 Hi, I am Penny Adler and my grad title is on the screen. It's Making Goats Milk Soap Business Sustainable by Implementing Standard Manufacturing and Testing Protocols. And just to kind of talk about it, I am a small farmer by Watertown, South Dakota. We raise goats and I make soap. One of the cool things though that we're doing is we're doing a new product and I see if I can show you, but this is the cream soap, it's soap in a jar. So it's not bar soap, it's just something totally different and it's pretty unique. There are very few people that do it. So what's unique about it is the lather and you can play with this lather and it'll go and go and go. So I just kind of want to show you that lather because that's part of the uniqueness of the product. The other part of the product though that I'll show you, and I'm making a mess here is that this is my batch and you can see it should be nice and brown and it should not have this. So I had a failed batch. And so that's kind of how this got going for the grant was because I love my product, I don't love failures. And then the other part of it is is I always want to be natural. So our tagline is wholesome living in a colorful world. We make colorful soaps, but we also like wholesome soaps. So the question was is can I make cream soaps 100% natural or what do I need to do to make it safe for my customers? So that was kind of the impetus for the grant. In the end, I wanted a consistent, safe product. I wanted to be sound financially lower my costs or know my costs, lower my costs. And then also because I'm excited about doing this I wanted to be able to market that, hey, when you buy from me, you know what you're getting a consistent, safe product. Our goals are, these were the four product goals from our grant. I'm going to today talk to you about the first one, create manufacturing and testing protocols. If you like what you hear, I would love to talk about the other ones. So you can always invite me back and I would love to talk about preservatives and also product testing. So the first thing I wanna talk about is everything that I do is soap, almost everything. So, but I'm gonna tell you that everything I developed in this is based on cosmetics. So the question is for you, is soap a cosmetic? And the answer is sometimes. So if you want your soap to be soap, you have to have a consistent alkali of salt and fatty acids and that's no problem. Soon as you mix lye and oils, you meet that definition. So everybody meets that definition usually. And the product must be labeled, sold and represented solely as soap. So that means if you sell something that cleans, you are selling soap and the cosmetics don't apply to you. However, sometimes your soap is a cosmetic. So I do not sell soap. I sell a product that will make your skin feel good after you use it. It makes your skin feel soft. It feels moisturizing. I make the process of making soap. The interaction between the lyes and the oils creates glycerin. Glycerin is a humectant. It attracts moisture out of the air to your skin and doesn't that sound moisturizing? Soon as I say any of those things, I'm a cosmetic. So because of that, everything I've developed in this presentation or in my own practices is based on I am a cosmetic. I am not a drug. If I sell a soap and I tell you that this soap is really good for acne, I am crossing a line. So even if I formulate it, maybe it's a high coconut oil soap so it's high in cleansing. If I promise that it's going to do something, I fall under the Food and Drug Administration and have to have my product tested and whatever it takes to be approved. There are other examples are antibacterial cleansers than any of you talk about the one, but a lot of our soaps are good for people with psoriasis and other skin conditions, but as soon as you start talking about that, you're a drug. So everything I talk about today, I'm gonna talk about is gonna be based on what the Federal Drug and Cosmetic Act talks about. So there's two things that they really talk about is you must sell a product that's not adulterated or misbranded. And that's what I'm gonna talk about because what I did then is develop my good manufacturing practices so that I can meet these two answers or things you have to meet. All right, so here's the first goal. I'm going to create manufacturing and testing protocols. We're gonna establish GMP to reduce the risk and the documentation that you can use for this also is ones from the federal government that basically exactly tells you what's in their regulation. And then Marie Gale also puts out a book that is specifically directed towards GMP for soap makers and cosmetic makers. So it's very good for us. Just to give you an idea, these are all the sections. GMP is big and it gets real detailed and my goal was not to add all of this administrative work to make my job harder. My goal was to make my product better. And so everything I did to create accountability for me so that my customers could have that sense of that they knew what they were gonna get every time. So I don't look at it as a bad thing even though it's a lot of regulation or a lot of documentation because it's gonna mean a better product and accountability for me. Just so you know, GMP is not regulations. It is practices. It is not enforceable. There is no audit from anybody. The cosmetics, I believe the government wants you to register. It is optional and so I haven't done it and probably won't because I'm not sure what