Proponents of HR5786, which shadily masquerades under the title, “The Safe Cosmetics Act 2010,” claim that the bill will finally bring regulation to an unregulated industry, and that it will make our products safe, and bring an end to the pandemic use of toxic chemicals.

That’s exactly what EWG, The Environmental Working Group would like us to believe. They are a major supporter of this bill, and along with efforts by the Campaign for Safe Cosmetics, EWG wants to convince the public that the cosmetics we purchase are not regulated, and teeming with carcinogenic, toxic chemicals. They are doing their best to convince the public that the overreaching monstrosity known as HR5786 will provide the regulation necessary to ensure safe cosmetics for consumers.

Supporters of HR5786 may be interested to know that the FDA already regulates cosmetics. Here are some enlightening facts. FDA requires cosmetic products to not be “adulterated” (contaminated, unsafe, etc), or “misbranded” (falsely, lackingly or misleadingly labeled). They require manufacturers to be responsible for substantiating the safety of their product. Under current FDA regulation, it is illegal to market products that are known to be unsafe.

Under HR5786, manufacturers will still be responsible for substantiating safety…and products will still be required to be labeled in an accurate way. And, as before, the FDA will continue to prohibit the use of chemicals that are known to be unsafe in cosmetics.

So, what exactly is HR5786 doing that is not already being done, aside from creating an overreaching, excessive paperwork load for all cosmetic manufacturers, and increasing costs for everyone?

If we want to effect positive change, then the FDA needs to be given the resources to enforce CURRENT legislation. There is no need for NEW legislation since the requirement for manufacturers to create safe cosmetics already exists.

I’ve been reading quite a bit about the non-profit Environmental Working Group. In addition to being known for their support of this bill, they are also known for promoting bad science and creating media hype and consumer hysteria, as I feel they are doing with HR5786. I find it particularly notable that the Campaign for Safe Cosmetics released their cutesy YouTube video, “The Truth Behind Cosmetics” the same week that HR5786 was released in Congress. Scare tactics and fearmongering are despicable ways to ensnare an uniformed public into supporting legislation that ultimately will profit EWG and CFSC, and drive prices up for consumers.

This is not the first time EWG has resorted to such tactics. Their involvement in numerous bad-science issues can be found all over the internet. Luckily, an equal amount of information can be found which repudiates their dishonest hype. For example, the FDA’s official response to reports by EWG and others about TOXIC LEVELS of LEAD in lipstick is particularly telling. As it turns out, when EWG claimed that lipsticks had toxic levels of lead in them, they were using data on acceptable levels of lead in CANDY (intended to be consumed, and taken internally), as a basis for their analysis of the amount of lead in lipstick (which is applied topically, with minimal ingestion). FDA.gov has the entire report, complete with testing that reveals the truth, and safety of lipstick. Or, read here (http://activistcash.com/organization_overview.cfm/o/113-environmental-working-group) about EWG’s false claims of contaminated tap water in Florida. Turns out that EWG was basing that unnecessary hysteria on a test performed on untreated groundwater. These two examples are only a drop in the bucket representing EWG’s proven track record for junk science.

I do not feel that a complete overhaul of our current cosmetic regulations are necessary. There are certainly ingredients that could be added to the “do not use” database. But, I feel that funding the FDA to enforce the laws already on the books would be a more effective way to ensure safe cosmetics than by incorporating EWG’s junk-science-based Skin Deep Database into our cosmetic laws, and bulking up the salaries of their already over-paid executives.

For more information on this topic, please read our other blog posts HERE, and visit http://opencongress.org to read the full text of HR5786 The Safe Cosmetics Act 2010. There are many great blogs and comments there as well, that help to explain the many negative effects this bill will cause if allowed to pass.

Please also consider opposing this bill, and signing the petition: HERE. And, know that we do NOT oppose safe cosmetics. On the contrary, we oppose over-regulation, unreasonable paperwork loads, and the killing of small business and entrepreneurial spirit.

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“At Formulation” requires the listing of lye, either sodium hydroxide or potassium hydroxide.

“At Use” requires the use of the terms for the salts of the fatty acids that the oils become, for example, sodium cocoate, sodium palmitate.

Either customers have to be educated on the fact that lye reacts completely and is not present in the finished product, or that “chemical sounding names” are really just natural oils converted into soap.

