Honest Troubles: Raw Material Risk Management in Focus
[Posted on: Thursday, 17 March, 2016]

The cardinal rule of raw material vendor management is to verify that vendor’s specification and documents related to the raw material being sourced. Errors in the quality of raw material could compromise the quality of the final product. In pharmaceutical GMP, raw material risk management is one of the core competencies. Not so in other industries. Recently, the Honest Company had to publicly deal with a faulty raw material vendor leading to bad publicity and possibly loss of business. Honest Co’s brand is built on avoiding known harmful components in its products. It used to claim that its laundry detergents do not contain sodium lauryl sulfate or SLS which could potentially cause skin rashes. The Wall Street Journal conducted independent testing of the laundry detergent sold by Honest Co and found high levels of SLS, almost the same as other laundry detergents such as Tide. The tests were confirmed by two independent testing labs. Upon further investigation, it was discovered that Honest Co does not manufacture its laundry detergents but sources then from a vendor called Earth Friendly Products, LLC where the claim of “zero SLS content” originated. Honest Co never tests its laundry detergent supplies but takes Earth Friendly at its word. Earth Friendly also sells the same detergent under a different brand name, Ecos, which does   not claim “zero SLS”. Earth Friendly in turn purchases the laundry detergent from a sub-vendor Trichromatic West, Inc. who does not test for SLS content either. The key ingredient for the laundry detergent sold by Trichromatic West comes from an India-based vendor called Galaxy Surfactants that labels the product sold to Trichromatic West as SLS. So, in the process where multiple vendors and sub-vendors led to a final product, it seems no one ever tested for SLS content before making the claim on the label. Honest Co, bought from Earth Friendly, who bought from Trichromatic West who in turn used a key ingredient from Galaxy Surfactants. Honest Co never dealt directly with the sub-vendors and it does not appear that any vendor specification verifications were conducted. The case highlights several issues with vendor management and claim validation. SLS is a common component of several products such a laundry detergents, tooth paste, shampoo, body wash, mouth wash and hand wash. It is also a common research reagent used in electrophoresis. While it is known to cause skin irritation in pure form, it is considered safe at the concentrations used in everyday household products. Honest Co made a big claim based on partial science. No one involved ever cared to test for the SLS content of the final product. All vendors claimed that since they did not “add SLS” to the product, it does not contain any SLS, forgetting the basic science of how SLS is manufactured in the first place. In all fairness, SLS or its milder version sodium coco sulfate (SCS) are both manufactured from coconut or palm kernel oil so they are manufactured from “natural sources” and occur together. The issue was with the claim which clearly was false. Honest quickly changed its labels to remove any claims for “zero SLS” and so did Earth Friendly. They are fortunate to work in an unregulated industry so there are no legal or regulatory consequences. In the pharmaceutical world, such issues with raw material would lead to product recalls, bans, Warning Letters and fines.