Location(s): Title: Document Number: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual QMS-004 Revision: E Owner: Joe Coscia Supplier Quality Manual Page 1 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia Table of Contents 1 2 3 4 GENERAL REQUIREMENTS ................................................................................................... 4 1.1 Quality Management Systems (QMS) & Audits .............................................................. 4 1.2 Waiver / Deviation of Requirements ................................................................................ 4 1.3 Special Process Suppliers ............................................................................................... 5 1.4 Sub-Tier Supplier Requirements ..................................................................................... 5 1.5 Restricted, Controlled, and Reportable Substances ....................................................... 5 1.6 Contingency Planning ...................................................................................................... 6 QUALITY REQUIREMENTS ..................................................................................................... 6 2.1 Lot Coding (Serialization) ................................................................................................ 6 2.2 Identification & Traceability .............................................................................................. 6 2.3 Shipment Related Documents ......................................................................................... 7 2.3.1 Product/Process Certificate of Conformance ............................................................ 8 2.3.2 Raw Material Certificate of Conformance ................................................................... 8 2.4 Change Notification ......................................................................................................... 8 2.5 First Article Sample Requirements (FAS) / Production Approval .................................... 9 2.6 Process Capability/Risk Assessment .............................................................................. 9 2.7 Inspections & Sample Plans ............................................................................................ 9 2.8 Symmetry Medical Inc. Supplied Material ..................................................................... 10 2.9 Control of Inspection, Measuring and Testing Equipment............................................. 10 Cleaning (categorized as a special process) .......................................................................... 10 3.1 Marking – Screen Printing ............................................................................................. 10 3.2 Welding (Excluding Casting and Forging operations per specific specifications) ......... 10 3.3 Documentation Accuracy and Legibility......................................................................... 11 3.4 Records/ Archiving......................................................................................................... 11 3.5 Commercial or Subcontracted Storage Facility Requirements……………………………11 3.6 International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR)…………………………………………………………………………………………12 3.7 Foreign Object Detection (FOD) Policy………………………………………………………...…………………………………12 3.8 Calibration and Laboratory Testing Suppliers……………………………………………………………….………………………12 SUPPLIER PERFORMANCE & EVALUTION ........................................................................ 13 4.1 Nonconforming Material ................................................................................................ 13 4.2 Supplier Corrective/Preventive Actions ......................................................................... 13 4.3 Supplier Performance .................................................................................................... 14 5 Requirements for Change Notification .................................................................................... 14 6 Receipt and Acceptance of this Agreement ............................................................................ 16 Page 2 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: Document Number: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual QMS-004 Revision: E Owner: Joe Coscia INTRODUCTION We at Symmetry Medical Inc. are dedicated to continuously striving to meet our customer’s goals by expecting the best from our suppliers. We ask you, our supplier, to join us in providing the best products to our customers with respect to Quality, Delivery and Price. This manual is designed in conjunction with the requirements of ISO 9001, ISO 13485, CDMDCAS, PAL, AS 9100, NADCAP, and the FDA Quality System Regulations/Good Manufacturing practices to help you understand all the expectations that Symmetry Medical Inc. requires for supplied goods and product/process related services. COMPANY OVERVIEW & PROFILE Symmetry Medical Inc. is the leading provider of implants, instruments and cases to the global orthopedic industry by specializing in precision forging and machining, as well