[PhilGeis]

ngarayeva001 said:

Marketing shouldn’t be deceptive, marketers are just lazy. It’s easier to throw unsubstantiated claims like ‘cellular’, ‘genefique’, ‘antiaging’, ‘stem cells technology’ than creating an experience. I remember commercials of camay soap in 90’s. It was all about experience and ‘luxury’ and having a fine perfume added to a bar of soap. It was a popular soap back then. Consumer happily pays for  experience. Having said that unsubstantiated claims come from both sides. In case of large companies it just gets proof read by the legal department. 

Consumers haven’t happily paid for the Camay experience in decades - tho’ last I heard it had some presence in Eastern Europe. P&G hasn’t suppoorted the brand in many years and sold what’s left to Unilever. 
Large companies typically have all claims reviewed by legal - not “proof read” - and do generate data for many relevant claims tho’ puffery is still in practice.  I disagree with the your claim of equivalency to small companies in this context.  If nothing eelse, it’s much less expensive and impactful on brand to generate (even seemingly) relevant data than defend vs. challenge. 

[PhilGeis]

To Pharma’s point, if Kathon, only use Kathon CG.  
You might check with Thor’s Microcare line of isothiazolinones.

You can add preservatives individually, but making your preservative blend is not a good idea.

[PhilGeis]

Understand marketer frsutration, but a lot of what is claimed as benefit is pretty subjective if not silly.  Mark’s point is much more compelling - the risk better be very small.  By ignorance or worse, smaller companies are often guilty of driving failed risk assessment.

[PhilGeis]

I’m with Dr. Pratt - like that one, Perry.

[PhilGeis]

Thanks Perry - maybe not yet - but if CARB thinks it a source (and 20% will look significant) , they’ll place a limit. 

[PhilGeis]

Dr Catherine Pratt said:

If you are trying to keep to environmental regulations and go natural you can use ethanol that is produced from grains and is just called Bio-ethanol.

Why do you only want to use ethanol as your only preservative. If you have to use up to 20% as Perry suggested, then this would change the viscosity, have you tried it out yet.

Please let us know how you go? Cheers Catherine

The regulations I think Perry addressed focus on VOC’s as chemicals and do not exempt “Bio-ethanol”.  Example: California’s ARB regs - don’t think they’ve placed regulatory limits on VOC’s from lotions at this point.   Most other states and the feds follow some aspect of California’s.  https://ww2.arb.ca.gov/sites/default/files/2020-12/cp_reg_article-2.pdf

[PhilGeis]

As jemplian said, follow manufacturers’ directions.   Solubility of some preservatives decreases at lower temps.  With precipitation, fluid dispensed from drums (for example) will not establish effective levels. 

[PhilGeis]

Aziz’s a “man behind” effectively does not exist, esp. as adequate satisfaction of the parameters of stability, safety, microiology may require data not just judgement.   
A large company will have “men” behind each discipline with data and data-based judgement.   A small company will deal with greater risk - fewer men behind and lesser testing capabilities. 

[PhilGeis]

Definition of and benefit “natural”.

[PhilGeis]

To Pattsi’s good point.  In 2017, FDA reported the >70 cosmetic sku’s recalled for micro issues - all from smaller companies most pursuing natural formulation/alternative preservation.  Previous years showed increases to this peak.  Following years saw consistent decline - <20 in 2020.
Also this - https://sfamjournals.onlinelibrary.wiley.com/doi/abs/10.1111/lam.12995

[PhilGeis]

“Eco preservative” is marketing hype and that system is pretty weak and not natural. How much incidental water is actually in the bar and, if wetted, what is the pH? 
Likely you don’t need a preservtive but that is your risk to address.

[PhilGeis]

With that appropriate concern, there is no way this product should be distributed to consumers - even with compliant labeling
 21 CFR 740.10

A cosmetic is considered misbranded if its safety has not adequately been substantiated, and it does not bear the following conspicuous statement on the PDP:

Warning - The safety of this product has not been determined.

[PhilGeis]

I’d say the same Perry.  

