SKIN DEEP – Scratching Below the Surface

Posted by denegodfrey on May 14, 2010 · 31 Comments

From the EWG web site:

“The mission of the Environmental Working Group (EWG) is to use the power of public information to protect public health and the environment. EWG is a 501(c)(3) non-profit organization, founded in 1993 by Ken Cook and Richard Wiles.

In 2002, we founded the EWG Action Fund, a 501(c)(4) organization that advocates on Capitol Hill for health-protective and subsidy-shifting policies.

EWG specializes in providing useful resources (like Skin Deep and the Shoppers’ Guide to Pesticides in Produce) to consumers while simultaneously pushing for national policy change.”

From the Skin Deep home page:

“In 2004 we launched Skin Deep, an online safety guide for cosmetics and personal care products. Our aim was to fill in where companies and the government leave off: companies are allowed to use almost any ingredient they wish, and our government doesn’t require companies to test products for safety before they’re sold. EWG’s scientists built Skin Deep to be a one-of-a-kind resource, integrating our in-house collection of personal care product ingredient listings with more than 50 toxicity and regulatory databases.

Now in its fourth year and third major update, our Skin Deep database provides you with easy-to-navigate safety ratings for nearly a quarter of all products on the market — 54,866 products with 8,983 ingredients. At about one million page views per month, Skin Deep is the world’s largest and most popular product safety guide”

The aims of both the EWG and their Skin Deep database are laudable – who could disagree that cosmetics should be safe? I doubt that any responsible manufacturer would ever knowingly put their customers at risk by placing products on the market that are not safe for their intended use. EWG insist that there is virtually no regulation of cosmetics in the USA, but this is not the case. The FDA requires that manufacturers do not place products on the market that are unsafe to human health and, whilst there may not be the same level of regulation as in , for example, the European Union, it is not true to say that cosmetics are unregulated. The EWG/Skin Deep promote themselves as the champions of safety (in cosmetics, for the purposes of this paper), but this is not actually what they achieve.

The database uses an impressive array of numbers (of products and data sources) and an impressive-looking amount of detailed explanation as to how their system of classification works, including some complicated-looking formulae. For the fine detail, click more

The mainstays of this system are the following:

“Hazard (concern) rating. We developed a hazard rating that represents a synthesis of known and suspected hazards associated with ingredients and products. Hazard ratings within Skin Deep are shown as low, moderate, or higher concern categories, with numeric rankings spanning those categories that range from 0 (low concern) to 10 (higher concern).

Data gap rating. We developed a data gap rating within Skin Deep, primarily to describe the extent to which low hazard scores associated with some ingredients or products are based on definitive data demonstrating safety or, at the other extreme, on a near absence of data either demonstrating or disproving hazard. Data gap ratings are represented within Skin Deep by a numeric percentage ranging from 100% (complete absence of safety data) to 0% (comprehensive safety data). “

Already, several concerns creep in:

1) It is not possible (at least, not without a high degree of subjectivity) to assign a numerical value to a hazard. A hazard is a hazard. It is not logical to compare something that is highly corrosive to something that is toxic by ingestion – it is the same as comparing apples with pears.

2) On whose authority is the “suspected” hazard determined. Again, this is highly subjective. If there are no data, how is it possible to suspect a hazard?

3) How is it possible to rate a data gap so empirically? The impact of any data gap is wholly dependent upon the nature of the data that are missing.

4) They make the statement – “A hazard rating of “low concern” (shown as a green circle in Skin Deep) might be rated in that category because of definitive data proving its safety, or because of a near absence of any safety studies that would illuminate hazards.” How can absence (or near absence) of data ever be shown to illuminate hazards?

5) They claim to offer “safety ratings” – they do not – they only offer hazard ratings.

On looking more closely into the database and, specifically, at various products and their hazard scores, there are many obvious issues. There is a group of closely-related compounds that are assigned hazard scores entirely the opposite of their true relative hazardous nature. There are examples of the same chemical being listed under two different names with different hazard scores.

One word that has arisen many times in this discussion, and on the Skin Deep database is “hazard”, and therein lies the basic issue with Skin Deep. It is entirely based on hazard, with no attempt whatsoever to evaluate risk. It is not possible to evaluate safety of the basis of hazard alone. If a chemical was in existance that required only a single molecule to kill a human, that would be described as extremely hazardous. However, if only one molecule of that chemical actually existed, then the chance of human exposure is insignificant, and the risk to human health is also insignificant. I use an extreme example to better explain the relationship between hazard and risk, which may be summarised as follows:

RISK = HAZARD x EXPOSURE

Because the database only highlights the hazard of the ingredient, there is no possible way the consumer can know the actual risk involved in its presence in a cosmetic product. In our daily lives we constantly assess risk, albeit mostly subconciously. If we avoided every hazard without ever considering risk, we would never cross a road, and we would never stay in our homes (as the majority of accidents occur in the home, so there is a definite hazard associated with being at home). As it is nonsense to live our lives with assessing risk, it is equally nonsense to avoid any particular chemical without assessing the risk. It may even be the case that high exposure to a product classified by Skin Deep as zero is less safe than low exposure to a product classified as 10 on this database. Therefore, the database offers no useful information on the safety of cosmetic products, and is misleading to consumers.

