Who is the manufacturer of Renuvion® Micro Handpiece?

Apyx Medical Corporation filed the 510(k) submission for Renuvion® Micro Handpiece (K230586).

What is the FDA product code for Renuvion® Micro Handpiece?

GEI. It is classified under 21 CFR 878.4400 as a Class 2 device in the General, Plastic Surgery panel.

What is the regulatory pathway for Renuvion® Micro Handpiece?

510(k) clearance (submission type: Traditional).

What are the predicate devices for Renuvion® Micro Handpiece?

Renuvion® APR Handpiece (K223262); Renuvion® APR Handpiece (K230272).

Who can help prepare an FDA 510(k) submission like Renuvion® Micro Handpiece?

Innolitics — a medical-device software consultancy — provides regulatory and engineering support for FDA 510(k) submissions. See https://innolitics.com/services/510ks/ or contact https://innolitics.com/contact.

Renuvion® Micro Handpiece

K230586 · Apyx Medical Corporation · GEI · Jun 9, 2023 · General, Plastic Surgery

Device Facts

Record ID	K230586
Device Name	Renuvion® Micro Handpiece
Applicant	Apyx Medical Corporation
Product Code	GEI · General, Plastic Surgery
Decision Date	Jun 9, 2023
Decision	SESE
Submission Type	Traditional
Regulation	21 CFR 878.4400
Device Class	Class 2
Attributes	Therapeutic

Intended Use

Renuvion® Micro 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® Micro Handpiece is compatible with the Apyx One Console Generator, owned by Apyx Medical.

Device Story

Sterile, single-use monopolar electrosurgical handpiece; used with Apyx One Console Generator. Inputs: radiofrequency energy from generator, helium gas. Operation: helium gas passes over energized electrode to generate helium plasma for soft tissue coagulation/contraction. Features: 10cm low-profile shaft (2mm distal tip tapering to 1.5mm), front-port ceramic nozzle, sterile saline flush port. Used by clinicians in surgical settings. Output: thermal energy delivered to soft tissue. Benefits: enables coagulation/contraction in smaller anatomical areas via reduced device profile. Healthcare providers use output to achieve tissue effects; device performance verified via bench and ex-vivo thermal tissue testing.

Clinical Evidence

No clinical data. Substantial equivalence supported by bench testing (mechanical functionality, system compatibility, packaging validation, electrical safety/EMC per IEC 60601 series) and ex-vivo tissue studies. Ex-vivo testing demonstrated equal or less thermal effect compared to predicate and confirmed tissue temperature maintenance (>85°C for >45 msec). Biocompatibility testing (cytotoxicity, sensitization, irritation, systemic toxicity, pyrogenicity) confirmed safety for limited duration (<24h) external communicating tissue/bone/dentin contact.

Technological Characteristics

Monopolar electrosurgical handpiece; stainless steel shaft with outer polymer layer. Energy: RF and helium plasma. Power: up to 12W (30% setting). Helium flow: 1-1.5 L/min. Dimensions: 10cm shaft, 2mm distal tip tapering to 1.5mm. Connectivity: connects to Apyx One Console Generator. Sterilization: sterile, single-use. Standards: ANSI/AAMI/IEC 60601-1, 60601-2-2, 60601-1-2, ISO 10993-1.

Indications for Use

Indicated for coagulation/contraction of soft tissue, including subcutaneous tissue, using radiofrequency energy and/or helium plasma.

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.

Predicate Devices

Renuvion® APR Handpiece (K223262)
Renuvion® APR Handpiece (K230272)

Related Devices

K191542 — Apyx Plasma/RF Handpiece · Bovie Medical Corporation Dba Apyx Medical Corporation · Oct 11, 2019
K191484 — Renuvion/J-Plasma Precise Handpiece · Apyx Medical Corporation(Formerly Bovie Medical Corporation) · Jul 30, 2019
K202880 — J-Plasma Precise FLEX Handpiece · Apyx Medical Corporation (Formerly Bovie Medical Corporation · Jan 4, 2021
K230272 — Renuvion® APR Handpiece · Apyx Medical Corporation · Apr 27, 2023
K151325 — Bovie J-Plasma Handpiece · Bovie Medical Corporation · Aug 4, 2015

