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  • PhilGeis

    Member
    March 20, 2023 at 5:17 am in reply to: $200 Benchmark Splitting

    That is a pretty poor preservative system

  • PhilGeis

    Member
    March 19, 2023 at 9:30 am in reply to: Do saturated free fatty acids turn rancid?

    Rr fatty acids you mentioned, I’d not worry that much about chemical oxidation. They can be metabolized by microorganisms via “beta oxidation” - that would require gross contamination.

  • PhilGeis

    Member
    March 16, 2023 at 8:36 am in reply to: Inactivation of Phenoxyethanol by Polysorbate 20

    Mark is right. The nonionic Polysorbate (Tween) 80 is used as preservative neutralizer in finished product micro testing. It may or may not have the same effect as ingredient in finished product formulation,

  • PhilGeis

    Member
    March 15, 2023 at 5:09 pm in reply to: Really, really stupid company

    Thanks. Do they ever ask questions re. the data?

  • PhilGeis

    Member
    March 15, 2023 at 4:19 pm in reply to: LEUCIDAL SF MAX & AMTICIDE COCONUT

    I’ve not heard anything about Leucidal and methylisothiazolinone. I hope it’s not true - I’ve met the Leucidal folks. They didn’t seem the type to salt the mine - just folks selling an ineffective product.

  • PhilGeis

    Member
    March 15, 2023 at 10:16 am in reply to: LEUCIDAL SF MAX & AMTICIDE COCONUT

    And remember the enviro-angst-ers wringing their hands over parabens in sunscreen killing coral reefs? Of course the data supporting the claim were Darbre-caliber irrelevant and meaningless.

    BUT a coral reef-isolated marine bacterium was shown to produce parabens. No data offered that it produced parabens while on an actual reef but it is natural reef flora.

    Discovery of a Marine Bacterium Producing 4-Hydroxybenzoate and Its Alkyl Esters, Parabens

    https://citeseerx.ist.psu.edu/document?repid=rep1&type=pdf&doi=3dbac0e854cbeb26d0d324fd9682b07b2dabf141

  • Please pay attention to KMRCSMiami’s comment re/ preservation. You can do better.

    Not so sure “all natural” is defensible

  • PhilGeis

    Member
    March 15, 2023 at 5:09 am in reply to: Really, really stupid company

    @mikethair

    What is “everything” GMP data? Finished product and raw material testing? monitoring data? water testing? batch sheets? yield? training records?

  • PhilGeis

    Member
    March 14, 2023 at 9:47 am in reply to: Formulation

    Hair spray? Can you please explain formulation. That much water and Ethoxydiglycol at rel low VP - wonder if it’ll ever dry, and ethoxydiglycol is an eye irritant. “Active” as Diphenyl diselenide - for hold or orange hair?

  • PhilGeis

    Member
    March 14, 2023 at 7:16 am in reply to: Really, really stupid company

    @mikethair

    What “GMP data” are you sharing?

  • PhilGeis

    Member
    March 13, 2023 at 3:37 pm in reply to: FDA Urea limitations on cosmetic products???

    Both links should be accessible - maybe I screwed up the cut and paste.

    The 1st was from FDA’s GRAS (Generally Recognized As Safe) notice for foods and it said there was no limitation - https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=184.1923

    The second was from CIR (Cosmetic Ingredient Review) and they concluded was safe as used in cosmetics but the max they saw used was 10% so that’s the limit of what they said was safe. They didn’t say greater was unsafe and talked about results for some exposures up to 60%. You can also find the info below on Google Scholar. Let me know if it still won’t open - I’ll down load andemail to you.

    https://online.personalcarecouncil.org/ctfa-static/online/lists/cir-pdfs/PRS310.pdf

  • PhilGeis

    Member
    March 13, 2023 at 11:41 am in reply to: What is CLEAN beauty?

    @MarkBroussard

    You might point out which ingredients condemn the 2nd formula to the depths of the unclean.

  • PhilGeis

    Member
    March 13, 2023 at 6:14 am in reply to: FDA Urea limitations on cosmetic products???

    Urea is GRAS - re. foods https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=184.1923

    “In accordance with § 184.1(b)(1), the ingredient is used in food with no limitation other than current good manufacturing practice.”

    Found nothing from FDA re cosmetic application. Here’s CIR https://online.personalcarecouncil.org/ctfa-static/online/lists/cir-pdfs/PRS310.pdf. Looks likke they considered up to 10%.

  • PhilGeis

    Member
    March 13, 2023 at 4:03 am in reply to: Really, really stupid company

    Right - this is garbage waiting for a bug to drop in. Suppose it’s feasible it might have met the nominal criteria of 51 but no GMP’s will save that mess and in-use contamination is certain.

    Granted this is obvious but a lot of the Ecocert and other “clean” systems I’ve seen here are not much better.

  • PhilGeis

    Member
    March 9, 2023 at 4:24 am in reply to: Saponified oils would solve a lot of the Clean Beauty dilemmas

    @mikethair

    Thanks for the explanation.

