The FDA monitors cosmetics and make-up for safety, BEFORE  they hit consumer shelves. Learn how cosmetic safety legislation threatens to spur more recalls, and the proper recall planning can test your recall readiness.

In fact, since the business of creating and selling makeup became big business for YouTubers, influencers across the globe jumped on the trend. However, with a flood of imposter makeup palettes appearing for major makeup influencers like Jeffree Star, the U.S. Food and Drug Administration’s Safe Cosmetics and Personal Care Products Act of 2019 has been introduced into Congress, where it’s sitting in a House Subcommittee on Health.

This bill holds makeup companies accountable for a clean supply chain with transparent data and nontoxic ingredients. It allows the FDA to place bans on toxic chemical ingredients, require production facility registration, mandate reporting and recalls, and protect vulnerable populations, like infants, children, the elderly, and pregnant women. This means product recalls are heading for the cosmetics industry fast. Let’s look at what that means for you.

Cosmetics Health Concerns

Looking good has a cost. Cosmetics have a long line of potential health risks, including eye infections, bacterial skin infections, allergic reactions, fire hazards, and more. Much of it will come down to user error, but there are ingredients widely used in cosmetics that are known to cause cancer and other adverse health reactions. The American Cancer Society doesn’t maintain a specific list of ingredients for legal reasons, but it does explain more about how cosmetics are (and should be) regulated.

Both the ACA and FDA include perfumes, moisturizers, lipsticks, eye and face makeup, shampoo/conditioner, hair dye, toothpaste, deodorant, and nail polish among its list of cosmetics. Often the side effects of these products are short term and go away when the product is no longer used. However, sometimes more serious long-term effects (like cancer) can occur. In order to determine how, we need to perform clinical trials.

Studying the Problem

There’s little study done on these effects so far. For example, we don’t know the long-term effects of dying your hair regularly. Current legislation allows for testing of each individual ingredient, but the final product isn’t tested. This means the combinations of each ingredient causes unknown end reactions. Performing lab studies on many of these products will take 10 to 20 years or longer.

Animal testing of human cosmetics in labs isn’t looked upon favorably in the western world. This leaves companies to perform epidemiologic studies. These look at humans as a species in our natural environments. It’s unscientific, because humans aren’t living in closed environments, even during a global pandemic. However, using both lab-based and epidemiologic data, we have a general idea of the safety and efficacy of different cosmetics.

This gives the FDA information to work with to regulate the cosmetics market.

Bringing Safety to the Cosmetics Industry

Most cosmetics (and their ingredients) testing is done to determine short-term effects. If eyeliner causes eye irritation or foundation causes your skin to itch, that’s something scientists want to know immediately. However, even though the FDA requires safe cosmetics, it can’t require testing. Because it’s voluntary, the agency splits the difference by requiring untested cosmetics products to carry the label, “Warning – the safety of this product has not been determined.”

Retail cosmetics are required to have ingredients listed on the packaging, but free samples and professional products can avoid these labels. However, if any issues are found, the FDA can currently take one of four actions:

1. Request an injunction from federal court.

2. Ask U.S. Marshalls to seize products.

3. File criminal charges.

4. Block cosmetic imports.

In addition to these powers, the FDA can currently ask a company to perform a recall. The pending cosmetics legislation would change that to allow the FDA to mandate these recalls. Cosmetics manufacturers have been resistant, because of the associated costs of performing a recall. Thankfully, there’s a solution on the market.

Managing Recalls Safely and Efficiently

Managing a product recall is a resource-intensive process when done manually. Both customers and internal stakeholders need real-time access to every step of an organized workflow. Customers must be notified, recalled products must be tracked, and regulators need to be kept in the loop of reporting. This process can often take up to a year or longer, draining valuable resources in the process.

A joint study from the Food Marketing Institute and Grocery Manufacturers Association estimates recalls cost $10 million in direct costs, plus additional unquantifiable damage to brand equity and lost sales. These costs need to be mitigated through proper recall training and an organized, automated recall management workflow. That’s what Mock Recalls provides.

Meet MockRecalls

MockRecalls is a mock recall planning,training and consulting program to test your recall readiness. We are purely focused on protecting your product investment by working with you to create a new recall plan or analyze your current recall plan and then put it through a mock recall or recall simulation test to insure you are prepared for a possible product recall. We use our on-demand SaaS based recall management platform that eliminates common mistakes manually conducting recalls, by automating the most tedious steps of a product recall. It is a simple to use platform that just focuses on handling product recalls quickly and efficiently. Through our mock recall training using our dedicated recall platform, companies can improve the recall process, increase response rates, and document and communicate with all stakeholders.

Our program can analyze your company’s readiness in many of the typical elements of the recall process including:

  • Initiation, investigation, and communication process
  • Recall working team and decision team composition and dynamics
  • Team roles and responsibilities
  • Process flow and lot traceability
  • And retrieval capability and effectiveness checks

Our recall simulation program is conducted as an escalating model using real product facts and potential issues, with multiple inputs such as consumer complaints, social media, FDA/USDA/local health department and law enforcement. Conducting a recall simulation will also allow the recall team and all involved personnel to become familiar with their responsibilities throughout the recall procedure. This gives them time to effectively communicate any concerns about the plan while the company isn’t dealing with the pressure of an actual recall.

Looking to test your product recall readiness across your organization? MockRecalls will help create and/or test your recall program. Click here to learn more or call us!