I have just picked up on an interesting story on Twitter. Lush are being gently mocked because people are finding that one of their soap bars that contains some seeds are sprouting in people’s bathrooms. This is a nice easter story – germination is something that is associated with spring after all. And it is quite funny. I have feeling that the people responsible for quality at Lush aren’t laughing though. I can remember a similar incident from long ago in my career. This was before Twitter but in any case didn’t get out into the public domain.
A large batch of strawberry seeds were weighed out in a factory with the intention that they should be used in a batch of exfoliator. They were left for a few days in the humid environment that you have in a cosmetic factory and they too sprang into life, expanding to several times their initial volume.
This was actually a stroke of luck because had this not happened they would have gone into the product without anyone realising they were viable until a customer noticed.
While this had its funny side, this kind of thing is actually a brand holders nightmare. I don’t suppose anybody had problems with the Lush product. There isn’t anything intrinsically dangerous about a tiny seedling. But that isn’t really the way the people who make mass market products need to think. If you are planning on shipping serious quantities of a product you have to be thinking about risks that could happen one time in a million. That is the risk you are actually running. To take a really critical look at this soap bar with seeds, you have to bear in mind that you will be handling viable seeds in large quantities in a factory. The risk of them sprouting is just one problem. If they are alive then there is a good chance that the bacteria that they had on them are also alive, and there is not telling what they might do. Very few people ever suffer any kind of harm from being poisoned by chemicals. Many people die each year even in the most advanced countries from eating stuff that has been contaminated by germs.
And microbes can have other effects. One theory about the prevalence of peanut allergies is that it isn’t anything to do with the peanuts themselves at all. The suggestion is that when the peanuts are being stored a fungus grows on them and releases proteins that are prone to trigger off allergies. I don’t think this theory is widely held any more, but it is certainly one that was plausible enough to be put forward. The large batches of these seeds in the factory could easily be prone to exactly the same issue. In fact, the seeds could start off fine and develop this problem later. The odds are very much against it, but triggering off an allergic reaction is within the bounds of possible outcomes from this otherwise comical incident.
The way that the legislators deal with this kind of issue is quite interesting. There are so many cosmetic manufacturers doing so many diverse things it would be impossible to come up with a set of rules that everyone should follow. And so nobody has tried. There is an international standard on what is called good cosmetic manufacturing practice, its number is ISO 22716 if you want to look it up, but it doesn’t say that you should only use seeds that have been treated to prevent them from sprouting anywhere in it. It just lays down the the structure of the way production and quality should be organised. It is only legal to make products following the principles of good cosmetic manufacturing practice, but producers have to interpret what that means in such a way that their products are safe under all normal and foreseeable conditions of use. Seeds sprouting is certainly foreseeable. Indeed it was a problem that I warned about in a webinar I did about exfoliants only a couple of months ago. It was organised by SpecialChem so I don’t know if anyone from Lush attended it. So while I hope that the people employed to enforce regulations don’t waste their time on this kind of trivia, it wouldn’t surprise me if there was a legal case against Lush here.
But even if Lush showed all necessary due diligence, I think the warning message here is that the assumption that natural products are safer than more conventional ones is a very weak one. With their funky packaging, zany marketing and their embracing of the alternative view of life Lush come across as a brand with their hearts in the right place. And I don’t doubt that it is. They are certainly keen enough on biodiversity to introduce it to your plughole. But they still need to have some hard nosed Quality Assurance in place as well.