Regarding hazard, it is possible, given the correct dose and route of administration to establish a hazard for EVERY chemical in existance, be it natural or synthetic. If anyone decided to carry out an inhalation study using any chemical either in vapour, mist or powder form, it would result in death. The only substance that would not have this effect is air (although the individual components of air would cause death), and even inhalation of too much air too quickly can result in dizziness and unconciousness. Therefore every chemical is hazardous.

For a little light relief, I suggest that you investigate the extreme hazards posed by dihydrogen monoxide by clicking Dihydrogen Monoxide.

The treatment of data gaps is of particular concern. This is, again, highly subjective. Some ingredients with 100% data gaps are assigned zero, but others are assigned 3, or higher. How is it possible to assign a hazard rating when there are no data? It is entirely possible that many companies, appreciative of the marketing benefits of being able to claim a zero hazard rating on Skin Deep, are designing products specifically using ingredients with a zero hazard rating. There is certainly at least one company using this tactic. This means that products are being manufactured using ingredients with no safety data! Given that the EWG make great play of their claim that the USA do not regulate cosmetics, is it wise of them to encourage this practise, albeit tacitly?

The use of hazard classification alone enables Skin Deep to provoke concern amongst consumers. Without this concern, they would get little in the way of donations.

Another quote from the EWG site:

“Under federal law, companies can put virtually anything they wish into personal care products, and many of them do. Mercury, lead, and placenta extract — all of these and many other hazardous materials are in products that millions of Americans, including children, use every day,” said Jane Houlihan, Vice President of Research at EWG.

This strongly implies that mercury and lead are deliberately added into cosmetic products which (apart from a few mercury-based products used as skin-whiteners) is simply not true. Again, the comment focuses on hazard only. I am not going to comment on placenta extract as I don’t know why anyone would want to use that in the first place, and I am not sure of the potential risks involved in its use., but this is more evidence of manipulation of information in order to scare consumers in a misleading manner.

At the 2010 Expo West (which, for the benefit of those not based in the US, is the largest natural products show in the country) the Environmental Working Group’s Skin Deep Safety Review Group’s booth reportedly had a banner which read “If you can’t pronounce it, it can’t be safe”!

Following this logic it must be the case that if you CAN pronounce it, it must be safe. Try pronouncing “hydrogen cyanide”.

Two final quotes from the Skin Deep web site:

“This scoring system does not account for individual sensitivities or differences between the severities of different health endpoints within a particular category.”

And at the head of every product’s hazard rating:

“Given the incomplete information made available by companies and the government, EWG provides additional information on personal care product ingredients from the published scientific literature. The chart below indicates that research studies have found that exposure to one or more ingredients in this product — not the product itself — caused the indicated health effect(s) in the studies reviewed by Skin Deep researchers. Actual health risks, if any, will vary based on the level of exposure to the ingredient and individual susceptibility — information not available in Skin Deep.” (My bold type; not Skin Deep’s)

Does the average consumer looking at the database even read these disclaimers, never mind understand that they are saying that their ratings refer to the individual ingredients and that information on the ACTUAL health risks of the product in question is not available in Skin Deep?

In summary, the Skin Deep database does not offer any insight into the true safety in use of any cosmetic product. Indeed, by encouraging the use of ingredients with no supporting toxicity data, they are risking the health of the very consumers they pupport to be seeking to protect. This database should be radically amended (and corrected) to better reflect it’s true worth, or closed down.

