Category Archives: Uncategorized

Welcome

So – new physical site seemed to indicate we needed a new web site. One that I can change at will. And I will … change it as needed.

Basically – I’ll be getting rid of certain pages that seem pointless. I’ll try to keep the pricing page for small pack sizes current and I’ll keep adding posts as time allows.

Your comments are welcome (except for all those phantom web site companies who want to sell me their services – please go away).

Go out and save the planet.

FDA – Big Fun in the Little Warehouse

So…FDA came by to visit. It all went fine but most of what went on did not make sense.

First, they do not tell you what they are there for, or if they do, it is a fairly vague referral. In my case I sold a material four years ago that was fully declared as non-compliant for cosmetic OTC GMPs* but compliant with Food GMPs. A company used it in, what we all thought, was an acceptable way. There were no complaints, nothing filed with FDA. No harm, no foul.

The FDA ran a random sample on a finished product that led them to a small brand and then to a small lab and then to me.

Again, the product caused no damage to anyone (and probably never would have – this said with my physiologist hat on).

It is clear that there is really no immediate risk from the ingredient. In fact, it was imported and FDA clears all imported ingredients so they already cleared it for sale in the US. If there had been any issues, they would have shown up 24 months prior when they did the first random test. No one was hurt and FDA can’t even really say if there is a problem. They said that they are “assessing” the ingredient.

Secondly, they just kept digging. I finally made the local FDA Supervisor answer the question: “what is your authority?” I then asked her to please show me in the regulation why they were there. I shipped a duly labeled ingredient with a C of A that fully disclosed it’s characteristic – so I was compliant. I had not even changed the package it arrived to me in.

Her final answer was that she could not make me hand over any documents and that I had done nothing wrong, although she kept implying I was in the wrong in the way she cited the regulation. I did cooperate up to the point that I thought it was appropriate and that if they wanted to go back to the supplier of the suspect item, they could.

So – what is FDA doing? The vague rumor is they are looking at how organic and natural products are made and trying to come up with some “guidance.” In this case those rules will apply to safety, not whether or not the organic or natural claims are accurate or truthful. If they seriously want to do this they need to work with us, not disrupt small businesses, and pick on the smallest sector of the industry. We do pay their salary – or am I missing something?

I don’t see the FDA looking into whether or not 1, 4 Dioxins are accumulating in our water ways as a result of the millions of tons of surfactants going down drains every single day or how we can get Bisphenol A and other endocrine disruptors out of the production stream.

We sell only organic (plus three non-GMO) ingredients. The organic cosmetic industry is probably less than .005 of the total cosmetic industry – the rest of the cosmetic industry continues to put out finished products that pollute both the planet and our bodies.

So…who the hell is the FDA protecting by investigating our teeny segment of the industry?

They certainly are not protecting the people who want safer products.

*OTC-GMPs = Over the Counter Drug Good Manufacturing Practices.

What is Up with the Organic and Natural Part of the Cosmetic ISO Standard?

So
– if you read the last blog about why GMOs are bad, then this blog will make a
little more sense. I think GMOs are a threat to food security for the entire
world. How does that fit in with cosmetics?
Background:
ISO
is the Int’l Standards Organization based in Switzerland (you know those very organized Swiss). Many industries
look to ISO to set broad, clear standards for everything from how to test
bacteria to how to make a screw. It is supposed to be a fair, transparent
process. However, like all things in life that involve people, there are
agendas. The people at the table are trying to meet the expectations of
multiple players, countries, and value systems as well as trying to keep their
employers happy.
The
theory is that “anyone can participate” however it is very expensive: they move
the meetings all over the world, it takes a lot of time, and if you are a small
business, it is beyond reach. Consequently, the people on the committee serve
at the pleasure of large corporations who can afford to send people to these
locations and afford to pay them to pay attention. Current members seated at the
table include large trade associations that are funded by large manufacturers
in many cases. I would not say it is an impartial process.
The
Result of the ISO Standard Work for Organic and Natural:
If
you are in the “organic” or “natural” industry, one of the areas of concern is
how they defined these two O & N words. Most of the focus on organic goes
back to the legal definitions set by the various agricultural laws (in the US,
Japan and the EU for starters). Since we fought all those battle, that is less
of an issue than “natural”. The big showdown for this ISO Standard was: can
“natural” ingredients be made from GMO feed stock? Evidently the vote was a “yes”.
Gee whiz, what a surprise. Big companies want to sell “natural products” to
uninformed consumers who only want to trust a label.
Another
note is that the ISO Organic and Natural Cosmetic Standard has a lot of loop holes
– this is because of all of the players combined with the different laws in
different countries – plus those agendas I referred to. So there are all sorts of exceptions in the standard. We’ll see how that plays out.
Having
sat in meetings where chemist clearly do not know where their food comes from, I’m not
really surprised that many of them supported allowing GM feed stocks to be
called out as “natural” – but I disagree with them.
Fundamentally
any description of genetic engineering includes the fact that a gene from a
plant or animal is transferred into another plant. On the face of it, that is not
a natural act. Many people want it to be “natural” because they have so much money
invested. That is not a good reason to make up a false claim. Consumers
eventually figure it out.
I
think genetic engineering is important. There are probably very useful and safe
applications for it but open pollinator crops that depend on adaptation and
seed collection to improve the species are not the right candidates. They are
simply the most lucrative application that the current brand of producers could
think of at the time. Doesn’t say a lot for their creative spirit and it certainly does not
bode well for the future of transparency in labeling or for a secure food supply.
If
you have the opportunity and if you care, make your opinion known. Write an
email to the Personal Care Products Council (www.personalcarecouncil.org – lower right “contact us” button) and tell them that GMO derived
ingredients in cosmetics are not natural. Act on your principles.

