QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 QMS MANUAL TAPEMARK 1685 M ar t haler Lane W est St. Paul, Minnesota 55118-3537 USA Phone: 800-535-1998 Fax: 651-450-8403 www.tapemark.com QMS MANUAL APPROVAL SIGN OFF President & COO Andy Rensink 09/03/2014 Date Vice-President, Technical Operations Steve Rau 08/25/2014 Date Director, Quality Assurance Steve Leno 09/03/2014 Date TAPEMARK COMPANY CONFIDENTIAL PAGE 1 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 QMS MANUAL TABLE OF CONTENTS 0100 QMS PURPOSE AND COMPANY OVERVIEW A) QMS Purpose B) TM Overview Page 4 0200 QMS SCOPE AND RESPONSIBILITY A) QMS Responsibility Statement B) PROCESS APPROACH (FLOW CHART) 0300 QMS MANUAL INFORMATION A) QMS Manual Revision Control B) QMS Manual Control Information Page 6 Page 8 0400 QUALITY MANAGEMENT SYSTEM 0410 GENERAL REQUIREMENTS 0420 DOCUMENTATION REQUIREMENTS 0421 General 0422 Quality manual 0423 Control of documents 0424 Control of records Page 9 Page 10 0500 MANAGEMENT RESPONSIBILITY 0510 MANAGEMENT COMMITMENT 0520 CUSTOMER FOCUS 0530 QUALITY POLICY 0531 Vision Statement 0540 PLANNING 0541 Quality objectives 0542 Quality management system planning 0550 RESPONSIBILITY, AUTHORITY AND COMMUNICATION 0551 Responsibility and authority 0552 Management representative 0553 Internal communication 0560 MANAGEMENT REVIEW 0561 General 0562 Review input 0563 Review output Page 13 Page 13 Page 14 Page 15 Page 16 Page 16 0600 RESOURCE MANAGEMENT 0610 PROVISION OF RESOURCES 0620 HUMAN RESOURCES 0621 General 0622 Competence, awareness, and training 0630 INFRASTRUCTURE 0640 WORK ENVIRONMENT TAPEMARK COMPANY CONFIDENTIAL Page 18 Page 18 Page 19 Page 20 PAGE 2 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 QMS MANUAL TABLE OF CONTENTS 0700 PRODUCT REALIZATION 0710 PLANNING OF PRODUCT REALIZATION 0720 CUSTOMER-RELATED PROCESSES 0721 Determination of requirements related to the product 0722 Review of requirements related to the product 0723 Customer communication 0730 DESIGN AND DEVELOPMENT 0731 Design and development planning 0732 Design and development inputs 0733 Design and development outputs 0734 Design and development review 0735 Design and development verification 0736 Design and development validation 0737 Control of design and development changes 0740 PURCHASING 0741 Purchasing process 0742 Purchasing information 0743 Verification of purchased product 0750 PRODUCTION AND SERVICE PROVISION 0751 Control of production and service provision 0752 Validation of processes for production and service provision 0753 Identification and traceability 0754 Customer property 0755 Preservation of product 0760 CONTROL OF MONITORING AND MEASURING DEVICES Page 21 Page 21 Page 23 Page 25 Page 26 Page 30 0800 MEASUREMENT, ANALYSIS AND IMPROVEMENT 0810 GENERAL 0820 MONITORING AND MEASUREMENT 0821 Customer satisfaction 0822 Internal audit 0823 Monitoring and measurement of processes 0824 Monitoring and measurement of product 0830 CONTROL OF NONCONFORMING PRODUCT 0840 ANALYSIS OF DATA 0850 IMPROVEMENT 0851 Continual improvement 0852 Corrective action 0853 Preventive action GLOSSARY TAPEMARK COMPANY Page 31 Page 31 Page 33 Page 34 Page 35 Page 37 CONFIDENTIAL PAGE 3 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0100 ISSUED DATE: 09/03/2014 QMS PURPOSE AND COMPANY OVERVIEW A) QUALITY MANAGEMENT SYSTEM (QMS) PURPOSE The Tapemark Company (TM) Quality Management System (QMS) complies with the following referenced standards: A) ANSI/ISO/ASQ Q9001:2008 Quality Management System Requirements. B) ISO 13485:2003 Medical devices - Quality Management Systems – Requirements for regulatory purposes. C) ISO 14971 Medical devices – Application of Risk Management to Medical Devices D) 21 Code of Federal Regulations: Part 110, Part 111, Part 210, Part 211, Part 820 and Part 11. E) Council Directives 2003/94/EC (EU GMP) and 2001/83/EC – standards of manufacture for any product intended for human use F) EU GMP- EudraLex Volume 4 – Good Manufacturing Practices - Concerning Medicinal Products for Human and Veterinary use G) Council Directive 93/42/EEC concerning Medical Devices Throughout the QMS Manual where the phrase “TM referenced requirements” is stated, the above list of requirements is also applicable. The purpose of the QMS manual is to: A) Describe TM’s quality management business operating system. B) Define responsibilities, authorities, and interrelationships of the key operation management segments at TM. C) Provide direction for each of the functional activities at TM. D) Provide controls that ensure the requirements for quality will be met at TM. TM’s focus on meeting the needs of its customers through continual improvement and customer satisfaction is the primary reason for implementing the quality management system. The QMS manual may be used for external purposes such as third party audits and to provide customers with information concerning the QMS in place at TM. B) TAPEMARK OVERVIEW Tapemark is a privately-held contract development and manufacturing organization with multiple facilities in West St. Paul, Minnesota. In the early 1950’s Tapemark pioneered a technique for printing on clear, self-wound tape. That innovation coupled with industry advancements in paper and film materials propelled Tapemark into a leadership position in printing and converting of pressure sensitive labels for product identification and labeling. Today, Tapemark is a leader in innovative technologies that address unique customer needs. Expanding its quality commitment, Tapemark is ISO 9001 and 13485 certified, is FDA registered as a Food, Drug, and Device manufacturer, certified to EU Drug GMPs, and licensed as a DEA Controlled Substance manufacturer. Tapemark’s integrated converting capabilities include, compounding, coating, printing, die cutting and packaging of complex components and products for the medical, pharmaceutical, and consumer products markets. Travanti Medical™, a business entity of Tapemark since 2011, designs, develops, manufactures and markets medical device products, including the IontoPatch® line of iontophoretic devices. Tapemark manufactures products in three locations: TAPEMARK COMPANY CONFIDENTIAL PAGE 4 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q · 1685 Marthaler Lane, West Saint Paul, Minnesota, 55118 USA · 232 Lothenbach Avenue, West Saint Paul, Minnesota, 55118 USA · 223 East Marie Avenue, West Saint Paul, Minnesota, 55118 USA TAPEMARK COMPANY CONFIDENTIAL ISSUED DATE: 09/03/2014 PAGE 5 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0200 ISSUED DATE: 09/03/2014 QMS SCOPE AND RESPONSIBILITY A) QMS RESPONSIBILITY STATEMENT: TM’s management and personnel are responsible to uphold the quality management system based on the TM referenced requirements as documented in the QMS manual, supporting procedures, and documentation. For reference, an outline of TM’s quality responsibility and authority is located in section 0550 “Responsibility, Authority, and Communication” of this QMS manual. TM stands behind its commitment for quality. B) TAPEMARK PROCESS APPROACH: Tapemark maintains a process approach to its quality systems utilizing a PDCA (Plan Do Check Act) cycle. It effectively integrates Continuous Improvement, Quality by Design and Risk Management into all aspects of its system. See below flow chart: Overview of Quality System Continuous Improvement Trending, SPC, CAPA Input Requirements: Customer and Regulatory Outputs: Management Responsibility Resource Management D&D -Product Lifecycle Measurement and Analysis Customer Satisfaction and Quality Product Quality by Design Risk Management TAPEMARK COMPANY CONFIDENTIAL PAGE 6 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 Tapemark QMS Reference Documents for the process approach defined above include: INPUT REQUIREMENTS – SOP-18.01 – DESIGN CONTROL – TRAVANTI MEDICAL™ – TMP-72.02 – CUSTOMER MANAGEMENT AND CONTROLS – TMP-73.03 – PROJECT DEVELOPMENT AND DESIGN CONTROLS MANAGEMENT RESPONSIBILITY – TMP-41.01 – QUALITY MANAGEMENT SYSTEM – TMP-50.01 – TAPEMARK QUALITY POLICY – TMP-56.01 – MANAGEMENT REVIEW RESOURCE MANAGEMENT – TMP-62.02 – EMPLOYEE TRAINING – TMP- 63.02 – FACILITY QUALIFICATION – TMP-63.03 – EQUIPMENT CONTROL – TMP-63.04 – CLEANING VALIDATION – TMP-63.05 – MATERIALS CONTROL – TMP-63.06 – SUPPLIER QUALIFICATION AND MONITORING – TMP-64.02 – ENVIRONMENTAL CONTROL AND MONITORING PROGRAM PRODUCT REALIZATION – SOP-18.01 - DESIGN CONTROL – TRAVANTI MEDICAL™ – SOP-18.02 – RISK MANAGEMENT – TRAVANTI MEDICAL™ – SOP-30.20 - VERIFICATION – TMP-63.06 – SUPPLIER QUALIFICATION AND