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510(k) Data Aggregation

    K Number
    K983543
    Date Cleared
    1998-12-16

    (68 days)

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

    For use in cutting, vaporizing and coagulating soft tissue for clinical applications in dermatology, plastic surgery, podiatry, neurosurgery, gynecology, otorhinolaryngology, arthroscopy, open & endoscopic general surgery.

    Device Description

    Accu-Pulse 1000 is a DC excited gas-slab pulsed CO2 laser which produces 1-15 watts average power (see below for additional Surgical specifications).

    AI/ML Overview

    Here's an analysis of the provided 510(k) summary regarding the Accu-Pulse 1000 CO2 Surgical Laser System:

    1. Table of Acceptance Criteria and Reported Device Performance

    The provided document does not explicitly present "acceptance criteria" in the format of pass/fail metrics with associated studies for the Accu-Pulse 1000 CO2 Surgical Laser System. Instead, it relies on demonstrating substantial equivalence to a previously marketed predicate device (Accu-Pulse pulsed CO2 laser). The "reported device performance" is essentially a comparison of specifications to the predicate device and another similar device.

    Here's a table based on the provided "Table of Substantial Equivalence":

    FeatureAcceptance Criteria (Predicate Device K971830)Reported Device Performance (Accu-Pulse 1000)Meets Criteria?
    Power1-15 Watts1-15 WattsYes
    Wavelength10.6 microns9.6 or 10.6 microns(See Note 1)
    Indications for UseCoagulation, vaporization, ablation of or cutting of soft tissue in dermatology, plastic surgery, podiatry and otorhinolaryngologyCoagulation, vaporization, ablation of or cutting of soft tissue in dermatology, plastic surgery, podiatry and otorhinolaryngologyYes
    Laser TypeDC slab excitedDC slab excitedYes
    Spot Size3mm, 5mm & 7mm250 microns-3mm(See Note 2)
    Average Power1-15 Watts1-15 WattsYes
    ModeMulti-modeTEM 00(See Note 3)
    Exposure Duration4 us4-10 ps(See Note 4)
    Control SystemMicroprocessor, self diagnosisMicroprocessor, self diagnosisYes
    Repetition Rate0.5-5Hz1-20 Hz(See Note 5)
    Aiming Beam633 nanometer633 nanometerYes
    ExcitationDC excitedDC excitedYes

    Notes on "Meets Criteria?":

    1. Wavelength: The Accu-Pulse 1000 offers an additional wavelength (9.6 microns) which is a difference from the predicate. The FDA's approval indicates this difference was considered acceptable for substantial equivalence, likely due to similar tissue interaction properties or it being an enhancement.
    2. Spot Size: The Accu-Pulse 1000 has a significantly different spot size range (250 microns-3mm) compared to the predicate (3mm, 5mm & 7mm). This represents a change in performance/capability. Again, the FDA's approval implies this was deemed acceptable for substantial equivalence, perhaps offering more precise control.
    3. Mode: The Accu-Pulse 1000 operates in "TEM 00" mode, while the predicate is "Multi-mode". TEM 00 (Transverse Electromagnetic Mode 00) is often referred to as a Gaussian mode and typically provides a more focused and precise beam profile compared to multi-mode. This is a significant difference in laser beam quality and performance. The FDA's acceptance suggests this change was considered an improvement or not a significant safety/effectiveness difference that would preclude substantial equivalence.
    4. Exposure Duration: The Accu-Pulse 1000's exposure duration is in picoseconds (ps) versus microseconds (us) for the predicate. This is a massive difference (picoseconds are orders of magnitude shorter than microseconds). Ultrafast lasers (picosecond/femtosecond) have very different tissue interaction characteristics (e.g., photoablation with minimal thermal damage). This is a major technological change and would typically require a strong justification for substantial equivalence if the indications for use remain the same. The FDA's approval implies this difference was considered acceptable.
    5. Repetition Rate: The Accu-Pulse 1000 has a higher repetition rate (1-20 Hz) compared to the predicate (0.5-5Hz). This allows for faster treatment.

