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510(k) Data Aggregation

    K Number
    K231896
    Date Cleared
    2024-02-20

    (237 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 Diode Laser Therapy System (Model: FG2000-B/FG2000-B Pro) is indicated for temporary hair reduction.

    The Diode Laser Therapy System(Model: FG2000-D+Pro/FG2000-D) is indicated for permanent reduction in hair regrowth defined as a long term, stable reduction in the number of hairs re-growing when measured at 6,9 and 12 months after the completion of a treatment regimen. It is suitable for all skin types (Fitzpatrick skin type I-VI), including tanned skin.

    Device Description

    The Diode Laser Therapy System consists of main unit, handpiece, and its accessories. Diode Laser Therapy System is intended for hair removal, mainly based on the principle of selective photothermal interaction, which means that lasers of specific wavelengths can only be selectively absorbed by the target color base.

    The Diode Laser Therapy System(Model: FG2000-B/FG2000-B Pro) are desktop devices, which combines 3 wavelengths (755+808+1064 nm) into a single handpiece to achieve purpose for temporary hair reduction.

    The Diode Laser Therapy System (Model: FG2000-D+Fro/ FG2000-E) are vertical device, which is a single wavelength (808 nm only) device.

    AI/ML Overview

    This document describes the FDA's 510(k) premarket notification for the "Diode Laser Therapy System" by Beijing ADSS Development Co., Ltd. A 510(k) submission aims to demonstrate that a new medical device is substantially equivalent to a legally marketed predicate device, rather than proving its safety and effectiveness de novo through clinical trials, as would be required for a PMA (Premarket Approval) device.

    Therefore, the provided document does not contain information typically found in a study proving a device meets acceptance criteria derived from a clinical trial for AI/ML-based medical devices. The device in question is a laser therapy system, not an AI/ML-based device that would require complex performance metrics like sensitivity, specificity, or AUC, nor would it involve human readers, expert ground truth adjudication, or MRMC studies.

    The "acceptance criteria" discussed in this document relate to the substantial equivalence to predicate devices and compliance with relevant performance and safety standards for laser devices.

    Here's an analysis based on the provided text, addressing the points you raised where applicable to a non-AI/ML device:

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

    The document does not present a formal table of "acceptance criteria" in terms of performance metrics like sensitivity/specificity for an AI/ML device. Instead, "acceptance criteria" are implied by the demonstration of "substantial equivalence" to predicate devices and compliance with recognized international standards for medical electrical equipment and laser products.

    The tables provided in Section 6, "Summary of technological characteristics of device compared to the predicate device," serve as the primary comparison metrics to show substantial equivalence.

    Acceptance Criteria (Implied by Substantial Equivalence and Standards Compliance) and Reported Device Performance:

