Perfectio LED infrared device

K152332 · Omm Imports Inc Dba Zero Gravity · OHS · Feb 25, 2016 · General, Plastic Surgery

Device Facts

• Record ID: K152332
• Device Name: Perfectio LED infrared device
• Applicant: Omm Imports Inc Dba Zero Gravity
• Product Code: OHS · General, Plastic Surgery
• Decision Date: Feb 25, 2016
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.4810
• Device Class: Class 2
• Attributes: Therapeutic

Indications for Use

Perfectio LED infrared device is an over the counter device indicated to emit energy in the red and IR region of the spectrum for use in dermatology for the treatment of periorbital wrinkles.

Device Story

Perfectio LED infrared device is a battery-operated, handheld LED device for home-use treatment of periorbital wrinkles. Device emits light energy at red (633 ±5nm) and infrared (830 ±5nm) wavelengths using 25 LEDs distributed over 17cm². Device includes a handpiece, charging base, and AC adapter. User operates device by applying light energy to treatment zones for 15-20 minutes per session. No complex algorithms or software-based analysis; device provides uniform light distribution. Benefits include non-invasive treatment of periorbital lines and wrinkles.

Clinical Evidence

No clinical data included. Evidence consists of bench testing for electrical safety, electromagnetic compatibility, photobiological safety, and biocompatibility. A usability/label comprehension study with 35 participants demonstrated 100% success in device setup, operation, and cleaning, and 95% success in questionnaire accuracy.

Technological Characteristics

Handheld LED device; 25 LEDs; wavelengths 633 ±5nm and 830 ±5nm; constant waveform. Materials: ABS (body), Stainless steel 304 (head). Power: 100~240V AC adapter, 2x3.7V 900 mAh Lithium battery. Standards: AAMI/ANSI ES60601-1, IEC 60601-1-2, IEC 60601-1-11, IEC 62471. Biocompatibility: ISO 10993-1, -5, -10. No software-based algorithm.

Indications for Use

Indicated for individuals with periorbital wrinkles for use in dermatology.

Regulatory Classification

Identification

(1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.

Predicate Devices

• Silk'n FX (K110301)

Submission Summary (Full Text)

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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

February 25, 2016

Omm Imports Inc Dba Zero Gravity % Ms. Susan Anthoney-DeWet Aegis Regulatory, Inc. 2424 Dempster Drive Coralville, IA 52241

Re: K152332

Trade/Device Name: Perfectio LED Infrared Device Regulation Number: 21 CFR 878.4810 Regulation Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Regulatory Class: II Product Code: OHS Dated: January 27, 2015 Received: January 27, 2015

Dear Ms. Anthoney-DeWet:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical devicerelated adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in

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the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Post-market Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number [phone] or [phone] or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Jennifer R. Stevenson -S

For Binita S. Ashar, M.D., M.B.A., F.A.C.S. Director Division of Surgical Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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# Indications for Use

510(k) Number (if known) K152332

Device Name Perfectio LED infrared Device

Indications for Use (Describe)

Perfectio LED infrared device is an over the counter device indicated to emit energy in the red and IR region of the spectrum for use in dermatology for the treatment of periorbital wrinkles.

| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|

Prescription Use (Part 21 CFR 801 Subpart D)

X Over-The-Counter Use (21 CFR 801 Subpart C)

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## Section 5 510(k) Summary

[As required by 21 CFR 807.92]

#### 1. Submission Information:

| 510(k) Number: | K152332 |
|------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Date: | Aug 10, 2015 |
| Type of 510(k) Submission: | Traditional |
| Basis for 510(k) Submission: | New device |
| Submitter/Manufacturer: | OMM IMPORTS INC DBA ZERO GRAVITY;<br>1945 S OCEAN DR APT 509 HALLANDLE BEACH BLVD,FLORIDA<br>33009, US |
| Contact: | Doris Dong (Consultant)<br>Shanghai CV Technology Co., Ltd.<br>Room 1706, No. 128 Songle Rd., Songjiang Area, Shanghai, 201600 China<br>E-mail: [e-mail]<br>Tel: [phone] |

#### 2. Device Description:

| Proprietary Name: | Perfectio LED infrared device |
|----------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Common Name: | Light Emitting Diode (LED) device |
| Classification Name: | Laser surgical instrument for use in general and plastic surgery and in dermatology |
| Product Code: | OHS |
| Device Class: | II |
| Regulation Number: | 21 CFR 878.4810 |
| Review Panel: | General & Plastic Surgery |
| Indications for use: | Perfectio LED infrared device is an over the counter device indicated to emit energy in the red and IR region of the spectrum for use in dermatology for the treatment of periorbital wrinkles. |
| Device Description: | Perfectio LED infrared device is a battery operated device that uses low power light spectrum at red and infrared LED, at wavelength of 633 ±5nm, 830 ±5nm emitting optical power in a uniform distribution with no hot spots. The device is composed of a handpiece for delivery of light energy, base unit for charging and storage when not in use, and A.C. charging adapter. It is a hand held light emitting diode (LED) device for the treatment of periorbital wrinkles designed for home-use. |

#### 3. Predicate Device Identification

510(k) Number: K110301 Clearing date: August 19, 2011 Product Name: Silk'n FX Manufacturer: Home Skinovations Ltd.