MONITORING – TMP-63.05 – MATERIALS CONTROL – TMP-72.02 – CUSTOMER MANAGEMENT AND CONTROLS – TMP-73.02 – VALIDATION AND QUALIFICATION OF MANUFACTURING PROCESSES AND TESTING METHODS – TMP-73.03 – PROJECT DEVELOPMENT AND DESIGN CONTROLS – TMP-75.02 – MANUFACTURING OF PRODUCT FOR COMMERCIAL USE – TMP-75.05 – MEASURING AND MONITORING DEVICE CONTROLS – TMP-81.01 – RISK MANAGEMENT MEASUREMENT & ANALYSIS – SOP-30.49 – NON-CONFORMANCE MANAGEMENT – TMP-75.02 – MANUFACTURING OF PRODUCT FOR COMMERCIAL USE – TMP-75.05 – MEASURING AND MONITORING DEVICE CONTROLS – TMP-82.02 – AUDITING TAPEMARK OPERATIONS OUTPUT REQUIREMENTS – SOP-36.19 – CUSTOMER SATISFACTION – TMP-56.01 – MANAGEMENT REVIEW CONTINUOUS IMPROVEMENT – SOP-30.49 – NON-CONFORMANCE MANAGEMENT – SOP-30.72 – SYSTEM IMPACT ASSESSMENT – SOP-31.25 – STATISTICAL CONTROL AND ANALYSIS – SOP-36.07 – DESIGN REVIEW RISK MANAGEMENT – TMP-81.01 – RISK MANAGEMENT QUALITY BY DESIGN: A PHILOSOPHY THAT IS INTEGRATED THROUGHOUT TM’S QUALITY MANAGEMENT SYSTEM. THE QUALITY SYSTEMS TRAINING PROVIDED TO ALL EMPLOYEES EMPHASIZES THIS APPROACH, AND IT IS FURTHER ENFORCED DURING THE DAY-TO-DAY IMPLEMENTATION OF TM’S QUALITY MANAGEMENT SYSTEM AS DEFINED THROUGHOUT THIS MANUAL. TAPEMARK COMPANY CONFIDENTIAL PAGE 7 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0300 ISSUED DATE: 09/03/2014 QMS MANUAL INFORMATION A) QMS MANUAL REVISION CONTROL: Revisions and amendments to the quality management system (QMS) manual are maintained in Tapemark’s electronic documentation system. The QMS manual is reviewed at least annually in the management review meeting (see section 0562 Review Input). Any revisions/changes/additions made to the TM’s quality management system manual must be made with the cooperation and approval of TM management affected. B) QMS MANUAL CONTROL INFORMATION: CONTROLLED QMS Manual Copies: TM’s ISO Management Representative assigns controlled copies. Controlled copies are stamped “CONTROLLED.” Controlled copies are obsolete once revisions have been made to the master (see section 0300 A) QMS Manual Revision Control for current effective dates). The ISO Management Representative will distribute revisions to holders of controlled copies UNCONTROLLED QMS Manual Copies: Quality manuals may be issued by the ISO Management Representative or delegate for one time use and are considered “reference only” at the time of issue if stamped or marked “CONTROLLED” in black or not stamped at all as stated in TMP-42.02 DOCUMENT CONTROL SYSTEM. 0300 REFERENCE DOCUMENTATION TMP-42.02 DOCUMENT CONTROL SYSTEM TAPEMARK COMPANY CONFIDENTIAL PAGE 8 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0400 ISSUED DATE: 09/03/2014 QUALITY MANAGEMENT SYSTEM 0410 GENERAL REQUIREMENTS TM has established and continues to maintain a company-wide QMS, which is continually reviewed for effectiveness and audited as a means to ensure product conformity to customer specified requirements, as well as compliance with the TM referenced requirements (see TMP 41.01 - QUALITY MANAGEMENT SYSTEM). In establishing the QMS, TM has: A) Identified the necessary processes and their application throughout the organization. B) Determined the sequence and interaction of the processes. C) Defined criteria and methods for evaluating the effectiveness of the operation and control of these processes. D) Ensured availability of resources and information necessary to support the operation and monitoring of these processes. E) Established controls to monitor, measure, and analyze the processes within the QMS. F) Implemented actions to achieve planned results and continual improvement processes. TM personnel who manage, perform, and verify work-affecting quality are responsible for implementing, maintaining, and ensuring continued effectiveness of the QMS. The ISO Management Representative is responsible for coordinating, establishing, monitoring, and auditing the QMS. Implementation of the QMS is assessed regularly by way of internal and external audits following corrective and preventive action procedures, as well as QMS management reviews. If at any time TM has chosen to outsource any process that affects product conformity or contracted requirements, procedures have been established to ensure control over such processes. These controls are identified within the QMS and are referred to within processes for management activities, provisions of resources, product realization, measurement analysis and improvement activities where applicable. 0410 REFERENCE DOCUMENTATION TMP-41.01 QUALITY MANAGEMENT SYSTEM TAPEMARK COMPANY CONFIDENTIAL PAGE 9 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0420 DOCUMENTATION REQUIREMENTS 0421 GENERAL The quality management system documentation is divided into four levels. The levels are as follows: Level 1 Document: Level 1 document is limited to the Quality Manual. This document establishes TAPEMARK’s commitment to control systems, it assigns responsibility for the systems, and links each system to the other levels of documents that fulfill these commitments routinely. Level 2 Documents: Level 2 documents provide greater detail on the quality system commitments of the Quality Manual, and documents that provide product/project specific requirements from customers. Level 3 Documents: Level 3 documents direct the routine work of development, manufacturing, testing, etc. They define tasks needed to fulfill the requirements of Level 2 and Level 1 documents. Level 4 Documents: Level 4 documents are the records created when Level 3 documents are used. The QMS is an organizational structure consisting of a manual, procedures, and form documentation (or quality records when completed), which has been established to ensure the effective planning, operation, and control of its processes. Documentation can be in any form, data, or type of medium. When necessary, records are maintained to meet the TM referenced requirements. 0422 QUALITY MANUAL TM has established and maintains a QMS manual that: A) Includes a quality scope (see section 0200 A) TM Quality Scope Statement) as well as noting any exclusions to the TM referenced requirements (see section 751 Control of Production and Service Provision – Post Delivery Servicing). B) References documentation used to meet the TM referenced requirements. C) Describes the interaction between the QMS processes. TAPEMARK COMPANY CONFIDENTIAL PAGE 10 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0423 CONTROL OF DOCUMENTS Documents required by the QMS are controlled. Records are a special type of document and controlled according to established requirements (see section 0424 Control of Records). Documented procedures have been established that define the controls needed for: A) QMS Documentation: see TMP-42.02- DOCUMENT CONTROL SYSTEM. B) Customer-supplied Prints, Databases, or Specifications: see SOP-30.03 - CONTROL OF EXTERNAL DOCUMENTS. C) Vendor-supplied Prints, Databases, or Specifications: see SOP-30.03 - CONTROL OF EXTERNAL DOCUMENTS. D) Internal Specifications and Forms: see SOP-30.02 – DOCUMENTATION CONTROL PRACTICES. E) Internal Design Records: see SOP-18.01 – Design Control – Travanti Medical™ and TMP-73.03 PROJECT DEVELOPMENT AND DESIGN CONTROLS. These control procedures are documented to ensure: A) Approval of documents for adequacy prior to use. B) Reviews and updates are made as necessary and outline the re-approval of documents. C) Changes and current revision status of documents is identified. D) Relevant versions of applicable documents and data are available at the locations where operations are essential for the effective functioning of the TM QMS. Document placement is regulated by documented procedures. E) Documents remain legible and are readily identifiable. F) External documents and specifications are maintained to control the distribution of external specifications (see). G) The prevention of unintended use of obsolete documents, and to apply suitable identification to them if they are retained for any purpose. TAPEMARK COMPANY CONFIDENTIAL PAGE 11 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0424 CONTROL OF RECORDS Records have been established and are maintained to provide evidence of conformity to requirements and effective operation of the QMS. Records will remain legible, readily identifiable, and retrievable. SOP30.02 - DOCUMENTATION CONTROL PRACTICES defines the controls needed for identification, storage, protection, retrieval, retention time, and disposition of records. 