Category Archives: Uncategorized

Blog About a Blog (and RBD Oil)

Google Blogger now shows you how many times each blog has been viewed. When I looked at my blog numbers,  the highest viewership of my blogs was for “What is RBD Oil?”.

You guys – I had no idea! It really tells me that you look at technical info and I will heed that advise.

Thank you for voting with your eyes.

The heck with my opinions, technical info it is from here on out. You’ll get what you have asked for.

How Old Will You Be in 2040?

When major corporations issue press releases about their “Sustainability” programs and then talk about how much energy they saved using different light bulbs or reducing the amount of plastic they use in their bottles, I am duly impressed by their thriftiness, however,  that is NOT sustainability. That is waste reduction.

Sustainability, in most every legitimate definition, is founded on the notion that you do not destroy or deplete a resource. In simplistic terms, do not kill the golden goose. It is not about saving money and cutting waste – both of which are laudable and good but not, I repeat, not “sustainability”. 

I challenge you big corporation people to get serious. Create “sustainability” programs that represent the meaning of the word, not just focusing on light bulbs and carbon footprint. We need to do those other things too, but those are waste reduction. (Admittedly, a “Waste Reduction” program does not sound as sexy, as a “Sustainability Program”.) I also challenge you to sit down with the rest of world and come up with a clear definition of what sustainable sourcing is – I’m sorry, I just can’t buy it if each of you has your own, unique, definition.

Life is confusing enough without making up your own meaning of “sustainable”. It is well defined in the Oxford English Dictionary.

The planet is in serious trouble. I have 2 children and I’d like them to have a livable world. Hell, I’d like to have a livable world. I recently figured out that I have a good chance of living another 40 years – I don’t want the planet to look like the movie Blade Runner. Get real. Grab your gonads and make some hard decisions and make the world a better place. Design REAL sustainability programs and make real differences. Just think about what you want the world to look like in 2040 – because you may still be here.

Alert: New Potential Laws Governing Cosmetics!

There are 3 updates to the cosmetic laws that are competing their way through our Federal system. They reportedly share (I have read 2 out of the 3 – just heard about the other): – Requiring registration of cosmetic producers or brands (TBD). – Requiring some level of reporting on the formulas sold to the public – Some language about “safety” – Some language about ingredients – Fees There are 2 proposed laws from the Democrat side: one from the EWG and one from Dingell’s office (the Congressman responsible for the Food Modernization Act). The Republican bill is, reportedly, sponsored by the PCPC and…no one in the public has seen it yet. I will not make any comments about transparency. Well, not many. Not sure how this will all settle out but one of the big sticking points in the competing bills will be where the dictionary of ingredient names lives, aka INCI. Currently it is privately owned by the Personal Care Product Council (PCPC) – which means a few things: – They make a lot of money off of selling the INCI Dictionary and it’s updates so probably want to maintain control. – PCPC and it’s members have total control over “the rules”. – Much of the proceedings to make the rules and set the names and review “safety” are, essentially, secret. – And even though they saw “INCI is the law” – it isn’t. It is not in the CFR so no judge can enforce it. * Once a I heard a client of mine say, “I’m not going to use INCI until it is available to me for free.” I suspect a lot of people feel that way. The concept of INCI is great for international business and for harmony in the industry. I have my concerns, however (like 17 different names for the same thing? Come on) and I think the discussion around these new potential laws may bring a lot out of the dark. Let’s hope that which ever law wins is not rushed through the process in the middle of the night. * It is called an underground regulation – there are a number of these in laws both in the States and Federal systems – in the “olden days” when laws used to refer to private dictionaries or other non-laws, they were okay but at some point some smart judge figured that you cannot call it a “law” if the citizens do not have equal access to it . . . that pesky Constitution! So you really can call your ingredients by common names as long as you are clear and truthful.

Happy Valentine’s Day – Kiss Kiss! 02/17/12

Yesterday morning the Washington Post reported recent FDA findings on lead in lipstick for 400 lipsticks. (See below for link). I was very concerned by the paucity of the report. It seemed to lack context and background information. We all need to be concerned about how adulterants get into products. We need safe consumer products. We also need to be complete and truthful about the context, the threats and the real goals. While I understand that it is easier to focus on the cosmetic industry and to hope that women will put pressure on the government about beauty products, the real problem in this country is with chemicals and how they are made. The EPA is under constant attack by lobbyist and the current Congress to reduce their authority to mandate SAFETY and HEALTH for all Americans. Criticizing lipstick is a sidebar at best and distracts from the real issue at worst. The article failed to explain how different levels of lead are allowed in different agencies, from 15 ppm for water under EPA to 0.01ppm for children’s candy under the CPSC. Nor does it make clear that lead is not classified as a carcinogen but is a neural toxin for developing children. (In fact, the article does not say why lead is a problem at all). Babies exposed to lead tend to accumulate the lead in their bones where it continues to effect how their brains and other nerves develop into adulthood. There are not any studies that indicate any anyone has suffered anything from using lipstick (except that time I got in trouble for drawing on white walls with my mom’s lipstick when I was 3). Bottom line: everything can be safer and healthier. If we are serious about safety, we need to look at the chemical industry, the base manufacturer of everything we buy and use. This constant harping on the cosmetic industry seems to avoid the hard work of changing how we make and sell chemicals in this country. Let’s get real and do the hard work. Start by using as much organic product as possible. LINK: http://www.washingtonpost.com/business/economy/400-lipstick-brands-contain-lead-fda-says/2012/02/14/gIQAhOyeDR_story.html

