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510(k) Data Aggregation

    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The intended use of the Electric Wheelchair (Robooter E60), Models name: BBR-E60-01,BBR-E60-02, BBR-E60-03, BBR-E60-04,BBR-E60-05,BBR-E60-06,BBR-E60-07,BBR-E60-08, is to provide outdoor and indoor mobility to persons limited to a seated position that are capable of operating a powered wheelchair.

    Device Description

    The Electric Wheelchair (Robooter E60), Models name: BBR-E60-01, BBR-E60-02, BBR-E60-03, BBR-E60-04, BBR-E60-05, BBR-E60-06, BBR-E60-07, BBR-E60-08, is an indoor/outdoor, batteryoperated, 2-wheel drive (rear-wheel drive) powered wheelchair.

    It consists of four modules: seat system, control system, and drive system. The user sits in the wheelchair seat and uses the control system.

    The control pad positioned on the right armrest, user can turn the wheelchair on, control the speed, and direct the movement.

    The braking system employs an electromagnetic brake, when release the controller rocker, the electromagnetic brakes will be actuated, and the electric wheelchair will stop in several seconds.

    Electromagnetic brake will not take effect immediately, it will take effect after the wheel rotates for 1/2 cycle.

    The wheelchair is powered by a 24V DC,20Ah or 25Ah rechargeable lithium-ion battery charged by an offboard lithium-ion battery charger. The wheelchair is driven by two DC motors.

    The Electric Wheelchair (Robooter E60), Models name: BBR-E60-01, BBR-E60-02, BBR-E60-03, BBR-E60-04, BBR-E60-05, BBR-E60-06, BBR-E60-07, BBR-E60-08, contains Bluetooth 4.1 BLE technology. The device can be controlled by the controller rocker or remote control by a smartphone app via Bluetooth 4.1 Low Energy (BLE) wireless communication interface. The smartphone app is used to drive the chair remotely. For safety, controller rocker control is priority over the remote control by design. The smartphone app can also view the battery's status, adjust the speed gear level and lock/unlock the unattended device.

    The wheelchair can be controlled an optional Bluetooth remote controller (BBR-BLERC series)

    The wheelchair can be folded/expanded manually. The Left and right handrails (joystick) can be interchange.

    AI/ML Overview

    The provided documentation is a 510(k) summary for an Electric Wheelchair (Robooter E60). This type of submission focuses on demonstrating substantial equivalence to a legally marketed predicate device rather than providing extensive details on a comprehensive clinical study to define and meet specific acceptance criteria in the same way one might for a novel diagnostic or therapeutic device.

    Based on the provided text, the "acceptance criteria" are primarily defined by compliance with a comprehensive set of ISO 7176 series standards for wheelchairs, along with other relevant ISO and ANSI standards. The "study" proving the device meets these criteria refers to the non-clinical testing performed against these standards.

    Here's the breakdown of the requested information based on the document:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are essentially the requirements set forth by the listed ISO and ANSI standards. The reported device performance is that it met these standards. Since the document doesn't provide specific numerical performance values for each standard (e.g., exact braking distance for a specific test case, or specific stability angles beyond the general 9° dynamic stability), but rather states "test results meet its design specification" or "all test results meet the requirements," a direct comparative table with quantitative acceptance vs. performance for each test is not fully derivable. However, we can represent the overall compliance.

