K Number
K132257
Date Cleared
2014-02-13

(209 days)

Product Code
Regulation Number
890.3850
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The device is intended for medical purposes to provide mobility to persons restricted to a sitting position. It is designed for use indoors and outdoors, over smooth surfaces (all standard indoor flooring surfaces, concrete, asphalt and packed dirt) that are free of large obstacles and inclines greater than 8 degrees.

Device Description

A mechanical wheelchair is a chair with wheels, designed to be a replacement for walking, where it is propelled by the seated occupant turning the rear wheels by hand. There are also handles behind the seat for someone else to do the pushing. Wheelchairs are used by people for whom walking is difficult or impossible due to illness, injury, or disability.

The Manual Wheelchairs Model SY 100-MA02 (02A & 02B) and Model SY 100-MA06 (or other clients private labeling) are user propelled, manually operated folding wheelchairs that are indicated for use indoors and outdoors, over smooth surfaces (all standard indoor flooring surfaces, concrete, asphalt and packed dirt) that are free of large obstacles and inclines greater than 8 degrees. Each consists of four wheels, a mechanical steel frame and nylon upholstery that is ignition resistant. The device is designed to be lightweight and foldable, and can be dissembled. In both models, both rear and caster wheels use solid tires.

The model SY100-MA02 has two sub-models (02A & 02B) which both has a physical dimension of 1025 (depth) x 661 (width) x 920 (height) mm, with the seat itself has a dimension of 408 (depth) x 440 (width) x 455 (height) mm. The device has a weight capacity of 130 kilograms.

Sub-model MA02A uses hard plastic back wheels and weighs approximately 16.5 kilograms. Sub-model MA02B uses wired steel wheels and weighs 13.8 kilograms. Both sub-models are dark green in color.

Model SY100-MA06 has a physical dimension of 1026 (depth) x 651 (width) x 860 (height) mm. with the seat itself has a dimension of 394 (depth) x 374 (width) x 482 (height) mm, and a weight capacity of 100 kilograms, and weighs approximately 15.2 kilograms.

AI/ML Overview

The provided text describes a 510(k) premarket notification for a manual wheelchair and does not contain information about an AI/ML powered device. Therefore, many of the requested categories in the prompt are not applicable.

However, I can extract information related to the acceptance criteria and the study performed for this manual wheelchair.

1. Table of Acceptance Criteria and Reported Device Performance

DescriptionAcceptance Criteria (Test Standard)Reported Device Performance
Static StabilityMeets ISO 7176-1:1999Meets ISO 7176-1:1999
Effectiveness of BrakesMeets ISO 7176-3: 2003Meets ISO 7176-3: 2003
Static StrengthMeets ISO 7176-8: 1998Meets ISO 7176-8: 1998
Impact StrengthMeets ISO 7176-8: 1998Meets ISO 7176-8: 1998
Fatigue StrengthMeets ISO 7176-8:1998Meets ISO 7176-8:1998
Resistance to IgnitionMeets ISO 7176-16:1997Meets ISO 7176-16:1997
Weight Capacity (Model SY100-MA02)130 Kg130 Kg
Weight Capacity (Model SY100-MA06)100 Kg100 Kg

2. Sample size used for the test set and the data provenance:

  • Sample Size: Not explicitly stated. The document refers to "Our Devices" (Manual Wheelchair Model SY100-MA02 (02A & 02B) and Model SY100-MA06) as having undergone testing. It's implied that at least one of each model/sub-model was tested.
  • Data Provenance: The tests were conducted following recommended procedures outlined in consensus standards (ISO 7176 series). The document does not specify the country of origin for the testing or whether the data was retrospective or prospective, but it's non-clinical testing.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

  • Not applicable. This is a non-clinical performance assessment of a mechanical device against international standards, not an AI/ML device requiring expert ground truth for image interpretation or diagnosis.

4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

  • Not applicable. This is a technical performance test, not a 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:

  • Not applicable. This is not an AI-powered device.

6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

  • Not applicable. This is not an AI-powered device.

7. The type of ground truth used (expert consensus, pathology, outcomes data, etc):

  • The "ground truth" for this medical device is adherence to established international performance standards (ISO 7176 series) for mechanical wheelchairs. These standards define the acceptable physical and functional characteristics.

8. The sample size for the training set:

  • Not applicable. This is not an AI/ML device that requires a training set.

9. How the ground truth for the training set was established:

  • Not applicable. This is not an AI/ML device that requires a training set.

