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Archive for August, 2010

My last post led me into a debate that has become quite daunting and time-consuming for me ( I would rather write about the benefits of lavender oil). I don’t want to seem like I am against small businesses and crafters obviously – I live and breathe it – I just think that there are a handful of people who don’t want any legislation ever. One of the women leading the campaign against the Safe Cosmetics Act was opposed to it before she even read it. I don’t think it is an industry that should go without proper legislation. I side with many cancer researchers and environmentalists on this one – it will not only protect the consumer but it will protect our water systems and wildlife as well.

It seems like people are reading into specific lines of the bill and coming up with the worst case scenario. For instance, the  labelling requirements  have an  ingredient definition of  “any individual component of a botanical, petroleum-derived, animal-derived, or other ingredient that the Secretary determines be considered an ingredient”. My interpretation of this is that the Secretary may demand that certain problematic chemical constituents that occur in botanical ingredients such as linalool be labelled. This mirrors the European Union’s labelling.  The interpretation by others is that this means every chemical constituent of every botanical ingredient will need to be on the label – so basically thousands for each product. I didn’t get that and it is obviously an absurd idea.

People are also claiming that all products will have to be tested for all sorts of things because of this section:

INITIAL SUBMISSION- Not later than 1 year after the date of the enactment of the Safe Cosmetics Act of 2010, manufacturers and distributors of cosmetics and ingredients shall submit to the Secretary (in an electronic format that the Secretary shall determine) all reasonably available information in the possession or control of the manufacturer or distributor that has not previously been submitted to the Secretary regarding the physical, chemical, and toxicological properties of single or multiple chemicals listed on the cosmetic labels under section 613, including–

  • `(i) functions and uses
  • `(ii) exposure and fate information;
  • `(iii) tests of finished cosmetics; and
  • `(iv) any other information used to substantiate the safety of such cosmetics or ingredients.

My interpretation of this is that if I already have any research or testing on my products or ingredients available, I will need to submit it. To me, this does not apply to a home-based soap maker. This would apply to the large companies that have huge amounts of research behind their products.  The extreme interpretation of this is that everyone has to have all of their products tested. Again, I didn’t get that.

I don’t argue just to be right. If I get information that changes my mind, I will back down. This just hasn’t happened yet. Of course, I can be patronized with “did you get your lawyer to look at it?’ As in, you are not qualified to make any judgements. My lawyer understands wording but does not understand formulation, cosmetic safety or the industry in general.

My final gripe with the backlash is the denial that any safety issues exist within the cosmetic industry. I read a post that justified lead in lipstick “there are higher levels in your tap water”. I don’t know where they live, but there is no lead in my tap water. They should get their pipes replaced.

Like most people, cancer has affected my life. I have had many healthy, thin, non-smoking, non-tanning friends and family (including children) suffer from this disease.  I believe that environmental factors are to blame. I don’t think that unsafe cosmetics are solely responsible for cancer but they certainly add to toxic bioaccumulation in our bodies. The President’s Cancer Panel report for 2008-2009 (released in 2010) focused on reducing environmental cancer risks (which included cosmetics).  The report stated that “the true burden of environmentally induced cancer has been grossly underestimated” and it made recommendations for more regulations. I couldn’t agree more.

I keep hearing “bad science” and “not based on scientific fact” when it comes to cosmetic safety concerns. I thought for fun I would dig up some studies from this year alone. You can decide if this is bad science.

Higher blood concentrations of synthetic musks in women above fifty years than in younger women; International Journal of Hygiene and Environmental HealthVolume 213, Issue 2, March 2010, Pages 124-130  Synthetic musks (11) were found in women’s blood proving that this ingredient does, in fact, enter the blood stream.

