K Number
K221799
Device Name
Electric Wheelchair, Model: 9000N
Date Cleared
2022-09-16

(87 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The Electrical Wheelchair (Model: 9000N) is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to the disabled, the elderly and the infirm for short-distance travel.
Device Description
The proposed device, Electrical wheelchair, mainly powered by battery, motivated by DC motor, driven by user controlling joystick and adjusting speed. The electrical wheelchair consists of two foldable armrests, a seat cushion, a foldable frame, two rear driving wheels with hub motor/electromagnetic brake assemblies, two pivoting casters, a Lithium-ion battery, a battery charger, a controller and master module. . Wheelchair frame: Foldable for easy storage and transportation. Controller and Master module: control the forward, steering and speed adjustment of the electric wheelchair. Battery: It was installed at the bottom of the wheelchair. Rear wheel (Driving Wheel): equipped with motor and electric brake device. Front wheel: Provide support to keep the wheelchair stable. The battery of electrical wheelchair is Lithium-ion 24V, 11AH, and the charger is Input: 100-240VAC,50-60Hz, 1.2-0.5A, Output:DC24V,3A The maximum weight limitation of the user is 100kg. This product can be quickly folded, disassembled, and is easy to place in the trunk of a car or lift upstairs. The wheelchair is made of high-quality aluminum alloy. The weight without battery is 23kg. This product is an indoor wheelchair that can be driven indoors or on flat roads near buildings. In principle, it cannot be cross-country. It is not recommended to drive on grass, gravel roads, slopes greater than 12°, and motor vehicle lanes.
More Information

Not Found

No
The description focuses on basic electrical and mechanical components and control via a joystick, with no mention of adaptive learning, data analysis for control, or any terms associated with AI/ML.

No
The device is an indoor transportation vehicle designed to provide mobility for the disabled, elderly, and infirm, not to provide therapy or treatment for a medical condition.

No

The device is an electrical wheelchair for mobility, not designed to diagnose any medical condition. Its performance evaluations are against safety and physical standards for wheelchairs, not diagnostic accuracy metrics.

No

The device description clearly outlines multiple hardware components including a frame, wheels, motor, battery, and controller. While there is a "Controller and Master module" which likely contains software, the device is fundamentally a physical, motor-driven wheelchair.

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

Here's why:

  • Intended Use: The intended use of this device is to provide mobility to individuals. This is a physical function, not a diagnostic one.
  • Device Description: The description details the components and operation of a wheelchair, which is a mobility aid.
  • Lack of Diagnostic Function: There is no mention of this device being used to test samples (blood, urine, tissue, etc.) or to provide information about a patient's health status or condition.
  • Performance Studies: The performance studies focus on the physical and safety characteristics of the wheelchair (stability, speed, braking, etc.), not on diagnostic accuracy.
  • Key Metrics: The key metrics listed are related to the physical performance of the wheelchair, not diagnostic metrics like sensitivity or specificity.

An In Vitro Diagnostic device is used to examine specimens derived from the human body to provide information for the diagnosis, prevention, monitoring, treatment, or alleviation of disease. This electrical wheelchair does not perform any of these functions.

N/A

Intended Use / Indications for Use

The Electrical Wheelchair (Model: 9000N) is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to the disabled, the elderly and the infirm for short-distance travel.

Product codes

ITI

Device Description

The proposed device, Electrical wheelchair, mainly powered by battery, motivated by DC motor, driven by user controlling joystick and adjusting speed.

The electrical wheelchair consists of two foldable armrests, a seat cushion, a foldable frame, two rear driving wheels with hub motor/electromagnetic brake assemblies, two pivoting casters, a Lithiumion battery, a battery charger, a controller and master module. .

Wheelchair frame: Foldable for easy storage and transportation.

Controller and Master module: control the forward, steering and speed adjustment of the electric wheelchair.

Battery: It was installed at the bottom of the wheelchair.

Rear wheel (Driving Wheel): equipped with motor and electric brake device.

Front wheel: Provide support to keep the wheelchair stable.

The battery of electrical wheelchair is Lithium-ion 24V, 11AH, and the charger is Input: 100-240VAC,50-60Hz, 1.2-0.5A, Output:DC24V,3A

The maximum weight limitation of the user is 100kg.

This product can be quickly folded, disassembled, and is easy to place in the trunk of a car or lift upstairs.

