Opening Lines
Tackling Labels—Together
After a daylong cosmetic educational workshop on complicated FDA labeling regulations, I was exhausted. We had heard from FDA's OTC Compliance Team and the Independent Cosmetic Manufacturers & Distributors Inc.'s legal counsel, who addressed the over-the-counter (OTC) labeling final rule that goes into effect this May.
Just when I thought the session was about to wrap up, allowing us to digest all this information for a later day, we were asked to develop our own labels for cosmetic and cosmetic drug products. Assignments included creating a label for a hair dye, a label for a suntan product containing sunscreen, and so forth. We were prepared for these tasks, but some of us, myself included, sat numbly as the group exercise got underway. Perhaps with so much to consider in a label's creation, we weren't sure where to start, and we didn't know if we had the energy.
But we did start. We got comfortable in groups, and the groups got to work. Teams of unlikely teammates—marketers, chemists, brand managers, and label suppliers, for instance—were audibly enthusiastic. Looking back, I think the surge of energy and resulting enthusiasm stemmed simply from people realizing that they're not alone.
A fellow attendee, Paul Bryson, remembers the group activity similarly. "By interacting with people of different disciplines and from different companies, one picks up important information. People ask questions you might not have thought of, and they make mistakes that you can learn from." Bryson, codirector of research and development for O.P.I. Products Inc. (North Hollywood, CA), says he benefited as much from such unexpected exchanges as he did from the day's lectures.
Now, please don't misunderstand me. I'm not suggesting that it's practical for marketers and chemists, for example, to always collaborate on labels in the real world. While marketers and chemists undoubtedly labor together in the product development phase, their work in the context of making labels is different.
What I do suggest, if you have questions about the OTC labeling final rule, is that you contact FDA and each other. Get together with others in industry, whether they share your job function or have never heard of it. Labels are a common interest, and one you'll probably feel better sharing. And who knows, maybe you'll learn something.
For more on FDA's OTC labeling final rule, and labels in general, see pages Business Beat, Lables That Fit The Bill, and On Display: Labels in this issue.
Lori Bryan
Editor