Forum Replies Created

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  • PhilGeis

    Member
    March 7, 2021 at 2:50 pm in reply to: Stability testing for a beginner

    Unclear if you said you would market products - but if you’re limited to what you can do at home - do not market.  You are responsible for the product safety (chemcial, microbiological) - an affirmative, data-based effort.  You’re not going to generate necessary data at home.

  • PhilGeis

    Member
    March 7, 2021 at 2:44 pm in reply to: Bug food

    Think the “bug food” concept is largely fiction.  Bugs can matabolize most of the ingredients in cosmetics, and cepacia, for one, can grow to large numbers in distilled water.

  • PhilGeis

    Member
    March 4, 2021 at 12:33 pm in reply to: Preservation

    Sure - a formaldehyde releaser with parabens (and EDTA) was the classic combination late last century - tho typically methyl and propyl parabens.  Try 2500 DMDM H with methyl propyl 2000/1000 ppm.
    If you’re marketing in EU be aware of free formaldehyde limits.

  • Change control

  • PhilGeis

    Member
    March 3, 2021 at 1:38 pm in reply to: Dry heat oven sterilizer

    Isopropyl or ethyl (~70% and not booze, just alcohol) - rinse, spritz or wipe depending in equipment.  Do not rinse with any water - that merely adds bugs.

  • PhilGeis

    Member
    March 2, 2021 at 4:46 pm in reply to: Dry heat oven sterilizer

    With Pharma - you neither need nor can you effetively achieve/maintain sterility.  But appreciate your desire for quality.

  • PhilGeis

    Member
    March 1, 2021 at 12:28 pm in reply to: Preservation

    Look for data re. “Euxyl 9010” (90% phenoxy/10% ehg).  EU directive allows to 1% Phenoxyethanol  - suggest starting ~5000 ppm.
    Think this leaves a gap re. fungi - might consdier IPBC or organic acid.

  • PhilGeis

    Member
    February 27, 2021 at 2:36 pm in reply to: Acceptance Criteria EU?

    Think you can develop your own technical defense re. principles established in 22716.  Avoid PET defining your risk - if you must generate data - try some in-use testing.. 

  • Hey Matt - not aware of data but prob less effective exposure if addition is after clay is in formulation.  But that also leaves previous formulation protected only by GMP’s/time/temp etc. and demands late addition doesn’t run afoul other formula interactions.  

  • Benzoic and maybe other organic acids reportedly absorbed by clays and may have issues with EDTA as preservative adjunct.  

  • PhilGeis

    Member
    February 24, 2021 at 1:33 pm in reply to: Acceptance Criteria EU?

    Accepotance criteria in what context?   Might consider ISO 29621 for micro risk.   https://www.iso.org/obp/ui/#iso:std:iso:29621:ed-2:v1:en

    “Reasonably archaic”.  Please don’t be casual re. GMP’s.   Per the Drective: 
    To ensure their safety, cosmetic products placed on the
    market should be produced according to good manufacturing practice.

  • PhilGeis

    Member
    February 23, 2021 at 11:23 am in reply to: Labeling Question

    Good point from Dr. Pratt, but think 50 gram net weight may be too much for the  exemption.   Perhaps follow the Olay regenerist line labeling - those are ~50 grams.
    “The PDP of a “boudoir-type” or decorative cosmetic container, e.g., cartridge, pill box, compact or special variety, and those containing 1/4 oz or less may be a tear-away tag or tape affixed to the container [21 CFR 701.13(e)(1)]. It may also be the display panel of a card to which the immediate container is affixed [21 CFR 701.13(e)(2)].”

  • PhilGeis

    Member
    February 22, 2021 at 12:02 pm in reply to: PH Level in Concentrated Solution and After Dilution
  • PhilGeis

    Member
    February 22, 2021 at 11:55 am in reply to: PET Testing Vendors

    and Advanced Testing Laboratory  https://www.atlscience.com/

  • PhilGeis

    Member
    February 15, 2021 at 1:49 pm in reply to: natural preservative for low ph product

    Back to the original inquiry - please understand major manufacturers have rarely engaged in “natural” preservation.   In context of consumer protection, they’ve found the approach inadequate, and that is consistent with the fact that most of the recalls involve natural/alternative preservative systems.  Few are also willing to engage in the head fake of Ecocert et al.

    Unless your willing to show with efficacy testing (as limited an indicator as that is) an effectvie and stable system - and confirm appropriate compostin of every batch of “natural” preservative, stay out of the category.  You’ll put your consumer at risk for a trivial  claim.

