K Number
K173199
Device Name
PicoSure Workstation
Manufacturer
Date Cleared
2018-02-07

(128 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
755mm: The PicoSure Workstation is indicated for tattoo and benign pigmented lesions removal. The PicoSure Workstation with the 2mm and 6mm hand pieces and the Focus Array are indicated for the treatment of acne scars and wrinkles in Skin Types I - IV. 532mm: The PicoSure 532mm Laser Delivery System is indicated for tattoo removal and benign pigmented lesion removal in Skin Types I - III. 1064nm: The PicoSure 1064nm Laser Delivery System is indicated for tattoo and benign pigmented lesions removal.
Device Description
The PicoSureTM Workstation is a high-powered, Alexandrite system that delivers laser energy in the 755-nm nominal wavelength. The system offers fast and efficient treatment through a variety of spot sizes, fluences and repetition rates. Laser activation is by footswitch. In addition to the 755nm handpiece, optional 532nm Laser Delivery System and/or 1064nm Laser Delivery System can replace the 755nm handpiece at the distal end of the articulated arm. These Delivery Systems convert the 755nm laser energy into a 532nm wavelength or a 1064 nm wavelength, and are available in multiple spot sizes.
More Information

Not Found

No
The summary describes a laser system for tattoo and lesion removal and wrinkle treatment. There is no mention of AI, ML, image processing, or any features that would suggest the use of such technologies. The performance evaluation relies on clinical assessment by dermatologists, not algorithmic analysis.

Yes
The device is indicated for the treatment of various medical conditions such as acne scars, wrinkles, and benign pigmented lesions, which aligns with the definition of a therapeutic device.

No

Explanation: The device is described as a laser system indicated for the removal of tattoos, benign pigmented lesions, acne scars, and wrinkles, which are all treatment applications, not diagnostic ones.

No

The device description clearly states it is a "high-powered, Alexandrite system that delivers laser energy" and includes physical components like handpieces and an articulated arm. This indicates a hardware-based medical device, not software-only.

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

Here's why:

  • Intended Use/Indications for Use: The intended use is for tattoo removal, benign pigmented lesion removal, acne scar treatment, and wrinkle treatment. These are all procedures performed directly on the patient's body.
  • Device Description: The device is a laser system that delivers energy to the skin. This is a therapeutic device, not a diagnostic one.
  • Lack of IVD Characteristics: There is no mention of analyzing samples (blood, tissue, etc.) outside of the body, which is the defining characteristic of an in vitro diagnostic device. The performance studies involve evaluating the visual improvement of the treated areas on the patient.

In summary, the PicoSure Workstation is a therapeutic laser device used for cosmetic and dermatological treatments, not a device used for diagnosing conditions by examining samples outside the body.

N/A

Intended Use / Indications for Use

755mm:

The PicoSure Workstation is indicated for tattoo and benign pigmented lesions removal. The PicoSure Workstation with the 2mm and 6mm hand pieces and the Focus Array are indicated for the treatment of acne scars and wrinkles in Skin Types I - IV.

532mm:

The PicoSure 532mm Laser Delivery System is indicated for tattoo removal and benign pigmented lesion removal in Skin Types I - III.

1064nm:

The PicoSure 1064nm Laser Delivery System is indicated for tattoo and benign pigmented lesions removal.

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

GEX

Device Description

The PicoSureTM Workstation is a high-powered, Alexandrite system that delivers laser energy in the 755-nm nominal wavelength. The system offers fast and efficient treatment through a variety of spot sizes, fluences and repetition rates. Laser activation is by footswitch. In addition to the 755nm handpiece, optional 532nm Laser Delivery System and/or 1064nm Laser Delivery System can replace the 755nm handpiece at the distal end of the articulated arm. These Delivery Systems convert the 755nm laser energy into a 532nm wavelength or a 1064 nm wavelength, and are available in multiple spot sizes.

