(105 days)
The electric wheelchair (Model: DH01108(2)) is a motor driven, and indoor transportation vehicle with the intended use to provide mobility to a disabled or an elderly person limited to a seated position.
The proposed device, Electric Wheelchair , mainly powered by rechargeable battery, motivated by motor, driven by user controlling joystick and adjusting speed. The electric wheelchair is composed of front frame, rear frame, backrest frame, armrest, front wheel, controller, battery pack, motor rear wheel, footplate, seat cushion, back cushion, handle.
The electric wheelchair is intended to provide mobility to a person with a disability or an older adult limited to a sitting position.This wheelchair is suitable for the user who with weight less than 100kg.
The device is folding design. This foldable electric wheelchair has front frame, backrest frame,armrest. The wheelchair can be easily folded, when folding the wheelchair, turn over the armrest successively.
Controller : The controller includes a power key/speed adjustment key , a direction joystick and speed light ,battery capacity light.
Joystick: It is used to control the electric wheelchair drive direction and speed. The joystick pushes away in the same direction as the wheelchair moves forward.
The wheelchair also provided with max speed limit setting so that user can select the max speed level by the round key.
Frame design: overall size: 905999cm, net weight: 22kg
The operation mode of the folding mechanism is to remove the locking device by someone else and manually push the backrest frame to complete the folding operation under non-riding state.
The motor of electric wheelchair is DC24V 200W*2; Inner power is DC24, 10Ah; The charger of Lithium ion battery Input:AC 100-240V;50-60Hz;1.2-0.5A; output : DC 24V,2,0A.
The provided text describes a 510(k) premarket notification for an Electric Wheelchair. It focuses on demonstrating substantial equivalence to a predicate device rather than presenting a study proving that the device meets specific acceptance criteria based on its performance in a clinical setting.
Therefore, many of the requested details about acceptance criteria derived from clinical studies, expert-established ground truth, sample sizes for test and training sets, adjudication methods, or MRMC studies are not applicable or available in this document.
However, the document does detail non-clinical testing performed against established international standards to demonstrate safety and performance. I will present the information related to the closest equivalent of "acceptance criteria" and "device performance" available in the document, which are the relevant sections from the comparison to the predicate device and the summary of non-clinical testing.
Here's the information derived from the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't explicitly list "acceptance criteria" against which a device is tested with a singular "reported device performance." Instead, it performs a comparison to a predicate device and states that non-clinical tests were conducted according to various international standards. The "Verdict" column in the tables below indicates whether the subject device meets the same characteristics or if differences are deemed not to raise new safety or effectiveness concerns.
| Element of Comparison / Test Standard | Acceptance Criteria (from Predicate or Standard) / Predicate Performance | Subject Device Performance | Verdict |
|---|---|---|---|
| General Characteristics | |||
| Manufacturer | JERRY MEDICAL INSTRUMENT (SHANGHAI) CO., LTD. | Foshan Dahao Medical Technology Co.,Ltd. | -- |
| Product Code | ITI | ITI | Same |
| Regulation No. | 21 CFR 890.3860 | 21 CFR 890.3860 | Same |
| Class | II | II | Same |
| Product name | Electric Wheelchair | Electric Wheelchair | Same |
| Intended Use | To provide mobility to a disabled or an elderly person limited to a seated position. | To provide mobility to a disabled or an elderly person limited to a seated position. | Same |
| Use environment | Indoor use | Indoor use | Same |
