Book Availability

books-amazon-hscgAs you may have heard, I announced that Jere and I are planning to “run away from home” in our new (to us) RV.  It’s actually happening! All goes well, we’ll be heading out next Monday, August 10th.

Obviously, I can’t be stocking and shipping books while we’re on the road (not enough storage space, for one thing!).  So, I’ve made arrangements to ensure that my books are still readily available. You have a couple of options.

Continue reading Book Availability


Mary’s Monkey

As one of my personal projects, I am scanning and correctly, archivally storing the family collection of papers and documents.  Yesterday I scanned a collection of 400 post cards dating from 1908 to 1920.

One little series mentioned soap, so I read it carefully … and I just have to share:

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Mary has a little Monkey
Just as cute as it can be,
It was covered with the softest hair
That ever did you see.

Continue reading Mary’s Monkey

Myth: Soap Labels Aren’t Regulated

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One of the myths that I still frequently hear is that “I can put whatever I want on my soap labels because they aren’t regulated.”  I believe that particular myth got started because of the “soap exemption” in the FDA’s definition of “cosmetic”:

A product, except soap, intended to be applied to the human body for cleansing, beautifying, promoting attractiveness or altering the appearance. 1

Right – soap can be exempted from the definition of a cosmetic (and thus the labeling regulations for cosmetics). But there are still other regulations that apply to the labeling of soap. Continue reading Myth: Soap Labels Aren’t Regulated

References   [ + ]

1. Food, Drug and Cosmetic Act, 21 USC 321(i)

It’s harder than you think

ebay storeRunning away from home in our new RV is turning out to be a little more complicated than one would think. So many things to consider and take care of. The biggest issue is getting rid of all our STUFF, since it won’t fit in the RV!  The good news is that we’re making progress.  The bad news … lots more progress to be made!

What have we accomplished so far?

Continue reading It’s harder than you think

FDA Warning Letters – Drug Claims for Cosmetics

dreamstime_m_6105588I get notices when the FDA sends out warning letters and it seemed like there has been an increase in warnings to cosmetic companies for drug claims. So I checked. Yes – there definitely has been an increase. One would guess that the FDA is looking a little more carefully at the claims being made. So far in 2015, there have been 5 warning letters on the subject of drug claims made for cosmetic products. That’s more than any year from 2005 until now (except for 2012 which had 11 warning letters for the whole year).

So, what sort of claims are these companies making for their products?

Continue reading FDA Warning Letters – Drug Claims for Cosmetics

Personal Care Products Safety Act (2015)

laws-regsOn April 20th, 2015, Senators Diane Feinstein (D – CA) and Susan Collins (R – ME) introduced The Personal Care Products Safety Act (S. 1014), which, if passed, will update the Food, Drug and Cosmetic Act as it pertains to cosmetics.

There has been considerable discussion about various aspects of the bill and what its effects will be.  Several people have asked me for my take on the bill, so I’ve gone through the bill in detail . (What a process!) My comments about it and what it might mean are detailed below.

Continue reading Personal Care Products Safety Act (2015)

Running Away From Home in an RV

Last month, Jere and I announced to family our intention to get an RV and “run away from home,” living and working on the road as we travel around the US seeing the sights and visiting friends and family.

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Marie driving our new (to us) RV for the first time

Yesterday it became a lot more REAL.  I actually drove our new (to us) RV. Actually, it wasn’t as hard as I thought it would be, although I did nearly take out part of our fence on the narrow section of our driveway.

Continue reading Running Away From Home in an RV

Wildlife Society Award to Chandler Family Ranch

ortws-logo_detailedI was just informed that our ranch, of which I have been the Operations Manager for 12 years, has been awarded the Private Landowner Stewardship Award by the Oregon Chapter of the Wildlife Society!  The award is one of two civic recognitions they give out annually.  From their website:

“Private Landowner Stewardship Award

“This civic award recognizes private landowners for implementing positive wildlife conservation programs or actions on their land in conjunction with their commercial operation.”

Continue reading Wildlife Society Award to Chandler Family Ranch

What is the “Common Name”?

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The FDA has said that the “common name”1 is required for cosmetic ingredients.

But what does that mean, exactly?

Let me tell you the story of the Cosmetic Ingredient Dictionary and INCI names.

Once upon a time …

Back in the 1970’s, a book called the Cosmetic Ingredient Dictionary (CID) was published by the Cosmetic Toiletries and Fragrance Association, a US trade association for the cosmetic industry.  The CID listed the acceptable (“common”), human understandable, names for cosmetic ingredients.  Since it was a US publication, the plant-based (botanical) ingredients were listed by their common English names.

