It sounds compelling but is this reality or is this marketing?
Words on the Label are Meaningless
The FDA does not regulate certain terms that are commonly used on product labels and in advertisements. “Natural”, “non-toxic” “safe” and “clean” are strictly marketing terms and no standards need to be met to use them. Any brand can use these terms to describe any product. The term “organic” is also not regulated by the FDA though the U.S. Department of Agriculture (USDA) regulates the term only as it relates to agricultural ingredient marketing and a certain percentage of ingredients need to be organic to use that label.
“Chemical-Free” is the Mother of all Marketing Terms
If you see anything being advertised as “chemical-free”, recognize that the product-makers are either ignorant of basic science or else they are trying to manipulate you. Chemical-free is a misnomer. Chemicals are the building blocks of absolutely everything, including water, air, flowers and all personal care products, including “natural” ones. Even a banana is full of chemicals, all of which are completely safe. Of course, what marketers are trying to say is “free of toxic chemicals”. We all want safe products so how do we know if what we are using is safe?
How To Determine What is Safe and What’s Not
Natural beauty products have an image that they are safer, but are they? Some people think synthetic ingredients (made in a lab) are dangerous while natural (plant-derived) ingredients are safe, but this is an incorrect assumption. The toxicity of an ingredient is not determined by where it comes from. Synthetic ingredients can be safe or unsafe. Natural ingredients can be safe or unsafe. Lead and arsenic are natural and unsafe and even plant-derived chemicals can be deadly including belladonna and cassava. In a survey of toxicologists, 87 percent of them disagreed with the claim that organic or “natural” products are safer than synthetic products. The toxicity of a chemical needs to be determined independently of whether it’s synthetic or natural.
The EWG wrote the book on fear-mongering
The Environmental Working Group (EWG) is an environmental research and advocacy group that aims to educate the public about possible risks of synthetic chemicals used in food and consumer products. They pressure companies to eliminate ingredients they view as unsafe and they work to advance their political agenda.
The EWG earns its nickname the Environmental Worry Group by exaggerating the risk of chemicals while ignoring crucial facts like the dose needed to actually cause harm. Determining the safety of a chemical without considering dosage is misleading because every chemical has safe and unsafe doses, even water. For example, aspirin could be toxic if you consumed an entire bottle. However aspirin is safe and effective when you take two pills for a headache.
A tenet of the field of toxicology is “the dose makes the poison.” How one is exposed to a chemical is also important. Some chemicals might be hazardous if inhaled but safe when mixed in a skin cream.
“It’s important to have a sense of the difference between the hazard an ingredient may pose and the risk a person faces from being exposed to it. Scientists use the term hazard to describe the potential of a chemical to cause unwanted health effects. Risk is used to describe the chances of an unwanted health effect in a person from normal use of the ingredient. A substance may be deemed to be potentially hazardous for some reason, but it may pose very little risk to people during normal use.” American Cancer Society
The EWG does not represent the views of mainstream science.
The EWG and it’s partner, the Campaign for Safer Cosmetics (CSC) created an app called the Skin Deep database which allows consumers to look up a safety score for personal care products prior to purchasing them. While the idea behind this is good, the Skin Deep database is not an accurate source of information. The EWG and the CSC are frequently criticized by scientists for using flawed methodology to determine what is safe and what is not. For example, the database has given excellent safety scores to chemicals with no safety data at all, and they also listed a chemical that doesn’t even exist. Independent scientists often disagree with the positions EWG takes. The criticism is extensive.
According to a survey of 937 toxicologists, 79% of the members of the Society of Toxicology thought the EWG exaggerated chemical risk. Toxicologists are experts in determining what is safe and what is not and 92% of toxicologists disagreed with the statement “any level of exposure is unacceptable for chemicals that have been identified as carcinogens, mutagens, or reproductive toxicants.”
The EWG has even published papers suggesting a link between vaccines and autism, a theory that came from the now unlicensed physician Andrew Wakefield who published a paper using fraudulent data. This theory has been thoroughly and repeatedly debunked by mainstream science in industrialized countries all over the world. The fact that the EWG publishes information like that is very telling of its credibility.