The wheelchair is made of high-quality aluminum alloy. The weight without battery is 23kg.

This product is an indoor wheelchair that can be driven indoors or on flat roads near buildings. In principle, it cannot be cross-country. It is not recommended to drive on grass, gravel roads, slopes greater than 12°, and motor vehicle lanes.

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

Indoor use

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 Electrical Wheelchair has been evaluated the safety and performance by lab bench testing according to the following standards: ISO 7176-1: 2014, ISO 7176-2: 2017, ISO 7176-3: 2012, ISO 7176-4: 2008, ISO 7176-5: 2008, ISO 7176-6: 2018, ISO 7176-7: 1998, ISO 7176-8: 2014, ISO 7176-9: 2009, ISO 7176-10: 2008, ISO 7176-11: 2012, ISO 7176-13: 1989, ISO 7176-14: 2008, ISO 7176-15: 1996, ISO 7176-16: 2012, ISO 7176-19:2008. EMC testing was performed according to ISO 7176-21: 2009 and IEC 60601-1-2:2014. Biocompatibility testing for materials in contact with the user (Joystick handle, Joystick buttons, Upper/lower cover of Joystick, Armrest, Seat cushion) was performed according to ISO 10993-1:2018, ISO 10993-5:2009, and ISO 10993-10:2010.

No animal study and clinical studies are available for our device. Clinical testing was not required to demonstrate the substantial equivalence of the electrical wheelchair to its predicate device.

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

Not Found

Predicate Device(s)

K192739

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). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

September 16, 2022

Silver Fox Corporation Limited % Iris Fung Regulation Manager Guangdong Jianda Medical Technology Co., Ltd. 906 Room, Longxiang Garden, Tianhe District Guangzhou. 510000 China

Re: K221799

Trade/Device Name: Electric Wheelchair, Model: 9000N Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: June 13, 2022 Received: June 21, 2022

Dear Iris Fung:

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 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,

Tushar Bansal, Ph.D Acting 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

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Indications for Use

510(k) Number (if known) K221799

Device Name Electrical Wheelchair, Model: 9000N

Indications for Use (Describe)

The Electrical Wheelchair (Model: 9000N) is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to the disabled, the elderly and the infirm for short-distance travel.

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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510(k) Summary

This summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of 21 CFR 807.92.

1. Submitter Information

Sponsor Company Name: Silver Fox Corporation Limited Address: No.18, 1st TongLe Road, TongLe Industrial Zone, TangXa Town, PengJiang District, JiangMen City, GuangDong Province, China. Phone: +86-13422526650 Contact Person (including title): CHEN YAN /QA manager E-mail: Yan.chen@silverfox.cn

Application Correspondent: Guangdong Jianda Medical Technology Co Ltd. Address: 906 Room, Longxiang Garden, Tianhe district, Guangzhou, China Contact Person:Ms. Iris Fung Tile: Regulation Manager Tel: +86- 13211147965 Email: mdc-fs@foxmail.com; jianda-lee@foxmail.com

2. Subject Device Information

Type of 510(k) submission: Traditional Common Name: Powered Wheelchair Trade Name: Electrical Wheelchair Classification Name: Powered Wheelchair Review Panel: Physical Medicine Product Code: ITI Regulation Number: 21 CFR 890.3860 Regulation Class: Class II

3. Predicate Device Information

Sponsor: JERRY MEDICAL INSTRUMENT (SHANGHAI) CO., LTD. Common Name: Powered Wheelchair Trade Name: Electric Wheelchair

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510(k) number: K192739 Review Panel: Physical Medicine Product Code: ITI Regulation Number: 21 CFR 890.3860 Regulation Class: Class II

4. Device Description

The proposed device, Electrical wheelchair, mainly powered by battery, motivated by DC motor, driven by user controlling joystick and adjusting speed.

The electrical wheelchair consists of two foldable armrests, a seat cushion, a foldable frame, two rear driving wheels with hub motor/electromagnetic brake assemblies, two pivoting casters, a Lithiumion battery, a battery charger, a controller and master module. .

Wheelchair frame: Foldable for easy storage and transportation.

Controller and Master module: control the forward, steering and speed adjustment of the electric wheelchair.

Battery: It was installed at the bottom of the wheelchair.

Rear wheel (Driving Wheel): equipped with motor and electric brake device.

