22 FORMULATION
ethylhexylglycerin among them—permeabilize the Gram-negative outer membrane and potentiate the primary preservative, often allowing effective protection at lower total loading. Another strategy to destabilize the cell barrier
leverages the structural nature of P. gergoviae itself. As a Gram-negative bacterium, its outer membrane relies on divalent cations (Ca2+
and Mg2+
) to maintain structural integrity.11
Introducing a chelating agent sequesters these essential ions, weakening the membrane and increasing biocide permeability. Tetrasodium glutamate diacetate (GLDA) performs exceptionally well across a broad spectrum, serving as an eco-friendly alternative to EDTA, while sodium phytate offers an effective natural alternative at pH < 6. Screening for viable hurdle combinations
across a shrinking, heavily regulated palette is a formidable task. Platforms like Green Chem Finder simplify this process by indexing multifunctionals, boosters, chelating agents, and preservative blends by antimicrobial mode of action, regulatory status, and application— enabling formulators to design tailored, multi- hurdle systems based on robust chemistry rather than supplier convenience.
5. Expand your testing protocols Two changes to testing protocols, both straightforward. Add P. gergoviae to the challenge panel. ISO 11930’s five organisms are a floor, not a ceiling. For any aqueous product including P. gergoviae as an additional challenge organism is not a regulatory requirement — it is a scientific necessity, and a commercial preservation decision. Use your own factory isolates. As Elmadi
notes: “Factory isolates play a crucial role in GMP and NPD, and their inclusion helps detect potential contamination risks that might otherwise go unnoticed during batch testing. Newer organisms of interest — B. cepacia and P. gergoviae — are ones to watch out for due to their impact on product safety and recalls.”
6. Work it as a system None of the above works as a set of isolated activities. Trend the data — water, environmental monitoring, raw materials, release results — and treat a pattern of low-level recoveries as signal rather than noise within specification. Escalate on the trend for prevention, not on the first product positive. Catching organisms before they become a problem depends on monitoring designed to detect drift, not to confirm compliance. Prevention is boring, but less expensive at the outset than the alternative — which is finding out from a laboratory report attached to a finished batch.
Conclusion In the Jergens and Oribe recalls, Kao acted voluntarily based on its own surveillance—a model of a quality system functioning as intended, not failing. The standard for formulators and quality
PERSONAL CARE MAGAZINE September 2026 Figure 3: Factory floor protocol: surveillance and quality control flow
manufacturers is not managing a crisis post- detection; it is ensuring your monitoring protocols are rigorous enough to catch the strain in the first place. P. gergoviae is not going away. It lives in
water; we make products largely out of water. It has demonstrated across two decades of published work that it can adapt to our preservatives faster than our permitted palette can expand. Better hygiene, tighter water control, more
diverse antimicrobial systems and broader testing protocols cost time and money up front. What they buy is not merely the avoidance of a recall — it is the preservation of Annex V as a functioning toolkit. The organism adapts and fast. The question is whether we do.
References 1. Olioso B. Why the Oribe Serene Scalp Densifying Shampoo P. gergoviae Recall Matters for Formulators. GreenChem Finder.
https://greenchemfinder.com/why-the- oribe-serene-scalp-densifying-shampoo-p- gergoviae-recall-matters-for-formulators/
2. Olioso B. Preserving Plant-Based Wipes: Lessons from the Neutrogena Wipe Recall. GreenChem Finde https://greenchemfinder. com/preserving-plant-based-wipes-lessons- from-the-neutrogena-wipe-recall/
3. UK OPSS (2025). Product Recall PSD 2501-0013: Amika Mirrorball High Shine + Protect Antioxidant Shampoo. https://assets.
publishing.service.gov.uk/media/67acdaf948 169f7508af60cb/2501-0013-product-recall- amika-mirrorball-shampoo.pdf
4. US FDA (2022). Kao USA Conducts Voluntary
Recall of Jergens® Ultra Healing Moisturizer.
https://www.fda.gov/safety/recalls-market- withdrawals-safety-alerts/kao-usa-conducts- voluntary-recall-jergensr-ultra-healing- moisturizer
5. Brady C et al. Taxonomic evaluation of the genus Enterobacter based on multilocus sequence analysis. Systematic and Applied Microbiology. 2013; 36(5), 309–319
6. BfR (2020). Skin creams, make-up and shampoos should be free from Pluralibacter. Updated BfR Opinion No 038/2020. https://
www.bfr.bund.de/cm/349/skin-creams-make- up-and-shampoos-should-be-free-from- pluralibacter.pdf
PCM
7. Davin-Regli A et al. Enterobacter gergoviae and the prevalence of efflux in parabens resistance. Journal of Antimicrobial Chemotherapy, 2006; 57, 757–760
8. Périamé M, Pagès JM, Davin-Regli A. Enterobacter gergoviae adaptation to preservatives commonly used in cosmetic industry. International Journal of Cosmetic Science. 2014; 36, 386–395
9. Périamé M, Pagès JM, Davin-Regli A. Enterobacter gergoviae membrane modifications are involved in the adaptive response to preservatives used in cosmetic industry. Journal of Applied Microbiology, 2015; 118, 49–61
10. Green Chem Finder. https://greenchemfinder. com/compendium/
11. Nikaido H. Molecular Orientation and Outer Membrane Permeability. Microbiology and Molecular Biology Reviews, 2003; 67(4), 593–656
12. MSL Solutions Providers.
https://msl.io/ www.personalcaremagazine.com
Photo Credit: Green Chem Finder
https://greenchemfinder.com
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