K Number
K212697
Device Name
Leaf Smooth
Date Cleared
2021-11-19

(86 days)

Product Code
Regulation Number
878.4810
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Leaf Smooth is an over-the-counter device intended for removal of unwanted body and/or facial hair.

Device Description

The Leaf Smooth (LH-LIPLB) is a personal, light-based, hair reduction device intended to be sold over-the-counter directly to the end user. The device provides hair reduction using Intense Pulsed Light (IPL) technology. It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain. The device is only powered by the external power adapter and its IPL emission activation is by finger switch. The device contains a Xenon Arc Flashlamp, capacitive sensor to detect appropriate skin contact and a skin sensor to detect appropriate skin color. If the device is not properly applied to the treatment area (in full contact with the skin), the device cannot emit the treatment light pulses. The device is for single-person use only. The Leaf Smooth has 6 levels output intensity.

AI/ML Overview

This document is a 510(k) Premarket Notification for the "Leaf Smooth" hair removal device. It focuses on demonstrating substantial equivalence to predicate devices, rather than presenting a de novo study with specific performance metrics defined by acceptance criteria in the way an AI/ML device would.

Therefore, many of the requested criteria for an AI/ML device (e.g., sample size for AI test set, number of experts for ground truth, MRMC study, standalone performance, training set details) are not applicable to this submission, as it's for a non-AI hardware device (Intense Pulsed Light hair removal device).

However, I can extract the relevant "acceptance criteria" (which are more akin to design specifications and regulatory compliance) and the "study" (non-clinical testing) that proves the device meets these.

Here's the information based on the provided document:


Acceptance Criteria and Device Performance for Leaf Smooth (LH-LIPLB)

1. Table of Acceptance Criteria and Reported Device Performance

For this type of device (IPL hair removal), "acceptance criteria" are derived from recognized consensus standards and comparisons to predicate devices. The "reported device performance" indicates compliance or similarity.

Criterion TypeAcceptance CriteriaReported Device Performance / Compliance
Device Characteristics & Intended Use
Intended UseOver-the-counter device intended for removal of unwanted body and/or facial hair. (Same as predicates)Leaf Smooth: Over-the-counter device intended for removal of unwanted body and/or facial hair. (Matches predicates)
Product CodeOHT (Same as predicates)Leaf Smooth: OHT (Matches predicates)
Classification (Regulation)21 CFR 878.4810 (Laser surgical instrument for use in general and plastic surgery and in dermatology) (Same as predicates)Leaf Smooth: 21 CFR 878.4810 (Matches predicates)
Prescription UseOver-The-Counter Use (Not Prescription) (Same as predicates)Leaf Smooth: OTC (Matches predicates)
Pulsing ControlFinger switch (Same as predicates)Leaf Smooth: Finger switch (Matches predicates)
Delivery DeviceDirect illumination to tissue (Same as predicates)Leaf Smooth: Direct illumination to tissue (Matches predicates)
Energy MediumXenon Arc Flashlamp (Same as predicates)Leaf Smooth: Xenon Arc Flashlamp (Matches predicates)
Wavelength RangeSimilar to predicates (e.g., Predicate K192432: 510-1100nm)Leaf Smooth: 475-1100 nm (Similar to predicates - "Remark: Similar")
Spot SizeSimilar to predicates (e.g., Predicate K192432: 4.5 $cm^2$, 2.0 $cm^2$, 3.0 $cm^2$)Leaf Smooth: 3.8 $cm^2$ (Similar to predicates - "Remark: Similar")
FluenceSimilar to predicates (e.g., Predicate K192432: 2.0-4.0 J/ $cm^2$, 2.5-4.5 J/ $cm^2$; Predicate K181568: Max 5 J/ $cm^2$; Predicate K160968: 3-6 J/ $cm^2$)Leaf Smooth: 4-6 J/ $cm^2$ (Similar to predicates - "Remark: Similar")
Pulse DurationSimilar to predicates (e.g., Predicate K192432: 7.5-14ms; Predicate K181568: 11-12ms; Predicate K160968: 2-10ms)Leaf Smooth: 2-10ms (Similar to predicates - "Remark: Similar")
Safety & Performance Standards
Biocompatibility (Cytotoxicity)No Cytotoxicity (as per ISO 10993-5)Leaf Smooth: No Cytotoxicity (Matches predicates)
Biocompatibility (Sensitization)No evidence of sensitization (as per ISO 10993-10)Leaf Smooth: No evidence of sensitization (Matches predicates)
Biocompatibility (Irritation)No evidence of irritation (as per ISO 10993-10)Leaf Smooth: No evidence of irritation (Matches predicates)
Electrical SafetyComply with ANSI/AAMI ES60601-1, IEC 60601-1-11Leaf Smooth: Comply with ANSI/AAMI ES60601-1, IEC 60601-1-11 (Matches predicates)
EMCComply with IEC 60601-1-2Leaf Smooth: Comply with IEC 60601-1-2 (Matches predicates)
Light SafetyComply with IEC 60601-2-57, IEC 62471Leaf Smooth: Comply with IEC 60601-2-57, IEC 62471 (Matches predicates)
Software"Moderate level of concern" software documentation. All software requirement specifications met and hazards mitigated to acceptable risk levels. (Per 510(k) requirements for software in medical devices)Leaf Smooth: Software documentation consistent with moderate level of concern was submitted. System validation testing demonstrated all software requirement specifications are met and all software hazards have been mitigated to acceptable risk levels.
Performance TestingSpot Size Accuracy and Energy Output Accuracy verified.Leaf Smooth: Performance Testing for Spot Size Accuracy and Energy Output Accuracy was conducted. (Implied compliance with specifications, as stated in the conclusion that non-clinical tests verified all design specifications).

