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510(k) Data Aggregation
(224 days)
The ND YAG Q-switch Laser Therapy Machine is indicated for the treatment of: benign cutaneous lesions, such as Warts, Scars, Striae and Psoriasis; benign pigmented lesions, such as Lentigines, nevus, and birthmark; and the removal of black or blue tattoos.
The ND YAG Q-switch Laser Therapy Machine is laser system which delivers laser at a wavelength 1064nm or 532nm.
There are 3 models included, FG 2010, FG 2010-B, FG 2010-C, the three models have same intended use, mechanism of action, principle and specification, only differences are the configurations.
The provided text describes a 510(k) premarket notification for a medical device, which focuses on demonstrating substantial equivalence to a predicate device rather than presenting novel acceptance criteria or comprehensive study results for a new AI/software system. Therefore, much of the requested information regarding AI-specific criteria, studies, and ground truth establishment is not applicable or available in this document.
However, I can extract the relevant information from the provided text as it pertains to the device's performance claims and the studies conducted to support its substantial equivalence.
1. A table of acceptance criteria and the reported device performance
The document does not explicitly state acceptance criteria in the typical sense for a new AI/software device. Instead, it compares the proposed device's specifications and performance to a predicate device to demonstrate "substantial equivalence" (SE). The "reported device performance" is essentially the detailed specifications of the proposed device as presented for comparison.
| Criterion Type | Acceptance Criteria (Predicate Device K072536) | Reported Device Performance (Proposed Device) | Remark |
|---|---|---|---|
| Regulatory Information | |||
| Product Code | GEX | GEX | SE |
| Regulation No. | 21 CFR 878.4810 | 21 CFR 878.4810 | SE |
| Class | 2 | 2 | SE |
| Intended Use | Benign cutaneous lesions, benign pigmented lesions, tattoo removal, vascular lesions, non-ablative treatment of facial wrinkles, laser skin resurfacing, reduction of red pigmentation in scars, use on all skin types. | Benign cutaneous lesions (Warts, Scars, Striae, Psoriasis); benign pigmented lesions (Lentigines, nevus, birthmark); removal of black or blue tattoos. | SE |
| Performance Comparison | |||
| Laser Medium | Nd:YAG | Nd:YAG | SE |
| Wavelength | 1064 nm, 532 nm | 1064 nm, 532 nm | SE |
| Output energy | 400-1200mJ | 100-1000mJ for 1064nm, 50-500mJ for 532nm | SE |
| Max. Energy Density | 16.9 J/cm² | 31.8 J/cm² (for 1064nm), 15.9 J/cm² (for 532nm) | Analysis |
| Spot Size | 3, 5 mm | 2-10mm | Analysis |
| Pulse Width | 20 ns | 5ns-8ns | Analysis |
| Repetition Rate | 1, 2, 4 Hz | 1-10 Hz | Analysis |
| Disinfection | --- | Disinfect the handpiece before and after every treatment by 75% medicinal alcohol | Analysis |
| Laser Class | Class 4 | Class 4 | SE |
| Cooling method for treated skin | N.A. | N.A. | SE |
| Aiming Beam | N.A. | Red Laser, < 6mW | Analysis |
| Safety Comparison | |||
| Patient Contact Materials | Treatment Probe (Stainless Steel) | Treatment Probe (Stainless Steel) | SE |
| Cytotoxicity | Comply with ISO 10993-1 | No Cytotoxicity | |
| Sensitization | --- | No evidence of sensitization | SE |
| Irritation | --- | No evidence of irritation | |
| Electrical Safety | Comply with IEC 60601-1, IEC 60601-2-22 | Comply with IEC 60601-1, IEC 60601-2-22 | SE |
| EMC | Comply with IEC 60601-1-2 | Comply with IEC 60601-1-2 | SE |
| Laser Safety | Comply with IEC 60601-2-22, IEC 60825 | Comply with IEC 60601-2-22, IEC 60825 | SE |
2. Sample size used for the test set and the data provenance
No clinical test set or data provenance is mentioned as this device is not an AI/software product requiring such a test set. This submission relies on non-clinical testing to demonstrate substantial equivalence 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. No ground truth establishment by experts for a test set is described, as the device is not an AI/software product that requires diagnostic performance evaluation.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. No test set adjudication method is described.
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 machine, not an AI-assisted diagnostic tool, so an MRMC study is not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This device is a laser therapy machine, not an algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
Not applicable. The equivalence is based on technical specifications and safety standards rather than diagnostic ground truth.
8. The sample size for the training set
Not applicable. No training set is mentioned for this device.
9. How the ground truth for the training set was established
Not applicable. No training set or ground truth establishment for a training set is described.
Summary of the Study Proving Acceptance Criteria (Substantial Equivalence):
The study primarily consisted of non-clinical tests to verify that the proposed device met design specifications and was substantially equivalent (SE) to the predicate device (Harmony XL Multiple Application Platform, K072564).
The tests conducted focused on:
- Compliance with International Standards:
- IEC 60601-1:2012 (Medical Electrical Equipment - Basic Safety and Essential Performance)
- IEC 60601-2-22:2007 (Medical Electrical Equipment - Surgical, Cosmetic, Therapeutic And Diagnostic Laser Equipment)
- IEC 60825-1:2007 (Safety of laser products - Equipment classification and requirements)
- IEC 60601-1-2:2007 (Electromagnetic compatibility)
- Biocompatibility:
- ISO 10993-5:2009 (Tests for Vitro cytotoxicity)
- ISO 10993-10:2002/Amd. 1: 2006 (Test for irritation and delay-type hypersensitivity)
- Specific Device Performance Tests:
- Performance Testing for Spot Size Accuracy.
- Thermal Energy Distribution Test (to determine the difference for thermal energy distribution of proposed device with predicate device).
No clinical study was included in this submission. The approach relied on demonstrating that the proposed device performed "as safe, as effective, and performs as well as the legally marketed predicate device" based on direct technical and safety comparisons and adherence to established medical device standards.
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