Sunday, October 11, 2026

AI in Parenteral Quality Control: Representative Training Data May Matter More Than Model Complexity


Introduction⇒ An October 2026 pharmaceutical-quality study shows that reliable AI classification of subvisible particles in parenteral products depends strongly on representative training libraries, challenging particle morphologies and explainable model behaviour.

Artificial intelligence is moving into an area where pharmaceutical quality decisions depend heavily on images: identification and classification of subvisible particles in parenteral products.

A study published in the International Journal of Pharmaceutics in October 2026 evaluated convolutional neural network (CNN) models for classification of pharmaceutically relevant particles using microscopy images.

The study provides an important lesson for regulated AI that extends far beyond particle analysis:

A sophisticated model cannot compensate for an incomplete or unrepresentative training dataset.

Why Subvisible Particle Classification Is Difficult

Particle characterization in parenteral products can involve visually very different materials.

The researchers developed a pharmaceutical particle image library containing representative examples including:

  • protein aggregates;
  • silicone oil droplets;
  • rubber particles;
  • glass lamellae.

Glass lamellae were particularly important because different morphologies were deliberately represented in the training library.

Some particles are relatively distinctive.

Others are transparent, low contrast or visually similar to another particle type.

That makes automated classification considerably more difficult than recognizing highly differentiated objects in conventional computer-vision applications.

The Training Library Determined Model Robustness

The researchers compared CNN models trained with comprehensive particle libraries with models trained using more limited categories or incomplete morphological representation.

The result was clear.

Models trained on comprehensive and representative libraries showed high and stable classification performance across complex mixtures.

When important particle morphologies were missing from the training data, robustness decreased and misclassification increased.

The effect was particularly visible for transparent and low-contrast particles.

This is an important pharmaceutical AI principle:

Model performance is conditional on what the model has been allowed to learn.

A validation dataset may demonstrate excellent accuracy while still failing to reveal an important weakness if both training and validation datasets contain the same limited representation of the real process.

The GMP Question Is Therefore Bigger Than Accuracy

In a regulated application it is tempting to ask:

“What is the model accuracy?”

That is necessary, but insufficient.

For a pharmaceutical-quality application, additional questions should include:

  • Which particle classes were represented during training?
  • Were different morphologies within each class represented?
  • Were difficult or ambiguous examples deliberately included?
  • Are the data representative of routine manufacturing conditions?
  • Are rare but quality-relevant particle types represented?
  • Was performance challenged using realistic multi-particle mixtures?
  • How does the model behave when it encounters something outside its training distribution?

This moves validation from a simple model-performance exercise toward a scientifically justified assessment of the entire data-model relationship.

Representative Data Become Part of the Control Strategy

For conventional computerized systems, requirements normally define what the software needs to do.

Machine-learning systems introduce another critical element:

the data used to establish the required behaviour.

For image-based pharmaceutical AI, the assurance chain could therefore look like:

Intended Use

↓

Particle Taxonomy

↓

Representative Image Library

↓

Data Curation and Provenance

↓

Model Training

↓

Independent Performance Testing

↓

Routine Performance Monitoring

A weakness at the image-library stage can propagate through every subsequent stage.

A Random Train-Test Split May Not Be Enough

This study also illustrates a broader AI-validation issue.

Randomly dividing a dataset into training and testing subsets can produce reassuring performance statistics.

But if both datasets originate from the same narrow image population, they may share the same blind spots.

For pharmaceutical applications, validation may therefore need deliberate challenge sets.

These could include:

  • uncommon morphologies;
  • low-contrast images;
  • borderline classifications;
  • complex particle mixtures;
  • variation in imaging conditions;
  • examples obtained independently from the original training population.

The objective should not simply be to prove that the model performs well on familiar data.

The more important question is:

Where does the model stop being reliable?

Explainability Was Also Investigated

The work did not rely only on classification accuracy.

The researchers also investigated feature importance and model behaviour using approaches including principal component analysis, decision trees and Gradient-weighted Class Activation Mapping (Grad-CAM).

Grad-CAM can show which regions of an image contribute most strongly to a CNN classification.

For pharmaceutical applications, this type of analysis can help determine whether a model is using scientifically plausible visual characteristics rather than irrelevant image artefacts.

