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510(k) Data Aggregation
(315 days)
Batec is not intended for specific clinical use, but as a support to the mobility of active manual wheelchairs' users. It is designed to add auxiliary power to the manual wheelchair, increasing the mobility for the wheelchair's user. Therefore, bearing in mind the operating precautions described in this document, there is no need for professional, technical or aptitude requirements to operate or use a Batec device.
Batec devices are intended as add-on devices for wheelchairs, thus the intended user is a person with motor disability who needs of the wheelchair support for movement.
The Handbike Batec Electric is a handcycle mechanism that adapts to a manual wheelchair, forming a three-wheeled chair, allowing the user to move with the help of an electric motor located in the front wheel, optimizing the user's capabilities and increasing their autonomy.
Handbike Batec Electric aims to convert a manual wheelchair into an electrically propelled tricycle that allows the disabled collective to make larger and more complex movements and routes that can be made only with the manual wheelchair, increasing their independence and autonomy in daily life by performing recreational and sporting activities.
The operation of the Handbike Batec Electric is the same in all models, changing only the wheel size, maximum speed, and equipment. First the handbike must be coupled to the wheelchair. Once the two parts are attached, we will have a set consisting of three wheelchair seat, the transmission and traction on the front wheel. To operate the handbike, the transmission of the handbike must be operated by pedaling with the controls or by pressing the accelerator. In this way we will drive the front wheel with the manufactured product.
The device has two independent mechanical brakes (right and a parking brake. In addition. there is an automatic speed-limiting motor brake managed by software, which prevents exceeding 120% of the speed limit setting in each mode.
This document is a 510(k) Premarket Notification for the "Handbike Batec Electric." It seeks to establish substantial equivalence to a legally marketed predicate device, "Klick (Product Code ITI)."
The provided document describes a physical medical device (a powered add-on for manual wheelchairs), not an AI/Software as a Medical Device (SaMD). Therefore, many of the requested criteria related to AI/SaMD performance studies (e.g., sample size for test/training sets, data provenance, expert ground truth, MRMC studies, standalone algorithm performance) are not applicable to this submission.
The acceptance criteria and proof of meeting those criteria for this non-SaMD device primarily rely on compliance with established performance standards and comparison to a predicate device.
Here's an analysis of the provided information based on the typical requirements for a physical medical device 510(k) submission:
1. A table of acceptance criteria and the reported device performance:
The document doesn't present a formal "acceptance criteria" table in the way one might see for an SaMD with performance metrics like sensitivity, specificity, or AUC. Instead, it demonstrates compliance through non-clinical testing against recognized standards and a detailed comparison table with the predicate device. The "reported device performance" is implied by its adherence to these standards and the equivalence shown in the comparative table.
Here's a summary derived from the "SUMMARY OF COMPARISON WITH PREDICATE DEVICE" table and "SUMMARY DISCUSSION OF NON-CLINICAL DATA":
| Criterion/Feature (Implicit Acceptance Criteria: Equivalence to Predicate, Compliance with Standards) | Handbike Batec Electric (Subject Device) Performance/Specification | Klick (Predicate Device) Performance/Specification | Equivalence Discussion (Meets Acceptance) |
|---|---|---|---|
| Regulatory Information | |||
| 510(k) Number | K241159 | K222502 | - |
| Product Code | ITI | ITI | Same |
| Class | Class II | Class II | Same |
| Regulation Number | 21 CFR 890.3860 | 21 CFR 890.3860 | Same |
| Intended Use/Indications | |||
| Device Name | Handbike Batec electric | Handbike klaxon Klick | Equivalent |
| Indication for Use | Support mobility of active manual wheelchair users; adds auxiliary power. Not for specific clinical use; no professional/technical requirements needed to operate. Intended for persons with motor disability needing wheelchair support. | Same wording. | Same |
| Intended Use | Medical device for active, disabled wheelchair users (max 110 kg), adds auxiliary power. Intended user: person with motor disability needing wheelchair support. Raises front castors; single front wheel for steering. Improves mobility, allows for larger routes. First setup by Batec's trained specialist. | Similar wording, max 120 kg weight. First setup by Klaxon's trained specialist. | Same (slight difference in max user weight, but deemed equivalent). |
| Use condition | Indoor and outdoor. | Indoor and outdoor. | Same |
| Technical Specifications | |||
| Number of wheels | 1 | 1 | Same |
| Function of wheels | Front wheel: driven, suitable for rotation, acceleration, brake. | Front wheel: driven, suitable for rotation, acceleration, brake. | Same |
| Movement control method | Electronic and mechanic system | Electronic and mechanic system | Same |
| Driving System | Direct drive, steering bar, handlebar and twist throttle | Direct drive, steering bar, handlebar and twist throttle | Same |
| Display | LCD display | LCD display | Same |
| Brake system | Two mechanical brake levers, two callipers, one disc brake (Ø140mm/Ø200mm). Automatic electronic brake limits max speed to ≤ 120% of set limit. | Electronic brake, left and right mechanical brake. | Similar, no safety or effectiveness concerns. |
| Braking distance | < 1.5 meters at 15 km/h in dry conditions | Not publicly available | Similarly, no safety or effectiveness concerns. |
| Maximum Safe operational incline degree | 10° | 6°/ 10% | Similar (deemed equivalent). |
