K201773 · Hironic Co., Ltd. · GEX · Oct 19, 2021 · General, Plastic Surgery
Device Facts
Record ID
K201773
Device Name
PICOHI
Applicant
Hironic Co., Ltd.
Product Code
GEX · General, Plastic Surgery
Decision Date
Oct 19, 2021
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The PICOHI is indicated for the following at the specified wavelength: - 1064nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple. - 532nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange. - Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.
Device Story
PICOHI is a solid-state Nd:YAG laser system delivering 1064nm and 532nm wavelengths in picosecond pulses (275-300ps). The system uses a single laser head with frequency doubling to generate both wavelengths, which are delivered colinearly through an articulated arm and handpiece. Operated by clinicians in a professional setting, the device targets pigment particles via selective photothermolysis. The clinician selects parameters based on the target lesion or tattoo color and skin type. The output energy fragments pigment particles, facilitating clearance by the body's immune system. The device is intended for tattoo removal and treatment of benign pigmented lesions.
Clinical Evidence
No clinical performance testing was performed. Safety and effectiveness were demonstrated through non-clinical bench testing, including electrical safety, electromagnetic compatibility, and laser safety verification.
Indicated for tattoo removal (1064nm: Fitzpatrick I-VI, black/brown/green/blue/purple; 532nm: Fitzpatrick I-III, red/yellow/orange) and treatment of benign pigmented lesions (Fitzpatrick I-IV).
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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October 19, 2021
Hironic Co., Ltd. Seo Ji Yeong Regulatory Affairs 19F,767, Sinsu-Ro, Suji-Gu Yongin-Si, Gyeonggi-do 16827 Korea, Republic Of
Re: K201773
Trade/Device Name: PICOHI 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: September 15, 2021 Received: September 15, 2021
Dear Seo Ji Yeong:
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.
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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 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 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.
Purva Pandya 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
510(k) Number (if known) K201773
Device Name PICOHI
Indications for Use (Describe)
The PICOHI is indicated for the following at the specified wavelength:
- · 1064nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.
- · 532nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.
- · Treatment of benign pigmented lesions on Fitzpatrick skin types I-IV.
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------|----------------------------------------------------------------|
| <div> Prescription Use (Part 21 CFR 801 Subpart D) </div> | <div> Over-The-Counter Use (21 CFR 801 Subpart C) </div> |
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Image /page/3/Picture/0 description: The image shows the word "HIRONIC" in black letters with a red square to the left of the word. The font is sans-serif and the letters are bold. The red square is a stylized version of the letter "H".
# 510(k) Summary
K201773
This summary of 510(k) Safety and effectiveness information is being submitted in accordance with the requirements of 21 CFR 807.92.
# 1. Submitter Information – 807.92(a)(1)
| Applicant | Hironic Co., Ltd. |
|---------------------|------------------------------------------------------|
| Address | 19F, 767, Sinsu-ro, Suji-gu, Yongin-si, Gyeonggi-do, |
| | 16827, Republic of Korea |
| Phone Number | +82-31-525-7000 |
| Fax Number | +82-31-525-7010 |
| Contact Person | Jiyeon, Woo |
| Contact Information | m. +82-10-8725-4345 |
| | e. ra@hironic.com |
| Preparation Date | 2021/09/10 |
# 2. Device Name and Code - 807.92(a)(2)
| Device Trade Name | PICOHI |
|---------------------|-----------------------------------|
| Common Name | Laser Surgical Instrument |
| Classification Name | Powered Laser Surgical Instrument |
| Product Code | GEX |
| Regulation Number | 21 CFR § 878.4810 |
| Regulatory Class | Class II |
| Review Panel | General & Plastic Surgery |
# 3. Legally marketed device(s) to which equivalence is claimed - 807.92(a)(3)
| Predicate Devices for laser | PICOWAY(K191685)<br>This predicate devices have not been subject to a<br>design-related recall. |
|-----------------------------|-------------------------------------------------------------------------------------------------|
|-----------------------------|-------------------------------------------------------------------------------------------------|
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## 4. Device Description - 807.92(a)(4)
The PICOHI is a solid-state laser capable of delivering energy at wavelengths of 1064nm, 532nm at extremely short duration in the range of 275-300ps. The laser system contains one 1064nm (Nd:YAG) laser head which is used to create the 1064nm picosecond wavelength which can be frequency-doubled to 532nm as desired. The outputs of the two lasers are designed to be colinear on the laser rail so that their beam paths are identical as they exit the laser system. This allows the use of a single delivery system which can output either the 1064nm or 532nm wavelengths. All these energies are delivered through an articulated arm and corresponding handpiece.
