Quality Information. Buchs Manufacturing Site

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1 Buchs Manufacturing Site Related Documents Buchs ISO 9001:2008 Certificate Buchs cgmp Certificate Buchs ISO 13485:2012 Certificate Buchs ISO 17025:2005/ ISO Guide 34 Certificate Buchs Management System Overview Buchs Organization Chart Environmental Protection, Health and Safety Policy Shipping Conditions & Recommended Long-term Storage Information Statement Product Dating Information Statement

2 Go to Table of Contents The Sigma-Aldrich Buchs facility adapts its supply chain and quality management systems to support your raw materials supply for industrial use Our Buchs facility is a major center of innovation and supply chain services, where product management and R&D teams launch hundreds of new products every year with a strong focus on analytical applications. They serve our customers in the research area and provide an internal pipeline supplying raw materials for our customers with industrial applications. Buchs provides procurement, manufacturing, quality control, packaging, quality assurance and customization beyond expectation. This creates a supply chain designed to serve the needs of industry customers and power the research and development business. The Buchs manufacturing center is located in the Swiss Alpes and encompasses 402,400 ft² ( m²) of manufacturing space. Our site Buchs holds the following certifications: ISO 9001:2008 ISO 13485:2012 ISO 17025:2005 and ISO Guide 34 GMP Page 1 of 16

3 Table 1. Quality Management Principles Responsibilities of the Quality Units Responsibilities for Production activities Internal Audits (Self Inspection) Product quality review 4 2. Personnel General Information Personnel Qualifications Personnel Hygiene 5 3. Buildings and Facilities Design and construction Utilities Water Containment Lighting Sewage and Refuse Sanitation and Maintenance 7 4. Process Equipment Design and Construction Equipment Maintenance and Cleaning Calibration Computerized Systems 8 5. Documents and Records Documentation System and Specifications Equipment Cleaning and Use Log Records of Raw Materials, Intermediates, Products, Labelling and Packaging Materials Master production instructions (Master production and control records) Batch Production Records Laboratory controls 9 6. Materials Management General Controls Batch Numbering System Receipt and Quarantine Sampling and Testing of Incoming Production Materials Storage Reevaluation Production and In-Process Controls Production Operations Time Limits Blending Batches Contamination Control Packaging and Identification Labelling of Products General Packaging Materials Label Issuance Control Packaging and Labelling Operations Storage and Distribution Warehousing Procedures Distribution Procedures Laboratory Controls General Controls Certificates of Analysis Stability Monitoring Expiry and Retest Dating Validation Change Control Rejection and Reuse of Materials Rejection Reprocessing Reworking Recovery of Materials and Solvents Returns Complaints and Recalls Contract Manufacturers (Including Laboratories) Agents, Brokers, Traders, Distributors, Repackers, and Relabellers Applicability Traceability of Distributed Products Quality Management Repacking, Re-labelling and Holding of Products Repacking, Re-labelling and Holding of Products Stability Transfer of Information Handling of Complaints and Recalls 16 Page 2 of 16

