Saturday, February 28, 2009

Room Perfume - Incense Warmer is a wonderful smoke-free way to add natural fragrance to your home or office

Natural Perfumers Guild member Katlyn Breene of Mermade Magickal Arts is the Supplier of this wonderful gadget that allows me to enjoy incense once again.

I'm very allergic to smoke. I used to smoke two packs a day and quit many years ago. I guess it was just overexposure to smoke that brought the allergy on. The first bad episode I remember was in the aftermath of Hurricane Andrew. They burned tons of debris for weeks on end, and started coughing, having respiratory problems and headaches. No - wait. I remember an earlier incident. In 1987 I was visiting my family up north and we went to a restaurant and there was smoking and I was "stuffed up" for a week. But the Andrew aftermath really got me good, and by that I mean bad.

During the mid-90's, I did some freelance PR work for music artists here in Miami, but by 98 or so I had to stop because they still allowed smoking in clubs and I just couldn't attend events I had planned and was hosting.

I still used stick incense occasionally, usually champaca. Sometimes I burned frankincense resin, cedarwood, sandalwood and other natural materials. I had to stop, because even with the ceiling fans to disperse the smoke, it was too much.

About eight years ago, David Oller gifted me with the most wondrous array of incenses (smokeless) and the Kodo bowl components to gently "smoulder" incense. The Japanese incense can be almost smokeless, and quite wondrous in scent quality, but I still had a problem, and my clumsy ways made tamping the makko and arranging the ceremony a bit of a laborious job.

So when Katlyn of Mermade joined the Natural Perfumers Guild and sent me samples of her gorgeous handmade natural incense, all I could do was hold them in my hand and sniff. I could tell they were lovely, but I couldn't release the scent because I didn't want to burn them and release smoke.

Then I found out that Katlyn offered an "incense warmer" that was guaranteed to release the incense, resin, essential oil, wood or other fragrant materials in a smoke-free manner. How exciting!

I believe Katlyn is the only US distributor of these great gadgets, and that she had them rewired and the thermostat tinkered with to make them more compatible to the US market. They definitely look like an piece of Indian technology, with a handle that makes carrying or moving a heated container easy, if also making it resemble a coffee cup. Hmmm.... maybe I should try to warm some coffee grounds and see how that works!

Katlyn provides instructions with it, and I found another friend who had one was being a bit careless, letting it "run" all night. It's not meant to be on constantly. The termostat will shut on and off to keep the temperature you select constant, but overuse is self-defeating as the fragrant materials become "spent" after a time.

Ross, the guru of Olfactory Rescue Service, found out I was getting one and kindly sent me a great selection of loose incense, some 'wet' incense, some sandalwood shavings and such. Waving back to Berkeley and saying thanks to Ross ;-)

After placing the foil liner in the top 'cup' I was ready to go. Oh! Beautiful scent filled my home in less than a minute! Just a small pinch of loose incense spread its aromatic magic to each corner of my home and a bit went out the front door. I kept the setting low, and when it looked dark brown, I shut it off. The scent lingered for an hour or more.

Next into the cup went a procession of fabulous stuff, including Katlyn's assortment of pressed incenses, hojari frankincense, myrrh, opopanax, David's stuff, a drop or two of essential oil, etc.

A few nights ago a friend came by before we went out to dinner and exclaimed at the gorgeous vibe given off by the scent the minute she walked in the front door. I had just turned on the warmer one minute previously, so that shows you how quickly it disperses scent.

Katlyn and Ross warn about putting the thermostat too high, and I have been good about that for the most part. If your hojari is bubbling, it's too high, and you'll destroy the top notes. I do have to turn it higher for some pressed incense and some resins and woods, but I'll get the system down soon.

I hope you will, too. The fragrant smokeless atmosphere I now enjoy is truly lovely and inspiring and I predict the wave of the future for incense and indoor fragrance for homes, salons, spas, offices, etc.

Friday, February 27, 2009

Anya's Garden Temple Perfume Featured in Sniffapalooza Magazine

The March 1, 2009 issue of Sniffapalooza Magazine features Anya's Garden Temple Perfume in the article Comforting Scents for Uncomfortable Times by Michelyn Camen, Senior Contributing Editor. Temple was created with the purpose of comforting and focusing people - particularly, but not limited to women - who had undergone a traumatic incident. I gave away 100 samples for those who asked for a sample because I felt it was just a good way to pay forward the comfort and security I had found from natural aromatics, friends and family.