0420 REFERENCE DOCUMENTATION TMP-42.02 TMP-73.03 SOP-30.02 SOP-30.03 SOP-18.01 DOCUMENT CONTROL SYSTEM PROJECT DEVELOPMENT AND DESIGN CONTROLS DOCUMENTATION CONTROL PRACTICES CONTROL OF EXTERNAL DOCUMENTS DESIGN CONTROL – TRAVANTI MEDICAL™ TAPEMARK COMPANY CONFIDENTIAL PAGE 12 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0500 ISSUED DATE: 09/03/2014 MANAGEMENT RESPONSIBILITY 0510 MANAGEMENT COMMITMENT TM management has demonstrated its commitment to the development and implementation of the QMS, and continual improvement of its effectiveness by (see SOP-30.18 - MANAGEMENT COMMITMENT): A) Communicating to the organization of the importance of complying with customer, regulatory, and statutory requirements through written procedures as referenced in the QMS manual. B) Establishing and communicating the quality policy throughout the organization (see section 0530 Quality Policy). C) Establishing, communicating, and enforcing the quality objectives (see section 0541 Quality Objectives). D) Conducting QMS management review meetings (see section 560 Management Review). E) Providing for necessary resources (see section 0610 Provision of Resources). 0510 REFERENCE DOCUMENTATION SOP-30.18 MANAGEMENT COMMITMENT 0520 CUSTOMER FOCUS TM management ensures that customer requirements are determined, converted into requirements, and fulfilled with the aim of achieving customer satisfaction (see sections 0720 Customer-related Processes, 0821 Customer Satisfaction and TMP-72.02 - CUSTOMER MANAGEMENT AND CONTROLS). 0520 REFERENCE DOCUMENTATION TMP-72.02 CUSTOMER MANAGEMENT AND CONTROLS TAPEMARK COMPANY CONFIDENTIAL PAGE 13 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0530 QUALITY POLICY TM management is responsible to establish the quality policy and quality objectives that are appropriate to the purposes of the organization. Through the quality policy, a commitment to comply with the quality requirements and continually improve the effectiveness of the QMS has been established. The quality policy is the framework from which the quality objectives have been established and will be continually reviewed. TAPEMARK COMPANY QUALITY POLICY "COMMITMENT TO EXCELLENCE THROUGH INNOVATION, DESIGN AND CONTINUOUS IMPROVEMENT" The Quality Policy is communicated throughout the Tapemark facilities. Training is completed to ensure TM personnel understand the quality policy and its objectives. Compliance to the quality policy is monitored through internal and external audits. The quality policy was developed, defined, and is supported by TM Management. 0530 REFERENCE DOCUMENTATION TMP-50.01 TAPEMARK QUALITY POLICY 0531 VISION STATEMENT Tapemark’s Vision is a separate but interrelated Statement that is created by Senior Management Staff in an effort to provide both direction and commitment to fulfilling the intent of the Quality Policy. ‘Tapemark is a premier, quality-focused, values-driven contract manufacturer, supporting customers whose products are produced in a cGMP and FDA-compliant business environment. Our vision will be achieved through business relationships with high-growth, market-leading customers that are active in regulated markets; through continuous investment in, and development of, our existing and emerging manufacturing capabilities; and through the development, acquisition or accessing of technologies that promote our long-term growth. Tapemark commits to comply with the requirements of the standards and continually improve the effectiveness of the QMS.’ TAPEMARK COMPANY CONFIDENTIAL PAGE 14 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0540 PLANNING 0541 QUALITY OBJECTIVES TM Management will ensure that the quality objectives, including those needed to meet requirements for product (see section 0710 Planning of Product Realization) are established at relevant functions and levels within the organization. The quality objectives are measurable and consistent with the quality policy. These quality objectives have been established during the quality planning process and are continually reviewed during the QMS management review process (see TMP-56.01 - MANAGEMENT REVIEW and SOP-30.16 - QUALITY PLANNING). 0542 QUALITY MANAGEMENT SYSTEM PLANNING Led by the Head of Quality Assurance and assisted by members of management, TM ensures that: A) The understanding, planning, and implementation of the QMS is carried out in order to meet the requirements in section 0541 Quality Objectives as well as the quality requirements (see section 0560 Management Review). B) The integrity of the QMS is maintained when changes to the QMS are planned and implemented (see section 0560 Management Review). 0540 REFERENCE DOCUMENTATION TMP-56.01 SOP-30.16 MANAGEMENT REVIEW QUALITY PLANNING TAPEMARK COMPANY CONFIDENTIAL PAGE 15 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0550 RESPONSIBILITY, AUTHORITY AND COMMUNICATION 0551 RESPONSIBILITY AND AUTHORITY The responsibility, authority, and the interrelation of personnel, who manage, perform and verify workaffecting quality are listed in the organizational chart and is communicated throughout the organization. Each individual understands his/her function and has the freedom to bring forth any preventive/corrective actions necessary to implement and maintain the quality program at TM (see SOP-30.18- MANAGEMENT COMMITMENT). 0552 MANAGEMENT REPRESENTATIVE (M.R.) The President/COO, with the support and partnership of TM’s management, is ultimately responsible for establishing, implementing, and maintaining the quality system for continual improvement. This management team will also work to ensure the promotion of awareness of customer requirements throughout the organization. The ISO M.R. (Head of Quality Assurance) is appointed by and reports to the President/COO. If the appointed ISO M.R. is unavailable, a designated Senior Level Quality Employee will serve as the Deputy ISO M.R. in the absence of the Head of QA. 0553 INTERNAL COMMUNICATION TM uses various methods of communicating decision-making and effectiveness of the QMS. This is achieved through internal memos, newsletters, and company/employee meetings. 0550 REFERENCE DOCUMENTATION SOP-30.18 MANAGEMENT COMMITMENT 0560 MANAGEMENT REVIEW 0561 GENERAL Management reviews the QMS periodically to ensure its continuing suitability, adequacy, and effectiveness. The review meetings will include assessing opportunities for improvement and/or changes to the QMS, including the quality policy and quality objectives. The intervals between the meetings are planned and periodically reviewed to ensure the continuing suitability and effectiveness of the QMS. Frequency of reviews and levels of input will depend on individual circumstances. The ISO M.R. is responsible for scheduling and conducting these reviews as outlined in the TMP-56.01 MANAGEMENT REVIEW. Detailed records of these meetings are prepared and maintained by the ISO M.R. or delegate for review and follow up. Records of meeting minutes and attendance are maintained. 0562 REVIEW INPUT QMS management review meeting agenda items are: A) Internal feedback: audit results. B) External feedback: customer complaints and satisfaction information. TAPEMARK COMPANY CONFIDENTIAL PAGE 16 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 C) Process and/or product conformity results (including delivery performance) and trends (statistical techniques). D) Status of corrective/preventive actions: Non-compliances of QMS or consistent non-conformances. E) Previous QMS meetings: Follow-up action items and meeting notes. F) Review of any changes at TM that would affect the QMS (i.e., increased growth). G) Recommendations for improvements. H) Causes of product non-conformances: internal and external. I) Adequacy of the organizational structure, including its staffing and resources. J) Compliance with the QMS documentation, including the QMS manual, quality policy, and quality objectives. K) New or revised Regulatory Requirements Items may be added when judged appropriate or as required. TM management’s focus is to identify trends of quality successes and/or opportunities for improvement. Should issues arise that have become chronic problems, these areas receive special attention and more frequent reviews. Issues that arise as a result of a management review meeting receive prompt attention. 0563 REVIEW OUTPUT QMS management review meeting agenda will include decision and actions related to: A) Improvement of the effectiveness of the QMS and its processes. B) Improvement of the product related to customer requirements. C) Resources needed. 