totalshavingsolution.com

Andrea · July 5, 2004, 1:55am

From a reader:

<blockquote>quote:<hr />The following website promotes a product that
claims to make shaving easier and reduce most
if not all problems the average shaver experiences.

www.totalshavingsolution.com <http://www.totalshavingsolution.com>
www.totalshavingsolution.nu <http://www.totalshavingsolution.nu>

However, my husband tried it and a couple of
days later he experienced skipped heartbeats.
He stopped using it and the skipping stopped.

About six months later, he tried it again. And
the same thing happened. Naturally, he will
never use it again. Although it has never bothered
me that way, I am not particularly keen on its
aroma, but that dissipates within an hour. Still,
without knowing the ingredients, I am now a
little leary of using this product. The company
refuses to list any of its ingredients.

Are companies legally allowed not to list
ingredients? What if it has peanut oil and someone
is allergic to peanut oil?

Do you have any information on this company?
All I have found out is what their website says. <hr /></blockquote>It is unlikely that a response to a topical product would be delayed like that, but you do raise an important point about products that do not list ingredients. Most of these are “mom and pop” places that are under the radar of the US Food & Drug Administration (FDA), which regulates products of this sort.

One problem with certain products that are not sold as drugs, but as cosmetics, is that they are not always required to list ingredients. As you note, some of the oils used may be types that cause allergic reactions.

I don’t have any further information on this company at this time. If you wish to pursue this further, I can give you contact information for FDA.

Take care,
Andrea

Andrea · July 6, 2004, 7:33am

Here is how to contact FDA about a cosmetic (there are different places for medical devices):

http://www.fda.gov/opacom/backgrounders/problem.html

Here is the relevant regulation for cosmetics of the sort you purchased:

Cosmetics produced or distributed for retail sale to consumers for their personal care are required to bear an ingredient declaration (21 CFR 701.3). Cosmetics not customarily distributed for retail sale, e.g., hair preparations or make-up products used by professionals on customers at their establishments and skin cleansing or emollient creams used by persons at their places of work, are exempt from this requirement provided these products are not also sold to consumers at professional establishments or workplaces for their consumption at home.

The ingredient declaration must be conspicuous so that it is likely to be read at the time of purchase. It may appear on any information panel of the package, i.e., the folding carton, box wrapping if the immediate container is so packaged, and may also appear on a firmly affixed tag, tape or card. The letters must not be less than 1/16 of an inch in height (21 CFR 701.3 (b)). If the total package surface available to bear labeling is less than 12 square inches, the letters must not be less than 1/32 of an inch in height (21 CFR 701.3§). Off-package ingredient labeling is permitted if the cosmetic is held in tightly compartmented trays or racks, it is not enclosed in a folding carton, and the package surface area is less than 12 square inches (21 CFR 701.3(i)).

The ingredients must be declared in descending order of predominance. Color additives (21 CFR 701.3(f)(3)) and ingredients present at one percent or less (21 CFR 701.3(f)(2)) may be declared without regard for predominance. The ingredients must be identified by the names established or adopted by regulation (21 CFR 701.3©); those accepted by the FDA as exempt from public disclosure may be stated as “and other ingredients” (21 CFR 701.3(a)).

Cosmetics which are also drugs must first identify the drug ingredient(s) as “active ingredient(s)” before listing the cosmetic ingredients (21 CFR 701.3(d)).

All label statements required by regulation must be in the English language and must be placed on the label or labeling with such prominence and conspicuousness that they are readily noticed and understood by consumers under customary conditions of purchase (21 CFR 701.2).