This post was inspired by a discussion initiated on the LinkedIn “Safe Personal Care Products – The Right Way” group:

“EWG Rates NYR Organic as NOT TOXIC!
I send lot’s [sic] of clients and prospects to the EWG SkinDeep database as almost ALL of the NYR Organic (Neal’s Yard Remedies) products are shown to have a lovely GREEN ZERO, meaning, not toxic! NYR has been at this for 31 years, and is growing internationally. Check it out.”

I have written before about the fundamental (and fatal) flaw associated with the Skin Deep database only being based on hazard, and not on exposure (, so I won’t repeat myself here. Instead, I would like to focus on the major contradiction that this LinkedIn posting brings to light, and I should explain that I am not directly criticising NYR per se in this piece. Much is made of the overall product rating of zero and, on the face of it, this is great – who doesn’t want products that are completely safe. Leaving aside the insinuation that, as NYR products, specifically, are “NOT TOXIC”, then other products must be toxic, it is worth checking on the link to Skin Deep that was helpfully provided in the above posting. What this shows is that every “zero-rated” NYR product is rated so on the basis of “limited data” (as quoted on the database). I have touched on this in the previously-mentioned article, in terms of the difficulty of justifying a hazard rating (especially a zero rating) on the basis of such limited data, but the real issue of the contradiction this introduces has only just occurred to me.

One of the EWG’s favourite complaints about the cosmetics industry is that between 70 and 90% (depending on the source) of all ingredients have not been fully tested for safety. This is probably their single major issue in cosmetics. This, however, does not stop them from providing a rating on many ingredients, despite there being only limited data available. How can they possibly justify making a public performance about their claimed lack of data, then go on to provide zero ratings on both ingredients, and products that contain such ingredients? In effect, they promote products containing the very ingredients against which they campaign! If the data are not available then, surely, there is room for doubt over the safety of the ingredient, according to their own standards. There are other ingredients with a similar lack of data for which the “rating” is high (i.e. “not safe”). Again, how is a distinction made when there are insufficient data?

Part of the issue here is that there is a naive assumption that “natural is safe; synthetic is dangerous”. This is something that, again, I have covered previously (, so I won’t dwell further on this here. What I WILL reiterate from a previous article is the fact that some companies actively formulate with “zero-rated” ingredients in order to achieve a low Skin Deep score. This means that these companies are specifically using ingredients with very little safety data available (in most cases). From a safety point of view, this is counter-intuitive. Consumers should be concerned.

If the EWG were honest and consistent about safety, they would refuse to rate any ingredient for which there were insufficient data (or give it a high “default” rating). They don’t. They can’t (or shouldn’t) be taken seriously.

(Post script – I am aware that PCT has been criticised in the past for disproportionate focussing on EWG issues, but this is an illusion! In its 3 years of existence, PCT has posted 496 articles; fewer than 10 have been specific to the EWG.)


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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