(83 days)
No
The device description and performance studies focus on light therapy technology and standard software control for preprogrammed modes. There is no mention of AI, ML, or any adaptive or learning capabilities.
Yes
The "Device Description" explicitly states, "...the Biophotas Celluma RESTORE is a portable, therapeutic device whose purpose is to provide even, cool, narrow-band wavelengths of polychromatic light...to treat a variety of skin and musculoskeletal conditions..."
No
The device is a therapeutic device that uses visible red light to treat androgenetic alopecia and promote hair growth, and it also treats various skin and musculoskeletal conditions. It does not mention any diagnostic functions.
No
The device description clearly outlines hardware components including LEDs, a flexible frame, a control panel with buttons, and a power cable with an AC adaptor. While software is mentioned as controlling the device, it is integrated into a physical system.
Based on the provided text, this device is not an IVD (In Vitro Diagnostic).
Here's why:
- IVD Definition: In Vitro Diagnostics are devices intended for use in the collection, preparation, and examination of specimens taken from the human body (such as blood, urine, or tissue) to provide information for diagnosis, monitoring, or screening.
- Device Function: The BioPhotas Celluma RESTORE system is a light therapy device that applies light directly to the scalp to treat hair loss and promote hair growth. It does not involve the collection or analysis of any biological specimens.
- Intended Use: The intended use clearly states it is for treating Androgenetic Alopecia and promoting hair growth, which is a therapeutic application, not a diagnostic one.
- Device Description: The description details a light-emitting device applied externally, not a system for analyzing samples.
Therefore, the BioPhotas Celluma RESTORE system falls under the category of a therapeutic device, not an In Vitro Diagnostic device.
N/A
Intended Use / Indications for Use
The BioPhotas Celluma RESTORE system is indicated to treat Androgenetic Alopecia and promote hair growth in males who have Norwood- Hamilton Classifications of IIa - V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2 or frontal patterns of hair loss; both with Fitzpatrick Skin Types I - IV.
Product codes (comma separated list FDA assigned to the subject device)
OAP
Device Description
The BioPhotas Celluma RESTORE system uses visible red light (640nm) and is indicated to treat Androgenetic Alopecia and promote hair growth in males who have Norwood- Hamilton Classifications of IIa - V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2 or frontal patterns of hair loss; both with Fitzpatrick Skin Types I - IV.
In addition, the Biophotas Celluma RESTORE is a portable, therapeutic device whose purpose is to provide even, cool, narrow-band wavelengths of polychromatic light (blue, 465nm red, 640nm and Near infra-red, 880nm) produced by super-luminous LEDs (light emitting diodes) to treat a variety of skin and musculoskeletal conditions as previously cleared under K122237, K131113, K152280 and K171323.
The system comprises of a flexible, shape-taking frame upon which is mounted an array of LEDs, this allows the device to be contoured to the treatment area. The LEDs are embedded within a biocompatible foam covering that holds a transparent polycarbonate cover recessed within it. The biocompatibility nature of allows the device to be placed in contact with the skin. Nevertheless, the design of the device provides for maintaining a small distance between the surface of the skin and the surface of the device.
The flexible LED panel is permanently connected by a three-foot long cable attached to a control panel that contains the circuitry and software that controls the device. The control panel contains several push buttons beneath a sealed cover. A power button that switches the device ON/OFF, a mode button that allows the user to select from 3 preprogrammed treatment modes "Hair", "Wrinkles", and "Aches and Pains", and a Start button that activates the desired treatment mode. The control panel receives its power from a separate cable that connects via an AC adaptor for 110-220 Volts to a standard U.S. electrical power outlet. The control panel contains an automatic shut-off safety feature.
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
Scalp
Indicated Patient Age Range
Not Found
Intended User / Care Setting
Over-The-Counter Use
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)
To demonstrate safety and effectiveness of the Biophotas Celluma RESTORE and to demonstrate substantial equivalence to the predicate devices, Biophotas Inc has completed several non-clinical performance tests. The RESTORE meets established requirements for overall design, electrical safety, software validation and usability studies confirming that the design outputs meet design input requirements and established specifications.
