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.

How to Validate a Non-Deterministic LLM Without Pretending It Is Deterministic

Bounded nondeterminism, guardrail qualification, abstention thresholds and revalidation triggers, a complete test strategy for generative systems inside regulated pharmaceutical processes.

GxP, validation & assurance · 17 min read

Your Validated Model Has a Retirement Date

Cloud platforms silently upgrade model deployments unless disabled, turning one deployment property into a genuine change-control obligation for validated systems.

GxP, validation & assurance · 11 min read

Human Oversight Is a Control You Qualify, Not a Sentence in Your Risk Assessment

Reduced model testing is bought with monitored operator performance; most oversight designs never budget for that second expensive operating obligation.

GxP, validation & assurance · 11 min read

Computer Software Assurance Is Device Guidance — Cite It for a Drug System and Fail

FDA reissued Computer Software Assurance in February 2026 for medical devices only; here is what drug sponsors must cite instead.

GxP, validation & assurance · 11 min read

EU GMP Annex 22, Clause by Clause

Every numbered requirement in the draft artificial intelligence annex, translated into the exact evidence a GMP inspector will actually demand.

GxP, validation & assurance · 16 min read

Nineteen Pages, Seventeen Chapters: The Annex 11 Revision Clauses That Cost Money

A line-by-line reading of the revised computerised systems annex, flagging every new obligation that carries a real budget consequence today.

GxP, validation & assurance · 13 min read

Nine Contract Clauses Your AI Vendor Will Refuse to Sign

What a GxP quality agreement must contain for an AI or SaaS supplier, and which model providers refuse outright today.

GxP, validation & assurance · 10 min read

Drift, Abstention and Audit Trails: The Operating Plan a Deployed GxP Model Needs

Six monitoring signals, the metrics behind each, and the change-control decisions determining when a deployed regulated model must be retested.

GxP, validation & assurance · 15 min read