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BONE RANT

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Fri, 23 Apr 2010 14:39:00 +0000

Okay – I’ve just had it with the calcium/bone loss commercials.

I have a degree in both archeology and physiology –so I’ve looked at a lot of bones for a variety of reasons. For the moment, please ignore my whole organic cosmetic thing.

Human bodies are amazingly efficient. If you are not using your bones by pulling on them with your muscles, they really have no reason to lay down calcium and get stronger. SO – you can take all the calcium by mouth you want but if you are not using your muscles to pull on bones, the essential signal to your body to increase bones strength and density is not communicated. And why should it be?

One of the reasons we know this is true, is that when you look at skeletons you can almost tell their profession by the bumps on the bones where muscles attach: people who did a lot of physical labor had larger, denser bones with pronounced muscle attachment points. The wealthy (think nobles in Europe who had servants) tended to have finer, smoother bones with less density. And you should see the hand bones of pianist!

So when I see these dumb commercials selling calcium and drugs to reverse bones loss, I just want to scream. They don’t work well and many of them lay down a layer of a completely different mineral (not calcium) that is brittle and in no way protects you from breaking your hip or crushing a vertebra.

All humans, especially woman, should do 2 days a week of 20 minutes each session of weight training from 40 years on. It is the only way to ensure that you have safe bones as you age.

Why the US needs private organic cosmetics standard

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Thu, 11 Mar 2010 01:31:00 +0000

This was originally published in CosmeticsDesign.com on March 8, 2010

Why the US needs private organic cosmetics standards

Organic certification creates an even playing field for the industry, it provides answers for consumers, and it supports credible exports; broadening the marketplace for both American-produced cosmetics and for organic raw materials.
It allows clear education and communication and is vital to the development of new ingredients and technologies. It provides a platform that supports investment in this industry sector.

However, in a recent survey by the Organic Trade Association, 26 percent of its personal care members were certified to any standard, while only 8 percent were certified organic to the USDA National Organic Program.

Meanwhile, over 60 percent of European companies making organic claims are certified. This means that American companies are at a disadvantage in international markets and in their ability to answer US consumers' questions about organic claims.

Why USDA-NOP is not good for certifying cosmetics

The existing USDA-NOP works well for food, not for cosmetics. Cosmetics require synthesized chemicals (surfactants, emulsifiers, preservatives) for functionality.

As a result, the NOP rule has been used to certify as organic, non-food synthetics like soap (potassium cocoate) and mono-and di-glycerides. Synthetics are not “bad”, but they are very different from organic food.

Separate standards for cosmetics will channel the creation of cosmetic ingredients to an appropriate industry sector and protect organic food while supporting increased use of organically farmed materials.

In addition, the NOP must reconcile with the FDA how to regulate ‘organic’ cosmetics. This process will take many years. We are wasting time if we wait for it to become final.

Furthermore, the NOP program never fully included “sustainability” in processing standards as they did in farming.

Farmers are required to prove that they improve their environment as a result of farming, but processors are not required to meet these criteria.

We can have a better standard that includes sustainable practices for manufacturers and drives sustainability throughout the supply chain.

Role of retailers

Retailers did a great job supporting organic food certifiers in the 1990’s, but have seriously dropped the ball for cosmetics claims. In the mid-90s, one could not sell a food product labeled “organic” to a retailer unless one was third party certified to a private standard.

Today, instead of requiring this in the US, retailers are making up their own ‘standards’ that are only lists of ‘allowed’ ingredients and are not focused on ‘organic’ but exclusively support ‘natural’ claims.

In the 90s, we had the perfect confluence of private certifiers, market demand, and retailers demanding third party certification. This drove organic market innovation, supported consumers, and increased the demand for organically farmed products.

During this time the infrastructure of the organic food industry grew to support the need for the NOP. This model gave us a great food program. Retailers should once again support certification, not unverified ingredient claims. They should be the gatekeepers for all of the stakeholders.

Get off the Fence!

The personal care industry needs a clear, sustainable future; that future should give better products and better information to consumers.

As long as we avoid the responsibility for certification of organic claims, we can do neither. Avoiding certification causes us to lose out in our efforts to ‘grow’ organic farming, and few will invest in the future of companies making self-professed ‘organic’ label claims.

The European companies exhibit a robust market for investing in ‘organic’ companies, using private certification.

American personal care companies need to make a choice and get certified - to any of the organic standards.

Choose a standard and go with it

All of the ‘organic’ personal care companies should stop ‘waiting for things to settle down’ and commit to a standard, and tell the National Organic Standards Board to back off; the industry needs to try private certification in the marketplace.

Likewise, retailers should recognize and support the important role they play. As a result, all the stakeholders would benefit.

Fear of lawsuits and lack of market incentives and consumer understanding has effectively stopped the conversation about what defines an ‘organic cosmetic’.

Until we allow this conversation to move forward in the US, we will continue to deal with ‘wishful’ organic labels, an uninformed public and ‘organic’ retailers who support ‘natural’ cosmetics.

This is a betrayal of the original goal of the organic movement: to nurture and grow the organic market place for farmers.

