Toxins in Cosmetics. What Consumers and Government can do to get Safer Cosmetic Products on the Market

Transcription

1 Toxins in Cosmetics What Consumers and Government can do to get Safer Cosmetic Products on the Market Tag Words: Toxins in Cosmetics, Toxic Substances Control Act, TSCA, Alternative Cosmetic Products, Alternatives to Toxic Ingredients, Cosmetics, Human and Animal Testing, Harmful Ingredients, Organic Cosmetics, GRAS, Generally Regarded As Safe, Think Dirty, GoodGuide Authors: Angielly Dominguez and Julie M. Fagan, Ph.D. Summary: Many cosmetics on the market today contain potentially harmful ingredients. Some companies knowingly include chemicals that have been shown to be toxic at high enough levels (like lead in lipstick and certain eyeliners). The safety of many other ingredients is actually not known because they were in use and already on the market before the Toxic Substances Control Act (TSCA) was put in place in In 2016, it is expected that the TSCA will be amended to require retesting these GRAS ( Generally Regarded As Safe because they are in use) chemicals and the cosmetic manufacturers will need to reformulate their products to not contain these harmful ingredients. In the meantime, consumers should utilize available apps like Think Dirty or GoodGuide to determine whether the product contains toxins, provide feedback to the cosmetic companies directly, and opt to purchase ones considered safer. Video Link: The Issue: Toxins in Cosmetic Products For some, cosmetics play an important role in everyday life. It is not infrequent that a women may express the feeling of feeling naked without applying face makeup or needing to apply makeup prior to their leaving their residence. Young and old of both sexes commonly use cosmetics for special occasions like Halloween, fans during sporting events and weddings, where people dress up. Cosmetics contain ingredients, some of which are known toxins that may negatively affect human health. Although people are becoming more health conscious with respect to the foods they consume, they generally don t think twice about the products applied topically. If people knew they were applying heavy metals like lead or arsenic and that these were being absorbed into their body, surely they would consider purchasing cosmetic products without these harmful ingredients. What are cosmetics? Cosmetics allow people to enhance their appearance by applying products on their face, hair, and body. Cosmetics include products like body cleansers, lotions, hair dyes, toothpastes, deodorants, perfumes, and eye and face makeup (1). However, the definition of a cosmetic product differs depending on the country. In the United States, a cosmetic is defined as an article intended to be rubbed, poured, sprinkled...or otherwise applied to the human body or any part thereof for cleansing, beautifying, promoting attractiveness, or altering the appearance. The European Union, EU, defines cosmetics as any substance or preparation intended to be placed in contact with various external parts of the human body (epidermis, hair system, nails, lips, and external genital organs) or with the teeth and the mucous membranes of the oral cavity

2 with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance and/or correcting body odours and/or protecting them or keeping them in good condition. EU s definition includes both the concept that cosmetics are agents that clean, perfume or change appearance and that cosmetics serve to protect or keep in good condition various parts of the body. The US, on the other hand, makes a distinction between products that are purely cosmetics, that when applied, act to improve appearance and those that act as drugs; cosmetics that serve to mitigate, treat, or prevent disease and that intend to affect the structure or any function of the body (2). So certain products can be both a cosmetic and a drug and must comply with regulatory requirements for both cosmetics and drugs. What are the main toxins found in cosmetics and what purpose do they serve? Below is a list of some common ingredients found in cosmetics, most of which are considered to be toxic depending on the amount absorbed and the person s short and long term exposure to them. 1. Butylated Hydroxyanisole (BHA) and butylated hydroxytoluene (BHT) BHA and BHT are preservatives found in lipsticks and moisturizers. They are also closely related to synthetic antioxidants and can cause an allergic reaction to the skin. According to the European Commission, BHA is an endocrine disruptor because it interferes hormone function. 2. Coal Tar Dyes The darker a hair dye product, the more of the coal-tar derived product it contains. Coal tarderived colors are listed as either FD&C Blue No.1 or Blue 1. They are derived from petroleum, but may also be contaminated with heavy metals. These dyes are recognized as a human carcinogen. 3. DEA, cocamide DEA and lauramide DEA Diethanolamine related ingredients are typically found in soaps, shampoos, and cleansers. They are used in cosmetics to create creamy products, but is mainly used as a ph balancer to relieve acidity from other ingredients. Because of its ability to linger in the human body, the European Union classifies DEA-related ingredients as a threat to human health from prolonged exposure to the chemicals. 4. Dibutyl Phthalate (DBP) DBP, is used mainly in nail products as a solvent for dyes and also to prevent nail polishes from becoming brittle. According to the European Union, it is a suspect for endocrine disruption, meaning that it may interfere with hormone function and also as a suspect for reproduction disruption with regards to posing a threat to fertility and unborn children. Evidence from Health Canada shows that exposure may cause liver and kidney failure in children that have put DBPcontaining products in their mouth. 5. Formaldehyde-releasing preservatives: DMDM hydantoin, diazolidinyl urea, imidazolidinyl urea, methenamine, quaternium-15, and sodium hydroxymethylglycinate It is mainly used as a preservative for cosmetics. The chemicals listed above are known to release small amounts of formaldehyde over time. Formaldehyde is typically found in industrial applications such as vinyl flooring and other plastics, permanent-press fabric, toilet bowl cleaners, and the production of resins in wood products. The International Agency for Research on Cancer (IARC) classifies formaldehyde as a human carcinogen. It can cause skin and eye irritation and trigger an allergic reaction, even in small doses. 6. Paraben, Methylparaben, Butylparaben, and Propylparaben

