K Number
K983520
Date Cleared
1998-11-06

(29 days)

Product Code
Regulation Number
890.3860
Reference & Predicate Devices
Predicate For
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Alternate input devices are designed to provide those with sever physical disabilities the independence to operate a power wheelchair, a power seating system, and an environmental control unit from a single actuating device.

Device Description

Alternate actuators (input devices) are designed to provide those with severe physical disabilities the independence to operate a power wheelchair, a power seating system, and an environmental control unit using a device other than the standard joystick. A variety of alternate input actuators are currently available on the market as many power wheelchair users require some form of input control other than a joystick.

In prior submissions, several alternate input devices (specialty controls) and their interface modules were employed in addition to the main wheelchair controller. These included the breath tube interface, which contained a pressure transducer, a single switch scanner module and a display. Other specialty control functions also required independent display boxes and / or displays. However Quickie's new controllers, that are intended to interface with specialty input devices, have incorporated these functions into the Controller/ USCM (Universal Specialty Control Module). This greatly simplifies the wheelchair's configuration as it eliminates the need for additional dedicated interface boxes and displays to be mounted on the chair.

As with the devices currently marketed by Quickie, the alternate actuator is used to signal both the speed and direction of the power chair, as well as the selection of various operating modes which are then controlled by the wheelchair controller/USCM. Examples of the various modes that can be controlled are: maximum speed, drive profile (e.g. indoor/outdoor), latched driving, powered seating systems and environmental controls systems.

The method of selection for both drive control and mode is dependent upon the type of alternate input actuator. Two basic types of input actuators exist: proportional and switched. Both types are compatible with Quickie's controller/USCM. When using alternate input actuators, the wheelchair controller will enter a sleep state if the actuator has not sent a signal for a specified period of time. This helps to extend the life of the chair batteries, and reduces the likelihood of unintentional movement.

The primary change being addressed is the modification of one of the standard connectors used to interface with the Quickie Controllers that have a Universal Specialty Control Unit (USCM). Two of the three connections that were made to the old Multi-mode remain the same. Some devices used a breath tube that activated a pressure transducer that translated the air pressure to electrical signals. This connection remains unchanged. Some devices used a single jack connector to transfer signal. This connection also remains unchanged. The third type of connector employed by the prior Multi-mode device was a DB15 connector. The Controller/ USCM, which replaces the Multi-mode, translates the same signals using a DB9 connector. The DB9 was selected for the Controller/USCM because it has developed across the specialty input device industry as the standard connector. The DB-9 is used by many companies making specialty input devices including Switch-it, Tash, and ASL.

AI/ML Overview

Here's an analysis of the provided text regarding acceptance criteria and the study:

The provided document describes a 510(k) premarket notification for "QUICKIE SPECIALTY INPUT DEVICE" and its various models. However, it does not contain a formal study designed to prove the device meets specific acceptance criteria in the way one might expect for a typical medical device with measurable performance metrics (e.g., diagnostic accuracy, precision).

Instead, this submission is focused on demonstrating substantial equivalence to predicate devices. The "study" here is primarily a comparison to predicate devices and basic engineering testing, not a clinical trial or performance study against predefined targets.

Here's a breakdown based on your requested information, with explanations for what is present and what is absent:


1. A table of acceptance criteria and the reported device performance

Acceptance Criteria (Implied)Reported Device Performance
Functional Equivalence to Predicate Devices"The indications for use are the same, the technological characteristics are the same, and the performance characteristics are the same for both the modified and predicate devices."
Mechanical Integrity (Connectors)
Pull Out StrengthPass
Insertion ForcePass
Pin Activity CompatibilityPass
Safety (General Wheelchair Safety)Analysis of complaints against Quickie chairs completed and charted (Chart #1). Literature search conducted by third party on general wheelchair complaints, MDRs, and recalls. Demonstrated "common issues across all manufacturers product lines, and varying levels approximately comparable to relative market share."
Efficacy (General Wheelchair Efficacy)Articles provided on the use and efficacy of mechanical reclining wheelchairs (Appendix D).

Explanation: The "acceptance criteria" are not explicitly stated with quantitative targets. Instead, the document argues for substantial equivalence by asserting that the device's characteristics and performance are "the same" as the predicate devices. The mechanical tests (pull out strength, insertion force, pin activity compatibility) are the only truly explicit performance tests mentioned, and their "acceptance criteria" appear to be simply "Pass."


