Harmony or Sustainable Public Policy?

There has been a lot of talk about the need to harmonize the few organic standards out there for cosmetics. I don't believe we need to do this just yet. This does not mean that I don't recognize that there is confusion - there is! Let's ask the question - how do harmonized standards come into being? History, conveniently, shows us in the story of how we got organic food standards; I lived it for the organic food standards and only recently really came to understand how I lived through the creation of "public policy".

Once upon a time a bunch of farmers decided they wanted to "certify" their growing practices. So they each inspected the other and this evolved into 3rd party certification of organic practices (this is the really short story of certifiers like CCOF, Oregon Tilth, OCIA, an most of the non-profits). This happened in the '70s and '80s. Then in the '90s, people wanted to have "certified" processed foods. So the various certifiers (of whom there were over 40) started to write "processing" standards borrowing parts of standards from each other, and eventually we had over 40 certifiers in the US with over 40 different standards and every one was "better" than every one else but it was all "organic". This went on for 11 years. There were over 40 seals and everyone had the chance to develop a market without too many restrictions - good or bad as that may be. In the late ‘90s there was a real problem with reciprocity – for example, a CCOF product may not accept a QAI certified ingredient.

The lack of reciprocity prompted the OTA (The Organic Trade Association) to push to harmonize the standards. A draft harmonized Standard was written by an OTA commissioned group and, in 1999, most of the larger certifiers signed on and agreed to use it, (of course this meant they had many meetings with their members and collected their thoughts). This was just as the NOP draft standard was being designed in Washington DC. A note – the first draft garnered something like 360,000 written comments sent to Washington. This is the heart and soul of the public working on their own regulatory policy.

By October 2002, when the NOP was implemented, there was a robust "organic" food industry and a clear perception by many manufacturers that the idea of making ingredients for the organic industry was a great niche. This motivated the creation of multiple specialized organic ingredients and motivated better and more organic products. So - what we had was 12 years of education of growers, inspectors, manufacturers, retailers and consumers. We “grew” the market along with the idea of organic. It was clear that processed foods could be "organic" and were a viable market force. This gave people the time to develop the necessary infrastructure to make organic food a reality.

Somehow we went off the tracks when we tried to do the same thing with cosmetics. People seemed to think there should be a single, regulated standard for cosmetics without any of the opportunities to develop the infrastructure that goes along with building the standard. It is important to realize that no government will regulate anything that does not have a consensus in the intended industry. While we may find “organic” clearly better, the FDA does not perceive the use of organic ingredients to be a health issue. They are not going to go out of their way to support this and USDA cannot do it without FDA – USDA has no regulatory authority and they do not have any chemist on staff that could credibly oversee the program. I believe USDA would be extremely averse to regulating cosmetics in any way without buy-in from FDA. You’ve got to ask yourself, is that what you want?

In the mean time we have people announcing they have the "one true standard" (gee, why does that feel like England in the 1700s?) and people suing other people over "ideas" (and why does this feel like the 1950s?) of what a standard should look like and certifiers who are certifying organic cosmetics that have no idea of what happens in a cosmetic manufacturing environment. Yes, it is confusing. It is also normal when new ideas butt up against people who have a business in the mix.

The way I see it, everyone; the manufacturers, the ingredient people, the consumers, and the advocates, need to hammer away on various standards until we get closer and closer and can all, finally, agree on what "organic" means" when it is on a cosmetic. We can't do that until we get some standards out there and stimulate more ingredient innovation and production and get people involved! Right now we have all sorts of ideas but not much action

Based on history, we should do the same thing that occurred throughout the '90s for organic food; respect and support the various standards out there, keep demanding more credibility and more organic ingredients, and continue to evolve this very important path to clean and sustainable cosmetics and personal care products. The folks who are extremely concerned about “organic” can buy USDA certified organic personal care products until such time as other standards are acceptable to them. In the mean time, I want to participate in the good old messy American process of “public policy” work.

Okay - so this has nothing to do with organic cosmetics - just with humanity. 

I've always that thought that the people who go on those low carb diets were nuts. The human body needs fruit, vegetables and some other form of carbs. Now I know, they aren't just nuts, they are dumb. In a recent article in a science journal, "Appetite", a group of researchers at Tufts documented that low carb diets, compared to restricted calorie diets, resulted in reduced cognitive abilities of the participants. If you eat less but still a balanced diet, you get glucose to your brain and every thing works as normal. When you go no carb - there's less glucose getting to your brain. You get dumb. The person that figured out the no carb diet must have been on a  . .  no carb diet! 

Does Our Skin Absorb Personal Care Products?

Some of you may not know that, although I do not practice, my education was as a physiologist and the science habits I learned have lingered. I can’t hear people make certain types of claims without wanting to know the source of their science and wanting to know their definitions.

