K Number
K211574
Device Name
Extreme X8
Manufacturer
Date Cleared
2021-07-09

(49 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Extreme X8 Power Wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position who have the capability of operating a power wheelchair.
Device Description
The Extreme X8 Power Wheelchair is designed for everyday use for both indoor and outdoor environments including care facilities and private residences. The subject device is intended to provide mobility to persons who are restricted or limited to a sitting position. The Extreme X8 Power Wheelchair is a battery powered, electric motor driven device that can be used on both indoor and outdoor surfaces (i.e., concrete, asphalt, indoor flooring such as carpet, gravel, grass, and bark/woodchips).The Extreme X8 Power Wheelchair offers two basic seating options: MPS and Rehab. The MPS option is more static and does not allow for additional aftermarket cushions. The Rehab option is more adjustable to adhere to recommendations from the user's physician or physical therapist.
More Information

No
The summary does not mention AI, ML, or any related concepts like image processing, training sets, or specific algorithms typically associated with AI/ML in medical devices. The performance studies focus on standard wheelchair safety and performance metrics.

Yes
The device is described as "intended for medical purposes to provide mobility to persons restricted to a sitting position," which aligns with the definition of a therapeutic device that aims to treat or mitigate a condition.

No

Explanation: The device is a power wheelchair, a mobility aid for individuals restricted to a sitting position. Its purpose is to provide mobility, not to diagnose a medical condition or ailment.

No

The device description clearly states it is a "battery-operated device with wheels" and a "battery powered, electric motor driven device," indicating it is a physical hardware device, not software-only. While software is mentioned in the performance studies (IEC 62304), it is part of a larger hardware system.

Based on the provided information, the Extreme X8 Power Wheelchair is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • Intended Use: The intended use is to "provide mobility to persons restricted to a sitting position who have the capability of operating a power wheelchair." This is a mechanical function for physical assistance, not a diagnostic test performed on samples from the human body.
  • Device Description: The description details a battery-operated device with wheels for mobility. It focuses on physical features, power systems, and seating options. There is no mention of analyzing biological samples or providing diagnostic information.
  • Lack of IVD Indicators: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing blood, urine, tissue, or other biological samples.
    • Detecting or measuring substances in the body.
    • Providing information for the diagnosis, monitoring, or treatment of a disease or condition based on in vitro analysis.

The device is clearly a mobility aid, falling under a different regulatory category than IVDs.

N/A

Intended Use / Indications for Use

The Extreme X8 Power Wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position who have the capability of operating a power wheelchair.

Product codes

ITI

Device Description

The Extreme X8 Power Wheelchair is designed for everyday use for both indoor and outdoor environments including care facilities and private residences. The subject device is intended to provide mobility to persons who are restricted or limited to a sitting position.

The Extreme X8 Power Wheelchair is a battery powered, electric motor driven device that can be used on both indoor and outdoor surfaces (i.e., concrete, asphalt, indoor flooring such as carpet, gravel, grass, and bark/woodchips).The Extreme X8 Power Wheelchair offers two basic seating options: MPS and Rehab. The MPS option is more static and does not allow for additional aftermarket cushions. The Rehab option is more adjustable to adhere to recommendations from the user's physician or physical therapist.

The Extreme X8 Power Wheelchair includes the following accessories:

  • Extra spreader bar
  • Slide in table ●
  • Lights
  • Luggage rack
  • Accessory charger ●
  • Posture belt
  • Roho cushion
  • Jay cushion
  • MPS push rail
  • MPS peg push handle
  • Scooter stopper ●
  • Retractable docking pin
  • Fold forward kit
  • Steering lock

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

adults and children

Intended User / Care Setting

Magic Mobility power chairs are designed for the exclusive use of people (adults and children) who are unable to walk or have limited mobility and have the cognitive, physical and visual ability to control the vehicle safety. The Magic Mobility Extreme X8 is intended to be selfpropelled on a range of surfaces. The All-Terrain tires can be used on both indoor and outdoor surfaces (i.e., concrete, asphalt, indoor flooring such as carpet, gravel, grass, and bark/woodchips).

