Professional Documents
Culture Documents
Functional Ingredient Solutions
Functional Ingredient Solutions
Product Name:
Tiddley Pom Organic Massage Oil 50ml1
Product Code:
CU000375281
Product Name:
Tiddley Pom Organic Massage Oil 150ml
Product Code:
CU00068642
Responsible Person:
Tiddley Pom Ltd, 15 Rose Hill, Dorking, Surrey, RH4 2ED,
UK.
1 – Tiddley Pom Organic Baby Massage Experience (Product Code CU00068643) is
a “gift set” containing the products below:
CONTENTS
Volume 1
A statement confirming the name and place of manufacture
A statement confirming compliance with good manufacturing practice (GMP) and referring to
a description of the method of manufacturing
A statement confirming that no animal testing is performed by the manufacturer, his agents
or suppliers, relating to the safety of this product
Stability
Packaging Information
Allergens Declaration
IFRA Statement
Volume 2
Cosmetic Product Safety Assessment and Cosmetic Product Safety Report according to
Regulation (EC) No. 1223/2009
VOLUME 1
Name and Place of Manufacture
The products are manufactured at:
Inovia International, Unit 11, King’s Cliffe Industrial Estate, Wansford, Peterborough,
Cambridgeshire, PE8 6PB.
It is also confirmed that no animal testing is carried out via third parties on behalf of
the company.
Physical/Chemical Characteristics
The raw material specifications and the finished product specifications are held on
file at Inovia International.
Stability
The stability of the product is acceptable.
Tiddley Pom Organic Massage Oil 50ml and 150ml is a single ingredient (100%
sunflower oil). Certificates of analysis for each batch, that show the production date
and the expiry date, are held on file at Inovia International.
Packaging Information
Packaging Information is held on file at Inovia International.
Allergens Declarations
Tiddley Pom Organic Massage Oil 50ml and 150ml is a single ingredient (100%
sunflower oil) and the product contains no allergens.
IFRA Statement
Tiddley Pom Organic Massage Oil 50ml and 150ml is a single ingredient (100%
sunflower oil). According to the IFRA Standards, sunflower oil is not restricted.
Artwork PDF file name “Box_Step 2__Organic Massage Oil 150ml - CU00068642”
Artwork PDF file name “Label_Step 2_Organic Massage Oil_150ml - CU00068642”
Artwork PDF file name “TP Gift Set - Tiddley Pom_4 Step Massage_Box_Base -
CU00068643”
Artwork PDF file name “TP Gift Set - Tiddley Pom_4 Step Massage_Box_Top -
CU00068643”
Artwork PDF file name “TP Gift Set Labels_Step 1-2-3_50ml - CU00068643”
……………………………
Technical and Regulatory Department
For Inovia International
17th March 2014
VOLUME 2
SAFETY ASSESSMENT/
CONSUMER PRODUCT SAFETY REPORT
REVIEW OF INGREDIENTS
All of the ingredients have a history of use in cosmetic and toiletry products.
Ingredients that are:
1
• Prohibited under EU Cosmetics Regulations
• Restricted when used beyond the allowed authorised conditions
• With toxicological data incompatible with the intended concentration and
use
• Which have insufficient toxicological data nor safety in use experience
• Which are not properly characterised with regard to purity and analytical
composition are excluded.
ASSESSMENT
This is a leave-on product for application to infant whole body as a skin protectant
and moisturiser.
The product may reasonably be typically used up to 1-2 times daily as required,
Ingredients are listed below. Detailed information on the safety and toxicology of
ingredients is presented below.
The above ingredients have been reviewed for potential to be skin irritants,
sensitisers or photo-sensitisers.
Where data is available for systemic and sub-chronic toxicity this has been taken
into account.
A review of the literature and of the structural chemistry has been made for each
ingredient to estimate the likely potential for genotoxicity, reproductive effects and
carcinogenicity.
No animal testing has been conducted on this formulation. All safety data is taken
from existing published sources.
2
EXPOSURE TO THE PRODUCT/ EXPOSURE TO THE SUBSTANCES
MARGINS OF SAFETY
Data for Estimated daily exposure levels is taken from the current Colipa data as
presented in THE SCCS NOTES OF GUIDANCE, FOR THE TESTING OF
COSMETIC INGREDIENTS AND THEIR SAFETY EVALUATION, 8th REVISION,
2012.
Table 3: Estimated daily exposure levels for different cosmetic product types according
to Colipa data [SCCNFP/0321/02; Hall et al. 2007, 2011].
