Toxins in Toiletries

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My daily grooming routine usually involves a little shampoo, conditioner and soap in the shower, moisturizing cream for my body and another for my face, lip balm, and if I’m going out at night probably some make-up. According to the Environmental Working Group (EWG) in the United States, if I am an “average adult,” this routine exposes me each day to 126 unique chemical ingredients. They may be entirely innocuous. My soap and shampoo usually make positive claims on their packaging, promising healthy-looking skin or hair. On the other hand, those cosmetics may expose me to human carcinogens.

Every day in the United States, one in every 13 women comes into contact, via her cosmetics, with chemicals that are known or probable carcinogens. My cosmetics may also expose me to known or probable reproductive and developmental toxins; one woman in 24 in the United States is. Men are not exempt; their cosmetics and toiletries expose them to 85 unique ingredients every day, some of which may be inherently toxic. Canada’s cosmetics regulations ban a few more toxic chemicals than US regulations, so the average numbers in this country may be slightly different. Yet in Canada, just as in the United States, toxic chemicals are found in many cosmetics and toiletries, including products marketed for use on babies.

The cosmetics industry is facing growing skepticism from tuned-in consumers, and for good reason. The news is getting out, and it’s smearing the beauty industry. Toxic chemicals that have the potential to cause chronic or life-threatening harm (carcinogens, reproductive and developmental toxins, allergens, sensitizers), to change the way our body’s hormonal systems function (endocrine disruptors), or to change our DNA (mutagens), sometimes permanently so that those changes are passed on to our children, can be found in beauty aisles and at cosmetics counters. One or two exposures will not cause health problems. The effects are more insidious and stem from the cumulative exposure of a lifetime of small, daily doses, which is just how we use these products. There are also gaps in our understanding of the long-term health effects of individual cosmetic ingredients as well as how they behave in mixtures. Finally, right-to-know warning labels indicating potential chronic harm from a single ingredient or a mixture of products are not required and are being actively opposed by industry.

On November 16, 2006, the laws on cosmetic labelling in Canada changed. Now, companies are required to list all ingredients on cosmetic packages, except for those that are protected by trade secrets. The ingredients that make up a fragrance fall under into this category. Under the law, the label is allowed to list the term “fragrance” even though a fragrance may consist of five or 100 unique ingredients. While ingredient listing is an important step toward providing better access to information, there are barriers to reading and understanding the labels. The print is small and, for most of us, the words don’t have much meaning. This is why warning labels, indicating the presence of and risks from toxic substances found in cosmetics would be useful. Manufacturers tell us about the benefits of the products we buy; we should be informed of the risks as well.

How did toxic chemicals creep into our daily grooming routines? Many people are surprised to learn that cosmetics companies are not required to demonstrate a product’s safety before it is sold. Manufacturers are only required to send a list of the product’s ingredients to Health Canada 10 days after a new product lands on shelves. Health Canada does have the Cosmetic Ingredient Hotlist, a list of over 500 ingredients that are either prohibited or restricted from use in cosmetics. It prohibits some known human carcinogens, such as coal tar dyes, but other toxic ingredients, such as dibutyl phthalates (DBP), don’t appear on the list. DBP can be found in nail polishes and fragrances and these phthalates mimic estrogen and have been linked to genital birth defects in baby boys.

Although regulators at Health Canada do review existing literature, particularly when a cosmetic ingredient is banned in other jurisdictions, they do not take a clear stand on the presence of toxic chemicals in cosmetics. Specifically, Health Canada looks at individual ingredients, considers their cosmetic use and potential health risks, and then makes a decision. For example, formaldehyde is a known human carcinogen according to the International Agency for Research on Cancer, yet this label does not merit a full prohibition on the Hotlist. Formaldehyde is often found in nail products. In addition, the individual ingredient assessment approach overlooks the regulation of toxic impurities, such as 1,4-Dioxane that may inadvertently show up in baby bubble bath products—as an accidental byproduct.

The Canadian Cosmetic, Toiletry and Fragrance Association (CCTFA) is the industry’s trade association in Canada. It relies on ingredient information from its American counterpart, the Cosmetic, Toiletry and Fragrance Association (CTFA). Financially supported by the CTFA, the Cosmetic Ingredient Review (CIR) is a group of scientific experts who assess the safety of cosmetic ingredients. In its 30-year history, the CIR has tested only about 13% of the 10,500 ingredients used in cosmetics.

