(155 days)
No
The description focuses on the laser technology, control panel, and safety features, with no mention of AI or ML capabilities. The software validation mentioned is for firmware, not AI/ML algorithms.
Yes
The device is intended for incision, vaporization, ablation, hemostasis, and coagulation of soft tissue, which are therapeutic medical procedures.
No
Explanation: The device is described as a laser intended for soft tissue procedures (incision, vaporization, ablation, hemostasis, and coagulation), which are therapeutic actions, not diagnostic ones. There is no mention of it being used to detect or identify medical conditions.
No
The device description clearly outlines a physical laser system with hardware components like semiconductor laser diodes, a control panel, and a beam transporting system. While it includes firmware validation, it is not solely software.
Based on the provided information, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- Intended Use: The intended use is for "incision, vaporization, ablation, hemostasis and coagulation of soft tissue." This describes a therapeutic or surgical procedure performed directly on the patient's body.
- Device Description: The description details a laser system that delivers energy to "affected surfaces and organs." This is consistent with a device used for direct medical intervention.
- Lack of IVD Characteristics: An IVD device is used to examine specimens derived from the human body (like blood, urine, tissue samples) to provide information for diagnosis, monitoring, or screening. The description of the Leonardo Mini Blue does not mention any interaction with such specimens or any diagnostic purpose.
- Anatomical Site: The anatomical site is "soft tissue," which is where the laser is applied directly.
- Predicate Device: The predicate device (K192272) is also a laser system for soft tissue procedures, further supporting its classification as a therapeutic device, not an IVD.
Therefore, the Leonardo Mini Blue 445nm Laser is a medical device used for surgical and therapeutic procedures on soft tissue, not an in vitro diagnostic device.
N/A
Intended Use / Indications for Use
The Leonardo Mini Blue 445nm Laser is intended for incision, vaporization, ablation, hemostasis and coagulation of soft tissue.
Product codes
GEX
Device Description
The laser family LEONARDO® Mini Blue is a laser system with functions and ergonomics specially developed for medical applications. A control panel is used to set treatment parameters, such as laser power. User-friendly menu navigation ensures a reliable operation while allowing physicians to concentrate on the essential aspects of treatment. The fiber-coupled semiconductor laser diodes convert electrical energy to coherent laser radiation with the wavelength of 445 nm (aiming beam 635 nm). A beam transporting system delivers this energy to affected surfaces and organs. Depending on the model, the LEONARDO® Mini Blue laser has the following maximum laser output power: LEONARDO® Mini Blue: 10W@445nm. LEONARDO® Mini Blue is available as a single-wavelength device with 445 nm. All LEONARDO® Mini Blue laser can be operated in continuous mode. Additional special treatment modes for specific treatment procedures or in combination with corresponding application fibers are available, depending on the configuration of the unit. For safety reasons, the LEONARDO® Mini Blue laser is equipped with a system for automatic recognition of the optical fibers used. Application fibers from CeramOptec have coding for communicating with the laser device.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
soft 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)
The results of bench testing indicate that the new device is as safe and effective as the predicate device. Firmware was validated according to the FDA Guidance: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document issued on: May 11, 2005. Software validation documents were provided for a moderate level of concern. Clinical testing was not required to establish substantial equivalence.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
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/0 description: The image contains the logos of the Department of Health & Human Services and the Food and Drug Administration (FDA). The Department of Health & Human Services logo is on the left, and the FDA logo is on the right. The FDA logo includes the text "U.S. Food & Drug Administration" in blue.
September 1, 2021
CeramOptec GmbH % Daniel Kamm Principal Engineer Kamm & Associates 8870 Ravello Ct Naples, Florida 34114
Re: K210951
Trade/Device Name: Leonardo Mini Blue 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: March 28, 2021 Received: March 30, 2021
Dear Daniel Kamm:
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.
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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.
Purva Pandya Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
510(k) Number (if known) K210951
Device Name Leonardo Mini Blue 445nm Laser
Indications for Use (Describe)
The Leonardo Mini Blue 445nm Laser is intended for incision, vaporization, ablation, hemostasis and coagulation of soft tissue.
Prescription Use (Part 21 CFR 801 Subpart D)
| Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary: 510(k) Number K210951 CeramOptec GMBH Siemensstrabe 44 Bonn Nordrhein-Westfalen, Bonn, Germany D-53121 Registration Number: 3003340844 Phone Number: +49 (228) 97 967 - 0 Date Prepared: August 31, 2021 Contact: Dr. Roland Dreschau, Director
-
- Identification of the Device: Trade/Device Name: Leonardo® Mini Blue 445nm Laser 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
-
- Equivalent legally marketed device: K192272, A.R.C. Laser GmbH Trade/Device Name: Wolf 445nm 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
-
- Reference Devices (Sterile Single Patient Use Fiberoptic Probes) Biolitec Medical Devices, Inc.: MegaBeam ENT Probe: K113858., 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 and Biolitec Medical Devices, Inc.: MegaBeam 400 Micron Forward fire: K113709. 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
-
- Indications for Use: The Leonardo Mini Blue 445nm Laser is intended for incision, excision, vaporization, ablation, hemostasis and coagulation of soft tissue.