Dermatologists Speak out Against EWG
Each year the EWG creates an annual Sunscreen Guide to help consumers choose sunscreen. The EWG does not actually test how well sunscreens work in protecting the skin from UV radiation. Instead they analyze the ingredients in the sunscreens and label some as safe and some as unsafe. Their criteria disregards dosages and concentrations of ingredients which are crucial for determining safety.
One of the sunscreen ingredients the EWG considers unsafe is oxybenzone. This is based on a study which showed that oxybenzone was an endocrine disruptor when given to rats ORALLY in large amounts.
Dermatologists have spoken out regarding inaccurate conclusions drawn by the EWG. Scientists from the Dermatology Service at Memorial Sloan-Kettering Cancer Center published a peer-reviewed study in JAMA Dermatology in which they said “Oxybenzone did not demonstrate significant endocrine disruption, even with application of a formulation containing 10% oxybenzone.” [the maximum concentration of oxybenzone in sunscreen sold within the United States was assumed to be 6% in this study].
The paper points out that if a person applied a typical amount to their face, neck, hands and arms, it would take 277 years of applying it every single day to reach the amount that was given to the rats. This is also assuming that oxybenzone accumulates in the body though multiple studies have shown it is excreted in the urine.
They went on to say, “In fact, after 40 years of use, we are not aware of any published study that demonstrates acute toxic effects in humans with systemic absorption of oxybenzone.”
Though the views of the scientific majority change over time based on new research, the EWG seems unwilling to change their position when new information comes to light which contradicts their position. “A lot of their sunscreen recommendations are based on very old technology, and some of the best sunscreens on the market have newer chemicals that are much more effective. A lot of their opinions are not keeping pace with technology and an understanding of the science of these formulations.” said Dr. Zoe Draelos in an interview in Huff Post. Dr Draelos is a dermatologist and a Duke University School of Medicine professor who also tests sunscreens in her laboratory.
The American Academy of Dermatologists also spoke out against the EWG’s conclusion.
“Current scientific data does not support claims that sunscreen ingredients are toxic or a hazard to human health. Rather, evidence supports the benefits of applying sunscreen to minimize short- and long-term damage to the skin from the sun’s harmful ultraviolet rays” says Dr. Henry Lim, president of the American Academy of Dermatology.
The Skin Cancer Foundation also spoke out against the EWG’s Sunscreen Guide also, specifically standing behind oxybenzone as well as the ingredient retinyl palmitate, which the EWG also labels as unsafe.
There is an environmental concern regarding oxybenzone however, as it has been found to be harmful to coral reefs. It should remain an option though (that people aren’t afraid to use), especially for the majority of the population who do not live or travel near reefs. UV radiation is a proven carcinogen and its important that there are many sunscreen options available to people in order to reduce the risk of skin cancer.
One of the most effective tactics “non-toxic” marketers use is pointing out how many chemicals people are exposed to from their personal care products. They then go on to claim those chemicals “are linked” to health problems, including even cancer, though there is no evidence that any chemical in personal care products causes cancer in the dosages people actually use.
Advancements in science make it possible to isolate nearly any chemical in the body, regardless of what it is or whether it is harmful. Detecting a chemical in the body does not prove harm, and in fact 81 percent of toxicologists rejected the notion that the detection of any level of a chemical in the body indicates a significant health risk. Science also allows the chemicals in “safer” brands to be identified in the body just like any others, but that fact is less obvious.
Correlating chemicals from cosmetics to rising cancer rates as a way to market “safer” products is unethical and the facts cited are often exaggerated. According to government research, rates for new cancer diagnosis of any type have actually been falling on average 1.1% each year over the last 10 years.
Regarding breast cancer specifically, 40 years ago the rate was actually 1 in 10, not 1 in 20, according to the National Cancer Institute. This is an increased rate from 1 in 8 now, but not nearly as much of an increase as this advertisement suggests. According to the American Association of Cancer Research, the increased cancer rate is attributed to obesity, delayed childbearing, and improved screening, not from use of personal care products.
The misunderstood study where the media first linked the preservatives known as parabens to breast cancer did not prove parabens cause cancer and the study’s own authors admitted that and said, “No claim was made that the presence of parabens had caused the breast cancers.” In fact, in the study parabens were also found in normal breast tissue. Independent scientists have also highly criticized the way the study was carried out and the fact that the paper was not peer-reviewed.
