People should expect reasonable and sensible protection from harm by those who regulate consumer products, and vulnerable groups such as children and pregnant women may need special consideration. Therefore, cosmetics that are totally free of all carcinogens and teratogens may sound like a good idea. But is it realistic? And is more legislation needed?
One problem is in that word “totally”. If you want to avoid encountering one molecule of a toxic substance, then you need to either live in a bubble, or stop eating, drinking, and breathing. Traces of cyanide, for instance, are found in foods and beverages, both natural and manufactured. That doesn’t mean its OK to consume in quantity, but toxicity is avoided by limiting the permitted amount to a few parts per million. The same goes for heavy metals and in fact most other toxins.
Why not zero tolerance? Well, in many cases it is both unrealistic, and unnecessary. All toxic substances have NOAELs (No-Adverse-Effect-Levels) even carcinogens. NOAELs are established in animal studies, and then ratcheted down by 100 or 500 or 1,000 times. These mathematical excursions are a bit arbitrary sometimes, but if anything, they result in too much protection, not too little.
A “zero tolerance” bill is on the table in the state of Colorado, and you can find more information about it here and here. Enacting this bill would mean, for example, that any amount of acetaldehyde would not be permitted in personal care products. Your body produces acetaldehyde whenever you drink alcohol, as it’s the major metabolite of ethanol. And chronic alcoholism can lead to cancer, with acetaldehyde the main suspect. Acetaldehyde is also a trace constituent of apples, bananas, bilberries, cherries, citrus fruits, cranberries, grapes, olives, passionfruit, peaches, plums, strawberries, raspberries, carrots, celery, cucumbers, garlic, onions, peas, potatoes and tomatoes. So, goodbye fruit extracts in cosmetics.
If you see a strawberry only as something that contains acetaldehyde (tunnel vision), then suddenly, everything you thought was good for you, is now bad for you. But (problem number two), fruits and vegetables contain a plethora of antioxidants and antimutagens that more than compensate for any toxicity from the tiny traces of acetaldehyde they contain.
Also, goodbye to rose otto and rose absolute. It was nice knowing you. And so long to nutmeg oil, mace oil, myrtle oil, basil oil, holy basil oil, citronella oil, ho leaf oil (linalool ct), elemi oil, and many other less common essential oils. Not because they contain acetaldehyde, but because they contain methyleugenol (ME). ME is occasionally found in traces in rosemary oil, clove oil, hyssop oil, tea tree oil, cananga oil, mastic oil, cassia oil, cinnamon leaf oil, savory oil, black pepper oil and, again, many others. Have you eaten any fresh basil or pesto lately? Then you have been consuming ME. But, neither fresh basil nor pesto is carcinogenic, because they also contain antimutagens and anticarcinogens that counteract any toxic effect of ME. I’m not just saying this, it has been demonstrated. The same goes for holy basil oil, to take one example – not only is it non-carcinogenic, but it is actually anticarcinogenic. The high content of geraniol in rose otto is almost certainly protective because of its anticarcinogenic action.
Does this make a difference? Not if you have tunnel vision.
The Environmental Working Group (and associated Skin Deep and Campaign for Safe Cosmetics) is an increasingly vociferous pressure group, which is now flexing its political muscle. Everywhere these people look, they find dangerous toxins, and guess what – if you look for them you will find them. And, if your vision becomes so narrow that all you can see is toxins, and the poor fetuses and children that you convince yourself they must be harming, it becomes difficult to take a step back and see the big picture. The EWG do not seem to appreciate that finding a substance in human tissue does not necessarily mean that the owner of that tissue has been harmed.
Risk assessment has many facets (problem number three) but basically it is about deciding whether exposure to a substance in a particular way is or is not actually harmful, and where safety thresholds lie. Risk assessment is not about scaremongering, it’s not about getting people fired up about “chemicals”, and it should not be about pre-emptive and sweeping legislation. It should be about ensuring safety by looking at all aspects of a problem, and then making the best decision you can. I agree with many of the EWG campaigns. It’s just a shame that they have adopted the same “single-chemical” view of essential oils that has infected the EC legislation.
If you live in Colorado and you agree with my opinion, you should act. If you don’t live in Colorado stay vigilant, because there’s more of the same on the way.