K180359 · BTL Industries, Inc. · GEI · Dec 13, 2018 · General, Plastic Surgery
Device Facts
Record ID
K180359
Device Name
BTL-FR2000
Applicant
BTL Industries, Inc.
Product Code
GEI · General, Plastic Surgery
Decision Date
Dec 13, 2018
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4400
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Applicator 786-1 of BTL-FR2000 device is indicated for use in dermatological and general surgical procedures for electrocoagulation and hemostasis. The Applicator 786-2 of BTL-FR2000 device is intended for dermatological procedures requiring fractional treatment of the skin.
Device Story
BTL-FR2000 is a radiofrequency (RF) system for dermatological and general surgical procedures. The system comprises a microprocessor-driven control unit with an 8.4" color touch screen, an RF generator, and two types of applicators (786-1 and 786-2) with exchangeable tips. The operator uses the touch screen to guide therapy and a handpiece button to control energy delivery. The device delivers 1 MHz electromagnetic energy to the skin via gold-plated micro-needle electrodes (0.5–3.5mm depth). The system operates in monopolar mode to achieve target tissue temperatures for coagulation, hemostasis, or fractional skin treatment. It is intended for use by healthcare professionals in clinical settings. The device provides visual feedback on energy flow via an illuminated treatment tip. Clinical benefits include precise tissue heating for surgical and dermatological applications.
Clinical Evidence
Bench testing only. Testing demonstrated the device's ability to achieve required temperatures in the treated area. Electrical safety and electromagnetic compatibility were verified against IEC 60601-1, IEC 60601-1-2, and IEC 60601-2-2 standards.
Technological Characteristics
System console with RF generator, computer, and 8.4" touchscreen. Energy source: 100-240V AC, 50-60 Hz. RF frequency: 1 MHz. Monopolar energy delivery. Applicators use sterile, exchangeable gold-plated micro-needle electrodes (0.5-3.5mm depth, 1.7mm spacing). Electrical protection: Class II, BF. Sterilization: Ethylene oxide (ISO 11135). Software lifecycle: IEC 62304.
Indications for Use
Indicated for patients requiring dermatological or general surgical procedures for electrocoagulation, hemostasis, or fractional skin treatment.
Regulatory Classification
Identification
An electrosurgical cutting and coagulation device and accessories is a device intended to remove tissue and control bleeding by use of high-frequency electrical current.
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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
December 13, 2018
BTL Industries, Inc. David Chmel VP of Operations 362 Elm Street Marlborough, Massachusetts 01752
Re: K180359
Trade/Device Name: BTL-FR2000 Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical Cutting and Coagulation Device and Accessories Regulatory Class: Class II Product Code: GEI Dated: November 8, 2018 Received: November 13, 2018
Dear David Chmel:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 device-related adverse events) (21 CFR 803) for
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devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely.
Long H.
Chen -S
Digitally signed by
Long H. Chen -S
Date: 2018.12.13
13:27:30 -05'00'
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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DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
510(k) Number (if known) K180359
Device Name BTL-FR2000
Indications for Use (Describe)
The Applicator 786-1 of BTL-FR2000 device is indicated for use in dermatological and general surgical procedures for electrocoagulation and hemostasis.
| CONTINUE ON A SEPARATE PAGE IF NEEDED. | | |
|------------------------------------------------|---------------------------------------------|--|
| X Prescription Use (Part 21 CFR 801 Subpart D) | Over-The-Counter Use (21 CFR 801 Subpart C) | |
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Druq Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
Type of Use (Select one or both, as applicable)
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Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2020
See PRA Statement below.
DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
#### Indications for Use
510(k) Number (if known) K180359
Device Name BTL-FR2000
Indications for Use (Describe)
The Applicator 786-2 of BTL-FR2000 device is intended for dermatological procedures requiring fractional treatment of the skin.
| Type of Use (Select one or both, as applicable) |
|-------------------------------------------------|
|-------------------------------------------------|
> Prescription Use (Part 21 CFR 801 Subpart D)
__ Over-The-Counter Use (21 CFR 801 Subpart C)
#### CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Druq Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
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K180359
Image /page/4/Picture/1 description: The image shows the logo for BTL Industries. The logo consists of three blue squares that are stacked on top of each other. The letters "BTL" are written in white inside the top square. To the right of the squares, the words "BTL Industries" are written in gray.
# 510(k) Summary
# General Information
| Sponsor: | BTL Industries, Inc.<br>362 Elm Street<br>Marlborough, MA 01752<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
|------------------------------|-----------------------------------------------------------------------------------------------------------------|
| Applicant: | BTL Industries, Inc.<br>362 Elm Street<br>Marlborough, MA 01752<br>Tel: +1-866-285-1656<br>Fax: +1-888-499-2502 |
| Contact Person: | David Chmel<br>BTL Industries, Inc.<br>chmel@btlnet.com |
| Summary Preparation<br>Date: | December 13, 2018 |
# Device
| Trade/Proprietary Name: | BTL-FR2000 |
|------------------------------|-------------------------------------------------------------------|
| Primary Classification Name: | Electrosurgical cutting and coagulation device and<br>accessories |
| Classification Regulation: | 21 CFR 878.4400, Class II |
| Classification Product Code: | GEI |
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Image /page/5/Picture/1 description: The image shows the logo for BTL Industries. The logo consists of three interconnected blue squares on the left side, with the letters "BTL" inside the leftmost square. To the right of the squares, the words "BTL Industries" are written in a gray, sans-serif font.