0560 REFERENCE DOCUMENTATION TMP-56.01 MANAGEMENT REVIEW TAPEMARK COMPANY CONFIDENTIAL PAGE 17 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0600 ISSUED DATE: 09/03/2014 RESOURCE MANAGEMENT 0610 PROVISION OF RESOURCES TM management has the responsibility and authority to ensure there are adequate resources to support the QMS. Resources necessary to provide adequate equipment and process needs are reviewed by TM management through management review meetings. Each member of management provides adequate resources to: A) Implement and maintain the QMS and continually improve on its effectiveness. B) Enhance customer satisfaction by meeting regulatory and customer requirements. C) Provide adequate training programs for personnel to carry out the QMS quality policy and quality objectives. In order to achieve continual improvement and monitor effectiveness, internal audits are performed. Trained quality auditors are aware of and utilize the QMS manual and procedures when performing internal audits. Records are evaluated and maintained by the ISO M.R. as the lead quality auditor. Follow up includes corrective actions as necessary (see section 0822 Internal Audit). 0620 HUMAN RESOURCES 0621 GENERAL The competence of personnel performing work affecting product quality is determined based on appropriate education, training, skills, and experience (see TMP-62.02 - EMPLOYEE TRAINING). 0622 COMPETENCE, AWARENESS, AND TRAINING Tapemark: A) Determines the necessary competence for personnel performing work affecting product quality through its established training programs and records. B) Provides internal and external training programs, through which TM personnel are trained on the relevance and importance of their activities and how they contribute to the achievement of the quality objectives. C) Evaluates the training programs for effectiveness by performing internal audits, documenting the results, and then reviewing the results with management for corrective and preventive action as needed. D) Ensures that its personnel are aware of the relevance and importance of their activities and how they contribute to the achievement of the quality objectives. E) Maintains the training records on the education, skills, and experiences each employee has achieved that identify the competency of his/her current position. F) Ensures that employees performing specific assigned tasks are qualified on the basis of appropriate education training and/or experience as required. TAPEMARK COMPANY CONFIDENTIAL PAGE 18 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 G) Ensures that for current employee’s undefined training needs are addressed as the need arises or at the request of employees or employer for further training needs/advancements. Procedures are documented and maintained for training needs in each department and/or area. Department managers/supervisors are responsible for the annual review and evaluation of employees (see SOP-38.01 EMPLOYEE DEVELOPMENT and SOP-38.02 - QUALITY SYSTEMS TRAINING). 0620 REFERENCE DOCUMENTATION TMP-62.02 SOP-38.01 SOP-38.02 EMPLOYEE TRAINING EMPLOYEE DEVELOPMENT QUALITY SYSTEMS TRAINING 0630 INFRASTRUCTURE TM has determined, provided, and maintains an infrastructure needed to achieve conformity to product requirements. Infrastructure includes, as applicable: A) Buildings, workspace, and associated utilities. B) Process equipment (both hardware and software). C) Supporting services (such as transport or communications). TM Maintenance Program: By operating a preventive and corrective maintenance program and through its safety program, controls are established to secure suitable work equipment and environment. The Maintenance Supervisor or delegate is in charge of corrective and preventive equipment maintenance. This manager is responsible to ensure that continued process capability can be met or resources are allocated to meet these capabilities. Equipment receives prior approval by appropriate personnel before release/installation to production (SOP-34.05 - PREVENTIVE MAINTENANCE PROGRAM and SOP-34.06 - WORK ORDER SYSTEM). 0630 REFERENCE DOCUMENTATION SOP-34.05 SOP-34.06 PREVENTIVE MAINTENANCE PROGRAM WORK ORDER SYSTEM TAPEMARK COMPANY CONFIDENTIAL PAGE 19 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0640 WORK ENVIRONMENT TM has determined and manages the work environment to assure its suitability for achieving conformity to product requirements, including product regulatory requirements such as production clean room environments (see TMP-64.02 - ENVIRONMENTAL CONTROL AND MONITORING PROGRAM AND SOP-30.51 – PERSONNEL RESPONSIBILITIES IN CONTROLLED ENVIRONMENTS). Product requirements are determined at the time of the contract review with the customer. The Safety and Security Manager, who schedules job safety training, reviews safety issues and OSHA requirements that affect each new employee, current employees, and product safety requirements. A) TM will establish documented requirements for health, cleanliness, and clothing of personnel if contact between such personnel and the product or work environment could adversely affect the quality of the product. B) Where work environment conditions can have an adverse effect on product quality, TM will establish documented conditions and documented procedures to monitor and control work environment conditions. C) TM will ensure that all personnel who are required to work temporarily under special environmental conditions within the work environment are appropriately trained or supervised by trained personnel. D) Special precautions are established to control contaminated or potentially contaminated product in order to prevent contamination of other product, the work environment or personnel. 0640 REFERENCE DOCUMENTATION TMP-64.02 SOP-30.51 ENVIRONMENTAL CONTROL AND MONITORING PROGRAM PERSONNEL RESPONSIBILITIES IN CONTROLLED ENVIRONMENTS TAPEMARK COMPANY CONFIDENTIAL PAGE 20 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0700 ISSUED DATE: 09/03/2014 PRODUCT REALIZATION 0710 PLANNING OF PRODUCT REALIZATION TM will plan and develop the processes needed for product realization. If a particular development project or customer request cannot be fulfilled by existing procedures, quality plans are created to ensure that the specific requirements are met. Planning of product realization will be consistent with the other processes of the QMS (see TMP-73.03 - PROJECT DEVELOPMENT AND DESIGN CONTROLS). Documented requirements for risk management throughout product realization are specified in TMP-81.01 – RISK MANAGEMENT and SOP-18.02 – RISK MANAGEMENT – Travanti Medical™. In planning product realization, TM has determined the following, as appropriate: A) Identification and acquisition of necessary controls, equipment, fixtures, resources, and skills needed to achieve quality objectives and requirements for the product. B) Provision for procedures, work instructions, inspections, tests, resources, etc. to ensure product is manufactured to customer expectations and requirements. C) Required verification, validation, monitoring, inspection, and test activities specific to the product and the criteria for the product acceptance. D) Identification and preparation of quality records to provide evidence that the realization processes and resulting product meet requirements, as well as for the clarification of acceptable standards and requirements of finished product (see section 0424 Control of Records). 0710 REFERENCE DOCUMENTATION TMP-73.03 TMP-81.01 SOP-18.01 SOP-18.02 PROJECT DEVELOPMENT AND DESIGN CONTROLS RISK MANAGEMENT DESIGN CONTROL – TRAVANTI MEDICAL™ RISK MANAGEMENT – TRAVANTI MEDICAL™ 0720 CUSTOMER-RELATED PROCESSES 0721 DETERMINATION OF REQUIREMENTS RELATED TO THE PRODUCT Contract review activities include the following: A) TM personnel will work one on one with the customer to clearly achieve an understanding and document the customer’s requirements as to the product, delivery, post delivery, and other critical factors needed to meet and exceed expectations (see section 0730 Design and Development). B) TM will apply all related knowledge not stated by the customer’s requirements to meet or exceed product expectations. C) TM is responsible for identifying, documenting, and reviewing design input from the customer, including statutory and regulatory requirements as contractually agreed upon. D) TM will include any additional requirements determined for product conformance. TAPEMARK COMPANY CONFIDENTIAL PAGE 21 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0722 REVIEW OF REQUIREMENTS RELATED TO THE PRODUCT TM reviews the requirements related to the product. This review is conducted prior to the commitment of a quotation or acceptance of an order (see SOP-36.16 - CONTRACT REVIEW). Prior to entering an order into the TM computer system, verbal or written customer orders are reviewed carefully to ensure that: A) The order is clearly understood, adequately documented, and product requirements are defined. B) Any differences between the contract and the quotation with the customer are resolved prior to acceptance. C) TM has the ability to meet the defined requirements. Records of contract reviews and actions arising from the review are maintained. When the customer provides no documented statement of requirement, TM confirms the customer requirements prior to acceptance. Where product requirements are changed, TM ensures that relevant documents are amended and the relevant personnel are made aware of the changed requirements. 