Lead Astray by the “Campaign For Scaring Consumers”

Lead in lipstick – is it an issue? It is for the Campaign For Safe Cosmetics!

A recent FDA study of the lead content in 400 lipsticks found that lead concentrations ranged between 0.02 parts per million (ppm) and 7.17ppm. The average concentration over the 400 samples was 1.11ppm. 1.11ppm is 0.000111% – a very small amount. A previous study by the FDA on only 20 different lipsticks found an average concentration of lead of 1.07ppm, and the highest value was 3.06ppm. The full results of these studies can be found here.

It is important to note that the highest levels from the 2 different studies were well above the average in each case. The CFSC is using the results from the single highest in each study to claim that lead concentrations in lipstick have doubled since the first study was carried out in 2007 (from 3.06ppm to 7.17ppm). That claim constitutes an unforgiveable manipulation of the data and is, basically, a lie. Taking one single data point from one study and comparing it with the highest data point from another study cannot remotely be considered as evidence of a doubling of the lead content in lipsticks in general, or even for that specific lipstick, as the highest lead content was found in different brands in each study. I cannot overemphasize just how big a lie the CFSC claim is. The REAL comparison is in the average lead concentrations; the first study was 1.07ppm, the second was 1.11ppm. Statistically, there is no difference in these figures, and there is no basis for claiming ANY increase whatsoever. Given that the second study used 20 times the number of samples, it was almost inevitable that a few would be shown to contain higher levels that those in the much smaller, earlier study.

Exposure to lead is not a good thing, however, and it would be better to avoid wherever possible. The problem is that lead is all around us, thanks in part to the lead compounds used as “anti-knocking” agents in fuel for many decades. It is in the air, in the soil, in our food and in our drinks.

The REAL question is “is the presence of lead in lipstick a significant source of exposure for humans”.

A risk assessment can tell us the answer.

Let’s take the average figure of lead in those lipsticks – 1.11ppm. Let’s then work out the exposure (i.e. how much lipstick is used on a daily basis). One study of 360 women (Food Chem Toxicol. 2005 Feb;43(2):279-91.) found a mean exposure to lipstick of 24mg/day, so that would seem to be a reasonable starting point, but let’s increase the figure for exposure to 100mg/day to consider someone who uses 4 times the mean exposure (and to make the calculation much easier for me!).

1.11ppm of lead in 100mg of lipstick is a daily exposure of 111ng (111 nanograms – 1 nanogram is 0.000000001g).

Some toxicologists have been quoted by the CFSC (possibly out of context) that there is no safe level of exposure to lead, but there are no studies that give a specific dose that will cause any of the effects to which lead exposure is linked. It is not possible, therefore, to place a specific risk on the use of lipsticks due to the lead content. What IS possible is to place the exposure from lead in lipstick into some sort of context that is meaningful. One way to do this is to look at the lead in our drinking water.  I will take the EPA limit of 15 parts per billion (ppb) for drinking water as the basis for comparison. A small cup of coffee would contain about 100g of water. If the water used in the coffee contained lead at the maximum permitted concentration, this would be an exposure of 0.0000001g of lead, or 10,000 nanograms – almost 100 times the amount of exposure from lipstick (from above – 111ng – using an exposure of 4 times the mean usage of lipstick) – from a SINGLE CUP OF COFFEE! How many cups of coffee do you drink each day – or tea, or water, or beer, or any soft drink?

Even assuming an extremely low daily water intake of 200g, the lead exposure is 400 times the exposure from lipstick! Most people will drink at least 5 times that quantity of water in one form or another. OK, I have taken the lead content of drinking water at the maximum permitted level but, even if your water is one tenth of the limit for lead content, lipstick is at least 40 times less harmful than water. Furthermore, this assumes that all the lipstick applied is ingested (not the case) and that the lead in the lipstick that IS ingested will be available for the body to absorb (again, not the case). The calculation I have carried out errs strongly on the side of caution in every aspect, and still it can be seen that lipstick is by no means a significant contribution to daily exposure to lead. I am not using numbers to play some sort of devious trick to prove a point – these are justifiable numbers erring hugely on the side of caution sufficiently to be able to claim that I may have underestimated the comparative safety factor of 40 by a further factor of 100 quite easily, to give a comparative safety factor of up to 4000. (For the pedantic, this is because I have taken a tenth of the maximum permitted level in water, where a fifth may be closer to the reality, plus a factor of at least one fifth of the likely water consumption, and assumed that all the lipstick is ingested when 50% may be closer to the absolute maximum, and a highly conservative factor for the lack of bioavailability of 20% – which works out at 2 x 5 x 2 x 5 = 100.)