Explainability should not, however, be confused with validation.

An attractive heat map does not prove that a model is fit for GMP use.

Its value is different:

it can provide additional scientific evidence that model behaviour is understandable and consistent with the intended analytical problem.

A Useful Lesson for AI Validation Beyond Microscopy

The same principle applies to many other pharmaceutical AI applications.

Consider models used for:

  • visual inspection;
  • environmental-monitoring trend analysis;
  • deviation classification;
  • predictive maintenance;
  • spectroscopic analysis;
  • process prediction.

In every case, model performance depends on whether the development data adequately represent the situations the model will encounter during actual use.

A model trained predominantly on normal operation may perform poorly when faced with the rare abnormal conditions that are most important to Quality.

Edge Cases May Be More Important Than Average Performance

For pharmaceutical Quality Assurance, average accuracy is often not the most relevant performance measure.

A model could classify 99% of routine images correctly while systematically misclassifying a rare but important defect.

From a patient-risk perspective, that could be less acceptable than a model with slightly lower overall accuracy but more reliable identification of critical abnormalities.

AI performance criteria should therefore be connected to:

quality risk and intended use

rather than selected only because they generate impressive statistical results.

Training Data Should Be Treated as a Controlled Asset

This also has implications for data governance.

For a GxP-relevant ML application, an image library should not simply be regarded as a collection of files used by the data-science team.

Depending on the application and risk, controls may need to address:

  • data provenance;
  • classification and annotation;
  • expert review;
  • version control;
  • addition and removal of images;
  • traceability to training runs;
  • representativeness assessments;
  • change control.

This is especially important when the model is retrained.

If the training dataset changes, the model changes - even when the software code remains identical.

A Better Definition of AI Validation

The study supports a broader interpretation of pharmaceutical AI validation.

Instead of:

Model + Accuracy Test = Validated AI

a more appropriate structure is:

Intended Use + Representative Data + Appropriate Model + Independent Challenge Testing + Explainability + Lifecycle Control

This closely aligns AI assurance with established pharmaceutical principles of scientific understanding and risk-based control.

Why This Matters for Pharmaceutical Companies

AI-based image analysis has significant potential in pharmaceutical Quality Control.

It can process much larger image populations than manual classification and may improve consistency and speed.

But the major lesson from this study is not that CNN technology is ready to replace pharmaceutical scientists.

It is that:

the quality of an AI decision cannot be separated from the quality and representativeness of the data used to develop the model.

For regulated pharmaceutical AI, the training dataset may therefore become as important to validation as the algorithm itself.

Regulatory Status Note

This is a peer-reviewed scientific publication and does not constitute FDA, EMA, pharmacopoeial or other regulatory guidance.

The study demonstrates technical and scientific approaches to machine-learning-based particle classification. It does not establish regulatory acceptance of CNN classification as a replacement for any required compendial or validated analytical procedure.

The GMP observations above represent an interpretation of the study’s findings in the context of pharmaceutical AI lifecycle control.

Sources

Mohan S. et al. - Developing machine learning models with pharmaceutically relevant microscopy images to improve classification of multi particulate systems for parenteral delivery. International Journal of Pharmaceutics. Volume 703, 5 October 2026, Article 127313.

https://pubmed.ncbi. … lm.nih.gov/42603574/

DOI:

https://www.scienced … 326007611?via%3Dihub

Tuesday, October 6, 2026

FDA Makes AI a Cross-Lifecycle Regulatory Science Priority – Including Commercial Drug Manufacturing


Introduction⇒ FDA's current regulatory-science framework identifies AI as a cross-lifecycle priority, including commercial drug manufacturing, quality decision-making, regulatory review, postmarket surveillance and inspector capability-building.

Artificial intelligence is now positioned by FDA as a regulatory science topic spanning essentially the entire lifecycle of regulated medical products.

In its current Focus Areas of Regulatory Science framework, FDA identifies artificial intelligence as relevant to:

  • product development;
  • commercial manufacturing;
  • regulatory assessment;
  • postmarket surveillance;
  • inspectional activities.

For pharmaceutical companies, one point is particularly important.