3
1 The retention factor was introduced by the SCCNFP to take into account rinsing off and dilution of
finished products by application on wet skin or hair (e.g. shower gels, shampoos, …)
[SCCNFP/0321/00]
It was concluded that all ingredients, when considered both individually and
in combination have an adequate Margin of Safety, ie > 100.
PHYSICAL/CHEMICAL CHARACTERISTICS
The raw material Specifications and the Finished Product Specification are
provided. It is considered that all Specifications meet good standards for safe use
of this product.
See Appendix
All raw materials are from reputable sources of supply and are considered to meet
current standards of purity and quality.
The physical and chemical properties and microbiological of the raw materials
have been reviewed. It is noted that all are to current standards and there are no
banned or restricted materials present.
The Molecular formulae for defined chemical substances are as recorded in the
current Edition of ICID.
Manufacturers Material data sheets/ Certificates are Appended
The raw materials meet current good standards for quality and purity.
Manufacturers Material data sheets/ Certificates are presented in Appendix.
STABILITY
The product is deemed stable under normal and foreseeable conditions of use.
Stability data is summarised in Appendix.
MICROBIAL QUALITY
INGREDIENTS
It is a requirement that all raw materials/ ingredients meet a microbial quality of <
100 cfu/ gram for Infant products
4
FINSHED PRODUCT
It is a requirement that the Finished Product meets a microbial quality of < 100 cfu/
gram for Infant products and zero harmfuls.
PACKAGING
The above formulation is based on known ingredients with history of safe use in
cosmetic products.
The product is considered to be protected from microbial growth.
It is noted that all ingredients are used within limits as specified in the cosmetics
Directive.
The microbial content (Total Viable Count) at time of manufacture must be within
recognised limits (nmt 1000cfu and zero harmfuls /gm).
5
INGREDIENT TOXICOLOGY PROFILE & SAFETY REVIEW
CAS: 8001-21-6
EINECS: 232-273-9
Sunflower seed oil is a vegetable oil with a safety and toxicity profile similar to
vegetable oil and as described below. The fatty acid profile includes linoleic acid
(63%), oleic acid (23%) and palmitic acid (6%) as the major fatty acids. In common
with other vegetable oils this is a blend of C16-C18 triglycerides.
Limited formal safety data is available since this is a GRAS substance (Generally
Regarded As Safe).
A human repeat insult patch test on vegetable oil on 88 subjects gave no signs of
irritation or sensitisation. The fatty acid profile of Sunflower oil is similar to that of
Coconut oil and Palm oil, and the safety of these oils is relevant to Sunflower oil.
Coconut oil is the subject of a CIR monograph (2010) and of a review in JACT
(1986). It is reported non-irritant to skin and eyes in animals nor is it a sensitiser.
There was no indication that products containing coconut oil were phototoxic nor
were primary irritants.
Palm oil is the subject of a CIR monograph (2010) also shows no adverse toxicity.
The oral LD50 in rats is low at >5g/kg. Short term and sub-chronic feeding studies
showed no evidence of toxicity.
In summary this ingredient is considered to be safe as used in this formulation.
6
Accidental Oral Ingestion
The potential of accidental oral ingestion is related to the problem that infants and
children are recognised to eat or drink cosmetic products. It is therefore important
that product formulations have a very low potential for acute toxic effects especially
in infants where the bodyweight is much less than an adult.
Based on the known acute toxicity to rodents of the components of the formulation,
it is estimated that the formulation will have an LD50 of >10gm/kg bodyweight.
This would indicate a very low order of acute oral toxicity. An infant aged 1 year
and typically of weight 10kg, would not be harmed by oral ingestion of 100 gm of
baby massage oil. The potential for systemic adverse effects has been considered.
Ingredients that have the potential for intestinal absorption are readily metabolised
and excreted and are not considered likely to have systemic toxic effects.
Consideration has been given to the potential for dermal penetration of the
ingredients of the formulation.
It is recognised that infants are not the same as small adults in assessing the
safety and toxicity potential of materials. In particular the infant has a much greater
surface area/ bodyweight ratio than an adult, resulting in a greater potential for
systemic toxicity.
It is recognised that pre-term (premature) infants have the potential for greater
dermal penetration of any cosmetic ingredient as a result of thinner and immature
skin. In addition, although the skin permeability of full-term infants is essentially
identical to that of adults, occlusion of the scrotum in males and of damaged skin in
the diaper area, may have the potential to increase dermal absorption of certain
cosmetic ingredients.
It is considered that the ingredients are readily metabolised where there is dermal
absorption and are not likely to have adverse systemic toxicity.
