PhilGeis
Forum Replies Created
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@Graillotion
I think you’re ok without an attempt at head space protection. Open pots have been around for around a century. My experience - we didn’t worry about growth on inner package surface. -
considered - as regarded, thought of as
Less than consensus - there is no objective definition.
Safe - clearly clean products as a group are LESS safe - with their limited, sometimes ridiculous preservative systems. We are charged to market safe products - Clean ingredients, esp. relevant preservatives, typically have profoundly less safety data than the priority materials they replace - materials specifically addressed by the FDA as safe in use.
Eco-friendly is a technically garbage term.
I understand/know Clean as an advertising claim without technical significance. -
@Graillotion
Consumer touches? Can you explain?
Have you seen contamination on inner package surfaces? -
@MarkBroussard
LOL - you are a marketing devil! -
@RobboAU
“…considered safe, non-toxic, and environmentally friendly.
Bull - the functional term is “considered” as in marketed under these meaningless terms.I’m impressed they put so much BS behind it.
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Life cycle analysis - ask Dupont.
Think you’ll get lost in the weeds in comparison. -
O-Cymen-5-ol vapor pressure is a bit < PEA’s. Don’t know if either would be effective for headspace from cosmetic matrix
Are you sure you need headspace preservation? -
Phenyl ethyl is not so good vs. Gram positives. For headspace - IF it volatilizes from your product at level - it might inhibit Gram neg’s and fungi.
https://microbeonline.com/phenylethyl-alcohol-agar-pea-principle-composition-and-preparation/
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Wet sponge - micro compromise of both the product and implement.
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As Graillotion said, the “new preservative” is not novel - a marketing combination and nothing special. You need something for fungi.
Your current preservative is overkill. Drop the phenoxy entirely, Germall+ should ~3000 ppm. A chlelar (EDTA is appropriate).
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There was the famous problem in the 70’s that really fired up the FDA back then https://europepmc.org/article/med/409295
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They accepted the fair accompli of 4000 pages. It’s on them - but doubt they’d have read it if it was on its own
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Of course there were ALL those hearings from experts and congressmen read every page before voting.
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think about exposure and use - what role spit, tap water have in consumer use and does product take up water on its own.
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@Graillotion
They’re some of my friends, so I’d be a bit kinder.
Who pushed it through? I know the big guys wanted federal preemption of California and other state crazies and got it here. The rest of the bill is just what they’re doing now and it dumps on the rest of the industry. Win Win.As for the moronic politicians - I spoke to the cos of the original model bill a few years back and asked “why?”. response was - this is a unregulated category and we’re worried about things like Wen and hair loss.
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@Rockstargirl
Look at marketed products from major brands. Wouldn’t put much confidence in Glyceryl caprylate. “caprate”
Will formula, package, implement and anticipated use bring water/Aw into consideration?
Consider parabens -
@Ghita37
Consider - https://panmore.com/procter-gamble-mission-statement-vision-statement-analysis
It can be actionable. I recall pointing out with effect that specific production with limited micro quality was not consistent with our mission “We will provide branded products and services of superior quality..” -
The bill is legislation for legislation sake. The lawmakers know nothing of Etsy - they can’t stand an industry that isn’t heavily regulated. CFSAN (FDA division responsible for cosmetics) cares about food and knows about nothing of cosmetics.
For Safety Substantiation - I see a bunch of cynical “toxicologists” rubber stamping “SAFE” along the lines of EWG’s certification. -
@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.