The Biophotas Celluma RESTORE successfully passed testing per internal verification/validation requirements and national/international standards illustrated below:
- Electrical safety per IEC 60601-1
- EMC testing per IEC 60601-1-2
- Software validation per IEC 62304 and the FDA Guidance document.
- Usability Study per IEC 62366.
A usability and label comprehension study was conducted with 25 test subjects. Each test subject was provided with the product packaging and the User's Manual and device and allowed to read the labeling provided and interact with the product. Following the subject's review of the User Manual, packaging, and the device the subject was asked a series of questions to address comprehension and understanding of the User Manual. No new use errors, hazards, hazardous situations, or hazard-related use scenarios were discovered.
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.
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.
K122237, K131113, K152280, K171323
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
§ 890.5500 Infrared lamp.
(a)
Identification. An infrared lamp is a device intended for medical purposes that emits energy at infrared frequencies (approximately 700 nanometers to 50,000 nanometers) to provide topical heating.(b)
Classification. Class II (special controls). The device, when it is an infrared therapeutic heating lamp, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.
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June 29, 2021
Biophotas INC Patrick Johnson CEO 1000 E. Howell Ave. Ste A Anaheim, California 92805
Re: K211038
Trade/Device Name: Biophotas Celluma RESTORE Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared Lamp Regulatory Class: Class II Product Code: OAP Dated: March 31, 2021 Received: April 7, 2021
Dear Patrick Johnson:
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 mediation-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) K211038
Device Name Biophotas Celluma RESTORE
Indications for Use (Describe)
The BioPhotas Celluma RESTORE system is indicated to treat Androgenetic Alopecia and promote hair growth in males who have Norwood- Hamilton Classifications of IIa - V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2 or frontal patterns of hair loss; both with Fitzpatrick Skin Types I - IV.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| ------------------------------------------------- | -- |
| | Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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Image /page/3/Picture/0 description: The image contains the logo for "biophotas". The logo consists of a stylized graphic to the left and the word "biophotas" to the right. The graphic is a blue burst of dots emanating from a central point. The word "biophotas" is written in a sans-serif font, with "bio" in blue and "photas" in green.
510(k) Summary K211038
This 510(k) Summary is submitted in accordance with 21 CFR Part 807, Section 807.92(c).
| Submitter's Name: | BioPhotas, Inc. |
|---|---|
| Submitter's Contact: | Patrick Johnson |
| Submitter's Address: | 1000 E. Howell Ave., Ste A, Anaheim, CA 92805 |
| Phone: | 714-978-0080 |
| Fax: | 714-978-0085 |
Date Prepared: June 24th 2021.
Device Trade Name: Biophotas Celluma RESTORE
Device Common name: Lamp, non-heating, for promotion of hair growth
Device Classification Information:
| Regulation
Number | Device
Classification
name | Device
Class | Product
Code | Classification
Panel | Type |
|----------------------|--------------------------------------|-----------------|-----------------|------------------------------|------------------------|
| 21 CFR
890.5500 | Infrared lamp per
21 CFR 890.5500 | Class 2 | OAP | General &
Plastic Surgery | Traditional
510 (k) |
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Device Description
The BioPhotas Celluma RESTORE system uses visible red light (640nm) and is indicated to treat Androgenetic Alopecia and promote hair growth in males who have Norwood- Hamilton Classifications of IIa - V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2 or frontal patterns of hair loss; both with Fitzpatrick Skin Types I - IV.
In addition, the Biophotas Celluma RESTORE is a portable, therapeutic device whose purpose is to provide even, cool, narrow-band wavelengths of polychromatic light (blue, 465nm red, 640nm and Near infra-red, 880nm) produced by super-luminous LEDs (light emitting diodes) to treat a variety of skin and musculoskeletal conditions as previously cleared under K122237, K131113, K152280 and K171323.
