Many associations and individuals claim that cosmetics are not safe. These people have lost confidence and think cosmetics are dangerous; they believe many cosmetic ingredients are “toxic”.
Where are the data that support their attacks on the industry? Nobody seems to really know, but the problem persists. Or let me rephrase: some data are available, but they do not systematically reflect facts (but also many assumptions). Conclusions made based on these partially-flawed data (note a) tend to forget some important facts (cosmetic safety has been proven over the years, for example) and are “de facto” not very conclusive.
On top of that, there is an “X” factor in this story. Safety, in the opinion of the assailants, has many aspects, many angles to be viewed. But do all consumers only understand these many aspects? Does the cosmetic industry really have to reply about safety only?
One can see articles in public magazines concerning cosmetic “safety” also considering animal testing or carbon footprint. The David Suzuki Foundation’s report on the “dirty dozen” was also making the confusion between safety and other aspects recently. Marks are being given on the EWG’s Skin Deep data base according to multi-criterial hidden parameters (so it seems), with the aim of finally assessing “safety” when far more than what is usually considered safety is actually under scrutiny.
I think it is time to reveal all the criteria I assume to be commonly considered under “safety” by the opposing parties and define whether or not it is legitimate to use them to rate cosmetic safety; because semantics are not to be forgotten when dealing with such an important subject.
The criteria chosen by them seem to be:
1. Does the end product show toxicity/tolerance issues towards humans when used in normal or predictable conditions (note b)?
2. Do any of the ingredients in the end product show toxicity/tolerance issues towards animals/humans when used at the usual appropriate dosage, and in the light of the other ingredients present in the formula to avoid any unwanted chemical reaction?
3. Do any of the ingredients in the end product show toxicity/tolerance issues towards animals/humans when used pure?
4. Did the manufacturer of the end product do some toxicity/tolerance or other tests on animals (other than humans)?
5. Did the suppliers of each ingredient contained in the end product do some toxicity/tolerance or other tests on animals (other than humans)?
6. Is the production of any of the ingredients present in the end product harmful or disruptive to the environment and wildlife? This in the short, medium or long term?
7. Is there any toxic or environmentally-unfriendly substance used during the production of each ingredient entering the end product? How does the manufacturer of the ingredient get rid of this substance and does it eventually accumulate in nature?
8. Is the elimination of any of the ingredients in the end product harmful or disruptive to the environment and wildlife (after washing or if excreted as such after use by the human consumer)? This in the short, medium or long term?
9. Is any metabolite (product of the human metabolic process) of each of the ingredients contained in the end product excreted after use by the human consumer (urine, sweat, etc.) harmful or disruptive to the environment and wildlife? This in the short, medium or long term?
10. What is the carbon footprint of the production of each ingredient and, eventually, the carbon footprint of the production of the end product?
11. Are any of the ingredients present in the end product coming from a poorly sustainable source?
12. Are any of the ingredients present in the end product prone to more forest destruction if bigger production volumes are to be expected?
13. Do the ingredients accumulate in the body over time, letting toxicity issues rise after years of exposure or a certain threshold of dose?
And sometimes also:
14. Are any of the ingredients present in the end product being used in another badly-regarded industry or in other unappealing products outside cosmetics? Or
15. Does the end product contain any synthetic substance?
When cosmetic scientists consider “safety” issues, they stop at point 2. It is regrettable that point 13 is not addressed, but due to knowledge on skin absorption and fast metabolism (note c), this is not accounted. The “weakest link”, in my opinion, but not one of definite concern. One to improve nonetheless!
Point 3 is not important as all cosmetics are mixtures and very few ingredients are used in concentrations sufficiently high to require the same handling conditions as specified in the MSDS for the neat material (there still is some talent behind cosmetics, I swear).
Points 4 and 5 are cruelty issues and this is already well-looked-upon by regulations on animal testing (4 is not a point to consider any more in Europe and starting from 2013, 5 should not be relevant any more – there is a deadline on this for all ingredients used in Europe and I doubt there are many ingredients used in the US or elsewhere that are not being used in Europe).
Safety is indirectly concerned, of course, but not human safety.
Points 6, 7, 8, 9, 10 11 and 12 are environmental issues, not safety ones.
Points 14 is simply misunderstanding (not anything related to safety).
Same for point 15 as people think natural substances to be safer, which is wrong (if they could only see what difference it makes to be able to synthesize a molecule found in nature rather than exploit huge fields on the other side of the world to extract it! – this avoids destroying nature and keeps land available for food! (note d).
I do not say points 4 to 12 should never be considered; I say they are not human safety issues. If safety is viewed on a broader scale than just human safety (this is not the common view within the cosmetic industry), yes, there is some work to do but be sure sustainability, biodegradability, biodiversity, renewable energies, or ethics and environment in general are now aspects being worked on tremendously (some will say too late; they will maybe be right, but this is not the point).
I deplore the “chemophobes” who mix all these aspects to finally only speak about safety as, when most read safety, they actually read “human safety” (and so do cosmetic scientists). This is doing wrong to the whole industry.
