K Number
K200116
Device Name
PicoSecond Nd: YAG Laser System
Date Cleared
2020-05-28

(128 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The PicoSecond Nd: YAG Laser System is intended for use in surgical and aesthetic application in the medical dermatology and general and plastic surgery as follows: 1064nm wavelength: - Removal of tattoos on all skin type (Fitzpatrick skin types I-VI) with the following tattoo colors: black, brown, green, blue and purple. - Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV. 532nm wavelength: - Removal of tattoos on Fitzpatrick skin types I-III with the following tattoo colors: red, yellow and orange. - Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.
Device Description
The PicoSecond Nd: YAG Laser System is a Nd: YAG solid state laser, which can deliver the energy at picosecond pulse bursts to the skin. The system is composed of laser generator, articulated arm, handpence, laser power supply, cooling system, display and control system. The PicoSecond Nd: YAG Laser System produces a pulsed beam of coherent near infrared (1064nm) and visible (532nm) light. This beam is directed to the treatment zone by means of an articulated arm coupled to a handpiece. The outputs of the two lasers are designed to be co-linear on the laser rail so that their beam paths are identical as they exit the laser system.
More Information

Not Found

No
The summary describes a laser system with specific wavelengths and pulse characteristics for tattoo and lesion removal. There is no mention of AI, ML, image processing, or any data-driven decision-making components. The performance studies focus on compliance with electrical and laser safety standards.

Yes.
The device is used for removal of tattoos and treatment of benign pigmented lesions, which are aesthetic and medical treatments, therefore classifying it as a therapeutic device.

No.
The document describes the intended use of the device for surgical and aesthetic applications like tattoo removal and treatment of benign pigmented lesions, and does not mention diagnostic capabilities.

No

The device description explicitly lists multiple hardware components including a laser generator, articulated arm, handpiece, laser power supply, and cooling system, indicating it is a hardware-based medical device.

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 perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health.
  • Device Function: The PicoSecond Nd: YAG Laser System is a laser device that delivers energy to the skin for surgical and aesthetic applications (tattoo removal, treatment of pigmented lesions). It directly interacts with the patient's body.
  • Lack of Sample Analysis: There is no mention of this device analyzing any biological samples taken from the patient. Its function is based on the direct application of laser energy to the skin.

Therefore, the intended use and description clearly indicate that this is a therapeutic and aesthetic device, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The PicoSecond Nd: YAG Laser System is intended for use in surgical and aesthetic application in the medical dermatology and general and plastic surgery as follows:

1064nm wavelength:

  • Removal of tattoos on all skin type (Fitzpatrick skin types I-VI) with the following tattoo colors: black, brown, green, blue and purple.
  • Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.

532nm wavelength:

  • Removal of tattoos on Fitzpatrick skin types I-III with the following tattoo colors: red, yellow and orange.
  • Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.

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

GEX

Device Description

The PicoSecond Nd: YAG Laser System is a Nd: YAG solid state laser, which can deliver the energy at picosecond pulse bursts to the skin. The system is composed of laser generator, articulated arm, handpence, laser power supply, cooling system, display and control system.

The PicoSecond Nd: YAG Laser System produces a pulsed beam of coherent near infrared (1064nm) and visible (532nm) light. This beam is directed to the treatment zone by means of an articulated arm coupled to a handpiece. The outputs of the two lasers are designed to be co-linear on the laser rail so that their beam paths are identical as they exit the laser system.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Skin and subcutaneous tissue

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)

Non-Clinical Testing: A battery of tests was performed to verify that the proposed device met all design specification. The test result demonstrated that the proposed device complies with the following standards: IEC 60601-1: 2005+corr.1:2006+Corr.2.2007+A1:2012, IEC 60601-1-2:2014, IEC 60601-2-22:2007+A1: 2012, IEC 60825-1:2014.

Clinical Testing: It is not applicable.

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.

K191685, K173700

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.

