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510(k) Data Aggregation
(22 days)
Merits Health Products Co., LTD.
The Merits P335 Powered Wheelchair is intended to provide indoor mobility to persons limited to a seating position that are capable of operating a powered wheelchair.
The Merits P335 Powered Wheelchair is to provide indoor and outdoor mobility to persons limited to a seating position that are capable of operating a powered wheelchair.
The Merits P335 Powered Wheelchair is battery powered, front wheel motor driven and is controlled by the PG power wheelchair R-net 120 amp controller. The user interface is a joystick. P335 is powered by two 12 VDC 60ah batteries. The batteries are charged by 6A off-board charger connect with 3-pin Microphone Connector to charging socket on joystick. The approximate driving range on fully charged batteries is up to 30km (19mi). The chair frame is a welded steel construction and includes two front drive wheels with drive units (including motor, gear, and brake), batteries and rear pivoting casters. Depending on users' needs, the joystick motor control is mounted to the left or right armrest. When the user activates the joystick, the controller receives a signal to release the brakes. With the brakes released, the wheelchair is allowed to move in the direction the joystick is actuated. When the user releases the joystick, the chair slows to a stop and the brakes are automatically re-engaged. The solenoid electromechanical brakes allow the user stop by letting go of the joystick.
The device is equipped with a Power Seating System consists of a power tilt unit, a power recline module and an optional power elevating seat module. The tilt, reclining and elevating systems are actuated by 24V DC motorized linear actuator. The tilt system includes one motorized linear actuator caused the seat frame to shift forward. This enhances stability since the center of gravity is kept substantially in place while the user is tilting. The recline system include one motorized linear actuator change the position of the backrest with respect to the seat pan. The optional elevating seat module use one motorized linear actuator which allows the user to elevate the seat pan for easy accessing things stored in higher places.
The upholstery of the device complies with ISO 7176-16:2012: Wheelchairs -- Part 16: Resistance to ignition of postural support devices.
The device can be operated on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.
The provided document is a 510(k) premarket notification for a powered wheelchair (Merits P335). It does not describe an AI/ML powered medical device, an imaging device, or diagnostic software. Therefore, the requested information about acceptance criteria for an AI/ML device, sample sizes for test sets, expert ground truth, adjudication methods, MRMC studies, standalone performance, training set details, or data provenance is not applicable to this document.
The document primarily focuses on demonstrating substantial equivalence to a predicate device (Permobil F3 FWD Powered Wheelchair). The acceptance criteria described are in the form of compliance with various ISO and IEC standards related to powered wheelchairs, and the "study" is the non-clinical testing performed to confirm adherence to these standards.
Here's the relevant information based on the document:
1. A table of acceptance criteria and the reported device performance:
The acceptance criteria are implicitly meeting the requirements of the listed international standards (ISO and IEC). The reported device performance is that the "results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device."
STD No. | Title of Standard | FDA Rec. No. | Reported Device Performance |
---|---|---|---|
ISO 7176-1:2014 | Determination of Static Stability | 16-195 | Passed |
ISO 7176-2:2017 | Determination of Dynamic Stability of electric | ||
wheelchairs | 16-202 | Passed | |
ISO 7176-3:2012 | Determination of effectiveness of brakes | 16-192 | Passed |
ISO 7176-4:2008 | Energy consumption of electric wheelchairs and | ||
scooters for determination of theoretical distance | |||
range | 16-162 | Met | |
ISO 7176-5:2008 | Determination of overall dimensions, mass and | ||
maneuvering space | 16-163 | Met | |
ISO 7176-6:2018 | Determination of maximum speed, acceleration and | ||
deceleration of electric wheelchairs | 16-204 | Met | |
ISO 7176-7:1998 | Method of Measurement of Seating and Wheel | ||
Dimensions | 16-196 | Met | |
ISO 7176-8:2014 | Requirements and test methods for static, impact and | ||
fatigue strengths | 16-197 | Passed | |
ISO 7176-9:2009 | Climatic tests for wheelchairs | 16-167 | Met |
ISO 7176-10:2008 | Determination of obstacle-climbing ability of | ||
electrically power wheelchairs | 16-164 | Met | |
ISO 7176-11:2012 | Test dummies | 16-190 | Used as specified |
ISO 7176-13:1989 | Determination of coefficient of friction of test surfaces | 16-25 | Met |
ISO 7176-14:2008 | Power and control systems for electrically powered | ||
wheelchairs and scooter- Requirements and test | |||
methods. | 16-165 | Met | |
ISO 7176-15:1996 | Requirements for Information Disclosure, | ||
Documentation and Labeling | 16-27 | Met | |
ISO 7176-16:2012 | Resistance to ignition of postural support devices | 16-191 | Met |
ISO 7176-21:2009 | Requirements and test methods for electromagnetic | ||
compatibility of electrically powered wheelchairs and | |||
scooters, and battery chargers. | 16-166 | Met | |
ISO 7176-25:2013 | Batteries and charger for powered wheelchairs | 16-194 | Passed |
ISO 10993-1:2018 | Biological evaluation of medical devices - Part 1: | ||
Evaluation and testing within a risk management | |||
process | 2-258 | Compliant | |
IEC60601-1-2:2020 | Medical electrical equipment - Part 1-2: General | ||
requirements for basic safety and essential | |||
performance - Collateral Standard: Electromagnetic | |||
disturbances - Requirements and tests | 19-36 | Met |
2. Sample size used for the test set and the data provenance: Not applicable. This is a physical device, and testing is performed according to the specified standards (e.g., durability cycles, static/dynamic stability tests), not on a "test set" of data in the AI/ML sense. Data provenance is not specified beyond "non-clinical testing."
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts: Not applicable. Ground truth for a physical medical device meeting performance standards is established by adherence to the objective criteria and methodologies outlined in the international standards, not by expert consensus on a test set.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set: Not applicable.
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 is not an AI-powered device or a diagnostic imaging device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done: Not applicable.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc): The "ground truth" here is compliance with established international performance and safety standards for powered wheelchairs (e.g., ISO 7176 series, IEC 60601-1-2) which involve objective measurements and tests.
8. The sample size for the training set: Not applicable. There is no AI/ML component; therefore, no training set.
9. How the ground truth for the training set was established: Not applicable.
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(260 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits Yoga Power Scooter, S542, is to provide mobility to adult persons limited to a sitting position and capable to operate a few simple controls.
The Merits Yoga Power Scooter, S542, is battery powered, rear transaxle driven and is controlled by the PG S-Drive 45amp controller. The user interface is a wig-wag control lever and a speed knob on the control panel. S542 is powered by one 12 VDC 11.5Ah battery. The batteries are charged by 4.3A off-board charger connect with 3-pin Microphone Connector to charging socket on the rear shroud. The approximate driving range on fully charged batteries is up to 18km (11.3mi). The scooter frame is a welded aluminum construction and includes 2 rear wheels with drive units (including motor, gear box, and brake), a removable battery pack, a front wheel set which consists of 2 wheels for better stability and a tiller to control its turning direction. When the user activates the wig-wag control lever, the controller receives a signal to release the brakes. With the brakes released, the scooter is allowed to move forwards or backwards. When the user releases the control lever, the scooter slows to a stop and the brakes are automatically re-engaged. The solenoid electromechanical brakes allow the user stop by letting go of the control lever. The frame is designed to be foldable for easy storage and transportation.
