MarkBroussard
Forum Replies Created
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This would have been in the 2004 - 2008 timeframe as I was living in Portugal at the time. Different people are sensitive to different ingredients in different ways … my skin just reacted to it by peeling. No big deal, I just moved on to another product.
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Here’s the issue with the Paula’s Choice 2% BHA product … some consumers use it as a general exfoliant, some use it if they have acne.
There is a category where a product can be considered both a cosmetic and an OTC drug … this probably falls into that category.
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@Perry:
No point in worrying about something you cannot control, that being what may happen in the future. What you can do to protect yourself is not use “controversial” ingredients, keep track of the consumer trends and try to stay a step ahead.
Unless the government provides some sort of liability shield to companies that properly use ingredients that are approved by the FDA for use in cosmetic/personal care products, these class action lawsuits will certainly continue.
You would think that the large consumer products companies under attack would put pressure on politicians to effect some rational changes regarding the legal system. There’s a whole industry of law firms who specialize in consumer class action lawsuits.
As I mentioned, I had a client who was threatened by a consumer claiming they suffered burns on their face from a Hyaluronic Acid serum.
I can assure you that there is some ingredient or ingredient combination in the Tresemme product line that causes skin peeling. I have experienced it myself and confirmed that it is Tresemme Shampoo that caused that reaction on my skin.
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I understand your motivation, but the regulations are clear in this regard. If your product is not an OTC, then you can’t use the dissease name associated with your product in any way. Some companies take the chance hoping that the FDA will not become aware of the violation and fly under the radar until they get a violation notice.
The DermaHarmony product you are referencing above is indeed an OTC-registered product. They list Active Ingredient: 2% Salicylic Acid, so they are in compliance.
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To quote BobZChemist: “The customer isn’t always right, but the customer is the customer”
There are other alternatives for preservation … it’s not as though DMDM is the only preservation option available to formulators.
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When consumers speak … smart brands listen … it’s the most basic fundamental of marketing.
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Yep … peel like a snake shedding its skin when I use Tresemme.
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Why would you be putting the name of a skin condition (ie: disease) as part of the name of your product if not with intent to deceive consumers?
Reminds me … I need to dust that formula for Covid Cola off the shelf!
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I have no idea and did not really investigate regarding specific ingredients. I noticed that my hands started peeling quite badly and thought that perhaps Tresemme was the issue. Switched to Dove Creamy Sensitive Skin Body wash and the peeling went away. Tried Tresemme again and the peeling came back. Switched back to Dove and the peeling stopped. I did not notice any irritation on my scalp, interestingly enough.
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I once had a client who had to deal with a consumer who threatened to sue claiming that the consumer’s face was burned by the Hyaluronic Acid serum I developed. It only contained multi-molecular weight HA, water and preservative.
I suspect this will get settled out of court and J&J will replace DMDM in the OGX line.
BTW: I personally cannot use Tresemme shampoo … it literally makes the skin on my hands peel.
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Sucrose Stearate will not give you any viscosity build … your emulsion will be water-thin. If you are looking to formula a cream, you’ll need a companion emulsifier or thickeners to build viscosity. SS is a good emulsifier.
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@Bobzchemist … always valued his posts … anyone know of his whereabouts lately?
You missed a shout out to @chemicalmatt whose vast knowledge of the field is truly amazing.
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(1) Heat your water phase to 55C to dissolve both the Allantoin (0.5% maximum) and Geogard Ultra which is normally soluble in water at RT, but heat always helps. Don’t heat above 55C as at higher temps you may see some Allantoin crystalize out.
(2) Panthenol (Powder) … this implies that you are using a D,L Panthenol. If you want to load up Panthenol at 9.5%, you’ll be better off using D-Panthenol, which is a liquid (available from DSM and repacked by Making Cosmetics).
(3) With that high a load of Panthenol (assuming D-Panthenol) and Glycerin in a water-based formula, this is going to be an unpleasantly sticky mess of a concoction.
Don’t chase the percentages that other people use in their formulas. Formulas advertising very high loads of indivudual ingredients are generally nonsense. Enough is enough, more is not necessarily better. With D-Panthenol, 0.5% to 1.0% would be sufficient.
