(70 days)
The Psoria-Light Model PS1000 is indicated for use in targeted PUVA photochemistry and UVB phototherapy for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis (eczema), and seborrheic dermatitis. In addition, the system UVB channel is indicated for the treatment of leukoderma.
Psoria-Light™ Model PS1000 delivers targeted ultraviolet (UV) light to small regions of affected skin (2.88 cm), sparring healthy skin. The system is capable of delivering either UVB light (300 to 320nm) or UVA light (350 to 395nm). Psoria-Light™ Model PS1000 generates both UVA and UVB light via LED technology, avoiding environmental concerns associated with disposal and exchange of mercury gas lamps, Xenon, and Chlorine gases commonly associated with targeted UV phototherapy devices. Psoria-Light's™ UVB LEDs emit light between 300 and 320 nm, avoiding light emissions below 300nm. Psoria-Light™ Model PS1000 incorporates a unique safety feature, a non-contact sensor located about the aperture of the handpiece that detects human skin. The trigger mechanism for UV dosage administration (located on the handpiece) is disabled until a suitable surface is detected by this sensor.
The Psoria-Light Model PS1000 is a targeted UVA/UVB phototherapy system for dermatologic disorders. The provided document is a 510(k) summary for the device, focusing on its substantial equivalence to previously cleared predicate devices rather than new clinical effectiveness studies.
1. Table of Acceptance Criteria and Reported Device Performance
| Acceptance Criteria | Reported Device Performance |
|---|---|
| Clinical Performance: | |
| New Indications for Use | No new indications for use introduced by Psoria-Light Model PS1000. All indications (psoriasis, vitiligo, atopic dermatitis (eczema), seborrheic dermatitis, and leukoderma for UVB) have been previously cleared for predicate devices. |
| Product Performance (Non-Clinical): | |
| Conformance to IEC 60601 series of standards | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
| Conformance to 21 CFR Part 1040.10 (Performance Standard for Light-Emitting Products) | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
| Certification to UL 60601-1 Medical Electrical Equipment classification standard | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
| Compliance with EMC requirements (FCC rules part 15, IEC 60601-1-2, EN55011) | The Psoria-Light Model PS1000 shall have completed all testing to these standards prior to sale. |
| Application of risk management per ISO 14971 | The Psoria-Light Model PS1000 has been reviewed for risk management utilizing ISO 14971, ensuring all aspects are reviewed for potential hazards. |
| Manufacturing in an FDA-registered facility | Products shall be produced and distributed by a facility that has been registered with the FDA to manufacture medical devices. |
| Substantial Equivalence: | |
| Equivalent design, composition, and function to predicate devices | The characteristics of the Psoria-Shield Psoria-Light Model PS1000 are substantially equivalent to those of the predicate devices (TheraLight Inc. DuaLight UV120-2, PhotoMedex, Inc. XTRAC Ultra2 Excimer Laser System). |
| Equivalent output wavelengths, power, and light sources to predicate devices | Operation of the predicate devices, including output wavelengths, power, and light sources, received 510(k) clearance previously. The Psoria-Light Model PS1000 performs in a substantially equivalent manner. |
2. Sample Size Used for the Test Set and Data Provenance
No clinical performance test set (i.e., patient data) was used for this 510(k) submission. The submission explicitly states that "duplicative clinical data is not required as a condition of granting market clearance" because the device does not introduce new indications for use and performs in a substantially equivalent manner to predicate devices. The "study" for acceptance criteria was based on demonstrating substantial equivalence to these previously cleared devices through non-clinical performance testing and comparison of device specifications.
3. Number of Experts Used to Establish the Ground Truth for the Test Set and Qualifications of Those Experts
Not applicable. No clinical test set requiring expert ground truth was employed for this 510(k) submission. The device's safety and effectiveness were argued based on substantial equivalence to predicate devices, which had presumably undergone such evaluations during their own clearance processes.
4. Adjudication Method for the Test Set
Not applicable. No clinical test set requiring adjudication was employed.
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
Not applicable. This device is a phototherapy system, not an AI-assisted diagnostic or interpretive tool. Therefore, an MRMC study related to human reader performance with or without AI assistance is not relevant.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) Was Done
Not applicable. This device is a hardware phototherapy system, not an algorithm. Its performance is evaluated based on its physical characteristics, light output, and compliance with safety and electrical standards.
7. The Type of Ground Truth Used
For the non-clinical product performance testing, the "ground truth" would be established by the specifications and requirements of the referenced international and national standards (e.g., IEC 60601, 21 CFR Part 1040.10, UL 60601-1, ISO 14971, FCC rules). The device's performance is measured against these established engineering and safety benchmarks. For the clinical indications, the "ground truth" was established by the previous 510(k) clearances of the predicate devices, which had demonstrated clinical effectiveness for the stated indications.
8. The Sample Size for the Training Set
Not applicable. This device is a hardware phototherapy system and does not involve AI or machine learning that would require a 'training set.'
9. How the Ground Truth for the Training Set Was Established
Not applicable. No training set was used.
