Kristin and I started Personal Care Truth for a variety of reasons. The main one being we were and still are, tired of the half truths and fear mongering floating around on the web. The misleading information is sprouting up because of the alarmists cramming scare tactics down the throats of consumers.
When writing about the things we hear, see and do in the personal care products industry, it is really nice to have audio of scientific data or claims made by either side of the isle. Kristin and I pride ourselves on providing truthful information and when we have the opportunity to share an audio of something we have both written posts on, well, it gives more credibility to our cause.
As my dad always says, “I’m from Missouri, you’ve got to show me”. Well, here ya go. You’ve read many posts that reference the Colorado Safe Personal Care Products Act that was brought before Colorado legislators back in March, 2010. We’ve all quoted what we heard while listening live to the session. Now, you can hear what we heard and then blogged about. It’s hard to say you didn’t say something when there is a recording to prove otherwise.
For the record, I contacted Robin with the Colorado Legislative Council and received permission to use snippets from the recording I captured of the live session in March, 2010.
The following audio snippet contains Susan Roll, a social worker and a founding member of the Campaign for Safe Cosmetics, testifying as the Vice Chair of The Women’s Lobby of Colorado. Ms. Roll was asked by Representative Daniel Kagan, “Where are the independent scientific studies”? Listen below.
The audio speaks for itself…the Campaign for Safe Cosmetics, EWG and their database Skin Deep has no science.
Sagescript
It will never cease to amaze me that they introduced this bill and that they think it has any validity or worth-fullness. Even their scientific expert could not back it. If they are really concerned about estrogens in the water system they should look at birth control pills and hormone replacement therapy.
I have to say you have completely misinterpreted the precautionary principle here. The “action” referred to in this case is the ability of manufacturers to include certain ingredients in personal care products. Thus, the burden of proof to prove these ingredients are not harmful falls on the industry itself. Since hundreds of ingredients have not been tested for safety to this point, the industry continues to operate with little regard for the precautionary principle.
Take the classic example of parabens – certainly controversial, with studies emerging on both sides of the issue (safe and non-safe). Triclosan is another example where the potential benefit does not justify their use over traditional, safe alternatives, given the potential risk involved. The simple truth is that they should be disallowed, not allowed, until the industry can point to substantial (non-industry-funded) studies which prove their safety. The burden should not be on consumer advocates to prove otherwise.
I agree with your views that the dose level is crucial, and natural ingredients like olive oil should not be ruled out for minute traces of certain chemicals – however, neither does the industry provide information on how much of each ingredient goes into their products. Do you think a “nutrition facts” model is the answer, to fully inform consumers of how much of each ingredient is in their product and absorbed by their bodies, rather than simply the basic ingredient list? The Skin Deep Database works with the information that is available to them. If the “science is not there”, the burden is on the industry, not the consumers and their advocates, to do research into the safety of particular dose levels.
If you think that the legislation is oversimplified, please do not respond with an equally oversimplified argument that “the science is not there”. There are hundreds of substantiated studies pointing to toxic effects of certain ingredients. Of course there needs to be more completed – but at the very least, you have to acknowledge that if the industry were asked to prove beyond doubt that all of their ingredients were safe in the long term for consumers, “the science is not THERE” either.
I would appreciate if you would point out the exact pieces of the current bill you take issue with, and why, so that an informed debate could take place on the topic rather than a blame game from both sides.
http://www.cactusandivy.com Lisa M. Rodgers
Hey JakeL -
Thank you for your comments. An open dialogue is most welcome and the answer to your last paragraph is as taken from our petition, this is why the small business manufacturers oppose 'HR 5786 The Safe Cosmetics Act of 2010':
While we are unquestionably in favor of safe cosmetics, this bill contains a number of unnecessary provisions that would decimate our nation's small scale cosmetics manufacturers without any benefit at all to consumers.
This bill treats a company making 100 bottles of lotion each year the same way it treats a multi-billion dollar, multi-national company making 100 bottles of lotion each second. It is grossly unfair, unduly burdensome, intrusive and unnecessary in a number of aways, among them the following:
Point 1: HR 5786 is unnecessary. Small cosmetics companies have a history of producing safe cosmetics pursuant to current laws that require companies to clearly identify the products they sell, provide all manufacturer contact information and truthfully label products with ingredients.