Why Mono-cropped GM Food Crops are Really Bad (and Dumb)

I have really been hit or miss with this blog –
apologies. Hoping to get more regular about this.
This is a quickie blog to explain my position on
GMOs. I believe it is an issue of food security.
I guess seeing Interstellar really frightened me –
I think the possibility of our food system degrading into complete failure is
very real. Here is why:
GM crop companies have narrowed the gene pool of our food crops down to one or two varieties of seed. This is neither healthy nor smart.
Historically, farmers saved the seeds that were
most adapted, most robust and that seemed to respond best to the microclimate
in the area in which they were grown. This allowed farmers over 1000s of years to
regionally develop different survival and yield rates for different varieties
within a crop species.
The use of GMO crops has stopped farmers from saving and re-planting adapted and adaptable seeds. GMO seeds are mules – they cannot reproduce nor can they adapt to things like climate change. They are “engineered” that
way.
Want a scary and real example?
From 1845 to 1852 the Irish Potato Famine caused
the deaths of over 1 million people and caused another million or more people to leave Ireland. Why
did this famine happen? Because there was only one variety of potato in Ireland
and every one depended on it. Sort of like the GM soy and corn that forms the
foundation of the US diet (and a fuel source and cosmetic ingredients and vitamins
and etc.…). Potatoes are not planted from seeds, they are, essentially, cloned. So – they had the same situation, one set of genes that was not adaptable or adapted.

We’ve actually allowed a couple of corporations to make the
gene pool so damn shallow that all it would take is one bad virus and the
American soy crop would be wiped out. Same for corn or sugar beets. 

To me this is an astonishing threat to food
security.
The whole scenario just is short-sighted. How can
scientists allow everything we know about evolution to be swept aside? Shame on
them. Remember that phrase – survival of the fittest? You need a healthy, fit gene pool for productive plants to survive. 

So – next time some one starts ranting about GMOs, on either side of the
argument, ask them, how do GM crops affect food security? And then explain the
above. It should scare some sense into a few people.

HAPPY 4th 2014 – Putting it out to the Universe

Last week I had lunch with friends from Argentina. When I
asked why they came to the US, they explained that one morning they woke up and
all their money (in their bank account) was gone. Yep. You read that right.
They went on to explain that there had been 5 Presidents in a 2 week period. The country was in an insane
mess and the Presidents were taking the money of the people directly out of
their personal accounts. Then the Presidents left town. With the money.
I can’t even imagine.
So – while I am furious with the male-centric Supreme Court
(and send supportive thoughts to those 3 women on the Supreme Court) and while I resent
the waste of our resources by the US Congress, I am thankful that we have the
Constitution and a government structure that would never allow the sort of
devolution that happened in Argentina. I am grateful to all the men and women who fought to gain and protect the rights laid out in that rather amazing document that allowed this country to become America, home of the brave, land of the free.
Now we have an obligation to repay all of those who came before us: we need to get active and
demand action through the voter’s booth. We can get the Congress back on
track! Okay – so I’m being a little over optimistic. Maybe we can push harder and make a few changes and nudge the balance into a direction of compromise? Thoughtfulness? Problem solving discussion?

Happy 4th of July. Let’s all take greater care of
our country. Vote, write emails, make phone calls. Act within your rights as a
citizen. Let’s get better at being free.

Certified Organic Is Non-GMO . . . by Law. Wow!

I’ve had
enough. Organic Certified Products are so
much better in so many ways
than Non-GMO. I am appalled and saddened at the
confusion I read on the Internet and hear from consumers. Disclaimer: I absolutely believe that anything that contains GM ingredients should be labeled. Go labeling laws! Informed consent!
ORGANIC = Non-GMO
            Confusion # 1 – if it says organic, ALL of the ingredients for a finished product and all of the farm inputs (that means fertilizer and pest management tools) are reviewed because GMO sourced ingredients are prohibited under law. 
           