For safety reason, this solenoid electromechanical brake is designed as normal close type. In case of the brake or electrical failure, the brake shoe will re-engage automatically to prevent the movement of the scooter. The upholstery of the device complies with ISO 7176-16:2012 Resistance to ignition of postural support devices.
The device can be operated on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.
This document is a 510(k) premarket notification for the Merits Yoga Power Scooter, S542. It focuses on demonstrating substantial equivalence to a predicate device rather than detailing specific acceptance criteria and an independent study for the S542. Therefore, much of the requested information about device performance against acceptance criteria for an AI/CAD-type device is not applicable or cannot be extracted from this document, as this is a physical medical device.
However, I can extract information related to the performance testing done to show substantial equivalence.
Here's the breakdown of what can be extracted:
1. Table of Acceptance Criteria and Reported Device Performance
The document doesn't provide a typical "acceptance criteria" table in the sense of a statistical performance target for a diagnostic device (e.g., sensitivity, specificity). Instead, it relies on demonstrating compliance with a series of ISO standards for mobility devices and comparing key characteristics to a predicate device. The "reported device performance" is essentially that the device passed these ISO tests and its characteristics are within an acceptable range or are superior to the predicate device without raising new safety concerns.
Characteristic / Test | Acceptance Criteria (Implied by ISO Standard Compliance & Predicate Comparison) | Reported Device Performance (Merits Yoga Power Scooter, S542) |
---|---|---|
Functional & Safety Standards | Compliance with relevant ISO 7176 series standards for wheelchairs and scooters, and ISO 14971 for risk management. | Passed: |
- ISO 7176-1:1999 Determination of Static Stability | - Device passed. | |
- ISO 7176-2:2001 Determination of Dynamic Stability of electric wheelchairs | - Device passed. Addressed differences in Turning Radius, Dimension, and Max. Speed by confirming no deleterious effect. | |
- ISO 7176-3:2012 Determination of effectiveness of brakes | - Device passed. | |
- ISO 7176-4:2008 Energy consumption... determination of theoretical distance range | - Device passed. Travel range of 11.25 miles (better than predicate's 10 miles). | |
- ISO 7176-5:2008 Determination of overall dimensions, mass and maneuvering space | - Device passed. Differences in dimensions accepted due to stability tests. | |
- ISO 7176-6:2001 Determination of maximum speed, acceleration and deceleration | - Device passed. Max. Speed 4 mph (vs predicate's 4.5 mph), confirmed no deleterious effect. | |
- ISO 7176-7:1998 Method of Measurement of Seating and Wheel Dimensions | - Device passed. | |
- ISO 7176-8:1998 Requirements and test methods for static, impact and fatigue strengths | - Device passed. Addressed differences in Max. Speed, Weight, and Battery by confirming no deleterious effect. | |
- ISO 7176-9:2009 Climatic tests for wheelchairs | - Device passed. | |
- ISO 7176-10:2008 Determination of obstacle-climbing ability | - Device passed. | |
- ISO 7176-11:2012 Test dummies | - Device passed. | |
- ISO 7176-13:1989 Determination of coefficient of friction of test surfaces | - Device passed. | |
- ISO 7176-14:2008 Power and control systems... | - Device passed. | |
- ISO 7176-15:1996 Requirements for Information Disclosure, Documentation and Labeling | - Device passed. | |
- ISO 7176-16:2012 Resistance to ignition of postural support devices | - Device passed. Upholstery complies. | |
- ISO 7176-21:2009 Requirements and test methods for electromagnetic compatibility | - Device passed. | |
- ISO 14971:2007 Medical devices -- Application of risk management | - Device passed. | |
Key Device Characteristics (Comparison to Predicate: Merits Travel Ease Electric Scooter, Model Pioneer 5) | Substantially equivalent or demonstrably safe/effective despite differences. | |
Max. Speed | No deleterious effect compared to predicate (4.5 mph). | 4 mph (Passed ISO 7176-2 & ISO 7176-8 tests demonstrating no deleterious effect despite lower speed). |
Range up to | No less than predicate (10 miles). | 11.25 miles (Better than predicate). |
Weight | No deleterious effect compared to predicate (92 lb total, 50 lb base). | 56.7 lb total, 53 lb base (lighter, passed ISO 7176-8 confirming no deleterious effect; beneficial for transport). |
Battery | Safe and effective compared to predicate (24V/12Ah Lead Acid Battery). | 24V/11.5Ah Li-ion Battery (lighter, longer range; passed ISO 7176-8 and UN 38.3 Transportation Testing for safety, confirming no deleterious effect). |
Turning Radius | No deleterious effect compared to predicate (33.8"). | 37.8" (Passed ISO 7176-2 tests confirming no deleterious effect). |
Dimension (L, W, H) | No deleterious effect compared to predicate (L: 38.5", W: 19.7", H: 48"). | L: 39"/20.2", W: 17.2", H: 39.6"/24.2" (Passed ISO 7176-1 & ISO 7176-2 tests confirming no deleterious effect). |
Suspension | No deleterious effect compared to predicate (No Suspension). | Front Wheel Leaf Spring (More comfortable; passed ISO 7176-2 & ISO 7176-8 tests confirming no deleterious effect). |
2. Sample size used for the test set and the data provenance
- Sample Size: The document does not specify a "sample size" in terms of number of devices tested or cases, but implies that one or more Merits Yoga Power Scooters, S542, were subjected to the specified ISO standard tests. For physical device testing against standards, typically a representative sample is used, but a specific number is not provided.
- Data Provenance: The tests were conducted to comply with international (ISO) standards. The manufacturer is Merits Health Products Co., Ltd. in Taiwan, which implies the testing likely occurred at accredited labs in Taiwan or through international certification bodies. The document does not explicitly state if the testing was retrospective or prospective, but standard compliance testing is typically performed prospectively as part of product development and validation.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- This is not applicable to a physical mobility device like a scooter. "Ground truth" established by experts is typically relevant for diagnostic AI/CAD devices where clinical opinions or pathology results define the correct answer. For this product, the "ground truth" is defined by compliance with engineering standards and performance specifications.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- This is not applicable. Adjudication methods are specific to expert review or consensus building for diagnostic interpretations, not for physical device performance testing against objective standards.
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
- This is not applicable. MRMC studies are for evaluating diagnostic image interpretation by human readers, often with and without AI assistance. This document describes a physical mobility device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This is not applicable. "Standalone performance" refers to the performance of an algorithm without human interaction, relevant for AI/CAD devices. This is a physical scooter.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.)
- The "ground truth" for this device is compliance with established international engineering and safety standards (ISO 7176 series, ISO 14971) and meeting stated performance specifications (e.g., speed, range, weight capacity). The benchmark for "substantial equivalence" is also the performance and characteristics of the identified predicate device (Merits Travel Ease Electric Scooter, Model Pioneer 5 – K013788).
