Eesti Farmaatsia GruppESTONIAN PHARMACEUTICAL GROUP
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Twelve out of fifteen is not a pass

We hid fifteen errors in a fictional quality system and asked a local AI model to find them. Here is what it found, what it missed, and what it invented.

Test 1 · synthetic data25 documents of a fictional company, "Demo Pharma". No real company's documents were used. Model: Qwen 3.6 27B (4-bit), run with Ollama on a laptop with 48 GB memory, offline. All 25 documents in one prompt; 3.4 minutes.
1

The result

12 / 15errors found
3missed
2false findings
≥ 13our target

Below our own pass mark. Easy errors 6 of 7, medium 4 of 5, hard 2 of 3. A bonus gap (no complaints SOP at all, EU GMP Chapter 8) was not reported.

2

The answer key

#LevelPlanted errorResult
1EasySOP refers to a complaints SOP that does not existFound
2EasySOP refers to form FRM-QA-006; the forms stop at 005Found
3EasyReference to version 2 of an SOP; version 3 is in forceFound
4EasyWrong title given for a QC SOPFound
5EasyReference to Appendix 2; the SOP has only Appendix 1Found
6EasyQuality manual lists an SOP under the wrong titleMissed
7EasyTwo SOPs point to each other for numbering rules; neither has themFound
8MediumDeviation closure: 30 calendar days vs 20 working daysFound
9MediumBatch certified by "QA manager" instead of the QPFound
10MediumAssay limits 90–110 % vs specification 95–105 %Found
11MediumSOP uses an autoclave retired from serviceFound
12MediumCAPA effectiveness sent to self-inspection, which does not cover itMissed
13HardSOP based on the 2008 Annex 1Found
14HardGrade A limit "1 CFU" vs "no growth" (Annex 1 2022, Table 6)Found
15HardAseptic process simulation once a year instead of twice (Annex 1 §9.38)Missed, and called it correct
3

What it invented

  • It called the record retention rule wrong, with a reason that does not match EU GMP: the periods in the SOP are those of clause 4.11 for batch documentation. The SOP applies them to all GMP documents, which the model did not point out.
  • It said three consecutive aseptic process simulations are "outdated". Annex 1 (2022) still asks for at least three for initial validation (§9.38).

Both were stated with confidence. A tired reviewer could have accepted them.

4

What we learned

  • It is good at contradictions between documents: numbers, deadlines, roles and equipment. Fast, too.
  • It is dangerous when it answers regulation from memory. The two false findings and the worst miss (#15) all came from regulatory "knowledge" the model did not have right. This is the risk the draft Annex 22 warns about. Read more →
  • Mechanical checks belong to rules, not AI. A simple script that compares document codes, titles and versions would have caught #6 every time.
  • The raw output is not a report. It repeated findings and "thought aloud" about non-errors. A person had to sort it.
5

What we change for test 2

  1. A rule-based pre-check for codes, titles, versions and appendices.
  2. The relevant clauses of Annex 1 and EU GMP Chapter 4 given to the model as text, so it quotes instead of remembering.
  3. A stricter output format: one line per real finding, each with its source.
  4. The same test on a second model, one change at a time.

We will publish test 2 the same way, including what it misses. Read test 2 →