K Number
K231110
Device Name
Manual Wheelchair (A006)
Date Cleared
2023-06-16

(58 days)

Product Code
Regulation Number
890.3850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
The A006 Manual Wheelchair is to provide mobility to persons limited to a sitting position.
Device Description
The subject device is a mechanical wheelchair which is a manually operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position. It can be folded for transport by bringing the two sides together. The manual wheelchair incorporates a main frame, a seat, two adjustable footrests and four wheels. The larger rear wheels have hand rims of slightly smaller diameter projecting just beyond the tire. These allows the user to maneuver the chair by pushing them on without requiring them to grasp the tires. The manual wheelchairs have brakes that bear on the tires of the rear wheels and two push handles at the upper rear of the frame to allow for manual propulsion by an assistant.
More Information

Not Found

No
The device description clearly states it is a "mechanical wheelchair" and details its manual operation and components. There is no mention of any software, algorithms, or data processing that would indicate the use of AI/ML. The performance studies focus on mechanical and material standards.

Yes
The device is a manual wheelchair, which is a common therapeutic device used to provide mobility and support to individuals with limited mobility. It helps in rehabilitation and improves the quality of life for users.

No
The device is a manual wheelchair, which is described as providing mobility to persons limited to a sitting position. Its function is to assist with movement, not to diagnose a medical condition.

No

The device description clearly states it is a mechanical wheelchair with physical components like a frame, seat, wheels, and brakes, and the performance studies focus on the mechanical and material properties of these components.

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

Here's why:

  • Intended Use: The intended use is to "provide mobility to persons limited to a sitting position." This is a mechanical function for physical support and movement.
  • Device Description: The description details a mechanical device with wheels, a frame, seat, and footrests. It describes how it is operated and its physical components.
  • Lack of IVD Characteristics: IVD devices are used to examine specimens (like blood, urine, or tissue) from the human body to provide information for diagnosis, monitoring, or screening. This device does not interact with biological specimens in this way.
  • Performance Studies: The performance studies focus on mechanical aspects like stability, braking, dimensions, strength, and biocompatibility of materials that contact the patient's skin. These are typical tests for a physical medical device, not an IVD.

The A006 Manual Wheelchair is a physical medical device designed for mobility assistance.

N/A

Intended Use / Indications for Use

The A006 Manual Wheelchair is to provide mobility to persons limited to a sitting position.

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

IOR

Device Description

The subject device is a mechanical wheelchair which is a manually operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position. It can be folded for transport by bringing the two sides together. The manual wheelchair incorporates a main frame, a seat, two adjustable footrests and four wheels. The larger rear wheels have hand rims of slightly smaller diameter projecting just beyond the tire. These allows the user to maneuver the chair by pushing them on without requiring them to grasp the tires. The manual wheelchairs have brakes that bear on the tires of the rear wheels and two push handles at the upper rear of the frame to allow for manual propulsion by an assistant.

Main Components: Main frame, back upholstery, seat upholstery, handgrip, armrest, front wheel, rear wheel, hand rim, crossbar, leg rest strap, footrest, seat belt, brake.

The device can be operated indoors, or outdoors on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.

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 tests were conducted to verify that the subject device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
ISO 7176-1:2014 Wheelchairs - Part 1: Determination of static stability
ISO 7176-3:2012 Wheelchairs - Part 3: Determination of effectiveness of brakes
ISO 7176-5: 2008 Wheelchairs - Part 5: Determination of overall dimensions, mass and maneuvering space
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 7176-11: 2012 Wheelchairs - Part 11: Test dummies
ISO 7176-13: 1989 Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces
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 7176-22:2014 Wheelchairs - Part 22: Set-up procedures

Biocompatibility testing was conducted in accordance with the 2020 FDA guidance Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1: Evaluation and testing within a risk management process." Testing included:

  • Cytotoxicity (ISO 10993-5:2009)
  • Sensitization (ISO 10993-10:2010)
  • Irritation (ISO 10993-10:2010)
    The testing supports the biocompatibility of the patient-contacting device materials that were shown to be non-cytotoxic, non-irritating, and non-sensitizing.

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.

K201461

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

§ 890.3850 Mechanical wheelchair.

(a)
Identification. A mechanical wheelchair is a manually operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position.(b)
Classification. Class I (general controls).

0

Image /page/0/Picture/0 description: The image contains 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 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.