3 About 75% to 90% of cosmetics contain parabens and have the ability to penetrate the skin. They are suspected of interfering with hormone function. Cosmetic companies synthetically derive parabens from petrochemicals. Parabens are also found in some foods like strawberries, barley, carrots, onions, and more. However, when eaten, parabens are metabolized (where it does not mimic estrogen, for example) whereas, when absorbed into the body through the skin, parabens enter the bloodstream and then have the ability to affect organs. 7. Parfum (Fragrance) The term fragrance in a cosmetic product represents a mixture of potentially 3000 individual chemicals. Products that may be marketed as fragrance-free or unscented may still contain fragrance ingredients that prevent the brain from recognizing any odors. Fragrance is also used for products like laundry detergent, softeners, and cleaning products. Fragrance ingredients can cause an allergic reaction, migraine, and asthma. 8. Polyethylene glycols (PEGs) PEGs (ethoxylated compounds), a petroleum-based compound, is found in cosmetics as a thickener, softener, moisture-carrier, and used as a solvent. PEGs may be contaminated with 1,4-dioxirane, another chemical that is classified as a possible human carcinogen by IARC. PEGs pose a threat to human health because there is evidence that shows that PEGs may alter genetics (or cause genotoxicity), can irritate the skin, and is toxic. 9. Petrolatum This is used to hold moisture in the skin and is also used to make hair shine. It is classified as a human carcinogen by the EU and has restricted use. Petroleum is known to be contaminated with polycyclic aromatic carbons (PAHs), which is known to cause skin irritation and allergies. 10 Siloxanes: Cyclotetrasiloxane (D4), cyclopentasiloxane (D5), cyclohexasiloxane (D6), and cyclomethicone They are used in cosmetics that aim to moisturize and smooth the skin mainly found in moisturizers and facial treatments. A study by the group Environment Canada concluded that D4 and D5 are toxic and persistent (meaning that they remain in the body for a long period of time). The EU says D4 is known to interfere with human hormone function and is listed as a suspect of reproductive toxicant. In addition, D5 can influence neurotransmitters in the nervous system. 11. Sodium Laureth Sulfate (SLES) SLES is used to make products, like shampoo, bubble and foam; also found in household cleaning products. Also an ethoxylated ingredient, like PEGS, can also be contaminated with 1,4-dioxirane. 12. Lead A study by the Campaign for Safe Cosmetics, found lead in more than half of the 33 brands tested. Lead is commonly found in lipsticks, a product that could easily and mistakenly be ingested by consumers. The lead is typically a contaminant of the raw resources used to create the cosmetic product. There is no safe amount of lead. It s known to cause neurodevelopmental problems in children and has also been linked to infertility and miscarriages (3, 4). What are some heavy metals found in cosmetics? Heavy metals are found in a variety of personal care products including lipsticks, whitening toothpaste, eyeliner, nail polish, foundation, sunscreen, eye shadow, blush, concealer, moisturizer, and eye drops. Some of the heavy metals, like lead or aluminum for instance, are

4 either added as ingredients or are found as contaminant byproducts. Exposure has been linked to health concerns like reproductive, immune, and nervous system toxicity. Examples of the intentionally added metals come up as lead acetate, chromium, thimerosal, hydrogenated cottonseed oil, sodium hexametaphosphate. Heavy metals have been banned, or found unsafe, in Canada, Japan, and the European Union, while in the United States these are still are present in the end product as they remain under restricted use. According to a study done by Health Canada, the following were found in cosmetics: 100% contain nickel 96% contain lead 90% contain beryllium At least one of the products tested contained 7 of the 8 heavy metals of concern o Arsenic, cadmium, lead, mercury, beryllium, nickel, selenium, and thallium On average, products contained 4 of the 8 metals of concern The highest levels of arsenic, 70 parts per million (ppm), cadmium at 3 ppm, and lead at 110 ppm were found in lip gloss; a product that can be ingested In the United States, products that contain contaminant heavy metals are not required to be listed on ingredient labels (5, 6). Health risks linked to using cosmetic products containing toxins The main concern with using cosmetic products is the ability of the toxic ingredients to penetrate the skin and remain in the body for a long period of time. We may not be concerned about the lead found in our lipstick because for the majority of us there is no apparent reaction after application. However, because these ingredients in cosmetics can accumulate in the body, they can cause a handful of health problems in the long-run. The build-up of these chemicals can cause: Cancer Reproductive and developmental disorders Neurological problems Memory loss Mood Swings Nerve, joint, and muscle disorders Cardiovascular, skeletal, blood, immune system, kidney, and renal problems Headaches Vomiting and nausea Lung damage Contact dermatitis Brittle hair Hair loss There exists no exact measure of how much of a contaminant products can have before it is deemed unsafe. Figuring out the impacts that cosmetics will have on humans is a challenge because it depends on how much of the product is used, the amount of contaminant found, the exposure of other toxins and a variety of other factors that differ from person to person. Additionally, there are other sources of exposure to toxins, like arsenic found in drinking water

