(29 days)
No
The document describes a laser system with standard components and operation, with no mention of AI or ML in the intended use, device description, or performance studies.
Yes
The device is indicated for medical procedures such as coagulation, cutting of soft tissue, and skin resurfacing, which are therapeutic interventions.
No.
The device's intended use is for coagulation or cutting of soft tissue and skin resurfacing, which are therapeutic procedures, not diagnostic ones.
No
The device description clearly states it is a pulsed Er:YAG laser system comprising a main console unit, detachable handpieces, and a footswitch, indicating it is a hardware-based medical device.
Based on the provided information, the Dermablate System is not an In Vitro Diagnostic (IVD) device.
Here's why:
- Intended Use: The intended use clearly states that the device is used for "coagulation, or cutting of soft tissue (skin)" and "Dermatological procedures and Skin resurfacing procedures." These are direct surgical or therapeutic interventions on the patient's body.
- Device Description: The description details a laser system that emits a wavelength to interact with tissue. This is consistent with a surgical or therapeutic device, not a device that analyzes samples outside the body.
- Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue samples, etc.) or providing diagnostic information based on such analysis. IVD devices are designed to examine specimens obtained from the human body to provide information for diagnosis, monitoring, or screening.
Therefore, the Dermablate System is a medical device used for surgical and therapeutic procedures, not an IVD.
N/A
Intended Use / Indications for Use
Dermablate System with its accessories is indicated for coagulation, or cutting of soft tissue (skin) in Dermatology, Plastic Surgery, Oral Surgery, ENT, Gynecology, General Surgery, Podiatry, and Ophthalmology (skin around the eyes).
Dermablate System, when used with its micro beam handpieces, is intended for use in Dermatological procedures and Skin resurfacing procedures.
Product codes
GEX
Device Description
Dermablate is a pulsed Er:YAG laser emitting a wavelength of 2940 nm. The system comprises a main console unit, detachable handpieces, and a footswitch. The device can be operated with micro beam and non-micro beam handpieces. The system incorporates a suction unit for the safe removal of laser plume. The laser is fired with a foot-operated switch (footswitch).
Mentions image processing
Not Found
Mentions AI, DNN, or ML
Not Found
Input Imaging Modality
Not Found
Anatomical Site
soft tissue (skin), skin around the eyes
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 device underwent and successfully passed performance testing and software verifications and validation according to the relevant standards.
Dermablate passed all the required testing and is in compliance will all applicable sections of the abovementioned performance standards.
Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)
Not Found
Predicate Device(s)
Reference Device(s)
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/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, with the letters "FDA" in a blue box. To the right of the blue box is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
July 3, 2024
Asclepion Laser Technologies GmbH Tom Gruender RA Manager Bruesseler Strasse 10 Jena, 07745 Germany
Re: K241600
Trade/Device Name: Dermablate 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 23, 2024 Received: June 4, 2024
Dear Tom Gruender:
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 (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 available at https://www.accessdata.fda.gov/scripts/cdrb/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
Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).
Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).
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 Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.
Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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).
2
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-devices/deviceadvice-comprehensive-regulatory-assistance/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,
| Digitally signed by | |
|---|---|
| TANISHA | TANISHA L. HITHE - |
| L. HITHE -S | Date: 2024.07.03 |
| 10:25:21 -04'00' |
Tanisha Hithe Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical & Infection Control Devices, Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
3
Indications for Use
510(k) Number (if known) K241600
Device Name Dermablate
Indications for Use (Describe)
Dermablate System with its accessories is indicated for coagulation, or cutting of soft tissue (skin) in Dermatology, Plastic Surgery, Oral Surgery, ENT, Gynecology, General Surgery, Podiatry, and Ophthalmology (skin around the eyes).
Dermablate System, when used with its micro beam handpieces, is intended for use in Dermatological procedures and Skin resurfacing procedures.
| Type of Use (Select one or both, as applicable) | |
|---|---|
| Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff(@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
4
510(k) Summa K2416
| Applicant /
| Manufacturer | Asclepion Laser Technologies GmbH | |
|---|---|---|
| Name and Address: | Bruesseler Strasse 10, 07745 Jena - Germany | |
| 510(k) Contact Person: | Mr. Tom Gruender | |
| Regulatory Affairs Manager | ||
| Tel.: 0049 3641 7700 201 | ||
| E-Mail: tom.gruender@asclepion.com | ||
| Date Prepared: | July 2, 2024 | |
| Trade Name: | Dermablate | |
| Classification: | Class II | |
| Classification Name: | Laser surgical instrument for use in general and plastic surgery | |
| and in dermatology. | ||
| Regulation Number: | 21 CFR 878.4810 | |
| Product Code: | GEX | |
| Main Predicate Device | MCL 31 Dermablate (K210634), Asclepion Laser Technologies | |
| GmbH | ||
| Reference Device | Erise (K202258), El.En SpA |
Description of the device:
Dermablate is a pulsed Er:YAG laser emitting a wavelength of 2940 nm. The system comprises a main console unit, detachable handpieces, and a footswitch. The device can be operated with micro beam and non-micro beam handpieces. The system incorporates a suction unit for the safe removal of laser plume. The laser is fired with a foot-operated switch (footswitch).