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#### OMM IMPORTS INC DBA ZERO GRAVITY; 1945 S OCEAN DR APT 509 HALLANDLE BEACH BLVD,FLORIDA 33009

## 4. Non-Clinical Test Conclusion

Bench tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device conforms with the following standards:

* AAMI / ANSI ES60601-1:2005/(R) 2012 And A1:2012, C1:2009/(R) 2012 And A2:2010/(R)2012 (Consolidated Text) Medical Electrical Equipment - Part 1: General Requirements for Basic Safety and Essential Performance.

* IEC 60601-1-2:2014, Medical Electrical Equipment - Part 1-2: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Electromagnetic Disturbances - Requirements and Tests. * IEC 60601-1-11:2010, Medical Electrical Equipment - Part 1-11: General Requirements for Basic Safety and Essential Performance - Collateral Standard: Requirements for Medical Electrical Equipment and Medical Electrical Systems Used in the Home Healthcare Environment

* IEC 62471:2006, Photobiological Safety of Lamps and Lamp Systems

The patient contact materials in Perfectio LED infrared device are the body housing material of ABS and the head housing material of Stainless steel 304. Both the two materials were tested and found to meet the biocompatibility standards of:

* ISO 10993-1:2009, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process

* ISO 10993-5:2009, Biological evaluation of medical devices - Part 5: Tests for In Vitro cytotoxicity, and * ISO 10993-10:2010, Biological evaluation of medical devices - Part 10: Tests for irritation and

delayed-type hypersensitivity

A Usability/Label Comprehension Study was conducted with 35 participants.

The results of the study showed that (100%) were able to:

-Correctly self-select as being an appropriate user of the device.

-Correctly demonstrate how to set up the device, perform the Light Sensitivity Test, operate the device (apply Tx), and clean the device.

And that (95%) of participants were able to correctly answer each question for the Questionnaire portion of the Study.

## 5. Substantial Equivalent Based on Assessment of Clinical Performance Data:

Clinical data was not included in this submission.

| | New Device | Predicate Device |
|----------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) Number: | K152332 | K110301 |
| Product Code: | OHS | OHS |
| Proprietary Name: | Perfectio LED infrared device | Silk'n FX |
| Manufacturer: | OMM IMPORTS INC DBA ZERO<br>GRAVITY | Home Skinovations Ltd. |
| Indications for use: | Perfectio LED infrared device is an over<br>the counter device indicated to emit energy<br>in the red and IR region of the spectrum for<br>use in dermatology for the treatment of | Silkn FX is an over the counter device<br>indicated to emit energy in the red and IR<br>region of the spectrum for use in<br>dermatology for the treatment of |

### 6. Substantially Equivalent Comparison Conclusion

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#### OMM IMPORTS INC DBA ZERO GRAVITY; 1945 S OCEAN DR APT 509 HALLANDLE BEACH BLVD,FLORIDA 33009

| | periorbital wrinkles. | periorbital wrinkles. |
|--------------------------|------------------------------------------|------------------------------------------|
| Handheld | Yes | Yes |
| Materials | ABS and stainless steel | ABS and stainless steel |
| Wavelengths | 633 ±5nm, 830 ±5nm | 633 ±5nm, 830 ±5nm |
| Light source | Light emitting diode(LED) | Light emitting diode(LED) |
| Waveform | Constant | Constant |
| Energy Source | 25 LEDs over 17cm² | 24 LEDs over 12 cm² |
| Power supply | Adaptor:100~240V AC 50/60Hz 0.2A | Adaptor:100~240V AC 50/60Hz 0.4A |
| | Lithium battery: 2x3.7V, 900 mAh | Lithium battery: 2x3.7V, 750±50mAh |
| Initial treatment course | For the first month (4 weeks), treatment | For the first month (4 weeks), treatment |
| | should be performed 3 times a week for | should be performed 3 times a week for |
| | 15-20 minutes each time.(5-7 minutes on | 15-20 minutes each time.(5-7 minutes on |
| | each treatment zone). | each treatment zone). |
| Maintenance regime | Once a week for 15-20 minutes | Once a week for 15-20 minutes |
| Target Population | Individuals with periorbital lines and | Individuals with periorbital lines and |
| | wrinkles | wrinkles |
| Location for use | OTC | OTC |
| Standard meet | IEC60601-1 | IEC60601-1 |
| | IEC60601-1-2 | IEC60601-1-2 |
| | IEC60601-1-11 | IEC62471 |
| | IEC62471 | |

### The Conclusions:

Taking into consideration the table for substantial equivalence, an analysis of safety, indications, intended uses, performance, and technological properties, the proposed device raises no new issues of safety or effectiveness and has been found to be substantially equivalent to the predicate device.

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