In summary, the exposure to lead from using lipstick is a tiny proportion of the overall daily exposure to lead from water (and I haven’t even included food in the calculation). The Campaign For Safe Cosmetics is making a great deal of noise, because the disinformation they are spreading about lead in lipsticks is scary for the average consumer, and more books get sold and more donations are made to “the cause”. The companies who are jumping on the “scary lipstick” bandwagon are equally guilty of misrepresentation of the facts. Many of these companies promote “natural” products, but they need to be wary of this stance. Someone may start looking at the lead content in the natural extracts – lead is in the soil, remember. I wonder how much they will find . . . . . . . ?

Post script:

It is interesting to note that, amongst the CFSC’s Compact signatories, there is a company, with two products containing lead in the second FDA study.

114 – Colorganics Hemp Organics Purple Haze (1.38ppm)

119 – Colorganics Hemp Organics Purple Haze (1.36ppm)

Given that the CFSC claim there is NO safe limit for lead in cosmetics, I wonder what action they intend taking with their errant signatory?

The safety of cosmetics is a serious subject, but the CFSC are playing games with numbers – without the science (or logic) to support them. Why?

Declaration of interest:

I have absolutely no commercial interest in lipstick whatsoever. However, I know many lovely ladies who wear a lot of lipstick, and I would hate them to stop using it because a self-appointed “consumer safety” organisation decides to twist facts and manipulate data.

  • Dene62

    I would like to make it very clear that I am not specially targeting Colorganics or suggesting that their lipstick is not safe, but simply showing an example of the lack of consistency of the CFSC. It may be the case that many (most?) other products – from other Compact signatories and non-signatories – also contain similarly low levels of lead. In the absence of testing, we don’t know. I will address this in a future article here.

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

      In my opinion, Dene, it’s a matter of public record since the FDA study has been released, appears on the FDA website, and has been mentioned in a blue million posts. The fact of the matter is, one of the CFSC’s own tested positive for lead. As they say in the south, “you need to sweep off your own front porch before you start sweeping mine.” Basically, get your house in order before you start pointing the finger at others.

      I would be interested in knowing how many more CFSC’s “Market Shift” companies have products that test positive for lead.

      Taken from the CFSC website, “Market Shift highlights the 322 cosmetics companies (we call
      them “Champions”) that met the goals of the Compact. Another 110
      companies (we call them “Innovators”) made significant progress toward
      those goals.* This is great news for you, the consumer, and for the
      Campaign, the cosmetics industry and the lawmakers working to pass the
      Safe Cosmetics Act. These 432 companies are leading the industry toward
      safety, showing it’s possible to make products without using the
      hazardous chemicals that are all too common in conventional personal
      care products.”

      Colorganics is on the list of “Champions”.


      Interesting stuff indeed.

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

        I am supposed to be doing other things…but I will check! 

        • summertimebluesandgreens

          If “natural” and/or “organic” makeup lines are using the same FDA regulated colorants then we consumers need to know this. If the colorants contain the lead in question then there is a problem, eh hem, with advertising. This must be said. I am a supporter of small, natural/organic companies but not a supporter of untruths, even if they were unaware.

  • http://demiurgiclust.net shelly

    If Colorganics is a signatory and one of CFSC’s (“Campaign for Scaring Consumers” = yes!) “Champions”, then of course they’d show them more favour than a non-signatory. Not cool, in my book. If anything, they should be held to a higher standard, IMO!

    There was an email forward circulating the internet years ago regarding the whole “lead in lipstick” thing, which Snopes also debunked. So this is nothing really new; it’s just one of those things that makes the rounds every so often. You’d think consumers would’ve learned CFSC is full of it by now. *shakes head*

    • summertimebluesandgreens

      Folks haven’t learned. I remember something from years ago, too. That may be what set me on the path to learn more since I thought that was settled: pigments, no big deal. We just have to keep talking. Go Us!