5 or lead, found in old paint. Low-doses of exposure can be cumulative and as a result, affect human health on the long-run (5). Why are some heavy metals not required to be listed on labels? In Canada, for example, cosmetic companies by law are not allowed to purposely use heavy metals as part of an ingredient for a cosmetic product as heavy metals are banned. However, heavy metals are not required to be labeled when they appear as an impurity. Heavy metals, for example, can be formed in the making of the product as a byproduct or by the decomposition of other ingredients. The cases expressing how heavy metals can slip into the ingredients of a cosmetic, will result in the heavy metal representing an impurity and therefore, the cosmetic company will not be required to list the impurity for what it really is; a heavy metal. The proposed Safe Cosmetics Act of 2010, from the US, would require cosmetic companies to explicit list all ingredients that exceed the feasible detection limits (7). Alternatives to using the toxic ingredients in cosmetics While our makeup may not seem to pose any threat during present day, we do not know what could possibly happen 50 years after using the same everyday cosmetic products. Fortunately, nature offers a variety of safe alternatives that could be used in place of the toxic ingredients. Below are some of the natural alternatives that could replace some of the chemicals listed above. Coconut Oil Coconut oil works beautifully as a skin moisturizer and helps to slow the formation of wrinkles. Its ability to penetrate the skin deep into the hair shaft is what allows it to condition and moisturize the skin for long periods of time. Coconut oil is an antioxidant that contains vitamin E, which helps prevent wrinkles. Henna Henna is used in weddings in the Indian culture as a dye that temporarily tattoos the skin. However, henna can also be used to dye the hair. Combining it with sesame oil and curry leaves, or with beetroot juice, or adding it into a mix of curd, or lemon juice and tea will produce a temporary dye. Turmeric Turmeric is a spice that can be purchased at the local supermarket or grocery store. Given that most face products contain preservatives, turmeric mixed with some curd or mash ripe papaya fruit can be used on the face as a rejuvenating face pack Aloe Vera Aloe vera can be used as a skin moisturizer. Garlic and Sandalwood Oil It has been reported that by peeling out the outer layer of a garlic clove, pimples can be relieved by rubbing the clove on it. Sandalwood oil, mixed with some almond oil, not only serves as a pimple relief, but it can also serve as a skin moisturizer. Soapnuts and Shikakai Shampoos typically contain the chemical sodium lauryl sulfate to remove and cleanse the hair from dirt and oil. While everyone wants to make sure they have clean hair, the hair contains oils that are essential to support and maintain a healthy head of hair. This chemical removes all of the oil in the head which is bad for your hair and gives room for further damage to the head.

6 An equal mixture of soapnuts and shikakai can provide a healthier shampoo alternative for consumers. Pomegranate Seeds Smoking, caffeine consumption, exposure to the sun, and dehydration all can cause the lips to darken. The use of lip sticks can also cause the lips to darken over time because of the chemicals used to make them. A scrub consisting of crushed pomegranate seeds with milk cream or sugar and olive oil can aid in restoring the beautiful pink shade the lips are naturally supposed to have (8). Available alternative cosmetic products that do not use the problem ingredients Toxins and heavy metals are used in cosmetics to enhance their performance in, for example, cleaning the face and body, moisturizing, beautifying, and improving odors. And in the process of enhancing the body through cosmetics there are a lot of chemicals involved that are not necessarily beneficial to the body. So the question is, are there any products that provide the same advantages, but lack the problem ingredients? Makeup Makeup refers to cosmetic products used in the eyes, lips, and face. The following are some of the brands offer products that are free from the toxic ingredients typically found in makeup % Pure Their products are safe to eat we can conclude that their products are also safe to use on the body. Their products include ingredients that replace the industrial preservatives typically found in other cosmetics. This firm also uses plant-based ingredients in their products. 2. Bite Beauty Their lipsticks are made with ingredients like argan oil and manuka honey. 3. Josie Maran Another firm that offers products with plant-based ingredients like avocado and coconut oil. 4. Scotch Naturals This company offers toxic-free nail polish. 5. Lavanila This firm offers fragrance-free perfumes. 6. Pacifica Perfume They produce fragrances that only include safe ingredients. Skin and Body Care The following include all possible products that can be applied to the skin. For instance, lotion, face washes, moisturizers, and body washes. 1. Skin Care for Athletes Offers products that are free from the problem ingredients. 2. Weleda Another firm that offers products with plant-based ingredients. Their international gardens allow this firm to grow their ingredients in a variety of different climates. 3. Dr. Bronner s

