K170787 · Nanjing Jin Bai HE Medical Apparatus Co., Ltd. · ITI · Aug 9, 2017 · Physical Medicine
Device Facts
Record ID
K170787
Device Name
Powered Wheelchair DYW30A(D09)
Applicant
Nanjing Jin Bai HE Medical Apparatus Co., Ltd.
Product Code
ITI · Physical Medicine
Decision Date
Aug 9, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 890.3860
Device Class
Class 2
Attributes
Therapeutic, Real-World Evidence
Real-World Evidence
Submission
Device
Sponsor
RWD Sources
RWE Use Summary
Key Tags
K170787 · Aug 9, 2017
Powered Wheelchair DYW30A(D09)
Nanjing Jin Bai HE Medical Apparatus Co., Ltd.
Post-market sales data; Customer complaint/adverse event records
The sponsor used post-market performance data (thousands of units sold with no adverse customer claims) to support the biocompatibility of materials used in the wheelchair's seat, backrest, safety belt, and armrests.
Post-market surveillance / retrospective review of customer claims
Users of wheelchairs containing the specified PVC Vinyl and PU Foam materials; Sample Size: Thousands of units sold
Not applicable for this study
Absence of adverse conditions/customer claims
Indications for Use
The device is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to a disabled or an elderly person limited to a seated position.
Device Story
Powered wheelchair DYW30A(D09) provides indoor mobility for disabled or elderly users. Device input is user-actuated joystick movement; output is motorized propulsion via two 250W brushless DC motors. System includes foldable frame, seat, armrests, two Li-ion batteries, and electromagnetic brakes. User operates joystick to control direction and speed; releasing joystick triggers automatic braking. Device is intended for indoor use only; maximum speed 3.75 mph; maximum weight capacity 264 lbs. Benefits include increased mobility and portability for individuals with walking difficulties. Healthcare providers do not operate the device; it is for patient use.
Clinical Evidence
No clinical data. Substantial equivalence is supported by bench testing, including ISO 7176 series (stability, energy consumption, dimensions, speed/acceleration, strength, climatic tests, obstacle climbing, power/control systems, electromagnetic compatibility) and IEC 60601-1-2. Biocompatibility testing for patient-contacting materials (PVC Vinyl, PU Foam) was conducted per ISO 10993-5 and ISO 10993-10.
Technological Characteristics
Frame: 6063 aluminum alloy. Propulsion: Dual 250W brushless DC motors. Power: Two 12V/6Ah Li-ion batteries. Control: Joystick-actuated, smart electromagnetic brakes. Dimensions: 37.4" x 22.6" x 36.2". Connectivity: None. Sterilization: N/A. Standards: ISO 7176 series, IEC 60601-1-2, IEC 62133.
Indications for Use
Indicated for disabled or elderly persons with walking difficulties who require a motor-driven indoor transportation vehicle while in a seated position. Not for outdoor use, stairs, escalators, or inclines exceeding 8 degrees.
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.
Predicate Devices
SUZHOU KD MEDICAL APPLIANCE CO. LTD. PL001 power wheelchair (K113463)
Submission Summary (Full Text)
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Image /page/0/Picture/0 description: The image shows the logo for JBH Wheelchair. The logo has a green letter "D" on the left side. To the right of the "D" is the text "JBH Wheelchair" in orange. Below the text is the phrase "Portable, Light, Safe".
