K130982 · Lerado Global (Macao Commercial Offshore) Limited · ITI · Feb 28, 2014 · Physical Medicine
Device Facts
Record ID
K130982
Device Name
LERADO, POWER WHEELCHAIR
Applicant
Lerado Global (Macao Commercial Offshore) Limited
Product Code
ITI · Physical Medicine
Decision Date
Feb 28, 2014
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.3860
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The device is intended for medical purposes to provide mobility to persons restricted to a seated position.
Device Story
LERADO DF4110 is a battery-operated, four-wheeled powered wheelchair for indoor/outdoor use. Rider operates device via hand controls on steering column. Features include electromagnetic braking, foldable design for transport, and off-board battery charger. Device provides mobility to individuals restricted to seated position. Clinical benefit is restored mobility. No complex software or AI/ML algorithms; operation is electromechanical.
Clinical Evidence
Bench testing only. Device performance validated against ANSI/RESNA WC Vol.2 and ISO 7176 series standards (Parts 1-11, 13, 15) covering electromagnetic compatibility, static stability, braking effectiveness, energy consumption, dimensions, speed/acceleration, fatigue strength, and climatic testing.
Technological Characteristics
Frame: SPCC Steel Pipe. Upholstery: PVC leather, fabric, foam. Propulsion: 24VDC carbon brush motor (200W). Controller: Dynamic Shark 40A. Battery: 35Ah x 12V x 2pcs. Braking: Electromagnetic. Tires: PU solid. Connectivity: None. Sterilization: N/A.
Indications for Use
Indicated for persons restricted to a seated position requiring mobility assistance. No specific age or gender restrictions noted.
Regulatory Classification
Identification
A powered wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position.
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Image /page/0/Picture/1 description: The image shows the logo for Lerado. The logo consists of the word "LERADO" in bold, sans-serif font. The "A" in "LERADO" is replaced by a black triangle. Below the word "LERADO" is the word "DESIGNS" in a smaller font.
Avenida Marciano Baotista. No.26-54b. 7 Andar. H7 Edif. Centro Com. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
#### K130982 66 510(k) SUMMARY "
Date summary prepared:
December 31, 2013
Submitter's Name: LERADO Global (MACAO Commercial Offshore) Limited
Avenida Marciano Baotista, No.26-54b, 7 Andar, H7 Edif. Centro Com., Chong Fok Macau, China.
Name of Contact Person:
Dr. Jen, Ke-Min Tel: +852-5-2475605 Fax:+852-5-2379627 Email:ceirs.jen@msa.hinet.net
Device Name:
Proprietary Name: Common or Usual Name: Classification Name:
LERADO Power Wheelchair, DF4110 Powered Wheelchair Powered Wheelchair, Class II, 21 CFR 890.3860
Indications for Use:
The device is intended for medical purposes to provide mobility to persons restricted to a seated position.
Description of the device:
LERADO, Powered Wheelchair, DF4110 series include the devices with the same mechanic and electric controlling structure but with different colors of body and veneer. The LERADO Powered Wheelchair, DF4110 is an indoor / outdoor wheelchair that has a base with four-wheeled with a seat and is battery operated. The device can be disassembled for transportation, easily foldable and is provided with an off-board battery charger. The movement of the wheelchair is controlled by the rider who uses hand controls located at the top of the steering column.
Performance Testing:
- ANSI / RESNA WC Vol.2 Wheelchair Part 2: Electromagnetic compatibility, 2009. .
- · ISO7176-1 Wheelchairs Part 1: Determination of Static Stability, 1999.
- ISO7176-2 Wheelchairs Part 2:Determination of electric wheelchairs, 2001.
- · ISO7176-3 Wheelchairs Part 3: Determination of effectiveness of brakes, 2003.
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Image /page/1/Picture/0 description: The image shows the logo for Lerado Group. The logo consists of the word "LERADO" in bold, sans-serif font, with a triangle in place of the letter "A". Below the word "LERADO" is the word "GROUP" in a smaller, sans-serif font. The logo is simple and modern, and the use of the triangle adds a touch of visual interest.
