Absolutely. A pre-removal risk assessment assesses the same legal test as a refugee claim. They're still assessing whether someone has been persecuted or their life is at risk. They're assessing a very complex question.
Sometimes the people making these applications don't have all the evidence that someone might want to see on paper. If they have the opportunity to speak orally to present their evidence and the opportunity for their lawyers to answer any questions, then they have the procedural safeguards.