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510(k) Data Aggregation

    K Number
    K030510
    Date Cleared
    2003-05-14

    (84 days)

    Product Code
    Regulation Number
    878.4810
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    DEPILASE TWIN YAG LASER SYSTEM

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DEPILASE TWIN YAG Laser System is intended for the coagulation and haemostasis of vascular lesions (1064 and 532 nm wavelengths), the removal and permanent reduction of unwanted hair in Fitzpatrick skin type I - VI and the dermatological use for the non invasive treatment of facial wrinkles (1064 nm wavelength).

    Device Description

    The DEPILASE TWIN YAG Laser System is based on Nd: YAG laser technology. Within the system, an optical cavity contains the Nd: YAG crystal, which is activated by means of the use of a flashlamp, with the option of frequency doubling the fundamental laser wavelength, from 1064 nm to 532 nm. The frequency doubling wavelength is obtained by passing with the laser radiation through a special crystal called Second Harmonic Crystal (SHC). After the cavity, a red diode aiming beam is reflected onto a coaxial beam path using a beamsplitter assembly. The combined therapeutic and aiming beams are guided down an optical fibre delivery system to a focusing handpiece. The laser is used in a non-contact mode.

    The DEPILASE TWIN YAG Laser System is designed with 5 major sub-systems:
    a) A high voltage power supply which converts and rectifies the a.c. mains current to provide regulated power for the flashlamp simmer current and main triggering pulse.
    b) A cooling system consisting of an internal water flow circuit together with water to air heat exchanger.
    c) An Nd: YAG laser rod, capable of generating optical pulses at a frequency up to 3 Hz
    d) An optical delivery system, interfacing the energy from the laser to the patient via an optical fibre and focusing handpiece.
    e) The microprocessor based controller which regulates the functions of the laser and allows parameter selection by the user.

    AI/ML Overview

    The provided text is a 510(k) summary for the DEPILASE TWIN YAG Laser System. It focuses on demonstrating substantial equivalence to a predicate device rather than describing a performance study with specific acceptance criteria and detailed results.

    Therefore, most of the information requested regarding acceptance criteria, study design, sample sizes, ground truth establishment, expert qualifications, and MRMC studies is not present in the provided document.

    Here's a breakdown of what can and cannot be extracted:

    1. A table of acceptance criteria and the reported device performance

    • Not present. The document does not specify quantitative acceptance criteria for device performance or report specific performance metrics from a study. It asserts "The DEPILASE TWIN YAG Laser System output characteristics are very similar to those of the predicate device" but provides no data.

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

    • Not present. No test set or clinical study data is described. The submission relies on substantial equivalence to a previously cleared device.

    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 present. No ground truth establishment for a test set is described.

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

    • Not present. No adjudication method is described because no test set or clinical study is detailed.

    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 device is a laser system for dermatological applications, not an AI-based diagnostic tool that would typically involve human readers or MRMC studies. No such study is mentioned.

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

    • Not applicable. This is a laser device, not an algorithm. Standalone performance is not relevant in the context of this device type as it's not an AI/software-as-a-medical-device.

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

    • Not present. No ground truth is described because no clinical performance study is detailed.

    8. The sample size for the training set

    • Not applicable/Present (indirectly). This device is a physical laser system, not a machine learning algorithm that requires a "training set" in the conventional sense. The "training" for this device would refer to its design, engineering, and manufacturing process based on established laser technology. The comparison focuses on the predicate device, the Laserscope Lyra (K020021), which serves as the benchmark for equivalence.

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

    • Not applicable. As above, no training set for an AI algorithm is involved.

    Summary of Device and Equivalence Claim (from the document):

    The DEPILASE TWIN YAG Laser System is an Nd:YAG laser system for dermatological applications.

    Intended Use: Non-invasive treatment of facial wrinkles (1064 nm laser emission). Other indications mentioned in Appendix F include: coagulation and haemostasis of vascular lesions (1064 and 532 nm wavelengths), and removal and permanent reduction of unwanted hair in Fitzpatrick skin type I - VI.

