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510(k) Data Aggregation

    K Number
    K220671
    Date Cleared
    2022-07-21

    (136 days)

    Product Code
    Regulation Number
    890.3850
    Reference & Predicate Devices
    Why did this record match?
    Reference Devices :

    K180852

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

    The Manual Wheelchair is intended for medical purposes to provide mobility to persons restricted to a sitting position.

    Device Description

    The Manual Wheelchair is a wheeled personal mobility device that incorporates a seat-support system for a person with a disability or a person without the full capacity to walk designed to be manually propelled by the user while seated in the device or by an attendant. The occupant moves the wheelchair by rotating two handrims protruding from rear wheels. An attendant moves the device by pushing or pulling handles on the device. The device can be folded for transport. The device can be operated indoor or outdoor on dry, smooth surfaces composed of concrete, blacktop or asphalt under normal driving conditions. The subject manual wheelchair is a mechanical wheelchair with four wheels, including two front casters and two rear wheels, a frame made of carbon steel, a seat and a backrest made of oxford fabric, which is soft and water-resistant, two handles, armrests, handrims, foot pedals, legrest strap and seat belt. The subject manual wheelchair has a physical dimension of 1085mm × 700mm ×935mm (length × width × height). The device has a weight capacity of 100 kilograms, and its total mass is 17.3kg. The color is black.

    AI/ML Overview

    This document describes the premarket notification (510(k)) for a Manual Wheelchair (Model: SYIV100-RLD-G01) seeking clearance from the U.S. Food and Drug Administration (FDA).

    It's important to note that this is a Class I medical device (Mechanical Wheelchair, Product Code: IOR), which are generally considered low risk and do not require extensive clinical trials or complex AI performance criteria as seen with higher-class devices. The primary method for proving substantial equivalence for such devices is often through non-clinical performance testing and comparison to an existing predicate device.

    Therefore, many of the typical "AI device" specific questions (like MRMC studies, training set details, or expert consensus for ground truth) are not applicable to this specific submission, as the device is not an AI-powered diagnostic or therapeutic tool. The "acceptance criteria" here refer to the device meeting established performance standards for manual wheelchairs, rather than AI performance metrics.

    Here is the information based on the provided document:


    1. Table of Acceptance Criteria and Reported Device Performance

    For this manual wheelchair, the acceptance criteria are based on compliance with recognized performance and safety standards, and demonstrating that the proposed device performs "as well as" a legally marketed predicate device. The document does not present a formal "table of acceptance criteria and reported device performance" as one might see for an AI algorithm with metrics like sensitivity/specificity. Instead, it demonstrates compliance through adherence to ISO standards and a comparative analysis.

    Acceptance Criteria (Implicit: Compliance with Standards and Predicate Equivalence)

    Criteria CategorySpecific Standards/TestsReported Device Performance
    Mechanical PerformanceISO 7176-1: Determination of static stabilityComplies with ISO 7176-1 (Static stability: longitudinal forward tilt ≥ 10°, longitudinal backward tilt ≥ 10°, flank tilt ≥ 15°)
    ISO 7176-3: Determination of effectiveness of brakesComplies with ISO 7176-3 (Hill-holding performance: ≥8°)
    ISO 7176-5: Determination of overall dimensions, mass and manoeuvring spaceComplies with ISO 7176-5 (Overall dimensions, weight, min. turning radius, min. reversing width as specified: Length: 1085mm, Width: 700mm, Height: 935mm, Weight: 17.3kg, Min. Turning Radius: ≤850mm, Min. Reversing Width: ≤1500mm, Sliding offset: ≤350mm)
    ISO 7176-7: Measurement of seating and wheel dimensionsComplies with ISO 7176-7 (Seat width: 420mm, Seat depth: 410mm, Seat height from floor: 505mm, Backrest height: 405mm, etc. as specified)
    ISO 7176-8: Requirements and test methods for static, impact and fatigue strengthsComplies with ISO 7176-8 (Load capacity: 100kg)
    ISO 7176-11: Test dummiesComplies with ISO 7176-11 (Used for relevant tests)
    ISO 7176-13: Determination of coefficient of friction of test surfacesComplies with ISO 7176-13 (Used for relevant tests)
    ISO 7176-15: Requirements for information disclosure, documentation and labelingComplies with ISO 7176-15
    ISO 7176-16: Resistance to ignition of postural support devicesComplies with ISO 7176-16
    ISO 7676-22: Set-up proceduresComplies with ISO 7176-22
    BiocompatibilityISO 10993-1: Biological evaluation of medical devices - Part 1: Evaluation and testing within a risk management processComplies with ISO 10993-1
    ISO 10993-5: Biological evaluation of medical devices Part 5: Tests for in vitro cytotoxicityComplies with ISO 10993-5 (for PP material)
    ISO 10993-10: Biological evaluation of medical devices - Part 10: Tests for irritation and skin sensitizationComplies with ISO 10993-10 (for handrim and PP armrest material)
    LabelingConforms to FDA Regulatory RequirementsConforms to FDA Regulatory Requirements (Table 3)
    Substantial EquivalenceDevice performs "as well as" legally marketed predicate device (K180852) despite minor differences in dimensions or material choices.All differences analyzed and demonstrated not to affect safety or effectiveness, with performance confirmed through compliance with relevant ISO standards. Conclusion: "as safe, as effective, and performs as well as the legally marketed predicate device."

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

    • Test Set Sample Size: Not explicitly stated as a "sample size" in terms of number of patients or images, because this is a physical medical device. The "test set" here refers to the physical units of the manual wheelchair subjected to various engineering and biocompatibility tests. Typically, a small number of units (e.g., 1-3) are tested to demonstrate compliance with standards for Class I devices like this.
    • Data Provenance: The tests are non-clinical (laboratory and engineering tests) conducted on the manufactured device. The geographic origin of the testing is not specified, but the manufacturer is based in China. The data would be considered prospective in the sense that the tests were performed specifically for this 510(k) submission.

    3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts

    • This is not applicable to this type of device submission. There is no "ground truth" established by human experts in the context of diagnostic or AI performance for a manual wheelchair. The "ground truth" for this device's performance is objective measurements against established engineering and biocompatibility standards.

    4. Adjudication method for the test set

    • This is not applicable. No adjudication method (like 2+1, 3+1 consensus) is relevant for non-clinical engineering and biocompatibility testing of a physical product like a manual wheelchair.

    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. This is not an AI device or an imaging device requiring human reader studies.

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

    • This is not applicable. This is not an AI algorithm.

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

    • The "ground truth" for this device's performance is based on objective measurements and results from standardized non-clinical engineering tests (ISO 7176 series) and biocompatibility tests (ISO 10993 series). For example, a wheelchair either passes the static stability test at a certain angle or it doesn't; this is a measured outcome against a defined specification, not an expert opinion.

    8. The sample size for the training set

    • This is not applicable. This device is a physical product and does not involve AI/machine learning models that require training sets.

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

    • This is not applicable. As it's not an AI device, there is no training set or associated ground truth establishment process.
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