2. Sample Size Used for the Test Set and Data Provenance

  • Sample Size: Not explicitly stated as a number of "samples" in the context of a typical AI/ML test set. The testing conducted was primarily non-clinical (bench testing, electrical, light, EMC, biocompatibility).
  • Data Provenance: The tests are likely performed in a laboratory setting by the manufacturer (Shenzhen Leaflife Technology Co., Ltd) or a contract testing organization. The document does not specify a country of origin for data, but the manufacturer is based in Shenzhen, China.
  • Retrospective/Prospective: Not applicable to this type of non-clinical device testing.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications of Those Experts

  • Not applicable. Ground truth for non-clinical tests (e.g., electrical safety, light output) is established by adherence to recognized international standards (e.g., IEC, ISO, ANSI/AAMI) and the results are measurements from calibrated equipment, not expert consensus (as would be for image interpretation).

4. Adjudication Method for the Test Set

  • Not applicable. This is not a study assessing diagnostic performance where adjudication of ambiguous cases is required.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done

  • No. This is a hardware device submission, not an AI/ML device requiring an MRMC study to assess human reader improvement.
  • Effect Size: Not applicable.

6. If a Standalone (i.e. algorithm only without human-in-the loop performance) was done

  • Yes, in a sense. The "non-clinical tests" represent the standalone performance of the device against its design specifications and relevant safety standards. The device is intended for over-the-counter use by lay users, so there isn't a "human-in-the-loop" professional interpretation component that would differentiate from a "standalone algorithm." The device itself is the "algorithm" that produces the hair reduction effect.

7. The Type of Ground Truth Used

  • The "ground truth" for the non-clinical tests are the requirements set by the consensus standards (e.g., IEC 60601-1, ISO 10993 series) for electrical safety, biocompatibility, light safety, EMC, and the device's own design specifications for output (fluence, wavelength, spot size accuracy). These are objective, measurable criteria.

8. The Sample Size for the Training Set

  • Not applicable. This is not an AI/ML device that requires a training set. The device's "knowledge" is embedded in its hardware design and manufacturing processes based on engineering principles and regulatory standards.

