What a difference a shave makes…at least to regulators and business competitors. A few months ago, Energizer Personal Care commissioned an independent, double-blind Skicon instrument study consisting of 30 panelists ages 18-55 to determine whether Hydro Silk hydrates the skin. On the test day, the pre-screened participants were placed in a controlled environment.
Measurements were taken at baseline and after shaving and air-drying. The results showed that the intact Hydro Silk razor moisturized legs at all timepoints at a 95% confidence level, compared to the Hydro Silk razor without the moisturizing serum.
The results settled a dispute between the National Advertising Division (NAD) of the Council of Better Business Bureaus over whether or not Energizer Personal Care could support claims about its Schick Hydro Silk razors. The challenge was raised by The Gillette Company, which questioned performance claims made by Energizer in assorted media and packaging.
NAD determined that the advertiser’s test provided a reasonable basis for the challenged expressed and implied claims and found that the challenger’s scientific evidence was not sufficient to rebut the advertiser’s evidence. Energizer, in an advertiser’s statement, said it “will take NAD’s recommendations into account in future advertising. Energizer appreciates the opportunity to participate in the self-regulatory process and commends NAD for its efforts and commitment to a careful review of the evidence.”
The case of Energizer is one of many which proves that testing service providers are crucial to successfully marketing a product in the household and personal care industry.
“Testing laboratories should enjoy an open and collaborative relationship with their clients,” noted Craig Weiss, president, Consumer Product Testing Co., Inc. (CPTC), Fairfield, NJ. “A testing laboratory should maintain a strong quality system, and comply with the regulatory requirements for the types of services they offer. The ultimate goal is to have ethical testing performed which meets the client’s needs in a timely manner.”
Testing in the industry is not always related to the product development phase, noted Matt Hubert, manager, product development and testing, Chemir – EAG, Maryland Heights, MO. He told Happi, “Customers tend to focus on the front end tests needed to launch a stable and subsequently successful product that meets certain claims. Lack of knowledge tends to appear when it regards products that fail when introduced in the marketplace.”
For example, testing is needed if an established product is off-odor or off-color or if the formulation is unstable.
“Analytical testing is a useful tool in determining possible causes of such failures,” he said.
Weiss of CPTC noted that one of the main challenges his clients have is when they decide to take a product to a different marketplace with different regulatory entrance requirements.
“Additional challenges are met when importing products from abroad and domestically, (especially) with the move by many states to regulate cosmetics on a state-by-state basis,” he explained.
Preventing skin irritation is still a top concern for both marketers and consumers, which is creating demand for InVitro International’s Irritection Assay System, according to the company’s president and CEO W. Richard Ulmer.
This standardized, quantitative in vitro test method can be employed to detect, rank, and predict the ocular and/or dermal irritation potential of cosmetics, consumer products, pharmaceuticals and even chemical raw materials. This advanced technology enhances and replaces the company’s earlier Eytex and Skintex products. InVitro International, which is expanding its R&D capabilities, is currently shopping for a new space for 2014.
Analysis of heavy metals continues to be at the forefront of formulators’ concerns as well, according to Bradford Rope, president, BioScreen Testing, Torrance, CA. In addition, trace level analysis for prohibited compounds such as formaldehyde, parabens, diethanolamine and phthalates continues to drive the business. As a result, BioScreen has increased its laboratory space as well as equipment to service the industry.
“Our chemistry laboratory has a new state of the art Agilent ICP-MS for testing heavy metals, Waters UPLC for faster through-put of sunscreen analysis and automated sample digestion system for titanium dioxide and zinc oxide and a new photostability chamber,” Rope told Happi.
There is a growing demand among finished product marketers and raw material suppliers for high through-put screening, according to Mafalda Salvi, business development manager, SGS – Consumer Testing Services, Fairfield, NJ.
“This has created a demand for innovation of laboratory equipment through the use of robotics to our testing capabilities for automatic and hand dish and continuous cycle for fabric detergents that replicate human activity,” explained Salvi. ”SGS’ detergents labs are constantly driving innovations to the benefit of our clients.”
This season, AMA Laboratories, which specializes in SPF determination and RIPT (Repeat Insult Patch Test) evaluation for both finished products and raw materials, has enjoyed an increase in business across the board, observed Howard Kaminsky, director of marketing, AMA Laboratories, New City, NY.
“This general trend is due to the worldwide growth of the industry and the increasing need for fast, reliable testing at highly competitive pricing. Unquestionably, the main concern of our customers is production deadlines, so rapid turn-over time is imperative,” he told Happi, adding that his company continues to monitor world changes in testing requirements.
Rules and Regulations
On the regulatory front, US and global requirements are shaping the testing sector, especially by way of natural personal care. According to Amy McDade, senior certification project manager, NSF International, Ann Arbor, MI, her company has requests increase to prove compliance with ISO and European directives.
“As manufacturers look to expand globally, they may have products that currently meet US requirements but they need to know if the same approach meets requirements for Europe,” she told Happi.
As of July 2013, there are mandated GMP requirements in the EU (ISO 22716). But in the US, H.R. 1385 would require GMPs for Cosmetics, in addition to other requirements such as facility registration with FDA, established safety standards and labeling requirements, review of safety of cosmetics marketed in interstate commerce, serious adverse event reporting, and gives the FDA authority to order a recall along with others.
“What we are seeing now is greater overlap in requirements for testing, validation and certification services as consumers ask more questions and demand more information regarding the safety and origin of ingredients for personal care products,” noted McDade.
“Here in the US, the FDA is showing more involvement in cosmetic regulations, particularly as to what claims a product can make and have demonstrated this by issuing warnings to several companies,” added Hubert of Chemir. “Globally, the EU has completed its initiative against animal testing. We can see US customers leaning more toward this aspect as well to complement the desire for eco-friendly, natural and organic products.”
Weiss of CPTC agreed. He told Happi, “In the US, there is a push backed by the government and NGOs to create a regulatory framework for the personal care industry as seen in the past year with three different cosmetic safety bills and one bill reintroduced this year.”
Weiss added that in the EU, the recast of the cosmetic directive should allow for easier entrance into this important international marketplace.
“More companies are selling their products globally, and not just domestically, which requires a full understanding of the entrance requirements by marketplace,” he said.
Waves of the Future
As the household and personal care industry continues to expand, so will the need for testing service providers, according to industry insiders. For example, in the past year, Chemir has seen an increase in ethnic hair and skin care testing.
Hubert said that ultimately, the testing service sector is fielding more requests for analysis of products to ensure competitors are using “what they say they use regarding ingredients, likely driven by companies desiring to ensure that they are not unfairly taking market share by inappropriately substituting ingredients.”
According to Ulmer of InVitro International, “More and more elements of commercial business will look at cost and timing of production with regulatory agencies making an emphasis on what everyone does. Our industry looks to the pharmaceutical business on how many days it takes to get a product into the market—and how much time is lost getting it there—so testing services will be more and more attractive.”
Testing the Waters
Household and personal care companies count on testing providers to bridge the gap between supplier, marketer and consumer.
By Melissa Meisel , Associate Editor
Published September 27, 2013
blog comments powered by Disqus