Feb 1, 2026

Operationalizing Frontier AI Safety: A Canadian Framework for Risk Thresholds, Compliance Infrastructure, and Healthcare Agentic AI Governance

Ibrahim Elchami

This paper presents a governance framework for operationalizing frontier AI safety in Canada,addressing three critical domains: (1) risk thresholds and red lines derived from comparative analysis of Anthropic's ASL, OpenAI's Preparedness Framework, and DeepMind's Frontier Safety Framework; (2) compliance infrastructure for monitoring and enforcing AI safety commitments aligned with the EU AI Act Code of Practice; and (3) healthcare-specific governance for agentic and embodied AI systems. Our analysis reveals significant gaps in Canada's current regulatory approach following the demise of AIDA (Bill C-27), including the absence of compute governance mechanisms, a 30-44% implementation shortfall in voluntary safety commitments, and no classification system for autonomous healthcare AI. We propose a taxonomy distinguishing predictive (L1), reactive (L2), and agentic (L3) AI systems, with risk multipliers for healthcare (3x) and embodied (2.5x) applications. The framework includes a mandatory pre-deployment testing pipeline, third-party audit mechanisms, and integration with BC Health Authority governance structures. We present Motion M-XXX template for parliamentary action and a 30-month implementation timeline leveraging Canada's G7 2025presidency. This work contributes an actionable regulatory blueprint that balances innovation with safety, positioning Canada as a leader in responsible AI governance.

Reviewer's Comments

Reviewer's Comments

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Thank you for a very well researched paper. I liked the compliance gap analysis and healthcare incident case studies. The quantitative proposals (the 3x healthcare multiplier and the autonomy percentage cutoffs for L1/L2/L3) would benefit from explicit justification for why those specific numbers were chosen.

This is a strong policy blueprint. It takes frontier lab safety ideas and turns them into something that could actually be implemented in Canada, especially in healthcare where risks are real. If adopted, this could have real impact.

The main limitation is that it’s mostly synthesis + proposal. The scoring formulas / thresholds feel more conceptual than validated. Execution is solid for a governance paper, but it’s not backed by original data or strong sensitivity analysis.

Presentation is clear and structured. If you want to level it up, I’d add a tighter “assumptions vs recommendations” split and a clearer threat model for what failures you’re trying to prevent.

Cite this work

@misc {

title={

(HckPrj) Operationalizing Frontier AI Safety: A Canadian Framework for Risk Thresholds, Compliance Infrastructure, and Healthcare Agentic AI Governance

},

author={

Ibrahim Elchami

},

date={

2/1/26

},

organization={Apart Research},

note={Research submission to the research sprint hosted by Apart.},

howpublished={https://apartresearch.com}

}

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This work was done during one weekend by research workshop participants and does not represent the work of Apart Research.
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