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)

The following tests were performed to demonstrate substantial equivalence based on current industry and FDA recognized standards. The results of these tests indicate that the Extreme X8 Power Wheelchair is substantially equivalent to the predicate device.

PERFORMANCE

  • Static stability (per ISO 7176-1) ●
  • Dynamic stability (per ISO 7176-2) ●
  • Effectiveness of brakes (per ISO 7176-3)
  • Energy consumption (per ISO 7176-4) ●
  • . Dimensions, mass, and maneuvering space (per ISO 7176-5)
  • Maximum speed, acceleration, and deceleration (per ISO 7176-6)
  • Measurement of seat and wheel dimensions (per ISO 7176-7)
  • Static, impact, and fatigue (per ISO 7176-8)
  • Climatic test (per ISO 7176-9)
  • Obstacle climbing (per ISO 7176-10)
  • Test dummies (per ISO 7176-11)
  • Power and control systems for power wheelchairs (per ISO 7176-14)
  • Documentation and labeling (per ISO 7176-15)
  • Resistance to ignition (per ISO 7176-16)
  • Dynamic Test (per ISO 71716-19)
  • Vocabulary (per ISO 7176-26)

EMC AND ELECTRICAL SAFETY

  • EMC testing (per ISO 7176-21) ●
  • Batteries and chargers per (per ISO 7176-25)

BIOCOMPATIBILITY

  • Evaluation and testing within a risk management process (per ISO 10993-1) ●
  • In vitro cytotoxicity (per ISO 10993-5)

The materials used in the subject device are identical composition, formulation processing, sterilization, and geometry as the materials found in the Extreme 4x4-X8 Power Wheelchair by Magic Mobility LLC (K090350) and the Quickie Q700-UP M by Sunrise Medical (US) LLC (K172384) device. Furthermore, the Extreme X8 Power Wheelchair has the same nature of tissue contact and contact duration as the predicate and reference devices. Therefore, based on previous use and the cytotoxicity testing conducted, the subject device is considered to have met the requirements of ISO 10993-1 and FDA's Guidance for Industry and Food and Drug Administration Staff – Use of International ISO 10993-1, "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process.

SOFTWARE

  • Software life cycle process (per IEC 62304)

CONCLUSION
Based on the testing performed (including wheelchair dynamic testing and flammability) it can be concluded that the subject device does not raise new issues of safety or effectiveness compared to the predicate device. The similar indications for use, technological characteristics, and performance characteristics for the proposed Extreme X8 Power Wheelchair are assessed to be substantially equivalent to the predicate device.

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

Not Found

Predicate Device(s)

K090350

Reference Device(s)

K172384

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

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July 9, 2021

Magic Mobility % Michelle Rubin-Onur Senior Regulatory Specialist AcKnowledge Regulatory Strategies, LLC 2251 San Diego Ave Suite B-257 San Diego, California 92110

Re: K211574

Trade/Device Name: Extreme X8 Power Wheelchair Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: May 20, 2021 Received: May 21, 2021

Dear Michelle Rubin-Onur:

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/cdrl/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.

1

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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); 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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). 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 (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely.

Heather Dean, PhD Assistant Director, Acute Injury Devices Team DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K211574

Device Name Extreme X8 Power Wheelchair

Indications for Use (Describe)

The Extreme X8 Power Wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position who have the capability of operating a power wheelchair.

