All posts by ohohorg.com

THE CERTIFICATION PROCESS
Let’s talk about how cosmetic products get certified under the NOP. Maybe it will help people see how this food model interacts (or does not) with cosmetics.
Start with the qualifications – the NOP allowed everyone who wanted to, to become a certifier initially (2001) – whether they had the experts on hand or not. As years have gone on, the NOP has tightened up and are requiring more and more of the certifiers to demonstrate greater management expertise and product/service expertise. They have still not looked at the education as it relates to fine points but they do require that you show that the people making decisions have some education, training, and/or experience in the area that they are certifying, i.e., livestock decisions need to made by people that have qualifications for working with livestock management. The NOP is actually rescinding the right to certify in certain areas of the “Scope” (Farm, Livestock, Processing) if the certifier cannot demonstrate the necessary expertise to assess and make an informed decision about the products at hand.
Then what happens?
An applicant fills in forms (that were designed to evaluate food production) and submits these along with a recipe or formula or …whatever you want to call it. In their “Organic System Plan” they explain how they manage the procurement identification, physical handling, and batching of the organic and allowed non-organic inputs to the finished product. They also have to provide documents that “prove” that the non-organic ingredients comply with the requirements of the regulation (non-gmo, not irradiated, not solvent extracted, etc.). The certifier is obligated to “confirm the ability to comply” and then they can set up an inspection. Then you (applicant) should be able to “prove” through documentation that anything you say you do, you have, indeed, done. For example, if you say that you wash down the line and remove the residue of the sanitizer, you should be able to prove that, 1) the sanitizer can be removed (which is not the case for quaternary ammonia products) and that, 2) you have logged the practice of implementing your sanitizing procedure. If you say an ingredient is “organic”, you need to have a current certificate AND an invoice to prove you purchased ingredient. Oh – the certificate needs to match the invoice. You can’t buy it from someone that is not qualified to sell it – unless the package is intact and the vendor is a broker of a trader. An example of this is that I sell some oils in their original drums and can provide the cert from the original packer and their label is on my certificate – either way it proves my handling of those products is compliant. This is what the certification world refers to as “audit trail”.
So then – it comes to the “on site” inspection. The certifier sends an inspector to verify that what ever you say you do, is being done and that you are not doing things that you have not represented in the “Organic System Plan” or OSP (think of the OSP as GMPs for organic.) 
Here are a few of my concerns: in an environment where a company is synthesizing ingredients like soaps or glycerin or esters, the certifiers usually have no experience at all in synthesis chemistry. Now this is fine if the applicant knows all the rules and does it all according to the rules, but if the chemist is thinking one thing and the inspector is thinking another and there is a lack of understanding…than things can get certified that, perhaps, should not be. This can happen, for example, because certifiers ask for “processing aids” and never mention reagents or catalysts (again, not used in food production) or simply because what is so simple or normal to a chemist and may not be allowed under the NOP but “food” language if different than “synthesis chemistry” language and things can get cloudy. Another area of concern is the making of finished products. If a company runs hair care products through their equipment and does not have dedicated organic equipment or a way to truly remove the residue from quats and silicons, they are making “organic” product that is contaminated due to contact with these 2 categories of materials. Since most certifiers are unaware that these materials are used as ingredients (in the food world they would only look for quats in sanitizers and they don’t use silicons at all in food) so…they may not ask about these materials at all, they would be invisible and would remain as contaminants under an NOP system.
Further more – since many of the certifiers do not have chemists on staff, they are making, what I call, “Google Decisions” about some of the processes that they certify – they have no first hand experience or knowledge of the process but they’ve looked it up on Google and seem to glean enough info to make them comfortable about certifying it.
I won’t even get into the issue of certifying cosmetics to a food standard that requires food labeling laws but are being labeled under INCI.
Summed up: when decisions are made by a certifier who is not FULLY informed, there exists a chance that the certificate could be pulled at some date, or that labels are wrong, or lord knows what else. That is the time to remember that the applicant is responsible for the law. You need to understand it better than your certifier because they will have plenty of customers and no one really knows who they are. Brands, on the other hand, have a reputation to protect. Look at Johnson & Johnson.

