Parabens in Perspective: Part VII

Posted by denegodfrey on December 20, 2010 · 81 Comments

And finally……..Parabens are safe. IT’S OFFICIAL!!!

In contrast to my earlier posts on parabens, I will keep this one very brief. During this series of articles, I hope that I have provided food for thought and placed the major studies that have contributed most to the parabens hysteria into appropriate context.

It remains a complete mystery to me why so many people would rather place faith in the charlatans and random unqualified bloggers who have been publishing complete rubbish about parabens on the internet for several years, rather than believe the opinion of the independent experts that comprise the EU’s Scientific Committee for Consumer Safety (SCCS). . . people who actually know what they are talking about!

In June 2008, the SCCP (as they were then known) published their 4^th opinion on parabens, which was that methylparaben and ethylparaben were considered safe for use in cosmetics at concentrations up to 0.4% (as before), but the committee required further data on propylparaben and butylparaben before a final opinion on these parabens would be considered.

I am delighted to be able to share the fact that the SCCS have, in the past few days, released their draft final opinion on propylparaben and butylparaben, their conclusion being that these are considered safe for use in cosmetics to a maximum total concentration of 0.19% (of these two parabens) – this concentration is independent of the concentration of methylparaben and ethylparaben.

The information can be accessed via this link:

Scientific Committee on Consumer Safety (SCCS) Opinion on Parabens

And the CTPA comment by this link:

The Commission’s Scientific Committee Gives Parabens a Positive Opinion

Whilst this latest conclusion does reduce the maximum permitted concentrations of propyl and butylparaben, these new maximum concentrations are rarely exceeded in cosmetics, and very few existing products would fall outside of this range, so anyone who subsequently claims that any existing products are not safe as a result of this opinion is guilty of trying to mislead.

Isopropylparaben and isobutylparaben were not considered in this opinion, and industry did not include these in the studies submitted for consideration, and so they are designated as having no definable safe concentration. This does NOT mean that these iso-parabens are not safe, it simply means that there is not sufficient data to draw a firm conclusion on safe levels, which is very different. Products containing these two iso-parabens will now be phased out unless someone decides to generate the required data, which is unlikely.

This latest opinion now means that there are no further question marks over the use of the four parabens evaluated AND THEIR USE IN COSMETICS IS CONSIDERED AS SAFE, BY REAL EXPERTS. I am sure that this will not stop those who adopt a typical chemophobic stance from continuing to publish distortions and lies, but at least I can now say with a greater degree of confidence than ever before – THEY ARE WRONG. You have no idea how good that feels!

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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 Information · Tagged with butylparaben, CTPA, Dene Godfrey, parabens, parabens are safe, Personal Care Truth, propylparaben, safe cosmetics, SCCS

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Melissa Bastian

Just a few things you may want to consider, up there on your “we are right and all you people are stupid” high horse: asbestos was considered safe BY REAL EXPERTS; DDT was considered safe BY REAL EXPERTS. For decades people were told to smoke BY DOCTORS. Sometimes REAL EXPERTS get things really, really wrong. Just sayin’.
- Dene Godfrey
  
  And much more often than not REAL EXPERTS get things right. 3 examples is not enough to justify dismissing all conclusions reached by experts. Science has come a long way since the examples you have provided were an issue. I am loving the high horse moment – I have just been vindicated for the defence I have put up for parabens for the past 6 years. Jump up on my horse – the view is wonderful! (And, just for the record – I didn’t make any mention of people being stupid in my article – please quote me properly if you are going to criticise what I say).
  - http://www.sterlingminerals.com/ Katherine
    
    Dene you make a valid point, and correct me if I am wrong, yet again the reference is made to problems with chemicals as related to environmental issues. In context all of these became problematic in terms of inhalation or ingestion and not through skin contact. Plus I am not aware of a single reference of a doctor actually telling anyone to smoke. The correlation the chemophobes continue to try to make by extrapolating environmental toxins with those used in cosmetics….frankly is beating a dead horse if you ask me….just sayin~
    - Dene Godfrey
      
      Thanks Katherine – I don’t need to correct you at all! In fact, I should add that I am not convinced that asbestos is even a valid example, as I suspect that it was not until it was actually tested that it was found that SOME forms of asbestos can cause cancer. I am not aware of REAL EXPERTS ever actually denying this, once the information was available. (And asbestos is, of course, a natural material., but that’s for another discussion!). DDT was developed as a pesticide in the days before extensive testing was required – again, I am not convinced that REAL EXPERTS ever tried to defend its use once the issues were identified. This is a non-argument, whichever way you look at it!
      
      It would be much more productive to deal with specific issues relevant to the safety of parabens rather than a blanket criticism of those who are qualified to make the judgement – a criticism with absolutely no validity or qualification whatsoever, incidentally. If anyone else wishes to make a point about the safety of parabens, it would be very useful to have specific information on the reason(s) for disagreeing with the SCCS. Then we can have a meaningful discussion.
      - Perry R
        
        It’s much easier to argue against straw men than it is to argue against evidence.
        
        The thing that people forget is that even if REAL EXPERTS get things wrong, it is the REAL EXPERTS who figure out what is right. REAL EXPERTS scientists figured out that smoking was bad for you.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        I guess it just depends on who’s paying the REAL EXPERTS to do the research…
      - Perry R
        
        Doesn’t it depend more on whether the REAL EXPERTS support what you want to believe?
        It seems the fundamental problem with your position (as gleaned from this thread and things I’ve read on your blog) is that you start with what you want to believe…e.g. Parabens are bad, propylene glycol is bad, etc. and you are unable to change your position based on evidence.
        
        What evidence would you need to see that would demonstrate parabens or SLS or any other chemical is not unsafe? Have you ever thought a chemical was unsafe then changed your mind based on evidence?
        
        I understand how this would be difficult for you however. If there was ever evidence that demonstrated chemicals were not harmful, that would pretty much kill the positioning of your business.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        If there ever was evidence strong enough to prove the safety of an ingredient, I’d be happy to change my position. However, I’ve never seen evidence strong enough to change my mind. I’m always going to be on the side of caution, rather than take chances with my health. So it would take a lot for me to change my mind. Parabens, for instance, if time goes on and more studies on their SULT function arise and they all show that SULT function is not affected, and more human studies on estrogen receptors came forth showing that parabens do not act estrogenically, then I would consider changing my mind.
      - Philippe Papadimitriou
        
        If SULT is your only worry, how do you argue when somebody asks you why you accept other ingredients?
        I do not know of any study showing that no rose extract or no fatty acid acts on SULT (even if it is less likely).
        Oleic acid plays a role in collagen and elastine production after all (http://www.ncbi.nlm.nih.gov/pubmed/21146503).
        
        “If there ever was evidence strong enough to prove the safety of an ingredient, I’d be happy to change my position”. What is your strong evidence for all the ingredients you use? Are they really all more documented than the parabens? With such an assessment, I am suprised to even be told you are a manufacturer.
        
        No offence, simple logic.
      - Philippe Papadimitriou
        
        Sorry, I meant “protection”, not production (Oleic Acid).
        I do not know how to edit my comment.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Sorry, I needed to add some modifiers in there…I should have said “If there ever was evidence strong enough to prove the safety of an ingredient that I had previously considered questionable, I’d be happy to change my position.” Hope that clarifies it.
      - Philippe Papadimitriou
        
        What makes you question yourself regarding ingredients?
        