7 Products are made with only organic ingredients like jojoba, peppermint, and a variety of other oils. Products include body wash, hand soap, shampoo, and toothpaste. 4. Suki This company makes skin care systems for every skin type. The products are made by a list of plant-based ingredients. 5. Indigo Wild Known for their Zum soap, they are a skin care company that offers products free of the toxic ingredients. 6. Primal Life Organics They are called Primal Life Organics because their products were made by someone who supports the paleo way of life. Their products are also free of gluten and vegan. 7. Trillium Organics Replacing anti-bacterial hand soaps containing triclosan is a toxic chemical this company eliminates in their products. Hair Products Below are examples of a few companies making hair products 1. Acure Organics This firm makes hair care products that are free from toxic ingredients. 2. Yarok Hair Another firm that offers non-toxic hair care products. 3. DIY Hair Wax A simple mix of coconut oil and beeswax can be used to replace the hair care products that include the problem ingredients. Sunscreen Zinc oxide, the safest UV-filter, is a physical filter that can be applied to the skin instead of using chemical UV-filters like oxybenzone. It is a physical filter because it is applied to the skin and it acts as a shield to prevent damage to the skin from UV rays; known to also minimize whitening. 1. Badger Balm This firm offers sunscreen with zinc-oxide. 2. Raw Elements Eco Formula Also offers zinc-oxide containing sunscreen. 3. Kabana Skin Care Ingredients include zinc oxide and vitamin D, in order to make up for the UVB rays you are primarily blocking. 4. Mexitan They also make nontoxic, zinc oxide containing sunscreen. Deodorant There are a variety of deodorant choices for those that do not wish to use products with potentially toxic ingredients typically found in deodorants. 1. Primal Pit Paste A company that offers coconut-based deodorant.

8 2. Thai Crystal Offers a spray and roll-on deodorant free of the toxic ingredients. 3. Coconut and Baking Soda Coconut oil and baking soda could be used as a deodorant. However, the substance can become gooey or milky in warm weather, but it gets the job done (9). Cost of all-natural or organic products Given that a. natural ingredients may be harder to come by at prices as low as the chemicals used in conventional (containing potential toxins) cosmetic products, b. that methods used to incorporate these products may be more elaborate, and c. the fact the organic or natural products are likely to have a shorter shelf life, the costs to the customer for the toxin-free products may be higher than conventional cosmetics. Because cosmetic companies care more about keeping up sales and profit, one of the obstacles faced in getting cosmetic companies to produce organic/allnatural products is the cost that lies behind making these changes. For example, mineral oil may cost 80 cents per pound versus olive oil that may cost $1.50 per pound. Non-organic products tend to contain preservatives that allow the product to last longer after they have been purchased. Organic products however lack preservatives because preservatives contain the chemicals that should be avoided. That being said, organic products have a shorter shelf life because the nutritious ingredients begin to break down after some time. While a shorter shelf life may discourage the manufacturers, in the long-run, attracting more customers to purchase their products without toxins will be seen as a benefit. These products definitely outweigh the possible threats to human health found in the chemically-rich cosmetic products. Formulating these products with natural ingredients can be less efficient as opposed to using synthetic ingredients that may yield a larger amount of the product. The method of production also goes in correspondence with the cost because in order to produce a product you need the ingredients. So, this becomes a vicious cycle of either purchasing natural ingredients or synthetic ingredients to then make the decision of using either a synthetic or natural process (10,11). The Toxic Substances Control Act of 1976 The Toxic Substances Control Act of 1976 (TSCA) is the nation s main law aimed at regulating chemicals used in everyday products, like cosmetics. This law provides the EPA with the authority to require reporting, record-keeping and testing requirements, and restrictions relating to chemical substances and/or mixtures. In the documentary, The Human Experiment, it shows that most of the chemicals in the U.S. are not tested for safety because the industry does not have to prove a chemical is safe before it gets into the market. In addition, when this act was passed, there had already been 62,000 chemicals on the market which were grandfathered in and assumed safe because they were already in use and Generally Regarded as Safe (GRAS). Unfortunately, the EPA was unable to collect the appropriate data to remove - or at least test or question - all those grandfathered chemicals because of this law (10-12). Consequences of TSCA TSCA is a law that allows the chemical industry to release products where the ingredients are innocent until proven guilty. A prime example of this is the asbestos case. It took the EPA 10 years to provide the analysis on asbestos before it was able to have it banned. The industry responded by suing the EPA which in turn sparked a battle in court. As a result, the court overturned the ban. Even though the EPA had appropriate data on the potential threats to human

9 health caused by asbestos, the industry was able to fight back without any consequences thanks to TSCA. The multi-billion dollar companies have all the cash in the world to continue to shut down bills that aim to discontinue the use of such harmful toxins or chemicals in their products. Not to mention the fact that chemical industries have the audacity to discredit research and scientists when such information shows that a toxin is harmful. Whether you are a politician, a legislator, or a protester, the industry always finds a way to shut down any efforts that may harm a company financially; even if it means having to hire a lobbyist. As a result of TSCA being a reactive legislation, there has been an incredible and alarming rise, over the past 45 years, in childhood brain cancer, asthma, autism, childhood leukemia, early onset puberty, ADHD, genital deformities in baby boys, and life-threatening birth defects since the chemical revolution. The precautionary principle could (and should) be practiced such that the cosmetics products should not be put out into the market because no one is aware of the potential dangers that come from using the products. If cosmetic products are deemed safe for use and have been tested on animals, it means that the company had to ensure the safety of their ingredients by testing their product on animals. However, the products listed under the organic and all-natural, are typically not tested on animals and therefore need no justification of safety. Keeping this alternative in mind, if a majority of the cosmetic companies turn to reducing their use of toxic chemicals and start using organic ingredients, then there would no longer be a need for testing on animals and humans. Because cosmetics are eventually absorbed through the skin, cosmetics companies should have to follow safety precautions in order to produce safer cosmetics for consumers (12). FDA-approved cosmetic products on the market in the US that contain ingredients that are banned by the European Union It is truly disheartening to learn that the US Food and Drug Administration (FDA) has banned only a total of ten chemicals of the 1,100 chemicals found in cosmetics by the European Union. Interestingly, cosmetic products like mascara, for instance, contains the same ingredient found in wart removers; petroleum distillates, which is a byproduct of oil and happens to be illegal in Europe. Many of the FDA-approved chemicals that are banned in Europe may cause birth defects, genetic mutation, cancer, and organ damage from prolonged use of cosmetic products manufactured for the US market. One would never think to directly put these chemicals on their eyes if it is also found in a product that is also used to remove something as noticeable as a wart. The following chemicals banned in the United States as of 2010 are Chlorofluorocarbon, Chloroform, Halogenated salicylanilides, Hexachlorophene, Mercury, Ethylene chloride, Bithionol, Prohibited cattle material; like tallow and the byproducts, Trichloroethane and Zirconium. Up until a few decades ago, the chemicals listed above were found in cosmetic products like shampoo, deodorants, aerosol hairspray, and face creams. Even though the FDA has banned the chemicals listed above, consumers are still able to purchase products containing these chemicals if they are coming from other countries because the United States does not have a law that prohibits imported products. For example, skin bleaching and whitening products usually