as providing specialized products and services to the aerospace market. The Company designs, develops and produces these products for companies in other segments of the medical device market, including dental, osteobiologic and endoscopy sectors, and provides specialized products and services to non-healthcare markets. SYMMETRY MISSION Symmetry Medical Inc. is dedicated to providing quality products and services for all our customers; both internal and external. We are committed to the statutory and regulatory requirements and maintaining the effectiveness of our quality management system. The foundation of our success is the people. It is through our commitment to employee development and continuous improvement that we are able to achieve our quality objectives and meet our customers’ expectations. OBJECTIVES OF THIS MANUAL The purpose of this Manual, in conjunction with the purchase order general terms and conditions and long term agreement (if applicable), is to establish the quality assurance and purchasing requirements for our suppliers when providing a product or service. Where conflicts exist, the long term agreement / purchase order requirements take precedence over the requirement(s) in this manual. Facility purchasing/quality will determine on a case by case basis as to which suppliers are excluded from the requirements of this manual. Please review the content of this manual and document any exceptions or areas that do not apply to the products or services you provide or those areas where further clarification is required on the acceptance page at the end of this document. Contact Symmetry supplier quality to discuss these areas prior to signing the agreement. Once in agreement, please sign the receipt and acceptance of this agreement. Page 3 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia 1 GENERAL REQUIREMENTS 1.1 Quality Management Systems (QMS) & Audits A supplier may be required to maintain a QMS. If it is deemed necessary, those suppliers may be required to participate in supplier QMS audit to ISO / AS / NADCAP / FDA / CDMDCAS / PAL as determined by Symmetry Medical Inc. This determination will be derived from the evaluation of the following, but not limited to: risk association, products or services being rendered, frequency of purchase, special requirements (e.g. customer dictated), etc. The audit is designed to give the supplier feedback on how well their processes and system align with specified standard(s) and Symmetry Medical requirements. Right of Entry: Symmetry Medical as well as its Customers and Regulatory Agencies reserve the right to audit all process steps taken to ensure the quality of its products and to verify the conformance to the requirements defined in this document and other purchasing agreements. NOTE: Where suppliers systems are not in compliance with all applicable ISO/AS/NADCAP/ FDA/CDMDCAS/PAL standards/regulations, Symmetry Medical Inc. will confirm the supplier’s systems revolving around identification and traceability, document and material control, training, process control, nonconforming product control, corrective action activities, maintenance/preventive maintenance, and calibration systems to assure compliance to the regulations, subsequently mitigating any associated risks, relative to quality or product integrity. 1.2 Waiver / Deviation of Requirements Symmetry Medical Inc. Quality/Purchasing may waive any portion of these requirements as deemed necessary. Federal and State laws and regulations cannot be waived. This waiver shall be communicated to the supplier in writing; verbal waivers are not permitted. Suppliers providing services in accordance with applicable Current Good Manufacturing Practice (cGMP) and / or Good Laboratory Practice (GLP) regulations may be allowed exemptions from appropriate paragraphs of this manual. A Supplier may seek a deviation request or waiver request on product manufactured for Symmetry Medical Inc. that is nonconforming. Deviation Request form may be obtained from Symmetry Purchasing department or supplier may submit request on an internal form. Adequate time must be allowed to process request without affecting original due date. When seeking any deviation, product shall NOT be shipped to Symmetry Medical Inc. or their designee prior to the written notification of acceptance. Deviations are approved by Symmetry Purchasing/Quality. Page 4 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: 1.3 QMS-004 Revision: E Owner: Joe Coscia Special Process Suppliers All suppliers performing the special processes, listed below, must have a documented quality system in place to validate products, processes, and inspection and test systems. This requirement applies to all Symmetry suppliers as well as their sub-contractors and/or other suppliers. Special Process definition: Where the results of a process cannot be fully verified by subsequent inspection and test, the process shall be validated with a high degree of assurance and approved according to established procedures. All special process suppliers must be approved by Symmetry Medical in advance. For a list of current approved special process providers, contact the appropriate Symmetry Medical purchasing agent. Special process services procured by Symmetry Medical Inc. are, but not limited to: Non-Destructive Testing (NDT) Heat Treating Chemical Processing Material Testing Lab Aerospace Suppliers: All suppliers of special processes must be NADCAP accredited for the process/service being procured. NADCAP accreditation may be waived only by Symmetry Medical Inc. Quality/Purchasing representatives. 