K Number
K152529
Device Name
NaturaLase CO2 Laser System
Manufacturer
Date Cleared
2016-02-04

(154 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
NaturaLase CO2 laser operating in tractionated mode is indicated for incision, excision, ablation, vaporization, and coagulation of body soft tissues including intraoral tissues, in medical specialties including aesthetic (dermatology and plastic surgery), otolaryngology (ENT), gynecology, neurosurgery, dental and oral surgery and genitourinary surgery. NaturaLase CO2 laser operating in fractional mode is indicated for ablative skin resurfacing.
Device Description
The NaturaLase CO2 is an RF excited CO2 laser. The main console of the NaturaLase CO2 laser system contains the following components: - CO2 laser tube - Power Supply - Optical bench assembly - Articulated Arm - Hand-pieces: scanning and surgical - Touch screen controller/user interface The laser source is a sealed CO2 laser tube that is mounted vertically within the main cabinet and the laser beam is passed from the laser tube into the articulated arm. The NaturaLase CO2 laser unit is equipped with a switching-mode power supply, which converts the input line voltage to the high voltage required for laser operation. The optical bench assembly consists of the articulated arm mount, the aiming beam diode laser (3mW @ 650nm) and optics to align the laser beam and the aiming beam to the articulated arm. The laser energy is delivered through an articulated arm to a hand-piece (scanner or surgical) that distributes the laser energy on the target in a controlled and uniformed way. The user-interface microprocessor-based touch screen allows operator to control all operating functions.
More Information

Not Found

No
The device description and summary of performance studies focus on the hardware components, laser technology, and standard electrical and safety testing. There is no mention of AI, ML, image processing, or any data-driven algorithms that would suggest the use of AI/ML.

Yes
The device is used for incision, excision, ablation, vaporization, and coagulation of body soft tissues for various medical specialities, which are therapeutic actions.

No

The device description and intended use clearly state that the NaturaLase CO2 laser is used for surgical procedures (incision, excision, ablation, vaporization, coagulation) and skin resurfacing, which are therapeutic and not diagnostic functions.

No

The device description clearly outlines multiple hardware components including a laser tube, power supply, optical bench assembly, articulated arm, and hand-pieces. While it mentions a software-based touch screen controller, the device is fundamentally a hardware system that utilizes software for control.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information for diagnosis, monitoring, or screening.
  • Device Function: The NaturaLase CO2 laser is described as a surgical laser used for incision, excision, ablation, vaporization, and coagulation of body soft tissues. It directly interacts with the patient's body during a procedure.
  • Lack of Specimen Analysis: There is no mention of this device analyzing any biological specimens taken from the patient. Its function is to deliver laser energy to tissue.

Therefore, the NaturaLase CO2 laser falls under the category of a therapeutic or surgical device, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

NaturaLase CO2 laser operating in tractionated mode is indicated for incision, excision, ablation, vaporization, and coagulation of body soft tissues including intraoral tissues, in medical specialties including aesthetic (dermatology and plastic surgery), otolaryngology (ENT), gynecology, neurosurgery, dental and oral surgery and genitourinary surgery.

NaturaLase CO2 laser operating in fractional mode is indicated for ablative skin resurfacing.

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

GEX, ONG

Device Description

The NaturaLase CO2 is an RF excited CO2 laser. The main console of the NaturaLase CO2 laser system contains the following components:

  • CO2 laser tube
  • Power Supply
  • Optical bench assembly
  • Articulated Arm
  • Hand-pieces: scanning and surgical
  • Touch screen controller/user interface

The laser source is a sealed CO2 laser tube that is mounted vertically within the main cabinet and the laser beam is passed from the laser tube into the articulated arm. The NaturaLase CO2 laser unit is equipped with a switching-mode power supply, which converts the input line voltage to the high voltage required for laser operation. The optical bench assembly consists of the articulated arm mount, the aiming beam diode laser (3mW @ 650nm) and optics to align the laser beam and the aiming beam to the articulated arm. The laser energy is delivered through an articulated arm to a hand-piece (scanner or surgical) that distributes the laser energy on the target in a controlled and uniformed way. The user-interface microprocessor-based touch screen allows operator to control all operating functions.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

body soft tissues including intraoral tissues, skin

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)

All performance testing demonstrated that the NaturaLase CO2 laser performs according to specifications and functions as intended. The NaturaLase CO2 laser system was determined to be in conformance with all applicable standards. Electrical safety and electromagnetic compatibility (EMC) testing for the NaturaLase CO2 laser system was conducted by an independent laboratory in accordance with IEC 60601-1. Medical electrical equipment, part 1: general requirements for basic safety and essential performance. The NaturaLase CO2 laser was determined to be in conformance with applicable IEC standards (IEC 62366, 60601-1-6, 60601-1-6, 60601-2-22, and IEC 60825-1). The biocompatibility of the NaruraLase CO2 laser is consistent with the ISO 10993.