2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)

  • Test Set Sample Size: Not applicable in the traditional sense of a clinical or performance study.
    • For the mechanical tests (Pull Out Strength, Insertion Force, Pin Activity Compatibility), the sample size is not specified. It would typically be a small number of connectors tested in a lab setting.
    • For the safety analysis, the "sample" was the complaints against Quickie chairs and a literature review of general wheelchair complaints/MDRs/recalls. The size of these datasets is not specified.
  • Data Provenance: Not explicitly stated. Given it's a US 510(k) submission, it's likely primarily related to the US market, but this is not confirmed.
  • Retrospective or Prospective:
    • The mechanical tests would be prospective (conducted specifically for this submission).
    • The safety analysis based on complaints/MDRs/recalls is inherently retrospective.
    • The efficacy articles provided would be retrospective literature.

3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts (e.g. radiologist with 10 years of experience)

Not applicable. This is not a study that requires expert adjudication of ground truth for device output. The substantial equivalence argument relies on comparing the device's features to those of predicate devices and general knowledge of wheelchair safety and efficacy.


4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

Not applicable. No expert adjudication of a test set was performed.


5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance

Not applicable. This device is a physical input device for wheelchairs, not an AI-powered diagnostic or assistive tool for human readers.


6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done

Not applicable. This device is a physical input device, not an algorithm. Its function is to convert user input into signals for a wheelchair controller. Human-in-the-loop is fundamental to its operation.


7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

Not applicable. This submission relies on:

  • Engineering test results for mechanical properties ("Pass" indicates meeting an engineering specification).
  • Comparison of features and intended use to legally marketed predicate devices.
  • Analysis of existing safety data (complaints, MDRs, recalls) related to wheelchairs in general.
  • Existing literature on wheelchair efficacy.

8. The sample size for the training set

Not applicable. This device is not an AI/ML device that requires a training set. It's a hardware input device.


9. How the ground truth for the training set was established

Not applicable. As above, this device does not utilize a training set in the AI/ML sense.

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13.0 510(k) SUMMARY OF SAFETY AND EFFICACY

Rebecca Andersen

6 1998 NO Submitter: Date:

K98 3520

Names of the devices:

QUICKIE SPECIALTY INPUT DEVICE

9/28/98

ModelNumberDevice DescriptionPerformanceFeaturesSwitchTypeFunction
139700Breath ControlSameSwitched InputActuator
139900Electronic Head ArraySame as the 3519, onlyclose proximity to sensorcauses activationSwitched InputActuator
139702Tri Switch Head ArraySameSwitched InputActuator
139703HD Switched JoystickSameSwitched InputActuator
139923CA - 5SameSwitched InputActuator
139924Penta5 single switchespackaged in small disc.Single finger control.Switched InputActuator
139925Star Board Switch5 single switchespackaged in "plus"arrangement. Smallhand control.Switched InputActuator
139922Wafer Board5 single switchesSwitched InputActuator
139706Mini switched JoystickSameSwitched InputActuator
139720Treadle SwitchSameSingle SwitchActuator
139721Ribbon SwitchSameSingle SwitchActuator
139722Disc SwitchSameSingle SwitchActuator
139920Buddy ButtonSame as Disc SwitchSingle SwitchActuator
139921Micro LightVery light touch singleswitchSingle SwitchActuator
139926PlateVery light touch singleswitchSingle SwitchActuator
139927GraspSingle switch activatedby grasping a tubeSingle SwitchActuator
139928SoftFoam covered singleswitch. Designed toprotect user from hardsurfaces.Single SwitchActuator
139910Wobble SwitchLarge activation area,used for gross motormovementsSingle SwitchActuator
ModelNumberDevice DescriptionPerformanceFeaturesSwitchTypeFunction
139909139907139908139906Zero TouchProximity switch, willactivate when usercomes close to sensorSingle SwitchActuator
139704Proportional HeadControlSameProportional InputActuator
139705Proportional ChinControl / Mini JoystickSameProportional InputActuator
3514Head Rest MountSameMountMount
26102611Swing Away MountSameMountMount
2615Bib MountSameMountMount
3395347034202660Arm Rest MountMounts the USCM to thearmrest. PositionsdisplayMountMount
3205Midline MountPositions joystick inmiddle of seatMountMount
34703420Remote MountSameMountMount

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:

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Identification of predicate devices:

PREDICATEPREDICATEPREDICATE
DEVICEDEVICEDEVICE
DUFCOQUICKIE DUFCOINVACARE
PredicateDevice Desc.In SubmissionK881463PredicateModel #In SubmissionK881463PredicateCurrentQuickie DufcoDescriptionPredicateCurrentQuickie DufcoModel #PredicateInvacareModel #PredicateInvacareDeviceDescription
BreathActuator2910Breath Control3365SNPM4Sip-N-Puff
N/AN/AElectronic HeadArray3519ASL105CElectronic HeadArray Straightw/bracket
Tri-switchHead arrayN/ATri SwitchHead array3519
Joystickactuator2656HD SwitchedJoystick26565020MSNPMini Joystickw/Pushw/SNP/DI
Four - To -One Adaptor2355CA-5JunctionBoxASL5025 SwitchAdapter
N/AN/APenta
N/AN/AStar Board
JoystickActuator2656-XMini-SwitchedJoystick2656 -X5020Mini Joystickw/Push
Wafer SwitchActuator2715Wafer Board27155018Wafer Board
Treadle Switch1474PassiveTreadleSwitch1474Passive
Ribbon Switch1475PassiveRibbonSwitch1475Passive
N/AN/ADisc Switch3265Passive
N/AN/ABuddy ButtonSwitchPassive
N/AN/AMicro LightPassive
N/AN/APlatePassive
N/AN/AGraspPassive
PredicateDevice Desc.In Sub-missionK881463PredicateModel #In Sub-missionK881463PredicateCurrentQuickie DufcoDescriptionPredicateCurrentQuickie DufcoModel #PredicateInvacareModel #PredicateInvacareDeviceDescription
N/AN/ASoftPassive5830M4Soft SwitchPackagew/SNP/DI/Display /Adapte
N/AN/AWobble SwitchPassive
N/AN/AZero TouchActive
N/AN/AProportionalHead Control35001500M4RIM HeadControl w/Adj.Slide tube
JoystickActuator(with chincupoption)2651Proportional chincontrol / Mini -Joystick265131851558M4CompactJoystick withDisplay
Actuator/Switched Output2620Switched OutputController33293340335036303660
N/AN/AHead RestMountOr Swing AwayMount3514 & 15RIMHWRIM HardwareFor 1500M4
Swing AwayMount2610 & 11Swing-away mount2610 & 11
Breath TubeKit2422Breath ControlMount2422PKG32666Sip-N-Puff, 16"Fixed
Bib Kit2615Bib Mount26153390PKG32669Complete BibAssembly
ArmrestMount2660Armrest Mount33953470342026601679Arm AttachHdwr For1555M4
N/AN/AMid-line mount3205JCMM4
N/AN/ARemote Mount orChair Back Clamp34703420

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Description of the device:

Alternate actuators (input devices) are designed to provide those with severe physical disabilities the independence to operate a power wheelchair, a power seating system, and an environmental control unit using a device other than the standard joystick. A variety of alternate input actuators are currently available on the market as many power wheelchair users require some form of input control other than a joystick.

In prior submissions, several alternate input devices (specialty controls) and their interface modules were employed in addition to the main wheelchair controller. These included the breath tube interface, which contained a pressure transducer, a single switch scanner module and a display. Other specialty control functions also required independent display boxes and / or displays. However Quickie's new controllers, that are intended to interface with specialty input devices, have incorporated these functions into the Controller/ USCM (Universal Specialty Control Module). This greatly simplifies the wheelchair's configuration as it eliminates the need for additional dedicated interface boxes and displays to be mounted on the chair.

As with the devices currently marketed by Quickie, the alternate actuator is used to signal both the speed and direction of the power chair, as well as the selection of various operating modes which are then controlled by the wheelchair controller/USCM. Examples of the various modes that can be controlled are: maximum speed, drive profile (e.g. indoor/outdoor), latched driving, powered seating systems and environmental controls systems.

The method of selection for both drive control and mode is dependent upon the type of alternate input actuator. Two basic types of input actuators exist: proportional and switched. Both types are compatible with Quickie's controller/USCM. When using alternate input actuators, the wheelchair controller will enter a sleep state if the actuator has not sent a signal for a specified period of time. This helps to extend the life of the chair batteries, and reduces the likelihood of unintentional movement.

The primary change being addressed is the modification of one of the standard connectors used to interface with the Quickie Controllers that have a Universal Specialty Control Unit (USCM). Two of the three connections that were made to the old Multi-mode remain the same. Some devices used a breath tube that activated a pressure transducer that translated the air pressure to electrical signals. This connection remains unchanged. Some devices used a single jack connector to transfer signal. This connection also remains unchanged. The third type of connector employed by the prior Multi-mode device was a DB15 connector. The Controller/ USCM, which replaces the Multi-mode, translates the same signals using a DB9 connector. The DB9 was selected for the Controller/USCM because it has developed across the specialty input device industry as the standard connector. The DB-9 is used by many companies making specialty input devices including Switch-it, Tash, and ASL.

{5}------------------------------------------------

Warnings, cautions and contraindications are in the user's manual.

COMPARISON OF DEVICE CHARACTERISTICS TO PREDICATE(S):

Testing:

Pull Out StrengthPass
Insertion ForcePass
Pin Activity CompatibilityPass

Safety:

An analysis of complaints against Quickie chairs was completed and charted. See Chart # 1 in This analysis was supported by a literature search which was conducted by a this section. third party to determine the number of complaints, MDR's and recalls that have been reported to the FDA concerning wheelchairs in general. This information was summarized, and presented in a Management Review report dated 2/20/97. The analysis demonstrated common issues across all manufacturers product lines, and varying levels approximately comparable to relative market share.

