K192272 · A.R.C Laser GmbH · GEX · Mar 17, 2020 · General, Plastic Surgery
Device Facts
Record ID
K192272
Device Name
Wolf445nm
Applicant
A.R.C Laser GmbH
Product Code
GEX · General, Plastic Surgery
Decision Date
Mar 17, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Wolf 445nm is intended for incision, vaporization, ablation, hemostasis and coagulation of soft tissue.
Device Story
Wolf 445nm is a compact diode laser system used for soft tissue surgery; operates via laser diode emitting 445nm wavelength; includes green 532nm aiming beam. Physician operates device via high-resolution color touchscreen; laser energy delivered through optical fibers (300, 400, 600 µm) with or without handpieces. Device performs incision, excision, vaporization, ablation, hemostasis, and coagulation. Air-cooled system; powered by 100-240V AC. Output affects tissue through thermal interaction; provides clinical benefit by enabling precise soft tissue management in general, plastic, and dermatological surgery.
Clinical Evidence
No clinical data. Bench testing only. Comparison of 445nm vs 532nm laser devices evaluated cut depth and thermal damage zones via histological samples to demonstrate equivalent tissue interaction performance. Electrical safety, EMC, and software verification/validation testing performed.
Indicated for incision, excision, vaporization, ablation, hemostasis, and coagulation of soft tissue in patients requiring surgical intervention.
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.
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March 17, 2020
A.R.C. Laser GmbH Angela Thyzel General Manager Bessemer St. 14 Nurnberg, 90411 De
Re: K192272 Trade/Device Name: Wolf 445nm Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: GEX Dated: February 3, 2020 Received: February 10, 2020
Dear Angela Thyzel:
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
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requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801 and Part 809); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
Jessica Mavadia-Shukla, Ph.D. Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: 06/30/2020 See PRA Statement below.
510(k) Number (if known) K192272
Device Name Wolf 445nm
Indications for Use (Describe)
The Wolf 445nm is intended for incision, vaporization, ablation, hemostasis and coagulation of soft tissue.
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)
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Image /page/3/Picture/1 description: The image is a logo for A.R.C. Laser. The logo is set against a blue background. The text "A.R.C." is in large, bold, white letters. Below that, the word "LASER" is in a white box. Underneath the box, the phrase "enlighten your surgery." is written in a cursive font.
## 510(k) Summary - K192272
| Submitter: | A.R.C. Laser GmbH<br>Bessemer St. 14<br>90411, Nurnberg<br>Germany |
|---------------------------------------------|-----------------------------------------------------------------------------------------------|
| Contact person :<br>Phone<br>Fax<br>E-Mail: | Angela Thyzel, General Manager<br>0911-21779-0<br>0911-21779-99<br>a.thyzel@arclaser.de |
| Date<br>Prepared: | March 6, 2020 |
| Device Trade<br>Name: | Wolf 445nm |
| Common<br>Name: | Diode Laser System |
| Classification<br>Name: | Laser surgical instrument for use in general and plastic surgery and in<br>dermatology |
| Device product<br>code: | GEX |
| Device<br>Classification | 21 CFR 878.4810 |
| Predicate<br>Devices: | Aura Laser System, K951034, Primary Predicate<br>SiroLaser Blue, K180044, Reference Predicate |
Device Description:
The Wolf Diode Lasers are a family of products with a laser diode as the beam source. Dependent on the chosen diode the laser system can radiate one wavelength with either 445nm, 980nm or 1470nm. This submission refers to and includes only one model, the Wolf 445nm.
The Wolf 445nm is a compact diode laser with a high resolution color touchscreen for user control. The laser utilizes a green (532nm) aiming beam diode to indicate the area to be irradiated by the laser beam.
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Image /page/4/Picture/1 description: The image shows the logo for A.R.C. Laser. The logo is in a blue box with the text "A.R.C." in large, bold, white letters. Below that is the word "LASER" in smaller, white letters. Underneath the word laser is the company's slogan, "enlighten your surgery" in a cursive font.
# 510(k) Summary – K192272
Indications for Use: The Wolf 445nm is intended for incision, excision, vaporization, ablation, hemostasis and coagulation of soft tissue.
# Comparison of Technological Characteristics with the Predicate Devices
The primary predicate device is the Aura laser system (K951034), a KTP laser with a wavelength of 532nm with same intended use as the subject device.
The SiroLaser Blue, K180044, is a reference device, with the same intended use although is used for dental applications, shares the same wavelength, the same product code GEX, same device class and same classification name and number.