How To Learn To Use Chopsticks

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Tue, 23 Feb 2010 21:40:00 +0000

Can’t talk about organic all the time! So the other evening my daughters and I were smiling while watching someone in a restaurant struggle with chop sticks. My youngest (13 yrs.) was rather smug about her skill with said sticks. Then we remembered how they learned to use them. It was not from growing up in a family that used them nightly.

When it came to teaching my kids here is what I did:
- Gave them a big bowl of popcorn and each a set of chop sticks,
- Told them they could only eat what they got in their mouths with the chop sticks.
- Then they graduated down to some sort of cereal that was roughly the size and shape of Trix.

They were around 6 and 8 at the time and they really did master the skill.

That is one way to learn how to use chop sticks.

Scones

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Tue, 16 Feb 2010 01:40:00 +0000

There is a big difference between "organic" and great cooks. It would be amazing if I could get the great cooks I know to use organic ingredients; I'll keep working on it. That is just my disclaimer - now I'm going to tell you about some wonderful products I've found lately. Not cosmetics.

As some of you know, my brother had a stroke. Lately he has had some other issues. As children of Southern parents (Georgia and Tennessee), there are certain foods we just love. Biscuits are a form of high art in Southern Cuisine. So when I was looking for something to cheer my brother, it was natural for my eyes to fall on scones, a special biscuit with "stuff" added.

So here is the best scone I have ever eaten in my whole life: "Charmed Scones". I found them at the Los Feliz Farmer's market on Vermont on Sunday mornings. Or you can buy them at: http://www.etsy.com/view_listing.php?listing_id=34670624 (use this address - I went to Etsy.com and couldn't get the company to come up by writing "charmed scones" in the search box. Weird??).

I never push products but these were so good that she deserves loud and abundant praise. Scones are hard to make well. They are usually heavy and crumby an not awe inspiring. These Charmed Scones are awe inspiring.

Then go over to the Hollywood and Vine (really Hollywood and Ivar Street) Farmer's Market on Sunday morning and try the organic coffee in the food aisle. Amazing - especially the latte. Again, awe inspiring if you are a person who loves the taste of coffee (not just the effects).

I love Farmer's Markets and I've been in LA a lot lately. If you are ever there on a weekend, check these out. Support organic farmers and these markets. Experience artisanal, lovingly grown and made food. At home it is the Campbell Market for me, but there are many good markets. Buy produce from producers! Not grocery men. They can have all the other money.

Here's to scones and coffee!

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Thu, 21 Jan 2010 23:59:00 +0000

If you own a company that makes personal care products and uses organic claims on your products, you may want to seriously study the issues in the recent complaint filed with the USDA- NOP by OCA and Dr. Bronner’s Magic Soap, and Essential Organics against personal care brands that use “organic” claims.

Complaint:
The “Complainers” are saying that the “Defendants” are “cheating” because, regardless of the amount of organic content these companies use, they are not certified to the USDA-NOP. The "complainers" hold the view that the defendants, should not have the right to use the word "organic" unless they are certified to the USDA-NOP.

Background:
The USDA-NOP is an agricultural agency dedicated to supporting American farmers and ranchers. The NOP (Nat’l Organic Program) was originally conceived (in 1991) as a labeling program to create an “even playing field” for organic products in interstate commerce and on the international market. Throughout the law it refers to “food”, 35 times in fact. There is no reference to personal care. If you can make it and label it as though it were a food, then you may get certified. The NOP has published a document on their web site that states that a personal care product MAY be certified to the NOP but it may also get certified to a private standard. They also state that they have no jurisdiction over cosmetic labels, as that is the job of the FDA.

What Ifs:
IF this complaint were to be acted on by the NOP, IF they could because they had jurisdiction and IF there were laws that any of these companies had violated, what would happen?* NOP would begin to mandate that all personal care companies be certified to the NOP.

What Is NOP Organic?
In order to make an “organic” claim, ALL of your ingredients, except for the few that are listed in the law as “allowed non-organic” must be certified organic to the NOP. The “allowed” list includes non-organic glycerin and tocopherol and a few other things. These must be used in less than 5%. That means, no, you may not use just a couple of drops of non-organic jasmine or sandalwood oil because they are NOT on the “allowed list”. You could not add a little bit of ANY non-organic emulsifier. Your only preservation option would be org. alcohol. You’d need to have a current certificate for every single organic ingredient you use and it would probably cost around 1800.00 per year or more to get and stay certified.

In the complaint Bronner, et al, includes the Stella McCartney products - this line is certified to the EcoCert Organic Cosmetic Standard. In France law requires that they include water when calculating any label claim. Their label laws wants consumers to know the actual percentage of a package that makes any claim. Under the U.S. organic law we exclude water. So here someone can make a product that is water, salt and a few drops of lavender oil and call it “95% organic” - even though it is actual less than 1% organic in total. In France and under EcoCert it is the actual percentage of the total. International laws make this type of labeling complicated so the OCA complaint about that product line may be wrong - if they calculated it the same way we do, they may well meet the threshold of 95% for certain products. If you were to apply the same principle as the French use to “made with organic” soap, the label would have to claim around 5% of the total as “organic” content. Liquid soap would not meet the EcoCert standard for skin care, for example. They make an exception for soap and allow it to be 5% and use the claim. I think that may be the more honest approach.

