Soap Makers and Soap Lovers
Safe cosmetics Act 2011
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Bringing this back up...
In a nutshell:
Small businesses are NOT exempt from all of the bill's regulations, just the registration and fees part... and that exemption leaves small businesses open to criticism for not registering. Imagine what the big corporations will say about small-biz, unregistered soapers & cosmetic makers... unregistered = unsafe.
Highlights from Kayla of Essential U's post:
* Small businesses, and big, could never comply with the “reasonable certainty of no harm” section of the bill that requires omniscient-like knowledge of consumers environment and buying habits to account for “additive effects” and “cumulative exposures” of every potential customer of their cosmetics.
* Small businesses that are not registered will not receive up to date information regarding changes in regulations, ingredient safety and will suffer due to the fact that they are segregated out of the communication loop between the FDA and cosmetic companies.
* Because of testing, the costs of raw materials will increase for everyone.
* All businesses will be required to disclose their supply sources to the government rather than simply INCI names or CAS # of an ingredient.
* All finished cosmetics, whether from a big or small business, will require pre-market testing in order to comply with the parts per billion contaminant ingredient listing and MSDS creation.
* The simple fact of requiring a MSDS for all finished cosmetics treats them as if cosmetics are hazardous materials.
* Many small businesses specialize in natural and organic cosmetic products. There is no exemption for botanicals and no guarantee that they will be among the first 300 ingredients given listing and approval in the first year.
* The requirement for all suppliers and manufacturers to submit safety data and information for their ingredient will virtually end the supply of fair trade and small farm natural botanicals.
* The bill requires that the Secretary send “notification of failure” to “each known customer” if the Secretary fails to act in time to a cosmetic or ingredient. This would require small businesses to track their customers, even if they sell at a craft or farmers market.
* Many times throughout the bill there are requirements for tests to be repeated even if the ingredient was tested already by another source. Even if the supplier of an ingredient has complied the manufacturer of the cosmetic must repeat the process for the finished good in the retail packaging.
* The 24 hours given to respond and appeal a “cease distribution” will require small businesses to have 24 hour legal representation on hand.
* All small businesses who think they got a pass with the registration and registration fee need to be well aware that your products will not be exempt from this random testing.
See Kayla's post in its entirety here:
Posted at 7:18am Jul 18, 2011 EDT