SEEING IS BELIEVING
            All Organic producers are inspected
annually. I did an inspection in which the applicant had an affidavit that the
Vit. E they were adding to their product was “non-GMO” (this is what the
Non-GMO Project accepts – an affidavit signed by God knows who).  When I looked at the box on the shelf of the
factory, it said “Vitamin E in Soy Oil, product of USA”. Over 90% of the soy
produced in the US is GM – so….no, it was not non-GMO. They had to find a
compliant source of Vitamin E because I saw what they were doing.
REALLY FOLKS, IT’S THE LAW
            Organic certifiers are required by
the National Organic Standard (7 CFR Part 205.105 (e)) to screen ALL inputs for
farming and organic production for “Excluded Methods” which are defined in the
Definitions Section of the organic regulations as “genetically modified”. This
means a document signed by the manufacturer of the ingredient that is was not
made from a GM source – and in the case of farms, where seeds are being
planted, there is random testing required by the National Organic Program. If these
affidavits are signed fraudulently or intended to deceive, it is punishable by
law.
            The bottom line here is that
anything agricultural making an “Organic” claim is required by Federal law to be
non-GMO. It has the added benefit of being produced using environmentally
sustainable practices (no synthetic pesticides or fertilizers poisoning our
water, soil and air). Plus – it has the force of law…if someone lies, they
can be fined and even go to jail. 
Non-GMO Label ≠ Organic
            Non-GMO products may be tested for
GM ingredients, but they are also often produced using pesticides,
petro-chemically based fertilizers, all sorts of food additives, colors, fragrances,
flavors, etc. Their Standard is about GMs, not about organic production. Don’t be fooled. Plus – the Non-GMO Project is a private standard. If someone cheats…who’s
going to do anything?
           Ask yourself: why is this product NOT labeled as organic? Because it isn’t organic. Duh.
WHO YA’ GONNA’ TRUST?

            If you are going to trust something,
trust a regulations that gets “boots on the ground” every year to inspect how your
food and other organic products are made
. Trust “USDA – Organic”, not some private, non-profit that is
accountable to no one. Organic food has 40 years of rule making behind – it started in Calif. in 1976 with the first regulation and we are still working on law today at the Federal level as we improve the organic regulation. Support Organic. Support your own health. Support the planet.
            And write your Congressman and demand that all GM containing products be labeled, not the other way around.

Toxic Chemicals: Why Do Moms Always Have To Clean Up?

This past week I attended a conference that talked about the toxic chemicals
allowed for use in the U.S. They effect all of us, especially our children. 

The conversation went like this:

      Chemical manufacturers: “We are not doing anything illegal. 
                                                We are
giving consumers what they
 ask for.”


      Toxicologists:                  “Consumers do
not know how toxic this stuff is 

                                                and we need green chemistry alternatives”. 

These are all technically accurate statements, but there are no real solutions offered by either side.

Take away – if we want a healthier planet, we seriously need to push regulators for
safer chemical solutions. Check out www.sixclasses.org.
Watch the 15 minute modules on the families of chemicals that we need to get
out of our homes and off the planet. Get informed and get busy. 

Email your representatives. 

Make a phone call. 

Get mad.

I am. 

Org. Certification for Cosmetic Ingredients: Be Careful

Be CAREFUL with
your ingredient certifications…

There are 2 types of certifications for org. ingredients that we use in
cosmetics:
– PUBLIC: these are regulations enforceable under law and
– PRIVATE: these are standards owned by organizations that are not part
of a government.
Examples of PUBLIC STANDARDS are certificates that show that a product
is certifed to the USDA-NOP Regulation, 7 CFR Part 205 or the EU Directive
EC-Regulation No. 834/2007 and 9889/2008 and COR – the Canadian Standard. If
these numbers and/or standard descriptions do not appear on the certificate,
the product is not considered oganic in the U.S.
Examples of Private certificates are NSF, NaTrue, EcoCert Greenlife,
Cosmos, Soil Association Organic Cosmetis Standard. These standards are used in
the EU to certify both cosmetic ingredients and finished products.
INGREDIENTS CERTIFIED TO ANY OF THE PRIVATE STANDARDS ARE NOT RECOGNIZED
AS “ORGANIC” BY THE NOP AND MAY NOT BE CALLED ORGANIC ON LABELS SOLD IN THE
U.S.
I know this is a royal pain and we need to find a way to fix it – but if
you are a national brand (or want to be a national brand), you really need to
understand the regulation differences. Unfortunately, there are many
distributors who are new to organic and they don’t really know about these
differences. Don’t formulate anything in until you have seen the certificate
with your own eyes and you know which standard it meets and if that standard is
accepted by your certifier.
Happy New Year!