Scan is a software<br>device intended for<br>quantitative measurement |
| | HepaFatSmart | HepaFat-Al | HepaFat-Scan |
| | confirmed or suspected fatty liver disease;<br>Support the subsequent clinical decision-making processes for patients under management for fatty liver related disease or metabolic syndromes; Aid in the assessment and screening of living donors for liver transplant. Results, when interpreted by a trained physician can be used to support clinical diagnoses about the status of liver fat content, the subsequent clinical decision-making processes for the management of fatty liver related diseases, metabolic syndromes, liver donor screening and lifestyle change. HepaFatSmart can be used to analyse the MRI images of patients of all population independent of age and gender, with suspected clinical conditions related to the level of liver fat. | proton density fat fraction and steatosis grade in individuals with confirmed or suspected fatty liver disease;<br>Monitor liver fat content in patients undergoing weight loss management; Aid in the assessment and screening of living donors for liver transplant. | of the triglyceride fat fraction in magnetic resonance images of the liver. It utilises magnetic resonance images that exploit the difference in resonance frequencies between hydrogen nuclei in water and triglyceride fat. The quantitative triglyceride fat fraction is based on the measurement of a magnetic resonance parameter that reflects the ratio of the proton density signal of triglyceride fat to the total proton density signal in the liver.<br><br>When interpreted by a trained physician, the results provide information that can aid in diagnosis. |
| User | Radiologist | Radiologist | Resonance Health's trained analyst |
| Hosting platform | Cloud-based or onsite platform | Cloud-based or onsite platform | Resonance Health's internal server |
| Image-type utilized | Magnetic Resonance | Magnetic Resonance | Magnetic Resonance |
| Image format | DICOM | DICOM | DICOM |
| Data Acquisition method | Gradient Recalled Echo (GRE) | Gradient Recalled Echo (GRE) | Gradient Recalled Echo (GRE) |
| | HepaFatSmart | HepaFat-Al | HepaFat-Scan |
| Anatomical Sites | Liver | Liver | Liver |
| Result report<br>content | Unique Report ID Patient ID, patient name, and date of birth for full identification of the patient. Scan date, and analysis date. Referrer and MRI centre. Results displayed: VLFF (%), PDFF (%) and Steatosis grade, associated with confidence intervals and normal range. Pictures of the 2 TEs of the analysed slice and analysis liver ROI placed on 1 TE. Liver colour map (for illustration purpose only, not for diagnostic) | Unique Report ID Patient ID, patient name, and date of birth for full identification of the patient. Scan date, and analysis date. Referrer and MRI centre. Results displayed: VLFF (%), PDFF (%) and Steatosis grade, associated with confidence intervals and normal range. Pictures of the 3 TEs of the analysed slice. Liver colour map (for illustration purpose only, not for diagnostic) | Unique Report ID Patient ID, patient name, and date of birth for full identification of the patient. Scan date, and analysis date. Referrer and MRI centre. Results displayed: VLFF (%) associated with confidence intervals and normal range. Picture of the analysed slice. |
| Result report<br>format | PDF (encrypted) and<br>secondary capture<br>(DICOM) | HTML and PDF | PDF |
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#### SUMMARY OF HEPAFATSMART PERFORMANCE - SUBSTANTIAL EQUIVALENCE
The device HepaFatSmart is in principle a new version of the predicate HepaFat-Al but with the name changed. As indicated in the Software Validation Report, three different technical analyses were performed to indicate the technical equivalency of HepaFatSmart compared with the reference standard HepaFat-Scan: Repeatability Study, Linear Regression Analysis and Bland Altman Analysis.
#### Repeatability Study (n = 42)
Repeatability study using a dataset with two different MRI scans for each subject to evaluate the device performance is a self-proven process as each paired data for a subject is supposed to produce the same analysis outcome. Briefly, the results are summarised as following:
Image /page/10/Figure/4 description: The image contains two scatter plots, labeled A and B, comparing two sets of measurements. Plot A compares 'HepaFat-Scan VLFF Scan 1 (%)' on the x-axis with 'HepaFat-Scan VLFF Scan 2 (%)' on the y-axis, showing a positive correlation. Plot B compares 'HepaFatSmart VLFF Scan 1 (%)' on the x-axis with 'HepaFatSmart VLFF Scan 2 (%)' on the y-axis, also showing a positive correlation. Both plots feature a diagonal line, indicating a perfect agreement between the two scans, and data points clustered closely around this line.