8. The sample size for the training set
- This is not applicable. There is no "training set" in the context of a physical mobility device. Training sets are relevant for machine learning algorithms.
9. How the ground truth for the training set was established
- This is not applicable for the same reason as above.
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(268 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits Transformer Power Scooter, S941, is to provide mobility to adult persons limited to a sitting position and capable to operate a few simple controls.
The Merits Transformer Power Scooter, S941, is battery powered, rear transaxle driven and is controlled by the Dynamic Rhino-2 120amp controller. The user interface is a throttle lever and control buttons on the control panel. S941 is powered by two 12 VDC 50ah (22NF) batteries. The batteries are charged by 5A off-board charger connect with 3-pin Microphone Connector to charging socket on Tiller. The approximate driving range on fully charged batteries is up to 40km (25mi). The scooter frame is a welded steel construction and includes 2 rear wheels with drive units (including motor, gear box, and brake), batteries, 2 front wheels and a tiller to control its turning direction. When the user activates the throttle lever, the controller receives a signal to release the brakes. With the brakes released, the scooter is allowed to move forwards or backwards. When the user releases the throttle lever, the scooter slows to a stop and the brakes are automatically re-engaged. The solenoid electromechanical brakes allow the user stop by letting go of the throttle lever. The upholstery of the device complies with ISO 7176-16:2012 Resistance to ignition of postural support devices.
The device can be operated on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.
This document describes a 510(k) premarket notification for the Merits Transformer Power Scooter, S941, and its substantial equivalence to a predicate device. This is a notification for a physical product, not a software device, and therefore the requested information regarding AI/algorithm performance and study details is not applicable.
Here's a breakdown of the provided information, focusing on the device, not an algorithm:
1. Table of Acceptance Criteria and Reported Device Performance
The acceptance criteria are established by a series of ISO standards for wheelchairs and scooters. The document states that the device was tested against these standards and "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device."
Acceptance Criteria (ISO Standard) | Reported Device Performance |
---|---|
ISO 7176-1:1999 Determination of Static Stability | Meets specifications |
ISO 7176-2:2001 Determination of Dynamic Stability of electric wheelchairs | Meets specifications |
ISO 7176-3:2012 Determination of effectiveness of brakes | Meets specifications |
ISO 7176-4:2008 Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range | Meets specifications |
ISO 7176-5:2008 Determination of overall dimensions, mass and maneuvering space | Meets specifications |
ISO 7176-6:2001 Determination of maximum speed, acceleration and deceleration of electric wheelchairs | Meets specifications |
ISO 7176-7:1998 Method of Measurement of Seating and Wheel Dimensions | Meets specifications |
ISO 7176-8:1998 Requirements and test methods for static, impact and fatigue strengths | Meets specifications |
ISO 7176-9:2009 Climatic tests for wheelchairs | Meets specifications |
ISO 7176-10:2008 Determination of obstacle-climbing ability of electrically power wheelchairs | Meets specifications |
ISO 7176-11:2012 Test dummies | Meets specifications |
ISO 7176-13:1989 Determination of coefficient of friction of test surfaces | Meets specifications |
ISO 7176-14:2008 Power and control systems for electrically powered wheelchairs and scooter- Requirements and test methods. | Meets specifications |
ISO 7176-15:1996 Requirements for Information Disclosure, Documentation and Labeling | Meets specifications |
ISO 7176-16:2012 Resistance to ignition of postural support devices | Meets specifications |
ISO 7176-21:2009 Requirements and test methods for electromagnetic compatibility of electrically powered wheelchairs and scooters, and battery chargers. | Meets specifications |
ISO 14971:2007 Medical devices -- Application of risk management to medical devices | Meets specifications |
2. Sample size used for the test set and the data provenance
The document does not specify a "sample size" in the context of an algorithm's test set. The tests were performed on the physical device itself. The provenance of the testing data would be from the manufacturing facility or a contracted testing lab. The study is a non-clinical performance evaluation of the physical device, not an analysis of a dataset.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
This is not applicable as there is no "ground truth" to be established by experts for a physical device's performance against engineering standards. The ground truth here is derived from the objective measurements and pass/fail criteria of the ISO standards.
4. Adjudication method for the test set
Not applicable. The tests against ISO standards have predefined criteria for pass/fail, not human adjudication.
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 is for a physical medical device (a scooter), not an AI algorithm.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. This is for a physical medical device, not an algorithm.
7. The type of ground truth used
The "ground truth" for the device's performance is adherence to the specified ISO standards. These standards define objective test methods and acceptable performance limits (e.g., stability angles, braking distances, speed ranges).
8. The sample size for the training set
Not applicable. This submission is for a physical device, not an algorithm trained on data.
9. How the ground truth for the training set was established
Not applicable. There is no training set for a physical device.
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(159 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits Model P322 Powered Wheelchair is to provide outdoor and indoor mobility to persons limited to a seated position that are capable of operating a powered wheelchair.
Model P322 Powered Wheelchair is battery powered, front wheel motor driven and is controlled by the PG power wheelchair VR-2 50amp controller. The user interface is a joystick. P322 is powered by two 12 VDC 34ah (U1) batteries. The batteries are charged by 4A off-board charger connect with 3-pin Microphone Connector to charging socket on joystick. The approximate driving range on fully charged batteries is up to 28km (18mi). The chair frame is a rived nut and welded steel construction and includes two front drive wheels with drive units (including motor, gear, brake), batteries and rear pivoting casters. Depending on users needs, the joystick motor control is mounted to the left or right armrest. When the user activates the joystick, the controller receives a signal to release the brakes. With the brakes released, the wheelchair is allowed to move in the direction the joystick is actuated. When the user releases the joystick, the chair slows to a stop and the brakes are automatically re-engaged. The solenoid electromechanical brakes allow the user stop by letting go of the joystick.
The upholstery of the device complies with EN 1021-1/-2:2006: Furniture: Assessment of the ignitability of upholstered furniture: Ignition source: Smouldering cigarette/ Match flame equivalent
The device can be operated on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.
The document describes a 510(k) premarket notification for the Merits Model P322 Powered Wheelchair. This type of submission relies on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving novel efficacy. Therefore, the "acceptance criteria" discussed are primarily related to meeting established performance standards for powered wheelchairs, and the "study" is a series of non-clinical tests to show compliance with these standards.
