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Organic Documents for Organic Ingredients – MiniBlog

Do you have the organic certificate for each of the organic ingredients you call out on your
ingredients list?

Think about it – a label is a promise to a consumer. If you have not verified that you have a duly certified product, you could be in trouble and that would be a problem for your growing brand. Maybe you only use organic ingredients. That is great but…the USDA-NOP (National Organic Program) has the right to ask you to show them an organic certificate for each ingredient at any time – especially in California (where we have a State Organic enforcement program). Do you have those certificates on file?

Here is some info about requesting organic certificates:

  • What Standards are acceptable? The USDA-NOP is a LAW in the US that establishes the rules for organic production – from seed to finished product. There is an equally rigorous law in the EU member States and the US and the EU have reciprocity – we accept each other’s organic certificates by any ACA.
  • What is an ACA? An Accredited Certification Agency – these folks have been inspected and approved by the USDA. The link takes you to a list of US ACAs that are in good standing.
  • Do I need to have a finished product certified? You do not – however, if you claim that an ingredient is organic, it must be certified. If someone won’t send you a cert, they may not be certified and the ingredient may not be organic.
  • What if I want to be certified? Since cosmetics may contain ingredients that cannot be certified
    (surfactants, emulsifiers, and preservatives) under the food rules you may want to look at the Cosmetic Standards: COSMOS, NaTrue, or NSF-305

We are certified by Oregon Tilth (aka OTCO) and we are inspected once a year and receive a new
certificate each year. If you are using organic ingredients you are responsible for requesting a copy of the certificate each year.

“Natural” Documents – MiniBlog

Have you defined what NATURAL

means to you?

If you use the term “natural” to describe your ingredients or your finished products you may want to consider writing a definition of “natural” on your web site.

First, let’s make clear that a synthetic, in my world, means a human has made a new molecule.

What? New molecules? Well, oil, for example is naturally occurring in seeds and nuts and the molecules that make the oil is not changed when it is pressed out of the seeds. A simple example of a new molecule is soap: oil and lye are reacted. The mixture gets hot, a new molecule is formed and, violá, you have soap or Potassium Cocoate (made from Coconut Oil plus Lye – for example this is how they make Dr. Bronner’s soap).

I further categorize synthetics as good chemicals or bad chemicals. Good chemicals are made using a renewable resource plus using the Principles of Green Chemistry (see previous mini-blog for the reference to this paper). Bad chemicals are everything else and usually bad for the environment and most living creatures.

A “natural” ingredient is extracted from a plant using mechanical means like pressure, steam, or water extraction. This definition is published in the EPA regulations, although people seem to believe that “there is no legal definition of natural”. Wrong, it is in our existing laws.

Different companies define “natural” different ways – but you need to be clear. If you can verbalize a definition to your consumers, the courts are more likely to support you. Also – if you can’t explain it, how can you mean it?

For more on definitions, check our Definitions & Links page.

My Product is Certified Natural – Isn’t It “All Natural”?

The problem with “All Natural” or “100% Natural” claims

There is some confusion about the claim “All Natural” or “100% Natural” or even just “natural” by
companies that are certified to a “Natural” standard.

This is how it works: both the natural and the organic cosmetic standards allow the use of
synthetics (human made molecules), however they need to be made using plant based feed stocks and the Principles of Green Chemistry*. This means that people use ingredients that are “allowed” because they meet these rules but they are synthetic ingredients. They also use natural ingredients that are not synthesized like oils and waxes and plant extracts.

Example – the Principles of Green Chemistry allow hydrogenation as long as the molecules are fully saturated (not trans-fats). That means we are allowed to use vegetable waxes in COSMOS (formerly EcoCert) products if they meet the requirements of the standard. But they are still synthetic. Another example is plain old Castile Soap: coconut is reacted with potassium hydroxide to make “potassium cocoate”. Clearly a “chemical” even when “made from organic” ingredients.