Regardless of these inconvenient facts, the EWG and the natural beauty industry continues to perpetuate the myth that parabens and other chemicals cause cancer. The general public often confuses the EWG as a legitimate scientific agency and accepts their recommendations at face value. The news media is not scientifically literate enough to analyze these claims and stories like these make great headlines.
Financial Ties and Conflicts of Interest
What is the EWG’s motivation for exaggerating risks of chemicals in personal care products? Increasing fear and doubt surrounding certain chemicals motivates people to look for products that they perceive to be safer. The EWG is largely supported by the organic food and natural product industries and they have a vested interest in promoting the brands that offer it financial support. As fear increases, sales of “safer” products increase as do donations to the EWG which helps advance their political agenda. Among the EWG’s biggest financial supporters are Beautycounter, Juice Beauty, and Dr. Bronner Soaps.
The EWG not only accepts financial support from industry, but it also invites people from industry to sit on their board of directors, including Christine Gardner who is a beauty ambassador for Beautycounter. This is a huge conflict of interest considering the EWG is supposed to review brands in a non-biased way.
How the FDA works in the US
The EWG and the CSC leverage the fact that the industry is under-regulated to feed the fear of chemicals. Often glossed over is the fact that sunscreens are regulated as over-the-counter drugs by the FDA and these products are pre-approved for safety and efficacy before being sold in the US. There is no lack of oversite here, in fact the FDA has been criticized for not approving new sunscreen ingredients fast enough.
Regarding cosmetics and personal care products other than sunscreens, products do not have to be pre-approved by the FDA before entering the market. The FDA requires that products be properly labeled and that ingredients be “generally recognized as safe” when used as directed. Safety is determined by relying on toxicological data already available on individual ingredients and product formulations.
The FDA researches ingredient safety, follows up on complaints of adverse effects and performs inspections. They charge fines to product producers who sell unsafe products. They can suggest but not mandate recalls of unsafe products.
The “safer” brands are subject to the same (lack of) regulations as all the other brands on the market.
Europe Bans Thousands of Chemicals
The EWG and natural product producers love to point out that Europe bans thousands of chemicals for use in personal care products and the US only bans 11. That is indeed true, but why? Are Americans less safe because of it?
The Scientific Committee for Consumer Safety (SCCS) is a group of independent scientists in the European Union who determine chemical safety. They carefully analyze the scientific literature and write consensus statements regarding the safety of individual ingredients used in personal care products. This is the organization that generates the list of banned substances.
Other than a long list of chemicals that no non-chemist would recognize, there are other banned substances on the list that are recognizable including metformin (a diabetes drug), amitriptyline (an anti-depressant), warfarin (a blood thinner), colchicine (a gout medicine), nicotine, radioactive substances, vaccines, asbestos and jet fuel.
While the length of the list is impressive, many of these are substances that would never be in personal care products anyway so the size of the list is misleading. Why the EU took the time to include these items on the list is unclear but it’s doubtful that American consumers are less safe because the US doesn’t have a list like this.
The irony in all of this is that some of the ingredients that are most often villainized by “safer” beauty companies are actually deemed safe by the super strict European standards!
The safe list includes:
- Vitamin A derivatives retinyl palmitate and retinol
- Even Parabens! Methylparaben and ethylparaben are the most commonly used parabens and are deemed safe. Butylparaben and propylparaben were also considered safe to the consumer, as long as the sum of their individual concentrations does not exceed 0.19%. Other less commonly used parabens were not studied.
- Formaldehyde is also considered safe in the minute amounts it is used to prevent bacterial growth in personal care products. The SCCS considers formaldehyde safe in personal care products up to 2,000 parts per million whereas products on the market ranges from 54 to 610 parts per million, well below the safe threshold.
The natural beauty industry gets new customers based on fear and confusion over what is safe. They portray the science as being uncertain by cherry-picking low quality studies and ignoring others which disprove their claims. They utilize the “better safe than sorry” selling tactic called the precautionary principle.
The precautionary principle states that a substance suspected to cause harm should be banned even without scientific consensus. At face value that sounds reasonable but what a lot of people don’t understand is that science does not prove safety, rather science determines safety by trying and failing to prove harm. The precautionary principle is taking a page from the anti-vaccine playbook. Anti-vaxxers demand studies that show vaccines are safe while continually rejecting a huge mountain of studies done in multiple countries that fail to link vaccines to harm. No amount of studies will ever be enough for these critics and anti-synthetic chemical advocates operate the same way.