Dene Godfrey

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More about the author: Dene Godfrey has been involved with preservatives for cosmetics since 1981, from both technical and commercial angles and has a degree in chemistry. Read more from this author

Filed under Science · Tagged with cosmetic database, Dene Godfrey, EWG, personal care products, safe cosmetics, skin deep

mariondove

I was waiting for someone to write an article like this one about that site

thanks Dene
http://www.dotandlil.com Anne Dardick

THANK YOU. So often consumers use Skin Deep as a resource because there is a lack of information elsewhere. Now they have you!
http://greenskincareblog.com/ Kristin Fraser Cotte

Dene,
A very well written, science backed argument that there clearly is no science (or semantics) behind Skin Deep.
Dene Godfrey

Thanks to you all for your kind comments so far. I hope that we can get this information out there to as many consumer as possible – they need to know the truth about Skin Deep!
http://www.neveroverthehill.com John Hill

I have always warned consumers NEVER to use the Skin Deep database when questioning cosmetic products or ingredients. The information is pure propoganda, driven by the EWG (Envionmental Working Group). If you dig a little deeper it is not surprising to find that the EWG is working with a group called “Democracy in Action”, a group with the slogan “Wiring the Progressive Movement”. From their own site you can read their agenda: “DemocracyInAction, a 501(c)3 nonprofit organization itself, believes technology can be a decisive force for social change. We exist to empower those who share our values of ecological and social justice to advance the progressive agenda”.

We need to work against this group with as much, if not more fortitude and fire of will! They will stop at nothing until total redistribution of wealth is complete, and all free market capability is controlled in every aspect. They are doing it now with the Skin Deep site. We can counter with this personalcaretruth site. And, you can do your part by informing everyone you know, and every cosmetic and personal care products consumer, of the true safety and efficacy of today's scientifically based products.
SUSAN

“I doubt that any responsible manufacturer would ever knowingly put their customers at risk by placing products on the market that are not safe for their intended use.” Oh but they do, every time they sell a product with synthetic fragrance. Knowingly, purposefully, put their customers and our planet at risk by using synthetic fragrances…and for one reason, money. They don't make the product work better, they do nothing for the skin, there is one benefit…perception that the product smells “good” and so the manufacturer will make more money by selling products that smell “good”. Synthetic fragrances are toxic, they are air pollution and pollute the water (they are not extracted by waste treatment plants so we are also consuming them.) 95% of synthetic fragrances are made from petrochemicals so while people realistically often have no choice but to drive their car to work…they do NOT have to buy products with petrochemicals in them but they CHOOSE to.

And as for the Skin Deep database…THANK YOU. Thank you for having the courage to take this on. Most of my posts to their Facebook page have been removed, and I've been warned to be friendly and brief (or else). I disagree with one thing you said “How is it possible to rate a data gap so empirically? The impact of any data gap is wholly dependent upon the nature of the data that are missing.” DATA ISN”T MISSING in the REAL WORLD! It's simply missing from Skin Deep. I will give them credit that when I brought a number of ingredients to their attention, they finally updated them. But quite literally, I could spend 8 hours a day, every day, pointing out the mistakes, duplicate entries with different scores, MSDS information readily available that contradicts their supposed “GAP” in data. They have led consumers, and formulators who work backwards from their “zeros” when formulating, to believe that “zero” means safe, and data gap means nothing bad exists about the ingredient, and that simply is not true. I sited a number of examples on my blog: Greenwashing. Thank you for bringing this to a new audience!
SUSAN

“I doubt that any responsible manufacturer would ever knowingly put their customers at risk by placing products on the market that are not safe for their intended use.” Oh but they do, every time they sell a product with synthetic fragrance. Knowingly, purposefully, put their customers and our planet at risk by using synthetic fragrances…and for one reason, money. They don't make the product work better, they do nothing for the skin, there is one benefit…perception that the product smells “good” and so the manufacturer will make more money by selling products that smell “good”. Synthetic fragrances are toxic, they are air pollution and pollute the water (they are not extracted by waste treatment plants so we are also consuming them.) 95% of synthetic fragrances are made from petrochemicals so while people realistically often have no choice but to drive their car to work…they do NOT have to buy products with petrochemicals in them but they CHOOSE to.

And as for the Skin Deep database…THANK YOU. Thank you for having the courage to take this on. Most of my posts to their Facebook page have been removed, and I've been warned to be friendly and brief (or else). I disagree with one thing you said “How is it possible to rate a data gap so empirically? The impact of any data gap is wholly dependent upon the nature of the data that are missing.” DATA ISN”T MISSING in the REAL WORLD! It's simply missing from Skin Deep. I will give them credit that when I brought a number of ingredients to their attention, they finally updated them. But quite literally, I could spend 8 hours a day, every day, pointing out the mistakes, duplicate entries with different scores, MSDS information readily available that contradicts their supposed “GAP” in data. They have led consumers, and formulators who work backwards from their “zeros” when formulating, to believe that “zero” means safe, and data gap means nothing bad exists about the ingredient, and that simply is not true. I sited a number of examples on my blog: Greenwashing. Thank you for bringing this to a new audience!
AlexEWG

I've reviewed http://personalcaretruth.com – and it's fairly evident the site is funded and maintained by representatives of the cosmetics industry.