The outpouring of intimate and touching stories that accompanied the request for samples humbled and also encouraged me I was on the right path with my concept. So, Temple, my first aromatherapy perfume was introduced to the world. Aromatherapy perfumes are created with a purpose, and the purpose is healing on some level, always.

Myself, I find Temple a bit overpowering to wear. The deep, narcotic Oud used in it overwhelms my nose, and instead I use it on a tissue, or in a bit of water in a tea light warmer, where it diffuses into the room and accomplishes what it is intended to do - soothe and relax. To others, Oud is the mother of all aromatics, the one that resonates to them on the deepest level. In it's own way, Oud works its magic, whether you can wear it or not. It is the "go-to" fragrance for strength, comfort and centering.

Thursday, February 26, 2009

Perfume and fragrance and body care business owners - don't be caught asleep at the wheel with the FDAGA2009 HR 759

You can't move forward in fear. You must be motivated and feel you have some power, some ability to change things, or effect a different outcome. The following blog is meant to erase fear and replace it with a sense of being awake and aware at the forces that shape our artful industry.

What is all means to me: I don't want any more government regulations that can limit my ability to conduct a safe, environmentally-friendly small business. "If it ain't broke, don't fix it."

If you have a small USA-based business that manufactures perfume, aromatherapy or body care products such as lotions, body butters, soaps (soaps with a claim of moisturizing or some other attribute beyond cleaning) and related products, the Federal Drug Administration's Global Harmonization Act of 2009 (FDAGA2009), currently in committee, but fast moving towards a vote into law, can pose problematic to you continuing your business. The requirements for testing, paperwork and personnel are overwhelming, and that will be written about in future blogs.

In today's blog I will be addressing one portion of the FDAGA2009, and I urge you to keep yourself informed on each and every issue as they are blogged about here and elsewhere, to check the FDA paper trail yourself, and most importantly, get active in protecting your small business against more government regulations being imposed. I'll share a cautionary tale that I keep at the forefront of my thoughts when new regulations are promoted. After this intro, I'll get into the topic for this blog, just one tiny section of the Good Manufacturing Practices (GMP) that the FDA is attempting to convert from voluntary to mandatory via registration.

A few years ago, shortly after I first blogged on the International Fragrance Association (IFRA) "guidelines" that morphed into European Union (EU) laws that resulted in the reformulation of classic perfumes and severely limited the ingredients used in modern perfumes, I spoke with a retired perfumer, a card-carrying member of the American Society of Perfumers. He had seen the industry fall in step, timidly, not challenging the ever-increasing laws from the EU. It didn't matter if your perfume company was in the USA, or if your revenues topped $100 million dollars a year, you capitulated.

Perfumistas on internet forums bemoan the fact that the classic chypres perfumes have been reformulated to a former shadow of themselves (oakmoss now severely restricted in blends, ditto for bergamot re: IFRA.) Or that classic colognes have lost all their lively, beautiful citrus topnotes (again, IFRA.)

After a long discussion, wherein the perfumer related a chronological litany of the avalanche of regulations that brought us to the point that you can get more orange oil on your hand peeling an orange than is allowed in a modern perfume, I asked "How did you let this happen?"

His simple reply:

"We were asleep at the wheel."

I will never be asleep at the wheel, and I hope you won't, either.

I've been blogging about the IFRA/EU and Globalization threats to our small businesses for two years now. Robert Tisserand and Tony Burfield and I worked on a Primer about the IFRA amendments and a FAQ in February 2007. We devoted about two months of our lives to that project, at the expense of our businesses. We almost burned out. Why? We're not asleep. The word did get out, but it's amazing how few people here in the States know about the threat. Wake up, folks, it's coming at you like a runaway train, and the IFRA/EU Globalization is now taken up by our FDA.

Now to the first bit of bad news regarding the FDAGA2009 - and I'll blog about the others, but just one small bite at a time.

Bear in mind these GMP guidelines have been law for some time now. Enrollment was voluntary. The FDAGA2009 now wants to make enrollment (registration) mandatory.

There is one guideline that might be very problematic if you're a one-person small business. Anya's Garden Perfumes has grown so that I now have a part-time bookkeeper and a part-time assistant, and since I am math-challenged, I have them check *everything*, not just weighing and measuring of raw materials. But what if you don't have folks like this? Also, how does the FDA define this second person? Full time employee? Your kid in high school - can he or she fill the role? Your partner who is not affiliated with the business but wants to help? The nexus of the definition of that second person is one thing we're trying to dig out.

