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

Mr. Alspach,

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
Tisserand Aromatherapy

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


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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