| Patient Population | Disabled or older adult limited to a sitting position | Disabled or older adult limited to a sitting position | Same |
| Product structure | Foldable armrests, backrest, seat cushion, foldable frame, two rear driving wheels with hub motor/electromagnetic brake assemblies, two pivoting casters, Li-ion batteries, off-board battery charger, control panel, electric motor controller. | Front frame, rear frame, backrest frame, two foldable armrests, two pivoting front wheel, controller, lithium-ion battery pack, two motor rear wheel, off-board battery charger, anti-roll wheel, footplate, seat cushion, back cushion, handle. | Same |
| Driving system | Direct drive on the rear wheels | Direct drive on the rear wheels | Same |
| Number of wheels | 4 | 4 | Same |
| Main frame material | Aluminium alloy | Aluminium alloy | Same |
| Max. loading | 220lbs (100kg) | 220lbs (100kg) | Same |
| Maximum safe operational incline | 10 degrees | 9° | Same (within acceptable range) |
| Speed control method | Joystick control method | Joystick control method | Same |
| Label and Labeling | Conforms to FDA Regulatory Requirements | Conforms to FDA Regulatory Requirements | Same |
| Level of Concern of the Software | Moderate | Moderate | Same |
| Performance Characteristics | |||
| Motor | DC24V* 180W*2pcs | DC 24V*200W * 2pcs | Minor differences in dimensions, will not impact safety. |
| Battery | DC 24V 20Ah Lithium-ion, 1 pcs | Lithium-ion 24V, 10AH, 1pcs | Minor differences in capacity, will not impact safety/effectiveness. |
| Battery charger Output | DC 24V, 6 Amp | DC 24V, 2.0Amp | Minor differences in output, will not impact safety/effectiveness. |
| Dimensions | 38.1"x24.0"x37.0" (JRWD6010), 39.3"x23.6"x37.0" (JRWD6012) | 90cm x59cm x99cm | Similar |
| Stowage dimensions (Lengthwidthheight) | 44cm x40cm x46cm (JRWD6010) / 44cm x46cm x46cm (JRWD6012) | 53cmx38cm x40cm | Minor difference, won't cause different performance as all performance tests are according to ISO 7176 series. |
| Weight, w/ Battery | 58.4 lbs./26.5kg (JRWD6010), 58.2 lbs./26.4kg (JRWD6012) | 48.5Ibs./22kg | Will not raise any new safety and effectiveness concerns. |
| Front wheel (inch) | 8 (PU solid tire) | 6 (PU solid tire) | Smaller sizes, will not raise new safety/effectiveness concerns. |
| Rear tire (inch) | 10 (PU solid tire) (JRWD6010), 12 (Pneumatic tire) (JRWD6012) | 8 (PU solid tire) | Will not raise any new safety/effectiveness concerns. |
| Cruising Range (km) | 20 (JRWD6012) | 10-25 | Actual range varies; will not affect safety/effectiveness. |
| Obstacle climbing (mm) | 50 | 25 | Lower obstacle climbing, but will not affect safety/effectiveness. |
| Max. Speed (km/h) | 6 | 5.4 | Smaller max speed, but will not affect product function and safety. |
| Static stability forward | 21.8° | ≥6° | Both evaluated per ISO 7176-1:2014, differences won't impact safety/effectiveness. |
| Static stability rearward | 19° | ≥6° | Both evaluated per ISO 7176-1:2014, differences won't impact safety/effectiveness. |
| Static stability sideways | 19.2° | ≥6° | Both evaluated per ISO 7176-1:2014, differences won't impact safety/effectiveness. |
| Min. Turning radium | 1820mm (JRWD6012) | 900mm | Difference brings more convenience; will not raise new safety/effectiveness concerns. |
| Minimum braking distance | 1m (JRWD6012) | ≤1.6m (3°) (max safety slope braking) | Similar |
| Max Speed Forwards | 3.75 mph (6 km/h) | 5.4km/h | Both evaluated per ISO 7176-6:2018, differences won't impact safety/effectiveness. |
| Max. Speed Backward | 2.80 mph (4.5 km/h) | 5.4km/h | Both evaluated per ISO 7176-6:2018, differences won't impact safety/effectiveness. |
| Controller | PG Drives Technology Ltd., newVSI | GigaDevice Semiconductor Inc. | Different, but both control systems are similar in function and evaluated per ISO 7176-14:2008 and software validation; no new safety/effectiveness concerns. |
| Main materials (e.g., Frame) | Aluminium alloy | Aluminium alloy | Same |