        I have visited your blog and it seems you only question the same old questionned ones. Am I wrong?
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Do you mean what makes me question an ingredient? Well, if there is a history of debate, or studies that would indicate a harmful effect, then I would investigate the matter. Check around my blog–I don’t just question all the usual suspects. I furthered the conversation about Japanese Honeysuckle Extract more than anyone had previously (and actually cleared up the issue if it contained parabens or not), I questioned the “0″ risk score Magnesium Silicate had and brought it to the attention of the Cosmetics Database, I clarified much about Grapefruit Seed Extract and how it’s made, I stirred up a debate about Phenoxyethanol. These aren’t the usual suspects of SLS and Parabens. The last time I had written about parabens before this was three years ago when I started the website…I’m not about re-hashing the same old stuff—I’m about stirring up new debate! I’m also not a chemophobe who says that everything natural is safe and everything synthetic is dangerous. There are several synthetics that I’ve stood behind and stated as safe, and several natural ingredients I suggest avoiding. I’m not one of those bloggers that just regurgitates what others have written; everything on my blogs are original content, and I don’t make a claim unless I can back it up with a credible source.
      - Philippe Papadimitriou
        
        I see.
        If you dig, you will almost always be able to find “nasty things”. So if you only dig where holes do already exist, you will have more success.
        
        I see a problem with your academical/theoretical research (even if I sincerely consider it with admiration). Your obstinence shows you are not fully considering the APPLICABILITY of what you find or claim.
        1) You claim more research needs to be done. Don’t you think more needs to be done on other topics as well? Including essential oil components with phenol functions, for example? Don’t you think Eugenol (to pick one thing) has a low NOAEL? Don’t you think it might be risky to put it in products for axillary contact (a region known for its particular sensitivity, nature and blood irrigation), when eugenol is a known hepatotoxic?
        
        2) I think you are right, the SULT issue is not addressed in Dene’s serie of articles (what does not make it less valid); it’s a parallel pathway to estradiol receptor binding that may have its importance in regard to oestrogenicity. But you didn’t answer my comment in regard to SULTs. SULT1 is a member of a family (SULTs). Do they all show paraben competitive binding (inhibition)? Are they not upregulated when more action is needed? What is the compared Kb between the most competitive paraben and estradiol? What about SLUT1 A1 to D1? What about other SULTs (SULT2 and 4)? Do E1 genetic polymorphisms show differences in binding and what is the most common/abundant polymorphism in the population (as polymorphisms have been shown to affect enzyme function)?
        
        3) You dare make some very dangerous shortcuts in your discourse. You state: “We DO know that estrogen stimulates breast cancer growth (and other reproductive cancers)”. What is your source? Do we have to fear estrogen? Women on the first hand? You also warn us to avoid estogen build-ups in our skin. Don’t you think phytoestrogens contained in plants (mainly in the insaponifiable part Shea Butter you seem to like so much) have a higher Kb than parabens towards SULTs? Their strcuture is far more similar at least. What about cholestrerol; do we need to ban that substance?
        
        I thought an educated scientist, pretending to not be a chemophobe, would positively write “that’s it – Only good stuff!” at the end of her formulas, rather than the obviously more negative “that’s it – No ‘Bad’ Stuff!” (in more visible letters and with a capital b for bad).
        
        You still are right; you bring new lights on some used subjects, with finesse and reflexion. I appreciate.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        I have tried to post my response here five different times, but each time it says that it needs to be moderated, and it never posts!
      - http://www.cactusandivy.com Lisa M. Rodgers
        
        Hey Stephanie -
        
        Posts that contain links must be approved. Your last comment that contained links that needed to be moderated was done so this morning.
        
        Thanks,
        
        Lisa
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Let’s try this again…this is what I’ve been trying to post for the last three days but it never lets me: Hello Phillipe…
        
        Yes, regarding eugenol, that is a topic that I have researched and considered. These are products that I use myself, so much care is taken when choosing these ingredients. I am aware of the phenoleic structure of eugenol and have researched it. Eugenol is not proven to be estrogenic. Here is one study: http://www.ncbi.nlm.nih.gov/pubmed/12495555 Regarding it being hepatoxic, that is only when ingested at high doses. As used in a deodorant at less than a .5% concentration, it doesn’t pose these risks. Know that this discussion about doses is not lost on me, in regards to our previous discussion.
        
        Regarding your questions about SULTs…there is no research that has been done that can answer any of these questions. Study of SULT function has only begun in the last five or so years; I hope that it continues so we have answers to these many questions.
        
        Regarding estrogen….it is widely known in the oncological community that many types of cancers are estrogen-dependent. I don’t have the time to compile a list of studies for you, but here is one: http://www.ncbi.nlm.nih.gov/pubmed/20644568 a search through pubmed archives will give you a wealth of information.
        
        There are some phytoestrogens that I personally avoid, such as soy. Other phytoestrogens can be very helpful, such as the lignans found in flax. You’re asking me to speculate on a theory for which there is not much data regarding their SULT interaction.
        
        I can respect your point about chemophobia…I guess we all have different definitions of it. My point is that some people would suggest avoiding all synthetics altogether in everything, and that is not my viewpoint, as I have suggested that there are some safe synthetics. But, perhaps, by your definition I would be a chemophobe, because I view synthetics with much caution and use the precautionary principle in most situations regarding synthetics.
        
        I appreciate your respectful dialogue, Phillipe.
      - http://www.sterlingminerals.com/ Katherine
        
        Well Stephanie I must say this last statement has caused me to review more in depth your articles at your site. I am disappointed by your marketing approach. It is clear you market to the negative and are a chemophobe, yet you deny this. Your site is nothing more than negative campaigning and is about instilling fear in those that find your articles or your products.
        
        You try to appear objective, however you are regurgitating same info since you begin each article with a reference to the EWG SCORE of every ingredient you write about. Is this your credible source? This shows that you are clearly using them to create the fear you need to make your products seem benign and more healthy for the consumer.
        
        The article in particular I found to be disconcerting was on Phenoxyethanol. You begin the classification of its’ structure citing it’s precursors as being carcinogens. However, as you should know, chemistry is what makes a finished ingredient and changes it’s structure entirely rendering it safer than the components which may construct it, removing any correlation.
        
        http://chemicaloftheday.squarespace.com/todays-chemical/2009/6/19/phenoxyethanol.html
        
        Then you created a rebuttal piece to a challenge made by a scientist taking issue with your article and as I stated here, he and I seem to concur on the premise of your articles.
        
        http://chemicaloftheday.squarespace.com/most-controversial/2009/11/9/a-chemist-takes-stephanie-to-task-on-phenoxyethanol.html
        
        What I found interesting, you based your analogy on the unproven argument that exposure to a multitude of products our body absorbs everyday is what contributes to the toxicload of ingredients. Is that a medical term? Do you have any actual studies our bodies assimilate these ingredients? Can you show conclusively that beyond absorption into the epidermis, these ingredients are penetrating not only the dermis layer but into the blood brain barrier.. …since this would move to a nano particle scenario. How many cosmetic and skincare formulators are using nano particles? Is there a study on this that I have missed?
        
        Question: What ingredient is used to saponify the oils in your body washes, face care and shampoos btw? I’ll assume it is potassium hydroxide (caustic potash, lye) since you can’t saponify oils without it, unless you know of some new chemical reaction I am unaware of.
        