Front wheel: Provide support to keep the wheelchair stable.

The battery of electrical wheelchair is Lithium-ion 24V, 11AH, and the charger is Input: 100-240VAC,50-

60Hz, 1.2-0.5A, Output:DC24V,3A

The maximum weight limitation of the user is 100kg.

This product can be quickly folded, disassembled, and is easy to place in the trunk of a car or lift upstairs.

The wheelchair is made of high-quality aluminum alloy. The weight without battery is 23kg.

This product is an indoor wheelchair that can be driven indoors or on flat roads near buildings. In principle, it cannot be cross-country. It is not recommended to drive on grass, gravel roads, slopes greater than 12°, and motor vehicle lanes.

5. Intended Use

The Electrical Wheelchair (Model: 9000N) is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to the disabled, the elderly and the infirm for short-distance travel.

6. Test Summary of Non-clinical Testing

The Electrical Wheelchair has been evaluated the safety and performance by lab bench testing according to the following standards:

  • . ISO 7176-1: 2014 Wheelchairs - Part 1: Determination of static stability

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  • . ISO 7176-2: 2017 Wheelchairs - Part 2:Determination of dynamic stability of electrically powered 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 manoeuving space
  • . ISO 7176-6: 2018 Wheelchairs - Part 6: Determination of maximum speed. acceleration and deceleration of electric wheelchairs
  • . 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 - Part 11: 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 7176-19:2008 Wheelchairs - Part 19: Wheeled mobility devices for use as seats in motor vehicles

EMC

  • . ISO 7176-21: 2009 Wheelchairs - Part 21: Requirements and test methods for electromagnetic compatibility of electrically powered wheelchairs and scooters, and battery chargers
  • . IEC 60601-1-2:2014 Medical electrical equipment - Part 1-2: General requirements for safety - Collateral standard: Electromagnetic compatibility - Requirements and tests

Biocompatibility

The parts in contact with the user include: Joystick handle , is made of 100% Nitrile rubber; Joystick buttons are made of 100% silica gel; Upper/lower cover of Joystick are made of 100% ABS; Armrest are

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made of 100% polyurethane (PU); Seat cushion, is made of 100% Ployester. All contact materials have passed biological tests and are harmless to humans.

  • . ISO 10993-1:2018 Biological evaluation of medical devices — Part 1: Evaluation and testing within a risk management process
  • . ISO 10993-5:2009 Biological evaluation of medical devices — Part 5: Tests for in vitro cytotoxicity
  • . ISO 10993-10:2010 Biological evaluation of medical devices — Part 10: Tests for irritation and skin sensitization

7. Comparison to Predicate Device

Compare with predicate device, the subject device is very similar in design principle, intended use,

functions, material and the applicable standards. The differences between subject device and predicate device do not raise and new questions of safety or effectiveness.

| Elements of

ComparisonSubject DevicePredicate DeviceVerdict
Product CodeITIITISame
Regulation No.21 CFR 890.386021 CFR 890.3860Same
ClassIIIISame
Product nameElectrical WheelchairElectric WheelchairSame
510 (k)
NumberK221799K192739--
Models9000NJRWD6010, JRWD6012--
Intended UseThe Electrical Wheelchair (Model: 9000N) is a motor-driven, and indoor
transportation vehicle with the intended
use to provide mobility to the disabled,
the elderly and the infirm for short-
distance travel.The device is a motor-driven, and
indoor transportation vehicle with the
intended use to provide mobility to a
disabled or an elderly person limited to
a seated position.Same
Use
environmentIndoor useIndoor useSame
Patient
PopulationThis electrical wheelchair is suitable
for short-distance travel for the
disabled and the elderly person.The electric wheelchair is intended to
provide mobility to a person with a
disability or an older adult limited to a
sitting positionSame
Product
structureConsists of two foldable armrests, a
backrest, a seat cushion, a foldable
frame, two rear driving wheels withConsists of two foldable armrests, a
backrest, a seat cushion, a foldable
frame, two rear driving wheels with hubSame

