We are Certified!

I'm happy to announce that our farm has just become Certified Naturally Grown (CNG). I am excited about this program and you can read more about here http://www.naturallygrown.org/.  Its standards are similar to the USDA's Certified Organic program in that it does not allow synthetic fertilizers, pesticides, herbicides, fungicides or GMO seeds. It differs in that it is a small, private and grass roots organization not associated with the government and encourages collaboration, transparency and community involvement.

I've never been quite comfortable with the Certified Organic Program; its a government sponsored program that seems more tailored towards the larger sometimes corporate farms involved in monocropping. Not to mention their ownership of the word 'organic'. USDA COP farm inspectors are forbidden to make suggestions or help the farmers in any way while CNP farm inspectors are peers and volunteers that are encouraged to share information.  I look forward to my first farm inspection this spring by one of my peers who has volunteered to do so and I expect it to be a learning process. I've asked Darrell Cook of Ginger Cat Farm to do my inspection. CNP relies on volunteers like this which encourages community involvement and collaborations.

At Colorado Aromatics Herb Farm I grow things the way my Mother taught me and she learned from her Mother, the traditional way, long before there even were synthetic fertilizers, herbicides and pesticides. I do have the benefit of having herbs and lavender as my main crop which are probably easier to grow than vegetable crops. But we fertilize our fields in the winter using manure produced by our horses, goats and chickens. Although we are still learning how to best control weeks; we pick by hand until our backs ache, we use weed cloth and we hoe (we also accept volunteers). We try to reduce the amount of gasoline we use on the farm too by doing most of the work by hand rather than by tractor (we don't own a tractor). Because of the way we farm, beneficial insects such as bees, ladybugs and praying mantis abound. When we do get damaging insects such as aphids our first choice is to take care of them with the garden hose.

I think growing my herbs with the Certified Naturally Grown seal partners well with the extracts I make from them for natural cosmetics. I'll soon be adding pictures and information to our profile at CNG http://www.naturallygrown.org/farms/3421.

Safe Cosmetics Act of 2011

After spending a good several hours reading the new Safe Cosmetics Act of 2011 I see that the changes in this bill compared to 2010 are minimal. Here is my initial take on the bill which may or may not change depending on if some points get clarified or others appear as I reread it.

Again this bill includes in the definition of an ingredient any contaminants that are present at levels above technically feasible detection limits. As we all know, detection limits now are quite minute so any type of contaminant would be included here. This includes contaminants from the container as well. But what contaminants are they referring to here and why don’t they specify?

Ingredient safety can fall under just two categories: ‘Safe Without Limits’ and ‘Prohibited and Restricted’ This is misleading to both the consumer and the manufacturer since there is no such thing as a substance that is safe without limits. Even water can be lethal under certain conditions. It mentions ‘considerations’ in determining toxicity such as “is found to be present in the body through biomonitoring”. Does this mean that something is toxic if found in the body? I’m not sure I understand this. Many things are found in the body through biomonitoring including water. A second consideration is an ingredient that is suspected immunological toxicant. Is this another way of saying “allergen”? If so, does this mean that a substance that causes allergies will be prohibited? Anything can be an allergen and some common allergens are shea butter, almond butter, soy oil, milk, etc. Many herbs are also allergens. All in all, the bill has very poor definitions of toxicity and leaves most of it up to the FDA to determine in one year’s time! Wow, where is the FDA going to find those resources?

Labels must list ingredients in decreasing order of concentration. This is already required by the FDA so is redundant here. Contaminants however must also be listed. Knowing that water alone can contain any number of contaminants this immediately causes problems. Is testing of all our ingredients for contamination required?? Besides water, vegetable oils will contain contaminants, herbs grown in the backyard could contain contaminants. However, it does allow the FDA to determine such possible contaminants within one year’s time as well as determine requirements for testing and detection limits. If it is determined that cosmetic manufacturers are required to test for various contaminants this would add considerably to the cost of cosmetics. I am glad to see that ingredient lists are required on websites that sell cosmetics.

Some of the most dangerous contaminants of cosmetics are fungus and bacteria that can grow on nutrients in the product. Unfortunately, no specific mention of this is made. This is one area where consumers have suffered because of improperly made and improperly preserved products – in fact, this is the only area of documented harm to consumers from cosmetics.

Again, toxic is defined as a 1 in a million risk for adverse health effects. Toxic effects include allergic reactions and I challenge anyone to find any ingredient natural or synthetic that does not cause an allergic reaction in one in a million people.

Many things are not clear for instance “the safety standard results in exposure to the amount or concentration of an ingredient or cosmetic that is shown to produce no adverse health effects, incorporating a margin of safety of at least 1,000 and considering the impact of cumulative exposure from all sources (including environmental sources).” Does anyone know what this means and if so can you tell me? Does it mean 1000^th of the determined toxic dose? If so, who determines this dose?

The bill goes on to require that the FDA issue guidance prescribing Good Manufacturing Practices. This is something that again, the FDA already has issued and so is redundant.

The bill requires manufacturers of cosmetics and ingredients to submit information including toxicological properties of each such ingredient or cosmetic. I’m not sure if this means the manufacturer who is buying ingredients is required to submit data to the FDA on those ingredients or not. Since the source of this data would probably be from the ingredient manufacturer this seems redundant. When this ingredient is purchased at the grocery store such as some small manufacturers do with vegetable oils, where is the toxicological data and contaminant data and how is this reported as an ingredient source? When the ingredient is an herb from the small manufacturer’s back yard where will this toxicological information come from or will this no longer be possible? I am still very concerned about the future of using natural ingredients in cosmetics with this bill. There are many herbs, oils, and natural extracts that have quite a data gap in toxicological studies.