Software verification and validation testing results are acceptable for software release.

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.

K110333, K123573

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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Image /page/0/Picture/0 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with flowing lines representing hair or clothing.

Public Health Service

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

February 4, 2016

Focus Medical, LLC % Michail Pankratov Principal MMP Medical Associates LLC 16 Appleton Street Waltham, Massachusetts 02453

Re: K152529

Trade/Device Name: Naturalase Co2 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: Class II Product Code: GEX. ONG Dated: January 7, 2016 Received: January 8, 2016

Dear Michail Pankratov:

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 CFR

1

Part 807); labeling (21 CFR Part 801); medical device reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) 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/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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,

Jennifer R. Stevenson -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)

Device Name NaturaLase CO2 Laser System

Indications for Use (Describe)

NaturaLase CO2 laser operating in tractionated mode is indicated for incision, excision, ablation, vaporization, and coagulation of body soft tissues including intraoral tissues, in medical specialties including aesthetic (dermatology and plastic surgery), otolaryngology (ENT), gynecology, neurosurgery, dental and oral surgery and genitourinary surgery.

NaturaLase CO2 laser operating in fractional mode is indicated for ablative skin resurfacing.

Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

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510(K) SUMMARY

As required by section 21 CFR 807.92

I. General Information

Applicant:Focus Medical, LLC
2 Francis J Clarke Circle
Bethel, CT 06801
TEL: 203-730-8885
FAX: 203-730-8851
Contact Person:Michail M. Pankratov, MD, PhD
MMP Regulatory Consultants, LLC
16 Appleton Street
Waltham, MA 02453
TEL: 617-480-4543
clregconsult@aol.com
Preparation Date:August 26, 2015

II. Device Information

Trade Name:NaturaLase CO2 Laser System
Common/Usual Name:CO2 Laser System
Classification:Class II
Regulation Number:878.4810
Product Code:GEX; ONG
Classification Name:Powered Laser Surgical Instrument
Review Panel:General & Plastic Surgery
Predicate Devices:K110333 - NaturaLase CO2 Laser System, Focus
Medical
LLC; K123573 – YOULASER CO2 Laser System, Quanta
System S.P.A.

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III. Device Description:

The NaturaLase CO2 is an RF excited CO2 laser. The main console of the NaturaLase CO2 laser system contains the following components:

  • CO2 laser tube
  • Power Supply
  • Optical bench assembly
  • Articulated Arm
  • Hand-pieces: scanning and surgical
  • Touch screen controller/user interface

The laser source is a sealed CO2 laser tube that is mounted vertically within the main cabinet and the laser beam is passed from the laser tube into the articulated arm. The NaturaLase CO2 laser unit is equipped with a switching-mode power supply, which converts the input line voltage to the high voltage required for laser operation. The optical bench assembly consists of the articulated arm mount, the aiming beam diode laser (3mW @ 650nm) and optics to align the laser beam and the aiming beam to the articulated arm. The laser energy is delivered through an articulated arm to a hand-piece (scanner or surgical) that distributes the laser energy on the target in a controlled and uniformed way. The user-interface microprocessor-based touch screen allows operator to control all operating functions.

IV. Indication for Use:

NaturaLase CO2 laser operating in traditional non-fractionated mode is indicated for incision, excision, ablation, vaporization, and coagulation of body soft tissues including intraoral tissues, in medical specialties including aesthetic (dermatology and plastic surgery), otolaryngology (ENT), gynecology, urology, neurosurgery, dental and oral surgery and genitourinary surgery. NaturaLase CO2 laser operating in fractional mode is indicated for ablative skin resurfacing.

V. Technological Characteristics:

The NaturaLase CO2 laser technical specifications are very similar to the predicate devices. All have the same intended use, technological characteristics and operating principles as the previously cleared NaturaLase CO2 Laser system (K110333) and Quanta System YOULASER Laser System (K123573). The NaturaLase CO2 laser design and components are very similar to those of the predicate devices. Their treatment handpieces connected to the articulated arm that is connected to the main console where the user interface is located. Differences between the NaturaLase CO2 laser and predicate devices in specific maximum energy levels and fluence delivered do not raise any new safety or effectiveness issues because the NaturaLase CO2 laser parameters fall within the range of parameters delivered by the predicate devices.

VI. Testing Performance

All performance testing demonstrated that the NaturaLase CO2 laser performs according to specifications and functions as intended. The NaturaLase CO2 laser system was determined to be in conformance with all applicable standards. Electrical safety and electromagnetic compatibility (EMC) testing for the NaturaLase CO2 laser system was conducted by an independent laboratory

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in accordance with IEC 60601-1. Medical electrical equipment, part 1: general requirements for basic safety and essential performance. The NaturaLase CO2 laser was determined to be in conformance with applicable IEC standards (IEC 62366, 60601-1-6, 60601-1-6, 60601-2-22, and IEC 60825-1). The biocompatibility of the NaruraLase CO2 laser is consistent with the ISO 10993.