FDA explicitly states that it is:

exploring how AI is used during commercial drug manufacturing to improve quality decision-making.

This places AI directly within the pharmaceutical-quality and manufacturing regulatory-science agenda rather than treating it solely as a clinical, digital-health or administrative technology.

AI Is Being Considered Across the Entire Product Lifecycle

FDA’s regulatory science framework shows AI as applicable across:

  • product characterisation, manufacturing and quality;
  • nonclinical premarket evaluation;
  • clinical premarket evaluation;
  • postmarket activities.

This broad scope matters.

Pharmaceutical AI governance is sometimes organised as if different applications belong to completely separate domains:

R&D AI

Clinical AI

Manufacturing AI

Quality AI

Regulatory AI

FDA’s regulatory-science perspective increasingly suggests that these should instead be seen as different Contexts of Use within one broader AI lifecycle.

The technology may differ, but recurring regulatory questions remain similar:

  • Are the data appropriate?
  • Is the model sufficiently reliable?
  • Is performance robust to changing conditions?
  • Can the output be understood and verified?
  • How are changes controlled?
  • Who remains accountable?

Commercial Drug Manufacturing Is Explicitly Included

The direct reference to commercial drug manufacturing is particularly relevant for GMP professionals.

Potential AI applications in manufacturing can include:

  • process monitoring;
  • predictive process models;
  • advanced process control;
  • deviation and trend analysis;
  • predictive maintenance;
  • visual inspection;
  • Quality System analytics;
  • knowledge management.

FDA does not state that all of these uses are automatically acceptable.

The important signal is that the Agency is actively studying how AI can support manufacturing quality decisions.

This means that AI in manufacturing is increasingly becoming a regulatory-science problem rather than merely an industry innovation project.

Robustness to Changing Conditions Is Becoming a Regulatory Question

Another particularly important FDA research activity concerns model robustness.

FDA describes work aimed at understanding how machine-learning models respond to:

  • changes in real-world data;
  • changing contextual factors;
  • distributional shifts;
  • different intended-use conditions.

This issue is fundamental for pharmaceutical AI.

A model may perform well during development and validation but later encounter:

  • different raw-material characteristics;
  • new equipment;
  • process changes;
  • new sites;
  • different populations;
  • changing documentation patterns;
  • different operating conditions.

The key regulatory question therefore becomes:

Does the model remain sufficiently reliable when its operating environment changes?

This is closely related to the concept of maintaining AI in a continued state of control.

Validation Cannot Stop at Initial Accuracy

For conventional software, validation commonly demonstrates that predefined functions operate as expected.

AI requires an additional question:

Will the model continue to perform adequately when the data distribution or context changes?

This can require controls such as:

  • ongoing performance monitoring;
  • drift detection;
  • periodic reassessment;
  • defined performance limits;
  • change-control triggers;
  • revalidation criteria.

A possible lifecycle therefore becomes:

Initial Validation

↓

Controlled Deployment

↓

Operational Performance Monitoring

↓

Detection of Context or Data Change

↓

Impact Assessment

↓

Revalidation or Model Update Where Necessary

FDA Is Also Studying Synthetic Data

FDA’s current AI research activities include evaluating synthetic datasets used for model training and testing.

This is another important area for pharmaceutical companies.

Synthetic data may potentially support:

  • model development where real data are limited;
  • privacy protection;
  • simulation of rare events;
  • test-set expansion;
  • model robustness assessment.

But synthetic data create their own credibility questions.

For example:

  • How representative are they?
  • What assumptions were used to generate them?
  • Could important edge cases be missing?
  • Could bias in the source data be amplified?
  • Can the generation process be reconstructed?

Synthetic data therefore do not eliminate the need for data governance.

They create an additional data-generation process that itself may need to be understood and controlled.

AI Is Also Entering Regulatory Review and Pharmacovigilance

FDA describes several internal or research applications involving AI.

These include:

  • natural-language processing of regulatory submissions;
  • classification of submission complexity;
  • analysis of clinical-trial data;
  • processing and evaluation of safety reports;
  • MedDRA coding support;
  • pharmacometrics;
  • precision-medicine applications.

This is strategically important for pharmaceutical companies.