10 contain mercury and are often brought into the country from outside sources like China or India; mercury is known to cause kidney, brain, and lung damage. The FDA has no authorization to demand testing of chemicals in cosmetics, to recall cosmetic products, or to demand safety of chemicals before the product is available to consumers. The vague definition for cosmetics, as mentioned previously, allows cosmetic companies to produce products with toxic ingredients without the stress of government interference. In comparison, the specificity of the definition of cosmetics by the EU is what forces cosmetic companies to really consider what ingredients they shall use in their products because by definition their products cannot be a threat to human health and they must protect them or keep them in good condition. Another positive benefit that the members of the European Union have is that besides having these specific instructions for how their cosmetic products should be, they can also choose specific ways of regulating their products within the nation (15). What bureau is responsible for testing cosmetic products? The bureau in charge of testing cosmetic products in the United States is the Cosmetic Ingredient Review (CIR); they make their own guidelines and they serve as the main source of scientific data for the FDA. Their website states that the Cosmetic Ingredient Review thoroughly reviews and assesses the safety of ingredients used in cosmetics in an open, unbiased, and expert manner, and publishes the results in the peer-reviewed scientific literature. Ironically, the CIR source of funding comes from the Personal Care Products Council (PCPC), which just so happens to be a group of multiple cosmetic companies. This appears to be a conflict of interest with regards to promoting and ensuring safer cosmetics when the PCPC is able to spend ridiculous amounts of money hiring lobbyists to prevent, for instance, the Safe Cosmetics Act of 2005 from becoming a legislation in California; a law asking cosmetic companies to share any information on ingredients that are deemed unsafe by adding them to their product labels. Environmental and public-health groups that support the campaign for safe cosmetics found that the chemicals deemed safe by CIR were actually unsafe ; hence why cosmetic companies in PCPC did everything in their power to shut the legislation down. Back in 2007, the Environmental Working Group found that 1 in 30 products sold in the US fails to meet both industry or government standards, About 400 products sold in the US, like Crest Whitestrips or Neutrogena s daily face cream contained chemicals banned in Japan, Canada, and the European Union, 98% of all products tested contained one or more ingredients never tested for safety. Interestingly, the CIR is only allowed to suggest ingredient changes; they are not allowed to regulate anything. This is perhaps one reason that these products remain on the market. Cosmetic companies continue to formulate products that violate safety standards, even with the reports that are easily accessible and are provided by the CIR. Cosmetic companies are fully aware that their ingredients pose a threat to human health, but choose to argue that consumers should use as directed to reduce health risks. While cosmetic products contain small amounts of the toxic ingredients, over time they may accumulate in the human body and could reach extremely unhealthy levels (15). REACH Program, the European Commission

11 The European Commission is responsible for creating environmental policies for the members in the European Union. The European Commission offers a program, or regulation, called REACH. The purpose of this regulation is to improve the protection of human health and the environment through the proactive act of identifying the basic properties of chemical substances early-on before they are exposed to consumers. REACH follows four main processes of registration, evaluation, authorization, and restriction of chemicals. This group also aims to promote further innovation and competition of the chemical industry in the European Union. Their motto, no data, no market pressures the chemical industry to take the responsibility for the management of the risks from the chemicals they wish to use in their products. Furthermore, the motto also forces the chemical industry in Europe to provide safety information on the substances. Both manufacturers and importers are responsible for gathering information on the properties of their chemical substances and for registering information to a central database in the European Chemical Agency (ECHA) in Helsinki, Finland. ECHA is held liable for managing the databases necessary to operate the system, coordinating an explicit evaluation of questionable chemicals, and setting up a database, with any possible hazardous data, that is available to the general public. Not only is this a proactive regulation that aims to keep the general public safe from harmful chemicals, this regulation is also focused on removing chemicals that are in the market and are found to be of high concern or dangerous; after better alternatives have been confirmed to be suitable. Lack of information on the hazards of the chemical substances used in products on the market is what prompted this program to follow the preventative route. This program would perfectly fill the gaps that the chemical industry in the US refuses to close up (16). Cosmetic Testing According to the Humane Society of the United States, the Federal Food, Drug and Cosmetic Act prohibit the sale of mislabeled and contaminated cosmetic products; regulated by the FDA. However, this regulation does not require animal testing as a means of justifying the safety of cosmetic products. Instead of using animals to test their products, cosmetic companies can ensure the safety of their products by using chemicals that are known to be safe and pose no threat to human health. In addition, cosmetic companies usually resort to animal testing in cases where a product might contain new ingredients. Several tests are performed on mice, rats, rabbits, and guinea pigs by exposing them to cosmetic ingredients (17); even though, by law cosmetic testing is not required. Tests consist of: Skin and eye irritation tests where chemicals are rubbed onto the shaved skin or dripped into the eyes of restrained rabbits without any pain relief Repeating force-feeding studies that may last weeks to months to find signs of general illness or specific health hazards like cancer, birth defects, and etc. Lethal dose tests, where animals are forced to swallow large amounts of a test chemical to determine the dose that leads to demise Unfortunately, the number of animals used in the testing of these products are not necessarily considered in official statistics and have limited or no protection under the Animal Welfare Act.