That leaves the big question of how we create credibility for organic claims? In the food industry, the organic farmers and food processors worked for over 40 years to get their standard made and passed into law. We don’t use preservatives in food because we cook it or refrigerate it, and then we use it up or feed it to the dog. It doesn’t stay on the bathroom shelf for 4 years. As to emulsifiers, egg yolks and mustard are dandy emulsifiers - again for food. Not a good idea for skin care.

How do we get a standard that recognizes the unique challenges of cosmetic formulation and product shelf life? Do we use a food standard? Is that a smart thing?

I continue to be struck by the fact that no one will buy a product that does not perform to meet a consumers expectation. I suspect that the reason I never see USDA shampoos, lotions and conditioners in the stores is because they do not sell well. (Frankly, I am well over 50 and darned if I will use alcohol on my skin).

Personally, I want to see strong standards that are credible. I think the EcoCert Standard and the OASIS Standard are both valid standards that will evolve into the future of “organic” cosmetics. I know from the history of the organic food movement that we need a solution to a problem that includes some real challenges:
Thousands of small businesses, all of whom have (sort of) made their own rules about what their “organic” claim means.
Insufficient organic ingredients to emulsify and preserve products that perform.
International legal labeling issues that should be integrated into any standard.
And a lack of clarity due to both deliberate and unintentional misinformation.

I would like to see all of the non-certified personal care companies make the effort to understand the NOP rules (call me - happy go over your ingredient statement and explain where you fit) and to work together to create a plan to serve all these small businesses and their very specific needs. The food regulations were never intended to do this and soap is certainly not food.

* A judge has already examined the charges in the complaint and ruled that there was no violation of law. Actually, 2 judges.

No Growth Blues for Greens

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Mon, 14 Dec 2009 19:12:00 +0000

This morning the TABS Group, a U.S. based consumer analysis firm announced a study finding that there was little or no growth in “organic” personal care product sales in the U.S.. Recently Organic Monitor, out of the UK, announced that double digit growth in “organic” personal care continues in European markets.

What is up with that?

I think it has to do with certification. In the EU over 60% of the products making organic and natural claims are certified. The Europeans have used various standards for many years. BDIH, a natural standard, has been around since 1951, certifying “natural” since 1996. Soil Association and EcoCert both put out organic and natural standards in the early 2000s. The Europeans are not allowed by law to certify cosmetics to a agricultural standard so they use private standards. As a result:
Manufacturers get educated through the certification process
- They educate their consumers
- Consumers can look up the standards on line and hold someone accountable
- Retailers know they are getting a product that has been vetted by a third party
- Organic farmers continue to be supported
- Sustainable production is increasing as a result of this work

Man, I hate it when the Europeans are ahead of us.

On our side of the pond, things are a mess. Yep, you read it, a mess. “Organic” cosmetic companies are not getting certified nor are they compelled or encouraged to get certified. Why?

- A litigious party brought a law suit and made many people paranoid that they might be sued too. So they just keep doing what they are doing hoping that no one will notice them.
- Whole Foods made their own “list” which they call a “standard” but there is no third party certification, just people saying they meet it. So, what is that all about? It has nothing to do w/ organic!
- OCA (who only ever prints half of any story, because if you knew the full story they wouldn’t be able to scare you into making a contribution), has done their level best to support the use of the organic food laws to certify synthetics!! Why? I wonder if it is because of who they get money from?
- No one seems to remember the 90s, when we all bought privately certified food products because we were working out what processed organic food was. It took 12 years! Cosmetics needs the same thing.
- Finally; why would anyone use a food law to certify cosmetic chemicals? Why?

Another opinion, although one supported by consumer research; people buy products that work, they want “performance”. So the challenge to the “organic” cosmetic industry is to make products that perform AND that are made from organic materials. In order to do this, we have to use organic raw materials, like coconut and palm oil and react them in similar ways to conventional products, using environmentally safe processes and technologies. This will make “organic” ingredients that perform (under a separate standard). Again, the EU is far ahead on this path.

What can you do? Write the National Organic Program Director, miles.mcevoy@ams.usda.gov and tell him you don’t want the USDA to regulate personal care products until private standards have been developed enough to give us the ingredients and standards that are appropriate for personal care. Twisting the organic food regulation in order to certify synthesized chemicals is simply hurting the organic food community. Further more, it s a statement by a very few that consumers are not smart enough to tell the difference between a food standard and a cosmetic standard. Consumers are smart enough and they deserve respect and certified products that work. Not some lousy “shampoo” that you have to follow with a lemon juice rise so that you don’t completely destroy your hair. Yes, it will take a couple years but the Europeans are already providing the model for good and functional standards that will, eventually, vastly increase the market for organic raw materials. Time for a few people to check their egos at the door and do what is right to promote more organic agriculture in a time when our planet desperately needs it.

Copyright G. Timmons 12/14/09

Progress Or Backslide?