    Attempts with various lab bugs to generate growing contaminating in products seemingly “self-preserving” like soap aren’t effective. Recall similar attempts with unpreserved high pH products (e.g. Mr. Clean and L:iq Tide) - both of which suffered contamination with bugs that only grow at high pH.

    But the primary issue for cosmetics is micro risk in use. A liq. soap failed P&G’s challenge test only with dilution to the extent observed with consumer in-use testing.

    Risks in making can be controlled but In-use risk is apparently not controlled per discussion- not unusual as it looks like only the big guys (can) address it. It is boiler plate but assessors are ignorant to call the question.

  • PhilGeis

    Member
    March 8, 2023 at 12:02 pm in reply to: What is CLEAN beauty?

    Parabens to Molokai !!! Or maybe Dreyfus to Devil’s Island.

  • PhilGeis

    Member
    March 8, 2023 at 11:30 am in reply to: What is CLEAN beauty?

    @MarkBroussard

    So just “unclean” ingredients?

  • PhilGeis

    Member
    March 8, 2023 at 11:28 am in reply to: Regulatory

    Regulatory Affairs Professionals Association https://www.raps.org/

  • PhilGeis

    Member
    March 8, 2023 at 6:39 am in reply to: What is CLEAN beauty?

    @healthybooth

    I did not see ingredient listed on your website so can’t comment to your application of “clean beauty.”

    However, please understand safety is an affirmative process - you must have data that shows safety for all your “clean beauty ingredients and products re. appropriate endpoints - carcinogenicity, sensitization, irritation, eye safety, teratogenicity, preservative efficacy, etc.? Without such appropriate data - your product are not safe and in US would be labelled.

    “<strong style=”font-family: inherit; font-size: inherit; color: var(-bb-body-text-color);”>Warning-The safety of this product has not been determined.”

  • PhilGeis

    Member
    March 8, 2023 at 6:17 am in reply to: What is CLEAN beauty?

    @healthybooth

    Clean beauty is a technically meaningless marketing claim - there is no technical synonomity with safety or “non-toxic” ingredients. Ironically, many of the “clean beauty” ingredients (esp. preservatives) have very little human safety data in context while those rejected are a among the best qualified in terms of safety in use as document by the FDA and SCCP (e.g. https://www.fda.gov/cosmetics/cosmetic-ingredients/parabens-cosmetics).

    Please, if you insist on a technical basis for this makrei8ng claim - please provide the technical support. Repeating the marking BS does not establish its validity.

  • PhilGeis

    Member
    March 8, 2023 at 5:42 am in reply to: in vitro efficacy testing of finished products?

    To the previous comment, I’ll add that you must consider how you will validate your in vitro protocol to consumer use.

  • PhilGeis

    Member
    March 8, 2023 at 5:37 am in reply to: What do the letters ‘pH’ stand for?

    As he said, terminology “pH” - “p” means the negative log value, here concentration, and “H” refers to hydrogen ion.

    and pH balanced is largely BS.

  • PhilGeis

    Member
    March 8, 2023 at 5:27 am in reply to: Saponified oils would solve a lot of the Clean Beauty dilemmas

    Soap is certainly not immune from contamination - esp. with bugs that are not readily picked up with routine testing - e.g. https://onlinelibrary.wiley.com/doi/abs/10.1111/ics.12401

    Are the body wash/shampoo/etc. products in question all of the classic soap, alkaline pH-based composition? This is generally ok as made clean - BUT - common consumer practice is dilution - by intent or unintended exposure in shower.

    Most of the cosmetic recalls are of the “clean beauty” preservative type. All no doubt passed their version of <51>, probably +/-total “kill” at early time points. Not only does the test fail to address fairly minor manuf. issues (“minor” as I’ve consulted on some) , it’s not relevant to the primary objective of consumer protection. Major companies qualify their preservative systems and to some extent their own challenge test with in-use experience (e.g. https://journals.asm.org/doi/abs/10.1128/aem.53.8.1827-1832.1987).

    Think any novel approach to preservation should be qualified vs consumer use. Not aware Dr. Bronner has so qualified their systems and wouldn’t take just their word for it anyway. Their systems don;t impress.

    I know you are a veteran of the cosmetic industry science and sure have learned a lot from your posts. On this matter, I don’t understand the justification or science.

  • PhilGeis

    Member
    March 6, 2023 at 3:38 pm in reply to: Saponified oils would solve a lot of the Clean Beauty dilemmas

    Please explain the data set - not that no one challenged. That said, the purpose of preservation is consumer protection - and none of the compendial challenge tests are validated for that purpose. What data do you have in that context.

    btw - you have a totally incompetent and negligent assessor.

  • PhilGeis

    Member
    March 6, 2023 at 8:41 am in reply to: Saponified oils would solve a lot of the Clean Beauty dilemmas

    Ketchito may be addressing soap fatty acids av. synthetics as in Ivory v. Dove. I recall of the FA’s, laurate C12 had the greatest irritation and antimicrobial potential.

    Not familiar with pipes but we all know soap scum.

    Could you address the microbiology - preservative-free - aspect please.

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