4 1. Quality Management 1.1 Principles Does establish, document and implement an effective system for managing quality that involves the active participation of management and appropriate manufacturing personnel? has implemented a comprehensive Management System certified to ISO 9001:2008. The Management System covers all activities performed at our Buchs site in Switzerland. Please refer to our MS overview for more information Has quality unit(s) that fulfils both quality assurance (QA) and quality control (QC) responsibilities either in the form of separate QA and QC units or a single individual or group? Yes, they exist as separate QA and QC units Is the quality unit independent from production? Yes, QC and QA are independent from production Does employ specified personnel who is authorised to release products? For each product a qualified function in QC or QA is responsible for release/ rejection of lots Are procedures existing for notifying responsible management in a timely manner of regulatory inspections, serious GMP deficiencies, product defects and related actions (e.g. quality related complaints, recalls, regulatory actions etc.)? During the regular management review meetings all quality related aspects are addressed. 1.2 Responsibilities of the Quality Units Are the quality units involved in all quality related matters? The Quality units are appropriately involved in all decisions and all documents in the Management System are reviewed and approved by QA What is the role of the Quality Unit concerning release or rejection of all raw materials and products? The release / rejection of all products and raw materials is done by QC or QA Do the Quality Units make sure that internal audits are performed? Yes, according to the internal audit schedule. Audits performed are ISO 9001, performed by QA, > 10/ year GMP, where appropriate, > 10/ year Safety audits Does have procedures in place to make sure that quality related complaints are investigated and resolved? All quality complaints are recorded, investigated and assessed by qualified personnel in QC/ QA. Actions are dated, responsibilities are defined and managed in a data base. Follow up and reporting to Management is done by QA Are materials appropriately tested and the results reported? All products are tested against predefined specifications. 1.3 Responsibilities for Production activities Does make sure that necessary calibrations are performed and records kept? All critical measuring devices are appropriately qualified and regularly calibrated Does makes sure that the premises and equipment are maintained and records kept? A comprehensive preventive maintenance plan is defined and managed through a stateof-the-art software application. Page 3 of 16

5 1.3.3 Does the Quality Unit make sure that all activities are performed following pre-approved instructions? A Standard Operation Procedure is in place requiring all production activities to be performed following pre-approved instructions Does the quality unit assure that all deviations from pre-approved instructions are appropriately recorded and investigated? A Standard Operation Procedure defines actions to be performed in case of deviation from pre-approved instructions. 1.4 Internal Audits (Self Inspection) Are at Sigma-Aldrich internal audits performed in accordance with an approved schedule in order to verify compliance with the principles of the quality requirements for the products? Yes, according to the internal audit schedule. Audits performed are ISO 9001, performed by QA, > 10/ year GMP, where appropriate, > 10/ year Safety audits Are audit findings and corrective actions documented and brought to the attention of Sigma- Aldrich s responsible management? The audit findings and corrective actions are managed through our CAPA System, recorded in our database and regularly reported to the management Does Sigma-Aldrich ensure that agreed corrective actions are completed in a timely and effective manner? Regular review of all CAPA is done by QA and deviations from timelines are reported to management. 1.5 Product quality review Are product quality reviews performed on a regular basis? Formalistic product quality reviews are performed by QA for our API production. For standard catalogue products product quality oversight is a responsibility of the person responsible for product release. This is done based on the data in our LIMS and not formally recorded. 2. Personnel 2.1 General Information How many employees work at the Sigma-Aldrich site Buchs? Approximately 480 employees How many employees work in quality assurance, quality control, manufacturing, and logistics? Quality assurance: 16 Quality control: 45 Manufacturing: 82 Supply Chain: Personnel Qualifications Is an adequate number of personnel qualified by appropriate education, training and / or experience to perform and supervise the manufacture of products? Approximately 20% of our employees hold a scientific university degree. A training program is in place to assure proper qualification of all employees relating to the field of responsibility Does Buchs keep records of the trainings? Is efficiency of training regularly checked? Yes, as appropriate. Normally this is done by assessment of employees by superiors. In specific cases tools like multiple choice-tests are performed. Page 4 of 16

6 2.2.4 Does Buchs have documented goals concerning work safety? Yes, EHS Policy and Goals Does Buchs perform risk analyses? Does Buchs perform analyses on accidents? Yes, please refer to our Environmental Protection, Health and Safety Policy. 2.3 Personnel Hygiene Does Buchs have a hygiene plan for personnel and facilities? Yes: Personnel is provided with appropriate work clothes. Eating/drinking/smoking is prohibited in all production areas. Personnel with infectious diseases or open lesions are excluded from work with open products. Additional protective clothing is applied to avoid direct contact with chemicals Is medical check for workers obligatory? Page 5 of 16