But that's not the real point of this blog, it only illustrates how unfriendly the FDA is to small businesses. Why can't a reasonable, responsible business person be allowed to run a sole proprietorship just that way - solely? Could you hire or otherwise have someone on hand to meet the FDA GMP on Sec. 5.d?

The team of savvy, concerned, engaged folks I'm working with right now are trying to rush (the FDAGA2009 is being rushed through committee, heading for a vote) while being deliberate and poring over all of the Act, the GMPs, and the root definitions of all the guidelines.

In the next few weeks we'll be contacting cosmetic and food associations with our White Paper on this critical issue. We'll have a draft letter in place for the associations to distribute to their members, along with a link to contact your congressional representative. I'll have all the links here soon, so please check back.

And don't be caught asleep at the wheel, you owe it to your business and your artisan indie community - we need to have reasonable government to allow us to thrive.

Anya McCoy

Wednesday, February 18, 2009

The Architecture of the new Grasse International Perfume Museum

Many of us perfumers and perfume lovers have read about the opening of the refurbished International Perfume Museum in Grasse, France in October, 2008. There is a short, illustrated piece from Metropolis magazine that captures the theory and application behind the design, and for me, a former landscape architect who loves design as much as I love perfume, it transports me there, immediately. I am able to understand how and why the architect Fréd­éric Jung arrived at the final design. Here is a link to the article.

Monday, February 16, 2009

More to worry about - spread the word - hidden in the FDA Globalization Act 2009 HR 759

From the Farm Stand to the Farmers Market - if you make food or cosmetics, the FDA wants to change your way of life

I've been putting these mini updates on Twitter and Facebook to the neglect of my blog. I'm going to start posting them here, too. Spread the word, and look for a more in-depth post in a few days.

1. The way the FDAGA2009 is written - it reads like there are no fees now, but they can set fees in a year or two. At their discretion.

2. The FDAGA2009 revised - allows an exemption for foodie small businesses (to be given special consideration because they are a small business) but NO exemption for cosmetic small businesses! Big trouble looming. More later.

3. T
he FDAGA09 will allow the FDA to force registration of farm kitchen goods for sale. Up til now, it was the USDA. TWO Federal agencies in your kitchen?

All artisan, craft and indie associations we can find will be contacted about this. If you can spread the word to foodies - breadmakers, chocolatiers, folks with farm kitchens that sell locally, farmers markets, etc.

There is a lot of concern that folks have been lulled into a sense of security falsely - there is still a great threat to small business folk who make cosmetics (all body care products) and food items.

Book Review: Roja Dove's "The Essence of Perfume

Anya McCoy's review of "The Essence of Perfume" by Roja Dove has been published by Basenotes.

Sunday, February 08, 2009

Please spread this letter to all natural aromatics groups and blogs - EU-based bad science is once again gunning for natural aromatics

Hello Everyone:

For those of you who know me and know how long and how hard I have fought against the creeping over-regulation of natural aromatics, please be aware that here is a new threat: a thesis from a student who seems to be on track with the bad science and agenda of RIFM.

I hope you can perhaps give back to the natural aromatics community by paying attention to our fight against the US Food and Drug Administrations Global Harmonization Act of 2009, which is the way the EU anti-naturals, anti-small business agenda makers are getting their foot in the door of our government. It will mean the end of our businesses, and perhaps even the end of our access to natural oils for home use.

I've already posted this on the Natural Perfumers Guild blog and my blog, and I urge you to do the same if you have a blog, and also send it to relevant aromatherapy or perfumery groups you may be on.


Here is Tony's open letter - please spread it across the internet and if you can, work in any way possible to help turn back this bad science.

The Trouble With Theories About The Oxidation of Essential Oils.

by Tony Burfield Feb 2009.

