(88 days)
No
The description focuses on hardware components (IPL, microcurrents, sensors) and standard safety/performance testing, with no mention of AI/ML algorithms or data processing for learning or adaptation.
No.
The device is intended for hair removal and facial stimulation for aesthetic use, not for treating, diagnosing, or preventing a disease or condition.
No
Explanation: The "Intended Use / Indications for Use" section clearly states that the device is intended for "removal of unwanted hair", "permanent reduction in hair regrowth", and "facial stimulation for over-the-counter aesthetic use." These are cosmetic and therapeutic applications, not diagnostic ones.
No
The device description clearly states it is a hand-held, home-use device utilizing Intense Pulsed Light (IPL) and galvanic microcurrents, comprising a power adaptor and applicator with physical components like a lamp, touch electrode, buttons, LED indicators, and sensors. This indicates it is a hardware device with integrated software, not a software-only device.
Based on the provided information, the Silk'n Infinity device is not an IVD (In Vitro Diagnostic) device.
Here's why:
- Intended Use: The intended use is for hair removal and facial stimulation. IVD devices are used to examine specimens taken from the human body (like blood, urine, or tissue) to provide information for diagnosis, monitoring, or screening. The Silk'n Infinity directly interacts with the body's surface.
- Device Description: The device uses Intense Pulsed Light (IPL) and galvanic microcurrents applied externally to the skin. IVD devices typically involve analyzing biological samples.
- Lack of IVD-specific information: The document does not mention any analysis of biological samples, diagnostic purposes, or any of the typical characteristics of an IVD device.
Therefore, the Silk'n Infinity is a therapeutic or aesthetic device, not an in vitro diagnostic device.
N/A
Intended Use / Indications for Use
The Silk'n Infinity is an over the counter device intended for the removal of unwanted hair. The Infinity device is also intended for permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
The Silk'n Infinity electric output is indicated for facial stimulation for over-the-counter aesthetic use.
Product codes
OHT, ONF, NFO
Device Description
The Silk'n Infinity device is designed as a hand held, home use device, which utilizes Intense Pulsed Light (IPL) for hair removal and galvanic microcurrents for skin stimulation. The device comprises a power adaptor and device applicator. The applicator consists of a single lamp producing the light energy that is emitted via the flash window, and a chrome-coting stripe (touch electrode) located around the flash window, through which the micro-current pulses are discharged. The applicator spot size is 2.7cm2 The user interface located on the applicator contains ON/OFF button, pulsed trigger button and six green LED indicators which provide information on the energy level, system status & errors. The Silk'n Infinity device contains a skin sensor, providing the user with an additional safety measure to detect appropriate skin tones and a proximity sensor that identifies full contact with the skin before pulse activation. The light output power range is from 3 to 5 J/cm 2, the optical filter cut off wavelength is 475-1200nm.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Intense Pulsed Light (IPL)
Anatomical Site
Not Found (device is for hair removal and facial stimulation, but no specific anatomical sites are listed)
Indicated Patient Age Range
Not Found
Intended User / Care Setting
hand held, home use device
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
Non-Clinical (Bench) Performance Data:
- The Silk'n Infinity device, IPL optical output performance specifications are based on the same performance specifications as those of the main predicate, the Silk'n Glide which were already evaluated and well established in K131870 & K141242.
- Two additional bench tests were performed utilizing the Silk'n Infinity device; the first was evaluating the output performance specifications of the added microcurrent technology.
- Test results demonstrated that the output parameters complied with the device design requirements and were in line with the reference predicate output specifications.
- The second bench test was evaluating the device safety in simulated home use settings, utilizing the device on eight human volunteers while covering five different body areas.
- Test results showed that the device was safe for use as intended.
- Furthermore, the Silk'n Infinity device underwent software validation testing as well as was tested and found to comply with the Electrical and mechanical safety standard (IEC 60601-1), the electromagnetic compatibility standard (IEC 60601-1-2), the nonlaser light source equipment standard (IEC 60601-2-57), requirements for the medical electrical equipment and medical electrical systems used in the home healthcare environment (IEC 60601-1-11) and particular requirements for the basic safety and essential performance of nerve and muscle stimulators (IEC 60601-2-10).