Submission Summary (Full Text)

{0}------------------------------------------------ Image /page/0/Picture/0 description: The image contains 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. Underneath the square are the words "U.S. FOOD & DRUG ADMINISTRATION" in blue. June 9, 2023 Apyx Medical Corporation Mark Evans Sr. Premarket Regulatory Affairs Specialist (formerly Bovie Medical Corporation) 5115 Ulmerton Road Clearwater, Florida 33760-4004 Re: K230586 Trade/Device Name: Renuvion® Micro Handpiece Regulation Number: 21 CFR 878.4400 Regulation Name: Electrosurgical cutting and coagulation device and accessories Regulatory Class: Class II Product Code: GEI Dated: May 15, 2023 Received: May 15, 2023 Dear Mark Evans: 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 {1}------------------------------------------------ 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 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 (QS) 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 medical devices and radiation-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, Digitally signed by Mark Mark Trumbore -S Trumbore -S Date: 2023.06.09 15:33:07 -04'00' Mark Trumbore, Ph.D. Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration ### Indications for Use 510(k) Number (if known) Device Name Renuvion® Micro Handpiece Indications for Use (Describe) Renuvion® Micro 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® Micro Handpiece is compatible with the Apyx One Console Generator, owned by Apyx Medical. | 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 Drug 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." {3}------------------------------------------------ Image /page/3/Picture/2 description: The image shows the logo for Apyx Medical. The logo is comprised of the word "Apyx" in orange, with a blue triangle in place of the "A". Below the word "Apyx" is the word "MEDICAL" in blue. The logo is simple and modern, and the colors are bright and eye-catching. - 1. General Information: | Submitted by: | Apyx Medical Corporation 5115 Ulmerton Road Clearwater, Florida 33760-4004 United States of America | |----------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Establishment Registration #: | 3007593903 | | Contact Person: | Mark D. Evans, Sr. Premarket Regulatory Affairs Specialist 5115 Ulmerton Road Clearwater, Florida 33760-4004 United States of America Phone: (856) 524-5037 Email: mark.evans@apyxmedical.com | | Date Prepared: | March 2, 2023 | | Trade Names (Model Numbers): | Renuvion® Micro Handpiece (APYX-10-Micro) | | Common Name: | Electrosurgical Handpiece | | Classification: | Class II per 21CFR 878.4400 - Electrosurgical Cutting and Coagulation Device and Accessories Product Code GEI | | Primary Predicate Device: Secondary Predicate Device: | Renuvion® APR Handpiece (K223262) Renuvion® APR Handpiece (K230272) | ### 2. Proposed Indications for Use: Renuvion® Micro 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® Micro Handpiece is compatible with the Apyx One Console Generator, owned by Apyx Medical. - 3. Device Description and Technological Characteristics: {4}------------------------------------------------ Image /page/4/Picture/2 description: The image shows the logo for Apyx Medical. The word "Apyx" is in orange, with a blue triangle in the "A". The word "MEDICAL" is in blue and is located below the word "Apyx". The logo is simple and modern. The Renuvion® Micro System with all components and accessories is show in the picture below. The system is comprised of a compatible electrosurgical generator (Apyx One Console)¹, a sterile, single use handpiece, and a supply of helium gas. Additional accessories include a digital gas regulator2, grounding pad3 and optional footswitch4. The front view of the entire system with all components and accessories is depicted in Figure 1 below. Image /page/4/Picture/6 description: The image shows a medical device setup. The main component is a white generator (ESU) with a black screen. Connected to it are a handpiece and cable, a digital regulator attached to a helium tank, foot switches labeled "J-PLASMA" and "COOL COAG", and a grounding pad. Figure 1: Front View of System 1 510(K) Number: K221830 2 510(K) Number: K221830 3 510(k) Number: K092761 4 510(K) Number: K170188 {5}------------------------------------------------ Image /page/5/Picture/2 description: The image shows the logo for Apyx Medical. The logo consists of the word "Apyx" in orange, with a blue triangle in the "A". The word "MEDICAL" is written in blue below the word "Apyx". The Renuvion® Micro handpiece is a sterile, single use electrosurgical (monopolar) device intended to be used in conjunction