Category Archives: Uncategorized

The CIA, You & Organic – Back to Work!

Okay – so this is not overtly about organic but…the more I read the news the more I believe that extramarital affairs are as old as human kind and what has really changed here is communication.

We are so very attached to “devices”. Computers, cell phones, iPads, and the “Cloud” have clouded our minds. If you write things down in an open forum, they are out there for all to see.

I never write anything without a thinking to myself: do I care if anyone else sees this? And basically, I don’t care. I talk in person or on a good old land line to the people I love. Everything else is connected to my passion for increasing sustainable production or my business (or my kids’ activities) and all of those things are transparent.

People will always do stupid things driven by their (as my mom used to say) gonads or pure stupidity. Let’s hope they keep it private. I really don’t want to know about other people’s sex lives or about their betrayals or even about their religion or politics.

Life is short and precious and I want a healthy nation, a planet that is solving the problems we humans have created and a loving community.

Let’s pay attention to solving shared problems and let individuals solve their own, personal problems.

We need to get back to work on demanding labeling on GMO products and (newish one) demanding labeling on household cleaners. Lots to do.

I am thankful for people who are discrete. Happy Holidays – coming at ya’!

Aveeno: Losing Organic Certification!

You may have read recently that Aveeno lost organic
certification for a product and subsequently seems to have pulled the entire
line. The line was Aveeno Baby Organic Harvest (a horrible name anyway – it
sounds like someone is out in a field harvesting babies off of plants. Who
thought of that?)
How in the heck did this happen?
Well – we know that the USDA – National Organic Program did
an “investigation”. They only do that if a complaint has been filed. I can say
having looked at the ingredients statement on the lotion that it was obvious to
me that they used a non-compliant preservative. The real question is why didn’t
Aveeno/Johnson and Johnson know it? Were they ignorant or did they deliberately
mislead the certifier? Why didn’t the certifier know it? Were they ignorant or
just greedy?
We can’t really know answers to those questions but I can
repeat – READ THE DAMN LAW. If you want to be certified to the NOP regulation,
a food regulation, but you make cosmetics, you need to read the law or hire
someone (shameless plug for self here) who knows the law.
It was inexcusable for a major corporation to have made a
mistake of this size. The cost of product and market development, the deception
of consumers  (baby products no less),
and the cost to make the line disappear – well, it is probably more than my
whole business is worth.
Folks – this is not rocket science. It says in the NOP
regulation exactly what ingredients you can use. It should never have gotten by
the certifier – but then I’ve had a problem with organic food certifiers
certifying cosmetics all along, I still don’t believe they know what they are
looking at, and this proves it.

What if Prop 37 Passes?

Will you need or want to
re-formulate your products to meet either the new law or newly inspired
consumer demand? Here’s the screen to use:
1 – Q: Are your products
certified organic?               
      A: No worries.
2 – Q: Not organic? Call your products “natural”?   
      A: You need to verify that none of your
ingredients are from GM raw materials.
do you know what ingredients are at high risk of being made from genetically
modified derived raw materials?
– you really need to know how the ingredient was made. If it is something
simple like flour or oil – then all you need is a signed affidavit from the
manufacturer (not the distributor) of the ingredient that the source of the
grain or seeds used were not genetically modified. The plant origins of concern
are corn, soy, canola, and sugar beets.
it is a more complex ingredient, like a vitamin or some sort of processing aid
(citric acid) or something else like that, then you need to know exactly what
the source raw material was and whether or not it was GM. Who made it? How was
it made?
not, unless you are buying grain or flour (only those 2 ingredients), accept a
“PCR” test or a statement that a test shows that the product “negative”. You
need to know the source of the raw materials used to make the product if it is
a processed. Tests don’t count if the product is heavily processed.
all else fails, you can hire us.
YES ON PROP 37! (Not because we need more work but because no one can make an
informed decision if they don’t have the information!)

Tilth – CCOF Merger Voted Down

Yesterday, by an undisclosed number of votes, the merger of
Oregon Tilth and CCOF was voted down by the Tilth membership. No idea what will
happen on the CCOF side – they count their votes Oct. 15th … but it
doesn’t really matter now.
Based on what went on at the Tilth membership meeting, lots
of changes coming. I believe they need new leadership on the Board and they
need solid advice on how to balance the financial pressures of certification
versus the services people want. You think it is a pain to get certified? Try
being an accredited certifier answering to the USDA-NOP. Accreditation is lots
of work, lots of paper, and cost lots of money.
I have been certified by Tilth for 2 years and in that time
have come to profoundly appreciate the good service and fair prices they offer.
They are responsive, fast and nice.
I was a founding member of the CCOF Processor Chapter back
in 1993. I went on to serve as the President of the Chapter for something like
12 years and was Secretary of the CCOF Board for 11 years. I know them fairly
well. They do an okay job, but I don’t think their service is as good as
Tilth’s and I don’t think they have the same general attitude about serving
their members that Tilth does.
I was happy to hear that, for now, things will stay the way
they are for Oregon Tilth and their members and fans!