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Pattsi said:The lawsuit argues that Johnson & Johnson chose to use DMDM hydantoin in its OGX products despite being fully aware of its potential adverse health effects and the availability of alternative non-synthetic preservatives that “do not release known human carcinogens.” These include glyoxylic acid, potassium sorbate, sorbic acid, citric acid, rosemary oil extract, neem oil extract, lavender oil, grapefruit seed extract and vinegar. The use of DMDM hydantoin as a preservative was therefore an “entirely unnecessary risk” given safer alternatives exist, the case alleges.
… huh? …
I think the more significant, salient fact here is that J&J apparently had removed DMDM from all of its other products, and issued public statements that it would do so by 2015, and did indeed deliver on that public statement.
But, it did not remove DMDM from the OGX line post 2016 acquisition. So, it appears that J&J is in a bit of a box as to the duality of removing DMDM across the board except for this one product line in explaining it’s conflicting position on DMDM in its products.
This is an extension of the Tresemme class action suit that alleges the same.
And, this all started on TikTok … There’s a good lesson here: Using “controversial” ingredients can be expensive, both monetarily and as it affects brand reputation.
The lawsuit may not have much merit, but that does not mean that news of it will not damage the brand/product line and the legal fees defending it could get quite pricy.
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I’ve had a client get a letter from the FDA and had to pull it’s stock, re-label it’s products and correct its marketing language until the FDA-compliant line was completed. This was for a product that was positioned for Eczema, but was not an OTC. So, if you want to be too-clever-by-half … imaginary gray areas can be expensive.
I am currently working on a baby care line and one of the competitors labels its product container as a Diaper Care Cleanser & Moisturizer and claims that it’s 3-in-1 product that can replace Diaper Rash Creams.
And, as @Microformulation pointed out, several of their reviews refer to it as a Diaper Rash Cream and their marketing claims that it “prevents Diaper Rash”, but it is not an OTC product.
If the FDA becomes aware of this, they will definitely take action. Hmmm … I wonder how that might happen?
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No, the BASF product is a complex of SA with Acacia Gum that enhances the solubility of SA in water and creates a slow release of SA. In fact, it is completely water soluble.
Simply adding uncomplexed SA and Acacia Gum as separate ingredients will not be equivalent to the BASF product.
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You cannot use the word “Eczema” in your product name or marketing if your product does not contain a Monograph OTC active for Eczema and it is not an OTC-registered product with the FDA. There is no “gray area”
You can call it an Intense Cream, but not refer to your product being for eczema-prone skin. You simply cannot use the word “Eczema” unless your product is an OTC.
Generally, No. A good example is Paula’s Choice BHA Exfoliating Lotion … it contains 2% SA, but is targeted at general exfoliation for anyone and nowhere does it mention the word “Acne” … But, teen consumers latched on to it and it was selected as the Teen Vogue acne product of the year reader’s choice. That was a consumer’s choice, not how Paula’s Choice marketed the product.
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I thought the 5% rule was where you add every ingredient at 5% each to keep the math simple?
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You might be better off dissolving the SA in Butylene Glycol with 1% Sodium Citrate with a final pH adjustment to 3.5 to 4.0 … I think that will give you a more long-term stable solution.
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You’re not going to get that much SA deposition on the skin in a cleansing product. Better to develop a good cleanser w/o SA and a companion leave-on product that contains the SA. Although, you may want the marketing claim of SA in the cleanser … no harm done, but a cleanser will not be that effective at exfoliation.
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The FPLA is a guideline from the Federal Trade Commission, which is different from the FDA … No, most companies in the US label in accordance with your #2 … INCI name with (common name in parentheses).
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In the US, you must use the INCI name and can also include the common name in brackets, sor both 1 and 2 are in compliance.
Your option 3, I don’t think would be compliant.
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Yes, that would appear to be about right. Firgure the Glycolic Acid is loaded at 8-10%, so you would be in the right ballpark
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The Salicylic Acid is most likely dissolved in a combination of Butylene Glycol and Alcohol.
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Argan Oil … Jojoba Oil is actually a wax and it may have a propensity to clog hair follicles, exactly the opposite of what you want in an acne-oriented face oil.