Continue reading What is the “Common Name”?

References   [ + ]

1. Ingredient Names, FDA Website. Also 15 USC 1454(c)(3)

Unpackaged Cosmetic Products

2015-03-28-lush-bath-bombsWe all know that the Fair Packaging and Labeling Act requires that all consumer products (including cosmetics) have the identity of the product and the net contents on the front, the name and address of the manufacturer somewhere on the label.  Cosmetics also require the ingredients to be listed.

Here’s a question that has come up more than once:  How do stores that carry unwrapped products in bins with just signs get away with it?

Good question.

Let’s take a look at how they might (or might not) be complying with the actual regulations or at least the intent of the law.
Continue reading Unpackaged Cosmetic Products

Proposed Revisions to Labeling Regulations under the FPLA

dreamstime_l_31478130The Federal Trade Commission is looking to update their regulations under the Fair Packaging and Labeling Act, and “modernize the place-of-business listing requirement.”  These are the regulations that apply to “true soap” that is exempt from the FDA definition of a cosmetic. The proposed change would amend 16 CFR 500.5(c) to read:

(c) The statement of the place of business shall include the street address, city, state, and zip code; however, the street address may be omitted if it is listed in a readily accessible, widely published, and publicly available resource, including but not limited to a printed directory, electronic database, or Web site.

This is very good news for everyone who makes true soap or other consumer commodities. Comments are being accepted until March 30, 2015.

Continue reading Proposed Revisions to Labeling Regulations under the FPLA

Helpful Pages from Updated FDA Site

FDA.jgpThe FDA continues to update their website, clarifying and making things more understandable.  I love the new articles as they are very clear and easy to understand (as well as many of them being targetted to small and emerging business).  The only thing is that they are a little hard to find … I still can’t figure out the categorization and menu system!

Here’s a list of some of the more helpful pages, directly linked so they are easier to find:

Continue reading Helpful Pages from Updated FDA Site

Labeling Book 2015 Edition – Preorder

cover-5-purpleWell, it’s finally happened. I’m OUT OF STOCK on the 2nd Edition of the book (2010)!

The 2015 updated 3rd Edition (I’m calling it the “purple edition”) is almost finished. I’m on the final round of edits and updates. In a way, it’s good that the project was delayed a bit because now I’ll be able to include information about the FDA’s response to the HSCG’s PO Box Petition.

At the moment, it looks like the book will be winging its way to the printer sometime near the end of January, and I’ll have books in stock around the end of February.

Cost of this edition is the same ($24.95 with free shipping in the US), but orders placed before the book is back in stock will get a 20% discount (reducing the price to $20.00).

Continue reading Labeling Book 2015 Edition – Preorder

FDA Responds to HSCG PO Box Petition

As handcrafters, often working out of our homes, it’s always been an issue that the street address is required on the label unless published in a current  phone or city directory.  The HSCG just announced that the petition they filed with the FDA in 2012 to allow the use of a PO Box in lieu of street address, has received a final response from the FDA.

The FDA denied the HSCG’s PO Box petition, but it did provide some clarification that a “current phone or city directory” includes ONLINE directories as well as printed directories.  This is VERY GOOD NEWS!

Continue reading FDA Responds to HSCG PO Box Petition

Liquid Soapmaking by Jackie Thompson

liquid-soapmaking-by-thompsonJackie Thompson’s long awaited book, Liquid Soapmaking, is finally here – and more than worth the wait.

For those who make handcrafted soap bars, transitioning to making liquid soap can be daunting. While the chemistry is essentially the same, when it comes to the finished product, opaque bar soap is much more forgiving than liquid soap that should be completely clear and of the right consistency. Jackie has researched (for years) and has managed to capture all you need to know about liquid soapmaking in just 207 pages!

I admit, I’ve made liquid soap.  I also admit that while it turned out “okay” as soap (I mean, it didn’t harm anyone and it did lather and clean) – it wasn’t what I’d call “great.” Certainly not anything I’d be willing to package and sell to a customer.  The thing is, I never knew exactly what the problem was, or how to fix it.  I didn’t know enough about advanced soap chemistry, how the chemical qualitities of various oils affect liquid soap, and the effects of different additives. Without that understanding, it’s not surprising that I gave up on making liquid soap.