| Specification | Subject Device<br>Wolf 445nm | Primary Predicate Device<br>Aura Laser System | Reference Predicate<br>Device SIROLaserBlue |
|---------------------------|-------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) # | K192272 | K951034 | K180044 |
| Regulation # | 878.4810 | 878.4810 | 878.4810 |
| Class Code | GEX | GEX | GEX & ILY |
| Class | II | II | II |
| Indications for<br>Use | The Wolf 445nm is intended for use<br>in incision/excision, vaporization,<br>ablation, hemostasis and coagulation<br>of soft tissue | Aura XP is intended for use in in<br>incision/excision, vaporization,<br>ablation, hemostasis and<br>coagulation of soft tissue | SIROLaserBlue is intended<br>for intra and extra oral<br>surgery including incision,<br>excision, hemostasis,<br>coagulation & vaporization<br>of soft tissue |
| Use of device | RX only | RX only | RX only |
| Laser type | Diode Laser | Flash Lamp Pulsed KTP Laser | Diode Laser |
| Laser power | 0.5 W to 10 W | 0.5 W to 15 W | 0.2 W - 3.0 W |
| Wavelength | 445 nm | 532 nm | 445 nm, 660 nm, 970 nm |
| Laser Class | 4 | 4 | 4 |
| Operation<br>mode | Pulsed, Continuous Wave (CW) or<br>Single Pulse (SP) | Pulsed, Quasi continuous wave | Continuous wave (CW) or<br>Pulsed |
| Pulse length/<br>duration | < 4 Watt: 1 ms to 45 sec and CW<br>> 4 Watt: 1 ms to 60 ms | 1 to 50 milliseconds in 1 ms<br>increments, then .1 to 1 sec in<br>0.1 increment, then .5 sec<br>increments to continuous | 10 µs to 0.99 sec. |
| Pulse<br>frequency | < 4 Watt: 0.01 Hz to 500 Hz and SP<br>> 4 Watt: 0.02 Hz to 6.6 Hz and SP | 0.5 Hz to 5 Hz | 1 Hz to 10 kHz |
| Aiming beam<br>wavelength | 532 nm | 635 nm | 660 ± 5 nm |
| Aiming beam<br>power | < 5 mW | 5 mW | max. 1 mW |
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Image /page/5/Picture/1 description: The image features the logo of A.R.C. Laser, set against a solid blue background. The acronym "A.R.C." is prominently displayed in large, bold white letters, positioned above the word "LASER," which is enclosed in a white box. Below the boxed word, the tagline "enlighten your surgery." is written in a cursive font, completing the logo's design.
#### Page 2 of 4 510(k) Summary - K192272
| Specification | Subject Device<br>Wolf 445nm | Primary Predicate Device<br>Aura Laser System | Reference Predicate<br>Device<br>SIROLaserBlue |
|-------------------------|------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------|----------------------------------------------------------------------------|
| Use in<br>combination | Delivery devices<br>optical fibers 300 µm, 400 µm and<br>600 µm with or without hand<br>pieces | Delivery devices - Multiple<br>Aura Fibers and accessories<br>for various applications | Delivery devices, fibers<br>200 µm, 320 µm |
| Cooling | Air | Air | Air |
| Display | Touch screen | Buttons and regulators | Touch screen |
| Main power<br>Supply | 100-240 V~, 47-63 Hz, 1.06-0.45 A | 120 V AC/ 15 AMPS<br>230 V AC/ 10 AMPS | 15 V DC 6.66 A max.<br>100 VA MPU101-106 |
| Dimensions<br>of system | H 10.06 cm (3.9 inches)<br>W 20.3 cm (7.9 inches)<br>L 23.9 cm (9.4 inches) | H 41 cm (16 inches)<br>W 30.5 cm (12 inches)<br>L 58 cm (23 inches) | H 18.2 cm (7.1 inches)<br>W 19.7 cm (7.7 inches)<br>L 18.9 cm (7.4 inches) |
| Weight | 2.8 kg (6.17 pounds) | 27 kg (60 pounds) | 1.3 kg (2.86 pounds) |
#### Comparison of Technological Characteristics with the Predicate Devices (continuation)
### Performance Data
The safety and effectiveness determination of the 445nm subject device compared to the primary predicate with wavelength 532nm is supported by the Electrical Safety, EMC, Software, and non-clinical comparison bench tests provided in the submission.
### Non clinical testing :
A comparison bench test between 445 nm and 532 nm laser devices was conducted with the purpose of demonstrating that the Wolf 445 nm provides as safe & effective performance data as a KTP Laser (532 nm) in terms of tissue interaction processes.
The cut depth (effectiveness) and thermal damage (safety) zones of the 445nm laser device were used for the purpose of comparison.
Following the tests, histological samples were evaluated for areas of visible alteration of depth and width of the incision as well as zones of thermal and mechanical damage created by the tests.
# Electrical Safety and EMC testing:
Electrical safety and EMC testing were conducted on the Wolf 445nm, consisting of Diode laser console and optical fibers.
The Wolf 445nm system has been tested for Electrical Safety according to IEC 60601-1:2005 A1:2012 and /or EN 60601-1:2006/A1:2013, for Laser Safety according to IEC 60825-1: 2014 (edition 3.0), for Safety of laser according to IEC 60825-1:2014 and IEC 60601-2-22:2007/A1:2012, for Usability with IEC 60601-1-6:2010/A1:2013 and IEC 62366:20017, AMD1:2014.
Electromagnetic Compatibility was tested according to IEC 60601-1-2:2014, (edition 4.0).
### Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices."
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Image /page/6/Picture/1 description: The image is a logo for A.R.C. Laser. The logo is set against a blue background. The text "A.R.C." is in large, bold, white letters, stacked above the word "LASER", which is also in white. Below "LASER" is the tagline "enlighten your surgery.", written in a smaller, italicized font.
Page 3 of 4
# 510(k) Summary - K192272
The software is considered as a moderate level of concern and the documentation was provided accordingly.
### Summary
Based on the clinical performance, technological characteristics and performance data as documented in this submission, the Wolf 445nm was found to have a safety and effectiveness profile that is similar to the predicate devices.
# Conclusion
The safety and effectiveness determination between the subject and the predicate devices is supported by the performance data provided in the submission, the electrical and EMC testing, the software verification and validation testing and the non-clinical bench test demonstrating that the Wolf 445nm performs comparably to the predicate device that is currently marketed for the same intended use.
Animal or clinical studies: None
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.