I find it interesting that the ‘authoritative source’ of toxicology information includes the (A) Environmental Protection Agency,

(B) the International Agency for Research on Cancer,

(C) the National Toxicology Program,

(D) the California Environmental Protection Agency and

(E) any other authoritative international, Federal, and State Entity, as determined by the Secretary.

I’m not sure what E means but I know there are pseudo science activists groups who may pose as an authority so that they can determine law. I would rather be sure toxicity was determined by peer reviewed scientific literature.

Some of the considerations in the bill for toxicity are also quite vague, for instance; if it is found in the body through biomonitoring. Does this imply that if something is found in the body it is toxic? I use water in my cosmetic formulas and I know it is found in the body. Another consideration is known or suspected immunological toxicant. Is an immunological toxicant the same thing as an allergen? Anyone can be allergic to anything but some of the more common allergens are shea butter, almond oil, soy oil, wheat and herbs. Will these ingredients be prohibited?

There is no definition of an ingredient manufacture. Many small companies use ingredients from their backyard; herbs and other botanicals. Are these companies required to have these ingredients tested to find what contaminants might be present and in what levels?

The thing that concerns me the most here though is that microbusinesses (those with sales less than $2 million) are not required to register with the FDA. Although I am glad to see that the bill waives a costly registration fee for these small companies (of which I am one) I don’t understand the lack of even registering with the FDA. Registration allows a link with the FDA so that companies can get timely information regarding ingredients and toxicity but just as important is that it allows consumers a way to report adverse effects that may occur due to cosmetic usage. By not registering, these microbusinesses are out of the communications link with the FDA. FDA will have no knowledge of the microbusiness’s existence, their activities, the products they manufacture or the functions and toxicities of those cosmetics. In the initial bill of 2010 small businesses rallied hard to be exempt from paying high registration and testing fees. However, we did not rally against registration.

If small companies are exempt from registering and having communication with the FDA are they exempt from submitting information on toxicological properties of ingredients and cosmetic product; exempt from “cease distribution” orders due to misbranding; exempt from use that causes serious adverse health effects; exempt from using contaminants and testing for these contaminants, exempt from good manufacturing practices issued by the FDA, etc? Having that link to the FDA could be valuable for a small business to learn the laws and requirements necessary especially when it comes to testing. This concerns me because many small cosmetics business owners just starting out do not have the knowledge base to draw from to know how to make safe cosmetics and have the potential to put something out there that is less than safe. And consumers should have a way to report possible adverse effects. It was the costs involved in the first version of this bill that had small business owners concerned, not having to register and be held accountable for their actions.

Should small businesses be just as responsible for their actions? Registration is important to keep open communication with the FDA.

Overall it is still a case of an activist group who knows nothing about the cosmetics business trying to make laws about things they do not understand. The bottom line still is that this bill will not make cosmetics safer.

The Farm in Spring

Colorado had a long cold winter with lots of snow and a good amount of rain in April. With temperatures gradually warming the gardens should do well this summer as long as we can keep them watered during the heat of summer. Chives, clary sage, mint, parsley as well as hops and southernwood are all growing well so far.

Over the winter I have gone over what herbs I used the most of and what I need more of. This summer I will find more room for calendula. I probably use calendula more than any other herb in my products. It is high in carotenoids which help skin cells grow to promote wound healing and help replenish epithelial cells. This is always important but becomes more so as we age. I’ll need more calendula for my own products as well as with hopes of selling calendula extracts this summer. I will also be offering green tea extracts, rosemary extracts, plantain, red clover and raspberry extracts for those interested in using them in products. They are all very good herbs for skin care.

Mint is also low but I know that just being one year older will make a big difference in how abundant their stems are. I make a mint infused oil to use in many of my products as mint helps to soften the skin and leaves a nice feel. I’ll be putting in more lavender of course, probably one to two more rows and then have to decide if I want to dig up pasture for additional lavender. Perhaps another rose bush, but again, with one more year’s growth my roses should be flourishing this summer. I choose my roses based on having high fragrance. I use ground rose petals in soap, salt scrub and facial steams and would like to have enough to distill for the aromatic water. I also make infused oil from rose petals that I think will be an ingredient in my olive oil cleanser.

Much of my time right now is taken up in getting products ready for the Farmers Market. Summer of course is busy for all gardeners and sometimes its hard to find enough time for anything else. Having a high number of products at the beginning of the summer makes it easier to fit in time for weeding, watering, planting, harvesting and drying. I may have to look for help this summer in the form of an apprentice who will trade work for learning experience. If you are interested or know someone who is please point them in my direction.

Besides planning for this year’s plantings I like to go through what dried herbs I have from last year and use up what I have leftover. One fun way to use up these herbs is to do a steam facial. Almost any herbs will work for this but rose, lavender, fennel and mint are especially good for a steam facial. Put a handful of dried herbs in a bowl and pour boiling water over it. Hold your head over the bowl with a towel over your head to help hold in the steam. Let the steam rise to your skin to hydrate, clean your pores and relax your body. What herbs do you have to use up before you harvest this summer?