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106 Tel: 0086(25)85780699 Fax: 00861860 556 5636 Email: njjbhch@gmail.com Website: www.jbhwheelchair.com
### 510(k) Summary of Safety and Effectiveness 5.
(per 21 CFR 807.92)
| Submitter's Name: | Nanjing Jin Bai He Medical Apparatus Co., Ltd.<br>No. 61 Qinhuai Road, Jiangning Economic and Technological<br>Development Zone, Nanjing, Jiangsu, China 211106 |
|-------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Date summary prepared: | July 5, 2017 |
| Proprietary Name: | Powered Wheelchair, DYW30A(D09) |
| Common or Usual Name: | Powered Wheelchair |
| Classification Name: | Powered Wheelchair, Class II, 21 CFR 890.3860 |
| Product Code: | ITI |
| Company contact person: | Dr. KE-MIN JEN (Email: ceirs.jen@msa.hinet.net)<br>TEL: +886-3-5208829, FAX:+886-3-5209783 |
| Predicate Device: | SUZHOU KD MEDICAL APPLIANCE CO. LTD.<br>PL001 power wheelchair<br>K113463 |
### ● Indications for Use:
The device is a motor-driven, and indoor transportation vehicle with the intended use to provide mobility to a disabled or an elderly person limited to a seated position.
### ● Device Description:
The powered wheelchair DYW30A(D09) is driven by two DC motors, and is suitable for indoor uses. It is an individual transportation vehicle for disabled and elderly people that experience difficulties in walking. The powered wheelchair DYW30A(D09) comes as preassembled, designed to be lightweight, easily maneuvered, highly portable, and most importantly, safe and comfortable.
It consists of two foldable armrests, a seat belt, a backrest, a seat cushion, a foldable frame, two rear driving wheels with hub motor/electromagnetic brake assemblies, two pivoting casters, two Li-ion batteries, an off-board battery charger, a control panel, and an electric motor controller.
{1}------------------------------------------------
Image /page/1/Picture/0 description: The image contains the logo for JBH Wheelchair. The logo features a green stylized letter "D" on the left, followed by the text "JBH Wheelchair" in orange. Below the text, there is a tagline that reads "Portable, Light, Safe".
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106 Tel: 0086(25)85780699 Fax: 00861860 556 5636 Email: njjbhch@gmail.com Website: www.jbhwheelchair.com
The device is powered by two 12 volt / 6 Ah Lithium-ion batteries with 11.2 miles travel range that can be recharged by an off-board battery charger that can be plugged into an AC outlet (110-220 V, 50-60 Hz), when the device is not in use.
The user can activate the joystick to move in the direction of the joystick is actuated. When the user releases the joystick, the device slows to stop and the brakes are automatically re-engaged. The maximum weight capacity of DYW30A(D09) is 264 lbs and its maximum speed is 3.75 mph.
The following surfaces are recommended NOT to operate on:
- Sand surface �
- Wet or icy surface ◆
- Road maintenance hole metal cover �
- � Do not use on stairs
- � Do not use escalators. Use the elevator.
- ◆ Too steep incline over 8 degrees.
- Obstacle climbing ability: 1.36"
- Do not use outdoors
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Image /page/2/Picture/0 description: The image is a logo for JBH Wheelchair. The logo features a green letter "D" with a small orange accent at the top. To the right of the "D" is the text "JBH Wheelchair" in orange. Below the text is the phrase "Portable, Light, Safe" in a smaller font, also in orange.
No. 61 Oinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106 Tel: 0086(25)85780699 Fax: 00861860 556 5636 Email: njjbhch@gmail.com Website: www.jbhwheelchair.com
### ● Performance Testing:
- v ISO 7176-1:2014 Wheelchairs - Part 1: Determination of static stability
- v ISO 7176-2:2001 Wheelchairs - Part 2: Determination of dynamic stability of electric wheelchairs
- く ISO 7176-3:2013 Wheelchairs - Part 3: Determination of effectiveness of brakes
- v ISO 7176-4:2008 Wheelchairs - Part 4: Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range
- V ISO 7176-5:2008 Wheelchairs - Part 5: Determination of dimensions, mass and maneuvering space
- V ISO 7176-6:2001 Wheelchairs - Part 6: Determination of maximum speed, acceleration and deceleration of electric wheelchairs
- V ISO 7176-7:1998 Wheelchairs - Part 7: Measurement of seating and wheel dimensions
- V ISO 7176-8:2014 Wheelchairs - Part 8: Requirements and test methods for static, impact and fatigue strength
- v ISO 7176-9:2009 Wheelchairs - Part 9: Climatic tests for electric wheelchairs
- V ISO 7176-10:2008 Wheelchairs - Part 10: Determination of obstacle-climbing ability of electrically powered wheelchairs
- V ISO 7176-11:2012 Wheelchairs -- Part 11: Test dummies
- V ISO 7176-13:1989 Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces.
