PhilGeis
Forum Replies Created
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Does ACA charge for certification?
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You can find info for small companies on the net - e.g. https://www.modernsoapmaking.com/blog/understanding-the-2022-united-states-cosmetic-regulation-changes-with-mocra
To your immediate question
small businesses are fully exempt from facility registration and product listing submission if their average gross annual sales for the previous 3-year period is less than $1,000,000 and do not make any of the following:
- cosmetics that come in contact with mucus membranes of the eye
- cosmetics that are injected
- cosmetics that are intended for internal use
- cosmetics that intend to alter the appearance for more than 24 hours
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Washed, there is no issue
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Very doubtful you’re not encountering NaOH per se.
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Sorry - very doubtful that you ARE encountering….
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No
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what is your package?
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As Perry said - this is unnecessary. I’ll add it’s BAD idea. Bacteria growing while you’re trying to “dry out”.
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What’s the preservative?
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Thanks Mark.
Sure hope you guys make it fee for necessary services rather than the predatory piece of the action - ala a bunch we all know too well.
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Is aloe the only source of water? Do you see this as oil in water or water in oil emulsion?
Preservation of the finished product is your responsibility - not your supplier’s.
If you determine no further preservation is needed, you’ll need to add the supplier’s preservative (system) top your ingredient label.’
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There is no “sodium hydrochloric acid” and hydrochloric acid like NaOH is ionic so not the parent compound in water but the ions H and Cl. Not much use in cosmetics but perhaps to adjust pH and that at low levels.
Glycolic acid? This is not relevant to either of the above.
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No. You should see it far down on the ingredient label and a little sodium will not be an issue.
Maybe the pH of the products bothers you. Look for that on SDS documents.
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Right - they would not approach it without a wellthought out positioning/strategy. Need to see how FDA responds.
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Think you’ll looking at the regulators more than the clinicians.
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Wonder of just “100%” is enough
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maybe they thought e-wax meant ear wax.
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Has it passed challenge?
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Good perspective. To OP’s question
More hexanediol. I don’t see it in the ingredient list - to that, please use chemical or INCI names. Maybe missed a commercial name.
For shampoos/surfactants - rinse-off products, chloromethyl isothiazolinone is more traditional esp with EDTA and benzoate*. Phenoxy/EHG/Benzoate/EDTA is prob pretty effective. Unless you’ve resources to qualify a diol, suggest you not chase it.
* not for fungi, they rarely cause issues in surfactant products, but as co-preservative, esp. to mitigate adaptation to the primary. Na benzoate serves this well and is effective beyond it’s pKa when combined with many surfactants (i.e. demonstrable efficacy up to pH neutrality).
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You’ve CHA and piroctone is insoluble.
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Piroctone is waste as a preservative.
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3 weeks at 60C is BS. If that’s the only condition that causes the issue - then you have no issue. T
Some officious clown in your company has you guys wasting your time and energy for no benefit.
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Spot on. Many fungal treatments are based on siderophore - hydroxamate (ZPT) or hydroxamate like (Piroctone) structure. ZPT safety in use is partially due to its poor solubility - the highly soluble NaPT is fairly toxic. Mechanism is divalent cation binding that screws up functins like DNA synthesis and repair. Pharma mentions many other points.
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They clearly have no knowledge of the cosmetic industry - not ingredients, microbiology, preservatives, testing CIR, etc. They worked off MIC’s and hung efficacy confirmation on single applications in USP 51, but cut it back to only two of the bugs. No consideration of in-use or even understanding of the purpose of preservation.
They published a similar article in 2017 in the same journal claiming octyl gallate was the panacea.
Mentioned the 3G comedy as ongoing - when it closed out with failure years ago.
This kind of garbage adds fuel to the even more ignorant regulators and profoundly ignorant (esp. state) legislators giving us bans ala Wash state.
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3 weeks at 60C? This is excessive - relevance to real life long term aging is highly doubtful.