Table1 General Comparison

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| Elements of

ComparisonSubject DevicePredicate DeviceVerdict
hub
motor/electromagnetic brake
assemblies, two pivoting casters, a
Lithium-ion battery, a battery charger,
a controller and master module.motor/electromagnetic brake
assemblies, two pivoting casters, a Li-
ion batteries, an off-board battery
charger, a control panel, and an electric
motor controller.
Driving systemDirect drive on the rear wheelsDirect drive on the rear wheelsSame
Number of
wheels44Same
Main frame
materialAluminium alloyAluminium alloySame
MotorDC 24V* 180W * 2pcsDC24V* 180W*2pcsSame
BatteryLithium-ion 24V, 11AH,1pcsDC 24V 20Ah Lithium-ion, 1 pcsSubject Device
has a lower output
current, but this
will not affect the
use of the product
function and
safety.
Battery chargerInput:AC 100-240V, 50/60Hz
Output:DC24V, 3A maxHigh Power Technology Inc.
HP0180WL2
Input: 100-240 VAC
Output: DC 24V, 6 AmpSubject Device
has a lower output
current, but this
will not affect the
use of the product
function and
safety.

Table2 Performance Comparison

Elements ofSubject DevicePredicate DeviceVerdict
ComparisonJRWD6010JRWD6012
Dimensions39.0"x24.0"x38.0"38.1"x24.0"x37.0"39.3"x23.6"x37.0"Similar
Folded
Dimensions26.0"x24.0"x16.0"Not publicly available--
Seat Cushion
size18.0"x18.0"x3.0"Not publicly available--
Weight,w/
Battery50lbs./23kg58.4 lbs. /26.5kg58.2 lbs./26.4kgSubject Device has a
lighter weight, but this
will not affect the use of
the product function and
safety.
Frame designFoldable/
The device consists of a foldable
and non-rigid type of power
wheelchair base with rear drive
and 2 casters in the front and 2
anti-tippers in the rear.Foldable /
The device consists of a foldable and
non-rigid type of power wheelchair base
with rear drive and 2 casters in the front
and two anti-tippers in the rear.Same
Folding
mechanismA foldable seat frames
(The backrest could be folded toA foldable seat frames
(The backrest could be folded to seat)Same
Elements ofPredicate Device
ComparisonSubject DeviceJRWD6010JRWD6012Verdict
seat)
Front wheel
(inch )88
(PU solid tire)
Rear tire
(inch)8
(PU solid tire)10
(PU solid tire)12
(Pneumatic tire)Smaller sizes of rear
wheels, The difference
will not raise any new
safety and effectiveness
concerns.
Cruising
Range(km)15.520Subject Device has a
shorter cruising range,
but this will not affect
the use of the product
function and safety.
Obstacle
climbing(mm)2550Subject Device has
a
lower obstacle climbing,
but this will not affect
the use of the product
function and safety.
Max. Speed
(km/h)4.56Subject Device has a
smaller Max. speed, but
this will not affect the
of the product
use
function and safety.
Static stability
forward18.2°21.8°Both of the devices are
evaluated according to
Static stability
rearward18.0°19°standard
ISO 7176-
1:2014, so the different
Static stability
sidewaysLeft: 17.6°
Right: 16.6°19.2°static stability will not
impact the safety and
effectiveness.
Max. loading
(kg)220lbs(100kg)220lbs (100kg)Same
Maximum
safe
operational
incline10°10 degreesSame
Min. Turning
radium950mm1820mmThe difference in the
tuming radius will bring
more convenience when
it turns.The difference
will not raise any new
safety and effectiveness
concerns.
Minimum
braking
distance≤1meter (39
inches )
flat,
≤1.6meter (63 inches) at 3°slope1mSimilar
Max Speed
Forwards2.46mph(3.96km/h)3.75 mph (6 km/h)Both of the devices are
evaluated according to
Max. Speed
Backward1.57mph(2.52km/h)2.80 mph (4.5 km/h)standard
ISO 7176-
6:2018, so the different
Elements of
ComparisonSubject DevicePredicate DeviceVerdict
JRWD6010JRWD6012
will not impact the
safety and effectiveness
ControllerSilver Fox Corporation LimitedPG Drives Technology Ltd., new VSIDifferent Although
different controller is
used, both the control
system, including the
joystick controller, the
electromagnetic brakes
are similar. The joystick
controls the directions
and speed of movement,
and when the joystick is
released, the powered
wheelchair will slow
down to stop and the
brakes will
automatically re-engage.
The controller also
provides the battery
status displaying and
abnormal condition
displaying. Both of the
control systems are
evaluated according to
standard ISO 7176-
14:2008 and software
validation requirement
and there are no new
safety and effectiveness
concerns due to the
difference.
Speed control
methodJoystick control methodJoystick control methodSame

