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
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.
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.
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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
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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
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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) |
|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| <span style="font-size:10px;"> <span style="font-family:Arial;"></span> </span> <span style="font-size:10px;"> <span style="font-family:Arial;"> <span style="font-size:10px;"> <span style="font-family:Arial;">☑ Prescription Use (Part 21 CFR 801 Subpart D)</span> </span> </span> </span> |
| <span style="font-size:10px;"> <span style="font-family:Arial;"></span> </span> <span style="font-size:10px;"> <span style="font-family:Arial;"> <span style="font-size:10px;"> <span style="font-family:Arial;">☐ Over-The-Counter Use (21 CFR 801 Subpart C)</span> </span> </span> </span> |
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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<br>5115 Ulmerton Road Clearwater, Florida<br>33760-4004<br>United States of America |
|----------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Establishment Registration #: | 3007593903 |
| Contact Person: | Mark D. Evans, Sr. Premarket Regulatory Affairs<br>Specialist<br>5115 Ulmerton Road<br>Clearwater, Florida 33760-4004<br>United States of America<br>Phone: (856) 524-5037<br>Email: mark.evans@apyxmedical.com |
| Date Prepared: | March 2, 2023 |
| Trade Names (Model Numbers): | Renuvion® Micro Handpiece<br>(APYX-10-Micro) |
| Common Name: | Electrosurgical Handpiece |
| Classification: | Class II per 21CFR 878.4400 - Electrosurgical<br>Cutting and Coagulation Device and Accessories<br>Product Code GEI |
| Primary Predicate Device:<br>Secondary Predicate Device: | Renuvion® APR Handpiece (K223262)<br>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:
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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
<sup>1 510(</sup>K) Number: K221830
<sup>2 510(</sup>K) Number: K221830
<sup>3 510(</sup>k) Number: K092761
<sup>4 510(</sup>K) Number: K170188
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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:
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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<br>Verification<br>&<br>Functionality | Verify Mechanical functionality of<br>the Renuvion® Micro Handpiece | Mechanical functionality<br>requirements met |
| System<br>compatibility<br>Testing | Verify the device, when connected<br>to the generators (with all the<br>components and accessories<br>working together as a system), are<br>working as intended and are<br>compatible with all system<br>components. | System compatibility requirements<br>met |
| Inspectional<br>Verification | Document parameters that can be<br>verified through inspection of the<br>Micro Handpiece Labeling and IFU. | Inspectional requirements met |
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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<br>Validation | Evaluate simulated (and/or real-<br>time) aging and associated<br>package integrity and shelf-life<br>claims. Assess the potential for<br>damage to the device (e.g., drop<br>tests of the instrument in its<br>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 |
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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<br>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<br>Tissue<br>Effect | Evaluate the thermal effect between<br>Renuvion Micro Handpiece (APYX-10-<br>MICRO) against its predicate device<br>(Renuvion APR Handpiece, 15 cm, Twin<br>Port, APYX-15-TP). | The test device (APYX-10-MICRO) was<br>subjected to tissue thermal testing and<br>demonstrated an equal or less tissue<br>thermal effect when compared to the<br>predicate device (APYX-15-TP) on five<br>different tissue types at different Renuvion<br>settings. |
| Tissue<br>Temperature<br>Over 85<br>Degrees<br>Celsius<br>Comparison | Evaluate the tissue time over 85 degrees<br>Celsius between the Renuvion Micro<br>Handpiece (APYX-10-MICRO) and its<br>predicate device (Renuvion APR<br>Handpiece, 15 cm, Twin Port, APYX-15-<br>TP) when used at the recommended<br>setting per the IFU for<br>coagulation/contraction of soft tissue such<br>as subcutaneous tissues. | The test device (APYX-10-MICRO) met<br>the acceptance criteria demonstrating that<br>on average the device is at or above 85<br>degrees for greater than 45 msec. The<br>predicate device showed similar results<br>as a control. |