If one takes out points 4and 5 (somewhat soon addressed) and 14 and 15 (simple nonsense), this leaves the cosmetic industry with no innovation at all. Thinking a bit more, this leaves the cosmetic industry with almost nothing. An inert cosmetic product (no real efficacy) based on one or a couple of ingredients at the most, unless point 10 does not become the major last selection factor. Don’t you think it would be a waste to only have organic vegetable oil to be used as a cosmetic product? Not any organic vegetable oil, but only the one produced by your neighbor, out of the plant from the field in front of your house, please.
Where would all the talent be? Where would all the innovation be? Where would all the efficacy be?
It is up to everyone to make their own choices about what to put on their skin or face, just as it is up to everyone to choose what they eat. But it is not up to a minority to choose for all others by selecting other criteria than safety to judge “safety”.
If this attack happens to be deliberate, it is sad, incomprehensible, and intolerable.
If all this turns out to simply not being well-thought-out, it is not an attack towards the cosmetic industry, but a call for “degrowth” (or “powerdown” – “décroissance” in French). And it would still be sad, incomprehensible, and intolerable that this takes the form of an attack towards the cosmetic industry.
De-growth and the safety of cosmetics is not the same fight. I personally think de-growth is needed, if not inevitable. I personally have a lot of facts to share regarding ingredients’ safety nonetheless.
Some more evidence for the Skin Deep data base’s inaccuracy is presented here:
“International use restrictions”
This would seem to be an excellent idea to judge the safety of one ingredient, but this is badly addressed, as incomplete.
International uses are of eventual interest as they show a product is under restrictive use in some countries or even totally banned (restrictions or bans are important as they show safety is not considered perfect worldwide), but when the nature of restrictions are not explained, it only induces fear.
Restrictions in some classes (leave-on vs rinse off, for example) may exist as safety or might be an issue in some particular conditions or applications methods, but these restrictions are hints that demonstrate safety has been clearly evidenced in other classes!
Take Chlorphenesin, a preservative, as example. Chlorphenesin is allowed up to 0.3% in cosmetic products in Europe and the US (two of the three biggest regulatory blocs). On EWG, one finds that there is a restriction on Chlorphenesin in Japan (the third of the three biggest regulatory blocs). This is scary, because one thinks Chlorphenesin is not accepted in Japan or maybe only allowed up to 0.05% or 0.1% (who knows?). EWG should clearly mention that the restriction applies to “mucous-membrane-contacting products” (lips, eyes, intimate hygiene) only. This is fact, not scare tactics. It doesn’t mean it’s safer in all aspects; only that it’s still regulated at 0.3% in both rinse-off and leave-on products in Japan. Such a dosage might then eventually be considered safe worldwide except for “mucous-membrane-contacting products”.
Additional fact (not considered on the data base, but easily proven on the web): Chlorphenesin was used between 0.5 and 1% in pharmaceutical foot care bactericidal products. As conclusion, one reader could at least accept to use this ingredient in foot creams and lotions up to 0.3%.
-> Without knowing the nature of the restriction, Chlorphenesin become unsafe in the mind.
This information is lacking on the data base and it does not offer a full overview of the safety. Showing only one side of the medal is not showing the medal.
These are also of use, but they are not correctly addressed either (not coming back on judging safety positively or negatively when a data gap is 100%, which is simply absurd).
This gap in particular: “Not assessed for safety in cosmetics by industry panel”. Expert panels on the safety of one ingredient are only created on either cases of serious toxicity doubt or eventually repeated attacks by consumers (lesser doubt – the case of parabens). If no conclusions have been requested, it is because there was no need; conclusions were already well-established. A data gap of this kind should then be improving the safety of the ingredient rather than improving its potential toxicity in the mind of the reader.
Quoting Medline/Pubmed is good, but not explaining the articles (which is of course unfortunately impossible) is not appropriate. Does the usual reader understand the title of the articles listed or the abstracts if she/he follows the links? Does she/he have the knowledge to:
1) understand the meaning of the abstract and the value of the conclusions?
2) question the materials and methods or the relevance of the study or its application?
The Darbre study (Darbre, P.D, Aljarrah, A, Miller, W. R, Coldham, N. G, Sauer, M. J. and Pope, G. S, J. Appl. Toxicol. 24, 5 – 13 (2004)), is probably the worst and most-known case to be mentioned. No one should refer to such a poorly conducted study.
(b) The mention of “normal or predictable conditions” refers to the fact consumers should be aware of the proper use of a cosmetic reference. Eating a foundation is not “normal” and not “predictable” in this sense. But it is predictable that a product designed for the peripheral area of the eye might somehow go in the eye during application.
(c) Please refer to Colin’s article “Do Chemicals in Cosmetics Accumulate in Your Body?” and the comments by Cindy and Dene on this article.
Philippe Papadimitriou, R&D manager at Hormeta SA, conducted studies in biochemistry at the University of Geneva in Switzerland, where he majored in pharmacology and neurosciences. Thanks to his strong background in physiology and cell biology, he also acts as a consultant for companies in the cosmetic field when it comes to the development or selection of ingredients. Philippe is a member of the Jury of the International Exhibition of Inventions of Geneva dealing with new ideas, concepts and creations in the class “food, drinks, cosmetics, paramedical, health and hygiene” since 2004, year when he finished his studies and integrated Hormeta Labs. He is a member of the Swiss SCC (Society of Cosmetic Chemists) since 2005.