[mikethair]

We saponified coconut oil for our shampoo, and the pH was around 9. This provided both stability and functionality. At pH 9.0 we had zero microbial issues.

[mikethair]

From my experience, it’s all to do with temperature. My approach was to set up an Excel spreadsheet and record data on various temperature parameters.

Also, look at the lid on/off after the balm is poured, the temperature, and type of the surface the filled balm containers are resting on as they are poured.

There is no quick answer/advice as we are unaware of the conditions you are working in.

You will need to experiment, but with the Excel data you should be able to solve the problem….we did.

[mikethair]

I’m an Australian, and we co-founded a skincare manufacturing company in Malaysia that we run for 20 years, and in March 2023 I retired. What we did was set up and run our manufacturing facility as GMP Certified. This required annual and periodic inspections of our facility by departmental officers.

The advantage of adopting the GMP Certified mindset was that it required the adoption of all the points identified by the original poster here. I would recommend this to anyone going down the MoCRA route.

[mikethair]

The difference between a “Cosmetic Chemist and Formulator” is nonsense. Importantly, what you do require is a talent for formulating. In my opinion, with talent, you either have it or you don’t. And if you do not have the talent then no amount of academic qualifications will make any difference.

I have worked globally as a formulator for around three decades. And yes, I do have a PhD, MSc, and BSc. But in my opinion, I always had a natural talent for formulating, and my academic qualifications add little to my formulation talent.

[mikethair]

For two decades my company formulated and manufactured liquid castile made by saponifying extra virgin olive oil. We produced wholesale quantities of products that were exported globally. And in twenty years never had any issues.

I should also mention that we were not hobbyists / DIY and were GMP Certified.

But care needs to be taken with selecting the “scrub” component of the formulation.

[mikethair]

I’m an Australian skincare Master Formulator with more than two decades
of experience as the co-founder and Managing Director of a certified GMP
cosmetics manufacturing facility.

I have formulated and manufactured all-natural skincare for brands
globally.

I have also provided private consulting to new and established cosmetics
companies globally.

I like to stick to my own lane. This includes formulating using only
100% renewable plant ingredients that can be traced back to their
source; artisan-made using time-proven traditional methods, and full
cosmetic regulatory compliance.

Dr Mike Thair

[mikethair]

My approach would be to have your manufacturer produce a test batch and have a group of your customers try the product.

Yes indeed, logic tells us that fragrance would attract bees, but it has never been an issue with products we have manufactured for 20+ years.

[mikethair]

I would check with your country’s cosmetics compliance authority. In our case I had our QC Manager do the checking with our local authorities and those of the destination countries of the brands we manufactured for, and in all cases, it was a no no.

The only option we had was if the brands we were manufacturing for returned the used containers to us and these were cleaned under our GMP conditions. And cleaning pumps was mission impossible, therefore pumps needed to be replaced.

And I question the eco-friendliness of this approach. Shipping empty containers back to us is not cost and carbon-free.

[mikethair]

<div>In my opinion, you will find incompatibilities among your set of ingredients.</div><div>

</div><div>

My approach was to saponify coconut oil to produce Potassium Cocoate. In our manufacturing facility, we produced this shampoo base for 20+ years. We used this base to produce shampoo for brands globally. It was just a matter of adding essential and other oils to meet client requirements.

And what attracted brands was that the shampoo was synthetic free, and worked.

Contact me if you want to know more.

Kind regards,

Dr. Mike Thair

</div><div>

</div>

[mikethair]

Some of the substances are much
more effective permeabilizers than others. And they may have variable potential as
antibacterials. Yes, EDTA, nitrilotriacetic acid, and sodium hexametaphosphate,
which disintegrate the outer membrane by removing Mg2+ and Ca2+, are theoretically effective permeabilizers.

My suggestion regarding GLDS is to set up a proper trial in your lab. And I’d do the same with EDTA. It is not something one would want to predict remotely.

[mikethair]

My approach would always be to have our QC Manager approach your cosmetics compliance authority and seek clarification.

[mikethair]

It would be impractical to have Amazon and
Etsy require companies to submit
PCT test results before a product can be listed. Would Amazon and Etsy have the qualified staff to make sense of these test results? And the extra workload for Amazon and Etsy would be enormous.

A far more practical and cost-effective approach would need to be developed.

[mikethair]

Yes indeed….provides a fair bit of wriggle room for the unscrupulous.

[mikethair]

Yes, but the great formulations from a talented formulator will have the heads of big companies sit up and take notice. So, my advice is to let your formulations do the talking for you.

[mikethair]

What do you mean by”What is the practice in public/group bathrooms?“

It’s not a term I’m familiar with.

[mikethair]

Yes, I would agree. For the compliance efforts required, brands can leverage other areas to gain more brand traction and increase revenue.

