K Number
K062963
Device Name
PHAROS EXCIMER LASER SYSTEM, MODEL EX-308
Date Cleared
2007-04-03

(186 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The PHAROS Excimer Laser will be indicated for use for the treatment of psoriasis, vitiligo, atopic dermatitis and leukoderma.
Device Description
RA Medical Systems, Inc.'s PHAROS Excimer Laser is a medical laser that is a self-contained UV laser light source that emits a wavelength of 308 nm. The PHAROS Excimer Laser utilizes a XeCl gas mixture to generate an operator-selected dose and targetspecific UV light. The laser dose is activated by a footswitch with the therapeutic radiation emitting from a handheld device. The laser operation is key controlled and is contained within an interlocked housing.
More Information

Not Found

No
The summary describes a laser device with operator-selected dose and target-specific UV light, activated by a footswitch. There is no mention of AI, ML, image processing, or any data-driven decision-making processes. The performance studies focus on conformance to standards and equivalence to predicate devices, not on AI/ML performance metrics.

Yes
The intended use statement explicitly states the device is for "treatment of psoriasis, vitiligo, atopic dermatitis and leukoderma," indicating a therapeutic purpose.

No.
The "Intended Use / Indications for Use" section states that the device is "indicated for use for the treatment of psoriasis, vitiligo, atopic dermatitis and leukoderma," which are therapeutic applications, not diagnostic ones. The "Device Description" also describes it as a "medical laser" that emits UV light for treatment.

No

The device description clearly states it is a "medical laser" and describes physical components like a "self-contained UV laser light source," "handheld device," and "footswitch," indicating it is a hardware device.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for the treatment of skin conditions (psoriasis, vitiligo, atopic dermatitis, leukoderma). IVDs are used for the diagnosis or monitoring of diseases or conditions by examining specimens from the human body.
  • Device Description: The device is a laser that emits UV light for therapeutic purposes. It does not involve the analysis of biological samples.
  • Lack of IVD Characteristics: The description does not mention any components or processes related to collecting, preparing, or analyzing biological specimens (like blood, urine, tissue, etc.), which are fundamental to IVDs.

Therefore, the PHAROS Excimer Laser is a therapeutic medical device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The PHAROS Excimer Laser will be indicated for use for the treatment of psoriasis, vitiligo, atopic dermatitis and leukoderma.

Product codes (comma separated list FDA assigned to the subject device)

GEX

Device Description

RA Medical Systems, Inc.'s PHAROS Excimer Laser is a medical laser that is a self-contained UV laser light source that emits a wavelength of 308 nm. The PHAROS Excimer Laser utilizes a XeCl gas mixture to generate an operator-selected dose and targetspecific UV light. The laser dose is activated by a footswitch with the therapeutic radiation emitting from a handheld device. The laser operation is key controlled and is contained within an interlocked housing.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Product Performance Testing: Testing conducted on the PHAROS EX-308 laser shows that it conforms to the relevant applicable standard.
Clinical Performance Testing: the indications requested have been previously cleared in predicate devices. The PHAROS EX-308 does not introduce any new indications for use, and will clinically perform equivalent to the predicate devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K993328 and K020973, K992914, K003705, K020847, and K011382, K041943, K011197, K020591 and K021762, K024020 and K022165, K041212

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 878.4810 Laser surgical instrument for use in general and plastic surgery and in dermatology.

(a)
Identification. (1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
(b)
Classification. (1) Class II.(2) Class I for special laser gas mixtures used as a lasing medium for this class of lasers. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 878.9.

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KO62963 510 (k) PRE-MARKET NOTIFICATION SUMMARY

General Information: This 510(k) provides notification of substantial equivalence for RA MEDICAL SYSTEMS, INC.'s PHAROS Excimer Laser, which is substantially equivalent to several previously marketed devices, including PhotoMedex's Xtrac AL7000 and AL8000, SurgiLight EX-308, and the Lumins BClear Photo Clearing System. It is intended for use in the treatment of psoriasis, vitiligo, atopic dermatitis, and leukoderma.

