K Number
K173313
Device Name
SupaChair Powered Wheelchair: COMBI 18, COMBI 18SP, COMBI 20, COMBI 20SP
Date Cleared
2018-02-13

(117 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The device is a power wheelchair intended to provide mobility to persons restricted to a sitting position.
Device Description
The device is a power wheelchair. Common Name: Powered Wheelchair Trade Name: "SupaChair" Powered Wheelchair Classification Name: Powered Wheelchair Regulation Number: 890.3860 Product Code: ITI Device Class: Class 2 Model: COMBI 18/ COMBI 20/ COMBI 18SP/ COMBI 20SP
More Information

Not Found

No
The summary does not mention AI, ML, or any related technologies. The performance studies focus on compliance with ISO standards, typical for a power wheelchair.

No.
A therapeutic device is typically one that treats, mitigates, or prevents a disease or condition. A power wheelchair provides mobility support but does not directly treat a medical condition.

No

The device is described as a power wheelchair designed for mobility, with no mention of diagnostic capabilities, measurements, or analysis of physiological data.

No

The device is explicitly described as a power wheelchair, which is a physical hardware device, not software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is clearly stated as providing mobility to persons restricted to a sitting position. This is a mechanical function, not a diagnostic one.
  • Device Description: The device is described as a power wheelchair, which is a mobility aid.
  • Regulation Number: The regulation number 890.3860 corresponds to "Powered wheelchair" under the Physical Medicine regulation area, not IVD regulations.
  • Product Code: The product code ITI also corresponds to "Powered Wheelchair".
  • Lack of Diagnostic Elements: There is no mention of analyzing samples (blood, urine, tissue, etc.), detecting diseases, or providing diagnostic information.

IVD devices are used to examine specimens from the human body to provide information for the diagnosis, prevention, or treatment of a disease or condition. This power wheelchair does not perform any such function.

N/A

Intended Use / Indications for Use

The device is a power wheelchair intended to provide mobility to persons restricted to a sitting position

Product codes

ITI

Device Description

Intended Use : "The device is a powered wheelchair intended to provide mobility to persons restricted to a sitting position."

ItemDescription
Common NamePowered Wheelchair
Trade Name"SupaChair" Powered Wheelchair
Classification NamePowered Wheelchair
Regulation Number890.3860
Product CodeITI
Device ClassClass 2
ModelCOMBI 18/ COMBI 20/ COMBI 18SP/ COMBI 20SP

Drive wheel size: 200mm (8") / 260mm (10")
Caster wheel size: 178mm (7") / 200mm (8")
Overall Length: 1180mm (46.5")
Overall Width: 580620mm (22.825.2")
Overall Height: 1010mm (39.8")
Standard Seat Width: 450490mm (17.719.3")
Standard Seat Depth: 450mm (17.7")
Backrest height: 470mm (18.5")
Weight capacity: 150kg (330 lbs)
Total weight with batteries (SLA): 37.339.8kg (8287.5 lbs)
Weight of motor mount complete: 14.917.4kg (32.838.2 lbs)
Heaviest Piece: 14.917.4kg (32.838.2 lbs)
Breaks down into: 6 pieces
Maximum speed SLA battery: 6.59kph (45.6mph)
Turning Radius: 9001100mm (35.443.3")
Ground clearance: 83mm (3.3")
Battery (SLA/Lithium): 24V-15ah
Weight of battery (SLA/Lithium): 9.2/4 kg (20/9 lbs)
Slope grade ability: 89 degrees
Travel Distance SLA/Lithium: Up to 10/16.5km (Up to 6.2/10.2 mile)
Battery charger SLA: 2A Off board
Battery charger Lithium: 4 A Off board
Armrest height: 160
215mm (6.38.5")
Brake: Dynamic braking and electromagnetic brake
Brake distance-Normal operation (Horizontal-Forward-Max speed): 1.0
1.5 m/s Adjustable from software according to market demand.
Attendant joystick (Optional): Detachable joystick either mount on power chair or handle bar.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies (study type, sample size, AUC, MRMC, standalone performance, key results)

Non-clinical Testing: "SupaChair" powered wheelchair has done the series test to confirmation its safety and effectiveness in pre-clinical test. The tests are conducted with ISO 7176 serial standards. All test results are in compliance with it and were similar to predicate device.

