Comment by Gregory A. Miller

A large frontier developer shall write, implement, comply with, and clearly and conspicuously publish on its internet website a frontier AI framework that applies to the large frontier developer's frontier models and describes in detail how the large frontier developer approaches all of the following: [...] (2) Defining and assessing the large frontier developer's thresholds to identify and assess whether a frontier model has capabilities that may pose a catastrophic risk [...] (3) Applying mitigations to address potential catastrophic risks identified under Paragraph (2) [...] (4) Reviewing assessments and adequacy of mitigations as part of the decision to deploy a frontier model or use it extensively and internally. [...] (10) Assessing and managing catastrophic risk resulting from the internal use of its frontier models, including risks resulting from a frontier model circumventing oversight mechanisms.