K Number
K172409
Device Name
Lite
Date Cleared
2018-05-02

(266 days)

Product Code
Regulation Number
890.3800
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The Lite is a mobility assistive device for indoor use and outdoor use on mild terrain. It is not used as a transportation vehicle on roads and freeways used by cars.

Device Description

The Lite scooter is an electrically powered scooter. It is intended to be used by individuals that are able to walk, but suffer from mobility limitations. The user must have sufficient arm and leg strength to get on and off the Lite alone and to safely steer under all driving conditions. The Lite is intended for indoor use and restricted outdoor use on pavements or paved footpaths only. The Lite can be folded. This allows for easy storage and enables portability of the Lite. The control panel houses all the controls for operating the device. The control panel has a key switch for turning the device on and off, a lever for forward/reverse driving and a knob for speed adjustment. The control panel also contains the control indicator for the status of the device and a battery gauge. The LED control indicator shows the status of the scooter: steady light mean that all is well, blinking indicates an issue. The number of flashes indicate the type of issue. The User Manual contains a troubleshooting section where each type of error and its solution is specified. The steering column can be adjusted and put it in the position which is most comfortable for the operator. The armrests can be lifted to enable easy entry and exit from the scooter.

AI/ML Overview

The provided document describes the FDA 510(k) clearance for the "Lite" mobility assistive device. This type of document typically focuses on demonstrating substantial equivalence to a predicate device rather than presenting a detailed independent study with clinical endpoints and statistical power for performance metrics like sensitivity, specificity, etc., that would be expected for an AI/ML powered device.

Therefore, many of the requested fields are not applicable (N/A) in this context, as the "Lite" is a physical mobility device and not a diagnostic or AI-powered system that would require such studies.

Here's an analysis based on the provided text:

Acceptance Criteria and Device Performance for "Lite" Mobility Assistive Device

1. A table of acceptance criteria and the reported device performance

The acceptance criteria are generally met by demonstrating compliance with various ISO 7176 series safety standards. The reported device performance is presented as a comparison to a predicate device ("Elite").

Acceptance Criteria (Measured by ISO Standards)Reported Device Performance (Lite)Predicate Device Performance (Elite)Compliance Outcome
ISO 7176-1: Static stabilityPassedPassedYes
ISO 7176-2: Dynamic stabilityPassedPassedYes
ISO 7176-3: Effectiveness of brakesPassedPassedYes
ISO 7176-4: Energy consumptionPassedPassedYes
ISO 7176-5: Overall dimensions, mass, maneuvering spacePassedPassedYes
ISO 7176-6: Maximum speed, acceleration, decelerationPassedPassedYes
ISO 7176-7: Seating and wheel dimensionsPassedPassedYes
ISO 7176-8: Static, impact, fatigue strengthsPassedPassedYes
ISO 7176-9: Climatic testsPassedPassedYes
ISO 7176-10: Obstacle-climbing abilityPassedPassedYes
ISO 7176-11: Test dummiesPassedPassedYes
ISO 7176-13: Coefficient of friction of test surfacesPassedPassedYes
ISO 7176-14: Power and control systemsPassedPassedYes
ISO 7176-16: Resistance to ignitionPassedPassedYes
ISO 7176-21: Electromagnetic compatibilityPassedPassedYes
ISO 7176-25: Batteries and chargersPassedN/A (for Elite, newer standard)N/A (No direct Elite comparison possible)

Additional Performance Characteristics (Comparison to Predicate):

CharacteristicLite PerformanceElite Performance
Maximum Speed3.7 mph3.7 mph
Turning Radius35"37"
Carrying Capacity250 lbs250 lbs
Climbing Slope
Curb Clearance1.6"2"
Dimensions39x22x35"43x22x35"
WeightTotal: 66 lbs (Lead Acid), 58 lbs (Lithium)Total: 64 lbs
Battery Pack (weight)18 lbs (12A/h Lead Acid), 10 lbs (12A/h Lithium)18 lbs (12A/h Lead Acid)
Rangeup to 8 mi (Lead Acid), up to 9.8 mi (Lithium)up to 8 mi (Lead Acid)

2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

This device is not an AI/ML or diagnostic device that typically uses "test sets" of data in the common sense. The testing involved physical units of the device to confirm compliance with international standards.