7 3. Buildings and Facilities 3.1 Design and construction Are the facilities designed to adequately prevent contamination, cross contamination, mix ups? Does Sigma-Aldrich provide defined areas or other control systems for the following activities: Storage of released materials? Production operations? Packaging and labelling operations? Laboratory operations? Are adequate, clean washing and toilet facilities provided for personnel, equipped with hot and cold water as appropriate, soap or detergent, air driers or single service towels? Are the washing and toilet facilities separate from, but easily accessible to, manufacturing areas? Yes Are adequate facilities for showering and / or changing clothes provided? 3.2 Utilities Does Sigma-Aldrich take appropriate measures to control risks of contamination and crosscontamination concerning the HVAC (heating, ventilation and air conditioning) systems? The air is filtered and not recirculated Does Sigma-Aldrich ensure that drains are of adequate size and are provided with an air break or a suitable device to prevent back siphonage? Yes, where appropriate. 3.3 Water Does process water used at Sigma-Aldrich, meet, at a minimum, world Health Organization guidelines for drinking (potable) water quality Various qualities of water are available; in our production facility purified water acc. to Ph.Eur./USP is used as process water. The water is produced in a double RO system and has been validated. Page 6 of 16

8 3.4 Containment Does Sigma-Aldrich produce highly sensitizing materials such as penicillines or cephalosporins? No. In our production facilities no highly sensitizing materials are produced. In our filling department (segregated building) highly sensitizing materials are handled using appropriate containment technologies. 3.5 Lighting Is adequate lighting provided in all areas at Sigma-Aldrich to facilitate cleaning, maintenance, and proper operations? 3.6 Sewage and Refuse How does Sigma-Aldrich dispose sewage, refuse, and other waste (e.g. solids, liquids, or gaseous by-products from manufacturing) in and from buildings and the immediate surrounding area? Waste is disposed of in a safe, timely and sanitary manner. Containers and/or pipes for waste materials are clearly labelled for identification and in order to avoid mistakes. Industrial waste water is cleaned in our waste water treatment plant. 3.7 Sanitation and Maintenance Are buildings used in the manufacture of products properly maintained and repaired and kept in a clean condition? All buildings and facilities are part of our preventive maintenance program. Cleaning programs are defined for all areas. 4. Process Equipment 4.1 Design and Construction Is equipment constructed so that surfaces that contact raw materials or products do not alter the quality of the products? Are major equipment (e.g. reactors, storage containers) and permanently installed processing lines used during the production of a material, appropriately identified? 4.2 Equipment Maintenance and Cleaning Are schedules and procedures (including assignment of responsibility) established for the preventive maintenance of equipment? Preventive maintenance plans are defined for all pieces of equipment Are written procedures established for the cleaning of facilities and equipment used in the manufacture of products? Is the cleaning recorded and records kept? Is the cleaning success verified by appropriate means? Standard techniques are visual assessment, and specific and unspecific tests on the last rinse or swab samples Is the use of cleaning agents regulated in writing? The type and amount of cleaning agents is defined in Standard Operation Procedures Is non-dedicated equipment cleaned between the production of different materials to prevent cross-contamination? Specific cleaning procedures are in place for the various types of equipment and product changeover. Page 7 of 16