Here's the information requested, based on the provided text:
1. A table of acceptance criteria and the reported device performance
Acceptance Criteria Category | Specific Standard/Test | Description/Purpose (Acceptance Criteria) | Reported Device Performance |
---|---|---|---|
Stability | ISO 7176-1:1999 | Determination of Static Stability | Meets specifications |
ISO 7176-2:2001 | Determination of Dynamic Stability of electric wheelchairs | Meets specifications | |
Braking | ISO 7176-3:2003 | Determination of effectiveness of brakes | Meets specifications |
Range/Power | ISO 7176-4:2008 | Energy consumption for determination of theoretical distance range | Up to 28km (18mi) on fully charged batteries; Meets specifications |
Dimensions/Maneuvering | ISO 7176-5:2008 | Determination of overall dimensions, mass and maneuvering space | Meets specifications |
Acceleration/Deceleration | ISO 7176-6:2001 | Determination of maximum acceleration and deceleration of electric wheelchairs | Meets specifications |
Seating/Wheel Dimensions | ISO 7176-7:1998 | Method of Measurement of Seating and Wheel Dimensions | Meets specifications |
Strength/Durability | ISO 7176-8:1998 | Requirements and test methods for static, impact and fatigue strengths | Meets specifications |
Environmental | ISO 7176-9:2009 | Climatic tests for wheelchairs | Meets specifications |
Obstacle Climbing | ISO 7176-10:2008 | Determination of obstacle-climbing ability of electrically power wheelchairs | Meets specifications |
Test Dummies | ISO 7176-11:1992 | Test dummies (Standard for test methodology) | N/A (Standard for test design) |
Friction Coefficient | ISO 7176-13:1989 | Determination of coefficient of friction of test surfaces | Meets specifications |
Control Systems | ISO 7176-14:2008 | Power control systems for electrically powered wheelchairs and scooters - Requirements and test methods | Meets specifications |
Information/Labeling | ISO 7176-15:1996 | Requirements for Information Disclosure, Documentation and Labeling | Meets specifications |
Electrical Safety | IEC 60601-1:1988 | General requirements for safety | Meets specifications |
EMC | IEC 60601-1-2:2007 | Electromagnetic Compatibility Requirements and Tests | Meets specifications |
Risk Management | ISO 14971:2007 | Application of risk management to medical devices | Meets specifications |
Upholstery Ignitability | EN 1021-1:2006 | Ignition source: Smouldering cigarette | Complies |
EN 1021-2:2006 | Ignition source: Match flame equivalent | Complies |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
The document describes non-clinical testing of the Merits Model P322 Powered Wheelchair. This type of testing typically involves one or more physical units of the device being subjected to standardized tests in a laboratory setting. There is no specific sample size mentioned (e.g., "N=X wheelchairs tested"), nor is there information about data provenance in terms of country of origin or retrospective/prospective nature, as these concepts usually apply to clinical studies with human subjects or real-world data. The tests are prospective in the sense that they are performed on the device to demonstrate compliance.
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)
This section is not applicable to this type of device and submission. The "ground truth" for the performance tests of a powered wheelchair is defined by the technical specifications and requirements of the ISO, IEC, and EN standards listed. The "experts" involved would be the engineers and technicians performing the tests, qualified in understanding and executing these specific technical standards. Their qualifications are not detailed in the submission, as it's assumed they are competent to perform the standard tests.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable. Adjudication methods like 2+1 or 3+1 are used in clinical studies, particularly for diagnostic devices, to resolve disagreements among human readers or experts on ground truth determination. For engineering performance tests, the outcome is typically an objective measurement against a defined standard.
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
This is not applicable. MRMC studies are relevant for diagnostic devices (often AI-assisted) where human interpretation of medical images or data is involved. This submission is for a powered wheelchair, which does not involve human readers interpreting AI outputs.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
This is not applicable. A powered wheelchair is a physical device, not an algorithm. The "standalone performance" refers to the device's ability to meet the specified performance metrics (e.g., stability, braking, range) on its own, which is precisely what the non-clinical tests demonstrate.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
The "ground truth" for the Merits Model P322 Powered Wheelchair's performance is established by international and national engineering and safety standards (ISO, IEC, EN). Compliance with these standards serves as the objective measure of the device's technical performance and safety. There is no expert consensus, pathology, or outcomes data used as ground truth in this context.
8. The sample size for the training set
This is not applicable. This device is a physical product (a powered wheelchair) and does not involve AI or machine learning, which rely on training data sets.
9. How the ground truth for the training set was established
This is not applicable, as there is no training set for this device.
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(155 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits Model R series Positioning System for Powered Wheelchair is intended for people using a powered wheelchair and requiring positional change. Its intended function and use is to aid in the pressure relief to persons confined to a powered wheelchair, by way of tilt and reclining seat back.
The R Series Positioning System for Powered Wheelchair is designed for use with power wheelchairs. The R Series Positioning System for Powered Wheelchair use the Merits Model P323 Power Wheelchair as the base unit for the tilting and reclining System. The Positioning System and base unit is to be sold together. Model P323 Powered Wheelchair is battery powered, center wheel motor driven and is controlled by the PG power wheelchair VR-2 60amp controller. The user interface is a joystick. P323 is powered by two 12 VDC 64ah batteries. The batteries are charged by 5A off-board charger connect with 3-pin Microphone Connector to charging socket on joystick. The approximate driving range on fully charged batteries is up to 38km (24mi). The chair frame is a rived nut and welded steel construction and includes two center drive wheels with drive units (including motor, gear, brake), batteries and front and rear pivoting casters. Depending on users needs, the joystick motor control is mounted to the left or right armrest. When the user activates the joystick, the controller receives a signal to release the brakes. With the brakes released, the wheelchair is allowed to move in the direction the joystick is actuated. When the user releases the joystick, the chair slows to a stop and the brakes are automatically re-engaged. The solenoid electromechanical brakes allow the user stop by letting go of the joystick. The intended function of the R Series Positioning System for Powered Wheelchair is to aid in the pressure relief of persons confined to a wheelchair, by providing a method of tilting the seat and reclining the seat back. The R series Positioning System consists of tilt, recline and shear reduction power seat modules. The tilting and reclining systems are separate modules and are independent of each other. As such, they will be offered as either a complete tilt/recline system, or as a separate tilt system or reclining system depending upon the user' needs. The tilting and reclining systems are actuated by 24V DC motorized linear actuator. The tilt system include one motorized linear actuator (Manufacturer: Moteck / Model: FD-24-A4-323) causes the seat frame to shift forward. This enhances stability since the center of gravity is kept substantially in plane while the user is tiliting. The recline system include one motorized linear actuator (Manufacturer: Moteck / Model: FD-24-A4-278) change the position of the backrest with respect to the seat pan. The shear reduction module works with recline function to reduce the shear movement between the user and the backress The reclining system also includes a movable leg rest feature. There two basic models included in the R Series Positioning System. They are Model R153(tilt) and R154(tilt +reclining). The upholstery of the device complies with EN 1021-1/-2:2006: Furniture: Assessment of the ignitability of upholstered furniture: Ignition annuce: Smouldering cigarette/ Match flame equivalent. The device can be operated on dry, level surfaces composed of concrete, blacktop, or asphalt under normal driving conditions.
The provided text describes a 510(k) premarket notification for a medical device, the Merits Model R Series Positioning System for Powered Wheelchair. This submission focuses on establishing substantial equivalence to a predicate device through non-clinical testing, rather than a clinical study evaluating the device's performance against specific clinical acceptance criteria in a human population.
Therefore, many of the requested categories related to clinical study design, such as "sample size used for the test set," "data provenance," "number of experts used to establish ground truth," "adjudication method," "MRMC comparative effectiveness study," "standalone performance," "type of ground truth," and "training set details," are not applicable in this context. The information provided pertains to engineering and safety performance testing.