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Sat, 21 Nov 2009 20:18:00 +0000

Two weeks ago the Advisory Board (the NOSB) to the USDA-NOP passed a “recommendation” that the Dept. of Agriculture should regulate organic claims on cosmetics. Currently, the FDA regulates cosmetics labels, not the USDA-NOP. Then a bunch of “natural” food stores sent out policies or letters telling their vendors that, if they make an organic claim on a personal care item, they needed to get certified to the NOP. Spare me.

There are thousands of small companies all over the US and Canada that make uncertified “organic” claims on personal care items. Most of them do not follow the NOSB. Even in OTA, an organization that one assumes attracts dedicated “organic” businesses, in a recent survey discovered that only 9% of their personal care members are certified to the USDA-NOP. Again: nine percent!!!!

Why?

Cosmetics depend on synthetic ingredients to function well. There are simply not enough of the functional ingredients necessary to make a personal care product that performs well, which assures repeat sales. This means that conventional synthetics must be used.

How did we get to a regulation for organic food? The effort included 40-plus private certifiers serving the “organic” community from the 1960s until 2002 which created the momentum and infra-structure necessary to arrive at and support USDA-NOP certified food. It takes time to create a market and all the parts of the market necessary to make it work. (A factoid: Whole Foods profited for 24 years on non-NOP “organic” claims.)

Organic food contains certified agricultural ingredients. In cosmetics the “organic” certification of potassium cocoate, mono and di glycerides, and sucrose palmate is certification of non-agricultural ingredients. Is it best for all “organic” stakeholders to include the certification of “synthetics” under the Dept. of Agriculture?

This is what I see: people want the “organic” label to mean the same on all product categories, but it doesn’t and it can’t. I don’t want certified organic synthetic ingredients in my food. I want organic food to stay pure. I also want certified organic personal care products, but I know they need to be made using synthesized ingredients, and I want those ingredients to be synthesized out of organic raw materials. I also know putting this in place will take years.

The FDA and the NOP, under ideal conditions, cannot “enforce” a law until they have a law. First they have to agree to do this type of enforcement (remember, cosmetic labels are not currently reviewed). Then they have to either amend the Organic Food Production Law or pass a new law. Then they have to write the standard. I'd guess this could take 5 to 8 years. The NOSB seems to imply that they want enforcement now. It simply cannot happen - what do we do in the meantime?

We do what they did with food: use private standards. This could support the NOSB recommendation to the NOP and help make organic certification of cosmetics a reality. To tell companies that they “have to” get certified to the NOP when there are no safe preservatives, no mild surfactants, and no non-slimy emulsifiers is literally throwing the baby out with the bath water. We will end up back in the 1980s with an array of “natural” products and a very few “organic” products. Why can’t the NOSB support private organic cosmetic standards for now? At least people could be certified to something!

The Organic Food Production Act of 1990 was written expressly to certify AGRICULTURAL products. Personal care items are not food, I don’t want to eat them; I want them to work to clean my hair, sooth my skin, and keep my children from getting sunburned. That will not happen using a food paradigm. I want a strategic plan to get us from where we are now to that ideal certified organic cosmetic. The fact is that a number of people have made NOP PC shampoos and lotions and they do not seem to sell well. I suspect this is why we don’t see these products in Whole Foods and other “natural” stores. If we can’t get repeat sales, we can’t “grow” organic agriculture. And why would a store carry something that does not sell?

Isn’t that what this is all about? Increasing the market for organic ingredients? It won’t happen just because of the NOP seal. It will only happen if the products are good enough to create repeat sales. Shampoo is not an apple or cookies. The production of an organic apple cleans up the planet but it pretty much tastes and looks like a conventional apple. “Organic” shampoo under the NOP dries out my hair and I can’t use the lotion due to the alcohol preservative. They are not comparable to the more functional conventional versions. Darn it, I want organic versions.

Get real folks - we have a lot of work to do and it is important to do it but let’s use our brains and apply history. The NOSB’s message is well intended but poorly executed. As leaders of the industry, they should be able to supply a timeline, and a plan that will take us from 91% non-certified to 100% of players certified. Their recommendation does not do that. It just further confuses things and seems to be encouraging the removal of some pretty nice “organic” products that are not certified from the shelves. This move by the NOSB and some of the “natural” stores is a shame and diminishes the use of organic ingredients. I think we are backsliding, not making progress. What do you think?

Gay Timmons

NOSB

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Tue, 10 Nov 2009 04:01:00 +0000

It is unwise to take the recent Personal Care Recommendation by the NOSB (Nat’l Organic Standards Board, an advisory board to the NOP) out of the context of the whole meeting and even out of the context of the NOSB's history.

On the NOP web site, there are 10 pages listing the titles of Recommendations (that go back 9 years) by the NOSB to the NOP (this does not include those recommendations that go back to 1994, prior to implementation nor the recommendations passed this latest meeting). Many of these are for materials, which the NOSB does a a really good job at handling. Reportedly, 65 different policy recommendations are still unresolved between the NOSB and the NOP; we still do not have standards for pet foods, textiles, or aquaculture. This is not a criticism, it is an observation about how government works. There are issues of priority, regulatory complexity, expertise within the department to deal with a particular problem that all influence the forward motion of any recommendation.