| Materials contacting user | Armrest: PU; Backrest: oxford cloth; Seat: oxford cloth; Joystick knob: Santoprene 101-80; Joystick Gaiter: Silicone 3032 (50%) & 5031 (50%); Enclosure Moulding(s): ABS/PC Wonderloy PC-540; Keypad: Silicone keypad coatings TC-2407 & CH-6330 | Armrest: PU; Backrest: PU; Seat: PU; Joystick controller: TPU(80%), Fire retardant(15%), Fertilize( 5%). | Different materials for some components, but biocompatibility evaluation (ISO 10993-1) was performed for the subject device; no new safety/effectiveness concerns. |
| Biocompatibility of materials contacting user | Comply with ISO 10993-1, FDA Cytotoxicity (ISO 10993-5:2009), Sensitization and Intracutaneous Reactivity (ISO 10993-10:2010) | Comply with ISO 10993-1, FDA Cytotoxicity (ISO 10993-5:2009), Sensitization and Irritation Reactivity (ISO 10993-10:2010) | Difference in irritation test (subject device only skin irritation); test qualified material in contact with patient; no new safety/effectiveness concerns. |
| Compliance with Standards | |||
| Electrically powered wheelchairs, scooters and their chargers. Requirements and test methods | EN 12184:2014 | EN 12184:2014, ISO 7176 series, IEC standards, ISO 10993 series | Complied |
| Static stability | ISO 7176-1: 2014 | ISO 7176-1: 2014 | Complied |
| Dynamic stability of electrically powered wheelchairs | ISO 7176-2: 2017 | ISO 7176-2: 2017 | Complied |
| Effectiveness of brakes | ISO 7176-3: 2012 | ISO 7176-3: 2012 | Complied |
| Energy consumption/theoretical distance range | ISO 7176-4: 2008 | ISO 7176-4: 2008 | Complied |
| Overall dimensions, mass and manoeuving space | ISO 7176-5: 2008 | ISO 7176-5: 2018 | Complied |
| Maximum speed, acceleration and deceleration | ISO 7176-6: 2018 | ISO 7176-6: 2018 | Complied |
| Measurement of seating and wheel dimensions | ISO 7176-7: 1998 | ISO 7176-7: 1998 | Complied |
| Static, impact and fatigue strengths | ISO 7176-8: 2014 | ISO 7176-8: 2014 | Complied |
| Climatic tests | ISO 7176-9: 2009 | ISO 7176-9: 2009 | Complied |
| Obstacle-climbing ability | ISO 7176-10: 2008 | ISO 7176-10: 2008 | Complied |
| Test dummies | ISO 7176-11: 2012 | ISO 7176-11: 2012 | Complied |
| Coefficient of friction of test surfaces | ISO 7176-13: 1989 | ISO 7176-13: 1989 | Complied |
| Power and control systems | ISO 7176-14: 2008 | ISO 7176-14: 2008 | Complied |
| Information disclosure, documentation and labeling | ISO 7176-15: 1996 | ISO 7176-15: 1996 | Complied |
| Resistance to ignition of postural support devices | ISO 7176-16: 2012 | ISO 7176-16: 2012 | Complied |
| Set-up procedures | ISO 7176-22:2014 | ISO 7176-22:2014 | Complied |
| Batteries and chargers for powered wheelchairs | ISO 7176-25: 2013 | ISO 7176-25: 2013 | Complied |
| Secondary cells and batteries (Safety requirements) | IEC 62133-2: 2017 | IEC 62133-2: 2017 | Complied |
| Electromagnetic compatibility (EMC) | ISO 7176-21: 2009 | ISO 7176-21: 2009 | Complied |
| Medical electrical equipment Part 1-2 (EMC) | IEC 60601-1-2:2015 | IEC 60601-1-2:2015 | Complied |
| Biological evaluation of medical devices (Risk management) | ISO 10993-1: 2018 | ISO 10993-1: 2018 | Complied |
| Cytotoxicity | ISO 10993-5:2009 | ISO 10993-5:2009 | Complied |
| Irritation and skin sensitization | ISO 10993-10:2010 | ISO 10993-10:2010 | Complied |
2. Sample size used for the test set and the data provenance
The document describes non-clinical bench testing conducted according to ISO and IEC standards. These standards typically specify the number of units or samples required for each test. However, the exact sample sizes for each specific test (e.g., how many wheelchairs were subjected to fatigue strength testing) are not explicitly stated in this summary. The data provenance is "lab bench testing" (Paragraph 6, Page 5) in China (Company Address, Page 3). This is typically prospective testing of manufactured devices.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This information is not applicable as the document describes non-clinical engineering and laboratory tests against recognized standards, not human-expert-driven ground truth for a clinical dataset.
