Deal With It
One of the reasons that the organic food program works is because of certification. I’m not convinced that consumers understand or care about a certification seal but I am convinced that the certification process provides the growers and manufacturers with the knowledge and resources to improve and expand both their organic production and their commitment. I have always thought it was like when someone quits smoking and becomes the biggest advocate a la’: I did it and it is great so everyone should do it! Certification educates producers and provides the path to “grow” the entire industry.
This motivating force, certification, is not being used here in the US for organic cosmetics and personal care products. There is no law that says it needs to be used and the litigation that hangs as a looming threat from a certain soap family, has discouraged everyone I know from working with the private voluntary standards that exist. While there are probably over 5000 certified personal care products in Europe, there are a handful here in the US due to this barrier. (And most of them are either simple blended oil lip balms or, what I consider to be, misbranded “organic” soap”.)
You might ask how, thinking that companies can get certified to the USDA-NOP. While this is true for certain products, it is questionable for certain other products. The organic food law was designed for food and is fairly clear in it’s intent that “synthetic” materials are not to be added to “certified organic” finished products. So, somehow some of the certifiers thought that certification of some synthetics was okay. Philosophically and legally I do not agree. When the chemical reaction between oil and lye is finished, there is neither oil nor lye remaining: it is a whole new molecule, a soap molecule. That reacted product is the very definition of “synthetic”. The creation of a new molecule = synthesis. A loop hole in the food law allows this: we use lye in food in less than 1/2 a percent for a few limited purposes, mostly to de-nature proteins, we use lye in soap as a reagent/ingredient to react with and become part of the soap molecule in 8% to 16% normally. Besides, you can’t eat it.
I am not saying that we should not have organic personal care ingredients, we should. I am saying that the food law should stand alone to protect it’s credibility and that we should start working with private standards for cosmetics. We need education and growth to get polluting chemicals out of our personal care products. We need certification to motivate that education and growth process. The private standards may well result in a regulation after a few years.
I also believe strongly that we need to be honest with consumers. The ingredients necessary to make bread, well, they grow, they are combined, baked and used as food. The ingredients necessary to make shampoo must be manufactured in a chemical plant. We need to look at that manufacturing environment very differently - does it make a safe product? Does it’s manufacturing process pollute? How does this material affect the whole planet?
If we are going to live in a clean world, we need to look at every aspect of what we make, use, and discard. One day we may have 100 different manufacturing standards; food, personal care, tennis shoes, drugs, everything conceivable. We cannot continue to use up resources and toss out the trash. We also need an ethic and certification standards that will help us all learn about the particular product, the “cradle to grave” affect of that product on the planet and the ultimate responsibility we bear as a result of using that product. We need that certification to be a truthful representation. We cannot do this by pretending that good synthetic ingredients are just like food. They are not. They are what they are, synthesized - so, as my attitudinal 15 year old says, deal with it. This is all about credibility.
How do we get past the barrier of the legal threat from a single bully? I think we should band together, come up with a new phrase to indicate that personal care products are made using organic ingredients that may have been synthesized into environmentally responsible chemicals and get on with certification. We should build a branded seal that stands separate but right next to the USDA-NOP food standard. We should deal with it. Otherwise we will be in court for another 2 years. Copyright - G. Timmons - 07.19.09


1 Comments:
This is some of the finest analysis of what is going on in the personal care products industry that I've read. As a chemist, I entirely agree that once ANY chemical modification has been made, indeed a synthesis has been achieved and the resultant product can no longer be classified as 'organic' other than that it's carbon-based chemistry... I've argued with several of the standardizing companies about synthetic modification, even many who claim that all their 'approved' ingredients are synthetic-free which is simply not the case when acid catalyzed esterification syntheses have been made via industrial chemical processes.
We do indeed need new standards, but something akin to the USDA might be in order since many personal care products can be prepared with majority ingredients that are directly derived from a living organism without the use of petrochemicals - that has been our definition of what constitutes a natural ingredient for some time. If it's grown under organic standards, that's even better.
Thus I think any sort of standardization must evaluate certified organic content, however applying the USDA guidelines in skin care, for instance, is inappropriate given that a mineral based sunscreen emulsion may be more than 50% mineral (water and zinc oxide for instance). However many other carbon based ingredients can be sourced organically and should be listed as such.
The savvy consumer does understand this, but it's generally a result of their own research and learning process, and very few consumers take the time to develop a savvy understanding of the fundamental ingredients present in a personal care product.
Manufacturers must also stop the use of misleading ingredients, or esoteric synonyms. INCI is an option, but I find that the latin names of the various sources unnecessarily convolutes ingredient lists and actually dissuades consumers from comprehensive ingredient education because it simply becomes overwhelming. Too often do I see companies with major natural brand equity advertising SLS free yet using ingredients such as sodium coco-sulfate, which is greater than 50% SLS given that the majority fatty acid in coconut oil is lauric acid, which, sulphated is precisely SLS.
We need more evaluation that is based on the real chemistry at hand, potential for side reactions leading to undesirable or toxic contaminants, analysis of externalities associated with production processes and ideally energy and waste flows.
And for the benefit of humanity, will manufacturers and evaluators cease to use the term 'chemical-free?!' Everything on the planet is made from a chemical and describing a personal care product as 'chemical-free' is utterly ignorant!!!
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