Teach Soap

I'm only halfway through reading the bill as well, but so far it sounds more like a way to create more government jobs, than to actually improve the cosmetic industry...

_________________
Linda
I know the voices in my head aren't real, but they sure have some great ideas!

Lavender Lady, too true about the nasty people on this earth, I sometimes need to remind myself to step back and take my rose colored glasses off. MY hope is that if a bill must pass that it is modified to help small businesses so that we can operate within the confines of it. The way this bill looks now it's a long way off.

TC; that is my understanding as well.
Citymouse; yes, rose colored glasses are nice, but not the way of the world. Unfortunately if this passes as is we will all be under. So we now need to try and make sure it fails so they can go back to the drawing board! So go and sign the petition and contact your reps!

_________________
Remember, it's not just that we weather the storm, but how we dance in the rain.

Tammy

_________________
Irena
Closed minds are like faulty parachutes; they refuse to open.

Yes the word organic is a regulated word, however soap is excluded from that regulation I believe that it should be included.

You can only get in trouble if you put the USDA label on it.



And what if it's "soap"?

Soap is a category that needs special explanation. That's because the regulatory definition of "soap" is different from the way in which people commonly use the word. Products that meet the definition of "soap" are exempt from the provisions of the FD&C Act because -- even though Section 201(i)(1) of the act includes "articles...for cleansing" in the definition of a cosmetic -- Section 201(i)(2) excludes soap from the definition of a cosmetic.
How FDA defines "soap"

Not every product marketed as soap meets FDA's definition of the term. FDA interprets the term "soap" to apply only when --

The bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the product's detergent properties are due to the alkali-fatty acid compounds, and
The product is labeled, sold, and represented solely as soap [21 CFR 701.20].



As for "organic", organic is a regulated word and, as such, has standards of use. The word "natural" is not regulated, and therefore, there is no standard for it, so anyone can use it on their labeling or advertising.

Ken, I guess I just dont really see/understand your point. I think we all understand the difference between soap and syndant bars, and the labeling requirements of each. This difference allows us to simplify our labeling, and I think we all appreciate that. As for labeling the word "organic", my understanding, and what I was told when I called the FDA, is that you cannot use the word on your label unless you meet the standards, whether or not you use "FDA" before it or not, and whether or not the soap is true soap or syndat. Because, if you label your soap (which you are not obligated to do, as it now stands) you must label accurately and follow the guidelines for labeling (order of proportion, etc). Now enforcement is another story, as they dont have the staff to check out these things unless a complaint is made.

Either way, and whatever your desires for regulations, the current bill is unrealistic and would certainly put all of us out of business, and even a great number of "large" small businesses. This bill needs to fail!

_________________
Remember, it's not just that we weather the storm, but how we dance in the rain.

Tammy

_________________
Happy Soaping!

Anne-Marie
blog: www.soap-queen.blogspot.com
supplies: www.brambleberry.com

Ann Marie I certainly hope you are correct about it failing, and yes there are much more important issues for our country right now.
I will have to re-read the bill again, because I didnt reach the same conclusion you did about soap being excluded. Also, I know that there were exemptions money/registration wise, but the testing for that "adequate" labeling seems to me to be too cost prohibitive for the majority of small businesses.
Also, I guess I am curious as to why BB doesnt yet have a position on this bill as it now stands? It really surprised me when I read that. I mean, its not like you are a new Mom, have a hubby to care for, have a business to run, a blog to write, videos to make, interviews to do, or anything else!

_________________
Remember, it's not just that we weather the storm, but how we dance in the rain.

Tammy

My point is that I made a complaint about a store that was using the word Organic on the PDP with the only organic ingredient they used was a FO. I called the FDA and was told as long as it was soap, they only care if they put the FDA logo on the label.

As far as the bill goes, it will never see the light of day. I can tell you as an engineer as it stands now it is impossible to implement.

However, I believe that strict enforcement of all applicable laws should be. It is rouge soap makers like the one I described above that will eventually cause legislation of this sort to be enacted and cause financial harm to all of us.

It is amazing how many people do not follow labeling guidelines. Putting things like "around 4 oz" or putting the word 'Organic" on the PDP using base oils in the ingredient list but not listing NaOH

......so.....did anyone else see the letter that HSMG put out today regarding this bill? Seems like they are in support of it for the most part bearing some revisions???

