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510(k) Data Aggregation

    K Number
    K191086
    Device Name
    Exciplex
    Manufacturer
    Date Cleared
    2019-12-11

    (231 days)

    Product Code
    Regulation Number
    878.4630
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Exciplex

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

    The exciplex® is intended to be used for the treatment of psoriasis, vitiligo, atopic dermatitis, and leukoderma. The reusable polycarbonate/ABS reduction tips and reusable silicone masks are for use on intact skin only.

    Device Description

    The Exciplex is a compact handheld excimer device that emits a narrow-band UVB light at 308 nm. This ultraviolet wavelength of light is known to be beneficial in the treatment of various dermatological conditions such as psoriasis and vitiligo. The UVB light is homogeneously delivered through a 5x5 cm² output window at an irradiance of 100 mW/cm². Treatments are performed by applying the output window over the affected area with the help of reduction tips or silicone masks to shield the surrounding healthy skin. A treatment might consist of a series of light pulses where the device is used multiple times along the affected area.

    AI/ML Overview

    The provided text is a 510(k) summary for the Exciplex device, which is an ultraviolet lamp for dermatologic disorders. The summary focuses on establishing substantial equivalence to a predicate device (K171702, also named Exciplex308nm/Clarteis) rather than presenting a study demonstrating the device meets a set of performance acceptance criteria.

    The key information provided is that the subject device has identical design, dimensions, materials, intended use, and technological characteristics (light source, wavelength, treatment area size, fluence range) as the predicate device. The main differences are:

    1. Reprocessing of existing silicone masks and reduction tips: In the subject device, these components are reusable, whereas in the predicate device, they were single-use.
    2. Minor software changes: These changes do not affect the intended use.

    Therefore, the "acceptance criteria" and the "study that proves the device meets the acceptance criteria" in this context are focused on these differences, specifically demonstrating that the reusability and software changes do not negatively impact safety and effectiveness compared to the predicate.

    Here's the information requested, extrapolated from the provided text:

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

    Acceptance Criteria CategorySpecific CriteriaReported Device Performance/Testing
    Reprocessing ValidationReprocessing methods for reusable components (reduction tips and silicone masks) must be acceptable and not raise new safety and effectiveness issues compared to the predicate device.Reprocessing of reduction tips and silicone masks was validated per AAMI TIR 12:2010 ("Designing, testing, and labeling reusable medical devices for reprocessing in health care facilities: A guide for medical device manufacturers") and AAMI TIR 30:2011 ("A compendium of processes, materials, test methods, and acceptance criteria for cleaning reusable medical devices").
    Software VerificationSoftware changes must not affect the safety and effectiveness of the device compared to the predicate.Software development and testing were executed in compliance with IEC 62304 ("Medical device software – Software life cycle processes") and ISO 14971 ("Medical devices - Application of risk management to medical devices"). Verification and validation testing were conducted to ensure that the software changes do not affect safety and effectiveness.
    Clinical Performance(Implicit: Clinical performance is substantially equivalent to predicate)No clinical data were provided to demonstrate substantial equivalence, based on the assertion that the device has identical design, intended use, and technological characteristics to the predicate, with differences only in reusability and minor software changes.

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

    The document does not specify a "test set sample size" in the context of clinical data for the subject device because no clinical data were provided. The testing performed was non-clinical (reprocessing validation and software verification). For these non-clinical tests, specific sample sizes (e.g., number of tips/masks reprocessed, number of software test cases) are not detailed in this summary.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    Not applicable. No clinical expert-driven ground truth was established for the subject device's performance demonstration. Non-clinical testing relied on industry standards and internal verification/validation processes.

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

    Not applicable. No expert adjudication method (like 2+1, 3+1) was used as there was no clinical study generating data requiring such adjudication.

    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 an ultraviolet lamp for dermatologic disorders, not an AI-assisted diagnostic tool.

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

    Not applicable. This device is an ultraviolet lamp, not an algorithm.

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

    For the non-clinical tests:

    • Reprocessing Validation: "Ground truth" was adherence to established industry standards (AAMI TIR 12:2010 and AAMI TIR 30:2011) and demonstrating that cleaning methods are acceptable and do not compromise material integrity or safety.
    • Software Verification: "Ground truth" was adherence to established software development and risk management standards (IEC 62304 and ISO 14971) and successful completion of verification and validation testing, ensuring software functions as intended and does not negatively impact device safety or effectiveness.