Mr. Godrey's erroneous claim in a recent blog comment that “Skin Deep’s ratings bear NO relation to the safety of ANY cosmetic product” doesn't hold up against the facts.

Since Skin Deep launched in 2004, EWG has gathered information on ingredients in thousands of personal care products and has matched these chemicals with hazard data contained in nearly 60 toxicity and regulatory databases. Read more on how each item in the database is scored here: http://www.cosmeticsdatabase.com/faq.php#1

The TRUTH is the Skin Deep database isn't necessarily good for sales depending on what ingredients a particular product contains, and as a result has drawn the ire from various companies and industry PR reps. People are becoming aware that the personal care products industry, of which Mr. Godfrey and Lisa Rogers are representatives of, can often use suspect chemicals and other ingredients in products most consumers would rather not slather on their skin.

The good news is since the inception of Skin Deep a number of companies have re-formulated their products by removing certain ingredients associated with serious health risks, including cancer.

Of course, I wasn't alarmed when I saw a blog post on the group's site from the chemical industry's premier apologist, Elizabeth Whelan panning the recent report by the President's Cancer Panel, which listed exposures to known and probable carcinogens as one of the primary causes of cancer – along with smoking, obesity and alcohol abuse. Read “Doctor” Whelan's rant here: http://personalcaretruth.com/2010/06/crying-wol…

Whelan is the president of the American Council on Science and Health (ACSH). What a great name. It reminds me of The Tobacco Institute and the Council for Tobacco Research. The ACSH stopped reporting where it receives its funding back in the early 1990s, but press reports have stated the group has received up to 75 percent of its money from the chemical industry. Whelan has disputed that figure, recently telling a reporter with The New Yorker that only 1/3 of its annual budget comes from industry. http://www.newyorker.com/reporting/2010/05/31/1…

The medical community commonly defines a carcinogen as any substance, radionuclide or radiation, that is an agent directly involved in the exacerbation of cancer or in the increase of its propagation.

Anyone who dismisses chemicals associated with causing cancer as a source for developing the disease is either ill-informed or has a financial interest to do so.

Allowing someone with Ms. Whelan's views to use your website to promote her position that chemicals, regardless of how toxic, are some how safe for human health, erodes any credibility personalcaretruth.com may have enjoyed.
Dene62

Well done, Alex. You have managed to put across your point of view without addressing a single issue that was raised in my article. Please don't give me the tired old rant of “vested interest”. You simply cannot (or, rather, SHOULD not) dismiss everything that emanates from within the industry as being untrustworthy. Facts are facts, and the FACT is that SD relies solely upon hazard ratings which, as I thought I had made perfectly clear CANNOT be used as a guide to safety. FACT. Your own disclaimer (quoted in the article) supports this statement and, therefore, I don't understand how you can deny this. Having said that, you didn't exactly deny it – more like avoided it. Much of the EWG income is derived from groups with a vested interest in scaremongering, as it keeps them in a job. Touché?
Bacarrington

Alex, I have a few questions for you. Having worked in politics for most of my adult career, and having absolutely no ties to the chemical industry whatsoever, can EWG explain why it has not filed a tax return since 1998, and also serves as its own D.C. lobbyist having paid itself almost $400 k in the last couple of years? Oh, and one more thing…one of the lobbyists listed on your quarterly reports is actually a lobbyist for an oil company. Can you please enlighten me?
http://twitter.com/chemistscorner Chemists Corner

ad hominems aside, what about the claims made in the article?

“Some ingredients with 100% data gaps are assigned zero, but others are assigned 3, or higher. How is it possible to assign a hazard rating when there are no data?”
Dene62

A brief addendum to my earlier comments to cover this vested interest charge. The articles I write and the comments I make are made largely in my own time. My employer does NOT employ me to do this as part of my job, and my comments represent my personal opinions. The only vested interest I claim is an interest in truth and clarity and a deep interest in battling against the non-scientific, disinformative scaremongering spread by organisations such as the EWG.
Neveroverthehill

It would be rather easy to attack AlexEWG's comments posted above, but I'd prefer to join in as a friendly “discussion”, and pose some questions for him to answer. Each of these come to mind as I read his post.

