#459: The Purolea Warning Letter & Validating AI in Medical Devices - What FDA Actually Requires
Host Etienne Nichols analyzes the FDA's warning letter to Purolea Cosmetics Lab, arguing that the citation was not a crackdown on AI but a failure of quality system oversight and process validation. He explains that while Purolea used AI agents to draft specifications, the core violation was the lack of human review and accountability under 21 CFR 211.22. Nichols outlines a three-part validation framework for AI/ML-based Software as a Medical Device (SaMD), emphasizing the separation of training, validation, and holdout test data. He concludes by listing essential regulatory standards and five concrete questions to assess if a quality system is ready for FDA AI inspections.