Oh spare me. The Environmental Working Group should know better than to focus on cosmetics using the “Cosmetic Safety Act of 2010”: "safety" concerns should be motivating a righteous noise about a comprehensive chemical policy in this country. They should be hammering on the Toxic Chemical Safety Act of 2010 (TCSA). That will solve most of the problem. Any parent knows you’ve got to choose your battles wisely. Let’s make TCSA well designed and implemented, then let’s see what is left to clean up with the cosmetic industry and other product sectors.
Energy is finite and, when it comes to politics, energy is expensive. If EWG:
- thought more comprehensively about safety
- if they really understood the cosmetic industry
- if they were honest that the same chemicals in cosmetics are in medicine, household goods, and food (wow!)
then they would recognize that it all leads back to the chemicals that are made and allowed to be used in this country. They would use their energy and money to regulate chemicals instead of one portion of the consumer products industry.
ALL consumer products should be safe. This proposed Cosmetic Safety Act is making one consumer product group responsible for a small part of the pollution and safety risk we all face. Folks - why make it hard for thousands of small businesses when the responsibility sits with the chemical industry in this country and those of us who have the voices to change it? Hello!! Cosmetics are blended chemicals. The cosmetic companies don't make the chemicals, chemical companies do. How do we push them to make safer chemicals?
I advocate that we delay this poorly written Act that will hurt small cosmetic companies and not really make cosmetics any safer and focus on the real issue: comprehensive chemical reform.
(Oh - and if you watch the video that they made, you might want to note that when the narrator reels off her chemical body burden, most of the chemicals are products from food or household furniture, not from cosmetics).
Saturday, July 24, 2010
Thursday, July 1, 2010
Whole Foods may want to re-think the timeline and method of their mandated organic certification policy for personal care products. The concept is great, appropriate, and what we all need to do. Cheers to Whole foods for finally recognizing that they have an important role in guiding the industry. However, the time frame and choice of certifiers needs work.
Part One – Changing products loses customers.
One of the points has been that there is “chaos” in the market place. I think the chaos of not knowing what “organic” means for personal care products, pales in comparison to the chaos created when brands change their packaging, formula or any other detail. If the brand loses customers, so does Whole Foods, so does the organic community and so does the organic farmer. Any seasoned brand manager will tell you that when you change something about a product, you lose customers. If a large percentage of WF brands are changed all at the same time, both the brands and WF will lose customers. How does that help expand the use of organic ingredients? I want to see more organic content in everything, not less and I know this strategy, in the short term, reduces the use of organic ingredients and adds confusion. (I know this because numerous companies have stopped buying organic ingredients since the advent of the lawsuits and now they are telling me that to comply with WF they need to become “natural” and will stop buying other organic ingredients.)
Part 2 – Most Cosmetics ARE Synthetic! USDA-NOP Organic Should not be.
Another comment from WF has been that their customers don’t expect a big difference in the meaning of “organic” between personal care and food. This is a serious flaw: there IS a big difference. Bread and pasta sauce (organic foods) do not require CAS numbers because they are not synthesized chemicals (and under the jurisdiction of the EPA). Organic = food and Cosmetics = chemicals. To pretend that consumers won’t notice that there are “organic” chemicals listed on products seems a bit more than naïve to me. Someone will ask, ”Since chemicals are synthetic, how can you have a “certified organic” chemical?” Really, how can you? Certified organic mono and di glycerides?? Outrageous, but they exist.
Part 3 Where Is That Word “Sustainable” in the Relationships?
If indeed Whole Foods supports the sustainable principles inherent in organic agricultural production, they need to apply those same principles to cosmetics. Cosmetics are made from chemicals. The chemical industry will not be motivated to use organic raw materials unless it can identify and quantify the demand for raw materials made using those inputs. They can’t do that for a few years and need cooperative planning. Telling people to get certified to a food law in a 12 month period will not promote the creation of the necessary chemicals to make “organic” personal care. For one thing, it will take the NOSB 5 years just to get to a place where they can review all of the new materials and processes needed to make these organic chemicals. The USDA-NOP program doesn’t even have an agreed upon definition for “synthetic” – how can you make “organic” chemicals unless you know what the word “synthetic” means under that law? That will take another 18 months to resolve. Can’t the timeline change a bit?
Part 4 – What Should We be Doing?
We have an amazing opportunity to take the concept of “organic”, a single measurement of one type of sustainable agricultural product, and extend it to the production of cosmetics, a large international market and make a truly sustainable model for consumer good production. We can take all the good raw materials created on the agricultural side and ethically mandate chemical production methods that use those organic raw materials using only sound environmental production methods. We can teach people that there is, indeed, better living through chemistry, but only if we are honest that there is chemistry.
This is a complex picture. Using a thoughtful and strategic path that incorporates stakeholders and cooperation instead of lawsuits and threats will benefit the planet instead of hurting some and confusing many more. It is time for our corporate behavior to be as sustainable as the organic farms we support.
The Joke:
Here is the joke I use for WF as a parable:
John went on vacation. He asked his brother to take care of his adored cat. About day 3 of the vacation, the brother calls John and says, “Your cat died.” John gets upset with his brother and says, “First you should have told me that the cat was on the roof, then called in a few hours to say that the Fire Dept. was there. Then called a couple hours later to tell me that the cat was not doing well and was at the Vet’s. Then a few hours later you should have told me that the cat was dead.” John’s brother felt really bad.
