November 16, 2021 • 34 mins
The FDA stands for The Food and Drug Administration, but they are also key in regulating the cosmetic industry. In 1938, The Federal Food, Drug, and Cosmetic Act gave the FDA the responsibility for regulating cosmetics and protecting customers.
To explore how cosmetics are regulated, Charmain Rodriques, Regulatory Affairs Manager at LVMH joins us to explore how the FDA, FTC, and even customers shape the cosmetic industry. Hope you enjoy!
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Episode Transcript
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Aaron Harmon (00:00):
The following is an excerpt from Ruth lambs book
(00:02):
called The American chamber ofhorrors written in 1936. Your
government has not the legalright under the present Food and
Drugs Act to protect you againstdangerous cosmetics. The law
does not apply to toiletpreparations, and those which
are harmful, not be taken offthe market no matter what pain
and disfigurement they inflict.
tragedies from the use of suchproducts are by no means of
uncommon occurrence. On themorning of May 17 1933, a
(00:25):
charming lady whom we shall knowis Mrs. Brown, drove downtown to
have her picture taken. She'dworked hard all winter as
secretary of the local ParentTeachers Association, and as a
chairman of the EntertainmentCommittee. That evening, her
associates were giving herbanquet in her honor. They had
asked for a picture of her toput in the state PTA magazine,
(00:45):
so she was having a made an hourlater, she stopped a birds
beauty shop to get shampoo andhaircut. But since this was to
be a special occasion, and shenaturally wanted to look her
best, she let herself bepersuaded to have her brows and
lashes touched up.
Hi, I'm Aaron Harmon, and thisis inside out quality, a podcast
about real life events andexperiences shared by our guests
(01:08):
of when things have gone wrong,and how we can learn from them
to build better products,companies and improve lives
through an effective qualitysystem.
The year before the elixirsulfanilamide disaster, two
years before the first Food Drugand Cosmetic deck. Ruth was the
chief educational officer forthe FDA. Her book was written to
(01:30):
warn customers of the potentialdangers of marketed products at
that time. Here's that excerpt.
Ruth was describing whathappened to Hazel Fay, who ended
up being permanently blindedfrom a cosmetic name Lafleur.
The beauty industry continues toflourish in 2021. With social
influencers, cosmetic brands andeven drugstore sellers offering
millions of ways to alter one'sappearance. People regularly
(01:51):
pick up a tube of mascara attheir local store without
questioning. Will this make mego blind? Am I going to have a
life threatening reaction? Wedon't ask these questions thanks
for the work of agencies likethe FDA. In a world before the
1938 Food, Drug and CosmeticAct, products like lash there
could be sold and marketedwithout any oversight. The
company marketed this product asan eyelash and eyebrow dye,
(02:12):
which boasted permanence and thecoveted dark color fashion at
that time. What it didn't sharewas that it was all banks to
paratha aniline dynamin fromaniline, a coal tar component
and known allergen, according tothe American Academy of
Ophthalmology. In 1933. severalcases of severe reactions to the
die were reported, includingblindness blisters, and in one
(02:33):
case even deaths from theinfection. The incidents were
highly publicized, including anFDA exhibit in the 1933 Chicago
World's Fair, as they inproponents petitioned for the
revision of the 1906 Food andDrugs Act. After a few years of
industry resistance, the FoodDrug and Cosmetic Act finally
emerged as the first federalregulation of cosmetics. It
provided a list of safe approvedingredients and gave the
(02:56):
government power to pull harmfulproducts from the shelves. And
what was the first product thatthe FDA withdrew from the
market. It was Lafleur the Foodand Drug cosmetics Act has spent
the last 80 years holdingcosmetic producers accountable
for bringing safer beautyproducts to consumers. Now it's
time to learn more and aprevious intermission, I
introduced Jenny elstead, one ofthe interns with Inside Out
(03:17):
quality. In this episode. Shejoins me as a co host and help
us with that is CharmaineRodriquez. She is the Regulatory
Affairs Manager for perfumes,Christian Dior, welcome to
Inside Out quality Charmaine.
Charmaine Rodriques (03:30):
Thank you, Aaron. I'm really excited to be
here. Thank you for inviting me.
Aaron Harmon (03:35):
I am glad I got to speak to you and convince you to
be on the show with us. Prettyexcited as well. So first, how
did your career path bring youthe role that you're in now with
Christian Dior?
Charmaine Rodriques (03:46):
I'm gonna say Aaron that the past my
current role is regulatorymanager for advertising
compliance has been one that hasbeen fairly progressive, I would
say it wasn't a path that Ideliberately set out on. But I
now happily find myself in thisposition based upon my prior
experiences. One of my firstjobs was actually in the
(04:07):
cosmetic industry. I worked as alab tech for a company that
formulated lip liners andeyeliners. So I was involved in
the batch formulation then. Andin addition, I got, I was
introduced to color matching. Sothe company that I worked for
was a contract manufacturer, wewould match colors for clients.
(04:31):
So it was just, you know, one ofmy first introduction to the
beauty industry. But after thatI worked in the pharmaceutical
area as a QC chemist for anumber of years. And while I was
in that field, I started andfinished a graduate degree in
environmental studies. I thoughtmy intent was to have a career
in the environmental space. Andso after graduating, I took a
(04:55):
position at the GoodHousekeeping Research Institute
as a chemistIn their beauty lab, and the
that role involved chemistry andenvironmental studies, so or
environmental science, so it wasone that was, you know, really
perfect for me. And I workedthere for a number of years,
testing beauty products againstthe or efficacy as well as
(05:17):
evaluating product ingredientand label claims. I was able to
contribute to a number of blogsand worked with the editors,
their magazine articles onsafety issues in the beauty
industry. Good Housekeepingmagazine has a very rich history
of consumer safety and advocacy,and in fact, was one of the few
(05:37):
magazines or maybe the onlymagazine at that time that
reviewed advertising on itspages to ensure claims were
supported. My next role afterthat was research editor at NBC
Universal, there was responsiblefor reviewing clinical studies
and other support documents foradvertising that you see on TV.
I did that for about threeyears, then moved on to racket,
(06:00):
where I worked on the legal teamas an advertising claims review
manager. And there I worked on awide variety of brands,
including personal care, beautyOTC and dietary supplements. And
they're worked closely with theregulatory department, the r&d
as well as clinical to make surethat the claims from my brands
(06:22):
were validated. And now at Dior,I validate advertising claims
for several of the beauty brandsthere under the LVMH umbrella.
So that's pretty much my journeyin a nutshell. That's a fabulous
journey. I would never expectsomeone could have a farmer job
working for NBC. Exactly.
Aaron Harmon (06:46):
Some totally blew my mind. Oh, you said that.
Yeah. And just out of curiosity,you said you did efficacy
testing for some of the productsearly on? What does that look
like in the cosmetic space.
