SECURITY ADVISER VS SECURITY ASSESSOR – The Regulation 1223/2009 The regulation on cosmetic products introduces a requirement to provide specific, assessed information to ensure they are safe to use. Therefore, it is necessary to have certain toxicological knowledge, which will enable us to establish the optimal criteria for collecting and evaluating such information. It is therefore advisable to have a expert who can advise on its content and, if necessary, carry out an assessment of it.
The new Cosmetics Regulation refers to two parties: the first – whether a natural or legal person – is the «Person in charge«, which will ensure compliance with the relevant requirements set out in the aforementioned Regulation. And the second – physical – the «Safety assessor«, responsible for assessing the safety of the cosmetic product on the basis of the information provided, in accordance with Part A of Annex I.
Following the publication of the Regulation, a considerable number of discussion forums have sprung up. In some of them, there is talk of «Security adviser» to refer to the «Safety assessor«An adviser is someone who advises, that is to say, someone who gives advice. Whereas an assessor is someone who assesses, that is to say, someone who estimates, evaluates or calculates the value of something. In this case, the safety report for a cosmetic product, provided by the person responsible. It is likely that the confusion between ‘adviser’ and ‘evaluator’ may stem from an error in the translation of the English term adviser by «adviser». In any case, it is advisable always to refer to the term used in the text of the Regulation. This is none other than ‘assessor’, when referring to the person who assesses the information referred to in Part A of Annex I.
What, in our case, is a safety adviser?
An adviser is someone who can offer advice on the strategy that should be followed in order to deal with the information that is to form the Safety report of a cosmetic product, prior to its placing on the market. The Regulation 1223/2009 on Cosmetic Products has introduced a series of requirements, including toxicological basis, in order to achieve a high level of protection for human health. This has represented a new development in the world of cosmetics, which requires a range of technical and toxicological knowledge. Acquiring this knowledge, in turn, requires a certain amount of time spent on theoretical and, above all, practical training. In many cases, this period will be longer than the timeframe before the Regulation comes into full force. To resolve this issue, the person responsible may need to engage the services of an expert to advise them on these matters.
And what about the formulator of a cosmetic product?
Traditionally, the formulator has played a key role in bringing a cosmetic product to market. It is the formulator who, by interpreting market requirements, designs the cosmetic product, always guided by criteria of safety and efficacy. Formulators have a thorough understanding of the ingredients used in cosmetics, their properties, incompatibilities and any risks they may pose. Indeed, thousands of cosmetic products have been designed and used without, to date, posing any health risks. One of the two objectives of the Regulation is to achieve a a high level of protection for human health. Consequently, it has made it compulsory to collect certain information relating to the safety of a cosmetic product and its subsequent assessment.
Whilst the formulator is able to design a safe cosmetic product, sometimes, due to a lack of technical knowledge of toxicology, is unable to establish criteria for standardising the procedure. In this case, a security adviser It can be very useful for assessing the extent of potential risks and establishing the criteria for weighing them up, whether based on literature data or on the results of specific studies.
We might ask ourselves the following question:
Can the same person act as both an adviser and an assessor?
The answer is that not only can they, but it is also advisable that they do so. The assessor must have extensive toxicological knowledge regarding the application of topical products in general and cosmetic products in particular. Furthermore, they must be familiar with the Regulation. For this reason, they must also be qualified to advise on the adequacy of the information required to ensure a high level of protection for human health when using cosmetic products.
Conclusions
In view of the above, given that the Cosmetics Regulation requires us to have certain assessed information on the safety of cosmetic products – both those already on the market and those to be placed on the market from the date of the Regulation’s full entry into force – it would be advisable to have an expert who can advise on the aforementioned information, or even provide it, and who can assess it once it has been compiled.
Would you like more information about safety advice and assessment for your cosmetic products? Do not hesitate to contact us to seek expert advice. Our proposal? Solutions!
- The Expert opinion was written in 2012 for the former GTF M. Camps website. And it coincided with a context of doubts regarding the interpretation of Regulation (EC) No 1223/2009 on cosmetic products. Today, these issues are still of great relevance for the cosmetics sector.