Releasing so many changes at once to production
This question as it is posed is quite leading - the use of adjective &quot;bad&quot; to describe what you are doing implies that there is a &quot;good&quot; way. Nobody can answer whether your process is &quot;good&quot; or &quot;bad&quot; but you, and it should be judged on the effectiveness of the process. Perhaps this way of doing things is good for your environment...
However, what we can say is that the situation you describe goes against the principles of continuous delivery and continuous integration.
For example, describing the principle of &quot;work in small batches&quot;,
the Continous Delivery website states:

In traditional phased approaches to software development, handoffs from dev to test or test to IT operations consist of whole releases: months worth of work by teams consisting of tens or hundreds of people.

This sounds like your situation.
It goes on to state:

In continuous delivery, we take the opposite approach, and try and get every change in version control as far towards release as we can, getting comprehensive feedback as rapidly as possible.
Working in small batches has many benefits. It reduces the time it takes to get feedback on our work, makes it easier to triage and remediate problems, increases efficiency and motivation, and prevents us from succumbing to the sunk cost fallacy.

So, by this comparision, yes, your release management is &quot;bad&quot;, because it doesn't work in small batches, or continuously. (Again, with the caveat that any process that is executable effectively is a good process).
Another widely-used reference text, the Google Site Reliability Engineering Book has a whole chapter on release engineering. It says:

We have embraced the philosophy that frequent releases result in fewer changes between versions

Your process seems to run counter to this statement, and though you don't specify what level if testing or canary deployments you use, one may surmise from the fact that there is no continuous integration that this is very small, if any. Therefore, by &quot;SRE logic&quot;, every new deploy is high-risk, because it contains a large amount of untested changes.
There is another aspect which increases the risk in doing things &quot;your&quot; way. It is not reasonable to expect that a CAB will be able to make an informed decision on whether or not a given build should be released, without feedback on the performance or behaviour of the application in it's target environment (i.e. prod). They will be making decisions based on predictions and assumptions, rather than data.
For all these reasons, and probably many more, I think the consensus of this community would be that the answer to your question would be &quot;yes, this is a bad way of doing release engineering&quot;.
A better way would be to:

Have a minimum of testing in place, and work on extending that with every deploy
Start to automate the tests as far as possible and have clear documentation for how to test it when automation is currently infeasible.
delivery artifacts continuously and run canary deploys to a test environment; work on aligning  that environment as closely as possible with the production environment
Aim for the option of deploying any given build, and have a means for rolling back in the case of problems, to reduce the fear associated with deployment.

Smaller, and more deployments mean smaller changes at a time, which are easier to fix, and observing the deployment procedure continuously will give better insight into its reliability and where to improve things.
Automate, measure, improve. Repeat.