9. How the Ground Truth for the Training Set Was Established

  • Not applicable (see #8).

In summary, the "study" proving the device meets its "acceptance criteria" for the Leaf Smooth (LH-LIPLB) device consists of a series of non-clinical bench tests (e.g., electrical safety, EMC, light safety, biocompatibility, performance accuracy) that confirm the device adheres to recognized international standards and its own design specifications, thereby demonstrating substantial equivalence to predicate devices and ensuring safety and effectiveness for its intended use. Clinical studies were explicitly stated as not included in this submission.

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Image /page/0/Picture/0 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.

November 19, 2021

Shenzhen Leaflife Technology Co., Ltd Cheng Qiang Regulatory Registration Supervisor 4 F,Bldg. C, JMD Industrial Park, No.39 Qingfeng Blvd., Baolong Industrial Area, Longgang District Shenzhen, Guangdong 518116 China

Re: K212697

Trade/Device Name: Leaf Smooth Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: OHT Dated: August 18, 2021 Received: August 25, 2021

Dear Cheng Qiang:

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 and Part 809); 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) K212697

Device Name Leaf Smooth

Indications for Use (Describe)

The Leaf Smooth is an over-the-counter device intended for removal of unwanted body and/or facial hair.

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 shows the logo for LEAFLIFE. The logo is composed of the word "LEAFLIFE" in a stylized font, with the "LEAF" portion in blue and the "LIFE" portion in green. Above the word "LEAFLIFE" is a green leaf and a series of green dots. Below the word "LEAFLIFE" are two Chinese characters in gray.

510(k) Summary

In accordance with 21 CFR 807.92 the following summary of information is provided:

SUBMITTER l.

Shenzhen Leaflife Technology Co., Ltd 4F, Bldg. C JMD Industrial Park, No.39 Qingfeng Blvd., Baolong Industrial Area, Longgang Dist., Shenzhen, RP China Phone: 086-(0)17875910506 Fax: 086-0755-27215592

Primary Contact Person:Cheng Qiang
Regulatory registration supervisor
Shenzhen Leaflife Technology Co., Ltd
Phone:086-(0)17875910506
Tel:086-0755-27216609
Fax:086-0755-27215592
Email:cq@leaflife.com

Date Prepared:

08/20/2021

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Image /page/4/Picture/1 description: The image shows the logo for LEAFLIFE. The logo has the word LEAFLIFE in blue and green, with a green leaf above the letter "E". There are also some Chinese characters below the word LEAFLIFE. The logo is simple and modern, and it conveys a sense of nature and health.

II. PROPOSED DEVICE

Trade Name:Leaf Smooth
Model(s):LH-LIPLB
Common Name:Light Based Over-The-Counter Hair Removal
Classification Name:Laser surgical instrument for use in general and plasticsurgery and in dermatology
Regulation Number:21 CFR 878.4810
Regulation Class:II
Product Code:OHT
Review Panel:General & Plastic Surgery

III. PREDICATE DEVICE

Predicate device 1#IPL Home Use Hair Removal Device, Model D-1128:K192432
Predicate device 2#IPL Salon Hair Reduction System, Model F60001:K181568
Predicate device 3#iPulse SmoothSkin Gold Hair Removal System, K160968

The predicate has not been subject to a design-related recall.

IV. DEVICE DESCRIPTION

The Leaf Smooth (LH-LIPLB) is a personal, light-based, hair reduction device intended to be sold over-the-counter directly to the end user. The device provides hair reduction using Intense Pulsed Light (IPL) technology. It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain. The device is only powered by the external power adapter and its IPL emission activation is by finger switch.

The device contains a Xenon Arc Flashlamp, capacitive sensor to detect appropriate skin contact and a skin sensor to detect appropriate skin color. If the device is not properly applied to the treatment area (in full contact with the skin), the device cannot emit the treatment light pulses. The device is for single-person use only.