This assessment includes a review of the likely irritancy and sensitisation potential
of each of the ingredients of the formulation. It is considered that there is an
extremely low potential for dermal irritancy or allergenicity.
It can therefore be concluded that the formulation is safe for the intended use and
that there is no significant risk of irritancy or allergy.
7
PART A SAFETY SUMMARY
In reviewing the safety and toxicity profile of the ingredients used and their history
of safe use, it is concluded that there are no likely safety hazards from normal use
of this product and when used as directed or from foreseeable conditions of
misuse.
PART B
SUMMARY
Reasoning:
This Assessment has considered the safety and toxicological profile of all raw
materials and any trace components present. Consideration has been given to
parameters of weight of evidence (particularly for long established materials) and
also published toxicity data for NOAEL’s allowing calculations of Margins of Safety,
based on established use of the product. Margins of Safety have been calculated
to confirm safety from a systemic aspect.
Assessment for local effects, including skin and eye irritation, dermal sensitization
and photoallergenicity was evaluated based on established safe use for dermal
safety, derived from manufacturers data, and data published by CIR and also in
the public domain.
Assessment for systemic effects including target organ toxicity, effects on maternal
and reproductive toxicity and a review of genotoxic and carcinogenic safety was
evaluated based on established safe use and from manufacturers data, and data
published by CIR and also in the public domain.
Established use and consumer exposure is derived from data produced by SCCS
in Notes of Guidance.
8
The above formulation is based on known ingredients with history of safe use in
cosmetic products.
The Assessment has considered the safety of the individual ingredients both
separately and in combination to produce the final formulation.
A review of the data relating to raw material purity indicates that all materials and
packaging have a satisfactory physical and chemical profile. There are no
unacceptable levels of prohibited substances or impurities.
Conclusion
In reviewing the safety and toxicity profile of the ingredients and their history of
safe use, raw material standards and labelling, it is concluded that there are no
likely safety hazards from normal use of this product and when used as directed or
from foreseeable conditions of misuse.
Safety Assessor
9
The Elms ! Oxford Rd ! Chieveley ! Newbury ! RG20 8RT! United Kingdom
Telephone: +44 1635 248830 Fax: +44 1635 247206
Email: innova47@aol.com
JOHN HOPKINS
CURRICULUM VITAE
Academic Qualifications.
Membership of Societies
Relevant Experience
1
1976-1999. Employed by Johnson and Johnson.
Several positions from Toxicology head, Head of Medical Dept, and
R&D Director in UK and Director in the USA.
At Johnson & Johnson, was responsible for safety of both medical devices
and skin and hair care products in the European business. Developed
methods for cell culture evaluation of shampoo and detergent products as an
alternative to the rabbit eye test.
Also cell culture methods for safety evaluation of implantable medical devices.
Developed methods for safety evaluation of bone repair plates, carbon fibre
and polyester ligament repair systems, prior to human clinical studies.
In positions of Research Director in Johnson & Johnson, was responsible for
new product development for both adult and infant care areas of business.
PUBLICATIONS
Hopkins J and Tudhope GR. The effects of Drugs on erythrocytes in vitro. Brit.
J. Clin. Pharmac. 1:191 (1974)
Hopkins J. Baby Powder- exploring the Myths and Realities. Brit.J. Midwifery
9 (9) 545-547 (2001).
2
Hopkins J. The safe and effective use of baby powder. RCM Midwives Journal
4 (9) 285-286 (2001).
Hopkins J., Baby Powder – Dusting off the Myths. Chemist & Druggist, 15th
Dec 2001. pp 32-33 (2001)
Hopkins J. The Safe use of Fragrance in Cosmetics. Chemist & Druggist, 3rd
August.2002, p 30 (2002).
PUBLISHED PROCEEDINGS
PATENTS
Application filed 1998: Composition for the Treatment of Prickly Heat Rash in
Infants.
Application filed 1999: Composition for a body wash with skin moisturising
benefits.
Johnson & Johnson Skin Care Symposium, New Brunswick, USA. Role of
Zinc oxide in the treatment of Nappy rash, studies in a rat model and human
infant evaluation (poster). Hopkins J. 1994.
3
European Soc. Dermatology. June 1999, London. Efficacy of the association
of retinol and lactose and hydroxy acid on the signs of skin ageing. Clinical
study with comparison to placebo (poster). Bertin C, Hopkins J.
Congress of the Polish Neonatal Society, Mikolajaki, Poland, 2001. Infant Skin
and its special caring needs (lecture). Hopkins J. 2001.
Member of Colipa Zinc Oxide task force to present safety data and support to
European Commission SCCNFP for continued use of zinc oxide in skin care
products (1999-2004).