- V ISO 7176-14:2008 Wheelchairs -- Part 14: Power and control systems for electrically powered wheelchairs and scooters -- Requirements and test methods
- V ISO 7176-15:1996 Wheelchairs - Part 15: Requirements for information disclosure, documentation and labeling.
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Image /page/3/Picture/0 description: The image contains the logo for JBH Wheelchair. The logo features a green stylized letter "D" with a smaller green symbol below it. To the right of the "D" is the text "JBH Wheelchair" in orange. Below the text is the phrase "Portable, Light, Safe" also in orange.
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106 Tel: 0086(25)85780699 Fax: 00861860 556 5636 Email: njjbhch@gmail.com Website: www.jbhwheelchair.com
- V ISO 7176-16:2012 Wheelchairs -- Part 16: Resistance to ignition of postural support devices
- イ ISO 7176-21:2009 Wheelchairs - Requirements and test methods for electromagnetic compatibility of electrically powered wheelchairs and scooters
- く ISO 7176-25:2013 Wheelchairs - Batteries and chargers for powered wheelchairs
- V IEC 60601-1-2:2014 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
- V IEC 62133:2012 Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications
| Patient-contacting parts | Materials | Rational for biocompatibility testing | Conclusion |
|---------------------------------------------|-----------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|
| Seat<br>Backrest<br>Safety belt<br>Joystick | PVC Vinyl | *ISO 10993-1:2009<br>*PVC Vinyl material is adopted by many<br>wheelchair manufacturers in the market, and<br>it is common and mature material for<br>wheelchair parts.<br>*No customer claim with adverse conditions<br>for more than thousands of units sold in the<br>market. | We conduct the<br>ISO 10993-5<br>and ISO<br>10993-10 tests. |
| Armrest | PU Foam | *ISO 10993-1:2009<br>*PU Foam material is adopted by many<br>wheelchair manufacturers in the market, and<br>it is common and mature material for<br>wheelchair parts.<br>*No customer claim with adverse conditions<br>for more than thousands of units sold in the<br>market. | We conduct the<br>ISO 10993-5<br>and ISO<br>10993-10. tests. |
### ● Biocompatibility of patient-contacting material
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Image /page/4/Picture/0 description: The image shows the logo for JBH Wheelchair. The logo features a green stylized letter "J" next to the orange text "JBH Wheelchair". Below the text is the tagline "Portable, Light, Safe" in a smaller font. The logo is clean and modern, with a focus on the brand name and its key attributes.