GM Crops: “Single Point of Failure”

Over a holiday BBQ with friends in the computer industry, I
was describing my concern that GM crops in the US represent a threat to food
I explained my suspicion that if we limit the number of genetically
unique seeds sold as GM corn and GM soy crops in the US that it makes the crops
vulnerable. It is my understanding that there are only a few genomes from which
these crops were originally engineered.
I was thinking of this because of the “Great Potato Famine”
of Ireland. They ended up with a single type of potato that was the primary
food source for people and for the cattle and cows in Ireland. Then a disease
attacked that potato and it was disastrous. We use corn for food, animal feed,
and fuel. And soy is in virtually everything. They only had 5 million to feed
to feed at the time of the “Great” Famine. A million people left Ireland. We
have 311 million plus people. Where the heck would we go?
A single crop with limited diversity–characteristics can be more
easily destroyed by a pest or by weather – because there is not sufficient
diversity to create strong and resistant strains that thrive in the vast number
of microclimates around this nation. Even old numbers from the PEW Institute
indicate that at least 90% of all corn and soy (and cotton) in the U.S. is now
from GE seed.
I support Prop 37 – the requirement to label GM crops –
mainly because of the above. I believe that a few corporations have ignored
this essential point of food security in the interest of profit over sanity.
When I finished stating my concerns, one of my friends (remember the first
paragraph?) used the term ”single point of failure” – and I thought it summed
it up beautifully. It is, I gather, an engineering term that means exactly what
it says, that a single action can bring down an entire system. It is what the
U.S. GM crops of corn and soy are building to – a single point of failure. We
are all at risk.

Cause and Effect: An Organic Law Suit

In March of 2008 David Bronner and his company sued a long list of personal care companies that used  organic claims. They also sued OASIS and EcoCert. Four and a half years later the judge dismissed the whole enchilada. 
The looming nature of this law suit caused many companies to stop using organic ingredients all together. Kiss My Face, after years of adding organic content, shifted their whole line to “natural” (natural, a word which has no meaning) but they seem to use organic aloe in a few products. Multiple other companies also stopped using organic ingredients other than aloe. The Avalon brand did get certified to the NSF Standard, which, because it only requires 70% organic content,  again means . . . a lot of aloe. So – lots more organic aloe being used. Gee. 
This is not to say that these are not good companies – they are making well designed products for the most part – but there is no incentive to use more than the minimum organic when it comes to designing the products so…there is little or no innovation in organic ingredients for cosmetics. This combined with the Whole Foods policy requiring that one use the NOP or the NSF Standard has hurt the industry rather than stimulated it. I so wish WF would add EcoCert and Soil Association cosmetic standards. That competition between standards just MIGHT push things forward. 
As for the rest of you who are clearly committed to using as many organic ingredients as possible to support farms and healthy ingredients and an environment with less garbage going down our drains: thank you.

Organic Cosmetics: Summer School

Organic Cosmetic  Summer School
Short Course # 2 (Of 3):
In a 1 hour Webinar, Brush Up On the Rules – 
  • What are the laws about “organic” labels on cosmetics?
  • What do consumers expect in “organic” cosmetics?
  •  Do I need to be certified?
  • Do I need to be registered?
  • How can I label product if I am not certified?
  • How do I get certified or registered? (Contact info will be provided).
  • Where can I find information and ingredient resources?
  • What documents should I ask for when I buy ingredients?
  • Big picture concerns: GMOs? Preservatives? 
  • Your questions . . .
This course will supply you with the links, the lists, and the knowledge to produce “organic” products with integrity. 

Sit in front of your computer, watch the presentation then call in for Q & A.

When: Sept. 14th
Time: Noon Pacific, 3 pm Eastern
Where: Your computer and phone
Cost: $30.00 (please call with cc info if you want to take this class).
How to sign up? Email:

Once you have signed up and paid for the class we will send the log-in, the conference phone number and the power point.

This is a random picture of a fully bloomed artichoke at my local farmer’s market. 

Organic Cosmetic Integrity and the Rules

Every few years I realize anew that this organic cosmetic thing is a bit confusing. Many of you are being your lovely, creative selves and are unaware of the politics, laws,  and philosophies that have evolved around using  “organic” claims.

Let’s lay out the legal part with respect to “organic” cosmetic labeling:

You must be certified by a USDA Accredited Certifier if:
  • If you sell a finished cosmetic product that is labeled as “USDA Organic” . 
  • If you sell wholesale ingredients (oil, sugar, whatever) in packages that you create labelled as “organic”, 100% organic”, USDA Organic, or “certified organic”.
If you make cosmetics and call them “organic”, you are under the authority of FDA and you need not be certified for those retail products to the USDA law. If you re-package organic ingredients and sell them you are under the regulatory authority of USDA.

You may want to look at the products you sell and your web site and make sure that a consumer could not be confused by the way you present the product. If you are referring to certified organic ingredients in a whole product, part of which is not from organic ingredients, make sure that is clear.

Make sure you have a a certificate(s) from the entity you purchased your ingredients from, than you can prove that those ingredients are organic and therefore that label claim is truthful.

Also – if you manufacture in the State of California and you call a cosmetic “organic” you are required by law to be registered with the Calif. Department of Health as an organic handler. Not terribly expensive so look into it. 