        What is interesting, you reference MSDS for many of your articles on ingredients you don’t care for, showing the potential reaction of an undiluted form further confusing your readers and not explaining the difference between dose and actual risk until Alan Eastman, PhD pointed this out. This shows your bias and the intention of your marketing tactics and is at the very least irresponsible as a formulator and has no basis as an indicator for harm. Plus to date I have not found you to make the clarification where the EWG score indicator is used to help your reader understand it, after stating in this article you would do so in the future.
        
        Furthermore, you state that your articles are an opinion piece, which I find to be a cop out for making a mistake. The reality is, your readers come to respect you based on the information you provide through the offering of your products and a philosophy they support. They do not look at your articles as opinion but well researched articles which you also make claim to in your responses here as backing up everything you write about. This lends credibility and offers facts making your article technically factual and on point. My readers come to expect the same from me and believe me I have made corrections and apologies to my readers when I have gotten it wrong, or jumped to a conclusion without all the actual data available. It goes with the territory, but instead of doing this, you dismiss the contesting of your article as it being just an “opinion piece.” When you know full well it has more of an impact than a mere opinion on your readers…let’s not simplify it.
        
        You may find the MSDS for this ingredient scary and may want to warn your customers of it’s potential harm, since this has danger all over it.
        
        http://www.sciencelab.com/msds.php?msdsId=9927230
        
        However, this would be silly now wouldn’t it, because I am sure your are fully aware that through chemical reaction and upon the completion of the saponification process, it renders it completely harmless and no lye remains in the product.
        
        I also noted you denigrate a commentator on this same article named violet, basically insinuating that her reaction is nothing more than protective posturing due to the crackdowns within our industry and how we wish to continue to sell our water downed products for high profit margins. You not only insult me and others in our industry, but you also have hurt any integrity I thought you might have.
        
        Then you remark to another commentator, Natalja, “What’s wrong with using pure oils and butters? That is, in fact, what I recommend—using waterless products so you don’t expose yourself to these chemicals OR mold and bacteria.”
        
        I made a brief comment earlier in this respect, again this is misleading your customers. What about contamination after the purchase? Do you explain to your customers that with no preservatives and once they dip their fingers or if they should get a single drop of water inside the jar, they now have created a breeding ground for mold and bacteria? Do you explain with continual opening and closing of the jar without the use of antioxidants the qualitative values of your ingredients degrades and 10 month sustainability after opening is unlikely. It would be interesting to put some of your product under a microscope after only 30 days from opening to see what microbes are building a home inside that jar. It would also be naive to think that your customers never inserted a damp hand in to their jar or stored it in a humid bathroom. Your stance against preservation systems is baseless and does not support the actual facts of what occurs with your products.
        
        I apologize if this latest comment seems contentious, but I do get extremely frustrated when those that profess an ideology, make excuses for it when faced with substantiated facts and are faced with the obvious as with your rebuttal to Dene Godfrey article. At this point I agree with Dene, it is futile to continue this discussion with someone who will maintain a stance even when faced with realities of valued information within our industry.
        
        Cheers!
        
        Furthermore, I wonder what your customers would say if you disclosed the “lye” component to your formulas? Your ingredient deck makes it seem so harmless, but don’t get me wrong, it is, but lye in it’s purest form is highly dangerous….I didn’t see an MSDS sheet on that one. You are quick to point out dangers of ingredients you don’t like, but do much to avoid facts on the potential problems with your own products when they are not in line with your business mantra.
      - Dene Godfrey
        
        Katherine, whilst I will always give credit to Stephanie for being so willing to engage, I have to say that, after following the link you provided to her diatribe on phenoxyethanol, I have lost all hope for any value judgement from her. Her understanding of chemistry (one atom away, etc, etc – oh – yes, my recent post on that very subject) is clearly not up to the standard required to enable her to justify her self-positioning as a blogger with some expertise in researching ingredients, and it causes me dismay to see the naive, sycophantic comments of those who read her misleading information. Sorry, Stephanie, that single article removes your credibility for me, and I have to say that,despite your claims to the contrary, I don’t believe that you have sufficient understanding to correctly interpret many of the studies you research. That genuinely makes me sad.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Dene, if you’d like to have an actual conversation about phenoxyethanol, I’d be happy to entertain it. While you’ve made some broad statements about me and my character, you’ve not made a single constructive comment or critique regarding my article about phenoxyethanol or why you disagree with it.
      - Dene Godfrey
        
        Stephanie, I do not mean to be rude or dismissive, but this is not the forum to be discussing phenoxyethanol in detail, and I have no real interest in trying to correct what I believe to be wrong on this subject in your blog Suffice to say that I agree totally with Dr. Eastman’s comments. Every time information is offered, you always seem to need more data, as Philippe observed. Parabens have probably more toxicity data available than almost every other cosmetic ingredient, and experts have judged them to be safe within the specified limits – but you STILL want more data. I can’t discuss this any further, it is simply not productive. Sorry.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Well, if you’d ever like to refute my claims, feel free to come on over to my blog and we’ll discuss it.
      - Philippe Papadimitriou
        
        Dear Stephanie,
        
        While I think the discussions have somehow become childish here (with mistakes here and there, but I am no referee here and do not want to engage on side-subjects), I still find it very disappointing you didn’t address my comments.
        
        For other contributors to know, I also have yesterday sent you an e-mail at the following address: feedback@bubbleandbee.com for you to be able to give me a proper reply on some specific points, points you seem to have forgotten in your diatribe arguing the SCCS was wrong (…) or maybe too prompt with their decision (i.e. wrong). I think many of the points I have listed were either considered or well-understood by the SCCS experts’ panel and a reason important enough for their decision to be valid and safe.
        
        This is science and every single conclusion needs to be reviewed sometimes. There is no such thing as an “exception to the rule” in science, just wrong rules that need updates THIS IS SCIENCE. I am sure the SCCS knows it and will not hesitate one single second if new data appear that demonstrate some estrogen disrupting activites by parabens. This is not the case by now.
        
        I regret that you have spent so much time writing your posts on SULT1 and the parabens to finally think you have won some type of contest. I regret that you have preferred to engage on personal defence. You know what, I do not want to share with you on the subject on your blog. Not that I do not want to (on the contrary and it would even be better for the audience), but I prefer to let you live with in mind a wrong published theory. Your lack of response at my intention shows at least I was maybe not so wrong on this SULT issue.
        
        I wish you great success with your range. I haven’t seen it in depth, but find it fun. Many points to criticize (among which your shelf life – duration after purchase..! production would make more sense), but this is not my objective here.
        
        Take care and Merry Christmas!
        
        Phil
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Phillippe–I just sent you an e-mail but it bounced back to me. I’ve also tried posting my reply here but it won’t let me post the full thing. Maybe it’s too long? I don’t know what’s going on with it.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Katherine—again we’ve strayed from the discussion at hand, but I’ll be happy to address your comments.
        
        First, note that I do include the EWG risk score for the ingredients, but they are far from my only source. Many times I disagree with the risk score that they give. I republish it simply for my readers quick reference, because many people find their scoring system to be an easy-to-understand starting point when making decisions about chemicals. Many times I disagree with scores they give.
        
        You’ve laid out a number of questions, and I’ll try to address as many as I can. Is a “toxic load” a medical term? No, I never stated that it was. I believe your question to be disingenuous. However, there is a concept of body burden, and I don’t believe that I have to cite any studies, you can find them yourself. PCBs, phthalates, PVC…so many chemicals end up in our bodies. Do a google search for “body burden” or “body burden testing” to understand more.
        