The Leaf Smooth has 6 levels output intensity.

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Image /page/5/Picture/2 description: The image shows the logo for LEAFLIFE. The logo is composed of the word "LEAFLIFE" in blue and green, with a green leaf above the "L". There is a blue arc under the word "LEAFLIFE", and some Chinese characters to the right of the arc. The logo is simple and modern, and it conveys a sense of nature and freshness.

V. INTENDED USE

The Leaf Smooth is an over-the-counter device intended for removal of unwanted body and/or facial hair.

vi. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE

The Leaf Smooth (LH-LIPLB) has same intended use as the predicate devices. Technological characteristics such as fluence, laser wavelength, spot size, and pulse duration, of the Leaf Smooth device are similar to those of the predicate devices.

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Image /page/6/Figure/0 description: The image shows the logo for LEAFLIFE. The logo is in blue and green, with the word "LEAFLIFE" in blue and green. There is a green leaf above the word "LEAFLIFE". Below the word "LEAFLIFE" are two Chinese characters in gray.

ItemProposed DevicePredicate DeviceK192432(Primary)Predicate DeviceK181568Predicate DeviceK160968Remark
Device nameLeaf Smooth (LH-LIPLB)IPL Home Use Hair RemovalDeviceIPL Salon Hair ReductionSystemiPulse SmoothSkin Gold/
K numberOn pendingK192432K181568K160968/
Product codeOHTOHTOHTOHTSame
Classificationregulation21 CFR 878.481021 CFR 878.481021 CFR 878.481021 CFR 878.4810Same
Indications forUseThe Leaf Smooth is anover-the-counter deviceintended for removal ofunwanted body and/or facialhair.IPL Home Use Hair RemovalDevice is an over-the-counterdevice intended for removal ofunwanted body and/or facialhairThe IPL Salon Hair ReductionSystem (Model: F60001) isan over the Counter deviceintended for the removal ofunwanted body and/or facialhair in adults. It is alsointended for permanentreduction in unwanted hair.Permanent hair reduction isdefined as the long-termstable reduction in thenumber of hairs re-growingwhen measured at 6, 9 and12 months after thecompletion of a treatmentregimen.The iPulse SmoothSkin GoldHair Removal System isindicated for the removal ofunwanted hair. The iPulseSmoothskin Gold is alsoindicated for the permanentreduction in hair regrowth,defined as the long-term,stable reduction in the numberof hairs regrowing whenmeasured at 6, 9 and 12months after the completion ofa treatment regime.Same
Prescription useor notOTCOTCOTCOTCSame
ItemProposed DevicePredicate DeviceK192432(Primary)Predicate DeviceK181568Predicate DeviceK160968Remark
Pulsing controlFinger switchFinger switchFinger switchFinger switchSame
Delivery deviceDirect illumination to tissueDirect illumination to tissueDirect illumination to tissueDirect illumination to tissueSame
Energy mediumXenon Arc FlashlampXenon Arc FlashlampXenon Arc FlashlampXenon Arc FlashlampSame
Wavelengthrange475-1100 nm510-1100nm475-1200nm510-1100nmSimilar
Spot size3.8 $cm^2$4.5 $cm^2$ , 2.0 $cm^2$ , 3.0 $cm^2$3.02 $cm^2$1.72 $cm^2$3 $cm^2$Similar
Fluence4-6 J/ $cm^2$2.0-4.0 J/ $cm^2$ , 2.5-4.5 J/ $cm^2$Max 5 J/ $cm^2$3-6 J/ $cm^2$Similar
Pulse Duration2-10ms7.5-14ms11-12ms2-10msSimilar

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Image /page/7/Picture/0 description: The image shows the logo for LEAFLIFE. The logo is blue and green, with a stylized leaf above the text. The text is in a sans-serif font, and there is some Chinese text below the English text. The logo is simple and modern, and it conveys a sense of nature and life.