Avenida Marciano Baotista. No.26-54b. 7 Andar. H7 Edif. Centro Com. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
- · ISO7176-4 Wheelchairs Part 4:Determination of energy consumption of electric wheelchairs, 2008.
- · ISO7176-5 Wheelchairs Part 5: Determination of overall dimensions, mass and maneuvering space, 2008.
- · ISO7176-6 Wheelchairs Part 6:Determination of maximum speed, acceleration and retardation of electric wheelchairs, 2001.
- · ISO7176-7 Wheelchairs Part 7: Measurement of seating and wheel dimensions, 1998.
- · ISO7176-8 Wheelchairs Part 8: Requirements and test methods for static, impact and fatigue strengths, 1998.
- · ISO 7176-9 Wheelchairs Part 9: Climatic tests for electric wheelchairs, 2009.
- · ISO7176-10 Wheelchairs Part 10:Determination of the climbing ability of electric wheelchairs, 2008.
- · ISO7176-11 Wheelchairs Part 11: Test dummies, 1992.
- · ISO7176-13 Wheelchairs Part 13:Determination of coefficient of friction of test surfaces, 1989.
- · ISO7176-15 Wheelchairs Part 15:Requirements for information disclosure, documentation and labelling, 1996.
Materials of the subject device:
| Components | Materials | Test regulation |
|-------------------------------|------------------------------|-----------------------------------------------------------------------------------------------------------|
| FRAME | High-Quality SPCC Steel Pipe | CAS# 7439-89-6 |
| SEAT Leather | PVC Leather | EN 1021-1/-2:2006 Resistant to<br>ignition source smouldering<br>cigarette, and match flame<br>equivalent |
| UPHOLSTERY<br>FABRIC & LINING | Fabric and Foam | ANSI/BIFMA X5.1-1993,<br>ISO 8191-1/-2, ISO 7176-16:<br>resistance to ignition |
| TIRE | PU Solid Tire | CAS# 101-68-8 |
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Image /page/2/Picture/0 description: The image shows the logo for Lerado Group. The logo consists of the word "LERADO" in a bold, sans-serif font, with a triangular shape in place of the "A". Below the word "LERADO" is the word "GROUP" in a smaller font. The logo is black and white.
Avenida Marciano Baotista. No.26-54b. 7 Andar. H7 Edif. Centro Con. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
Specifications of the subject device:
- . Frame Material: High Quality SPCC Steel Pipe
- Framework: Unfoldable
- Controller: Dynamic Shark 40A ●
- Motor output :
- Motor: ●
Trade name: Chiapua Components Group
Type: GD35D-05T, DC24V Direct Current Carbon Brush Motor
Size: �88.5mm x 109mm
Output: 200W
RPM: 2955RPM
- Battery: 35Ahx12Vx2pcs .
- . Charger : 3A
- Brake : Electromagnetic brake
- Max Speed : 6km/h (4mile/h)
- Continuous trip distance : 20km /12.4mile
- Climbing ability:6°
- Front wheel: 10" PU Solid tire
- Rear wheel : 6" PU Solid tire
- Seat depth : 410 mm (16.1" )
- Seat height: 530 mm (20.9")
- Seat width : 475 mm (18.7" )
- Max loading: 136kgs(300lbs)
- . Available color: black (body), red/yellow/blue (veneer)
- Total weight:70.3 kgs / 155 lbs
- . Ground clearance:48 mm / 1.9"
- Turning diameter : 1,230 mm / 48.4"
- Dimension ( L*W*H ): 1,040 * 625 * 1,250 mm
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Image /page/3/Picture/0 description: The image shows the logo for "LERADO DESIGNS". The logo is in black and white, with the word "LERADO" in large, bold letters. The letter "A" in "LERADO" is replaced by a triangle. Below the word "LERADO" is the word "DESIGNS" in smaller letters.