with the Apyx One Console Electrosurgical Generator for the percutaneous delivery of radiofrequency and helium plasma energy to soft tissue. When connected to the Apyx One Generator, the device operates at an adjustable power of up to 12 W (expressed as 0 - 30% where 30% is 12 W) and an adjustable helium gas flow of 1 -1.5 L/Min. Radiofrequency energy is delivered to the handpiece by the generator and used to energize the electrode. When helium gas is passed over the energized electrode, a helium plasma is generated for soft tissue coagulation/contraction. The handpiece has a non-extendable electrode to generate helium plasma. The handpiece features a low-profile shaft that is 10cm in length. The distal end of the shaft and tip has a 2mm outer diameter that tapers down to 1.5mm for the remaining length of the shaft. Image /page/5/Figure/6 description: The image shows a Renuvion device with its various components labeled. The device consists of a handle with an activation button, a stainless steel shaft with an energy exit port and tip distance indicators, and a flush port. Additionally, there is a plug connector and a cable attached to the device. The Renuvion® Micro Handpiece is pictured in Figure 2 below. Figure 2: Renuvion® Micro Handpiece Major Components The Renuvion® Micro Handpiece is a modification to the primary predicate device that was cleared in K223262 (Renuvion® APR Handpiece). There are no changes to the principle of operation or mechanism of action. The Renuvion® Micro Handpiece as compared to the predicate devices has the following differences in technological characteristics to enable overall dimensional profile: {6}------------------------------------------------ Image /page/6/Picture/2 description: The image shows the logo for Apyx Medical. The logo is comprised of the word "Apyx" in orange, with a blue triangle in place of the letter "A". Below the word "Apyx" is the word "MEDICAL" in blue. The "®" symbol is located to the right of the "X" in "Apyx". - front-port ceramic nozzle/tip, rather than predicate side-port configuration ● - introduces a sterile saline flush port to assist in removing coagulum build up on the ceramic tip. - The subject devices shaft material is stainless steel with an outer polymer layer, ● whereas the predicate used a polymer-based material throughout. - o The subject device maximum allowable power setting will lowered compared to the predicate, 30% power and maximum helium flow will be 1.5 L/min ### 4. Performance Data: #### a. Bench Testing All testing performed on the Renuvion® Micro Handpiece, hereinafter referred to as Micro Handpiece, was derived from the risk assessment in accordance with ISO 14971 which evaluated the safety and effectiveness of the design with Apyx Medical's Design and Development procedures. The test methodology and acceptance criteria were developed from the same standards and internal Design and Development procedures used for clearance of the primary predicate device. A risk analysis was conducted using the Design Risk Analysis and Control (DRAC) for the subject device (Micro Handpiece). The risk analysis concluded that no new failure modes or risk hazards were identified as a result of the design modifications. Performance testing to assure that the subject device met performance requirements was conducted in accordance with protocols to verify design specifications. The testing performed is summarized in the following table: | Test | Objective | Result | |--------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------| | Mechanical Verification & Functionality | Verify Mechanical functionality of the Renuvion® Micro Handpiece | Mechanical functionality requirements met | | System compatibility Testing | Verify the device, when connected to the generators (with all the components and accessories working together as a system), are working as intended and are compatible with all system components. | System compatibility requirements met | | Inspectional Verification | Document parameters that can be verified through inspection of the Micro Handpiece Labeling and IFU. | Inspectional requirements met | {7}------------------------------------------------ Image /page/7/Picture/2 description: The image shows the logo for Apyx Medical. The logo consists of the word "Apyx" in orange, with a blue triangle in the negative space of the "A". Below the word "Apyx" is the word "MEDICAL" in blue. The logo is simple and modern, and the colors are bright and eye-catching. | Test | Objective | Result | |-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------| | Packaging Validation | Evaluate simulated (and/or real- time) aging and associated package integrity