1) Alex, I am a cosmetic chemist, and I use on a daily basis virtually all of the products that I formulate for Never Over The Hill Cosmetics. I also use many other brands of personal care products. I advise and encourage my wife to use personal care products, and my children as well. I have absolutely no fears or worries about “dying” or being massively harmed in any way from using a personal care product. So, my first question is this:
When you wake up in the morning and take a shower, do you rinse off with water? Do you use a “soap” or a “liquid soap”? Do you wash your hair with a shampoo, and finish with a conditioner? Do you shave your face with a razor and water alone (ouch!!)? Do you dry off and then use a deodorant or an anti-perspirant, or do you prefer to share your personal body “aroma” with all others that you meet? Or perhaps you feel that if the neanderthals didn't need any of these products perhaps you don't need them either….. which leads to question 2.

2) If personal care products and the chemicals (both natural and synthetic) that are in them are so harmful and potentially deadly, why is the average life span for both men and women world wide at the highest point of all time in history? Men and women now live easily into their mid-80s and beyond. Why aren't we all dropping off like flies because of our personal care product use? Neanderthals usually died in their early 30s, which was thought to be “old age” at that time and they weren't exposed to any personal care chemicals. And, today's seniors are the ones who were using personal care products that have coincidentally “boomed” in the last 50 years as well. How do you explain this? And, to answer the answer that I'm sure you'll give…. cancer rates have risen simply because the human population has “boomed” exponentially during this time period. If you have billions more people added to the population each year, you would naturally expect more cancer cases… but not as a direct result of personal care product use.

3) When you go to the beach or visit me down here in Arizona, do you take the time to put on a sunscreen, or do you prefer baked, leather-like skin with the increased chance of contracting Melanoma Skin Cancer?

4) When you visit the cold upper mid west in January and your skin is bone dry and your lips are chapped, do you prefer to go around with the painfully cracked skin, or do you place some sort of emollient product on your skin and lips to protect them?

I could go on and on, but I think you get my point AlexEWG. So now, we await your answers to the above questions.
http://www.cactusandivy.com Lisa M. Rodgers

Hey Alex -

Thanks for taking the time to review Personal Care Truth and you're right, PCT is funded and maintained by representatives of the cosmetic industry. That would be me and my partner Kristin.

“People are becoming aware that the personal care products industry, of which Mr. Godfrey and Lisa Rogers are representatives of, can often use suspect chemicals and other ingredients in products most consumers would rather not slather on their skin”.

It's comments like the above that prompted Kristin and I to start this site. We, as do countless others, manufacture under complete transparency. Our ingredients are visible on our website and labels and we do not use “suspect chemicals” in our products.

How ironic you would mention the funding of ACSH when EWG is one of the richest 'non-profits' around. Aren't you the pot calling the kettle black?

While I greatly appreciate you leaving your comments, Personal Care Truth does not consider EWG to be a reliable source of truthful information backed by scientific facts. If EWG is going to tell the story then they need to tell the entire story.

As long as EWG and Skin Deep continue to spread misinformation, Personal Care Truth will continue to shed truthful light on the issues at hand. Why doesn't EWG take some of the consumers hard earned money and put it towards actual research? Isn't that what you should be doing?

Thanks again for stopping by!
http://www.sterlingminerals.com/ Katherine

Personally I feel everyone on here made an excellent argument to AlexEWG. Especially in regard to the vested interest.

AlexEWG I assume you are drawing a salary working for the EWG? So may I conclude that you have a vested interest in siding with their position on determining hazard in ingredients? Which by the way hazard is a rating assigned to full exposure to an individual ingredient in terms of the manufacturing process or undiluted exposure. Risk does not equal hazard so to quote that EWG acquired their data from nearly 60 toxicity databases is irrelevant since the consumer is not remotely close to being exposed at these levels. Also individual ingredients based solely on their chemical nature as to two chemicals being used to make another perfectly safe ingredient, is also not relevant.

It has been the habit of EWG to dissect ingredient compounds as to what makes up a newly formed ingredient, when after the chemical process is complete, they are not even remotely related and the hazard changes, if there is one. Lye is a perfect example when used to make soap.

Although your passion is profound AlexEWG, you must be aware that our passion is no less equal to yours, yet what we know and have researched is the actual science behind our products ingredients.

I think Squeaky said it best at this thread: http://mybiggestcomplaint.com/environmental-wor…

And I for one am extremely happy to see that more and more people are seeing through the rhetoric and propaganda for emoting fear in consumers, all to make a buck, which I might add is the very thing AlexEWG accuses us of doing. Hmmm….now there is a unique perspective!
http://www.brambleberry.com/ Anne-Marie

Thank you for the article about the Skin Deep site. I have often scratched my head at some of the ratings on the Skin Deep website. Having read many of the studies (line by line) that some of the ratings are based on, (broad brush) they are generally not conclusive (small studies, not human based, extremely high doses, often based on ingestion rather than leave on/rinse off).