9 4.3 Calibration Is a program in place to calibrate control, weighing, measuring, monitoring and test equipment that is critical for assuring the quality of products? Critical devices are defined in the maintenance program and calibrated according to a written calibration protocols and an established schedule Are equipment calibrations performed using standards traceable to certified standards? Are the calibration records kept? 4.4 Computerized Systems Is a list of computerized systems available? Are the computerized systems validated? Yes, as appropriate. Quality critical systems have been identified and validated Are changes to the quality critical computerized systems made according to a change procedure and formally authorized, documented and tested? Does Sigma-Aldrich keep records of all changes, including modifications and enhancements made to the hardware, software and any other critical components of the system? Do these records demonstrate that the system is maintained in a validated state? Yes, change control on critical computerized systems is applied. Records of changes are kept. The records show that the system is maintained in a validated state Have the computerized systems controls to prevent unauthorized access or changes to data? Yes, systems are provided with a user/ access authorization Is there a record of data changes made? Yes, validated computerized systems have an audit trail Is the security of the stored/archived data maintained? Yes, backup is performed regularly and stored in a secure place outside the company Can data be recorded by a second means in addition to the computer system? Yes, as appropriate Are electronic signatures used in the systems? Yes, electronic signatures are used in the non-gmp environment. 5. Documents and Records 5.1 Documentation System and Specifications Is the issuance, revision, superseding and withdrawal of all documents controlled with maintenance of revision histories? Has Sigma-Aldrich a procedure established for retaining all appropriate documents (e.g., development history reports, scale up reports, technical transfer reports, process validation reports, training records, production records, control records, and distribution records)? Are the retention periods for these documents specified? What is the retention time for batch records? Batch records (production and analytical) are kept for a minimum period of 10 years. 5.2 Equipment Cleaning and Use Log Are log books kept for major equipment listing the equipment history and applied cleaning procedures (chemical log)? Page 8 of 16

10 5.2.2 Are log books kept for major equipment listing all maintenance and repair work (technical log)? 5.3 Records of Raw Materials, Intermediates, Products, Labelling and Packaging Materials Is traceability of raw materials used in production and filling guaranteed? Yes, all used raw materials are traceable, as the used lot numbers are recorded in the batch records Are sample labels kept for each filling operation? 5.4 Master production instructions (Master production and control records) Does Sigma-Aldrich produce the products following written and approved procedures? Yes, for most of our products written approved Master Batch Records are available to ensure uniformity from batch to batch. Exceptions are productions in our innovation laboratories, where first market demand is produced in lab scale. These are recorded in laboratory notebooks, often following procedures from literature. 5.5 Batch Production Records Are production runs recorded by means of batch production records? In the batch production records all relevant parameters of the batch are recorded. 5.6 Laboratory controls Are all relevant information on the QC-Testing recorded? The laboratory records include complete data derived from all tests conducted to ensure compliance with established specifications and standards, including examinations and assays. Batch Production Record Review Are the production batch records reviewed by qualified personnel before release of a batch? A Standard Operation Procedure defines the appropriate functions qualified for the batch record review, and the scope of the review. 6. Materials Management 6.1 General Controls Does Sigma-Aldrich purchase the materials against an agreed specification, from a supplier or suppliers approved by the quality unit? All materials are purchased from qualified vendors. New vendors are qualified using quality questionnaires since Historical vendors were migrated as qualified into the system. 6.2 Batch Numbering System How is a batch defined at Sigma-Aldrich? A unique Sigma-Aldrich batch number is assigned to every received vendor lot. For inhouse manufactured materials a batch is defined as the material resulting from a single production run. If continuous processes are applied, a batch is defined as the material produced within a specific timeframe How are batch numbers defined at Sigma-Aldrich? The batch number consists of four letters, followed by four numbers and optionally a V : BCXY1234(V) BC site identifier for Buchs XY1234 serial alphanumeric number, running from BB0001 to ZZ9999 V if applicable; identifier for GHS compliant labelling Page 9 of 16