## 5. Indication for Use - 807.92(a)(5)
The PICOHI is indicated for the following at the specified wavelength:
- 532 nm: Removal of tattoos for Fitzpatrick skin types I-III to treat the following tattoo colors: red, yellow and orange.
- 1064 nm: Removal of tattoos for all skin types (Fitzpatrick I-VI) to treat the following tattoo colors: black, brown, green, blue and purple.
The PICOHI is also indicated for treatment of benign pigmented lesions for Fitzpatrick Skin Types I-IV.
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# 6. Summary of the Technological Characteristics of the Device Compared to the Predicate - 807.92(a)(6)
### (1) Predicate device
| | Proposed Device | Predicate Device |
|------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) Number | K201773 | K191685 |
| Manufacturer | Hironic Co., Ltd. | Candela Corporation |
| Device Name | PICOHI | PICOWAY |
| Classification<br>Name | Powered laser surgical instrument | Powered laser surgical instrument |
| Indication for use | The PICOHI is indicated for the following<br>at the specified wavelength:<br>• 532 nm: Removal of tattoos for<br>Fitzpatrick skin types I-III to treat the<br>following tattoo colors: red, yellow and<br>orange.<br>• 1064 nm: Removal of tattoos for all skin<br>types (Fitzpatrick I-VI) to treat the<br>following tattoo colors: black, brown,<br>green, blue and purple.<br>• Treatment of benign pigmented lesions<br>for Fitzpatrick skin types I-IV. | The PicoWay laser system is indicated<br>for the following at the specified<br>wavelength:<br>• 532 nm: Removal of tattoos for<br>Fitzpatrick skin types I-III to treat the<br>following tattoo colors: red, yellow and<br>orange.<br>• 730 nm: Removal of tattoos for<br>Fitzpatrick skin types II-IV to treat the<br>following tattoo colors: green and blue.<br>• 785 nm: Removal of tattoos for<br>Fitzpatrick skin types II-IV to treat the<br>following tattoo colors: green and blue.<br>• 1064 nm: Removal of tattoos for all skin<br>types (Fitzpatrick I-VI) to treat the<br>following tattoo colors: black, brown,<br>green, blue and purple.<br>• The Picoway laser system is also<br>indicated for benign pigmented lesions<br>removal for Fitzpatrick Skin Types I-IV.<br>• The Resolve handpiece (1064 nm) is<br>also indicated for the treatment of acne<br>scars in Fitzpatrick Skin Types II-V.<br>• The Resolve handpieces (532 nm HE,<br>532 nm, 1064 nm) are also indicated for<br>treatment of wrinkles in Fitzpatrick Skin<br>Types I-IV<br>• The Resolve Fusion handpiece (1064<br>nm) is indicated for the treatment of |
| | | wrinkles as well as benign pigmented |
| | | lesions in Fitzpatrick Skin Types I-IV |
| | | • The Resolve Fusion handpiece (532 |
| | | nm) is indicated for the treatment of |
| | | benign pigmented lesions in Fitzpatrick |
| | | Skin Types I-IV |
| Laser Source | Nd:YAG | Nd:YAG |
| Wavelength | 532/1064 nm | 532/1064 nm |
| Max. Fluence | 16.00 J/cm² | 12.5 J/cm² |
| Pulse Width | 275-300 ps | 375-450 ps |
| Max. Repetition | 10 Hz | 10 Hz |
| Spot Size | 1.5-13 mm | 2-10 mm |
| | • Zoom (532 nm): 1.5-7.5 mm | |
| | • Zoom (1064 nm): 10 mm | |
| | • Collimated (1064 nm): 10 mm | |
| | • VMLA (532/1064 nm): 13 mm | |
| | • ZMLA (532/1064 nm): 12 mm | |
| | • DOE (532/1064 nm): 10 mm | |
| Rated Input | 220-240 VAC, 50/60 Hz, 20 A | 200-240 VAC, 50/60 Hz, 30 A |
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# 7. Non-clinical tests submitted - 807.92(b)(1)
- Basic safety and essential performance of the PICOHI is evaluated in accordance with IEC 60601-1:2012.