In summary, companies claim “All Natural” because they are certified to a natural standard but
they clearly list synthetic ingredients on their ingredient list.  This is confusing to the consumer. It also means the Brands don’t really understand the standard they are using. Sometimes it means the Brand may be sued by mean attorneys who give nice attorneys a bad name and harass sweet brand owners. (Okay – I’m defensive.)

Synthetics are not “bad” if they are made from renewable inputs using safe methods and resulting in safe chemicals.

If you have been threatened by one of these suits and need a referral, let us know.

* The 12 Principles of Green Chemistry defined by: Anastas, P. T.; Warner, J. C. Green Chemistry: Theory and Practice, Oxford University Press: New York, 1998

Mislabeling: The FDA and the The No-No Words

A lot of cosmetic brands seem to have a “No-No List” of ingredients. I think it is time for a list of “No-No” words – because, you know, FDA and “mislabeling”.

The basic thing you need to keep in mind is that unless you are selling a registered, approved DRUG, you may not any use words that promise a medical outcome. That is considered mislabeling and mislabeling is against the law. So – here is a partial list of “No-No” words:

  •    HealMislabeling
  •    Healing
  •    Anti-inflammatory
  •    Anti-microbial
  •    Anti-bacterial
  •    Cures
  •    Penetrates to (heal, sooth, etc.)
  •    Stimulates circulation …
  •    Treats
  •    Alleviates eczema, rosacea, scarring, acne, etc
  •    Improves circulation
  •    Minimizes
  •    Improves the skin’s immunity
  •    Boosts collagen
  •    Protects from UV Rays (this = sunblock – and must be registered with the FDA)
  •    Protects against infection
  •    Cellular regeneration

Oh, I could go on. What these all have in common is what the FDA calls a “structure-function claim”.  Structure = a body part (skin, muscle) and Function = changing the physiology of that body part. These sorts of claims = DRUGS and are seen is mislabeling by the FDA. The USDA-FDA makes a lot of money approving drugs so if you have not sent them a couple 100,000 dollars, you are probably not selling a drug.

Look at your website – are you making structure-function claims? If so – use that wonderful, free thesaurus on Google and fix it before you get a scary letter from the FDA. You can “change the appearance of”, you can “sooth the symptoms of” you can do all sorts of things, but no structure function claims! You do not want a letter from FDA accusing you of mislabeling.

The organic and natural cosmetic industry needs to look good in the eyes of the law. We do not need big manufacturers telling the FDA that we should be heavily licensed or regulated. We need room to grow. Know the laws. Respect them. Do good work.

Hugs                   Resources:    Choose Your Words                          Link to FDA Article

 

3 Things to Know about Ingredient Quality

Organic Ingredient: Castor Oil
Castor Oil – I think it is beautiful!

You probably use a number of ingredient suppliers…

 

1 – When buying organic ingredients, always ask for a Specification from the supplier. This describes the physical and chemical characteristics of what you bought. Like: Color, Aroma, Form (liquid, solid, etc.), pH, and so on.

 

2 – Okay – you just received the ingredient shipment. You asked that it be sent with a C of A (Certificate of Analysis). This is the proof that the product meets the requirements described in the Specification. First, compare the C of A to the Spec. and make sure the C of A meets the description in the Spec. Now look at a small sample of the ingredient. Does it match the description on the Spec? See the example below.

 

3 – Small companies (us included) have neither a chemist nor the equipment in-house to test the product. If you compared the physical characteristics and they all passed, then you can trust the chemical characteristics EXCEPT: you should have a program that specifies that you send samples to a testing lab on some schedule.

 

Every other month we sent samples of at least 3 of our oils and other ingredients out for various types of tests. Since we sell oil, we like to know what the Peroxide Value is. This tells us if the oil is “stable” and not going rancid. We usually test the peroxide value and compare it to the Specification to assess the quality.

 

Sometimes we’ll send samples of our ingredients out to test for bacteria, yeast and mold. Although – oils do not support microbial growth so we’ve never had a positive.

 

You don’t need a full lab to assess quality. You need eyes, nose and commons sense and a written procedure to randomly test your ingredient quality at a reliable analytical lab.

