(80 days)
The CoolTouch Model CT3PZ Nd:YAG Surgical Laser is indicated for the following:
for use in dermatology for incision, excision, ablation and vaporization with hemostasis of soft tissue;
for treatment of fine lines and wrinkles;
for treatment of mild to moderate inflammatory acne vulgaris;
for treatment of back acne and atrophic acne scars, and;
for podiatry (ablation, vaporization, incision, excision, and coagulation of soft tissue) including:
o matrixectomy
o periungal and subungal warts
o plantar warts
o radical nail excision
o neuromas
The CoolTouch CT3PZ Laser System is an Nd:YAG laser producing laser emission at 1320 nm. The laser consists of a cabinet which houses the power supply, the cooling system, microcontroller, laser, foot switch, and the fiber optic for delivery of the laser energy with fiber optic handpiece setup.
Here's an analysis of the provided text regarding the acceptance criteria and study for the CoolTouch CT3PZ/CoolTouch CT3 Plus CoolBreeze Nd:YAG Surgical Laser system:
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria (Implied) | Reported Device Performance |
|---|---|
| Substantial Equivalence to Predicate Devices | "The CoolTouch CT3PZ Nd:YAG Laser System is substantially equivalent to the predicate devices for the indications requested." |
| Effective for use in podiatry | "Bench testing data produced results that indicate the CT3PZ is effective for use in podiatry." |
| Same principle of operation as predicate devices | "The Cooltouch CT3PZ has the same principle of operation... as the predicate devices." |
| Same wavelength as predicate devices | "The Cooltouch CT3PZ has... the same wavelength... as the predicate devices." |
| Essentially the same pulse energy rate as predicate devices | "The Cooltouch CT3PZ has... essentially the same pulse energy rate as the predicate devices." |
2. Sample Size Used for the Test Set and Data Provenance
- Test Set Sample Size: Not applicable. The submission relies entirely on nonclinical (bench) testing and comparison to predicate devices, not patient data in a "test set" in the context of clinical trials.
- Data Provenance: The "Bench testing data" would have been generated internally by New Star Lasers, Inc. (d.b.a. CoolTouch, Inc.). The document does not specify the country of origin for this testing but implies it was conducted by the manufacturer. It is retrospective in the sense that it's reported data, not actively collected during an FDA review process.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
- Not applicable. As this is a premarket notification for a laser system with nonclinical testing and substantial equivalence as the basis, there was no "ground truth" derived from expert consensus on patient data. The "ground truth" for the bench testing would be the physical measurements taken by the engineers/technicians according to established protocols.
4. Adjudication Method for the Test Set
- Not applicable. There was no "test set" of patient cases requiring adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No. This is a 510(k) submission for a surgical laser, not an AI/software device. There is no mention of AI or MRMC studies.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done
- No. This device is a laser system, not an algorithm.
7. The Type of Ground Truth Used
- Bench Test Results: The "ground truth" for the nonclinical performance data would be the objective measurements and observations from the bench testing (e.g., laser output power, wavelength, pulse characteristics) against the product specifications and the characteristics of the predicate devices.
- Predicate Device Characteristics: The characteristics and performance of the legally marketed predicate devices serve as the "ground truth" for the substantial equivalence claim.
8. The Sample Size for the Training Set
- Not applicable. There is no concept of a "training set" for this type of device submission. The device is not learning from data in the way an AI algorithm would.
9. How the Ground Truth for the Training Set Was Established
- Not applicable. No training set was used.
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K/01783
SEP 1 3 2010
Premarket Notification 510(k) Summary (As Required by 21 CFR 807.93)
This 510(k) Summary of safety and effectiveness for the New Star Model CoolTouch CT3PZ/CoolTouch CT3 Plus CoolBreeze Nd:YAG Surgical Laser system is submitted in accordance with the requirements of the SMDA 1990 and following guidance concerning the organization and content of a 510(k) summary.