So for the philosophy part of this blog, let’s talk about why labeling and the laws are important: integrity.

A label is a promise to a consumer. The word “organic” only has meaning (aka integrity) if 1) the label is truthful and 2) there is a direct link back to a certified ingredient source.  The organic agricultural industry started because people wanted to validate that they were being good stewards of the earth. Oh – and they wanted clean, safe food for their bodies and for the planet. Then a bunch of us decide to evolve that whole organic thing into the cosmetic world.

I once had an experienced regulator tell me about labels: “you can state anything that is TRUE. Just make sure it is true. I’ve always added (in my head) that I’d need to be able to prove it to a judge – and this means documentation!

Keep the value in the word organic. Know the laws. Be a good steward of the word “organic”. Be true to your school (Okay – only people of a certain age will get that).
 Hugs to all of you creative, inspired folks!

Indulging my love for period art…in this case, justice may be blind but judges are not.

Definition of “Organic” in Cosmetics

I just read an article from Inside Cosmeceuticals called “Recapturing Credibility in Beauty’s Natural and Organic Landscape”. It contained the quote:  “ “Organic ingredients are those produced using methods that do not involve synthetics such as pesticides, chemical fertilizers, do not contain genetically modified organisms (GMOs), and are not processed using irradiation and industrial solvents,” said David Djerassi, cosmetic industry expert, LycoRed”.
Allow me to refine a few of Mr. Djerassi’s ideas.
First – organic ingredients start on organic FARMS. These are all renewable, plant-derived materials. If they aren’t from farms, they cannot be certified organic. Mr. Djerassi’s comment could easily apply to mined zinc – definitely not from a farm.
Second – organic farming is founded on stewardship of the land. An organic farmer’s job is to improve the soil by adding nutrients that come from agricultural sources (like compost) and from using pesticides (yes – they use pesticides) that only come from renewable resources (that means from a plant) that are non-toxic. Contrary to the quote that says what is not there – farmers would never even think about it that way. Organic farming started as a philosophical commitment to improve rather than destroy the soil and other resources necessary to feed people. They grow, add, improve and manage land resources – they don’t just avoid a sentence worth of prohibited concepts. The fact that we can take these materials and then make ingredients for use in the cosmetic industry is an outgrowth of this commitment, and a happy one for us. It is not at all about what we can’t use – as inferred by the quote, it is all about what we can use without destroying our resources.
Third and final – the quote says organic production does not “involve synthetics” – we really need to work on our vocabulary here. Sorry to burst the bubble but the organic laws even contain a list of “allowed synthetics”. Further – to say that they don’t use “chemical fertilizers” implies that compost is not a set of very complex chemicals – which it is. It is just that these are naturally derived chemicals as opposed to synthesized chemicals. We all need to remember – water is a chemical – I can write the term “H2O” and you all know what I mean – but this is a naturally occurring substance. Let’s all work on refining our words to be as clear as possible. I like the terms synthesized chemicals and natural chemicals. Then we can divide the category of synthesized chemicals into environmentally benign chemicals and those that muck things up to the degree that we now find scary stuff in our seas, waterways, soil and air.

Organic ingredients are ingredients that come from certified organic agricultural raw materials. They are processed using environmentally accountable and benign processes. They are the products of a thoughtful approach to chemical production and a personal commitment to stewardship of this little spinning ball we live on. Let’s be a little more thoughtful about the words we choose – especially when we are “experts”.

What is a “Botanical Extract” in a Cosmetic?

The simple answer is that a botanical extract is any part
of a plant that has been dissolved and is now in a carrier – any carrier.

Then, there are the questions I ask when someone asks for a
botanical extract:
Water soluble?
Oil soluble?
With what preservative?
And, oh, do you want it standardized or not?
So – the basics: the word extract means to pull something
out – so an extract of green tea in water is just like the tea you might make
at home: put green tea leaves in water and those constituents in the leaves
that will dissolve into water will make that transfer. This brings up the issue
Solubility is when some thing will dissolve into a . . .
solvent. A solvent can be water, oil, alcohol, glycerin, propylene glycol, fat,
sugar, etc. This also means that the non-water soluble “things” in a plant will
NOT dissolve into certain solvents. So oil solubles will not dissolve into
water and water solubles will not dissolve into oil. Think about your goals.
A few examples: vanilla sugar is an extract of vanilla into
a solvent (solid) of sugar; truffle oil is an extract of truffles into oil.
Garlic oil is the same thing. For the cosmetic world we can take any plant part
(flower, leaves, stems, roots, whole) and put it into any solvent or carrier –
limited only by the solubility of what is in the plant. The choices depend on
the other ingredients in your formula.
Finally, a standardized extract is made so that the exact
same amount of the dissolved and extracted “stuff” (what ever that is) is in
the ingredient every time – you only need this if you are making a front label
claim about the specific strength of some active that you get from the extract
which has gone through clinical trials (to support that it really does – what
it says it does…). These are much more expensive products, harder to find and
to make.
Sum it up: “botanical extracts” are a range of plants
extracted into a variety of solvents.

sure that you know what solvent is used – it is not always listed on the label