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510(k) Data Aggregation

    K Number
    K212854
    Date Cleared
    2022-01-10

    (124 days)

    Product Code
    Regulation Number
    890.3860
    Reference & Predicate Devices
    Predicate For
    N/A
    AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
    Intended Use

    The XFGW30-107 and XFGW25-203 Powered Wheelchair 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. This product is suitable for disabled people with mobility difficulties and elderly people.

    Device Description

    The subject device, Powered Wheelchair, mainly powered by battery, motivated by DC motor, driven by user controlling joystick and adjusting speed. The Powered Wheelchairs consist of two foldable armrests, a backrest, a seat cushion, a safety belt, a foldable frame, two rear driving wheels with hub motor/electromagnetic brake assemblies, two pivoting casters, two Li-ion batteries, an off-board battery charger, a control panel, and an electric motor controller. The XFGW30-107 and XFGW25-203 Powered Wheelchair is intended to provide mobility to a disabled or elderly person limited to a seated position.

    AI/ML Overview

    The provided text is a 510(k) summary for a Powered Wheelchair (K212854). It details the device's characteristics and its comparison to a predicate device to establish substantial equivalence. However, this document does not describe the specific type of study, data, or adjudication methods typically used to prove that an AI/algorithm-based medical device meets acceptance criteria.

    The document discusses the regulatory clearance for a physical medical device (a powered wheelchair), not a software or AI-driven diagnostic/therapeutic tool. Therefore, the questions related to AI/algorithm performance, ground truth, expert consensus, MRMC studies, training/test sets, and adjudication methods are not applicable to this document.

    The "acceptance criteria" discussed in this document relate to the physical and functional performance of the wheelchair as measured against established ISO standards and comparison to a legally marketed predicate device.

    To answer your request based on the provided document, I will reinterpret "acceptance criteria" and "study" in the context of a powered wheelchair's regulatory submission.

    Reinterpretation for a Powered Wheelchair:

    • Acceptance Criteria: These are the performance and safety requirements that the powered wheelchair must meet, often defined by international standards (e.g., ISO 7176 series) and demonstrated through non-clinical testing.
    • Study Proving Acceptance: This refers to the non-clinical testing conducted to show compliance with the standards and substantial equivalence to the predicate device.

    Here's the information extracted and reinterpreted where appropriate based on the provided text:

    1. Table of Acceptance Criteria and Reported Device Performance

    The acceptance criteria are generally implied by adherence to the listed international standards (ISO 7176 series, IEC standards, EN 12184, ISO 10993 series). The reported device performance is presented in various sections, particularly in the "Performance Comparison" table (Table 2).