Tested standards include:

  • ISO 7176-1 : Static stability test
  • ISO 7176-2 : Dynamic stability test
  • ISO 7176-3 : Efficiency of brakes tests
  • ISO 7176-4 : Theoretical distance range tests
  • ISO 7176-5 : Overall dimensions, Mass, Turning, Diameter tests
  • ISO 7176-6 : Maximum speed, acceleration and retardation tests
  • ISO 7176-7 : Seating and wheel dimension tests
  • ISO 7176-8 : Static, impact and fatique strengths tests
  • ISO 7176-9 : Climatic tests
  • ISO 7176-10 : Obstacle-climbing ability tests
  • ISO 7176-11 : Test dummies
  • ISO 7176-13 : Determination of coefficient of friction of test surfaces
  • ISO 7176-14 : Power and control system
  • ISO 7176-15 : Information disclosure, documentation and labeling
  • ISO 7176-21 (EN 12184) : EMC test
  • ISO 7176-25 : Batteries and chargers for powered wheelchairs
  • IEC 62133 : 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.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s)

K052706

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 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).

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Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo is in blue and includes the letters "FDA" followed by the words "U.S. Food & Drug Administration" in a sans-serif font. The word "Administration" is on a separate line below "U.S. Food & Drug".

February 13, 2018

Eurogreen International Inc. David Hsieh General Manager No. 48, Lane 220, Sec. 1, Fu-Zun Rd., Yuan-Lin Township Chang-Hua County, Taiwan 51055 R.O.C.

Re: K173313

Trade/Device Name: "SupaChair" Powered Wheelchair: COMBI 18, COMBI 18SP, COMBI 20, COMBI 20SP Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: December 18, 2017 Received: January 22, 2018

Dear David Hsieh:

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 comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part

1

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

2

Indications for Use

510(k) Number (if known) K173313

Device Name

"SupaChair" Powered Wheelchair: COMBI 18, COMBI 18SP, COMBI 20, COMBI 20SP

Indications for Use (Describe)

The device is a power wheelchair intended to provide mobility to persons restricted to a sitting 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)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

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Image /page/3/Picture/0 description: The image shows the word "SupnChAiR" in a stylized font. The letters are black and the background is white. The letters are connected to each other, and the "A"s are shaped like triangles.

Date: Dec 18, 2017

5.1 Applicant Information

Type of SubmissionOriginal Application- Traditional 510(k)
Applicant NameEUROGREEN INTERNATIONAL INC.
AddressNo.48, Ln. 220, Sec. 1, Fuzun Rd., Yuanlin Township,
Changhua County, Taiwan
Phone+886-4-8319633
Fax+886-4-8332226
Contact PersonDavid Hsieh
Contact TitleGeneral Manager
Contact E-mailsales@lawia.com

5.2 Device Description

Intended Use : "The device is a powered wheelchair intended to provide mobility to persons restricted to a sitting position."

ItemDescription
Common NamePowered Wheelchair
Trade Name"SupaChair" Powered Wheelchair
Classification NamePowered Wheelchair
Regulation Number890.3860
Product CodeITI
Device ClassClass 2
ModelCOMBI 18/ COMBI 20/ COMBI 18SP/ COMBI 20SP

4

Section 5Page
510(k) Summary2 / 10
Drive wheel size200mm (8")
260mm (10")
Caster wheel size178mm (7")
200mm (8")
Overall Length1180mm (46.5")
Overall Width580620mm (22.825.2")
Overall Height1010mm (39.8")
Standard Seat Width450490mm (17.719.3")
Standard Seat Depth450mm (17.7")
Backrest height470mm (18.5")
Weight capacity150kg (330 lbs)
Total weight with
batteries (SLA)37.339.8kg (8287.5 lbs)
Weight of motor
mount complete14.917.4kg (32.838.2 lbs)
Heaviest Piece14.917.4kg (32.838.2 lbs)
Breaks down into6 pieces
Maximum speed SLA
battery6.59kph (45.6mph)
Turning Radius9001100mm (35.443.3")
Ground clearance83mm (3.3")
Battery (SLA/Lithium)24V-15ah
Weight of battery
(SLA/Lithium)9.2/4 kg (20/9 lbs)
Slope grade ability8~9 degrees
Travel Distance
SLA/LithiumUp to 10/16.5km (Up to 6.2/10.2 mile)
SUONCHARSection 5Page
510(k) Summary3 / 10
Battery charger SLA2A Off board
Battery charger
Lithium4 A Off board
Armrest height160215mm (6.38.5")
BrakeDynamic braking and electromagnetic brake
Brake distance-Normal
operation1.0~1.5 m/s
(Horizontal-Forward-Max
speed)Adjustable from software according to market demand.
Attendant joystickDetachable joystick either mount on power chair or
(Optional)handle bar.