AI is increasingly appearing on both sides of the regulatory interface.

Companies may use AI to:

generate → analyse → organise → submit regulatory information

while regulators may use AI to:

retrieve → classify → analyse → review regulatory information.

This increases the value of structured, traceable and machine-readable data.

FDA Is Building AI Knowledge Among Inspectors

One of the most interesting points from a GMP perspective is that FDA describes workshops designed to introduce AI and machine learning to Agency personnel.

FDA specifically notes that this helps keep its inspectional cadre informed about how these technologies may affect investigations.

This is a meaningful regulatory signal.

AI governance is gradually becoming relevant not only to:

  • regulatory policy;
  • scientific review;
  • guidance development;

but also to:

inspection capability.

For pharmaceutical companies, this means AI could increasingly become part of ordinary GMP inspection discussions whenever it materially affects a regulated process.

What Could an Inspector Eventually Ask?

A future inspection involving an AI-enabled quality or manufacturing process could reasonably explore questions such as:

  • Where is AI used?
  • What is the intended use?
  • What GMP decision does it influence?
  • Which data are used?
  • How was performance evaluated?
  • What are the known failure modes?
  • How are model and configuration changes controlled?
  • How is ongoing performance monitored?
  • What happens if the AI becomes unreliable?
  • Who is responsible for the final quality decision?

These are not presented by FDA as a new inspection checklist.

They are logical consequences of treating AI as part of the regulated pharmaceutical process.

A Broader AI Assurance Model Is Emerging

FDA’s regulatory-science priorities reinforce a pattern increasingly visible across pharmaceutical AI regulation.

The assurance model is moving beyond:

Validate the model.

towards:

Intended Use → Data → Performance → Robustness → Human Oversight → Change Control → Monitoring → Accountability

This is significantly closer to lifecycle Quality Risk Management than to conventional one-time software testing.

Why This Is Important

The significance of FDA’s current regulatory-science position is that AI is no longer treated as a narrow emerging technology.

It is explicitly connected with:

  • commercial drug manufacturing;
  • quality decision-making;
  • regulatory assessment;
  • postmarket surveillance;
  • inspection capability.

For pharmaceutical companies, this suggests that AI governance should increasingly become part of the normal Pharmaceutical Quality System and regulatory-science strategy.

The relevant question is becoming less:

“Do we have an AI policy?”

and more:

“Can we demonstrate that every important AI use remains appropriate, reliable and controlled for its specific regulated purpose?”

Regulatory Status Note

FDA’s Focus Areas of Regulatory Science describe research priorities and ongoing regulatory-science activities.

They are not guidance and do not establish new legally binding CGMP requirements.

FDA also explicitly notes that inclusion of research in the Focus Areas of Regulatory Science does not necessarily imply a determination regarding its future regulatory use.

Nevertheless, the framework provides an important indication of the scientific questions FDA considers relevant to future regulation.

Sources

FDA – Focus Area: Artificial Intelligence:

https://www.fda.gov/ … ificial-intelligence

FDA – Focus Areas of Regulatory Science Report:

https://www.fda.gov/ … atory-science-report

FDA – Lifecycle of FDA-Regulated Products:

https://www.fda.gov/ … a-regulated-products

Monday, October 5, 2026

European Biotech Act: AI Could Move from Regulatory Guidance to Dedicated Pharma Infrastructure


Introduction⇒ The proposed European Biotech Act could make AI a formal part of pharmaceutical regulatory infrastructure through EMA lifecycle guidance, trusted AI testing environments and data-quality accelerators supporting model training, validation and testing.

Artificial intelligence may soon become more deeply embedded in the European pharmaceutical regulatory framework.

The proposed European Biotech Act contains a dedicated chapter on artificial intelligence and data as biotechnology enablers.

Its significance goes beyond another set of general responsible-AI principles.

The proposal foresees three concrete elements with direct relevance to pharmaceutical companies:

    []EMA guidance on AI across the medicinal-product lifecycle;
    []trusted testing environments for AI-enabled biotechnology;

  • data-quality accelerators supporting AI training, testing and validation.

The proposal is still moving through the EU legislative process and is not yet final law.