Deep concern about a lack of regulatory oversight and awareness of the presence of toxic chemicals in cosmetics has brewed into a vibrant safe cosmetics movement, first in the United States and now in Canada. A few years ago, a number of large, American not-for-profit health, feminist and environmental organizations joined forces. They turned their critical eyes equally to manufacturers and regulators meanwhile engaging the public with a colourful website, fun publicity stunts, eyebrow-raising ads and brochures on the information they uncovered, including results of talks with cosmetic industry giants such as L’Oréal and Estée Lauder. A sister campaign was initiated in Canada by the activist organization Breast Cancer Action Montreal in 2006. The EWG is one of the American organizations spearheading the US campaign. To raise awareness and help people choose safer products, EWG developed a hugely popular cosmetics database called Skin Deep (www.cosmeticsdatabase.com), which provides safety information on over 25,000 cosmetics products. The process involves a double-blind assessment of each product’s ingredient list; safety assessments are communicated with traffic light symbols and a 0-to-10 hazard scale: green is a low hazard (0 to 2); yellow is moderate (3 to 6); and red is high (7 to 10). Similar information is available for each individual ingredient. The database is also a useful tool to assess the overall safety, or lack thereof, of cosmetics. EWG found that one out of every 30 products sold in the United States failed to meet one or more of the industry or governmental cosmetics safety standards. Over 400 products were found to contain ingredients that cosmetic safety panels, including the CIR, found unsafe when used as directed on product labels.

An email warning women about lead in certain lipsticks circulated for some time. Although the email was bogus, the Campaign decided to test lipsticks for lead—a potent neurotoxin, particularly for children. Unfortunately, their study of 33 lipsticks revealed that more than half of them contained trace amounts of lead. Not surprisingly, none of the lipsticks listed lead as an ingredient. Some had parts per million that exceeded US regulations for allowable levels of lead in candy. Yes, there is a regulated allowable limit for lead in candy, yet scientists have not determined a safety threshold for exposure to lead. When the Canadian media approached the CCTFA about the presence of lead in lipstick, they argued that we are all exposed to lead in the environment naturally and shouldn’t worry about a little exposure through lipstick. However, there should be cause for concern, particularly from a source of lead that is avoidable. According to the US campaign, a woman may inadvertently ingest two kilograms or more of lipstick over her lifetime.

The campaigns are an ongoing success with both industry and regulators. For example, an initiative targeting the salon nail polish OPI, which contained formaldehyde and DBPs, pushed the company to reformulate within six months. In the state of California, cosmetics manufacturers are now required to reveal to the government whether or not their cosmetics contain toxic chemicals. It is still unclear whether this new legislation will push companies to reformulate, but it is a step in the right direction for the consumer’s right-to-know.

Manufacturers say they are following regulations, and they are. But regulations are usually the base minimum. It is up to companies to determine how safe they want their products to be beyond the minimum standard, and there is almost no independent oversight. On the other hand, regulations work, and should work in the interest of public health. Lead acetate provides a good example. A known human carcinogen, lead acetate was added to the Hotlist as a prohibited ingredient last year. No one was dancing in the streets over the victory, but a men’s hair dye manufacturer quietly reformulated the lead acetate out of their Grecian Formula hair dye—only for the Canadian market. The Americans were stuck with the old, carcinogen-laced formula.

As for my daily grooming routine, before I buy a new soap or other cosmetics, I read the labels and check for ingredients that concern me. I try to buy from companies that I trust, and I check the Skin Deep database for safety information for ingredients I am unfamiliar with, or to find products available in Canada that don’t contain toxic chemicals. I also try to limit my use of cosmetics; I avoid fragrances and nail products. These are ways that I can reduce my daily exposures. I do this now, knowing that real change will come from public pressure, and structural changes such as a vamped-up Hotlist, stronger industry oversight, required demonstration of cosmetics safety pre-sale, and chronic risk hazard warning labels.

With a push for global harmonization of products, and the United States being Canada’s major trading partner, what kind of future do we have for safe cosmetics in Canada? We can make a difference by joining the Breast Cancer Action Montreal Safe Cosmetics Campaign. We can express to industry and government our interest in protecting public health through stricter cosmetic ingredient regulation, increased right-to-know labelling and our general concern over the quality and contents of our cosmetic products. As consumers we can influence Canada’s $5.4 billion dollar retail cosmetics industry. After all, that’s our $5.4 billion dollars.

Madeleine Bird was Chair of Breast Cancer Action Montreal’s Safe Cosmetics Campaign from 2006 to 2007. She was also the coordinator of the Health and Environment Awareness Project, a collaboration between Breast Cancer Action Montreal and the McGill Centre for Research and Teaching on Women, which worked to educate about the health risks associated with environmental toxins, particularly those found in cosmetics and household cleaners.