[PhilGeis]

Yasmin123 said:

Because it’s going to be in and out of water all the time i would need a preservative?

Not sure what this means.  Will the bar be in standing water - as in soap dish - or allow water pooling on the bar?  Neither of thise scenarios lends itself to effective preservation.
Any chance you know the water activity of the bar?   Is there any incidental water in the product?

[PhilGeis]

One more - you can’t legally sell this as a cleaner in the US.  For that, all the ingredients must be on the TSCA inventory (https://www.epa.gov/tsca-inventory).  Further, the preservatives must be registered pesticides per EPA FIFRA - the ones mentioned are not only weak, very unlikely they’re registered.  

Think you should scrap this stuff.

[PhilGeis]

“eco preservative”?  Sure you need a preservative?

[PhilGeis]

Filtered tap water and mineral water.   Not sure what the picture shows but it looks pretty jury rigged.  Think you’re approaching cosmetic productionn in a pretty casual fashion.   The cleaning application (other than dishwash) isn’t a bad idea but prob ned to rule ou bacteria or it will eventually stink. 

Yes - Serratia marcescens famously produces a red pigment in culture and I’ve seen cosmetics contaminated with the bug turn red.   ozgirl also made the excellent point that iron (mineral water?) complexes with capryl hydroxamate of Spectrastat GB Natural (natural here BS - it’s synthetic) to produce a red complex.   But your EDTA should compete for iron.

In any case, you donlt know why it’s red and you are resp;onsbile to prove the safety of your product and you can;t.

[PhilGeis]

Are you using city or well water?

[PhilGeis]

That 6 people have used it without irritation is not relevant. This is an off spec batch not made as intended.  It is adulterated and you fail in your responsibility to consumer  to do anything else than scrap the batch.  

I sure understand it is painful to scrap the product and that you are poorly capitalized to absorb the loss.  That does not change the risk/your responsibility to consumers.   It may be as seemingly trivial as iron (alot of iron in your water?) and  the hydroxamic acid in Spectrastat (prob not - with EDTA in system).  It may not. 
This is a test of your business practices.  What is your evaluation of quality?

[PhilGeis]

Abdullah said:

PhilGeis said:

Whatever it is, you need to scrap it.  It is clearly adulterated.  And that is a pretty lame presrvative system.

You mean scrap only that red part or the whole batch? 

Spectrastat G2 from Inolex has 
%0.1 caprylhydroxamic acid
%0.75 glyceryl caprylate
%0.15 glycerin 
And they say it is broad spectrum preservative.
So at pH 5, with a chelating agent isn’t that enough for Shampoo? 

Yes - the whole batch. “Broad spectrum” is the marketing hype offered for every preservative and that is very weak system - esp. for a shampoo.

[PhilGeis]

Doe you think your ingredeints are clean?  Is there heat in your process?    Just get a content test of a representative packaged product.

The general objetive of cleaning products is to deliver it of apprpriate quality rather than ensuring consumers don;t screw it up.

[PhilGeis]

Whatever it is, you need to scrap it.  It is clearly adulterated.  And that is a pretty lame presrvative system.

[PhilGeis]

I’m no sure you need a preservtive for this hard surface cleaning product.  recall preservatives are intended to protect consumers in-use and that is of diominished concern with hard surface cleaning products.  

But be aware - preservatives used in household/industrial products must be registered as pesticides and in context of product application.  Suttocide A is an excellent preservative, and you must use the version registered with EPA for your application.  Do not use the cosmetic grade.    See: https://www3.epa.gov/pesticides/chem_search/ppls/057978-00004-20031106.pdf

I’m not aware that it’s “useless above pH 6.”  Matt can you elaborate?  As marketed, its pH is 10-12.
https://www.ingredientstodiefor.com/item.php?item_id=262

[PhilGeis]

Thanks zetein - one is in a pump and surfactants as raw materials are often also preserved .  Combination wth sufactants does effectively increase pKa - still, good luck with those.   

[PhilGeis]

I’m with you in preferring addition of individual preservatives.  Prepared mixtures lock you into ratios.  
I assume you’re not selling in Japan.