and shelf-life claims. Assess the potential for damage to the device (e.g., drop tests of the instrument in its packaging). | Packaging requirements met | ### b. Electrical Safety and Electromaqnetic Compatibility (EMC) Electrical safety and EMC testing were conducted on the Renuvion® Micro System. The handpiece complies with the ANSI/AAMI/IEC 60601-1:2015/(R)2012 and A1:2012, and AAMI/ANSI/IEC 60601-2-2:2017 standards for safety and the AAMI/ANSI/IEC 60601-1-2:2014 (4th Edition) standard for EMC. The Renuvion® Micro System was determined to be in conformance with these standards. #### c. Biocompatibility Testing The biocompatibility evaluation for the Micro Handpiece was conducted in accordance with the June 16, 2016 FDA Guidance, "Use of International Standard ISO 10993-1, Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management process" and the AAMI/ANSI/ISO 10993-1:2018 standard, "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process". A Biological Evaluation Plan within Apyx Medical's risk management process was developed for the Micro Handpiece to determine the testing and risk assessment for the device and to develop a plan for the mitigation of risks identified. Biocompatibility testing performed is summarized below: Category: External Communicating Device Contact: Tissue / Bone / Dentin Duration of Contact: Limited < 24 hours | Test | Result | |---------------|---------------------------| | Cytotoxicity | Non-cytotoxic | | Sensitization | No sensitization reaction | {8}------------------------------------------------ Image /page/8/Picture/2 description: The image shows the logo for Apyx Medical. The logo is orange and blue. The word "MEDICAL" is written in blue below the logo. | Irritation | Non-irritant | |-------------------------------------------|---------------| | Acute Systemic Toxicity | Non-toxic | | Material Mediated Pyrogen/Pyrogenicity | Non-pyrogenic | The design of the subject device is supported by evidence of biocompatibility verification testing to ensure the device is safe for human use. The materials used in the manufacture of the device met biocompatibility test requirements for external communicating device, Tissue/Bone/Dentin, limited duration devices. ### 5. Pre-Clinical & Ex-Vivo Studies: Ex-vivo tissue testing was conducted and is summarized in the table below: | Test | Objective | Result | |----------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Thermal Tissue Effect | Evaluate the thermal effect between Renuvion Micro Handpiece (APYX-10- MICRO) against its predicate device (Renuvion APR Handpiece, 15 cm, Twin Port, APYX-15-TP). | The test device (APYX-10-MICRO) was subjected to tissue thermal testing and demonstrated an equal or less tissue thermal effect when compared to the predicate device (APYX-15-TP) on five different tissue types at different Renuvion settings. | | Tissue Temperature Over 85 Degrees Celsius Comparison | Evaluate the tissue time over 85 degrees Celsius between the Renuvion Micro Handpiece (APYX-10-MICRO) and its predicate device (Renuvion APR Handpiece, 15 cm, Twin Port, APYX-15- TP) when used at the recommended setting per the IFU for coagulation/contraction of soft tissue such as subcutaneous tissues. | The test device (APYX-10-MICRO) met the acceptance criteria demonstrating that on average the device is at or above 85 degrees for greater than 45 msec. The predicate device showed similar results as a control. | {9}------------------------------------------------ Image /page/9/Picture/2 description: The image shows the logo for "Aryx Medical". The logo is primarily orange, with the word "Aryx" in a stylized font. The "A" is shaped like a triangle with a small blue triangle inside, and the "y" is connected to the "x". Below "Aryx" is the word "MEDICAL" in blue, in a sans-serif font. ### 6. Clinical Studies: This premarket submission did not rely on the assessment of clinical performance data to demonstrate substantial equivalence. ### 7. Substantial Equivalence: The primary predicate and the secondary predicate are identical, with the exception of their indications for use. | | Subject Device | Primary Predicate Device | Secondary Predicate Device | |----------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Feature/ Characteristic | Renuvion® Micro Handpiece | Renuvion® APR Handpiece (K223262) | Renuvion® APR Handpiece (K230272) | | Classification | Class II | Class II | Class II | | Regulation Name and Product Code: | Electrosurgical cutting & coagulation device and accessories, GEI | Electrosurgical cutting & coagulation device and accessories, GEI | Electrosurgical cutting & coagulation device and accessories, GEI | | Indications for Use Statement | Renuvion® Micro Handpiece is intended for the delivery of radiofrequency energy and/or helium plasma coagulation/contraction of soft tissue is needed. Soft tissue includes subcutaneous tissue. The Renuvion® Micro Handpiece is compatible with the Apyx One Console Generator, owned by Apyx Medical. | Renuvion® APR Handpiece is intended for the delivery of radiofrequency energy and/or helium plasma 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 | 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 intended for the coagulation of subcutaneous soft tissues following liposuction for aesthetic body contouring. The Renuvion® APR Handpiece is indicated for use in subcutaneous | | Feature/ Characteristic | Subject Device | Primary Predicate Device | Secondary Predicate Device | | | Renuvion® Micro Handpiece | Renuvion® APR Handpiece (K223262) | Renuvion® APR Handpiece (K230272) | | | | be used with compatible electrosurgical generators owned by Apyx Medical. | dermatological and aesthetic procedures to improve the(loose) skin in the neck and submental region. The Renuvion® APR Handpiece is intended for the delivery of radiofrequency energy and/or helium plasma for cutting, coagulation and ablation of soft tissue during open surgical procedures. The Renuvion® APR Handpiece is intended to be used with compatible electrosurgical generators owned by Apyx Medical. | | Energy Source | RF Generator, Apyx One Console Generator | RF Generator, Generators owned by Apyx Medical | RF Generator, Generators owned by Apyx Medical | | Energy Type | Radio frequency (RF) Energy and Helium Gas | Radio frequency (RF) Energy and Helium Gas | Radio frequency (RF) Energy and Helium Gas | | System Components | The Renuvion® Micro System consists of: RF GeneratorDisposable HPFoot pedalPower cordGas regulator | The Apyx Plasma/RF System consists of: RF GeneratorDisposable HPFoot pedalPower cordGas regulator | The Apyx Plasma/RF System consists of: RF GeneratorDisposable HPFoot pedalPower cordGas regulator | | Feature/ Characteristic | Subject Device Renuvion® Micro Handpiece | Primary Predicate Device Renuvion® APR Handpiece (K223262) | Secondary Predicate Device Renuvion® APR Handpiece (K230272) | | Design & Energy Delivery Configuration | • Gas cylinder 10cm shaft with front- port configuration and indicator lines on the shaft | • Gas cylinder 15cm and 27cm long shaft with a side port configuration (single or twin) and indicator lines on the shaft | • Gas cylinder 15cm and 27cm long shaft with a side port configuration (single or twin) and indicator lines on the shaft | | Shaft and Tip Outer Diameter (OD) | Tip and Distal end of shaft OD: 2mm Shaft beyond distal end OD: 1.5mm | 3mm | 3mm | {10}------------------------------------------------ Image /page/10/Picture/1 description: The image shows the logo for Apyx Medical. The logo is orange and blue. The word "Apyx" is in orange, and the word "Medical" is in blue. {11}------------------------------------------------ Image /page/11/Picture/1 description: The image shows the logo for Apyx Medical. The word "Apyx" is in orange, with a blue triangle in the negative space of the "A". The word "MEDICAL" is in blue and is located below the word "Apyx". The logo is simple and modern. ### 8. Substantial Equivalence Determination The subject device design is based on the design of the Renuvion® APR Handpiece. The subject device has the same general intended use, principle of operation and system requirements. Both handpieces share many of the same technological characteristics except for the design modifications described in Section 3 above. The same performance testing completed for the Renuvion® APR Handpiece has also been conducted for the Micro Handpiece. The conclusions drawn from the bench and ex vivo tissue testing demonstrate that the Micro Handpiece is as safe and effective as the legally marketed primary predicate device and therefore is substantially equivalent. ### 9. Conclusion: The Renuvion® Micro Handpiece is identical in principle of operation, mechanism of action, clinical use, general intended use, and system requirements to the predicate device, Renuvion APR (K223262 and K230272). Overall, the subject device is a smaller version of the predicate devices with minor design modifications to enable device profile. The different technical characteristics do not raise new questions of safety or effectiveness of the subject device. The data presented in this 510(k) demonstrates that the subject device is as safe and effective as the predicate device and there have been no new questions of safety or effectiveness raised. Thus, supporting a substantial equivalence determination for the subject device.