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510(k) Data Aggregation

    K Number
    K213669
    Manufacturer
    Date Cleared
    2023-02-15

    (450 days)

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

    K123037, K132661

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

    The LightScalpel LS-4020 CO2 Laser Systems are intended for use in laser surgery procedures for incision, excision, vaporization, ablation, and/or coagulation of soft tissue in specialties such as: general surgery, dermatology, dentistry and oral surgery, otorhinolaryngology, plastic and reconstructive surgery, neurosurgery, podiatry, and urology.

    Device Description

    The LightScalpel LS-4020 laser system, similar to the previously released LS-1005 and LS-2010 laser systems are mobile platforms that utilizes a radio frequency (RF) excited carbon dioxide (CO2) laser tube to produce an infrared beam at a nominal 10.6 um wavelength at powers adjustable from 2 - 40 Watts Continuous Wave (CW) and 2 to 20 Watts SuperPulse (SP). The systems differ only in the laser tubes used and pre-programmed values in the controlling software, which allow higher laser tube outputs for the LS-2010 and LS-4020 systems. Laser energy is conducted to the point of application by a flexible fiber waveguide and handpiece assembly. Laser system operation is controlled by operator input on a touchscreen display panel. The RF laser drive is modulated to provide additional pulsed and SuperPulse emission modes selected from the laser system control panel.

    AI/ML Overview

    The provided document is a 510(k) summary for the LightScalpel LS-4020 CO2 Laser System. This type of submission is for demonstrating substantial equivalence to pre-existing legally marketed devices, rather than proving effectiveness through extensive clinical trials. Therefore, the information requested regarding acceptance criteria, extensive study details, and ground truth establishment, which are typical for novel devices requiring clinical validation, is largely not present in this document.

    Here's an analysis based on the available information:

    1. Table of Acceptance Criteria and Reported Device Performance

    The document does not explicitly state "acceptance criteria" in the format of a table with specific pass/fail thresholds for clinical performance. Instead, the substantial equivalence is based on technological characteristics and intended use being comparable to predicate devices.

    CharacteristicAcceptance Criteria (Implied as Comparable to Predicate)Reported Device Performance (LS-4020)
    Laser MediumCO2CO2
    Wavelength (μm)10.610.6
    Laser Drive SourceRFRF
    Output Power (W)Comparable to predicate (2-60W range)2-40
    Pulsed Power (W)Comparable to predicate (2-60W range)2-40
    Gated PW (ms)Comparable to predicate (5-1000ms range)5-500
    Gated Rep. Rate (pps)Comparable to predicate (1-100pps range)1-50
    Superpulse (W)Comparable to predicate (1-20W range)2-20
    Superpulse Peak (W)Comparable to predicate (50-240W range)100
    Superpulse Pulse DurationComparable to predicate (Up to 2ms)Up to 0.8 ms
    Beam Delivery SystemFlexible Fiber Waveguide or Articulated ArmFlexible Fiber Waveguide
    System HxWxD (in)Similar dimensions to predicate40x15x15
    System Weight (lb)Similar weight to predicate66
    Mobility4 Wheels & Handle4 Wheels & Handle
    Intended UseIncision, Excision, Vaporization, Ablation, and/or Coagulation of Soft Tissue, across various specialtiesIncision, Excision, Vaporization, Ablation, and/or Coagulation of Soft Tissue, across various specialties
    Line Voltage - Nom.100-240 VAC100-240 VAC

    2. Sample Size Used for the Test Set and Data Provenance

    • Sample Size for Test Set: Not applicable in the context of this 510(k) submission. No clinical "test set" of patients or images was used for performance evaluation that is described in the document.
    • Data Provenance: Not applicable. The document states "Non-clinical performance data: Each LS-4020 laser system is tested for electrical safety and output characteristics." This implies testing on the device itself, not patient data.

    3. Number of Experts Used to Establish Ground Truth and Qualifications

    Not applicable. No ground truth establishment by experts is mentioned as this was not a clinical study requiring such a process.

    4. Adjudication Method

    Not applicable. No clinical study or expert review requiring adjudication is mentioned.

    5. Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study

    No. The document explicitly states: "Clinical performance data: None. Clinical testing was determined to be unnecessary, as the performance parameters are consistent with predicate CO2 laser systems and technology." Therefore, no MRMC study or assessment of AI assistance was performed or reported.

    6. Standalone Performance Study

    Yes, in a sense, a standalone technical performance was assessed. The document states: "Each LS-4020 laser system is tested for electrical safety and output characteristics. Representative data is presented in the Bench Testing section of this report." This refers to the device's technical specifications and safety performance, not its clinical efficacy in a standalone "algorithm only" context.

    7. Type of Ground Truth Used

    Not applicable for clinical performance. The "ground truth" for the device's substantial equivalence is the technical and operational characteristics of the predicate devices, and the LS-4020's ability to meet those non-clinical specifications.

    8. Sample Size for the Training Set

    Not applicable. This device is a laser system, not an AI/ML algorithm that requires a training set of data.

    9. How the Ground Truth for the Training Set Was Established

    Not applicable. As above, this is a physical device, not an AI/ML algorithm trained on data.

    Summary of the Study Proving Substantial Equivalence:

    The study proving the device meets the acceptance criteria is a technical and comparative analysis against legally marketed predicate devices, specifically the LightScalpel LS-1005 / LS-2010 CO₂ Laser Systems (K141658) and the Lumenis Ultrapulse™ (K151331).

    The core of the submission relies on demonstrating that the LightScalpel LS-4020 has substantially equivalent technological characteristics and intended uses to these predicate devices. The document highlights that:

    • The LS-4020 uses the same laser medium (CO2), wavelength (10.6 μm), and laser drive source (RF) as the predicates.
    • Its output power, pulse settings, and superpulse parameters fall within the range of the predicates, or are otherwise comparable.
    • The beam delivery system (flexible fiber waveguide) and physical characteristics (size, weight, mobility) are also considered comparable.
    • Crucially, the Indications for Use for the LS-4020 are directly aligned with and appear to be largely identical to those of the predicate devices across numerous surgical specialties (General Surgery, Dermatology, Dentistry/Oral Surgery, ENT, Plastic/Reconstructive Surgery, Neurosurgery, Podiatry, Urology, Gynecology).

    The submission explicitly states that no clinical performance data was deemed necessary because of this consistency with predicate CO2 laser systems and technology. Instead, non-clinical bench testing confirmed the electrical safety and output characteristics of each LS-4020 laser system. This approach is standard for 510(k) clearances where a new device is shown to be similar enough to existing ones that new clinical effectiveness and safety studies are not required.

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