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K132257

FEB 1 3 2014

Section 5: 510(k) Summary:

This summary of 510k safety and effectiveness information is being submitted In accordance with the requirements of 21CFR 807.92

Submitter & Foreign Manufacture Identification

Zhejiang Jiafeng Electrical & Mechanical Co., Ltd No. 128 Jinxiu Road, Luoxing District, Jiashan, Zhejiang, 314100 China Submitter's FDA Registration Number: N/A

US Agent and Contact Person

Charles Shen Manton Business and Technology Services 5 Carey Street Pennington, NJ 08534 Tel: 608-217-9358 Email: cyshen@aol.com

Date of Summary: June 01, 2013

Device Name: Proprietary Name:

Common Name: Classification Name: Device Classification: Regulation Number: Panel: General Product Code:

Manual Wheelchair Model SY100-MA02 (02A & 02B) and Model SY 100-MA06 (or other clients private labeling) Mechanical Wheelchair Wheelchair, Mechanical l 21 CFR 890.3850 Physical Medicine IOR

Predicate Device Information:

(1) K062311, "KARMA Manual Wheelchair, Budget 800", manufactured by "KARMA Medical Products Co., Ltd. "

Device description:

A mechanical wheelchair is a chair with wheels, designed to be a replacement for walking, where it is propelled by the seated occupant turning the rear wheels by hand. There are also handles behind the seat for someone else to do the pushing. Wheelchairs are used by people for whom walking is difficult or impossible due to illness, injury, or disability.

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The Manual Wheelchairs Model SY 100-MA02 (02A & 02B) and Model SY 100-MA06 (or other clients private labeling) are user propelled, manually operated folding wheelchairs that are indicated for use indoors and outdoors, over smooth surfaces (all standard indoor flooring surfaces, concrete, asphalt and packed dirt) that are free of large obstacles and inclines greater than 8 degrees. Each consists of four wheels, a mechanical steel frame and nylon upholstery that is ignition resistant. The device is designed to be lightweight and foldable, and can be dissembled. In both models, both rear and caster wheels use solid tires.

The model SY100-MA02 has two sub-models (02A & 02B) which both has a physical dimension of 1025 (depth) x 661 (width) x 920 (height) mm, with the seat itself has a dimension of 408 (depth) x 440 (width) x 455 (height) mm. The device has a weight capacity of 130 kilograms.

Sub-model MA02A uses hard plastic back wheels and weighs approximately 16.5 kilograms. Sub-model MA02B uses wired steel wheels and weighs 13.8 kilograms. Both sub-models are dark green in color.

Model SY100-MA06 has a physical dimension of 1026 (depth) x 651 (width) x 860 (height) mm. with the seat itself has a dimension of 394 (depth) x 374 (width) x 482 (height) mm, and a weight capacity of 100 kilograms, and weighs approximately 15.2 kilograms.

Intended Use:

The device is intended for medical purposes to provide mobility to persons restricted to a sitting position. It is designed for use indoors and outdoors, over smooth surfaces (all standard indoor flooring surfaces, concrete, asphalt and packed dirt) that are free of large obstacles and inclines greater than 8 degrees.

Comparison to Predicate Devices

The Manual Wheelchair Model SY100-MA02 (02A & 02B) and Model SY100-MA06 (or other clients private labeling) are compared with the following Predicate Devices in terms of intended use, design, material, specifications, and performance.

(1) K062311, "KARMA Manual Wheelchair, Budget 800", manufactured by "KARMA Medical Products Co., Ltd. "

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The following table shows similarities and differences of use, design, and material between our devices and the predicate device.

DescriptionOur DevicesPredicate Device (K062311)
Indication forUseThe device is intended for medical purposesto provide mobility to persons restricted toa sitting position. It is designed for useindoors and outdoors, over smooth surfaces(all standard indoor flooring surfaces,concrete, asphalt and packed dirt) that are freeof large obstacles and inclines greater than 8degrees.The device is intended formedical purposes to providemobility to persons restricted toa sitting position.
Basic DesignFour wheels, a mechanical steel frame andnylon upholstery that is flame resistant.Same
MaterialsSteel and flame resistant fabricsSame
PowderMechanicalSame
DimensionSY 100 MA02 (02A & 02B):1025 x 661 x 920mm (depth x width x height)SY 100 MA06:1026 x 651 x 860 mm (depth xwidth x height)1080 x 610 x 432 mm (depth xwidth x height)
ArmrestArm Pad/Non Flip Back/Height AdjustableArm Pad/Flip Back/ Not HeightAdjustable
Rear AxleOffset Axle, Quick Release AxleSame
Back Wheel61 cm (=24 inch)24 inch
CastersSY 100 MA02 (02A & 02B): 20 cm (=8 inch)SY 100 MA06: 15 cm (= 6 inch)8 inch
Wheel LockPull to LockSame
WeightCapacitySY 100 MA02: 130 KgSY 100 MA06: 100 Kg115 Kg
WeightSY 100 MA02A: 16.5 Kg (plastic wheel)SY 100 MA02B: 13.8 Kg (netted steel wheel)SY 100 MA06: 15.2 Kg14.44 and 14.64 Kg
ColorSY 100 MA02 (02A & 02B): Dark GreenSY 100 MA06: BlackBlack/Blue
Table 5.1: Comparison of Intended Use, Design, and Material
-----------------------------------------------------------------

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Our devices and the predicate device are almost identical in terms of all areas described in the above table (Table 5.1). Our Indications for Use consists of two sentences. The first sentence is identical to the predicate device, the second sentence explains in detail of the surface suitable for use. This indication provides users better instruction as to what is the safe road condition for the wheelchair, and protects the users better.

