(93 days)
The Merits E600 Series Stair Lift System is a powered patient transport, also commonly known as a Stairway Chairlift, or Stairlift. It is a motorized device intended for medical purposes to assist transfers of patients, or mobility-impaired persons, up and down flights of stairs.
The Merits E600 Series Stair Lift basically consists of an upholstered chair assembly, a truck assembly, and a maximum 16 feet track. The chair and truck assemblies constitute the platform moving up and down along the inclined track. The entire lift is installed in either side of the indoor stairway in a private residence. All models share the same specifications such as driving means and safeties other than the power source. The Model E600 uses the AC power as its power source while the Model E601 employs the batteries and chargers. The operation of the lift is controlled by a momentary rocker control under one armrest and two infrared remote controls. The move of the lift will stop immediately when the button or switch of the controls is released.
The provided text describes a 510(k) premarket notification for the Merits E600 Series Stair Lift, which is a medical device. This document is a regulatory submission demonstrating substantial equivalence to a predicate device, rather than a study designed to establish new performance criteria or clinical efficacy with detailed statistical analysis as might be expected for an AI/ML medical device.
Therefore, many of the requested elements pertaining to acceptance criteria and performance studies (like sample sizes, ground truth establishment, expert qualifications, adjudication methods, MRMC studies, and standalone performance) are not applicable to this type of document or device submission.
However, I can extract information related to the device's comparison to its predicate and the general nature of its "performance data" as mentioned.
Here's an analysis based on the provided text, addressing the applicable points and explaining the non-applicability of others:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of quantitative acceptance criteria for performance metrics (such as accuracy, sensitivity, specificity) against which the device's performance is measured. Instead, the "acceptance criteria" are implied by the demonstration of "substantial equivalence" to a legally marketed predicate device (Bruno Electra-Ride II Indoor Straight Rail Stairlift Model SRE-1550, K033752).
- Implied Acceptance Criteria: The device must demonstrate similar technological characteristics and intended use, and show that its "performance data" confirms it meets specifications and is substantially equivalent to the predicate. This is a qualitative comparison rather than a quantitative one against predefined thresholds.
- Reported Device Performance: "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device." The document explicitly states the testing confirmed this, without providing specific numerical performance data.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not applicable. This is a premarket notification for a physical medical device (stair lift), not an AI/ML algorithm. The "testing" referred to likely involves engineering verification and validation testing (e.g., load bearing, safety mechanisms, durability) rather than a clinical trial with a "test set" of patients or data. The document does not specify details about these engineering tests, such as sample sizes or data provenance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)
Not applicable. Ground truth establishment by experts is relevant for diagnostic or AI/ML devices where a "correct answer" needs to be determined for comparison. For a stair lift, the "ground truth" would be the engineering specifications and safety standards, confirmed through physical testing.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods are typically used in clinical studies or for establishing ground truth when there is disagreement among experts about diagnostic labels or outcomes. This concept does not apply to the regulatory submission for a mechanical stair lift.
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
Not applicable. MRMC studies are used to evaluate the performance of diagnostic devices or AI algorithms often in the context of human-in-the-loop scenarios. This is not relevant for a stair lift.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. There is no algorithm or AI component mentioned in the description of the Merits E600 Series Stair Lift.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
As discussed in point 3, the concept of "ground truth" in the context of an AI/ML device is not applicable here. For this device, the "ground truth" implicitly refers to adherence to engineering design specifications, safety standards, and functional equivalence to the predicate device, which would be verified through mechanical and electrical testing.
8. The sample size for the training set
Not applicable. This device does not involve machine learning, so there is no "training set."
9. How the ground truth for the training set was established
Not applicable for the same reason as point 8.
§ 890.5150 Powered patient transport.
(a)
Powered patient stairway chair lifts —(1)Identification. A powered patient stairway chair lift is a motorized lift equipped with a seat and permanently mounted in one location that is intended for use in mitigating mobility impairment caused by injury or other disease by moving a person up and down a stairway.(2)
Classification. Class II. The stairway chair lift is exempt from premarket notification procedures in subpart E of part 807 of this chapter, subject to § 890.9 and the following conditions for exemption:(i) Appropriate analysis and nonclinical testing (such as that outlined in the currently FDA-recognized edition of American Society of Mechanical Engineers (ASME) A18.1 “Safety Standard for Platform Lifts and Stairway Chair Lifts”) must demonstrate that the safety controls are adequate to prevent a free fall of the chair in the event of a device failure;
(ii) Appropriate analysis and nonclinical testing must demonstrate the ability of the device, including armrests, to withstand the rated load with an appropriate factor of safety;
(iii) Appropriate restraints must be provided to prevent the user from falling from the device (such as that outlined in the currently FDA-recognized edition of ASME A18.1 “Safety Standard for Platform Lifts and Stairway Chair Lifts”);
(iv) Appropriate analysis and nonclinical testing (such as that outlined in the currently FDA-recognized editions of AAMI/ANSI/IEC 60601-1-2, “Medical Electrical Equipment—Part 1-2: General Requirements for Safety—Collateral Standard: Electromagnetic Compatibility—Requirements and Tests,” and ASME A18.1 “Safety Standard for Platform Lifts and Stairway Chair Lifts”) must validate electromagnetic compatibility and electrical safety; and
(v) Appropriate analysis and nonclinical testing must demonstrate the resistance of the device upholstery to ignition.
(b)
All other powered patient transport —(1)Identification. A powered patient transport is a motorized device intended for use in mitigating mobility impairment caused by injury or other disease by moving a person from one location or level to another, such as up and down flights of stairs (e.g., attendant-operated portable stair-climbing chairs). This generic type of device does not include motorized three-wheeled vehicles or wheelchairs.(2)
Classification. Class II.