Whole Panic! Will they empty the shelves?

This week I have received numerous calls asking: “What can I do to get certified for (you pick the question)…the Whole Foods List…the Whole Foods Standards…the NOP…the NSF…? And then they want to do all of this by June 1st for formulas that already exist and were never designed to meet any of those Standards. Certified by next Wednesday. Yeah, right. I have received “Help!” calls from brands, from private label labs, from cosmetic distributors, and from NOP certifiers who look at ingredient statements of things like: “Cocoamidopropylbetaine, Sodium Cocoaphoacetate, Sodium Cocoyl Sarcosinate” . . . and their eyes cross. (Just in case you don’t know, none of these ingredients would pass NOP or NSF). Folks – a few basics: #1 – The NOP Standard is for food. The NOP certifiers are looking for an ingredient statement that includes recognizable food ingredients. (Yes, I know you make cosmetics but…facts are facts). You will need to make sure that your INCI names translate into things like “sunflower oil”, “Non-GMO Vitamin E”, etc. You will not meet the NOP unless you used all food ingredients and a few allowed non-organic food ingredients like citric acid and malic acid. Good luck with that. #2 – The NSF Standard was designed without being tested by real cosmetic companies which means it will change repeatedly over the next few years. (Reminded me of that old line that a camel was a horse designed by a committee). They do NOT have a list of approved ingredients and it does not allow things like most vitamins (no C, no D, no A, etc.) and the only effective preservative it allows is potassium sorbate and sodium benzoate. Again, good luck. #3 – Whole Foods sent this letter to their vendors…what, a year ago? Well, 11 months anyway. Now what? Whole Foods decided that the NOP and/or the NSF were the only acceptable standards for their store. They have that right. One might argue that in the interest of promoting organic agriculture it would have served us all if they accepted the other organic standards, but . . . they didn’t and too many companies have waited until now to react. Results? As of today – there are only 2 private labels labs in the US certified to do NSF certified products and it takes a few months to get through the process. There is only 1 certifier offering this standard and my sense is that it is a struggle to get the right documents from their applicants and they are learning as they go. It is a confusing process that is evolving and will get easier – but not before June 1st. There are about 5 brands, (1 large, 4 small) who have gotten products certified.SOOOO – should we start a pool? Who thinks that WF will pull all the non-certified products that are not certified off the shelves next Wednesday? I really don’t know. I also don’t know if they realize how few people have gotten certified. I am working with a few who are trying to get certified – but it won’t be by next week.Stay tuned – this will be interesting!

How Stupid is This?

It has been 11 years since I started working on the concept of certified “organic” cosmetics. In Europe they have multiple standards and literally thousands of certified product. Where are we here in the US? Nowhere. The NOP is not designed to deal with chemicals (in spite of having certified multiple synthesized chemicals) and certainly can’t sanction the use of synthesized preservatives. We don’t really have a functional certification program. What constitutes a functional program? TRANSPARENCY – the process should be clear and understandable to the participants and to the public. RESPONSIVENESS – this is a young industry, any standard needs to be sufficiently responsive that when we learn something new or conditions change, the standard can be adapted in reasonable time and with reasonable effort. RIGOR – the standard needs to 1) continuously improve and 2) be tough enough that it meets the consumer idea of an “organic cosmetic”. CREDIBILITY – the certifiers offering the standard need to have enough understanding of cosmetic chemistry, chemical manufacturing, and the laws governing the manufacturing and sale of these products that they are trustworthy. The NSF Org. cosmetics program has been singled out by Whole Foods as its choice for standards and yet it does not seem to meet many of the criteria above. Consumers have no access to the standard (well – they can spend 100.00 and buy it). It is very cumbersome to change and so not responsive. It is not especially rigorous – there is no internal mechanism to review ingredients by experts before they are added to the allowed list and they don’t actively communicate with consumers. Finally – QAI continues to ignore the fact that they need to hire a chemical engineer (like EcoCert did) – so credibility? Not so much. They are looking at chemicals with no one on staff who is trained in how chemicals are manufactured. The continuing disconnect in this arena is that the cosmetics are made from chemicals. Whether people realize of not – even water is a chemical, H2O. And we all know that water can be contaminated by all sorts of nasty things. Until the retailers and organic NGOS support multiple private standards to compete for the respect and trust of the consumers, the US will continue to lag behind Europe when it comes to a functional organic cosmetic certification program. See? Like I said, how stupid is this?

