Regulatory Open Forum

 View Only
Expand all | Collapse all

ChatGPT for Regulatory Work

  • 1.  ChatGPT for Regulatory Work

    This message was posted by a user wishing to remain anonymous
    Posted 07-Mar-2023 08:19
    This message was posted by a user wishing to remain anonymous

    Has anyone used ChatGPT for writing summaries of published articles? I am curious if anyone has any experience in terms of its accuracy. 

    I realize this is a sensitive topic, I am just trying to see if there is merit in the output from ChatGPT. 



  • 2.  RE: ChatGPT for Regulatory Work

    Posted 07-Mar-2023 08:30

    Anon, here's a link to a somewhat related thread on ChatGPT from a few weeks ago. Thought it might be useful, though it doesn't exactly answer your question above.



    ------------------------------
    Ryan Connors
    Social Media and Communications Specialist
    RAPS
    ------------------------------



  • 3.  RE: ChatGPT for Regulatory Work

    Posted 07-Mar-2023 09:39

    Its "mostly" accurate.  I have not tried to summarize an article though.

    I might get hate for this but RA and law are two specialties that will probably see a large impact from AI like ChatGPT. They are very structured fields with many rules and laws and standards that are prime for AI to learn on.



    ------------------------------
    Edward Panek
    VP, QA/RA
    Med Device
    USN Veteran
    Research into Neural Nets - https://www.twitch.tv/edosani
    ------------------------------



  • 4.  RE: ChatGPT for Regulatory Work

    Posted 30-Mar-2023 09:38

    Out of curiosity to understand the capabilities of ChatGPT, I asked it a couple of things:

    1. To summarize the in vivo data of a straight forward paper that had clear headings stating "in vivo data". Notably, it gave me the wrong enzyme, it gave me 3 animal models plus conclusions on those animal models while there were only 2 animal models used in the paper. 
    2. I asked to provide me the equivalent of RMAT for other regions, it gave me RAPS, DIA, which is obviously not correct.
    3. I asked about the top 5 papers in a certain field (clearly defined). It responded that it cannot give me rankings as it was built as a literacy tool, but it did gave me some, looking at the titles, relevant papers. ChatGPT provided all with titles and authors. When looking them up in PubMed/search machine, they did not exist. All 5. I then asked it to give the me the DOIs of those papers. They were incorrect and provided me with papers from a totally different field that did not match the original title nor authors given by it originally.

    I realize that the way you define your ask plays a major role, and I have tried to ask the same question in different ways .

    After playing with it for a couple of hours, using scientific and regulatory search terms and refining them along the way, I concluded that I will not be using ChatGPT for any scientific/regulatory work as the tool is not there yet in my experience, not yet ready to be used in our line of work. At least, how I am able to use it ;) For other, not fact-based texts, it is fun to see what it can come up with.



    ------------------------------
    Merel Stok
    Mountain View CA
    United States
    ------------------------------



  • 5.  RE: ChatGPT for Regulatory Work

    Posted 31-Mar-2023 17:07

    This is a very valuable feedback Merel. My experience was somewhat similar as well. When it comes to pulling in reference information, ChatGPT gave me incorrect examples as well as links to the articles that did not exist. It is suffice to say that at least for now, ChatGPT is a useful tool for language development however in terms of actual scientific work its usefulness remains in question. 



    ------------------------------
    Rashmi Dalvi
    Buena Park CA
    United States
    ------------------------------



  • 6.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 08:36

    Chat GPT is all the rage, all over the news these days. And even a new version 4 has been released. Since the news is hyping it, it must be good, right?  


    Chat GPT "learns" from the internet, and we all know "if it is on the internet it must be true"

    So there is no guarantee that anything produced by Chat GPT has any regulatoryvvalue. 



    ------------------------------
    Edwin Bills MEd, BSc, ASQ Fellow, CQE, CQA, CQM/OE, RAC
    Principal Consultant
    Overland Park KS
    United States
    elb@edwinbillsconsultant.com
    ------------------------------



  • 7.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 13:50
      |   view attached

    Agree fully that ChatGPT learns from the Internet -but that's not all it can  learn from.

    Apart from public Internet, Wikipedia, all other corpus of datasets that now make up the trained  OpenAI ChatGPT(x) --AI Machine Learning can be geared towards proprietary data ,e,g your own SOPs within an organization, protocols, quality systems data, reports, etc. 