I’m going with “At formulation.”

Any thoughts? Please send me your comments.

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10. Body oils need to be removed in order to have clean skin.
9. The best soaps are pH balanced.
8. Antibacterial soap is better than regular soap.
7. Soap made with chemicals is bad for your skin.
6. If you can’t pronounce it, it shouldn’t go on your skin.
5. Lye soap is harsh.
4. Soap can be made without lye.
3. Castile soap is 100% olive oil.
2. Soap making is difficult and expensive.
1. Soap can’t be “all-natural” since it doesn’t exist in nature.

The Debunking Explanations:

Body Oils DO NOT need to be removed to have clean skin.

10. Clean skin doesn’t equal oil-free skin. Our bodies are constantly creating oils that help to clean pores, and guard against germs and dehydration. Using harsh cleansers that strip away natural oils is not necessary in order to be clean. The goal of skin cleansing, is to remove dirt and grime, sweat, and harmful bacteria.

pH  Balanced Soap is Not Necessary For Skin

9. Many soaps claim to be pH balanced implying that this is somehow beneficial to skin. pH is a scale used to describe the balance between acidity and alkalinity. Handcrafted soap is alkaline, generally having a pH somewhere between 8 and 10. Our bodies are generally more acidic on the outside, and more basic on the inside. One notable exception to this is the stomach, where harsh hydrochloric acid aids in digestion. pH varies from person to person, but in general, our skin is acidic. This helps to keep bacteria at appropriate levels. When we wash with soap, we temporarily remove some of this acidity, but the body quickly replaces it, and returns to it’s normal pH. Attempting to alter the pH of your skin is not only an exercise in futility, but is unnecessary. The body is designed to operate at the pH that occurs naturally. pH balancing soaps will not have a lasting effect on the pH of your skin.

However, we do know that when soap is first poured into a mold, it is highly alkaline. As it cures, the soap becomes less alkaline. Monitoring the change in pH can help determine whether the soap has cured adequately or not. There is such a range of pH’s, though, even in properly cured soap, that this is not an accurate or reliable measure of the gentleness of a soap. Those attributes are more affected bythe choice of oils used.

Antibacterial Soaps are Unnecessary

8. Plain old soap and water is effective at removing surface dirt, grime and germs. This is because soap is a surfactant- a solution that lifts crud, bonds with it, and allows it to be rinsed away with water. Antibacterial soaps, on the other hand, do this as well, but are also promoted as “germ killing.” To do this, the antibacterial agent must be in contact with bacteria for 20 seconds to be effective. Unfortunately, many people do not wash this long, which potentially leads to bacteria with increased antibacterial resistance. There is also concern about the safety of some commonly used antibacterial agents (i.e. triclosan) because of their similarity to dioxins, and links to endocrine system disruption. Being an Ann Arbor native, I’ll share the following that I found on wikipedia: “A comprehensive analysis from the University of Michigan School of Public Health indicated that plain soaps are just as effective as consumer-grade antibacterial soaps with triclosan in preventing illness and removing bacteria from the hands.”

Do Not Steer Clear of Soaps Made With Chemicals

7. Soaps made from chemicals are unavoidable. Chemicals are just the universe’s building blocks! Every substance that exists is made of chemicals. It would be pointless to try to avoid them. A couple of common chemicals found on soap labels include sodium hydroxide (the alkaline necessary to turn oils into harmless soap), and sodium cocoate (coconut oil that has been turned into soap using sodium hydroxide). An especially important, and harmless chemical used to make real soap is dihydrogen monoxide, otherwise known as…water.

Unpronounceable Ingredients are Not Necessarily Bad

6. What about those unfamiliar, unpronounceable chemicals? Cymbopogon Schoenanthus oil? Azadirachta Indica oil? These are just two examples of hard to pronounce chemicals that are found on many natural soap labels. They are the International Nomenclature terms for lemongrass essential oil and neem seed oil. Hard To Pronounce does not equal Bad For You.

Lye Soap Can Be Amazingly Gentle on Skin

5. Properly made Lye soap is NOT harsh. Since all real soap is made with lye, then lye soap and real soap are one and the same. When properly formulated and allowed to cure, real soap is a gentle, mildly cleansing product. In a properly formulated recipe, a soapcrafter ensures that lye is the “limiting reagent.” When the lye is gone, the reaction is over. We do this by “superfatting” our soaps. Additional oil is added to the formula to be absolutely sure that any trace of lye will be forced into reacting and creating soap. The unreacted oil remains in the soap as a conditioning agent.