4. Adjudication method for the test set
This information is not applicable as the document describes non-clinical engineering and laboratory tests based on objective measurements against standard requirements, not subjective assessment requiring adjudication.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
This information is not applicable. This is a submission for an Electric Wheelchair, not an AI software. The document explicitly states "No animal study and clinical studies are available for our device. Clinical testing was not required to demonstrate the substantial equivalence of the Electric Wheelchair to its predicate device" (Paragraph 9, Page 11).
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This information is not applicable. This is an Electric Wheelchair, not an algorithm.
7. The type of ground truth used
The "ground truth" in this context is the requirements specified by various international consensus standards (EN 12184, ISO 7176 series, IEC 60601-1-2, IEC 62133-2, ISO 10993 series). The device's components and performance characteristics were tested against these pre-defined, objective criteria.
8. The sample size for the training set
This information is not applicable. This is a physical device, not an AI model requiring a training set.
9. How the ground truth for the training set was established
This information is not applicable. (See point 8).
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Image /page/0/Picture/0 description: The image shows 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. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
July 5, 2022
Foshan Dahao Medical Technology Co.,Ltd % Iris Fung Regulation Manager Guangdong Jianda Medical Technology Co., Ltd 906 Room, Longxiang Garden, Tianhe District Guangzhou, Guangdong 510000 China
Re: K220827
Trade/Device Name: Electric Wheelchair Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: March 18, 2022 Received: March 22, 2022
Dear Iris Fung:
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,
for Heather Dean, PhD Assistant Director, Acute Injury Devices Team DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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Indications for Use
510(k) Number (if known) K220827
Device Name Electric Wheelchair
Indications for Use (Describe)
The electric wheelchair (Model: DH01108(2)) is a motor driven, and indoor transportation vehicle with the intended use to provide mobility to a disabled or an elderly person limited to a seated position.
Type of Use (Select one or both, as applicable)Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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510(k) Summary
This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirements of SMDA and 21 CFR 890.3860.
1. Submitter Information
Sponsor Company Name: Foshan Dahao Medical Technology Co.,Ltd. Address: Building 1, 2nd floor of building 2, 3rd floor of building 3、4、5、6、7, No.9 of Fanye Road,Leping town,Sanshui District,Foshan City,Guangdong Province,528137,China Phone: +86-13760674304 Contact Person (including title): BaoYi Xie (Regulation Manager) E-mail: 709111267@qq.com
Application Correspondent: Guangdong Jianda Medical Technology Co Ltd. Address:906 Room, Longxiang Garden, Tianhe district, Guangzhou, China Contact Person:Ms. Iris Fung Tile: Regulation Manager Tel:+86- 13211147965 Email:mdc-fs@foxmail.com; jianda-lee@foxmail.com
2. Subject Device Information
Type of 510(k) submission: Traditional Common Name: Powered Wheelchair Trade Name: Electric Wheelchair Classification Name: Powered Wheelchair Review Panel: Physical Medicine Product Code: ITI Requlation Number: 21 CFR 890.3860 Regulation Class: Class II
3. Predicate Device Information
Sponsor: JERRY MEDICAL INSTRUMENT (SHANGHAI) CO., LTD. Common Name: Powered Wheelchair Trade Name: Electric Wheelchair 510(k) number: K192739
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Review Panel: Physical Medicine Product Code: ITI Regulation Number: 21 CFR 890.3860 Regulation Class: Class II
4. Device Description
The proposed device, Electric Wheelchair , mainly powered by rechargeable battery, motivated by motor, driven by user controlling joystick and adjusting speed. The electric wheelchair is composed of front frame, rear frame, backrest frame, armrest, front wheel, controller, battery pack, motor rear wheel, footplate, seat cushion, back cushion, handle.
The electric wheelchair is intended to provide mobility to a person with a disability or an older adult limited to a sitting position.This wheelchair is suitable for the user who with weight less than 100kg.
The device is folding design. This foldable electric wheelchair has front frame, backrest frame,armrest. The wheelchair can be easily folded, when folding the wheelchair, turn over the armrest successively.