Avenida Marciano Baotista. No.26-54b. 7 Andar. H7 Edif. Centro Com. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
# Comparison table
| ITEMS | PREDICATE<br>DEVICE | SUBJECT DEVICE |
|--------------------------------------|-----------------------------------------------------------------------------------------------------------------------------|-----------------------------------------|
| BRAND NAME | LERADO | LERADO |
| MANUFACTURER | LERADO GROUP | LERADO GROUP |
| MODEL NO | PB Series | DF4110 Series |
| 510K NO | K070433 | K130982 |
| INTENDED USE | The device is<br>intended for medical<br>purposes to provide<br>mobility to persons<br>restricted to a sitting<br>position. | SAME |
| Frame | Fixed (unfoldable) | SAME |
| Overall dimension | | |
| Overall length | 650 mm / 25.59" | 1,040 mm / 40.94" |
| Overall width | 600 mm / 23.62" | 625 mm / 24.60" |
| Weight limit | 136 kgs / 300 lbs | SAME |
| Maximum speed | 6.0 km/hr (4mile/h) | SAME |
| Electronics<br>controller | Dynamic, DA50 | Dynamic, Shark 40A |
| Batteries | | |
| Quantity<br>Type<br>Range per charge | Two<br>36Ah 12VDC<br>36 km / 22.5 miles | Two<br>35Ah 12VDC<br>20 km / 12.4 miles |
| Suspension | Cross brace | SAME |
| Rear wheels | 10" solid x 2" | 6" PU solid tire |
| Casters | 8" solid x 2" | 10" PU solid tire |
| ITEMS | PREDICATE<br>DEVICE | SUBJECT DEVICE |
| Footplates | ABS | SAME |
| Frame material | High-Quality SPCC Steel<br>Pipe | SAME |
| Motor | | |
| Trade name | Motion Technology Electric &<br>Machinery Co., ltd. | Chiapua Components Group |
| Model number | EC82M | GD35D-05T |
| power | 320W | 200W |
| Type | 24VDC Carbon-brush | 24VDC Carbon-brush |
| Diameter | $Φ$ 82mm *149mm | $Φ$ 88.5mm * 109mm |
| Speed | 4600 RPM | 2955 RPM |
| Seat size | | |
| Width | 46~61 cm / 18~24" | 47.5 cm / 18.70" |
| Depth | 46 cm / 18" | 41 cm / 16.14" |
| Height | 53~58 cm / 21~23" | 53 cm / 20.86" |
| Incline | 6 degrees | 6 degrees |
| Back<br>upholstery | Fabric | SAME |
| Armrest types | Flip-backward | SAME |
| Wheelchair<br>Weight<br>w/batteries | 87 kgs | 70.3 kgs |
| Charger<br>Model<br>Voltage | HIGH POWER<br>HP8204B<br>24VDC | HIGH POWER<br>HP1211B1<br>24VDC |
| ITEMS | PREDICATE<br>DEVICE | SUBJECT DEVICE |
| Wheel Lock | Push-to-Lock | SAME |
| Type of brake | Dynamic electromagnetic<br>brake | SAME |
| Warranty | 3 years: Main frame<br>1 years: Controller / gear<br>motor / batteries w/o<br>exhaustive and wear<br>parts | SAME |
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Image /page/4/Picture/0 description: The image shows the logo for Lerado Group. The logo consists of the word "LERADO" in a stylized font, with a triangle in place of the "A". Below the word is the text "LERADO GROUP" in a smaller font. The logo is black and white.
Avenida Marciano Baotista. No.26-54b. 7 Andar. H7 Edif. Centro Com. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
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Image /page/5/Picture/0 description: The image shows the word "LERADO" in a stylized font. The "A" in the word is replaced by a triangle. Below the word, there is a series of dots and dashes.