  • Sample size: Not explicitly stated, but typically, a limited number of physical prototypes or production units would be tested for compliance with engineering standards.
  • Data provenance: Not applicable in the context of data for an AI/ML model. The tests were performed on the device itself. The manufacturer is Tzora Active Systems Ltd., located in Israel. The standards are international (ISO).

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

Not applicable. Ground truth, in the AI/ML sense, is not established for this type of device. Compliance is determined by objective measurements against established engineering and safety standards (ISO 7176 series). The "experts" would be the engineers and technicians performing the standard compliance tests, trained in their respective fields.

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

Not applicable. Adjudication methods are used to resolve disagreements in expert readings for diagnostic or AI/ML evaluations. This is a physical device tested against objective standards.

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-assisted diagnostic device.

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

Not applicable. This is a physical mobility device that requires a human operator for its intended function. There is no standalone algorithm performance to evaluate.

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

The "ground truth" for this device's safety and effectiveness is established by compliance with internationally recognized engineering and safety standards (ISO 7176 series). This involves objective physical measurements and tests performed on the device.

8. The sample size for the training set

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

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

Not applicable. There is no training set for this type of device.

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Image /page/0/Picture/0 description: The image contains two logos. The logo on the left is the Department of Health & Human Services - USA logo. The logo on the right is the FDA U.S. Food & Drug Administration logo. The FDA logo is blue and white.

May 2, 2018

Tzora Active Systems Ltd. % Moshe Rosenberg Regulatory Consultant A. Stein Regulatory Affairs Consulting Ltd. 20 Hataas St., Suite 102 Kfar Saba, 4442520 Il

Re: K172409 Trade/Device Name: Lite Regulation Number: 21 CFR 890.3800 Regulation Name: Motorized Three-Wheeled Vehicle Regulatory Class: Class II Product Code: INI Dated: March 28, 2018 Received: April 2, 2018

Dear Moshe Rosenberg:

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.

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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 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); 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.

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

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/MedicalDevices/DeviceRegulationandGuidance/) and CDRH Learn (http://www.fda.gov/Training/CDRHLearn). 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 (http://www.fda.gov/DICE) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Vivek J. Pinto -S

for Carlos L. Peña, PhD, MS 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) K172409

Device Name Lite

Indications for Use (Describe)

The Lite is a mobility assistive device for indoor use on pavements or mild terrain. It is not used as a transportation vehicle on roads and freeways used by cars.

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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SUMMARY OF SAFETY AND EFFECTIVENESS

K172409 (Premarket Notification [510(k)] Number)

1. Submitter Information

Manufacturer Name and AddressTzora Active Systems Ltd.
Kibbutz Tzora,
9980300,
Israel
Official CorrespondentMoshe Rosenberg
A. Stein - Regulatory Affairs Consulting Ltd.
20 Hata'as St. (Beit Hapaamon, Suite 102)
Kfar Saba 4442520,
Israel

Date Prepared: May 2, 2018 2.

3. Device Name Lite

Proprietary Name:Lite
Common Name:Vehicle, Motorized 3-Wheeled
FDA ClassificationName:21 CFR 890.3800; Vehicle, Motorized 3-Wheeled
FDA Classification:Class II, Product Code INI

Predicate Devices 4.

The Lite is substantially equivalent to the following devices:

ManufacturerDevice510(k)Date Cleared
Tzora Active Systems Ltd.EliteK052204February 15, 2006

Device Description 5.

The Lite scooter is an electrically powered scooter. It is intended to be used by individuals that are able to walk, but suffer from mobility limitations. The user must have sufficient arm and leg strength to get on and off the Lite alone and to safely steer under all driving conditions.

The Lite is intended for indoor use and restricted outdoor use on pavements or paved footpaths only.

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The Lite can be folded. This allows for easy storage and enables portability of the Lite.

The control panel houses all the controls for operating the device. The control panel has a key switch for turning the device on and off, a lever for forward/reverse driving and a knob for speed adjustment. The control panel also contains the control indicator for the status of the device and a battery gauge.

The LED control indicator shows the status of the scooter: steady light mean that all is well, blinking indicates an issue. The number of flashes indicate the type of issue. The User Manual contains a troubleshooting section where each type of error and its solution is specified.

The steering column can be adjusted and put it in the position which is most comfortable for the operator.