benefit it would give me but it is just a practice. It is big. You can tell from that previous slide. So what you wanna do is start with the biggest or the easiest areas that have the most risk to make mistakes. All right, so now we're gonna start talking about the different parts of GMP. So the easiest place most times to start is with your master formula. So this is basically your recipe with enough detail that when you follow it, you will get the same results every time and without it, you can't guarantee that to your customers with it, you already know of the base that you can create a consistent product. Couple of things that contains the ingredients and the quantity, detailed steps, but not just do this, do this, do this, but it also includes what temperature should the ingredients be at that step or how do you know when mixing is complete, what trace looks like, earthen trace or thick trace. Also details for quality control. What does it look like? What does it smell like? How thick should it be when it comes to cream soap? Those types of things. You know you have the right amount of detail when a person that's reasonably familiar with similar products can follow your master formula. So and that was the hardest thing because the examples, they go way, way, way deep. So remember my goal was not to create this administrative nightmare. So that was one of the hard things was to find a level of detail that was correct. The second thing is the batch record. So it is documenting that you are following your master formulation. The easiest thing you can do is kinda start with your master recipe and then create checkbox. That's the easiest way to move from that to that. Includes the date made, who made it, how many units and also a batch record or batch log number. All right, so that's the recipe. Now this came second for me but really in the process it happens before you make your recipe. Is your ingredients spec? So if your ingredients are not consistent from batch to batch you can't, even if you follow the same recipe you may get different results. So this part is establishing standard criterias for your ingredients and for your materials. Then you're also going to look at your suppliers and who will supply them to meet your specifications. And then as you go through your master record then you'll verify the ingredients before using them. One thing I learned is that you want to have two vendors for each of your ingredients or materials because what if they run out and you need to get some made or what if they quit selling your product. And you've all had that where they're back ordered and you're struggling to all of a sudden find it. The one thing I ran into was I used a lot of Malibu bottles for my lotion and I have yet to find a substitute supplier that I probably should have never started. I should have picked something out and I'm using another bottle, I don't like it as well. That's the way it is. All right, so far this is everything we've talked about. You need a master formula batch record, a batch log material, specs inventory log and inventory batch record. So that seems like a lot of information. So let's take a second look at it. So this is then how it starts, right? So before I can order ingredients I have to set my specs. This is my example of what I use for my material specs. I probably have a sheet of paper that has four of these on a page so that I can cut them up and I will have them posted on my racks so that when I look at them, I have in front of me my shelf life. When I, and it also tells me who I will order them from. It also has the scientific name. And we'll talk a little bit about that in the end why it's important. Here Cocoa Butter Raw. When you go to order if you don't have this. Now what did I use in that last recipe? Was it raw or refined? Because there's a difference in color and there's a difference in order and there's a difference in texture. So when you go to order it, that's when these things become important. When that ingredient then gets shipped to you, you come in and you have your incoming raw material log. So there you're gonna write your lot number and what I do for lot number is I use a system where the first two numbers are the year that I received it in. So I'll have 15 dash and then I'll have 001 and I'll go through and that's my lot number. When I received it, the name, the quantity and those things, expiration date, which is really cool because I have it on the specs so I know where that to find that information and then a little bit of the other information. There is a final column that says accept doesn't meet the specifications and that's real easy again. You have them right there in front of you. You know how it should look and you should know how it should smell. An example of one that you don't think of maybe is like tubes where the lids don't fit on type like lip balm tubes or I had a batch of bottles where the little plastic had a little catch on all of them. I mean, those are the kinds of things that you start to notice when you are actually inspecting things as they come in. When after I write on my log, then I also create a label for the product that I affixed to it and that just is real simple. It has product name, lot number and expiration date and that way when I pick something up because one of it was to verify it when you use it in your recipe, right? And so there is a quick way to verify the expiration date. Just so you know, when I started this, one