Judging by the response from Cropwatch supporters, many of you may have already read about a doctoral thesis and remarks made by Lina Hagvall, distributed via the cosmetics trade press. Many professionals have found the reported remarks condescending, as we are well aware and may have a wider understanding of the context of oxidized aroma materials than the source of the remarks. But I digress. The thesis in question is entitled “Formation of skin sensitizers from fragrance terpenes via oxidative activation routes: Chemical analysis, structure elucidation”, and Katie Bird (Bird 2009) recently covered the story for Cosmetics Design Europe, although, as with any news knocking natural products, the article is being very widely circulated on websites dealing with health interest and other matters. Many of us have found the Bird-penned article makes for confusing reading: for example what is ‘geraniol oil’? A better recourse is maybe to download the thesis itself from the University of Gothenburg website at

You will then be able to gather that the thesis is primarily concerned with the consideration of substances without contact allergenic properties, but which can be activated either via autoxidation in contact with air, or via cutaneous metabolism, to reactive products which can cause contact allergy. Primarily the study looks a five published articles for which the author has had a major involvement, studying the oxidation of geraniol, geranial (a conformational isomer of citral), linalool, linalyl acetate & lavender oil. For convenience these articles are referenced below (Hagvall et al. 2007; Hagvall et al. undated; Hagvall et al. 2008; Skold et al. 2008; Hagvall et al. 2008a).

If I were one of Hagvall’s invigilators, I would have insisted on a re-write of a number of parts of the thesis, where the science as presented is dubious, incomplete or, most importantly, does not present an accurate overview of the topic. Some knowledge of industrial practices would have aided its general acceptability as well, and a collection of these points will constitute a future article from this author.

Overall this author is not saying that the elucidation of underlying mechanisms whereby oxidized essential oils, which may be the cause of type IV allergy and acute contact dermatitis, is not important. But an overview to enable to put this work in perspective is importantly missing. Further, the mention of Axel Schnuch’s work (Schnuch et al. 2007) is selective, and a major omission to include the toxicological reviews of Hostyneck & Maibach’s on geraniol & linalool (Hostyneck & Maibach 2007a; Hostyneck & Maibach) is almost unforgivable, however inconvenient their conclusions to Hagvall’s work.

The reader is thus left to form his/her own independent opinion on the relevance of the study, especially against a background of an increasing number of published studies on the anti-oxidative properties of essential oils, the declining concentrations & use of essential oils in fragrances generally, the use of cold-storage & nitrogen-blanketing (amongst other measures) to prevent the oxidative deterioration of stored essential oil and natural isolate ingredients, and the addition of anti-oxidants, UV-filters and stabilizers to finished fragrances & cosmetics to extend shelf-life One is also tempted to mention that a major contributor to the cost of the studies was RIFM, a primary instigator to the culture of toxicological imperialism which has overtaken the regulation of cosmetics/fragrances in the West.

How does this thesis change anything? The lack of evidence of a clear cause-effect relationship between geraniol and linalool and cases of allergic contact dermatitis has been previously emphasized by Hostyneck & Maibach (2004 & 2008), and Cropwatch would guess from its’ own experience that adverse end-user effects would tend to support the same conclusion for lavender oil. Hostyneck & Maibach (2008) also comment on the relative stability of linalool, its low oxidation rate kinetics and speculate negatively about how readily linalool would oxidize in fragrances & cosmetics, as well as low consumer exposure levels to the ingredients. Great store seems to have been put on the Hagvall thesis by IFRA/RIFM juggernaut, but considering the importance of the sensitiser issue to the perfumery trade, and its impact on the use of natural ingredients in perfumery, the sponsoring of just one researcher to look (mainly) at the oxidation of geraniol & lavender oil seems an exceptionally disproportionate response to the problem.

Unless of course you believe that RIFM sees the future of perfumery as entirely synthetic.

Cropwatch is trying to work towards the sponsorship of toxicological research which emphasises a risk/benefit approach towards the elucidation of the safety of natural products - otherwise we will all drown in a sea of over-cautious toxicological negativity, which, it is becoming clear, has little relevance in terms of safety risks presented to the general public from natural-product containing products.


Bird K. (2009) “Essential oils can become allergens on contact with air and skin, says researcher.” Cosmetics-Design Europe 5th Feb 2009.

Hagvall L. (2009) “Formation of skin sensitizers from fragrance terpenes via oxidative activation routes: Chemical analysis, structure elucidation.” PhD Thesis University of Gothenberg.

Hagvall L., Bäcktorp C., Svensson S., Nyman G., Börje A. & Karlberg A-T. (2007)

“Fragrance Compound Geraniol Forms Contact Allergens on Air Exposure. Identification and Quantification of Oxidation Products and Effect on Skin Sensitization.” Chem. Res.Toxicol. 20, 807-814.

Hagvall L., Börje A. & Karlberg A-T. (date unknown) “Autoxidation of Geranial.” (Unpublished?) Manuscript.