| Battery charger | Mini 2: 36 V; Scrambler 2: 48 V | 48 V | Similar (coinciding where applicable). |
| Main frame material | Aluminium 7005-T6, Aluminium 6061-T6 | Aluminium | Similar, no safety or effectiveness concerns raised. |
| Seat cushion | No | No | Same |
| Overall Dimension | Mini 2: W=570, H=856, L=870; Scrambler 2: L=1070 W=580, H=1020 | Power: W 50cm x H 90cm x D 40cm; Monster: W 50cm x H 90cm x D 50cm | Similar (variations based on models, but overall concept equivalent). |
| Folded Dimension | Mini 2: W=369, H=719, L=736; Scrambler 2: W=310, H=825, L=925 | Not publicly available | n/a |
| Front wheel size/type | Mini 2: 12" Aluminium rim, 12.5 x 2.75" Tyre; Scrambler 2: 19" Aluminium rim, 20 x 2.5" Tyre | Aluminium rim, 14" diameter for Power and race, 20" for Monster | Similar, no safety or effectiveness concerns raised. |
| Analysis Rear wheel size/type | No | No | Same |
| Max forward speed | 15km/h | 15km/h | Same |
| Max reverse speed | 5 km/h | Not publicly available | n/a |
| Max loading weight | 110 kg | 120 kg | Similar (within acceptable range for typical use). |
| Battery | Li-ion battery: 36 V 280 Wh, 36 V 576 Wh, 48 V 748 Wh | 3 versions of Lithium-Ion battery 48V: 2.9 Ah (140Wh), 5.8 Ah (280Wh), 11.6 Ah (528Wh) | Similar |
| Maximum distance of travel on the fully charged battery | Mini 2: 21.5 km (280 Wh), 44 km (576 Wh); Scrambler 2: 57.5 km (748 Wh) | 45-50 km | Similar |
| Motor | Mini 2: Brushless, nominal 350 W, peak 600 W; Scrambler 2: Brushless, nominal 1440 W, peak 1620 W | Brushless, 250W nominal (Power), 1000W (Race/Monster) | Similar, no safety or effectiveness concerns raised. |
| Electronic controller | 20 A nominal – 30 A max | Not publicly available | n/a |
| Turning Radius | 1.2 meters | Not publicly available | n/a |
| Maximum obstacle climbing | Numerous specific measurements (e.g., 50mm without run-up, 75mm with run-up for climbing forwards) | "To go over steps higher than 50 mm, both uphill and downhill." | Similar (conceptually equivalent performance). |
| Non-clinical Testing Compliance | Conforms to listed ISO/IEC standards (See point 6) | (Implied predicate also conforms to relevant standards) | Demonstrates safety and performance equivalent to predicate and standards. |
2. Sample size used for the test set and the data provenance (e.g. country of origin of the data, retrospective or prospective)
This information is not applicable in the context of this 510(k) submission, as it relates to the evaluation of a physical device against performance standards and comparison to a predicate, not to a data-driven or AI/SaMD evaluation. The tests performed are engineering/bench tests on the device itself, not on a dataset of patient information. No patient data or clinical data is mentioned for 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)
This is not applicable here. "Ground truth" in the context of medical devices like this typically refers to validation against established physical properties, engineering specifications, and safety standards, not interpretation by medical experts.
4. Adjudication method (e.g. 2+1, 3+1, none) for the test set
This is not applicable. Adjudication methods are relevant for subjective medical image interpretation or clinical outcomes, not for objective physical device testing 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
This is not applicable. MRMC studies are for evaluating diagnostic performance of AI or imaging technologies with human readers, which is not the nature of this device.
6. If a standalone (i.e. algorithm only without human-in-the-loop performance) was done
This is not applicable. This is a physical device, not an algorithm. However, the document does state that non-clinical testing was performed to demonstrate conformance to specifications and requirements. This is equivalent to "standalone" testing for a physical device.
The document lists the following standards for non-clinical testing:
- ISO 7176-1:2014, ISO 7176-2:2017, ISO 7176-3:2012, ISO 7176-4:2008, ISO 7176-5:2008, ISO 7176-6:2018, ISO 7176-8:2014, ISO 7176-9:2009, ISO 7176-10:2014, ISO 7176-11:2012, ISO 7176-13:1989, ISO 7176-14:2008, ISO 7176-15:2014, ISO 7176-21:2009 (Wheelchairs)
- IEC 60601-1-2:2014 + A1:2020 (Medical electrical equipment)
- IEC 62133-2 Edition 1.0 2017-02 (Lithium batteries)
These tests are the "study" that proves the device meets the (implicit) acceptance criteria of safety and performance as defined by these consensus standards and substantial equivalence to the predicate.
7. The type of ground truth used (expert consensus, pathology, outcomes data, etc)
For this physical device, "ground truth" is defined by:
- Engineering specifications and design requirements: The device's components and measurements are designed to meet certain performance metrics.
- International Consensus Standards (ISO/IEC): These standards define acceptable performance, safety, and durability criteria for wheelchairs and their components.
- Comparison to Predicate Device: The predicate device, having already been cleared by the FDA, serves as a benchmark for acceptable safety and effectiveness.
8. The sample size for the training set
This is not applicable. This refers to machine learning algorithms, which are not part of this device.
9. How the ground truth for the training set was established
This is not applicable. This refers to machine learning algorithms, which are not part of this device.
In summary:
The "study" proving the Handbike Batec Electric meets its acceptance criteria is a series of non-clinical bench and engineering tests performed according to recognized international consensus standards (listed in point 6), and a direct comparison of its design, intended use, and technical specifications to a previously cleared predicate device. The acceptance criteria are implicitly defined by compliance with these standards and demonstrated substantial equivalence to the predicate, ensuring its safety and effectiveness for its intended use. No clinical data or human-in-the-loop performance studies were deemed necessary for this 510(k) submission.
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