    OpenAI publishes their API (Application programming Interface) such that one can take their out-of-the box ChatGPT LLM (Large Language Model you are citing) and customize or fine-tune with private training datasets to make it 'smarter'

    That's what we plan to do , i.e. customize ChatGPT-4 against all the 2600 and growing  FDA.Gov PDF Guidance we've collected along with the over 25K items that make up the FDA 21 CFRs HTML  on Subchapter H (medical devices), Subchapter F(Biologics) and Subchapter C &D (Drugs).
    This  take some major doing--I cover how and is part of my upcoming RAPS July Quarterly article in the works.

    That said--though ChatGPT can be made 'smarter' with private datasets--it can never match a Full-text index search hosted in Sharepoint Online created  from ACTUAL  FDA  PDFs document contents or 21 CFRs FDA publishes  on FDA.Gov. 

    The trade-off is that though you're searching Actual FDA published content that is full-text indexed- but not natural language like ChatGPT--some search operators (not rocket science and similar to Google) needs a little brushing up to learn.

    See sample on the mobile screen - https://tinyurl.com/3jbjcd7v    

    Our goal is to  pair the precision search Sharepoint renders with our FDA Guidance and 21 CFRs collections from FDA.Gov directly (all public domain)  while at the same time deploying a custom-trained ChatGPT on the same  platform for  keywords 'fishing' or 'mining' to get  two birds with one stone so to speak, i.e. a kind of dueling-banjo search style where may prompt ChatGPT with Natural Language (ie plain English) then repurposing possible handpicked ChatGPT response as  search keyword against a Sharepoint based search engine.

    There's challenges to doing these of course but the benefit would be awesome since the current US FDA website search sites for PDF Guidance and 21 CFRs are metadata and HTML single word based  & published respectively.

    To clarify further, if your search keywords do not match the tags assigned by FDA on a PDF Guidance hosted in FDA.Gov site-or if you wish to drill down on 21 CFRs where multiple keywords are needed for your search ('quality' 'supplier' 'audit' or 'biologics' referenced with 'stability' or 'assessment' -- you'll turn blue in the face and likely miss what's discoverable within  FDA.Gov  vaults but can't be found.

    Ram B



    ------------------------------
    Ram Balani
    CEO
    FDASmart Inc. /eSTARHelper LLC www.estarhelper.com
    Amawalk , New York
    rbalani@fdasmart.com
    2019130558
    https://tinyurl.com/3jbjcd7v
    on US FDA eSTAR for 510(K)
    ------------------------------

    Attachment(s)

    pdf
    DCATWeek-V-14.pdf   392 KB 1 version


  • 8.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 18:11
    Edited by Michaela O. 01-Apr-2023 18:20

    Don't forget there's a lot more documentation than just 21 CFR and the long and historic list of FDA guidance documents. There's global guidance, GMP, QSIT, EU regulations, MDCG documents, and lots of relevant context built into the ~200k FDA submissions (and around 85k submission-related documents) and all of their surrounding data.



    ------------------------------
    Michaela O.
    ------------------------------



  • 9.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 19:07

    Shortly after Chat GPT was released, someone had already released an App that could determine if a document was written using AI. That would be useful for teachers to analyze their pupils' submissions. 

    But I wonder what the characteristics of an AI document might be that another AI App could definitively say something was written using AI? And would the document be questioned simply because it was written by a bot?



    ------------------------------
    Edwin Bills MEd, BSc, ASQ Fellow, CQE, CQA, CQM/OE, RAC
    Principal Consultant
    Overland Park KS
    United States
    elb@edwinbillsconsultant.com
    ------------------------------



  • 10.  RE: ChatGPT for Regulatory Work

    Posted 02-Apr-2023 07:09

    Fully recognize the limited cope -ie that there are more FDA content hosted beyond US FDA PDF Guidance and 21 CFRs legal statutes for Subchapter H (devices), Subchapter F(Biologics) and Subchapter C& D (Drugs)

    That said--we decided to focus on what matters to most, i.e. leave out adverse events (MAUDE) database, 510K approved listings, etc.

    Our goal is not to replicate the FDA.Gov website-virtually impossible- but to render an enhanced search experience for regulatory INTELLIGENCE not necessarily  compliance. Relying on a subset of most often searched data hosted by  FDA.Gov we deemed better than not finding the search result though it is discoverable were it not for FDA.Gov abysmal stuck in the medieval ages metadata algorithms.