 

If you need help finding a lab, let us know. We may be able to refer you to one near you. If these documents are still a mystery, come take a class. See the classes listed in this site: http://ohohorganic.com/class-description/

 

For more information about why this issue is important, check out: https://www.beautyindependent.com/gay-timmons/

 

Plant a tree, start a compost pile, smell the glorious roses. Join www.nohba.org

What We Knew All Along: Sperm Count is the Canary in the Coal Mine

When any population shows a marked decrease in reproductive health, it is serious. Today we are talking about “humans”.

In an opinion piece quietly published in the NY Times by Evan Hepler-Smith, he pointed to a study that indicates sperm count for men in the US, the EU, and Australia/New Zealand has dropped since the 1970s by 50%.

I look at this statistic as a “vector”, an arrow pointing to a significant issue or trend – in this case this vector means that human reproductive health is seriously threatened.

He also pointed out that the massive number of chemicals we are exposed to is the most likely culprit.

Here is a link to the study: https://academic.oup.com/humupd/article/doi/10.1093/humupd/dmx022/4035689/Temporal-trends-in-sperm-count-a-systematic-review

These chemicals are coming towards us from every possible direction: food, the personal care products we use, the chemicals we use in our homes, even the substances that our furniture is made from.

As consumers, we need to demand that this massive animal experiment be stopped: we are not rats to be experimented on for the profit of some CEO & his shareholders at a chemical company.

Read labels. Complain through web sites. Write your Senators and Congressperson about the EPA.

Participate.

 

Hugs

 

 

 

 

 

 

Sustainability Rant #2 – July 31, 2017

What does “sustainability” mean?

For the past 20 or so years international companies have been talking about their “Sustainability Programs”.

We supply a couple of the international cosmetic companies. Recently one of them did a Sustainability Survey and our “sustainability” was evaluated and rated in the 70th percentile. This by a company that uses 4 layers of packaging when they sell you a single one ounce skin cream that invariably includes a significant number of petrochemicals and probably nothing organic.

Oddly, they liked that we replaced our lights with LEDs – they seem to think light conservation is more important than the ingredients they use.

None-the-less, I was irritated by the rating – hence the rant.

So – to be VERY clear (as everyone in DC seems to be saying these days), this is what Oh, Oh considers minimal sustainability practices & procedures for an ingredient business:

First – what is the principle statement of your “Sustainability Plan”? Ours is: We are committed to practices that looks at the long-term environmental impact of actions and decisions by our company, especially with reference to our major business activity. Decisions should be constantly re-evaluated and updated (on-going improvement).

So – what are some Sustainable Activities?

  • We sell ingredients as our major business so all of our products should be renewable:
    • Oh, Oh sells ONLY Certified Organic Agriculturally derived ingredients
    • We re-cycling everything possible. Goal: have less and less in the “garbage” can.
    • How do you use water? Much going down the drain? How can you change that?
    • Constantly assess packaging materials and look for more renewable alternatives.
    • Hire good people who care, train them, and pay them decently – it is your team. You need to depend on them. Let them go if it is not a good fit.
    • Try to provide health care to full time employees. (It took us 10 years but – it feels so good).
    • Think about freight impacts – we focus on the West Coast. We do offer a few things for our East Coast customers from a warehouse in NJ – we hope to open a full warehouse in NJ next year.

Then:

  • Practice what you preach:
    • Eat organic as much as possible.
    • Buy a hybrid or an electric car or a bike. Take public transit.
    • If you can’t do the above due to money – family – whatever – make a plan to get there (see “on-going improvement”).
    • You can always try again tomorrow.

And no – we are not certified to multiple various privates Standards. We are too small and too smart to pay 5 different companies to fly people to inspect our legal organic handling operation. We are not going to add to air pollution to have someone tell us that our skylight and roll up doors are a great replacement for electric lights. We are not going to pay for some volunteer ”sustainability” company that doesn’t care or practice what they preach and has no accountability.