Efficacy

Articles are being provided on the use and efficacy of mechanical reclining wheelchairs. See Appendix D.

510(k) number:

Not assigned at the writing of this summary

Conclusion:

There are no new issues of safety or efficacy.

The indications for use are the same, the technological characteristics are the same, and the performance characteristics are the same for both the modified and predicate devices.

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Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850

NOV 6 1998

Ms. Rebecca Andersen Vice President, Quality and Regulatory Affairs Sunrise Medical, Inc. Mobility Products Division 7477A East Dry Creek Parkway Longmont, Colorado 80503

Re : K983520 Trade Names: Breath Control, Model # 139700 Head Array, Model # 139900 Tri-switch Head Array, Model # 139702 Heavy Duty Switched Joystick, Model # 139703 CA-5 Junction Box, Model # 139923 Penta Switch, Model # 139924 4 Zero Touch Switch without Lap Tray, Model # 139907 5 Zero Touch Switch without Lap Tray, Model # 139908 5 Zero Touch Switch with Lap Tray, Model # 139906 Mini-Switched Joystick, Model # 139706 Wafer Board, Model # 139922 Star Board, Model # 139925 Treadle Switch, Model # 139720 Ribbon Switch, Model # 139721 Disc Switch, Model # 139722 Buddy Button Switch, Model # 139920 Micro Light Switch, Model # 139921 Plate, Model # 139926 Grasp, Model # 139927 Soft, Model # 139928 Wobble Switch, Model # 139910 Zero Touch, Model # 139909 Proportional Head Control, Model # 139704 Proportional Chin Control/Mini Joystick, Model # 139705 Head Control Mount, Model # 3514 Swing-away mount, Model # 3514-x Bib Mount, Model # 2615 Armrest Mount, Model # 2660 Mid-line Mount, Model # 3205 Regulatory Class: II Product Code: ITI Dated: September 28, 1998 Received: October 8, 1998

Dear Ms. Andersen:

We have reviewed your Section 510(k) notifications of intent to market the devices referenced above and we have determined these devices are substantially equivalent (for the indications for use stated in the enclosures) to devices

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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). You may, therefore, market the devices, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions aqainst misbranding and adulteration.

If your devices are classified (see above) into either class II (Special Controls) or class III (Premarket Approval), they may be subject to such additional controls. Existing major requlations affecting your devices can be found in the Code of Federal Requlations, Title 21, Parts 800 to 895. A substantially equivalent determination assumes compliance with the current Good Manufacturing Practice requirement, as set forth in the Quality System Regulation (QS) for Medical Devices: General regulation (21 CFR Part 820) and that, through periodic (QS) inspections, the Food and Drug Administration (FDA) will verify such assumptions. Failure to comply with the GMP regulation may result in regulatory In addition, FDA may publish further announcements action. concerning your devices in the Federal Register. Please note: this response to your premarket notification submission does not affect any obligation you might have under sections 531 through 542 of the Act for devices under the Electronic Product Radiation Control provisions, or other Federal laws or regulations.

This letter will allow you to beqin marketing your devices as described in your 510(k) premarket notification. The FDA finding of substantial equivalence of your devices to legally marketed predicate devices results in a classification for your devices and thus, permits your devices to proceed to the market.

If you desire specific advice for your devices on our labeling regulation (21 CFR Part 801 and additionally 809.10 for in vitro diaqnostic devices), please contact the Office of Compliance at (301) 594-4659. Additionally, for questions on the promotion and advertising of your devices, please contact the Office of Compliance at (301) 594-4639. Also, please note the regulation entitled, "Misbranding by reference to
premarket notification" (21 CFR 807.97). Other gener Other general information on your responsibilities under the Act may be

{8}------------------------------------------------

Page 3 - Page 2 - Ms. Rebecca Andersen

obtained from the Division of Small Manufacturers Assistance obtained Trom the Division of 6.0.2.2041 or (301) 443-6597 or at at fes corr free namber (s://www.fda.gov/cdrh/dsmamain.html".

Sincerely yours,

Celia M. Witten, Ph.D., M.D.

Director Division of General and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health

Enclosure

{9}------------------------------------------------

CONFIDENTIAL

12.2 Indications for Use

Alternate input devices are designed to provide those with sever physical disabilities the independence to operate a power wheelchair, a power seating system, and an environmental control unit from a single actuating device.

510(k) number: Not assigned as of this time

Device name: Input Actuators and Mounts

Concurrence of CDRH, Office of Device Evaluation (ODE)

Prescription use (per 21 CFR801.109)

[X] Over-the-counter use

bocollfo

Sign-Off f General Restorative Device 510(k) Number

§ 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).