June 16, 2023

Ningbo Shenyu Medical Equipment Co., Ltd. % Eva Li Consultant Shanghai SUNGO Management Consulting Co., Ltd. Room 1401, Dongfang Building, 1500# Century Ave. Shanghai, 200122 China

Re: K231110

Trade/Device Name: Manual Wheelchair (A006) Regulation Number: 21 CFR 890.3850 Regulation Name: Mechanical Wheelchair Regulatory Class: Class I, reserved Product Code: IOR Dated: March 13, 2023 Received: April 19, 2023

Dear Ms. Eva Li:

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 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 (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-reporting-mdr-howreport-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) 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 (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatorywebsite the DICE assistance/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 L. Dean -S

Heather Dean, Ph.D. Assistant Director, Acute Injury Devices Team DHT5B: Division of Neuromodulation and Rehabilitation 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) K231110

Device Name Manual Wheelchair (A006)

Indications for Use (Describe)

The A006 Manual Wheelchair is to provide mobility to persons limited 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)

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510(K) Summary

1. Submitter K231110

Ningbo Shenyu Medical Equipment Co.,Ltd. Address: No.1318 West of Tanjialing Road, Yuyao, Zhejiang, China Contact Person: Ding Jianjun Tel: +86- 574-62517777 Email: sales@shenyumedical.com

Submission Correspondent Eva Li Contact: + 86 (215) 881-7802 Phone: Email: eatereva@hotmail.com Shanghai SUNGO Management Consulting Co., Ltd. Room 1401, Dongfang Building, 1500# Century Ave, Shanghai, 200122 CHN

Prepared Date: May 10th,2023

2. Device

Name of Device: Manual Wheelchair Common Name: Manual Wheelchair Model(s): A006

Regulatory Information Classification Name: Mechanical Wheelchair Regulatory Class: I Product code: IOR Regulation Number: 890.3850 Review Panel: Physical Medicine

3. Predicate device:

K201461 Ningbo Shenyu Medical Equipment Co.,Ltd. Manual Wheelchair (A011) This predicate has not been subject to a design-related recall.

4. Device description

The subject device is a mechanical wheelchair which is a manually operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position. It can be folded for transport by bringing the two sides together. The manual wheelchair incorporates a main frame, a seat, two adjustable footrests and four wheels. The larger rear wheels have hand rims of slightly smaller diameter projecting just beyond the tire. These allows the user to maneuver the chair by pushing them on without requiring them to grasp the tires. The manual wheelchairs have brakes that bear on the

4

tires of the rear wheels and two push handles at the upper rear of the frame to allow for manual propulsion by an assistant.

Main Components:

Main frame, back upholstery, seat upholstery, handgrip, armrest, front wheel, rear wheel, hand rim, crossbar, leg rest strap, footrest, seat belt, brake

The device can be operated indoors, or outdoors on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.

Overall dimension1000(L)*690(W)*875(H) mm
Folded dimension800(L)*325(W)*875(H) mm
Seat width425 mmSeat plane angle10.4 °
Seat depth425 mmSeat height from floor445 mm
Backrest angle21.1°Backrest height470 mm
Backrest width430 mmFootrest-to-seat distance295 mm(min)
350 mm(max)
Footrest clearance110 mm(min)
160 mm(max)Footrest length145 mm
Armrest-to-seat distance260 mmFootrest-leg-angle98.0°(min)
100°(max)
Leg-to-seat-surface angle109°Front-armrest-to-backrest
distance260 mm
Front-armrest-to-backrest
distance430 mmArmrest length365 mm
Armrest width55 mmArmrest angle4.3°
Distance between
armrests425 mmFront location of armrest
structure440 mm
Hand rim diameterΦ530 mmMaterialAluminum
Horizontal location of axle6 mmVertical displacement of
wheel axle73 mm
Weight of the device(net) 14.0 kgMaximum weight bearing
capacity of the device100 kg
diameter of front wheelsΦ185 mmdiameter of rear wheelsΦ595 mm
Backpack carrier or
permissionL: 280 mm
W: 248 mmStatic stability sideways15°
Static stability uphill10°Static stability downhill10°
Minimum doorway entry depth1250 mm
Minimum turning radius900 mm
Minimum corridor width for side opening1170 mm
Parking brake
Max slope uphill12.9°
Max slope downhill10.6°
Bake operating force63.9 N

The specification table is as below:

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Ningbo Shenyu Medical Equipment Co.,Ltd. Address: No.1318 West of Tanjialing Road,Yuyao,Zhejiang,China

5. Indication for use

The A006 Manual Wheelchair is to provide mobility to persons limited to a sitting position.