12 While testing may aid in the advancement of new cosmetic products, animal testing is not always relevant to humans because each species can respond differently when exposed to the same chemicals. The majority of the results from these tests are either under- or over-estimations of real world hazards to human health. Tests that are inaccurate and ineffective serve no purpose in guaranteeing consumer safety, therefore animal testing should not be the main source of justification of safety for cosmetic products. Getting results from animal testing may take months or years whereas human cell-based tests can provide more accurate and relevant results within hours or days and tend to be more cost-effective than tests done on animals. The most obvious alternative to animal testing is simply replacing the toxic chemicals with chemicals that are deemed safe and pose no threat to human health. The nontoxic ingredients have been around for a long time and have been safely used in products; thus, no longer needed to test on animals. Cosmetic companies can also use non-animal tests or invest in finding an alternative method of testing in order to eliminate testing overall. There are about 50 non-animal testing methods that provide reliable data relevant to humans and that is also more efficient and cost-effective. Because the European Union has banned animals testing, it has placed a burden on the chemical industry, since they have no choice but to find other methods of testing that do not involve harming any animals. Until the United States takes this step of finding non-animal testing methods, the nation s cosmetic products will continue to be prohibited in Europe (18). Community Action: Campaign for Safer Cosmetics and Consumer Awareness There are videos consumers can watch that alert consumers to the potential health risks that come with cosmetics such as However, just telling the cosmetic consumer to be aware of the potentially toxic chemicals contained in the products they use and suggest that they consider purchasing cosmetics that don t contain potentially harmful ingredients is not sufficient. Navigating names of chemicals on labels is a task that some consumers may not be able or willing to do. Furthermore, information on what chemicals are in the product of question may be hard or impossible to find, since many products don't include ingredients listings. Cosmetic manufacturers are not required by the government to provide their ingredient list, and claim 'trade secrets' are more important than the consumer s right to know exactly what's in the stuff they slather on their bodies every day. Products that aren't ingested aren't held to the same standards as food or drugs, and many of the chemicals used in everyday products have never been tested for safety they are on the GRAS list, which stands for Generally Recognized As Safe (which only means that they haven't been proven to be harmful to people, but they also haven't been proven to be safe). The blatant disregard for consumer safety has spearheaded individuals and grassroots organizations like to provide ways for consumers to know what products may be safer than others. The Think Dirty app ( was developed that allows customers to scan the product s barcode which yields an easy-to-understand info on the product,{the ability to} track dirty ingredients and shop for cleaner options. They have an impressive 305,000+ cosmetics and personal care products mostly manufactured in Canada and the U.S. currently in their database

13 (19). Their Dirty Meter [provides] a comprehensive rating, rating..along along with detailed (but easy-tounderstand) information on ingredients, certifications, and health impacts. Another organization called Good Guide has also developed an iphone application that rates products on a scale of 0 to 10 for their health, environmental, and social impact ( In our video ( we urged that consumers contact the cosmetic companies that make the products they use in the hopes that the companies would consider replacing the toxic chemicals with nontoxic safer ingredients. If consumers don t don't buy the cosmetics containing nasty chemicals, it follows that the then dwindling sales of cosmetic products containing toxins will pressure cosmetic companies to reformulate their products using safer ingredients. We sent a letter to the cosmetic companies L'Oreal L Oreal and Almay (below) asking why they continue to use those ingredients that are known to possibly pose a threat to human health. In this letter to the cosmetic companies, some of the alternative ingredients that could replace the problem ingredients were discussed. Furthermore, we mention how even if they would like to continue using the same ingredients, then cosmetic companies should give consumers access to the full list of ingredients, through either the internet or by including a full list of ingredients on their products. In both (company, senator) letters, concern was expressed for the well-being of consumers and it was emphasized that consumers should be aware of what chemicals are in their products. Dear,, (L Oreal, (L'Oreal, Almay) Cosmetics play an important role in both of the lives of men and women lives. Whether it means waking up every morning to put on lotion or putting on deodorant or putting on makeup; everyone uses cosmetic products on a daily basis. It has come to my attention that there are ingredients used in our cosmetics that may pose a threat to human health. Interestingly, the majority of the cosmetic products sold in the US include ingredients that are banned in countries like Canada and Europe. I feel that consumers in the US should not only be fully aware of all the ingredients in their products, but also should be sold cosmetics that contain nontoxic ingredients. I am interested in knowing why the company chooses to use toxic ingredients in the cosmetics products if there are companies that do just as fine using nontoxic ingredients. Ingredients like olive oil, aloe vera, and turmeric could be used in place of some of the toxic ingredients. I am mainly concerned about human health because even though no one has proven that these chemicals are unsafe, I find it shocking that the majority of the products sold here contains ingredients that are banned in Europe. The risks include, but are not limited to, cancer, lung damage, genetic mutation, reproductive and developmental disorders, and neurological complications. Furthermore, the small doses that consumers are exposed to on a daily basis add to the possible risk of getting the previously mentioned complications. If cosmetic companies were to replace their toxic ingredients, then there would be no need for animal or human testing;

