K Number
K182946
Device Name
Invacare TDX SP2-HD with Captain's Seat
Date Cleared
2018-12-11

(49 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The indication for use of the Invacare® TDX® SP2-HD with Captain's Seat is to provide mobility and positioning to persons limited to a sitting position.
Device Description
The subject device is an update to the existing previously cleared Invacare® TDX® SP2 Power Wheelchair (K170507) with LiNX Electronics and Ultra Low Maxx Seating System. The updated subject version of the Invacare® TDX® SP2 Power Wheelchair has the following changes: - Increase in the weight capacity of the previously cleared device from 300 lb to 450 lb. Invacare® TDX® SP2 Power Wheelchair is a battery-powered, motor-driven powered wheelchair, controlled by the LiNX® control system with enhanced suspension and additional back, arm and leg rest types. The subject device is a rigid or "non-folding" type power wheelchair base with center-wheel drive capability, two casters in the rear and two casters in the front. It is powered by two 12-volt DC batteries and two 4-pole single stage drive motors. No new accessories were added to the new device.
More Information

Not Found

No
The document describes a power wheelchair with updated weight capacity and standard control systems. There is no mention of AI or ML in the device description, intended use, or performance studies.

No.
The device is a power wheelchair, a mobility aid that provides positioning and mobility to individuals limited to a sitting position, which is not considered a therapeutic function.

No
The device is described as a power wheelchair used for mobility and positioning, not for diagnosing medical conditions.

No

The device description clearly states it is a battery-powered, motor-driven powered wheelchair, which is a physical hardware device, not software only.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is to "provide mobility and positioning to persons limited to a sitting position." This describes a device used on a patient for physical support and movement, not a device used to examine specimens outside the body to diagnose or monitor a condition.
  • Device Description: The description details a power wheelchair with components like batteries, motors, and a control system. This is consistent with a mobility aid, not an IVD.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in samples
    • Providing diagnostic information about a disease or condition

Therefore, the Invacare® TDX® SP2-HD with Captain's Seat is a medical device for mobility and positioning, not an In Vitro Diagnostic device.

N/A

Intended Use / Indications for Use

The indication for use of the Invacare® TDX® SP2-HD with Captain's Seat is to provide mobility and positioning to persons limited to a sitting position.

Product codes (comma separated list FDA assigned to the subject device)

ITI

Device Description

The subject device is an update to the existing previously cleared Invacare® TDX® SP2 Power Wheelchair (K170507) with LiNX Electronics and Ultra Low Maxx Seating System. The updated subject version of the Invacare® TDX® SP2 Power Wheelchair has the following changes:

  • · Increase in the weight capacity of the previously cleared device from 300 lb to 450 lb.
    Invacare® TDX® SP2 Power Wheelchair is a battery-powered, motor-driven powered wheelchair, controlled by the LiNX® control system with enhanced suspension and additional back, arm and leg rest types. The subject device is a rigid or "non-folding" type power wheelchair base with center-wheel drive capability, two casters in the rear and two casters in the front. It is powered by two 12-volt DC batteries and two 4-pole single stage drive motors. No new accessories were added to the new device.

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

Adult Patient Only

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)

Design verification and validation testing was performed on the subject device meets the performance requirements and is substantially equivalent to the predicate device identified throughout this submission and do not raise any new questions of safety and effectiveness. The acceptance criteria for the full verification of the design and acceptance criteria for each section of the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) testing standard was met.
Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) testing was performed to demonstrate that the subject Invacare® TDX® SP2-HD with Captain's Seat meets the performance requirements and is substantially equivalent to the predicate device identified throughout this submission and do not raise any new questions of safety and effectiveness.
The following testing was performed according to FDA recognized consensus standards:

  • ANSI/RESNA WC-1:2009 Section 1: Determination of Static Stability ●
  • . ANSI/RESNA WC-1:2009 Section 2: Determination of Dynamic Stability of electrically Powered Wheelchairs
  • ANSI/RESNA WC-1:2009 Section 3: Determination of Effectiveness of Brakes .
  • ANSI/RESNA WC-2:2009 Section 4: Energy Consumption of Electrically Powered ● Wheelchairs and Scooters for Determination of Theoretical Distance Range
  • ANSI/RESNA WC-1:2009 Section 5: Determination of Dimensions, Mass . and Maneuvering Space
  • ANSI/RESNA WC-2:2009 Section 6: Determination of Maximum Speed, . Acceleration and Deceleration of Electrically Powered Wheelchairs
  • ANSI/RESNA WC-1:2009 Section 7: Method of Measurement of Seating and . Wheel Dimensions
  • · ANSI/RESNA WC-1:2009 Section 8: Requirements and Test Methods for Static, Impact and Fatigue Strengths
  • ANSI/RESNA WC-2:2009 Section 9: Climatic Tests for Electrically Powered Wheelchairs
  • ANSI/RESNA WC-2:2009 Section 10: Determination of Obstacle-Climbing Ability . of Electrically Powered Wheelchairs
  • ANSI/RESNA WC-1:2009 Section 11: Test Dummies .
  • ANSI/RESNA WC-1:2009 Section 13: Determination of Coefficient of ● Friction of Test Surfaces
  • . ANSI/RESNA WC-2:2009 Section 14: Power and Control Systems for Electrically Powered Wheelchairs
  • ANSI/RESNA WC-1 :2009 Section 15: Requirements for Information . Disclosure, Documentation and Labeling
  • ANSI/RESNA WC-1:2009 Section 16: Resistance to Ignition of Upholstered . Parts
  • . ANSI/RESNA WC-4: Section 19: Wheelchairs Used as Seats in Motor Vehicles
  • · ANSI/RESNA WC-2: 2009 Section 21: Requirements and Test Methods for Electromagnetic Compatibility of Electrically Powered Wheelchairs and Motorized Scooters
  • ISO 7176-25 First Edition 2013 Wheelchairs Part 25: Batteries and Chargers for . Powered Wheelchairs
  • . ISO 14971:2012 - Medical Devices - Application of Risk Management to Medical Devices
    Verification testing demonstrated that the subject Invacare® TDX® SP2-HD with Captain's Seat is substantially equivalent to the marketed predicate device.

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

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

Invacare® TDX® SP2 Power Wheelchair (K170507)

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

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).

0

Image /page/0/Picture/0 description: The image contains the logos of the Department of Health & Human Services and the U.S. Food & Drug Administration (FDA). The Department of Health & Human Services logo is on the left, featuring a stylized human figure. To the right of it is the FDA logo, with the letters "FDA" in a blue square, followed by the words "U.S. FOOD & DRUG ADMINISTRATION" in blue text.

December 11, 2018

Invacare Corporation Elijah Wreh Regulatory Affairs Manager One Invacare Way Elyria, Ohio 44035

Re: K182946

Trade/Device Name: Invacare TDX SPV2-HD with Captain's Seat Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: October 22, 2018 Received: October 23, 2018

Dear Elijah Wreh:

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

1

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 Part 809); 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/CombinationProducts/GuidanceRegulatoryInformation/ucm597488.html; 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 http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm.

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) K182946

Device Name Invacare® TDX® SP2-HD with Captain's Seat

Indications for Use (Describe)

The indication for use of the Invacare® TDX® SP2-HD with Captain's Seat is to provide mobility and positioning to persons limited to a sitting position.

Type of Use (Select one or both, as applicable)Prescription Use (Part 21 CFR 201 Subpart D) Over-The-Counter Use (21 CFR 201 Subpart C)Prescription Use (Part 21 CFR 201 Subpart D)Over-The-Counter Use (21 CFR 201 Subpart C)
Prescription Use (Part 21 CFR 201 Subpart D)
Over-The-Counter Use (21 CFR 201 Subpart C)

Prescription Use (Part 21 CFR 801 Subpart D)

| | Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

SUBMITTER per 21 CFR 807.92(a)(1):

Invacare Corporation One Invacare Way Elyria, OH 44035 Phone: (440) 329-6840 Email: ewreh@invacare.com

CONTACT PERSON: Elijah Wreh Regulatory Affairs Manager

MANUFACTURER:

Invacare Corporation 1200 Taylor Street Elyria, OH 44035

Date Prepared per 21 CFR 807.92(a)(1):

December 10, 2018

DEVICE INFORMATION per 21 CFR 807.92(a)(2)

Name of Device:Invacare® TDX® SP2-HD with Captain's Seat
Common or Usual Name:Wheelchair, Powered
Classification Name:Powered Wheelchair 21 CFR § 890.3860
Regulatory Class:2
Product Code:ITI
PREDICATE DEVICE:Invacare® TDX® SP2 Power Wheelchair (K170507)
Patient Population:Adult Patient Only

4

DEVICE DESCRIPTION per 21 CFR 808.92(a)(4)

The subject device is an update to the existing previously cleared Invacare® TDX® SP2 Power Wheelchair (K170507) with LiNX Electronics and Ultra Low Maxx Seating System. The updated subject version of the Invacare® TDX® SP2 Power Wheelchair has the following changes:

  • · Increase in the weight capacity of the previously cleared device from 300 lb to 450 lb.
Model NumberDescription
TDXSP2V-HDInvacare® TDX® SP2-HD with Captain's Seat

Invacare® TDX® SP2 Power Wheelchair is a battery-powered, motor-driven powered wheelchair, controlled by the LiNX® control system with enhanced suspension and additional back, arm and leg rest types. The subject device is a rigid or "non-folding" type power wheelchair base with center-wheel drive capability, two casters in the rear and two casters in the front. It is powered by two 12-volt DC batteries and two 4-pole single stage drive motors. No new accessories were added to the new device.