The next year John went on vacation. About 3 days in, his brother called him and said, “John, Mom is on the roof.”
The reason I use this “parable” is that WF really should have started this in 2003 when we implemented the Calif. Organic Products Act of 2003. They could have actually required compliance with the LAW, and that would have been the mental equivalent of the cat on the roof. While I am glad they agree that cosmetics need to be certified, the way they are going about it seems almost punitive. I don’t think that is the way you treat the vendors who have supported your growth for the entire history of you business. Can’t you add a couple of years and a few certifiers?
Hey, Whole Foods! Organic is on the roof! You will end up with more “natural” than organic on your shelves, you will lose customers and you could achieve the same goal (certification) using slightly different parameters. Come on – we can do this . . . together!
Part One – Changing products loses customers.
One of the points has been that there is “chaos” in the market place. I think the chaos of not knowing what “organic” means for personal care products, pales in comparison to the chaos created when brands change their packaging, formula or any other detail. If the brand loses customers, so does Whole Foods, so does the organic community and so does the organic farmer. Any seasoned brand manager will tell you that when you change something about a product, you lose customers. If a large percentage of WF brands are changed all at the same time, both the brands and WF will lose customers. How does that help expand the use of organic ingredients? I want to see more organic content in everything, not less and I know this strategy, in the short term, reduces the use of organic ingredients and adds confusion. (I know this because numerous companies have stopped buying organic ingredients since the advent of the lawsuits and now they are telling me that to comply with WF they need to become “natural” and will stop buying other organic ingredients.)
Part 2 – Most Cosmetics ARE Synthetic! USDA-NOP Organic Should not be.
Another comment from WF has been that their customers don’t expect a big difference in the meaning of “organic” between personal care and food. This is a serious flaw: there IS a big difference. Bread and pasta sauce (organic foods) do not require CAS numbers because they are not synthesized chemicals (and under the jurisdiction of the EPA). Organic = food and Cosmetics = chemicals. To pretend that consumers won’t notice that there are “organic” chemicals listed on products seems a bit more than naïve to me. Someone will ask, ”Since chemicals are synthetic, how can you have a “certified organic” chemical?” Really, how can you? Certified organic mono and di glycerides?? Outrageous, but they exist.
Part 3 Where Is That Word “Sustainable” in the Relationships?
If indeed Whole Foods supports the sustainable principles inherent in organic agricultural production, they need to apply those same principles to cosmetics. Cosmetics are made from chemicals. The chemical industry will not be motivated to use organic raw materials unless it can identify and quantify the demand for raw materials made using those inputs. They can’t do that for a few years and need cooperative planning. Telling people to get certified to a food law in a 12 month period will not promote the creation of the necessary chemicals to make “organic” personal care. For one thing, it will take the NOSB 5 years just to get to a place where they can review all of the new materials and processes needed to make these organic chemicals. The USDA-NOP program doesn’t even have an agreed upon definition for “synthetic” – how can you make “organic” chemicals unless you know what the word “synthetic” means under that law? That will take another 18 months to resolve. Can’t the timeline change a bit?
Part 4 – What Should We be Doing?
We have an amazing opportunity to take the concept of “organic”, a single measurement of one type of sustainable agricultural product, and extend it to the production of cosmetics, a large international market and make a truly sustainable model for consumer good production. We can take all the good raw materials created on the agricultural side and ethically mandate chemical production methods that use those organic raw materials using only sound environmental production methods. We can teach people that there is, indeed, better living through chemistry, but only if we are honest that there is chemistry.
This is a complex picture. Using a thoughtful and strategic path that incorporates stakeholders and cooperation instead of lawsuits and threats will benefit the planet instead of hurting some and confusing many more. It is time for our corporate behavior to be as sustainable as the organic farms we support.
The Joke:
Here is the joke I use for WF as a parable:
John went on vacation. He asked his brother to take care of his adored cat. About day 3 of the vacation, the brother calls John and says, “Your cat died.” John gets upset with his brother and says, “First you should have told me that the cat was on the roof, then called in a few hours to say that the Fire Dept. was there. Then called a couple hours later to tell me that the cat was not doing well and was at the Vet’s. Then a few hours later you should have told me that the cat was dead.” John’s brother felt really bad.
The next year John went on vacation. About 3 days in, his brother called him and said, “John, Mom is on the roof.”
The reason I use this “parable” is that WF really should have started this in 2003 when we implemented the Calif. Organic Products Act of 2003. They could have actually required compliance with the LAW, and that would have been the mental equivalent of the cat on the roof. While I am glad they agree that cosmetics need to be certified, the way they are going about it seems almost punitive. I don’t think that is the way you treat the vendors who have supported your growth for the entire history of you business. Can’t you add a couple of years and a few certifiers?
Hey, Whole Foods! Organic is on the roof! You will end up with more “natural” than organic on your shelves, you will lose customers and you could achieve the same goal (certification) using slightly different parameters. Come on – we can do this . . . together!
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