        “Do you have any actual studies that our bodies assimilate these ingredients? Can you show conclusively that beyond absorption into the epidermis, these ingredients are penetrating not only the dermis layer, but in to the blood brain barrier?” These are kind of impossible questions to answer, as I don’t know what you mean by “these ingredients.” Before, we were discussing parabens…if you’d like to start another discussion about another specific chemical, I’d be happy to. For a true discussion we have to go one chemical at a time. Again, if you’re not familiar with the term or concept of “body burden” I’d suggest reading up on it.
        
        Regarding your question about potash…yes. That is what is used.
        
        Regarding your comment about MSDS sheets…again a broad statement. Let’s take this one article/one chemical at a time. If you’d like to discuss a particular article or source, I’m always open to improvements and updates to my content. I’d be happy to flesh out any information you feel is inadequate or incorrect, if you’d like to discuss it one article at a time.
        
        Regarding your comments with Alan Eastman…the clarification for the EWG risk score was referring to when my articles were published in a local magazine, not on my blog.
        
        Regarding the articles being an opinion piece, again, this was referring to when my article was published in a local magazine. It’s not a disclaimer I have on my website.
        
        Regarding lye—I think that’s a good suggestion. I’ll add lye/potash to my queue of ingredients to write about.
        
        Regarding molds and bacteria in a non-water-based product…yes that is true. That is why we have very specific care instructions that we ship with our products. I appreciate your concerns.
        
        Regarding your final comments, while you’ve made some broad statements against me, and not addressed any specific articles, you still haven’t questioned anything that I’ve said in my article responding to Dene’s. I’d be happy to discuss any specific points you’d like to make.
      - http://www.sterlingminerals.com/ Katherine
        
        Unfortunately Stephanie you are now debating semantics and you have done an excellent job at deflecting the issue at hand by posturing confusion. My comment is in direct response to your last comment and I have not taken this off subject. My remarks could not be more clear in reference to your comment of backing up everything you claim with a credible resource to which I made a challenge. Plus your reference to Mommy Bliss Nipple cream was grossly overstated. Yes it was a mistake for these ingredients to end up in a nipple cream, but again this was an ingestion of the product to nursing babies. This does not extrapolate to skin absorption. In fact Chlorophenesin was more damaging to the product than phenoxyethanol since if you hadn’t taken the FDA statement out of context and make it seems more frightening than it actually was, it clearly stated the possibility of an interaction of the two ingredients may pose a health risk.http://www.fda.gov/ForConsumer…Furthermore in the ongoing report there had been no incidences of injury and this was a precaution, in response Mommy Bliss Cream was quickly removed from sale. Looking at the two as individual and not in combination, Phenoxyethanol in oral doses is practically non toxic and in skin application has no other issues as a whole.http://ijt.sagepub.com/content…Chlorphenesin on the other hand has some highly toxic attributes and is not commercially available in the United States and it clearly states in the warnings; it is not approved for use in small children. So this was absolutely a mistake and the FDA reacted quickly. http://www.emedicinehealth.com…I gave you the link to both articles in my last comment, and no matter the spin you place on it, your inference to phenoxyethanol is one of being a carcinogen, even though you respond to Violet with the comment 2. My post did not state that phenoxyethanol was classified as a known carcinogen. Yet in your expert opinion as you also emphasize in the continuation of your comments to this article:”Made out of carcinogenic, toxic compounds, phenoxyethanol is an ingredient that I would suggest avoiding.”What would be the inference to this otherwise? The connotation is nothing less of an accusation it is in all probability toxic or carcinogenic based on guilt by association. I also find it ironic that you don’t find it necessary to cite a single study on your supposition but I can go find them myself….that is because there aren’t any to date to fully substantiate your “inference” of absorption through the skin contributing to body burden. Environmental is not the same through ingestion or inhalation as much as you, EWG or the CFSC may wish it to be, based on the fact you do make this comparison in other articles you publish! MSDS references are throughout various ingredient articles and you know precisely in what context you use them. There is no reference I made to whether or not they are inaccurate, but is in reference to the misuse of them to try to inaccurately convey hazard.Bottom line your marketing is geared toward the “us against them” mindset and you do it with the intent, the rest of us in the same business, unless we are formulating to your standards, we are greedy, uncaring, providers of toxic products and for that type of business ethic, I have nothing but disdain for. This was apparent in your denigrating remark to Violet.”These ingredients” as I refer to, is the same broad premise you have provided in your responses to those which disagree with your theories and are stated in your blog and other articles, and they are theories and a personal opinion not based on any sound science. So my question to you was genuine in terms of showing me the studies proving that our skin is absorbing ingredients used in skincare products carrying them directly to the blood brain barrier outside of nano particles, such as in sunscreen materials.However, I realize you are absolutely entitled to your opinion in regard to your beliefs, but I believe your clients would benefit greatly when and if you ever showed both sides to a study of an ingredient, instead of the conveniently lopsided way of showing a potential risk without the final analysis such as we currently now have on Parabens from the SCCS, whether you agree with their findings or not. It is still the other side to your argument, and if you did this, then your clients really would be free to make a choice based on evidence presented for both sides, personal opinion aside. I for one know that sometimes it is difficult to get out of our own way when something we believe is so ingrained in our psyche. But I ask you to take a different tact and don’t further dismiss those who have a valid and differing opinion than yours….especially when the facts support.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        I have no idea how you think I’m deflecting…I went through each and every point you made and responded…I’m sorry if I have missed one.
        
        Thanks for your info about phenoxyethanol…No room to fully respond here, but perhaps this calls for a follow up question.
        
        Happy Holidays!
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Katherine, this is completely counter to what your website indicates. “No gluten, no fragrance, no preservatives.” You seem to indicate that preservatives are bad things, yet here, in order to attack me, you come to their defense.
      - http://www.sterlingminerals.com/ Katherine
        
        Well of course you would take it to mean that. Why is that? What is the basis for my stating this? If you had spent any time reviewing my articles or the reasons for no preservatives, I can assure you, it is not based on carcinogen scare tactics, but on the fact dry inert ingredients don’t need them. I’m surprised Stephanie you didn’t know that. And I concur preservatives can be an added skin sensitizer so why add them when women are trying to get away from irritating ingredients. But this relation as you perceive it has nothing to do with the declaration. You may want to get to know me more through my articles before making statements that have now become infantile and counter productive to the conversation.Movin’ on!Have a lovely holiday!
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Well, obviously powders wouldn’t need a preservative…but the same concept you’re pointing out would also apply to your products…what happens if someone added water to the powder? It too, could become contaminated.
      - http://www.sterlingminerals.com/ Katherine
        
        And I’m sure you researched every single article I’ve ever written, but for the purposes of concluding any further contact with someone who clearly is acting in defiance of being called to task on making declarations of hazard based on opinion and supposition, then I am all too happy to provide you a link to the science.
        
        http://www.ncbi.nlm.nih.gov/pubmed/19120928
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        How does that apply to your statement? It simply states that jojoba mixed with tea tree slows the growth of bacteria…not jojoba alone. Your article doesn’t mention tea tree at all. Just a thought.
        