    8. The sample size for the training set

    Not applicable. This device is an ultraviolet lamp; no training set in the machine learning sense is relevant for its safety and effectiveness demonstration in this submission.

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

    Not applicable, as there was no training set.

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    K Number
    K171702
    Device Name
    Exciplex308nm
    Manufacturer
    Date Cleared
    2017-10-13

    (127 days)

    Product Code
    Regulation Number
    878.4630
    Reference & Predicate Devices
    Why did this record match?
    Device Name :

    Exciplex308nm

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

    The Exciplex308nm is intended to be used for the treatment of psoriasis, vitiligo, atopic dermatitis, and leukoderma.

    Device Description

    The Exciplex 308m" is a compact handheld excimer device that emits a narrow-band UVB light at 308nm. This ultraviolet wavelength of light is known to be beneficial in the treatment of various dermatological conditions such as psoriasis and vitiligo. The UVB light is homogeneously delivered through a 5x5cm² output window at an irradiance of 100mW/cm². Treatments are performed by applying the output window over the affected area with the help of treatment tips or silicone masks to shield the surrounding healthy skin. A treatment might consist of a series of light "shots" where the device is used multiple times along the affected area.

    AI/ML Overview

    The provided text describes a 510(k) premarket notification for the Exciplex308nm device. This type of submission relies on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving safety and efficacy through clinical studies with predefined acceptance criteria. Therefore, the information requested in the prompt, which typically relates to clinical trials and statistical endpoints, is not fully present in the provided document.

    Here's an analysis based on the available information:

    1. Table of Acceptance Criteria and Reported Device Performance:

    The document does not provide a table of acceptance criteria and reported device performance in the context of a clinical study with pre-defined statistical endpoints. Instead, it describes non-clinical performance and substantial equivalence to predicate devices.

    The "performance" described relates to:

    • Irradiance uniformity: This is mentioned as part of the testing performed.
    • Ability of masks and tips to block UV light: Also mentioned as testing performed.
    • Classification of the UV lamp: This refers to safety standards.
    • Software and hardware verification testing: This ensures the device functions as designed.

    The acceptance of the device is based on demonstrating that these technical aspects meet relevant industry standards and that the device is substantially equivalent to existing predicate devices.

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

    No clinical test set is mentioned for evaluating the device's efficacy against specific acceptance criteria. The performance data discussed are non-clinical, related to the device's technical specifications and safety.

    3. Number of Experts Used to Establish Ground Truth and Qualifications:

    Not applicable. The document does not describe a study where experts established ground truth for a test set.

    4. Adjudication Method:

    Not applicable. No clinical test set requiring adjudication is mentioned.

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

    No MRMC study was performed or is referenced in this document. The submission is not for an AI-assisted device in that context.

    6. Standalone Performance:

    The document describes the device's technical performance (e.g., irradiance, UV blocking by accessories, software/hardware function) which could be considered "standalone" in the sense of evaluating the device's intrinsic characteristics. However, this is not a standalone clinical performance study against a specific clinical ground truth.

    7. Type of Ground Truth Used:

    For the non-clinical performance evaluation, the "ground truth" would be the established engineering and safety standards (e.g., IEC standards, irradiance specifications).

    8. Sample Size for the Training Set:

    Not applicable. This is not an AI/machine learning device requiring a training set.

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

    Not applicable.


    Summary of what is present in the document regarding "acceptance":

    The acceptance of the device by the FDA is based on demonstrating substantial equivalence to existing predicate devices (K073066, K150752, K051428) in terms of:

    • Intended Use: "treatment of psoriasis, vitiligo, atopic dermatitis, and leukoderma."
    • Technological Characteristics: light source, wavelength (308nm), treatment area size (5x5cm²), fluence range.
    • Performance: Non-clinical testing was performed to demonstrate safety based on current industry standards. These tests include:
      • Software Verification (compliance to IEC 60601-1, IEC 62304, ISO 14971)
      • Electromagnetic Compatibility and Electrical Safety (compliance to IEC 60601-1, IEC60601-1-2, IEC 60601-2-57)
      • Performance and usability testing (compliance to IEC 62471, IEC 62366-1, IEC 60601-1-6)
      • Irradiance uniformity
      • Ability of masks and tips to block UV light
      • Classification of the UV lamp

    The conclusion states that based on this testing, the device "does not raise new issues of safety or effectiveness compared to the predicate devices."

    In essence, the "acceptance criteria" here are that the new device is functionally and safely similar enough to already cleared devices that it doesn't require a full clinical trial to prove efficacy and safety from scratch.

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