14 since, the ingredients being used would be safe to human health. Overall, I feel that consumer safety should be the first priority in introducing new cosmetics to the market. Besides the possibility of replacing toxic ingredients, I feel that consumers deserve to know all the ingredients used in the manufacturing process, including any byproducts or contaminants. Is there a way for the company to provide a list of all the ingredients used in the making of a cosmetic product? If not on the actual product, perhaps by providing a link that allows the consumer to access the full ingredients list online. Sincerely, Angielly Dominguez From: <NoReply@consumerinformation.com> Date: Tuesday, December 8, 2015 Subject: In response to your comments from our website, A To: ad826@scarletmail.rutgers.edu ALMAY Ms. Angielly Dominguez 113 Centre Ave Secaucus, NJ Dear Ms. Dominguez: Thank you for your recent comments from our website and for taking the time to contact us. Revlon stands by the safety of our products. As a global company, all ingredients used by Revlon and products manufactured and sold by us are in compliance with both U.S. F.D.A and European Union regulations. Consumer safety is of paramount importance to Revlon. Our safety principles state that should we be unable to assess the safety of a raw ingredient or finished product, then that raw ingredient or product will not be sold or used in any Revlon formulation. Revlon s commitment to provide consumers with the most efficacious and safe products we can formulate will continue to lead our R&D efforts now and for future formulation activities. Revlon will continue to extensively evaluate our products and follow the regulatory guidelines set forth by U.S. and global legislative agencies to ensure the safety of our products. Thank you for your interest in our products. Please do not reply to this . Replies sent to this address cannot be answered. If you

15 have additional comments about this issue, please click here: then the link that they provided (not shown here). If you have comments on a separate issue, please return to our corporate website: Sincerely, Rita E. Hargrove Senior Consumer Information Representative Although the link they provided to allow us to provide additional comments did not work, we intend to respond to their letter with the following statement: I understand you are in compliance with current regulations. However, some of the ingredients in your cosmetic products are known to be toxins if enough is applied over time. There appear to be substitutes for some of these potential toxins as these substitutes are used by other companies that advertise their products as being toxin-free. Do you plan on/are you working on reformulating your products to deliberately remove ingredients that may pose a health hazard? You do realize that, in the long run, this would benefit the company by reducing/eliminating costs related to animal and human testing and also increase sales as those that want a toxin-free product would then consider purchasing yours. Letter to Our Legislators about the Inadequacies of the Current Toxic Substances Control Act of 1976 In order to potentially protect consumers, letters were sent to both New Jersey senators; Senator Cory A. Booker and Senator Robert Menendez. The goal in reaching out to them was to gain support in fighting for a more proactive regulation that will require cosmetic companies to justify that their ingredients are not toxic before releasing their products into the market. In the letter, it is emphasized how the Toxic Substances Control Act of 1976 has allowed cosmetic companies to continue to use toxic ingredients in their products because of how vague this regulation is worded and how it has been nearly impossible for politicians to introduce stricter legislations relating to this issue. If the nation could pass legislation that states specific guidelines for cosmetic companies to follow before introducing more products into the market, then the cosmetic companies will have no choice but to use safe ingredients in their products. Letter to Our Legislators: Dear Senator, Cosmetics play an important role in both of the lives of men and women lives. Whether it means waking up every morning to put on lotion or putting on deodorant or putting on makeup; everyone uses cosmetic products on a daily basis. Because we use cosmetic products so often, I feel that consumers should be fully aware of what they are really applying to their face, body,