        And on that note…I’ll be happy to conclude our conversation. I’m taking your suggestions to heart and appreciate your feedback.
- http://www.sterlingminerals.com/ Katherine
  
  Melissa,
  
  Just curious, could you please reference your information to the statement Doctors telling people to smoke for decades? What time period would this have fallen under?
- Philippe Papadimitriou
  
  Experts are people who in the light of all-known data draw objective conclusions. If the SCCS is to once be shown wrong, it would be on the basis of new data, not on the basis of wrongly-considered data.
  Their “final” decision is only final to the date of the report.
- Philippe Papadimitriou
  
  Experts are people who in the light of all-known data draw objective conclusions. If the SCCS is to once be shown wrong, it would be on the basis of new data, not on the basis of wrongly-considered data.
  Their “final” decision is only final to the date of the report.
http://twitter.com/essentialU Kayla Fioravanti

Does this mean we get to formulate with parabens again? Of course not, because we will never be able to unravel the web of misinformation enough to undo this one. What was great about parabens was how effective they are at such low concentrations in formulas — well that an how safe they always were and remain to be.
http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood

I guess you could consider the FDA to be “REAL EXPERTS” as well…how many unsafe drugs do they approve to put on the market that end up killing people because they’re under the pressure by the industry? How much pressure was the SCCS under by the cosmetics industry when they wrote this report? Perhaps here in the US, because of the failings of the FDA, we’re a bit skeptical in placing our trust in “REAL EXPERTS” because they’re so easily corrupted.
- http://www.sterlingminerals.com/ Katherine
  
  Stephanie, what you have stated is also a very broad statement….I assume you have referenced information showing the corruption of these entities or otherwise the experts in the field of studies?
- Dene Godfrey
  
  I cannot and will not comment on the FDA and their relationship with the pharmaceutical industry. Whatever the situation there, it is totally irrelevant to this scenario and does NOT constitute a proper argument against the SCCS opinion – you are comparing apples and pears! The SCCS are in no way pressurised by industry. If you took the time to actually read the full opinion, this would become clear. The SCCS disagrees with much of what industry proposed/claimed. And, let me tell you, the SCCS have a rich history of arriving at opinions that greatly upset the industry. They are a fiercely independent body appointed by the EU Commission and, whilst they have a duty to listen to industry, there is no mechanism by which industry can put any pressure on the SCCS to come to any specific decision. Again, like Melanie, you chose ONE example in order to tarnish ALL experts. This is, at best, disingenuous. I pity you (and Melanie) for your total cynicism. In reality, the bottom line seems to be that you will believe only what you chose to believe and there is no shifting. I can honestly state that, if the SCCS had determined that propylparaben and butylparaben were not safe due to evidence provided, then I would completely cease my efforts – all I need is the evidence – that is what I work on. Even when presented with the evidence, you chose to ignore it. That is your right and your prerogative, but please don’t try to justify your choice by disputing the integrity of the REAL EXPERTS – that is neither fair, nor justifiable, just because you don’t wish to accept their findings. In your blog post, you listed a whole package of things that you avoid, and state that you feel better for it. I am genuinely pleased that your strategy has worked for you, but you cannot use this circumstantial evidence as proof that parabens are not safe. You have avoided several substances – your improvement could be due to any single one of them, or even pure chance. This is not an argument to support an anti-parabens stance – at least, not a valid one.
  - Dene Godfrey
    
    Sorry – I meant Melissa – not Melanie – my apologies!
  - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
    
    Good to know, Dene. I look forward to responding to their paper (which I have downloaded and am reading). My point wasn’t that the SCCS is like the FDA, I’m just explaining skepticism you may encounter by people in the US.
    
    However, I do believe that you’re misrepresenting me here; my personal experience was maybe 1% of my article, and not the crux of my argument (for which you have no response or counter-argument) about SULT1E1 inhibition.
    
    What “evidence” have I ignored? I’ve responded to almost every point you’ve made in your series!
    - Dene Godfrey
      
      The SCCS addressed the SULT inhibition in their opinion, and I apologise if you feel I misrepresented you,but it did seem to me to be an important part of your argument. I appreciate your point about scepticism, but I still maintain that it is not a valid comparison.
      
      The evidence you have ignored is the conclusion of the SCCS! As simple as that!
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        I look forward to reviewing the SCCS paper.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        Looking through the paper here…they do cite the study about SULT inhibition, but they do not respond to it. Also to note, their declaration doesn’t prove that parabens are “safe.” They actually lowered the maximum suggested useage from .4% to .19%. One could also link to this study and say “parabens not as safe as previously thought!”
      - Dene Godfrey
        
        I was expecting that type of comment eventually! This is not a tenable argument. In terms of their use in cosmetics, the two parabens in question are EXACTLY as safe as they were before. The new maximum is determined using a specific margin of safety – that MoS has not changed, and it is essential to note that there will be VERY few products currently on the market that would exceed the new limits established in this opinion. Therefore, they are EXACTLY as safe as they ever were. Again, this is no real argument when related to real life and what has been the historic use levels since the late 70s. In essense, regarding the SULT inhibition they respond by mentioning it – beyond that, it is clearly not a major contributing factor in the final decision. Covered.
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        With regards to SULT inhibition, the studies that have been done are limited, so of course they’re not going to ban an ingredient that’s already on the market, that’s already been used for decades, based on one study. But that doesn’t mean that future findings won’t change the game. Just because they say it’s a “final” decision, doesn’t mean that future data will change their perspective. They themselves say that there are “substantial amounts of unmetabolised parabens were detected in human/pig skin samples (Janjua et al. 2007, Ye et al. 2006, Fasano 2004a) and in urine of exposed volunteers (Carwile et al. 2009). Thus, for human skin, no clear demonstration is given of fast and complete metabolism opinion on parabens of higher chain length parabens into the common and inactive metabolite PHBA, as is the case in rats.” pg 23 and 24. In other words, more needs to be known about the interaction of parabens in human skin. As informed consumers, it is our right to avoid an ingredient that is suspected on so many levels to be harmful.
      - Dene Godfrey
        
        Of course there is always the possibility that some future study may find some previous unobserved adverse effect, but if you argue the case for banning a substance on that basis, EVERYTHING should be banned – just in case! Yes, the data were not as complete as the SCCS would have liked, but the bottom line is that, because of this, they erred very much on the side of extra caution when picking the lowest no observed effect level (LOAEL) of 2mg/kg bodyweight. Had the data actually been available, all the indications are that a higher figure would have been used in the calculations. You have every right to make your own decision, but I don’t see any justification for the use of the phrase “suspected on so many levels to be harmful” – this is in direct conflict with the findings of the SCCS. Suspicion alone is not a good enough reason. And, finally, the SCCS would not hesitate for a moment to ban an ingredient they thought was unsafe – it is totally disingenuous to claim that they did not simply because these parabens have been on the market for so long. They found it incredibly easy to ban methyldibromo glutarontrile, on the market for many years – for example. Another argument that just doesn’t hold water, I’m afraid!
      - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
        
        When did I ever say I was arguing to ban the substance? All that I’ve ever said is that I as an informed consumer I have the right to choose not to use this ingredient.
        
        And I never suggested that the SCCS hesitated to ban the ingredient soley because it’s been on the market for the long time…I was saying they wouldn’t do ban it based on ONE study. (I know it’s getting late where you are, maybe you should go get some sleep so you don’t misread things.) When they banned methyldibromo glutarontrile, I doubt it was based on more than just one study.
        
