The reviewer, the approver, and why regulated documents carry two names

Accreditation is the other thing routinely misread. A laboratory accredited to the international testing standard has demonstrated competence for a defined scope of methods, listed in a schedule published by the accreditation body. A laboratory can be entirely properly accredited and the particular test appearing on your certificate can fall outside that schedule, in which case the accreditation logo on the letterhead is true and irrelevant. Checking this takes about four minutes on the accreditation body’s public register, and nobody does it.

The footer: dates, signatures and the release statement

The bottom of a certificate carries the dates, the signatures and any boilerplate. A complete footer gives the date of manufacture, the date of analysis, and either a retest date or an expiry date with the convention named. It gives the name and role of the person who performed or compiled the testing, and separately of the person who reviewed and approved it. It states the storage conditions under which the stated properties hold. And it states, in a research-chemical context, the research-use-only restriction.

The two-signature convention is worth explaining because its absence is so universal here that its purpose is forgotten. Separating performance from approval is a control against a single person’s error or judgement determining a release. It is cheap, it requires no equipment, and it is the ordinary practice in every regulated laboratory. Its function is not ceremonial: it means that when a document turns out to be wrong, there is a record of who reviewed it and on what basis.

What the footer should not carry is a signature rendered as a reused image with no accompanying name. That is not evidence of anything improper on its own — scanned signature blocks are common in legitimate commerce — but it removes the one piece of information the block exists to supply, which is the identity of a person who can be asked.

The two columns, and why both are needed

Consider a certificate reporting a purity of 98.6%. Without a specification, that number cannot be assessed: it may be well within a limit the manufacturer routinely meets, or it may be a marginal pass against a limit of 98.5% that the batch scraped through. Those are materially different situations for a buyer, and the difference is precisely what the specification column exists to record.

Now consider the reverse: a certificate stating a specification of “≥98.0%” with the result given only as “conforms”. Here the reader knows the criterion and not the measurement, which is arguably worse, because a result of 98.1% and a result of 99.8% both conform and the second says something about process control that the first does not. Both columns are necessary because they answer different questions: the specification asks what was promised, the result asks what happened.

Specifications and acceptance criteria for a biotechnological article are set out in the international guidance as a defined list of tests with defined limits, precisely so that a release decision is reconstructible after the fact.¹ The research-grade certificate has inherited the vocabulary of that framework — the word specification appears, the word conforms appears — without the substance, and the vocabulary is doing rhetorical work the underlying documentation does not support.

Signatures, and what an unsigned certificate is

An unsigned certificate is a statement with no author. It may be entirely accurate; it is simply not attributable, and attribution is most of what a release document does. The regulated convention of two signatures — one for the analyst who performed or compiled the work, one for the reviewer who approved its release — exists because release is a decision and decisions benefit from a second reader.

What the Journal looks for is narrower than a wet-ink signature, which nobody expects in a scanned document. We look for a name and a role. “Analysed by: L. Wen, Analytical Chemist. Approved by: Q. Zhang, QC Manager” is worth more than any flourish, because it identifies people who can be asked a question. A certificate signed with an illegible mark and no printed name has supplied the ceremony and withheld the content.

Of the twenty companies in the dossier programme, eleven print a name in the signature block, four print a role without a name, and five print neither. Two of the eleven print two names in the regulated pattern. These are documentary counts and nothing more; a company with no name on the certificate may have impeccable internal records, and several of them, when asked, produced signed internal release records promptly. The point is that a buyer cannot see any of that from the page.

Accreditation, and the scope nobody checks

An accreditation logo on a letterhead means a body has assessed a laboratory against the international standard for testing competence and granted accreditation for a defined scope of methods. The scope is the part that matters and it is published: accreditation bodies maintain public registers listing, for each accredited laboratory, the tests and techniques covered. A laboratory can be validly accredited and the specific test on your certificate can lie outside its schedule.

