Microneedling 510(k)

Microneedling 510(k)

The first microneedling 510(k) has been filed following the formal issuance of the Microneedling Classification Order this summer (link to Classification Order here). The FDA Atty firm worked with Esthetic Education LLC to file a microneedling 510(k) for its SkinStylus SteriLock MicroSystem. The SkinStylus is now under a 90-day review.

The SkinStylus Sterilock system is unique as it’s the only device with a removable nose cone that can be reprocessed for added safety, and also features a 12 pin and 36 pin needle configuration.

This 510(k) solidifies previous comments made on this site concerning microneedling devices. In particular, that it is no longer enough simply to register and list as a Class I 510(k) exempt device (previous post with details here). The Final Classification Order is now codified in the Code of Federal Regulations (CFR) and can be used for filing a microneedling 510(k), what is called a predicate.

For those considering a microneedling 510(k), there are two points to consider. First, there is currently only one predicate, the SkinPen Precision by Bellus Medical (DEN 160029). This means any device submitted must demonstrate Substantial Equivalence based on a comparison to SkinPen. Soon that could include the SkinStylus. As with any 510(k), this means matching intended use and technology. There can be differences but those differences cannot raise new questions of safety or efficacy, which may mean submitting additional data. Second, the data requirements are significant. The SkinStylus 510(k) included nearly 500-pages of data reports. That’s at the top-end of a 510(k). Below is a table of tests the FDA has identified as required for a microneedling 510(k).

A 510(k) is not only required but also ensures patient safety. FDA has identified several risks to health associated specifically with this type of device. Whether a device is designed to mitigate those risks rests on a FDA review as part of the 510(k) process.

There are benefits to filing a 510(k)compared to filing a De Novo. In particular, the review time is only 90-120 days. By comparison, the De Novo review can exceed 250-days.

Congratulations to Esthetic Education LLC for taking the first-step and leading the industry by filing the first microneedling 510(k) for its SkinStylus SteriLock MicroSystem. It’s time for others to follow suit.

Table 1—Microneedling Device for Aesthetic Use Risks and Mitigation Measures

Identified risks Mitigation measures
Adverse tissue reaction Biocompatibility evaluation and Labeling.
Cross-contamination and infection Sterilization validation, Reprocessing validation, Non-clinical performance testing, Shelf life testing, and Labeling.
Electrical shock or electromagnetic interference with other devices Electromagnetic compatibility testing, Electrical safety testing, and Labeling.
Damage to underlying tissue including nerves and blood vessels, scarring, and hyper/hypopigmentation due to: • Exceeding safe penetration depth • Mechanical failure • Software malfunction Non-clinical performance testing, Technological characteristics, Shelf life testing, Labeling, and Software verification, validation, and hazard analysis.

**Disclaimer: Marc C. Sanchez, Esq. is a FDA attorney in private practice and the above is not intended as legal advice. FDA Atty law firm is hosting this blog solely for educational purposes. Mr. Sanchez also worked with Bellus Medical on its De Novo submission.**

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Marc is dedicated to helping his clients navigate the complex world of FDA and USDA legislation. He represents FDA-regulated companies in the food, dietary supplement, beverage, cosmetic, medical device, and drug industries.

Marc is the author of two textbooks and a lecturer at Northeastern University. He is a member of the Washington State Bar Association and the D.C. Bar Association.

7 Comments

  1. Jessica on June 12, 2019 at 8:04 am

    I am an licensed esthetician interested in purchasing the microneedling device.

    • Marc Sanchez on June 12, 2019 at 9:18 am

      Thank you, Jessica. You would need to reach out to a manufacturer or distributor. You’ve reached a law firm specializing in microneedling regulation.

  2. Bridget on November 28, 2018 at 6:29 am

    I am a little unclear about the microneedling laws in PA. I am a cosmetic and medical tattoo artist. Are we allowed to offer microneedling? This is something our industry started as “dry needling” from what I am reading every state is different and Pennsylvania does not speak on microneedling at all. I am not sure if this is a service we can offer. Can someone please explain?

    • Marc Sanchez on November 29, 2018 at 9:05 am

      Hello Bridget, I recommend you reach out to American Med Spa (https://www.americanmedspa.org) for more resources. My firm only handles the FDA regulation of these devices.

  3. Carolynne on September 27, 2018 at 1:20 pm

    Hello, I am interested in a medically FDA cleared microneedling device. Are there any promotions going on?

    I’m interested in the tip pricing too?

    Thanks so much

    • Marc Sanchez on September 27, 2018 at 1:46 pm

      Thank you for the comment. Unfortunately, we’re a law firm working on microneedling medical devices not a vendor of microneedling devices.

  4. Lili Garcia on September 18, 2018 at 6:48 pm

    Still would not allow, only a doctor/ plastic surgeon, with seeing Certification
    Never a day spa nor a shop shop
    Might a well allow surgeons that have malpractice and I’ve lost license they’re probably would be better
    I would never allow anyone with needles on my skin
    Once damage had been done to nerves, no repair
    Not anyone has the touch!

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