1.4 Sub-Tier Supplier Requirements All suppliers are responsible for ensuring continued compliance to all requirements of sub-contractors (including any dictated suppliers). All suppliers shall request written authorization from Symmetry Medical Inc. prior to outsourcing any processes needed to complete PO requirements. In the event the supplier is permitted to utilize sub-tier suppliers, the supplier is responsible for communicating (flow down) all applicable terms and conditions and any other purchase order requirements. 1.5 Restricted, Controlled, and Reportable Substances All materials delivered under the Purchase Order shall satisfy current governmental and safety constraints or restricted toxic and hazardous materials; as well as environmental, electrical and electromagnetic considerations applicable to the country of manufacture and sale. Seller certifies that all goods, which qualify as chemical substances under the Toxic Substance Control Act (TSCA), have been registered on the official inventory of chemical substances maintained by the United States Protection Agency (EPA). Seller will provide immediate notice to buyer of any use restrictions, reporting requirements, or other obligations that the EPA imposes with respect to such goods. Page 5 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia All suppliers are required to maintain Material Safety Data Sheet (MSDS) on all manufacturing materials. Suppliers shall include with the first shipment and each revision of the product a copy of the Material Safety Data Sheet (MSDS) for such product. Suppliers performing service on a medical device component must comply with PROP65 list. All suppliers are required to comply with the obligations under the Dodd-Frank Wall Street Reform and Consumer Protection Act section 1502 requiring the supplier to disclose the purchase and/or use of conflict minerals including Gold, Tin, Tungsten and Tantalum that originated in the Democratic Republic of the Congo (DRC) and adjacent countries. All suppliers are required to notify Symmetry if any supplied product and/or material contain latex. Symmetry recommends that powder free non-latex gloves be used by suppliers. All suppliers that provide or perform a service on a medical device or implant are required to notify Symmetry if any animal tissue-derived materials are used in the manufacturing process or in any agent that will contact the device or implant. Some common sources of animal tissue-derived materials are polishing compounds (beef tallow), lubricants (fatty acids and fatty amines), and liquid soaps, lubricants, solvents (glycerol). Upon notification, Symmetry will work with the supplier to collect data, in accordance with FDA guidelines, and complete a risk assessment. 1.6 Contingency Planning Supplier shall have a documented contingency plan. The plan shall include, at a minimum, catastrophic key equipment failure, natural disasters common for the geographical region, and long term power loss. 2 QUALITY REQUIREMENTS 2.1 Lot Coding (Serialization) Materials procured by Symmetry Medical Inc. shall be consecutively lot coded. Individual lot codes or number series, for the deliverable material shall be marked on the Certificate of Conformance from the manufacturer or supplier. Where applicable the lot information would be provided by Symmetry Medical Inc. 2.2 Identification & Traceability The supplier is required to establish a documented system for the identification and traceability of all materials. The inspection and test status of all materials should be easily identifiable by the system, and documentation should include a description of any applicable containment areas and/or devices. Page 6 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia The following guidelines must be adhered to for both medical and aerospace product: The lot must be traceable from the moment the parts or materials enter the plant through the time of shipment. This information must be kept on file so that in case of failure it can be retrieved. Lot integrity cannot be broken. Parts are to remain with the lot that they arrived in and cannot be mixed with another lot. In the case of raw material, Symmetry Medical Purchasing must be notified before using material with a different Heat Code than the original heat issued to the work order so a new work order can be issued. Parts or products removed from the normal process flow must be segregated and clearly identified as nonconforming parts to prevent mixups. All prints and purchase orders must be adhered to 100% unless approved in writing by the appropriate personnel at Symmetry Medical. The supplier shall be able to provide a list of all manufacturing materials upon request. NOTE: per FDA 820.70 Regulation requirement: Where a manufacturing material could reasonably be expected to have an adverse effect on product quality, the manufacturer shall establish and maintain procedures for the use and removal of such manufacturing material to ensure that it is removed or limited to an amount that does not adversely affect the device’s quality. The removal or reduction of such manufacturing material shall be documented. 