0723 CUSTOMER COMMUNICATION TM has determined and implemented effective arrangements for communicating with customers in relation to: A) Product information. B) Inquiries, contracts, or order handling including amendments. C) Customer feedback, including customer complaints. (see SOP-18.03 – COMPLAINT PROCESSING AND RESOLUTION – TRAVANTI MEDICAL™ and SOP-30.46 – CUSTOMER COMPLAINTS) D) Advisory notices (see 0851) 0720 REFERENCE DOCUMENTATION SOP-18.03 SOP-30.46 SOP-36.16 COMPLAINT PROCESSING AND RESOLUTION – TRAVANTI MEDICAL™ CUSTOMER COMPLAINTS CONTRACT REVIEW TAPEMARK COMPANY CONFIDENTIAL PAGE 22 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0730 DESIGN AND DEVELOPMENT 0731 DESIGN AND DEVELOPMENT PLANNING TM plans and controls the design and development of the product. Procedures to control and verify designs at TM are established and maintained to ensure that customer requirements are met (see the SOP-18.01 – DESIGN CONTROL – TRAVANTI MEDICAL™ and TMP-73.03 - PROJECT DEVELOPMENT AND DESIGN CONTROLS). During the design and development planning, TM will determine: A) The design and development stage. B) The review, verification, validation, and design transfer activities that are appropriate to each design and development stage. C) The responsibilities and authorities for design and development. TM will manage the interfaces between different groups involved in design and development to ensure effective communication and clear assignment of responsibility. Planning output will be updated, as appropriate, as the design and development progresses. 0732 DESIGN AND DEVELOPMENT INPUTS Inputs relating to product requirements are determined and records maintained. These inputs include: A) Functional performance and safety requirements according to intended use. B) Applicable statutory and regulatory requirements. C) Where applicable, information derived from previous similar designs. D) Other requirements essential for design and development. E) Outputs of risk management (see 0710) These inputs are reviewed for adequacy and approved. Any incomplete, ambiguous, or conflicting requirements are resolved. Consideration is given to contract review activities throughout the stages of the design process (see section 0720 Customer-related Processes). TAPEMARK COMPANY CONFIDENTIAL PAGE 23 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0733 DESIGN AND DEVELOPMENT OUTPUTS Design output is documented in such a manner that it can be verified and validated against design input requirements prior to release. Design and development outputs will: A) Meet the design-input requirements. B) Provide appropriate information for purchasing, production and for service provision. C) Contain or reference product acceptance criteria. D) Specify those characteristics that provide for the safe and proper functioning of the product when identified by the customer. Records of the design and development outputs are maintained. 0734 DESIGN AND DEVELOPMENT REVIEW Design input requirements are reviewed for adequacy prior to developing design output. At suitable stages, systematic reviews of design and development are performed in accordance with planned arrangements. These reviews are planned and conducted to evaluate the ability of the results of design and development to meet requirements, as well as to identify any problems and propose necessary actions. Participants of design reviews can include representatives of functions concerned with the design being reviewed, as well as other technical personnel, as required. Records of Design Reviews are maintained. 0735 DESIGN AND DEVELOPMENT VERIFICATION Verification is performed in accordance with planned arrangements (see section 0731 Design and Development Planning), ensuring that design output requirements have been reviewed to the designinput requirements and have been met. Design verification includes activities such as: performing calculations, comparing new designs with similar designs, conducting tests and experiments, and/or reviewing the design documents before release as applicable. The verification results and any necessary follow up actions needed are recorded and maintained. TAPEMARK COMPANY CONFIDENTIAL PAGE 24 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0736 DESIGN AND DEVELOPMENT VALIDATION Design and development validation is performed in accordance with planned arrangements (see section 0731 Design and Development Planning) to ensure that the resulting product is capable of meeting the requirements for the specified application or intended use where known. Wherever practicable, validation is completed prior to the delivery or implementation of the product. Quality Assurance maintains records of the validation approval. (see TMP-73.02 – VALIDATION AND QUALIFICATION OF MANUFACTURING PROCESSES AND TESTING METHODS) 0737 CONTROL OF DESIGN AND DEVELOPMENT CHANGES When applicable, design and development changes are identified and records are maintained. Changes are reviewed, verified, and validated as appropriate, and approved prior to being implemented. The review of design and development changes will include evaluation of the effect of changes on constituent parts and/or product already produced when applicable. Quality Assurance maintains records of the results of changes and any necessary actions. 0730 REFERENCE DOCUMENTATION TMP-73.02 TMP-73.03 SOP-18.01 VALIDATION AND QUALIFICATION OF MANUFACTURING PROCESSES AND TESTING METHODS PROJECT DEVELOPMENT AND DESIGN CONTROLS DESIGN CONTROL – TRAVANTI MEDICAL™ 0740 PURCHASING 0741 PURCHASING PROCESS TM ensures that purchases product conforms to specified purchasing requirements. The type and extent of control applied to the supplier and the purchased product will be dependant upon the effective of the purchased product on subsequent product realization of the final product (see TMP-63.05 - MATERIALS CONTROL). TM will evaluate and select suppliers on their ability to supply product (including outsourced processes) in accordance with the organization’s requirements (see SOP-33.06 - SUPPLIER AND MATERIALS SELECTION & APPROVAL). Criteria for selection, evaluation, and re-evaluation have been established. Records of the results of the evaluations and any necessary actions arising from the evaluation are maintained. 0742 PURCHASING INFORMATION Purchasing information will describe the product to be purchased, including where appropriate: A) Requirements for approval of product, procedures, processes, and equipment. B) Requirements for qualification of personnel. C) Quality management system requirements. TM will ensure the adequacy of specified purchase requirements prior to their communication to the supplier. TAPEMARK COMPANY CONFIDENTIAL PAGE 25 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 TM will maintain relevant purchasing records to ensure required traceability. 0743 VERIFICATION OF PURCHASED PRODUCT- Inspection and Testing TM has established and implemented inspection or other activities necessary for ensuring that purchased product meets specified purchase requirements (see SOP-31.17 - INCOMING INSPECTION PROCEDURE). When TM or its customer intends to perform verification at the supplier’s premises, TM will state the intended verification arrangements and method of product release in the purchasing information. 