PhilGeis
Forum Replies Created
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@Graillotion
those guys will get the least attention -
@MarkBroussard
There will be plenty of $$ services to fill the gap. Be glad they didn’t include a California-style bounty hunter clause. -
Dont think EWG’s BS will pass but i bet those guys will sell something as shallow but looks better.
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Prob not
Section 608 requires Responsible Persons to ensure, and maintain records supporting, “adequate substantiation” showing a cosmetic product is “safe,” and establishes a safety standard that products must meet in order to be marketed in the U.S. MOCRA defines “adequate substantiation of safety” as meaning “tests or studies, research, analyses, or other evidence or information that is considered, among experts qualified by scientific training and experience to evaluate the safety of cosmetic products and their ingredients, sufficient to support a reasonable certainty that a cosmetic product is safe.”
Cosmetic products that do not have adequate safety substantiation will be considered adulterated under section 601 of the FDCA. -
Part s that do not appl to < 1 mill annually - registration and formal GMP’s. FDA will develop small business GMP’s.
Adverse event record keeping, documented safety assessment and labeling change are for everyone.
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January 25
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Why Dermasoft ECO? It’s a very questionable preservative system - esp. in a shampoo.
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@GeorgeBenson
Not yet - FDA has one year to generate.
I’d look at what’s in Cosm Directive. -
@chemicalmatt
Did you see any funding for the FDA to cover these new responsibilities. -
@chemicalmatt
Thanks for the details - what total garbage. -
Right Perry.
The big guys and PCPC are all in support - allegedly because it preempts the states. That mid sized guys are screwed with useless paperwork and administrative burden is just “sad” collateral damage. -
@mikethair
I’m with you in old - and most hard surface cleaners have an alkaline pH. Protein is often more soluble at alkaline pH. -
You might consider the approach of the major guys - pay attention to the peripheral elements, as simple as they seem - an attractive package: easily manipulated, effective closure that does clog or leak, label that does fade or wash out, that doesn’t leave inaccessible residual product, staged well on shelf; a stable consistent product without phase or color change, syneresis, mold etc. : Support with convincing targeted ads.
The big guy’s cost structures demands extensive repeat purchase tro make money - so all the above and more must be consistent through time and geography as cost savings are pursued at all levels. A true technical innovation consumers can perceive would help a lot but those are very rare in cosmetics.
For example, P&G did not make money with Pringles until almost a decade after introduction. -
btw Squinny
PlantserveE is not enough - you need something for fungi/Gram +’s as Mark said and at a proper pH -
Not within the typical formula range of cosmetics.
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Ghita - skin generally takes care of itself.
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I understand and appreciate your objective. It’s a tough one as passive water in open pots/jars has always deviled in use-micro.
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Bet someone is struggling to get “equity” into their marketing.
To Perry’s - Cosmetic industry scandal - bet some clown lab will discover “gasp!!” heavy metals or some other trace terrible in something (ala lead in lipstick).
Consider the impact of the cosmetic modernization act in US. Stuffed into the 1.7 trillion, >4000 page omnibus budget act that just passed, it won’t drive a consumer trend but sure will have a lot of industry folks jumping.
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Can you say more about the product and the micro risk you’re trying to control?
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This is often overblown. Skin is not passive in this context, waiting for a product to set its pH.
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@ketchito
Glycerin preservation may have been in the minds of formulators - but I’d not place much confidence in it. -
@zetein
Thanks for the additional info -
They may be relying on a hot fill and tube to protect.
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I’d not presume effective preservation.
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Calamine lotion is a drug - tho could make cosmetic claims.