Cosmetic Testing, Safety And Efficacy - Ontarioscc

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Cosmetic Testing, Safety and EfficacySCC Ontario April 6, 2016

Objectives Safety Testing TodayToday’ss standard Associated claims Efficacy testing Industry standard methodology Industry Standard instrumentation Studyy designg US regulatory NAD FTC What makes a good study Study responsibilities

Cosmetic Safety Testing Today In 1991 the CTFA published safety testing guidelines. Updated March 2007. Cosmetic IngredientgReview ppanel establishes ggenerallyyrecognized as safe (GRAS) ingredients. Testing new and existing products consisting of GRASingredients still needs to be performed. When developing a safety profile, the type of application andllengthh off contact withi h theh bodyb d must beb considered.id d

Cosmetic Safety TestingToday safety standard A cosmetic product shall be “generally recognized as safe”. There is no FDA safety standard for cosmetic products within the act. In the Federal Register of March 3, 1975 (40 FR 8912 at 8916), FDA advisedthat "the safety of a product can be adequately substantiated through (a)reliance on already available toxicological test data on individual ingredientsand on product formulations that are similar in composition to the particularcosmetic, and (b) performance of any additional toxicological and other teststhat are appropriate in light of such existing data and information. Althoughsatisfactory toxicological data may exist for each ingredient of a cosmeticproduct, it will still be necessary to conduct some toxicological testing withthe complete formulation to assure adequately the safety of the finishedcosmetic.cosmetic." CIR review of ingredients Voluntaryy Cosmetic RegistrationgProgramg(VCRP)() Voluntary reporting of serious adverse events (SAE)

Cosmetic Safety Testing Today Preclinical Testing Toxicity Tox Risk Assessment (TRA)In VitroIn-Vitro Dermal irritancy Skin culture techniques MTT Assay Biomarkers PLA2PLA2, prostaglandins and interleukinsNon skin vegetable based protein disassociation tests IRRITECTION Skintex

Cosmetic Safety Testing Today Ocular irritancy HET CAM assayTissueicultureltechniquesh i Non tissue vegetable based protein disassociation tests MTT AssayBiomarkers PLA2PLA2, prostaglandins and interleukinsIRRITECTION EytexNon-animal preclinical testing Mutagenicity (Ames)Microbiological APE

Cosmetic Safety Testing TodayThe Human Repeated Insult Patch Test (HRIPT) is the most popular safety test used today. It consists of thefollowing steps:Induction phase involves the repetitive application of a testmaterial under an adhesive patch unit, for at least 9, over aperiodi d off consecutiveti weeks.k TheTh patchest h are appliedli d totthe same skin site on 50, 100, 200 or more subjects definedas “normal” individuals.Rest or incubation phase. During this phase no furtherpatches are applied, for a period of approximately twoweeks.Challenge phase is the application of one patch, usually toa previously unpatched “virgin” site.The strength of this test is its ability to predict irritationand allergic response.

Cosmetic Safety Testing Today In-Use Studies: The product would be tested inuse or exaggeratedd use conditions.di iEvaluationE l iconducted by physician, trained evaluator or bythe test subject.subject Products containing known irritants Regime product groups HygieneHygiene products Pediatric products

Cosmetic Safety Testing Today Products to be used around the eye need specialconsideration. Children’s products need additional testing An ophthalmology in-use study should be considered.An in-use study monitored by a pediatrician should beconsidered.If any the ingredients are not GRAS, additionaltesting needs to be considered. A larger HRIPT PanelMultiple In-Vitro studies

Cosmetic Claims SupportClaims are made to: Persuade the consumer Stay competitive

Cosmetic Efficacy Claims Support A cosmetic claim is not a structure/function claim Efficacy Studies are used to validate claims Advertising is regulated by the Federal TradeCommission Efficacy claim on cosmetics labels must be supportedbyy valid (Industry(y Standards)) studies Validation studies must comply with industrystandards Labeling is regulated by the FDA Mandatory statements: ingredients, warnings, etcetera

Cosmetic Efficacy Claims Support Formulation Claims Contains Aloe Contains Honey “ A natural humectant” Oil Free Performance claims Hypoallergenic Dermatologistg Tested Ophthalmologist Tested Suitable for contact lens wearers Instantly boosts hydration levels by over X% In 2 weeks, consumers perceive a 74% decreasein fine lines and wrinkles Under most circumstances only performance claims need to bevalidated