    To use an analogy--Google search results gives you source of toaster ovens from where can purchase--what you purchase depends on your selection and choices. There's likely other sources you will never see since Google algorithm  will rank them on page 19 and who has time to sift thru 20 pages pf Google website data search results. 

    Though not perfect-we intend to update US FDA guidance and 21 CFRs whenever FDA updates-easy to do.



    ------------------------------
    Ram Balani
    CEO
    FDASmart Inc. /eSTARHelper LLC www.estarhelper.com
    Amawalk , New York
    rbalani@fdasmart.com
    2019130558
    https://tinyurl.com/3jbjcd7v
    on US FDA eSTAR for 510(K)
    ------------------------------



  • 11.  RE: ChatGPT for Regulatory Work

    Posted 02-Apr-2023 08:38

    Thank you Michaela for bringing that up.  This site is too often only focused on US and EU regulations and guidance.

    My thoughts on all these "helpful" tools follow below.

    All software engineer types will want to immediately customize and use ChatGPT or Huma.AI or any "tool" they can because it is interesting and "cool"- they are in the "cool kids club". 

    Companies will want to cut employee costs to maximize efficiency (god forbid you actually have human eyeballs and common sense to work through issues), cutting out actual people in the labor force.

    Great, but not many start-ups have bandwidth or $ or time to do this.  And we can see how "helpful" (not) e-Star will be, based on blogs from the likes of Hyman Phelps.  

    Some tools like the FDA Customer Collaboration Portal are quite useful - no more copying onto USB and having to drive to FedEx or USPS.  Actually that is a big win.  A very nice tool I loved using for my last QQSub this past February when we had a blizzard here and there was no way I was getting out of my long, long country driveway.

    Remember, there is value in crafting a story and appropriate tone for submissions; in healthcare, certainly use smart "write it right" communications across the board, when litigation is so prevalent these days. I am not ready to embrace ChatGPT to create my content; though it would be fun to dabble with it just to learn more. But  if use of AI becomes the new norm in larger CROs or consultancies why pay them 400-500 an hour for expertise? If adopted by industry, then hmmmm....  RA jobs become commodities.

    It won't affect me too much as I am in the last years of my career, but I am curious why younger RAs are not a little anxious they will be replaced by AI. You should be.




    ------------------------------
    Ginger Cantor, MBA, RAC
    Founder/Principal Consultant
    Centaur Consulting LLC
    River Falls, Wisconsin 54022 USA
    715-307-1850
    centaurconsultingllc@gmail.com
    ------------------------------



  • 12.  RE: ChatGPT for Regulatory Work

    Posted 30-Mar-2023 10:32

    I'll second Merel's comments and add that ChatGPT can only be as good as the source information which is publicly available in the electronic information ecosystem.  There's a lot of polluted information in that ecosystem, and it hasn't necessarily been properly vetted for integrity.  I did an informal mock audit of some ChatGPT-generated regulatory documents a few weeks back and I was able to issue regulatory nonconformities.  ChatGPT might be a way to avoid starting with a blank slate. But it ultimately can't compete with experienced, knowledgeable, sensitive, discerning people.



    ------------------------------
    Kevin Randall, ASQ CQA, RAC (Europe, U.S., Canada)
    Principal Consultant
    Ridgway, CO
    United States
    © Copyright 2023 by ComplianceAcuity, Inc. All rights reserved.
    ------------------------------



  • 13.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 18:17
    Edited by Michaela O. 02-Apr-2023 01:48

    Generative AI and its derivative products at the end of the day won't be perfect on its own. Google didn't stop people from doing research, it just made their research happen faster. The part that ChatGPT on its own misses is citation of sources (and of course relevant context outside of its knowledge base). As long as citation of sources is there, and the user of the tool can do due diligence to authenticate the veracity of the results, and tweak where needed, it's very useful and can't really go wrong. At the end of the day it's the responsibility of the user to verify their results and use available tools correctly.

    With that said, the most important aspect of this technology seeing professional use will be education. People will have to learn and figure out how to use these tools correctly, so that the results the person ultimately ends up with saves research and thinking time, however can be unquestionably verified.

    I recommend exploring this tool already present (as of a few days ago) for generative AI in med device regulation:
    https://www.linkedin.com/feed/update/urn:li:activity:7047369862796460032/

    I posted some stuff about it on another thread, but they are going to start hosting webinars and training sessions on correct use of these kinds of tools very soon.