  • http://www.sterlingminerals.com/ Katherine

    I forwarded this article to Fox and Friends attention to Gretchen Carlson, after seeing her report on Lead in Lipstick.  It was lacking clarity and she provided none of the actual risk assessments equated with using lipstick that Dene has done so well to provide.   She also pointed out the highest numbers as they pertained to only two companies, ignoring the rest.  So much for Fair and Balanced…disappointed viewer.

    • summertimebluesandgreens

      Good. I’ve tried sending something before, too. No response. Sigh…

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

    Posting on behalf of Dene Godfrey:

    Hi Lisa,
    For some reason, I can’t post any more comments on the PCT
    article. Please can you post this on my behalf?
    Stacy Malkan’s blog (http://notjustaprettyface.org/blog/send-a-valentine-to-the-beauty-industry-get-the-lead-out/comment-page-1#comment-85395)
    – I quote: “We want to hear what you have to say to these companies that are
    still selling leaded lipstick — and still saying “it’s safe because
    it’s legal” even though there are no safety standards and no regulations
    limiting lead in lipstick.”
    Well, Stacy, WE want to hear what YOU have
    to say about your own “Champion” selling “leaded lipstick”.
    I also
    challenge you to keep the link to this article that I have just posted on your
    blog. Or will you remove it, like you have with any of my comments that have
    forced you into a corner in the past? You only post the comments you think you
    have an answer for!
    I have no idea why it won’t let me post!

    • http://www.sterlingminerals.com/ Katherine

      I have a question for Stacy, since Dene you can bank on the fact your comment will never see the light of day.  It goes against the very fiber of her being to allow anyone to disagree with her, especially when you challenge with science.


      My question to Stacy’s quote.  If it is safe because it is legal as so many companies claim, but there are no safety standards and no regulations in regard to lead in lipstick, then what about the safety standards as set forth by the EPA and World Health Organization for drinking water? 

      Wouldn’t or couldn’t one assume at that point, that since food, water and our air carry far more contamination of lead exposure, and ppb and ppm ratios are set for safety and all these other daily activities consume 100% of our daily lives as compared to applying a bit of lipstick even at 6-10 times in a day, the levels of lead are still well below those allowed in these other things we partake in as set forth by these health organizations?

  • http://www.facebook.com/joseph.colas Joseph Colas

    this came up with exquisite timing, thank you dene!  last night i saw one of those commercials/previews for the news later in the evening…and one of the “investigations”?  lead in lipstick, thank goodness fox 29 news told people which ones are safe to use and which ones to avoid.  unfortunately i forgot to watch to see which way they took it but being a news show i’m quite sure they went the sensationalist, scare route.  i actually ‘liked’ their facebook page with intention to catch the bit of programming and comment on it, but you can only comment on their posts, you can’t make a ‘free’ post…plus i was tired and forgot to watch the news….again, thank you to you in the industry who work so hard to keep things in perspective…i know it seems like an uphill battle sometimes but please never give up!

  • Dene Godfrey

    Another way of looking at it:Stacy Malkan repeatedly claims that there is no safe dose of lead. If this were true, then a single atom of lead would cause a toxic response (and we would all be long dead!). This is clearly untrue, and if that isn’t scaremongering, I don’t know what is. Let’s turn this around and have a look at what could be considered a safe level for lipsticks, based on the current maximum permitted level in drinking water of 15ppb. I don’t know on what level of water intake the EPA determined that level, but let’s take a conservative 500g of water. 500g of water containing 15ppb of lead equates to 0.0000005g (or 50,000 nanograms) of lead.Using the lipstick exposure of 0.24mg/day (Food Chem Toxicol. 2005 Feb;43(2):279-91.), it is possible to calculate the permitted lead content in that lipstick that would equally the exposure from water by simply dividing 0.0000005 by 0.00024 (0.24mg expressed in grams) and dividing by 100 to give the percentage. This gives a figure of 0.208% which, expressed in parts per billion (ppb – to sound the same as the drinking water limit) is 208,000ppb (208 parts per million)– in other words the “safe” limit for lead in lipstick would have to be almost 14,000 times greater (13866 to be precise). No matter how you massage the figures (100 times the daily use of lipstick, for example, would still work out 140 times safer than drinking water – and just try using that much lipstick, no, try EATING that much lipstick!). 208 parts per million is 30 times greater than the quantity found in the “top-scoring” lipstick in the FDA study. Now tell me that the CFSC are not over-reacting and scaremongering!I wish I’d thought of this before I posted the article!