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Image /page/8/Picture/0 description: The image shows the logo for LEAFLIFE. The logo is in blue and green, with the word "LEAFLIFE" in blue and green letters. There is a green leaf above the "A" in LEAFLIFE. There is a blue curve below the "L" and "E" in LEAFLIFE. Below the word LEAFLIFE are two Chinese characters in gray.

ItemProposed DevicePredicate DeviceK192432Predicate DeviceK181568Predicate DeviceK160968Remark
Biocompatibility
CytotoxicityNo CytotoxicityNo CytotoxicityNo CytotoxicityNo CytotoxicitySame
SensitizationNo evidence of sensitizationNo evidence of sensitizationNo evidence of sensitizationNo evidence of sensitizationSame
IrritationNo evidence of irritationNo evidence of irritationNo evidence of irritationNo evidence of irritationSame
EMC, Electrical and Laser Safety
ElectricalSafetyComply with ANSI/AAMIES60601-1,IEC 60601-1-11Comply with IEC 60601-1,IEC 60601-1-11Comply with IEC 60601-1,IEC 60601-1-11Comply with IEC 60601-1,IEC 60601-1-11Same
EMCComply with IEC 60601-1-2Comply with IEC 60601-1-2Comply with IEC 60601-1-2Comply with IEC 60601-1-2Same
Light SafetyComply with IEC 60601-2-57,IEC 62471Comply with IEC 60601-2-57,IEC 62471Comply with IEC 60601-2-57,IEC 62471Comply with IEC 60601-2-57,IEC 62471Same

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Image /page/9/Picture/2 description: The image shows the logo for LEAFLIFE. The logo is a combination of text and a graphic. The text "LEAFLIFE" is written in a stylized font, with the "L" and "E" in blue, the "A" and "F" in green, and the "L", "I", "F", and "E" in blue. Above the text is a green leaf with a curved line. Below the text is some Chinese characters.

VII. Non-Clinical Test Conclusion

Non-clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:

ES60601-1:2005/(R) 2012 and A1:2012, C1:2009/(R)2012 and ANSI/AAMI A2:2010/(R)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 60601-1-11:2015, Medical electrical equipment - Part 1-11 General requirements for basic safety and essential performance - Collateral Standard: Requirements for medical electrical equipment and medical electrical systems used in the home healthcare environment.

IEC 60601-2-57:2011, Medical electrical equipment - Part 2-57: Particular requirements for the basic safety and essential performance of non-laser light source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use.

IEC 62471:2006, Photobiological safety of lamps and lamp systems.

ISO 10993-5 Third Edition 2009-06-01, Biological Evaluation of Medical Devices - Part 5: Tests For In Vitro Cytotoxicity. (Biocompatibility)

ISO 10993-10 Third Edition 2010-08-01, Biological Evaluation of Medical Devices -Part 10: Tests for Irritation and Skin Sensitization. (Biocompatibility)

Performance Testing for Spot Size Accuracy and Energy Output Accuracy.

Software documentation consistent with moderate level of concern was submitted in this 510(k). System validation testing presented in this 510(k) demonstrated that all software requirement specifications are met and all software hazards have been mitigated to acceptable risk levels.

VIII. CLINICAL TEST CONCLUSION

No clinical study is included in this submission.

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Image /page/10/Picture/2 description: The image shows the logo for LEAFLIFE. The logo is a combination of text and a graphic element. The text "LEAFLIFE" is written in a stylized font, with the letters in blue and green. Above the text is a green leaf. Below the text are two Chinese characters in gray.

IX. SUBSTANTIALLY EQUIVALENT (SE) CONCLUSION

The Leaf Smooth device has the same intended use and similar technology to those of the predicate devices. Performance testing conducted on the Leaf Smooth device supports that the Leaf Smooth can be used safely and effectively for the indications for use stated above.

Based on the comparison and analysis above, the proposed device is determined to be Substantially Equivalent (SE) to the predicate devices.

§ 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.