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106
il: njjbhch@gmail.com Website: www.jbhwheelchair.com
| ● | Comparison table | | |
|---------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Devices<br>Specifications | Predicate device | Subject device | Explaining no new<br>safety and effectiveness<br>concerns raised due to<br>the differences |
| Manufacturer | Suzhou KD Medical<br>Apparatus Co., Ltd. | Nanjing Jin Bai He<br>Medical Apparatus Co.,<br>Ltd. | Devices made by<br>different manufacturers |
| Proprietary name | Power Wheelchair | Powered Wheelchair, | Different devices |
| Model name | PL001 | DYW30A(D09) | Different models |
| 510(k) No. | K113463 | K170787 | New 510(k) submission |
| | | Similarities | |
| Indications for use | The device is a motor<br>driven. <b>indoor</b> and<br><b>outdoor</b> transportation<br>vehicle with the<br>intended use to Provide<br>mobility to a disabled or<br>elderly person limited to a<br>seated<br>position | The device is a motor-<br>driven, and <b>indoor</b><br>transportation vehicle<br>with the intended use to<br>provide mobility to a<br>disabled or an elderly<br>person limited to a seated<br>position. | The PL001 is for indoor<br>and outdoor uses and the<br>DYW30A(D09) is for<br>indoor use.<br>The restriction in indoor<br>use can decrease the risk<br>level for the subject<br>device, thus ensure no<br>new safety and<br>effectiveness concerns<br>raised due to the<br>difference. |
| Motor | Chongqing Mao Tian<br>Machinery Co., Ltd.,<br>Brushless DC motor<br>$180 W×24 VDCx2 pcs$ | Chongqing Mao Tian<br>Machinery Co., Ltd.,<br>Brushless DC motor<br>$250W x 24 VDC x 2 pcs$ | Similar motors are made<br>by the same company.<br>Our motor power is<br>larger than predicate<br>device, and this means<br>more driving force are<br>supplied to the subject<br>device, no safety and<br>effectiveness concerns<br>raised. |
| Battery | Jiangsu Feng Chi Green<br>Power Supply Co., Ltd.,<br>Lithium-ion<br>$10Ahx24 VDCx2 pcs$ | Jiangsu Feng Chi Green<br>Power Supply Co., Ltd.,<br>Lithium-ion, ITP2406<br>$6 Ah x 24 VDC x 2 pcs$ | Similar batteries are<br>made by the same<br>manufacturer.<br>Our battery meets ISO |
{5}------------------------------------------------
Image /page/5/Picture/0 description: The image is a logo for JBH Wheelchair. The logo features a green letter "D" with the letters "JBH" in a smaller font below it. To the right of the "D" is the word "Wheelchair" in orange. Below the word "Wheelchair" is the phrase "Portable, Light, Safe" in a smaller font.
**NANJING JIN BAI HE MEDICAL APPARATUS CO., LTD.**
9331 — Pateller Life Sale — NANING JIN BAL HE MEDICAL APPARATUS CO., LTD.
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China Ema
| ﺭ | ail: njjbhch(@gmail.com Website: www.jbhwheelchair.com |
|---|--------------------------------------------------------|
|---|--------------------------------------------------------|
| Email: njjbhch@gmail.com Website: www.jbhwheelchair.com | | | 7176-25:2013, and no<br>new safety and<br>effectiveness concerns<br>raised. |
|---------------------------------------------------------|---------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Charger model &<br>rating | High Power Technology<br>Inc.<br>HP1202B<br>Input: AC100-240V<br>Output: DC 24V, 2Amp | High Power Technology<br>Inc.<br>HP0060W(L2)<br>Input: 100-240 VAC<br>Output: DC 24V, 2 Amp | Similar chargers are<br>made by the same<br>manufacturer. Our<br>charger meets ISO<br>7176-25:2013, and no<br>new safety and<br>effectiveness concerns<br>raised. |
| | | | |
| Number of Wheels | 4 | 4 | Same number of wheels |
| Driving system | Direct drive on the rear<br>wheels | Direct drive on the rear<br>wheels | Same driving system |
| Brake System | Smart Electromagnetic<br>brake | Smart Electromagnetic<br>brake | Same brake system |
| Max Speed<br>(Forwards) | 3.75 mph (6 km/h) | 3.75 mph (6 km/h) | Same maximum speed,<br>forward |
| Speed control<br>method | Joystick control method | Joystick control method | Same speed control<br>method |
| Main frame<br>material | 6063 aluminum alloy | 6063 aluminum alloy | Same frame material |
| | | Differences | |
| Use environments | Indoor and outdoor use | Indoor use | Restricted use in the<br>indoor environment will<br>ensure lower risk level. |
| Front wheel size &<br>type | 6" x 2" (150×38 mm)<br>(PU Solid tire) | 7"x1.77" (180 x 45 mm)<br>(PU solid tire) | Larger sizes of front<br>wheels bring steadier<br>pivoting function than<br>predicate device. |
| Rear wheel size &<br>type | 8" x 2"<br>(200 x 50 mm)<br>(PU solid tire) | 12.5" x 2.25"<br>(320 x 57 mm)<br>(PU solid tire) | Larger sizes of rear<br>wheels bring more<br>comfortable ride feeling<br>than predicate device. |
| Maximum safe<br>operational incline | 12 degrees | 8 degrees | We restrict the use<br>environment for the<br>subject device to be<br>indoor. Safe operational |
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Image /page/6/Picture/0 description: The image shows the logo for JBH Wheelchair. The logo features a stylized letter "D" in green, with the letters "JBH" in orange to the right of the "D". The word "Wheelchair" is also in orange and is placed to the right of "JBH". Below the company name is the text "Portable, Light, Safe".