Avenida Marciano Baotista. No. 26-54b. 7 Andar. H7 Edif. Centro Com. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
#### Substantial equivalence comparison discussion:
We know from the above table that the intended use between two devices is the same; and they are from the same LERADO group and the same manufacturer. Mainframes of two devices are not foldable and all meet the strength and fatigue tests, thus they are similar for the material aspects. The overall dimensions are similar. The weight capabilities, maximum speed, suspension of cross brace, footplates, armrest, and the warranty are all the same. Back upholstery material is also the same fabric.
Especially, the electronic systems of two devices, for instance the motor, batteries, and charger are from the same supplier, and both are UL-certified. For the electronic controller, the predicate device uses the Dynamic DA series and the subject device use Dynamic Shark series, and both are UL-certified. Thus the same safety level for the two devices is assured.
Incline capabilities for the two devices are the same. The subject device and the predicate device can both drive under 6 degrees of incline. We place the limit of 6 degrees of climbing incline on the page 2 of the Owner's Manual and the user is not allowed to operate the device on the incline over the specified angle. The safety levels of the two devices are the same when operating the devices on the adequate inclines. They are substantially equivalent.
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Image /page/6/Picture/0 description: The image shows the word "LERADO" in a stylized font. The letters are in black and are spaced apart. The letter "A" is replaced by a black triangle. Below the word "LERADO" is the text "LERADO DESIGNS" in a smaller font.
Avenida Marciano Baotista. No.26-54b, 7 Andar. H7 Edif. Centro Com. Chong Fok Macau. China
TEL: 852-5-2475605 FAX: 852-5-2379627
The cruising ranges per charge are different; and the subject device is 12.4 miles and 22.5 miles for the predicate device. Certainly the real range depends on the practical environmental conditions, i.e., loading weight, driving surface, incline angle, and temperature. For the real life use, the two devices are substantially equivalent.
To sum up, the major differences existing between the two devices are the overall dimensions and cruising ranges. The overall appearance differences are not safety aspect. Thus the new device is substantially equivalent to the predicate devices in this aspect.
Based on the above the information and the analysis, we know that the subject device and the predicate device have the same intended use, the same technological aspects and only minor dimensions and material differences exist. We believe that FDA can decide the subject device and the predicate device are substantially equivalent.
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Image /page/7/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a stylized eagle with its wings spread, and the words "DEPARTMENT OF HEALTH & HUMAN SERVICES • USA" are arranged in a circular pattern around the eagle. The logo is black and white.
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
February 28, 2014
Lerado Global Limited c/o Dr. Jen, Ke-Min Avenida Marciano Baotista, No. 26-54b, 7 Andar H7 Edif Centro Com. Chong Fok Macau CHINA
Re: K130982
Trade/Device Name: LERADO Power Wheelchair, Model DF4110 Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: January 17, 2014 Received: January 30, 2014
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. 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 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
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Page 2 - Dr. Jen, Ke-Min
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 (reporting of medical device-related adverse events) (21 CFR 803); 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.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Small Manufacturers, International and Consumer Assistance at its tollfree number (800) 638-2041 or (301) 796-7100 or at its Internet address http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. 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/ResourcesforYou/Industry/default.htm.
Sincerely yours,
# Carlos L. Pena -S
Carlos Peña, Ph.D., M.S. Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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#### DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration
### Indications for Use
Form Approved: OMB No. 0910-0120 Expiration Date: December 31, 2013 See PRA Statement on last page.
510(k) Number (if known) K130982
Device Name
LERADO Power Wheelchair, model DF4110
Indications for Use (Describe)
The device is intended for medical purposes to provide mobility to persons restricted to a sitting position.
Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
[x] Over-The-Counter Use (21 CFR 801 Subpart C)
# PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON A SEPARATE PAGE IF NEEDED.
#### FOR FDA USE ONLY
Concurrence of Center for Devices and Radiological Health (CDRH) (Signature)
# Carlos L. Pena -S
FORM FDA 3881 (9/13)
{10}------------------------------------------------
This section applies only to requirements of the Paperwork Reduction Act of 1995.
#### *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.*
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
> Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
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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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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.
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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.
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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.
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Reading rule for every project: how many summaries do you read in full?
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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.
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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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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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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.
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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.