0740 REFERENCE DOCUMENTATION TMP-63.05 SOP-31.17 SOP-33.06 MATERIALS CONTROL INCOMING INSPECTION PROCEDURE SUPPLIER AND MATERIALS SELECTION AND APPROVAL 0750 PRODUCTION AND SERVICE PROVISION 0751 CONTROL OF PRODUCTION AND SERVICE PROVISION–GENERAL REQUIREMENTS (see TMP-75.02 MANUFACTURING OF PRODUCT FOR COMMERCIAL USE) 07511 CONTROL OF PRODUCTION AND SERVICE PROVISION TM plans and carries out production under controlled conditions, which will include, as applicable: A) Availability of product characteristic description information. B) Availability of procedural work instructions, where the absence would adversely affect quality. C) Use of suitable equipment. D) Availability and use of monitoring and measuring devices. E) Implementation of monitoring and measuring. F) Implementation of suitable release, delivery, and post-delivery activities. G) Implementation of defined operations for labeling and packaging. TM does not perform post delivery servicing of product, unless service is a direct result of product not meeting contractual requirements agreed upon at the time of contract acceptance (see section 0721 Determination of Requirements Related to the Product). TM will establish and maintain a record (see section 0424 Control of Records) for each batch that provides traceability to the extent specified in (section 0753 Identification and Traceability) and TAPEMARK COMPANY CONFIDENTIAL PAGE 26 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 identifies the amount manufactured and the amount approved for distribution. The batch record will be verified and approved. 07512 CONTROL REQUIREMENTS OF PRODUCTION AND SERVICE PROVISION–SPECIFIC 075121 CLEANLINESS OF PRODUCT AND CONTAMINATION CONTROL TM will establish documented requirements for cleanliness of product if: A) Product is cleaned by TM prior to sterilization and/or its use, or B) Product is supplied non-sterile to be subjected to a cleaning process prior to sterilization and/or its use, or C) Product is supplied to be used non-sterile and its cleanliness is of significance in use, or D) Process agents are to be removed from product during manufacture. If product is cleaned in accordance with A) or B) above, the requirements contained in 0640 A) and 0640 B) do not apply prior to the cleaning process. 075122 INSTALLATION ACTIVITIES TM currently does not provide any installation activities / services for its customers. 075123 SERVICING ACTIVITIES TM currently does not provide any servicing activities for its customers. 07513 PARTICULAR REQUIREMENTS FOR STERILE MEDICAL DEVICES TM currently does not provide contract services for sterile medical devices for its customers. TAPEMARK COMPANY CONFIDENTIAL PAGE 27 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0752 VALIDATION OR PROCESSES FOR PRODUCTION AND SERVICE PROVISION 07521 GENERAL REQUIREMENTS TM will establish processes for production and service requirements when continuous monitoring or measurement cannot verify the resulting output. This includes any processes where deficiencies become apparent only after the product has been delivered or in use. Validation is demonstrated by the ability of these processes to achieve planned results (see TMP-73.02 – VALIDATION AND QUALIFICATION OF MANUFACTURING PROCESSES AND TESTING METHODS) TM will establish arrangement for these processes including, as applicable: A) Defined criteria for review and approval of the processes. B) Approval of equipment and qualification of personnel. C) Use of specific methods and procedures. D) Requirements for records (see section 0424 Control of Records). E) When necessary, activities are implemented to revalidate a process. TM has established documented procedures for the validation of computer software (and changes to such software and / or its application) for production and service provision that affect the ability of the product to conform to specified requirements. Such software applications will be validated prior to initial use. Records of validation will be maintained. 07522 PARTICULAR REQUIREMENTS FOR STERILE MEDICAL DEVICES TM currently does not provide contract services for sterile medical devices for its customers. 0753 IDENTIFICATION AND TRACEABILITY 07531 IDENTIFICATION TM has established documented procedures for suitably identifying product throughout product realization. TM has established documented procedures for identifying and distinguishing returned product from conforming product. 07532 TRACEABILITY 075321 GENERAL TM has established documented procedures for traceability which define the extent of product traceability and the records required. TAPEMARK COMPANY CONFIDENTIAL PAGE 28 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 Where traceability is required, TM controls and records the unique identification of products. 075322 PARTICULAR REQUIREMENTS FOR ACTIVE IMPLANTABLE MEDICAL DEVICES AND IMPLANTABLE MEDICAL DEVICES TM currently does not provide contract services for active implantable medical devices and implantable medical devices for its customers. 07533 STATUS IDENTIFICATION TM identifies product status with respect to monitoring and measuring requirements. TM will identify the product by suitable means throughout the product realization (see SOP-33.02 MATERIAL IDENTIFICATION & TRACEABILITY). TM will identify the product status with respect to monitoring and measurement requirements (see SOP-30.19 – RAW MATERIAL AND PRODUCT STATUS IDENTIFICATION). TM will control and record the unique identification of the product (see section 0424 Control of Records). 0754 CUSTOMER PROPERTY TM maintains and follows documented procedures for controlling, verification, and storage of customer supplied product used in the production of finished product. Upon receipt of customer-supplied product (CSP), TM accepts responsibility to identify, verify, protect, and safeguard the product while it is in TM’s possession (see SOP-36.23 - CUSTOMER PROPERTY). Damaged, lost, or otherwise unsuitable customer-supplied product is identified, recorded, and reported to the customer. Receiving procedures are followed (see section 0743 Verification of Purchased Product). Records will be maintained. 0755 PRESERVATION OF PRODUCT Procedures are established, documented, and maintained for identification, handling, storage, packaging, preservation, and delivery of product. Incoming raw material, tooling, and TM manufactured product is protected up to and during delivery as documented in procedures. These procedures have been developed to ensure compliance with the customer’s requirements or accepted commercial practices (see SOP-33.09 MATERIAL HANDLING, SOP-33.03 - MATERIAL QUALITY CONTROL AND FLOW, SOP33.05 - SHIPPING) Preservation will also apply to the constituent parts of a product as applicable. 0750 REFERENCE DOCUMENTATION TAPEMARK COMPANY CONFIDENTIAL PAGE 29 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q TMP-73.02 TMP-75.02 SOP-30.19 SOP-33.02 SOP-33.03 SOP-33.05 SOP-33.09 SOP-36.23 ISSUED DATE: 09/03/2014 VALIDATION AND QUALIFICATION OF MANUFACTURING PROCESSES AND TESTING METHODS MANUFACTURING OF PRODUCT FOR COMMERCIAL USE RAW MATERIAL AND PRODUCT STATUS IDENTIFICATION MATERIAL IDENTIFICATION & TRACEABILITY MATERIAL QUALITY CONTROL AND FLOW SHIPPING MATERIAL HANDLING CUSTOMER PROPERTY 0760 CONTROL OF MONITORING AND MEASURING DEVICES TM had determined the monitoring and measurement to be undertaken and the monitoring and measuring devices needed to provide evidence of product conformity to be determined. TM has established processes to ensure that monitoring and measurement can be carried out and are carried out in a manner that is consistent with the monitoring and measurement requirements (see TMP-75.05 - MEASURING AND MONITORING DEVICE CONTROLS). When necessary to ensure valid results, measuring equipment will be: A) Calibrated or verified at specified intervals, or prior to use, against measurement standards traceable to international or national measurement standards. Where no such standards exist, the basis used for calibration or verification will be recorded. B) Adjusted or re-adjusted as necessary. C) Identified to enable the calibration status to be determined. D) Safeguarded from adjustments that would invalidate the measurement results. E) Protected from damage and deterioration during handling, maintenance, and storage. In addition, TM assesses and records the validity of the previous measuring results when the equipment is found not to conform to requirements. TM takes appropriate action on the equipment and any product affected. Records of the results of calibration and verification are maintained When used in the monitoring and measurement of specified requirements, the ability of computer software to satisfy the intended application is confirmed (see TMP-63.07 – SOFTWARE VALIDATION AND CHANGE CONTROL). This is undertaken prior to the initial use and reconfirmed as necessary. 