[mikethair]

<div>Hi PhilGeis, within the ASEAN Cosmetics Guidelines there is no specific reference to the use of recycled containers. Which, in my opinion, is fair enough. Any container must comply with the GMP standards.</div><div>

As a company, we went into this in great detail. But at the end of the day, the cost to our brands of returning the used containers, our cost of cleaning to meet the cosmetics compliance requirements, plus the carbon costs, it was just not economically viable or environmentally friendly.

The other option was to supply local and international brands with bulk containers (we found 5 Kg the optimum size) where customer bottles could be refilled in-store. But again, the cosmetics compliance authorities, both local and international, had issues with this. There were two main objections: (1) in-bottle contamination of the customer-returned bottles being refilled and (2) contamination during the filling by in-store staff.

The academic paper you cited (https://www.mdpi.com/2079-9284/9/2/27) gives some insight into how these objections could be mitigated, but most of these are impractical.

</div><div>

</div>

[mikethair]

There is no one regulation covering all countries. For example, under the ASEAN Cosmetics Guidelines combined with the terms/conditions of our GMP Licence, there is no capacity for refilling returned bottles. And at the same time, our QC Manager asked the question during our regular compliance inspections.

Similar applies to other countries.

The best approach is to raise the question with the regulatory authority in your own country.

And the reason I employed a QC Manager to sort out these issues. It is not a good idea to have bottle recycling raised and rejected during a GMP compliance inspection.

[mikethair]

It was “local” in Viet Nam and Malaysia (under the ASEAN Cosmetics Guidelines), and for the international brands we were manufacturing for. With the international brands, each product was Notified with the cosmetics regulation authorities of each destination country.

[mikethair]

<div>Hi Porag,</div><div>

The pH is one of many parameters that may be causing your hair to drop. May I suggest that you provide a list of ingredients for your shampoo formulation. This may provide a clue to your problem.

Kind regards,

Mike

[mikethair]

Hi ketchito,

Yes, I have read all of these papers. As a scientist, that’s what I do.

And yes, there are flaws in these papers and the peer review system. But what is the alternative?

[mikethair]

Hi PhilGeis,

I think that your response shows that we are communication from different sides of the pond.

In my case, as a scientist, my reference point has and always will be the scientific/medical literature. And based on my understanding this scientific literature I formulate. I maintained this approach for more than two decades as a co-founder and managing director of a cosmetics manufacturing company that provided products to brands globally.

And now I understand from your perspective from within the cosmerics industry “That they hire experts in the field to execute assessments is to their credit…”

This perspective you have explained is very illustrative to me. So thanks for that.

I’m not suggesting that one approach is better than the other. And I believe they can co-exist.

My phrase “call me old fashioned” is what I guess we call an idiom. And there are no suggestion here that you called me old-fashioned.

[mikethair]

Hi PhilGeis,

With great respect, I have read all of the papers I have cited. As a scientist and formulator, it’s what I do.

Call me old-fashioned if you like (OK, I’m in my 70s), but the papers I have cited are of concern to me. I have listed 100+ scientific papers listing concerns. That’s too many for me.

And again, I have gone through all of these papers.

[mikethair]

Hi Perry,

With respect, what concerns me is the research cited in scientific literature. For example:

• 2021 Jul 15;778:146150.

  doi: 10.1016/j.scitotenv.2021.146150.

  Epub 2021 Feb 27. Parabens as chemicals of emerging concern in the environment and humans: A review.

• 2019 Jan/Feb;30(1):32-45.

  doi: 10.1097/DER.0000000000000428. Paraben Toxicology

• 2022 Nov;87(5):389-405.

  doi: 10.1111/cod.14181.

  Epub 2022 Jul 18. Preservatives in non-cosmetic products: Increasing human exposure requires action for protection of health

• 2022 Oct;29(49):73648-73674.

  doi: 10.1007/s11356-022-22895-z.

  Epub 2022 Sep 9. Environmental contamination status with common
  ingredients of household and personal care products exhibiting
  endocrine-disrupting potential

• 2010 Sep;15(3):190-6.

  Toxic effects of the easily avoidable phthalates and parabens

And the list goes on. I should add that these are from peer-assessed papers and the scientists do not have any allegiance to cosmetics companies.

Further, if the check the following link, there are listed 100+ scientific papers (including those I have cited above):

https://pubmed.ncbi.nlm.nih.gov/?term=paraben%20concerns%20cosmetics

And what evidence would convince me that parabens are safe? Similar to what I have provided above citing peer-assessed papers saying that parabens are safe.

[mikethair]

Hi Harkem,

When you ask me if “oil base serum much better than water based?” two thoughts come to mind.

(1) I’m an old scientist (in my 70s) and when you mention the word ” serum” what comes to mind is the clear liquid part of the blood that remains after blood cells and clotting proteins have been removed. At one time I worked in a serology lab where we worked with bovine serum.

(2) I listen to my clients and the specs for new products they are asking me to formulate for their brand. And based on these specs, I will tend toward formulating high-quality oils.