Charmaine Rodriques (06:58):
So in the cosmetic space, there are like a
whole bunch of tests that youcan do. So when you see a
product that says it hydratesthe skin and moisturizes the
scan, that's a really commonclaim in this space. And so we
would do corny geometry studies.
It involves capacitancemeasurements, where you apply a
product to the skin, and see howwell it hydrates the skin.
(07:19):
That's one test that we woulddo, we'd also to Cutometer. To
see if a product from the skin,we had another instrument called
the Vizio complexion analyzer.
Without we took photos ofpanelists in a control light
setting. And so we'd send themhome with products to use for,
(07:43):
you know, several weeks, andthen we would take after photos
to look at to see if theirwrinkles were less visible, that
type of thing if their darkspots were less visible or
minimized. So it's quite a lot.
And we did a lot of hair testingto where we actually tested on
here swatches. We did a conetest to see how well
(08:04):
conditioners performed. So it'sa whole variety of tests.
Aaron Harmon (08:11):
Amazing. Yeah. So Lash Lure caused skin irritation
caused ulcerations of thecornea. And the result of that
was women being blinded. So howdoes this prevented now in the
cosmetic product development?
Charmaine Rodriques (08:24):
So first of all, I just want to say that
story is one that's extremelysad and disheartening, and I'd
never heard of it before. I wasjust kind of like blown away.
And a story like this shouldnever be repeated in this Age of
Information and Technology. Andnow we have the FDA. When it
(08:45):
comes to product development.
Every cosmetic manufacturerselling in the US has a legal
requirement to make sure thattheir products are safe for
consumers under the Food, Drugand Cosmetic Act. The FDA
prohibits the marketing ofadulterated or misbranded
cosmetics. And what they will dois that they will enforce
actions against companies thatdo not comply. One thing is that
(09:07):
the FDA does not approvedcosmetics before they hit the
market. And neither do theyprescribe a set of testing
methods that manufacturers needto abide by. So it's really up
to the responsibility of thatmanufacturer to make sure that
they're producing a product thatis safe for consumers. The
(09:27):
manufacturers will do cosmeticsafety tests. They will assess
toxicology data for theiringredients and the products
that they sell. Because if theydon't comply the agency which is
the FDA will take enforcementactions against brands and you
really don't want the governmentto come down on you. And in
(09:50):
terms of safety protocols therelike a wide variety of
established methods that aformulator can use Now, big
companies will have teams ofscientists in their research
labs that are dedicated tosafety testing. Or another
option is to have like a thirdparty lab that will conduct your
(10:10):
safety tests. And many of theselabs are accredited to the FDA
will actually do inspections aswell here. And in the product
development phase, companieswill conduct tests like
stability, which you're going toassess. And with this test,
you're going to assess how yourproduct stands up over time. So
(10:33):
you look at the cosmetics andthe the integrity of the
product. Is it separating? Isthe color changing? Does it
smell bad, so you're gonna dothis stability test after
specific intervals, like a weekor two weeks or two months, you
know, however you set that up.
(10:53):
And then another test that aformulator can do is
microbiological evaluation, toensure that your product is not
contaminated, while it's on theshelf for when it's being
transported to the consumer. Andeven when they actually
evaluating it as to how aconsumer would use it. Because a
(11:16):
lot of folks will dip theirhands you know, the wet hands
into a cream. So you want tomake sure that microbes don't
grow in your product. So a lotof companies will test how the
product will uphold insituations like that. And in
fact, the PC PC which personalcare products Council just came
out with updated guidelines acouple of weeks ago, maybe not a
(11:39):
week ago, but a couple weeksago. And in addition to this
companies will also conductclinical trials, such as the
human repeat in South patchtest. And again, they can either
do this in house or via a thirdparty. And then with this test
evaluates a product's potentialto cause irritation on the skin
(11:59):
or sensitization. So all of thistesting will be done in the
product development phase priorto a cosmetic hitting the market
just to ensure that safety hasbeen established. And then I
mentioned earlier that the FDAconducts inspection of
manufacturing and researchfacilities just to make sure
that all these safety protocolsare in place during formulation
(12:22):
and production. And a coupleother things that I want to
mention is that the the FDA hasa list of prohibited and
restricted ingredients forcosmetics on the website. And
then they're really extensiverestrictions when it comes to
color additives like I make upfor eye makeup that are used,
(12:42):
used on the skin, especially forthe eyes. So formulators can
familiarize themselves withthese lists when developing new
products. And in addition to theFDA, the FDA works with the PCPC
to publish what's called thecosmetic ingredient review. And
this is really, really animportant and fabulous website
(13:05):
because it lists the safetyprofiles of cosmetic ingredients
that are based on scientific andindependent expert assessments.
So if you're a new manufacturerin the industry, and you want to
use a specific ingredient inyour new serum, or your new
moisturizer, you can go on thereand you can identify any
(13:27):
potential hazard for thatingredient. And again, these
findings are based on peerreviewed scientific literature.
And what the database will doit, we'll establish certain
limits for certain ingredients.
So you have this particularingredient, but you shouldn't
use it more than 2%. Or youknow, or even point oh 1% in
your formula. So you can look atthat and get your safety data
(13:50):
and your toxicology data. Andthen just across the border
Health Canada, where a lot ofAmerican brands do business,
they also have a very rigoroussystem and strict set of
guidelines. They have what theypublish the hot list. And you
can find that on the HealthCanada website. And it's just a
(14:10):
list of ingredients that haverestrictions for use in beauty
products. And this is constantlybeing updated as new information
comes out about ingredients andpossible allergic reactions. And
then a manufacturer orformulator can actually get some
data from the ingredientsuppliers themselves, they will
(14:32):
have they should have saved MSDSis and relevant safety data for
the ingredients that they'regoing to be selling to their
clients. And then in terms ofthe for consumers. If the
consumer experiences an adversereaction to a an ingredient in a
cosmetic, they can report thatto the FDA or they can reach out
(14:55):
to the manufacturer as well. Themore You know, you know, that's
what's going to help you. Sothey're pretty much three
pillars that really keep brandsaccountable and formulators
accountable. The regulator, theindustry experts in the
consumers. So I hope thatanswers your question. I know it
(15:17):
was kind of long winded. It's soyeah, hear that? Yeah. Now we'll
Aaron Harmon (15:23):
take a quick break to hear from one of our
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that SD bio.org. Now back to theshow.
Jeni Fjelstad (16:05):
I was just curious, like how does like
public view and popular demandslike maybe taking parabens out
or like vegan in organicformulations? How does that
affect that quality productionside of making cosmetic products
and making them safe?
Charmaine Rodriques (16:23):
Right, so let me first start with
parabens. I mean, parabens areused in cosmetics as
preservative. But I am not awareof any data that supports that a
periban free formula willperform better than one without
parabens. As I said, they'vebeen used as effective
(16:43):
preservatives for many years.