    Acceptance Criterion (Standard Requirement)Reported Device Performance
    Biocompatibility: Conforms to ISO 10993-5 (Cytotoxicity), ISO 10993-10 (Sensitization), ISO 10993-23 (Irritation)All user directly contacting materials are compliant with ISO 10993-5, ISO 10993-10, and ISO 10993-23 requirements.
    EMC: Conforms to ISO 7176-21 and IEC 60601-2-1The EMC performance results meet the requirements of ISO 7176-21.
    Static Stability: Conforms to ISO 7176-1The static stability has been determined, and test results meet its design specification.
    Dynamic Stability: Conforms to ISO 7176-2 (e.g., 9° stability)The dynamic stability has been determined, and test results meet its design specification (9° for proposed and predicate).
    Brakes Effectiveness: Conforms to ISO 7176-3The effectiveness of brakes has been determined, and test results meet its design specification. (Min braking distance: 120cm for subject vs. 200cm for predicate, both compliant with the standard).
    Energy Consumption/Range: Conforms to ISO 7176-4The theoretical distance range has been determined, and test results meet its design specification.
    Dimensions, Mass, Maneuvering: Conforms to ISO 7176-5The dimensions and mass have been determined after testing.
    Speed, Acceleration, Deceleration: Conforms to ISO 7176-6The dimensions and mass have been determined after testing. (Max forward speed: 8km/h for subject vs. 10km/h for predicate, both compliant with the standard).
    Seating & Wheel Dimensions: Conforms to ISO 7176-7The seating and wheel dimensions have been determined after testing.
    Static, Impact, Fatigue Strengths: Conforms to ISO 7176-8All test results meet the requirements in Clause 4 of ISO 7176-8.
    Climatic Tests: Conforms to ISO 7176-9The device could continue to function according to manufacturer's specification after being subjected to each of the tests specified in Clause 8 of ISO 7176-9.
    Obstacle-Climbing Ability: Conforms to ISO 7176-10The obstacle-climbing ability has been determined. (Climbing Height: 50mm for both subject and predicate).
    Test Dummies: Conforms to ISO 7176-11The test dummies used in the testing series meet the requirements of ISO 7176-11.
    Coefficient of Friction of Test Surfaces: Conforms to ISO 7176-13The coefficient of friction of test surfaces has been determined for use in other 7176 series tests.
    Power and Control Systems: Conforms to ISO 7176-14All test results meet the requirements in various clauses of ISO 7176-14.
    Information Disclosure, Documentation, Labeling: Conforms to ISO 7176-15Information disclosure, documentation, and labeling of the device meet the requirements of ISO 7176-15.
    Resistance to Ignition of Postural Support Devices: Conforms to ISO 16840-10The performance of resistance to ignition meets the requirements of ISO 16840-10.
    Batteries and Chargers: Conforms to ISO 7176-25The performance of batteries and charger meets the Requirements in Clause 5 and 6 of ISO 7176-25.
    Wireless Coexistence: Conforms to ANSI C63.27-2017The wheelchair conforms to ANSI C63.27-2017.
    Software Verification & ValidationValidation testing of the priority of the on-board "controller rocker" (joystick) over the wireless remote controllers was conducted.

    2. Sample Sizes used for the Test Set and Data Provenance

    The document does not specify sample sizes (e.g., number of devices tested) for the non-clinical tests. It refers to these as "non-clinical tests" and details the standards followed. The data provenance is implied to be from the manufacturer's testing facilities (Shanghai Bangbang Robotics Co., Ltd.) as part of their submission for market clearance. These are prospective tests conducted to demonstrate compliance. There is no mention of country of origin of the data in terms of patient data, as this is a non-clinical submission.

    3. Number of Experts used to establish the Ground Truth for the Test Set and the Qualifications of those Experts

    This information is not applicable and not provided. The "ground truth" for non-clinical performance standards is defined by the standards themselves (e.g., a specific static stability angle, braking distance, etc.). Compliance is assessed by accredited testing bodies or manufacturer's internal quality systems against these defined requirements. There are no "experts" in the context of clinical interpretation to establish ground truth in this non-clinical submission.

    4. Adjudication Method for the Test Set

    This is not applicable to non-clinical technical performance testing. Adjudication methods (like 2+1, 3+1) are typically used in clinical studies involving interpretation by multiple human readers (e.g., radiologists) to establish a consensus ground truth when individual reader opinions might differ.

    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

    No such study was done or reported. This submission is for an electric wheelchair, a physical medical device, not an AI-powered diagnostic or interpretive tool that would involve human readers. The document explicitly states "No clinical study is included in this submission."

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

    This is not applicable. The device is an electric wheelchair, not an algorithm, and the testing focuses on its physical and electrical safety and performance characteristics.

    7. The Type of Ground Truth Used

    The "ground truth" for the non-clinical tests is the performance metrics and criteria defined within the referenced international standards (ISO 10993, ISO 7176 series, ANSI C63.27) and the device's design specifications. For example, for static stability, the ground truth is the minimum stability angle specified by ISO 7176-1. For braking, it's the effectiveness criteria of ISO 7176-3.

    8. The Sample Size for the Training Set

    This is not applicable. This is a physical medical device, not a machine learning model that requires a training set.

    9. How the Ground Truth for the Training Set was Established

    This is not applicable for the same reason as point 8.

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