K Number
K231750
Device Name
MA012 Aluminum wheelchair, MS019 steel wheelchair
Date Cleared
2023-08-15

(61 days)

Product Code
Regulation Number
890.3850
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
MA012 Aluminum wheelchair and MS019 steel wheelchair are intended for medical purpose to provide mobility to persons limited to a sitting position.
Device Description
MA012 Aluminum wheelchair and MS019 Steel wheelchair are mechanical wheelchairs which is a manually operated, attendant propelled transport device in a health care environment such as a hospital, nursing home or extended care facility. It is intended for medical purpose to provide mobility to persons limited to a sitting position. The wheelchair is controlled, steered and operated completely by a trained caregiver. The wheelchair incorporates a main frame, a seat, two adjustable footrests and four wheels. There are two models of the wheelchair, MA012 and MS019. The MA012 Aluminum wheelchair has an aluminum frame, fixed armrest and a foldable back, while the MS019 Steel wheelchair has a steel frame, fixed back and a detachable, flip-back armrest. The wheelchair can support users of up to115 kg.
More Information

Not Found

No
The device description clearly states it is a "mechanical wheelchair" that is "manually operated, attendant propelled" and "controlled, steered and operated completely by a trained caregiver." There is no mention of any automated or intelligent features.

No
The device provides mobility support for persons limited to a sitting position, which is a supportive function rather than an active therapeutic treatment or intervention.

No

The device is a wheelchair intended for mobility, not for diagnosing medical conditions.

No

The device description clearly states it is a mechanical wheelchair with a frame, seat, footrests, and wheels, indicating it is a hardware device.

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

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body (like blood, urine, tissue) to detect diseases, conditions, or infections.
  • Device Description: The description clearly states that the MA012 and MS019 wheelchairs are "mechanical wheelchairs" and "manually operated, attendant propelled transport devices." Their purpose is to provide mobility to individuals.
  • Intended Use: The intended use is to "provide mobility to persons limited to a sitting position." This is a physical function, not a diagnostic test performed on a sample.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples, performing tests, or providing diagnostic information based on laboratory analysis.

The device is a mobility aid, not a diagnostic tool.

N/A

Intended Use / Indications for Use

MA012 Aluminum wheelchair and MS019 steel wheelchair are intended for medical purpose to provide mobility to persons limited to a sitting position.

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

IOR

Device Description

MA012 Aluminum wheelchair and MS019 Steel wheelchair are mechanical wheelchairs which is a manually operated, attendant propelled transport device in a health care environment such as a hospital, nursing home or extended care facility. It is intended for medical purpose to provide mobility to persons limited to a sitting position. The wheelchair is controlled, steered and operated completely by a trained caregiver.

The wheelchair incorporates a main frame, a seat, two adjustable footrests and four wheels. There are two models of the wheelchair, MA012 and MS019. The MA012 Aluminum wheelchair has an aluminum frame, fixed armrest and a foldable back, while the MS019 Steel wheelchair has a steel frame, fixed back and a detachable, flip-back armrest. The wheelchair can support users of up to115 kg.

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

manually operated, attendant propelled transport device in a health care environment such as a hospital, nursing home or extended care facility.

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 proposed 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 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
  • ISO 10993-23: 2021 Biological evaluation of medical devices - Part 23: Tests for irritation
  • 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 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 strength
  • 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 Second edition 2012-12-01 Wheelchairs - Part 16: Resistance to ignition of postural support devices

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.

K181795

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 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.

August 15, 2023

Sichuan AST Medical Equipment Co., Ltd. % Ivy Wang Technical Manager Shanghai Sungo Management Consulting Company Limited 14th Floor, 1500# Central Avenue Shanghai, Shanghai 200122 China

Re: K231750

Trade/Device Name: MA012 Aluminum wheelchair, MS019 steel wheelchair Regulation Number: 21 CFR 890.3850 Regulation Name: Mechanical Wheelchair Regulatory Class: Class I, reserved Product Code: IOR Dated: June 15, 2023 Received: June 15, 2023

Dear Ivy Wang:

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.

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 website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatorythe 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.

Tushar Bansal -S

for 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) K231750

Device Name

MA012 Aluminum wheelchair, MS019 steel wheelchair

Indications for Use (Describe)

MA012 Aluminum wheelchair and MS019 steel wheelchair are intended for medical purpose 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

K231750

l. Applicant

Name: Sichuan AST Medical Equipment Co., Ltd.