And in the last decade or sothere have been implications
around the safety of parabens.
And so many brands have chosennot to include parabens in their
formula because of theuncertainty. And you know, I can
understand that. So what getsaround about parabens so
consumers don't want parabens intheir products either. There is
(17:07):
nothing conclusive yet, the FDAdoes have a statement on on
parabens on their website. Andthey're still investigating the
health effects. But a formulawithout parabens, I don't think
the data is there that say, youknow, if you have the screen
with Paramount and one without,you know, the one without is
going to perform better. I knowthat parabens are very good in
(17:31):
terms of being an effectivepreservative system, I don't
know in terms of the actualefficacy of the product, if that
makes a difference with the nonperiban formulations. But
manufacturers are required tohave a formula formulations that
are safe and adequatelypreserved. I think like vegan
(17:52):
and organic and naturals aresome of the other terms that
consumers are looking for. Forthose formulas that are vegan,
organic or natural. I think thathas more to do with ethics and
sustainability rather thanquality. These claims are based
more on a brand's ethicalvalues, then I would say
establish product efficacy. Idon't know of any research that
(18:16):
says a vegan versus you know, avegan formula is better than a
non vegan one, it's more or lessjust what consumers want now, or
where the ethics with the animaltesting, and all that how a
brand wants to present itself.
When
Aaron Harmon (18:31):
you described all the stuff you guys work through
to make sure that a product issafe before it goes out the
door. That works. Like blew meaway the amount of detail like
what you're describing is whatwe do in the pharmaceutical
industry. Right? And that's toother people. Are they surprised
when they hear how much goesinto into making sure these
products are safe? Yeah,
Charmaine Rodriques (18:49):
a lot of people are very surprised.
Because then you think about acosmetic. And it's like fun and
exciting. But your skin is thelargest organ. So you know you
have to take care of it and ithas whatever you put on your
skin has to be safe. So eventhough the industries itself is
fun and exciting, but it isserious, because medics can do
(19:12):
harm from the story that youmentioned earlier. So you know,
you still have to have veryscientific way about formulating
your products and making surethat they're safe.
Aaron Harmon (19:24):
Yeah, no, that's that's pretty impressive. In
terms like we talked about theFDA, there are other ways that
cosmetics are regulated.
Charmaine Rodriques (19:31):
Yeah, so as I mentioned the FDA, through the
Food, Drug and Cosmetic Act aswell as the fair packaging and
labeling act. These two acts arewhat the FDA use to regulate
cosmetics. And as I mentioned, alot of the responsibility lies
with the manufacturersthemselves. The Federal Trade
Commission, in addition to theFDA regulates advertising for
(19:56):
cosmetics, so the FTC will makeensure that companies are not
making say medical claims ontheir cosmetics or claims that
are misleading, like you can saythis skin cream is going to cure
your acne, there is an FDAmonograph, Acme products are OTC
products. So even though theyhave a cosmetic element in them,
(20:19):
they're regulated as drugs. Andso a cosmetic should never go
into that space. You can sayyour cosmetic will heal your
skin or make your skin cleareror something like that. So the
FTC regulates cosmetics in thatway, in terms of like,
advertising, you see on TVadvertising you see on the web,
(20:42):
anywhere, cosmetic company willadvertise this claim that the
FTC will have jurisdiction overthe advertising part of it. And
the FDA does that too. Inaddition to the FDA and the FTC,
you have the individual statesthat will have their own set of
regulations. And that becomes abit of a problem for a lot of
(21:06):
brands, for example, a claimsorry, states like California,
they're constantly adding newrestrictions, when it comes to
ingredients, or even issues likesustainability claims, they will
have their own set of rules, sayyou can't use over a certain
percentage of this ingredient,your product in say, if you want
(21:29):
to sell in California, I'm justkind of making that out. So if
you do that, you know a formula,or formulator has to decide,
okay, you know, if I have morethan that, does it mean I can
sell in California, you know,and so they'll have to
reformulate according to theseupdated guidelines. So
(21:49):
regulatory folks like me andhave to be knowledgeable, and
the on top of the newregulations that are coming out
with the individual states,especially if the brand wants to
do business nationwide, when itcomes to advertising, which is
what I deal with a lot. We havethe national advertising
division, which is a selfregulatory body that also
(22:13):
governs advertising. And theykind of work closely with the
FTC, even though they're selfregulatory. There's a team of
lawyers and they will do theirown routine monitoring, if they
see a cosmetic that's making amedical or health claim, they
can pretty much challenge thatadvertiser and review the
(22:33):
claims. Or, if the brand doesn'twant to comply, they'll actually
refer them to the FTC. And sothat's happened before. And then
the PCPC, which I mentionedbefore, the personal care
products Council, they're alsoan industry group. And it's
probably it's a, it's a tradeorganization that I would say
(22:57):
represents most of the beautybrands, especially the big ones
here in the US. And the PCPChelps to establish policies, and
they advocate for cosmeticsafety through scientific
evaluations, and you know,they'll have meetings and
they'll inform their brands ofnew regulations and just helping
(23:17):
them to comply. And then lastbut not least, are consumers,
consumers actually play a verybig role in keeping beauty
brands you know, they're likethe quote unquote regulator.
Keep beauty brands in linebecause they'll file class
action lawsuits against brandsif they feel like a brand is
(23:38):
making a misleading claim, or ifthe brand is failing to provide
a safe product for them. Soconsumers fall class action
lawsuits if they experience hairloss with a hair product or if
they use a product that burnttheir skin or that irritated
their skin. If they could findan attorney that could file a
(24:01):
class action if they feel thatespecially if the product
especially if the brand ismaking a claim on packaging that
it's safe or hyper allergenic,then they will challenge those
claims in a class actionlawsuit. So that's pretty much
it in terms of regulation herein the US.
Aaron Harmon (24:19):
How do you keep this all straight?
Charmaine Rodriques (24:23):
I know it's it's quite a bit that's why
there are teams of you know,regulatory people working Yeah,
just being on top of everythingall the time. It's your scouring
and making sure that nothingmisses you. Wow, you're
Jeni Fjelstad (24:39):
so so knowledgeable That is so
awesome. Thank you for sharingthat. You mentioned something
about like products beinghypoallergenic like allergy
tested the active ingredient inlash slur actually is like a
well known allergen now. I'm soI'm just curious like how people
should approach products tosafely check if there may be
allergic at all. Do it orperhaps there's like some
(25:02):
allergy testing that goes intocosmetic quality testing
nowadays pretty regularly.
Charmaine Rodriques (25:08):
Yeah, so that's a good question. If you
go to say, a Sephora or an OTA,you'll see and you pick up a
product, you'll see some of theclaims are like hypoallergenic
or allergy tested, you'll seethose claims on some of the
products. And that means thatthe products have been safety
(25:29):
tested, and should cause fewerallergic reactions than other
products. So this is typicallydone through some form of patch
testing. And the product isapplied repeatedly to the skin
over a period of time to see ifthe consumer experiences
irritation, or sensitization.