Real Soap Cannot Be Made Without Lye

4. No lye= no soap. It’s as simple as that. Lye is necessary for soap making. Soap is oil that has been “Saponified.” Saponification, by definition, is the reaction of lye with fatty acids to produce the salts of the fatty acids (”soap”). Without lye, saponification doesn’t happen. Therefore, no lye, means no soap. Now, there are many products out there that can be used for cleaning that are not really soap, and were not made with lye. These products are most likely detergents- synthetic cleansers often made with petroleum products, and harsh cleaning agents. They lack natural glycerin, and must have moisturizers added in to make them more gentle for skin. You may find soapcrafters who claim to “make soap” without using lye. These folks don’t make soap from scratch, but instead rely on premade bases that they melt down and mold. This is called the “Melt and Pour” technique. Be assured, though, that the manufacturer of their base used lye, or the base is a synthetic detergent. All real soap is made with lye.

Castile Soap is Soap that Contains a Large Percentage of Olive Oil

3. The term “Castile Soap” was once used exclusively to describe soaps made only with lye and olive oil. However, modern usage of the word refers to pure olive oil soap, as well as soaps with a high proportion of olive oil in their formula.

Soap Making is Simple and Affordable

2. Making soap is actually quite simple and affordable. The process of making soap involves measuring, mixing, and pouring. Online “soap calculators” are available that can help to create recipes and ensure the correct amounts of ingredients are specified. The difficulty some people experience in making soap lies in the precision that is necessary in weighing ingredients and stirring to the correct consistency, in the formulating (it can be tricky to come up with a nice formula that makes a soap with the qualities you want), and also in the precaution that must be taken when handling corrosive lye and lye solutions. Depending on a person’s comfort level with laboratory or kitchen methods, and on their dedication to studying their craft, the technique of making soap can be mastered. I always advise that people read, read, and read some more before attempting their first batch. As far as expense, soap can be made with grocery store ingredients such as lard, Crisco, olive oil, castor oil (from the pharmacy area), and other oils found in the baking aisle of most food stores. Lye (usually sodium hydroxide) can be bought on line, and also in some hardware stores. It is important to use 100% PURE sodium hydroxide, with no other chemicals in it. The equipment needed to make a simple batch of soap can be as basic as a couple of pyrex bowls, a scale, a stainless steel spoon, a microwave, and a shoebox for a mold. Obviously, more serious endeavors into soapmaking will require more elaborate equipment, but it need not even be expensive equipment.

Soap Made With Natural Ingredients Should Be Called “Natural”

1. We believe soap made with only natural ingredients deserves to be called “natural.” While soap is not naturally occurring, (with the exception of perhaps soap-like compounds found in several species of the genus Saponaria), the reaction between lye and fatty acids happens naturally. There is no catalyst needed, other than the simple act of adding one ingredient to the other. The reaction proceeds on it’s own. If natural oils (olive, coconut, palm, etc) are used, along with naturally occurring essential oils (lavender, sandalwood), or other additives (oatmeal, dried herbs), there is no reason to not feel comfortable calling the resulting soap “natural.”

