Governance and Risk: A.I.2 Safeguards for FMTVDM + ITIRD Deployments
- Richard M Fleming, PhD, MD, JD

- Oct 23
- 2 min read
Updated: Oct 25
Government and Ministerial summary
Combining FMTVDM with ITIRD requires robust A.I.2 safeguards to ensure human accountability, provenance, and stop‑gates that prevent opaque or harmful automation. Governance provisions protect clinical outcomes, national sovereignty, and public trust while enabling rapid, auditable innovation.
Core A.I.2 safeguards
Named human signoffs: every consequential ITIRD‑driven clinical decision must include a named institutional PI or delegated clinician signature.
Sovereign custody: on‑site data storage and escrowed keys for critical calibration artifacts and model control.
Immutable provenance: record model versions, phantom artifacts, operator IDs, and human rationale for every result.
Sentinel monitoring: automated detection of distributional drift or out‑of‑range ITIRD signatures with immediate stop‑gates.
Change control: legal clauses that require ministerial or delegated approval for model updates, retraining, or threshold changes.
Operational governance architecture
Governance board: ministerial delegate, technical leads, independent validator, and legal counsel.
Change control board: pre‑defined update windows and emergency procedures.
Independent validation lab: scheduled external checks and public summary audits.
Training & drills: routine incident response exercises to maintain human‑in‑the‑loop readiness.
Risk management without stifling utility
Phased rollouts: lock baseline models and staged updates after independent validation.
Targeted stop‑gates: human review only for consequential or out‑distribution cases to minimize routine friction.
Liability clarity: contractual allocation of responsibility for updates, errors, and remediation actions.
Pilot vignette (concise)
A pilot’s sentinel monitoring flagged an unexpected uptake distribution in an ITIRD subgroup; automatic stop‑gates routed cases for human review, led to immediate recalibration, and prevented incorrect therapy allocation before any clinical harm occurred.
CTA and next steps
Primary CTA: Request an A.I.2 governance audit tailored to FMTVDM + ITIRD deployments.
Secondary CTA: Book an executive briefing on legal and contractual safeguards.
KPIs to track
Sentinel alert rate and mean time to resolution.
Percentage of outputs with full provenance and signoff metadata.
Frequency and outcome of change control board reviews.
Independent validation pass rate and time to remediation when issues arise.





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