The armrests can be lifted to enable easy entry and exit from the scooter.

6. Indications for Use

The Lite is a mobility assistive device for indoor and outdoor use on mild terrain. It is not used as a transportation vehicle on roads and freeways used by cars.

These indications for use and intended use are identical to those of the predicate device.

7. Performance Testing

Testing was performed with the Lite to be in conformance with the following standards:

  • ISO 7176-1:2014 Wheelchairs Part 1: Determination of static stability .
  • ISO 7176-2:2001 Wheelchairs Part 2: Determination of dynamic stability of electric . 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 manoeuvring space
  • ISO 7176-6:2001 Wheelchairs Part 6: Determination of maximum speed, . acceleration and deceleration of electric wheelchairs

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  • 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 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 7176-21:2009 Wheelchairs Part Requirements and test methods for ● electromagnetic compatibility of electrically powered wheelchairs and scooters, and battery chargers
  • . ISO 7176-25:2013 Wheelchairs - Part 25: Batteries and chargers for powered wheelchairs

Technological Characteristics Compared to Predicate Device 8.

The following table shows a comparison between the Lite and the predicate Elite.

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COMPARISON TABLE

TechnologicalCharacteristicLiteTzora Active Systems Ltd.(K172409)EliteTzora Active Systems Ltd.(K052204)
Product Code,ClassINI,Class IIINI,Class II
Indications for UseThe Lite is a mobility assistive device for indoor useand outdoor use on mild terrain.It is not used as a transportation vehicle on roads andfreeways used by cars.The Elite is a mobility assistive device for indoor useand outdoor use on mild terrain.It is not used as a transportation vehicle on roads andfreeways used by cars.
Target PopulationIndividuals that are able to walk but suffer from minormobility limitations.Individuals that are able to walk but suffer from minormobility limitations.
Environment UsedIndoor and outdoorIndoor and outdoor
Energy Used /DeliveredNo energy deliveredNo energy delivered
Design:The Lite consists of a foldable frame, foldable steeringcolumn and removable battery pack.The Elite consists of a foldable frame, foldable anddetachable steering column and removable batterypack.
- Mechanism ofActionTransaxle motor drive unit, propelling both rearwheels.Pancake hub motor forming the front wheel.
- Components- 2 Front Wheels - Flat Free PU 8x2"- 2 Rear Wheels - Flat Free PU 8x2"- Transaxle Motor- Controller- Frame- 2x 12V 12A/h Sealed Lead Acid Batteries- 2x 12V 12 A/h Lithium Batteries (optional)- 1 Front Wheel - Flat Free PU 10x2"- 2 Rear Wheels - Flat Free PU 8x2"- Pancake hub motor- Controller- Front Frame- Rear Frame- 2x 12V 12A/h- 2x 12V 7A/h (*discontinued)
TechnologicalLiteElite
CharacteristicTzora Active Systems Ltd.Tzora Active Systems Ltd.
(K172409)(K052204)
- FeaturesMaximum Speed 3.7 mphMaximum Speed: 3.7 mph
Turning Radius: 35"Turning Radius: 37"
Carrying Capacity: 250 lbsCarrying Capacity: 250 lbs
Climbing Slope: 6°Climbing Slope: 6°
Curb Clearance: 1.6"Curb Clearance: 2"
- Dimensions39x22x35"43x22x35"
- WeightTotal: 66 lbs (Lead Acid), 58 lbs (Lithium)Total: 64 lbs
Frame: 48 lbsFront Column: 24 lbs
Rear Frame: 27 lbs
Battery Pack: 18 lbs (12A/h Lead Acid)Battery Pack: 18 lbs (12A/h Lead Acid)
10 lbs (12A/h Lithium)
- PerformanceRange: up to 8 mi (Lead Acid)Range: up to 8 mi (Lead Acid)
up to 9.8 mi (Lithium)
- Human FactorsControl Panel consists of:Control Panel consists of:
- On/Off Key Switch- On/Off Key Switch
- Control Lever Forward/Reverse- Control Lever Forward/Reverse
- Speed Adjustment Knob- Speed Adjustment Knob
- Battery Gauge- Battery Gauge
- Status Indicator LED- Status Indicator LED
- Standards MetISO 7176 series safety standardsISO 7176 series safety
- MaterialsFrame: Stainless SteelFrame: Stainless Steel
Seat: PolypropyleneSeat: Polypropylene
Upholstery: Vinyl Covered FoamUpholstery: Vinyl Covered Foam
Armrests: FoamArmrests: Foam
- BiocompatibilityMaterials are biocompatibleMaterials are biocompatible
TechnologicalCharacteristicLiteTzora Active Systems Ltd.(K172409)EliteTzora Active Systems Ltd.(K052204)
CompatibilityWith theEnvironment andOther DevicesThe Lite is compliant with the ISO 7176-21 standard.The Elite is compliant with the IEC 60601-1-2 (EMCCompatibility) standard.
Electrical SafetyPower Requirements:110-120 VAC / 60 Hz220-240 VAC / 50 HzThe Lite is compliant with the ISO 7176 series safetystandards.Power Requirements:110-120 VAC / 60 Hz220-240 VAC / 50 HzThe Elite is compliant with the EN 12184 (ElectricalSafety) standard.
Mechanical SafetyThe Lite is compliant with the ISO 7176 series safetystandards.The Elite is compliant with the EN 12184 (ElectricalSafety) standard.
Chemical SafetyNot ApplicableNot Applicable
Thermal SafetyThe Lite is compliant with the ISO 7176 series safetystandards.The Elite is compliant with the EN 12184 (ElectricalSafety) standard.
Radiation SafetyThe Lite is compliant with the ISO 7176-21 standard.The Elite is compliant with the IEC 60601-1-2 (EMCCompatibility) standard.

