JOURNAL OF THE SOCIETY OF COSMETIC CHEMISTS histology, cytology, tissue culture and other biological measurements require further development. Addi- tional experience in evaluating animal experiments in terms of human experience is urgent. These problems, however, will inevitably be resolved once there is sufficient incentive. This search for the new is perhaps the greatest and most promising opportunity facing the cosmetic chemist. It is a long-range objective with many problems to be overcome. In the meantime, there are countless day-to-day problems with which the chemo-biologist can assist a great deal more than may be fully appre- ciated. Many of these problems have been discussed on this and similar programmes in recent years. The objectives and procedures of co-operation have been outlined. Many of the biological methods have been discussed, including some of those used in regulatory enforcement. The problems of research, product development, regulatory activity and promotion can be expedited both economically and chronologically if we, as cosmetic chemists, would: 1. Educate ourselves concerning the contributions of the bio- logical sciences. 2. Seek the biological viewpoint and background early and con- sistently. 3. Make no change in product without biological evaluation. 4. Rely on biological studies to delineate our interest in new chemicals, new formulations, and new processes. 5. Remember at the beginning that it is the biological action that counts at the end. 6. Fully appreciate that biology, not chemistry, is the basis for safety evaluation and, there- fore, regulatory action. 7. Let the pharmacologist evalu- ate your regulatory status be- fore it becomes a problem. 8. Realise that it is much more prudent to prevent injury than to attempt the correction of it. Since. regulatory activity is now receiving so much attention, it may be worth while to evaluate some of its implications from the cosmetic chemists' point of view. If there had been no cosmetic chemists and hence, for practical purposes, no new products, there would have been practically nothing on which legisla- tors and officials could have hung their investigative hats. The very fact that there may be some basis for new legislation may, therefore, be laid on our doorstep. But have we taken time to realise and to acquaint our industry with the equally significant fact that if com- petent biological investigations had been carried through from beginning to end, there would have been even less on which to hang the investiga- tive hat ? The cosmetic industry is not alone in this position, let me hasten to add. The responsibility for adequate evaluation resides with the manu- facturer of the finished product, notwithstanding recent industrial views to the contrary. Food and Drug administrators cannot be ex- 172

THE BIOLOGICAL SCIENCES AND COSMETICS pected to screen every potential cosmetic ingredient as outlined above. Manufacturers of basic materials may not be interested in cosmetic application many of them are not. Neither of these groups can adequately evaluate a compounded formula by a study of its individual ingredients, and neither can be expected to protect private formula- tion. To argue either of these points is to ignore the biological and econo- mic facts of life. Time does not permit a more detailed discussion of this point, but it richly deserves much more careful consideration. Some of these views may not be popular either with the industry or the government agencies. The fact remains that, so far as we as cos- roetic chemists are concerned, chang- ing laws should be of little import unless our morals can be legislated. The same set of biologically docu- mented data which we are morally obliged to assemble on a really new product will be adequate either be- fore or after the law. Let us not, therefore, go into biological disintegration ourselves over this question. Hypertension, ulcers and nervous breakdowns are not fun, and are about as useless as anything can be. It is much more important that the cosmetic chem- ists, the chemo-biologists and man- agement get together on a compre- hensive research and development programme that will cure a big majority of the present headaches. All this may sound wonderful, and I frankly hope it does to some of you, but many of you are wonder- ing where and how you obtain these specially trained personnel and their facilities. Anything I have to say on this subject is tongue-in-cheek, primarily because the demand ex- ceeds the current supply. Perhaps the best answer is that few, if any, cosmetic manufacturers could econ- omically justify such a high-cost, high-overhead department as a per- manent entity. The alternative is a close-working relationship with the chemo-biologist, wherever he may be. In this case it is first the individual that is important, then his facilities, and finally any institu- tional relationship he may have. Be sure of your man's biological back- ground and don't try to be a biolo- gist yourself unless you are sure you can qualify. You may some day encounter the biologist who is a chemist because he had a course in inorganic and maybe organic chemis- try back in the good old days. Be sure he is practical and that he is free to undertake your problem. Consider that universities and tax exempt foundations are under obliga- tions to make their findings available to the public. At least that's what they tell the tax collector and Con- gress. Be sure you are completely honest with him, so he may do an honest and complete piece of investi- gation for you. Be sure you under- stand each other's positions in case of patentable invention. If you pay him adequately for his services, he should expect to protect you on patents. Remember that many basic problems may best be under- taken co-operatively between non- 173