Foundation — runs under every stage

GxP, validation & assurance

GAMP 5, Annex 11, draft Annex 22, Part 11, CSA, data integrity and AI governance — how you prove to an inspector that a system nobody can fully predict is under control.

  • Computer system validation
  • Computer software assurance
  • Data integrity & ALCOA++
  • AI governance & the EU AI Act
  • Audit & inspection readiness
In depth

8 articles

Specific problems, specific answers, each written against a named source and dated.

  1. 01How to Validate a Non-Deterministic LLM Without Pretending It Is DeterministicBounded nondeterminism, guardrail qualification, abstention thresholds and revalidation triggers, a complete test strategy for generative systems inside regulated pharmaceutical processes.17 min
  2. 02Your Validated Model Has a Retirement DateCloud platforms silently upgrade model deployments unless disabled, turning one deployment property into a genuine change-control obligation for validated systems.11 min
  3. 03Human Oversight Is a Control You Qualify, Not a Sentence in Your Risk AssessmentReduced model testing is bought with monitored operator performance; most oversight designs never budget for that second expensive operating obligation.11 min
  4. 04Computer Software Assurance Is Device Guidance — Cite It for a Drug System and FailFDA reissued Computer Software Assurance in February 2026 for medical devices only; here is what drug sponsors must cite instead.11 min
  5. 05EU GMP Annex 22, Clause by ClauseEvery numbered requirement in the draft artificial intelligence annex, translated into the exact evidence a GMP inspector will actually demand.16 min
  6. 06Nineteen Pages, Seventeen Chapters: The Annex 11 Revision Clauses That Cost MoneyA line-by-line reading of the revised computerised systems annex, flagging every new obligation that carries a real budget consequence today.13 min
  7. 07Nine Contract Clauses Your AI Vendor Will Refuse to SignWhat a GxP quality agreement must contain for an AI or SaaS supplier, and which model providers refuse outright today.10 min
  8. 08Drift, Abstention and Audit Trails: The Operating Plan a Deployed GxP Model NeedsSix monitoring signals, the metrics behind each, and the change-control decisions determining when a deployed regulated model must be retested.15 min