K231484 · Pureway Compliance, Inc. · MMK · Sep 14, 2023 · General Hospital
Device Facts
Record ID
K231484
Device Name
PureWay 1.4 Quart Sharps Collector
Applicant
Pureway Compliance, Inc.
Product Code
MMK · General Hospital
Decision Date
Sep 14, 2023
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 880.5570
Device Class
Class 2
Indications for Use
PureWay Compliance 1.4 Quart Sharps Collector Container is single-use, disposable, non-sterile and intended to be used for healthcare purposes for safe containment and disposal of hazardous sharps such as hypodermic needles, syringes, lancets and blood needles. The target user is for healthcare professionals.
Device Story
The PureWay 1.4 Quart Sharps Collector is a single-use, non-sterile, injection-molded HDPE plastic container designed for the safe containment and disposal of hazardous sharps (e.g., hypodermic needles, syringes, lancets). The device features a conical base and a snap-on clamshell lid to ensure a tight seal. It is intended for use by healthcare professionals in clinical settings. The container is puncture-resistant, leak-resistant, and stable. It includes a fill line indicator to prevent overfilling. The device is operated manually; the user places sharps into the container through the access opening and snaps the lid closed when full. The device provides a secure, puncture-resistant environment for sharps disposal, reducing the risk of accidental needlestick injuries to healthcare staff.
Clinical Evidence
No clinical data. Bench testing only. The device was tested for compliance with ISO 23907-1:2019, including container stability, resistance to penetration, resistance to damage/leakage after dropping and toppling, fill line indicator accuracy, and handle strength.
Technological Characteristics
Material: High Density Polyethylene (HDPE); Injection molded; Red color. Dimensions: 4.5" x 4.5" x 8". Capacity: 1.0 quart at fill line. Features: Conical base, snap-on clamshell lid, puncture/leak-resistant, fill line indicator. Standards: ISO 23907-1:2019. Sterilization: Non-sterile.
Indications for Use
Indicated for healthcare professionals for the safe containment and disposal of hazardous sharps, including hypodermic needles, syringes, lancets, and blood needles.
Regulatory Classification
Identification
A hypodermic single lumen needle is a device intended to inject fluids into, or withdraw fluids from, parts of the body below the surface of the skin. The device consists of a metal tube that is sharpened at one end and at the other end joined to a female connector (hub) designed to mate with a male connector (nozzle) of a piston syringe or an intravascular administration set.
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September 14, 2023
PureWay Compliance Inc. Jeffery Miglicco Director of Quality 201 Santa Monica Blvd. Suite 400 Santa Monica, California 90401
Re: K231484
Trade/Device Name: PureWay 1.4 Quart Sharps Collector Regulation Number: 21 CFR 880.5570 Regulation Name: Hypodermic Single Lumen Needle Regulatory Class: Class II Product Code: MMK Dated: Mav 23, 2023 Received: May 23, 2023
Dear Jeffery Miglicco:
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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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 comply with all the Act's
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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) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.
For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
Sincerely,
# Christopher K. Dugard -S
Christopher K. Dugard, M.S. Assistant Director DHT4B: Division of Infection Control and Plastic Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K231484
Device Name PureWay 1.4 Quart Sharps Collector
#### Indications for Use (Describe)
PureWay Compliance 1.4 Quart Sharps Collector Container is single-use, disposable, non-sterile and intended to be used for healthcare purposes for safe containment and disposal of hazardous sharps such as hypodermic needles, syringes, lancets and blood needles. The target user is for healthcare professionals.
| Type of Use (Select one or both, as applicable) | |
|-----------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------|
| <span style="white-space: nowrap;"><input type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D)</span> | <span style="white-space: nowrap;"><input checked="" type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C)</span> |
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Image /page/3/Picture/0 description: The image shows the logo for PureWay Total Compliance. The logo consists of an orange circle with a white star-like design inside, followed by the company name in black lettering. The words "TOTAL COMPLIANCE" are written in smaller letters below the company name.