Type of Use (Select one or both, as applicable)

_ Prescription Use (Part 21 CFR 801 Subpart D)

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)

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510(k) Summary

DATE PREPARED

July 9, 2021

MANUFACTURER AND 510(k) OWNER

Magic Mobility 3 International Court, Scoresby, VIC, 3179 Australia Telephone: Official Contact: Alex Suen, Quality Assurance and Regulatory Affairs Manager

REPRESENTATIVE/CONSULTANT

Michelle Rubin-Onur, Ph.D. Matthieu Kirkland, M.S. AcKnowledge Regulatory Strategies, LLC Telephone: Email: mrubin@acknowledge-rs.com

DEVICE INFORMATION

Proprietary Name/Trade Name:Extreme X8 Power Wheelchair
Common Name:Wheelchair, Powered
Regulation Number:21 CFR 890.3860
Class:Class II
Product Code:ITI
Premarket Review:Neuromodulation and Physical Medicine Devices (DHT5B)
Review Panel:Physical Medicine

PREDICATE DEVICE IDENTIFICATION

The Extreme X8 Power Wheelchair is substantially equivalent to the following predicates:

510(k) NumberPredicate Device Name / ManufacturerPredicate Relationship
K090350Extreme 4x4-X8 / Innovation In MotionPredicate Device
K172384Quickie® Q700-UP M / Sunrise Medical (US) LLCReference Device

4

DEVICE DESCRIPTION

The Extreme X8 Power Wheelchair is designed for everyday use for both indoor and outdoor environments including care facilities and private residences. The subject device is intended to provide mobility to persons who are restricted or limited to a sitting position.

The Extreme X8 Power Wheelchair is a battery powered, electric motor driven device that can be used on both indoor and outdoor surfaces (i.e., concrete, asphalt, indoor flooring such as carpet, gravel, grass, and bark/woodchips).The Extreme X8 Power Wheelchair offers two basic seating options: MPS and Rehab. The MPS option is more static and does not allow for additional aftermarket cushions. The Rehab option is more adjustable to adhere to recommendations from the user's physician or physical therapist.

The Extreme X8 Power Wheelchair includes the following accessories:

  • Extra spreader bar
  • Slide in table ●
  • Lights
  • Luggage rack
  • Accessory charger ●
  • Posture belt
  • Roho cushion
  • Jay cushion
  • MPS push rail
  • MPS peg push handle
  • Scooter stopper ●
  • Retractable docking pin
  • Fold forward kit
  • Steering lock

INTENDED USE

Magic Mobility power chairs are designed for the exclusive use of people (adults and children) who are unable to walk or have limited mobility and have the cognitive, physical and visual ability to control the vehicle safety. The Magic Mobility Extreme X8 is intended to be selfpropelled on a range of surfaces. The All-Terrain tires can be used on both indoor and outdoor surfaces (i.e., concrete, asphalt, indoor flooring such as carpet, gravel, grass, and bark/woodchips).

5

INDICATIONS FOR USE

The Extreme X8 Power Wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position who have the capability of operating a power wheelchair.

COMPARISON OF TECHNOLOGICAL CHARACTERISTICS

Magic Mobility believes that the Extreme X8 Power Wheelchair is substantially equivalent to the predicate device based on the information summarized here:

The subject device has a similar design and dimensions and uses similar or identical materials as the device cleared in K090350. The subject device has the same intended use and similar technological characteristics (i.e., base technology and OEM joystick control) to the devices cleared in K093050 and K172384. The subject device has the same intended use environment, including off road capabilities, as the device cleared in K090350. The subject device uses the same software as the device cleared in K172384. The Extreme X8 Power Wheelchair has undergone testing to ensure that any differences in technological characteristics (i.e., battery, castor wheels, and no anti-pitch mechanism) do not affect safety and effectiveness when compared to the predicate device.