MAKE A COMMITMENT!  Natural Beauty Summit May 2009 Report 
Okay – so I am not really “just back from” the Natural Beauty Summit (NBS) but, after a couple weeks of the normal mess involved with moving, I am getting around to a report. Keep in mind – these are the things that stuck in my head 2 weeks after the event.
After 2 days of (estimate) 30 people speaking, there is no doubt that “organic” and “natural” are here to stay for a while. At the same time these label claims are being increasingly held up to scrutiny, hence the various standards. Listening to the various people that got my attention, I came away with two messages –  1 – make a commitment, 2 – and we really do have a problem with waste in this industry.
Make a commitment: Mike Indursky of Burt’s Bees and Ido Lefler of Yes to Carrots hit the same theme: pick a standard, get certified, commit and support the standard you’ve signed on for – use the logo to your advantage, any logo, any program, just commit. We should keep in mind that not everyone has the million dollars that Burt’s put into marketing the NPA logo which, from what I hear, is expensive and not transparent in it’s delivery process – but what the heck – if you have an NPA product out there you should send a “thank you” letter to Mike. 
Then Jasper van Brakel (CEO Weleda North America) discussed the 80 odd year history of Weleda and their steady climb through the market place by recruiting growers to grow the Bio-Dynamic crops used for the herbal products they make. This is an “inside-out” approach – buy my product because of what is on the inside of the bottle. This is a commitment to their own company policy and ethos. Their company age and the simplicity of their ingredients makes this very achievable for them.
The counter to the above speeches was the presentation about the “Cosmos” Standard which is supposed to be the “harmonized” EU organic and natural standard that totally confused most people there. Evidently the “harmonization” is not planned to occur until 2012 and then they only need to use the standard as a base line! So much for that idea.
I presented about  OASIS, we are marching along (that is another blog) and Joe Smilie of QAI tried to convince everyone that the Dept. of Ag (USDA) would be able to enforce cosmetic labeling and use the NSF “made with” standard. He failed to mention that the use of synthetic materials is prohibited under the Organic Foods Production Act, the law upon which the USDA-NOP regulation is based so . . . it probably won’t happen. Hello! This is personal care – surfactants, preservatives ad emulsifiers are ALL synthetic, even if they are “good” synthetics. We need a different approach than the food world needs.
Waste: There was a great presentation about “cradle to grave” certification (something we are working on at OASIS). I know that personally the packaging of cosmetics has always blown my mind – of course I grew up next to Berkeley, Calif., in the days when we went to the first (real) Body Shop where one re-filled bottles with personal care product base and added one’s own choice of fragrance – at least until the State of California stopped that practice as “unsafe”. Okay – so maybe we needed to return our bottles and have them sterilized first but . . . what are a few bacteria compared to the tremendous pile of garbage we create daily? Point being, that this industry has much greater issues to grapple with in the future. There were many talks that touched on these long term issues. They start you thinking.
So – the marketers pushed the need to craft and commit to a clear message (put that way, it doesn’t sound very original, does it?) and the environmentalist pointed out the continued long term implications of what we put down the drain and in the garbage.
There were also sessions about using “food” as personal care ingredients, something I’ve worked on for 10 years – so, in view of my need to start moving 6 years of stuff into a new home, I opted to leave. I’ll make a few calls to folks that attended it and let you know the outcome.
All that said – it was a good conference, expensive but, I think worth it, and I look forward to the development of this particular venue to support and educate the cosmetic industry.

Whether You Are Certified Or Not; Good Ideas

I was talking with a friend about how I comply with my org. certification and he thought I should post it. Here you go:

One part of the regulation, 205.200, says: “Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality.”

Most certifiers do not enforce this – but I think it is a good idea regardless so every year I try to find a new way to add a practice in my business to my organic system plan (and my business procedures) to reduce my impact on the planet. The first year I simply made sure that all my boxes and all my office paper were recycled – to some percentage. The next year I figured out that I could give all of my empty drums to folks who were either in the bio-diesel business or who wanted to make barbecues – so I posted in the “for free” section of craigslist. No more problems looking for homes for my empty drums! Then I switched to 100% recycled/bio-degradable puff for packing our boxes. Most recently I wrote all of my customers and told them we wanted to shift to paperless invoicing – we email all invoices (I do have 2 customers that insist on paper). This saved paper, envelopes, time, gas to the P.O., stamps, and printing ink! We done a few other simple things, swirly light bulbs, up the recycle content of boxes and paper, we recycle everything anyway – it is law in our county.

For next year we are talking to the landlord and I’m helping them shift the entire landscape around our building to native & Mediterranean, low water need plants (getting rid of the grass – not like were playing football here!). Fortunately I have a hobby of brain dead low maintenance gardening so I’ve got the resources, suppliers and plants at my fingertips. We think we can save the building (CAM if your are a commercial renter) a bunch of money with this change.

Anybody have any other ideas?

Harmony or Sustainable Public Policy?

There has been a lot of talk about the need to harmonize the few organic standards out there for cosmetics. I don’t believe we need to do this just yet. This does not mean that I don’t recognize that there is confusion – there is! Let’s ask the question – how do harmonized standards come into being? History, conveniently, shows us in the story of how we got organic food standards; I lived it for the organic food standards and only recently really came to understand how I lived through the creation of “public policy”.

