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510(k) Data Aggregation
(86 days)
The Q-Switched Nd: YAG Laser Therapy System (1064nm or 532nm) is indicated for use in tattoo removal, treatment of benign vascular lesions, treatment of benign pigmented lesions, incision, excision, ablation, vaporization of soft tissue for general dermatology as follows:
1064nm: -Tattoo Removal Dark ink: blue and black. -Treatment of Benign Pigmented Lesions Nevus of ota. 532mm: -Tattoo Removal Light ink: red. Light ink: sky blue and green. - Treatment of Benign Vascular Lesions Port wine birthmarks; Telangiectasias; Spider angioma; Cherry angioma; Spider nevi. -Treatment of Benign Pigmented Lesions Cafe-au-lait birthmarks; Solar lentiginos; Senile lentiginos; Becker's nevi; Freckles; Nevus spilus.
The Q-Switched Nd:YAG Laser Systems is based on the Q-Switched Nd: YAG (1064 nm) and frequency doubled KTP Nd: YAG (532nm) Laser Technology. There is one optical cavity containing the Nd: YAG Crystal. It is composed of laser module, articulated arm, laser power supply, cooling system and display and control system.
The Q-Switched Nd: YAG Laser Therapy Systems works based on laser selective photothermy and blasting mechanism of Q-switched laser. Energy form particular wavelength with accurate dose will act on certain targeted color radicals: ink, carbon particles from derma and epidermis, exogenous pigment particles and endogenous melanophore from derma and epidermis. When suddenly being heated, pigment particles immediately blast into smaller pieces, which will be swallowed by macrophage phagocytosis and enters into lymph circulation system and finally be discharged out of body.
The physician is able to select the desired wavelength and the related output energy, spot size and fluency via control panel.
The provided document is a 510(k) summary for the Beijing Sincoheren Science And Technology Development Co.'s Q-Switched Nd:YAG Laser Therapy Systems. It aims to demonstrate substantial equivalence to a predicate device, not to establish new safety or effectiveness. Therefore, the document discusses performance data in the context of equivalence rather than proving acceptance criteria for a novel device.
The document does not describe specific acceptance criteria in the typical sense (e.g., minimum sensitivity, specificity, or accuracy) for a new clinical indication or a new type of device. Instead, it relies on demonstrating that the performance characteristics of the proposed device are comparable to or better than those of the predicate device, and that it complies with relevant safety standards.
Here's an analysis of the provided information based on your requested points, framed within the context of a 510(k) submission for substantial equivalence:
1. A table of acceptance criteria and the reported device performance
Since this is a 510(k) submission for substantial equivalence, the "acceptance criteria" are implicitly that the proposed device performs at least as well as, or is sufficiently similar to, the predicate device in terms of technical specifications and safety. The reported device performance is presented as a comparison table against the predicate device.
| Specification | Predicate device performance | Proposed device performance | Comparison Discussion (Implicit Acceptance) |
|---|---|---|---|
| K number | K133158 | -- | (Predicate ID) |
| Product Code | GEX | GEX | Identical |
| Manufacturer | Beijing Toplaser Technology Co., Ltd | Beijing Sincoheren Science and Technology Development Co., Ltd. | (Different companies, but not a performance metric) |
| Device name | Nd: YAG Laser System | Q-Switched Nd: YAG Laser Therapy Systems | Similar |
| Indications for use | 1064nm: -Tattoo Removal (Dark ink: blue and black) -Treatment of Benign Pigmented Lesions (Nevus of ota) 532nm: -Tattoo Removal (Light ink: red; Light ink: sky blue and green) - Treatment of Benign Vascular Lesions (Port wine birthmarks; Telangiectasias; Spider angioma; Cherry angioma; Spider nevi) -Treatment of Benign Pigmented Lesions (Cafe-au-lait birthmarks; Solar lentiginos; Senile lentiginos; Becker's nevi; Freckles; Nevus spilus.) | 1064nm: -Tattoo Removal (Dark ink: blue and black) -Treatment of Benign Pigmented Lesions (Nevus of ota) 532nm: -Tattoo Removal (Light ink: red; Light ink: sky blue and green) - Treatment of Benign Vascular Lesions (Port wine birthmarks; Telangiectasias; Spider angioma; Cherry angioma; Spider nevi) -Treatment of Benign Pigmented Lesions (Cafe-au-lait birthmarks; Solar lentiginos; Senile lentiginos; Becker's nevi; Freckles; Nevus spilus.) | Identical (Demonstrates equivalence in intended use) |
| Technology | Q-Switched ND:YAG and KTP Nd: YAG Laser | Q -Switched ND:YAG and KTP Nd: YAG Laser | Identical |
| Energy Source | Xenon Lamp | Xenon Lamp | Identical |
| Wavelength (nm) | 1064nm and 532nm | 1064nm and 532nm | Identical |
| Aiming beam wavelength | 635nm | 635nm | Identical |