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

      You are conceding much more to Stacy than you need to there Dene.  You are assuming the EPA are setting the lead limit on the basis of its toxicity.  It is highly unlikely that is the basis for it.  If you were responsible for making sure drinking water was safe you would want to ensure that the water supply is under control rather than permitting any contaminant going so long as it is not at toxic levels.  The approach I would take would be to measure lead levels in typical drinking water, and set a limit a couple of standard deviations above the average.  This would mean that if something goes wrong you have a figure that triggers action.  I wouldn’t be doing my job if I let lead levels creep upwards. Using the EPA limit in drinking water as proxy for the amount of lead that is safe in lipstick is setting the bar extremely high.

      • Dene Godfrey

        You are entirely correct, Colin, of course. I have very deliberately erred as far on the side of caution as the CFSC err on the side of hysteria. That way, it is even easier to justify the figures in the context of safety. I haven’t even bothered to address fully the fact that the majority of the lead in lipstick is not bioavailable and will pass through the body encapsulated in the pigment structure – that itself must add another order of magnitude to the margin of safety. This is my own personal “precautionary principle”!

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

          True, in fact it isn’t even really true to describe it as lead.  It is tied up in a lead containing mineral.  You don’t talk about the risks of the  chlorine content of a product that contains salt.  Add that the wax coating and the chances of any lead getting out of the lipstick into the body become too low to consider.

          I think this has to be the biggest mismatch between risk and panic level of any recent scare story.

    • summertimebluesandgreens

      I tried reading through but I am so angry I’m crying due to outside circumstances. Lead and Stacy and C..whatever. I’ve read it, I’ve tried to argue it. I’m not a scientist, if I could only be twenty years younger. They use this lead to their advantage. No safe exposure. All the other exposures we get means we should avoid lipstick with lead in it. Seriously. Counter it, refute it. Please. The lead we encounter in our cosmetics is nothing. They don’t understand science. I don’t understand science. But thanks to you all, I understand exposure, hazard and risk just enough to make better decisions. I am no longer falling for every scare. I am  not as gullible, thank goodness, as I was. (yes, I am giving deserved appreciation. guess who else could use some but in a different way)

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

    There is a new facebook page started by the same people that administer the Campaign for Safe Cosmetics page — Kiss the Lead Goodbye. Problem is…they only want to kiss it goodbye if the lead is in corporate brands! Here is their self-described mission: “Help us kiss lead in lipstick good bye! Why? Lead is extremely toxic, and there is no safe level of exposure. Yet some of the most popular brands of lipstick — hello L’Oreal, Cover Girl, Maybelline — contain the highest levels of lead. Join our page and send a message to the cosmetics industry: It’s time to get lead out of lipstick!” Point one: while there is no safe level of exposure per se, there are levels that are not considered a risk – and the amount of lead fall into those levels. So the amount in lipstick is not a concern.

    Point two: why is lead in “popular brands” more hazardous than the amount in brands that signed the Campaign for Safe Cosmetics compact and which are marketed by the Environmental Working Group and the Campaign?

    “Market Shift highlights the 322 cosmetics companies (we call them “Champions”) that met the goals of the Compact. Another 110 companies (we call them “Innovators”) made significant progress toward those goals.” Clearly the goals do not include lead free cosmetics!! WHY…if they have known for years and are genuinely concerned…why ignore this when creating a criteria for their marketing report?

    “In October 2007, we released a report, “A Poison Kiss: The Problem of Lead in Lipstick,” detailing test results that showed that lipsticks from top brands sold in the U.S. contained lead.” Does the Campaign only care about lead in the “top brands”? It seems so. Their Market Shift marketing document was published over four years after THEY first alerted consumers to the fact that there is lead in lipstick. So why wasn’t lead…or lack of lead…a criteria for being a Champion or an Innovator?

    I know why…because if it were…ZERO companies selling colored cosmetics would be in their report!

    Lets see the Kiss the Lead Goodbye videos condeming the Market Shift Champions and Innovators brands…then see how much support the Campaign gives to getting the lead out. Because IT IS IN THOSE LIPSTICKS TOO!

    Campaign for Safe Cosmetics misleads consusmers with it’s Market Watch report.