Here's an analysis based on the available information:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Standard & Section) | Reported Device Performance |
---|---|
ISO 7176-1:1999 (Determination of Static Stability) | Device meets specifications. |
ISO 7176-2:2001 (Determination of Dynamic Stability of electric wheelchairs) | Device meets specifications. |
ISO 7176-3:2003 (Determination of effectiveness of brakes) | Device meets specifications. |
ISO 7176-4:2008 (Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range) | Device meets specifications. |
ISO 7176-5:2008 (Determination of overall dimensions, mass and maneuvering space) | Device meets specifications. |
ISO 7176-6:2001 (Determination of maximum speed, acceleration and deceleration of electric wheelchairs) | Device meets specifications. |
ISO 7176-8:2009 (Requirements and test methods for static, impact and fatigue strengths) | Device meets specifications. |
ISO 7176-9:2009 (Climatic tests for wheelchairs) | Device meets specifications. |
ISO 7176-10:2008 (Determination of obstacle-climbing ability of electrically power wheelchairs) | Device meets specifications. |
ISO 7176-11:1992 (Test dummies) | Device meets specifications. |
ISO 7176-13:1989 (Determination of coefficient of friction of test surfaces) | Device meets specifications. |
ISO 7176-14:2008 (Power and Control Systems for Electric Powered Wheelchairs and Scooters-Requirements and Test methods) | Device meets specifications. |
ISO 7176-15:1996 (Requirements for Information Disclosure, Documentation and Labeling) | Device meets specifications. |
ISO 7176-21:2009 (Requirements and Test Methods for Electromagnetic Compatibility of Electrically Powered Wheelchairs and Scooters and Battery Chargers) | Device meets specifications. |
IEC 60601-1:1988 (Medical electrical equipment Part 1: General requirements for safety) | Device meets specifications. |
IEC 60601-1-2:2007 (Electromagnetic Compatibility - Requirements and Tests) | Device meets specifications. |
ISO 14971:2007 (Medical devices -- Application of risk management to medical devices) | Device meets specifications. |
EN 1021-1:2006 (Furniture Assessment of the ignitability of upholstered furniture : Ignition source: Smouldering cigarette) | Device complies. |
EN 1021-2:2006 (Furniture Assessment of the ignitability of upholstered furniture : Ignition source: Match flame equivalent) | Device complies. |
2. Sample size used for the test set and the data provenance
- Sample Size: The document does not specify the number of units tested. This type of non-clinical testing typically involves a limited number of production units or prototypes.
- Data Provenance: The testing was conducted by Merits Health Products Co., LTD. (Taiwan) according to international standards (ISO, IEC, EN). The data is retrospective in the sense that it was generated prior to the 510(k) submission to demonstrate compliance.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- This question is not applicable. For non-clinical performance and safety testing against international standards, "ground truth" is not established by clinical experts but by adherence to the specific test methodologies and criteria outlined in each standard. The expertise lies in the engineers and technicians performing and verifying the tests in accordance with these standards.
4. Adjudication method for the test set
- This question is not applicable. Adjudication methods like 2+1 or 3+1 are typically used in clinical studies for interpretation of images or symptoms. For this type of device testing, the results are objectively measured against the quantitative or qualitative pass/fail criteria of each standard.
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
- This question is not applicable. The device is a powered wheelchair positioning system, not an AI-assisted diagnostic or therapeutic tool. Therefore, an MRMC study is not relevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- This question is not applicable. The device is a mechanical and electrical system, not an algorithm, and is designed for human interaction (the user and caregivers).
7. The type of ground truth used
- The "ground truth" in this context is the established performance and safety requirements defined by the international ISO, IEC, and EN standards listed in the document. These standards specify objective test methods and acceptance criteria for various aspects of wheelchair performance, safety, and functionality (e.g., static stability, brake effectiveness, electromagnetic compatibility, material ignitability).
8. The sample size for the training set
- This question is not applicable. The device is not based on machine learning or AI that would require a "training set."
9. How the ground truth for the training set was established
- This question is not applicable for the reasons mentioned in point 8.
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(288 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits Model N Series Nebulizer Compressors are AC-powered air compressors intended to provide a source of compressed air for medical purposes for use in home health care. These devices are used in conjunction with a pneumatic nebulizers to produce fine aerosol mists of medication for respiratory therapy, for both children and adults suffering from respiratory disorders such as asthma, allergies, etc.
The Merits Model N Series Nebulizer Compressors consist of AC powered piston-type compressors that generates compressed air. They are small, lightweight and designed for convenience. The piston-type compressor is housed in a plastic cabinet with rubber bumpers. The motor driven piston compressor is connected with a power cord and a switch. The devices contain no microprocessors or other electronic components. They operate from 115VAC/60Hz. Each of them is supplied with tubing, a nebulizer kit and several replaceable filters.
Model N281 and N282 are identical in specifications and components. The only difference is they use different cabinets which are different in size and shape.
When using, the compressor is placed on a flat surface. Air delivery tubing and a nebulizer kit are connected to the outlet hose barb. The air passes the replaceable filter is compressed and delivered to the nebulizer kit through the tubing.
This 510(k) summary describes a Nebulizer Compressor, a device that provides a source of compressed air for pneumatic nebulizers. The context provided is a regulatory submission for a medical device trying to demonstrate "substantial equivalence" to a predicate device. This type of submission generally focuses on comparing the new device's specifications and performance to an already legally marketed device rather than proving novel effectiveness through a new study with strict "acceptance criteria" and "ground truth" as might be found for AI/ML or diagnostic devices.
Given the nature of the device (a nebulizer compressor) and the available document, the questions provided in the prompt are not directly applicable. This document is a 510(k) summary for a relatively simple mechanical device, not a sophisticated diagnostic or AI-driven system. Therefore, concepts like "ground truth," "expert adjudication," "MRMC studies," "training set," and "acceptance criteria" in the way they are typically applied to AI/ML or complex diagnostic devices are not detailed here.
However, I can interpret the document's content to extract what could be considered analogous to acceptance criteria and the "study" that proves it, within the framework of a substantial equivalence submission for this type of device.
Acceptance Criteria and Device Performance for Merits Model N Series Nebulizer Compressor
The "acceptance criteria" for this device are implicitly defined by its performance comparison to a legally marketed predicate device, the SAN UP S.A. Nebulizer Compressor Model: 3050 (K002468). The goal is to demonstrate "substantial equivalence," meaning its characteristics and performance are "basically the same" and "bring forth no new questions of safety and effectiveness."