| Laser output mode | Q-switched pulse | Q-switched pulse | Identical |
| Aiming laser output power | <5mw | 0.1-5mw | Identical |
| Maximum Pulse Energy | @1064nm wavelength: 1-1000mJ @532nm wavelength: 50-300mJ | @1064nm wavelength: 500mJ @532nm wavelength: 250mJ | Less than Predicate device, more safe (Acceptable as "safer" or at least equivalent for intended use) |
| Pulse Duration | 6~8ns | 5ns±1ns or 5ns | Less Pulse Duration, more peak power, more effective (Acceptable and potentially an improvement) |
| Repetition Rate | 1~10Hz | 1-5Hz | Less than Predicate device, more safe (Acceptable as "safer" or at least equivalent for intended use) |
| Nominal ocular hazard distance | NOHD 2.8km | NOHD 3.3km | Similar (Acceptable) |
| Spot Size | Adjustable Spot Size 3-9mm(Diameter) | Adjustable Spot Size 2-10mm(Diameter) | Wider adjustable range of spot size than predicate device, more useful (Acceptable and potentially an improvement) |
| Material | Steel, ABS | Steel, ABS | Identical |
| Beam delivery | Articulating Arm Light Guide | Articulating Arm Light Guide | Identical |
| Cooling | Internal distilled water circulating cooling | Internal distilled water circulating cooling | Identical |
| Anatomical Sites | Skin and subcutaneous tissue | Skin and subcutaneous tissue | Identical |
In addition to these direct comparisons, the submission outlines compliance with various safety and performance standards as "performance data" to support the substantial equivalence claim:
- Biocompatibility testing: Compliance with ISO 10993-1, including Cytotoxicity, Sensitization, and Irritation tests. (Implicit acceptance criteria: device materials must be biocompatible according to recognized standards for skin and subcutaneous tissue contact < 24 hours).
- Electrical safety and electromagnetic compatibility (EMC): Compliance with IEC 60601-1 (safety) and IEC 60601-1-2 (EMC). (Implicit acceptance criteria: device must meet electrical safety and EMC standards).
- Performance testing: Compliance with IEC 60825-1 (laser safety). (Implicit acceptance criteria: laser performance must meet safety standards).
- Software Verification and Validation Testing: Documentation provided as recommended by FDA guidance for "moderate" level of concern software. (Implicit acceptance criteria: software must be verified and validated according to FDA guidance for its risk level).
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" in the context of clinical or image-based studies. The performance data presented are primarily technical specifications and compliance with international standards, not data from a clinical test set. Therefore, information on sample size and data provenance for a test set is not applicable to this submission as described.
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, as there is no clinical or image-based "test set" described with ground truth established by experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable, as there is no clinical or image-based "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
Not applicable. This device is a laser therapy system, not an AI-assisted diagnostic or therapeutic tool that would involve human readers or image interpretation.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is a physical laser device, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. For this type of device and submission, the "ground truth" for demonstrating substantial equivalence lies in meeting established engineering standards (e.g., IEC 60601-1, IEC 60825-1, ISO 10993-1) and demonstrating comparable basic technical performance to a legally marketed predicate device for the same indications for use. There is no biological "ground truth" involved in the sense of clinical validation of a diagnostic or treatment outcome for this specific 510(k) submission.
8. The sample size for the training set
Not applicable. This is a hardware medical device, not a machine learning model, so there is no concept of a "training set" in this context.
9. How the ground truth for the training set was established
Not applicable, as there is no training set.
In summary:
This 510(k) submission primarily relies on bench testing, compliance with recognized international standards (IEC, ISO), and a direct comparison of technical specifications to a predicate device to demonstrate substantial equivalence. It does not involve experimental clinical studies, human reader studies, or AI algorithm validation data that would typically require "test sets," "ground truth," or "training sets" as you've defined them. The "acceptance criteria" are effectively met by demonstrating that the device is technically comparable or improved (e.g., safer, more effective according to physical principles) for the same intended use as a legally marketed predicate device, and that it adheres to relevant safety and performance standards for medical lasers.
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