    The organization claims “In order to get the gold standard status of Champion, companies had to fulfill all tenets of the Compact, which include: “Disclose all ingredients, including ingredients in “fragrance,” which in the United States can be claimed as “trade secrets,”even when they contain hormone disruptors, carcinogens and other harmful chemicals.”

    The CFSC is only concerned when the “popular brands” contain lead.

    They publically claim their Champions merit GOLD STANDARD STATUS meaning they “Disclose all ingredients, including …carcinogens and other harmful chemicals.” yet the Champions and Innovators lipsticks contain the EXACT SAME pigments/colorants in their lipstick so they hide the VERY SAME LEAD in their lipsicks!!

    This is FRAUD.

    • summertimebluesandgreens

      They’ve painted themselves into a corner.

  • http://www.sterlingminerals.com/ Katherine

    Campaign for Safe Cosmetics is not about TRUTH whatsoever.  There were several running threads on an FB page called Kiss Lead Goodbye, created by CFSC again.  We were providing the science, links back to their webpages showing the over blown video of get the lead out, proving their hypocrisy and Dene Godfrey provided mathematical analysis as he has done here.  Another consumer in favor of what the CFSC is doing also chimed in against what we were saying, most of which was quite civil on both Dene’s and my part, however, as is in most cases the proponent for CFSC at a certain point became defensive and snarky, lacking graciousness, and in several cases was rude or condescending, but nothing over the top for it to be flagged.  CFSC saw fit once more to remove every single one of our comments and remove the thread entirely. 

    Good healthy debate or anyone in direct opposition to them or trying to share the science, are censored each and every time we attempt the impossible it seems.  For lack of  a better terminology, Campaign for Safe Cosmetics has finally earned the title imo, of a group of political chemophobes, stirring controversy just to make a buck. 

    Shame on YOU to the CFSC groupies that run the page Kiss Lead Goodbye, for not allowing a dialog to play out and for others to learn for themselves the truth, instead of only YOUR half truths. ~DISGUSTED~

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

      Of course you are absolutely right Katherine, but it is also noticeable just how little popular interest there is in this story despite a lot of coverage in the mainstream media.  Stacy’s blog post on the subject has attracted no comments, not even from Dene.  My video is still linked from that Facebook page but looking at my analytics I can’t see any evidence that anyone has clicked through from there to view it.  (That probably explains why it is still there.)  There are huge numbers of posts on Twitter but given how well funded the ‘advocate’ groups are and how often exactly the same phrases get use that is quite likely to be more the result of a cheque book than genuine outrage.  

      I have mentioned the story to a couple of people whose reaction was that they aren’t worried by low levels of anything.   It could well be that the scaremongers are underestimating the public’s common sense on this one.

      • http://www.sterlingminerals.com/ Katherine

        Thanks Colin for that.  I realize the same thing and for that I am grateful the valid information is getting out there to the masses.  And after seeing the info on Their Champions list and them removing the pre market testing rules for absolute safety, to be a so called champion, it is clear to me that this level of expectation was never going to fly in legislation. 

        Since it appears we are systematically dismantling their “credo” piece by piece, I guess it was time to resurrect the old “lead in the Lipstick” campaign.   It seems if they don’t have something to gripe about, they would become non essential to those that find danger under every rock. 

        Besides, maybe book sales have slumped and they needed to revive it again since I noticed Stacy Malkin shamelessly shows her book in every marketing piece surrounding this latest of attempts to exploit fear and solicit funds over LEAD in LIPSTICK. 

        Thinking about it, It would be so exhausting to live life that way.  ;~P

        • summertimebluesandgreens

          I see articles sometimes but it seems to have died down a lot…for now. We’re too busy arguing over other things.

    • summertimebluesandgreens

      I’ve learned when you don’t have anything intelligent to add and you start being sarcastic and snarky, you’ve lost the argument.

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

    I have just done a search on ‘lead in lipstick’ on Twitter and the majority of the tweets that came up were debunking rather than scaremongering.  It was early morning in the UK and so in the middle of the night for the US, and there were some that were the result of Chris Flowers of the CTPA appearing on a local UK radio station.  (The story hasn’t made main stream media in UK.  So I suspect that the trend will reverse again shortly.  Even so I don’t recall a previous scare where the social media were so ambivalent.  I think scaremonger credibility is steadily leaching away.