2.3 Shipment Related Documents When shipping an order to Symmetry Medical, the supplier shall furnish the following: Completed inspection forms (reference First Article Inspection). First Article ONLY Certificate of Conformance, including any sub-tier suppliers, as required per the PO. Test reports, including any sub-tier suppliers, as required per the purchase order. All prints and process instruction sheets. (Site specific requirement, reference PO) When applicable any excess material and all nonconforming parts. Any gages, fixtures, special tools, etc., as required per the purchase order. Packing list. Special Process and Material certifications. Country of Origin (COO) & Melting Source All packing lists and invoices must have the following information: Page 7 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 2.3.1 Revision: E Owner: Joe Coscia Part number. Vendor Batch/Lot number/Heat number Purchase order number. Quantity good and scrap. Shelf Life Expiration Date (where product has a limited useable life) Product/Process Certificate of Conformance A certificate of conformance is required stating the product conforms to all purchase order requirements. This certificate must contain the following at a minimum: 2.3.2 A signature by an authorized agent of the Supplier including the agent’s title and date PO number, Part name/description, drawing number and revision level Unique identification number such as a lot/serial number (if applicable) Quantity shipped Any other Supplier specific information as required per PO Special process and material certifications. Raw Material Certificate of Conformance All raw material stock, purchased directly or indirectly for Symmetry Medical, shall be certified to conform to its applicable Symmetry Medical Inc. specification and/or applicable standard/specification denoted on the Purchase Order/Print. All raw material (acquired or provided by a supplier) certifications must state the country of origin and the original melt source defining the chemical, mechanical properties and must accompany each shipment. Raw materials from China – Except for Titanium which require sourcing from specific Symmetry approved mills, it is permissible to use raw materials procured from China providing the Chinese sources are directly affiliated with U.S.A based companies. Notification to Symmetry Medical purchasing/quality is required prior to procuring non-titanium material(s) from sources in China. All material certifications must be in English or include English translation. 2.4 Change Notification Section 5.0 identifies changes requiring Symmetry Medical notification and approval. Suppliers shall notify Symmetry Medical Inc. in writing prior to change to allow evaluation of the effect of the change upon the end product or service being rendered. No changes shall proceed without written authorization to do so from Symmetry Medical Inc. Request must be received Page 8 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia by Symmetry to allow adequate time for review and disposition without affecting original delivery date. NOTE: per FDA 820.50 regulation requirement: Suppliers agree to notify Symmetry of any changes in their product, processes, or service so that we may determine whether the change may affect the quality of a finished device. 2.5 First Article Sample Requirements (FAS) / Production Approval When required by the PO, the Supplier shall perform a 100% inspection of all drawing characteristics and notes; the quantity of samples needed shall also be noted on the PO and any PO specific inspection requirements. An inspection report shall be submitted identifying each characteristic noted on the engineering drawing. The inspector shall record each characteristic and drawing note indicating acceptance status. A certification statement referencing the PO number, part number and revision level, unique identification number such as a lot/serial number (if applicable), and quantity inspected shall accompany the FAS/Production Approval. The signature and date of an authorized agent of the supplier performing the FAS/Production Approval including the agent’s title must appear on the certification. 