The system comprises of a flexible, shape-taking frame upon which is mounted an array of LEDs, this allows the device to be contoured to the treatment area. The LEDs are embedded within a biocompatible foam covering that holds a transparent polycarbonate cover recessed within it. The biocompatibility nature of allows the device to be placed in contact with the skin. Nevertheless, the design of the device provides for maintaining a small distance between the surface of the skin and the surface of the device.
The flexible LED panel is permanently connected by a three-foot long cable attached to a control panel that contains the circuitry and software that controls the device. The control panel contains several push buttons beneath a sealed cover. A power button that switches the device ON/OFF, a mode button that allows the user to select from 3 preprogrammed treatment modes "Hair", "Wrinkles", and "Aches and Pains", and a Start button that activates the desired treatment mode. The control panel receives its power from a separate cable that connects via an AC adaptor for 110-220 Volts to a standard U.S. electrical power outlet. The control panel contains an automatic shut-off safety feature.
Indications/Intended Use
The BioPhotas Celluma RESTORE is indicated to treat Androgenetic Alopecia and promote hair growth in males who have Norwood- Hamilton Classifications of IIa - V patterns of hair loss and to treat Androgenetic Alopecia and promote hair growth in
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Image /page/5/Picture/0 description: The image shows the logo for biophotas. The logo consists of a blue, abstract graphic to the left of the word "biophotas". The word "bio" is in blue, and the word "photas" is in green. The logo is simple and modern.
females who have Ludwig-Savin Scale I-1 to I-4, II-1, II-2 or frontal patterns of hair loss; both with Fitzpatrick Skin Types I - IV.
Technological characteristics:
The key technological characteristics of the subject device and predicate devices are summarized in the following table;
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《biophotas
| Property | Proposed device.
RESTORE | K173729
Revian Red | K162782
iHelmet Hair Growth System | Significant
difference |
|-------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------|
| Device
Manufacturer | Biophotas Inc | PhotonMD, Inc | Slinph Technologies Co., LTD | na |
| Device Trade Name | Biophotas Celluma RESTORE | Revian Red | iHelmet Hair Growth System,
Model: LTD200S | na |
| 510(K) Number | K211038 | K173729 | K162782 | na |
| Device Product
Code -
Classification name | OAP | OAP | OAP | Identical |
| Device
Classification | Class II | Class II | Class II | Identical |
| Rx/OTC | ОТС | ОТС | ОТС | Identical |
| Intended use and
Indications | The BioPhotas Celluma
RESTORE is indicated to treat
Androgenetic Alopecia and
promote hair growth in males
who have Norwood-Hamilton
Classifications of IIa - V
patterns of hair loss and to
treat Androgenetic Alopecia
and promote hair growth in
females who have Ludwig-
Savin Scale I-1 to I-4, II-1,
II-2 or frontal patterns of hair
loss; both with Fitzpatrick
SkinTypes I - IV. | Revian Red is indicated to
treat Androgenetic Alopecia
and promote hair growth in
males who have Norwood-
Hamilton Classifications of IIa
- V patterns of hair loss and to
treat Androgenetic Alopecia
and promote hair growth in
females who have Ludwig-
Savin Scale I-1 to I-4, II-1, II-
2 or frontal patterns of hair
loss; both with Fitzpatrick
SkinTypes I - IV. | iHelmet Hair Growth System
(Model: LTD200S) is indicated to
promote hair growth in females
with androgenetic alopecia who
have Ludwig-Savin Classifications I - II, in males with androgenetic
alopecia who have Norwood
Hamilton Classifications IIa - V and
for both, Fitzpatrick Classification
of Skin Phototypes of I - IV. | Identical to K173729 |
| Property | Proposed device
RESTORE | K173729
Revian Red | K162782
iHelmet Hair Growth System | Significant
difference |
| Intended Location
of Use | Scalp | Scalp | Scalp | Identical to K173729 |
| Treatment area | Active treatment area
475 cm² | | 424.93 cm2