What Is RBD Oil?

RBD or RBDW is “Refined, bleached and deodorized” and the “W” is “winterized”. Is that allowed for “organic” certified? Let’s look at the process of how we get oil from a seed.
Vegetable seeds, all seeds in fact, contain some oil. Nuts have as high an oil content as 74% (macadamias – no wonder they taste so good). Other sources of commercial oils are sunflower seeds, soy beans (beans are seeds . . .), or the seeds from coconuts and palms. We are also familiar with peanut oil, canola oil, and flax seed oil.
Conventionally, all of these oils are extracted from seeds via some combo of heat, pressure and solvents. “Organic” or natural oils are “expeller pressed” – the seeds are mechanically pressed to squeeze out the oil. In commercial, conventional manufacturing plants, the seeds are also treated with hexane, a petrochemical solvent, to get the last little bit of oil out of the seed. In organic operations the use of hexane or other petrochemical solvents is prohibited.
The product of any of these processes is called crude oil. In some cases it is simply filtered and then sold. “Virgin” oils, like “virgin coconut” are crude oils that have been filtered to remove the non-oil remnants from the extraction. Castor is filtered and then boiled to volatilize off any moisture. Unfiltered oils may also be sold – this should be somewhere in the product description. I sell an unfiltered avocado oil that is so dark green it is almost black and it smells just like avocados. RBD avo oil is pale yellow-green and has no distinguishable smell.
Refined oils may go through a number of treatments. In the organic world this may include filtration through diatomaceous earth or fining clay which reduces the color and smell of the oil and a treatment with less than 1/2 % of citric acid. The citric acid binds to metal molecules and allows the refiner to make sure that there are no heavy metals floating around your oil. Finally, winterizing, is a chilling process that brings any waxes to the top and allows them to be removed to ensure that the oil stays as clear as possible.
Personally I recommend refined oils for personal care: they have less of an aroma to conflict with essential oils or other aromatics, they have no heavy metal risk (remember – plants grow in dirt, dirt has all sorts of molecules so heavy metals naturally occur in plant derived products), and they tend to have a better shelf life.
There are different processing details that apply to each of the different types of oils but this is the basic thing that happens to make an RBD or RBDW oil. These letters should appear on the Specification or Certificate of Analysis that should accompany any oil you buy.
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What is a “Safe” Cosmetic?

In 2000 (OMG, the Dark Ages!) I first started to participate in various industry discussions hoping to define “organic cosmetics”. What I heard was apples and oranges: one set of people who talked about product “safety” in terms of chemical exposures and the other set who said – “organic” ingredients were “safe” because they were food. I repeat – what is a “safe” cosmetic?

We all know about “food safety”. When that phrase is used most people think about control of bacteria and other contaminants. We want food that is free of salmonella, listeria, e-coli, insect parts, etc. Other than that, we generally seem to believe that there is enough information on food packages to allow us to make an informed decision – so long as we don’t get food poisoning.

Cosmetic “safety” has a broader and less clear meaning. “Safe Cosmetics” to some means that individual ingredients are somehow perceived of as “safe”, as we see on packages that state they are free of parabens, sulfates, etc. Additionally “safe cosmetics” includes protection from bacteria exposure or other adulterations (just like in food safety). To others the broader issue of environmental persistence from cosmetic waste moving downstream is a concern when assessing these products.

I point this out for a reason – do buyers have enough info on a package label to make an informed decision about cosmetics? Here are at least three areas of concern: individual ingredient safety, protection from contamination or adulteration, and downstream pollutants. Do you think about all three when you shop for your personal care regimen?

As a world of consumers we are using more of these products than ever. Mintel has reported that 93% of adults shampoo “almost daily”. That is a lot of downstream waste!

Pre-internet most cosmetics were made by large companies that had staff who understood the need to test for bacterial safety. Now I speak with small internet companies and learn that they are not testing the cosmetics for bacterial safety prior to selling over the internet. Scary!

The whole issue of the safety of individual ingredients is an on-going challenge and question. What , exactly, is wrong with sulfates? (There will be a blog). Is the Safe Cosmetics Database always right? (No, not always).