1. Table of Acceptance Criteria (Implicit) and Reported Device Performance:
Acceptance Criteria Category (Implicit) | Specific Criteria (Implicitly based on Predicate) | Reported Device Performance | Study that Proves it Meets Criteria |
---|---|---|---|
AC-Powered Operation | Should operate from 115VAC/60Hz, similar to predicate. | Operates from 115VAC/60Hz. | Comparative Performance Test of Merits N281/N282 Nebulizer Compressor & SanUp Model 3050 Compressor |
Filter Material | Use the same or equivalent filter material as predicate. | Contains the same filter material. | Comparative Performance Test |
Environmental/Safety/EMC | Meet relevant environmental, safety, and electromagnetic compatibility (EMC) requirements similar to predicate. | Meets Environmental, Safety and EMC requirements. | IEC/UL 60601-1, Medical Electrical Equipment Part1: General Requirements for Safety; IEC 60601-1-2, Medical Electrical Equipment Part 1-2: General Requirements for Safety - Collateral Standard: Electromagnetic Compatibility |
Compressor Operating Pressure Range | Similar compressor operating pressure range as predicate. | Within similar compressor operating pressure range. | Comparative Performance Test |
Compressor Flow Range | Similar compressor flow range as predicate. | Within similar compressor flow range. | Comparative Performance Test |
Performance Characteristics | Performance characteristics are "basically the same" as the predicate. | Performance characteristics are "basically the same." | Comparative Performance Test |
Particle Size Analysis (Nebulization Efficacy) | Produce fine aerosol mists for respiratory therapy, comparable to predicate. | Data from Cascade Impaction Testing for Particle Size Analysis. (Specific values not provided but implied to be acceptable) | Cascade Impaction Testing for Particle Size Analysis |
Emission of Harmful Substances | No harmful emissions (VOCs, CO, O3, PM2.5) above acceptable levels. | Emissions (VOCs, CO, O3 & PM2.5) evaluated. (Specific values not provided but implied to be acceptable) | Emission of VOCs, CO, O3 & PM2.5 |
Intended Use | Aligns with the predicate's intended use for respiratory therapy in home health care. | Intended use matches description for home health care, pneumatic nebulizers, respiratory therapy for children/adults with asthma, allergies, etc. | (Implicit, based on device design and intended use statement) |
The study that proves the device meets the acceptance criteria is detailed in Section 9.10, "Performance Data." This section lists various tests performed to demonstrate the device's safety and performance characteristics are substantially equivalent to the predicate.
2. Sample Size Used for the Test Set and Data Provenance:
- Sample Size for the Test Set: Not explicitly stated. For a mechanical device like a nebulizer compressor, "sample size" usually refers to the number of units tested. It's common in such submissions to test a limited number of production units (e.g., 3-5 units) to confirm specifications. The document refers to "Merits N281/N282 Nebulizer Compressor," implying at least one of each model was tested, but does not specify the number of individual units.
- Data Provenance (Country of origin, retrospective/prospective): Not specified. The submitter is Merits Health Products Co., LTD. in Taichung, Taiwan R.O.C. It is highly probable that the tests were conducted at their facilities or by a contracted lab, likely in Taiwan or a region that adheres to international testing standards (e.g., IEC/UL). These would be prospective tests performed on the new device designs.
3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:
- This concept is not applicable here. For a nebulizer compressor, "ground truth" is established by direct measurement of physical properties (e.g., pressure, flow, electrical safety, particle size) against established engineering standards and the predicate device's performance, not by expert consensus on interpretations of data (like medical images).
- The
IEC/UL 60601-1
andIEC 60601-1-2
standards are objective engineering and safety standards.Cascade Impaction Testing
andEmission Testing
also rely on objective laboratory measurements.
4. Adjudication Method for the Test Set:
- Not applicable. As described above, the evaluation relies on objective measurements against engineering standards and comparison to the predicate device's physical specifications and performance, not on subjective interpretations requiring adjudication.
5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was done:
- No, an MRMC study was not done. MRMC studies are typically performed for diagnostic devices where human readers (e.g., radiologists) interpret cases (e.g., medical images) and their performance is compared with and without AI assistance. This device is a mechanical air compressor, not a diagnostic tool or an AI-driven system.
6. If a Standalone (i.e., algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device does not have an "algorithm" in the sense of a standalone AI/ML component that performs a function subject to such evaluation. It is a mechanical device.
7. The Type of Ground Truth Used:
- For this device, the "ground truth" is objective physical and performance measurements obtained through standardized engineering and safety tests (e.g., IEC/UL standards, comparative performance tests for pressure/flow, cascade impaction for particle size, emission testing). The "truth" is that the device's measured parameters meet safety standards and are "basically the same" as those of the predicate device.
8. The Sample Size for the Training Set:
- Not applicable. This device does not use an "algorithm" based on AI/ML that requires a training set. Its design and operation are based on established mechanical engineering principles.
9. How the Ground Truth for the Training Set Was Established:
- Not applicable, as there is no training set for an AI/ML algorithm.
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(296 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Oxygen Concentrators with the Oxygen Filling accessory are indicated to provide supplemental oxygen to patients in the home and to supply pressurized oxygen to fill gas cylinders for the patient's personal ambulatory use. The device is not intended for life support nor does it provide any patient monitoring capabilities.
The Profill Q601 series oxygen filling machines are prescription devices designed for use in home by patients that require supplemental oxygen. It is intended to pressurize oxygen from an oxygen concentrator to fill gas cylinders for the patient's personal ambulatory use. It is not intended for life support nor does it provide any patient monitoring capabilities.
The device consists of a compressor module and a portable oxygen cylinder with a specially adapted cylinder fitting. It is compatible with available standard oxygen concentrators as the source of oxygen. The oxygen generated by the oxygen concentrator is inducted into a buffer tank. Then it flows to the compressor where the oxygen is pressurized and filled into the cylinder. The devices are not sold or labeled as sterile.
The provided document describes a K091716 submission for the Merits Health Products Profill Q601 Series Oxygen Filling Accessory. This device is subject to a 510(k) premarket notification, which focuses on demonstrating substantial equivalence to a legally marketed predicate device, rather than proving device performance against detailed acceptance criteria through a clinical study in the way an AI diagnostic device would.
Therefore, many of the typical questions for AI device studies regarding acceptance criteria, sample sizes, ground truth, and expert adjudication are not applicable in this context. This submission relies on performance data from engineering tests and a comparison of technological characteristics to establish substantial equivalence.
Here's the breakdown of the information that can be extracted, and where typical AI study information is not applicable:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria Category | Specific Test/Characteristic | Acceptance Criteria (Implicit) | Reported Device Performance |
---|---|---|---|
Safety Tests | Leakage Currents Test | Meets safety standards | Confirmed |
Dielectric Strength | Meets safety standards | Confirmed | |
Rigidity Test | Meets safety standards | Confirmed | |
Stability Test | Meets safety standards | Confirmed | |
Heating Test | Meets safety standards | Confirmed | |
Abnormal Operation & Fault Condition | Meets safety standards | Confirmed | |
Power Cord Test | Meets safety standards | Confirmed | |
Transformer Dielectric Strength | Meets safety standards | Confirmed | |
Ball Pressure Test | Meets safety standards | Confirmed | |
Electromagnetic Compatibility (EMC) Tests | EN60601-1-2 | Meets EMC standards | Finished |
EN61000-3-2 | Meets EMC standards | Finished | |
EN61000-3-3 | Meets EMC standards | Finished | |
Technological Characteristics | Oxygen Source | Same as predicate | Oxygen concentrator |
AC-Powered Motors | Similar to predicate | Similar | |
Oxygen Compressors | Same size & material as predicate | Same | |
Filling Time | Same as predicate | Same | |
Filling Pressure | Same as predicate | Same | |
Safety & EMC Requirements | Same as predicate | Same |
Note: For 510(k) submissions, the "acceptance criteria" for these engineering tests are implicitly that the device meets the relevant industry performance and safety standards. The document states "Verification testing has confirmed the product meets its specifications," which indicates successful completion of these tests in accordance with established benchmarks for safety and functionality.
