We propose a framework to evaluate the risk incurred when managing users and permissions through RBAC. The risk analysis framework does not require roles to be defined, thus making it applicable before the role engineering phase. In particular, the proposed approach highlights users and permissions that markedly deviate from others, and that might consequently be prone to error when roles are operating. By focusing on such users and permissions during the role definition process, it is possible to mitigate the risk of unauthorized accesses and role misuse.