The “Campaign for Safe Cosmetics” (CFSC) is a misnomer. It is NOT a campaign for safe cosmetics. It is a part of the political lobbying process engaged in by the Environmental Working Group, amongst others. In other words it is part of Ken Cook’s ragbag army of professional lobbyists (one of whom actually lobbies for an oil company), career anarchists, and a large number of well-meaning, but naive, dreamers. They rely on misinformation, disinformation and downright lies in order to scare the ordinary consumer.

I find the existence of a campaign for SAFE cosmetics an abhorrent insult to the rest of the industry, as the implication is that, if you are not a signatory to this campaign, you neither care about the safety of cosmetic products and the products you produce may not be safe. There is an insufferable smugness about the CFSC – a “we are right, and everyone else is wrong” kind of attitude. It is unfortunate that, in fact, it is the CFSC that is wrong.

How can I make this bold claim?

Easy! The whole basis of the CFSC, and the products that signatory companies produce, is the Skin Deep database. It is their “bible”. On their web site they invite you to “Visit the world’s largest database of chemicals in cosmetics to assess the toxicity of your favorite products and find safer alternatives.” I will not dwell in too much detail on the shortcomings of Skin Deep {see for full story}, but the bottom line is that Skin Deep does not work. It does not, and cannot, give any true indication of the safety or “toxicity” of any cosmetic product. In fact, this fatally flawed database actually has the opposite effect to that intended, as there are many companies deliberately formulating their products using only ingredients that are rated zero (ie the lowest “hazard rating”) on Skin Deep. On the face of it, this sounds great. The problem is, however, that the majority of “zero-rated” ingredients have huge data gaps – using the Skin Deep system of rating the data gaps, anything from 80 – 100% (ie NO DATA). Leaving aside the tricky question of how you actually rate a hazard on the basis of no data whatsoever, this means that products are being manufactured for which there are NO toxicity data for ANY of the ingredients. Can someone please explain to me how this is safe?

As an aside, I am surprised that so many companies – especially small ones – are willing to sign up to a campaign that actively encourages people to make their own cosmetics in their kitchen – they have a whole section dedicated to “DIY” cosmetics!

So, I repeat, the CFSC is wrong. It is misleading consumers in exactly the same way that the EWG misleads consumers, and for exactly the same reasons.

The ONLY way to best ensure the safety of any specific cosmetic product is to carry out a full safety assessment on each individual product, based on existing knowledge. This should be carried out by a competent person. This is done in the EU, so it is not impossible. The reason it is so important to do this assessment on a case by case basis is because the concentration of each ingredient is critical when assessing the safety. The same ingredient may be safe to use in a product at 1%, but potentially dangerous at 10%. (This is precisely the point at which Skin Deep fails spectacularly, as it does not consider concentrations). The safety assessment also takes impurities into consideration – at the relevant levels. Skin Deep does not do this. The Campaign For Safe Cosmetics is completely redundant in the EU (I know it is based in the US, but these things tend to crawl insidiously across the Atlantic) and, given that many products are similar, more or less redundant in the US.

Given that the EWG and CFSC use their large resource to publicise their campaign, it is difficult to counter their misinformation easily. If the PCPC attempt to do this, the EWG simply scream “vested interest” and, despite the fact that a vested interest should not mean that all data are biased and, therefore, invalid, the EWG are incredibly successful with this tactic. They are very quick to accuse ANYONE who disagrees with them as having some vested interest, irrespective of the truth of the matter – I have personal experience of this (see the comments section in that link earlier).

I think that it would be a good idea to set up an alternative resource, specifically designed solely to counter internet myths about cosmetics – how about the Scientific and Technical Assessment of Cosmetic Yarns (STACY)?


Dene Godfrey has been involved with preservatives for cosmetics since 1981, from both technical and commercial angles and has a degree in chemistry. Dene worked for one of the largest manufacturers of parabens from 1992 – 2002, and currently works for a UK company involved in the distribution of ingredients for cosmetics, health care and food. The Boots Company, 1973 – 92, Dene spent 11 years working with bronopol, although he was also involved in the initial development of Myavert C, now known as Biovert – a well-known “non-preservative”. Latterly was responsible (as Technical Manager) for the operation of the Formulation Laboratory and the Microbiology Laboratory. As Technical Manager when at Nipa Laboratories, Dene was responsible for development and sales of new preservative products, mainly into personal care. Developed the Nipaguard range of preservatives and co-patented a preservative system based on phenoxyethanol and IPBC. In 2002, Dene founded MGS MicroPure (as Technical & Sales Director) to compete with the giants of preservation, establishing the Paratexin brand name in the UK and several other markets (EU/ global). MGS MicroPure ceased trading in 2005. Since 2005, Dene has been employed by a major UK distributor of personal care ingredients, with his focus primarily on preservation systems. Dene’s articles are based solely on his personal opinions, observations and research, and are not intended to represent any official position of the part of his employer. Dene obtained a BSc (Hons) in Chemistry from the Open University in 1996. He also obtained the Professional Certificate in Management from the Open University in 1997. He has been an active member of the UK Society of Cosmetic Scientists since 1992, and has served 4 terms on the SCS Council, and is involved with the SCS Social Committee from 1993 to date; from 2004 – 7 as Social Secretary. Dene has presented papers at many SCS meetings and was President of the SCS (2009/10)

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