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Palm oil is used in soapmaking because it has a great ability to make hard bars of soap. One of the most common complaints of vegetable-oil based natural soap is that it tends to disappear quickly. The high glycerin content contributes to this, but so does the choice of oils a soapcrafter uses in their base formula. Other oils and fats can be used to create hardness, such as coconut oil, lard or tallow. Unfortunately, coconut oil, used in higher amounts, can be harsh and stripping, leaving skin dry and rough. Lard and tallow, being animals products, are contrary to many “natural soap” users’ ethics. While I have made palm-free soaps, I prefer the formulas with palm.
When I first began hearing about the controversy concerning palm oil, I was a bit alarmed. I certainly didn’t want to lose business because of an ingredient I was using. I didn’t want to offend my customers by making bad decisions about the oils I had chosen. But, rather than eliminating palm from my soaps, I chose instead to research the issue, and make an educated decision based on my findings.
What I have learned is very interesting. Palm oil accounts for over 47 million tons of the world’s 144 million ton vegetable oil production. It is grown in 17 countries, and for 20% of it’s growers, it is their only source of income. The palm-oil tree itself, is actually a very environmentally-friendly plant. Growing to incredible heights, the fruit of the palm tree can be used to create everything from biofuel to cosmetics to food. Palm oil plantations require far less use of pesticides and fertilizers than soy plantations do. And, palm plants produce more edible oil per acre than any other vegetable oil source. This is good news for a growing global population. Palm also allows many countries that grow it to become players in the global economy. Small tribal villages rely on palm oil to sustain their families and provide financial resources that contribute to the building of schools, and creation of clean drinking water.
Unfortunately, the global demand for palm oil is huge, and growing. This has led many countries to destroy rainforests to make room for more palm plantations. This in turn, destroys the biologically-diverse rainforest, and the species that depend on it, including orangutans. When rainforests are cleared to make way for plantations, carbon from the rich peat bogs on the rainforest floor is released into the atmosphere. For these reasons, many people are choosing to boycott palm oil, and any products containing it.
But this is not an answer to the problem. Because of palm’s prevalence in so many products, and because the global demand is so high, little effect will be made by boycotting. The boycott would have to be tremendously large in scale to make a difference. Further, any reduction in palm oil use, would simply shift demand to another oil, and because of palm’s incredible versatility and economy, there really is not a better alternative.
Therefore, the solution lies in responsibly growing and using palm. Many of us in the soapmaking arena have signed petitions to use “Sustainable Palm.” By obtaining our palm from suppliers who can provide us with documentation that their palm is grown and produced in an environmentally responsible, sustainable way, we are doing our part to ensure that the palm we use is not contributing to rainforest destruction, orangutan obliteration and unnecessary carbon emissions.
I applaud and support the efforts of both GreenPalm.org and The Roundtable on Sustainable Palm (RSPO.org). I will continue to seek out sustainable palm oil, and use it to make my soaps. In doing so, I know that I am providing you with incredible handcrafted soap, and also helping to support people and communities that depend on palm production for their livelihoods.

*Thank you to GreenPalm.org for the palm oil statistics quoted in my article.

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Natural Cucumber Soap

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Some talking points to consider:

1.  The Campaign For Safe Cosmetics, which claims to represent many of us in the cosmetic industry, sponsored the making and release of a cartoon YouTube video last week called The Story of Cosmetics, using skulls and crossbones and other scare tactics aimed at alarming the public. They were quite effective in  convincing many people that studies by Skin Deep and the EWG (Environmental Working Group) are scientific fact. Their studies are hardly the whole truth, though. Consider this article by Robert Tisserand, titled Tunnel Vision, that they don’t want to hear anything about.  These huge lobbying groups will of course not admit that the video they released is equivalent to yelling “FIRE!” in a crowded room when there is none.

2. Ingredient lists will be required to disclose each and every detectable trace chemical in a product. This does not mean that just the ingredients will be listed. It means that every single solitary molecule of anything that can be detected will be required to be put in the ingredient listing. Not only will this require those annoying “fold out” style product info lists because of the ludicrous number of trace chemicals, but it will overwhelm consumers with information they may not understand or find to be useful.

3. Because of the ingredient listing requirement, expensive testing will be necessary to determine each detectable trace chemical. Knowing which molecules exist in the parts-per-billion range is really not at all necessary. Many of the foods we eat, including  water, contain trace amounts of ingredients that are absolutely harmless, but which could needlessly scare consumers if mentioned. For example, arsenic in water. On June 29, 2010, our family used a water fountain in the visitor center at Mt. Rushmore that was found to have higher than normal amounts of arsenic in it’s supply.  The fountain was operating, but a sign was posted above it, stating the arsenic level, and that it was safe to drink. It is scary to think that a business could go under simply because a trace chemical that has always been there, now has to be reported, and will scare the consumer. Most natural ingredients contain elements which are toxic in large amounts.

4. The Campaign for Safe Cosmetics says we shouldn’t be worried about the cost of testing, because the large companies will pay to test their products and simply pass the results of those tests down to us little guys. I find that rather unlikely. Will our products be similar enough to use the results they file with the FDA? Will  these reports be written in lay-person terms? Would they be useful to us? Data is useless when it it can’t be understood. And, why would large companies, paying millions of dollars to have their products tested share those results FOR FREE with us?

