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An Open Letter to Stacy Malkan – The Dose Makes the Poison

Posted by on February 2, 2012 · 21 Comments 

Dear Stacy,

I have noted that you make the claim that “we used to think that the dose makes the poison, but we now know that this isn’t true”. You are highly vocal in your efforts to sell your book and promote the “Campaign For Safe Cosmetics” and have used this claim in writing and in your presentations in the last couple of years, or so; manifesting itself in several slightly different ways, for example in this link, The Dose Makes the Poison? We Know Better Now.

As you know, “the dose makes the poison” is loosely taken from a quote from Paracelsus, the actual quote being “All substances are poisonous, there is none that is not a poison; the right dose differentiates a poison from a remedy.” This observation was made in the 16th century, and has remained a central tenet of toxicology since that time. Your observation that this is no longer true is incorrect, and I struggle to understand how you feel that there is any reason to claim this. The only explanation to which I can give any serious consideration is that you don’t understand the concept of “dose” in the manner in which is employed in toxicology. For simplicity, you can consider “dose” as being equivalent to “exposure”.  Dose, or exposure, may be a single event, or it could be repeated ad infinitum. It remains a dose, and the dose, therefore, remains the poison.

You claim (in the link above):

Science has come a long way in that past five centuries [since Paracelsus]. Now we know: it’s not the dose that makes the poison, but also the timing of the dose, the size of the person and the toxicity of chemical mixtures — factors that aren’t considered in typical risk assessments.

This further compounds your lack of understanding of the meaning of “dose”. If you actually took the time to read a proper scientific study, you would see that the “dose” is always expressed in terms of weight of substance per kilo of bodyweight of the test subject per time period, e.g.  50mg/kg bodyweight/day. In other words, the dose means all the things you claim it doesn’t – quantity, timing AND the size of the person/subject species. (If a substance is suspected to have adverse effects during pregnancy, for example, it is generally tested at that stage in the test species, so the timing IS considered.)

Also, given that there are millions of chemical substances in existence, I am curious to know on what basis it would be decided which of the trillions upon trillions of different possible combinations should be tested in your quest to discover the toxicity of chemical mixtures. This is yet another example of the lack of understanding of the real world. If a particular combination of substances is suspected to be more toxic than the individual parts, for any specific reason, this could, and would, be tested.

I have no idea what constitutes a “typical risk assessment” in your world (that would be an interesting article to read), but I can give a typical risk assessment from the EU’s Scientific Committee for Consumer Safety (SCCS) that includes all of those things you say are omitted from these assessments – Clarification on Opinion SCCS/1348/10 in the light of the Danish clause of safeguard banning the use of parabens in cosmetic products intended for children under three years of age – all the studies considered in this extensive risk assessment quote the dose in terms of weight of substance per kilo of body weight of the test subject per time period.

This has not suddenly changed, and there is no “new thinking” as you attempt to suggest. Many toxicological studies are carried out on both a single dose basis and a repeat dose basis (to assess the effects of long term exposure), and have been for many decades. I hope that you will now stop claiming this as some wonderful new insight as it is simply not correct. Moreover, I trust that you will actually publish a retraction of your claim as it is clearly and totally incorrect, and serves only to mislead those who do not understand science.

Dene Godfrey

 

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

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  • Dene62

    I should express my thanks to Lisa Rodgers for making think again after my first draft, thereby ensuring a vastly improved letter!

    If anyone has any comments regarding any flaws in my logic or in the content, please share them publicly.

    • http://personalcaretruth.com Lisa M. Rodgers

      No thanks needed, Dene. I hope this encourages others to discuss the subject further.

  • http://colinsbeautypages.co.uk/ Colin

    Nicely put Dene, though I think you were rather charitable towards the original article by Stacey Malkin.  You have paraphrased it in such a way as to make it sound rather more convincing than it does in her own words.  I am not even sure that ‘the dose makes the poison’ is even really part of science. To my mind its just one of those aphorisms that sum up the way the world is succinctly.  You don’t need to know anything about toxicology or chemistry to understand what it is saying.  

  • Dan

    Very measured response Dene, its good that whilst the rest of us bang our heads against the wall someone can put the frustrations into words and take the time to publish, thank you.

  • http://twitter.com/loftsoap Jen Grimes

    I’m still in a bit of a shock that you had to write this post.  The amount of persuasive, very nice-sounding misinformation that persists is truly scary.  Thank you for reiterating the truth. 

    • http://personalcaretruth.com Lisa M. Rodgers

      It’s never ending, Jen. I have a hard time understanding why more don’t see the irresponsibility in providing misinformation to consumers. I’m more determined than ever to put the fear mongering to rest.

  • Lennonmarx22

    Are you familiar with the “Precautionary Principle”? 

    • http://greenskincareblog.com/ Kristin Fraser Cotte

      hi there, Thanks for your comment. We ran a great guest post by Emily Caswell on The Precautionary Principle you may enjoy reading http://personalcaretruth.com/2010/08/the-precautionary-principle-a-cautionary-tale/

    • Dene62

      Yes, I am famliar with the Precautionary Principle, and it is an excellent way of abrogating all responsibility for making an informed, rational decision. It ignores any attempt at a risk assessment and is a mechanism for panicking at the slightest hazard. It fails to recognise the relationship between hazard and risk.I fail to see, however, the relevance to this discussion.