Jackie’s book changed that.  After reading it, I became inspired (again) to make liquid soap.

Continue reading Liquid Soapmaking by Jackie Thompson

Cosmetic Claims and Required Approval

Recently there has been some discussion online (in a Facebook Group) as a result of a report of a conversation with someone from the FDA. The report was that this FDA representative said that if you wanted to use the word “moisturizing” to describe a soap, then your recipe would need to be submitted and evaluated for its composition of moisturizing properties. This FDA person also said that the term “lip balm” is regulated by the FDA as a drug.

I have absolutely no reason doubt that the person reporting this conversation reported it accurately. She was, in fact, doing her due dilligence in checking with the FDA to understand the rules and regulations.

The problem is that FDA staff are human, and may not be completely versed in all the applicable regulations when confronted with a question from the public. I doubt they intentionally give out wrong information, but it’s happened in the past, I expect it will happen in the future, and it’s likely that it happened in this instance. It’s generally better to understand the regulations by referring to the actual regulations, or at least to the written material the FDA provides as it has been vetted and double checked for accuracy.

So, here are a few documents to take a look at when evaluating the accuracy of the information provided by someone at the FDA in this case:

Continue reading Cosmetic Claims and Required Approval

FDA Sends Warning Letters to Two Essential Oil MLMs

FDA.jgpI have posted numerous times, including here and here, about FDA warning letters concerning “drug claims” used for supposedly cosmetic products.  After those posts went up, I had a number of people tell me about several national companies selling essential oils that were making all sorts of claims, and asking why they could get away with it.  Apparently, they can’t (and rightfully so).
Continue reading FDA Sends Warning Letters to Two Essential Oil MLMs

Quest for the Perfect Pickle and GMP

2014-08-19-picklesThis last week has been shaped by the bounty from our garden. When the tomatoes, peas, beans, zucchini and cucumbers are ripe, they get picked NOW … it’s not something that can be put off for a day or two.

Of course, having the picked vegetables means that you have to do something with them before they go bad – so I’ve been prepping and canning lots of pickles and making zucchini bread for the freezer.

Pickles – well, this MANY pickles, anyway – are new. I decided to try several different recipes and then keep track of which ones are good, better, best (or really bad). Casting about for a way to keep track of it, I realized that it’s just one piece of good manufacturing practices .. and I already know how to do that!
Continue reading Quest for the Perfect Pickle and GMP

Calculating Percentages for Blended Ingredients

calculatorIngredients are supposed to be listed in the ingredient declaration in “descending order of predominance”. In other words, the ingredient at the highest percentage (by weight) goes first, then then next highest, etc. Ingredients that are present at less than 1% can be listed in any order following the ingredients present at 1% or greater.

When a blended ingredient is used, all the component ingredients in it must be listed separately in the ingredient declaration, correctly placed in the descending order of predominance based on the component ingredient’s percentage of the entire formula.

So, how do you figure that out? Actually, it’s simple math, and not too hard when you know the formulas. Here’s an example:

Continue reading Calculating Percentages for Blended Ingredients

Monday Mailbag – August 4, 2014

mailbag

In this Monday Mailbag we have questions concerning the size of the net weight wording, getting started with GMP, handling incidental ingredients, INCI names and website software.

What are the size requirements for the net weight?

The size of the text for the net weight is dependent upon the size of the principal display panel. If the PDP is less than 5 square inches, height of the net contents must be at least 1/16”. If the PDP is 5 – 25 square inches, the net contents must be at least 1/8” high.

For most cosmetics and soaps, the PDP will be between 5 and 25 so the text of the net contents should be 1/8” high. If the text is in lower case or upper and lower case (i.e. “fl. Oz.” or “Fl. Oz.”), the height is measured by the height of a lowercase “o”. If the text is in only uppercase, it is measured by the height of the uppercase “L”.
net-contents-spacing
In addition, the text should be separated above and below by the space of an upper case “N” and on the sides by the width of three upper case “N’s”, as you can see in the image above.
Continue reading Monday Mailbag – August 4, 2014

Labeling Regulations – Don’t Know vs. Don’t Care

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I’ve been discussing, writing, and lecturing on the subject of soap and cosmetic labeling for nearly 10 years now. During that time I’ve discovered that people who are making handcrafted soap and cosmetics seem fall into categories when it comes to knowing and following the regulations.

As with all things, how a person deals with knowing or not knowing a subject, can say a lot about him or her.

Continue reading Labeling Regulations – Don’t Know vs. Don’t Care