11 6.3 Receipt and Quarantine Does Sigma-Aldrich examine upon receipt and before acceptance, each container or grouping of containers of materials visually for correct labelling (including correlation between the name used by the supplier and the in-house name, if these are different), container damage, broken seals and evidence of tampering or contamination? Are these materials held under quarantine until they have been sampled, examined or tested as appropriate, and released for use? Is each container or grouping of containers (batches) of materials assigned and identified with a distinctive code, batch, or receipt number? Is this number used in recording the disposition of each batch? Does Sigma-Aldrich have a system in place to identify the status of each batch? A unique Sigma-Aldrich batch number is assigned to every received vendor lot. The material can be traced through its life cycle in the SAP system. 6.4 Sampling and Testing of Incoming Production Materials Does Sigma-Aldrich conduct at least one test to verify the identity of each batch of material? Does Sigma-Aldrich take representative samples of the batch from which they are taken? Do the sampling methods specify the number of containers to be sampled, which part of the container to sample, and the amount of material to be taken from each container? Yes, according to the sampling plan laid down in the LIMS Is the sampling conducted at defined locations and by procedures designed to prevent contamination of the material sampled and contamination of other materials? A dedicated sampling area in our goods receipt is used. The sampling group is part of our QC department. 6.5 Storage Is material at Sigma-Aldrich handled and stored in a manner to prevent degradation, contamination and cross contamination? Appropriate storage facilities are available for all types of chemicals handled on site Does Sigma-Aldrich assure that materials stored in fibre drums, bags, or boxes stored off the floor and, when appropriate, suitably spaced to permit cleaning and inspection? Does Sigma-Aldrich assure that certain materials in suitable containers which are stored outdoors and provided identifying labels remain legible and containers are appropriately cleaned before opening and use? N/A. No storage area is outdoors. At least roofed buildings are used Does Sigma-Aldrich identify and control rejected materials under a quarantine system which is designed to prevent their unauthorised use in manufacturing? Blocked materials are not available for transportation. This is guaranteed by the SAP warehouse management system. 6.6 Reevaluation Are materials re-evaluated as appropriate to determine their suitability for use (e.g., after prolonged storage or exposure to heat or humidity)? Retest periods are defined for all materials in our LIMS. Retests are triggered by the system automatically. Page 10 of 16

12 7. Production and In-Process Controls 7.1 Production Operations Are raw materials for manufacturing weighed or measured under appropriate conditions that do not affect their suitability for use? Does Sigma-Aldrich assure that if a material is subdivided for later use in production operations, the container receiving the material should be suitable and should be so identified that the following information is available: Material name and / or item code? Receiving or control number? Weight or measure of material in the new container? Re-evaluation or retest date if appropriate? 7.2 Time Limits Are time limits for specific production activities defined in the master production instructions? Are written procedures established to monitor the progress and control the performance of processing steps that cause variability in the quality characteristics of products? Are in process controls and their acceptance criteria defined based on the information gained during the development stage or historical data? In process controls are performed as defined in the development reports and based on experience from previous production runs Does the acceptance criteria and type and extend of testing depend on the nature of the product being manufactured, the reaction or process step being conducted, and the degree to which the process introduces variability in the products quality? Are there written procedures in place which describe the sampling methods for in process materials? Are there sampling plans and procedures based on scientifically sound sampling practices in place? Methods and sampling plans are defined in the master batch record and in the LIMS Is process sampling conducted using procedures designed to prevent contamination of the sampled material? Are there procedures established to ensure the integrity of samples after collection? A detailed Standard Operation Procedure and additional instructions in the master batch records describes the process of in process sampling. 7.3 Blending Batches Are OOS batches blended with in specification batches for the purpose of bringing OOS material into spec? No Is blending of batches conducted in order to increase batch size? Yes, as appropriate. Only batches meeting the specifications are blended. 7.4 Contamination Control Are production operations conducted in a manner that will prevent contamination of product by other materials? Page 11 of 16

