March 24, 2012
Mr. Clay Alspach
The Committee on Energy and Commerce
Subcommittee on Health
2125 Rayburn House Office Building
Washington, DC 20515
Re: Examining the Current State of Cosmetics Hearing
Please accept the following as our formal statement, for the record, in regards to the ‘Examining the Current State of Cosmetics’ Hearing, Tuesday, March 27, 2012, at 10:15 a.m. in room 2322 of the Rayburn House Office Building.
Personal Care Truth Statement for the Record
As a group of independent business owners representing the interests of the cosmetics industry, Personal Care Truth believes in transparency and truth when it comes to the creation of cosmetics. And while we, too, fully support safe cosmetics and the need for the FDA to be more transparent, we don’t believe instilling fear is the way to go about it. Reviewing and improving current legislation related to the cosmetics industry is beneficial to all involved –from manufacturers to the ultimate consumer. But rewriting that legislation to meet the wants of a few – specifically non-governmental organizations that have not presented the science behind their arguments – does not benefit the whole. The cosmetics industry has a proven track record of safety – putting unnecessary regulations on the industry will be costly to implement and will likely do little to make cosmetics safer than they already are today.
We ask that the Subcommittee on Health base their decisions on scientific facts. We would like to share a few comments from industry thought leaders:
If consumer groups are concerned about formaldehyde and heavy metals in consumer products, they would be best served by drafting a bill that addresses formaldehyde and heavy metals in cosmetics and food products. (Consumers are exposed to very much more lead in food than they are in lipstick.) Using scare tactics to introduce sweeping new regulations with unknowable ramifications is neither sensible nor necessary.
Robert Tisserand, Expert in Aromatherapy and Essential Oil Research
Despite the fact that the skin care industry is the safest industry, it may be time for updating cosmetic regulations. However, new regulations need to be based on sound science and not hype, misinformation and scare tactics often used. The past several years has seen a spike in small, woman owned cosmetics companies. This is good because it benefits the economy and gives consumers more choice. One negative aspect though is that some small companies are not aware of the current FDA regulations concerning cosmetics. This is evidenced by blogs that continuously claim that the FDA has no regulations concerning cosmetics. Changes need to address ways to inform small startup companies of FDA regulations and good manufacturing practices (GMP). Any new regulations need to fit these small companies (especially when it comes to GMP) and not just the large manufacturers. Cosmetic regulations should not be stricter than regulations in the food industry. There needs to be a perspective on what causes cancer, because the term ‘carcinogen’ is used loosely. Minute (and harmless) amounts of suspected carcinogens that may occur in a product need to be taken into account. This is especially important in considering that all plants produce minute amounts of carcinogens, yet scientific studies show that eating plants decreases our risk of all cancers. We cannot have regulations that ban all ingredients containing carcinogens especially when in the food industry these same plants are considered generally recognized as safe (GRAS). More research is always good, and I encourage funding for more research on cosmetic ingredients.
Cindy L. A. Jones, Ph.D.
Sagescript Institute, LLC
We thank you for your thoughtful consideration as you review the legislation placed before you.
Lisa M. Rodgers and Kristin Fraser-Cotte
Co-Founders, Personal Care Truth