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Table3 Safety Comparison

| Elements of

ComparisonSubject DevicePredicate DeviceVerdict
Main materialsFrame: Aluminiumalloy;
Wheel, Armrest: PU;
Backrest:polyeterFrame: Aluminiumalloy;
Wheel, Armrest: PU;
Backrest: oxford clothThe material for the
main frame is the same.
Biocompatibility
evaluation has been
carried out per ISO
10993-1.
Materials
contacting userArmrest: PU;
Backrest, Seat cushion: polyeter
Joystick handle : Nitrile rubber;
Joystick buttons: silica gel;
Upper/lower cover of Joystick:
ABSArmrest: PU:
Backrest: oxford cloth
Seat: oxford cloth
newVSi electric wheelchair
controller:
Joystick knob: Santoprene 101-80;
Joystick Gaiter: Silicone 3032
(50%) & 5031 (50%)
Enclosure Moulding(s): ABS/PC
Wonderloy PC-540
Keypad: Silicone keypad coatingsThere are no new safety
and effectiveness
concerns due to the
difference.

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| Elements of

ComparisonSubject DevicePredicate DeviceVerdict
TC-2407 & CH-6330
Biocompatibility
of materials
contacting userComply with ISO 10993-1, FDA
Cytotoxicity (ISO 10993-5:2009),
Sensitization and Intracutaneous
Reactivity (ISO 10993-10:2010)Comply with ISO 10993-1, FDA
Cytotoxicity (ISO 10993-5:2009),
Sensitization and Intracutaneous
Reactivity (ISO 10993-10:2010)Same
Label and
LabelingConforms to FDA Regulatory
RequirementsConforms to FDA Regulatory
RequirementsSame
Level of
Concern of the
SoftwareModerateModerateSame

8. Summary of substantial equivalence discussion

The 9000N electrical wheelchair complied with the requirements of ISO 7176-2:2017, ISO 7176-3:2012, ISO 7176-4:2008, ISO 7176-5:2008, ISO 7176-6:2018, ISO 7176-7:1998, ISO 7176-8:2014. ISO 7176-9:2009. ISO 7176-10:2008. ISO 7176-11:2012. ISO 7176-13:1989. ISO 7176-14:2008. ISO 7176-15:1996, ISO 7176-16:2012, ISO 7176-19:2008, ISO 7176-21:2009, IEC 60601-1-2:2014, ISO 10993-1:2018, ISO10993-5:2009, ISO 10993-10:2010..

The intended uses for both devices are the same. Mainframes of two devices are folded by way of front and rear close, and frame materials all meet the Tensile Strength, Yield Load, and Elongation tests. The design principles of the controller and Driving system are the same, and both meet the requirements of the ISO 7176-14:2008. Software validation is carried out on both control systems. Brake system and speed control are designed in the same way as well, and both meet the requirements of the ISO 7176-3:2012. Maximum obstacle climbing, Max Speed and Static stability different while such differences will not impact the safety and effectiveness of the subject device or raise new safety and effectiveness concerns as well as both meet the requirements of the ISO 7176-2:2001,ISO 7176-6: 2018, ISO 7176-10:2008. The biocompatibility of the Predicate device and Subject device meet the requirements of the ISO 10993-5:2009 & ISO 10993-10:2010.

The flame retardant test of the seat cushion and armrest of subject device is carried out according to the ISO 7176-16 test. Therefore, the subject device meets the flame retardancy of FDA requirements.

In conclusion, the technological characteristics, features, specifications, materials, mode of operation, and intended use of the device substantially equivalent to the predicate quoted above. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness.

9. Summary of Clinical Test

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No animal study and clinical studies are available for our device. Clinical testing was not required to demonstrate the substantial equivalence of the electrical wheelchair to its predicate device.

10. Conclusion

The differences between 9000N electrical wheelchair and its predicate devices do not introduce a new intended use and do not raise new issues of safety and effectiveness. Verification and Validation testing demonstrated that no adverse effects have been introduced by these differences and that the device performs as intended. From the results of nonclinical testing described, it can be concluded that 9000N electrical wheelchair is substantially equivalent to the legally marketed predicate device.

11. Summary Prepared Date

13 June 2022