## 510(k) Number: K231484 PureWay 1.4 Quart Sharps Collector
| Device Information | Comments |
|-----------------------------------|-----------------------------------------------------------------------------------------------|
| Submitter | PureWay Compliance, Inc. |
| Headquarters | 1908 E. Dominguez St, Carson CA 90801 |
| Correspondent Contact Information | Jeffery Miglicco, Director of Quality<br>E-mail: jeffm@pureway.com<br>Cell: 713.248.2289 Fax: |
| Device Common Name | Sharps Container |
| Device Classification Name | Hypodermic single lumen needle (CFR 880.5570) |
| Product Code | MMK |
| Classification | Class II Device |
| Classification Panel | General Hospital |
Table 1: Device Information
| Predicate Device Information | |
|------------------------------|-----------------------------------------------|
| Sharps Container | |
| Manufacturer Name | Oakridge Products LLC. |
| Common Name | Sharps Container |
| Premarket Notification NO. | K130281 |
| Device Classification Name | Hypodermic single lumen needle (CFR 880.5570) |
| Product Code | MMK |
| Classification | Class II Device |
| Classification Panel | General Hospital |
#### Table 2: Predicate Device Information
- b. Date Prepared 05/23/2023
- c. Description of Device
The PureWay Sharps Collector is injection molded with High Density Polyethylene plastic (HDPE). Designed for single use, the container is puncture resistant, leak resistant on the sides and bottom, closable and stable. The container is labeled with a fill line and instructions for snapping
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Image /page/4/Picture/0 description: The image shows the logo for PureWay Total Compliance. The logo consists of an orange circle with a white star-like shape inside on the left. To the right of the circle is the text "PureWay" in a stylized font, with the words "TOTAL COMPLIANCE" in smaller letters underneath.
the container lid closed. "Do Not Overfill" to prevent overfill. The label is white and blue with white text and a black biohazard symbol is printed on a red background.
The container is made of two parts, (Base and Lid) that form a single unit. The red colored base is conical shaped, and the lid is a clamshell design snapped in place for a tight seal when the container is full.
The device is a non-sterile, single use, disposable infectious waste container and is designed to contain and hold sharps such as angio-caths, blood needles, lancets, cap needles, and various sized syringes. The shape of the container is conical which allows for one hand disposal of sharps and a clamshell lid for means of closure.
| Product<br>Description | Access Opening Size<br>in Inches | Overall Size<br>in Inches | Weight<br>(grams) | Capacity at<br>fill line |
|------------------------|----------------------------------|---------------------------|-------------------|--------------------------|
| 1.3 Quart | 1.25 inch | 7.75 x 3.9x 3.9 | 425 | 1 Quart |
#### Table 3: Device Description
#### d. Indications for Use
PureWay Compliance 1.4 Quart Sharps Collector Container is single-use, disposable, non-sterile and intended to be used for healthcare purposes for safe containment and disposal of hazardous sharps such as hypodermic needles, syringes, lancets and blood needles. The target user is for healthcare professionals.
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Image /page/5/Picture/0 description: The image contains the logo for PureWay Total Compliance. The logo consists of an orange circle with six white shapes inside, resembling a star or flower. To the right of the circle is the text "PureWay" in a clean, sans-serif font, with "TOTAL COMPLIANCE" in smaller letters underneath.
## e. Technological Characteristic Comparison
| Characteristics | Predicate Device Oakridge 1 Quart Container<br>(K130281) | PureWay 1.4 Quart Sharps Collector<br>(K231484) | Comparison |
|------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------|
| Indication for Use | The Oak Ridge Products Sharps containers are<br>single-use, disposable, non-sterile containers<br>intended to be used for healthcare purposes<br>for safe disposal of hazardous sharps such as<br>hypodermic needles, syringes, lancets and | The PureWay Sharps container is a single-use,<br>disposable, non-sterile container intended to<br>be used for healthcare purposes for safe<br>disposal of hazardous sharps such as<br>hypodermic needles, syringes, lancets and | Same |
| Use Location | The target population is for trained<br>healthcare professionals. | The target population is for trained healthcare<br>professionals. | Same |
| Material | Plastic Polypropylene<br>Material thickness .045" minimum<br>Injection Molded<br>Color Red | Plastic Polyethylene HDPE<br>Material thickness .045" minimum<br>Injection Molded<br>Color Red | Similar<br>Same<br>Same<br>Same |
| Is Container Reusable<br>or Single Use? | Single Use | Single Use | Same |
| Sterilization | Non-sterile | Non-sterile | Same |
| Design | Closable<br>Constructed to contain all contents and<br>prevent leakage during handling, storage,<br>transport, or shipping.<br>Impact resistant<br>Puncture resistant<br>Leak resistant<br>Overfill indication<br>Stable (maintaining upright position) | Closable<br>Constructed to contain all contents and<br>prevent leakage during handling, storage,<br>transport, or shipping.<br>Impact resistant<br>Puncture resistant<br>Leak resistant<br>Overfill indication<br>Stable (maintaining upright position) | Same<br>Same<br>Same<br>Same<br>Same<br>Same<br>Same<br>Same |
| Dimensions | | | Same |
| Access opening and<br>closure | Slide | Opening door | Same |
| Overall Size | 4.5" x 4.5"x 7.5" | 4.5" x 4.5" x 8" | Similar |
| Weight (grams) | 115 grams | 125 grams | Similar |
| Capacity at full line | .8 quarts | 1.0 quarts | Similar |
| No features to bend,<br>break or shear needle. | No feature present | No feature present | Same |
| Clarity | Minimum of one translucent component,<br>either base or top | Minimum one translucent component either<br>base or top | Same |
The PureWay 1.3 quart sharps collector is intended use and technology to the predicate device, Oakridge Products LLC. 1 Quart Sharps Container (K130281).