INTENDED USE per 21 CFR 807.92(A)(5)

The intended use of the device is to provide mobility and positioning to persons limited to a sitting position.

INDICATIONS FOR USE per FORM FDA 3881

The indication for use of the Invacare® TDX® SP2-HD with Captain's Seat is to provide mobility and positioning to persons limited to a sitting position.

INDICATIONS FOR USE (IFU) COMPARISON

The Indications for Use statement for the subject device is the same as the previously cleared predicate device. The determination was made based on Section 513(i)(1)(E)(i) of the FD&C Act.

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COMPARISON of TECHNOLOGICAL CHARACTERISTICS with the PREDICATE DEVICE per 21 CFR 807.92(a)(6)

The device comparison showed that the subject device is substantially equivalent in intended use, design, materials, and operational principles to the previously cleared predicate device in regard to provide mobility and positioning to persons limited to a sitting position.

The subject device and predicate device are battery powered, motor driven, rigid, non-folding type power wheelchairs with a micro-processor controlled electronic control systems, and nonpowered and powered seating.

The subject device has fixed non-powered and elevate seating systems that are similar to the previously cleared Invacare® TDX® SP2 Power Wheelchair (K170507).

BASIS of SUBSTANTIAL EQUIVALENCE per 21 CFR 807.100(b)(2)(ii)(A)

The substantial equivalence of the subject device was determined as per the FDA guidance document, "The 510(k) Program: Evaluating Substantial Equivalence in Premarket Notifications [510(k)/' and the technological characteristics which include materials, design, and other device related features, as defined in section 513(i)(1)(B) of the FD&C Act and 21 CFR 807.100(b)(2)(ii)(A).

The subject device components are safe and effective as the predicate device and do not raise different questions of safety and effectiveness. The design verification and validation testing, device comparison, and dimensional analysis demonstrates that the subject device components are substantially equivalent to the predicate device in regard to the following:

The data generated from the subject device design verification and validation test reports support a finding of substantial equivalence regarding device comparison, wireless capability and coexistence, dimensional analysis, device specifications, and design characteristics.

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Indications for Use (IFU) Comparison Table

| Description | Subject Device Invacare® TDX® SP2-HD with
Captain's Seat | Predicate Device
Invacare® TDX® SP2 Power Wheelchair |
|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------|
| 510(k) Number | Pending Submission | K170507 |
| Indications for
Use | The indication for use of the Invacare® TDX® SP2 Power
Wheelchair is to provide mobility and positioning to
persons limited to a sitting position. | The indication for use of the Invacare® TDX® SP2 Power Wheelchair
is to provide mobility and positioning to persons limited to a sitting
position. |

Design Characteristics Comparison – Finished Medical Device

| Description | Subject Device Invacare® TDX® SP2-HD with
Captain's Seat | Predicate Device
Invacare® TDX® SP2 Power Wheelchair |
|---------------------------------|-------------------------------------------------------------|---------------------------------------------------------------|
| Base Configuration | Centre Wheel Drive | Centre Wheel Drive |
| Suspension | Enhanced SureStep® Suspension | Enhanced SureStep® Suspension |
| Stability Lock | Locking gas cylinder | Locking gas cylinder |
| Speed | 5mph | 5mph or 5.8mph |
| Braking System | Electro-mechanical Friction Brake | Electro-mechanical Friction Brake |
| Range | GP24 Batteries > 20.7 miles | 22NF Batteries > 13.7 miles OR
GP24 Batteries > 20.7 miles |
| Weight Capacity | 450lb. | 300lb. |
| Length (without leg rests) | 31.5" to 45.3"
(depending on seat configuration) | 31.5" to 45.3"
(depending on seat configuration) |
| Base Width | 25.5" | 24" or 25.5"
(depending on battery type) |
| Incline Capability | 9° | 9° |
| Total Weight
(seat and base) | 291-450lbs.
(depending on seat configuration) | 291-450lbs.
(depending on seat configuration) |
| Obstacle Climbing | Forward 2.76" AND
Reverse 0.79" | Forward 2.95" AND
Reverse 0.95" |
| Drive Wheel Frame Material | Aluminum | Aluminum |
| Transport Option | Brackets bolt on frame | Brackets bolt on frame |