However, discussions continued within the Council Working Party on Pharmaceuticals and Medical Devices in September 2026, while EMA reported on 1 October that preparations for implementation of the Biotech Act are already influencing its future regulatory infrastructure.

For pharmaceutical companies, this is an important signal:

AI governance in Europe may evolve from individual guidance documents toward a coordinated regulatory and technical infrastructure for developing, validating and using AI across the medicines lifecycle.

EMA Could Receive a Broader AI Guidance Role

The proposed legislation would require EMA to develop and publish guidance, in cooperation with the European Commission and national competent authorities, on the deployment and use of advanced technologies including artificial intelligence.

The intended scope is broad.

It covers AI across areas such as:

    []medicinal-product development;
    []manufacturing;
    []clinical trials;
    []regulatory evaluation and authorisation;

  • post-authorisation activities.

This is important because current pharmaceutical AI guidance remains distributed across multiple documents and regulatory initiatives.

Examples include:

    []the EMA reflection paper on AI in the medicinal-product lifecycle;
    []FDA/EMA Guiding Principles of Good AI Practice;
    []draft EU GMP Annex 22;
    []planned AI guidance for pharmacovigilance;

  • digital technology qualification guidance.

The Biotech Act could provide a legal framework for bringing these activities into a more coherent lifecycle approach.

AI Guidance Would Not Be Limited to One Technology

The proposal refers not only to conventional machine-learning systems but also to:

AI systems and general-purpose AI models.

This distinction is increasingly important.

Pharmaceutical companies are moving beyond narrowly trained predictive models toward:

    []foundation models;
    []large language models;
    []Generative AI;
    []multimodal systems;
    []AI agents;
    []hybrid AI architectures.

A future EMA guidance framework may therefore need to address very different technological characteristics and risk profiles.

The regulatory question becomes less:

“Is this an AI system?”

and more:

“What does this AI do, what decision does it influence, and what level of assurance is required for that Context of Use?”

Trusted AI Testing Environments Could Be More Important Than Another Guidance Document

One of the most interesting elements of the proposed Biotech Act is the concept of trusted testing environments for advanced biotechnology innovations.

These environments would support technologies that are enabled or significantly enhanced by AI or advanced computational methods.

Their purpose would be to provide controlled environments where organisations can develop, test and validate innovations while operating under applicable regulatory requirements.

Potential applications identified in the proposal include advanced biotechnology areas such as:

    []immunology;
    []ATMP and gene-therapy development;
    []advanced computational methods;
    []New Approach Methodologies;

  • AI-supported biotechnology and biomanufacturing.

This creates a potentially important model:

Develop → Experiment → Validate → Generate Evidence → Inform Standards and Regulation

under controlled conditions.

For pharmaceutical AI, this could be particularly valuable because many current barriers are not purely technical.

Companies also need to understand what evidence regulators will consider sufficiently credible.

A Possible Bridge Between Innovation and Regulatory Acceptance

AI development often moves faster than formal pharmaceutical guidance.

This creates a familiar problem.

A company may develop a technically successful AI system but still face uncertainty regarding:

    []regulatory acceptability;
    []validation expectations;
    []documentation requirements;
    []acceptable performance criteria;
    []change management;
    []human oversight;

  • data requirements.

Trusted testing environments could create a more structured way of addressing these questions before large-scale regulatory deployment.

Instead of waiting until a marketing application, manufacturing change or regulatory submission is ready, developers could potentially generate regulatory learning earlier.

Conceptually, this creates a bridge between:

innovation experimentation

and

regulated pharmaceutical implementation.

Data Quality Accelerators Are the Third Pillar

The proposal also recognises a problem that is becoming increasingly obvious:

AI performance depends fundamentally on the quality of the data used to train, test and operate the system.

The proposed biotechnology data-quality accelerators would support the development of datasets that are:

    []high quality;
    []appropriately annotated;
    []standardised;
    []curated;
    []provenance verified;
    []suitable for AI training, validation and testing.

This may become particularly important in pharmaceutical environments where data are distributed across:

    []laboratory systems;
    []clinical systems;
    []manufacturing systems;
    []Quality Management Systems;
    []regulatory repositories;
    []real-world data sources.

The challenge is often not lack of data.