        Regarding the LOAEL levels, those were based on a Fisher’s 1999 study on rats injected with parabens. This truly has no direct indication of human safety as used in cosmetics. First, the parabens were injected, thus bypassing the SULT1E1 mechanism in the skin. Second, it has been shown that rats metabolize parabens differently than humans.
        
        But let’s say that for a moment I agreed with the SCCS report and agree that (butyl and propyl) parabens are safe at below .19 concentration. Just because they’ve been deemed safe at levels below .19 percent, doesn’t mean that these chemicals on their own are safe. Multiple in vitro and in vivo studies have shown the estrogenic effects of parabens. (Just read the paper.) So, let’s look at this analogy…trace amounts of cyanide can be found in cashews and we can eat moderate amounts of them safely. But that doesn’t mean that cyanide isn’t poisonous. You are taking their paper and stating that parabens are safe as chemicals. Period. But it’s simply not the case. The committee has deemed them safe below levels of .19 percent. That doesn’t mean that parabens as chemicals are safe.
        
        Secondly, American manufacturers aren’t going to listen to the SCCS and reformulate their products based on this recommendation. The industry standard, as you’ve set forth, is at about .3%, almost twice the maximum useage recommendation. Who knows what concentrations US companies are using, especially since we don’t have the industry oversight that Europe does. (Not to mention products that are made in China.)
      - Dene Godfrey
        
        I would NEVER claim that ANY substance is safe without qualification, either implied or overtly. I meant that these two parabens are safe within the constraints set down by the SCCS – I apologise if this was not clear.
        No manufacturer would need to reformulate their products that currently contain parabens – the 0.3% figure you mention includes methylparaben and ethylparaben, and they are permitted at up to 0.4% each, then add in propyl and butyl up to a total of 0.19%, with an overall maximum of 0.8%. I doubt that any curent product exceeds the new limits – it is simply not neccesary – formulators in the USA tend to take a similar veiw to those in the EU – they don’t use any more (of ANY preservative) than is neccesary. I am unable to comment on what the Chinese do,
      - Philippe Papadimitriou
        
        As an informed customer, you have the right to avoid an ingredient or not to use it, yes.
        How informed are you (or any other customer) on other ingredients? Natural ingredients with nasty phenol groups, for example?
      - Philippe Papadimitriou
        
        As an informed customer, you have the right to avoid an ingredient or not to use it, yes.
        How informed are you (or any other customer) on other ingredients? Natural ingredients with nasty phenol groups, for example?
      - Philippe Papadimitriou
        
        “More needs to be known” – you are very demending, aren’t you?
        This is why science never stops and why new scientific experiments are always conducted.
        
        Not easy to know more on human skin metabolism. Most skin models are incomplete and the human ex vivo model does not last long (15-20 days to the most -5 days generally- and still it is difficult to say it the explant is really operational at all levels during this period).
    - Philippe Papadimitriou
      
      This SULT issue is very important. I think it is too new to have been fully adressed by the SCCS (not many articles). I was personally not familiar with it.
      
      What about other SULTs? Isn’t there any feedback loop for more to be produced when more action is needed? What about this story on polymorphism? I see you quote the SULT1 E1, what about A1, B1, C1, D1 and eventual others?
      Besides, I am more than puzzled by the concept of a chemical group being transferred to a component by an enzyme. The definition of an enzyme does not match a protein that is altered when it catalyses its purposed reaction. The sole definition of the catalysis is made false. Are SULTs really enzymes in this regard?
- Philippe Papadimitriou
  
  Just visit:
  
  http://ec.europa.eu/health/scientific_committees/consumer_safety/members_committee/index_en.htm
  
  if you want to ask questions to the experts. Everything is transparent with the SCCS as it was for the SCCP, SCCNFP, Cosmetology Commision or any other such panels.
http://www.sterlingminerals.com/ Katherine

Thanks Stephanie, I found the article and letter very enlightening, and I will concur with the fact corruption is evident, as I find most of our government to be corrupt. However, I don’t necessarily think it negates independent studies by others in the science field. Yet in relation to the pharmaceutical industry which the context of this letter is surrounding, I feel it is a bit of a stretch to include cosmetic ingredient manufacturers within these parameters. As is the FDA statement and something repeated by CFSC, the FDA has no pre market testing regulations, so there really isn’t any basis to accuse the FDA as doing something underhanded in relation to the personal care industry and ingredient studies which are produced independently….so no conflict of interest or really no pressure to allow something when they cannot or are not directly involved with this part of the regulation process. So I still am at a loss as to how your initial comment correlates with the safety of cosmetic ingredients. The argument unfortunately cannot play out both ways.
- http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
  
  I was simply saying that in the US trust in “real experts” may be met with much skepticism because of the failures of the FDA and other organizations that are supposed to protect consumers. I look forward to fully reviewing and responding to the SCCS report.
  - http://www.sterlingminerals.com/ Katherine
    
    Unfortunately Stephanie, I now find your response disingenuous since visiting your website and in particular your comments on Parabens. You have in fact accused the FDA of not wanting to step on the cosmetic companies toes since they seem to have close ties with them. So you ignored the fact of FDA’s lack of regulation in cosmetics to now accusing them of being in collusion with cosmetic companies. It was a given on your premise of corruption with regard to pharma, but clearly your statement on parbens takes it to the level I addressed above. Quote from your companies page:
    
    “Why hasn’t the FDA banned them
    Because they claim that the evidence is not conclusive. The FDA doesn’t want to step on the cosmetic and pharmaceutical companies toes because of their close ties.”
    
    I also find it interesting that your source is from the breast cancer fund, and organization also affiliated with EWG….whereby proving the point that these are organizations comprised of like minded thinkers, pursuing a common goal and convoluted theories being used to support an agenda despite other evidence to the contrary.
    
    Perry I think stated it best in his comment below to you. Furthermore, I find it odd that other leading authorities findings are literally ignored since it would not give credence to your argument against parabens. “There are none so blind, as those who will not see.”
    
    http://www.cancer.org/Cancer/CancerCauses/OtherCarcinogens/AtHome/antiperspirants-and-breast-cancer-risk?sitearea=MED
    
    http://www.cancer.gov/cancertopics/factsheet/Risk/AP-Deo
    
    http://www.fda.gov/Cosmetics/ProductandIngredientSafety/SelectedCosmeticIngredients/ucm128042.htm
    - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
      
      Katherine, I believe you’re looking at a page I wrote over three years ago; I’ll go in and work on cleaning up some of my older articles with better sources. In the meantime, let’s stay focused on the article that I’ve written in response to Denes’.
      - http://www.sterlingminerals.com/ Katherine
        
        Yes let’s Stephanie, as I have only responded directly to the comments you have posted, so if this discussion went off task, I would ask you to please refer to your initial comments. I have remained focused as is reflected in my responses in relation to the comment I am addressing.
        
        Thank you for realizing your information is now antiquated and requires some serious updating. I too have had to do the same with my website as information evolves. Not so many moons ago I realized that something being all natural doesn’t make it necessarily safe as I once use to espouse. Open minds are what bring about change and compromise, while closed minds stifle it.
        
        I for one am pleased with the SCCS report overall and as far as parabens being estrogenic, you cannot also say with any certainty they have ill effects on the body or that the estrogen activity doesn’t come from something other than parabens such as fruits and vegetables. This has been the problem and well stated within other studies.
        