Controller : The controller includes a power key/speed adjustment key , a direction joystick and speed light ,battery capacity light.
Joystick: It is used to control the electric wheelchair drive direction and speed. The joystick pushes away in the same direction as the wheelchair moves forward.
The wheelchair also provided with max speed limit setting so that user can select the max speed level by the round key.
Frame design: overall size: 905999cm, net weight: 22kg
The operation mode of the folding mechanism is to remove the locking device by someone else and manually push the backrest frame to complete the folding operation under non-riding state.
The motor of electric wheelchair is DC24V 200W*2; Inner power is DC24, 10Ah; The charger of Lithium ion battery Input:AC 100-240V;50-60Hz;1.2-0.5A; output : DC 24V,2,0A.
5. Intended Use
The Electric Wheelchair (Model: DH01108 (2)) is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to a disabled or an elderly person limited to a seated position.
6. Test Summary of Non-clinical Testing
The Electrical Wheelchair has been evaluated the safety and performance by lab bench testing according to the following standards:
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- . EN 12184:2014 Electrically powered wheelchairs, scooters and their chargers. Requirements and test methods
- . ISO 7176-1: 2014 Wheelchairs - Part 1: Determination of static stability
- . ISO 7176-2: 2017 Wheelchairs - Part 2:Determination of dynamic stability of electrically powered wheelchairs
- . ISO 7176-3: 2012 Wheelchairs - Part 3: Determination of effectiveness of brakes
- ISO 7176-4: 2008 Wheelchairs Part 4: Energy consumption of electric wheelchairs and scooters for . determination of theoretical distance range
- . ISO 7176-5: 2008 Wheelchairs - Part 5: Determination of overall dimensions, mass and manoeuving space
- . ISO 7176-6: 2018 Wheelchairs - Part 6: Determination of maximum speed, acceleration and deceleration of electric wheelchairs
- . ISO 7176-7: 1998 Wheelchairs - Part 7: Measurement of seating and wheel dimensions
- . ISO 7176-8: 2014 Wheelchairs - Part 8: Requirements and test methods for static, impact and fatigue strengths
- ISO 7176-9: 2009 Wheelchairs - Part 9: Climatic tests for electric wheelchairs
- . ISO 7176-10: 2008 Wheelchairs - Part 10: Determination of obstacle-climbing ability of electrically powered wheelchairs
- . ISO 7176-11 : 2012 Wheelchairs - Part 11: Test dummies
- ISO 7176-13 : 1989 Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces
- . ISO 7176-14: 2008 Wheelchairs - Part 14: Power and control systems for electrically powered wheelchairs and scooters - Requirements and test methods
- ISO 7176-15: 1996 Wheelchairs - Part 15: Requirements for information disclosure,documentation and labeling
- . ISO 7176-16: 2012 Wheelchairs - Part 16: Resistance to ignition of postural support devices
- . ISO 7176-22:2014 Wheelchairs - Part 22: Set-up procedures
- . ISO 7176-25: 2013Wheelchairs - Part 25: Batteries and chargers for powered wheelchairs
- . IEC 62133-2: 2017 Secondary cells and batteries containing alkaline or other non-acid electrolytes -Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications-part 2: Lithium systems
EMC
- . ISO 7176-21: 2009 Wheelchairs - Part 21: Requirements and test methods for electromagnetic compatibility of electrically powered wheelchairs and scooters, and battery chargers
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- IEC 60601-1-2:2015 Medical electrical equipment Part 1-2: General requirements for safety Collateral . standard: Electromagnetic compatibility - Requirements and tests
Biocompatibility
The parts in contact with the user include: Joystick controller, is made of 80% Thermoplastic poly urethane elastomer rubber(TPU), 15%Fire retardant and 5% Fertilizer. Armrest and seat cushion are made of 100% polyurethane (PU) . All contact materials have passed biological tests and are harmless to humans. Patient-contacting material are carried out biocompatibility assessment in accordance with ISO 10993-1: 2018, including :
- . ISO 10993-1:2018 Biological evaluation of medical devices — Part 1: Evaluation and testing within a risk management process
- . ISO 10993-5:2009 Biological evaluation of medical devices - Part 5: Tests for in vitro cytotoxicity
- . ISO 10993-10:2010 Biological evaluation of medical devices — Part 10: Tests for irritation and skin sensitization
All contact materials have passed biological tests and are harmless to humans.