0760 REFERENCE DOCUMENTATION TMP-63.07 TMP-75.05 SOFTWARE VALIDATION AND CHANGE CONTROL MEASURING AND MONITORING DEVICE CONTROLS TAPEMARK COMPANY CONFIDENTIAL PAGE 30 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q 0800 ISSUED DATE: 09/03/2014 MEASUREMENT, ANALYSIS AND IMPROVEMENT 0810 GENERAL TM plans and implements monitoring, measuring, analysis, and improvement processes needed to: A) Demonstrate conformity of the product. B) Ensure conformity of the QMS. C) Continually improve the effectiveness of the QMS. This will include the applicable methods, including statistical techniques and the extent of their use (see SOP31.25 - STATISTICAL CONTROL AND ANALYSIS). 0810 REFERENCE DOCUMENTATION SOP-31.25 STATISTICAL CONTROL AND ANALYSIS 0820 MONITORING AND MEASUREMENT 0821 CUSTOMER SATISFACTION As one of the measurement of the QMS, TM monitors information and maintains records on customer perception, including satisfaction and/or dissatisfaction as one of the measurements of the QMS’s performance objectives. The methods for obtaining and using this information are determined during management review meetings and are documented in the QMS (see SOP-36.19 - CUSTOMER SATISFACTION). 0822 INTERNAL AUDIT TM conducts internal audits at planned internals to determine whether: A) The QMS conforms to the planned arrangements (see section 0710 Planning of Product Realization) and to the QMS requirements established by TM. B) The QMS is effectively implemented and maintained. An audit program is planned, taking into consideration the status and importance of the processes and areas to be audited, as well as the results of previous audits. The audit criteria, scope, frequency, and methods are defined. Selections of auditors and conduct of auditors will ensure objectivity and impartiality of the audit process. Auditors will not audit their own work. The responsibilities and requirements for planning and conducting audits, and for the reporting results and maintaining records is defined in SOP-30.92 - INTERNAL AUDITING. TAPEMARK COMPANY CONFIDENTIAL PAGE 31 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 The management responsible for the area being audited will ensure that actions are taken without undue delay to eliminate detected nonconformities and their causes. Follow-up activities include the verification of the actions taken and the reporting of verification results (see section 0852 Corrective Action). 0823 MONITORING AND MEASUREMENT OF QMS PROCESSES As the need is identified, suitable methods of measuring and monitoring are developed, reviewed, and maintained to meet internal or external requirements in statistical technique procedures. Statistical techniques may be used for verification of customer requirements. Special training in statistical techniques may be given to employees; specific statistical methods are available for application. Statistical technique implementation and control is defined in documented procedures (see section 0810 General). The customer can request additional statistical techniques when contractually agreed upon. These methods demonstrate the ability of the processes to achieve the planned results. When planned results are not met, corrective action is taken as appropriate to ensure conformity of the product is achieved to meet product requirements. 0824 MONITORING AND MEASUREMENT OF PRODUCT 08241 GENERAL REQUIREMENTS TM has developed documented procedures for monitoring and measuring the characteristics of product to verify that product requirements have been met. This will be carried out at appropriate stages of the product realization process in accordance with the planned arrangements (see section 0710 Planning of Product Realization, SOP-31.07 - FIRST ARTICLE INSPECTION, SOP-31.40 IN-PROCESS INSPECTION AND TESTING, and SOP-31.41 - FINAL INSPECTION AND TESTING). Evidence of conformity with the acceptance criteria will be maintained. person(s) who authorized the release product. Records will indicate the Product release and service delivery will not proceed until the planned arrangements (i.e., inspection and testing) have been satisfactorily completed, unless otherwise approved by a relevant authority and where applicable, by the customer. 08242 PARTICULAR REQUIREMENTS FOR ACTIVE IMPLANTABLE DEVICES AND IMPLANTABLE DEVICES. TM currently does not provide contract services for active implantable medical devices and implantable medical devices for its customers. 0820 REFERENCE DOCUMENTATION SOP-30.92 SOP-31.07 SOP-31.40 SOP-31.41 SOP-36.19 INTERNAL AUDITING FIRST ARTICLE INSPECTION IN-PROCESS INSPECTION AND TESTING FINAL INSPECTION AND TESTING CUSTOMER SATISFACTION TAPEMARK COMPANY CONFIDENTIAL PAGE 32 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0830 CONTROL OF NONCONFORMING PRODUCT TM has developed procedures that ensure product, which does not conform to requirements are identified and controlled to prevent its unintended use of delivery. The controls are related responsibilities/authorities for dealing with nonconforming product are defined (see SOP-30.49 - NONCONFORMANCE MANAGEMENT) When dealing with nonconforming product, TM follows one or more of these methods: A) By taking action to eliminate the detected nonconformity. B) By authorizing its use, release, or acceptance under concession C) By taking action to preclude its original interned use or applicable. Product may be accepted by concession only if regulatory requirements are met and records of the identity of the person(s) authorizing the concession are documented. Records of non-conformances include information on the nature of the nonconformance and subsequent actions taken, including concessions obtained. These records are maintained in the documentation area. When non-conforming product is corrected it will be subject to re-verification to demonstrate conformity to requirements. When non-conforming product is detected after delivery or use has started, TM will take action appropriate to the effects, or potential effects, of the nonconformity. If product needs to be reworked (one or more times) TM will document the rework process in a work instruction that has undergone the same authorization and approval procedure as the original work instruction, a determination of any adverse effect of the rework upon product shall be made and documented. 0830 REFERENCE DOCUMENTATION SOP-18.03 SOP-18.06 SOP-30.12 SOP-30.49 COMPLAINT PROCESSING AND RESOLUTION – TRAVANTI MEDICAL™ RECALL AND FIELD SAFETY CORRECTIVE ACTION – TRAVANTI MEDICAL™ PRODUCT RECALL NON-CONFORMANCE MANAGEMENT TAPEMARK COMPANY CONFIDENTIAL PAGE 33 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0840 ANALYSIS OF DATA TM will establish a documented procedure to determine, collect, and analyze appropriate data to demonstrate the suitability and effectiveness of the QMS and to evaluate where continual improvement of the effectiveness of the QMS can be made. This will include data generated as a result of monitoring and measurement and from other relevant sources (see SOP-31.25 - STATISTICAL CONTROL AND ANALYSIS). The analysis of data will provide information relating to: A) Customer satisfaction (see section 0821 Customer Satisfaction). B) Conformity to product requirements (see section 0721 Determination of Requirements Related to the Product). C) Characteristics and trends of process and product including opportunities for preventive action. D) Suppliers (see section 0741 Purchasing Process). Records of the result of the analysis will be maintained. 0840 REFERENCE DOCUMENTATION SOP-31.25 STATISTICAL CONTROL AND ANALYSIS TAPEMARK COMPANY CONFIDENTIAL PAGE 34 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0850 IMPROVEMENT 0851 CONTINUOUS IMPROVEMENT TM will continually improve the effectiveness of the QMS through the use of the quality policy, quality objectives, quality auditing results, analysis of data, corrective / preventive actions, and management review. TM takes exception to developing documented procedures to issue and implementation of advisory notices defined in this portion of clause 8.5.1 of ISO 13485:2003 for all processes/products except TravantiMedical™. TM will not issue notification of advisory notices for any product other than TravantiMedical™ (Reference SOP-18.03 – COMPLAINT PROCESSING AN D RESOLUTION and SOP-18.06 - RECALL AND FIELD SAFETY CORRECTIVE ACTION. Our customer of all Tapemark contract manufactured products will maintain responsibility for issuing notification of advisory notices. Records of customer complaint investigations will be maintained. If investigation determines that the activities outside the organization contributed to the customer complaint, relevant information will be exchanged between organizations involved. If any customer complaint is not followed by corrective and / or preventive action, the reason will be authorized and recorded. TM takes exception to developing documented procedures and issuing notification of adverse events defined in this portion of clause 8.5.1 of ISO 13485:2003 for all processes/products except TravantiMedical™. TM will not issue notification of adverse events for any product other than TravantiMedical™ (Reference SOP-18.03 – COMPLAINT PROCESSING AN D RESOLUTION and SOP-18.06 - RECALL AND FIELD SAFETY CORRECTIVE ACTION. Our customer of all Tapemark contract manufactured products will maintain responsibility for issuing notification of adverse events. 