5. I take the most issue with the reporting and registration requirements. My gross sales. Number of employees. Names and addresses of my suppliers. I constantly change suppliers, searching for better quality and better pricing. But, I also change suppliers from time to time because of out-of-stocks or their decision to discontinue a product I use often. The attention I will need to devote to reporting these changes to the FDA, essentially amounts to “busy work” and  does nothing to help me devote attention to making safe products.

5. As far as fees go, many small businesses are dismissing this part of the bill because there is an exemption for businesses making under $1 million a year.  Capitol Hill wants us to believe that this is a “Small Business-Friendly” bill that is somehow “Fair” because it only requires that fees be paid by those most able to afford them. I don’t agree with that. I don’t believe in taxing only the rich. Furthermore, we have yet to learn how much the fees will be. How much money will the government need to pay new FDA workers hired to file registrations, suppliers names and addresses, and updates? Until that is determined, the fees will remain undetermined. And, although small business will not be required to pay the fee directly, we can be assured we will pay in the long run. Large companies will trickle those costs down to our suppliers, and then down to us, and then down to the consumers, leaving them with less money to buy our already-safe products.

6. The bill includes a Savings Clause, which is pretty typical of federal legislation. It allows any state, or “tribe” (city, etc),  to enact legislation that is more specific or severe than the federal law. Currently, I can ship my product to any of the 50 states. But, if other states enact their own legislation, I may not be able to market the same product to Michigan as I do to Texas, for example. I would have to be sure that my product doesn’t violate another state’s cosmetic laws.

Although well-intentioned, HR 5786 really does little to ensure safe cosmetics.  Aggressive lobbying groups are using it for political gain, pitting the “Green” movement against corporate America. They are turning this into a Capitolist vs. Consumer Safety issue.  They tell indie businesses not to get our panties in knots about it, because the bill will definitely need to be “tweaked” before passing, and that we’ll reach a reasonable compromise. But look at all the time that us small business owners need to devote to this to ensure that happens. We are forced to stop making products, and instead focus on attempting to have our voices heard. I started following the Campaign For Safe Cosmetics several months ago because I thought they represented my best interests. It is abundantly clear that they do not. Their video with skulls and crossbones does everything to scare consumers into thinking even all-natural products aren’t safe. I even saw a blog that said “just because it’s natural doesn’t mean it’s good. Poison ivy is natural.” Please.

Our small businesses represent what’s good about America. We represent entrepreneurial spirit, and a desire to provide for our families. A desire to share good things with the good people of our country. I would venture to state that almost all indie cosmetic businesses are owned by women. We want to take care of our children, yet also provide financially for our families. We are being led to believe we are not important in this economy. We aren’t sitting around wiating for the government to bail us out. We are trying to survive in this economy by making products that meet the needs of our customers, are safe, inexpensive and useful. If the supporters of HR 5786 have the intention of requiring ALL cosmetic companies to formulate safe products, maybe they should consider spending less attention on the ones who already are, and instead, devoting more attention to those who aren’t.

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Attention Government: These are made with ALL NATURAL oils and essential oils. OLIVE. COCONUT. PALM. CASTOR. Nothing hazardous here, thank you very much!!

You don’t need to regulate them. I don’t need to add any hazardous material disclaimer to their labels.  Because THEY ARE SAFE!

Olive Oil Soap scented with Frankincense and Myrrh

Olive Oil Soap Purification Bar

And, for anyone wondering why I would want the government to know this is an all natural, SAFE product, check out my blog articles about current legislation being considered that would effectively put soapcrafters like me out of business. And, if you’d like, please sign the petition to oppose this horrid bill, HERE. Our nation needs Safe Cosmetics. Companies like ours are already providing them.

Thank you for your support!

Erin

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And, I got the best birthday present ever. My blog was picked up by http://opencongress.org, and was listed right on the homepage of HR 5786.  I’ve been busy with the comments on it all morning. People are lining up in opposition of the bill. They recognize that although the intention of reforming our current cosmetic ingredients is a good one, a noble one, a necessary one… this bill, HR 5786 is not the answer.Not even a propaganda-rich, cutesy and entertaining YouTube video sponsored by The Campaign for Safe Cosmetics can hide the ineffectiveness of  this bill from savvy soapcrafters and cosmetic users like us!

