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510(k) Data Aggregation
(488 days)
The Stannah power Chair is intended as a device to provide personal transport for a person with walking difficulties. It is specifically designed to for indoor use in a domestic type environment.
The Power Chair is a powered wheelchair based around a high quality office chair. Attached to the chair is a proprietary controller unit, which can be mounted on either side of the seat. The motion is operated by the user hand via a joystick. The attachment method allows the controller to be positioned further forward or backwards relative to the chair for comfort and convenience of the user.
The chair is attached to a base assembly containing the drive motors, drive wheels, castor wheels and batteries, by a Gas Strut (anti-rotate) which enables the chair to be raised or lowered within set limits. Operation may be either manual, using a hand lever, or with a powered version option, via a separate control on the controller unit. The powered height adjustment can not be made while the power chair is driving in any direction. The Base is a profiled and of folded sheet steel fabrication, to which the two drive motor/gearboxes, two drive wheels, five castor wheels and a footrest assembly are mounted directly.
This 510(k) submission for the Stannah Power Chair Model 201 does not provide a table of acceptance criteria or a detailed study proving the device meets specific performance metrics in the way one would expect for an AI/ML medical device. This is a premarket notification for a Class II medical device (a powered wheelchair) from 2001, and the regulatory requirements and documentation style are very different from what would be expected for an AI system today.
The "Performance Data" section in the document describes compliance with existing industry standards for powered wheelchairs rather than, for example, a clinical trial with statistical performance metrics against a medical condition.
However, I will extract the information that is present and interpret it in the context of device performance and what might be considered "acceptance criteria" for a traditional medical device like a wheelchair at that time (compliance with recognized standards).
Here's an analysis based on the provided document:
Acceptance Criteria and Reported Device Performance
For this traditional medical device (powered wheelchair), the "acceptance criteria" are compliance with established performance standards for such devices. The reported "performance" is that the device meets those standards.
Acceptance Criteria (Reference to Standard) | Reported Device Performance |
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BS/ISO Powered Wheelchair Standard #ISO 7176 parts 1-16 (appropriate sections) | "In all instances, the Stannah Power Chair Model 201 met the required performance criteria and functioned as intended." |
ISO EMC Draft Standard 7176-14 ("Draft ISO EMC Group Proposal: Electromagnetic Compatibility Addition" dated April 3rd, 1995) | "In all instances, the Stannah Power Chair Model 201 met the required performance criteria and functioned as intended." |
Study Details (as inferable for a traditional device, not an AI study)
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Sample size used for the test set and the data provenance:
- Sample Size: Not explicitly stated as a "test set" in the context of a data-driven model. For a physical product like a wheelchair, it would involve testing of prototypes or production units. The document implies at least one "Stannah Power Chair Model 201" underwent testing against the standards. There is no mention of country of origin of "data" in the AI sense, nor is there a distinction between retrospective or prospective study data.
- Data Provenance: The testing was conducted by Stannah Power Chair Ltd. against international standards (BS/ISO, ISO EMC).
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Number of experts used to establish the ground truth for the test set and the qualifications of those experts:
- Not applicable in the AI/ML sense. "Ground truth" for a wheelchair's performance is determined by physical testing against engineering specifications and safety standards, not by expert interpretation of data. The standards themselves are developed by expert committees, but that's a different context.
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Adjudication method (e.g. 2+1, 3+1, none) for the test set:
- Not applicable. Performance against engineering standards is typically measured objectively (e.g., speed, range, stability tests) rather than through subjective adjudication.
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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:
- Not applicable. This is not an AI-assisted device, nor is it a diagnostic device requiring human reader interpretation.
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If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:
- Not applicable. This is not an algorithm; it's a physical device.
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The type of ground truth used (expert consensus, pathology, outcomes data, etc):
- The "ground truth" for the device's performance is defined by established engineering and safety standards (BS/ISO 7176 series and ISO EMC 7176-14). Compliance is measured through physical tests of the device's operational characteristics (e.g., stability, maneuverability, electromagnetic compatibility).
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The sample size for the training set:
- Not applicable. This is not an AI/ML device that requires a training set.
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How the ground truth for the training set was established:
- Not applicable.
Summary for AI/ML Context vs. Traditional Device:
This document is a classic 510(k) premarket notification for a physical medical device from the early 2000s. The entire framework of questions provided (acceptance criteria, sample sizes, ground truth establishment, MRMC studies, training/test sets) is geared towards the evaluation of AI/ML software as a medical device (SaMD) or AI-enabled medical devices. These concepts simply do not apply to the Stannah Power Chair Model 201 as presented in this submission.
The "study" in this context is the performance testing conducted by the manufacturer against recognized international standards for powered wheelchairs and electromagnetic compatibility. The "proof" is the manufacturer's assertion that the device "met the required performance criteria and functioned as intended" in all instances of these tests. This level of detail was sufficient for a substantial equivalence determination for this type of device at that time.
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