If you look at the Livestock committee, for example, you see that the first recommendation on pasture access policy was in 2001. I think I read in the "Tweets" that this was finally adopted as policy by the NOP at the meeting last week - but I may be wrong on that. Am sure someone in the know will correct me. Just an example of why you should take the OCA “news” report with more than a grain of salt. It took from 2001 to now to get agreement on "Pasture Access" between all the members of the NOSB and then all of the departments within the USDA. This “high priority” issue took 9 years to get from “Recommendation” to “Policy”. (This is good - it took the FDA 11 years to agree on the legal definition of peanut butter).

We need uniform standards for organic cosmetics. It is also imperative that we continue to support the use of as many organic ingredients in cosmetics as possible. I just don’t think it will happen in the next few years as the result of the NOP. I believe that the NOP’s clear message that personal care is not a priority, as was stated during the meeting:

did not come from the program director but rather, represents the position of the Department of AGRICULTURE,
is a message to the industry to move forward with private standards which will only help any future efforts to write either an FDA or an NOP PC Standard,
is also a message to the cosmetic industry to make some of it’s own progress instead of waiting for the wheels of government to grind down their slow path.

The issues that need to be resolved in the NOP are highly complex and may start with this: that until the NOSB has submitted and the NOP has agreed to final, working definitions of "synthetic”, “non-synthetic”, and “non-agricultural", we cannot make ANY progress on a standard that depends on synthesis chemistry.

Then we need to define what we are certifying - I realize that NOSB set a proposed definition of "personal care" in their recommendation but it may be in conflict with FDA law - which includes things like brushes, candles, neti pots, nail clippers, and anything else sold for "personal" "care" in their legal view of that phrase.

Of course then there is the issue of safety - I would never use a product preserved with 15% alcohol, not on my body and especially not on a child. We have to deal with this. Alcohol is one of the few things that really can act as a transdermal carrier.

So - yes Mr. Bronner and the folks at OCA, after these and many other issues have been resolved, we may be able to move towards enforcement and standards writing, but this will take years. It is impossible to enforce laws that don’t exist;

In the meantime, we still have do not have retailers requiring any sort of certification (except "Natural - which does us no good). There are years of work facing the NOP and the NOSB needs to decide if animal cruelty, existing standards recommendations, certifier training, bio-diversity and food safety should be prioritized before or after personal care.

Folks - this is not going to happen any time soon. 74% of OTA members in the PC biz are not even certified and many of them would not meet the requirements and probably could not sustain their businesses if they did. And that is only OTA members. So let's add this question: in the worst recession we have seen since the “Great Depression” (why do they call it “great”?), is the NOP going to tell thousands of small businesses that they cannot do what they have been doing without some sort of long term lead up (like we did with food)?

We need a strategic path to get people into the fold of certification. This was the first volley across the bow by the NOSB and, as they even stated, it is intended to start a conversation, one that will go through the multi-year process of analyzing the industry. There is a lot of work to be done here. And most of us already have jobs. I continue to believe that we are all responsible for creating and enacting a long term strategic plan that will allow people to get certified, develop the necessary supporting infrastructure and do this thoughtfully. Sorry - it just takes a long time. It took organic food 40 years. It does not have to take the cosmetics industry that long but with the continued barriers being thrown up, it may.

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Mon, 28 Sep 2009 18:52:00 +0000

Even Government Committees Need to Do Their Homework

Secret Codes: (okay - so they are just acronyms . . .)

NOP = National Organic Program

USDA = Untied States Department of AGRICULTURE (Farms!!)

NOSB = the National Organic Standards Board

(They are supposed to represent “us” to the NOP).

CACC = The Compliance, Accreditation and Certification Committee

(A committee of the NOSB).

FDA = Food and Drug Administration

The CACC has made a recommendation to the NOSB that ALL organic personal care products must be certified to the NOP. The recommendation, if implemented the way it is written, would mean that if you have a product that is not certified, you could not call it “organic” - even if it were all organic unless you are certified to a food standard. So let’s get this straight:

1 - An organization that does not have a single member representing the cosmetic industry on it’s board is making this recommendation.

2 - The CACC has not even discussed that fact that there are THOUSANDS of companies in the US that have high content organic personal care items that are not certified (I confirmed this with the Chair person of the CACC). They have no strategy to addres this issue.

3 - In spite of the fact that they were sensibly asked to form a Task Force by OTA to look at the issue, they refused and just made the recommendation without input from the industry.

The really dumb thing about this is that they have no idea if it can even legally be done. The FDA has authority over cosmetic labels. It is unlikely that the USDA can mandate label authority. Even if the FDA and the USDA agreed to some sort of memorandum of understanding, the necessary regulations will take years to first be agreed upon and then to move through the regulatory process (3 years, 5 year, who knows).

