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510(k) Data Aggregation

    K Number
    K223262
    Date Cleared
    2023-02-23

    (122 days)

    Product Code
    Regulation Number
    878.4400
    Reference & Predicate Devices
    N/A
    Why did this record match?
    Reference Devices :

    Ellusa Bipolar Wands (K202558)

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

    The Renuvion® APR Handpiece is intended for the delivery of radiofrequency energy and/or helium plasma where coagulation/contraction of soft tissue is needed. Soft tissue includes subcutaneous tissue.

    The Renuvion® APR Handpiece is indicated for use in subcutaneous dermatological and aesthetic procedures to improve the appearance of lax (loose) skin in the neck and submental region.

    The Renuvion® APR Handpiece is intended to be used with compatible electrosurgical generators owned by Apyx Medical.

    Device Description

    The Renuvion® APR Handpiece is a sterile, single-use electrosurgical (monopolar) device intended to be used in conjunction with compatible electrosurgical generators. The compatible generators operate at an adjustable power of up to 40W (expressed as 0-100% where 100% is 40W) and provide an adjustable helium gas flow of 1-5 LPM. Radiofrequency energy is delivered to the handpiece by the generator and used to energize the electrode. When helium gas passes over the energized electrode, a helium plasma is generated which delivers thermal energy to soft tissue for the purposes of cutting, coagulation/contraction, or ablation.

    The handpiece is available in two different lengths: 15cm and 27cm. The 15cm length is available in a single port (APYX-15-SP) as well as a twin port configuration (APYX-15-TP). The 27cm length is only available with a twin port configuration (APYX-27-TP).

    AI/ML Overview

    This document is an FDA 510(k) premarket notification for the Renuvion® APR Handpiece. It discusses the device's substantial equivalence to previously cleared devices based on bench testing, electrical safety, biocompatibility, and pre-clinical/ex-vivo studies. Crucially, it states that "This premarket submission did not rely on the assessment of clinical performance data to demonstrate substantial equivalence." Therefore, there is no information in this document regarding acceptance criteria, human reader studies (MRMC), or specific expert consensus for establishing ground truth as these types of studies were not conducted for this specific submission to demonstrate substantial equivalence.

    However, the document does contain information about performance testing to support expanded indications for use. I will address the relevant points based on the provided text.


    Acceptance Criteria and Device Performance (as inferred from the pre-clinical/ex-vivo studies to support expanded indications)

    Since the submission did not rely on clinical performance data for substantial equivalence, formal acceptance criteria in the typical sense for a clinical study are not provided. Instead, the document describes the types of pre-clinical and ex-vivo studies conducted and the data they demonstrated to support the expanded indications.

    The expanded indication required demonstrating the ability of the device to achieve "coagulation/contraction of soft tissue" including "subcutaneous tissue."

    1. Table of Acceptance Criteria and Reported Device Performance

    Acceptance Criteria (Inferred from study purpose)Reported Device Performance (as described in the document)
    Demonstrate coagulative effect on various tissues (liver, kidney, muscle) via ex vivo testing, similar to a reference device.Apyx Medical conducted the "same ex vivo tissue testing using the Renuvion APR handpiece on liver, kidney, and muscle tissues at 20%, 50%, and 100% power and 1, 3, and 5 Lpm gas flow rate." Measurements of lateral spread and depth of thermal effect were characterized under histological examination. The results supported the addition of "coagulation/contraction of soft tissue" to the indications for use.
    Demonstrate thermal effects (e.g., depth of thermal effect) in subcutaneous tissue suitable for contraction via in vivo porcine study.A GLP Acute Porcine Study was conducted to assess thermal effects of the device on subcutaneous and connective tissue. The handpiece was moved continuously at 1 cm/sec at 60-80% power and 1.5 Lpm gas flow rate. "Depth of thermal effect in subcutaneous tissue was measured and analyzed via histology." The data "demonstrated the thermal effects of the device on subcutaneous soft tissues," supporting "contraction" and "subcutaneous tissue" in the indications.

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

    • Ex-Vivo Tissue Testing: The document mentions "liver, kidney, and muscle tissues" were used. A specific sample size (number of tissue samples or replicates) is not provided.
    • In-Vivo Acute Porcine Study: The document refers to "an in vivo acute porcine study" but does not specify the number of animals used.
    • Data Provenance: The document does not explicitly state the country of origin for the data. The studies were conducted by Apyx Medical, a US-based company. The nature of the studies (ex-vivo and acute in-vivo) suggests they are prospective laboratory and animal studies, not retrospective or prospective human clinical data.

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

    • Ground Truth for Ex-Vivo and In-Vivo Studies: Ground truth for these studies was established through "histological examination" to characterize lateral spread and depth of thermal effect. The document does not specify the number of experts or their exact qualifications (e.g., pathologist with X years of experience) who performed this histological analysis. It's implied this was done by qualified personnel in a lab setting, but specifics are missing from this FDA letter.

    4. Adjudication Method for the Test Set

    • Given the nature of the ground truth (histological examination), a multi-reader adjudication method like "2+1" or "3+1" is typically not applicable in the same way as for diagnostic imaging studies. Histological analysis would involve expert pathological review. The document does not describe any specific adjudication method, such as multiple pathologists reviewing and finding consensus, for the histological examinations.

    5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done

    • No. The document explicitly states: "This premarket submission did not rely on the assessment of clinical performance data to demonstrate substantial equivalence." An MRMC human reader study would fall under clinical performance data. Therefore, no information on human reader improvement with or without AI assistance is provided.

    6. If a Standalone (Algorithm Only Without Human-in-the-Loop Performance) Study was Done

    • Not applicable. This device is an electrosurgical handpiece, not an AI algorithm. Its performance is measured by its physical effect on tissue, not by an algorithm's diagnostic capabilities.

    7. The Type of Ground Truth Used

    • For the ex-vivo and in-vivo studies supporting the expanded indications, the ground truth was established through histological examination of treated tissues (liver, kidney, muscle, and subcutaneous tissue) to measure thermal effects, specifically lateral spread and depth of thermal effect. This is a form of pathology-based ground truth.

    8. The Sample Size for the Training Set

    • Not applicable. This submission is for a physical medical device (electrosurgical handpiece), not an AI/ML algorithm. Therefore, there is no "training set" in the context of machine learning.

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

    • Not applicable, as there is no training set for an AI/ML algorithm.
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