7. Comparison to Predicate Device
Compare with predicate device, the subject device is very similar in design principle, intended use,
functions, material and the applicable standards. The differences between subject device and predicate device do not raise and new questions of safety or effectiveness.
| Elements ofComparison | Subject Device | Predicate Device | Verdict |
|---|---|---|---|
| Manufacturer | Foshan Dahao Medical TechnologyCo.,Ltd. | JERRY MEDICAL INSTRUMENT(SHANGHAI) CO., LTD. | -- |
| Product Code | ITI | ITI | Same |
| Regulation No. | 21 CFR 890.3860 | 21 CFR 890.3860 | Same |
| Class | II | II | Same |
| Product name | Electric Wheelchair | Electric Wheelchair | Same |
| 510 (k)Number | K220827 | K192739 | -- |
| Models | DH01108 (2) | JRWD6010, JRWD6012 | -- |
| Intended Use | The Electric Wheelchair is a motor-driven, and indoor transportationvehicle with the intended use toprovide mobility to a disabled or anelderly person limited to a seated | The device is a motor-driven, andindoor transportation vehicle with theintended use to provide mobility to adisabled or an elderly person limitedto a seated position. | Same |
Table1 General Comparison
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| Elements of Comparison | Subject Device | Predicate Device | Verdict |
|---|---|---|---|
| position. | |||
| Useenvironment | Indoor use | Indoor use | Same |
| PatientPopulation | The electric wheelchair is intended toprovide mobility to a person with adisability or an older adult limited toa sitting position | The electric wheelchair is intended toprovide mobility to a person with adisability or an older adult limited toa sitting position | Same |
| Productstructure | composed of front frame, rear frame,backrestframe, two foldablearmrests, two pivoting front wheel,controller, lithium-ion battery pack,two motor rear wheel,an off-boardbattery charger, anti-roll wheel,footplate, seat cushion, back cushion,handle ,a controller | Consists of two foldable armrests, abackrest, a seat cushion, a foldableframe, two rear driving wheels withhub motor/electromagnetic brakeassemblies, two pivoting casters, a Li-ion batteries, an off-board batterycharger, a control panel, and anelectric motor controller. | Same |
| Driving system | Direct drive on the rear wheels | Direct drive on the rear wheels | Same |
| Number ofwheels | 4 | 4 | Same |
| Main framematerial | Aluminium alloy | Aluminium alloy | Same |
| Motor | DC 24V*200W * 2pcs | DC24V* 180W*2pcs | Minor differencesin the dimensions |
| Battery | Lithium-ion 24V, 10AH,1pcs | DC 24V 20Ah Lithium-ion,1 pcs | will notimpact the safety |
| Battery charger | Input: 100-240VACoutput : DC 24V ,2.0Amp | High Power Technology Inc.HP0180WL2Input: 100-240 VACOutput: DC 24V, 6 Amp | andeffectivenessofthesubstantialequivalence. |
Table2 Performance Comparison
| Elements ofComparison | Subject Device | Predicate Device | Verdict | |
|---|---|---|---|---|
| JRWD6010 | JRWD6012 | |||
| Manufacturer | Foshan Dahao MedicalTechnology Co.,Ltd. | JERRY MEDICAL INSTRUMENT(SHANGHAI) CO., LTD. | -- | |
| Dimensions | 90cm x59cm x99cm | 38.1"x24.0"x37.0" | 39.3"x23.6"x37.0" | Similar |
| Stowagedimensions(Length*width*height) | 53cmx38cm x40cm | 44cm x40cmx46cm | 44cm x46cmx46cm | Minor difference onStowage dimensionswill notcause differentperformance as allperformance tests areperformed according to |
| Elements ofComparison | Subject Device | Predicate Device | Verdict | |
| JRWD6010 | JRWD6012 | |||
| Weight,w/Battery | 48.5Ibs./22kg | 58.4 lbs./26.5kg | 58.2 lbs./26.4kg | standard ISO7176 seriesThe difference willnot raise any new safetyand effectivenessconcerns and will notaffect the safety andeffectiveness of thesubject device. |