2.6 Process Capability/Risk Assessment Where required by PO Process capability/risk needs to be quantified for all critical to quality features (CTQ’s), e.g. fit, form, function, labeling, marking and the corresponding sampling plan(s) need to be aligned with the recognized/demonstrated capability/risk, i.e. 2.7 greater than 1.33 Cp/Cpk, Pp/Ppk - 1.0 Sampling plan; less than 1.33 Cp/Cpk, Pp/Ppk - 100% inspection; or in lieu of statistical analysis, always 100% insp. CTQ’s Inspections & Sample Plans An inspection report, identifying the characteristics produced on the purchased part(s) with the applicable inspection results, is required with the shipment. This report is to be signed, dated, and traceable to the person performing the inspection. When the engineering drawing specifications or PO require 100% inspection or test, statistical sampling shall NOT be applied. Sampling procedure ANSI/ASQ Z1.4, current revision, shall be used. If sampling inspection is utilized, the plan shall not allow the acceptance of known defects in a lot, and 100% inspection shall be completed for any characteristic if it is found to be out of tolerance during sample method inspection. Sampling plan acceptance criteria is C=0. NOTE: In addition to quantified visual standards, the appropriate gage must be used to match the precision level of the print tolerance (e.g., 10:1 ratio between tolerance range being measured and gages ability to repeat and discriminate). Page 9 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: 2.8 QMS-004 Revision: E Owner: Joe Coscia Symmetry Medical Inc. Supplied Material The supplier shall choose one of two options when nonconforming product is generated from Symmetry Medical Inc. Supplied Material: 1. Return the product fully identified as scrap or nonconforming and segregated from conforming product. OR 2. Complete a deviation request to request that Symmetry Medical Inc. accept product as is. Refer to Purchase order general terms and conditions for additional requirements. 2.9 Control of Inspection, Measuring and Testing Equipment The supplier must have documented procedures to control, calibrate, and maintain inspection, measuring and test equipment used to demonstrate product conformance to required specifications. All inspection, measuring and testing equipment must be in compliance to the requirements of ISO17025 and/or traceable to the National Institute of Standards and Technology or equivalent international specification(s). 3 Cleaning (categorized as a special process) If cleaning is required all parts must be degreased and cleaned, preferably in a hot alkaline wash. Ultrasound cleaning is strongly recommended, notably for parts with significant surface roughness (parts subject to sandblasting, knurling, etc.). The use of products containing chlorine is prohibited. Tapped and blind holes must receive particular attention. Mounted units shall be cleaned both before and after assembly. Careful rinsing and drying shall follow all cleaning operations. 3.1 Marking – Screen Printing If marking is required, it must be in compliance with the supplied part drawing or instructions, and be biocompatible, indelible and fade-resistant, relative to handling, autoclave sterilization and alkaline wash products, etc. 3.2 Welding (Excluding Casting and Forging operations per specific specifications) All employees welding production hardware must be certified, per AWS D17.1:2001 “Qualification of Aircraft, Missile, and Aerospace Fusion Welders.” All Certified employees must be re-certified every 2 years. Welds must be machined and polished without destroying the weld bead and must not contain holes, cracks or porosity. Page 10 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: 3.3 QMS-004 Revision: E Owner: Joe Coscia Documentation Accuracy and Legibility The accuracy and legibility of the paperwork can be as critical as the dimensional accuracy of the product being manufactured. Examples of paperwork are Certificates of Conformance (Finished product and raw materials), Inspection paperwork (including first article and production inspection) and paperwork from subcontracted sources for work/processes done. All entries and sign-offs must be in blue or black ink 3.4 Records/ Archiving All product records related to the development, manufacturing, inspection, labeling, and packaging of implants and finished devices are to be kept available for 30 years. At the end of that time period, the supplier shall confer with Symmetry on how to proceed with these records. In case of termination of collaboration the supplier agrees to provide records to Symmetry in a timely manner. Alternatively, the supplier may commit to hand over all product records to Symmetry for archiving. In case of objection with regard to proprietary information, the supplier may choose to forward all records to a trustee. The use of a trustee shall be agreed with Symmetry in writing declaring the trustee concerned. These records shall be and shall remain legible, readily identifiable and retrievable. These records must be stored in safe conditions (i.e. in a room protected from fire, flooding, rodents, ultraviolet radiation and theft). All entries and sign offs must be in blue or black ink. Examples of product records are: inspection records, testing reports, NDT records, corrective action reports, personnel qualifications, C of C’s. 3.5 Commercial or Subcontracted Storage Facility Requirements The following requirements apply to commercial or subcontracted storage facilities used by Symmetry Medical and Symmetry Medical suppliers to store documents/records. All commercial or subcontracted storage facilities shall have a documented procedure for: Identification: Facility shall not cover, remove, duplicate, or make unreadable any marking/identification present on box/container at time of receipt. Supplier’s internal identification method may not obstruct customer marking/identification. Storage: Facility shall store documents in safe conditions to protect the integrity of container/documents. Storage area must be protected from fire, flooding, wild life, ultraviolet radiation, and theft or vandalism. Protection: Facility will document access to customer documents. Facility will ensure that documents are stored in an access controlled environment. Facility will limit access to Symmetry records to authorized personnel only. Authorized personnel will be defined in writing by storage facility and customer. Any Page 11 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia person requesting access to Symmetry documents will be checked against this list prior to authorizing access. Facility shall have a documented process for the identification, control, and customer notification for any damaged or opened boxes/containers. Retrieval: Documents shall be stored in such a way to allow prompt retrieval. Retention: facility shall store documents in accordance with stated requirements until such time as customer authorizes disposition, in writing. Facility shall ensure that requests for disposition are checked against the authorized personnel list prior to document disposition. Disposition: facility shall ensure disposition of records are performed in accordance with customer approved procedure. Facility shall notify customer prior to moving documents outside of the approved storage area. Facility shall notify customer when there have been any major changes in company management, facility, or financial conditions. Facility shall notify customer of any capacity issues and prior to reaching full capacity. 3.6 International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR) EAR and/or ITAR may be flowed down to suppliers in purchase orders, contracts, requisitions, or other written communications for certain aerospace product. If EAR or ITAR is flowed down to the supplier the supplier becomes subject to the federal laws governing EAR/ITAR. Suppliers should consult with the US State Department for any questions as Symmetry cannot offer legal advice. If your scope of work is limited to medical product then this section does not apply. 3.7 Foreign Object Detection (FOD) Policy Finished goods, special process, and suppliers performing any outside service on Symmetry product are required to have a documented FOD policy. This policy, at a minimum, must require preventing or detecting and removing any foreign debris that your process could have exposed the product to. Common examples of Foreign Object Debris are: Food, beverages, burrs, dirt, blast media, lubes, coolant, and metal/plastic shavings. 3.8 Calibration and Laboratory Testing Suppliers All supplier of calibration services are required to comply with the current version of ISO-17025, General Requirements for the Competence of Testing and Calibration Laboratories. In addition to complying with ISO-17025, Calibration and Laboratory Testing Suppliers shall; Page 12 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia a. Maintain any validated equipment in accordance with the documented validation plan and notify Symmetry of any changes to the validated state. b. Receive written approval from Symmetry for any deviation to ISO-17025 requirements. c. Provide calibration and laboratory test reports that comply with ISO-17025, Symmetry purchase order, and Symmetry Supplier Quality Manual requirements, unless otherwise agreed upon in writing. d. Provide reports free from blank spaces, errors, or invalid changes. If a hand written change is required to a report then a single line should be drawn through the error and the person performing the correction should record their initials or signature, the date of change, and the corrected text immediately next to where the error occurred. If a field on a report is not needed then “N/A” or similar verbiage must be recorded. e. Perform calibrations traceable to NIST standards. If no NIST standard is available then the standard used for calibration must be approved by Symmetry in writing. f. Seek written approval where methods used are not covered by Standard methods. g. Notify Symmetry if equipment used to perform testing or calibration for Symmetry is later found to be nonconforming or out of calibration. h. Notify Symmetry in any change in accreditation (ISO-17025, A2LA, NADCAP, etc.). i. Notify Symmetry of any change to sub-suppliers used to complete testing and/or calibration. j. Comply with all Company, state, and federal laws and regulations while on Symmetry property. This includes ITAR/EAR and all safety policies. 4 SUPPLIER PERFORMANCE & EVALUTION 4.1 Nonconforming Material If nonconforming material is discovered at Symmetry Medical Inc., or their designee, the supplier will be notified. If nonconforming material is discovered at the supplier, the supplier is required to immediately notify Symmetry Medical. 