0852 CORRECTIVE ACTION TM will take action to eliminate the cause of nonconformities in order to prevent recurrence. Corrective Actions will be appropriate to the effects of the nonconformities encountered. TM has established SOP-30.49 - NON-CONFORMANCE MANAGEMENT and SOP-30.45 – CORRECTIVE AND PREVENTIVE ACTION (CAPA) to define requirements for: A) Reviewing nonconformities (including customer complaints). B) Determining the causes of nonconformities. C) Evaluating the need for action to ensure that nonconformities do not recur. D) Determining and implementing action needed, including, if appropriate, updating documentation. E) Recording the results of any investigation and of action taken (see section 0424 Control of Records). F) Reviewing corrective action taken and its effectiveness. TAPEMARK COMPANY CONFIDENTIAL PAGE 35 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 0853 PREVENTIVE ACTION TM will take action to eliminate the causes of potential nonconformities in order to prevent recurrence. Preventive Actions will be appropriate to the effects of the potential nonconformities encountered. TM has established – SOP-30.49 NON-CONFORMANCE MANAGEMENT and SOP-30.45 – CORRECTIVE AND PREVENTIVE ACTION (CAPA) to define requirements for: a) Determining the potential nonconformities and their causes. b) Evaluating the need for action to prevent the occurrence of nonconformities. c) Determining and implementing action needed. d) Recording the results of any investigations and of action taken (see section 0424 Control of Records). e) Reviewing preventive action taken and its effectiveness. 0850 REFERENCE DOCUMENTATION SOP-18.03 SOP-18.06 SOP-30.45 SOP-30.49 COMPLAINT PROCESSING AN D RESOLUTION – TRAVANTI MEDICAL™ RECALL AND FIELD SAFETY CORRECTIVE ACTION – TRAVANTI MEDICAL™ CORRECTIVE AND PREVENTIVE ACTION (CAPA) NON-CONFORMANCE MANAGEMENT TAPEMARK COMPANY CONFIDENTIAL PAGE 36 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 GLOSSARY GENERAL TERMS: Customer: The recipient of a product manufactured and supplied by TM. Entity: That which can be individually described and understood. An entity may be for example: an activity or process, a product, an organization, a system or a person, or any combination thereof. Organization: A company, corporation, firm, enterprise or institution, or part thereof, whether corporate or not, public, or private that has its own function and administrator. Organization The responsibilities, authorities, and relationships arranged in a pattern, through which an Structure: organization performs it functions. Procedure: A specified way to perform an activity, usually in the form of a flowchart. Process: A set of interrelated resources and activities which transforms input into output. Product: The result of activities or processes. a) Product includes service, hardware, processed materials, software, or a combination thereof. b) A product can be tangible (assemblies or processed materials) or intangible (information on concepts, or a combination thereof). c) Product can be intended (offering to customers) or unintended (pollutant or unwanted effects). Purchaser: The recipient of a product provided by the supplier in a contractual situation. Service: The results generated by activities at the interface between the supplier and the customer by the supplier internal activities, to meet the customer needs. Subcontractor: The organization that provides a product or service to the supplier. TERMS RELATED TO QUALITY: Compatibility: The ability of entities to be used together under specific conditions to fulfill relevant requirements. Conformity: The fulfillment of specified requirements. Defect: The non-fulfillment of intended requirements, or a reasonable expectation, for use of an entity, including one concerned with safety. Inspection of: An activity such as measuring, examining, testing, or gauging one or more characteristics of an entity and comparing the results with specific requirements in order to establish whether conformity is achieved for each characteristic. Outsourced: Process or service that is provided by an outside contractor (eg: contract manufacturing, pest control, calibration services, laundry services, etc). Qualified: The status given to an entity when it has been demonstrated that it is capable of fulfilling specified requirements. Quality: The totality of characteristics of an entity that being on its ability to satisfy stated and implied needs. Requirements for An expressing of the needs of their translation into a set of quantitatively stated requirements for Quality: the characteristics of an entity to enable its realization and examination. Safety: The state in which the risk of harm or damage to persons is limited to an acceptable level. Verified/ Confirmation by examination and provision of objective evidence that specified requirements has Verification: been fulfilled. TAPEMARK COMPANY CONFIDENTIAL PAGE 37 of 38 QUALITY MANAGEMENT SYSTEM MANUAL REVISION – Q ISSUED DATE: 09/03/2014 GLOSSARY (Continued) TERMS RELATING TO THE QUALITY SYSTEM: Contract Review: The systematic activities carried out by the supplier before signing/accepting the contract or purchase order to ensure that the requirements for quality are adequately defined, free from ambiguity, documented and can be realized by supplier. Management A formal evaluation by top management of the status and adequacy of the quality system in Review: relation to the quality policy and objectives. Quality Control: The operational techniques and activities that are used to fulfill requirements for quality. Quality The actions taken throughout the organization to increase the effectiveness and efficiency of Improvement: activities and processes to provide added benefits to both the organization and its customer. Quality Manual: A document stating the quality policy and describing the quality system of the organization. Quality Plan: A document setting out the specific quality practices, resources and sequence of activities relevant to a particular product, project, or contract. Quality Policy: The overall intentions and direction of an organization with regard to quality as formally expressed by top management. Quality System: The organization structure, responsibilities, procedures, processes, and resources needed to implement quality management. Record: A document that furnishes objective evidence of activities performed or results achieved. Specification: A document stating requirements. Traceability: The ability to trace the history, application, or location of an entity, by means of recorded identifications. TERMS RELATING TO TOOLS AND TECHNIQUES: Corrective Action: An action taken to eliminate the cause(s) of an existing nonconformity, defect, or other undesirable situation in order to prevent recurrence. Disposition of The action to be taken to deal with an existing nonconforming entity in order to resolve the Nonconformity: nonconformity. Preventive Action: An action taken to eliminate the cause(s) of a potential nonconformity, defect, or other undesirable situation in order to prevent occurrence. Quality Audit: A systematic and independent examination to determine whether quality activities and related results comply with arrangements and whether these arrangements are implemented effectively and are suitable to achieve quality objectives. Quality Auditor: A person qualified to perform quality audits. Rework: The action taken on a nonconforming product so that it will fulfill the specified requirements. TAPEMARK COMPANY CONFIDENTIAL PAGE 38 of 38
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