I care about my health as much as the next person. I'm a big fan of sticking to proven anti-cancer tactics like working out 30 minuets a day, eating 5 servings of fruits & veggies, staying within your BMI range for weight, losing any extra belly fat you have and limiting alcohol to 1 glass per night (women)/2 glasses per night (men).

Thank you again for the article.
http://twitter.com/essentialU Kayla Fioravanti

The writers for Personal Care Truth do not get paid for their articles or research. Lisa and Kristin do not solicite funds or take a pay check. Of course, the experts are from the industry because we understand and work in the industry…doesn't that just make sense that an expert be an actual expert in the industry?

The EWG is one giant money making machine and pushing their agenda is very important to the pay checks of many. There are NO tax records for 2009 and 2010 available for EWG so here is 2008.

In 2008 Ken Cook was paid $219.401.00 plus another $21,295.00 estimated amount of other compensation from organization and related organizations.

Richard Wiles $179,218.00 plus $20,998.00 estimated amount of other compensation from the organization and related organizations.

Jane Houlihan $150,226.00 plus $19,448.00 estimated amount of other compensation from the organization and related organizations.

William Walker made $136,448.00 plus 19,743.00 estimated amount of other compensation from the organization and related organizations.

Susan Comfort $115,752.00 plus $7932.00 estimated amount of other compensation from the organization and related organizations.

Sandra Schubert $127,229.00 plus $4884.00 estimated amount of other compensation from the organization and related organizations.

Alexander Formuzis $120.592.00 plus $10,920.00. Could this be you AlexEWG? Why yes it must be you since you left a similiar comment on another site with your full name! I'm sure with your pay check you care quite abit about EWG and their agenda.

Christopher Campbell $136,909.00 plus $11,988.00 estimated amount of other compensation from the organization and related organizations.

In case you got sick of reading the pay that is a total of $1,185,775.00 being paid to the top 8 employees of the Environmental Working Group just in 2008. The total estimated amount of other compensation from the organization or related organizations for the top 8 at EWG was $117,248.00. The total reported 2008 salaries for EWG was $3,203,747.00 in 2008. The 2008 total revenue at EWG was $6,242,570.00. Almost half of their total revenue went into paying the employees of EWG.

The numbers alone are enough to discredit everything the EWG says…that and the fact the there is NO science backing up the claims.
Dene62

Wow, Kayla, fantastic detective work,and amazing information. I wish I had seen those numbers before I wrote the original article! I am tempted to re-write it and include your info as a post script. This makes a total mockery of the vested interest charges levelled at PCT by Alex. I wonder how many EWG contributors know how much if their money goes straight into the top guy's pockets. It will be interesting to see if Alex has anything to offer on this subject.
Rich Summers

I would also like to add a small comment as to the background of the commentator on safety of chemicals :
Alex Formuzis
Vice President for Media Relations. Alex came to EWG after 8 years as a senior aide to three members of the United States Senate. Prior to his time on Capitol Hill he was in the public affairs shop of the Clinton Treasury Department, in the policy shop for the NGO Independent Sector, and worked on state and local campaigns in Washington State. Alex was born and raised in the Northwest, spending his youth sailing, hiking and skiing from Southern California to British Columbia. Alex graduated from the University of Montana in 1995 with a B.A. in political science.

From the EWG website.

I can't personally see anything on this small CV that shows any chemical knowledge at all. Or have I missed something completely ?
Perhaps I should have taken politics rather than chemistry at university…………..
AlexEWG

I appreciate your colorful comments, and did chuckle a bit at your comparison of me with a neanderthal. I'll be sure to share that with my wife. I do use soap, shampoo, deodorant and sunscreens. I just try to use the most thorough information available in an effort to purchase products for myself and and my family that contain the fewest ingredients associated with a number of health risks – some of which are on the rise at alarming rates in the U.S.

It must be comforting not to be at all concerned with industrial chemicals, including probable carcinogens and hormone disruptors, as ingredients in many personal care products. That is where you and I just differ. I am worried about what a daily exposure from a mix of different chemicals may mean for human health; particularly for young children.

EWG's own research through the study of umbilical cord blood has identified well over 200 chemical pollutants, including those commonly used in personal care products, in the blood of babies still in the womb. Now, EWG doesn't believe that just because a chemical is found in a person's blood that it is automatically a threat to their health. But most chemicals are not sufficiently tested for safety before they are allowed onto the market and into products we all come in contact with everyday. It's EWG's belief that the way the federal government regulates and approves the use of chemicals is fundamentally flawed and must be changed.

And we are not alone in our concern. The Obama administration, congressional leaders and the head of the American Chemistry Council have all recognized the need to overhaul the federal Toxic Substances Control Act of 1976. The only major environmental law that has never been updated.