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Design Characteristics Comparison – Seating System

DescriptionSubject DevicePredicate Device
Invacare® TDX® SP2-HD with Captain's SeatInvacare® TDX® SP2 Power Wheelchair (K170507)
Seat TypesFixed, ElevateFixed, Tilt/Recline/Elevate, Tilt/Recline, Recline, Elevate, Tilt/Elevate, Tilt Only.
Seat Widths22" to 24"16" to 24"
Seat Depths18" to 22"16" to 23"
Back Heights18.5"18" to 25" (tilt only) OR
20" to 27" (tilt and recline)
UpholsteryVinylMeshtex, Startex, Spacetex, O-Vinyl, Polyester
Elevating Seat Range10"12"
Tilt RangeN/A50°
Recline Range117°168°

POWER BASE SUBSTANTIAL EQUIVALENCE TABLE

| Description | Subject Device
Invacare® TDX® SP2-HD with Captain's Seat
(Pending) | Predicate Device
Invacare® TDX® SP2 Power Wheelchair
(K170507) |
|---------------------------------|--------------------------------------------------------------------------|----------------------------------------------------------------------|
| Base Configuration | Centre Wheel Drive | Centre Wheel Drive |
| Suspension | Enhanced SureStep® Suspension | Enhanced SureStep® Suspension |
| Stability Lock | Locking gas cylinder | Locking gas cylinder |
| Stability Lock Mechanism | Internal locking valve mechanism in gas cylinder | Internal locking valve mechanism in gas cylinder |
| Stability Lock Side Dependency | Both sides lock/unlock together | Both sides lock/unlock together |
| Motors | 4-Pole SSD | 4-Pole SSD |
| Motor Voltage | 24V nominal | 24V nominal |
| Motor Power | 24V DC/324W (@13.5Amps) | 24V DC/324W (@13.5Amps) |
| Speed | 5mph | 5mph, or 5.8mph |
| Number of Batteries | 2 | 2 |
| Battery Types | GP24 | 22NF OR GP24 |
| Battery Chemistry | Sealed VRLA Gel Batteries | Sealed VRLA Gel Batteries |
| Battery Operating Voltage | 24V nominal
(2 * 12V) | 24V nominal
(2 * 12V) |
| Battery Amp-Hour Rating | GP24 = 63amp-hrs (C5) | 22NF = 43.2amp-hrs (C5)
GP24 = 63amp-hrs (C5) |
| Battery Weight | GP24 = 52lbs. | 22NF = 37lbs.
GP24 = 52lbs. |
| | Subject Device | Predicate Device |
| Description | Invacare® TDX® SP2-HD with Captain's Seat
(Pending) | Invacare® TDX® SP2 Power Wheelchair
(K170507) |
| Battery Chargers | 8-amp off board charger
(110V) | 8-amp off board charger
(110V) |
| Braking System | Electro-mechanical Friction Brake | Electro-mechanical Friction Brake |
| Range | GP24 Batteries > 20.7 miles | 22NF Batteries > 13.7 miles OR
GP24 Batteries > 20.7 miles |
| Stopping Distance | 45.7" to 69.3"
(depending on chair configuration) | 45.7" to 69.3"
(depending on chair configuration) |
| Weight Capacity | 450lbs. | 300lbs. |
| Length (without leg rests) | 31.5" to 55.4" | 31.5" to 55.4" |
| Base Width | 25.5" | 24" OR 25.5"
(depending on battery type) |
| Front Forks | Single OR double sided | Single OR double sided |
| Tires | Black gel tires.
Foam filled OR pneumatic | Black gel tires.
Foam filled OR pneumatic |
| Drive Wheel Size | 14" x 3" | 14" x 3" |
| Castor Size | 6" x 2" | 6" x 2" |
| Front Castor Force | Applied by proportional force gas spring | Applied by proportional force gas spring |
| Damping on Front Swing Arm | Gas spring has damping | Gas spring has damping |
| Incline Capability | 9° | 9° |
| Turning Diameter | 50.4" to 65.4"
(depending on seat configuration) | 50.4" to 65.4"
(depending on seat configuration) |
| Base Weight
(with batteries) | 264lbs (GP24 Batteries) | 264lbs (GP24 Batteries) |
| Total Weight
(seat and base) | 291 to 450lbs.
(depending on seat configuration) | 291 to 450lbs.
(depending on seat configuration) |
| Ground Clearance | > 2.5" | > 2.5" |
| Obstacle Climbing | Forward 2.95" AND
Reverse 0.98" | Forward 2.95" AND
Reverse 0.98" |
| Motor Gearbox Sound Level | 54dBa | 54dBa |
| Drive Wheel Frame Material | Aluminum | Aluminum |
| Transport Option | Brackets bolt on frame | Brackets bolt on frame |