Once upon a time a bunch of farmers decided they wanted to “certify” their growing practices. So they each inspected the other and this evolved into 3rd party certification of organic practices (this is the really short story of certifiers like CCOF, Oregon Tilth, OCIA, an most of the non-profits). This happened in the ’70s and ’80s. Then in the ’90s, people wanted to have “certified” processed foods. So the various certifiers (of whom there were over 40) started to write “processing” standards borrowing parts of standards from each other, and eventually we had over 40 certifiers in the US with over 40 different standards and every one was “better” than every one else but it was all “organic”. This went on for 11 years. There were over 40 seals and everyone had the chance to develop a market without too many restrictions – good or bad as that may be. In the late ‘90s there was a real problem with reciprocity – for example, a CCOF product may not accept a QAI certified ingredient.

The lack of reciprocity prompted the OTA (The Organic Trade Association) to push to harmonize the standards. A draft harmonized Standard was written by an OTA commissioned group and, in 1999, most of the larger certifiers signed on and agreed to use it, (of course this meant they had many meetings with their members and collected their thoughts). This was just as the NOP draft standard was being designed in Washington DC. A note – the first draft garnered something like 360,000 written comments sent to Washington. This is the heart and soul of the public working on their own regulatory policy.

By October 2002, when the NOP was implemented, there was a robust “organic” food industry and a clear perception by many manufacturers that the idea of making ingredients for the organic industry was a great niche. This motivated the creation of multiple specialized organic ingredients and motivated better and more organic products. So – what we had was 12 years of education of growers, inspectors, manufacturers, retailers and consumers. We “grew” the market along with the idea of organic. It was clear that processed foods could be “organic” and were a viable market force. This gave people the time to develop the necessary infrastructure to make organic food a reality.

Somehow we went off the tracks when we tried to do the same thing with cosmetics. People seemed to think there should be a single, regulated standard for cosmetics without any of the opportunities to develop the infrastructure that goes along with building the standard. It is important to realize that no government will regulate anything that does not have a consensus in the intended industry. While we may find “organic” clearly better, the FDA does not perceive the use of organic ingredients to be a health issue. They are not going to go out of their way to support this and USDA cannot do it without FDA – USDA has no regulatory authority and they do not have any chemist on staff that could credibly oversee the program. I believe USDA would be extremely averse to regulating cosmetics in any way without buy-in from FDA. You’ve got to ask yourself, is that what you want?

In the mean time we have people announcing they have the “one true standard” (gee, why does that feel like England in the 1700s?) and people suing other people over “ideas” (and why does this feel like the 1950s?) of what a standard should look like and certifiers who are certifying organic cosmetics that have no idea of what happens in a cosmetic manufacturing environment. Yes, it is confusing. It is also normal when new ideas butt up against people who have a business in the mix.

The way I see it, everyone; the manufacturers, the ingredient people, the consumers, and the advocates, need to hammer away on various standards until we get closer and closer and can all, finally, agree on what “organic” means” when it is on a cosmetic. We can’t do that until we get some standards out there and stimulate more ingredient innovation and production and get people involved! Right now we have all sorts of ideas but not much action

Based on history, we should do the same thing that occurred throughout the ’90s for organic food; respect and support the various standards out there, keep demanding more credibility and more organic ingredients, and continue to evolve this very important path to clean and sustainable cosmetics and personal care products. The folks who are extremely concerned about “organic” can buy USDA certified organic personal care products until such time as other standards are acceptable to them. In the mean time, I want to participate in the good old messy American process of “public policy” work.

Okay – so this has nothing to do with organic cosmetics – just with humanity. 

I’ve always that thought that the people who go on those low carb diets were nuts. The human body needs fruit, vegetables and some other form of carbs. Now I know, they aren’t just nuts, they are dumb. In a recent article in a science journal, “Appetite”, a group of researchers at Tufts documented that low carb diets, compared to restricted calorie diets, resulted in reduced cognitive abilities of the participants. If you eat less but still a balanced diet, you get glucose to your brain and every thing works as normal. When you go no carb – there’s less glucose getting to your brain. You get dumb. The person that figured out the no carb diet must have been on a  . .  no carb diet! 

Does Our Skin Absorb Personal Care Products?

Some of you may not know that, although I do not practice, my education was as a physiologist and the science habits I learned have lingered. I can’t hear people make certain types of claims without wanting to know the source of their science and wanting to know their definitions.

