Cosmetic Vigilance

You sometimes see people suggesting that cosmetics are in some way unregulated and we can get away with putting whatever we want in our products.  I sometimes wish it were true – I don’t think many people like having to keep up with continually changing regulations and I know I don’t.  But the fact is that anyone who makes a living developing cosmetics needs to have a good handle on the relevant legislation.  But the good news is that even this generally dull bit of the job can be made fun.  With some new legislation on the horizon the Society of Cosmetic Scientists held a meeting about cosmetics vigilance in Bristol earlier this week.  So as well as getting up to date on the new proposals I had a chance to catch up with some friends and eat some rather splendid scones.So what is cosemtics vigilance I am sure you are asking.  Basically it is keeping track of customer complaints.  All but the most amateurish of companies keep note of all the things their customers tell them and keep an eye out for patterns.  If a product gives an unusually high number of complaints it will be investigated and if necessary the formulation will be changed.  You can learn a lot from customer complaints if you are careful and organised about how you handle them.

In 2013 cosmetics vigilance will be not just something that anybody with any sense will do in their own best interests, it will become a legal requirement.  And the data will need to be generated in a standard form and reported to trading standards officers who will make it public.  This is quite a radical step and it will be interesting to see how it works out.  I don’t think that there will be much problem for the industry in complying with this particular change. I am pretty sure everyone is already doing pretty much what is required already.  It will be new work for trading standards who will have to either cut back on their other work or spend more money to cover it. So it will cost public money, and probably quite a lot.  I suppose someone somewhere must have worked it out.  I am sure they don’t just pass these bills without being sure that the money it will cost is being well spent.

So what are the public getting from this new legislation?  Well there is one clear advantage – if all the adverse reactions are being recorded across the whole market problems should be picked up quicker so any issues will be resolved more quickly. That has to be a good thing.  It might also help reassure people that products are safe, which again is a good thing.  But I wonder if it will also lead people to compare the numbers of skin reactions between different products.  When you think about it logically, there isn’t really any practical difference between a product that irritates 1 in 10,000 people and one that irritates 1 in 100,000.   In both cases the chances of you personally reacting are so trivially low that it is hardly worth worrying about.

But that may not be the way it works.  None of us really works from statistics.  If we did we would be much more worried getting on a bicycle than getting on a plane.  It could well be that the media will pick up on what are really minor differences and blow them out of all proportion.

If so, formulators might well decide that they need to make things as unlikely to provoke a skin reaction as possible.  How will they do that?  Well I know the first thing I would do.  If you want to avoid complaints about skin reactions there is only one choice of preservative.  The currently much maligned parabens will be first choice again. That was always one of the main reasons they were so popular.  I have a feeling that isn’t what the people who campaign for more cosmetic legislation were intending.