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9

DESIGN VERIFICATION AND VALIDATION TESTING DATA

Design verification and validation testing was performed on the subject device meets the performance requirements and is substantially equivalent to the predicate device identified throughout this submission and do not raise any new questions of safety and effectiveness. The acceptance criteria for the full verification of the design and acceptance criteria for each section of the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) testing standard was met.

Risk Management

Risk Management has been conducted in accordance with ISO 14971:2007 - Medical Devices -Application of Risk Management to Medical Devices.

Non-Clinical Test per 21 CFR 807.92(b)(1)

Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) testing was performed to demonstrate that the subject Invacare® TDX® SP2-HD with Captain's Seat meets the performance requirements and is substantially equivalent to the predicate device identified throughout this submission and do not raise any new questions of safety and effectiveness.

The following testing was performed according to FDA recognized consensus standards:

  • ANSI/RESNA WC-1:2009 Section 1: Determination of Static Stability ●
  • . ANSI/RESNA WC-1:2009 Section 2: Determination of Dynamic Stability of electrically Powered Wheelchairs
  • ANSI/RESNA WC-1:2009 Section 3: Determination of Effectiveness of Brakes .
  • ANSI/RESNA WC-2:2009 Section 4: Energy Consumption of Electrically Powered ● Wheelchairs and Scooters for Determination of Theoretical Distance Range
  • ANSI/RESNA WC-1:2009 Section 5: Determination of Dimensions, Mass . and Maneuvering Space
  • ANSI/RESNA WC-2:2009 Section 6: Determination of Maximum Speed, . Acceleration and Deceleration of Electrically Powered Wheelchairs
  • ANSI/RESNA WC-1:2009 Section 7: Method of Measurement of Seating and . Wheel Dimensions
  • · ANSI/RESNA WC-1:2009 Section 8: Requirements and Test Methods for Static, Impact and Fatigue Strengths
  • ANSI/RESNA WC-2:2009 Section 9: Climatic Tests for Electrically Powered Wheelchairs

10

  • ANSI/RESNA WC-2:2009 Section 10: Determination of Obstacle-Climbing Ability . of Electrically Powered Wheelchairs
  • ANSI/RESNA WC-1:2009 Section 11: Test Dummies .
  • ANSI/RESNA WC-1:2009 Section 13: Determination of Coefficient of ● Friction of Test Surfaces
  • . ANSI/RESNA WC-2:2009 Section 14: Power and Control Systems for Electrically Powered Wheelchairs
  • ANSI/RESNA WC-1 :2009 Section 15: Requirements for Information . Disclosure, Documentation and Labeling
  • ANSI/RESNA WC-1:2009 Section 16: Resistance to Ignition of Upholstered . Parts
  • . ANSI/RESNA WC-4: Section 19: Wheelchairs Used as Seats in Motor Vehicles
  • · ANSI/RESNA WC-2: 2009 Section 21: Requirements and Test Methods for Electromagnetic Compatibility of Electrically Powered Wheelchairs and Motorized Scooters
  • ISO 7176-25 First Edition 2013 Wheelchairs Part 25: Batteries and Chargers for . Powered Wheelchairs
  • . ISO 14971:2012 - Medical Devices - Application of Risk Management to Medical Devices

Verification testing demonstrated that the subject Invacare® TDX® SP2-HD with Captain's Seat is substantially equivalent to the marketed predicate device.

Animal Study

Animal testing was not required for this submission.

Clinical Testing

Clinical testing was not required for this submission.

CONCLUSIONS per 21 CFR 807.92(b)(3)

The subject device has the same intended use and technological characteristics as the predicate device. The design verification and validation data support the safety and performance of the subject device and demonstrate that the subject device will perform as intended in the specified use conditions. Therefore, the subject Invacare® TDX® SP2-HD with Captain's Seat accessories are compatible with the previously cleared Invacare® TDX® SP2 Power Wheelchair (K170507) device and demonstrate a basis of substantial equivalence.