Summary - this does not solve the existing problems:

Retailers do not make it a point to carry certified products; where is the incentive?
Even if you get certified to a standard, you might be sued by OCA or he who shall remain nameless.
There are thousands of people making products, they need to be “brought into the tent” of organic and there needs to be a reasonable strategy that will achieve this. This is not a reasonable strategy.

The NOSB is asking for comments on the recommendation. I am going to write them that they should not waste all of our time without doing the necessary work. NOSB, CACC - do your homework! Don't spin everyone’s wheels by asking for comments on a completely irresponsible recommendation. We need standards for organic cosmetics, but this is not the way to achieve them. You need to understand who the players are, what the barriers are, and come up with a sane solution. Just writing a law that puts thousands out of business is not a solution, it is a nightmare.

Go to the link below to read the recommendation and comment to the NOSB, then send them a note.

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5079488&acct=nosb

Gay Timmons 09/28/09 Copyright

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Sat, 01 Aug 2009 15:56:00 +0000

Alcohol and the American Home - Real Work

When I first started to sell organic ingredients into the cosmetic world, I received a pint of certified organic alcohol as a sample - I think of it as my own personal white lightening stash. Don’t get me wrong, you can’t drink this stuff. Here is what you can do:

Sterilize cuts (yes, it stings)
Get sticke goo of glasses and plates
Get Sharpie marks off clothing (they need to be fairly fresh)
Get leaky fountain pen ink off your hands
Remove ink pen off clothing (or your daughter’s arm!)
Get gum out of the rug (some gums, not all.)
Sterilize anything that needs to be sterilized.
Removes pine tar droppings from car windows and surface.

You don’t need special, pure alcohol, plain vodka will work as well as anything.

Two other points about alcohol: I have beautiful hard wood floors and when I moved in there was this one bad stain on the dining room floor. Just for the heck of it, I tried the alcohol. It worked! Now these are floors from the 1950’s. I don’t know what the finish is on them but it may have been that the alcohol acted as a solvent so I was able to remove the layer of whatever the stain was. It is worth a patch test. The other thing I know about alcohol is that it can be used to sterilize (as I repeat above). When a family friend was in the Peace Corp he complained about being unable to use running water and soap to clean or sterilize utensils and his tooth brush. It told him to find the local white lightening dealer and keep a jar of hooch to rinse his glass, eating utensils, and clean cuts to avoid infection. Anything over 15% alcohol content should have some ability to kill microbes.

Of course, organic alcohol is best. You can now buy organic vodka and tequila as well as the wines and beers that are on the market. Cheers!

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Sun, 19 Jul 2009 18:59:00 +0000

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

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Mon, 22 Jun 2009 14:37:00 +0000

EDUCATED TRANSPARENCY

The cosmetic industry seems obsessed by this notion of harmonized standards yet seems unaware that it took the organic food movement over 40 years to get most of the standards on a level field. Even today there is no reciprocity between the US and the EU for organic food standards. How can there be an expectation that the cosmetic industry is any more agreeable than the food folks?

Certification fills two major roles (among a number of roles): one is to teach the applicants about the principles of organic production in their work to conform with the standards aka education. Another is to push the industry to continuously improve as they strive to prove to the consumer that they are credible gatekeepers of the values consumers believe “organic” certification represents aka transparency.

We need companies to make decisions to get certified to any standard in order to begin the process of “organic” education and so to develop credibility through transparency. Until companies make a commitment and begin to use a standard and push it’s development, we will continue to read about the weaknesses of these systems.

Gay Timmons

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Mon, 01 Jun 2009 14:43:00 +0000

THE CERTIFICATION PROCESS

Let’s talk about how cosmetic products get certified under the NOP. Maybe it will help people see how this food model interacts (or does not) with cosmetics.

Start with the qualifications - the NOP allowed everyone who wanted to, to become a certifier initially (2001) - whether they had the experts on hand or not. As years have gone on, the NOP has tightened up and are requiring more and more of the certifiers to demonstrate greater management expertise and product/service expertise. They have still not looked at the education as it relates to fine points but they do require that you show that the people making decisions have some education, training, and/or experience in the area that they are certifying, i.e., livestock decisions need to made by people that have qualifications for working with livestock management. The NOP is actually rescinding the right to certify in certain areas of the “Scope” (Farm, Livestock, Processing) if the certifier cannot demonstrate the necessary expertise to assess and make an informed decision about the products at hand.

Then what happens?

An applicant fills in forms (that were designed to evaluate food production) and submits these along with a recipe or formula or ...whatever you want to call it. In their “Organic System Plan” they explain how they manage the procurement identification, physical handling, and batching of the organic and allowed non-organic inputs to the finished product. They also have to provide documents that “prove” that the non-organic ingredients comply with the requirements of the regulation (non-gmo, not irradiated, not solvent extracted, etc.). The certifier is obligated to “confirm the ability to comply” and then they can set up an inspection. Then you (applicant) should be able to “prove” through documentation that anything you say you do, you have, indeed, done. For example, if you say that you wash down the line and remove the residue of the sanitizer, you should be able to prove that, 1) the sanitizer can be removed (which is not the case for quaternary ammonia products) and that, 2) you have logged the practice of implementing your sanitizing procedure. If you say an ingredient is “organic”, you need to have a current certificate AND an invoice to prove you purchased ingredient. Oh - the certificate needs to match the invoice. You can’t buy it from someone that is not qualified to sell it - unless the package is intact and the vendor is a broker of a trader. An example of this is that I sell some oils in their original drums and can provide the cert from the original packer and their label is on my certificate - either way it proves my handling of those products is compliant. This is what the certification world refers to as “audit trail”.