Here is the email:

HSMG Advocacy Position
The Handcrafted Soapmakers Guild (HSMG) is a non-profit trade association for soapmakers, small businesses hand making soaps and the handmade soap making industry as a whole. Depending on the formulation and/or claims, handmade soaps can be regulated by the FDA or CPSC.

The following principles outline the HSMG policy positions:
Supports small businesses manufacturing safe soap and safe cosmetics.
Supports current cosmetic regulations for the Food, Drug and Cosmetic Act as a means of providing consumers with safe cosmetics.
Supports the current soap exemption as defined in the current cosmetic regulations for the Food, Drug and Cosmetic Act.
Supports all manufacturers having affordable and sufficient product & liability insurance.
Supports small business manufacturers having access to up to date information and education.
Supports positive advocacy strategies and communication as a means to affect change.
Opposes new regulations which would be overly burdensome or costly to small business while not significantly increasing consumer safety.
Safe Cosmetics Act 2011

The HSMG has been actively involved in advocacy for the handcrafted soap and cosmetics industry for the past several years. We have made tremendous progress during the past year in introducing and familiarizing our industry to Capital Hill with the assistance of our DC advocates Mary Anne Walsh and Rick Limardo . HSMG leaders have met with Members of Congress to educate them on our industry's businesses as well as the diverse products they produce. Most encouraging is Congress listened and took our concerns to heart.

When the Safe Cosmetics Act of 2010 was introduced last year, the handcrafted soap and cosmetics industry was unknown in Washington, DC. Many provisions in the 2010 bill would have negatively impacted thousands of small businesses throughout the United States. Through our meetings with the staff of the bill sponsors, Representatives Jan Schakowsky, Edward Markey and Tammy Baldwin, we learned that the legislation was not aimed at the handcrafted soap industry.

Now, a year later, we have attended several meetings with the sponsors of the bill and many other Members of Congress. They have listened to and heard our concerns. There have been many positive changes, and we are very encouraged that we have such an open line of communication to see our way forward.

On June 24, 2011, a new bill, the Safe Cosmetics Act of 2011 (HR 2359), was introduced. After a detailed review of the new legislation, we had another meeting with the bill sponsors to get clarification on some areas of concern with HR 2359 . At that meeting on July 13th, the staff was very gracious and willing to answer our questions and, more importantly, to help us understand their intention in drafting the legislation. We were very encouraged to find out that many of the worries that we had were due to misinterpreting the language in the bill or not understanding the intent behind certain portions.

Based on the information provided to us and our current understanding of the bill, we support the intent of The Safe Cosmetics Act of 2011.

During the week of July 24th, we will be placing a detailed summary of the bill on our website which will include the clarifications on issues of concern we have received from the sponsors. Until then, should you have any questions please do not hesitate to contact us.

This is far from over; the legislative process is long and includes committee hearings, amendments, mark-ups and hearings all before the bill moves to the House floor for any vote. The HSMG is very confident that with the relationships we have forged and with the guidance and advice of our legislative advocates, we are well positioned to have our voice heard throughout the process. It is very important to stay involved, stay informed and above all, stay calm. We have a seat at the table and we will continue our dialogue with the bill sponsors, committee members and others as the legislation moves forward.
Sincerely,

Leigh O'Donnell
HSMG President

I'm posting a position statement on this later tonight or tomorrow. It's basically that the bill isn't perfect (it's not), that it's a work in progress and that I'm thankful that we have active volunteers and paid lobbyists working for us and with us.

As I've stated before, I don't think this bill is going to get much traction and move with all the issues that are happening in DC right now (debt ceiling!). But that doesn't mean I won't be monitoring it all closely because yes, even if the intent isn't there, the bill isn't worded clearly enough to exempt small business from many of the things the 'big guys' would have to comply with.

Just my two cents. =)

_________________
Happy Soaping!

Anne-Marie
blog: www.soap-queen.blogspot.com
supplies: www.brambleberry.com

I hope you are correct, Soap Queen!

_________________
Linda
I know the voices in my head aren't real, but they sure have some great ideas!

"......because yes, even if the intent isn't there, the bill isn't worded clearly enough to exempt small business from many of the things the 'big guys' would have to comply with."
Just my two cents. =) "


Yes, I toss my two cents in with yours, so that puts us at four cents!

_________________
Remember, it's not just that we weather the storm, but how we dance in the rain.

Tammy