3/17/03

This is a follow up statement from David Bronner. David is currently serving on a committee of the Organic Trade Association to recomend standards to the USDA (which regulates the term Organic).

Subject: Substantive Comments on Real Body Care Ingredients

Hello All:

Regarding the productive discussion regarding permitted processes and ingredients, I'd like to propose broad categories for the various reaction products and processes Tim Kapsner and all generated based on simplicity versus complexity of manufacture, and agricultural versus non-agricultural reagents.

However, before I begin, I'd like to request that Tim Kapsner and others post out what are common reactions in food products currently designated as "organic". i.e. baked goods, like bread, and others. My take is that such reactions happen with whole relatively unprocessed agricultural ingredient recipes by at most heat, pressure and/or time, without additional non-agricultural reagents that substantively end up in the reaction product (versus processing/catalyzing aids). Any reaction or reagents more complicated than what is currently permitted for foods should be given a "Made From Organic _____" designation in cosmetics.

I like that the initial criteria screen has screened out all petrochemical reagents and ingredients, but going forward now for each reaction process and resulting ingredients, I'd like to see people post out exactly what toxicity issues there are in both the intended reaction product, the reagents and catalysts, and any potential trace side-reaction products. I.e. ethoxylation of fatty alcohols produces 1,4 dioxin in trace amounts; however, this is a non-issue as ethoxylation is already disqualified because ethylene oxide is petroleum derived. I would also like people to post out on any environmental toxicity issues or poor biodegradability issues for any particular ingredient, reaction process, and associated reagents and catalysts. I have heard there are concerns regarding estrogen mimicking effects of various substances that we need to look at in depth. Note that what we need now is particular information about particular substances and processes, not generalized unspecified concerns. The Soil Association references categories 1 and 2 of a Nordic Eco something or other list, and we should check that out in depth as well.

Anyway, regarding reaction and ingredient complexity, there are several categories to discuss. First, there is of course whole relatively unprocessed agricultural ingredients, such as fixed triglyceride oils and essential oils. Such ingredients should be denoted as "organic", and products made entirely from such ingredients consisting of 95% organic materials by non-water, non-salt weight should also be called "organic". These products are the creme de la creme of the organic ideal, and should be celebrated as such. Only products that are whole, self-preserving, utilizing only minimally processed whole ingredients should be able to call themselves "Organic ______". ANY formulation utilizing more complicated surfactant or preservative type ingredients, including soaps, should be AUTOMATICALLY required to have a "Made From" designation even if the product is over 95% organic; i.e. soaps can be "Made From Organic Oils", and not "Organic Soap."

Next, there is the category where something is derived from an agricultural material through a reaction process, but nothing added, as in the hydrolysis fat-splitting of whole triglyceride oils, which I believe is simply done with high pressure and temperatures, where the fatty acids are split from the glycerin, and then the fatty acids and glycerin are separated. The various fatty acids can be further fractionated through distillation by carbon chain length and degree of unsaturation (i.e. number of double bonds). The initial hydrolysis reaction is simply a heat and pressure reaction. However, the results of the hydrolysis reaction, glycerin and fatty acid, are chemically different than the fixed triglyceride oil from which they arose. Thus, this case is up in the air, and people should post their opinion on whether glycerin and fatty acids are: "Oleic Acid made from Organic Olive Oil" vs. "Organic Oleic Acid"; "Olive Fatty Acid made from Organic Olive Oil" vs. "Organic Olive Fatty Acid"; "Glycerin made from Organic Olive Oil" vs. "Organic Glycerin"; etc. etc. My personal preference is "Made From", as it notes the reaction/processing needed to achieve the ingredient. (Note that the ingredient listing would be unwieldy with all the "Made From" designations for each relevant ingredient, and the standard asterisk on ingredients should be used as is now the case for "Organic" in ingredients listing, with the asterisk note saying "Made From Organic _____" versus the usual "Organically Grown and Processed").