So then - it comes to the “on site” inspection. The certifier sends an inspector to verify that what ever you say you do, is being done and that you are not doing things that you have not represented in the “Organic System Plan” or OSP (think of the OSP as GMPs for organic.)

Here are a few of my concerns: in an environment where a company is synthesizing ingredients like soaps or glycerin or esters, the certifiers usually have no experience at all in synthesis chemistry. Now this is fine if the applicant knows all the rules and does it all according to the rules, but if the chemist is thinking one thing and the inspector is thinking another and there is a lack of understanding...than things can get certified that, perhaps, should not be. This can happen, for example, because certifiers ask for “processing aids” and never mention reagents or catalysts (again, not used in food production) or simply because what is so simple or normal to a chemist and may not be allowed under the NOP but "food" language if different than "synthesis chemistry" language and things can get cloudy. Another area of concern is the making of finished products. If a company runs hair care products through their equipment and does not have dedicated organic equipment or a way to truly remove the residue from quats and silicons, they are making “organic” product that is contaminated due to contact with these 2 categories of materials. Since most certifiers are unaware that these materials are used as ingredients (in the food world they would only look for quats in sanitizers and they don’t use silicons at all in food) so...they may not ask about these materials at all, they would be invisible and would remain as contaminants under an NOP system.

Further more - since many of the certifiers do not have chemists on staff, they are making, what I call, “Google Decisions” about some of the processes that they certify - they have no first hand experience or knowledge of the process but they’ve looked it up on Google and seem to glean enough info to make them comfortable about certifying it.

I won’t even get into the issue of certifying cosmetics to a food standard that requires food labeling laws but are being labeled under INCI.

Summed up: when decisions are made by a certifier who is not FULLY informed, there exists a chance that the certificate could be pulled at some date, or that labels are wrong, or lord knows what else. That is the time to remember that the applicant is responsible for the law. You need to understand it better than your certifier because they will have plenty of customers and no one really knows who they are. Brands, on the other hand, have a reputation to protect. Look at Johnson & Johnson.

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Wed, 20 May 2009 14:39:00 +0000

MAKE A COMMITMENT!

Natural Beauty Summit May 2009 Report

Okay - so I am not really “just back from” the Natural Beauty Summit (NBS) but, after a couple weeks of the normal mess involved with moving, I am getting around to a report. Keep in mind - these are the things that stuck in my head 2 weeks after the event.

After 2 days of (estimate) 30 people speaking, there is no doubt that “organic” and “natural” are here to stay for a while. At the same time these label claims are being increasingly held up to scrutiny, hence the various standards. Listening to the various people that got my attention, I came away with two messages -

1 - make a commitment,

2 - and we really do have a problem with waste in this industry.

Make a commitment: Mike Indursky of Burt’s Bees and Ido Lefler of Yes to Carrots hit the same theme: pick a standard, get certified, commit and support the standard you’ve signed on for - use the logo to your advantage, any logo, any program, just commit. We should keep in mind that not everyone has the million dollars that Burt’s put into marketing the NPA logo which, from what I hear, is expensive and not transparent in it’s delivery process - but what the heck - if you have an NPA product out there you should send a “thank you” letter to Mike.

Then Jasper van Brakel (CEO Weleda North America) discussed the 80 odd year history of Weleda and their steady climb through the market place by recruiting growers to grow the Bio-Dynamic crops used for the herbal products they make. This is an “inside-out” approach - buy my product because of what is on the inside of the bottle. This is a commitment to their own company policy and ethos. Their company age and the simplicity of their ingredients makes this very achievable for them.

The counter to the above speeches was the presentation about the “Cosmos” Standard which is supposed to be the “harmonized” EU organic and natural standard that totally confused most people there. Evidently the “harmonization” is not planned to occur until 2012 and then they only need to use the standard as a base line! So much for that idea.

I presented about OASIS, we are marching along (that is another blog) and Joe Smilie of QAI tried to convince everyone that the Dept. of Ag (USDA) would be able to enforce cosmetic labeling and use the NSF “made with” standard. He failed to mention that the use of synthetic materials is prohibited under the Organic Foods Production Act, the law upon which the USDA-NOP regulation is based so . . . it probably won’t happen. Hello! This is personal care - surfactants, preservatives ad emulsifiers are ALL synthetic, even if they are “good” synthetics. We need a different approach than the food world needs.

Waste: There was a great presentation about “cradle to grave” certification (something we are working on at OASIS). I know that personally the packaging of cosmetics has always blown my mind - of course I grew up next to Berkeley, Calif., in the days when we went to the first (real) Body Shop where one re-filled bottles with personal care product base and added one’s own choice of fragrance - at least until the State of California stopped that practice as “unsafe”. Okay - so maybe we needed to return our bottles and have them sterilized first but . . . what are a few bacteria compared to the tremendous pile of garbage we create daily? Point being, that this industry has much greater issues to grapple with in the future. There were many talks that touched on these long term issues. They start you thinking.

