“You can die from eating a few tablespoons of ordinary table salt at one time, but that doesn’t mean that table salt is a poison at the doses that humans normally consume.” —- George Bailey, Oregon State University Professor emeritus of molecular and environmental toxicology
Recently a bill has been proposed in Colorado, the ‘Colorado Safe Personal Care Products Act’. Here is a link to the full Act. There are hearings coming up in March in Colorado. You can attend to learn more or voice your opinions. To sum up the bill it would prohibit the sale of ‘…any personal care product that contains a chemical identified as causing cancer or reproductive toxicity.’ This in itself sounds good! After all, who could possibly argue with crafting safe products? But this bill is not setting reasonable limits – it would be an outright ban on anything that is even classified as a ‘potential’ carcinogen. It’s a broadly worded bill that would have many unintended consequences.
1. The bill is overly broad and would ban many natural ingredients.
For example, many people may not realize about this is that this Act would ban even naturally occurring substances that can be found in extracts and essential oils. For example, one of the components of Basil, Citronella, Rose Otto and Tarragon Essential Oils is Methyleugenol. This essential oil component is considered a carcinogen. Does that mean we wouldn’t be able to use these safe, natural additives in our formulations? The way the current legislation is written would open the manufacturer up to fines of $10,000. This law, while well-meaning, is too general and will harm small personal care manufacturers who have less choice of ingredients to use and may in fact, prefer to use all natural ingredients, like essential oils.
The proposed bill is very definite with its complete ban instead of safe usage restrictions which would make more sense (and already exist). Testing of chemicals and ingredients to classify them as ‘potential’ carcinogens is done in very concentrated amounts of the product, generally in larger amounts than the ingredients are used in ‘real life’.
2. How to make your voice heard.
For anyone who would like to voice their opinion, the House Judiciary Committee will be having a hearing for those both in support of and in opposition of this bill on March 1st. The meeting will be in the basement of the Capitol Building, in room 0107.
If you do not live in Colorado, here is all the info to contact the house members who are sponsoring this bill to get more information or suggest how the bill may better be crafted to meet the goals set out in the bill:
The bill is sponsored in the house by Dianne Primavera phone # 303-866-4667 click here to email
Dennis Apuan phone # 303-866-3069 click here to email
Karen Middleton phone # 303-866-3911 click here to email
Joe Miklosi Cap phone # 303-866-2910 click here to email
A group in Colorado that is in support of this bill is The Women’s Lobby of Colorado. They hold open meetings so anyone who would like to speak in opposition to this bill or in support of a bill simply asking for safe usage rates, can contact them at firstname.lastname@example.org for information on their meetings.
It is important that we speak up for safe regulations instead of a complete ban. Using natural and safe ingredients and taking care of our bodies is important. There is already a governing body that covers beauty ingredients and cosmetic products – the FDA. They have comprehensive guidelines on best manufacturing practices, labeling laws and there already are safety guidelines in place for essential oils, preservatives, fragrance oils and other additives.
3. The bill is backed by questionable science.
I have done research on the testing process to determine carcinogenity and generally, ingredients are tested via injection in high doses or in-vitro injection, nothing as simple as small percentage in a product that is used at skin level. According to Oregon State University:
The health impact of carcinogens is not always “linear,” This means experiments that are done using high concentrations of a carcinogen – a common practice made necessary by cost and logistics – may not accurately predict the actual risks of the compound when exposure in the real world is at lower levels over long time periods. (Oregon State University link to full article)
Here are some examples of wording from EWG or Skin Deep – a group that supports this bill shows testing results for the cancer causing substances that they want to completely ban. They list ‘concerns’ for the ingredients in question, one of these reads: ‘One or more animal studies show tumor formation at high doses‘. Another reads, ‘One or more in vitro tests on mammalian cells show positive mutation results.’ and yet another ‘Cancer – limited evidence.’
When I read these I see ‘high doses’, ‘in vitro tests’, and ‘limited evidence.’
Personal care products are not introduced directly into your body in a dose (like a drug); they are not in any way introduced ‘in vitro’. They are leave on and rinse off. If lotions really absorbed in all that well, anti-wrinkle creams would work like the packaging says they do. If the bill passes as written, many natural options would also be effectively no longer available. We need to speak up for safe and knowledgeable regulation that takes into consideration natural occurrence and recognizes the difference between concentrated doses and personal care product use. Remember, salt and water can kill and no one is looking to ban any of those items.
For a business perspective on why this bill doesn’t make sense, head over to Donna Maria’s blog here.
Other blogs on the subject:
Robert Tisserand’s blog “Tunnel Vision” http://roberttisserand.com/2010/02/tunnel-vision/
Donna Marie’s blog “Oppose the Colorado Safe Personal Care Product Act” http://www.indiebusinessblog.com/2010/02/23/oppose-the-colorado-safe-personal-care-products-act/
Ann-Marie’s blog “You Can Die from Salt Too” http://soap-queen.blogspot.com/2010/02/you-can-die-from-salt-too.html
Cindy Jones’ blog, “Colorado Safe Cosmetics Act” http://sagescript.blogspot.com/2010/02/colorado-safe-cosmetics-bill.html
Kelly Bloom’s blog, “Colorado Safe Personal Care Products Act” http://southernsoapers.com/news/causes-concerns/colorado-safe-personal-care-products-act/
Lisa Rodgers’ blog, “Colorado Safe Personal Care Products Act : How Will it Effect You?” http://cactusandivy.blogspot.com/2010/02/colorado-safe-personal-products-act-how.html
Katherine Corkill blog, “Oppose Colorado Safe Personal Care Products Act.” http://sterlingminerals.blogspot.com/2010/02/oppose-colorado-safe-personal-care.html
Happi Magazine mentions the topic in “Preservative Market Update” http://www.happi.com/articles/2007/05/preservative-market-update
Handcrafted Soapmakers Guild “From the President, Colorado Safe Personal Care Product Act” http://www.soapguild.org/blog/2010/02/from-the-president-colorado-safe-personal-care-products-act/
Cosmetic & Toiletries site, “Bill Proposes the Colorado Safe Personal Care Product Act.” http://www.cosmeticsandtoiletries.com/regulatory/region/northamerica/84985577.html
Michelle Gilbert’s blog “Colorado versus the cosmetic industry” http://sarvasoap.com/blog/?p=706