- Key results: The results of the tests demonstrated that all of the device specifications met the system requirements and do not raise new safety or effectiveness concerns.
Key Metrics
Not Found
Predicate Device(s)
Reference Device(s)
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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Image /page/0/Picture/2 description: The image is a black and white seal for the U.S. Department of Health & Human Services. The seal is circular, with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. In the center of the seal is a stylized image of three human profiles facing to the right, with three curved lines above them.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 11, 2017
Home Skinovations Ltd. % Amit Goren Regulatory Manager A. Stein - Regulatory Affairs Consulting Ltd. 20 Hata'as Str., Suite 102 Kfar Saba, Il
Re: K171433
Trade/Device Name: Silk'n Infinity 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: OHT Dated: May 10, 2017 Received: May 15, 2017
Dear Amit Goren:
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
1
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 devicerelated 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/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,
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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510(K) SUMMARY SILK'N INFINITY 510(k) Number K171433
| Applicant: | Home Skinovations Ltd.
Tavor Building, POB 533 |
|----------------------|------------------------------------------------------------------------------------------|
| | Yokneam Iillit 2069206 Israel |
| | Tel: +972(4)9097440 |
| | Fax: +972(4)9097471 |
| | E-mail: amit@asteinrac.com; |
| Contact Person: | Amit Goren |
| | A. Stein - Regulatory Affairs Consulting Ltd. |
| | 20 Hata'as Str., Suite 102 |
| | Kfar Saba 44425 Israel |
| | Tel: + 972-9-7670002 |
| | Fax: +972-9-7668534 |
| | E-mail: amit@asteinrac.com |
| Date Prepared: | August 08, 2017 |
| Trade Name: | Silk'n Infinity |
| Classification Name: | 21 CFR Classification sections 878.4810 and 882.5890; Product
codes OHT, ONF and NFO. |
| Classification: | Class II Medical Device |
Predicate Device
The Silk'n Infinity device is substantially equivalent to the previously cleared Silk'n Glide device (Main predicate), also manufactured by the applicant (HomeSkinovations Ltd.). In addition, the Facial Spa device is used as a reference predicate.
| Manufacturer | Device | 510(k) No. |
|---|---|---|
| Home Skinovations Ltd. | Silk'n Glide | K141242 |
| Nu Skin Enterprises Inc. | Facial SPA | K122711 |
Device Description
The Silk'n Infinity device is designed as a hand held, home use device, which utilizes Intense Pulsed Light (IPL) for hair removal and galvanic microcurrents for skin stimulation. The device comprises a power adaptor and device applicator. The applicator
4
consists of a single lamp producing the light energy that is emitted via the flash window, and a chrome-coting stripe (touch electrode) located around the flash window, through which the micro-current pulses are discharged. The applicator spot size is 2.7cm2 The user interface located on the applicator contains ON/OFF button, pulsed trigger button and six green LED indicators which provide information on the energy level, system status & errors. The Silk'n Infinity device contains a skin sensor, providing the user with an additional safety measure to detect appropriate skin tones and a proximity sensor that identifies full contact with the skin before pulse activation. The light output power range is from 3 to 5 J/cm 2, the optical filter cut off wavelength is 475-1200nm.
Device Specifications:
| Intense Pulsed Light (IPL) | |
|---|---|
| Light Output Power | 3 – 5 J/cm² |
| Pulse duration: | 500 – 800 µsec |
| Wavelength: | 475-1200nm |
| Galvanic current pulse parameters (R Load: 500 Ω & 1k Ω.) | |
| Maximal output current | 420 μA |
| Maximal output voltage | 210 mv & 840 mv |
Intended Use/Indication for Use
The Silk'n Infinity is an over the counter device intended for the removal of unwanted hair. The Infinity device is also intended for permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
The Silk'n Infinity electric output is indicated for facial stimulation for over-the-counter aesthetic use.
Performance Standards
The Silk'n Infinity device has been tested and complies with the following voluntary recognized standards:
- . IEC 60601-1:2012, Medical Electrical Equipment - Part 1: General Requirements for Basic Safety and Essential Performance
5
- IEC 60601-1-2 (2014): Medical Electrical Equipment-Part 1: General requirements . for safety and Part 1-2 Collateral standard: Electromagnetic Compatibility-Requirements and tests
- IEC 60601-2-57 (2011), Medical Electrical Equipment Part 2-57: Particular . Requirements For The Basic Safety And Essential Performance Of Non-Laser Light Source Equipment Intended For Therapeutic, Diagnostic, Monitoring And Cosmetic/Aesthetic Use.