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

A prospective clinical study was conducted using 30 treatment areas (2 areas for each of the 15 subjects), both male and female, in which the removal of benign pigmented lesions was performed using the PicoSure Workstation's 532nm Delivery System. Subjects in the study were 93% female, 7% male, and were between the ages (53 – 70) years old. They were a range of Fitzpatrick Skin Types I-III. All potential subjects were evaluated against the study's inclusion criteria to determine enrollment eligibility. During the course of the study, subjects received up to 4 treatments that were 4 weeks (+/- 2) apart using the PicoSure Workstation's 532mm wavelength haser energy. These subjects were then followed up on a (1 month) timeframe to assess for any adverse patient impacts at the treatment site. The clinical efficacy endpoint was evaluated through comparison of the pre-treatment images by three blinded, board certified Dermatologists as independent reviewers. The clinical investigator evaluated progress via the GAIS [Global Aesthetic Improvement Scale], where 91.1% of the subjects at [1 month follow-up] had a score of "1 – Very Much Improved". The safety endpoint sought to course of the study. All adverse effects from the clinical study were transient (resolving in 2-11 days) in form of reching, and blistering. These are all expected side effects from laser treatments. The objectives of the study were met and concluded that the use of PicoSure's 532nm Delivery System is a safe and effective method for the removal of benign pigmented lesions in Skin Types I-III.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

GAIS [Global Aesthetic Improvement Scale], where 91.1% of the subjects at [1 month follow-up] had a score of "1 – Very Much Improved".

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.

K160480, K133254

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 of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which consists of the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG" in blue, and then the word "ADMINISTRATION" in a smaller font size below that.

February 7, 2018

Cynosure, Inc Avinash Purohit Regulatory Affairs Specialist 5 Caelisle Road Westford, Massachusetts 01886

Re: K173199

Trade/Device Name: PicoSure Workstation 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 28, 2017 Received: October 2, 2017

Dear Avinash Purohit:

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 Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820);

1

and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely. Jennifer R. Stevenson -S3 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) K173199

Device Name PicoSure Workstation

Indications for Use (Describe) 755mm:

The PicoSure Workstation is indicated for tattoo and benign pigmented lesions removal. The PicoSure Workstation with the 2mm and 6mm hand pieces and the Focus Array are indicated for the treatment of acne scars and wrinkles in Skin Types I - IV.

532mm:

The PicoSure 532mm Laser Delivery System is indicated for tattoo removal and benign pigmented lesion removal in Skin Types I - III.

1064nm:

The PicoSure 1064nm Laser Delivery System is indicated for tattoo and benign pigmented lesions removal.

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 for the PicoSure Workstation
807.92(a)(1) Submitter Information
ApplicantCynosure, Inc.
Address5 Carlisle Road
Westford, MA 01886
Phone Number(978) 367-2450
Fax Number(978) 256-6556
Establishment Registration Number1222993
Contact PersonMr. Avinash Purohit
Preparation Date28 September 2017
807.92(a)(2) Name of Device
Trade or Proprietary NamePicoSure Workstation
Common or Usual NameLaser Workstation
Classification NamePowered Laser Surgical Instrument
Classification PanelGeneral & Plastic Surgery
Regulation878.4810
Product Code(s)GEX
807.92 (a)(3) Legally marketed device(s) to which equivalence is claimed
PicoSure Workstation - K160480
RevLite Q-Switched Nd:YAG Laser System - K133254
807.92(a)(4) Device Description
The PicoSureTM Workstation is a high-powered, Alexandrite
system that delivers laser energy in the 755-nm nominal
wavelength. The system offers fast and efficient treatment
through a variety of spot sizes, fluences and repetition rates. Laser
activation is by footswitch. In addition to the 755nm handpiece,
optional 532nm Laser Delivery System and/or 1064nm Laser
Delivery System can replace the 755nm handpiece at the distal
end of the articulated arm. These Delivery Systems convert the
755nm laser energy into a 532nm wavelength or a 1064 nm
wavelength, and are available in multiple spot sizes.
807.92(a)(5) Intended Use of the Device
755 nm:
The PicoSure Workstation is indicated for tattoo and benign
pigmented lesions removal. The PicoSure workstation with the
2mm and 6mm handpieces and the Focus Array are indicated for
the treatment of acne scars and wrinkles in Skin Types I-IV.
532 nm:
The PicoSure 532 nm delivery system is indicated for tattoo
removal and benign pigmented lesion removal in Skin Types I-
III.
1064 nm:
The PicoSure 1064 nm Laser Delivery System is indicated for
tattoo and benign pigmented lesions removal.