    Substantial Equivalence Claim: The device is claimed to be substantially equivalent to the Laserscope Lyra (K020021) Nd:YAG laser for the non-invasive treatment of facial wrinkles.

    Basis for Equivalence:

    • Identical intended use for facial wrinkles.
    • Technologically identical characteristics: flashlamp pumped Nd:YAG laser rod generating 1064 nm light, delivered via optical fiber and focusing handpiece.
    • "Very similar" output characteristics to the predicate device.
    • Both are microprocessor-controlled.
    • Both use Class I aiming beams.
    • Both use internal closed-loop water-air heat exchange for thermal control.
    • Risk and benefits are comparable to the predicate device for similar applications.

    The document does not detail a study conducted with the DEPILASE TWIN YAG Laser System to prove it meets specific acceptance criteria. Instead, it argues that its device is equivalent to a legally marketed predicate device, relying on the predicate's prior clearance and established safety and effectiveness.

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    K Number
    K020697
    Date Cleared
    2002-04-12

    (39 days)

    Product Code
    Regulation Number
    878.4810
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    DEPILASE TWIN YAG LASER SYSTEM

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The DEPILASE TWIN YAG Laser System is intended for the coagulation and haemostasis of vascular lesions( 1064 and 532 nm wavelengths) and the removal and permanent reduction of unwanted hair in Fitzpatrick skin types I -VI, including suntanned skin types (1064 nm wavelength).

    Device Description

    The DEPILASE TWIN YAG Laser System is based on Nd: YAG laser technology. Within the system, an optical cavity contains the Nd: YAG crystal, which is activated by means of the use of a flashlamp, with the option of frequency doubling the fundamental laser wavelength, from 1064 nm to 532 nm. The frequency doubling wavelength is obtained by warelonging with the laser radiation through a special crystal called Second Harmonic Crystal (SHC). After the cavity, a red diode aiming beam is reflected onto a coaxial beam path using (SHO). The combined therapeutic and aiming beams are guided down an optical fibre delivery system to a focusing handpiece. The laser is used in a non-contact mode.

    The DEPILASE TWIN YAG Laser System is designed with 5 major sub-systems:

    • a) A high voltage power supply which converts and rectifies the a.c. mains current to provide regulated power for the flashlamp simmer current and main triggering pulse.
    • b) A cooling system consisting of an internal water flow circuit together with water to air heat exchanger.
    • c) An Nd: YAG laser rod, capable of generating optical pulses at a frequency up to 3 Hz
    • d) An optical delivery system, interfacing the energy from the laser to the patient via an optical fibre and focusing handpiece.
    • e) The microprocessor based controller which regulates the functions of the laser and allows parameter selection by the user.
    AI/ML Overview

    Here's an analysis of the provided text regarding the Depilase Twin YAG Laser System, focusing on the acceptance criteria and study information.

    It's important to note that the provided 510(k) summary is for a laser system, not an AI/ML powered device. Therefore, many of the requested elements pertaining to AI/ML device studies (such as sample sizes for test and training sets, ground truth establishment, expert adjudication, MRMC studies, and standalone performance) are not applicable and will be marked as such. The "acceptance criteria" for this type of device typically revolve around demonstrating substantial equivalence to a predicate device in terms of intended use, technological characteristics, and safety/effectiveness.

    Acceptance Criteria and Study Information for Depilase Twin YAG Laser System (K020697)

