K Number
K141046
Device Name
MIDI-SRS
Manufacturer
Date Cleared
2014-12-24

(245 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
MiDi-SRS is intended for use in dermatological procedures requiring the coagulation of soft tissue.
Device Description
MiDi-SRS is designed to provide laser energy (1550nm) for use in a variety of dermatology and general surgery procedures. The product consists of main body, a tablet PC, a foot switch, an interlock switch and a key switch. The device fires a 1550nm Er- glass Fiber laser beam which is then split into a number of microscopic beams, producing tiny dot, or pixel-like treatment zones within the selected target area of the skin, leaving the other zones within it perfectly intact.
More Information

Not Found

No
The summary describes a laser device for dermatological procedures and does not mention any AI or ML capabilities.

Yes
The device is intended for dermatological procedures requiring the coagulation of soft tissue, which is a therapeutic action.

No
The device description states its intended use is for "dermatological procedures requiring the coagulation of soft tissue" and to "provide laser energy...for use in a variety of dermatology and general surgery procedures," which are therapeutic applications, not diagnostic ones.

No

The device description explicitly lists multiple hardware components including a main body, tablet PC, foot switch, interlock switch, and key switch, and describes the device as providing laser energy.

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

Here's why:

  • Intended Use: The intended use is for "dermatological procedures requiring the coagulation of soft tissue." This describes a therapeutic or surgical procedure performed directly on a patient's body (in vivo).
  • Device Description: The device delivers laser energy to the skin. This is a physical intervention, not a test performed on a sample taken from the body (in vitro).
  • Lack of IVD Characteristics: The description does not mention analyzing biological samples (blood, tissue, etc.) or providing diagnostic information based on such analysis.

IVD devices are used to examine specimens derived from the human body to provide information for diagnostic, monitoring, or compatibility purposes. The MiDi-SRS device's function is to directly treat tissue, which falls outside the scope of IVD.

N/A

Intended Use / Indications for Use

MiDi-SRS is intended for use in dermatological procedures requiring the coagulation of soft tissue.

Product codes

ONG, GEX

Device Description

MiDi-SRS is designed to provide laser energy (1550nm) for use in a variety of dermatology and general surgery procedures. The product consists of main body, a tablet PC, a foot switch, an interlock switch and a key switch. The device fires a 1550nm Er-glass Fiber laser beam which is then split into a number of microscopic beams, producing tiny dot, or pixel-like treatment zones within the selected target area of the skin, leaving the other zones within it perfectly intact.

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

Bench tests were performed according to EN 60601-2-22, 60601-1 and 60601-1-2 to evaluate its safety and EMC. All the test results met pre-set criteria and support substantial equivalence to the predicate devices.

In vivo animal testing using porcine models was also conducted to obtain histological data of values for depth and zone of ablation and thermal damage immediately post treatment; 3-5 days post treatment; and 10-14 days post treatment. The test results are as below and supports that the subject device would perform as well as the predicate device.

Microscopic treatment zones (MTZs)
Measurement value (µm)
Measured width (S.D.), Measured depth (S.D.), Thermal zone: lateral, Thermal zone: depth

G1 0:
10mJ: 17, 17, 151, 205
20mJ: 33, 34, 226, 290
30mJ: 29, 36, 277, 325

G2 3:
10mJ: 17, 64, 19, 57
20mJ: 13, 16, 42, 132
30mJ: 3, 10, 32, 104

G3 10:
10mJ: 0, 0, 0, 0
20mJ: 0, 0, 0, 0
30mJ: 0, 0, 0, 0

G4 15:
10mJ: 0, 0, 0, 0
20mJ: 0, 0, 0, 0
30mJ: 0, 0, 0, 0

Key Metrics

Not Found

Predicate Device(s)

K080382

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

December 23, 2014

SRMC Company, LTD % Ms. Priscilla Chung LK Consulting Group USA Incorporated 2651 East Chapman Avenue, Suite 110 Fullerton, California 92831

Re: K141046 Trade/Device Name: MiDi-SRS 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: ONG and GEX Dated: November 26, 2014 Received: December 2, 2014

Dear Ms. Chung:

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.

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

1

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 contact the Division of Industry and Consumer Education 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. 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 Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

David Krause -S

for

Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K141046

Device Name MiDi-SRS

Indications for Use (Describe)

MiDi-SRS is intended for use in dermatological procedures requiring the coagulation of soft tissue.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

| Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary (K141046)

This summary of 510(k)-safety and effectiveness information is being submitted in accordance with requirements of 21 CFR Part 807.92.

Date:

1. Applicant / Submitter:

SRMC CO., LTD 7F, 1130, 2 Sunhwan-ro, Heungdeok-gu, Cheongju-si, Chungcheongbuk-do,361-825, Republic of KOREA

Tel: +82-43-255-9595 Fax: +82-43-255-5551

2. Submission Correspondent:

Priscilla Chung LK Consulting Group USA, Inc. 2651 E Chapman Ave Ste 110. Fullerton, CA 92831 Phone: 714-202-5789 Fax: 714-409-3357 Email: juhee.c@lkconsultinggroup.com

3. Device:

Proprietary Name:MiDi-SRS
Common Name:Laser Surgical Unit
Classification Name:Powered Laser Surgical Instrument
Classification:Class II, 21 CFR 878.4810
Classification Product Code:ONG

Predicate Device: 4.

SellaS by Dinona Company, Ltd. (K080382)

5. Device Description:

MiDi-SRS is designed to provide laser energy (1550nm) for use in a variety of dermatology and general surgery procedures. The product consists of main body, a tablet PC, a foot switch, an interlock switch and a key switch. The device fires a 1550nm Er- glass Fiber laser beam which is

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then split into a number of microscopic beams, producing tiny dot, or pixel-like treatment zones within the selected target area of the skin, leaving the other zones within it perfectly intact.

Intended Use: 6.

MiDi-SRS is intended for use in dermatological procedures requiring the coagulation of soft tissue.

7. Performance Data(Non-Clinical):

Bench tests were performed according to EN 60601-2-22, 60601-1 and 60601-1-2 to evaluate its safety and EMC. All the test results met pre-set criteria and support substantial equivalence to the predicate devices.

In vivo animal testing using porcine models was also conducted to obtain histological data of values for depth and zone of ablation and thermal damage immediately post treatment; 3-5 days post treatment; and 10-14 days post treatment. The test results are as below and supports that the subject device would perform as well as the predicate device.

| Group /
Excision

daysMicroscopic treatment zones (MTZs)
Measurement value (µm)
Measured
width
(S.D.)Measured
depth
(S.D.)Thermal
zone: lateralThermal
zone: depth
G1
010mJ1717151205
20mJ3334226290
30mJ2936277325
G2
310mJ17641957
20mJ131642132
30mJ31032104
G3
1010mJ0000
20mJ0000
30mJ0000
G4
1510mJ0000
20mJ0000
30mJ0000

8. Substantial Equivalence

The MiDi-SRS is substantially equivalent to the predicate device in terms of indication for use and technology based on technical characteristics. The two devices are similar in the following

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characteristics: intended use, spot size, wave length, aiming beam, power output, energy range, output mode, laser type, and beam mode. The major difference is in the user interface, however, the SW validation report provided in the submission supports that the touch screen tablet SW of the Midi-SRS is substantially equivalent to the predicate device in effectiveness.

9. Conclusion:

Based on the substantial equivalence discussion and testing results, SRMC CO., LTD concludes that the MiDi-SRS is substantially equivalent to the predicate devices in safety and effectiveness.