5

6

Sup^Chair

Section 5

510(k) Summary

Page

COMBI 18COMBI 20COMBI 18SPCOMBI 20SP
Drive wheels size200mm (8")200mm (8")260mm (10")260mm (10")
Caster wheels size178mm (7")178mm (7")200mm (8")200mm (8")
Overall length1180mm (46.5")1180mm (46.5")1180mm (46.5")1180mm (46.5")
Overall width580mm (22.8")620mm (25.2")580mm (22.8")620mm (25.2")
Overall height1010mm (39.8")1010mm (39.8")1010mm (39.8")1010mm (39.8")
Standard seat width450mm (17.7")490mm (19.3")450mm (17.7")490mm (19.3")
Standard seat depth450mm (17.7")450mm (17.7")450mm (17.7")450mm (17.7")
Back rest height470mm (18.5")470mm (18.5")470mm (18.5")470mm (18.5")
Weight capacity150kg (330 lbs)150kg (330 lbs)150kg (330 lbs)150kg (330 lbs)
Total weight with batteries (SLA)37.3kg (82 lbs)37.7kg (83 lbs)39.7kg (87 lbs)39.8kg (87.5 lbs)
Weight of motor mount
complete14.9kg (32.8 lbs)15kg (33 lbs)17.3kg (38 lbs)17.4kg (38.2 lbs)
Heaviest piece14.9kg (32.8 lbs)15kg (33 lbs)17.3kg (38 lbs)17.4kg (38.2 lbs)
Breaks down into6 pieces6 pieces6 pieces6 pieces
Maximum speed SLA battery6.5kph (4mph)6.5kph (4mph)9kph (5.6mph)9kph (5.6mph)
Turning radius900mm (35.4")1100mm (43.3")900mm (35.4")1100mm (43.3")
Ground clearance83mm (3.3")83mm (3.3")83mm (3.3")83mm (3.3")
Battery (SLA/Lithium)24V15ah24V15ah24V15ah24V15ah
Weight of battery (SLA/Lithium)9.2/4kg (20/9 lbs)9.2/4kg (20/9 lbs)9.2/4kg (20/9 lbs)9.2/4kg (20/9 lbs)
Slope grade ability9 degree9 degree8 degree8 degree
Travel distance SLA/LithiumUp to 10/16.5km (Up
to 6.2/10.2mile)Up to 10/16.5km (Up
to 6.2/10.2mile)Up to 10/16.5km (Up
to 6.2/10.2mile)Up to 10/16.5km (Up
to 6.2/10.2mile)
Battery charger SLA2A off board2A off board2A off board2A off board
Battery charger Lithium4A off board4A off board4A off board4A off board
Armrest height160-215mm
(6.3-8.5")160-215mm
(6.3-8.5")160-215mm
(6.3-8.5")160-215mm
(6.3-8.5")
BrakeDynamic braking and
electromagnetic
brakeDynamic braking and
electromagnetic
brakeDynamic braking and
electromagnetic
brakeDynamic braking and
electromagnetic
brake
Brake distance-Normal operation
(Horizontal-Forward-Max speed)
*Adjustable from software according to
market demand.*1.0-1.5 m/s1.0-1.5 m/s1.0-1.5 m/s1.0-1.5 m/s
Attendant joystick (Optional)Detachable joystick either mount on power chair or handle bar.

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Image /page/7/Picture/0 description: The image shows the word "SupnChair" in a stylized font. The letters are all connected and have a unique design. The word is in black and the background is white.

Section 5

510(k) Summary

5 / 10

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Image /page/8/Picture/0 description: The image shows the word "SupaChair" in a stylized font. The letters are all connected and have a sleek, modern look. The word is in black and the background is white.

5.3 Equivalence comparison to marketed device

Technological characteristics :

Per the 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)], we choose OTTO BOCK Healthcare, LP to be our predicate device. The reasons are OTTO BOCK Healthcare, LP had 510k already, similar intended use and technological characteristics to our subject devices.

The device features and use parameters of the OTTO BOCK Healthcare, LP, A-200 Powered Wheelchair (K052706) are very similar. Both are battery operated and have brake systems. Batteries capacity and battery chargers are similar and provided with the powered wheelchair. Use parameters are very similar, varying only in minor parameters such as the grade climbable by the respective wheelchairs.

