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Micro specs in food vs Cosmetics
I have to use a food supplier for arrow root starch/flour materials. Their micro count for these products are much higher for the TPC than what I expected.. Example: <5000 or <100,000 . I understand the specs can be different between the industries but when we have to use food items like this can they be used with this high TPC count? Should I look for another suppliers? Irradiation?
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15 Replies
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Food standards are not acceptable for cosmetics.
Functionally, excessive microbial count in a raw material can put finished product over the quantitative limit for cosmetics - establishing an adulterated product. Even if processing (e.g. heat in making the cosmetic) eliminates the count, most would consider the raw material adulterated and therefore the product adulterated whatever the finished microbial content.
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I have contacted 2 cosmetic suppliers and they are telling they don’t have any supplies that could give me a TPC better than ~9000 cfu… Is this normal going into a cosmetic?
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A cosmetic grade would be gamma treated - https://www.makingcosmetics.us/certificate-of-analysis/coa-tapioca-starch.pdf
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Thank you so much! I have been round and round with the food manufacturer. They think its normal for starches to have these counts and are alright to use. I told them cosmetics do not have those standards. So how do you source “food type” raw materials? This is not the first time I have heard food suppliers wanting pass off food specs. for cosmetics….
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Food standards are associated with expectations of (often) heat treatment of finished food product, brief shelf life and established consumer “QC” practices (toss old, smelly, ugly, moldy, etc.). Cosmetics are rarely so treated in production, have effective shelf life of years and contamination is often not obvious.
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Thank you for answering me. I must ask with this expectation of the food industry is it a good idea to ask about irradiation of the food to ensure a good TPC count of a vendor? To beat a dead horse more…Is having a TPC count under 200 cfu/g considered “ok” or does it have to be totally under 100 cfu/g?
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For foods - QC counts are less important than what’s there - Salmonella, Listeria, coliforms etc. Hamburger has ~ million/gram and alot of E. coli. Grade A pastirized milk/ml not to exceed 20,000 tpc or 10 coliform. Think chips someplace have a 20,000/gram limit and no samonella.
Irradation - see https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=179&showFR=1. Be aware, appl can be limited to stuff like spices, NGO oppostion, labeling requirement in US that consumers may not like and i recall some countries constrain/ban irradiation of foods.
For cosmetics - FDA says 1000 in general and 100 for babies and eye.
Industry standard is <100 but in many applications there is no statistical difference between 100 and 200 in testing. Sounds odd - but you may be able justifiably to release with 200 with spec of 100. You can find thst justification on PMFlist. Most big guys control operating systems and raws to consistent no detect - something they need with high speed manufacturing and maximizing return.
Irradiation is problematic - it’s done routinely for earth derived raws like bentonite and talc but you can’t use it to fix an adulterated material - e.g. surfactant or shampoo contaminated/OOS with pseudomonas irradiated to sterility is still adulterated. If a RM supplier used irradiation- you should ask why. If there’s a problem with a raw in your product - it is your problem.
accessdata.fda.gov
CFR - Code of Federal Regulations Title 21
CFR - Code of Federal Regulations Title 21
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I am talking to a predominant food manufacturer about making my cosmetic product and preforming micro testing on the raw materials. They said they test micro against a AOAC/USP. Isn’t this for food industry. I asked them about performing USP 61/62 for micro or something similar. They were totally not familiar. How should I phrase this to do cosmetic micro testing so they can relay this to their testing lab?
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If they dont know 61/62 - wonder what they mean by knowing USP. There aren’t many other micro methods in USP. Show the methods - they’re online , can they run them?.
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Thank you again! The problem is they are trying to get us to run everything by food industry standards. They acted like they didn’t know what cosmetic specifications are for micro testing. I suggested they follow USP61/62. They are saying their testing lab is suggesting that AOAC/USP is the same as USP 61/62. Because they have been sent confusing information previously I am trying to confirm anything they say. How do I direct them to tell their 3rd party lab to just do normal cosmetic microtesting ( USP or their own validated methods)? There is a cost component to this also.
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There is no “AOAC/USP” - those are seperate compendia. Is this some in-house hybrid? Can you link the method they intend?
I understand they prob want to minimize complexity in their lab, but they sure aren’t being accomodating. Should I assume your business isn’t enough really to get their interest?
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No they are not being accommodating.
<font color=”rgba(0, 0, 0, 0)” face=”inherit”>They have have actually brought more confusion and don’t seem to understand cosmetic guidelines. We have their interest. I think they want us to move toward their comfort zone of being in food and not cosmetic. I think the 3rd party lab they are using should have their own methods for performing USP 61/62 normal cosmetic micro testing. How do can direct them into tell their 3rd party lab to just perform the labs cosmetic related micro testing with out suggesting a platform? </font>
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Ask who is 3rd party lab so you can talk directly. You want to confirm method, spec. and OOS protocol. Who will release? If not you - better be real confident if you delegate.
Please make sure to touch all the issues E.g. confirm micro spec - in QC micro, food guys are often more interested in the what and not the how many - for cosmetics its both and food whats are not the same as cosmetic whats.
How well in control is their water system?
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I have an idea of who their lab is. they wont specifically tell us. They can be on the call with us. I just want to move forward the best way. We have to get things check for global regulatory. This is frustrating to say the least. AOAC is for supplements, and food. Not sure how they equate this for beauty. our product is anhydrous so the water system is not need.
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You might offer that you want products tested to industry standards. Do not doubt for a moment that any legal action regarding product quality will observe “inappropriate” methods whether of technical signficance or not.
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