And then so some brands will dothis prior to a product hitting
(25:51):
the market just to make surethat it's not going to cause an
allergic reaction. Of course,there is no guarantee you right,
because a consumer, you candevelop an allergy anytime to
ingredient in the product. TheFDA legally requires cosmetics
to have ingredient lists ontheir labels, so that consumers
(26:14):
can you know, if you you knowthat you're allergic to a
specific chemical, you canquickly check the ingredient
list on your product to see ifthere are ingredients in there
that you potentially be harmfulfor you or risk for you. All
products, all products out thereon shelves should have these
ingredient lists, you can checkthe website to a lot of
(26:35):
companies are putting have theiringredient list on the website,
there's something there that youthink could be of harm to you,
then you shouldn't use thatproduct. Or if Surprise,
surprise, I used to scream freeday. And now Hey, it's given me
a rash, what do I do? So you cannotify the manufacturer, you can
reach out, you can look on yourpackaging, there should be an
(26:57):
800 number, some number whereyou can contact the brand. Or
you can even go to the FDAwebsite, they have a link there
where consumers can reportadverse events. it's importa
t for consumers. And I knw a lot of consumers are do
ng this now they're reading ingrdient list. They're very knowle
(27:19):
geable these days. So that's god practice.
Aaron Harmon (27:34):
We're definitely in an age where it's very easy
to transfer information, bothcustomers to manufacturers and
back and forth.
Charmaine Rodriques (27:41):
Absolutely.
Absolutely. Now with the QRcodes, too, you know, you can?
Yeah, I mean, nothing should behidden anymore. Yeah, it's all
it's all out there.
Aaron Harmon (27:54):
So in the case of like lash lawyer, there wasn't
many barriers at that time tokeep that product off the
market. And I say barriers,because I'll hear entrepreneurs
refer to regulations and qualitysystems, like a barrier
sometimes. But with everythingyou described, you know, what
does that view a business that'swell established and eventually
(28:17):
gets products on the market?
Charmaine Rodriques (28:18):
Yeah, I mean, I would say, you know, you
really don't have much of achoice these days, you just
really have to have a safeproduct, regardless of the the
barriers that are there. I mean,in this age of social media, I
would say word gets aroundreally fast about products. So
if you don't adhere to theguidelines, and God forbid,
(28:42):
somebody has a rash to yourproduct, that's basically or an
adverse event. That's basicallyit for you. I'm, I am part of a
mommy group. And they actuallydo their own like, brand or
product reviews, sometimes, youknow, they recommend products.
And it's back and forth, whereyou'll hear, you know, when mom
(29:05):
say, oh, no, I don't like that,my my child to give my child a
rash, or it smells bad, or itdidn't work. So you shouldn't
really view these regulations asbarriers, I would say because
you know, as especially forproduct safety, because when the
age of social media, you reallydon't want consumers saying
(29:27):
anything about it. Becausepretty much reputation is what a
lot of brands have, especiallyin a market that is so
competitive means so many peopleare making moisturizers and
serums. And, you know, how doyou stand out? It's your
reputation, really.
Aaron Harmon (29:44):
And like you mentioned earlier, the story of
last year you hadn't heard aboutthat? That's the case where
someone died from a cosmetic andnow that idea of someone dying
from a cosmetics unheard of.
Charmaine Rodriques (29:54):
Exactly, exactly. Yeah. Yeah. Yeah. You
really just have to be on top ofit and and
Think that nobody, no companiesout here now you know, wanting
to hurt consumer, that's whereyou're getting your you know
that they're the ones who arekeeping you in business. So, um,
people, I would say, arevigilant. And I would say trying
(30:18):
to be careful. So this like twoway communication kind of
between the producer of theproduct and then their consumers
and the regulators, does thatmean that the regulations or the
standards for cosmetics are likechanging more quickly these
days? Or how often are theychanging? I would say that
(30:38):
they're changing pretty. I mean,I don't know, if quickly would
be a term, but I know they'rethere. There's consistent
change. As I mentioned, before,a couple of weeks, the PCPC just
published new guidelines for thesafety test that's being done.
So I mean, when it comes tocompanies that do business in
(31:01):
Canada, you know, Health Canada,they're constantly updating
their hot lists. They'reconstantly updating their
regulations there to makeproducts safer. And so if a
company wants to do businessacross the border, they're
constantly having to changecompanies that do business in
(31:21):
Europe, it's the same things,too. You know, a lot of brands
here sell in Europe and China,and those regulations are
changing quite quickly. The FDAis actually looking to change
some regulations with sunscreenand sunscreen safety. So that's
going to be updated soon. So Iwould send and one more thing,
(31:42):
there's a I believe there arefour new bills, I believe those
are in California, don't quoteme on that, that are coming out
about cosmetic safety. And so wedon't know if those are going to
be passed yet. But they wereintroduced. So yeah, I would say
it's, it's changing. It'sconstant. It's constant. That's
(32:04):
a good thing. Yeah, it is a goodthing. As we learn more. Yeah,
it may not be such a good thingfor you know, companies, because
you're constantly having to formyou know, reformulate. And so it
can be challenging. But as weget new information, you know,
it's it's important that interms of like keeping your
(32:25):
consumers safe, that's reallyimportant. Jenny, was there any
other questions you want to ask?
I think that pretty much got itall covered from what I was
really curious about. I'm soglad that you came here today to
share all your knowledge, youknow, so, so much about the
cosmetics industry. So I'm soglad to have a couple moments to
(32:45):
learn from you today. Thank you,Jenny. It was a pleasure being
here. Yeah. Yeah, it's a it's awonderful industry. I enjoy
being in it. I actually can'tsee myself in another industry
right now. But you know, it'sreally exciting and good to be
able to work in an area whereyou actually use the products.
(33:07):
So it's, it's exciting. It'sfun. That's great. That's, I
think there's a certain amountof joy you get as somebody who
works in the space of bringingproducts to market when you can
go into a store and see yourproduct on the shelf.
Absolutely. Yes. That is thatthat's that's a big deal for me.
Yeah. When you can walk intothis for Neiman Marcus, and then
you see the brands that you workon on the shelves. Yeah, it's
(33:30):
like gives you a little bit ofjoy. Thank you for being on the
episode. Thank you, Erin. Thankyou for having me. Thanks for
listening to this episode, andstay tuned for our next one. We
hope you enjoyed this episode.
This is brought to you thanks toSouth Dakota biotech
Association. If you have a storyyou'd like us to explore and
(33:50):
share, let us know by visitingwww.sd bio.org. Also, if you
live in the Sioux Falls area,check out quit a local Quality
Assurance Professionals Network.