Both devices are injection molded plastic, designed for single use, puncture resistant, impact resistance, leak resistant, closable, and stable. The container is labeled with a fill line and instructions for snapping the container lid closed.
Both containers are made of three parts, (Base, Lid, and Label) that form a single unit. The red colored base is conical shaped, and the lid is designed to snap in place for a tight seal.
Both devices are single use only and not sterile.
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Image /page/6/Picture/0 description: The image shows the logo for PureWay Total Compliance. The logo consists of an orange circle with a white star-like shape inside, followed by the text "PureWay" in a stylized font. Below "PureWay" is the text "TOTAL COMPLIANCE" in smaller, all-caps letters.
## f. Summary of Non-Clinical Performance Data
| Test Performed | Test Method/Applicable<br>Standard (s) | Acceptance Criteria | Predicate<br>Device<br>(K130281) | PureWay 1.4<br>Quart<br>(K231484) |
|------------------------------------------------------|------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------|-----------------------------------------------------------------------------------------|
| Container stability | ISO 23907-1:2019 Section 5.1<br>Container stability | The container shall not topple over when tested. | Pass | Pass |
| Resistance to<br>penetration | ISO 23907-1:2019 Section 5.3<br>Resistance to penetration | When tested the force needed to penetrate test specimens<br>shall be a minimum of 16 N and an average of 18 N or<br>greater. | Pass | Pass |
| Resistance to damage<br>or leakage after<br>dropping | ISO 23907-1:2019 Section 5.4<br>Resistance to damage and<br>leakage after dropping | When tested there shall be no evidence of leakage and no<br>breach of the sharp's containment area.<br>Minimum five minutes after each topple, the following<br>points shall be visually checked: | Pass | Pass |
| | | 1. No evidence that the performance or function of<br>the container has been compromised. | Pass | Pass |
| | | 2. Container's temporary closure shall remain intact. | Pass | Pass |
| Resistance to<br>damage or leakage<br>after toppling | ISO 23907-1:2019 Section 5.5<br>Resistance to spillage by<br>toppling | There shall be no evidence of breach of the sharps<br>containment area.<br>Minimum five minutes after each topple, the following<br>points shall be visually checked: | Pass | Pass |
| | | 1. There shall be no evidence that the performance<br>or function of the container has been<br>compromised. | Pass | Pass |
| | | 2. The container's temporary closure shall remain<br>intact | Pass | Pass |
| Fill line indicator | ISO 23907-1:2019 Section<br>4.2.7 Fill line indicator | 1. Fill line shall be determined by the design of the<br>container, taking into account the risk of sharps<br>extending above the fill line, and shall be at a<br>level no greater than 85 % of the total volume of<br>the container.<br>2. Fill line feature helps prevent overfilling and is a<br>critical safety feature of a sharps container.<br>3. It shall be possible to ensure the sharps are not<br>above the fill line. This can be achieved either<br>visually or mechanically. | Pass | Pass |
| Strength of Handles | ISO 23907-1:2019 4.2.2 and<br>5.2 | 1. All sharps containers shall be provided with one<br>or several handles.<br>2. The handle/carrying feature shall not break or<br>detach during testing.<br>3. The position of the handles(s), finger recesses,<br>protrusions or flanges shall not interfere with the<br>normal use of the container.<br>4. Fill the container with a mass equivalent to 150% of<br>manufacturer's maximum allowable gross mass.<br>Suspend the container by its handles(s) at the<br>intended carrying points(s) from a rigid support for 1<br>h at a temperature of (23+/- 5) degrees Celsius.<br>Remove the container from the support and inspect<br>the handles for integrity and for any evidence of<br>detachment of the handles(s) from the container. | N/A<br>No Handles | Pass, no<br>evidence of<br>detachment<br>of the<br>handles(s)<br>from the<br>container. |
Bench testing has demonstrated that the device is in compliance with ISO 23907-11:2019 for Single Use Sharps Container and the expectation of the FDA Guidance Document, "Guidance on the content of Format of Premarket Notification (510(k)) submission for Sharps, dated October 1993.
## g. Summary of Clinical Data: Not Applicable
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Image /page/7/Picture/0 description: The image contains the logo for PureWay Total Compliance. The logo consists of an orange circle with a white star-like shape inside, followed by the text "PureWay" in a stylized font. Below "PureWay" is the text "TOTAL COMPLIANCE" in a smaller, sans-serif font.
#### h. Conclusion
The conclusions drawn for the non-clinical tests demonstrate that the device is as safe, as effective and performs as well as or better than the legally marketed predicate device.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
Part 1 — Search, results, and everyday workflows 16 min
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.
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.