16 and skin. I also feel that cosmetic companies should be required to formulate their products with ingredients that are not harmful or toxic to human beings. The Toxic Substances Control Act, or TSCA, was implemented back in 1976 and has not been modified since then. There have been many unsuccessful attempts to implement laws that require cosmetic companies to either use safer ingredients in their products or for the companies to test and make sure that they re ingredients do not pose a threat to human health. As a student who is concerned about the health of all consumers, I urge you to support the politicians that are fighting for amendments that pressure the chemical industry to deem their products safe before releasing them into the market. The Toxic Substances Control Act is the nation s main law aimed at regulating chemicals used in everyday products, like cosmetics. This law needs modifications because the chemical industry is allowed to introduce new chemicals to their products without having to justify if it is harmful to humans on the long-run. It isn t until a scientist proves that a chemical is toxic, that cosmetic companies are required to then test to see if a chemical poses a threat to human health. The precautionary principle could (and should) be practiced such that the cosmetics products should not be put out into the market until we the companies can prove that their ingredients pose no threat to human health; no one is aware of the potential dangers that come from using cosmetic products. The European Commission, for example, is responsible for creating environmental policies for the members in the European Union. In addition, the European Commission has a regulation, by the name of REACH, that aims to improve the protection of human health and the environment through the proactive act of identifying the basic properties of chemical substances early-on before they are exposed to consumers. REACH follows four main processes of registration, evaluation, authorization, and restriction of chemicals. This group also aims to promote further innovation and competition of the chemical industry in the European Union. Their motto no data, no market, pressures the chemical industry to have responsibility for the management of the risks from the chemicals they wish to use in their products. The European Union should serve as an example to the United States because of how proactive they are overall as opposed to our method of handling issues; which, happens to be in a reactive manner. In other words, we wait for terrible things to happen, in every possible aspect, before making any changes that will benefit the community of interest. In contrast, being proactive simply means that we will approach our issues with a preventative mindset. While the TSCA provides a sense of protection from harmful chemicals, the nation should be a little more cautious and proactive when introducing cosmetic products with new ingredients out into the market. In this era of technological advances, I m positive that we can find safer methods of producing these products with ingredients that will not negatively affect human health on the long-run. The REACH program from is an example of the proactive thinking that the United States, unfortunately, lacks. This program ensures the safety of products for consumers by making the cosmetic companies responsible for their actions. The firm dictates if their success by playing by the rules of the REACH regulation. If we can fight for more proactive regulations that require the chemical industry to test their products before they reach

17 the market, then eventually we can also eliminate animal testing; since the companies will then be required to only use safe ingredients in their products. If the ingredients in cosmetic products are tested and justified as safe, then animal testing will no longer be needed. Consumers deserve to have full disclosure of the chemicals being used in their cosmetic products. Sincerely, Angielly Dominguez Senator Bob Menendez s Response Forwarded message From: Senator Bob Menendez <Senator_Menendez@menendez.senate.gov> Date: Wednesday, December 30, 2015 Subject: Response from Senator Menendez To: ad826@scarletmail.rutgers.edu Dear Ms. Dominguez: Thank you for contacting me to express your support for S. 697, the Frank R. Lautenberg Chemical Safety for the 21st Century Act. Your opinion is very important to me, and I appreciate the opportunity to respond to you on this critical issue. This bill seeks to modernize the Toxic Substances Control Act (TSCA) to give the Environmental Protection Agency (EPA) the ability to ban unsafe chemicals, which is nearly impossible to do under current law, and would provide protections for vulnerable populations like pregnant women and children. Additionally, it ensures that the EPA has the power to secure the information necessary for a thorough evaluation, and eliminates the "least burdensome" regulation requirement that has for decades prevented the EPA from banning even the most dangerous chemicals like asbestos. You will be pleased to know that the Frank R. Lautenberg Chemical Safety for the 21st Century Act passed the Senate by voice vote on December 17, 2015, and now will be conferenced with a different bill passed by the House of Representatives. I believe this bill would be a significant improvement to current law by providing improved certainty to the industry and finally establishing a real process for the EPA to ban unsafe chemicals. While I have not cosponsored the legislation at this time, I continue to work with my colleagues to improve and advance this important measure. Please be assured that I will continue to work with my colleagues to improve this legislation as it moves through the legislative process, and will keep fighting to preserve the legacy of Senator Lautenberg, a steadfast champion of the environment and a leading voice for protecting the health and safety of our children. I will keep your thoughts squarely in mind should a final TSCA reform package come before the Senate for a vote. Again, thank you for sharing your thoughts with me. Please do not hesitate to contact me if I can be of further assistance. I invite you to visit my website ( to

18 learn more about how I am standing up for New Jersey families in the United States Senate. Sincerely, BOB MENENDEZ Umted States Senator Please do not reply to this as this address is not monitored. To contact my office, please use the contact form found on my website at Improvements to the Toxic Substances Control Act In Senator Bob Menendez s response on Dec 30 (below), we learned of the good news that action was taken by the senate on Dec. 17, 2015 to modernize the Toxic Substances Control Act (TSCA). In passing of bill S. 697, the Frank R. Lautenberg Chemical Safety for the 21st Century Act, the senate has afforded the EPA the process by which they can now ban unsafe chemicals, including some 62,000 GRAS chemicals that are currently Generally Regarded As Safe because they were already in use in products prior to the 1976 passing of TSCA. The House of Representatives had approved of a similar bill earlier in So now, in 2016, reconciliation of these two bills should occur after addressing some significant concerns expressed by legislators and advocates for chemical safety, such as: 1. Restoring the ability for States to protect their citizens while EPA reviews the safety of certain high-priority chemicals, and 2. Knowing exactly what chemicals are in use today. Amazingly, we have no clue as to how many and what chemicals are in use today. Somewhere between 7,700 and 85,000 chemicals under TSCA s jurisdiction are presently in commerce. It is necessary in this day and age that we should take an inventory to know exactly what chemicals are being used (and not used for whatever reason). Without this knowledge, how can the EPA scrutinize the chemicals for their safety without knowing what chemicals to look at? Our Concluding Message: Get informed Watch: / Look up: Contact your legislators about the Toxic Substances Control Act