        Personally I would rather have a preservative in my product rather than a product with no preservatives since contamination also occurs after a jar is opened. It doesn’t matter if it is made without water. It only takes a drop of moisture or humidity in a bathroom to compromise the product and to begin the process of bacterial and mold growth, something a consumer needs to be cognizant of, not that it is the best product because it doesn’t need preservatives because there is no water in the product. This is misleading and confusing to consumers and is not telling the whole story about natural or organic emulsions and how bacterial contamination begins. Parabens for generations have served the cosmetic industry well in providing safe cosmetics by preventing microbial growth which in turn could cause serious skin health risk to the consumer if not kept in check through the use of a preservative system….staph comes to mind and that is scary stuff and something I hope I may never experience!
http://www.fit2b.us Beth Learn

I thoroughly enjoyed posting this on facebook for all of my paranoid friends to see
http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood

I just read this…Today, Denmark’s Minister of Environment announced she will ban propyl- and butylparaben in child care products for kids under three years of age. I guess I’m not the only one who opposes parabens…http://www.forbrugerraadet.dk/tema/hormonkemi/analyse-det-mener-forbrugerne-om-hormonkemi/
- http://www.sterlingminerals.com/ Katherine
  
  Stephanie all this shows that they succumbed to the pressure put out by consumer groups similar to EWG and CFSC to ban endocrine disruptors in their nation. And again it shows they reacted out of fear over convoluted theories and poor science. Unfortunately this falls under the premise of old antiquated studies and the decision was clearly reached prior to the final findings by the SCCS. They are acting separately from the EU’s allowance of parabens in products and ignoring the safety determination now in current status.
  
  http://www.forbrugerraadet.dk/tema/hormonkemi/
  
  Short version in english…scroll to bottom.
  
  http://safewarequasar.com/newswire/newswire_january10.htm
- Philippe Papadimitriou
  
  Hello Stephanie,
  
  I have read many of your recent comments with interest today.
  
  I am sick at home for three days now and could only get up today to turn on my computer. I shall have a lot of things to say, but will not have much time in the coming days. I hope to be able to answer the points where I see a problem in your opinion sooner or later.
  
  In Europe, there is the safety assessment prior to market entry. I guess you have heard about it.
  
  For issueing a safety assessment, one expert has to consider the NOAEL or other toxicological values on all ingredients present in the formula. Many ingredients do not have such values (particularly a NOAEL for topical application) and this is a huge problem, but this is another story.
  NB: Most of the “OEL”-finishing values are linked to exposure and are expressed in [mg/kg].
  
  Depending on the NOAEL of the ingredients, the weight of the usual consumer and the application volume, a product will or will not be considered safe for an expert.
  
  A product containing ingredients will low NOAELs will maybe be considered safe when used only for the face of adults once a day (one application of 3-5ml a day for a 60-65kg person), but not for a body product for children (two or more application of 10-15ml a day for a <15kg child); you see there is a 4-fold factor (!) in terms of weight.
  
  Rather than seeing many safety assessors denying the safety assessment on baby body products (face products for kids aged 3 and less being often used on the whole body – "reasonably predictable"), a new regulation was created.
  
  This is the main reason for the concept of posology.
  
  This is only an assumption, but I guess it makes sense.
  
  PS: I have heard of a cosmetic example where everything was perfectly in agreement with regulations and was still not acceptable in terms of safety. I think this is a reason serious enough to adopt the EU safety assessment example in the US.
  - Philippe Papadimitriou
    
    The newly adopted NOAEL for the parabens in question is 2mg/kg (of body weight per day).
    I think I was right above.
Dene Godfrey

I will post this comment here, because I would like to make a general point regarding the earlier comments. It seems to me that we have a relatively new phenomenon – “parabens-deniers”. No matter what evidence is presented, they will deny any credence to that evidence, either by claiming that there is a vested interest involved (even if this is simply irrelevant) or by misquoting other studies, or studies that are not directly relevant. There is simply no way through the mental barrier that has been created, and it is a waste of time trying to convert the parabens-denier. It is, however, important to respond to all points raised, because other readers need to have the other side of the story, and to be able to make up their own minds as to what is correct. Personally, though, I have had enough of the comparisons with the FDA and the pharma industry – these are false comparisons, for whatever reason they may be made. I am personally satisfied that the SCCS came to their opinion based on the total current scientific evidence currently available, and that any data gaps as perceived by the SCCS conspired only to imnprove the margin of safety, as they consequently used a much lower figure in their calculation than would otherwise have been the case – in other words, they erred even more on the side of caution. Thanks to all for your input – it has been an interesting debate.
http://pulse.yahoo.com/_7Y2RWAKE2BFDZADCZMIBI6TK7U Lori

I just know from personal experience that cutting out products with parabens in them I now have significantly less skin irritation. Axing sulfates also significantly helped. I choose to skip them when making my products for that reason.
- Dene Godfrey
  
  I have to laugh at the fact that Stephanie has indicated that she liked this comment! Lori – I am sorry that you are one of the few unfortunate people who DO react to parabens. This is a well;known and well-documented phenomenon. I would entirely agree that you should avoid products containing parabens if you are definitely irritated by them. This does not, however, negate the SCCS findings in any way – with preservatives (of any chemical type) itis an unfortunate fact of life that there may be a small number of people who react on contact. This situation is the fundamental reason behind ingredient labelling – so that people who have allergies or irritant responses can avoid those ingredients.
- Philippe Papadimitriou
  
  As it is totally possible for people to react upon paraben contact, it is not as well-defined as it may be (I do not say this does not happen to you, Lori).
  
  Many people in Japan were claiming to experience methylparaben itching and they even were getting paid for specially-designed stinging tests by distributors or vendors (who wanted to find out about the quality of the products -impurities/full disclosure of ingredients- or manufacturer deontology/honesty for the declaration). Our agent in Japan and a Japanese supplier with whom I am now in quite friendly terms (he still is Japanese..) told me much about that.
  
  A 2000 Japanese study (http://sciencelinks.jp/j-east/article/200104/000020010400A0965372.php) did show that the “methylparaben stingers” were unfortunately unable to really tell about the presence of methylparaben in formulas, when more solid experiments were designed. I had heard about other studies showing the same results, but could not find them. The one mentioned above is for example not accessible through Pubmed/Medline.
  
  In regard to sulfates, the story might be different. Sulfate-based surfactants, like all surfactants (!) may cause irritation because of their inner nature (their chemical structure). Sulfates are old and have been replaced by less irritative alternatives recently (sulfoacetates, for example). Milder options than sulfates do now exist and should be preferred by people experiencing sensibility to surfactants.
  