  • PhilGeis

    Member
    February 15, 2021 at 10:22 am in reply to: natural preservative for low ph product

    A quIck glance.    I’ll pass on your insightful comments.

  • PhilGeis

    Member
    February 14, 2021 at 1:20 pm in reply to: natural preservative for low ph product

    Good advice from Pharma.  8% ethanol is helpful but not enough.  Decide what you consider “natural” - truely unchange from nature or by commercial redefintion ala Cosmocert.   Might take a look at recent chapter Dr. Amoroso (P&G) wrote on the subject.https://books.google.com/books?hl=en&lr=&id=Xq0CEAAAQBAJ&oi=fnd&pg=PT46&dq=amoroso+natural+preserve&ots=JXysHfmSwm&sig=k6pIcE2zBD9jHdis9VFXAhUnpG4#v=onepage&q&f=false

    But - avoid “as little as possible”.    FDA and EU note preservatives are intended to protect in -use, and challenge tests (USP 51 and it’s ISO, etc. knockoffs)  are not validated,   As you are unlikely to do in-use validation, work within recommended concentration parameters.   Be aware, most of the recalls are “natural” or preservative free products.  Also be aware the natural preservatuves as undefiune mixtures (essential oils, ferments, “parfum”, etc,.) vary from in composition and efficacy from batch to batch.  Grapefruit seed extract is a scam.

  • PhilGeis

    Member
    February 13, 2021 at 12:05 pm in reply to: Prop 65 warning question

    mhart123 makes a good point.  Why not contact the supplier  (assume Lubrizol) for their perspective.

  • PhilGeis

    Member
    February 13, 2021 at 12:00 pm in reply to: Possible spoiling oil-based mixture?

    Methyl paraben alone is a pretty weak preservative system.  Have you conducted any micro testing - challenge or content?

  • PhilGeis

    Member
    February 13, 2021 at 11:25 am in reply to: Does this formula need preservative?

    Good point - back to your original question.    At pH 11-12 you need no preservative.
    2%  EDTA is well beyond the preservative aduvant level (~0.1%).  In that context, citric acid is not as effective as EDTA and, at alkaline pH, will be its sodium salt.    

  • PhilGeis

    Member
    February 12, 2021 at 10:04 am in reply to: Does this formula need preservative?

    Pharma - assumptions/advertising -  the stuff hasn’t been shown to be “safe” or nice. Enzyme sensitization on inhalation is not uncommon.  One major marketer experimented tried protease enzymes in a bar soap context and ran into significant and serious allergenic response.   They’ve found even worse problems in manufacturing laundry detergents with enzymes.  Folks may also respond to the lactobacilli themsleves but, unwittingly those folks may have mitigated as lactobacilli in some context mitigate immune response.

    Are you aware of data fom those folks re. your imagined efficacy scenario?

    Also be aware that lactobacilli can carry markers for antibiotic resistance.  Unlikely to be medically signficant themselves, they could be a source for horizontal gene transfer.

  • PhilGeis

    Member
    February 12, 2021 at 9:54 am in reply to: Effective preservative system

    There is no such system.

  • PhilGeis

    Member
    February 11, 2021 at 2:56 pm in reply to: Prop 65 warning question

    Have you looked at the safety of your other ingredients? 

  • PhilGeis

    Member
    February 11, 2021 at 2:43 pm in reply to: Does this formula need preservative?

    Agree - ecofriendly is advertising hype in any context.   
    Have you sen any data for the “effective  microorganisms”?  I’ve seen it hyped on facebook  but the marketer didn’t offer any meaningful efficacy data.  
    A major concern they blow off is safety - spraying bacteria, fungi and their alleged enzymes in the beathing space is risk for sensitization.

  • PhilGeis

    Member
    February 9, 2021 at 12:12 pm in reply to: Ethanol as a broad spectrum preservative

    Perry, an obscure historic regulatory problem with ethanol.  Think 1989 or ’90, shortage of SD40 alcohol disrupted
    the industry – we couldn’t make hair sprays and gels and alcohol
    deodorants. 

    Issue - noncompliant SD40 alcohol.  Brucine (SD40 denaturant aka dimethoxy
    strychnine) included impurity strychnine > ATF standard.  World’s brucine supply from a few plantations
    (from seeds of nux vomica tree) in India came via a single supplier, and alcohol
    suppliers apparently no paid  attention
    until crisis.  No idea why supply that
    one year was off – not reported before or since.

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