You can find out more aboutQUIBIT by clicking on the link
on our website too. Thanks forlistening
The following is an excerpt from Ruth lambs book
(00:02):
called The American chamber ofhorrors written in 1936. Your
government has not the legalright under the present Food and
Drugs Act to protect you againstdangerous cosmetics. The law
does not apply to toiletpreparations, and those which
are harmful, not be taken offthe market no matter what pain
and disfigurement they inflict.
tragedies from the use of suchproducts are by no means of
uncommon occurrence. On themorning of May 17 1933, a
(00:25):
charming lady whom we shall knowis Mrs. Brown, drove downtown to
have her picture taken. She'dworked hard all winter as
secretary of the local ParentTeachers Association, and as a
chairman of the EntertainmentCommittee. That evening, her
associates were giving herbanquet in her honor. They had
asked for a picture of her toput in the state PTA magazine,
(00:45):
so she was having a made an hourlater, she stopped a birds
beauty shop to get shampoo andhaircut. But since this was to
be a special occasion, and shenaturally wanted to look her
best, she let herself bepersuaded to have her brows and
lashes touched up.
Hi, I'm Aaron Harmon, and thisis inside out quality, a podcast
about real life events andexperiences shared by our guests
(01:08):
of when things have gone wrong,and how we can learn from them
to build better products,companies and improve lives
through an effective qualitysystem.
The year before the elixirsulfanilamide disaster, two
years before the first Food Drugand Cosmetic deck. Ruth was the
chief educational officer forthe FDA. Her book was written to
(01:30):
warn customers of the potentialdangers of marketed products at
that time. Here's that excerpt.
Ruth was describing whathappened to Hazel Fay, who ended
up being permanently blindedfrom a cosmetic name Lafleur.
The beauty industry continues toflourish in 2021. With social
influencers, cosmetic brands andeven drugstore sellers offering
millions of ways to alter one'sappearance. People regularly
(01:51):
pick up a tube of mascara attheir local store without
questioning. Will this make mego blind? Am I going to have a
life threatening reaction? Wedon't ask these questions thanks
for the work of agencies likethe FDA. In a world before the
1938 Food, Drug and CosmeticAct, products like lash there
could be sold and marketedwithout any oversight. The
company marketed this product asan eyelash and eyebrow dye,
(02:12):
which boasted permanence and thecoveted dark color fashion at
that time. What it didn't sharewas that it was all banks to
paratha aniline dynamin fromaniline, a coal tar component
and known allergen, according tothe American Academy of
Ophthalmology. In 1933. severalcases of severe reactions to the
die were reported, includingblindness blisters, and in one
(02:33):
case even deaths from theinfection. The incidents were
highly publicized, including anFDA exhibit in the 1933 Chicago
World's Fair, as they inproponents petitioned for the
revision of the 1906 Food andDrugs Act. After a few years of
industry resistance, the FoodDrug and Cosmetic Act finally
emerged as the first federalregulation of cosmetics. It
provided a list of safe approvedingredients and gave the
(02:56):
government power to pull harmfulproducts from the shelves. And
what was the first product thatthe FDA withdrew from the
market. It was Lafleur the Foodand Drug cosmetics Act has spent
the last 80 years holdingcosmetic producers accountable
for bringing safer beautyproducts to consumers. Now it's
time to learn more and aprevious intermission, I
introduced Jenny elstead, one ofthe interns with Inside Out
(03:17):
quality. In this episode. Shejoins me as a co host and help
us with that is CharmaineRodriquez. She is the Regulatory
Affairs Manager for perfumes,Christian Dior, welcome to
Inside Out quality Charmaine.
Charmaine Rodriques (03:30):
Thank you, Aaron. I'm really excited to be
here. Thank you for inviting me.
Aaron Harmon (03:35):
I am glad I got to speak to you and convince you to
be on the show with us. Prettyexcited as well. So first, how
did your career path bring youthe role that you're in now with
Christian Dior?
Charmaine Rodriques (03:46):
I'm gonna say Aaron that the past my
current role is regulatorymanager for advertising
compliance has been one that hasbeen fairly progressive, I would
say it wasn't a path that Ideliberately set out on. But I
now happily find myself in thisposition based upon my prior
experiences. One of my firstjobs was actually in the
(04:07):
cosmetic industry. I worked as alab tech for a company that
formulated lip liners andeyeliners. So I was involved in
the batch formulation then. Andin addition, I got, I was
introduced to color matching. Sothe company that I worked for
was a contract manufacturer, wewould match colors for clients.
(04:31):
So it was just, you know, one ofmy first introduction to the
beauty industry. But after thatI worked in the pharmaceutical
area as a QC chemist for anumber of years. And while I was
in that field, I started andfinished a graduate degree in
environmental studies. I thoughtmy intent was to have a career
in the environmental space. Andso after graduating, I took a
(04:55):
position at the GoodHousekeeping Research Institute
as a chemistIn their beauty lab, and the
that role involved chemistry andenvironmental studies, so or
environmental science, so it wasone that was, you know, really
perfect for me. And I workedthere for a number of years,
testing beauty products againstthe or efficacy as well as
(05:17):
evaluating product ingredientand label claims. I was able to
contribute to a number of blogsand worked with the editors,
their magazine articles onsafety issues in the beauty
industry. Good Housekeepingmagazine has a very rich history
of consumer safety and advocacy,and in fact, was one of the few
(05:37):
magazines or maybe the onlymagazine at that time that
reviewed advertising on itspages to ensure claims were
supported. My next role afterthat was research editor at NBC
Universal, there was responsiblefor reviewing clinical studies
and other support documents foradvertising that you see on TV.
I did that for about threeyears, then moved on to racket,
(06:00):
where I worked on the legal teamas an advertising claims review
manager. And there I worked on awide variety of brands,
including personal care, beautyOTC and dietary supplements. And
they're worked closely with theregulatory department, the r&d
as well as clinical to make surethat the claims from my brands
(06:22):
were validated. And now at Dior,I validate advertising claims
for several of the beauty brandsthere under the LVMH umbrella.
So that's pretty much my journeyin a nutshell. That's a fabulous
journey. I would never expectsomeone could have a farmer job
working for NBC. Exactly.
Aaron Harmon (06:46):
Some totally blew my mind. Oh, you said that.
Yeah. And just out of curiosity,you said you did efficacy
testing for some of the productsearly on? What does that look
like in the cosmetic space.
Charmaine Rodriques (06:58):
So in the cosmetic space, there are like a
whole bunch of tests that youcan do. So when you see a
product that says it hydratesthe skin and moisturizes the
scan, that's a really commonclaim in this space. And so we
would do corny geometry studies.
It involves capacitancemeasurements, where you apply a
product to the skin, and see howwell it hydrates the skin.
(07:19):
That's one test that we woulddo, we'd also to Cutometer. To
see if a product from the skin,we had another instrument called
the Vizio complexion analyzer.