We do pay to be certified to a Federal Law (7 CFR part 205) – under the USDA National Organic Program. Sustainable practices are measured in the regulation! We are inspected every year. All of our suppliers are also certified to this program (except the Non-GMO Tocopherol – they are certified to the ISO program that is law in the EU).

I want grandchildren and I want them to be able to enjoy this planet. Let’s get on it folks!

 

 

FDA Bans 19 Antimicrobial Soap Ingredients

So many things went through my mind after the initial and loud cheer when I first read this announcement.

The first thing was my happiness about the act. Then I got scared because…the FDA has resisted this action since the 1970s and this ingredient list effects so many products (almost any soap that makes an “antibacterial claim”) that – there had to be serious pushback from the industry. What looming catastrophe caused them to finally do this? What sort of danger are we in?

Many of the banned ingredients are already banned in the EU and Canada. They are suspected hormone disruptors, bio-accumulative and known aquatic pollutants.

So now what?

All I can say is, if you know anything about DDT, it was banned in the 60s and we are still dealing with the long-term effects of this powerful environmental toxin and pollutant. This new FDA ban currently only applies to soap; these ingredients are also used in toothpaste, mouthwash, and other products.

So – FDA – now what?

Palm Done Right™

A Model For All Producers Part 2

 

This is personal: I have kids and I want grandkids and they should be able to breath and travel and love the world they live it. In order to clean up some of the mess that we’ve made to date, everything on the planet should be made from renewable resources using environmentally benign methods. Everything should be safe and replaceable without destroying the planet. So I am thrilled to be writing about Palm Done Right™.

Palm Done Right Logo

WHAT IS PALM DONE RIGHT™?

The simplest description is that Palm Done Right™ (PDR) is a model for growing and producing palm products that is not destructive.

Currently, PDR includes 130 farmers (and growing) in Ecuador plus more farmers in Sierra Leone who own their own farms and work in cooperation with Natural Habitats. Natural Habitats provides programs to improve farming methods and tools, community programs, crop collection and processing and then markets and sells the oil and oil products worldwide for these farmers. In 40 years of looking at farms, this is the only truly sustainable project I’ve ever seen with multiple growers for this type of crop.

Natural Habitats has created the Palm Done Right to help you to learn more about what they are doing. This site is also a partnering tool that will allow you to link your customers to this valuable information and to support the PDR program individually.

As they say, a picture is worth a thousand words. I pasted below some of the pictures from my trip and short commentary. Also, go to the Palm Done Right and read a more complete story.

Join us in partnership with Natural Habitats and Palm Done Right™ and show the world how to grow and use this amazing ingredient the right way.

 