Description of the modifications:
The laser is a modification to previously cleared MCL 31 Dermablate due the following main technical modifications:
- Increase of max pulse energy to 3J.
- Adding of a microbeam handpiece named "DeepSpot".
Hardware and software changes were implemented to accommodate the changes mentioned above.
The modified device has the same intended use of the unmodified device. Moreover, the intended use of the modified device, as described in its labeling, has not changed as a result of the modifications.
5
Based on the nature of the changes implemented, the device underwent and successfully passed performance testing and software verifications and validation according to the relevant standards.
Intended Use:
Dermablate with its accessories is indicated for coagulation, vaporization, ablation, or cutting of soft tissue (skin) in Dermatology, Plastic Surgery, Oral Surgery, ENT, Gynecology, General Surgery, Podiatry, and Ophthalmology (skin around the eyes).
Dermablate, when used with its micro beam handpieces, is intended for use in Dermatological procedures and Skin resurfacing procedures.
| | Main
Predicate Device | Reference
Predicate Device | Subject device |
|-------------------------------|--------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------|
| | MCL 31 Dermablate | Erise | Dermablate |
| 510k number | K210634 | K202258 | |
| Device Type | Er:YAG | Er:YAG | Er:YAG |
| Wavelength | 2940 nm | 2940 nm | 2940 nm |
| Energy, max | 2.5 J | 31 | 3 J |
| Fluence, max. | Up to 250 J/cm2 (non
microbeam mode)
Up to 150 J/cm2
(microbeam mode with
stacking pulses) | Up to 95 J/cm2 (non
microbeam mode)
Up to 121 J/cm2
(microbeam mode with
stacking pulses) | Up to 250 J/cm2 (non
microbeam mode)
Up to 150 J/cm2
(microbeam mode with
stacking pulses) |
| Pulse Duration | 0.1 to 1ms | 0.3 to 1.5ms | 0.1 to 1ms |
| Repetition rate,
max | 20 Hz | 6Hz | 20 Hz |
| Treatment area /
Spot size | VarioTEAM Handpieces:
from 1 to 12 mm | 2/4/9mm | VarioSpot Handpieces:
from 1 to 12 mm |
| | MicroSpot Handpiece:
350 µm to 600 µm spot
MY JULIET Handpiece:
425 µm & 600 µm spot | 300-600 µm microdot
diameter | MicroSpot Handpiece:
350 um to 600 um spot
DeepSpot Handpiece:
325 um to 400 um spot |
| | | | MY JULIET Handpiece:
425 µm & 600 µm spot |
Technological Characteristics Comparison
Non clinical Performance Data:
The following performance data were applied in support of the substantial equivalence determination:
- IEC 60601-1-6:2010/AMD1:2013: Medical electrical equipment Part 1: General requirements for . safety and essential performance
6
- . IEC 60601-1-2:2015: Medical electrical equipment – Part 1-2: General requirements for safety and essential performance – Collateral standard: Electromagnetic compatibility – Requirements and tests
- IEC 62304: Medical Device Software – Software life cycle processes
- IEC 62366-1:2015: Medical devices – Application of usability engineering to medical devices
- IEC 60601-2-22:2019: Medical electrical equipment – Part 2: Particular requirements for the safety of diagnostic and therapeutic laser equipment
- IEC 60825-1:2014: Safety of laser products - Part 1: Equipment classification, and requirement
- ISO 14971: Medical devices - Application of risk management to medical devices
- . Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices".
- EN/ISO 10993-1: Biological evaluation of medical devices - Part 1: Evaluation and testing
- within a risk management process
- . ISO 10993-5: Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
- ISO 10993-10: Biological evaluation of medical devices - Part 10 Tests for irritation and skin
- sensitization
- . ISO 10993-23: Biological evaluation of medical devices - Part 23 Tests for irritation
Dermablate passed all the required testing and is in compliance will all applicable sections of the abovementioned performance standards.
Biocompatibility:
The biocompatibility of Dermablate handpieces is established based on the predicate devices.
Comparison with predicate device:
The subject and predicate devices have intended use and the same fundamental scientific technology. Any minor difference does not raise concern about safety and effectiveness.
Conclusions
The differences in the indications for use and technological characteristics between the subject and predicate device do not raise new types of questions regarding safety and effectiveness, and the subject device is as safe, as effective, and performs as well as the legally marketed predicate devices.