Mathematically Max. derived | Identical to K162782 |
| Energy Type | Light emitting diodes | Light emitting diodes | Laser diodes | Identical to K173729 |
| Peak Wavelength
(FWHM) | Red: 640nm+/-25nm
(615-665nm) | 620 - 660 nm | 650+/-10nm
(640-660nm) | Proposed device is
within the bandwidth
of K173729 |
| Intensity
(mW/cm2) | 2.77 mW/cm² | Not publicly available | 2.3533 mW/cm²
Mathematically Max. derived | Substantially
equivalent to
K162782 |
| Treatment Dose
(J/cm2) | 4.98 J/cm² | Not publicly available | 4.9420 J/ cm²
Mathematically Max. derived | Substantially
equivalent to
K162782 |
| Treatment protocol
(Treatment time) | Each Treatment:30 min
Total Treatment: every other
day, for 16 weeks | Every day 10 minutes for 26
weeks | Each Treatment: 20-35 min
Total Treatment: every other
day, for 16 weeks | Substantially
equivalent to
K162782 |
| Total treatment
time. | 1680 minutes | 1820 minutes | 1680 minutes | Substantially
equivalent |
| Control | Device uses a timer and
software to control treatment
duration. | Device uses a timer and
software to control treatment
duration. | Device uses a timer and software
to control treatment duration | Identical |
| Electrical power | 110-120V | Uses 110 - 120 V
rechargeable.
Li Polymer battery | 110 -120V | Substantially
equivalent |
| Property | Proposed device
RESTORE | K173729
Revian Red | K162782
iHelmet Hair Growth System | Significant
difference |
| Electrical Safety | 60601-1:2012
60601-1-2:2014 | 60601-1
60601-1-2 | IEC 60601-1
and IEC 60601-1-2
IEC 60825-1 | Identical |
| Biocompatibility | All patient contacting
materials comply with
ISO 10993-5, ISO 10993-10 | All patient contacting
materials are complied with
ISO 10993-5, ISO 10993-10 | All patient contacting
materials are complied with
ISO 10993-5, ISO 10993-10 | Identical |
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Image /page/7/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a stylized graphic to the left of the word "biophotas". The graphic is a blue circular design with lines radiating outward. The word "bio" is in blue, and the word "photas" is in green.
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Image /page/8/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a stylized graphic to the left and the word "biophotas" to the right. The graphic is a blue, star-like shape made up of many small dots. The word "biophotas" is written in a sans-serif font, with "bio" in blue and "photas" in green.
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Image /page/9/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a stylized graphic to the left and the word "biophotas" to the right. The graphic is a blue burst of dots emanating from a central point. The word "biophotas" is written in a sans-serif font, with "bio" in blue and "photas" in green.
Similarities and Differences between the subject and predicate device:
Key Similarities
Please note: The proposed device Biophotas Celluma RESTORE is technologically similar to the previously cleared Biophotas Celluma devices (K122237, K131113, K152280 and K171323). In this application, the software of the device has been modified to allow a red light only mode "Hair."
Indications for use
The proposed device, BioPhotas Celluma RESTORE and Revian Red System K173729 use visible red light and are indicated to promote hair growth in females with androgenetic alopecia who have Ludwig-Savin Classifications I-1 to I-4, II-1, II-2 or frontal patterns of hair loss, and in males with androgenetic alopecia who have Norwood Hamilton Classifications IIa - V and for both, Fitzpatrick Classification of Skin Phototypes of I - IV.
The proposed device and both predicates K173729 Revian Red and K162782 iHelmet Hair Growth System are intended to treat the scalp.
Light technology and wavelengths produced.
The proposed device and K173729 Revian Red utilize Light emitting diodes as a light source and have equivalent wavebands of red light. (615-665nm and 620-660nm).
Treatment parameters
The proposed device, BioPhotas RESTORE, has a total treatment time that is within 93% of the predicate device K173729 Revian Red and identical to K162782 iHelmet Hair Growth System.
