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510(k) Data Aggregation

    K Number
    K234104
    Manufacturer
    Date Cleared
    2024-03-15

    (80 days)

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

    PICOANDY (Q-Switched Nd:YAG Laser)

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

    The PICOANDY is indicated for the following at the specified wavelength:

    · 1064 mm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.

    · 532 nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.

    · Treatment of benign pigmented lesions for Fitzpatrick skin types I-IV.

    Device Description

    The PICOANDY is the solid state laser capable of delivering energy at wavelengths of 1064nm or 532nm at short durations. The device system consists of a main unit, an articulated arm, a handpiece and a foot switch. The laser output is delivered to the skin through the articulated arm delivery system terminated by the handpiece. The fluence (energy density) and frequency are controlled from the LCD display/Touch Pad located on the front of the main unit. The LCD display is used to obtain feedback from the system, such as the number of pulses delivered or spot size selected.

    AI/ML Overview

    The provided document lists information for a medical device called PICOANDY (Q-Switched Nd:YAG Laser), which is a laser surgical instrument. It includes a 510(k) summary for FDA clearance.

    Here's an analysis of the acceptance criteria and the study that proves the device meets them, based only on the provided text:

    1. Table of acceptance criteria and the reported device performance:

    The document doesn't explicitly state "acceptance criteria" in a table format with specific target values for performance in the context of a clinical study or effectiveness evaluation. Instead, it details the technical specifications of the PICOANDY device and compares them against a predicate device (PICOHIGH), claiming "substantial equivalence."

    However, we can infer performance specifications from the "Performance Testing" section and the comparison to the predicate device.

    Performance CharacteristicAcceptance/Specification (for PICOANDY)Reported Device Performance (PICOANDY)Comparison to Predicate (PICOHIGH)
    Indications for Use:Matched predicate device for tattoo removal (1064nm for all skin types, black, brown, green, blue, purple; 532nm for Fitzpatrick I-III, red, yellow, orange) and treatment of benign pigmented lesions (Fitzpatrick I-IV).Matches the described indications.Same
    Anatomical Site:Skin and subcutaneous tissueSkin and subcutaneous tissueSame
    Wavelength:1064 nm and 532 nm1064nm±10%, 532nm±10%Same
    Pulse Width:350~550 ps (Proposed Device)1064nm mode: 450-550 ps, 532nm mode: 350-400 psSimilar (Proposed device higher, thus safer)
    Pulse Energy:- Zoom 1064nm: 30 ~ 550mJ ±10%
    • Zoom 532nm: 10 ~ 200mJ ±10%
    • Collimation Mode: 38 ~ 500mJ ±10%
    • MLA (1064nm): 30 ~ 550mJ ±10%
    • MLA (532nm): 10 ~ 200mJ ±10%
    • 1064nm DOE: 30 ~ 550mJ ±10%
    • 532nm DOE: 20 ~ 200mJ ±10% | Reported within these ranges. | Similar (Predicate range for handpiece output is only slightly different, including error range) |
      | Spot Size: | 2 to 10 mm (by 1mm step) | 1064nm mode: (2 to 10mm) step: 1mm, 532nm mode: (2 to 10mm) step: 1mm | Similar (Proposed device range included in predicate) |
      | Pulse Repetition Rate: | Max. 10Hz | 1064nm mode: 1-10Hz, 532nm mode: 1-10Hz | Same |
      | Laser Delivery Type: | Articulated Arm with Handpiece | Articulated Arm with Handpiece | Same |
      | Handpiece Types: | Zoom, Collimated, MLA, DOE | Zoom, Collimated, MLA, DOE | Same |
      | Patient Contact Material: | Aluminum Powder (Handpiece) | Aluminum Powder (Handpiece) | Same |

    The "acceptance criteria" here are implicitly the specifications of the device and its demonstrated ability to perform within those specifications, and critically, to be "substantially equivalent" to a legally marketed predicate device.

    Study Type and Details to Prove Acceptance:

    The document states: "No clinical studies were considered necessary and performed." This indicates that the device's clearance was based on non-clinical data and comparison to a predicate device.

    Therefore, the following information is not applicable or extractable from the provided document as no clinical or comparative effectiveness study was conducted:

    • Sample size used for the test set and data provenance
    • Number of experts used to establish the ground truth for the test set and their qualifications
    • Adjudication method for the test set
    • Multi Reader Multi Case (MRMC) comparative effectiveness study
    • Effect size of human readers improving with AI vs. without AI assistance
    • Standalone (algorithm only) performance study

    Here's what was used to prove the device meets acceptance criteria (i.e., substantial equivalence):

    2. Sample size used for the test set and the data provenance:

    • Not applicable / Not provided. No clinical test set. The evaluation relies on bench tests and comparison to a predicate device.

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

    • Not applicable / Not provided. No ground truth established by experts for a clinical test set since no clinical studies were performed.

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

    • Not applicable / Not provided. No clinical test set requiring 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:

    • No. An MRMC study was not done. This device is a laser system, not an AI-assisted diagnostic tool.

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

    • Not applicable / Not provided. This device is a physical laser system, not a software algorithm for standalone performance. "Software Validation" refers to the internal software controlling the device, not a standalone diagnostic algorithm.

    7. The type of ground truth used:

    • For the non-clinical tests, the "ground truth" implicitly refers to the engineering specifications and established safety and performance standards (e.g., IEC standards) and the characteristics of the predicate device. Compliance with these standards and demonstrating similar functionality to a predicate forms the basis of "truth" for substantial equivalence.

    8. The sample size for the training set:

    • Not applicable / Not provided. There is no "training set" in the context of an AI/ML algorithm for this device. The software validation mentioned is for the device's operational software, not for an AI model trained on data.

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

    • Not applicable / Not provided. As there's no training set for an AI/ML algorithm described.
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