    Acceptance Criteria Category (Derived from Standards)Specific Acceptance Criteria (from text)Reported Device Performance (Proposed Device)Predicate Device Performance (for comparison)Remark (from document)
    Static Stability* Forward Static Stability: 30° (ISO 7176-1:2014)30°Not publicly availableBoth evaluated to ISO 7176-1:2014; different static stability will not impact safety/effectiveness.
    * Rearward Static Stability: 17° (ISO 7176-1:2014)17°Not publicly available
    * Sideways Static Stability: 14° (ISO 7176-1:2014)14°Not publicly available
    Maximum Safe Operational InclineMust comply with relevant standards (e.g., ISO 7176-2:2017 for dynamic stability, implying incline capabilities).12 degrees8 degreesLarger safe operational incline is convenient; differences won't impact safety/effectiveness.
    Braking Effectiveness* Braking Time: ~2s~2sNot explicitly stated
    * Braking Distance: ≤1.5m (ISO 7176-3:2012)≤1.5m1.5mSame
    Speed* Max Speed Forward: 1.7m/s (6 km/h) (ISO 7176-6:2018)1.7m/s (6 km/h)1.5m/s (5.4 km/h)Evaluated to ISO 7176-6:2018; differences won't impact safety/effectiveness.
    * Max Speed Backward: 0.7m/s (2.52 km/h) (ISO 7176-6:2018)0.7m/s (2.52 km/h)0.8m/s (2.88 km/h)Evaluated to ISO 7176-6:2018; differences won't impact safety/effectiveness.
    Obstacle Climbing AbilityMust comply with relevant standards (ISO 7176-10:2008).40mm50mmSmaller height won't impact safety/effectiveness; both meet ISO 7176-10:2008.
    Cruising RangeMust comply with relevant standards (ISO 7176-4:2008 for energy consumption).22 km20 kmLarger cruising range for the subject device.
    Maximum LoadingMust comply with relevant standards (e.g., ISO 7176-8:2014 for strengths).100 kg (220 lbs)125 kg (275 lbs)Less loading weight means more convenient for transportation. The document implies compliance despite the difference in load capacity.
    BiocompatibilityCompliant with ISO 10993-1, 10993-5 (Cytotoxicity), 10993-10 (Irritation & Skin Sensitization).Tests included Cytotoxicity, Sensitization, Intracutaneous Reactivity; complies with ISO 10993-1, FDA Guidance.SameBiocompatibility evaluation carried out per ISO 10993-1; no new safety/effectiveness concerns.
    Electromagnetic Compatibility (EMC)Compliant with ISO 7176-21:2009 and IEC 60601-1-2:2015.The device complied with ISO 7176-21:2009 and IEC 60601-1-2:2015.Complied with relevant standards.N/A - compliance stated directly.
    Ignition ResistanceCompliant with ISO 7176-16:2012.Flame retardant test of seat/back cushion and armrest carried out according to ISO 7176-16. Device complied with ISO 7176-16:2012.Flame retardant test to ISO 7176-16.Both devices assured to be under the same safety level.
    Other General Performance & Safety StandardsCompliance with ISO 7176-5 (Dimensions, mass, maneuvering space), ISO 7176-7 (Seating/wheel dimensions), ISO 7176-8 (Strengths), ISO 7176-9 (Climatic tests), ISO 7176-11 (Test dummies), ISO 7176-13 (Friction), ISO 7176-14 (Power/control systems), ISO 7176-15 (Disclosure/labeling), ISO 7176-22 (Set-up procedures), IEC 62133-2 (Batteries), EN 12184 (Overall requirements).The device complied with all listed ISO and IEC standards. Non-clinical tests verified that the proposed device met all design specifications.Complied with relevant standards.N/A - extensive list of standards complied with to demonstrate safety and effectiveness, and substantial equivalence to predicate.

    2. Sample Size used for the test set and the data provenance

    • Sample Size: The document does not specify a "sample size" in the context of a test set for an algorithm, as this is a physical device. For non-clinical performance and safety testing, typically a certain number of units of the device would be tested to demonstrate compliance with standards. The document states "Non clinical tests were conducted to verify that the proposed device met all design specifications..." but doesn't quantify the number of devices or test repetitions.
    • Data Provenance: Not applicable in the sense of patient data for AI. The "data" here comes from a physical product's performance and safety testing.
      • Country of Origin: The manufacturer is Zhejiang Qianxi Vehicle Co., Ltd. (China). Testing would presumably be conducted by the manufacturer or accredited labs.
      • Retrospective or Prospective: Not applicable in the context of an AI study. This is product-specific testing.

    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" in this context is established by objective measurements and standardized test procedures defined in the ISO and IEC standards, not by human experts interpreting data.

    4. Adjudication method (e.g. 2+1, 3+1, none) for the test set

    • Not applicable. This is for product performance testing against standards, not for human interpretation of data for an AI algorithm.

    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 device is a powered wheelchair, not an AI-assisted diagnostic tool. No MRMC study was performed.

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

    • Not applicable. This is a physical medical device, not an algorithm.

    7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)

    • The "ground truth" for the device's performance is established by the specifications and test methods outlined in objective, internationally recognized standards (e.g., ISO 7176 series for wheelchair performance, ISO 10993 for biocompatibility). The measurements obtained from testing the physical device against these standards serve as the "truth."

    8. The sample size for the training set

    • Not applicable. This is a physical device, not an AI algorithm. There is no concept of a "training set" for the device itself in this submission.

    9. How the ground truth for the training set was established

    • Not applicable. As above, there is no "training set" for an AI algorithm.
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