- IEC 60601-1-11:2010, Medical electrical equipment Part 1-11: Requirements for the . medical electrical equipment and medical electrical systems used in the home healthcare environment.
- IEC 60601-2-10:2012, Medical Electrical Equipment Part 2-10: Particular . Requirements For The Basic Safety And Essential Performance Of Nerve And Muscle Stimulators
Non-Clinical (Bench) Performance Data
The Silk'n Infinity device, IPL optical output performance specifications are based on the same performance specifications as those of the main predicate, the Silk'n Glide which were already evaluated and well established in K131870 & K141242.
Two additional bench tests were performed utilizing the Silk'n Infinity device; the first was evaluating the output performance specifications of the added microcurrent technology. The test results demonstrated that the output parameters complied with the device design requirements and were in line with the reference predicate output specifications.
The second bench test was evaluating the device safety in simulated home use settings, utilizing the device on eight human volunteers while covering five different body areas. The test results showed that the device was safe for use as intended.
Furthermore, the Silk'n Infinity device underwent software validation testing as well as was tested and found to comply with the Electrical and mechanical safety standard
6
(IEC 60601-1), the electromagnetic compatibility standard (IEC 60601-1-2), the nonlaser light source equipment standard (IEC 60601-2-57), requirements for the medical electrical equipment and medical electrical systems used in the home healthcare environment (IEC 60601-1-11) and particular requirements for the basic safety and essential performance of nerve and muscle stimulators (IEC 60601-2-10).
The results of the tests demonstrated that all of the device specifications met the system requirements and do not raise new safety or effectiveness concerns.
Animal Performance Data / Histology Data
Not Applicable
Clinical Performance Data
Not Applicable
Substantial Equivalence
The Silk'n Infinity device is basically a modified and upgraded version of the main predicate Silk'n Glide device (510(k) K141242). Both devices utilize optical energy with the same pulse duration, wavelength and light output power. They are both powered on Continuous Operation. The Silk'n Infinity device has similar design, user interface and hardware components as the predicate Silk'n Glide device, with one major modification. The main reason for the submission of this 510(k) application is the addition of the galvanic microcurrents treatment step prior to the existing optical hair removal treatment step in order to add additional feature of skin stimulation to the current indication of hair reduction, while maintaining its safety and effectiveness.
The specifications of the microcurrent technology that is included in the Silk'n Infinity device are identical or in range to that of the Facial Spa device (510(k) K122711), the reference predicate device, a home use non-invasive device intended for facial skin stimulation. Microcurrent technology is a widely used technique in the home use cosmetic applications for skin stimulation. It produces an electrical current that stimulates the skin and increase local blood circulation.
The safety features and compliance with safety standards of the Silk'n Infinity device are similar to the safety features and compliance with safety standards of the predicate devices. All patient contacting materials were tested for biocompatibility and found to
7
comply with the ISO 10993-1 standard (see detailed biocompatibility testing in Section 15). Furthermore, the design and development phases of the Silk'n Infinity device were composed of a set of performance tests, including software validation testing (provided in Section 16), electrical and mechanical safety testing according to IEC 60601-1 standard, electromagnetic compatibility testing according to IEC 60601-1-2 standard, non-laser light source equipment testing according to IEC 60601-2-57 standard, medical electrical equipment testing in home use environment according to IEC 60601-1-11 standard and particular requirements for the basic safety and essential performance of nerve and muscle stimulators according to IEC 60601-2-10 standard (provided in Section 17) & performance bench tests (provided in Section 18). These performance tests demonstrated that the device specifications meet the system requirements and do not raise new safety or effectiveness concerns.
Consequently, it can be concluded that the Silk'n Infinity device is substantially equivalent to the main predicate Silk'n Glide device (cleared under 510(k) K141242) and to the reference predicate Facial Spa device (cleared under 510(k) K122711 and therefore, may be legally marketed in the USA.