    ItemAcceptance Criteria (Predicate Characteristics / Standard Compliance)Reported Device Performance (Subject Device Characteristics)Comparison / Outcome
    Intended Use / Indications for UsePredicate K230371 (Alma Soprano Titanium): Temporary hair reduction; permanent reduction in hair regrowth (6, 9, 12 months, all skin types I-VI, including tanned skin) for 810nm and 755nm applicators. Also includes dermatology procedures requiring coagulation, benign vascular and vascular dependent lesions, and topical heating for temporary relief of muscle pain, etc.Subject Device FG2000-B/FG2000-B Pro: Indicated for temporary hair reduction.Subject Device FG2000-D+/FG2000-D+Pro/FG2000-E: Indicated for permanent reduction in hair regrowth defined as a long term, stable reduction in the number of hairs re-growing when measured at 6, 9 and 12 months after the completion of a treatment regimen. Suitable for all skin types (Fitzpatrick skin type I-VI), including tanned skin.SE. Subject device's indications are covered by the predicate device (K230371, and K220381 for permanent hair reduction).
    Laser TypeDiode laserDiode laserSE
    Laser ClassificationClass IVClass IVSE
    Laser WavelengthPredicate K230371: combination of 755nm/810nm/1064nmSubject Device FG2000-B/FG2000-B Pro: combination of 755nm/808nm/1064nm (SE)Subject Device FG2000-D+/FG2000-D+Pro/FG2000-E: 808nm (SE)SE (808nm is common in diode lasers and considered equivalent to 810nm for these purposes)
    Spot SizePredicate K230371: 2010 mmmm (2cm²)Subject Device FG2000-B/FG2000-B Pro: 12×16 mm*mm(1.92cm²)Different. Deemed not to raise new questions of safety/effectiveness during bench testing.
    Predicate K220381: 15x15mm*mmSubject Device FG2000-D+/FG2000-D+Pro/FG2000-E: 10×10mm*mmDifferent. Deemed not to raise new questions of safety/effectiveness during bench testing.
    Pulse WidthPredicate K230371: Up to 200msSubject Device FG2000-B/FG2000-B Pro: up to 200msSE
    Predicate K220381: 1-300msSubject Device FG2000-D+/FG2000-D+Pro/FG2000-E: 2~100msDifferent. Deemed not to raise new questions of safety/effectiveness during bench testing.
    Energy FluencePredicate K230371: 2 to 8J/cm2Subject Device FG2000-B/FG2000-B Pro: 2~8J/cm2SE
    Predicate K220381: 1~100J/cm2Subject Device FG2000-D+/FG2000-D+Pro/FG2000-E: 2~100J/cm2Different (Lower minimum). Deemed not to raise new questions of safety/effectiveness during bench testing.
    Pulse FrequencyUp to 10 Hz / 1~10Hz1~10HzSE
    User InterfaceLCD Color TouchscreenLCD Color TouchscreenSE
    Electrical SafetyComply with ANSI/AAMA ES 60601-1, IEC 60601-2-22Comply with ANSI/AAMA ES 60601-1, IEC 60601-2-22SE
    EMCComply with IEC 60601-1-2Comply with IEC 60601-1-2SE
    Laser SafetyComply with IEC 60601-2-22, IEC 60825-1Comply with IEC 60601-2-22, IEC 60825-1SE
    Handpiece Tip MaterialSapphireQuartz crystalSE (Functionally equivalent for intended purpose)
    Biocompatibility (Cytotoxicity, Sensitization, Irritation)Comply with ISO 10993-5, ISO 10993-10 (older versions for predicates), ISO 10993-23Comply with ISO 10993-5:2009, ISO 10993-10:2021, ISO 10993-23:2021SE (newer standards complied with, indicating continued safety)

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

    • No clinical test set was used. Section 8 explicitly states: "There was no clinical testing performed."
    • The "test set" for this submission consists of non-clinical bench testing for performance and compliance with relevant standards. The data provenance is implied to be from Beijing ADSS Development Co., Ltd. (China), given their location and the submission coming from them.

    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 was no clinical testing or AI/ML component, there was no need for experts to establish ground truth in the context of diagnostic or treatment efficacy. The "ground truth" for substantial equivalence is the predicate device's proven characteristics and compliance with recognized standards.

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

    • Not applicable. No clinical data requiring adjudication was generated.

    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 relates to AI/ML device assessment, which this product is not.

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

    • Not applicable. This relates to AI/ML device assessment, which this product is not.

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

    • The "ground truth" in this context is the established safety and performance of the legally marketed predicate devices and compliance with internationally recognized performance and safety standards (e.g., IEC 60601 series, ISO 10993 series for biocompatibility, IEC 60825-1 for laser safety).

    8. The sample size for the training set

    • Not applicable. This device does not use a training set as it is not an AI/ML device.

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

    • Not applicable. No training set was used.

    In summary:

    This document is a 510(k) clearance letter for a diode laser therapy system. The "study" proving the device met "acceptance criteria" was primarily a non-clinical assessment based on:

    • Bench testing: To confirm the device's technical specifications and performance (e.g., laser wavelength, pulse characteristics, energy fluence).
    • Comparison to predicate devices: Demonstration of "substantial equivalence" in terms of intended use, technological characteristics, and safety features to legally marketed devices.
    • Compliance with recognized standards: Adherence to national and international safety and performance standards for medical electrical equipment, laser devices, and biocompatibility.

    The "acceptance criteria" are implied by meeting these requirements and showing that any differences from predicate devices do not raise new questions of safety or effectiveness. Clinical testing, human reader studies, and AI/ML specific evaluations (like those mentioned in your prompt) were not part of this clearance process for this type of device.

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