The purpose of The Gunnell Rehab Series Wheelchairs is to provide mobility to individuals limited to a seating position. They may also be used as attendant propelled transport devices in a health care environment such as a hospital, nursing home or extended care facility. The Kidster is the only device in the GRSW that is solely intended for pediatric users.
Device Story
Gunnell Rehab Series Wheelchairs (GRSW) are manually operated, mechanical wheelchairs designed for mobility and positioning. Models include tilt-in-space (TNT, MAC, Kidster) for pressure relief and comfort, and recline functions. Certain models (TNT, RAM, Kidster) feature optional 20° lateral tilt to assist with positioning, such as for scoliosis management. Bariatric versions (BTNT, BRAM) are available. Devices are used in clinics, hospitals, nursing homes, and extended care facilities, operated by patients or attendants. The mechanical design provides mobility for individuals confined to a seated position; tilt/recline features facilitate attendant access and patient comfort. No electronic or software components are involved.
Clinical Evidence
Bench testing only. The devices were tested in accordance with ISO 7176 standards (parts 1, 3, 5, 7, 8, and 15) covering static, impact, and fatigue strength requirements.
Technological Characteristics
Manual mechanical wheelchair; materials common to industry standards. Features include recline, tilt-in-space, and optional 20° lateral tilt. Tested per ISO 7176 (1, 3, 5, 7, 8, 15). No energy source, connectivity, or software.
Indications for Use
Indicated for individuals restricted to a sitting position requiring mobility assistance or attendant-propelled transport in healthcare settings. Kidster model indicated for pediatric users.
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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# 510(K) SUMMARY
510(k) #: K111636
APR - 3 2012
Submitter:
Gunnell, Inc. 8440 State Rd. PO Box 308 Millington, MI 48746 1-800-551-0055 (Phone) 989-871-4563 (Fax) Chris.chen@gunnell-inc.com (e-mail)
Contact Person: Chris Chen, Ph.D.
### DEVICE IDENTIFICATION
Collectively referred to as the Gunnell Rehab Series Wheelchairs Proprietary names: (GRSW)
- Rehab Tough and Tilt (TNT) .
- Rehab Recline and Mobility (RAM) ●
- Rehab Multi-Adjustable Chair (MAC) .
- Rehab Kidster (Kidster). .
- Bariatric Rehab Tough and Tilt (BTNT) ●
- Bariatric Rehab Recline and Mobility (BRAM) .
Generic name: Manual Wheelchair
Classification Name: Wheelchair, Mechanical
Regulatory Class: Class I
Product Code: IOR
| Identification of Predicate Devices: | PDG Eclipse 400 | (#K971389) | 5/9/1997 |
|--------------------------------------|------------------|------------|-----------|
| | PDG Stellar | (#K990557) | 3/22/1999 |
| | PDG Eclipse 600 | (#K961743) | 5/29/1996 |
| | Freedom CGX | (#K080270) | 4/16/2008 |
| | PDG Fuze T50 Jr. | (#K063736) | 1/17/2007 |
#### INTENDED USE
The purpose of The Gunnell Rehab Series Wheelchairs is to provide mobility to individuals limited to a seating position. They may also be used as attendant propelled transport devices in a health care environment such as a hospital, nursing home or
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extended care facility. The Kidster is the only device in the GRSW that is solely intended for pediatric users.
### DEVICE DESCRIPTION
The Gunnell Rehab Series of Wheelchairs (GRSW) are manually operated, mechanical wheelchairs. The GRSW are fabricated from materials common to many other wheelchairs in the industry. In addition, the GRSW offer the same options and exhibit the same features as many other mechanical wheelchairs in the market. The entire GRSW feature a recline function. The TNT. MAC, and Kidster include a tilt in space feature, which allows the upper frame of the wheelchair to be tilted. This feature is used to provide pressure relief as well as comfort to those users who may be confined to the wheelchair for extended periods of time. The tilt feature can also serve as an attendant aid in those situations where a patient needs to be tilted for attendant access. The TNT, RAM, and Kidster also have an optional lateral tilt feature allowing for 20° lateral tilt to the right and left. The lateral tilt feature is helpful in positioning individuals with a number of different conditions. For example, this feature allows for the seat to be on a lateral angle in response to the angle or degree of scoliosis exhibited by the user thereby providing better positioning for long term usage. The TNT and the RAM are available in bariatric sizes, featuring the same options and construction as that of their respective standard models.
## SAFETY AND EFFECTIVENESS
The Gunnell Rehab Series of Wheelchairs have been developed based on extensive knowledge and experience gained by providing mobility for individuals requiring assistive technology since the introduction of Gunnell Inc. in the late 1950's. This knowledge and experience has provided many satisfied individuals with durable and safe wheelchairs through the years. The GRSW are fabricated from the same materials as many wheelchairs in the industry, and offer many of the same features and options. Additionally, the GRSW successfully tested in accordance with the applicable parts of ISO 7176 (1, 3, 5, 7, 8, and 15) which includes testing for static, impact and fatigue strengths.
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Image /page/2/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the words "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" arranged around the perimeter. Inside the circle is a stylized image of an eagle or bird-like figure with outstretched wings.
Food and Drug Administration 10903 New Hampshire Avenue Document Control Room -WO66-G609 Silver Spring, MD 20993-0002
·Gunnell Incorporated % Chris Chen, Ph.D. 8440 State Road P.O. Box 308 Millington, Michigan 48746
APR - 3 2012
Re: K111636
Trade Name: Rehab Tough and Tilt (TNT) Bariatric Rehab Tough and Tilt (BTNT) Rehab Recline and Mobility (RAM) Bariatric Rehab Recline and Mobility (BRAM) Rehab Multi-Adjustable Chair (MAC) Rehab Kidster (Kidster)
Regulation Number: 21 CFR 890.3850 Regulation Name: Mechanical wheelchair Regulatory Class: Class I Product Code: IOR Dated: March 23, 2012 Received: March 27, 2012
Dear Dr. Chen:
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 10 wo sixion in 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 1 ou may, merelove, miams of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.
If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to 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 I loase of advised that i D. Forestion that your device complies with other requirements of the Act that I Dri has made a asternment administered by other Federal agencies. You must
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#### Page 2 - Chris Chen. Ph.D.
comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807): labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please go to http://www.fda.gov/AboutFDA/CentersOffices/CDRH/CDRHOffices/ucm115809.htm for the Center for Devices and Radiological Health's (CDRH's) Office of Compliance. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
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 (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm.
Sincerely yours.
Mark N. Melkerson
Director Division of Surgical, Orthopedic and Restorative Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### 510(k) Number (if known): K111636
Device Name:
Rehab Tough and Tilt (TNT) Bariatric Rehab Tough and Tilt (BTNT) Rehab Recline and Mobility (RAM) Baritric Rehab Recline and Mobility (BRAM) Rehab Multi-Adjustable Chair (MAC) Rehab Kidster (Kidster). All of the above, collectively referred to as the Gunnell Rehab Series Wheelchairs (GRSW).
Indications For Use:
The intended use of all of the GRSW's is to provide mobility to individuals restricted to a sitting position.
Prescription Use (Part 21 CFR 801 Subpart D) OR
Over-The-Counter Use (21 CFR 801 Subpart C)
な
(PLEASE DO NOT WRITE BELOW THIS LINE-CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
Wayne P. Rogers
(Division Sign-Off) Division of Surgical, Orthopedic, and Restorative Devices
510(k) Number K111636
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Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
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Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
4. Device detail page: chat and citations
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Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
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What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.