So - the marketers pushed the need to craft and commit to a clear message (put that way, it doesn’t sound very original, does it?) and the environmentalist pointed out the continued long term implications of what we put down the drain and in the garbage.

There were also sessions about using “food” as personal care ingredients, something I’ve worked on for 10 years - so, in view of my need to start moving 6 years of stuff into a new home, I opted to leave. I’ll make a few calls to folks that attended it and let you know the outcome.

All that said - it was a good conference, expensive but, I think worth it, and I look forward to the development of this particular venue to support and educate the cosmetic industry.

Whether You Are Certified Or Not; Good Ideas

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Fri, 27 Mar 2009 14:21:00 +0000

I was talking with a friend about how I comply with my org. certification and he thought I should post it. Here you go:

One part of the regulation, 205.200, says: "Production practices implemented in accordance with this subpart must maintain or improve the natural resources of the operation, including soil and water quality."

Most certifiers do not enforce this - but I think it is a good idea regardless so every year I try to find a new way to add a practice in my business to my organic system plan (and my business procedures) to reduce my impact on the planet. The first year I simply made sure that all my boxes and all my office paper were recycled - to some percentage. The next year I figured out that I could give all of my empty drums to folks who were either in the bio-diesel business or who wanted to make barbecues - so I posted in the "for free" section of craigslist. No more problems looking for homes for my empty drums! Then I switched to 100% recycled/bio-degradable puff for packing our boxes. Most recently I wrote all of my customers and told them we wanted to shift to paperless invoicing - we email all invoices (I do have 2 customers that insist on paper). This saved paper, envelopes, time, gas to the P.O., stamps, and printing ink! We done a few other simple things, swirly light bulbs, up the recycle content of boxes and paper, we recycle everything anyway - it is law in our county.

For next year we are talking to the landlord and I'm helping them shift the entire landscape around our building to native & Mediterranean, low water need plants (getting rid of the grass - not like were playing football here!). Fortunately I have a hobby of brain dead low maintenance gardening so I've got the resources, suppliers and plants at my fingertips. We think we can save the building (CAM if your are a commercial renter) a bunch of money with this change.

Anybody have any other ideas?

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Thu, 29 Jan 2009 14:51:00 +0000

DEFINING SUSTAINABLITY

Sustainability: I must have looked at 20 different definitions for this word. I am a bit obsessed lately with finding a reasonable definition that I can relay to my clients, members of OASIS, and especially to myself.

Maybe I should look at the opposite.

It is NOT sustainable to ignore reality. We have learned this. We had an administration that did not want to address global warming for the past 8 years and it seems pretty clear to the majority of the world that the bodies, the cars, and other machines they drive (and our gassy animals) are a big problem. The other part of this is all of the other pollution that we generate. Agriculture is an enormous contributor. I found in a publication by our GAO (U.S. Gen’l Accounting Office – (http://www.gao.gov/new.items/d031148.pdf) that we used over 100 million tons of nitrogen derived from natural gas on crops in 2003. So you need to remember that 1) commercial fertilizer comes from petrochemicals (natural gas) and, 2) that is 200 Billion pounds when you multiply it out.

Geez. That is a lot of chemical fertilizer.

Why do I bring this up? Because organic plant production does not allow the use of petrochemical derived fertilizers. You can make fertilizer out of waste, in fact very high quality nitrogen nutrients balanced with other necessary nutrients for plants – we know it as composting. What a concept. SO – if we can push more people to do more with organic production methods, we can:
1- Reduce nitrates in our water (the effect of commercial nitrogen fertilizer is nitrate accumulation in ground water)
2- Improve crop outcomes (compost fed tomatoes have higher fruit solids than commercially grown nitrogen tomatoes – imagine that – more nutrition!)
3- Reduce our dependence on imported petrochemical gas (we had to import almost 50% of our fertilizer in 2003 due to the price of natural gas – I wonder what it was last year!)
4- And we can use up compostable waste to make . . . fertilizer!

So – part of sustainability means that you can continuously do something because it is not destructive of its source. We grow food, we create waste, we convert that waste to nutrients to grow more food (or cosmetic ingredients in my world). Gotta’ say it again: what a concept!

I’ll work on the rest of "sustainability" in the future. As for this part,one definition may be "to create a production cycle that is self supporting". Still not sure. More work!
Copyright 01/29/09 Gay Timmons

Harmony or Sustainable Public Policy?

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Sat, 20 Dec 2008 17:13:00 +0000

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.

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Fri, 12 Dec 2008 15:17:00 +0000

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!

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Sun, 20 Jul 2008 03:55:00 +0000

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?

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Mon, 23 Jun 2008 16:46:00 +0000

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

info@ohohorganic.com (Oh, Oh Organic, Inc.) — Wed, 04 Jun 2008 21:48:00 +0000

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.