I continue to hear and read various claims about cosmetic products applied to the skin (I’ll address lipstick later):
- “80% of everything you put on your skin is absorbed!”
- “60% of everything you put on your skin is absorbed!”
- “98.8% of “chemical such and such” is absorbed into your skin.”
- “Your skin “eats” the products you put on it.”
These types of comments have always bothered me – why? My weird brain:
1 – Personal care formulas are made of a range of all water-base, all oil and everything in-between. If someone said that 60% of a formula absorbs into skin and it is 60% water and the rest is derived from oil, do they mean that 60% of the water soaked in? Or do they mean that some of the water and some of the other ingredients “absorb”? What do they mean?
2 – Think about it – if your skin absorbed 60 to 80% of what you put on it, wouldn’t you start to look a little puffy? I keep having visions of the Michelin Man when we get out of the shower . . . if we absorb all this stuff – where does it go? What happens in the shower, do we absorb all that water? Where is the logic in these statements?
3 – I know, because I have done my homework, that most oils are large molecules. They just are too big to be absorbed into skin – they sort of snuggle down into the 2nd layer of the epidermis and stay there, or they sit on top of the skin. There are some small molecules, and I would question those, but I doubt it is 60 or 80% of any formula.

I believe we should always question any blanket statement. They sound too much like myth. When you think about the fact that most liquids have some degree of volatility, then we need to account for temperature, humidity, and the individual volatility of the material. Alcohol, as we can all feel, evaporates rather quickly. If skin or the air is warm, alcohol volatilizes really fast. So, if essential oils are in the formula, do they evaporate? If it is cold, do they all congeal on top of your skin? What about formulas high in water? I'm going to guess they would behave differently in Arizona in July versus Maine in December.

The physical science of liquids (lotions and other products) applied to skin is extremely complex and NEVER predictable enough to say that any specific percent of any topical application is consistently “absorbed”. (I actually read a couple of heavy-duty research papers that demonstrate this statement through research). Next time you hear such a statement, ask what the heck they mean. Absorbed to where? Absorbed under what conditions? Which parts of the formulas – the water, the oil, some magic combination?

That said, I do suspect (have read verification) that the vast majority of personal care items are washed down our drains. That does worry me. More on that later.

Oh, and if you want to learn a bit more, check out this web site to learn about skin structure: http://dermatology.about.com/cs/skinanatomy/a/anatomy.htm

Happy Saturday! Gay

Seal, Seal, Who's Got the Seal?

Have you ever stopped to look at how many “organic” certification seals there are on “organic” food products? I just took a bunch of things out of my cupboard and when I placed them all out on my counter, I counted 11 different seals on 17 products: USDA, CCOF, QAI, OTCO, ICS, SGS, WSDA, TDA, CDA, GOCA, and EcoCert. Some had the USDA and the certifier seal, some had just one or the other. Question? Is the organic “seal” the important thing to the consumer? I don't think so.

So, at a recent conference when multiple presenters bemoaned that cosmetic “consumers will be confused by all the different organic and natural standard seals” I just had to shake my head in amazement. The market is growing at 20% to 25% per year (for food, more for cosmetics) and clearly, it can’t be because of the multiplicity of seals, maybe in spite of all those seals?

In the days when the country was collectively writing and commenting on what became the “USDA Organic” regulation, there was a REALLY big fight; the 40 odd certifiers in business here in the U.S. (we won’t even include the rest of the world) all wanted to continue to require the use of their own “seal” on products they certified. The USDA wanted only the USDA-NOP seal allowed. The final compromise was that you could use either one or both seals – your certifier seal, the USDA seal or both seals. This was an opinion that came from certifiers, not from consumers.

The USDA oversees the credibility of American agricultural products. In the case of the National Organic Program (the NOP) the meaning of the USDA Organic seal is intended to communicate that there is a single standard, one that means the same thing from Bangor to San Diego.

The fact is most people have a fuzzy idea of how certification works. I probably explain once a week that if you are getting certified to the USDA-NOP, you are being certified to a Federal LAW by an accredited private agency, also known as an Accredited Certification Agent (ACA). You are NOT certified to CCOF or Oregon Tilth or QAI – they certify you to the USDA-NOP regulation. To my mind it would be better if the food world only used the USDA seal, then they would be sending a unified message.

Back to the issue of “new” seals on organic cosmetics: if a few more certification agencies pop up in our part of the world (body care), I think it is okay. It really can’t get any more confusing than it already is in the food world. There are 98 ACAs in the US, all of them pushing their respective seals on products. A few more that are specific to cosmetics probably really won’t change the landscape all that much. Meanwhile, we work to collectively decide what “organic” means on a “cosmetic” or personal care product. This has worked for the 40-year history of the organic food standards and I don’t think it will hurt “organic” cosmetic standards to take a similar path.

Happy Saturday – Gay

Copyright, G. Timmons - June 7, 2008

Welcome to the Oh, Oh Organic blog

These are my personal musings on some of the issues in the organic industry, the cosmetic industry , and our collective responsibility to be informed and make this world a better place.