    ------------------------------
    Michaela O.
    ------------------------------



  • 14.  RE: ChatGPT for Regulatory Work

    Posted 31-Mar-2023 04:53

    ChatGPT is new and the possibilities are exciting.  However it really is no different to google and other search engines, in that it relies heavily on the users ability to state the query accurately, and then to verify, filter and contextualise the result.
    My advise is to use with caution, and to provide feed back to ChatGPT on the result - thumbs up or down.  This should assist in improving the results in the longer term.



    ------------------------------
    Mark Banfield
    Consultant
    Johannesburg
    South Africa
    ------------------------------



  • 15.  RE: ChatGPT for Regulatory Work

    This message was posted by a user wishing to remain anonymous
    Posted 03-Apr-2023 08:02
    This message was posted by a user wishing to remain anonymous

    Oh, my. That sounds like my former manager's thinking process. Making random assertions about things that are somehow related, without being precise about the nature of the relationships. Spooky!




  • 16.  RE: ChatGPT for Regulatory Work

    Posted 31-Mar-2023 12:32

    Hi Everyone,
    This is a great topic. I am too interested and researching the same. I think Chat GTP will particularly help the clinical and regulatory coordinator. It can help to:
    1. Summarize the regulatory laws
    2. Rewrite the consent form in the 8th-grade level
    3. Help construct the smart phrases 
    4. Some other functions that will make the clinical coordinator and regulatory specialists' life easy.

    I would also argue that it is different from Google and other search engines because it summarizes the information you need after searching from different internet sources, while other search engines provide vast resources and the user have to search within them to summarize the information.

    I want to write and publish a paper about this topic. I would like to ask if anyone here is interested to collaborate.

    Thanks



    ------------------------------
    Amrita Ghosh
    Cupertino CA
    United States
    ------------------------------



  • 17.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 04:39
      |   view attached

    Agree with most thats been said in this post about ChatGPT-3, i.e. good starter but approach with caution, not adequately 'trained' as of now, etc.

    ChatGPT-3 now ChatGPT-4 also-- relies on an LLM (Large Language Model) machine learning against massive datasets  but  NOT trained with actual US FDA.Gov content, e.g. FDA Guidance documents, 21 CFRs, etc.

    Therefore it cannot be as accurate as we expect common everyday  prompts like - 'am going to Mexico City, plan a safe travel itinerary for me and family of 4'! . Once  adequately   trained  however against ACTUAL  US FDA content --ChatGPT-3 2ill  begin to emerge as a potential game changer.

    It's why we decided for time being  to harvest US FDA Guidance content  and 21 CFRS and host them on Sharepoint Online for full-text every word indexing --all information is public domain in FDA.Gov-we verified with the FDA.

    Once rendered full text--one can elegantly and accurately search against ACTUAL FDA CONTENT--not some distillations or analysis or summaries or completion prediction probabilities  (its how ChatGPT works with machine learning!)

    See link below - for a quick sample/screenshots of how 'ill-behaved' ChatGPT-3  today is vs  an actual Sharepoint hosted search we set up - i.e. a side by side dueling banjo style search with ChatGPT-3 and the Sharepoint hosted FDA content search we set up.
    ( Pages 1-3 shows ChatGPT-3 responses to the prompts while pages 4-onwards what a Sharepoint Online hosted search produces when searching for FDA PDF Guidance or 21 CFRS  where the 'term 'biosimilar' is next to the term 'interchange and terms 'efficacy' 'safety' 'quality' are found in the same PDF) 

    https://tinyurl.com/ycyymcz6

    Stay tuned for a RAP Quarterly article am working on for RAP July Quarterly release in which I plan to discuss the following topics below:

    Title: "Booster for a Smarter US FDA Regulatory Intelligence & Content Searching" 

    Article Outline:

     

    📝 Basic introduction to searching FDA regulatory  site contents- including how to currently search PDF Guidance documents  and 21 CFRs regulations, illustrate  inherent deficiencies  with FDA  meta-data search on medical devices, biologics and pharmaceutical (small molecule) drugs

    📝 Tips to resolve FDA site  search deficiencies for biologics manufacturing -find 'hidden' but 'discoverable' Guidance PDFs or 21 CFRs regulations issued by FDA Agencies- CDRH, CBER, CDER  then  propose deployment on  Microsoft SharePoint Online, including a quick primer how-to on this approach's benefits & challenges for deployment

