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510(k) Data Aggregation

    K Number
    K223492
    Manufacturer
    Date Cleared
    2023-02-22

    (93 days)

    Product Code
    Regulation Number
    890.3800
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The "eFOLDI Scooter, Lite" is a motor driven, indoor transportation vehicle with the intended use to provide mobility to a disabled or elderly person limited to a seated position.

    Device Description

    The eFoldi Scooter. Lite is an indoor/outdoor electric scooter that is intended to be used by individuals that are able to walk but suffer from mobility limitations. It has a base with metal alloy frame, one front wheels, two rear wheels, a seat, an adjustable steering column, a tiller console, an electric motor, an electromagnetic brake, 2 rechargeable Lithium-Ion Battery with an off-board charger. The movement of the scooter is controlled by the rider who operates the throttle lever, speed control handle on the tiller console. The device is installed with an electromagnetic brake that will engage automatically when the scooter is not in use and the brake cannot be used manually. The Scooter only can be operated on the flat road or slopes less than 6 degrees. The scooter is foldable.

    AI/ML Overview

    This document describes the regulatory approval for the eFOLDi Scooter, Lite, a motorized three-wheeled vehicle. The provided text is a 510(k) summary, which focuses on demonstrating substantial equivalence to a predicate device rather than presenting a performance study with acceptance criteria in the typical sense of a clinical trial for a novel AI device or diagnostic.

    Therefore, many of the requested items (e.g., sample sizes for training/test sets, expert adjudication, MRMC studies, ground truth establishment for AI models) are not applicable to this type of regulatory submission for a physical medical device like an electric scooter. The "acceptance criteria" here are defined by compliance with recognized standards and a comparison against a predicate device.

    Here's an analysis based on the provided document:


    Acceptance Criteria and Device Performance (Based on Non-Clinical Testing and Predicate Comparison):

    The acceptance criteria for this device are primarily demonstrated through compliance with recognized international standards (ISO 7176 series for wheelchairs and scooters, ISO 10993-1 for biocompatibility, and ISO 7176-21 for EMC) and by showing that any differences from the predicate device do not raise new safety or effectiveness concerns.

    Table of Acceptance Criteria and Reported Device Performance:

    Acceptance Criteria CategorySpecific Criteria (from document)Reported Device Performance / Compliance
    Safety Standards ComplianceNon-Clinical Tests: Compliance with various ISO 7176 standards, ISO 10993-1, ISO 7176-21 for EMC. This serves as acceptance criteria indicating the device's safety.Non-clinical tests were conducted and met all design specifications and comply with the following standards:- Biocompatibility: ISO10993-1 requirements met for all user-contacting materials.- EMC: ISO7176-21 compliant.- Performance (General Safety & Functionality): - ISO 7176-1 (Static stability) compliant. - ISO 7176-2 (Dynamic stability of electrically powered wheelchairs) compliant. - ISO 7176-3 (Effectiveness of brakes) compliant. - ISO 7176-4 (Energy consumption/range) compliant. - ISO 7176-5 (Overall dimensions, mass, maneuvering space) compliant. - ISO 7176-6 (Max speed, acceleration, deceleration) compliant. - ISO 7176-7 (Seating and wheel dimensions) compliant. - ISO 7176-8 (Static, impact, fatigue strengths) compliant. - ISO 7176-9 (Climatic tests) compliant. - ISO 7176-10 (Obstacle-climbing ability) compliant. - ISO 7176-14 (Power and control systems) compliant. - ISO 7176-16 (Resistance to ignition of postural support devices) compliant.Specific Performance Parameters (compared to predicate):- Minimum braking distance and time: 0.7 meter for 6km/h speed, <1s (S.E. to predicate's 1.1 meter for 6km/h, <1s). This shows the device meets or exceeds the predicate's performance in safety critical braking.- Max speed Forward: 6 km/h (S.E. to predicate).- Max speed Reverse: 2 km/h (S.E. to predicate's 3 km/h). Minor difference, concluded "S.E."- Maximum Occupant Mass: 120 KG (S.E. to predicate).- Maximum Incline: ≥ 15° for all directions (S.E. to predicate).
    Functional Equivalence to Predicate"Minor differences... do not raise any concerns in terms of safety and effectiveness." (e.g., Indication for Use, Motor Type, Batteries, Charger Type, Actuator, Brake, Wheel Lock, Operating surface & environment)Substantial Equivalence (S.E.) demonstrated for:- Indication for use: Motor driven, indoor/outdoor transportation for disabled/elderly limited to seated position.- Motor Type: 24V DC brush differential front axle (subject) vs. rear axle (predicate) - deemed S.E.- Motor Output: 24V 180W (S.E. to predicate).- Batteries: Lithium battery (S.E. to predicate).- Range per Charge: 6 hours (S.E. to predicate).- Charger Type: Carry-on (S.E. to predicate).- Actuator: Intelligent, Regenerative and Electromagnetic brake system (S.E. to predicate).- Brake: Electromagnetic brake (S.E. to predicate).- Wheel Lock (type): Electromagnetic brake (S.E. to predicate).- Back Upholstery: Leather package (S.E. to predicate).- Operating surface & environment: Indoor and outdoor use (S.E. to predicate).Similar/Different but deemed acceptable:- Overall Dimensions: Similar (1170x550x950 mm vs 1050x550x870 mm).- Folded Dimensions: Similar (370x550x670 mm vs 480x550x790 mm).- Weight with batteries: Similar (16.7 KG vs 29 KG).- Weight without batteries: Similar (15 KG vs 24.2 KG).- Controller: Different (MM32SPIN05X vs British PG Controller PG45A) - Accepted as "Different" but not impacting S.E.- Drive Style: Different (Front-wheel drive vs Rear-wheel drive) - Accepted as "Different" but not impacting S.E.- Charger Input/Output Power: Similar (100-240VAC 50/60Hz 2A vs 100-240VAC 50/60Hz 1.2-0.5A).- Rear Wheels Size: Similar (10 inches vs 8 inches).- Front Tire Size: Similar (8 inches vs 7 inches).- Anti-tip Wheels: Different (N/A vs 2.5 inches) - Accepted as "Different" but not impacting S.E.- Curb Climbing ability: Different (40 mm vs 60 mm) - Accepted as "Different" but not impacting S.E.- Ground clearance: Different (100 mm vs 50 mm) - Accepted as "Different" but not impacting S.E.- Minimum Turning Radius: Different (1.97 m vs 1.2m) - Accepted as "Different" but not impacting S.E.- Footplates: Different (Aluminum vs ABS plastics) - Accepted as "Different" but not impacting S.E.- Tire Pressure (if pneumatic): N/A (subject) vs NA (predicate) - S.E.

    Detailed Responses to Specific Questions:

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

      • Please see the table above. The "acceptance criteria" for this device are demonstrated by its compliance with various ISO standards for safety and performance (the non-clinical tests) and by showing that its specifications are substantially equivalent to a legally marketed predicate device, even with some differences that are deemed not to raise new questions of safety or effectiveness.
    2. Sample sizes used for the test set and the data provenance:

      • N/A. This is a physical medical device (electric scooter), not an AI/software device requiring a "test set" of data in the typical sense. Performance is verified through engineering tests on the physical product and comparison to specifications and a predicate device. There is no mention of a "test set" of patient data.
    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts:

      • N/A. Ground truth as defined for diagnostic AI models (e.g., radiologist reads, pathology) is not relevant for this device. The "ground truth" here is established by engineering standards, physical measurements, and compliance testing performed by qualified test labs/engineers.
    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set:

      • N/A. No multi-reader or adjudication process for a "test set" is 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:

      • N/A. This is not an AI-assisted diagnostic device. No MRMC study was conducted or relevant.
    6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done:

      • N/A. Not an algorithm-only device.
    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc.):

      • The "ground truth" for this device's safety and effectiveness is established by:
        • Compliance with recognized international performance and safety standards (ISO 7176 series, ISO 10993-1, ISO 7176-21).
        • Engineering specifications and test results of the physical device.
        • Demonstrated substantial equivalence to a predicate device, meaning its performance falls within acceptable parameters compared to a device already deemed safe and effective.
    8. The sample size for the training set:

      • N/A. No training set for an AI model.
    9. How the ground truth for the training set was established:

      • N/A. No training set for an AI model.

    Conclusion from the Document (Section 9.0):
    "The conclusions drawn from the nonclinical tests that demonstrate is that the subject device is as safe, as effective, and performs as well as the legally marketed device." This statement summarizes the "proof" that the device meets its regulatory acceptance criteria for substantial equivalence.

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