Without we took photos ofpanelists in a control light
setting. And so we'd send themhome with products to use for,
(07:43):
you know, several weeks, andthen we would take after photos
to look at to see if theirwrinkles were less visible, that
type of thing if their darkspots were less visible or
minimized. So it's quite a lot.
And we did a lot of hair testingto where we actually tested on
here swatches. We did a conetest to see how well
(08:04):
conditioners performed. So it'sa whole variety of tests.
Aaron Harmon (08:11):
Amazing. Yeah. So Lash Lure caused skin irritation
caused ulcerations of thecornea. And the result of that
was women being blinded. So howdoes this prevented now in the
cosmetic product development?
Charmaine Rodriques (08:24):
So first of all, I just want to say that
story is one that's extremelysad and disheartening, and I'd
never heard of it before. I wasjust kind of like blown away.
And a story like this shouldnever be repeated in this Age of
Information and Technology. Andnow we have the FDA. When it
(08:45):
comes to product development.
Every cosmetic manufacturerselling in the US has a legal
requirement to make sure thattheir products are safe for
consumers under the Food, Drugand Cosmetic Act. The FDA
prohibits the marketing ofadulterated or misbranded
cosmetics. And what they will dois that they will enforce
actions against companies thatdo not comply. One thing is that
(09:07):
the FDA does not approvedcosmetics before they hit the
market. And neither do theyprescribe a set of testing
methods that manufacturers needto abide by. So it's really up
to the responsibility of thatmanufacturer to make sure that
they're producing a product thatis safe for consumers. The
(09:27):
manufacturers will do cosmeticsafety tests. They will assess
toxicology data for theiringredients and the products
that they sell. Because if theydon't comply the agency which is
the FDA will take enforcementactions against brands and you
really don't want the governmentto come down on you. And in
(09:50):
terms of safety protocols therelike a wide variety of
established methods that aformulator can use Now, big
companies will have teams ofscientists in their research
labs that are dedicated tosafety testing. Or another
option is to have like a thirdparty lab that will conduct your
(10:10):
safety tests. And many of theselabs are accredited to the FDA
will actually do inspections aswell here. And in the product
development phase, companieswill conduct tests like
stability, which you're going toassess. And with this test,
you're going to assess how yourproduct stands up over time. So
(10:33):
you look at the cosmetics andthe the integrity of the
product. Is it separating? Isthe color changing? Does it
smell bad, so you're gonna dothis stability test after
specific intervals, like a weekor two weeks or two months, you
know, however you set that up.
(10:53):
And then another test that aformulator can do is
microbiological evaluation, toensure that your product is not
contaminated, while it's on theshelf for when it's being
transported to the consumer. Andeven when they actually
evaluating it as to how aconsumer would use it. Because a
(11:16):
lot of folks will dip theirhands you know, the wet hands
into a cream. So you want tomake sure that microbes don't
grow in your product. So a lotof companies will test how the
product will uphold insituations like that. And in
fact, the PC PC which personalcare products Council just came
out with updated guidelines acouple of weeks ago, maybe not a
(11:39):
week ago, but a couple weeksago. And in addition to this
companies will also conductclinical trials, such as the
human repeat in South patchtest. And again, they can either
do this in house or via a thirdparty. And then with this test
evaluates a product's potentialto cause irritation on the skin
(11:59):
or sensitization. So all of thistesting will be done in the
product development phase priorto a cosmetic hitting the market
just to ensure that safety hasbeen established. And then I
mentioned earlier that the FDAconducts inspection of
manufacturing and researchfacilities just to make sure
that all these safety protocolsare in place during formulation
(12:22):
and production. And a coupleother things that I want to
mention is that the the FDA hasa list of prohibited and
restricted ingredients forcosmetics on the website. And
then they're really extensiverestrictions when it comes to
color additives like I make upfor eye makeup that are used,
(12:42):
used on the skin, especially forthe eyes. So formulators can
familiarize themselves withthese lists when developing new
products. And in addition to theFDA, the FDA works with the PCPC
to publish what's called thecosmetic ingredient review. And
this is really, really animportant and fabulous website
(13:05):
because it lists the safetyprofiles of cosmetic ingredients
that are based on scientific andindependent expert assessments.
So if you're a new manufacturerin the industry, and you want to
use a specific ingredient inyour new serum, or your new
moisturizer, you can go on thereand you can identify any
(13:27):
potential hazard for thatingredient. And again, these
findings are based on peerreviewed scientific literature.
And what the database will doit, we'll establish certain
limits for certain ingredients.
So you have this particularingredient, but you shouldn't
use it more than 2%. Or youknow, or even point oh 1% in
your formula. So you can look atthat and get your safety data
(13:50):
and your toxicology data. Andthen just across the border
Health Canada, where a lot ofAmerican brands do business,
they also have a very rigoroussystem and strict set of
guidelines. They have what theypublish the hot list. And you
can find that on the HealthCanada website. And it's just a
(14:10):
list of ingredients that haverestrictions for use in beauty
products. And this is constantlybeing updated as new information
comes out about ingredients andpossible allergic reactions. And
then a manufacturer orformulator can actually get some
data from the ingredientsuppliers themselves, they will
(14:32):
have they should have saved MSDSis and relevant safety data for
the ingredients that they'regoing to be selling to their
clients. And then in terms ofthe for consumers. If the
consumer experiences an adversereaction to a an ingredient in a
cosmetic, they can report thatto the FDA or they can reach out
(14:55):
to the manufacturer as well. Themore You know, you know, that's
what's going to help you. Sothey're pretty much three
pillars that really keep brandsaccountable and formulators
accountable. The regulator, theindustry experts in the
consumers. So I hope thatanswers your question. I know it
(15:17):
was kind of long winded. It's soyeah, hear that? Yeah. Now we'll
Aaron Harmon (15:23):
take a quick break to hear from one of our
sponsors.
Joni Ekstrum (15:25):
Today's startups become tomorrow's growth
engines. In South Dakota, we'reentering a new stage of
expansion for our biotechindustry, and you'll want to be
part of it. Hi, I'm TonyJohnson, Executive Director of
South Dakota biotech, where thestate affiliate of the
International bio organizationand we're proud to be leading a
state that's driving innovationto feed, fuel and heal the
(15:46):
world. South Dakota biotech ishere to inform, to connect, and
to advocate for our criticalindustry. Whether you're
directly involved inbiotechnology, or looking to
learn more about it, we want tohear from you find us at www
that SD bio.org. Now back to theshow.
Jeni Fjelstad (16:05):
I was just curious, like how does like
public view and popular demandslike maybe taking parabens out
or like vegan in organicformulations? How does that
affect that quality productionside of making cosmetic products
and making them safe?
Charmaine Rodriques (16:23):
Right, so let me first start with
parabens. I mean, parabens areused in cosmetics as
preservative. But I am not awareof any data that supports that a
periban free formula willperform better than one without
parabens. As I said, they'vebeen used as effective
(16:43):
preservatives for many years.
