KARMA MANUAL WHEELCHAIR, MODELS S-ERGO 305 AND S-ERGO 105
K062309 · Karma Medical Products Co., Ltd. · IOR · Oct 10, 2006 · Physical Medicine
Device Facts
Record ID
K062309
Device Name
KARMA MANUAL WHEELCHAIR, MODELS S-ERGO 305 AND S-ERGO 105
Applicant
Karma Medical Products Co., Ltd.
Product Code
IOR · Physical Medicine
Decision Date
Oct 10, 2006
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.3850
Device Class
Class 1
Indications for Use
The device is intended for medical purposes to provide mobility to persons restricted to a seated position.
Device Story
The KARMA Manual Wheelchair (S-Ergo 305 & S-Ergo 105) is a foldable, four-wheeled mechanical wheelchair designed for indoor and outdoor use. It provides mobility to individuals restricted to a seated position. The device features a seat, backrest, armrests, and footplates. It is designed to be easily disassembled and folded for transport. The user or a caregiver operates the wheelchair manually. The device benefits the patient by facilitating mobility and ease of transport. Clinical decision-making is not affected by the device as it is a mechanical mobility aid.
Clinical Evidence
Bench testing only. The device met applicable performance requirements specified in ANSI/RESNA WC vol. 1 and ISO 7176 Wheelchair Standards.
Technological Characteristics
Mechanical manual wheelchair; foldable frame; four-wheeled base. Materials include resistance-ignitability fabric for back upholstery and stainless steel for footplates. Features include adjustable armrests, footplates, and seat height (S-Ergo 305). Dimensions: 630mm width, 990mm depth. Weight: 15 kg. Manual operation; no energy source or software.
Indications for Use
Indicated for persons restricted to a seated position requiring mobility assistance.
Regulatory Classification
Identification
A mechanical wheelchair is a manually operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position.
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Ka62309
Image /page/0/Picture/1 description: The image shows the logo for Karma Mobility. The word "KARMA" is in large, bold, sans-serif font. The letter "M" is stylized with a heart shape. Above the heart is a small wing. Below the word "KARMA" is the word "mobility" in a smaller, sans-serif font.
## KARMA MEDICAL PRODUCTS CO., LTD.
No.2363, Sec.2, Da-Shiue Rd., Min-Hsiung Shiang, Chia-Yi Hsien 62144, Taiwan, R.O.C. TEL:886-5-206-6688 FAX : 886-5-206-7788 E-mail:eukarma@ms29.hinet.net http://www.karmamedical.com.tw
OC7 1 0 2006
August 5, 2006
#### 66 510(k) SUMMARY "
Submitter's Name: KARMA Medical Products Co., Ltd.
No. 2363, Sec.2, Da-Shiue Road, Min-Hsiung Shiang, Chia-Yi Hsien, 62144, Taiwan, R.O.C.
Date summary prepared:
Device Name:
Proprietary Name:
Common or Usual Name: Classification Name:
KARMA Manual Wheelchair, S-Ergo 305 & S-Ergo 105 Mechanical Wheelchair Mechanical Wheelchair, Class I. 21 CFR 890.3850
Indications for Use:
The device is intended for medical purposes to provide mobility to persons restricted to a seated position.
Description of the device:
The KARMA Manual Wheelchair, S-Ergo 305 & S-Ergo 105 are indoor / outdoor wheelchairs that have the base with four-wheeled with a seat. The devices can be disassembled for transport and it is foldable easily. Back upholstery material is also the same resistance-ignitability fabric.
Performance Testing:
The KARMA Manual Wheelchair, S-Ergo 305 & S-Ergo 105 are Foldable Wheelchair meet the applicable performance requirements as specified in ANSI/RESNA WC vol. 1 and ISO 7176 Wheelchair Standards.
Legally marketed device for substantial equivalence comparison:
WH Convertible Lightweight Wheelchair, WHL100 ( K060251 )
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Image /page/1/Picture/0 description: The image shows the logo for Karma Mobility. The word "KARMA" is in large, bold, sans-serif font, with a heart shape above the "M". A wing-like design is above the heart. Below "KARMA" is the word "mobility" in a smaller, sans-serif font.
KARMA MEDICAL PRODUCTS CO., LTD. No.2363, Sec.2, Da-Shiue Rd., Min-Hsiung Shiang, Chia-Yi Hsien 62144, Taiwan, R.O.C. TEL:886-5-206-6688 FAX:886-5-206-7788 E-mail:eukarma@ms29.hinet.net
http://www.karmamedical.com.tw
# Comparison Table
| ITEMS | SUBJECT DEVICE | PREDICATE DEVICE |
|-----------------------|-------------------------------------|-----------------------------------------------------------------------------------------------------------------------|
| BRAND NAME | KARMA | WH |
| MANUFACTURER | KARMA Medical Products<br>Co., Ltd. | Well Home Health Products Co |
| MODEL No. | S-Ergo 305 | WML100 |
| 510K No. | K062309 | K060251 |
| INTENDED USE | SAME | The device is intended for<br>medical purposes to provide<br>mobility to persons restricted<br>to a sitting position. |
| FRAME | | |
| Width | 630 mm | 21" (534mm) |
| Cross brace | SAME | YES |
| Depth | 990 mm | 15.7"(400mm) |
| Seat | width: 457mm<br>length: 432mm | width: 18" (458mm)<br>depth: 16" (406mm) |
| Backrest height | SAME | adjustable |
| Reclining backrest | SAME | fixed |
| Seat sling | SAME | padded nylon |
| Frame colors | SAME | blue, black |
| ARMREST | | |
| Arm pad | Padded, adjustable | Padded |
| Flip back | YES, detachable | YES, non-detachable |
| Height-adjustable | adjustable | NO |
| HANGERS | | |
| Swing-away | SAME | NO |
| Elevating leg rest | SAME | NO |
| Articulating leg rest | SAME | NO |
| Footplate style | Stainless, adjustable | Nylon fiber(one-piece style) |
| Heel loop | SAME | NO |
| Footrest angle | 30° | 70° |
| REAR AXLE | | |
| Offset axle | SAME | YES |
| ITEMS | SUBJECT DEVICE | SUBJECT DEVICE |
| MODEL No. | S-Ergo 305 | S-Ergo105 |
| FOOTPLATE STYLE | Stainless, adjustable | Stainless, fixed |
| ARMREST | Padded, adjustable | Padded, fixed |
| SEAT HEIGHT | Adjustable | Fixed |
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Image /page/2/Picture/0 description: The image shows the logo for Karma Mobility. The word "KARMA" is written in large, bold, black letters. Above the "M" is a heart with a wing coming out of the top right. Below the word "KARMA" is the word "mobility" in a smaller, less bold font.