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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<br>Device | Secondary Predicate<br>Device |
|----------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Feature/<br>Characteristic | Renuvion® Micro<br>Handpiece | Renuvion® APR<br>Handpiece (K223262) | Renuvion® APR<br>Handpiece (K230272) |
| Classification | Class II | Class II | Class II |
| Regulation Name<br>and Product Code: | Electrosurgical cutting &<br>coagulation device and<br>accessories, GEI | Electrosurgical cutting &<br>coagulation device and<br>accessories, GEI | Electrosurgical cutting &<br>coagulation device and<br>accessories, GEI |
| Indications for Use<br>Statement | Renuvion® Micro<br>Handpiece is intended<br>for the delivery of<br>radiofrequency energy<br>and/or helium plasma<br>coagulation/contraction<br>of soft tissue is needed.<br>Soft tissue includes<br>subcutaneous tissue.<br>The Renuvion® Micro<br>Handpiece is compatible<br>with the Apyx One<br>Console Generator,<br>owned by Apyx Medical. | Renuvion® APR<br>Handpiece is intended<br>for the delivery of<br>radiofrequency energy<br>and/or helium plasma<br>coagulation/contraction<br>of soft tissue is needed.<br>Soft tissue includes<br>subcutaneous tissue.<br>The Renuvion® APR<br>Handpiece is indicated<br>for use in subcutaneous<br>dermatological and<br>aesthetic procedures to<br>improve the appearance<br>of lax (loose) skin in the<br>neck and submental<br>region.<br>The Renuvion® APR<br>Handpiece is intended to | Renuvion® APR<br>Handpiece is intended<br>for the delivery of<br>radiofrequency energy<br>and/or helium plasma<br>where<br>coagulation/contraction<br>of soft tissue is needed.<br>Soft tissue includes<br>subcutaneous tissue.<br>The Renuvion® APR<br>Handpiece is intended<br>for the coagulation of<br>subcutaneous soft<br>tissues following<br>liposuction for aesthetic<br>body contouring.<br>The Renuvion® APR<br>Handpiece is indicated<br>for use in<br>subcutaneous |
| Feature/<br>Characteristic | Subject Device | Primary Predicate<br>Device | Secondary Predicate<br>Device |
| | Renuvion® Micro<br>Handpiece | Renuvion® APR<br>Handpiece (K223262) | Renuvion® APR<br>Handpiece (K230272) |
| | | be used with compatible<br>electrosurgical<br>generators owned by<br>Apyx Medical. | dermatological and<br>aesthetic procedures to<br>improve the(loose) skin in the neck<br>and submental region.<br><br>The Renuvion®<br>APR Handpiece is<br>intended for the<br>delivery of<br>radiofrequency<br>energy and/or<br>helium plasma for<br>cutting, coagulation<br>and ablation of soft<br>tissue during open<br>surgical procedures.<br><br>The Renuvion® APR<br>Handpiece is intended to<br>be used with compatible<br>electrosurgical<br>generators owned by<br>Apyx Medical. |
| Energy Source | RF Generator, Apyx One<br>Console Generator | RF Generator,<br>Generators owned by<br>Apyx Medical | RF Generator,<br>Generators owned by<br>Apyx Medical |
| Energy Type | Radio frequency (RF)<br>Energy and Helium Gas | Radio frequency (RF)<br>Energy and Helium Gas | Radio frequency (RF)<br>Energy and Helium Gas |
| System Components | The Renuvion® Micro<br>System consists of:<br>RF GeneratorDisposable HPFoot pedalPower cordGas regulator | The Apyx Plasma/RF<br>System consists of:<br>RF GeneratorDisposable HPFoot pedalPower cordGas regulator | The Apyx Plasma/RF<br>System consists of:<br>RF GeneratorDisposable HPFoot pedalPower cordGas regulator |
| Feature/<br>Characteristic | Subject Device<br><br>Renuvion® Micro<br>Handpiece | Primary Predicate<br>Device<br><br>Renuvion® APR<br>Handpiece (K223262) | Secondary Predicate<br>Device<br><br>Renuvion® APR<br>Handpiece (K230272) |
| Design & Energy<br>Delivery<br>Configuration | • Gas cylinder<br>10cm shaft with front-<br>port configuration and<br>indicator lines on the<br>shaft | • Gas cylinder<br>15cm and 27cm long<br>shaft with a side port<br>configuration (single or<br>twin) and indicator lines<br>on the shaft | • Gas cylinder<br>15cm and 27cm long<br>shaft with a side port<br>configuration (single or<br>twin) and indicator lines<br>on the shaft |
| Shaft and Tip Outer<br>Diameter (OD) | Tip and Distal end of<br>shaft OD: 2mm<br>Shaft beyond distal end<br>OD: 1.5mm | 3mm | 3mm |
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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.
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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.
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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.