In terms of design, in addition to small size differences, the first slight difference is the armrest design. The armrests in predicate device are able to flip back and not height adiustable, while in our devices they are not able to flip back, but are able to be dissembled, and are height adjustable for the comfort of passenger. Detailed drawings of the armrest design can be found in Section 11. The second difference is that SY 100-MA 02 (02A & 02B) has a secondary hand brake located in the push handle area for the convenient use by the care providers. These minor differences with the predicate device don't affect the function or indications for use of the device.

The following table shows similarities and differences of the performance between our devices and the predicate device. Tests were conducted following the recommended procedures outlined in the respective consensus standards, and results for Manual Wheelchair Model SY 100-MA02 (02A & 02B) and Model SY 100-MA06 (or other clients private labeling), manufactured by "Zhejiang Jiafeng Electrical & Mechanical Co., Ltd. " met all relevant requirements in the test standards, our internal specifications, and are comparable to the predicate device.

DescriptionOur DevicesPredicate Device (K062311)
Static StabilityMeets ISO 7176-1:1999
Effectiveness of BrakesMeets ISO 7176-3: 2003Met ISO 7176 WheelchairStandards
Static StrengthMeets ISO 7176-8: 1998
Impact StrengthMeets ISO 7176-8: 1998
Fatigue StrengthMeets ISO 7176-8:1998
Resistance to IgnitionMeets ISO 7176-16:1997
Table 5.2: Comparison of Physical, Biocompatibility and Performance Testing

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A brief discussion of the non-clinical testing data that was submitted, referenced or relied on to demonstrate that the Subject Device is safe and effective, and whose performance meets the requirements of its user-defined acceptance criteria and intended uses:

Manual Wheelchair Model SY 100-MA02 (02A & 02B) and Model SY 100-MA06 (or other clients private labeling) meets performance requirements per ISO 7176-1:1999, ISO 7176-3: 2003, ISO 7176-8: 1998, and ISO 7176-16:1997. They are safe and effective, and their performances meet the requirements of their pre-defined acceptance criteria and intended uses.

A brief discussion of the clinical submitted, reference, or relied on in the premarket notification submission for a determination of substantial equivalence.

Clinical data is not needed for manual wheelchair cleared by the 510(k) process.

Substantial Equivalent Conclusions

Based on the comparison of intended use, design, materials, and performance, our Manual Wheelchair Model SY 100-MA02 (02A & 02B) and Model SY 100-MA06 (or other clients private labeling) are substantial equivalent to their predicate devices.

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DEPARTMENT OF HEALTH & HUMAN SERVICES

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

February 13, 2014

Zhejiang Jiafeng Electrical & Mechanical Co., Ltd. c/o Charles Shen Manton Business and Technology Services 5 Carey Street Pennington, NJ 08534

Re: K132257

Trade/Device Name: Manual Wheelchair Model SY100-MA02 (02A & 02B) and Model SY100-MA06 Regulation Number: 21 CFR 890.3850 Regulation Name: Mechanical Wheelchair Regulatory Class: Class I Product Code: IOR Dated: November 30, 2013 Received: December 3, 2013

Dear Charles Shen:

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. 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 statutes and regulations administered by other Federal agencies. You must

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Page 2 - Mr. Charles Shen

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 (reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Joyce M. Whang -S

for Carlos L. Peña, Ph.D., M.S. Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K132257

Device Name

Manual Wheelchair Model SY100-MA02 (02A & 02B) and Model SY100-MA06

Indications for Use (Describe)

The device is intended for medical purposes to provide mobility to persons restricted to a sitting position. It is designed for use indoors and outdoors, over smooth surfaces (all standard indoor flooring surfaces, concrete, asphalt and packed dirt) that are free of large obstacles and inclines greater than 8 degrees.

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)

PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.

FOR FDA USE ONLY

Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)

Image /page/7/Picture/13 description: The image shows the name "Joyce MFWHang -S" in a bold, sans-serif font. The letters are large and black, with the exception of "MFWH", which appears to have a textured or patterned fill. The name is displayed horizontally across the image.

FORM FDA 3881 (1/14)

PSC Publishing Services (301) 443-6740 EF

Form Approved: OMB No. 0910-0120 Expiration Date: January 31, 2017 See PRA Statement on last page.

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§ 890.3850 Mechanical wheelchair.

(a)
Identification. A mechanical wheelchair is a manually operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position.(b)
Classification. Class I (general controls).