| | EUROGREEN
International Inc. | OTTO BOCK Healthcare,
LP | Differences |
|---------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------|
| K number | K173313 | K052706 | |
| Identification | Subject devices | Predicate device | |
| Indication for Use | "The device is a
powered wheelchair
intended to provide
mobility to persons
restricted to a sitting
position." | Provide mobility to
persons physically
challenged and limited
to sitting positions. | Similar |
| Model Type | COMBI 18/ COMBI
20/ COMBI 18SP/
COMBI 20SP | A-200 | |
| Drive wheel size | 200 mm (8")
260 mm (10") | | Smaller wheel for lower
speed and better output
for torque. |
| | | | |
| Caster wheel size | 178 mm ( 7 " )
200 mm (8") | | Not effect to output |
| Overall Length | 1180 mm (46.5") | 1000 mm | Similar |
| Overall Width | 580620 mm
(22.8
25.2") | 570 mm | Similar |
| Overall Height | 1010 mm (39.8") | | Similar |
| Standard Seat Width | 450490 mm
(17.7
19.3") | 340480 mm | Similar |
| Standard Seat Depth | 450 mm (17.7") | 340
500 mm | Similar |
| Back rest height | 470 mm (18.5") | 550/500/450 mm | Similar |
| Weight Capacity | 150 kg (330 lbs) | 100 kg | These are options
according the customer
needs. All models passed
the loading test.
(Appendix 7.37.6) |
| Total Weight With
Batteries (SLA) | 37.3
39.8 kg
(8287.5 Ibs) | 66 kg | It doesn't affect the
safety and performance. |
| Weight of Motor
mount complete | 14.9
17.4 kg
(32.838.2 lbs) | | |
| Heaviest Piece | 14.9
17.4 kg
(32.838.2 lbs) | | |
| Breaks Down Into | 6 pieces | | |
| Maximum Speed SLA
battery | 6.5
9 kph
(45.6 mph) | 6 km/h | Similar |
| Turning Radius | 900
1100 mm
(35.443.3") | 870 mm | Similar |
| Ground Clearance | 83 mm (3.3") | | |
| Battery (SLA/Lithium) | 24V 15ah | 28 Ah (C5) AGM
batteries | It doesn't affect the
safety. |
| Weight of battery
(SLA/Lithium) | 9.2 kg/4kg (20/9 lbs) | | It doesn't affect the
safety. |
| | | | |
| Slope Grade Ability | 8
9 degree | 12% | Similar |
| Travel Distance
SLA/Lithium | Up to 10/16.5 km (Up
to 6.2/10.2 mile) | 15 km | It doesn't affect the
safety and performance. |
| Battery Charger SLA | 2A Off Board | | It doesn't affect the
safety and performance. |
| Battery Charger
Lithium | 4A Off Board | | |
| Armrest Height | 160215 mm
(6.3
8.5") | 225350 mm | Similar |
| Brake | Dynamic Braking and
Electromagnetic
Brake | | Similar |
| Brake distance-
Normal operation
(Horizontal-Forward-Max
speed)
Adjustable from software according
to market demand.
| 1.0
1.5 m/s | | It doesn't affect the
safety and performance.
(Ref. Appendix 7.3~7.6) |
| Attendant joystick
(Optional) | Detachable joystick
either mount on power
chair or handle bar. | | |

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Image /page/9/Picture/0 description: The image shows the word "SupnChair" in a stylized font. The letters are black and the word is written in a single line. The "A" in "Chair" is stylized to look like a chair.

Section 5 510(k) Summary

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Image /page/10/Picture/0 description: The image shows the word "Supachair" in a stylized font. The letters are all lowercase except for the "C" and "R", which are uppercase. The "A"s are shaped like triangles without the horizontal line. The text is black and the background is white.

5.4 Safety and Effectiveness

The substantially equivalence to other commercially product (powered wheelchair) OTTO BOCK HEALTHCARE, LP, A-200 Powered Wheelchair (K052706). The comparison table on above list the primary technical aspects and specifications that are pertinent to powered wheelchair. The "SupaChair" powered wheelchair is as safe and effective as the predicate devices.

11

Sup^Ch^iR

5.5 Non-clinical Testing

"SupaChair" powered wheelchair has done the series test to confirmation its safety and effectiveness in pre-clinical test. The tests are conducted with ISO 7176 serial standards. All test results are in compliance with it and were similar to predicate device.

  • ISO 7176-1 : Static stability test ●
  • ISO 7176-2 : Dynamic stability test ●
  • ISO 7176-3 : Efficiency of brakes tests ●
  • ISO 7176-4 : Theoretical distance range tests
  • ISO 7176-5 : Overall dimensions, Mass, Turning, Diameter tests
  • ISO 7176-6 : Maximum speed, acceleration and retardation tests
  • ISO 7176-7 : Seating and wheel dimension tests ●
  • ISO 7176-8 : Static, impact and fatique strengths tests
  • ISO 7176-9 : Climatic tests
  • ISO 7176-10 : Obstacle-climbing ability tests ●
  • ISO 7176-11 : Test dummies ●
  • ISO 7176-13 : Determination of coefficient of friction of test surfaces
  • ISO 7176-14 : Power and control system ●
  • ISO 7176-15 : Information disclosure, documentation and labeling
  • ISO 7176-21 (EN 12184) : EMC test
  • ISO 7176-25 : Batteries and chargers for powered wheelchairs ●
  • IEC 62133 : 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.

12

Sup^Chair

5.6 Conclusion

"SupaChair" powered wheelchair is a safe, reliable and effective medical device, meeting all declared requirements of its intended use and the device does not introduce new risks and does not present any adverse health effects or safety risks to patients when used as intended.