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Risk Assessment Plug-and-play starting point AI & Automation

Risk Assessment: AI Use Classification and Tiering for Regulatory and CMC Content

A plug-and-play risk assessment that classifies each proposed AI use in regulatory affairs and CMC content production into internal-intelligence, assistive-draft, consistency-check, or direct-to-record tiers, names the accountable role, and rules out the unacceptable tier, with a filled specimen.

Document type: Risk Assessment

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use risk assessment that turns the classification step of AI governance for regulatory and CMC content into a documented, repeatable decision, rather than a one-time narrative judgment. It classifies each proposed AI use by where its output goes and who is accountable for it, and rules the direct-to-record pattern out explicitly for every use assessed. Replace every <<FILL: ...>> placeholder with your own specifics, set your document numbers and dates, and route it through document control and approval. A filled specimen follows. Verify each cited regulation against the current source before you rely on it.

Document control header

FieldEntry
Document titleAI Use Classification Risk Assessment for <<FILL: FUNCTION / PROGRAM>>
Document number<<FILL: RA-ID>>
Version<<FILL: version, e.g. 1.0>>
Effective date<<FILL: effective date>>
Supersedes<<FILL: prior version or "New">>
Document owner<<FILL: role, e.g. Regulatory Affairs Lead>>
Linked AI system validation record(s)<<FILL>>

1. Purpose

This assessment classifies each proposed or in-use AI application within regulatory affairs and CMC content production into a governance tier, so the accuracy, traceability, and human-authorship controls applied to each use match what it actually does and where its output goes, per AI in regulatory affairs and CMC.

2. Scope

This assessment covers every AI-assisted activity in regulatory writing, submission assembly, regulatory intelligence, and labeling/change management for <<FILL: program / function>>. It does not cover AI models used for scientific or clinical data analysis feeding a regulatory decision directly, which fall under a separate credibility-assessment framework referenced in section 6.

3. Method

3.1 Classify each use by output destination and accountability

For each proposed or existing AI use, answer in one sentence: what does the AI output, what does it feed, and who is the named human who owns the result. Then assign the tier below.

TierPatternWhere output goesAcceptable for filed content?
Internal intelligenceAI summarizes public or internal information for a human decisionInternal strategy, not filedN/A, not filed
Assistive draftAI drafts content a qualified human verifies and owns before useFiled after human authoring and approvalYes, with full controls
Consistency / conformance checkAI flags candidate issues a human adjudicatesInternal QC, human decides each flagN/A, not filed directly
Direct-to-recordAI output enters a controlled record without human authoringWould be filed unverifiedNever acceptable

3.2 For assistive-draft uses, confirm the supporting controls exist

ControlPresent?Evidence
The AI system and version are pinned and version-controlled<<FILL>><<FILL>>
The model is grounded via retrieval in named source documents, not general training<<FILL>><<FILL>>
The draft requires inline source citation per claim<<FILL>><<FILL>>
A named human author verifies and owns the content before filing<<FILL>><<FILL>>
Records of AI involvement are retained in the controlled document system<<FILL>><<FILL>>

4. Use classification register

Complete one row per proposed or existing AI use.

#Use description (one sentence: output, feeds what, named owner)TierRationaleControls confirmed (3.2, if assistive-draft)Approved?
<<FILL>><<FILL>><<FILL>><<FILL>><<FILL>><<FILL>>
<<FILL>><<FILL>><<FILL>><<FILL>><<FILL>><<FILL>>

5. Acceptance criteria

  • Every AI use in scope has a one-sentence classification statement and an assigned tier, with the reasoning recorded, not just the label.
  • No use is classified or operated as direct-to-record; any use trending that way is stopped and reclassified.
  • Every assistive-draft use has the section 3.2 controls confirmed present before it is approved to produce filed content.
  • The register is reviewed whenever a new AI use is proposed and at the periodic cadence defined in the governing SOP.

6. References

FDA draft guidance, Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products (January 2025, draft; narrower scope, models generating data for a regulatory decision). EU GMP draft Annex 22, Artificial Intelligence (draft; limits generative AI to non-critical uses with human oversight). Guiding Principles of Good AI Practice in Drug Development (FDA and EMA, 14 January 2026; non-binding principles, cite as framing only). ICH Q9(R1), Quality Risk Management. 21 CFR Part 11 / EU GMP Annex 11 (the human accountability and electronic signature framework filed content still runs through).

Confirm the current status (draft or final) of each AI-specific document before relying on it; several are actively moving.

7. Revision history

VersionDateAuthorSummary of change
<<FILL: 1.0>><<FILL: date>><<FILL: author>>Initial issue.

8. Approvals

RoleNameSignatureDate
Author (Regulatory Affairs)<<FILL>>
IT / Data Science<<FILL>>
Approver (QA)<<FILL>>

Filled specimen

#Use descriptionTierRationaleControls confirmedApproved?
1AI drafts a first-pass nonclinical written summary from provided study reports; the lead regulatory writer verifies every claim and owns the final sectionAssistive draftOutput becomes filed CTD content; a named writer verifies against source before filingAll five controls in 3.2 confirmed presentYes
2AI summarizes competitor labels and public advisory-committee materials for internal strategy discussionInternal intelligenceOutput stays internal, informs strategy only, never filedN/AYes
3AI flags specification-value inconsistencies across dossier sections before eCTD compilationConsistency checkHuman adjudicates every flag; nothing is changed without reviewN/AYes
4Proposed: auto-populate a variation’s justification field directly from AI output with QA “spot-checking” a sampleDirect-to-recordContent would enter a controlled record without per-instance human authoring; spot-checking is not authoringNot applicable, use rejectedNo, rejected

Use 4 is the point of the exercise: it looked like a productivity win, but classifying it plainly against the tier definitions showed it was direct-to-record wearing an assistive-draft costume, and it was rejected before it reached production rather than discovered during an audit.

Common inspection findings this risk assessment prevents

  • “AI helps with regulatory writing” treated as one undifferentiated activity with no per-use classification.
  • An assistive-draft use approved without confirming the grounding, citation, and authorship controls actually exist.
  • A consistency-check tool’s flags applied automatically without human adjudication, quietly becoming direct-to-record.
  • A non-binding AI principles document or a draft guidance cited as if it authorized a specific technical shortcut.

How to adapt this risk assessment

  1. List every current and proposed AI use in regulatory and CMC content production, not just the ones already in production.
  2. Force the one-sentence classification statement for each use before assigning a tier; a vague description usually hides a direct-to-record pattern.
  3. For every assistive-draft use, walk section 3.2 and require evidence, not an assertion, for each control.
  4. Reject and document any use that lands in the direct-to-record tier rather than trying to make it acceptable with a lighter review step.
  5. Re-run this assessment whenever a new AI use is proposed, and confirm the AI-specific reference documents’ status has not changed at each periodic review.
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