    • http://twitter.com/SueApitoLikes Sue Sawhill Apito

      Realistically — if we all made lifestyle choices based on “where there is smoke, there must be fire” — we’d never drink a glass of wine, put honey in our tea, take a vitamin (or not), eat a spinach salad.  I’m old enough to remember when butter was “bad” and everyone was told that in order to be healthy, they needed to replace butter with margarine.  Then margarine was bad.  Now both butter and margarine are bad and we should be eating oils instead.  But canola oil is really bad…we really should be eating olive oil.  But the monoculture of growing olives might be bad for the environment.  And on and on and on. 

      Risk vs. benefit needs to be weighed. For 50 years or so, aluminum has been suspected as being a possible cause or contributor of Alzeheimer’s disease. But science has failed to prove this. Let’s say you just found out that your grandparents have Alzheimer’s.  For you, a person with a family history — maybe you weigh the facts and decide that the precautionary principle applies and you find an alternative deoderant, and toss all your aluminum pots and pans.  I look at the same ‘science’ and decide, I don’t feel the risk is sufficient that I am willing to give up my deoderant. Conclusions about issues are not black and white.  There are people right now who continue to avoid lavender essential oil based on the precautionary principle — they read one article and decided to believe that article and nothing else they read changes their mind.  The precautionary principle is simply not something that results in the same conclusion for each individual.  100 people can look at the same data and come to 100 different conclusions.  If you are afraid of every product and every ingredient based on “what if” — you will not be able to eat at a restaurant because the chef might be a MRSA carrier and not wash his hands enough; the ice machine might be covered in slime mold and staph bacteria; the waitress might give you a receipt that has BPA and you are afraid to touch it because you might absorb it through your hands; and good heavens…we all know dollar bills are the dirtiest things on the planet!  You could not eat, drink or consume any food; much less use any personal care products!  I understood the point of this article to be, everything — EVERY THING — has risk.  You can even drink too much water and die — but the risks something that need to be weighed in perspective — not feared to the point that you are unable to live a safe, healthy, life.

      • Dene62

        Excellent, Sue – you should consider expanding on that and making it a seperate article on here, imo.

        • http://twitter.com/SueApitoLikes Sue Sawhill Apito

          Thanks…having my own experience with Stacy where I was told lies about the EWG fundraising activities…I think I am too hot-headed to be logical when it comes to more than a passing comment here and there. 

  • JSand MD

    Dene, I think you are missing the real point here. It’s not about how to calculate risk. It’s not even about toxicology. It’s about sloganeering — which is how you get noticed so you can start a “campaign”, gain notoriety, make a name for yourself, sell books, get TV appearances. She lays claim to challenging dogma that is five centuries old. The rest of us were not clever enough to see it, we just bought in to the old ways. It took a really perceptive mind to get out of the box, a new perspective. In short, this is not about science. It’s about human economic behavior. It’s about making a buck. Deep down, Stacy actually agrees with you. But what profit is there in admitting that?

  • Davidhamiltonjeffries

    Likley she will say wahtever helps sell her books and perpetuate fear among everyday citizens like me….

  • http://twitter.com/HealthScout Nancy Michelli

    You obviously create or sell these toxic products.  Your information is archaic and innacurate.  Your type of self serving misinformtion helps to harm people.

    • Dene62

      @Nancy – the article is about a basic principle of toxicology; not about any specific substance. You missed the point, I think. It would be more helpful if you could explain precisely why you think my information is “archaic and inaccurate”, otherwise I cannot possibly respond in any meaningful way, or defend myself against your vague accusations. You make a very serious claim, but not very specific. If by “these toxic products”, you mean parabens, that is a whole different discussion which, I suspect, would be wasted on you (and you are clearly not interested in the science to which that link lead), but I gave that simply as an example of a very rigorous risk assessment. The company for which I work sells several thousand different cosmetic ingredients, from synthetic to nature-identical to natural/organic/Freetrade. The principle of “the dose makes the poison” applies to ALL substances. Again, I am not discussing substances of any specific origin, just the basic principle.

    • http://twitter.com/SueApitoLikes Sue Sawhill Apito

      Nancy – I visited your blog.  You sell products that in overdose — can kill someone.  That makes the products you sell toxic, according to your critique of this article, does it not?

  • http://twitter.com/SueApitoLikes Sue Sawhill Apito

    I just wanted to say thank you for allowing open debate on your website.  I keep coming back because I always get a fresh perspective on many of the issues of concern to me.  “We” disagree on many fundamental issues — mostly about the benefits of living closer to nature and supporting the organic movement through our consumer choices — but when it comes to explaining how “science” works in the “real world” of cosmetic chemistry, no one does it better.  I applaud your contributors willingness to continue to try to explain what to many of us, seem to be simple concepts — everything is made of chemicals, for example. There are real hazards and even toxins out there in our consumer products, cosmetics included. But by raising the ALARM for products or ingredients that realistically present so little actual risk…all I think of is the story of “The Boy Who Cried Wolf”.   

    • Dene62

      I know you are including all the contributors in your comment, Sue, but I would like to say thanks on my own behalf – your comments mean a great deal. I know we have clashed in the past, and we certainly never will agree on anything, but I will keep working on you! :-) Please could you have a quiet word with my friend Nancy, who commented earlier? :-)

      • http://twitter.com/SueApitoLikes Sue Sawhill Apito

        I hope you meant to way we will never agree on EVERYTHING rather than never agree on anything!  You forget…we first met years ago when we agreed that the woman selling her “paraben-free” cosmetics that were full of japanese honeysuckle extract — was lying to her customers!

        • Dene62

          lol – well spotted – I wanted to make sure you were reading it properly – of course I meant we will never agree on EVERYTHING! :-) We do agree on quite a lot, though!