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510(k) Data Aggregation
(239 days)
The Garaventa X3 inclined platform lift is intended to mechanically transport one person in a wheelchair or in a fold-down seat up and down stairs in a private or public facility either indoors or outdoors.
The Garaventa X3 inclined platform lift is intended to mechanically transport one person in a wheelchair or in a fold down seat equipped with a seat belt, up and down stairs in a private or public facility either indoors or outdoors, on straight stairways.
The Garaventa X3 inclined platform lift uses two custom-cut extruded aluminum guide rails to guide and support the platform. An upper rail houses the drive rack that is engaged by the pinion gear providing platform movement as well as acting as the raceway for the control wiring. A lower rail stabilizes the platform keeping it in a level traveling position. The Garaventa X3 inclined platform lift has steel guide rails and haul ropes or cables are used for those products instead of extruded aluminum.
The Garaventa X3 inclined platform lift does not require a special cabinet to house the drive system. The drive system of the Garaventa X3 inclined platform lift is an on-board rack and pinion drive system. The drive system is protected from accidental contact by the user by a conveyance "hard" cover.
The Garaventa X3 inclined platform lift is a computer-controlled device equipped with a microprocessor and the software resides inside the conveyance controller.
The safety network monitors several switches, landing cam, the battery voltage and motor current limits. These are independent of the microprocessor system and provide a positive electromechanical means to reliably and safely stop the lift in any possible hazardous situation.
The controller is located in the conveyance unit. It receives the operating commands from the call station or from the conveyance controller. The conveyance control module always has a priority over the call stations.
The conveyance controller is powered by 24V DC batteries that are attached to the conveyance. The conveyance controller also controls the "barrier arms" motor, platform side-load motor and the platform motor in either of the landings.
The status of the safety switches and the emergency stop button are monitored by the conveyance controller.
There is a call station located at each landing. The call station transmits commands using a wireless simplex channel while the conveyance continuously scans all RF signals (decoded) from both call stations.
Call stations allow the user to call and send the unit into the desired landing and also fold and unfold the platform. The call stations are linked with the conveyance through the wireless link. The system uses a 2.4 GHz ISM band using encoded pulse for each call station does not process the button / command but simply transfers the state of each button to the conveyance.
The Garaventa X3 inclined platform lift is provided in four models: one fully automatic, two semi automatic, and one fully manual.
The provided text describes a 510(k) summary for the Garaventa X3 inclined platform lift, a device for transporting individuals in wheelchairs up and down stairs. This document is a regulatory submission to the FDA, demonstrating substantial equivalence to a predicate device.
Unfortunately, the provided text does not contain the level of detail typically found in a scientific study designed to establish acceptance criteria and prove device performance in the context of advanced AI/ML systems. This document is a regulatory submission for a physical medical device (a wheelchair elevator).
Therefore, many of the requested categories for a study proving device performance are not applicable or cannot be extracted from this document. The document focuses on demonstrating that the new device (Garaventa X3) is substantially equivalent in safety and effectiveness to a previously cleared predicate device (Garaventa STAIR-LIFT K981486) by highlighting design changes and testing against applicable standards for physical lifts, not AI/ML performance metrics.
I will, however, extract the relevant information where available and explicitly state when information is not present or applicable.
1. A table of acceptance criteria and the reported device performance
The document frames "acceptance criteria" and "reported device performance" in terms of compliance with established safety standards and functionality relative to a predicate device, rather than specific quantitative performance metrics common in AI/ML validation (e.g., sensitivity, specificity, AUC).
Category | Acceptance Criteria (Implied) | Reported Device Performance |
---|---|---|
Rail System (X3 uses GSL2 rail) | Compliance with ASME 18.1-2008 and CSA B335-09. | "Tested with 'X3 Safety Circuit Test' attached in this report in tab J Item 26 to comply with ASME 18.1-2008 and CSA B335-09." |
Hanger System (X3 uses GSL 1/3 hanger) | Compliance with ASME 18.1-2008 and CSA B335-09. | "Safety tests done and documented in 'X3 Safety Circuit Test' attached in this report in Tab J Item 26 to comply with ASME 18.1-2008 and CSA B335-09." |
Platform System (X3 uses GSL 1/3 platform) | Compliance with ASME 18.1-2008 and CSA B335-09. | "Safety tests done and documented in 'X3 Safety Circuit Test' attached in this report in Tab J Item 26 to comply with ASME 18.1-2008 and CSA B335-09." |
Call Station (Remote Control) | Design compliance to ASME 18.1 - 2008 and CSA B 335-09. Allocated band frequency has no conflict with outside radio frequencies. | "Remote control Call station designed for wireless operation...Allocated band frequency has no conflict with outside radio frequencies. Design compliance to ASME 18.1 - 2008 and CSA B 335-09." |
Power Source (Battery only) | Design compliance to ASME 18.1 - 2008 and CSA B 335-09. | "Design compliance to ASME 18.1 - 2008 and CSA B 335-09." |
Overall Safety & Functionality | As safe and effective as, and performs as well as or better than the predicate device(s). | "As shown in the safety tests and functionality of the equipment, X3 performs effectively as the predicate devices." |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
- Sample Size for Test Set: Not applicable in the context of this device. The testing described is for the physical components and safety circuits of a single device or a small number of prototypes, not a data-driven test set for an algorithm.
- Data Provenance: Not applicable. The "testing" refers to physical compliance testing, not data collection for algorithms. The manufacturer is Garaventa (Canada) LTD, suggesting testing likely occurred in Canada or under Canadian/US standards.
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)
- Number of Experts & Qualifications: Not applicable. Ground truth, in this context, would be the adherence to engineering standards and proper mechanical function, validated by engineers or certified testing bodies, rather than medical experts interpreting data.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
- Adjudication Method: Not applicable. This concept applies to human review of ambiguous cases in data interpretation, which is not relevant for the physical testing of an inclined platform lift. Testing involves pass/fail criteria against engineering 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
- MRMC Study: Not applicable. This type of study is used for diagnostic AI systems where human readers interpret patient data. The Garaventa X3 is a physical transport device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
- Standalone Performance: While the device is "computer-controlled" with a "microprocessor," the context is mechanical safety and operation, not an AI algorithm performing diagnostic tasks. The "safety network" and "conveyance controller" monitor switches and parameters to ensure safe mechanical operation. Therefore, this concept is not applicable as described for an AI application.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
- Type of Ground Truth: The "ground truth" for this device's performance is adherence to recognized engineering and safety standards for inclined platform lifts, specifically ASME 18.1-2008 and CSA B335-09. This is a standards-based ground truth or engineering compliance ground truth.
8. The sample size for the training set
- Sample Size for Training Set: Not applicable. This device is not an AI/ML system that requires a "training set" of data in the conventional sense. The "training" in this context refers to the engineering design, development, and testing processes.
9. How the ground truth for the training set was established
- How Ground Truth for Training Set was Established: Not applicable. As there’s no training set for an AI/ML model, there’s no ground truth established in that manner. The "ground truth" (i.e., correct design and functionality) for the device's development would be based on established mechanical engineering principles, safety regulations, and the performance characteristics of the predicate device.
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