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Control Panel

The Lite has the same control panel as the predicate device.

Maximum speed

The Lite can reach the same maximum speed of 3.7 mph as the predicate device (K052204). Also the minimum braking distance remained the same: 0.7 m.

Batteries

The Lite batteries are identical to the batteries of the predicate device: two 12V 12A/h sealed lead acid batteries.

The Lite can also be provided with two 12V 12A/h lithium batteries.

Seat

The Lite has the same seat and armrests as the predicate device.

Frame

The Lite has a foldable frame, where the seat and the steering column can be folded down. The Elite has a foldable and detachable frame, where the steering column can be folded with the frame or it can be detached from the frame.

Wheels

The Lite has 4 wheels (2 front, 2 rear wheels), whereas the predicate device has 3 wheels (1 front, 2 rear wheels). The 4-wheel design is identical to the previously cleared EasyTravel (K012592).

Motor

The Lite is propelled by a transaxle motor with electromagnetic brake. This motor unit is attached to the rear of the frame and has the rear wheels attached to it. The predicate device is propelled by a pancake motor placed, with the electromagnetic brake, in the front drive wheel.

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The differences in the above specifications do not adversely affect the safety and effectiveness and performance of the Lite. The Lite was tested to be in conformance with the in section 8 aforementioned standards and found compliant.

StandardSubject: Lite (K172409)Predicate: Elite (K052204)Equivalent?
ISO 7176-1PassedPassedYes
ISO 7176-2PassedPassedYes
ISO 7176-3PassedPassedYes
ISO 7176-4PassedPassedYes
ISO 7176-5PassedPassedYes
ISO 7176-6PassedPassedYes
ISO 7176-7PassedPassedYes
ISO 7176-8PassedPassedYes
ISO 7176-9PassedPassedYes
ISO 7176-10PassedPassedYes
ISO 7176-11PassedPassedYes
ISO 7176-13PassedPassedYes
ISO 7176-14PassedPassedYes
ISO 7176-16PassedPassedYes
ISO 7176-21PassedPassedYes
ISO 7176-25PassedN/AN/A

The technological characteristics, e.g., overall design, materials, mechanism of action, mode of operation, performance characteristics, etc., and the indications for use of the Lite are substantially equivalent to the predicate device cited above.

9. Conclusion

The performance testing and comparison to the predicate device demonstrate that the Lite is as safe, as effective and performs as well as the legally marketed Elite predicate device. Therefore, the Lite is substantially equivalent to the Elite and may be legally marketed in the USA.

§ 890.3800 Motorized three-wheeled vehicle.

(a)
Identification. A motorized three-wheeled vehicle is a gasoline-fueled or battery-powered device intended for medical purposes that is used for outside transportation by disabled persons.(b)
Classification. Class II (performance standards).