I continue to hear and read various claims about cosmetic products applied to the skin (I’ll address lipstick later):
– “80% of everything you put on your skin is absorbed!”
– “60% of everything you put on your skin is absorbed!”
– “98.8% of “chemical such and such” is absorbed into your skin.”
– “Your skin “eats” the products you put on it.”
These types of comments have always bothered me – why? My weird brain:
1 – Personal care formulas are made of a range of all water-base, all oil and everything in-between. If someone said that 60% of a formula absorbs into skin and it is 60% water and the rest is derived from oil, do they mean that 60% of the water soaked in? Or do they mean that some of the water and some of the other ingredients “absorb”? What do they mean?
2 – Think about it – if your skin absorbed 60 to 80% of what you put on it, wouldn’t you start to look a little puffy? I keep having visions of the Michelin Man when we get out of the shower . . . if we absorb all this stuff – where does it go? What happens in the shower, do we absorb all that water? Where is the logic in these statements?
3 – I know, because I have done my homework, that most oils are large molecules. They just are too big to be absorbed into skin – they sort of snuggle down into the 2nd layer of the epidermis and stay there, or they sit on top of the skin. There are some small molecules, and I would question those, but I doubt it is 60 or 80% of any formula.

I believe we should always question any blanket statement. They sound too much like myth. When you think about the fact that most liquids have some degree of volatility, then we need to account for temperature, humidity, and the individual volatility of the material. Alcohol, as we can all feel, evaporates rather quickly. If skin or the air is warm, alcohol volatilizes really fast. So, if essential oils are in the formula, do they evaporate? If it is cold, do they all congeal on top of your skin? What about formulas high in water? I’m going to guess they would behave differently in Arizona in July versus Maine in December.

The physical science of liquids (lotions and other products) applied to skin is extremely complex and NEVER predictable enough to say that any specific percent of any topical application is consistently “absorbed”. (I actually read a couple of heavy-duty research papers that demonstrate this statement through research). Next time you hear such a statement, ask what the heck they mean. Absorbed to where? Absorbed under what conditions? Which parts of the formulas – the water, the oil, some magic combination?

That said, I do suspect (have read verification) that the vast majority of personal care items are washed down our drains. That does worry me. More on that later.

Oh, and if you want to learn a bit more, check out this web site to learn about skin structure: http://dermatology.about.com/cs/skinanatomy/a/anatomy.htm

Happy Saturday! Gay

Seal, Seal, Who’s Got the Seal?

Have you ever stopped to look at how many “organic” certification seals there are on “organic” food products? I just took a bunch of things out of my cupboard and when I placed them all out on my counter, I counted 11 different seals on 17 products: USDA, CCOF, QAI, OTCO, ICS, SGS, WSDA, TDA, CDA, GOCA, and EcoCert. Some had the USDA and the certifier seal, some had just one or the other. Question? Is the organic “seal” the important thing to the consumer? I don’t think so.

So, at a recent conference when multiple presenters bemoaned that cosmetic “consumers will be confused by all the different organic and natural standard seals” I just had to shake my head in amazement. The market is growing at 20% to 25% per year (for food, more for cosmetics) and clearly, it can’t be because of the multiplicity of seals, maybe in spite of all those seals?

In the days when the country was collectively writing and commenting on what became the “USDA Organic” regulation, there was a REALLY big fight; the 40 odd certifiers in business here in the U.S. (we won’t even include the rest of the world) all wanted to continue to require the use of their own “seal” on products they certified. The USDA wanted only the USDA-NOP seal allowed. The final compromise was that you could use either one or both seals – your certifier seal, the USDA seal or both seals. This was an opinion that came from certifiers, not from consumers.

The USDA oversees the credibility of American agricultural products. In the case of the National Organic Program (the NOP) the meaning of the USDA Organic seal is intended to communicate that there is a single standard, one that means the same thing from Bangor to San Diego.

The fact is most people have a fuzzy idea of how certification works. I probably explain once a week that if you are getting certified to the USDA-NOP, you are being certified to a Federal LAW by an accredited private agency, also known as an Accredited Certification Agent (ACA). You are NOT certified to CCOF or Oregon Tilth or QAI – they certify you to the USDA-NOP regulation. To my mind it would be better if the food world only used the USDA seal, then they would be sending a unified message.

Back to the issue of “new” seals on organic cosmetics: if a few more certification agencies pop up in our part of the world (body care), I think it is okay. It really can’t get any more confusing than it already is in the food world. There are 98 ACAs in the US, all of them pushing their respective seals on products. A few more that are specific to cosmetics probably really won’t change the landscape all that much. Meanwhile, we work to collectively decide what “organic” means on a “cosmetic” or personal care product. This has worked for the 40-year history of the organic food standards and I don’t think it will hurt “organic” cosmetic standards to take a similar path.

Happy Saturday – Gay

Copyright, G. Timmons – June 7, 2008