of the things I did do was an inventory of my ingredients and anything that I couldn't go back that year to find the invoice for and I knew some of it was older than a year. Those special ingredients, you gotta try ones. And I threw out because I couldn't validate that. And so I said, gonna do it right. Gonna have that consistent product. So there was ingredients I threw out at the beginning of the process. Here's an example of my master batch recipe. So it's kind of like the bottom part of my cream soap recipe and then it has the directions. And I include the ingredient, how much of it and also then I include the NC name because I want those so accessible when it comes to writing labels that I just make it part of everything. And then those are the directions. So yeah, so now you can see, I weigh the coconut oil and add it to the slow cooker. I weigh the sunflower oil and add it to the slow cooker. They're pretty detailed. Possibly you could say add your soft oils, add your hard oils. You would have to really think about that. However, like number 13, just to point out, it's like pour the lyes into the water under the stove vent on high. So I think that's good because you do and I also talk about stir and it isn't, it's stir until it's dissolved and water is clear. So that's an example of not only mix the two but what it should look like afterwards. To me, this is the best part that I've really loved is the batch log. It has product number and I'll talk about how I come up with my product number in the next slide. Product name, date, here's my batch number. So the first thing that this does is when you start the next batch, you go to the batch log to find out what batch number you're starting with next. So that's a big thing. I use my batch log when I say, okay, which soaps are done curing, I go to my batch log. I say, okay, these and I'm ready to be done curing. I didn't talk about that but you would also have a master recipe for how to package your soaps. So it isn't just for the manufacturing side but it's also for the packaging side and how you get them out the door. You think the cream soaps are probably harder because how am I gonna get them in my jars? So it might feel like a little bit more. Then it talks about how many units. So if I make a log of soap, it's 16 bars at four and a half ounces each. And so that's what I'll fill in. So product number, you have to come up with your own way. This is what I do. I have the first two letters talk about what kind of product it is. So my CS is cream soap, my LS is liquid soap, my BS is bath soap or bar soap. Then my middle one. The next segment we'll talk about what recipe it is. So under LS dash form one, that is my first recipe. If I have more liquid soaps, I'll add form two. The bath soap you can see there, I have a swirl recipe that's a little bit slower moving for me. Facial soap will have more gentle ingredients. And so it's formulated different. So I will, that tells me what recipe I'm using. And then the last segment will tell me fragrance. Because I also, and I'm trying to do this better, I don't buy a lot of different colors when I make soap. I try and buy my primary colors and mix them. Well, if I want to get the same purple, now I'm gonna have to start documenting. So that'll come into play even when I do that. Or how much fragrance this kind of soap gets over this kind of soap that all comes into play. And that's why it's important to have them for that. So on that batch log, then that's my product ID. We'll have my BS dash SW dash, whatever. All right, so now I'm ready to make soap finally. And so now I'm going to follow my batch record. So it's similar to the master record, except you can check things off, except there's a few other things to point out. At the top, you have your product ID. So I have that. You also have your batch number. So those are the two things that this will identify this batch of soap. And then you also have your date. And I put a start time and an end time because I want to know how much my soap is costing me to make. So that helps me with my labor. When I do my costing, I will start an end time for manufacturing, start an end time for packaging. And so I get a true cost of my labor. And then I'll have the grams listed. And then I will also document the actual amount used. And again, this is because what is my standard operating procedure going to say if I get a little bit too much, is that okay? Is 5% over okay, is 1% over okay, or 1% under okay? I mean, what is my variance level that I'm okay with? Because I don't always pour straight. And then as soon as I do that, then I create a little tag that has the product name, the batch number, and the manufacturing date. And that goes with, first with the log, and then after I cut it, it goes with that. And that's how it's identified on the shelves. I didn't say that when I create that tag for the ingredients. A lot of times I have to put packaging tape over it. Because I'm telling you, there is not a whole lot of inks that can hold up to oils. And so that helps. All right, then standard operating procedures. So these are the ones with the most words, I think, and the harder, because you just do it. Or you don't do it and you should be doing it. So the good thing about standard operating procedures is it makes you question your, how you do things. So I have a scale. Is it accurate? How are you gonna know? How often should you test it to make sure it's accurate? Is there a right answer? The