Cosmetic Efficacy Claims SupportPerformance Claims Anti-agingAntiagingFine line and wrinkles((appearance)pp)Skin elasticitySkin firmnessAge spotsSkin textureM i i iMoisturizationHumectantcyBarrier functionFlaky skinSkin toneOil controlComedone control Skin elasticity Skin soothing claims SafeSafe for sensitive skin Reduce the appearance ofcellulite EvennessEoff skinki tonet

Cosmetic Efficacy Claims SupportPerformance Claims Hair product claimsBounceVolumeManageabilityColorColor fadeFrizz and split endsNail product claimsPeelingC kiCrackingStrengtheningSalon testing

Cosmetic Efficacy Claims SupportPerformance ClaimsClinical significance versus statistical significance Clinical significance: readily apparent the changesmade as a result of the products performance. Statistical significance: Does the data provide areal change, as tested by statistical methods, chisquared, t-test, ANOVA, SAS, etcetera. Regulators want to see both clinical and statisticalsignificant product benefits to substantiate a claim. Clinical photography is often used as an integralpart of proving, or documenting both statisticaland clinical significance

Cosmetic Efficacy Claims SupportPerformance ClaimsClaims can be substantiated, or validated using one orboth of the following ways Subjective Support “In two weeks consumers perceived a X% decrease in fine lines andwrinkles”“Long wearing”Sensoryy ClaimsCalibrated expert gradersObjective Support Bio-instrumentation Reduction of wrinkles by X%Calibrated expert graders Instantly boost hydration level by X%

Cosmetic Efficacy Claims SupportPerformance ClaimsClaims that can be substantiated by subjective methods SensorySensor Claims Consumer preference Odor and malodorStingFeelProduct A versus BTest pproduct versus the consumers “normal” productpSelf-perceived product benefits In-use questionnaire based studies

Cosmetic Efficacy Claims SupportPerformance ClaimsClaims that MUST be substantiated by objective methods Quantitative claims Wrinkle and fine line reductionFirmnessMoisturization Percentage increaseElasticitySki toneSkintSebum productionFlaking skin

Cosmetic Efficacy Claims Support MethodsAll efficacy studies for skincare products should bepperformed in an appropriatepp penvironmental room.

Cosmetic Efficacy Claims Support MethodsMoisturization Electrical conductance/capacitance Corneometer Novameter MoistureMeter Transepidermal water loss TEWL Meter Vapometerp Servomed Evaporimeter

Cosmetic Efficacy Claims Support MethodsWrinkle and fine line reductionPRIMOS 3D3D State of the art imaging system to quantify wrinkles and fine lines Competitive instrumentation, Foytes system Skin-Visiometer SV 600 CCompetitivetiti technologyt h l Image analysis of silicone replicas Calibrated expert grading

Cosmetic Efficacy Claims Support MethodsViscoelasticityVil ti it Suction/Torsion Cutometer Dermflex Twistometer Competitiveinstrumentation Balistometer Competitive technology Pinch/Recoil method

Cosmetic Efficacy Claims Support MethodsSkin Tone Measurements L*A*B* measurement instruments Minolta Chromameter IMS Smartprobe Datacolor Competitive instrumentation Digital photography with computercolor image analysis Competitive Technology Expert calibrated grading

Cosmetic Efficacy Claims Support MethodsClinical Photography VISIA CR PhotographicSys eSystem Charmview Digital MicroscopeS tSystemsEpiflash systems Epiflash

Study design Seasonality Study duration/number of visits How long will the product take to reach peak efficacy plusadd a bit more as a safety margin To ensure most of the panel reached peak efficacy Possible regressiong Volunteer population Number of subjects Statistical ppower computationp Industry standard Inclusion criteria Gender Ethnicity Age AnyAny desired medical condition Atopic Diabetic

Study design ExclusionExclusion criteria Interfering medication Inappropriate skin type DiseaseDior medicaldi l conditionditi Inability to follow instructions Methodology Instrumental Expert graders UsageUsage direction from the sponsor Optional questionnaire from the sponsor

Study designAnti-ageing Seasonality (Winter is cold and dry) Duration/numberDuration/number of visits How long will the product take to reach peak efficacy plus asafety margin Supplier data 8 weeks To ensure most of the panel reached peak efficacy Possible regression 12 week study, bassline, 6 and 12 weeks Volunteer population Number of subjects Statistical power computation, Two group 60each Industryy standard 30-35 subjectj in one or two groups?g p Inclusion criteria Gender Female Ethnicity All Age range 55-69 years of age Any medical condition Mild to moderate wrinkles

Study design Exclusion criteria Interfering medication InappropriateInappropriate skin type Disease skin or medical condition Inability to follow instructions Methodology Instrumental Moisturemeter (hydration) Elastometer (firmness/elasticity) PRIMOS 3D (fine lines and wrinkles) VISIA pphotos ((documentation)) Expert graders Yes (clinical relevance) Usage direction from the sponsor Yes Optional questionnaire from sponsor Yes