Point 2: HR 5786 contains onerous registration requirements. HR 5786 contains intrusive and unnecessary requirements that would force small companies to disclose to the federal government information that the government does not need, which is unduly burdensome for small companies to provide and which does nothing to protect consumers from unsafe cosmetics. Specifically, in addition to having to register their company name and location, small companies would also have to file with the federal government product descriptions, product ingredients, trace ingredient in products, gross sales numbers, the name and contact information of the suppliers of the ingredients used in their cosmetics and their number of employees.
Point 3: HR 5786 contains unnecessary labeling requirements. Current cosmetics laws already require small companies to list ingredients on labels. HR 5786 expands labeling requirements to include trace elements found inside those ingredients. For example, a product containing water (or any other natural ingredient), would have to contain a label listing the water and also every other trace element inside that water. (Water contains a number of chemicals, including nickel, lead, copper, silver and dozens more — depending on the water source.) Requiring small companies to include such a list on each label is onerous and unnecessary.
Point 4: HR 5786 requires small companies to conduct unnecessary scientific testing. Under the bill as drafted, small companies would be required to test all of the products they make, and be in a position to produce data to the federal government about the ingredients, components of ingredients, and also, components that may be produced when known ingredients are combined. Those are impossible (and unnecessary) standards.
Point 5: HR 5786 is anti-American. At a time when our Congressional representatives should be seeking to revitalize the American economy, especially where manufacturing is concerned, HR 5786 would eliminate it in cites and towns in every state across this nation.
Point 6: HR 5786 specifically allows all 50 states to pass stricter requirements. Even with the sweeping nature of HR 5786, it specifically states that each state can pass additional laws as it sees fit. This provision is Congressional permission for each state to pass whatever laws it wants, creating a patchwork quilt of laws that no small company can comply with. If Texas adds labeling or manufacturing requirements that are different from HR 5786, and also different from other states, then no company will be able to sell so much as a quarter-ounce tube of lip balm without first checking to make sure they are not in violation of 51 separate cosmetics laws. No small company can do that (and most large ones can't either).
Point 7: HR 5786 does not contain an exemption for small business owners. Many laws in this country exempt small companies because compliance would put them out of business without any real benefit to society. The same is true in this case. HR 5786 treats the smallest company making 50 products a day the same way it treats our nation's multi-million dollar companies. While there is an exemption from the annual payment of fees, the testing and paperwork requirements in this bill place burdens on very small businesses that are unfair, overreaching, unnecessary, offensive and intrusive.
America's Small Businesses Our nation's small cosmetics companies are in large part launched by men and women who want to create alternatives to products that can be purchased at “Big Box” stores. They use a high proportion of naturally occurring ingredients when compared to larger companies, and they are not producing cosmetics on a large scale at all. And that's why their customers love their products, and that's why Congress must make sure that it passes no law that puts them out of business without any benefit to consumers. This is one such law.
Summary Small companies are the backbone of our nation's economy. In fact, today, they are sustaining it almost single-handedly. As unemployment figures continue to rise, small companies are hiring employees, contractors, vendors and other small scale service providers to help their businesses grow.
Consumer Choice At farmer's markets, locally owned spas and boutiques and in the retail stores that small cosmetics manufacturers are opening everywhere, consumers are able to choose to buy a wide and appealing variety of cosmetics to suit their personal needs. They can choose from products made by big companies and they can choose from products made by smaller companies. That choice will be removed if HR 5786 becomes law. if that happens, consumers will be left with a small selection of products sold only by our nation's largest retail chains.
America is filled with talented innovators and entrepreneurs who don't need a big bank loan or a huge line of credit to manage a profitable business. Small cosmetics companies can continue to do their share to carry this nation, but not if HR 5786 passes.
It is the duty of our Congressional representatives to pass laws that are carefully tailored to deal with specific problems that need to be addressed on a national scale. HR 5786 is not carefully tailored to help anyone.
If HR 5786 as drafted becomes law, it will close multiple thousands of small companies immediately and in one fell swoop.