| Submitter: | New Star Lasers, Inc. d.b.a. CoolTouch, Inc. |
|---|---|
| Address: | 9085 Foothills BoulevardRoseville, CA 95747 |
| Contact Person: | Natalie VollrathQuality and Regulatory Manager |
| Telephone/Fax/Email: | (916) 677-1912 - Phone(916) 677-1901 - Faxnvollrath@newstarlasers.com - Email |
| Date prepared: | June 24, 2010 |
| Device Trade Name: | CoolTouch CT3PZ/CoolTouch CT3 Plus CoolBreezeNd:YAG Surgical Laser |
| Common Name: | Nd: YAG Surgical Laser |
| Classification Name: | Instrument, surgical, powered, laser79-GEX -21 CFR §878.4810 |
| Legally Marketed Predicate Devices: | CoolTouch CT3 Nd:YAG laser systemCoolTouch CT3S Nd:YAG laser systemCoolTouch Varia Nd:YAG laser systemPatholase PinPointe FootLaser Nd:YAG laser system |
| Device Description: | The CoolTouch CT3PZ Laser System is an Nd:YAG laserproducing laser emission at 1320 nm. The laser consists of acabinet which houses the power supply, the cooling system,microcontroller, laser, foot switch, and the fiber optic fordelivery of the laser energy with fiber optic handpiece setup. |
| Intended Use: | For use in dermatology for incision, excision, ablation, andvaporization with hemostasis of soft tissue; for treatment offine lines and wrinkles; for mild to moderate inflammatoryacne vulgaris; for back acne and atrophic scarring, and; forpodiatry, (incision, excision, and coagulation of soft tissue)including matrixectomy, periungal and subungal warts,plantar warts, radical nail excision, and neuromas. |
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| Comparison: | The Cooltouch CT3PZ has the same principle of operation,the same wavelength and essentially the same pulse energyrate as the predicate devices. |
|---|---|
| Nonclinical Performance Data | Bench testing data produced results that indicate the CT3PZis effective for use in podiatry. |
| Clinical Performance Data: | None |
| Conclusion: | The CoolTouch CT3PZ Nd:YAG Laser System issubstantially equivalent to the predicate devices for theindications requested. |
| Additional Information: | None requested at this time. |
:
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DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/2/Picture/1 description: The image shows the seal of the U.S. Department of Health & Human Services. The seal features a stylized eagle with its wings spread, symbolizing protection and service. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" are arranged in a circular pattern around the eagle.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
New Star Lasers, Inc. % Ms. Natalie R. Vollrath Quality and Regulatory Manager 9085 Foothills Boulevard Roseville, California 95747
SEP 1 8 2010
Re: K101783
Trade/Device Name: CoolTouch CT3PZ/CoolTouch CT3 Plus CoolBreeze Regulation Number: 21 CFR 878.4810 Regulation Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Regulatory Class: Class II Product Code: GEX Dated: September 02, 2010 Received: September 07, 2010
Dear Ms. Vollrath:
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. 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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Page 2 - Ms. Natalie R. Vollrath
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 device-related adverse events) (21 CFR 803); 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.
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 (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely vours.
Mark N. Melkerson Director Division of Surgical, Orthopedic And Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Indications for Use Statement
510(k) Number
SEP 1 8 2010
| Device Name | CoolTouch CT3PZ/CoolTouch CT3 Plus CoolBreeze | |
|---|---|---|
| Indications forUse | The CoolTouch Model CT3PZ Nd:YAG Surgical Laser isindicated for the following: | |
| for use in dermatology for incision, excision, ablation and•vaporization with hemostasis of soft tissue; | ||
| for treatment of fine lines and wrinkles; | ||
| for treatment of mild to moderate inflammatory acne•vulgaris; | ||
| for treatment of back acne and atrophic acne scars, and; | ||
| for podiatry (ablation, vaporization, incision, excision, andcoagulation of soft tissue) including:o matrixectomyo periungal and subungal wartso plantar wartso radical nail excisiono neuromas | ||
| Prescription Use X(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)
Neil RP dyke for mxm
(sin off)
(Division Sign-Off) (Division Sign-Olf)
Division of Surgical, Orthopedic, Orthopedic, Division of Surgices Division of Sure
and Restorative Devices
510(k) Number K101783
Page 1 of _1
§ 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.