| Frame design | Foldable /The device consists of a foldableand non-rigid type of powerwheelchair base with rear driveand 2 casters in the front and 2anti-tippers in the rear. | Foldable /The device consists of a foldable andnon-rigid type of power wheelchairbase with rear drive and 2 casters in thefront and two anti-tippers in the rear. | Same | |
| Foldingmechanism | A foldable seat frames(The backrest could be folded toseat) | A foldable seat frames(The backrest could be folded to seat) | Same | |
| Front wheel(inch ) | 6(PU solid tire) | 8(PU solid tire) | Smaller sizes ofwheels, The differencewill not raise any newsafety and effectivenessconcerns. | |
| Rear tire(inch) | 8(PU solid tire) | 10(PU solid tire) | 12(Pneumatic tire) | will not raise any newsafety and effectivenessconcerns. |
| CruisingRange(km) | 10-25 | 20 | Actual CruisingRange varies dependingon the rider's weight,environment and batteryusage, this will notaffect the safety andeffectiveness of thesubject device. | |
| Obstacleclimbing(mm) | 25 | 50 | Subject Device has alower obstacle climbing,but this will not affectthe safety andeffectiveness of thesubject device. | |
| Max. Speed(km/h) | 5.4 | 6 | Subject Device has asmaller Max. speed, butthis will not affect theuse of the productfunction and safety. | |
| Static stabilityforward | ≥6° | 21.8° | Both of the devices areevaluated according tostandard ISO 7176-1:2014, so the differentstatic stability will notimpact the safety andeffectiveness. | |
| Static stabilityrearward | ≥6° | 19° | standard ISO 7176-1:2014, so the differentstatic stability will notimpact the safety andeffectiveness. | |
| Static stabilitysideways | ≥6° | 19.2° | static stability will notimpact the safety andeffectiveness. | |
| Max. loading(kg) | 220lbs(100kg) | 220lbs (100kg) | Same | |
| Maximum | 9° | 10 degrees | Same | |
| Elements ofComparison | Subject Device | Predicate DeviceJRWD6010 | Predicate DeviceJRWD6012 | Verdict |
| safeoperationalincline | ||||
| Min. Turningradium | 900mm | 1820mm | The difference in thetuming radius will bringmore convenience whenit turns.The differencewill not raise any newsafety and effectivenessconcerns. | |
| Minimumbrakingdistance | max safety slope braking: ≤1.6m(3°) | 1m | Similar | |
| Max SpeedForwards | 5.4km/h | 3.75 mph (6 km/h) | Both of the devices areevaluated according to | |
| Max. SpeedBackward | 5.4km/h | 2.80 mph (4.5 km/h) | standardISO 7176-6:2018, so the differentwill not impact thesafety and effectiveness | |
| Controller | GigaDevice Semiconductor Inc. | PG Drives Technology Ltd., newVSI | Different Althoughdifferent controller isused, both the controlsystem, including thejoystick controller, theelectromagnetic brakesare similar. The joystickcontrols the directionsand speed of movement,and when the joystick isreleased, the poweredwheelchair will slowdown to stop and thebrakes willautomatically re-engage.The controller alsoprovides the batterystatus displaying andabnormal conditiondisplaying. Both of thecontrol systems areevaluated according tostandard ISO 7176-14:2008 and softwarevalidation requirementand there are no newsafety and effectivenessconcerns due to thedifference. | |
| Speed controlmethod | Joystick control method | Joystick control method | Same | |
| Elements ofComparison | Subject Device | Predicate Device | Verdict | |
| Manufacturer | Foshan Dahao MedicalTechnology Co.,Ltd. | JERRY MEDICAL INSTRUMENT(SHANGHAI) CO., LTD. | -- | |
| Main materials | Frame: Aluminiumalloy;Wheel, Armrest: PU;Backrest: PU | Frame: Aluminiumalloy;Wheel, Armrest: PU;Backrest: oxford cloth | The material for the | |
| Materialscontacting user | Armrest: PU;Backrest:PUSeat: PUJoystick controller: TPU(80%),Fire retardant(15%),Fertilize( 5% ). | Armrest: PU;Backrest: oxford clothSeat: oxford clothnewVSi electric wheelchaircontroller:Joystick knob: Santoprene 101-80;Joystick Gaiter: Silicone 3032(50%) & 5031 (50%)Enclosure Moulding(s): ABS/PCWonderloy PC-540Keypad: Silicone keypad coatingsTC-2407 & CH-6330 | main frame is the same.Biocompatibilityevaluationhasbeencarried out perISO10993-1.There are no new safetyandeffectivenessconcernsdue tothedifference. | |