6. Comparison of technological characteristics with the predicate device

DevicePredicate DeviceProposed DeviceResults
510K NumberK201461K231110
ManufacturerNingbo Shenyu Medical Equipment
Co., Ltd.Ningbo Shenyu Medical Equipment
Co., Ltd.Same
Proprietary NameManual WheelchairManual WheelchairSame
ModelA011A006
ClassificationIISame
Indications for useThe A011 Manual wheelchair is to
provide mobility to persons limited
to a sitting position.The A006 Manual Wheelchairs is to
provide mobility to persons limited
to a sitting position.Same
Design
CharacteristicManual Operation, Four-Wheels,
Foldable, Cross-Brace, Pull-to-Lock,
Armrest, Backrest, Foot restManual Operation, Four-Wheels,
Foldable, Cross-Brace, Pull-to-Lock,
Armrest, Backrest, Foot rest, skirt
guardSimilar*1
Brake controlOccupant-operated brake only1. Occupant-operated brake
  1. Attendant-operated brake | Similar2 |
    | Operation
    Environment | For indoor/outdoor us | For indoor/outdoor us | Same |
    | Control Mode | Mechanical | Mechanical | Same |
    | Size(unfold) | 1100 (L)660 (W) * 910 mm (H) | 1000 (L)690 (W)875 (H) mm | Different3 |
    | Stowage
    length/width/height | 810 (L)320 (W) * 930 mm (H) | 800 (L)325 (W)875 (H) mm | Different3 |
    | Weight(Total) | 16 kg (35.2 lbs) | 14 kg (30.9 lbs) | Different
    3 |
    | Weight Capacity | 136 kg(300 lbs) | 100 kg(220 lbs) | Different
    3 |
    | Seat Width | 480 mm | 425 mm | Different
    3 |
    | Seat height | 540 mm | 425 mm | Different
    3 |
    | Seat depth | 420 mm | 445 mm | Different
    3 |
    | Back type | Fixed | Fixed | Same |

6

Ningbo Shenyu Medical Equipment Co.,Ltd. Address: No.1318 West of Tanjialing Road, Yuyao, Zhejiang, China

Anti-tippersOptionalWithout Anti-tippersDifferent*4
TiresFront: 200 mm (8")Front: 185 mm (7")Different*3
Rear: 610 mm (24")Rear: 595 mm (23")
ArmrestFlip back armrestFixed armrestDifferent*5
Foot restOptional/swing awayFixed/swing awayDifferent*5
Rear Axle PositionSingleSingleSame
FrameFoldable frameFoldable frameSame
ConstructionPush inward from left and right
sides to foldPush inward from left and right
sides to foldSame
Safety FeatureManual Wheel Lock
PerformanceComply with:Comply with:Same
ISO7176-1ISO7176-1
ISO7176-3ISO7176-3
ISO7176-5ISO7176-5
ISO7176-7ISO7176-7
ISO7176-8ISO7176-8
ISO7176-11ISO7176-11
ISO7176-13ISO7176-13
ISO7176-15
ISO7176-16ISO7176-15
ISO7176-16
BiocompatibilityComply with:Comply with:Same
ISO10993-1
ISO10993-5ISO10993-1
ISO10993-5
ISO10993-10ISO10993-10

Disscussion :

| Similar1: | Compare the predicate device, the subject device adds two skirt guard which
are installed to the sides of the seat frame under the arm rests to provide a
barrier between the occupants and the wheels. This feature can prevent
occupants clothes from getting caught in the wheels. This feature will not raise
any new risk of safety or effectiveness. |
|--------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Similar
2: | Compare the predicate device, the subject device adds attendant-operated brakes
which the attendant can squeeze upwards the brake hand grip to brake the device.
The subject device passed the test of , so it will not raise any new risk of safety or effectiveness. |
| Different3: | Compare the predicate device, the subject device has different values on the
unfold size, stowage size, device weight, capacity, seat width, seat height, seat
depth, tire size. However, the subject has passed the and , so the above
difference will not raise any new risk of safety or effectiveness. |
| Different
4: | Compare the predicate device, the subject device does not equip Anti-tippers.
However the subject device pass the test , so this difference will not raise any new risk of safety or effectiveness. |

7. Summary of Non-Clinic Performance Testing

Performance Testing

Non-clinical tests were conducted to verify that the subject device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards: ISO 7176-1:2014 Wheelchairs - Part 1: Determination of static stability

ISO 7176-3:2012 Wheelchairs - Part 3: Determination of effectiveness of brakes

ISO 7176-5: 2008 Wheelchairs - Part 5: Determination of overall dimensions, mass and maneuvering space

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 7176-11: 2012 Wheelchairs - Part 11: Test dummies

ISO 7176-13: 1989 Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces

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 7176-22:2014 Wheelchairs - Part 22: Set-up procedures

Biocompatibility

Biocompatibility testing was conducted in accordance with the 2020 FDA guidance Use of International Standard ISO 10993-1, "Biological Evaluation of Medical Devices – Part 1: Evaluation and testing within a risk management process." Testing included:

  • Cytotoxicity (ISO 10993-5:2009)
  • · Sensitization (ISO 10993-10:2010)
  • · Irritation (ISO 10993-10:2010)

The testing supports the biocompatibility of the patient-contacting device materials that were shown to be non-cytotoxic, non-irritating, and non-sensitizing.

8. Clinical Test Conclusion

No clinical study is included in this submission.

9. Conclusion

The conclusion drawn from the nonclinical tests demonstrates that the subject device in 510(K) submission, the Manual Wheelchair is as safe, as effective, as well as the legally marketed predicate device cleared under K201461.