And in the last decade or sothere have been implications
around the safety of parabens.
And so many brands have chosennot to include parabens in their
formula because of theuncertainty. And you know, I can
understand that. So what getsaround about parabens so
consumers don't want parabens intheir products either. There is
(17:07):
nothing conclusive yet, the FDAdoes have a statement on on
parabens on their website. Andthey're still investigating the
health effects. But a formulawithout parabens, I don't think
the data is there that say, youknow, if you have the screen
with Paramount and one without,you know, the one without is
going to perform better. I knowthat parabens are very good in
(17:31):
terms of being an effectivepreservative system, I don't
know in terms of the actualefficacy of the product, if that
makes a difference with the nonperiban formulations. But
manufacturers are required tohave a formula formulations that
are safe and adequatelypreserved. I think like vegan
(17:52):
and organic and naturals aresome of the other terms that
consumers are looking for. Forthose formulas that are vegan,
organic or natural. I think thathas more to do with ethics and
sustainability rather thanquality. These claims are based
more on a brand's ethicalvalues, then I would say
establish product efficacy. Idon't know of any research that
(18:16):
says a vegan versus you know, avegan formula is better than a
non vegan one, it's more or lessjust what consumers want now, or
where the ethics with the animaltesting, and all that how a
brand wants to present itself.
When
Aaron Harmon (18:31):
you described all the stuff you guys work through
to make sure that a product issafe before it goes out the
door. That works. Like blew meaway the amount of detail like
what you're describing is whatwe do in the pharmaceutical
industry. Right? And that's toother people. Are they surprised
when they hear how much goesinto into making sure these
products are safe? Yeah,
Charmaine Rodriques (18:49):
a lot of people are very surprised.
Because then you think about acosmetic. And it's like fun and
exciting. But your skin is thelargest organ. So you know you
have to take care of it and ithas whatever you put on your
skin has to be safe. So eventhough the industries itself is
fun and exciting, but it isserious, because medics can do
(19:12):
harm from the story that youmentioned earlier. So you know,
you still have to have veryscientific way about formulating
your products and making surethat they're safe.
Aaron Harmon (19:24):
Yeah, no, that's that's pretty impressive. In
terms like we talked about theFDA, there are other ways that
cosmetics are regulated.
Charmaine Rodriques (19:31):
Yeah, so as I mentioned the FDA, through the
Food, Drug and Cosmetic Act aswell as the fair packaging and
labeling act. These two acts arewhat the FDA use to regulate
cosmetics. And as I mentioned, alot of the responsibility lies
with the manufacturersthemselves. The Federal Trade
Commission, in addition to theFDA regulates advertising for
(19:56):
cosmetics, so the FTC will makeensure that companies are not
making say medical claims ontheir cosmetics or claims that
are misleading, like you can saythis skin cream is going to cure
your acne, there is an FDAmonograph, Acme products are OTC
products. So even though theyhave a cosmetic element in them,
(20:19):
they're regulated as drugs. Andso a cosmetic should never go
into that space. You can sayyour cosmetic will heal your
skin or make your skin cleareror something like that. So the
FTC regulates cosmetics in thatway, in terms of like,
advertising, you see on TVadvertising you see on the web,
(20:42):
anywhere, cosmetic company willadvertise this claim that the
FTC will have jurisdiction overthe advertising part of it. And
the FDA does that too. Inaddition to the FDA and the FTC,
you have the individual statesthat will have their own set of
regulations. And that becomes abit of a problem for a lot of
(21:06):
brands, for example, a claimsorry, states like California,
they're constantly adding newrestrictions, when it comes to
ingredients, or even issues likesustainability claims, they will
have their own set of rules, sayyou can't use over a certain
percentage of this ingredient,your product in say, if you want
(21:29):
to sell in California, I'm justkind of making that out. So if
you do that, you know a formula,or formulator has to decide,
okay, you know, if I have morethan that, does it mean I can
sell in California, you know,and so they'll have to
reformulate according to theseupdated guidelines. So
(21:49):
regulatory folks like me andhave to be knowledgeable, and
the on top of the newregulations that are coming out
with the individual states,especially if the brand wants to
do business nationwide, when itcomes to advertising, which is
what I deal with a lot. We havethe national advertising
division, which is a selfregulatory body that also
(22:13):
governs advertising. And theykind of work closely with the
FTC, even though they're selfregulatory. There's a team of
lawyers and they will do theirown routine monitoring, if they
see a cosmetic that's making amedical or health claim, they
can pretty much challenge thatadvertiser and review the
(22:33):
claims. Or, if the brand doesn'twant to comply, they'll actually
refer them to the FTC. And sothat's happened before. And then
the PCPC, which I mentionedbefore, the personal care
products Council, they're alsoan industry group. And it's
probably it's a, it's a tradeorganization that I would say
(22:57):
represents most of the beautybrands, especially the big ones
here in the US. And the PCPChelps to establish policies, and
they advocate for cosmeticsafety through scientific
evaluations, and you know,they'll have meetings and
they'll inform their brands ofnew regulations and just helping
(23:17):
them to comply. And then lastbut not least, are consumers,
consumers actually play a verybig role in keeping beauty
brands you know, they're likethe quote unquote regulator.
Keep beauty brands in linebecause they'll file class
action lawsuits against brandsif they feel like a brand is
(23:38):
making a misleading claim, or ifthe brand is failing to provide
a safe product for them. Soconsumers fall class action
lawsuits if they experience hairloss with a hair product or if
they use a product that burnttheir skin or that irritated
their skin. If they could findan attorney that could file a
(24:01):
class action if they feel thatespecially if the product
especially if the brand ismaking a claim on packaging that
it's safe or hyper allergenic,then they will challenge those
claims in a class actionlawsuit. So that's pretty much
it in terms of regulation herein the US.
Aaron Harmon (24:19):
How do you keep this all straight?
Charmaine Rodriques (24:23):
I know it's it's quite a bit that's why
there are teams of you know,regulatory people working Yeah,
just being on top of everythingall the time. It's your scouring
and making sure that nothingmisses you. Wow, you're
Jeni Fjelstad (24:39):
so so knowledgeable That is so
awesome. Thank you for sharingthat. You mentioned something
about like products beinghypoallergenic like allergy
tested the active ingredient inlash slur actually is like a
well known allergen now. I'm soI'm just curious like how people
should approach products tosafely check if there may be
allergic at all. Do it orperhaps there's like some
(25:02):
allergy testing that goes intocosmetic quality testing
nowadays pretty regularly.
Charmaine Rodriques (25:08):
Yeah, so that's a good question. If you
go to say, a Sephora or an OTA,you'll see and you pick up a
product, you'll see some of theclaims are like hypoallergenic
or allergy tested, you'll seethose claims on some of the
products. And that means thatthe products have been safety
(25:29):
tested, and should cause fewerallergic reactions than other
products. So this is typicallydone through some form of patch
testing. And the product isapplied repeatedly to the skin
over a period of time to see ifthe consumer experiences
irritation, or sensitization.