I'm going to digress here and deal with the animal versus plant origin issue. Animal fats are chemically the same as vegetable oils, and tallow (beef fat) produces much of the commercially available glycerin and fatty acids such as oleic. People should post their opinion whether certified organic animal sources are valid. The Soil Association made a strong requirement that ANY animal based ingredient had to be sourced from certified organic animal feedstock. I.e. NO conventional lanolin, animal glycerin, etc. can be used in a product making any organic claims. I think this is reasonable, given the host of hormones and anti-biotics involved in conventional factory farming, let alone the degree of suffering. (I am personally vegan, but recognize that animal production is covered under organic regs, and appreciate the quality of life standards organic regs require).

The next category would be for compounds that result from two agricultural products being reacted together, but without any additional non-agricultural reagents involved. This would be the case of esterification that Tim Kapsner talked about. Despite there being no non-agricultural reagent involved, I believe that the resulting chemical reaction product is very different from the agricultural reagent inputs, and should be designated as "made from Organic ______". I also remember Diana pointing out some trace toxic side reaction issues with esterification that I'd like to hear more about.

The final category are compounds produced from an agricultural product reacting with certain allowed non-agricultural reagents in various reaction processes (such as hydrogen, sulfates, sodium/potassium hydroxide, etc.). In the instance of soap, and to reassure Gay, the soap is essentially the "salt" of the acid-base reaction between the strong alkali and weak fatty acids of the triglyceride oil. The reaction products are soap, water and glycerin. No alkali remains. In fact, the soap is simply the sodium or potassium salt of a fatty acid, just like sodium chloride is the sodium salt of the chlorine ion. NO alkali remains, and it is useful to keep in mind that poisonous chlorine gas and explosive sodium can come together to form sodium chloride, table salt, which is completely innocuous. Making soap is one of the oldest and simplest reactions of humanity besides baking bread, and is straightforward and ecological versus more complicated detergent/surfactant manfucature. Nonetheless, I believe soap along with all more complicated ingredients should have a "made from" designation; not only because of the degree of change in the final reaction product, but also because non-agricultural reagents are being incorporated into the final product. Note that this would include hydrogenation (someone, I believe Peter, objected to hydrogenation on other grounds; I know I've heard bad things about hydrogenation in the food world; what are the issues?).

There is also the whole issue of preservation, which Tim Schaeffer alluded to. Tim is completely correct that formulations need to be adequately preserved with broad-spectrum effective agents. In the seventies, there were a number of instances of people going blind because of contaminated inadequately preserved shampoos infecting eyes. However, preservation ingredients are generally the worst culprits regarding provoking allergic reactions, and each have additional issues. At Dr. Bronner's, when I was reformulating our all-purpose hard-surface vegetable surfactant based cleaner (Sal Suds) five years ago, we finally gave up trying to find a preservative without issues, and simply made the product concentrated enough and at a high enough pH that it was self-preserving. A lot of work will have to be done in this area identifying the best of a bad lot, and is the farthest from the organic ideal of anything we have to deal with.

Anyway, I'm on the committee that has been formed that Tim Kapsner is chairing that will hash through these issues in more detail, but anyone with any concerns or ideas should post out generally about any particular ingredient, as I am far from expert in all the potential issues around various ingredients and processes. In fact, I think we should identify someone(s) who is such an expert from the environmental and consumer protection worlds and invite them onto this task force and committee.

A brief ending note about hydrosols in this context: none of the above matters at all if hydrosols are allowed, as there will be an enormous disincentive to source primary ingredients organically if label claims are permitted through the use of non-agricultural water. Again, hydrosols did not exist as an ingredient until companies started to use them for fluff claims, notwithstanding "therapeutic properties" (are there any peer-reviewed double-blind studies in reputable journals regarding hydrosols in rinse-off petroleum-based products someone would like to share?). Let's not make this effort a complete waste of time. If companies want, they can pay farmers directly some more money to help them out, but not so they then make a deceptive 70% label claim with non-agricultural water. Maybe a compromise is that companies can simply state the % hydrosol independent of the % non-water organic ingredient weight on their labels. This seems to be the solution that the Soil Association worked out.

Also, I call it like a I see it, and am not afraid to ruffle feathers. Ignoring reality is not helpful and has helped corrupt the marketplace. We are striving as hard as we can to ensure that the final result of this task force is something substantial that consumers trust. I imagine there are more than enough seconds to Mark Egide's motion, although I've not seen any. Phil, are we voting or not on my removal? If so, I vote I should stay.

Sincerely,

David Bronner
Dr. Bronner's Magic Soaps