Regarding the study that proves the device meets the acceptance criteria (and other AI-specific questions):
For this type of device (an Oxygen Filling Accessory), the "study" proving it meets acceptance criteria is a series of engineering and safety tests, not a clinical study involving patients or human readers as would be typical for an AI diagnostic device.
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Not Applicable (N/A). This device is an oxygen filling accessory, not an AI diagnostic tool. The performance data is based on engineering and safety tests of the device itself, not on a test set of patient data or images.
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 (N/A). Ground truth in the context of AI refers to expert labeling of data. For this device, "ground truth" relates to the physical and electrical safety standards that the device must meet, which are objectively measurable by testing engineers.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not Applicable (N/A). This pertains to resolving discrepancies in expert labeling for AI ground truth, which is not relevant here.
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 (N/A). This type of study is for evaluating AI's impact on human performance in diagnostic tasks and is not relevant for an oxygen filling accessory.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Not Applicable (N/A). This refers to the performance of an AI algorithm in isolation, which is not relevant for this device. The device's "performance" is its ability to safely and effectively pressurize oxygen and fill cylinders.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Objective Engineering Standards and Safety Regulations. The "ground truth" for this device's performance is adherence to established international and national safety, electrical, and EMC standards (e.g., EN60601-1-2, EN61000-3-2, EN61000-3-3) and the device's functional specifications (filling time, pressure).
8. The sample size for the training set
- Not Applicable (N/A). This device does not involve machine learning or a training set.
9. How the ground truth for the training set was established
- Not Applicable (N/A). As there is no training set, this question is not relevant.
In summary: The provided document is a 510(k) summary for a medical device that demonstrates substantial equivalence through technical comparisons and adherence to engineering safety standards, rather than clinical efficacy studies often associated with AI diagnostic tools.
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(93 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits E600 Series Stair Lift System is a powered patient transport, also commonly known as a Stairway Chairlift, or Stairlift. It is a motorized device intended for medical purposes to assist transfers of patients, or mobility-impaired persons, up and down flights of stairs.
The Merits E600 Series Stair Lift basically consists of an upholstered chair assembly, a truck assembly, and a maximum 16 feet track. The chair and truck assemblies constitute the platform moving up and down along the inclined track. The entire lift is installed in either side of the indoor stairway in a private residence. All models share the same specifications such as driving means and safeties other than the power source. The Model E600 uses the AC power as its power source while the Model E601 employs the batteries and chargers. The operation of the lift is controlled by a momentary rocker control under one armrest and two infrared remote controls. The move of the lift will stop immediately when the button or switch of the controls is released.
The provided text describes a 510(k) premarket notification for the Merits E600 Series Stair Lift, which is a medical device. This document is a regulatory submission demonstrating substantial equivalence to a predicate device, rather than a study designed to establish new performance criteria or clinical efficacy with detailed statistical analysis as might be expected for an AI/ML medical device.
Therefore, many of the requested elements pertaining to acceptance criteria and performance studies (like sample sizes, ground truth establishment, expert qualifications, adjudication methods, MRMC studies, and standalone performance) are not applicable to this type of document or device submission.
However, I can extract information related to the device's comparison to its predicate and the general nature of its "performance data" as mentioned.
Here's an analysis based on the provided text, addressing the applicable points and explaining the non-applicability of others:
1. A table of acceptance criteria and the reported device performance
The document does not explicitly present a table of quantitative acceptance criteria for performance metrics (such as accuracy, sensitivity, specificity) against which the device's performance is measured. Instead, the "acceptance criteria" are implied by the demonstration of "substantial equivalence" to a legally marketed predicate device (Bruno Electra-Ride II Indoor Straight Rail Stairlift Model SRE-1550, K033752).
- Implied Acceptance Criteria: The device must demonstrate similar technological characteristics and intended use, and show that its "performance data" confirms it meets specifications and is substantially equivalent to the predicate. This is a qualitative comparison rather than a quantitative one against predefined thresholds.
- Reported Device Performance: "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device." The document explicitly states the testing confirmed this, without providing specific numerical performance data.
2. Sample sized used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
Not applicable. This is a premarket notification for a physical medical device (stair lift), not an AI/ML algorithm. The "testing" referred to likely involves engineering verification and validation testing (e.g., load bearing, safety mechanisms, durability) rather than a clinical trial with a "test set" of patients or data. The document does not specify details about these engineering tests, such as sample sizes or data provenance.
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. Ground truth establishment by experts is relevant for diagnostic or AI/ML devices where a "correct answer" needs to be determined for comparison. For a stair lift, the "ground truth" would be the engineering specifications and safety standards, confirmed through physical testing.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
Not applicable. Adjudication methods are typically used in clinical studies or for establishing ground truth when there is disagreement among experts about diagnostic labels or outcomes. This concept does not apply to the regulatory submission for a mechanical stair lift.
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. MRMC studies are used to evaluate the performance of diagnostic devices or AI algorithms often in the context of human-in-the-loop scenarios. This is not relevant for a stair lift.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
Not applicable. There is no algorithm or AI component mentioned in the description of the Merits E600 Series Stair Lift.
7. The type of ground truth used (expert concensus, pathology, outcomes data, etc)
As discussed in point 3, the concept of "ground truth" in the context of an AI/ML device is not applicable here. For this device, the "ground truth" implicitly refers to adherence to engineering design specifications, safety standards, and functional equivalence to the predicate device, which would be verified through mechanical and electrical testing.
8. The sample size for the training set
Not applicable. This device does not involve machine learning, so there is no "training set."
9. How the ground truth for the training set was established
Not applicable for the same reason as point 8.
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(31 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits E700 Porch Lift System is a wheelchair elevator, also commonly known as a vertical platform lift. It is a motorized device intended to mechanically transport an individual with mobility disability, either in a wheelchair device or ambulatory, from one level to another in a private residence.
The Merits E700 Porch Lift basically consists of a platform assembly and a driving machine case assembly. The platform assembly vertically moves along a guide rail welded to the driving machine case assembly. The sides of the platform assembly are guarded by sheet steel plates. The lower landing side of the platform is equipped with an automatic folding ramp to not only offer easy access to the platform but also to prevent the mobility device rolling off the edges. The ramp will be automatically folded up as the lift begins to move upward and remain in elevated position until the platform returns to the lower landing. The underside of the platform is equipped with a safety plate to stop the motion when the platform is obstructed in the downward direction. The driving machine case assembly contains all necessary operation systems in the case. The operation of the lift is controlled by the platform operating panel and the call/send controls. These control devices are designed by means of continuous pressure type, which stop the lift immediately when the switch is released. The Merits E700 Porch Lift is using AC power as its power source.