13 8. Packaging and Identification Labelling of Products 8.1 General Are products packaged and labelled following written procedures? 8.2 Packaging Materials Are products packaged in predefined containers which provide adequate protection of the product against deterioration or contamination of the product that may occur during transportation and recommended storage? Containers are defined according to our vast experience with chemicals and in accordance with the shipping regulations. 8.3 Label Issuance Control Are procedures in place to reconcile the quantities of labels issued, used, and returned and to evaluate discrepancies found between the number of containers labelled and the number of labels issued. Label reconciliation is part of the manufacturing process and deviations are investigated appropriately. 8.4 Packaging and Labelling Operations Are procedures in place to guarantee correct packaging materials are used? The packaging material is defined in the bill of material issued with the packaging forms Are procedures in place that correct labels are used? The labels are identified by a unique label identification number which is referenced in the bill of material. The printed labels are additionally checked against the information on the bulk and the work order Are procedures in place to prevent mix ups during packaging and labelling operations? All materials and operations are appropriately segregated Are records kept for packaging and labelling operations? 9. Storage and Distribution 9.1 Warehousing Procedures Are at Sigma-Aldrich facilities available for the storage of all materials under appropriate conditions (e.g. controlled temperature and humidity when necessary)? Are records maintained of these conditions if they are critical for the maintenance of material characteristics? SAP assigns the storage location based on recommended storage conditions. 9.2 Distribution Procedures Does Sigma-Aldrich assure that product are only released for distribution to third parties after they have been released by the quality unit? Shipment of blocked stock is not possible. Release of not fully tested or OOS material against a written authorisation by a customer is possible Are products transported in a manner that does not adversely affect their quality? Shipping instructions laid down in SAP assure that the product specific requirements are met Are special transport or storage conditions stated on the label? Does Sigma-Aldrich ensure that the contract acceptor for transportation of the products knows and follows the appropriate transport and storage conditions? Page 12 of 16

14 10. Laboratory Controls 10.1 General Controls Does personnel at Sigma-Aldrich use documented procedures describing sampling, testing, approval or rejection of materials, and recording and storage of laboratory data? Does Sigma-Aldrich assure that reagents and standard solutions are prepared and labelled following written procedures? Are Use up dates applied as appropriate for analytical reagents or standard solutions? Are primary reference standards obtained as appropriate for the manufacture? Is the source of each primary reference standard documented? Are records maintained of each primary reference standards storage and use in accordance with the suppliers recommendations? Yes, if appropriate Are secondary reference standards appropriately prepared, identified, tested, approved and stored? Is the suitability of each batch of secondary reference standard determined prior to first use by comparing against a primary reference standard? Is each batch of secondary reference standard periodically re-qualified in accordance with a written protocol? Yes, as appropriate Are appropriate laboratory tests conducted to determine conformance to specifications? Does Sigma-Aldrich establish impurity profiles for research grade products? No Are the standard research grade materials tested regularly tested for bioburden? Only if specified in the product specification Certificates of Analysis Is a procedure in place defining the creation, the content and release of Certificates of Analysis? Are certificates dated and signed by authorized personnel of the quality unit and show the name, address, telephone number of the original releasing site? Are Certificates of Analysis available for all lots of products? The certificates are available from Sigma-Aldrich s web site Stability Monitoring Is a program in place to establish stability data to support expiry / retest dates for standard research products? Regular retesting of material on stock provides adequate data for the assignment of retest/expiry date as appropriate Are stability trials conducted following GMP / ICH guidelines? Only for a limited number of products Expiry and Retest Dating Is a program in place to establish stability data to support expiry / retest dates for standard research products? Regular retesting of material on stock provides adequate data for the assignment of retest/expiry date (as appropriate). Page 13 of 16

15 11. Validation Does Sigma-Aldrich have a defined philosophy concerning validation activities?? A validation master plan is available Are production processes for standard research materials validated? Yes, as appropriate. The validation process for standard research chemicals uses a non formalistic life cycle approach beginning from the first batches produced in our innovation labs through scale up and later full scale production runs. Validation acc. to ICH /GMP guidelines is performed for APIs Are analytical methods validated? Yes, as appropriate. All methods are thoroughly tested during the new product design process before it is applied as release test. Validation acc. to ICH /GMP guidelines is performed for APIs. 12. Change Control Is a change control system defined to prevent unauthorized changes to established procedures? Yes, all changes are appropriately assessed and approved by qualified personnel. 13. Rejection and Reuse of Materials 13.1 Rejection Are products failing to meet established specifications identified as such and quarantined and the final disposition of the materials recorded? 13.2 Reprocessing Is reprocessing of material conducted? Yes, if necessary Reworking Is rework of material not meeting the specifications conducted? Yes, if necessary Recovery of Materials and Solvents Is it common practice to recover solvents and other materials for further use in production operations? No Returns Are returned materials appropriately identified, checked for integrity, and records concerning the final disposition kept? Is the final disposition of returned products approved by the quality unit? Page 14 of 16