By following the precautionary principle and rejecting a certain chemical, it begs the question of what that chemical will be replaced with. Why is it there in the first place? What’s the risk of removing it? Is there a substitute ingredient that’s better?
The Risk of Under-preserved Products
Products contain preservatives in trace amounts to prevent bacteria and mold growth. In addition to weighing the risks of certain preservatives, one must weight the risks of removing it or of replacing it with another chemical with unknown risks. There are serious risks with poorly-preserved products.
For example, in 2009, a hospital in Saudi Arabia used baby shampoo that was contaminated and 15 babies were infected with Serratia marcescens and one of the babies died.
In 2006 in Barcelona, a hospital used moisturizing lotion that was unknowingly contaminated with the bacteria Burkholderia cepacia. Five patients became critically ill with respiratory tract, urinary tract and blood infections.
Outside of hospitals and closer to home it is not uncommon for under-preserved products to be recalled due to contamination. Beautycounter, Liz Earle, Juice Beauty and Honest Beauty (more than once) have all been affected.
As parabens have fallen out of favor due to bad press, other preservatives have taken their place. But are they safe and effective? Grapefruit seed extract is a “natural” alternative that is not nearly as effective as parabens so a larger concentration is required to prevent bacterial growth. Also, it is a common allergen.
Methylisothiazolinone has also become more popular though it commonly causes allergies and was named the 2013 “Allergen of the Year” by the American Contact Dermatitis Society.
Phenoxyethanol is an organic compound that is also used as a preservative. This and the other newer preservatives do not have a long track record of use and safety data is not that plentiful, so if one considers parabens unsafe, is it logical to consider other preservatives safer when there is little or no safety data? The FDA issued an alert in 2008 due to concern of harmful ingredients including phenoxyethanol in Mother’s Bliss Nipple Cream which was feared to cause diarrhea and nervous system problems.
Attempts to change the laws
The FDA began having authority over the personal care product and cosmetic industry after the Food Drug and Cosmetic Act was passed in 1938 and the law has not been updated since then. Spearheaded by Senator Dianne Feinstein, lawmakers have tried to pass updated legislation several times in recent years without success. This proposed law would give the FDA the authority to mandate recalls (rather than only suggest them like it does now). It would also force beauty companies to disclose customer complaints to the FDA and mandate that the FDA do further research on chemicals suspected to cause harm each year.
These common sense recommendations are predictably supported by the EWG and the CSC but this bill is actually supported by the majority of the industry as well. According to the press release issued by Senator Feinstein’s office, the Personal Care Products Safety Act has the support of numerous industry trade and consumer groups, including the Personal Care Products Council (a trade association representing more than 600 companies in the industry), as well as the companies that make Neutrogena, Aveeno, Clairol, Cover Girl, Olay, Estee Lauder, Clinique, MAC, Bobbi Brown, St. Ives, Lancome, Kiehl’s, Gucci, Dolce & Gabbana, La Mer, La Roche-Posay, The Body Shop and Redken, among others. Small beauty companies do not support the bill however, fearing financial harm.
- The words “non-toxic” and “safer” are meaningless buzzwords used to sell more products.
- When certain companies market themselves as being “safer”, it sends a message that all other brands are harmful, however “safer” brands are held to the same standards as all other products.
- Using Europe’s own strict standards, the chemicals used in personal care products that are most feared are considered safe.
- Common sense reforms at the FDA are supported by the industry as a whole.
- The EWG provides biased information that is not scientifically sound. They are a political advocacy group whose goal is to promote the natural and organic industries.
- The growth of the “safer” beauty movement hinges on fear so expect more ingredients to be villainized because if no one was afraid, the entire industry would be irrelevant.
- The “safer” beauty companies are not altruistic. They have their eyes on profits just as much as any other conventional brand.
- Choose your personal care products based on what works, what’s affordable or for whatever other reason you like, but recognize that products marketed as safer are not safer.
Ann Marie Strong is a certified physician assistant who practices primary care medicine in the Minneapolis area, is a skincare consultant and blogs at strongsavvystylish.com.