The provided text concerns a 510(k) submission for a Merits E700 Porch Lift, which is a vertical platform lift. This document is a regulatory submission for a medical device that assists with mobility. The 510(k) summary focuses on demonstrating substantial equivalence to a predicate device rather than presenting a performance study with detailed acceptance criteria and statistical analysis typical for diagnostic AI/ML devices.
Therefore, many of the requested elements for an AI/ML study (like sample size for test sets, number of experts for ground truth, adjudication methods, MRMC studies, standalone performance, training set details, etc.) are not applicable to this type of device and submission.
Here's the information that can be extracted or deduced based on the provided text:
1. Table of Acceptance Criteria and Reported Device Performance
Acceptance Criteria (Implied) | Reported Device Performance |
---|---|
Safe and reliable operation as a vertical platform lift. | "The results of the testing confirm that the device meets specifications." |
Substantially equivalent in function to the predicate device Bruno Residential Vertical Platform Lift Model VPL-3100 (K061514). | "Merits E700 Porch Lift is equivalent in functions to the legally marketed predicate device." "The utilization of chain sprocket by Merits E700 Porch Lift is still reliable to satisfy the driving needs." "The technology of chains is mature enough to provide the reliable method to satisfy the specific functional requirements." |
Mechanically transport an individual with mobility disability, either in a wheelchair device or ambulatory, from one level to another in a private residence. | Stated as the "Intended use" and is the core function for which equivalency is claimed. |
Note: The acceptance criteria are "implied" because the document focuses on demonstrating substantial equivalence rather than explicit, quantifiable performance metrics for a novel technology.
2. Sample size used for the test set and the data provenance:
- Not applicable. This submission is for a mechanical device; it does not involve a test set of data in the context of an AI/ML diagnostic algorithm. The "testing" likely refers to engineering verification and validation tests common for mechanical devices (e.g., load testing, cycle testing, safety mechanism verification). The document does not specify the nature or sample size of these engineering tests, nor does it refer to data provenance in the context of patient data.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable. Ground truth in the context of expert consensus on medical images or diagnostic data is not relevant for this mechanical device. The "ground truth" here would be established by engineering specifications, safety standards, and functional requirements.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. An adjudication method for a test set is not relevant for a mechanical device submission.
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 is a mechanical device, not an AI/ML diagnostic tool, so an MRMC study is irrelevant.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This device does not have an AI algorithm.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):
- Not applicable in the context of diagnostic AI/ML. The "ground truth" for this device would be adherence to established engineering standards, safety regulations (e.g., related to lifts, general mechanical safety), and functional specifications. The performance is assessed against these technical and safety requirements, and by comparison to the established predicate device's performance characteristics.
8. The sample size for the training set:
- Not applicable. This submission does not involve a training set for an AI/ML model.
9. How the ground truth for the training set was established:
- Not applicable. This submission does not involve a training set for an AI/ML model.
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(221 days)
MERITS HEALTH PRODUCTS CO., LTD.
The Merits Health Products Portable Nebulizers are designed to deliver the prescribed liquid medication to treat patients' respiratory disorders, such as asthma, allergies, and bronchitis. The device is not intended for life support nor does it provide any patient monitoring capabilities.
The Merits Health Products Portable Nebulizer system consists of a DC powered piston-type compressor that generates compressed air. Small, lightweight and designed for convenience, the Merits device offers the user a choice of running off of AC power via a universal adapter or DC power via an option 12 volt auto adapter or an optional rechargeable battery pack. The device consists of a motor driven piston compressor, a printed circuit board and a switch. The circuit board does not incorporate a microprocessor but serves as a means to prevent double feed of power. The circuit board is not a part of the charging circuit for the battery pack.
The nebulizer, which employs a venturi effect to convert the medication into a fine aerosol mist, is used snapped directly onto the compressor outlet. The nebulizer is designed for single patient use, specifically for use only with the Merits compressor. Use different kinds of compressors may impair the performance.
The provided text is a 510(k) summary for the Merits Health Products Portable Nebulizer, submitted to the FDA in 2006. This document primarily focuses on establishing substantial equivalence to previously marketed devices rather than presenting a performance study with detailed acceptance criteria and testing against those criteria in a typical clinical study format.
Key takeaway regarding performance data in this document:
The document explicitly states: "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device." However, it does not provide specific acceptance criteria or detailed results of these tests. It only makes a general statement of compliance and equivalence.
Therefore, many of the requested sections regarding detailed acceptance criteria, sample sizes, ground truth establishment, and expert involvement cannot be extracted directly from this document. The study mentioned is primarily a verification and validation study to demonstrate the device meets its own internal specifications and is comparable to predicate devices.
Here's an attempt to answer as much as possible based on the provided text, with clear indications where the information is not present:
Acceptance Criteria and Device Performance
Acceptance Criteria (Specific Value/Metric) | Reported Device Performance |
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Not explicitly stated in the document. The general criterion is "meets specifications" and "substantially equivalent to the predicate device." | "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device." |
Additional Study Information
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Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size: Not specified. The document refers to "testing" performed, but does not provide details on the number of units tested or any patient data.
- Data Provenance: Not specified. The manufacturer is Merits Health Products Co., LTD. in Taichung, Taiwan R.O.C., which is likely where the testing would have been conducted or overseen. The data type is related to device performance, not clinical patient data.
- Retrospective or Prospective: Not applicable to the type of engineering/performance testing described.
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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. The "testing" referred to is likely engineering and performance verification against internal specifications and potentially comparison with predicate device specifications, not a clinical study requiring expert ground truth in the medical sense.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Not applicable. This concept is relevant for clinical studies with subjective assessments, which is not the nature of the "testing" described here.
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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
- No. This study is for a portable nebulizer, which is a medical device for drug delivery, not an AI-powered diagnostic tool. MRMC studies are not relevant here.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- No. This is a physical medical device, not an algorithm.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Not applicable in the clinical sense. The "ground truth" for the device's technical performance would be its design specifications, industry standards, and the performance characteristics of its predicate devices.
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The sample size for the training set
- Not applicable. This is not a machine learning or AI-driven device.
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How the ground truth for the training set was established
- Not applicable. This is not a machine learning or AI-driven device.
Summary of what the document implies about "Performance Data":
The "Performance Data" section (9.9) is very brief and generic. It states that "The results of the testing confirm that the device meets specifications and is substantially equivalent to the predicate device." This suggests that a series of tests (likely bench testing, electrical safety, biocompatibility of materials, and performance characteristics related to nebulization, such as aerosol output rates and particle size distribution, which are typical for nebulizers) were conducted to ensure the device performs as intended and is comparable to the predicate devices. However, the exact nature of these tests, their specific criteria, and the raw results are not included in this summary document. The 510(k) process primarily relies on demonstrating "substantial equivalence," meaning that the new device is as safe and effective as a legally marketed predicate device. This is often achieved through comparison of technological characteristics and, if necessary, performance testing to show that differences do not raise new questions of safety or effectiveness.
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