    Study That Proves the Device Meets Acceptance Criteria:

    The document explicitly states: "Performance Data: None. The specifications and intended use of the Accu-Pulse 1000 Surgical Laser System are the same or very similar to those of the Accu-Pulse pulsed CO2 laser. Because of this, performance data were not required."

    Therefore, there was no specific study conducted to prove the Accu-Pulse 1000 meets acceptance criteria in the traditional sense of comparative clinical or non-clinical performance data. The device's acceptance was based on a demonstration of substantial equivalence to a predicate device, arguing that its design and performance specifications are comparable or improved such that new safety and effectiveness concerns are not raised.


    Detailed Information based on the provided text:

    2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

    • Sample size for test set: Not applicable. No performance data or test set was used for substantial equivalence.
    • Data provenance: Not applicable.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

    • Not applicable. No ground truth was established by experts for a test set. Substantial equivalence was determined by comparing technical specifications and intended use with a predicate device.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. No test set requiring adjudication was used.

    5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

    • Not applicable. This is a surgical laser system, not an AI-assisted diagnostic device, and no MRMC study was performed.

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

    • Not applicable. This is a surgical laser system, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • Not applicable. The basis for approval was substantial equivalence to a predicate device, rather than performance against a defined ground truth derived from clinical data. The "ground truth" in this context is the established safety and effectiveness of the predicate device.

    8. The sample size for the training set

    • Not applicable. This is a physical device, not an AI model requiring a training set. The mention of "Software Development Procedure" and "software will be verified and validated" refers to internal software quality assurance processes for the device's control system, not machine learning model training.

    9. How the ground truth for the training set was established

    • Not applicable for the same reasons as above. The software validation mentioned refers to standard software engineering practices (verification against specifications, validation through testing against intended use and intentional breaches/breaks to confirm safety interlocks and input parameters), not ground truth for a machine learning model.
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    K Number
    K971830
    Date Cleared
    1997-08-14

    (90 days)

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

    For use in cutting, vaporizing and coagulating soft tissue for clinical applications in dermatology, plastic surgery, podiatry, neurosurgery, gynecology, otorhinolaryngology, arthroscopy, open & endoscopic general surger y

    Device Description

    Accu-Pulse is a DC excited gas-slab pulsed CO2 laser which produces 1-15 watts average power (see below for additional Surgical specifications).

    AI/ML Overview

    The document provided is a 510(k) summary for the Accu-Pulse CO2 Surgical Laser System. It focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than presenting a study to prove the device meets specific acceptance criteria. Therefore, most of the requested information regarding acceptance criteria and a study to prove device performance is not available in the provided text.

    Here's a breakdown of the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The submission does not present a formal table of acceptance criteria with corresponding device performance metrics from a study. Instead, it provides a "Table of Substantial Equivalence" which compares the Accu-Pulse to two predicate devices on various features. This table implicitly defines the acceptable range of performance as being comparable to the predicate devices.

    FeaturePredicate Device (Tissue Technologies Tru-Pulse)Accu-Pulse (Reported Performance)
    Power1-10 Watts1-15 Watts
    Wavelength10.6 microns10.6 microns
    Energy Density at Tissue5 J/cm²5 J/cm²
    Indications for UseCoagulation, vaporization, ablation of or cutting of soft tissue in dermatology, plastic surgery, podiatry and otorhinolaryngologyCoagulation, vaporization, ablation of or cutting of soft tissue in dermatology, plastic surgery, podiatry and otorhinolaryngology
    Laser TypeDC slab excitedDC slab excited
    Spot Size1, 3, 5mm3mm, 5mm & 7mm
    Average Power1-10 Watts1-15 Watts
    ModeMulti-modeMulti-mode
    Exposure Duration
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