BY MARTIN LUSH | GxP AI IMPLEMENTATION SPECIALIST
What if the next regulatory finding isn’t because you adopted AI, but because you didn’t?
I know this is provocative today but will it sound obvious in five years? In my experience some companies often approach new tech with the philosophy:
"Lets wait until regulators tell us it's OK"
This is fine when tech moves slowly but is it risky in the age of AI moving at warp speed? In helping clients define their AI strategy, my challenge to Pharma Leadership is not "Can we use AI?" but
"Can we still justify not using AI where it reduces risk?"

My discussions often begin with the assumption that regulators are reluctant about AI. That is only partly true. Regulators I’ve spoken with (who attend my AI courses) are rightly cautious about poorly governed AI systems making GxP decisions without appropriate oversight. I 100% agree.
However, GMP regulations also require manufacturers to use modern scientific knowledge and current technology to continually improve their systems. Doesn’t AI fall into this category?
So if AI consistently outperforms humans at certain activities at what point does continuing to rely on humans become difficult to defend?
1. Deviation investigations
Instead of investigating one deviation at a time, AI can identify recurring systemic causes across hundreds or thousands of investigations.
Result: Less symptom treatment and more prevention. How can you justify NOT doing this?
2. CAPA effectiveness
AI can detect whether CAPA's are genuinely reducing recurrence or simply creating paperwork that appears compliant.
3. Batch record review
I’ve used AI to identify inconsistencies, missing information and unusual relationships across extensive documentation significantly faster than manual review. Human oversight will always remain essential, but AI can do a lot of the grunt work
4. SOP simplification
AI can rapidly identify duplication, conflicting requirements and unnecessary complexity across hundreds of procedures while preserving regulatory intent.
Simpler systems = fewer human errors. Why would you NOT want to reduce errors?
5. Predictive quality risk management
Rather than waiting for failures, AI can identify combinations of weak signals that frequently precede deviations, complaints or inspection findings.
This moves quality from reactive investigation toward proactive prevention. Not using AI is indefensible.
The pharmaceutical industry has spent years asking:
"What could go wrong if we use AI?"
Although an important question, should we not be asking
"What could go wrong if we don't?"
If two companies manufacture the same medicine, one uses AI to detect emerging contamination risks weeks earlier. The other relies solely on retrospective manual review. Which organisation is applying the best available science? Which is better protecting patients? Which will regulators eventually expect to become the norm?
Not any time soon but regulatory expectations evolve. Paper batch records became electronic. Manual trending became statistical process control. Quality Risk Management became expected rather than optional. Continuous process verification became increasingly accepted.
In my 44 years experience every tech transition follows a similar pattern
Will AI follow the same trajectory?
Look, I know the title of this article is hypothetical but the principle behind it is not. The future may not belong to the organisations with the most AI. It’s more likely to belong to those who can demonstrate they have applied the best available science, managed the associated risks, and improved protection for patients.
Perhaps the most important question is no longer "can we trust AI" but "can we continue justifying decisions that ignore it?"
I just wanted to get everyone thinking from a different ‘frame of reference’ (a uniquely human quality!)
Let me know what you think!