Study design VisitsRecruiting Sign informed consent Qualification Soap pickup for conditioningBaseline Requalification/Acceptance Product/instruction/diary Questionnaire Moisturemeter (hydration) Elastometer(firmness/elasticity) PRIMOS 3D (fine lines andwrinkles)i kl ) VISIA CR photos(documentation) Expert grading6 weeks Moisturemeter (hydration)El tt (firmness/elasticity)(fi/ l ti it ) Elastometer PRIMOS 3D (fine lines andwrinkles) VISIA photos (documentation) Expert grading12 week Questionnaire Moisturemeter (hydration) Elastometer (firmness/elasticity) PRIMOS 3D (fine lines andwrinkles) VISIA CR photos(documentation) Expert grading

Contents of a “Good” Study Good Designed Preapproved Protocol by Primary Investigator (PI) Sub-investigatorsSub investigators Study Sponsor Institutional Review Board Amendments if necessary Appropriate Subject Selection Number as based on biostatical power computations Type as defined in the inclusion/exclusion criteria in theprotocol CompliantpSubjectsj Study direction in the protocol Compliant with the clinics requirements Visits Medical history Informed Consent that is HIPAA compliant

Contents of a “Good” Study Appropriate Test Environment Temperature and Humidity controlled ProperProper lighting for visual grading Well written usage instruction Adequate amount of supplies/test material IndustryI d t standardt d d equipmentit forf objectivebj ti supportt Well trained qualified graders for Objective support Subjective Support A designed questionnaire (when used) ValidatedValidated if used a sole support for a claim A Quality assurance statement A Well Written Easy to Understand Report Including any deviations,deviations amendments,amendments adverse fromprotocol and impact statement form PI

Testing Organizations Responsibilities Fair and unbiased results Confidentiality Access to YOUR study The ability to audit at anytime, including duringth biophasethebi hoff YOUR study,t d announcedd ormore importantly unannounced When appropriate interim or “toptop line”line results Good and timely advice Industry standard methodologies

Study Sponsor’s Responsibilities Give clear directions to the testing facility To audit the study at the testing facility Read, understand and sign the protocol Bring the testing facility into the planning stage This will decrease your time to market and costly mistakes Understand that all claims made are yourresponsibility

Cosmetic Efficacy Claims Federal Trade Commission FTCNational Advertising Division of Better BusinessBureau (NAD)FDA labeling onlyNational Advertising Division and ERST of theBetter Business BureauInternational regulatory bodies have similarorganizations

Cosmetic Claims Validation NAD and FTC require that you are responsiblefor testing your own productIssue that arises frequently in NAD casesinvolves whether testing must be performed onthe Advertised ProductNAD does not have enforcement authority

Label Review

Label Review “Made with botanicaloils and herbs” Formulation claim Possible noncompliantpclaims Protective((OTC monographg pclaim) Penetration(Drug claim)

Label Review 24h Cellular energizer cream Not sure if this is a claim that cansubstantiated Improves Firmness Viscoelasticity study Cellular renewel Dansyl chloride cellular renewal study

Label Review “Anti-wrinkle” Claim may not be allowable by someregulators “Results in minutes” Wrinkle evaluation would need to conductedwithin minutes 3 powerful antianti-agingaging technologiestechnologies,GABA, Matrixyl 3000 and HyaluronicAcid ClaimCli cannot beb basedb d on theh additionddi i off rawmaterials on multiple ingredients and withoutappropriate footnote

Label Review “Detoxify”Detoxify I am not sure if this is a supportable claim “DrawsDraws out impurities I am not sure if this is a supportable claim “RestoresRestores lost minerals”minerals Could be a drug or supplement claim

Label Review “Renews skin” Dansyl chloride cellularrenewal studyPossibleibl drugdclaim,l i drugdclaim,l idrug claim, etcetera, etceteraand etcetera

Contact InformationCraig R.R WeissConsumer Product Testing Company, Inc.70 New Dutch LaneFairfield, NJ 07004PhoneFacsimileE mailE-mail(973) 808-7111(973) 244-7503crweiss@cptclabs comcrweiss@cptclabs.com

Cosmetic Safety Testing Today safety standard A cosmetic product shall be "generally recognized as safe". There is no FDA safety standard for cosmeticThere is no FDA safety standard for cosmetic products within the actproducts within the act. In the Federal Register of March 3, 1975 (40 FR 8912 at 8916), FDA advised

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