**NANJING JIN BAI HE MEDICAL APPARATUS CO., LTD.**
1991 - 1978 - 1978 - 1978 - 1978 - 1978 - 1974 - 1974 - 1974 - 1974 - 1974 - 1979 - 1970.
No. 61 Qinhuai Road, Jan - 1990 - 1992 - 1996 (25 - 563 - 1986 1860 556 - 565 -E
| Email: njjbhch@gmail.com Website: www.jbhwheelchair.com |
|---------------------------------------------------------|
|---------------------------------------------------------|
| Email: njjbhch@gmail.com Website: www.jbhwheelchair.com | | | |
|---------------------------------------------------------|-------------------------------------------|-------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Dimensions<br>(LxWxH) | 38.2" x 23.2" x 33.1" | 37.4" x 22.6" x 36.2" | incline of 8 degrees for<br>the DYW30A(D09) is<br>enough for indoor use.<br>No new safety and<br>effectiveness concerns<br>are raised by this<br>difference.<br>Minor differences in the<br>dimensions will not<br>impact the safety and<br>effectiveness of the<br>substantial equivalence. |
| Weight, w/ Battery | 60.87 lbs. / 27.6 kg | 51.8" lbs. / 23.5 kg | Less weight will lead to<br>more convenience when<br>transported and there is<br>more cruising range than<br>predicate device. |
| Cruising Range | 9.3 miles (15 km) | 11.2 miles (18 km) | This difference is due to<br>the less weight and more<br>power for the subject<br>device, based on the<br>work and energy<br>theorem. There is a<br>larger cruising range for<br>the subject device. |
| Max Loading | 250 lbs. | 264 lbs. | More loading weight<br>means more convenient<br>for the transportation. |
| Max Speed<br>Backward | 2.4 mph (3.84 km/h) | 1.86 mph (3.0 km/h) | Smaller backward speed<br>means lower risk level<br>for the subject device. |
| Turning Radius | 31.5" (800 mm) | 32.5" (833 mm) | The minor difference in<br>the turning radius will<br>cause some<br>inconvenience when it<br>turns in a narrow space<br>and the difference will<br>not raise any new safety<br>and effectiveness<br>concerns |
| Maximum obstacle<br>climbing | 1.2" (30 mm) | 1.36" (34.5 mm) | The larger height in the<br>obstacle climbing will<br>not impact the safety<br>and effectiveness of the<br>subject device. |
| Controller | Brushless dual-drive rocker<br>controller | Changzhou Billon<br>Electronic Appliance Co.,<br>Ltd., WS-1 | Our controller passed<br>ISO 7176-14 and there<br>is no safety and<br>effectiveness concerns<br>raised due to this<br>difference. |
| Minimum braking<br>distance | 1.5 m | 1 m | Our minimum braking<br>distance is smaller than<br>the predicate device and<br>this ensures more safety.<br>There is no new safety<br>and effectiveness<br>concerns raised due to<br>the difference. |
{7}------------------------------------------------
Image /page/7/Picture/0 description: The image is a logo for JBH Wheelchair. The logo features the letters "JBH" in green and orange, with the word "Wheelchair" in orange next to it. Below the text is the phrase "Portable, Light, Safe" in orange. The logo is simple and modern, and it conveys the message that JBH Wheelchair is a company that provides high-quality, portable, light, and safe wheelchairs.