MY TRIP TO ECUADOR AND Palm Done Right

This is the first of 3 palm farms we visited - the growth on the tree trunks are epiphytes that live on the trunks and don’t seem to effect the tree’s fruit production. It was 93 degrees F and humid - like sweat through your clothes in 5 minutes humid/hot. These trees are about 20 years old and have about 5 more years before they are replaced because they get too tall to harvest. A 40 lb. bunch falling 25 ft. to the ground makes a real impact!
This is the first of 3 palm farms we visited – the growth on the tree trunks are epiphytes that live on the trunks and don’t seem to effect the tree’s fruit production. It was 93 degrees F and humid – like sweat through your clothes in 5 minutes humid/hot. These trees are about 20 years old and have about 5 more years before they are replaced because they get too tall to harvest. A 40 lb. bunch falling 25 ft. to the ground makes a real impact!
2nd farm - day 2. The trees behind this guy and his burro are about 3 years old. This is when they begin to bare fruit. The fruit contains both oil and a kernel that produces more oil. This guy will cut the ripe bunches of fruit out of the tree and these weigh about 40 lbs each. They load them into these containers on the burro or mule and bring them to the roads that wind through these hilly farms to a collection slab on the road. Trucks collect the bunches and take them to another central collection point in the town. then in a larger truck to the oil mill.
2nd farm – day 2. The trees behind this guy and his burro are about 3 years old. This is when they begin to bare fruit. The fruit contains both oil and a kernel that produces more oil. This guy will cut the ripe bunches of fruit out of the tree and these weigh about 40 lbs each. They load them into these containers on the burro or mule and bring them to the roads that wind through these hilly farms to a collection slab on the road. Trucks collect the bunches and take them to another central collection point in the town. then in a larger truck to the oil mill.
Don't these look like dinosaur toes? This is a young tree with newly growing fruit bunches coming out from the leaf base. These trees grow to about 25 feet high and the fruit always grows out like this - so as they get taller it is more a challenge to cut the bunches.
Don’t these look like dinosaur toes? This is a young tree with newly growing fruit bunches coming out from the leaf base. These trees grow to about 25 feet high and the fruit always grows out like this – so as they get taller it is more a challenge to cut the bunches.
This is the oil mill - where they produce crude oil. You are looking at the collection slab and beyond at one end of the plant.
This is the oil mill – where they produce crude oil. You are looking at the collection slab and beyond at one end of the plant.
The palm fruit bunches are loaded into these little rail cars and moved into the steam chamber. The steam loosens the fruit from the bunch. The left over plant material is burned to produce energy, the steamed bunches go into a rotating cylinder where the fruit falls out of the bunch.
The palm fruit bunches are loaded into these little rail cars and moved into the steam chamber. The steam loosens the fruit from the bunch. The left over plant material is burned to produce energy, the steamed bunches go into a rotating cylinder where the fruit falls out of the bunch.
The next pictures are from the most beautiful farm we saw – owned by an engineer and his wife - the Andrades. They have a gorgeous bamboo home with this beautiful bamboo deck where we met the owner.
These pictures are from the most beautiful farm we saw – owned by an engineer and his wife – the Andrades. They have a gorgeous bamboo home with this beautiful bamboo deck where we met the owner.
Various buildings on the property. Nice digs for an Alpaca!
Various buildings on the property. Nice digs for an Alpaca!
Can't resist a picture of this gorgeous collection of local fruit.
Can’t resist a picture of this gorgeous collection of local fruit.

 

 

 

 

Palm Done Right™ – Why Is Palm Oil Such a BIG Deal? Part 1

Facts about Palm Trees and Palm Oil Products:

  • African Palm Trees are the highest volume producer of oil per acre of any plant.
  • Both palm and coconut trees only grow in the equatorial belt (rain forest).
  • Palm trees may produce twice-as-much oil per acre or hectare as coconut trees.
  • Palm trees live for about 40 years and produce year round.
  • There is a worldwide push to reduce the use of palm oil.
  • Palm oil and coconut oil are chemically very similar.
  • 70% of all cosmetic chemicals are made using palm oil.

Now let’s connect some dots: if palm trees produce twice as much oil as coconut trees, then if people stop using palm oil, the chemical manufacturers will turn to coconut oil. Which…uses twice as much rain forest land.

Do you really want to destroy twice as much rain forest?

One proposed solution was to write the RSPO (Roundtable on Sustainable Palm Oil) standards and ask all the palm producers to follow them. There are four levels to this standard – none of which really protect the people or animals that have lived on the lands for millennia nor does the standard protect the diversity of rain forest. The highest level requires that one can track their palm products back to the farm (“Identity Preserved”). Natural Habitats is certified to this level of the RSPO Standard. The lowest level is similar to a cap and trade system – one buys “RSPO” tradeable certificates. There are multiple problems with this standard and with the economics of most palm producers. Not impressed.

A better solution is to use a model that empowers individual farmers and supports a return to rain forest land diversity and economically sane production. We should also demand that governments get out of the business: right now they are giving land over wholesale to large corporations who have no concern for the people, plants or animals that have always been on this land.

There is a way to grow what we need and do it without destroying the planet.

For more on that – see our blog: Palm Done Right™ – Part 2. A description of the model developed by Natural Habitats Inc. that is being used in Ecuador and Sierra Leone to grow and process organic palm in a completely sustainable model.

Save the planet, look good doing it.

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