Submitted by: RA MEDICAL SYSTEMS, INC.

Address:

2270-L Camino Vida Roble Carlsbad, CA 92011

APR - 3 2007

Contact Person: Dean Irwin President

Date Prepared: 27 September 2006

Device Trade Name: PHAROS Excimer Laser EX-308

Device Common Name: XeCl excimer laser, excimer phototherapy laser.

Classification: Laser surgical instrument for use in general and plastic surgery and in dermatology (21 CFR §878.4810). Product Code: GEX

Predicate Device:

SurgiLight Inc. EX-308 Excimer Laser, 510(k) numbers: K993328 and K020973.

PhotoMedex XTRAC Excimer Laser, model AL7000, 510(k) numbers: K992914, K003705, K020847, and K011382 XTRAC Excimer Laser, model AL8000, 510(k) number: K041943

Lumins Inc. BClear Targeted PhotoClearing System, 510(k) numbers: K011197, K020591 and K021762.

TheraLight, Inc. Targeted UVA / UVB Phototherapy System, model UV120-2 UVA/UVB, 510(k) numbers: K024020 and K022165.

National Biological Corp. Houva 3 With PhotoSense II, 510(k) numbers K041212

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  • Device Description: RA Medical Systems, Inc.'s PHAROS Excimer Laser is a medical laser that is a self-contained UV laser light source that emits a wavelength of 308 nm. The PHAROS Excimer Laser utilizes a XeCl gas mixture to generate an operator-selected dose and targetspecific UV light. The laser dose is activated by a footswitch with the therapeutic radiation emitting from a handheld device. The laser operation is key controlled and is contained within an interlocked housing.
  • Intended Use: UVB phototherapy for the treatment of psoriasis, vitiligo, atopic dermatitis and leukoderma.
  • Substantial Equivalence: The PHAROS Excimer Laser, from both a design and clinical perspective, uses similar or identical technology as the cited predicate devices and has the same intended uses. Based upon the predicted overall performance characteristics for the PHAROS Excimer Laser, RA Medical Systems, Inc. believes that no significant differences exists between PHAROS and the cited predicate devices.
  • Product Performance Testing: Testing conducted on the PHAROS EX-308 laser shows that it conforms to the relevant applicable standard.
  • Clinical Performance Testing: the indications requested have been previously cleared in predicate devices. The PHAROS EX-308 does not introduce any new indications for use, and will clinically perform equivalent to the predicate devices.
  • Conclusions: The PHAROS EX-308 Excimer laser uses a similar or identical technology as the predicate devices. Therefore, RA Medicals Systems, Inc.'s PHAROS Excimer laser should not raise any concerns regarding the safety and effectiveness of the laser to treat psoriasis, vitiligo, atopic dermatitis and leukoderma. Ra Medical believes that the PHAROS EX-308 is substantially equivalent to the predicate devices.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized caduceus symbol, which is a staff with two snakes coiled around it. The logo also includes the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged in a circular pattern around the caduceus.

ood and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

RA Medical Systems, Inc. % Mr. Dean Irwin 2270-L Camino Vida Roble Carlsbad, California 92011

APR - 3 2007

Re: K062963

Trade/Device Name: PHAROS EX-308 Excimer Laser System Regulation Number: 21 CFR 878.4810 Regulation Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Regulatory Class: II Product Code: GEX Dated: March 6, 2007 Received: March 13, 2007

Dear Mr. Irwin:

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 such 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); 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.

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Page 2 - Mr. Dean Irwin

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 our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0115. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR 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 (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.

Sincerely yours

Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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510(k) Number (if known): KOOO 2963

Device Name:

PHAROS EX-308 Excimer Laser System

Indications for Use:

The PHAROS Excimer Laser will be indicated for use for the treatment of psoriasis, vitiligo, atopic dermatitis and leukoderma.

Prescription use X (Part 21 CFR 801 Subpart D)

AND/OR

Over-the-Counter Use (Part 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)

(Division Sign-Off)
Division of General, Restorative,
and Neurological Devices

510(k) Number 11062962