Hagvall L., Baron J. M., Börje A., Weidolf L., Merk H. & Karlberg A-T (2008) “Cytochrome P450 mediated activation of the fragrance compound geraniol forms potent contact allergens.” Toxicol. Appl. Pharmacol. 233, 308-313.

Hagvall L., Sköld M., Bråred-Christensson J., Börje A. & Karlberg, A.T. (2008a) “Lavender Oil Lacks Natural Protection Against Autoxidation, Forming Strong Contact Allergens on Air Exposure.” Contact Dermatitis 59, 143-150.

Hostyneck J.J. & Maibach H.I. (2004) “Is there evidence that geraniol causes allergic contact dermatitis?” Exogenous Dermatology 3(6), 318-331.

Hostyneck J.J. & Maibach H.I. (2008) “Allergic contact dermatitis to linalool.” Perf. & Flav. 33 (July 2008), 52-56.

Schnuch A., Uter W., Geier J, Lessmann H. & Frosch PJ. (2007) "Sensitization to 26 fragrances to be labelled according to current European regulation. Results of the IVDK and review of the literature." Contact Dermatitis 57(1), 1-10.

Sköld M., Hagvall L. & Karlberg A-T (2008).”Autoxidation of linalyl acetate, the main component of lavender

Thursday, February 05, 2009

So what if your perfume might stain? So does coffee, tea, red wine, etc.

Saffron stigmas

Saffron absolute, made from the stigmas of the Crocus sativa flower are prized in cookery because of the slightly bitter, aromatic flavor they impart to food. The thread-like stigmas also impart a shade of yellow to the food, ranging from pale to moderately orange-yellow. The color comes from the catetonoid content of the stigmas, the same coloring agent found in tomatoes. Like tomatoes, saffron can stain clothes if you drop some of that yummy risotto you've made with the stigmas onto your white shirt. Like tomato, the saffron stain is pretty stubborn to remove.

So, you are careful when you twirl the spaghetti on a fork, laden with marinara sauce, and you are careful when you lift the fork of saffron risotto to your lips.

You pretty much take the same care when drinking coffee, tea or wine - same staining power, different dye chemical. Still, the same idea. Just be careful so you can enjoy your meal or drink.

Over the years I've spoken with perfumers and even a distiller who bemoaned the fact that they can't figure out how to get around the saffron staining factor. I do recall someone saying at one time there might be a new process to eliminate the stain, but darned if I can remember who, or what the process was.

Boronia flowers

Thing is, caretinoids are responsible for a lot of the scent in saffron, and also in boronia, Boronia megastigma, a glorious golden floral absolute from Tasmania that will stain your clothes with as beautiful a ochre-colored spot as saffron. I adore the rare Boronia, with its yellow freesia-like topnotes and glorious wide-open airy spicy balsamic fragrance. (The golden bornonia is not to be confused with the more herbaceous green boronia.)

When I create custom perfumes for Anya's Garden Perfumes, most clients exclaim with delight when they smell bornonia during the evaluation process. I warn them about the staining factor, and they usually draw back, or crinkle their nose, like they smelled something nasty. This - just a moment after exclaiming it's so beautiful. I've always managed to get around the prejudice against staining by reminding them they're careful with coffee, tea, red wine, marinara sauce, curry sauce and similar stain-producing drink and foodstuffs. That is usually enough to win them over, the nose uncrinkles, they see the logic of my pro-boronia stance.

I was recently able to obtain a nice quantity of the Fall, 2008 boronia absolute from the AU producer. The boronia was made available only to Natural Perfumers Guild members when I rebottled it. Now, I am kind of surprised that the few dozen perfumers in the Guild who received the boronia haven't brought up the staining issue in our private Yahoo group. Oh, one did - he sent me a sample of his first mod, and it's glorious. He wrote that it's "not commercial" because of the staining.

Well, I think all that's needed is a little education. State on the website, label, and by other means that there is no reason to deny using a perfume containing this beautiful floral. Just treat it as if it's coffee, tea - well, you know the drill by now. Apply to the neck, wrists, hair, back of knees - just be careful.

I found that I love to spray or drop some on the collar or decolletage area of a dark-colored piece of clothing I'm wearing because the boronia is persistent, often lasting up to 24 hours. This is with straight boronia absolute, just diluted in alcohol. Any natural perfume will last a long time on cloth, or hair, and I've spritzed the boronia on my light blond hair without staining.

So just educate your customers and private clients, and well, why not do it over a nice glass of red wine or cup of coffee, if you can? The point will be very quickly and easily made.