Address: No.58 JinPeng Road, Area C, West Industrial Park, Luxian County, Luzhou, Sichuan,

646100 CN

Name of contact person: Ms. Mae Tse

Telephone: +86 830 8130333

Email: sales01@ast168.cn

Date prepared: 2023-08-11

II. Submission Correspondent

Ms. Ivy Wang

Shanghai SUNGO Management Consulting Co., Ltd.

Tel: +86-21-5881 7802

Email: zxfdaf@sungoglobal.com

III. Device

Device trade name: MA012 Aluminum wheelchair, MS019 Steel wheelchair

Common name: Manual Wheelchair

Regulatory Information:

Classification name: Mechanical Wheelchair

Regulation class: 1

Regulation number: 21CFR 890.3850

Panel: Physical Medicine

Product code: IOR

IV. Predicate device

Primary - K181795

AST Model MA012 and MS019 Rehab Wheelchair

Sichuan AST Medical Equipment Co., Ltd

4

V. Device description

MA012 Aluminum wheelchair and MS019 Steel wheelchair are mechanical wheelchairs which is a manually operated, attendant propelled transport device in a health care environment such as a hospital, nursing home or extended care facility. It is intended for medical purpose to provide mobility to persons limited to a sitting position. The wheelchair is controlled, steered and operated completely by a trained caregiver.

The wheelchair incorporates a main frame, a seat, two adjustable footrests and four wheels. There are two models of the wheelchair, MA012 and MS019. The MA012 Aluminum wheelchair has an aluminum frame, fixed armrest and a foldable back, while the MS019 Steel wheelchair has a steel frame, fixed back and a detachable, flip-back armrest. The wheelchair can support users of up to115 kg.

VI. Indication for use

MA012 Aluminum wheelchair and MS019 steel wheelchair are intended for medical purpose to provide mobility to persons limited to a sitting position.

VII. Non-Clinical Test Conclusion

Non-clinical tests were conducted to verify that the proposed 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 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
  • ISO 10993-23: 2021 Biological evaluation of medical devices - Part 23: Tests for irritation
  • . 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 dimensions, mass and

5

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 strength
  • . 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 Second edition 2012-12-01 Wheelchairs - Part 16: Resistance to ignition of postural support devices

VIII. Comparison with the predicate device

AttributeSubject devicePredicate deviceResults
ManufacturerSichuan AST Medical
Equipment Co., Ltd.Sichuan AST Medical Equipment
Co., Ltd./
Proprietary name,
modelMA012 Aluminum wheelchair,
MS019 Steel wheelchairAST Model MA012 and MS019
Rehab Wheelchair/
510(k) numberK231750K181795/
Device classification
nameClass IClass ISame
Classification
regulations21 CFR 890. 385021 CFR 890. 3850Same
Product codeIORIORSame
Indication for useMA012 Aluminum wheelchair
and MS019 steel wheelchair
are intended for medical
purpose to provide mobility to
persons limited to a sitting
position.The AST Model MA012 and
MS019 Rehab Wheelchairs are
to provide mobility to persons
limited to a sitting position.Same
Dimension (Length x
Width x Height)Model MA012:
950x610x970mm
Model MS019:
916x574x896mmModel MA012:
1173x645x892mm (±1mm)
Model MS019:
1196x775x894mm (±1mm)Similar
The two physical
dimensions are
different. The
difference does
AttributeSubject devicePredicate deviceResults
Total weightModel MA012: 11.5kg/25 lbs
Model MS019: 18.7kg/41 lbsModel MA012: 17.2kg/38 lbs
Model MS019: 20kg/ 46 lbsnot affect
effectiveness and
safety.
Similar
Different weight of
the device do not
raise the safety
and effectiveness
of the device.
Weight Capacity115 kg/250lbsModel MS019: 200 kg/450 lbs,
Model MA012: 136kg/ 300 lbsSimilar
Difference on
loading weight will
not cause
different
performance.
Lower weight
provide less
pressure to the
chair and easy for
the transportation.
Seat depthModel MA012: 390mm
Model MS019: 420mmModel MA012:
16"-20" (406mm-508mm)
Model MS019:
18"-20" (457mm-508mm)Similar
Different seat size
do not raise the
safety and
Seat widthModel MA012: 420mm
Model MS019: 450mmModel MA012: 16" (406mm); 18"
(457mm); 20" (508mm)
Model MS019: 18" (457mm);
20" (508mm); 22" (558mm); 24"
(609mm)effectiveness of
the device.
Seat heightModel MA012: 520mm
Model MS019: 596mmModel MA012: 19.7" (500mm)
Model MS019: 19.8" (503mm)
Frame typeFoldableFoldableSame
Frame materialModel MA012: Aluminum
Model MS019: SteelModel MA012: Aluminum
Model MS019: SteelSame
Back styleModel MS019: Fixed
Model MA012: foldableModel MS019: Fixed
Model MA012: AdjustableSimilar
The slight
difference on back
style do not raise
the safety and
effectiveness of
the device.
ArmrestFlip back armrestModel MA012: Height Adjustable
desk length armrest. Flip backSimilar
The height of
AttributeSubject devicePredicate deviceResults
Model MS019: Fixed or adjustable height; desk or full length; removablearmrest of proposed device can not be adjustable.
FootrestOptional/ swing awayOptional/ swing awaySame
Rear Axle PositionSingleMultipleSimilar
The rear axle of proposed device has only one size.
TiresFront: 200mm (8")
Rear: 315mm (12.5")Front: 6",7",8"
Rear: 20",22",24"Similar
Minor difference on dimension of driven wheel will not cause different performance.