KARMA MEDICAL PRODUCTS CO., LTD.
No.2363, Sec.2, Da-Shiue Rd., Min-Hsiung Shiang, Chia-Yi Hsien 62144, Taiwan, R.O.C. FAX:886-5-206-7788 TEL:886-5-206-6688 E-mail:eukarma@ms29.hinet.net http://www.karmamedical.com.tw
SUBJECT DEVICE PREDICATE DEVICE ITEMS MODEL No. S-Ergo 305 WML100 REAR WHEEL convert Size 24" 12" or 24" Tire type Handrim material CASTERS 8" 7" Size Solid Solid Tire type WHEEL LOCK SAME Pull-to-Lock 250 lbs / 115 kg SAME WEIGHT CAPACITY 15 kg (33 lb) 12.9 kg WEIGHT OF CHAIR 6 years on frame 5 years on frame WARRANTY OPTIONALACCESSORIES YES YES Anti-tipper YES Rear stepper YES Fold down push handle YES YES r l
Note: the subject device S-Ergo105 is same as S-Ergo 305 the difference as below:
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Image /page/3/Picture/0 description: The image shows the word "KARMA" in large, bold, sans-serif font. Above the letter "M" is a heart shape with a wing extending from the right side. Below the word "KARMA" is the word "mobility" in a smaller, sans-serif font. The image appears to be a logo or brand name.
KARMA MEDICAL PRODUCTS CO., LTD. No.2363, Sec.2, Da-Shiue Rd., Min-Hsiung Shiang, Chia-Yi Hsien 62144, Taiwan, R.O.C. TEL : 886-5-206-6688 FAX:886-5-206-7788 E-mail:eukarma@ms29.hinet.net http://www.karmamedical.com.tw
Summary for substantial equivalence comparison:
The intended use of the two devices is the same, and mainframes of two devices are the same foldable. The overall dimensions are similar. Back upholstery material is also the same resistance -ignitability fabric. The major differences existing are the overall dimension, and the size of tires are differences between the two devices. Especially, the subject device S-Ergo 305 has the adjustable armrest and footplate. The overall appearance differences are not safety aspect. So the new device is substantially equivalent to the predicate devices in this aspect.
The weight limit of the subject device and the predicate device are also 115 kgs, The seat heights between the new device and the predicate device have small difference, not leading to any safety hazard. The hanger and rear axle designs are The light and portable weight of the new device is similar to the predicate same. device and the user can feel more convenient transport it. At last the optional accessories for the two devices are same, and the users have the same status to choose the needed accessories to accommodate their needs.
Thus the new device is substantially equivalent to the predicate devices in this aspect.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Image /page/4/Picture/1 description: The image shows the seal of the Department of Health & Human Services (HHS) of the United States of America. The seal features a stylized eagle with its wings spread, symbolizing protection and service. The words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the eagle, indicating the department's name and national affiliation. The seal is presented in black and white.
Food and Drug Administration 9200 Corporate Boulevard Rockville MD 20850
Karma Medical Products Co., Ltd. % Dr. Jen Ke-Min No. 2363, Sec.2, Da-Shiue Road Min-Hsiung Shiang Chia-Yi Hsien 62144, Taiwan, R.O.C
OCT 1 0 2006
Re: K062309
Trade/Device Name: KARMA Manual Wheelchair, S-Ergo 305 & S-Ergo 105 Regulation Number: 21 CFR 890.3850 Regulation Name: Mechanical wheelchair Regulatory Class: Class I Product Code: IOR Dated: September 23, 2006 Received: September 27, 2006
Dear Dr. Ke-Min:
We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.
Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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Page 2 -- Dr. Jen Ke-Min
This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification. The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Office of Compliance at (240) 276-0120 . Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807.97). You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (240) 276-3150 or at its Internet address http://www.fda.gov/cdrh/industry/support/index.html.
Sincerely yours.
barbare Buelms
Mark N. Melkerson Director Division of General, Restorative and Neurological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510 (K) Number ( If Known ):__________________________________________________________________________________________________________________________________________________
Device Name: KARMA Manual Wheelchair, S-Ergo 305 & S-Ergo 105
Indications for Use:
The device is intended for medical purposes to provide mobility to persons restricted to a sitting position.
Prescription Use
AND/OR
Over-The-Counter Use
(Part 21 CFR 801 Subpart D)
(21 CFR 807 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
| Concurrence of CDRH Office of Device Evaluation (ODE) | |
|------------------------------------------------------------|-------------|
| (Division Sign-Off) | |
| Division of General, Restorative, and Neurological Devices | Page 1 of 1 |
| 510(k) Number | K06 2309 |
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