I'd be curious to get your position on whether reform is needed, or if the status quo of issuing thousands of chemicals into commerce with little or no safety tests is the best way to protect the consumer from the potential risks toxic chemicals may pose to people.
AlexEWG

Rich – If this is the logic you apply to your own life then I take it you have no position, concerns or any other thoughts about any subject outside of the field of chemistry. How liberating. Able to walk through life without a care or concern about such important issues as war, healthcare, the state of public education, famine or poverty because you didn't major in those topics during college.

I have never claimed to be a scientist. I work with many folks that are, though. They are smart, dedicated people who have a collective interest in reducing the use of and exposure to certain chemicals known to be toxic that are used in thousands of products we all use and come in contact with daily. It's important work, and I'm honored to be part of it, even though I didn't major in chemistry.
Rich Summers

Not at all, I have quite a varied and strong opinion on quite a large number of topics ( as anyone who knows me well would attest to ). I do however stop at that, having an opinon. I do not try to change government policy on ecomonic housing for example, as I have absolutely no clue about this. And this I think is where we differ. The EWG is trying to convince people of “truths” when the people writting this information have no background in this, or are out to promote some governmental change by lobbying using this information. Information that is always alarmist, mostly scaremongering and sometimes incorrect. Information that is mostly provided by research that is done “on behalf of” the EWG, by people who are directly funding the EWG by donations, and thereby paying your salary.

This is of course if I have understood the various parts of policy and pieces of information I have read in good faith on the internet, as I am sure you read about chemical hazards.

I am in a slilghtly different situation to most on here as I am in the UK, where we do have a number of different pieces of legislation covering chemical risk ( and please note I do use the term risk here, not hazard ). Cosmetics must undergo a safety assessment here, and all the companies that I deal with that only sell products to the US do these as well, to the EU standard.

The biggest thing I object to is the assumption that we as an industry are trying to somehow sneak “toxic” materials into peoples homes. I think that everyone on here would agree that product safety is paramount to selling products. There may well be some in the industry who disagree, I can't speak for everyone, but I do feel that if there are they would be very few and far between and quite outspoken.

I am glad that you have replied, I have nothing personal against you and as Media relations I suppose it kind of is your job. I do also notice however that you haven't yet actually addressed any of the points in the initial article and subsequent comments about risk, hazard, data gaps and general product safety, relating specifically to Skin Deep, rather than the slightly off topic comments about the EWG as a whole.
http://www.sterlingminerals.com/ Katherine

The problem with the study you are referring to AlexEWG is it is extremely flawed.

First off the study is done on minority children based on socioeconomic status they are more likely to be exposed to environmental pollutants. Pollutants in our environment are a given and all of us are exposed to them. Furthermore, since this study could not actually identify how the exposure took place such as ingestion, inhalation, skin contact, it is only showing what is the obvious for all Americans. This was solely based on randomly checking cord blood for chemicals. It also did not deal with examples of drinkers or smokers and what they expose unborn infants to.

In an excerpt from the article I located:

“Each time we look for the latest chemical of concern in infant cord blood, we find it,” said Anila Jacob, M.D., EWG senior scientist and co-author of the report. “This time we discovered BPA, among other dangerous substances, in almost every infant's cord blood we tested.”

“This study proves newborns are exposed to BPA in the womb,” Jacob said. “After they are born, they'll encounter more BPA by drinking from a bottle, drinking canned infant formula and, eventually, eating canned food like ravioli and chicken noodle soup.”

“When I learned of EWG's groundbreaking biomonitoring research four years ago, I knew Rachel's Network members would want to be involved. We are proud to have funded this research, and it is imperative that Congress now take action to strengthen chemical regulation,” said Winsome McIntosh, founder and president of Rachel's Network. “This issue affects all of us; EWG's testing proves that a toxic chemical burden exists in women and children regardless of geographic location or socioeconomic status.”

This suggests that concerns come mainly from ingestion and not from topical exposure, plus she makes Dr. Whelans argument for her since she also states if we look hard enough for an exposure, we can find something, somewhere always….So I go back to what Personal Care Truth was created for, personal care products and cosmetics.

No one eats their cosmetics and nothing has been substantiated in any scientific research outside of nano particles which shows that any cosmetic ingredient, even those deemed penetration enhancers, as going any deeper than the Dermis layer and not actually proven to cross into the blood brain barrier.

Phthalates were a prime example of this debate with Whelan and Swan. Even by EWG's own disclaimers throughout their site and your comment:

“Now, EWG doesn't believe that just because a chemical is found in a person's blood that it is automatically a threat to their health.”