Table 1 General Comparison

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Substantial equivalence Analysis:

The design and technological characteristics of the subject device is basically similar to the predicate device chosen. There are some minor differences with the predicate device don't affect the safety or effectiveness of the subject device. Moreover, the non-clinical tests and the predicate comparisons demonstrate that these differences in their technological characteristics do not raise any questions as to the safety and effectiveness.

Therefore, the subject device is substantially equivalent to the predicate device.

AttributeSubject devicePredicate deviceResults
BiocompatibilityAll user directly contacting
materials are compliance with
ISO10993-5,
ISO10993-10, ISO 10993-23
requirements.All user directly contacting
materials are compliance with
ISO10993-5 and
ISO10993-10 requirements.S.E.
PerformanceISO7176 seriesISO7176 seriesS.E.
Label and labelingConforms to FDA RegulatoryConforms to FDA RegulatoryS.E.

Table 2 Safety comparison

Table 3 Safety comparison

AttributeSubject devicePredicate deviceResults
ISO7176-1The Static stability has been
determined after the testing
according to the ISO 7176-1, and
test results meet its design
specification.The Static stability has been
determined after the testing
according to the ISO 7176-1,
and test results meet its design
specification.S.E.
AttributeSubject devicePredicate deviceResults
ISO7176-3The effectiveness of brakes has been determined after the testing according to the ISO 7176-3, and test results meet its design specification.The effectiveness of brakes has been determined after the testing according to the ISO 7176-3, and test results meet its design specification.S.E.
ISO7176-5The dimensions, mass has been determined after the testing according to the ISO 7176-5.The dimensions, mass has been determined after the testing according to the ISO 7176-5.S.E.
ISO7176-7The seating and wheel dimensions has been determined after the testing according to the ISO 7176-7The seating and wheel dimensions has been determined after the testing according to the ISO 7176-7S.E.
ISO7176-8All test results meet the requirements in Clause 4 of ISO 7176-8All test results meet the requirements in Clause 4 of ISO 7176-8S.E.
ISO7176-11The test dummies used in the testing of ISO 7176 series are meet the requirements of ISO 7176-11.The test dummies used in the testing of ISO 7176 series are meet the requirements of ISO 7176-11.S.E.
ISO7176-13The coefficient of friction of test surfaces has been determined, which could be used in other 7176 series tests involvedThe coefficient of friction of test surfaces has been determined, which could be used in other 7176 series tests involvedS.E.
ISO7176-15The test results shown that information disclosure, documentation and labelling of device meet the requirements of ISO 7176-15The test results shown that information disclosure, documentation and labelling of device meet the requirements of ISO 7176-15S.E.
ISO 7176-16The performance of resistance to ignition meets the requirements of ISO 7176-16The performance of resistance to ignition meets the requirements of ISO 7176-16.S.E.

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IX. Summary of clinical testing

No clinical study is included in this submission.

Conclusions X.

The conclusions drawn from the nonclinical tests demonstrate that the subject device is as safe, as effective, and performs as well the legally marketed predicate device K181795.