right answer is whatever you put in your standard operating procedures. And there probably is a little bit, for some of them, a little bit better. The calibrate, your pH meter is supposed to be every month, but there are other things. Safety precautions, look at wild hair. Do I need to wear a hair net? You know, all of those things. I have a workshop, my husband walks by my workshop and wants to come in. Do I let him in after he's been out in the goat barn? You know, it's some of that stuff, which he doesn't like it when I think like that and I kick him out. The other thing we didn't talk about is 10 minutes, okay? Is how do you handle complaints? So there's another possibly log that you can create, but afterwards it's really hard because it's the emotional thing. Do it ahead of time, it's not so bad. All right. And these are examples, just of other things that you can talk about. I guess I didn't show you on that other screen. There was a link. Marie Gale also has a good book on standard operating procedures. Oh, there it is. So, oh, we're gonna talk about labeling. Yeah, so that was the other part for cosmetics. You have to have an adulterated product and you have to have good labeling. So we're gonna talk about that next. And they have different rules for your front panel, which is what the customers are most likely to read in the other panels, which are called information panels. And on the front panel, you have to have your name, your identity, and your contents. Your contents must be in both metric and in US measurements. You have to identify, is it soap or is it whatever else is it? And also then, this is the part that I put up with from the government then, is then that your texts, they get very specific and needs to be an eighth of an inch high based on the letter lowercase O, placed bottom parallel in the bottom 30% of your label. These things, they will say good practice is even if you're selling soap to have this much. Again, those soap is not regulated. The information panels, the back or side panels, and that's what they say. If you're selling soap, you at least want to have your name and address. Oh, did I? Okay. Directions for safe use. And you have to have your ingredients and warning statements. So let's take a look at a couple of those. Your name and address. I live on the farm. Do I really want my farm address on my label? The answer is no, but you will. The caveat is, is if you're listed in a printed phone book, you don't have to. So I may look at that. I do have people that drive up in my yard and oh, we just stopped to see your thing. And that's okay, but I would prefer a phone call. Can I use a post office box? And the answer is no. Right now the H-S-C-G, Handcrafted Soap Cosmetic Guild is putting together a petition to allow PO boxes, but right now you cannot use them. It has to be your physical location. Ingredients you need to use the NC name, which is from the cosmetic ingredient dictionary, except your botanical ingredients, you use the common name. So you list them in order, the ingredient that there's the most stuff is first, and then you go down. If you buy any type of a base or a blend, you have to list those ingredients individually too, with respect to your soap. So you can't just add, I don't buy any base blends or bases, so I'm not sure what you have, but you have to split them out. Well, I used to do a lotion base that I would buy. So I can't just say lotion base. I would have to list any ingredients. I have a really good recipe now. Ingredients, a couple more things. Fragrance, you can list as a catch-all. You don't have to break it free. So a lot of us like to say that we're failate free or paraben free or all those things. They don't have to list it. Other products don't have to list it because of this. And you can just list fragrance. Ingredients that are less than 1%, you don't have to worry about the amount there. Any order is fine. Color additives, there is a list of approved color additives and you have to abide by that, but you can list them all last, no matter if they're above that 1% or above that other. So those are always last, after all the other ingredients. So some of you use essential oils. So do, and you like to probably say, hey, I use lemongrass essential oil. What if you use lemongrass and tea tree? So if you want to list that you are using a lemongrass essential oil and you also have something else, you have to list all of them. You can't, you know, if it's a proprietary blend and you only want to list a couple of them, nope, you have to list all of the essential oils. If you don't want to do that, then you have to list it as fragrance and then you don't have to give out your proprietary blend. There are some special rules about trade secrets and those I don't know, nor did I include them, so. So that kind of is the end of my presentation. Was there any questions for me? So the question was, is how many goats do you need to make it worthwhile? So for a bar of soap, I say that one fourth of your bar is goat's milk. So if I make a four ounce bar, I need one ounce of goat's milk. So in a gallon of goat milk, I get 128 ounces, so that can make me 128 bars from that one gallon of goat's milk. So if you're making, milking a goat and they're giving you a gallon of milk a day, you're making a lot of soap every day. So one goat for you to start will do it. And I only have a handful of goats that I milk. I don't, the rest are meat crusts or meat, commercial meats.