The US Food and Drug Administration (FDA) has issued new draft industry guidance on Cosmetic Good Manufacturing Practices, so now is a good time to be reviewing your water system for compliance. In particular, the draft guidance states that the water used as a cosmetic ingredient should be of a defined quality standard and should be tested or monitored regularly to verify that it meets the standard set out in the guidance, in terms of chemical, physical and microbiological quality. Further, the water quality must not be affected by materials of construction used in the water treatment and distribution system. It should be engineered to avoid stagnation and risk of contamination, and to be routinely cleaned and sanitised to ensure that there is no biofilm build-up. Let’s look at these points in turn.
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