Software verification and validation testing results are acceptable for software release.

VII. Summary of Substantial Equivalence

Review of the technological characteristics for the primary predicate device and the NaturaLase CO2 Laser shows close similarity in parameters principally for generating tissue effects (see Table below).

The NaturaLase CO2 laser has the same intended use as the predicate devices with similar indications for use. It presents similar technological characteristics as the predicate devices including the laser type, wavelengths, device design, pulse width, frequency, spot sizes and system components. Few differences between the NaturaLase CO2 laser and its predicate devices in terms of maximum pulse energy, fluence, pulse duration, etc, do not present any new concerns of safety and effectiveness. The NaturaLase CO2 laser and its predicates all operate with the same mechanism of action based on selective photothermolysis. Therefore, the NaturaLase CO2 laser has the same intended use and similar indications for use, technological characteristics, and principles of operation as predicate devices. The NaturaLase CO2 laser is substantially equivalent to the predicate devices.

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510(k)K123573K110333
ManufacturerQuanta System S.P.AFocus Medical LLCFocus Medical LLC
Device NameYOULASER CO2 LaserNaturaLase CO2NaturaLase CO2
Device
Classification
NamePowered Laser Surgical
InstrumentPowered Laser Surgical
Instrument
Microbeam/Fractional OutputPowered Laser Surgical
Instrument
Microbeam/Fractional Output
Regulation Number878.4810878.4810878.4810
Product CodeGEXONGGEX, ONG
Laser SourceCO2CO2CO2
Wavelength10.6 μm10.6 μm10.6 μm
PowerUp to 30 WUp to 30 WUp to 30 W
Pulse
widthFraction0.2 - 20 ms0.2-10 ms0.2-10 ms
Surgical0.5 – 80 ms-.2 to 10ms
Spot SizeFraction300 μm120 and 300 μm120 and 300 μm
Surgical200, 400, 1000 μm300 μm
Energy EmissionPulse/single pulse/cwPulse/single pulse/cwPulse/single pulse/cw
Energy to tissue10-45 mJ per micro spot10-45 mJ per micro spot
Peak power60 W60 W
Aiming beamYOULASER CO2 laser when
used in fractional mode (dot
scanner) is indicated for ablative
skin resurfacingfractional spot sizes are used in the
treatment of wrinkles; rhytides,
furrows, fine lines, textural
irregularities, pigmented lesions
and vasculardyschromia.specialties including aesthetic
(dermatology and plastic surgery),
otolaryngology
(ENT),
urology,
neurosurgery, dental and oral surgery
and genitourinary surgery.
NATURALASE CO2 laser
operating in fractional mode is
indicated for ablative skin
resurfacing.
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Device Description
The YOULASER CO2 Laser
System includes a single model
named YOULASER CO2 emitting
a maximum power of
30 Watt at 10.6 µm. The
YOULASER CO2 Laser
composed externally of metallic
shell with a frontal polyurethane
panel containing the touch screen
display. On this panel the key
switch, emergency red push button
and the operation led are inserted
too. On the rear panel the
footswitch connector, the remote
interlock, the power switch are
located. The system is composed
of power supply, CO2 laser source
with air cooling system, optical
bench, articulated arm with CO2
scanner, the control electronics.
The electronic, based on a
microcontroller, manages the
voltage power supply and the CO2
laser source.The NaturaLase CO2 is an RF
excited CO2 laser. The laser energy
is delivered through an articulated
arm and with a scanner, that
distributes the laser energy on the
skin in a controlled way with
uniform distribution. The scanner
design allows the system to ablate
small micro spots of tissue. The
system has the ability to deliver
micro spots with a size of 120
microns and up to 45 mJ of optical
energy per micro spot.
The NaturaLase CO2 laser system
consists of
-CO2 laser tube,
-Power supply,
-Closed loop cooling system,
  • user interface control
  • an articulated arm
  • a scanning hand piece
  • a traditional hand piece | The NaturaLase CO2 is an RF
    excited CO2 laser. The laser energy
    is delivered through an articulated
    arm and with a scanner, that
    distributes the laser energy on the
    skin in a controlled way with
    uniform distribution. The scanner
    design allows the system to ablate
    small micro spots of tissue. The
    system has the ability to deliver
    micro spots with a size of 120
    microns and up to 45 mJ of optical
    energy per micro spot.
    The NaturaLase CO2 laser system
    consists of
    -CO2 laser tube,
    -Power supply,
    -Closed loop cooling system,
  • user interface control
  • an articulated arm
  • a scanning hand piece
  • a traditional hand piece |