The challenge is whether those data are sufficiently structured, controlled and contextualised to support a regulated AI application.

Data Provenance Could Become Part of AI Validation

Traditional computerized-system validation often focuses strongly on application functionality.

AI adds another layer.

The credibility of the output can depend on the entire data chain:

Source Data

↓

Curation and Transformation

↓

Training / Validation Dataset

↓

AI Model

↓

AI Output

↓

Regulated Decision

This means that validation of an AI-enabled pharmaceutical process may increasingly require evidence not only about the model, but also about:

    []where the data originated;
    []how the data were transformed;
    []which version was used;
    []whether important populations or conditions were represented;

  • whether data quality remains suitable during operation.

The proposed emphasis on provenance-verified datasets is therefore particularly relevant for GxP environments.

The Biotech Act Could Help Connect the AI Act with Pharmaceutical Regulation

Another important aspect is the relationship with the EU AI Act.

The Biotech Act proposal foresees interaction between pharmaceutical AI testing environments and AI testing or regulatory mechanisms established under Regulation (EU) 2024/1689.

This is strategically important.

Pharmaceutical companies may need to manage two regulatory dimensions simultaneously:

horizontal AI regulation

and

sector-specific pharmaceutical regulation.

These frameworks ask different questions.

The AI Act focuses on the governance and risks of AI systems.

Pharmaceutical regulation focuses on:

    []patient safety;
    []product quality;
    []clinical evidence;
    []manufacturing control;

  • regulatory decision-making.

The challenge will be to avoid creating two disconnected assurance systems for the same AI application.

Relevance to GMP Manufacturing

The proposal explicitly includes manufacturing within the future lifecycle AI-guidance framework.

For GMP organisations, this is particularly important.

AI applications may increasingly support:

    []process monitoring;
    []predictive process modelling;
    []deviation analysis;
    []maintenance;
    []Quality System analytics;
    []advanced process control;

  • manufacturing knowledge management.

Draft Annex 22 is currently the most visible European GMP-specific AI initiative.

The Biotech Act suggests that Annex 22 may eventually sit inside a broader European AI regulatory architecture rather than functioning as an isolated GMP document.

The Regulatory Model Is Becoming Multi-Layered

A future European pharmaceutical AI framework could increasingly consist of several layers:

EU AI Act

↓

European Biotech Act

↓

EMA Lifecycle AI Guidance

↓

Domain-Specific Guidance such as GMP Annex 22

↓

Testing Environments and Regulatory Sandboxes

↓

Company AI Governance and Validation

For global pharmaceutical companies, understanding how these layers interact may become as important as understanding each document individually.

Current Regulatory Status

The European Biotech Act remains a legislative proposal.

It is currently being considered by the European Parliament and Council and its final wording may change.

Council working-party discussions on the proposal continued during September 2026.

EMA has also confirmed that it is preparing for potential implementation of the legislation while progressing its broader data and artificial-intelligence activities.

Therefore, pharmaceutical companies should not treat the proposed AI provisions as current binding requirements.

They should instead be viewed as a strong indication of the future direction of European pharmaceutical AI regulation.

Why This Matters

Most pharmaceutical AI regulation to date has focused on principles and guidance.

The Biotech Act introduces something different:

regulatory infrastructure.

The emerging model is not only:

write guidance → ask industry to comply.

It increasingly looks like:

Guidance → Trusted Testing → High-Quality Data → Regulatory Learning → Validation → Deployment.

If implemented, this could significantly influence how pharmaceutical companies develop and validate AI systems in Europe.

It also reinforces a broader message:

Trustworthy pharmaceutical AI will depend not only on the algorithm, but on the regulatory, data and testing infrastructure surrounding it.

Sources

European Commission – European Biotech Act:

https://health.ec.eu … opean-biotech-act_en

EUR-Lex – Proposal for the European Biotech Act:

https://eur-lex.euro … ri=CELEX:52025PC1022

Council of the European Union – Working Party on Pharmaceuticals and Medical Devices, 16 September 2026:

https://www.consiliu … evices-%28369737%29/

EMA – Management Board highlights, September 2026 meeting:

https://www.ema.euro … ptember-2026-meeting