Tuesday, February 03, 2009

The FDA Globalization Act of 2009 HR 759 is cause for alarm to all artisan businesspeople

What the FDAGA 2009 will do to the American artisan food of cosmetic businessperson

Do you make any body care or foodie product in the artisan manner? Artisan soap, artisan bread, artisan cheese, artisan perfume, etc? Don't let your guard down over the new "improved" Food and Drug Administration Act of 2009 (FDAGA2009). Please bookmark the links I'm providing here, you'll need them if you are an artisan. Also subscribe to this blog and others who are updating our efforts to understand (and in my case, fight) the FDAGA2009.

A big sigh of relief went out from many who had opposed the horrifying fees proposed in the Food and Drug Administration Act of 2008 were eliminated from the Food and Drug Administration Act of 2009. I agree, dropping the fee was a great act. I called Donna Maria of the Indie Beauty Network in early June of 2008, alarmed. I had blogged about it the month before, and knew it was trouble, but couldn't figure out just what the trouble was. Donna Maria asked me a lot of questions, such as "what committee is overseeing it, etc." but heck if I knew.

I just knew I had been warning about Globalization for two years and it was bad. I hadn't gotten my hands on the Act, but Donna Maria called me a few days later and by then she had gotten her hands on it and was alarmed. Folks went to Washington, I spoke with several key legislators, and I formed alliances with others who are taking a broader view and including food artisans, not just cosmetics folks. We'll announce our website soon, and in the meantime we have a great team of volunteers who are working with us.

If you're a foodie artisan reading this, please join our effort. Subscribe to this blog or write to me via my website and we'll get you on our outreach list. We have some volunteers who will be researching all the foodie organizations, guilds and associations we can find asap and reaching out to y'all.

Sure, the fees were waived for the cosmetics folks like myself who made a stink - but you foodies had no representatives who protested, so you'll still be hit with the fees, in addition to the stuff listed below. Your fee? $2,000 to $12,000 per year!

Basically, we believe the new, revised FDAGA2009 is a false, misleading and deceptive act. There are provisions written in FDAGA2009 that will prove a great burden on small artisan business, perhaps drowning them in paperwork at the very least, and putting them right out of business in the worst scenario.

Wake up, people, please - this is a Trojan Horse.

Don't roll over and accept the kumbaya - or you'll live to regret it. I'll be blogging about this frequently, and I urge others who are blogging on the FDAGA2009 to link up with me.

Look, I am the first to admit I am a dummy when it comes to really understanding legislative acts. They're boring to read, contain a lot of language I'm not familiar with, and relate back to other legislation - it's like following a hazy, crazy paper trail. But follow it you must. I have some savvy folks assisting me, one who has served on a lot of committees and another who has written legislation.

Ok, deep breath, let's plunge into the murky waters of FDAGA 2009:

1. The act requires registration, every year. Why be against registration, you ask? Isn't it responsible and something we should do if we are in business?

If you register, you must supply a list of your products, a list of the ingredients, and if you change an ingredient, you must inform them via update within 60 days. This means all your formulas will be public record, out there for an competitor to copy. (Technically, the law says it won't be available, but I'm skeptical.) The paperwork burden is tremendous. We're just small businesses. We've operated for decades, actually, hundreds of years without major incidents of public injury. Why the rush to get us all on the public record? American businesses have operated quite well so far, why fix what's not broken?

2. You'll have to adhere to the FDA Good Manufacturing Practices.

The GMP is written for companies the size and nature of pharmaceutical companies. The requirements are so stringent no indie artisan small business person I know can meet them.

You have to have your ingredients sussed out before use, and then after incorporation in a product. You have to have a paperwork trail of lot, batch and control number. Do you have any idea what this entails? Do you have any idea of the software and technical help needed to track this?

This costs a LOT of money - do you have it?

You know what this really means? You'll have to go to contract manufacturing. Contract manufacturing facilities have large minimums. Can you afford that? What if you produce organic or "all natural" products?

Make artisan cheese and can't meet the GMP requirements and have to send your milk and cultures to a big foodie contract manufacturer? That is what the GMP will cause.

Artisan chocolate maker? Good luck keeping your product up to your standards if it's in that hopper.

We will NOT be able to survive this government red tape - it will strangle our businesses.

We are planning to seek relief in the form of an exemption for small artisan businesses. Join us!

United we stand, divided we fall.