Tracy,

I am currently taking classes towards a Masters in Health Product
Regulation.  I have spent a lot of time with various FDA regulations
and the way I would interpret "most" is that it has to  more than 50%
of the final product.  Therefore you could take pure soap and mix 49%
dirt into it and sell it as soap.  Not many people would buy 49% dirt
soap, but it would meet the FDA's description of "Soap".  I would have
to lookup the definition of cosmetics to be sure, but the main
differences between soaps, cosmetics and drugs are what you claim it
does.

You are correct about the soap reaction, by-product glycerin can be
added to soap but cannot be made into soap.

My only suggestion on how to determine the amount of lye to use would
be to do small trial batches or some form of titration.

Andy


On Sat, 12 Feb 2005 00:50:47 -0800 (PST), Jeremy & Tracy Longworth
<[EMAIL PROTECTED]> wrote:
> My name is Tracy, and I am Jeremy's wife.  I am also a soapmaker.  There are 
> a few things that concern me about making soap with the by-product of 
> biodiesel.
> 
> First, imho, the wvo is not exactly the cleanest stuff to begin with and I 
> think there might be problems with the government in producing soap with it.  
> The FDA defines soap as "a product in which most of the nonvolatile matter 
> consists of an alkali salt of fatty acids and whose detergent properties are 
> due to these alkali-fatty acid compounds".  If I read the regulations 
> correctly, if a "soap" is made mostly of anything else, it is then considered 
> a cosmetic and comes under certain regulations.  True soap is not regulated 
> by the FDA: cosmetics are.
> 
> Secondly, soap cannot be made from primarily glycerin.  Glycerin is a 
> by-product of soapmaking and is left in handmade soaps or extracted from 
> commercially made soaps.  The soap is formed from the reaction of a caustic 
> soda and fatty acids.  If anyone is truly making soap from the by-product of 
> making biodiesel, then it would stand to reason that there are left-over oils 
> in the glycerin.
> 
> Third, there is no way to know for certain what kinds of oils comprise WVO.  
> Many restaurants don't always use the same kind of oil.  That being the case, 
> I can't see how one could accurately figure the amount of lye needed in order 
> to achieve proper saponification.  Every oil requires a different amount of 
> lye in order for it to properly saponify.  If one were to use too much lye, 
> the resultant soap would be "lye heavy" and too harsh for anyone to use.
> 
> I did also see written that the lye was to be added to warm water, I believe. 
>  I, and the soapmakers I am in contact with, add their lye to cold water.  
> When the lye is added to water, the resulting solution can reach temperatures 
> near boiling at times.  If one was to start out with warm water, the solution 
> could volcano and create quite a mess, not to mention it could also cause 
> harm to anyone around at the time.
> 
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