-
- Description of the Device: The laser family LEONARDO® Mini Blue is a laser system with functions and ergonomics specially developed for medical applications. A control panel is used to set treatment
4
parameters, such as laser power. User-friendly menu navigation ensures a reliable operation while allowing physicians to concentrate on the essential aspects of treatment. The fiber-coupled semiconductor laser diodes convert electrical energy to coherent laser radiation with the wavelength of 445 nm (aiming beam 635 nm). A beam transporting system delivers this energy to affected surfaces and organs. Depending on the model, the LEONARDO® Mini Blue laser has the following maximum laser output power:
LEONARDO® Mini Blue: 10W@445nm
LEONARDO® Mini Blue is available as a single-wavelength device with 445 nm. All LEONARDO® Mini Blue laser can be operated in continuous mode. Additional special treatment modes for specific treatment procedures or in combination with corresponding application fibers are available, depending on the configuration of the unit. For safety reasons, the LEONARDO® Mini Blue laser is equipped with a system for automatic recognition of the optical fibers used. Application fibers from CeramOptec have coding for communicating with the laser device.
| Characteristic | A.R.C. Laser GmbH
Device Wolf 445nm K192272 | CeramOptec GMBH
Leonardo® Mini Blue 445nm Laser |
|------------------------|------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for
Use | The Wolf 445 nm is intended for incision,
excision, vaporization, ablation, hemostasis
and coagulation of soft tissue. | The Leonardo Mini Blue 445nm Laser is
intended for incision, excision, vaporization,
ablation, hemostasis and coagulation of soft
tissue. SAME |
| Photo | Image: A.R.C. Laser GmbH Device Wolf 445nm K192272 | Image: CeramOptec GMBH Leonardo® Mini Blue 445nm Laser |
| Display | Touch Screen | Touch Screen SAME |
| Mode | Diode Laser | Diode Laser SAME |
| Laser power | 0.5 W up to 10 W | Up to 10 W SAME |
| Laser type | Diode Laser | Diode Laser SAME |
| Wavelength | 445 nm | 445 nm SAME |
Substantial Equivalence Chart
5
| Characteristic | A.R.C. Laser GmbH
Device Wolf 445nm K192272 | CeramOptec GMBH
Leonardo® Mini Blue 445nm Laser |
|---------------------------|--------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|
| Aiming beam | 532 nm | 635 nm Both predicate and proposed
device aiming beams are within the
readily visible spectrum. No adverse
safety or effectiveness impact. |
| Aiming beam
power | ≤ 5 mW | Max. 4 Mw. Comparable. No adverse safety
or effectiveness impact. |
| Laser Class | 4 | 4 |
| Operation
mode | Pulsed, Continuous Wave (CW) | Pulsed, Continuous Wave (CW) SAME |
| Pulse length/
duration | ≤ 4 Watt: 1 ms to 45 sec and CW
4 Watt: 1 ms to 60 ms | 10 Watt: 10 ms to 1 sec and CW.
Useful range for the indications. No adverse
safety or effectiveness impact. |
| Pulse
frequency | ≤ 4 Watt: 0.01 Hz to 500 Hz and SP
4 Watt: 0.02 Hz to 6.6 Hz and SP | 10 Watt: 0.5Hz - 50Hz
Useful range for the indications. No adverse
safety or effectiveness impact. |
| Cooling | Air | Internal Fan. No adverse safety or
effectiveness impact. |
| Main power
Supply | 100-240 V~, 47-63 Hz, 1.06-0.45 A | Mains operated OR Li-ion rechargeable
battery. No adverse safety or effectiveness
impact. |
| Dimensions of
system | H 10.06 cm (3.9 inches), W 20.3 cm (7.9
inches), 23.9 cm (9.4 inches) | H 6 cm, W 9 cm, L 21,5 cm. SMALLER. No
adverse safety or effectiveness impact. |
| Weight | 2.8 kg (6.17 pounds) | 0.960kg (without batteries)
2x 0.045kg (battery weight)
LIGHTER WEIGHT No adverse safety or
effectiveness impact. |
-
- The technological characteristics are substantially the same, so there are no issues impacting safety and effectiveness. Safety and Effectiveness, comparison to predicate device. The results of bench testing indicate that the new device is as safe and effective as the predicate device.
7) Summary of non-clinical testing:
Firmware was validated according to the FDA Guidance: Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices Document issued on: May 11, 2005. Software validation documents were provided for a moderate level of concern. This device complies with the applicable portions of the standards listed below:
21 CFR Part 1040 PERFORMANCE STANDARDS FOR LIGHT-EMITTING PRODUCTS
EN 1041:2008 Information Supplied By The Manufacturer Of Medical Devices
ISO 14971: 2007 Medical devices — Application of risk management to medical devices FDA # 5-40
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IEC ISO 15223-1:2016 (Corrected Version 2017-03) Medical devices - Symbols to be used with medical device labels, labelling, and information to be supplied - Part 1: General requirements FDA # 5-117
IEC 60601-1:2005+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 60601-1-6:2010+A1:2013 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
IEC 60601-2-22: 2007+A1:2012 Medical electrical equipment - Part 2-22: Particular requirements for basic safety and essential performance of surgical, cosmetic, therapeutic and diagnostic laser equipment FDA # 12-268
IEC 62304: 2006 Medical device software - Software life cycle processes
IEC 62366-1:2007+A1:2014 Medical devices - Part 1: Application of usability engineering to medical devices FDA # 5-114
IEC 60825-1: 2007 Safety of laser products - Part 1: Equipment classification, and requirements [Including: Technical Corrigendum 1 (2008), Interpretation Sheet 1 (2007), Interpretation Sheet 2 (2007)] FDA # 12-273
The IEC standards testing was conducted by an accredited testing laboratory "EZU".
-
- Summary of clinical testing: Clinical testing was not required to establish substantial equivalence.
-
- Conclusion: After analyzing bench and clinical tests, it is the conclusion of CeramOptec GMBH that the new CeramOptec GMBH Leonardo® Mini Blue 445nm Laser is as safe and effective as the predicate device, have few technological differences, and has the same indications for use, thus rendering it substantially equivalent to the predicate device.