For · Pharma vertical
FDA · PART 11 · ALCOA+

FDA-era compliance

Re-walk every clinical-trial and pharmacovigilance decision in front of an FDA reviewer.21 CFR Part 11 evidence. ALCOA+ retention. One hash-chained replay trail.

The FDA / GxP auditor’s questions almost never match the dashboard your model team built — so Plumbline writes every clinical-trial decisioning, pharmacovigilance signal review, and SaMD post-market record the model rendered onto an HMAC-SHA-256 chain that’s already the answer. Per-workspace 21 CFR Part 11 evidence package, ALCOA+ retention addendum, GMLP-attested validator, and a tamper-evident audit PDF your FDA reviewer can re-derive from the public /verify page.

§01 · Auditor posture

What 21 CFR Part 11, ALCOA+, and GMLP ask for — and where Plumbline lives in the answer.

The FDA / GxP auditor’s questions are almost always the same. Every row below is a real regulator expectation and the Plumbline artifact the ledger already produces on the way through — no after-the-fact paste-up.

  1. 21 CFR Part 11 · §11.10(a)–(k)

    Electronic records and signatures live in a validated closed system; the audit trail captures every create / modify / delete against the same record.

    Plumbline artifact · PART 11 · CLOSED-SYSTEM

    Per-workspace HMAC-SHA-256 chain binds input digest, scorer output, model id + version, and timestamps on every record. Tamper-evident audit PDF is co-signed onto the same chain.

  2. 21 CFR Part 11 · §11.50 / 70

    Electronic signatures are permanently linked to the record they sign, and the signatory identity is independently re-derivable from the row.

    Plumbline artifact · SIGNATURE · LINKED

    Per-workspace signing key anchored to the buyer’s KMS. Signer identity + key fingerprint ride on the same canonical-JSON row as the decision; the signature is provable from the record alone.

  3. ALCOA+ · data integrity

    Records are Attributable, Legible, Contemporaneous, Original, Accurate, plus Complete, Consistent, Enduring, and Available throughout their retention window.

    Plumbline artifact · ALCOA+ · CHAINED

    Chain at write time (contemporaneous). Canonical-JSON view (legible / accurate). Key-anchored HMAC (attributable / enduring). Tombstoned deletion record (consistent / available). One bundle, not four.

  4. ICH E6(R3) · GMLP

    Computerised systems supporting trial decision-making are validated, with an audit trail of changes and role-based access controls governing who can change a model artifact.

    Plumbline artifact · GMLP · VALIDATED

    Model card + independent validator + rationale evaluator all ride one chain. Access-scope tuples set at write time; change-control events are signed records, not wiki edits.

  5. FDA AI/ML SaMD · 21 CFR 820.198 / PCCP

    AI/ML medical-device software has a written change-control plan and post-market surveillance tied to drift monitoring across the model lifecycle.

    Plumbline artifact · SaMD · PCCP-LINKED

    Drift ledger + incident records ride the same chain. The cause → detect → resolve sequence is provable end to end against a signed audit-export — reviewers walk back the SaMD lifecycle, not a slide deck.

  6. FDA GMLP · CDS expectations

    AI assisting risk evaluation of adverse-event signals records both the rationale behind the recommendation and the source it relied on.

    Plumbline artifact · CDS · ATTRIBUTED

    Independent rationale evaluator + source-attribution column on the same row as the signal score. The pharmacovigilance reviewer reads the basis, not just the recommendation.

  7. EU AI Act · Annex IV technical documentation

    Technical documentation is reproducible from on-chain records alone — provenance, version, and intended purpose can be re-derived without a vendor round-trip.

    Plumbline artifact · ANNEX IV · RE-DERIVABLE

    Tamper-evident audit PDF is re-derivable from /verify. Sub-processor matrix + signature chain ride the same record. Verification is pure computation, no oracle or platform call back to engineering.

§02 · The replay walk-back

An AI-assisted AE triage, opened two quarters later.What the record carries — and what the FDA reviewer walks back.

  1. 1.What decision did the model surface?The PV triage path (expedite 15-day reporting) and the underlying MedDRA-mapped signal sit on the same row as the model version and the rationale evaluator’s score.
  2. 2.Was the basis for the expedited classification on the record? ALCOA+ requires contemporaneous capture with rationale and source. The evaluator set signs both, pins them to the row, and includes the MedDRA SMQ citation on the chain itself.
  3. 3.Did the calibration drift before or after? Score distribution walks back through the same ledger 30, 60, or 90 days at a time — no separate PCCP monitoring lake to reconcile against the production record.
  4. 4.Who has read this record since? Scope is set at write time. PV-OPS, the medical reviewer, and the audit role are stamped on the row against the FDA-scoped access list — no after-the-fact redaction.
  5. 5.Has the record been edited since capture? The HMAC-SHA-256 chain breaks visibly at the next record; tampering is detected at fetch, not at audit time.
  6. 6.What does the FDA reviewer hand back to counsel? A tamper-evident audit PDF (model card + record hash + signature chain), re-derivable from the public /verify page — counsel reads the same bundle, once.

§03 · Cross-links

§04 · Talk to us
Two paths in

Reserve a pharma pilot, or send the procurement team our Part 11 evidence packet.

Buying for a clinical-AI or pharmacovigilance program and want the walk-through? Drop your email and the Part 11 scoping checklist lands in your inbox before any contract is drawn up. Buying at the enterprise level with a validation plan already on the desk? Send the procurement team the intake form and we'll reply with the evidence packet and a short validation offer.

PLU-007 · Pharma vertical
Vertical pilot
Reserve a pharma / life-sciences Evidence Pilot intake
Each pharma pilot ships with a 21 CFR Part 11 evidence package, an ALCOA+ retention window agreed with you up front, a GMLP-validated model attestation, and a signature chain your FDA reviewer can walk back from the public surface. Drop your email and we'll send the scoping checklist before a contract is drawn up.

We'll never share your email. No marketing blast — only the next-step note when a slot opens. If you already have a Part 11 validation plan in flight, mention it on the call.

Enterprise intake
Part 11 · ALCOA+
Compliance needs

Pick every shape your procurement team will ask about.

§06 · Pricing

Ready to see this on your models?

Start with the $1,000 Evidence Pilot: one workflow, one model, and 30 days ending in a replayable evidence package. Plumbline captures forward from the moment you connect, and the full pilot fee is credited toward Regulated Team.