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FEB 10 20il
ENCLOSURE E
Non-Confidential 510(k) Summary of Safety and Effectiveness
Psoria-Shield Inc. 6408 W. Linebaugh Avenue Suite 104 Tampa, FL 33625
| Official Contact: | Scot JohnsonChief Technology Officer |
|---|---|
| Trade/Device Name: | Psoria-Light Model PS1000 |
| Device Common Name: | Targeted UVA / UVB Phototherapy System |
| Regulation Number: | 878.4630 |
| Regulation Name: | Ultraviolet lamp for dermatologic disorders |
| Regulatory Class: | Class II |
| Product Code: | FTC |
| Predicate Devices: | This product is substantially equivalent in design,composition, and function to: |
| TheraLight Inc.DuaLight UV120-2 UVA/UVB Phototherapy SystemK024020 | |
| PhotoMedex, Inc.XTRAC Ultra2 Excimer Laser System, Model AL10000K073659 |
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pg 2 of 3
ENCLOSURE E
Non-Confidential 510(k) Summary of Safety and Effectiveness
Device Description:
Psoria-Light™ Model PS1000 delivers targeted ultraviolet (UV) light to small regions of affected skin (2.88 cm), sparring healthy skin. The system is capable of delivering either UVB light (300 to 320nm) or UVA light (350 to 395nm). Psoria-Light™ Model PS1000 generates both UVA and UVB light via LED technology, avoiding environmental concerns associated with disposal and exchange of mercury gas lamps, Xenon, and Chlorine gases commonly associated with targeted UV phototherapy devices. Psoria-Light's™ UVB LEDs emit light between 300 and 320 nm, avoiding light emissions below 300nm.
Psoria-Light™ Model PS1000 incorporates a unique safety feature, a non-contact sensor located about the aperture of the handpiece that detects human skin. The trigger mechanism for UV dosage administration (located on the handpiece) is disabled until a suitable surface is detected by this sensor.
Labeling and Instructions for Use:
See Proposed Labeling and Instructions for Use in sections J and Q respectively.
Intended Use:
The Psoria-Light Model PS1000 is indicated for use in targeted PUVA photochemistry and UVB phototherapy for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis (eczema), and seborrheic dermatitis. In addition, the system UVB channel is indicated for the treatment of leukoderma.
Substantial Equivalence:
The characteristics of the Psoria-Shield Psoria-Light Model PS1000 are substantially equivalent to those of the predicate devices. Operation of the predicate devices, including output wavelengths, power, and light sources have received 510(k) clearance previously for these type of treatments.
Clinical Performance Testing:
All clinical indications requested in this application have been previously cleared in the identified predicate devices. The Psoria-Light Model PS1000 does not introduce any new indications for use, and will perform in a substantially equivalent manner as the identified predicates. Therefore Psoria-Shield believes duplicative clinical data is not required as a condition of granting market clearance for the Psoria-Light Model PS1000.
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pg 3 of 3
ENCLOSURE E
Non-Confidential 510(k) Summary of Safety and Effectiveness
Product Performance Testing:
Testing and certification relevant to the Psoria-Light Model PS1000 includes conformance to current applicable international IEC 60601 series of standards, 21 CFR Part 1040.10, Performance Standard for Light-Emitting Products and certification to the UL 60601-1 Medical Electrical Equipment classification standard. Product will also comply with EMC (Electromagnetic Compatibility) requirements per FCC rules part 15, IEC 60601-1-2 and its particular Standards for susceptibility and emissions, as well as EN55011. The Psoria-Light Model PS1000 has been reviewed for risk management utilizing ISO 14971, Application of risk management to medical devices ensuring all aspects of the device are reviewed for potential hazards.
The Psoria-Light Model PS1000 shall have completed all testing to the standards and procedures identified in this submission prior to any product being released for sale. Products shall be produced and distributed by a facility that has been registered with the FDA to manufacture medical devices.
Conclusions:
The comparison to the predicate devices demonstrates that the proposed device is safe and effective and is Substantially Equivalent to the predicate devices and it does not introduce any new issues of safety or efficacy. The Indications for Use and methods of operation are substantially equivalent to the predicates for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis (eczema), seborrheic dermatitis, and of leukoderma.
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Image /page/3/Picture/1 description: The image shows the logo for the U.S. Department of Health and Human Services. The logo consists of a stylized eagle-like symbol with three curved lines representing the body and wings. The text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular fashion around the symbol.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
Psoria-Shield. Inc. % Technireg, Inc. Mr. Wayne Glover 19404 Pine Valley Drive Odessa, Florida 33556
FEB 10 201
Re: K103540
Trade/Device Name: Psoria-Light Model PS 1000 Regulation Number: 21 CFR 878.4630 Regulation Name: Ultraviolet lamp for dermatologic disorders Regulatory Class: Class II Product Code: FTC Dated: November 30, 2010 Received: December 02, 2010
Dear Mr. Glover:
and the comments of the comments of the comments of
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, Orug, 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 Ice 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.
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
a participal production in the lineral in
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Page 2 – Mr. Wayne Glover
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/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.
A.S. B. R. h
for
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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ENCLOSURE D
INDICATIONS FOR USE
510(k) Number (if known):
Device Name:
Psoria-Light Model PS1000
Indications for Use:
The Psoria-Light Model PS1000 is indicated for use in targeted PUVA photochemistry and UVB phototherapy for the treatment of skin conditions including psoriasis, vitiligo, atopic dermatitis (eczema), and seborrheic dermatitis. In addition, the system UVB channel is indicated for the treatment of leukoderma.
Prescription Use X (Per 21 CFR 801 Subpart D) and/or
Over-the-counter use (Per 21 CFR 801 Subpart C)
PJ
Tofal
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Nut ReQs for mxm
(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number K103540
§ 878.4630 Ultraviolet lamp for dermatologic disorders.
(a)
Identification. An ultraviolet lamp for dermatologic disorders is a device (including a fixture) intended to provide ultraviolet radiation of the body to photoactivate a drug in the treatment of a dermatologic disorder if the labeling of the drug intended for use with the device bears adequate directions for the device's use with that drug.(b)
Classification. Class II.