Figure 1. Plot A of HepaFat-Scan 2 against HepaFat-Scan VLFF measured at scan 1 for the 42 subjects in the repeatability study. Plot B is for HepaFatSmart (41 subjects). The solid line is the line of equivalence. Note, 41 instead of 42 subjects were used in the HepaFatSmart related analysis as a single case was identified as a high iron case with the newly introduced excessive iron assessment algorithm. All the results are closely scattered around the equivalency line, indicating good performance and substantial equivalence for both the predicate HepaFatSmart,
From the linear regression analysis shown in Figure 1 for both the reference standard HepaFat-Scan (plot A) and HepaFatSmart (plot B), all the results are closely scattered around the equivalency line and difficult to tell visually which one is better.
Image /page/10/Figure/7 description: The image contains two Bland-Altman plots comparing HepaFat-Scan and HepaFatSmart measurements. The left plot, labeled "A. HepaFat-Scan (reference standard)," displays the difference between two HepaFat-Scan measurements against their mean, with the y axis labeled as "HepaFat-Scan VLFF Scan 2 - HepaFat-Scan VLFF Scan 1" and the x axis labeled as "Mean HepaFat-Scan VLFF (%)". The right plot, labeled "B. HepaFatSmart," shows the difference between two HepaFatSmart measurements against their mean, with the y axis labeled as "HepaFatSmart VLFF Scan 2 - HepaFatSmart VLFF Scan 1" and the x axis labeled as "Mean HepaFatSmart VLFF (%)".
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Figure 2. Bland Altman analysis of the repeatability study: plot A - HepaFat-Scan VLFF measured scan 1 and 2 for the 42 subjects; plot B is for HepaFatSmart (41 subjects). Bias and both repeatability coefficients are slightly better for HepaFatSmart compared with the reference standard HepaFat-Scan.
From the Bland Altman analysis shown in Figure 2 for both the reference standard HepaFat-Scan (plot A) and HepaFatSmart (plot B), bias and both repeatability coefficients for the HepaFatSmart are slightly better than those obtained from the repeated scans of HepaFat-Scan, indicating the performance of the HepaFatSmart is comparable (no worse) than human for the repeatability data analysed. This does not suggest yet that the HepaFatSmart is better than human analyst as the original human analysis (HepaFat-Scan) historically used two small liver ROIs rather than a single large liver ROI used in the HepaFatSmart with potentially slightly larger sampling error in the original HepaFat-Scan analysis. From the repeatability data, there was no statistically significant bias and tight repeatability coefficients for the HepaFatSmart, indicating the substantial equivalence to the predicate HepaFat-Scan and a possibility that the results from HepaFatSmart and HepaFat-Scan could be interchangeable.
In addition, HepaFatSmart demonstrated 100% repeatable (reproducible) in the repeatability study using the same datasets analysed twice with zero VLFF difference between the first and second analyses, which is better than human analysis with HepaFat-Scan.
#### Validation Study (n=300)
Validation study using a dataset with two different MRI scans for each subject to evaluate the device performance is a self-proven process as each paired data for a subject is supposed to produce the same analysis outcome. Briefly, the results are summarised as following (note the study population size is smaller than 300 as per the IQC module in place):
Image /page/11/Figure/5 description: The image contains two scatter plots, labeled A and B, comparing HepaFatSmart VLF and HepaFat-Scan VLFF. Plot A shows a broader range of values, extending up to 45% on both axes, while plot B focuses on a smaller range, up to 10%. Both plots show a positive correlation between the two methods, with data points clustered around a diagonal line, indicating agreement between HepaFatSmart and HepaFat-Scan VLFF measurements.
Figure 3. Linear regression analysis of the validation study (n = 281) by comparing HepaFatSmart with the reference standard HepaFat-Scan: plot A shows the full VLFF range and plot B shows the VLFF range between 0 – 10%. The solid line is the line of equivalence. 281 da…
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.