0

Image /page/0/Picture/1 description: The image contains 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 is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Shanghai Apolo Medical Technology Co., Ltd. % Claire Zhang Manager Shanghai Landlink Medical Information Technology Co., Ltd. Room 703, 705 , Building 1, West Guangzhong Road 555, Jingan District Shanghai, 200071 Cn

Re: K200116

Trade/Device Name: PicoSecond Nd: YAG 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 Dated: April 16, 2020 Received: April 27, 2020

Dear Claire Zhang:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Colin Kejing Chen Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

2

Image /page/2/Picture/1 description: The image contains 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 is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

Shanghai Apolo Medical Technology Co., Ltd. % Claire Zhang Manager Shanghai Landlink Medical Information Technology Co., Ltd. Room 703, 705 , Building 1, West Guangzhong Road 555, Jingan District Shanghai, 200071 Cn

Re: K200116

Trade/Device Name: PicoSecond Nd: YAG 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 Dated: April 16, 2020 Received: April 27, 2020

Dear Claire Zhang:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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.

3

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

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/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Colin Kejing Chen Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

4

K200116-510(k) summary

l Submitter

Shanghai Apolo Medical Technology Co., Ltd. 4F, Building A, No.388, Yindu Road, Xuhui District, Shanghai 200231, China Preparation date: Apr. 09, 2020

Establishment Registration Number: 3007120647

Contact person: Felix Li Position: Regulatory Affairs Phone: +86-138 4919 0618 Fax: +86-21-34622840 E-mail: liqiang@apolo.com.cn

II Proposed Device

Trade Name:PicoSecond Nd: YAG Laser System
Common name:Powered Laser Surgical Instrument
Regulation Number:21 CFR 878.4810
Regulatory Class:Class II
Product code:GEX
Review Panel:General & Plastic Surgery

III Predicate Devices

510(k) Number:K191685
Trade name:PicoWay Laser System
Common name:Laser Surgical Instrument
Classification:Class II
Product Code:GEX
ManufacturerCandela Corporation
510(k) Number:K173700
Trade name:Picoplus laser system
Common name:Laser Surgical Instrument
Classification:Class II
Product Code:GEX

5

Lutronic Corporation Manufacturer

IV Device description

The PicoSecond Nd: YAG Laser System is a Nd: YAG solid state laser, which can deliver the energy at picosecond pulse bursts to the skin. The system is composed of laser generator, articulated arm, handpence, laser power supply, cooling system, display and control system.

The PicoSecond Nd: YAG Laser System produces a pulsed beam of coherent near infrared (1064nm) and visible (532nm) light. This beam is directed to the treatment zone by means of an articulated arm coupled to a handpiece. The outputs of the two lasers are designed to be co-linear on the laser rail so that their beam paths are identical as they exit the laser system.

V Indication for use

Indication for use

The PicoSecond Nd: YAG Laser System is intended for use in surgical and aesthetic application in the medical dermatology and general and plastic surgery as follows:

1064nm wavelength:

  • Removal of tattoos on all skin type (Fitzpatrick skin types I-VI) with the following tattoo colors: black, brown, green, blue and purple.
  • Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.

532nm wavelength:

  • Removal of tattoos on Fitzpatrick skin types I-III with the following tattoo colors: red, yellow and orange.
  • Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.

VI Comparison of technological characteristics with the predicate devices

A table comparing the key features of the proposed and predicate devices is provided below.

ItemSubject devicePredicate device (K191685)Predicate device (K173700)
Product namePicoSecond Nd:
YAG Laser SystemPicoWay Laser SystemPicoplus laser system
Product CodeGEXGEXGEX

