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510(k) Data Aggregation

    K Number
    K131757
    Date Cleared
    2014-07-17

    (395 days)

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

    The TattooStar Effect Combo is indicated for incision, ablation and vaporization of soft tissue in general dermatology and the removal of tattoos, pigmented lesions and skin resurfacing procedures. Depending on the wavelength selected, the indications are as follows:

    Wavelength 1064 nm: Removal of black and blue tattoo color, Skin resurfacing
    Wavelength 532 nm: Removal of pigmented lesions (including but not limited to lentigo benigna, hyperpigmented bum and boil scar, naevus Ota / Ito, freckles, Becker naevi, Cafe-au-lait spots), Removal of red tattoo color
    Wavelength 585 nm: Removal of sky blue tattoo color
    Wavelength 694nm: Removal of pigmented lesions, Removal of black, blue and green tattoo color

    Device Description

    The TattooStar Effect Combo is a combination of a Nd:YAG laser and a Ruby laser. Both lasers are pulsed q-switched lasers, the Nd:YAG can optionally emit millisecond pulses in the Free-running mode. The Nd:YAG laser emits wavelengths of 1064nm and 532nm. The beam can be converted to 585nm by means of an optional dye handpiece. The Ruby laser emits 694 nm radiation.

    AI/ML Overview

    The provided document is a 510(k) summary for the TattooStar Effect Combo, a laser surgical instrument. It primarily focuses on demonstrating substantial equivalence to previously cleared devices rather than presenting detailed acceptance criteria and performance data from a clinical or non-clinical study for a novel device.

    Therefore, many of the requested sections regarding acceptance criteria and study details cannot be fully extracted from this document as they are not present. This type of submission relies on showing that the new device is as safe and effective as a predicate device, often without new clinical studies if the technology and indications are sufficiently similar.

    Here's the breakdown of what can be gathered:

    1. Table of acceptance criteria and the reported device performance

    The document does not explicitly state "acceptance criteria" in the traditional sense for a new clinical study. Instead, it compares the technical specifications and indications of the TattooStar Effect Combo to its predicate devices (TattooStar R and TattooStar Effect Y) to demonstrate substantial equivalence. The "performance" is implied by matching or being within acceptable ranges of the predicate device's specifications.

    Feature / ParameterProposed Modified Device (TattooStar Effect Combo - Ruby Module)Un-Modified Predicate Device (TattooStar R)Proposed Modified Device (TattooStar Effect Combo - Nd:YAG Module)Un-Modified Predicate Device (TattooStar Effect Y)
    IndicationsIncision, excision, vaporization and ablation of soft tissue, the removal of tattoos and benign pigmented lesionsCutting, vaporization and ablation of soft tissue, the removal of tattoos and of benign pigmented lesionsIncision, excision, vaporization and ablation of soft tissue, the removal of tattoos, pigmented lesions, vascular lesions and hair and skin resurfacing proceduresIncision, excision, vaporization and ablation of soft tissue, the removal of tattoos, pigmented lesions, vascular lesions and hair and skin resurfacing procedures
    Device TypeRubyRubyNd:YAGNd:YAG
    DeliveryArticulated mirror armArticulated mirror armArticulated mirror armArticulated mirror arm
    Wavelength694 nm694 nm1064 / 532 / 585 nm1064 / 532 / 585 nm
    Max. Energy per Pulse1.15 J1.2 J1064 nm: 0.8 J (q-switch), 1.5 J (free running); 532 nm: 0.4 J (q-switch); 585 nm: 0.25 J (q-switch)1064 nm: 0.8 J (q-switch), 1.5 J (free running); 532 nm: 0.4 J (q-switch); 585 nm: 0.25 J (q-switch)
    Max. Fluence on skin25 J/cm²20 J/cm²20 J/cm² (q-switch), 37 J/cm² (free running)20 J/cm² (q-switch), 37 J/cm² (free running)
    Pulse Duration40 ns40 ns8 ns (q-switch), 300 µs (free running)8 ns (q-switch), 300 µs (free running)
    Repetition RateUp to 2 HzUp to 2 HzUp to 10 HzUp to 10 Hz
    Spot Sizes2 – 7 mm2.5 - 6 mm2 – 7 mm2 – 7 mm

    Note on "Acceptance Criteria": The implied acceptance criteria for a 510(k) submission primarily revolve around demonstrating "substantial equivalence" to a predicate device. This means showing that the new device has the same intended use, and either the same technological characteristics, or different technological characteristics that do not raise new questions of safety and effectiveness. The table above shows the comparison of technological characteristics.

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

    The document explicitly states:

    • Nonclinical Performance Data: None
    • Clinical Performance Data: None

    This means there was no specific test set or clinical study conducted for this 510(k) submission to assess the device's performance in a traditional sense. The device's safety and effectiveness are established by its substantial equivalence to previously cleared devices.

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

    Not applicable, as no dedicated test set or clinical study was presented.

    4. Adjudication method for the test set

    Not applicable, as no dedicated test set or clinical study was presented.

    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, not an AI-powered diagnostic tool. No MRMC study was mentioned.

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

    Not applicable, as this is a medical device (laser) and not an algorithm requiring standalone performance evaluation in that context.

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

    Not applicable, as no dedicated test set or clinical study was presented that would require establishing ground truth. The basis for clearance is substantial equivalence to predicate devices, whose ground truth for effectiveness would have been established historically.

    8. The sample size for the training set

    Not applicable, as this is a medical device (laser) and not an algorithm that typically uses a "training set."

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

    Not applicable, as no training set was used.

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