- Effect to the device by electromagnetic disturbances is evaluated in accordance with the FDArecognized consensus standard, IEC 60601-1-2:2014.
- Safety of laser products are evaluated in accordance with IEC 60825-1:2014.
- General Requirements for Basic Safety and Essential Performance Collateral Standard: Usability is evaluated in accordance with the FDA-recognized consensus standard, IEC 60601-1-6:2013.
- Particular Requirements for Basic Safety and Essential Performance of Low Intensity Laser System are evaluated in accordance with IEC 60601-2-22:2012.
- Risk management is recorded in the reference of ISO 14971:2007.
- The software for PICOHI is verified and validated in accordance with its moderate level of concern. Software life cycle processes are evaluated according to the FDA-recognized consensus standard, IEC 62304:2006.
- Application of usability engineering to medical devices is evaluated in accordance with IEC 62366:2007.
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### 8. Clinical tests submitted - 807.92(b)(2)
No clinical performance testing was performed.
### 9. Conclusions drawn from clinical and non-clinical tests submitted
The PICOHI and the predicate devices have the same intended use with similar indications for use. The PICOHI Laser System presents the same or similar technological characteristics as its predicate devices, including the laser type, wavelengths, device design, pulse width, frequency, spot sizes and system components. PICOHI is substantially equivalent to its predicate devices with same indication for use and technological characteristics. The non-clinical data for proposed device, including biocompatibility, bench testing, hardware, and software documentation shows that the device should perform as intended in the specified use. In addition, the Electromagnetic Compatibility and Electrical Safety testing shows that the device is safe to use and meets required standards. These non-clinical tests show that the PICOHI can safely deliver laser energies to the patient as intended. The device meets design specifications as well as performance requirements. Any minor differences do not present any new types of safety or effectiveness questions since the PICOHI parameters are similar to or within the range of the predicates. Further, PICOHI performance has been demonstrated in non-clinical investigations, and results confirm the safety and performance of the device. The PICOHI device and its predicates all operate with the same mechanism of action based on selective photothermolysis of pigment particles using laser energy. Therefore, the PICOHI has the same intended use and similar indications for use, technological characteristics, and principles of operation as the predicate devices. The PICOHI is substantially equivalent to the predicate devices.
### 10. Summary of Substantial Equivalence
PICOHI is substantially equivalent to its predicate devices with same indication for use and technological characteristics. The non-clinical data for proposed device, including biocompatibility, bench testing, hardware, and software documentation shows that the device should perform as intended in the specified use. In addition, the Electromagnetic Compatibility and Electrical Safety testing shows that the device is safe to use and meets required standards. These non-clinical tests show that the PICOHI can safely deliver laser energies to the patient as intended. The device meets design specifications as well as performance requirements.
Any minor differences in the human interface and accessories design do not raise any new types of safety and effectiveness issues, as verified by performance testing.
In accordance with the Federal Food, Drug and Cosmetic Act, 21 CFR Part 807 and based on the information provided in this premarket notification that we conclude that substantially equivalent with predicate device.
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Best Regard,
September 10, 2021
S
Regulatory Affair Manager, R&D Dept.
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.