6

| Regulation

No.21 CFR 878.481021 CFR 878.481021 CFR 878.4810
ClassClass IIClass IIClass II
Indication
for useThe PicoSecond Nd:
YAG Laser System
is intended for use in
surgical and
aesthetic application
in the medical
dermatology and
general and plastic
surgery as follows:
1064nm
wavelength:
• Removal of
tattoos on all
skin type
(Fitzpatrick skin
types I-VI) with
the following
tattoo colors:
black, brown,
green, blue and
purple.
• Treatment of
benign
pigmented
lesions on
Fitzpatrick skin
types I-IV.
532nm wavelength:
• Removal ofThe PicoWay laser
system is indicated
for the following at
the specified
wavelength
532 nm: Removal of
tattoos for Fitzpatrick
skin types I - III to
treat the following
tattoo colors: red,
yellow and orange.
730 nm: Removal of
tattoos for Fitzpatrick
skin types II - IV to
treat the following
tattoo colors: green
and blue.
785 nm: Removal of
tattoos for Fitzpatrick
skin types II - IV to
treat the following
tattoo colors: green
and blue.
1064 nm: Removal of
tattoos for all skin
types (Fitzpatrick I -
VI) to treat the
following tattoo
colors: black, brown,
green, blue and
purple.
The Picoway laser
system is also
indicated for benign
pigmented lesionsThe Picoplus Laser
system is indication
for use in surgical
and aesthetic
application in the
medical specialties
of dermatology and
general and plastic
surgery as follows:
The 532 nm
wavelength and 450
pico-second pulse
duration of the
PICOPLUS system
is indicated for
• Removal of
tattoos for
Fitzpatrick skin
types I-III with
the following
tattoo colors:
red, yellow and
orange.
• Treatment of
benign
pigmented
lesions removal
for Fitzpatrick
Skin Types I-IV.
The 1064 nm
wavelength and 450
pico-second pulse
duration of the
PICOPLUS system
is indicated for:
Fitzpatrick skinremoval for
Fitzpatrick Skin
Types I - IV.Removal of
tattoos on all
skin types
(Fitzpatrick skin
types I-VI) with
the following
tattoo colors:
types I-III with
the following
tattoo colors:
red, yellow and
orange.The Resolve
handpiece (1064 nm)
is also indicated for
the treatment of acne
scars in Fitzpatrick
Skin Types II - V.black, brown,
green, blue and
purple.
• Treatment of
benign
pigmented
lesions on
Fitzpatrick skin
types I-IV.The Resolve
handpieces (532 nm
HE, 532nm, 1064nm)
are also indicated for
treatment of wrinkles
in Fitzpatrick Skin
Types I - IV• Treatment of
benign
pigmented
lesions on
Fitzpatrick skin
types I-IV.
The Resolve Fusion
handpiece (1064 nm)
is indicated for the
treatment of wrinkles
as well as benign
pigmented lesions in
Fitzpatrick Skin
Types I - IVThe 1064 nm
wavelength and
nanosecond pulse
duration of the
PICOPLUS system
is indicated for:
The Resolve Fusion
handpiece (532 nm)
is indicated for the
treatment of benign
pigmented lesions in
Fitzpatrick Skin
Types I - IV.• Treatment of
benign
pigmented
lesions on
Fitzpatrick skin
types I-VI
• Removal of dark
and mult
i-colored tattoos
containing dark
colored tattoo
inks on
Fitzpatrick skin
types I-VI
The 532 nm