And then so some brands will dothis prior to a product hitting
(25:51):
the market just to make surethat it's not going to cause an
allergic reaction. Of course,there is no guarantee you right,
because a consumer, you candevelop an allergy anytime to
ingredient in the product. TheFDA legally requires cosmetics
to have ingredient lists ontheir labels, so that consumers
(26:14):
can you know, if you you knowthat you're allergic to a
specific chemical, you canquickly check the ingredient
list on your product to see ifthere are ingredients in there
that you potentially be harmfulfor you or risk for you. All
products, all products out thereon shelves should have these
ingredient lists, you can checkthe website to a lot of
(26:35):
companies are putting have theiringredient list on the website,
there's something there that youthink could be of harm to you,
then you shouldn't use thatproduct. Or if Surprise,
surprise, I used to scream freeday. And now Hey, it's given me
a rash, what do I do? So you cannotify the manufacturer, you can
reach out, you can look on yourpackaging, there should be an
(26:57):
800 number, some number whereyou can contact the brand. Or
you can even go to the FDAwebsite, they have a link there
where consumers can reportadverse events. it's importa
t for consumers. And I knw a lot of consumers are do
ng this now they're reading ingrdient list. They're very knowle
(27:19):
geable these days. So that's god practice.
Aaron Harmon (27:34):
We're definitely in an age where it's very easy
to transfer information, bothcustomers to manufacturers and
back and forth.
Charmaine Rodriques (27:41):
Absolutely.
Absolutely. Now with the QRcodes, too, you know, you can?
Yeah, I mean, nothing should behidden anymore. Yeah, it's all
it's all out there.
Aaron Harmon (27:54):
So in the case of like lash lawyer, there wasn't
many barriers at that time tokeep that product off the
market. And I say barriers,because I'll hear entrepreneurs
refer to regulations and qualitysystems, like a barrier
sometimes. But with everythingyou described, you know, what
does that view a business that'swell established and eventually
(28:17):
gets products on the market?
Charmaine Rodriques (28:18):
Yeah, I mean, I would say, you know, you
really don't have much of achoice these days, you just
really have to have a safeproduct, regardless of the the
barriers that are there. I mean,in this age of social media, I
would say word gets aroundreally fast about products. So
if you don't adhere to theguidelines, and God forbid,
(28:42):
somebody has a rash to yourproduct, that's basically or an
adverse event. That's basicallyit for you. I'm, I am part of a
mommy group. And they actuallydo their own like, brand or
product reviews, sometimes, youknow, they recommend products.
And it's back and forth, whereyou'll hear, you know, when mom
(29:05):
say, oh, no, I don't like that,my my child to give my child a
rash, or it smells bad, or itdidn't work. So you shouldn't
really view these regulations asbarriers, I would say because
you know, as especially forproduct safety, because when the
age of social media, you reallydon't want consumers saying
(29:27):
anything about it. Becausepretty much reputation is what a
lot of brands have, especiallyin a market that is so
competitive means so many peopleare making moisturizers and
serums. And, you know, how doyou stand out? It's your
reputation, really.
Aaron Harmon (29:44):
And like you mentioned earlier, the story of
last year you hadn't heard aboutthat? That's the case where
someone died from a cosmetic andnow that idea of someone dying
from a cosmetics unheard of.
Charmaine Rodriques (29:54):
Exactly, exactly. Yeah. Yeah. Yeah. You
really just have to be on top ofit and and
Think that nobody, no companiesout here now you know, wanting
to hurt consumer, that's whereyou're getting your you know
that they're the ones who arekeeping you in business. So, um,
people, I would say, arevigilant. And I would say trying
(30:18):
to be careful. So this like twoway communication kind of
between the producer of theproduct and then their consumers
and the regulators, does thatmean that the regulations or the
standards for cosmetics are likechanging more quickly these
days? Or how often are theychanging? I would say that
(30:38):
they're changing pretty. I mean,I don't know, if quickly would
be a term, but I know they'rethere. There's consistent
change. As I mentioned, before,a couple of weeks, the PCPC just
published new guidelines for thesafety test that's being done.
So I mean, when it comes tocompanies that do business in
(31:01):
Canada, you know, Health Canada,they're constantly updating
their hot lists. They'reconstantly updating their
regulations there to makeproducts safer. And so if a
company wants to do businessacross the border, they're
constantly having to changecompanies that do business in
(31:21):
Europe, it's the same things,too. You know, a lot of brands
here sell in Europe and China,and those regulations are
changing quite quickly. The FDAis actually looking to change
some regulations with sunscreenand sunscreen safety. So that's
going to be updated soon. So Iwould send and one more thing,
(31:42):
there's a I believe there arefour new bills, I believe those
are in California, don't quoteme on that, that are coming out
about cosmetic safety. And so wedon't know if those are going to
be passed yet. But they wereintroduced. So yeah, I would say
it's, it's changing. It'sconstant. It's constant. That's
(32:04):
a good thing. Yeah, it is a goodthing. As we learn more. Yeah,
it may not be such a good thingfor you know, companies, because
you're constantly having to formyou know, reformulate. And so it
can be challenging. But as weget new information, you know,
it's it's important that interms of like keeping your
(32:25):
consumers safe, that's reallyimportant. Jenny, was there any
other questions you want to ask?
I think that pretty much got itall covered from what I was
really curious about. I'm soglad that you came here today to
share all your knowledge, youknow, so, so much about the
cosmetics industry. So I'm soglad to have a couple moments to
(32:45):
learn from you today. Thank you,Jenny. It was a pleasure being
here. Yeah. Yeah, it's a it's awonderful industry. I enjoy
being in it. I actually can'tsee myself in another industry
right now. But you know, it'sreally exciting and good to be
able to work in an area whereyou actually use the products.
(33:07):
So it's, it's exciting. It'sfun. That's great. That's, I
think there's a certain amountof joy you get as somebody who
works in the space of bringingproducts to market when you can
go into a store and see yourproduct on the shelf.
Absolutely. Yes. That is thatthat's that's a big deal for me.
Yeah. When you can walk intothis for Neiman Marcus, and then
you see the brands that you workon on the shelves. Yeah, it's
(33:30):
like gives you a little bit ofjoy. Thank you for being on the
episode. Thank you, Erin. Thankyou for having me. Thanks for
listening to this episode, andstay tuned for our next one. We
hope you enjoyed this episode.
This is brought to you thanks toSouth Dakota biotech
Association. If you have a storyyou'd like us to explore and
(33:50):
share, let us know by visitingwww.sd bio.org. Also, if you
live in the Sioux Falls area,check out quit a local Quality
Assurance Professionals Network.
You can find out more aboutQUIBIT by clicking on the link
on our website too. Thanks forlistening
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