Thanks, JakeL, I WILL take the classic example of parabens, as you suggest. I presume that you have heard of Stacy Malkan, and you may even have read or participated in some of her blogs on her web site “Not Just A Pretty Face”, used to publicise her book of the same name. In a post earlier today, Stacy demanded that safety studies should be carried out; made public and assessed by scientists employed by the government in order to fully satisfy safety criteria. I took the trouble to point out to Stacy that there are many hundreds of published studies in peer-reviewed journals and that, in the European Union, there is a committee of independent scientists employed by the European Commission to scrutinise these published studies and assess the safety of the ingredient in question, and to give an opinion on its suitability for use in cosmetics. This system has been in place for over 20 years. This system meets all of Stacys demands that she makes of US legislation specifically regarding safety assessment. Additionally, in my reply, I pointed out that this independent group of experienced scientists recently issued a report that concluded that methylparaben and ethylparaben are safe for use in cosmetics at concentrations not exceeding 0.8% in total. I then challenged Stacy to accept that parabens were acceptable cosmetic ingredients, as the system that is in place for assessing their safety met all her stringent requirements. For some inexplicable reason, my post was not published. This is the second time that I have challenged Ms. Malkan on parabens, and it is the second time that she has found herself backed into a corner from which there is no escape – so she just censors the comments. At the time of writing this post, I have a pending comment awaiting “moderation” (quite an inappropriate word, under the circumstances), whereby I am challenging her to post my earlier comments and engage in an open and honest debate. She may change her mind; she may not. We will see . . , but I doubt that “credibility” will ever become her middle name!
I have to take you to task regarding your comments about “not having the science”. In order to make a decision on health and safety of cosmetic ingredients, there HAS to be a scientific basis upon which that decision must be made. Toxicology is a science, so how else can the decision be made? If “the science is not there”, there can be no basis for a decision, so that is a perfectly acceptable and logical response, and it is not an oversimplification. The point is that Susan Rolls was representing an organisation trying to force adoption of legislation that required a science-based decision, and the science was NOT there. Making unscientific scientific decisions is less than an oxymoron – there is nothing oxy about it! Proving safety” without doubt” is not possible. Proving an acceptable level of risk based on current knowledge, however, is achievable, and has been acheived for many more ingredients than EWG are prepared to admit.
Dene Godfrey
Let me offer an alternative definition of The Precautionary Principle:
The Precautionary Principle states that as soon as a study is published that identifies any adverse effect for any synthetic chemical, regardless of the quality of that study, or any risk assessment carried out on the results obtained, the Environmental Working Group shall immediately post distorted and misleading stories around the internet, all of which must include the term “toxic chemicals” at least three times.
Ridiculous? I think not.
Returning to your/my earlier example of parabens – a study published in 1998 by Routledge et al, measured in vivo oestrogenic activity in butylparaben (and NONE in methylparaben). Despite the FACT that the activity measured was 100,000 times weaker than oestradiol, and even this minor effect required a dose around 4,000 times greater than any possible daily exposure in humans (plus intravenous injection to administer this massive dose, further exacerbating any adverse effect), this was seized upon as evidence that “parabens cause cancer”. Further exacerbation resulted from the publication of a candidate for the title of The Worst Scientific Study Ever Published in 2004 (Darbre et al), claiming to have detected intact parabens in human breast cancer tissue. This latter study was exposed by many commentators are being deeply flawed in many respects, and there is no unequivocal proof that parabens were actually present in the tissues as claimed and, furthermore, the conclusions of the study stated very clearly that the “findings” did not prove any link between parabens and cancer. That statement, and the other mitigating factors I have just described did not prevent the invocation of The Precautionary Principle and the subsequent campaign of hysterical opposition to their continuing use in cosmetics. So forgive my cynicism when the PP is mentioned, but it is an entirely subjective principle and, as I said before, not a basis for legislation.
Someone should stop the fear-munger’s strategies to manipulate the industry.
This is like sending everyone to jail because they have the potential to harm someone, and only letting them out if they have proven to be on highly mind-numbing brain-drain drugs that make you incapable of using your free will…. HELLO!!
Everyone knows that to develop cancer you actually have to be in a toxic and acidic pH state – cancer does not develop in a pH alkaline body.
Thanks for posting this. This is not about “safety” it’s about money and power.
This is going to hurt all of us Indie Companies who really care about our ingredients & what we offer to our clients! I am making a name for my company & growing every year! If all this passes, it will put myself along with others totally out of business! When I first started this business, I did sign that compact because I thought it was doing the right thing! AS soon as I found out their agenda, I had them remove me off the list & told them the reason why. I actually received a reply from her telling me they would protect all the small indie companies & we would not be affected by the regulations like the big corporations! If you believe that….
Shame on her for trying to persuade me to stay on the compact! I told her no thanks!
Thanks for loading the audio! Its appreciated! I just don’t see how this could be happening in our country! It’s all about the mighty dollar & how much they can benefit! SHAME ON THEM!
Kristin and I started Personal Care Truth for a variety of reasons. The main one being we were and still are, tired of the half truths and fear mongering floating around on the web. The misleading information is sprouting up because of the alarmists cramming scare tactics down the throats of consumers.
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