    📝 A sample  search use case on FDA regulatory , i.e. a 'Dueling Banjos style' , side by side   search  comparison between FDA site search  and SharePoint Online full-text document management  systems search  using same keywords -  e.g. find or locate   PDF Guidance documents or/and 21  CFR statutes where 'immunogenicity' references 'assessment' or 'testing' 

    📝 ChatGPT-3-for US FDA Regulatory Intelligence & Compliance Searching- the Good, Bad & the Ugly! Let the Games Begin



    ------------------------------
    Ram Balani
    CEO
    FDASmart Inc. /eSTARHelper LLC www.estarhelper.com
    Amawalk , New York
    rbalani@fdasmart.com
    2019130558
    https://tinyurl.com/2wkxp69y
    on US FDA eSTAR for 510(K)
    ------------------------------



  • 18.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 18:33
    Edited by Michaela O. 02-Apr-2023 02:46

    Where can I read your quarterly article when you post it?



    ------------------------------
    Michaela O.
    ------------------------------



  • 19.  RE: ChatGPT for Regulatory Work

    Posted 01-Apr-2023 08:19

    You might want to investigate Huma.AI  They state "Leading Generative AI Platform for Life Sciences Huma.AI Begins Where ChatGPT Ends"
    Has anyone tried them?



    ------------------------------
    David Manalan
    Principal, INQC Consulting
    Acton MA
    United States
    ------------------------------



  • 20.  RE: ChatGPT for Regulatory Work

    Posted 02-Apr-2023 02:42
    Edited by Stephanie Grassmann 02-Apr-2023 04:59

    Dear All

    This Forum may be used similar to AI with the use of the Query. 
    -> Strongly recommend RAPS to further enhance the Regulatory Open Forum and to allow Advanced Searches to enable quick searches to find possible answers .
    The great thing of this Open Forum is that the Source of the information is transparent as well as the counter-arguments, agreements and disagreements. Sometimes, web sites are included so that the information/ data can be further checked. 

    With regards to my recommendations of (i) checking the source of the data and (ii) V&V of the AI and its source data, I have been told by some that if there is more data collection then everything will be fine. 
    My contra-argument: we have had drug approvals 30-50 years ago which were based on a data set of white males; women had not been represented in the study group. Some drugs turned out to cause harmful side effects to women and not men. Recently, we have also had a blood flow measurement device which resulted in people of colour receiving wrong measurements. 

    High quality clinical studies clearly outline the patient population (gender, age, co-morbidities, smokers, etc.) in which the clinical study results are based. 

    Please be aware that history appears to be repeating itself. Some of these databases in which AI are based: the source data is >70% men, white, of European descent, etc. 

    Yes, I realise that AI can address other areas which are not clinical. These are only examples.

    Here I would like to encourage us all to question the sources and the V&V so that this technology may be used to its full benefit and we minimise potential costly and harmful situations.  


    Best Regards,
    Stephanie





    ------------------------------
    Stephanie Grassmann
    Founder & Managing Director of MedTechXperts Ltd
    Biberstein
    Switzerland
    ------------------------------



  • 21.  RE: ChatGPT for Regulatory Work

    Posted 02-Apr-2023 09:43

    I asked ChatGPT a few questions about approvals. Although I was amazed by its fast response and comprehensive coverage, its answers weren't good enough. 
    When I corrected ChatGPT, it admitted that it couldn't access most updated databases so its answers could be limited. 
    There are a lot of discussions regarding whether AI can replace human beings, and here is the answer--it should be regulated. 
    I asked ChatGPT whether the FDA should regulate ChatGPT. Below is its answer.

    As an AI language model, ChatGPT does not concern the FDA as it is not a medical or healthcare product. Therefore, it is unlikely that the FDA will have any regulations on ChatGPT.However, there are other ways that might urge regulatory bodies to place regulations on ChatGPT. For example, if ChatGPT is used in a way that violates privacy laws or ethical codes of conduct, it may attract the attention of regulatory agencies. Additionally, if ChatGPT is used with malicious intent or for spreading hate speech, regulatory bodies may intervene to ensure that it is being used in a responsible and ethical manner.

    In summary, although the FDA is unlikely to have any regulations on ChatGPT, there are other regulatory bodies that may step in if they deem it necessary to ensure that ChatGPT is being used in a proper and responsible manner.



    ------------------------------
    Yuwei Zhang
    Waltham MA
    United States
    ------------------------------