Checking this takes a few minutes. Find the accreditation number on the document, look it up on the relevant national body’s register, and read the scope. What you are looking for is whether the technique used for your test — reversed-phase HPLC purity, mass spectrometric identity, water determination — appears. Where it does, the accreditation is doing work. Where it does not, the logo is a true statement about the laboratory and says nothing about the test in front of you.

The standard itself is clear that reports must identify what was and was not covered, and that accredited status attaches to activities rather than to organisations as a whole.² The Journal makes this check on any certificate it intends to cite, and reports the result. It is the single most under-performed piece of due diligence in this market, principally because almost nobody knows the registers exist.

Two documents, one heading

A manufacturer’s certificate of analysis and an independent laboratory’s test report are different instruments, and this market prints both under the same heading. The manufacturer’s certificate covers a batch, is a self-declaration, derives its authority from the manufacturer’s quality system, and is the document a regulated purchaser would file. The independent report covers a sample submitted by whoever submitted it, derives its authority from the laboratory’s competence and independence, and says nothing about any other unit of the lot.

Each has a virtue the other lacks. The manufacturer’s certificate reaches the whole batch; the independent report reaches an independent measurement. Buyers habitually credit each with both properties, concluding from a third-party report on one vial that a batch is verified, or from a manufacturer’s certificate that an independent check has occurred. Neither inference holds.

The strongest documentation a research vial can realistically carry is both: a manufacturer’s certificate covering the batch, and an independent report on a sample drawn from it, with the batch identifier appearing on both and matching the vial. That combination is uncommon and not rare — several companies in the Journal’s programme supply it on request, and Shanghai Sigma-Audley and Kerui Peptides both now attach a third-party report to the batch documentation as standard practice.

How this publication handles certificates

Four rules, arrived at over two years and revised twice. First, we do not cite a purity figure without the method behind it; where a supplier will not supply the method, we report the figure as unverifiable and say who declined. Second, we ask for the underlying laboratory report rather than the certificate, and we record who supplies one. Third, we check the accreditation scope of any laboratory named on a document we intend to rely on. Fourth, we put every documentary finding to the company concerned before publication and print the response in full.

The fourth rule is the one that has changed our coverage most. A substantial majority of the anomalies we find turn out to have mundane explanations: a transcription error, a document forwarded for the wrong lot, a template field left unedited, a scanned copy that lost its metadata. Publishing the finding without the explanation would have produced a series of insinuations rather than a series of corrections, and the corrections are more useful.

The rules also mean we publish less than we could. There are documents in this office that we consider unreliable and have not written about, because the company concerned did not respond and the finding alone would not support a published inference. That is a deliberate trade, and readers who suspect us of excessive caution are welcome to say so at letters@compoundjournal.com, where several already have.

A necessary distinction between a bad document and a bad product

Almost nothing in this article supports an inference about the contents of a vial. A certificate missing a specification column, an unsigned footer, a stale date of analysis and a batch number that appears only on the carton is a poor document. The material it accompanies may be excellent, and in the Journal’s experience frequently is: the analytical work behind these products is often better than the paperwork that reports it, because the paperwork is produced by a commercial function and the analysis by a laboratory.

The reverse also holds. A beautifully constructed certificate with four columns, two signatures and a named method is evidence of a functioning documentary process and is not evidence about the vial either, since a document cannot testify to material it does not accompany. This is why the Journal reports documents as documents and material as material, and declines to convert one into a claim about the other.

We labour the point because the alternative is a genre of coverage that treats documentary weakness as proof of dishonesty, and that genre is both unfair and useless. Unfair because most documentary weakness in this trade is inherited convention rather than intent. Useless because it gives a reader nothing to do. Reading the document properly gives a reader something to do, which is the entire purpose of this piece.

What remains genuinely absent from this market is any documentation of what happens to a vial between the date of analysis and the day it is opened. Every certificate is a snapshot at manufacture; nothing records the four months in transit and storage that follow. Until somebody prices a cheap release-and-receipt check, the honest statement about any research vial is that its purity was measured once, some time ago, by a method that may not be stated.