What is the “big picture” effect of cosmetics on us and our world and what should we buy? We need to identify the problems so that we can address them. We need sensible solutions, even if those solutions take time. Consumers need to know what questions to ask of their retailers.

For the short term, look at the big picture and make sure the products you buy have been made by companies that are consistently improving and sold by retailers who can answer these concerns. Ask the questions above, was this product tested? What do you know about the downstream effects of this product?

The stores are the gate keepers, you vote with your dollars. Good luck out there!

Why The Proposed Safe Cosmetic Act of 2010 Won’t Work

The proposed “Safe Cosmetics Act of 2010” (SCA 2010) won’t work. Yep, really, it will not work even though the intent, consumer protection, is a great goal.

It won’t work because laws all depend on each other. The SCA 2010 has at it’s center this requirement:
… a manufacturer of an ingredient or a cosmetic… “shall provide to the Secretary, through a statement under paragraph (3), all information required to determine if an ingredient or cosmetic meets the safety standard.”

This proposed law assumes that the FDA can make informed choices based on this mandate. Herein lies the rub: chemicals (the ingredients used to make most anything that is not legally defined as “food”) are regulated by the EPA and the the EPA does not have the legal authority to require COMPLETE safety data for all chemicals. So – if you make chemicals or cosmetics, you only have to give the FDA the (excuse my language) half-axxxd safety info you have because that is all you can get under law. Then the FDA is supposed make an informed decision based on half-axxxd information. Then we are all supposed to pay for it because the SCA 2010 will add a significant department to FDA that does not now exist. They will need a large number of high salaried scientist and they will need to run tests and they will need to manage the registration of thousands of companies and ALL of their manufacturing information – and that ain’t cheap! Further more, the financial burden will land on the cosmetics industry (and then on consumers) and the chemical companies get to skip along the same old path with no accountability.

It is not all bad news, there is also a proposed law that could give the EPA the power they need to hold chemical manufacturers accountable. This is a reform of TSCA – the Toxic Substance Control Act from the 1970s. We, as a country, desperately need to reform this Act. Most people have not heard of this. (Consider yourself informed, write a letter to your congress person today).

So – why has Ken Cook, the President of the Environmental Working Group, who stood up in front of the US Congress and supported the TSCA Reform not mentioned this via the rather significant press ability that the EWG has? Why have they put all of their press resources into backing a bill that can’t work while not mentioning to anyone that we might need to pay attention to the real problem; the chemicals that are manufactured and sold with less than complete accountability in this country? And why just cosmetics? Why not focus on ALL of the chemicals that seem to do harm?

We all need better consumer goods protection and it strikes me odd that the EWG is not making a really big fuss about TSCA and pushing Americans to support this very important bill that will protect us across all consumer good. I guess they think the cosmetic industry is an easier target and that they will get more contributions in support of cosmetic reform than they would if they tried to explain Reform of TSCA?

Mr. Cook – get real. If you want to reform how cosmetics are made you have to go back to the root problem, the chemicals that are used to make those products. The rest of us should support TSCA Reform, then cosmetics, drugs, carpeting, clothing, food, and toys will get cleaned up by themselves.

Safe Cosmetics Act of 2010 (Not)

Oh spare me. The Environmental Working Group should know better than to focus on cosmetics using the “Cosmetic Safety Act of 2010”: “safety” concerns should be motivating a righteous noise about a comprehensive chemical policy in this country. They should be hammering on the Toxic Chemical Safety Act of 2010 (TCSA). That will solve most of the problem. Any parent knows you’ve got to choose your battles wisely. Let’s make TCSA well designed and implemented, then let’s see what is left to clean up with the cosmetic industry and other product sectors.

Energy is finite and, when it comes to politics, energy is expensive. If EWG:
– thought more comprehensively about safety
– if they really understood the cosmetic industry
– if they were honest that the same chemicals in cosmetics are in medicine, household goods, and food (wow!)
then they would recognize that it all leads back to the chemicals that are made and allowed to be used in this country. They would use their energy and money to regulate chemicals instead of one portion of the consumer products industry.

ALL consumer products should be safe. This proposed Cosmetic Safety Act is making one consumer product group responsible for a small part of the pollution and safety risk we all face. Folks – why make it hard for thousands of small businesses when the responsibility sits with the chemical industry in this country and those of us who have the voices to change it? Hello!! Cosmetics are blended chemicals. The cosmetic companies don’t make the chemicals, chemical companies do. How do we push them to make safer chemicals?

I advocate that we delay this poorly written Act that will hurt small cosmetic companies and not really make cosmetics any safer and focus on the real issue: comprehensive chemical reform.

(Oh – and if you watch the video that they made, you might want to note that when the narrator reels off her chemical body burden, most of the chemicals are products from food or household furniture, not from cosmetics).