  Surfactants are a very interesting topic and a joyful toy for the cosmetic formulator (how foam can be modified in terms of density, duration, volume, etc.), but this is not my field of expertise at all. I am also not well-versed in terms of surfactant issues linked to tolerance or the environement. Sorry to add this, but I prefer to be clear not be be questionned on things I do not know much about.
Dani Abrahams

You state that the SCCS says a total concentration of 0.19%. However, when is the consumer made aware of these concentrations? Manufactures don’t have to list the % of parabens they use. What happens when the levels reach over 0.19% for the 2 parabens? Does the SCCS have a study on that?
- Dene Godfrey
  
  There is no reason for the manufacturer to list the concentrations of any ingredients – this would not be commercially viable as there has to be SOME protection of the formulation details – it is already fairly easy to copy any product, and there is no gain in terms of safety. The point of the SCCS opinion is that it is based on a significant margin of safety. This means that a product containing 1% total parabens is still generally safe (although it would slightly increase the risk of irritation,sensitisation). It would be a very rare thing to use more than the 0.19% of these two parabens in any case – a specific study is not neccesary.
  - Dani Abrahams
    
    What about the studies done on parabens exceeding the 0.19%?
    - Dene Godfrey
      
      I am sorry Dani, but your question is very vague. What studies? Dermal absorption? Acute toxicity? Skin irritation? There are dozens of studies that could be carried out. I don’t understand what you are looking for. The SCCS examined all the available evidence, and that included various studies on parabens at higher concentrations than 0.19%. Check out the SCCS opinion. I have said that the SCCS uses a calculation to give a specific margin of safety – this margin is at least 100-fold. As part of this calculation, the SCCS used a higher dermal absorption figure than some studies suggested was the case, and a lower no observed adverse effect level (LOAEL) – so both factors were beyond the worst case scenario. Moreover, they assumed that the parabens were present in ALL cosmetic products to give the exposure figure in the calculation which, whilst they may be used in a large proportion of cosmetics, is another overestimation. So, in all 3 parts of the calculation, the SCCS erred very much on the side of caution (as is right and proper) so, whilst the MoS is ostensibly approximately 100, in reality, it is likely to be significantly more than this. It is important to understand the concept of the MoS being more than 100-fold. The new maximum concentration is not a magical toxicological cut-off point beyond which adverse effects can be observed. In theory, these parabens are safe up to 19% (with zero margin of safety). However, it is, of course, important to have a wide MoS, and I am not complaining about this – just explaining how it works. Is this clear now?
- Philippe Papadimitriou
  
  The SCCS is a European expert panel that gives its information to EU regulations bodies.
  Parabens are considered under #12 of the Annex V (visit: http://ec.europa.eu/consumers/cosmetics/cosing/index.cfm?fuseaction=ref_data.annexes_v2). As you see, there is a restrictive percentage (by now the “old” one). When this will be corrected, this will become a rule and manufacturers will have to be in conformity with this rule (with a period of adaptation – even if this will highly probably not be necessary for manufacturers in regard to the concentrations used today) or be fined.
  
  As such, no consumer info.
  If in the meantime EU customers want to know more about the actual percentage in the formula, they may contact the manufacturer who has 3 weeks to answer with the info, according to the actual version of the EU Cosmetic 76/768/CEE Directive to become in 2013 the EU Cosmetic 1223/2009 Regulation (Article 21 – Access to information for the public).
  
  PS: The SCCS is not officially given credit in the US today. I believe its conclusion are respected (but not enforced in any way).
http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood

Trying one last time…this is my response to some of Phillipe’s questions. It won’t let me post it as a reply

Hello Phillipe…

Yes, regarding eugenol, that is a topic that I have researched and considered. These are products that I use myself, so much care is taken when choosing these ingredients. I am aware of the phenoleic structure of eugenol and have researched it. Eugenol is not proven to be estrogenic. Here is one study: http://www.ncbi.nlm.nih.gov/pubmed/12495555 Regarding it being hepatoxic, that is only when ingested at high doses. As used in a deodorant at less than a .5% concentration, it doesn’t pose these risks. Know that this discussion about doses is not lost on me, in regards to our previous discussion.

Regarding your questions about SULTs…there is no research that has been done that can answer any of these questions. Study of SULT function has only begun in the last five or so years; I hope that it continues so we have answers to these many questions.

Regarding estrogen….it is widely known in the oncological community that many types of cancers are estrogen-dependent. I don’t have the time to compile a list of studies for you, but here is one: http://www.ncbi.nlm.nih.gov/pubmed/20644568 a search through pubmed archives will give you a wealth of information.

There are some phytoestrogens that I personally avoid, such as soy. Other phytoestrogens can be very helpful, such as the lignans found in flax. You’re asking me to speculate on a theory for which there is not much data regarding their SULT interaction.

I can respect your point about chemophobia…I guess we all have different definitions of it. My point is that some people would suggest avoiding all synthetics altogether in everything, and that is not my viewpoint, as I have suggested that there are some safe synthetics. But, perhaps, by your definition I would be a chemophobe, because I view synthetics with much caution and use the precautionary principle in most situations regarding synthetics.

I appreciate your respectful dialogue, Phillipe.
- http://www.cactusandivy.com Lisa M. Rodgers
  
  Hey Stephanie -
  
  As I mentioned in a reply at the end of the comments, when we receive comments that contain a link, they must be moderated. All of the comments you made should be showing.
  
  Thanks,
  
  Lisa
  - http://www.facebook.com/profile.php?id=1051543778 Stephanie Greenwood
    
    Oh thanks, Lisa, I appreciate it.
- Philippe Papadimitriou
  
  Dear Stephanie,
  
  I hope you have had a Merry Christmas (this I hope for all contributors and readers!).
  
  I mentioned Eugenol, but this is only one component. Do you think we have enough data to be sure about Eugenol’s safety? Definitely? I personally think we do not. But in the light of what is published, Eugenol is safe. The same applies for parabens. And Eugenol was not considered by the SCCS. If you want a more complex one, try Methyleugenol.
  But whatever the name of components I will be able to list, I believe you see my point.
  
  SULTs are not a well-known topic, that’s true, but I quoted some other aspects of the subject to let people understand that chances are that this issue of SULT1 E1 is not that problematic. I do not know either, but it is also a matter a seeing an issue in its whole context, not only viewing a part of it, ..out of its system.
  
  Regarding estrogens, I agree. I am not well-versed in the subject to be frank with you and I am sure I may find much on Pubmed/Medline. But this doesn’t mean I may not give an opinion. This opinion is rather on the concept, than on the form. Telling uninformed people about the link between estrogen and cancer is not very constructive. This is a argument bringing fear in a subject that already causes panic. I only regret that you overtly provide this link…
  I see no problem with chemophobes, persons only willing to buy natural stuff or better-informed ones who do not mix things, but are still on the side of caution (as you). I only deplore that such views are spread on the net, as this causes free paranoia. In France, half a million of shower gels + shampoos are sold per day; 370’000 units of fragrance bottles (from all brands) are sold in a single day in the same country (figures given orally at the last French Cosmetology Society meeting). How many problems of cosmetovigilance? 232 cases declared in 2009. Among which 76% were allergic responses… (for the official link -in French-: http://www.afssaps.fr/var/afssaps_site/storage/original/application/180ad73ea3cb1544b0c144efc739a1c3.pdf) Are cosmetic products so toxic? NO.
  I agree that these figures do not include eventual cancers and pathological diseases, but until a link will clearly be demonstrated (when exposure to food, pollution, drugs, etc., etc. is so important in comparison), such problems may not be attributed to cosmetics. They should not at least.
  
  I do not want us to engage on a what’s good and what bad in your products. You make your choices and they seems to sometimes be well-thought out. My take home message here is: if you want to find danger in a ingredient, it is always possible. Dene’s article on water, no matter how ridiculous to some is an excellent proof of this statement.
  
  Regards,
  
  Phil
  
  NB: It should be known than IFRA class 2 (products applied under the the arms) is the stricter of all. Even stricter than lip products. Penetration is enhanced there because of the nature of the skin in this area (thickness, hairs,..) and we all are somehow aware it is a delicate area. It should be told that every woman needs to be cautious when applying a product there, particularly after depilation..!
  Sorry to have gone further than a simple answer with this additional nota bene. It is not aimed at Stephanie. I could have made this a post scriptum, couldn’t I?
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