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SOZO

ImpediMed Limited • Cardiovascular • 11/25/2019

510(k)IEC 62304 Class C
FDA Summary PDF

Device Purpose

The SOZO® system utilizes multi-frequency bioimpedance spectroscopy to non-invasively measure electrical properties of the human body, aiding clinicians in assessing protein-calorie malnutrition risk and tracking detailed body composition parameters. Its methodology involves applying a low-level electrical current across a wide range of frequencies through hand and footplate electrodes, with algorithms then converting the measured impedance data into clinically relevant metrics like fluid volumes, fat mass, and muscle mass.

Summary

The SOZO® system is a bioimpedance spectroscopy device designed to aid clinicians in assessing patients at risk of protein-calorie malnutrition by serving as an adjunct to Subjective Global Assessment tools. It also estimates and tracks various body composition parameters over time, including fat mass, fat-free mass, total body water (differentiating intracellular and extracellular fluid), and skeletal muscle mass. The system operates by having a patient make contact with stainless steel electrodes on a connected hand and footplate. A small electrical current (200μA RMS) is applied across 256 frequencies (3kHz to 1000kHz), and the device measures the resulting voltage and phase angle to calculate impedance, resistance, and reactance. These bioimpedance measurements (current, voltage, phase angle, resistance, reactance, impedance) are then processed by established algorithms within the SOZOapp on a paired Android tablet. The system provides outputs such as Body Mass Index, basal metabolic rate, and protein/mineral content (dry lean mass), in addition to the primary body composition parameters. Data is stored and managed via the SOZOhub database. Performance testing confirmed the device's electrical safety, biocompatibility, software validity, and functional reliability. Clinical studies have supported the applicability of its bioimpedance spectroscopy technology for body composition assessment, and comparative testing showed strong correlation with a predicate device.

AI Regulatory Concerns

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Keywords

Bioimpedance Spectroscopy (BIS)Body CompositionProtein-Calorie Malnutrition (PCM)Extracellular FluidIntracellular FluidSkeletal Muscle MassImpedance PlethysmographSubjective Global Assessment (SGA)Multi-frequency bioimpedanceNon-invasive monitoring

Device Metadata

Submission Number
K190529
Company
ImpediMed Limited
Panel
Cardiovascular
Product Code
N/A
Data Type
Signals
Clinical Function
Assessment
AI Function
Analysis
AI Subclass
quantification/feature localization

Relevant Clinical Questions

  • Q1. What is the specific accuracy and precision of the SOZO system in differentiating between intracellular and extracellular fluid compared to gold-standard methods like dilution techniques across diverse patient populations (e.g., varying hydration states, renal patients)?; How do the "established algorithms" used by SOZO account for variations in body geometry, ethnicity, and age, and what is the evidence supporting their validity across these demographics for each reported parameter?; For its use as an adjunct in assessing protein-calorie malnutrition risk, what is the quantitative impact or added diagnostic value of SOZO measurements when combined with SGA tools, particularly in early detection or severity grading of PCM?; Given the wide frequency range (3kHz to 1000kHz), how does the SOZO system specifically utilize data from different parts of this spectrum to derive distinct body composition parameters, and are there specific frequencies critical for certain estimations like skeletal muscle mass?; How does the system's performance, particularly the stability and reproducibility of measurements, vary with repeated use over its intended life, especially concerning electrode integrity and calibration requirements in a clinical setting?

Risk Classification

ESL Analysis
FDA Device ClassII

FDA Class II via 510(k) pathway; IEC 62304 Class C (software safety classification); Authorized before §524B enforcement

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Cybersecurity Evidence

Powered by SBOMator™

Based on AI-generated device summaries, not the full FDA submission. Items not detected here may still be present in the complete submission package.

Cyber Score25/100
SBOM Evidence⚠ Not mentioned in summary
Cyber Risk Assessment⚠ Not mentioned in summary
Postmarket Plan✓ Detected in Summary
§524B ApplicableNo

Supply Chain BOM Evidence

Based on the CycloneDX / OWASP ECMA-424 xBOM ecosystem. Detection is from the AI-generated summary.

SBOMSoftware Bill of Materials
- Not detected
ML-BOMMachine Learning Bill of Materials(algorithm)
✓ Detected
SaaSBOMSoftware-as-a-Service Bill of Materials(cellular)
✓ Detected
HBOMHardware Bill of Materials
- Not detected
CBOMCryptography Bill of Materials
- Not detected
VDR/VEXVulnerability Disclosure Report / Vulnerability Exploitability eXchange
- Not detected
OBOMOperations Bill of Materials
- Not detected

Analysis:

• Analysis is based on the AI-generated device summary, not the full FDA submission package. Click "Analyze Full FDA PDF" below to scan the actual submission document.

• Evidence of ML-BOM, SaaSBOM detected in AI-generated device summary.

• This device was authorized before §524B took effect. Cybersecurity evidence requirements were less prescriptive at the time.

• Not detected in AI-generated device summary: SBOM, HBOM, CBOM, VDR/VEX, OBOM. These may be present in the full FDA submission.

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SOZO - ImpediMed Limited | ESL FDA AI Device Intelligence