6

Subject DevicePredicate DeviceReference Device
Magic MobilityInnovation In MotionSunrise Medical (US) LLCStatement of Equivalence
Extreme X8 Power WheelchairExtreme 4x4-X8Quickie® Q700-UP M
K090350K172384
Indications for UseThe Extreme X8 Power Wheelchair is a
battery-operated device with wheels
that is intended for medical purposes
to provide mobility to persons
restricted to a sitting position who have
the capability of operating a power
wheelchair.The intended use of the X8 power
wheelchair is to provide mobility to
persons limited to a sitting position, who
have the capability of operating a power
wheelchair.The Sunrise Medical Quickie®
Q700-UP M power wheelchairs
are battery operated devices,
that are indicated for medical
purposes to provide mobility
and repositioning of the user,
including a stand-up feature.Identical to predicate device. No
impact on safety or
effectiveness.
Product Codes /
Regulation NumberITI / 21 CFR 890.3860ITI / 21 CFR 890.3860IPL / 21 CFR 890.3900Identical to predicate device. No
impact on safety and
effectiveness.
Regulation DescriptionPowered WheelchairPowered WheelchairStandup WheelchairIdentical to predicate device. No
impact on safety and
effectiveness.
Technical Specifications
General
Maximum User Weight
(lbs.)400400265Identical to predicate device. No
impact on safety and
effectiveness.
Storage Temperature
(°C)-40 to 70°C-40 to 70°C-40 to 70Identical to predicate and
reference devices. No impact on
safety and effectiveness.
Location for UseIndoors and outdoors including care
facilities, residences, and soft/rough
terrain.Indoors and outdoors including care
facilities, and residencesIndoors and outdoors including
care facilities, and residencesIdentical to predicate and
reference devices. No impact on
safety and effectiveness.
Frame MaterialSteelSteelSteel and aluminumIdentical to predicate and
reference devices. No impact on
safety and effectiveness.
BiocompatibilityUses materials common to many
wheelchairsUses materials common to many
wheelchairsUses materials common to
many wheelchairsIdentical to predicate and
reference devices. No impact on
safety and effectiveness.
Ground Clearance4"4"UnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Base
Overall Dimensions
(length by width;
inches)45.25"x37"45.25"x37"25"x36"Identical to predicate device. No
impact on safety and
effectiveness.
Subject DevicePredicate DeviceReference Device
Magic MobilityInnovation In MotionSunrise Medical (US) LLCStatement of Equivalence
Extreme X8 Power WheelchairExtreme 4x4-X8Quickie® Q700-UP M
K090350K172384
Rolling Base Weight
(lbs.)145145152Identical to predicate device. No
impact on safety and
effectiveness.
Power SourceBatteriesBatteriesBatteriesIdentical to predicate and
reference devices. No impact on
safety and effectiveness.
Battery Details2- 73 AMP/hour AGM Group 24 12-volt
Weight 55 lbs2- 73 AMP/hour AGM Group 24 12 volt
Weight 55 lbs24V (2x12V) / 73 Ah/20hIdentical to predicate device. No
impact on safety and
effectiveness.
Battery Charger Input
Voltage (volts)110110UnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Motors4-24V, 4 pole direct drive gear in line
motors/gearbox. Freewheeling
lever/motor lock releases & engages
rear motor brakes4-24V, 4 pole direct drive gear in line
motors/gearbox. Freewheeling
lever/motor lock releases & engages rear
motor brakesUnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Wheel Size (inches)4"x14"4"x14"UnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Turing Radius (inches)52"52"UnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Range (miles)15.515.5UnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Maximum Speed (mph)6.26.26 (with an option of 8)Identical to predicate device. No
impact on safety and
effectiveness.
Anti-pitch Mechanism
for ClimbingNoneNoneAdditional anti-pitch lock outIdentical to predicate device. No
impact on safety and
effectiveness.
Lift Range (inches)0-120-120-12Identical to predicate device. No
impact on safety and
effectiveness.
Tilt Range (degrees)0-500-500-50Identical to predicate device. No
impact on safety and
effectiveness.
Recline Range (degrees)0-1700-1700-172Identical to predicate device. No
impact on safety and
effectiveness.
Subject DevicePredicate DeviceReference Device
Magic MobilityInnovation In MotionSunrise Medical (US) LLCStatement of Equivalence
Extreme X8 Power WheelchairExtreme 4x4-X8Quickie® Q700-UP M
K090350K172384
impact on safety and
effectiveness.
SuspensionNoneNoneUnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Braking SystemElectromagnetic, regenerative brakes
with a free-wheeling modeElectromagnetic, regenerative brakes
with a free-wheeling modeUnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Minimum Braking
Distance at Maximum
Speed (meters)1.71.7UnknownIdentical to predicate device. No
impact on safety and
effectiveness.
User ControllerJoystick and hand control buttonsJoystick and hand control buttonsJoystick and hand control
buttonsIdentical to predicate device. No
impact on safety and
effectiveness.
Joystick MountFixed mount, height adjustable, swing-
awayFixed mount, height adjustable, swing-
awayFixed mount, height adjustable,
swing-awayIdentical to predicate device. No
impact on safety and
effectiveness.
Software
SoftwareR-Net from PGDTDynamic DX2-PMA70L electronic control
and joystickR-Net from PGDTIdentical to reference device.
No impact on safety and
effectiveness.
Seat/Armrest/Footrest
Seat Height (minimum,
inches)19"19"16.2"Identical to predicate device. No
impact on safety and
effectiveness.
Seat Width (inches)16"-24"16"-24"16"-22"Identical to predicate device. No
impact on safety and
effectiveness.
ArmrestHeight adjustable, removable, flip up
optionHeight adjustable, removable, flip up
optionUnknownIdentical to predicate device. No
impact on safety and
effectiveness.
Footrest1 or 2 pieces, fixed or flip up, angle and
height adjustable rigid footplates, and
others1 or 2 pieces, fixed or flip up, angle and
height adjustable rigid footplates, and
othersUnknownIdentical to predicate device. No
impact on safety and
effectiveness.