While I appreciate the intent of HR 5786, the regulations suggested are far too overreaching. The FDA has a hard time enforcing the regulations that DO exist. How will they handle the influx of duties this new law could create? Natural products, especially innovative ones being developed by “Green” companies require constant experimentation. This bill would require changes to be documented and reported each time they are made. It will require documents to be filed each time a home-based natural soap crafter changes suppliers to get better pricing on raw ingredients. This will cause small businesses to close, at a time when our nation’s people desperately need work. Reform is needed, but in order for this bill to be useful, it needs to be re-written to not penalize Green Businesses who are already using safe, natural oils (olive, coconut) and other natural ingredients in their products. Lumping us into the same boat as the corporate, hazardous chemical using behemoths is not the answer.

It’s OK to oppose The Safe Cosmetic Act. It doesn’t mean we oppose Safe Cosmetics. We oppose this horrendously written, pathetically overreaching  attempt to reform the cosmetic industry. Rather than effecting any positive change, this bill shrinks entrepreneurial small business, while growing government.

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We all know there is a lot of “junk” in our personal care products. We know of the drying, harsh effects of detergents. We know that many commercially produced products have ingredients that are known to cause cancer and reproductive issues in animals when used in large amounts. It is a travesty that these ingredients are allowed to be put into products used by babies, children, and all of us other humans, too. The writers of this legislation obviously recognized the need for regulating what can be used in our nation’s cosmetics. Unfortunately, they missed the boat with this garbage bill they want to push through.

If HP 5786 is allowed to pass, it will effectively put an end to the cottage industry of natural soapcrafting. It will squelch our ability to be creative, to choose suppliers that offer the best quality and pricing on our raw materials, and will require us to file documents, registrations and updates about our revenues, employees, suppliers and proprietary recipes.

The complete bill can be read by clicking here:  HR5786

The text of the “Registration” section of the bill requires that all manufacturers of cosmetic products furnish:

“(B) a description of the establishment’s activities with respect to cosmetics;

(C) the number of workers employed at the establishment;

(D) the gross receipts of sales; and

(E) the name and address of any company that supplies the establishment, if the establishment manufactures cosmetics, with any ingredient (including preservatives, fragrances, or any other chemical component of a finished cosmetic product) and the name of the ingredient supplied to such establishment by such supplier.”

While this may not seem like a big deal, consider that many of us smaller soap making business (unlike Proctor and Gamble, for example), are creative types, who constantly come up with new scents, and formulas for their soaps. What does the bill say about making changes?

“(A) IN GENERAL- The registrant shall notify the Secretary in a timely manner of changes to the information described in paragraph (1).”

So, every time I use a new ingredient, or change suppliers,  I will have to forward new documents to the Secretary.

Additionally, there is a provision that states I must “notify the Secretary of any change in the products, function, or legal status…including cessation of business activities,  not later than 60 days after the date of such change.”

The companies who really should be targeted with legislation such as this are the huge commercial manufacturers who only care about profit. They are the ones using synthetically derived detergents in their body products. They are the ones who use labeling such as Clairol’s Herbal Essences that falsely leads consumers into thinking the product is actually GOOD for them…

Unfortunately, the text of this bill makes no distinction between small and large businesses as far as the registration policies are concerned. We certainly do need to reform the cosmetic industry. I just don’t think that lumping all natural cosmetic makers into the same boat as corporate, synthetic beauty product behemoths  is the way to go.

Please help us fight this poorly written legislation by signing this petition:

Sign Petition Opposing HR 5786

Reform is definitely needed, but this is not the reform we need.

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Coconut Chocolate Swirl Soap

As always, our soaps are made with all-natural ingredients! Why? Because we can! The range of colors and scents available in Mother Nature’s pantry is enough to spoil any dedicated soapcrafter!

Natural Cucumber Soap

And, because we like to experiment with ingredients, here’s a new bar that’s lots of fun! It’s colored with mica that is tinted with naturally-derived oxides.

Citrus Rainbow Swirl Soap

So there you have ‘em! To reserve a bar of any of these natural soaps, or to even give me a “thumbs up,” please visit our facebook company page and post a comment.

I’m going off to make more soap!

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