| Biocompatibilityof materialscontacting user | Comply with ISO 10993-1, FDACytotoxicity (ISO 10993-5:2009),Sensitization and IrritationReactivity (ISO 10993-10:2010) | Comply with ISO 10993-1, FDACytotoxicity (ISO 10993-5:2009),Sensitization and IntracutaneousReactivity (ISO 10993-10:2010) | DifferenceintheIrritation test,the subjectdevice only made skincontact with the patient,so the skin irritation testwascarriedoutaccording to ISO10993-1, and the material incontact with the patientwasqualifiedbytest.There are no newsafety and effectivenessconcerns due tothedifference. | |
| Label andLabeling | Conforms to FDA RegulatoryRequirements | Conforms to FDA RegulatoryRequirements | Same | |
| Level ofConcern of theSoftware | Moderate | Moderate | Same |
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Table3 Safety Comparison
8. Summary of substantial equivalence discussion
The DH01108 (2) Electric Wheelchair complied with the requirements of ISO 7176-1:2014, ISO 7176-2:2017, ISO 7176-3:2012, ISO 7176-4:2008, ISO 7176-5:2018, ISO 7176-6:2018, ISO 7176-7:1998, ISO 7176-8:2014, ISO 7176-9:2009, ISO 7176-10:2008, ISO 7176-11:2012, ISO 7176-13:1989, ISO 7176-14:2008, ISO 7176-15:1996, ISO 7176-16:2012, ISO 7176-19:2008, ISO 7176-21:2009, ISO 7176-22:2014,ISO 7176-25: 2013, IEC 60601-1-2:2014, IEC 62133-2:2017,ISO 10993-1:2018, ISO10993-5:2009, ISO 10993-10:2010.
The intended uses for both devices are the same. Mainframes of two devices are folded by way of front and rear close, and frame materials all meet the Tensile Strength, Yield Load, and Elongation tests. The
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design principles of the controller and Driving system are the same, and both meet the requirements of the ISO 7176-14:2008. Software validation is carried out on both control systems. Brake system and speed control are designed in the same way as well, and both meet the requirements of the ISO 7176-3:2012. Maximum obstacle climbing, Max Speed and Static stability different while such differences will not impact the safety and effectiveness of the subject device or raise new safety and effectiveness concerns as well as both meet the requirements of the ISO 7176-6: 2018, ISO 7176-10:2008. The biocompatibility of the Predicate device and Subject device meet the requirements of the ISO 10993-5:2009 & ISO 10993-10:2010.
The flame retardant test of the seat cushion and armrest of subject device is carried out according to the ISO 7176-16 test. Therefore, the subject device meets the flame retardancy of FDA requirements.
In conclusion, the technological characteristics, features, specifications, mode of operation, and intended use of the device substantially equivalent to the predicate devices quoted above. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness. .
9. Summary of Clinical Test
No animal study and clinical studies are available for our device. Clinical testing was not required to demonstrate the substantial equivalence of the Electric Wheelchair to its predicate device.
10. Conclusion
The differences between DH01108 (2) Electric Wheelchair and its predicate devices do not introduce a new intended use and do not raise new issues of safety and effectiveness. Verification and Validation testing demonstrated that no adverse effects have been introduced by these differences and that the device performs as intended. From the results of nonclinical testing described, it can be concluded that DH01108 (2) Electric Wheelchair is substantially equivalent to the legally marketed predicate device.
11. Summary Prepared Date
17 June 2022
§ 890.3860 Powered wheelchair.
(a)
Identification. A powered wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position.(b)
Classification. Class II (performance standards).