7

8

| | | | wavelength and
nanosecond pulse
duration of the
PICOPLUS system
is indicated for: | | | to be co - linear on
the laser rail so that
their beam paths are
identical as they exit
the laser system.
This allows the use
of a single delivery
system which can
output either the 532
nm or 1064
nm wavelengths. | linear on the laser rail
so that their beam
paths are identical as
they exit the laser
system. This allows
the use of a single
delivery system
which can output
either the 532 nm or
1064 nm
wavelengths. | | | | | | | |
|--------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------|----------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------|---------------------------|---------------------------|----------------------------|-----------------------------|---------------------------------------------------|---------|
| | | | • Treatment of
benign
pigmented
lesions on
Fitzpatrick skin
types I-IV | Wavelengt
h (nm) | 1064nm | 532nm | 1064nm | 532nm | 1064nm | 532nm | | | 1064 nm);
Zoom handpiece
(532nm, 1064 nm). | |
| | | | • Removal of
lighter colored
tattoo inks,
including red
and yellow inks,
on Fitzpatrick
skin types I-III | Maximum
pulse
energy | 500mJ | 250mJ | 400mJ | 200mJ | 800mJ
(picosec
ond) | 300mJ
(picosec
ond) | System
dimension | 97cm H x 48cm W x
97cm D | 107 cm H x 46 cm W
x 69 cm D | unknown |
| Anatomical
site | Skin and
subcutaneous tissue | Skin and
subcutaneous tissue | | Pulse
duration | 300 – 500 ps | | 240-500ps | | 450ps | | System
weight | 130kg | 125kg | unknown |
| Technology | The PicoSecond Nd:
YAG Laser System
produces a pulsed
beam of coherent
near infrared
(1064nm) and
visible (532nm) light.
It can crush lesions
tissue efficient by
instantaneous emit
laser energy, 1064 &
532nm wavelength
act on the target
tissue in a short time
(300-500ps). The
outputs of the two
lasers are designed | The PicoWay Laser
System is a solid -
state laser capable of
delivering energy at
wavelengths of 1064
nm, 532 nm, 730 nm
or 785 nm at
extremely short
duration in the range
of 240 - 500 ps.
The 1064 nm
wavelength can be
frequency - doubled
to 532 nm as desired.
The outputs of the
two lasers are
designed to be co - | The PICOPLUS
Laser System is a
laser system,
delivering energy at
wavelengths of 1064
nm and 532 nm, both
at pulse durations of
450 picoseconds
(ps) and 2
nanoseconds (ns).
The laser system is
comprised of a
system console, an
articulated arm and
attached
handpieces. | Repetition
rate | Single, 1, 2, 3, 4, 5,
6, 7, 8, 9, 10 Hz | | Single, 1, 2, 3, 4, 5,
6, 7, 8, 9, 10 Hz | | N/A | | Electrical
requirements | 120VAC 10A,
50/60Hz | 200-240 VAC, 50/60
Hz, 30 A, 4600 VA
single | unknown |
| Spot size | Adjustable spot size
2~10mm | | 2, 3, 4, 5, 6, 7, 8, 9,
10 mm | | 1064nm
Handpiece 1
(450ps):
3, 5, 4 6mm
Handpiece 2: 6, 7, 8,
9, 10mm | 532nm
Handpiece 1
(450ps): 3.3, 4.3,
5.3mm
Handpiece 2: 4.3,
5.3, 6.5, 8mm | | | | | | | | |
| Beam
delivery | Articulated arm light
guide | | Articulated arm light
guide | | Articulated arm light
guide | | | | | | | | | |
| Handpiece | Zoom handpiece
(532nm, 1064 nm) | | Resolve handpieces
(532 nm HE, 532nm,
1064nm);
The Resolve Fusion
handpiece (532nm | | Handpiece 1, 2
(450ps) (1064nm,
532nm)
Handpiece1, 2 (2ns)
(1064nm, 532nm) | | | | | | | | | |

9

10

The indication of the proposed device is covered by the predicate. The maximum pulse energy of the proposed device is higher than the K191683, and lower than the K113700 predicate device. It can be considered that the propose device can achieve its intended use and is safety. The handpiece types of proposed device are less than the predicate devices. This difference does not affect the safety and effective of proposed device.

VII Non-Clinical Testing

A battery of tests was performed to verify that the proposed device met all design specification. The test result demonstrated that the proposed device complies with the following standards:

Electrical safety and electromagnetic compatibility

IEC 60601-1: 2005+corr.1:2006+Corr.2.2007+A1:2012 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance IEC 60601-1-2:2014 Medical electrical equipment -Part 1-2: General requirements for basic safety and essential performance-Collateral Standard: Electromagnetic disturbances - Requirements and tests

IEC 60601-2-22:2007+A1: 2012 Medical electrical equipment - Part 2-22: Particular requirements for the safety and essential performance of surgical, cosmetic, therapeutic and diagnostic laser equipment

IEC 60825-1:2014 Safety of Laser products-Part 1: Equipment classification and requirements

VIII Clinical Testing

It is not applicable.

IX Conclusion

The proposed device, PicoSecond Nd: YAG Laser System has the same the

11

intended use as the predicate device. It presents similar technological characteristics as the predicate device including the laser type, wavelengths, device design, pulse width, frequency, spot sizes. The non-clinical testing determined that the subject device is substantially equivalent to the predicate device.