CHICAGO, IL, July 2, 2004 --/WORLD-WIRE/--
The Environmental Working Group (EWG) should be commended for its June "Skin Deep" report on personal care products. EWG should also be commended for its FDA petition to recall or issue "warning labels on 356 personal care products" that, as admitted by the industry's Cosmetic Ingredient Review safety panel, "lack sufficient data to support their safe use in personal care products." Regrettably, however, EWG's report is confusing and scientifically flawed.

EWG emphasizes that "only 11 percent of 10,500 personal care products, identified by the industry's trade association, have been publicly assessed for safety." However, this seems an overstatement. Such "suspect" ingredients include: purified water; sodium chloride (table salt); citric acid; natural amino acids; natural botanicals; FDA-approved colorants; and many food additives approved in 1958 by the FDA as "Generally Recognized As Safe."

Moreover, EWG is apparently unaware that substantial information on a wide range of carcinogenic ingredients, carcinogenic contaminants in other ingredients, and ingredients causing dermatitis in most products, marketed by most major companies, has been widely available for nearly a decade. The Safe Shopper's Bible (Macmillan, 1995), which I co-authored, details such information on these unsafe products. The book also provides information on safer products, marketed by smaller companies.

Furthermore, EWG's claim that "consumers and government officials have no way of knowing of ingredients that can be contaminated with impurities linked to cancer" is questionable. This information is admitted, although trivialized, by the Cosmetic Ingredient Review, with particular reference to a large group of detergents (ethoxylates) which, unless purified, are contaminated with potent carcinogenic impurities. More disturbingly, officials of the federal National Cancer Institute are fully aware of such long-standing information, of which they have failed to inform consumers; the American Cancer Society goes still further by virtually dismissing any cancer risks from cosmetics.

EWG's listing of "Carcinogens in Personal Care Products" identifies eight "known and probable human carcinogens." However, no reference is made to talc, identified as a lung carcinogen, following inhalation tests in rodents by the National Toxicology Program in 1993. This is of particular importance in view of the common use of talcum baby powders. Of greater importance are several publications, in leading medical journals since 1982, reporting that frequent use of talc as a genital dusting powder, practiced by about 17% of women, increases risk of ovarian cancer by four-fold.

Based on these concerns, the Cancer Prevention Coalition and the Center for Constitutional Rights filed a 1994 petition to the FDA seeking "Carcinogenic Labeling on all Cosmetic Talc Products." The FDA has remained unresponsive.

EWG's computerized "Skin Deep" report is detailed in two major searchable sections, Find Products You Use, and Customer Shoppers Guide. The Find Products section evaluates 7,500 products sold by many leading cosmetic companies. These products are evaluated on the basis of "Health Concerns," including: cancer; pregnancy problems; safety violations; harmful impurities; penetration enhancers (ingredients which increase skin absorption of other ingredients); unstudied ingredients; and allergies and other health concerns. Products in 25 different categories are each evaluated on the basis of "Top Five Ingredients of Concern."

However, these evaluations are marred by errors of omission and commission:

  • "Ingredients of Concern," incriminated as posing risks of cancer in different products, include: tocopherol (vitamin E); hydrogen peroxide; acetone; menthol; sodium borate; boric acid; zinc sulfate; propylene glycol; and parabens. However, there is no evidence on the carcinogenicity of these ingredients, although there has been such speculation for parabens.
  • More puzzling are the Top Five Ingredients incriminated as posing risks of "Allergies and Other Health Problems." These include sodium borate; boric acid; tocopherol; acetone, and silica. However, none of these are known allergens. Also, contrary to EWG, a fragrance is not an ingredient, nor as implied, necessarily allergenic. In fact, fragrances contain mixtures of ingredients, many of which pose no risks of allergy. Moreover, no information is provided as to nature of the unspecified "Health Problems."
  • Inexplicably, the report omits any reference to ingredients known to induce genetic damage (mutagens), such as aminophenol, hydroquinone, and crotonaldehyde, even though these have been clearly incriminated in recent European Scientific Committee reports.
  • EWG unfavorably rates all products containing "penetration enhancer" ingredients, which facilitate absorption of other ingredients through the skin. However, this rating extends to most products, as these contain water, and oil or fatty ingredients. These ingredients are necessarily mixed together to form stable solutions, by the addition of detergent (surfactant) ingredients. There are two main types of detergents, sodium or ammonium lauryl sulfate, and a wide range of unrelated ingredients, known as ethoxylates. Most companies avoid the use of sulfate detergents, as they irritate or damage the skin. While purified ethoxylates are not irritants, they are safe "penetration enhancers." However, this is of no concern, unless the product also contains toxic ingredients.

In view of these widely ranging considerations, EWG's ratings of product safety, scored at decimal intervals from 0 to 10, with 10 of the highest concern, are at best pseudoscientific.

Surprisingly, the EWG report makes no reference to pending European regulations banning known or probable carcinogens, mutagens, and reproductive toxics, and requiring labeling of allergenic ingredients. These regulations will clearly stimulate compliance in the U.S., in view of the virtually uniform international marketing practices of all major personal care and cosmetic companies. These European regulations may also preempt any unlikely FDA responsiveness to EWG's petition.

CONTACT: Samuel S. Epstein, M.D., professor emeritus Environmental & Occupational Medicine, University of Illinois at Chicago School of Public Health; Chairman, Cancer Prevention Coalition.;