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

      Companies are using this as a marketing tool saying “don’t buy XYZ” and listing a lipstick that was tested — buy OURS instead — no lead.  Only problem…they have not been tested.  I checked to see what Ava Anderson Nontoxic uses since the company was featured in the ABC NEWS blog article (no surprise…I wonder how the folks interviewing the people from the Campaign for Safe Cosmetics “happened” to find this company…$$$!!!)  Anyway, they use BEETs for their colorants.  Not legal in the USA for cosmetics.  And so I looked further…beet power contains lead.  The Handbook of US Colorants says so and so do the suppliers who sell the ingredient.  SURPRISE (not).Here is my article with graphics: http://sueapitolikes.com/2012/beet-powder-contains-lead/

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

        Excellent point Sue.  I have taken the liberty of posting a link to that post on the lead thread over on Facebook in response to someone who was asking about the lead content of lipsticks in general.

  • Vickieebw

    Is this different from the lead based products coming from China? I have had two clients, years ago, that had what looked like burns on their lips and they were using a brand named lipstick that was made in China. I would not trust anything coming from China, I am wrong in this line of thinking? Thank you for all the great work you do! Vickie

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

      Vickieebw, I think you are right to be concerned about some of the cosmetics coming out of China.  I have had direct personal experience of high lead levels in Chinese produced materials and there are published figures as well.  It isn’t so much the lead itself.  Although the levels are higher than the levels being talked about here, they are still pretty low.  The problem is that it indicates a lack of control in the manufacturing process.  I don’t think lead would cause burns, but if lipsticks are being made in poor conditions you can’t be sure what is in them.  That in itself is reason enough to avoid them.  US, Japanese, Korean and European manufactured product is safe and there is still plenty to chose from.

  • http://www.timeforwellness.org/ Info

    Wow! I have been searching the published literature for an estimation like this and there isn’t one, which is a bit crazy considering that a number of toxicology reviews and the CDC advice avoidance of cosmetics to minimize lead exposure.

    Thanks for putting this together!

    • Dene62

      Thanks – it’s always good to be appreciated! Please feel free to pass the information on :-)

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

    In case anyone missed this article – really nails the lead issue on the head!


  • Alheeley

    Talking of nails, formaldehyde and DBP in nail varnish are the next line of panic from the Lead Lipstick brigade. As usual I expect  are not geting e full or balanced picture from the “All-Chemicals-Are-Evil” lobby.

    • http://www.facebook.com/SueSawhillApito Sue Sawhill Apito

      As a person who gets very ill from these ingredients – I must disagree.  They are not safe – which is why most popular/well-known brands have removed them.  I seriously doubt all of these companies would buckle to just peer pressure…there is science to support avoiding them as a consumer.

  • Karlin

    I think you have your zeros up the wrong tube sister. A MICROGRAM has 6 zeros, and that is what relates to “PPM” since “a millionth” is six zeros, not 9. But its a small deal, don’t worry, other zeros are everywhere.

    Furthermore, lead is accumulative. Your advice that “since lead is everywhere, go ahead eat your lipstick” seems over-the-counter-intuitive [ ha ha, I am so funny, as in brain damaged]
    Common sense says – “if there are NO other sources, go ahead”… but adding more, even in small amounts, to an overloaded biological system makes no sense.

    You sound like an apologist for corporations – I read some of your other articles too and gee by golly did you go to business school?

    • DeneGodfrey

      Karlin, I can assure you that I am NOT your “sister” – proof of which is in the fact that I have fathered two children! A microgram does not have any zeros – a microgram is a microgram. 1 part per million = 0.0001% – you cannot aways claim a certain number of zeros for ppm, because it depends on the units and the context.
      Yes, lead is accumulative, but you have taken this out of context on two levels. Firstly, only lead that is bioavailable can possibly be accumulative – the rest (as in the majority of lead in lipstick) is NOT accumulative. Secondly, there are studies that have demonstrated that approx 50% of bioavailable lead actually accumulates – you have made the mistake of assuming that ALL lead absorbed/ingested accumulates – this is incorrect. On what authority do you state that the biological systems are “overloaded”? That assumes we are all overloaded with lead already, if I understand you correctly. How can that be true? We would be dead!
      I am not going to respond to your comment about me being an apologist (for anyone or anything) because that is beside the point of the article, and I find the concept ridiculous.