Understanding your product through the supply chain

Written on: November 1, 2023 by Nicholas Georges

When I worked in R&D, I was often asked how well I knew the products I was creating. I, of course, thought that I knew these products better than anyone else—I was the one making them, after all. I knew why I had chosen one ingredient over another, why I decided to use a particular concentration or how I determined that a specific order of addition was required to achieve the desired formulation.
However, the level of scrutiny surrounding the ingredients in a product (intentionally added or not) has significantly increased since I was in the lab almost a decade ago. Demand for more transparency from consumers, non-governmental organizations (NGOs), legislators and regulators has resulted in longer lists of chemicals of concern, which include more impurities and contaminants than intentionally-added compounds. In addition to longer lists, there have also been improvements to analytical instrumentation that allow for detection of parts-per-billion and even parts-per-trillion in some cases.
Even with this level of detection, it is nearly impossible for one company to know every detail about a product on its own. However, it is still the responsibility of each company to know what is in their product, and it is critical to work with the entire supply chain to discover this information. A thorough evaluation will help companies understand, not only what is being tested, but also what theoretical substances could be within various materials throughout the product’s life cycle, such as unintended reactions during manufacturing, interactions in the final package, potential sources of contamination or instability in the final product. Additionally, consideration of what substances could theoretically be in a product is more important now than ever because current analytical techniques will eventually advance to provide new intelligence.
Ultimately, this information will guide a company’s supplier choice(s), specifications or analytical capabilities beyond the traditional pricing and capacity considerations. Today, these are important factors to consider because a company’s reputation or brand could be damaged by the presence of a chemical of concern.
Communication throughout the supply chain is even more critical for aerosols because of the potential difficulties in testing the finished product. Understanding the analytical instrumentation and its ability to detect a particular substance at low levels requires the expertise of analytical chemists who are trained on each specific instrument and type of chemistry. While spraying an aerosol product is easy and convenient for consumers and workers, it is not that simple for analytical testing purposes, which is why such a high-level of expertise is required. The tester needs to understand the chemistry within the product, whether the analyte is in the concentrate or the propellant, and the packaging. Depending on the situation, different methodologies must be employed for the sample preparation and be compatible with the analytical instrument. I don’t want to oversimplify the testing of raw materials; however, most ingredients and components are easier to analyze that a finished aerosol product.
We’ve all heard about a time (or been in the situation ourselves) when a chemical of concern has been found in a product. Asking the right questions is key:
• Was the chemical present in the formulation or the packaging?
• Is the chemical in all lots of the product?
• Is the chemical present, but at differing levels than reported?
• Were the samples prepared and properly analyzed using a validated method?
The answers to these questions will be ready and available if there is communication and collaboration across the supply chain. Product manufacturers must be informed at every step of the way, understanding everything from analytical capabilities to their vendor’s compliance to what could theoretically be within a material.
At the end of the day, the finished aerosol product manufacturer is responsible for what is in the container, so it’s important to do your due diligence! Understanding the latest information on chemicals of concern, including how they are being tested, is at the top of the list. Otherwise, how will you respond if a third party tests your product and claims the presence of a chemical of concern?
How well do you know your product? Would you be comfortable answering challenging questions from regulators or if subpoenaed?  If you don’t already know, this is your sign to contact your supply chains to ask how they test for chemcials of concern.
For more information, please contact me at ngeorges@thehcpa.org. SPRAY