16 14. Complaints and Recalls Does Sigma-Aldrich record and investigate all quality related complaints, whether received orally or in writing, according to a written procedure Does the complaint records include: Name and address of complainant Name (and where appropriate, title) and phone number of person submitting the complaint Complaint nature (including name and batch number of the product) Date complaint is received Action initially taken (including dates and identity of person taking the action) Any follow up action taken Response provided to the originator of complaint (including date response sent) and final decision of product? Are records of complaints retained in order to evaluate trends, product related frequencies, and severity with a view to taking additional, and if appropriate, immediate corrective action? Trending on complaints and management reporting is the responsibility of quality assurance Is a written procedure established that defines the circumstances under which a recall of a product should be considered. In all cases where the safety of customers / patients could be affected Does the recall procedure designate who should be involved in evaluating the information, how a recall should be initiated, who should be informed about the recall, and how the recalled material should be treated? Does Sigma-Aldrich assure that in the event of a serious or potentially life threatening situation, local, national, and/or international authorities are informed and their advice sought? 15. Contract Manufacturers (Including Laboratories) Are contract Laboratories and contract manufacturers appropriately qualified? Is there a list available of all contract manufacturers, including contract laboratories, which are used for quality critical activities? Yes, for all GMP relevant contractors Are quality agreements in place for the quality critical contract manufacturers, including contract laboratories? Yes, contracts are in place with all GMP relevant contractors. Page 15 of 16

17 16. Agents, Brokers, Traders, Distributors, Repackers, and Relabellers 16.1 Applicability Does Sigma-Aldrich produce all products offered? No, approximately 45 % of our offer is not produced in house Traceability of Distributed Products Is traceability to the vendor guaranteed for all products? Is traceability to the manufacturer guaranteed for all products? No. In some cases we purchase materials from vendors which do not disclose the manufacturer s name Is the name of the manufacturer communicated to the customers for standard research products? Not generally. On special request it is possible to disclose this information Quality Management Repacking, Re-labelling and Holding of Products Does Sigma-Aldrich perform analytical testing on traded products to assure that all lots meet the predefined specifications? All products are tested appropriately following written instructions Are results from suppliers certificates accepted without testing? Yes, in special cases results are taken from suppliers CoAs Are results taken over from suppliers CoAs marked as such in Sigma-Aldrich s CoA? No Repacking, Re-labelling and Holding of Products Are traded products repackaged and relabelled at Sigma-Aldrich? Is the packaging and labelling operation designed to prevent mix ups and contamination? The packaging and labelling process for traded products is similar to the process for produced materials Stability Does Sigma-Aldrich handle the traded materials according to the manufacturers instructions? 16.6 Transfer of Information Is information from the vendor/manufacturer concerning the products communicated to the customers? Yes, in serious cases like safety hazards, product mix ups, this information is communicated to the customer Are changes in the vendor/manufacturer communicated to customers? Yes, on request change control and notification agreements can be set up Handling of Complaints and Recalls Are complaints from Sigma-Aldrich s customers communicated to the vendor/manufacturer in order to facilitate corrective at the manufacturer? Yes, as appropriate. Page 16 of 16

18 Sigma-Aldrich Buchs Organizational Chart Q Systems GMP Q Support Finance HR PI Product Mgt, R&D 1 VP Operations EMEA Site Director EMEA EHS Admin Assist EMEA QA Supply Chain Supply Chain Engineering EHS Production QC QA Operations Services & Fac Mgt Security Health,Safety Bulk Mfg Packaging Labs Procurement Engineering Environment Lab Mfg Logistics RCs Planning Workshops Compliance Prod Dev& Proj Mgt SAFC Order Mgt Innovation Order Mgt Facilities

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