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106 Tel: 0086(25)85780699 Fax: 00861860 556 5636
### ● Substantial equivalent discussion
Firstly please refer to the explanations in the comparison table. The engineering design and technical properties of DYW30A(D09) powered wheelchair are very similar to the predicate device, PL001 power wheelchair. Both chairs utilize dual brushless motors as their power sources, and the motors are manufactured by the same company, while PL001 uses 180W motors, DYW30A(D09) uses 250W motors.
The Lithium-ion batteries used by both powered wheelchairs come from the same manufacturer as well, though PL001 power wheelchair uses 10Ah batteries and DYW30A(D09) powered wheelchair uses 6Ah batteries. The maximum speed of DYW30A(D09) is the same as the predicate device.
The control system, including the joystick controller, the smart electromagnetic brakes and their user interface are similar. The joystick controls the directions of the powered wheelchair, move the joystick in the direction that the user is looking to go, and when the joystick is released, the powered wheelchair will come to a stop slowly, and the brakes will automatically re-engage. The control system of the subject device passed the ISO 7176-14:2008 and there are no new safety and effectiveness concerns due to the difference.
{8}------------------------------------------------
Image /page/8/Picture/0 description: The image shows the logo for JBH Wheelchair. The logo features a stylized letter "D" in green, followed by the text "JBH Wheelchair" in orange. Below the text, there is a tagline that reads "Portable, Light, Safe".
No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone, Nanjing, Jiangsu, China 211106 Tel: 0086(25)85780699 Fax: 00861860 556 5636 Email: njjbhch@gmail.com Website: www.jbhwheelchair.com
The turning radius of the subject device is larger than that of the predicate device by 1.0". This difference will bring slight inconvenience to the user of the subject device while doing a turning in the limited space, but this is not related to the safety aspect.
Other minor differences between two powered wheelchairs include weights, overall dimensions and maximum weight capacity, and these do not change the overall functions and intended uses of the DYW30A(D09).
DYW30A(D09) has passed the relevant testing, including ISO 7176 series and IEC 60601-1-2:2014, to ensure there are no new safety and effectiveness concerns when compared with the predicate device.
Image /page/8/Picture/6 description: The image shows a black electric wheelchair with a silver frame. The wheelchair has a padded seat and backrest, as well as armrests and a footrest. A joystick is mounted on the right armrest, which is used to control the wheelchair's movement. The wheelchair has four wheels, with the two front wheels being smaller than the two rear wheels.
Predicate device: PL001 power wheelchair
Image /page/8/Picture/8 description: The image shows a red and black electric wheelchair. The wheelchair has a black seat and backrest, and a red frame. It has a joystick control on the left armrest. The wheelchair is sitting on a gray floor.
Subject device: DYW30A(D09) powered wheelchair
#### ● CONCLUSIONS
The subject device, DYW30A(D09), is as safe and effective as, and functions in a manner equivalent to the predicate device, PL001 (K113463). The conclusions drawn from the non-clinical tests demonstrate that the device is as safe, as effective, and performs as well as the legally marketed device identified in the submission. Thus the subject device is substantially equivalent to the predicate device.
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### DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
Nanjing Jin Bai He Medical Apparatus Co., Ltd. Jen Ke-Min Official Correspondent No. 61 Qinhuai Road, Jiangning Economic and Technological Development Zone Nanjing, 211106 CN
Re: K170787
Trade/Device Name: Powered Wheelchair DYW30A(D09) Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: March 10, 2017 Received: March 16, 2017
Dear Jen 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
{11}------------------------------------------------
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); medical device reporting (reporting of medical devicerelated 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 Industry and Consumer Education 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. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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 Industry and Consumer Education 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.
Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
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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.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
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.
Where do you find a device's intended use without opening the PDF?
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
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
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.
6. Collections
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.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
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.
8. Chart view
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.