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8

9

SUMMARY OF NON-CLINICAL TESTING

The following tests were performed to demonstrate substantial equivalence based on current industry and FDA recognized standards. The results of these tests indicate that the Extreme X8 Power Wheelchair is substantially equivalent to the predicate device.

PERFORMANCE

  • Static stability (per ISO 7176-1) ●
  • Dynamic stability (per ISO 7176-2) ●
  • Effectiveness of brakes (per ISO 7176-3)
  • Energy consumption (per ISO 7176-4) ●
  • . Dimensions, mass, and maneuvering space (per ISO 7176-5)
  • Maximum speed, acceleration, and deceleration (per ISO 7176-6)
  • Measurement of seat and wheel dimensions (per ISO 7176-7)
  • Static, impact, and fatigue (per ISO 7176-8)
  • Climatic test (per ISO 7176-9)
  • Obstacle climbing (per ISO 7176-10)
  • Test dummies (per ISO 7176-11)
  • Power and control systems for power wheelchairs (per ISO 7176-14)
  • Documentation and labeling (per ISO 7176-15)
  • Resistance to ignition (per ISO 7176-16)
  • Dynamic Test (per ISO 71716-19)
  • Vocabulary (per ISO 7176-26)

EMC AND ELECTRICAL SAFETY

  • EMC testing (per ISO 7176-21) ●
  • Batteries and chargers per (per ISO 7176-25)

BIOCOMPATIBILITY

  • Evaluation and testing within a risk management process (per ISO 10993-1) ●
  • In vitro cytotoxicity (per ISO 10993-5)

The materials used in the subject device are identical composition, formulation processing, sterilization, and geometry as the materials found in the Extreme 4x4-X8 Power Wheelchair by Magic Mobility LLC (K090350) and the Quickie Q700-UP M by Sunrise Medical (US) LLC (K172384) device. Furthermore, the Extreme X8 Power Wheelchair has the same nature of tissue contact and contact duration as the predicate and reference devices. Therefore, based on previous use and the cytotoxicity testing conducted, the subject device is considered to have met the requirements of ISO 10993-1 and FDA's Guidance for Industry and Food and Drug Administration Staff – Use of International ISO 10993-1, "Biological evaluation of medical devices – Part 1: Evaluation and testing within a risk management process.

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SOFTWARE

  • Software life cycle process (per IEC 62304)

CONCLUSION

Based on the testing performed (including wheelchair dynamic testing and flammability) it can be concluded that the subject device does not raise new issues of safety or effectiveness compared to the predicate device. The similar indications for use, technological characteristics, and performance characteristics for the proposed Extreme X8 Power Wheelchair are assessed to be substantially equivalent to the predicate device.