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance
    Intended Use EquivalenceThe device's indications for use must be substantially equivalent to those of legally marketed predicate devices.Met: The DEPILASE TWIN YAG Laser System is indicated for:
    1. Coagulation and haemostasis of vascular lesions (1064 nm and 532 nm wavelengths).
    2. Removal and permanent reduction of unwanted hair in Fitzpatrick skin types I - VI, including suntanned skin types (1064 nm wavelength).
      These indications are stated to be the same as those of the predicate devices: Laserscope Lyra (K990718) and Altus Medical Aesthetic CoolGlide (K991798) for hair removal/vascular lesions (Nd:YAG), and Fotona Dualis KTP (K011939) for vascular lesions (532 nm). |
      | Technological Equivalence | The device's technological characteristics must be identical or very similar to those of legally marketed predicate devices, and any differences should not raise new questions of safety or effectiveness. | Met: The DEPILASE TWIN YAG Laser System, like the predicate devices, comprises:
    • Flashlamp-pumped Nd:YAG laser rod generating light at 1064nm (with optional 532nm via SHC).
    • Optical fiber delivery system and focusing handpiece.
    • Microprocessor controlled.
    • Class I aiming beams.
    • Internal closed-loop water-air heat exchange for thermal control.
      The output characteristics are reported as "very similar" to predicate devices. |
      | Safety and Effectiveness | The risks and benefits of the device, when used for its intended applications, must be comparable to those of the predicate devices, and the device should not raise new questions of safety or effectiveness. | Met: The submission asserts that "The risk and benefits of the DEPILASE TWIN YAG Laser System are comparable to the predicate devices when used for similar clinical applications." Concludes: "It is therefore believed that there are no new questions of Safety or Effectiveness raised by the introduction of this device." This is indirectly evidenced by the FDA's clearance of the device based on substantial equivalence. |

    2. Sample Size for the Test Set and Data Provenance

    • Not Applicable (N/A) for AI/ML device: This is a laser system, not an AI/ML device. Therefore, there isn't a "test set" in the context of evaluating algorithm performance on a dataset of images or other data types. The submission relies on demonstrating engineering and clinical equivalence to existing predicate devices.

    3. Number of Experts and Qualifications for Ground Truth

    • N/A for AI/ML device: Ground truth for AI/ML performance evaluation is not relevant for this type of laser system submission. The "ground truth" implicitly assessed here is the established safety and effectiveness of the predicate devices.

    4. Adjudication Method for the Test Set

    • N/A for AI/ML device: No test set or adjudication method as would be used for AI/ML algorithm performance.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    • No MRMC study performed: As this is a laser system, an MRMC study comparing human readers with and without AI assistance is not applicable. The device's effectiveness is established through clinical equivalence to predicate devices, not by assisting human interpretation of data.

    6. Standalone (Algorithm Only) Performance Study

    • No Standalone Study Performed: Not an AI/ML device. The "standalone" performance for this laser system would refer to its physical output and functional specifications, which were likely tested during development and manufacturing, but not in a formal "standalone performance study" akin to an AI algorithm.

    7. Type of Ground Truth Used

    • Clinical Equivalence/Predicate Devices' Established Safety and Effectiveness: For this type of device, the "ground truth" essentially comes from the established safety and effectiveness records and clinical use history of the identified predicate devices (Laserscope Lyra, Altus Medical Aesthetic CoolGlide, Fotona Dualis KTP). The applicant is arguing that their device operates similarly and achieves comparable outcomes, thus leveraging the "ground truth" already established for the predicates.

    8. Sample Size for the Training Set

    • N/A for AI/ML device: There is no "training set" as would be used for an AI/ML algorithm.

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

    • N/A for AI/ML device: No training set, therefore no associated ground truth establishment method.

    Summary of the Study (Substantial Equivalence Argument):

    The "study" presented in this 510(k) is a demonstration of substantial equivalence (not a randomized controlled trial or an AI performance study). The applicant, Depilase Group Ltd., systematically compares their DEPILASE TWIN YAG Laser System against three predicate devices already cleared by the FDA:

    The core of their argument is that their device shares identical intended use (coagulation/haemostasis of vascular lesions, permanent hair reduction) and substantially similar technological characteristics (Nd:YAG laser with optional 532nm, fiber optic delivery, microprocessor control, aiming beam, cooling system) with these predicates. They also assert that the device's output characteristics are "very similar" to the predicates. By demonstrating these similarities, the applicant aims to convince the FDA that their device raises no new questions of safety or effectiveness beyond what has already been established for the predicate devices. The FDA's clearance indicates their concurrence with this argument.

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