4.2 Supplier Corrective/Preventive Actions If a problem were to arise, Symmetry Medical may request the responsible supplier to perform a root cause and corrective action investigation. A detailed containment plan is due within 48 hours of discrepancy notification and is to include inventory levels at supplier, sub contractor(s), and any product in transit. Any containment plan should encompass any like product currently in process. The corrective/preventive action plan due date will be communicated Page 13 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia to supplier. Verification of the effectiveness of the corrective/preventive action is the responsibility of the supplier on the next production run. Verification is to be provided to Symmetry. 4.3 Supplier Performance Symmetry Medical Inc. monitors Supplier Quality and Delivery performance. Feedback will be provided to suppliers as appropriate. Each Symmetry facility will communicate the minimum expectations for delivery and quality. Suppliers failing to meet expectations may be required to submit correction action plan and/or be placed on new business hold. 5 Requirements for Change Notification The table below provides change notification requirements. Page 14 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: Document Number: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual QMS-004 Revision: Owner: E Joe Coscia Requirements for Change Notification Type of change or activity Production facility Special / Validated Processes* Implants NonImplants X X X Raw Matl Suppliers Examples (provided as an aid - not all inclusive) External supplier to in-house X3 Equipment Type of equipment X X Specific equipment X Movement of equipment w/in a facility X Reduced frequency or method of PM X Fixturing materials X X Subcontractor change X X X1 Inspection requirements X2 X2 X2 Production method that affects the composition and / or properties of the material X X Manufacturing materials that come in contact with the product X X Manufacturing process flow X X CNC Mill to CNC Lathe, CNC Mill to Manual Mill, Cutoff Mill to Saw, etc. X Bar sealer A to bar sealer B Acid change frequency Titanium jaws to aluminum jaws X Change from supplier A to supplier B, testing facilities for a product or service X4 Measurement methods, frequency reduction, changes to inspection criteria Heat treating, electropolish, forming, chemical processing, ingot processing, conversion processing, extrusion processing. Coolant, machine lubricants, polishing compounds, cleaning solutions, tumbling media, release agents X Re-sequencing, additions/deletions, rework X Rework not following original process Process parameters X Management / Company Ownership X X X X Top Management only Quality system registration changes X X X X Includes revocation, suspension Packaging, cleaning, and sterilization operations X X X Machine tooling design / Program X Design changes on non-customer designed finished devices X X X Time, temperature, pressure Changes in packaging materials, dose type and magnitude are reportable changes, Rinse cycles, cycle times, chemicals X1 – A subcontractor approved for supply of specific raw materials (ie 17-4 bar stock) may be used for any supplied non-implant using that material without requiring notifying Symmetry. X2 – Inspection changes that increase frequencies or change equipment to an instrument with higher accuracy and precision may be implemented before notifying Symmetry. However, the changes shall be communicated to Symmetry in a timely fashion. X3 – Addition of new melting methodology and/or new conversion equipment and/or extrusion equipment beyond current capabilities. Note: Adding additional equipment to increase capacity to an existing process does not require customer notification – qualify internally. X4 – Addition of a melting, conversion, and/or extrusion methodology not previously used. * Unless changes are specifically allowed within the Symmetry approved validation. Note: Multiple subcontractors, equipment, etc. that have historically been used on a given product, may continue to be used interchangeably without requiring notification. Page 15 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL Location(s): Title: SMA : SWI1; SMA : SNI; SMA : SLP; SMA : SEN; SMA : SAM; SMA : SRC; SMA : SMM Supplier Quality Manual Document Number: QMS-004 Revision: E Owner: Joe Coscia 6 Receipt and Acceptance of this Agreement Supplier acknowledges receipt of Symmetry Medical’s Supplier Quality Manual and understands Symmetry Medical’s requirements. Supplier agrees to maintain a quality system in compliance with these requirements. Supplier Company Name: Supplier Company Address: Supplier Representative Name: Supplier Representative Signature/Date: Identify sections which do not apply to your company or exceptions to the requirements listed: Symmetry purchasing acceptance to excluded sections and/or exceptions: _____________________________________________________________________________ Print Name Signature Date _____________________________________________________________________________ Print Name Signature Date Page 16 of 16 Valid Only on Date Printed: 2/13/2016 Effective Date: Sep 25, 2014 CONFIDENTIAL