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807.92(a)(6) Summary of the Technological Characteristics of the Device Compared to the Predicate
510(k) NumberPicoSure Workstation
(KPending)PicoSure Workstation
(K160480)RevLite Q-switched Nd:YAG
Laser System
(K133254)
Laser TypeNd:YVO4Frequency
doubled
Nd:YVO4AlexandriteNd:YVO4Frequency
doubled
Nd:YVO4AlexandriteFlashlamp Excited Q-Switched
Nd:YAG
Wavelength
(nm)1064 nm532 nm755 nm1064 nm532 nm755 nm1064 nm532 nm
Maximum
Average
Fluence (J/cm²)3.6 J/cm²1.5 J/cm²6.37 J/cm²3.6 J/cm²1.5 J/cm²6.37 J/cm²12 J/cm²5 J/cm²
Repetition
Rate (Hz)1, 2.5, 5, 10 Hz1, 2.5, 5, 10 HzSingle, 1, 2.5, 5,
10 Hz1, 2.5, 5,
10 Hz1, 2.5, 5,
10 HzSingle, 1, 2.5, 5,
10 HzSingle Shot, 1, 2, 5, 10 Hz
Pulse Duration450-900 ps450-900 ps7 – 20 ns
Spot Sizes
(mm)Fixed 1.4 –
4.0 mmFixed 1.5 –
3.5 mmZoom 2-6 mm,
Fixed 6, 8, 10
mmFixed 1.4 –
4.0 mmFixed 1.5 –
3.5 mmZoom 2-6 mm,
Fixed 6, 8, 10
mm2 – 8.5 mm with 0.1 mm
increments

807.92(b)(1) Non-clinical tests submitted

For this submission, software and electrical safety testing were not necessary for the expanded indication. However, incremental software updates required testing and was completed successfully. With regard to electrical safety, the device experienced only constructional changes as part of normal maintenance, so additional testing was not required. EMC testing was still performed on two components added to improve product reliability. All changes have been analyzed and successary. There necessary. There software updates/constructional changes do not affect the safety and efficacy of the PicoSure Workstation.

807.92(b)(2) Clinical tests submitted

A prospective clinical study was conducted using 30 treatment areas (2 areas for each of the 15 subjects), both male and female, in which the removal of benign pigmented lesions was performed using the PicoSure Workstation's 532nm Delivery System. Subjects in the study were 93% female, 7% male, and were between the ages (53 – 70) years old. They were a range of Fitzpatrick Skin Types I-III. All potential subjects were evaluated against the study's inclusion criteria to determine enrollment eligibility. During the course of the study, subjects received up to 4 treatments that were 4 weeks (+/- 2) apart using the PicoSure Workstation's 532mm wavelength haser energy. These subjects were then followed up on a (1 month) timeframe to assess for any adverse patient impacts at the treatment site. The clinical efficacy endpoint was evaluated through comparison of the pre-treatment images by three blinded, board certified Dermatologists as

5

independent reviewers. The clinical investigator evaluated progress via the GAIS [Global Aesthetic Improvement Scale], where 91.1% of the subjects at [1 month follow-up] had a score of "1 – Very Much Improved". The safety endpoint sought to course of the study. All adverse effects from the clinical study were transient (resolving in 2-11 days) in form of reching, and blistering. These are all expected side effects from laser treatments. The objectives of the study were met and concluded that the use of PicoSure's 532nm Delivery System is a safe and effective method for the removal of benign pigmented lesions in Skin Types I-III.

807.92(b)(3) Conclusions drawn from clinical and non-clinical tests submitted

The non-clinical data demonstrates support for safety and effectiveness of the device in regards to herded for treatment conditions. The clinical study demonstration using the 532mm Delivery System operated as expected and delivered safe and effective results with minimal side effects in subjects being pigmented lesion removal in Skin Types I-III.