Electrical safety and safety standards
To demonstrate safety and effectiveness of the Biophotas Celluma RESTORE and to demonstrate substantial equivalence to the predicate devices, Biophotas Inc has completed several non-clinical performance tests. The RESTORE meets established requirements for overall design, electrical safety, software validation and usability studies confirming that the design outputs meet design input requirements and established specifications.
The Biophotas Celluma RESTORE successfully passed testing per internal verification/validation requirements and national/international standards illustrated below:
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Image /page/10/Picture/0 description: The image shows the logo for "biophotas". The logo consists of a stylized graphic to the left of the word "biophotas". The graphic is a blue, star-like shape made up of many small dots. The word "bio" is in blue, and the word "photas" is in green.
- . Electrical safety per IEC 60601-1
- EMC testing per IEC 60601-1-2 ●
- Software validation per IEC 62304 and the FDA Guidance document .
- . Usability Study per IEC 62366.
The Biophotas Celluma RESTORE, and the predicate device have satisfied product safety testing to the IEC 60601-1 standard, and the electromagnetic safety testing to the IEC 60601-1-2 standard.
Since the Biophotas Celluma does not utilize laser diodes it is exempt from testing to IEC 60825-1 Safety of laser products - Part 1: Equipment classification and requirements.
Differences
There are no key differences between the Biophotas Celluma RESTORE and predicate device Revian RED K173729.
Other Non-Clinical Performance testing
To demonstrate safety and effectiveness and substantial equivalence the Biophotas Celluma RESTORE system has undergone a number of non-clinical performance tests in line with recognized standards in terms of general requirements, biocompatibility, electrical safety and software.
The following non-clinical performance data is provided in support of the substantial equivalence determination.
Biocompatibility
The Biophotas Celluma RESTORE systems hardware is identical to the previously cleared versions (K122237, K131113, K152280 and K171323) in terms of the material, manufacturing, and tissue contact type and duration. There is no change in biocompatibility since the previously cleared versions. Therefore, biocompatibility test data is not needed in this submission.
Software verification and validation testing
In accordance with IEC 62304: 2006 Medical device Software – software life cycle process Biophotas Inc has allocated a software safety classification of Class A for the LED system. The software has also been classified using the FDA level of concern matrix and the level of concern for the device software is: Minor.
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Image /page/11/Picture/0 description: The image shows the logo for biophotas. The logo consists of a stylized image to the left and the word "biophotas" to the right. The stylized image is a blue circular pattern with lines extending outward. The word "biophotas" is written in a sans-serif font, with the "bio" portion in blue and the "photas" portion in green.
Labelling
The Biophotas Celluma RESTORE has been assessed against IEC 62366:2015 Medical devices Application of usability engineering to medical devices.
A usability and label comprehension study was conducted with 25 test subjects. Each test subject was provided with the product packaging and the User's Manual and device and allowed to read the labeling provided and interact with the product.
Following the subject's review of the User Manual, packaging, and the device the subject was asked a series of questions to address comprehension and understanding of the User Manual.
No new use errors, hazards, hazardous situations, or hazard-related use scenarios were discovered. Further improvement of the user interface design as it relates to safety was deemed unnecessary and there were no suggested revisions to the version of the user manual tested.
Statement of Substantial Equivalence:
513(i) of the FD&C Act (21 U.S.C. 360c(i) states that for substantial equivalence a proposed device is required to have the same intended use and similar technological characteristics as the predicate device. Where there are differences in technological characteristics, these can be negated by appropriate clinical or scientific data demonstrating that the proposed device is as safe and effective as the predicate device, and that the proposed device does not raise any different questions of safety and effectiveness than the predicate device for the same intended use.
Biophotas has demonstrated that the RESTORE device has the same intended use as the predicate device, employs identical technological characteristics and is as safe and effective as the predicate K173729 Revian Red.
Therefore, the Biophotas RESTORE, as designed, and manufactured, has been demonstrated to be substantially equivalent to the referenced predicate Revian Red System K173729.