Environmental Oestrogens and Breast Cancer: Evidence for Combined Involvement of Dietary, Household and Cosmetic Xenoestrogens; Anticancer Research March 1, 2010 vol. 30 no. 3 815-827 Exposure to complex mixtures of oestrogenic chemicals  in consumer products is a  feasible factor in breast cancer development

Combined exposures to anti-androgenic chemicals: steps towards cumulative risk assessment; International Journal of AndrologyVolume 33 Issue 2, Pages 463 – 474 This research looked into the exposure of anti-androgens – phlalates, parabens, and some pesticides – and the irreversible de-masculinzing of male babies in utero. The analysis suggests limiting exposure to these chemicals in order to reduce the risk.

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There has been much hoopla recently from small personal care businesses about  new legislation being introduced in the United States called The Safe Cosmetics Act. It proposes to regulate the cosmetics industry in a very similar manner to Canada and the European Union. To put it in a nutshell, companies will be required to:

  • register their company and products with the FDA
  • disclose all ingredients on their packaging including trade secrets, fragrance components, and labelling of nanomaterials
  • pay fees based on annual sales – any companies making under $1,000,000  are excluded
  • share safety data that will be publicly available and based on research conducted by Environmental Protection Agency, the International Agency for Research on Cancer, the National Toxicity Program through the National Institutes of Health, the California Environmental Protection Agency, and other authoritative international, Federal, and State entities (as determined by the Secretary).

There will also be initiatives to phase out animal testing. So what’s the problem? I export to the United States from Canada and I would be happy to submit my company and products to the FDA. I was actually quite shocked when I initially researched export requirements and discovered that I didn’t need to do a thing. It’s the wild west of cosmetics!

In Canada, cosmetics manufacturers must submit product information sheets to Health Canada and must follow labelling requirements that include ingredient listing and both French and English translations. We also have a fairly extensive list of prohibited ingredients (last time I checked the number was 500. In the US it’s 11)

In the European Union under the Cosmetics Directive, a cosmetic manufacturer must provide:

  • A safety assessment of the finished cosmetic product must be performed before the product can be placed on the EU market;
  • A full technical file or product information file (PIF) for a cosmetic product must be kept available for inspection by authorities at a specified EU address. PIF shall include the qualitative and quantitative composition of the product; the physico-chemical and microbiological specifications of the raw materials and the finished product; the method of manufacture complying with GMP; assessment of the safety for human health of the finished product etc.;
  • Notification to competent authorities must be done to inform the competent authorities that a cosmetic product will be placed on the EU market.

 There are also restrictions for nanomaterials and animal testing.

So join the rest of us, United States. What excludes you from government regulation?

If you google The Safe Cosmetics Act, you will come up with a whole lot of whining from bloggers making claims that this new legislation will ruin small green businesses. How? If you are a legitimate business, you should be complying with laws  – it goes with the territory. Submitting your products to the government is a one time thing (unless you make changes). It might take 1/2 hour for each product. You won’t have to pay fees unless you are making more than $1,000,000 –  that’s surely not the sales levels of the businesses these bloggers are trying to defend. All research will be publicly available so you won’t have to foot the bill for your own safety assessments.

Another argument is that it isn’t going to make cosmetics safer. By saying this, they are discounting research conducted by the Environmental Protection Agency, the International Agency for Research on Cancer, the National Toxicity Program,  and the California Environmental Protection Agency.

Interesting…

I have also read that it will bring the cost of products up. Why? What does it cost a company to take a pen to paper for one day? Are they really going to have to build that into the cost of their product? Nonsense.

Another claim is that it will destroy green product innovation. Seriously? It’s not the green product manufacturers that should be worried right now. It’s the toxic chemical manufacturers that will have to make the necessary changes. Besides, green companies are usually quite happy to use the safest ingredients possible. I have had to make many changes over the years with Cocoon Apothecary i.e. spending loads more on a safer preservative and sourcing certified organics.

What really seems to be getting these blogger’s knickers in a knot is the Environmental Working Group. They start their entry about the Safe Cosmetics Act and then go into an unrelated rant about the Environmental Working Group – the non-profit organization behind the Cosmetic Database. I will always defend this organization. I am an environmentalist first, a cosmetic maker second. I will always put the health of people and the planet ahead of my business interests. Maybe it will be to my business’s detriment (so far it’s only been rewarded) but that’s how I roll.

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