## Legally Marketed Predicate Devices
The BTL-FR2000 is a state-of-the-art radiofrequency device with accessories. The device is substantially equivalent to the products that are already cleared for distribution in the USA under the following 510(k) Premarket Notification numbers:
- INFINI Radiofrequency System (K121481) .
- Matrix RF Applicator (K090025) ●
### Product Description
The BTL-FR2000 device enables application of therapy by a high-frequency field.
The control unit of the system is fitted with a color touch screen, to facilitate use of the device. The on-screen information guides the operator through the entire therapy. For easier control, the handpiece is equipped with button, enabling operation of the device during therapy. Quality of the energy flow is indicated by the illuminated treatment tip.
The BTL-FR2000 device comes with two types of the applicator, depending on the applicator tip attached - Applicator 786-1 and Applicator 786-2.
The BTL-FR2000 device consists of the following main components:
- microprocessor-driven control unit .
- . radiofrequency generator
- user interface with 8.4" color touch screen ●
- . applicator for an application of radiofrequency
- . exchangeable applicator tips
### Intended Use
The Applicator 786-1 of BTL-FR2000 device is indicated for use in dermatological and general surgical procedures for electrocoagulation and hemostasis.
The Applicator 786-2 of BTL-FR2000 device is intended for dermatological procedures requiring fractional treatment of the skin.
### Performance Data
The BTL-FR2000 device has been thoroughly evaluated for electrical safety. The device has been found to comply with applicable medical device safety standards:
- IEC 60601-1 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
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| IEC 60601-1-2 | Medical electrical equipment – Part 1-2: General requirements for<br>basic safety and essential performance - Collateral standard:<br>Electromagnetic compatibility – Requirements and tests |
|---------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| IEC 60601-2-2 | Medical electrical equipment - Part 2-2: Particular requirements for the<br>basic safety and essential performance of high frequency surgery<br>equipment and high frequency surgical accessories |
| IEC 62304 | Medical device software – Software life cycle processes |
| ISO 14971 | Medical devices – Application of risk management to medical devices |
| ISO 10993-1 | Biological evaluation of medical devices – Part 1: Evaluation and<br>testing within a risk management process |
| ISO 11135 | Sterilization of health-care products -- Ethylene oxide -- Requirements<br>for the development, validation and routine control of a sterilization<br>process for medical devices |
Bench testing has been performed in order to demonstrate the device is able to achieve required temperature in the treated area.
## Technological Characteristics
The BTL-FR2000 device has similar technological characteristics compared to its predicate devices. The BTL-FR2000 device and the predicates are comprised of a system console and applicator(s). The system console consists of the RF generator, computer, and the touchscreen control panel. The applicator is used with exchangeable tips as by predicates.
The energy source of the BTL-FR2000 device is 100 - 240 V AC, 50 - 60 Hz, alike the predicate devices. BTL-FR2000 electrical protection is classified as Class II, BF and it assures high level of electric shock protection.
Type of energy applied is identical to the devices being compared, the electromagnetic energy is used to achieve the intended use. The RF signal frequency of 1 MHz is also identical. The difference between BTL-FR2000 device and predicate devices is in mode of operation. The BTL-FR2000 device use monopolar mode of operation, compared to the bipolar mode by predicate devices. Nevertheless, monopolar mode of operation is also used by devices with similar intended use, cleared by the FDA. Moreover above mentioned bench testing has been conducted to verify the device is able to achieve required temperature in the treated area. Therefore the differences does not rise any new questions of safety nor effectiveness.
The BTL-FR2000 device, as well as the predicate devices, uses sterile exchangeable tips. The material used for production of superficial pins and needles is gold, identical material for the devices being compared. The depth of micro-needle electrodes of BTL-FR2000 device, 0.5 - 3.5mm is also identical to predicate device. The needle spacing of 1.7mm is comparable to the predicate devices. The tips size of compared devices slightly differ, but this difference does not rise any new questions of safety nor effectiveness.
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Image /page/7/Picture/1 description: The image contains the logo for BTL Industries. The logo consists of three interconnected blue squares with the letters "BTL" inside the leftmost square. To the right of the logo is the text "BTL Industries" in a gray, sans-serif font. The text is slightly spaced out, giving it a modern and clean appearance.
Furthermore, technological differences in the shape and dimensions of the BTL-FR2000 device console and predicate devices also do not raise any safety or effectiveness questions, given that the BTL-FR2000 device console design was previously cleared.
Therefore, the BTL-FR2000 device has similar technological characteristics compared to its predicate devices.
#### Substantial Equivalence
The BTL-FR2000 device has similar intended use and technological characteristics to the predicate devices. Any differences between the predicate devices and BTL-FR2000 device have no significant influence on safety or effectiveness of the BTL-FR2000 device. Therefore, the BTL-FR2000 device is substantially equivalent to the predicate devices.
#### Conclusion
Based upon the intended use and known technical information provided in this pre-market notification, the BTL-FR2000 device has been shown to be substantially equivalent to currently marketed predicate devices.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
Where do you find a device's intended use without opening the PDF?
Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
6. Collections
With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
8. Chart view
Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.