This in and of itself is the crux of the argument: Based on the “precautionary principle” the EWG feels this should be changed within the industry….Why, because EWG says so? Who are they? Perhaps read the latest article at the home page in this regard.

Proving something is safe is ridiculous and impossible again by EWG's own disclaimers. Not necessarily a health risk….If we set out to prove something was completely safe when there is no actual studies showing fundamentally they are unsafe, nothing and I do mean nothing, would ever come to market and we would all be staring at a bunch of empty shelves.

Drinking too much water can be unsafe and can kill you…..soaking in water can be unsafe to the point that excessive exposure can literally make skin fall away. And then, well the whole thing of having to resort back to being hunters and gatherers based on supposition and educated guesses….well to say the least is prehistoric.
Dene62

Whilst, on the one hand, I am pleased that Alex continues to engage, and I do appreciate that he has a sense of humour, on the other hand, this discussion is unlikely to achieve very much because, as a “trained politican”, Alex continues to evade the main point, ie that Skin Deep does NOT achieve what it claims, and misses the mark by a considerable distance. Additionally, he has failed to address the jaundiced and hypocritical approach to the “vested interest” accusation. It seems that vested interest only works in one direction for the EWG. Whilst I accept his comments (up to a point) in this discussion regarding his interpretation of the number of chemicals detected in umbilical cords, this is certainly NOT the manner in which the EWG portray the data. There is a definite insinuation that the number of chemicals is relevant (it isn't), and that their mere presence means danger.

One further, and possibly final, point from me – to refer back to the section of my original article where I mention the Skin Deep use of the “If you can't pronounce it, it can't be safe” argument; words almost fail me at the depth of sheer stupidity of this statement. Scaremongering at its indefensible worst. If Alex would care to give some direct answers to these charges, then further discussion may be of some value.
http://greenskincareblog.com/ Kristin Fraser Cotte

Wow Kayla, that's a bit unbelievable that someone who makes a generous 6 figure salary from EWG (the funding source for Skin Deep) would try to discredit this site due to it being run by people that are leaders in the beauty industry! Lisa, myself and our experts are researchers, formulators, chemists, aromatherapists, business owners, trade org leaders and more…

When I want the facts, I turn to experts, not people who solicit money to fund high salaries for their “non profit”. I will repeat your statement. Lisa and I make NO $ off this site. We do not solicit for $5 or $10 every week. We both were compact signers with the Campaign for Safe Cosmetics and found serious flaws with the Skin Deep rating system. That is why we started PersonalCareTruth.com. Consumers, industry peers, everyone deserves the truth.
Alex

You may want to read up on the US laws that “regulate” chemicals' use as ingredients in consumer goods, including personal care products – before you weigh into the issue. I only suggest this as it is always a good policy to know as much as one can before engaging others in a debate.

Unlike your country, the cosmetics industry in the US is largely unregulated – regardless of what those who maintain this website may say. Some companies use certain synthetic chemicals that are known and probable carcinogens as ingredients, and have every right to do so under the authority of federal law.

In the US, under the regulatory statutes of the federal Food and Drug Administration and the Environmental Protection Agency the window for either agency to show a chemical is a concern to human health is very short. As a result, it's nearly impossible to complete the necessary tests to ensure these products are actually safe.

We don't believe the cosmetics industry is “trying to somehow sneak “toxic” materials into peoples home.” As I just explained, they don't have to. It's legal. But, just because it's legal doesn't make it right.

I would just make this final point to your original critique that people without degrees in chemistry have no place in pursuing policy change of US federal chemicals law. I've worked closely on public policy issues at the state and federal level for 15 years, including the last 7 on pushing legislative fixes of current US laws dealing with the security of chemical facilities and the reform of the Toxic Substances Control Act, from within and outside of government.

I've also worked to reform aspects of the country's healthcare system, fiscal, education and energy policies, and have pitched in on a number of foreign policy issues, including terrorism as an aide to three members of the US Senate.
Dene62

You are very good at tackling the side issues Alex, but you have yet to defend Skin Deep against the fundamental accusation that it doesn't not, and cannnot do what it claims to do, ie it does not provide any useful information regarding the safety of any cosmetic product. All you have done is claimed that my statement is erroneous, but your rationale for your claim does not stand scrutiny because it simply does not give any justifiable explanation, nor repudiation of my charge, other than to say I am wrong!

I am also waiting for clarification regarding your accusation (and the associated implication that my my views are “tainted” in some way due to “vested interest”, especially in the light of the knowledge of the true extent of your personal vested interest. Either an explanation as to how you don't have a vested interest, or an apology for casting doubt on my veracity would be in order here.
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